NUREG-1437, Supplement 29 

 Vol. 1 

Generic Environmental 

Impact Statement for 

License Renewal of 

Nuclear Plants 

Supplement 29 

Regarding 

Pilgrim Nuclear Power Station 

Final Report – Main Report 

U.S. Nuclear Regulatory Commission 

Office of Nuclear Reactor Regulation 

Washington, DC 20555-0001 
AVAILABILITY OF REFERENCE MATERIALS

IN NRC PUBLICATIONS

NRC Reference Material

As of November 1999, you may electronically access

NUREG-series publications and other NRC records at

NRC’s Public Electronic Reading Room at

http://www.nrc.gov/reading-rm.html.

Publicly released records include, to name a few,

NUREG-series publications; Federal Register notices;

applicant, licensee, and vendor documents and

correspondence; NRC correspondence and internal

memoranda; bulletins and information notices;

inspection and investigative reports; licensee event

reports; and Commission papers and their attachments.

NRC publications in the NUREG series, NRC

regulations, and Title 10, Energy, in the Code of

Federal Regulations may also be purchased from one

of these two sources.

1. The Superintendent of Documents

 U.S. Government Printing Office

 Mail Stop SSOP

 Washington, DC 20402–0001

 Internet: bookstore.gpo.gov

 Telephone: 202-512-1800

 Fax: 202-512-2250

2. The National Technical Information Service

 Springfield, VA 22161–0002

 www.ntis.gov 

 1–800–553–6847 or, locally, 703–605–6000

A single copy of each NRC draft report for comment is

available free, to the extent of supply, upon written

request as follows:

Address: U.S. Nuclear Regulatory Commission 

 Office of Administration

 Mail, Distribution and Messenger Team 

 Washington, DC 20555-0001

E-mail: DISTRIBUTION@nrc.gov 

Facsimile: 301–415–2289 

Some publications in the NUREG series that are 

posted at NRC’s Web site address

http://www.nrc.gov/reading-rm/doc-collections/nuregs

are updated periodically and may differ from the last

printed version. Although references to material found

on a Web site bear the date the material was accessed,

the material available on the date cited may

subsequently be removed from the site.

Non-NRC Reference Material

Documents available from public and special technical

libraries include all open literature items, such as

books, journal articles, and transactions, Federal

Register notices, Federal and State legislation, and

congressional reports. Such documents as theses,

dissertations, foreign reports and translations, and

non-NRC conference proceedings may be purchased

from their sponsoring organization.

Copies of industry codes and standards used in a

substantive manner in the NRC regulatory process are

maintained at—

The NRC Technical Library 

Two White Flint North

11545 Rockville Pike

Rockville, MD 20852–2738

These standards are available in the library for

reference use by the public. Codes and standards are

usually copyrighted and may be purchased from the

originating organization or, if they are American

National Standards, from—

American National Standards Institute

11 West 42nd Street

New York, NY 10036–8002

www.ansi.org 

212–642–4900

Legally binding regulatory requirements are stated

only in laws; NRC regulations; licenses, including

technical specifications; or orders, not in 

NUREG-series publications. The views expressed

in contractor-prepared publications in this series are

not necessarily those of the NRC.

The NUREG series comprises (1) technical and

administrative reports and books prepared by the

staff (NUREG–XXXX) or agency contractors

(NUREG/CR–XXXX), (2) proceedings of

conferences (NUREG/CP–XXXX), (3) reports

resulting from international agreements

(NUREG/IA–XXXX), (4) brochures

(NUREG/BR–XXXX), and (5) compilations of legal

decisions and orders of the Commission and Atomic

and Safety Licensing Boards and of Directors’

decisions under Section 2.206 of NRC’s regulations

(NUREG–0750).
 NUREG-1437, Supplement 29 

 Vol. 1 

 

 

Generic Environmental 

Impact Statement for 

License Renewal of 

Nuclear Plants 

Supplement 29 

Regarding 

Pilgrim Nuclear Power Station 

Final Report – Main Report 

Manuscript Completed: July 2007 

Date Published: July 2007 

Division of License Renewal 

Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

(a) Environmental effects are not detectable or are so minor that they will neither destabilize nor

noticeably alter any important attribute of the resource.

(b) Environmental effects are sufficient to alter noticeably but not to destabilize important attributes of the

resource.

July 2007 iii NUREG-1437, Supplement 29

Abstract

The U.S. Nuclear Regulatory Commission (NRC) considered the environmental impacts of

renewing nuclear power plant operating licenses (OLs) for a 20-year period in its Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437,

Volumes 1 and 2, and codified the results in 10 CFR Part 51. In the GEIS (and its

Addendum 1), the staff identified 92 environmental issues and reached generic conclusions

related to environmental impacts for 69 of these issues that apply to all plants or to plants with

specific design or site characteristics. Additional plant-specific review is required for the

remaining 23 issues. These plant-specific reviews are to be included in a supplement to the

GEIS.

This supplemental environmental impact statement (SEIS) has been prepared in response to |

an application submitted by Entergy Nuclear Operations, Inc. (Entergy), a subsidiary of Entergy

Corporation, to the NRC to renew the OL for Pilgrim Nuclear Power Station (PNPS) for an

additional 20 years under 10 CFR Part 54. This SEIS includes the NRC staff’s analysis that |

considers and weighs the environmental impacts of the proposed action, the environmental

impacts of alternatives to the proposed action, and mitigation measures available for reducing

or avoiding adverse impacts. It also includes the staff’s recommendation regarding the |

proposed action.

Regarding the 69 issues for which the GEIS reached generic conclusions, neither Entergy nor

the staff has identified information that is both new and significant for any issue that applies to

PNPS. In addition, the staff determined that information provided during the scoping process

was not new and significant with respect to the conclusions in the GEIS. Therefore, the staff

concludes that the impacts of renewing the OL for PNPS would not be greater than impacts

identified for these issues in the GEIS. For each of these issues, the staff’s conclusion in the

GEIS is that the impact would be of SMALL significance (except for collective off-site |

(a)

radiological impacts from the fuel cycle and high-level waste and spent fuel, which were not

assigned a single significance level).

Regarding the remaining 23 issues, those that apply to PNPS are addressed in this SEIS. For |

each applicable issue, the staff concludes that the significance of the potential environmental

impacts of renewal of the OL would be SMALL, with the exception of marine aquatic resources. |

Due to entrainment and impingement, the continued operation of the cooling water system

would have MODERATE impacts on the local winter flounder (Pseudopleuronectes (b)

americanus) population, and the Jones River population of rainbow smelt (Osmerus mordax).
Abstract

NUREG-1437, Supplement 29 iv July 2007

Continued operation of the cooling water system would have SMALL to MODERATE

| impingement and entrainment impacts on other marine aquatic species as well. Cumulative

| impacts on the local winter flounder population and Jones River population of rainbow smelt

would be MODERATE, and cumulative impacts on other marine aquatic species would be

SMALL to MODERATE.

| The NRC staff’s recommendation is that the Commission determine that the adverse

environmental impacts of license renewal for PNPS are not so great that preserving the option

of license renewal for energy-planning decisionmakers would be unreasonable. This

recommendation is based on (1) the analysis and findings in the GEIS; (2) the Environmental

Report submitted by Entergy; (3) consultations with Federal, State, and local agencies; (4) the

| staff’s own independent review; and (5) the staff’s consideration of public comments.

Paperwork Reduction Act Statement

This NUREG does not contain information collection requirements and, therefore, is not

subject to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et

seq.).

Public Protection Notification

The NRC may not conduct or sponsor, and a person is not required to respond to, a request

for information or an information collection requirement unless the requesting document

displays a currently valid OMB control number.
July 2007 v NUREG-1437, Supplement 29

Contents

Abstract.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Executive Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xvii

Abbreviations/Acronyms. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xxii

1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

1.1 Report Contents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

1.2 Background.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3

1.2.1 Generic Environmental Impact Statement. . . . . . . . . . . . . . . . . . . . . 1-3

1.2.2 License Renewal Evaluation Process. . . . . . . . . . . . . . . . . . . . . . . . 1-5

1.3 The Proposed Federal Action. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-8

1.4 The Purpose and Need for the Proposed Action. . . . . . . . . . . . . . . . . . . . . . 1-8

1.5 Compliance and Consultations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-9

1.6 References..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-9

2.0 Description of Nuclear Power Plant and Site and Plant Interaction

with the Environment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

2.1 Plant and Site Description and Proposed Plant Operation During the

Renewal Term.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

2.1.1 External Appearance and Setting. . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4

2.1.2 Reactor Systems. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4

2.1.3 Cooling and Auxiliary Water Systems. . . . . . . . . . . . . . . . . . . . . . . . 2-7

2.1.4 Radioactive Waste Management Systems and Effluent

Control Systems. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-12

2.1.4.1 Liquid Waste Processing Systems and Effluent Controls. . 2-13

2.1.4.2 Gaseous Waste Processing Systems and Effluent 

Controls. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-15

2.1.4.3 Solid Waste Processing. . . . . . . . . . . . . . . . . . . . . . . . . . . 2-17

2.1.5 Nonradioactive Waste Systems.. . . . . . . . . . . . . . . . . . . . . . . . . . . 2-17

2.1.6 Plant Operation and Maintenance. . . . . . . . . . . . . . . . . . . . . . . . . . 2-18

2.1.7 Power Transmission System. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-18
Contents

vi

2.2 Plant Interaction with the Environment. . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-20

2.2.1 Land Use. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-21

2.2.2 Water Use. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-22

2.2.3 Water Quality.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-23

2.2.3.1 Surface Water. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-23

2.2.3.2 Groundwater.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-23

2.2.4 Air Quality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-26

| 2.2.5 Marine Aquatic Resources.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-28

2.2.5.1 Water Body Characteristics.. . . . . . . . . . . . . . . . . . . . . . . 2-28

2.2.5.2 Chemical Contaminants near PNPS. . . . . . . . . . . . . . . . . 2-30

2.2.5.3 Biological Communities. . . . . . . . . . . . . . . . . . . . . . . . . . . 2-31

2.2.5.3.1 Fish . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-31

2.2.5.3.2 Pelagic Invertebrates. . . . . . . . . . . . . . . . . . 2-73

2.2.5.3.3 Plankton. . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-74

| 2.2.5.3.4 Benthic Invertebrates. . . . . . . . . . . . . . . . . . 2-75

2.2.5.3.5 Marine Aquatic Plants. . . . . . . . . . . . . . . . . . 2-81

2.2.5.3.6 Marine Mammals . . . . . . . . . . . . . . . . . . . . . 2-82

| 2.2.5.3.7 Federally Listed Anadromous and Marine 

Species.. . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-83

2.2.6 Terrestrial and Freshwater Aquatic Resources. . . . . . . . . . . . . . . . 2-86

2.2.6.1 Description of Site Terrestrial and Freshwater Aquatic

Environments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-87

2.2.6.2 Transmission Line ROW. . . . . . . . . . . . . . . . . . . . . . . . . . 2-91

2.2.6.3 Rare Terrestrial and Freshwater Aquatic Species. . . . . . . 2-92

2.2.7 Radiological Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-98

2.2.8 Socioeconomic Factors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-100

2.2.8.1 Housing. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-100

2.2.8.2 Public Services. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-103

2.2.8.2.1 Water Supply. . . . . . . . . . . . . . . . . . . . . . . 2-103

2.2.8.2.2 Education. . . . . . . . . . . . . . . . . . . . . . . . . . 2-104

2.2.8.2.3 Transportation.. . . . . . . . . . . . . . . . . . . . . . 2-105
Contents

July 2007 vii NUREG-1437, Supplement 29

2.2.8.3 Off-site Land Use. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-106

2.2.8.3.1 Plymouth County.. . . . . . . . . . . . . . . . . . . . 2-108

2.2.8.3.2 Barnstable County. . . . . . . . . . . . . . . . . . . 2-110

2.2.8.4 Visual Aesthetics and Noise. . . . . . . . . . . . . . . . . . . . . . . 2-111

2.2.8.5 Demography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-112

2.2.8.5.1 Regional Population. . . . . . . . . . . . . . . . . . 2-112

2.2.8.5.2 Transient Population. . . . . . . . . . . . . . . . . . 2-113

2.2.8.5.3 Minority and Low-Income Populations.. . . . 2-113

2.2.8.5.4 Minority Populations. . . . . . . . . . . . . . . . . . 2-114

2.2.8.5.5 Low-Income Populations.. . . . . . . . . . . . . . 2-118

2.2.8.6 Economy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-120

2.2.8.6.1 Employment. . . . . . . . . . . . . . . . . . . . . . . . 2-120

2.2.8.6.2 Migrant Farm Labor. . . . . . . . . . . . . . . . . . 2-121

2.2.8.6.3 Taxes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-122

2.2.9 Historic and Archaeological Resources. . . . . . . . . . . . . . . . . . . . . 2-123

2.2.9.1 Cultural Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-124

2.2.9.2 Historic and Archaeological Resources at the PNPS 

Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-124

2.2.9.2.1 Previously Identified Resources. . . . . . . . . 2-124

2.2.9.2.2 Results of Walkover Survey. . . . . . . . . . . . 2-125

2.2.9.2.3 Potential Archaeological Resources. . . . . . 2-127

2.2.10 Related Federal Project Activities and Consultations.. . . . . . . . . . 2-127

2.3 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-128

3.0 Environmental Impacts of Refurbishment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

3.1 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4

4.0 Environmental Impacts of Operation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

4.1 Cooling System.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2
Contents

 NUREG-1437, Supplement 29 viii July 2007

4.1.1 Entrainment of Fish and Shellfish in Early Life Stages.. . . . . . . . . . 4-10

4.1.1.1 Environmental Monitoring.. . . . . . . . . . . . . . . . . . . . . . . 4-11

4.1.1.2 Entrainment Monitoring. . . . . . . . . . . . . . . . . . . . . . . . . 4-14

4.1.1.3 Assessment of Entrainment Impact. . . . . . . . . . . . . . . . 4-21

4.1.1.4 Summary of Entrainment Impacts. . . . . . . . . . . . . . . . . 4-26

4.1.2 Impingement of Fish and Shellfish.. . . . . . . . . . . . . . . . . . . . . . . . . 4-27

4.1.2.1 Impingement Monitoring.. . . . . . . . . . . . . . . . . . . . . . . . 4-27

4.1.2.2 Assessment of Impingement Impact. . . . . . . . . . . . . . . 4-29

4.1.2.3 Summary of Impingement Impacts.. . . . . . . . . . . . . . . . 4-33

4.1.3 Heat Shock. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-33

4.1.4 Potential Mitigation Measures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-39

4.2 Transmission Lines. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-43

4.2.1 Electromagnetic Fields-Acute Effects. . . . . . . . . . . . . . . . . . . . . . . 4-47

4.2.2 Electromagnetic Fields-Chronic Effects. . . . . . . . . . . . . . . . . . . . . . 4-49

4.3 Radiological Impacts of Normal Operations. . . . . . . . . . . . . . . . . . . . . . . . 4-49

4.4 Socioeconomic Impacts of Plant Operations During the License

Renewal Period .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-51

4.4.1 Housing Impacts During Operations. . . . . . . . . . . . . . . . . . . . . . . . 4-53

4.4.2 Public Services: Public Utility Impacts During Operations.. . . . . . . 4-54

4.4.3 Off-site Land Use During Operations.. . . . . . . . . . . . . . . . . . . . . . . 4-55

4.4.4 Public Services: Transportation Impacts During Operations. . . . . . 4-57

4.4.5 Historic and Archaeological Resources. . . . . . . . . . . . . . . . . . . . . . 4-57

4.4.5.1 Site Specific Cultural Resources Information. . . . . . . . . 4-58

4.4.5.2 Conclusions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-58

4.4.6 Environmental Justice. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-59

4.4.6.1 Minority Populations. . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-60

4.4.6.2 Low-Income Populations. . . . . . . . . . . . . . . . . . . . . . . . 4-60

4.5 Ground-Water Use and Quality.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-61

4.6 Threatened or Endangered Species. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-62
Contents

July 2007 ix NUREG-1437, Supplement 29

4.6.1 Anadromous Marine Aquatic Species. . . . . . . . . . . . . . . . . . . . . . . 4-63

4.6.2 Terrestrial and Freshwater Aquatic Species. . . . . . . . . . . . . . . . . . 4-64

4.7 Evaluation of New and Potentially Significant Information on Impacts of

Operations During the Renewal Term. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-66

4.8 Cumulative Impacts.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-74

4.8.1 Cumulative Impacts on Marine Aquatic Resources. . . . . . . . . . . . . 4-75

4.8.2 Cumulative Impacts on Terrestrial and Freshwater Aquatic 

Resources.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-77

4.8.3 Cumulative Human Health Impacts. . . . . . . . . . . . . . . . . . . . . . . . . 4-78 |

4.8.4 Cumulative Socioeconomic Impacts . . . . . . . . . . . . . . . . . . . . . . . . 4-79

4.8.5 Cumulative Impacts on Groundwater Use and Quality.. . . . . . . . . . 4-80

4.8.6 Cumulative Impacts on Threatened and Endangered Species. . . . 4-80

4.8.7 Conclusions Regarding Cumulative Impacts. . . . . . . . . . . . . . . . . . 4-81

4.9 Summary of Impacts of Operations During the Renewal Term. . . . . . . . . . 4-81

4.10 References..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-82

5.0 Environmental Impacts of Postulated Accidents. . . . . . . . . . . . . . . . . . . . . . . . . . 5-1

5.1 Postulated Plant Accidents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1

5.1.1 Design-Basis Accidents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2

5.1.2 Severe Accidents.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3

5.2 Severe Accident Mitigation Alternatives. . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5

5.2.1 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5

5.2.2 Estimate of Risk. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6

5.2.3 Potential Plant Improvements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-7

5.2.4 Evaluation of Risk Reduction and Costs of Improvements.. . . . . . . . 5-8

5.2.5 Cost-Benefit Comparison.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-9

5.2.6 Conclusions.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-10

5.3 References..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-10

6.0 Environmental Impacts of the Uranium Fuel Cycle and Solid Waste

Management. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1

6.1 The Uranium Fuel Cycle. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2
Contents

 NUREG-1437, Supplement 29 x July 2007

6.2 References..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-9

7.0 Environmental Impacts of Decommissioning. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1

7.1 Decommissioning. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-2

7.2 References..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-4

8.0 Environmental Impacts of Alternatives to License Renewal. . . . . . . . . . . . . . . . . . 8-1

8.1 No-Action Alternative.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-1

8.1.1 Land Use..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-2

8.1.2 Ecology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-3

8.1.3 Water Use and Quality - Surface Water.. . . . . . . . . . . . . . . . . . . . . 8-3

8.1.4 Water Use and Quality - Groundwater. . . . . . . . . . . . . . . . . . . . . . . 8-3

8.1.5 Air Quality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-3

8.1.6 Waste. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-4

8.1.7 Human Health. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-4

8.1.8 Socioeconomics.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-4

8.1.9 Socioeconomics (Transportation).. . . . . . . . . . . . . . . . . . . . . . . . . . 8-4

8.1.10 Aesthetics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-5

8.1.11 Historic and Archeological Resources. . . . . . . . . . . . . . . . . . . . . . . 8-5

8.1.12 Environmental Justice. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-5

8.2 Alternative Energy Sources.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-7

8.2.1 Coal-Fired Generation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-9

8.2.1.1 Closed-Cycle Cooling System. . . . . . . . . . . . . . . . . . . . . 8-10

8.2.1.2 Once-Through Cooling System. . . . . . . . . . . . . . . . . . . . 8-20

8.2.2 Natural Gas-Fired Generation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-21

8.2.2.1 Closed-Cycle Cooling System. . . . . . . . . . . . . . . . . . . . . 8-22

8.2.2.2 Once-Through Cooling System. . . . . . . . . . . . . . . . . . . . 8-31

8.2.3 Nuclear Power Generation.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-31

8.2.3.1 Closed-Cycle Cooling System. . . . . . . . . . . . . . . . . . . . . 8-33

8.2.3.2 Once-Through Cooling System. . . . . . . . . . . . . . . . . . . . 8-38
Contents

July 2007 xi NUREG-1437, Supplement 29

8.2.4 Purchased Electrical Power.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-39

8.2.5 Other Alternatives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-39

8.2.5.1 Oil-Fired Generation. . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-39

8.2.5.2 Wind Power. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-40

8.2.5.3 Solar Power. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-41

8.2.5.4 Hydropower. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-41

8.2.5.5 Geothermal Energy..... . . . . . . . . . . . . . . . . . . . . . . . . 8-42

8.2.5.6 Wood Waste. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-42

8.2.5.7 Municipal Solid Waste. . . . . . . . . . . . . . . . . . . . . . . . . . . 8-43

8.2.5.8 Other Biomass-Derived Fuels. . . . . . . . . . . . . . . . . . . . . 8-44

8.2.5.9 Fuel Cells.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-44

8.2.5.10 Delayed Retirement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-45

8.2.5.11 Conservation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-45

8.2.6 Combination of Alternatives.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-45

8.3 Summary of Alternatives Considered. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-48

8.4 References..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-49

9.0 Summary and Conclusions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-1

9.1 Environmental Impacts of the Proposed Action—License Renewal.. . . . . . . 9-4

9.1.1 Unavoidable Adverse Impacts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-6

9.1.2 Irreversible or Irretrievable Resource Commitments. . . . . . . . . . . . . 9-6

9.1.3 Short-Term Use Versus Long-Term Productivity. . . . . . . . . . . . . . . . 9-7

9.2 Relative Significance of the Environmental Impacts of License Renewal

and Alternatives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-7

9.3 Staff Conclusions and Recommendations.. . . . . . . . . . . . . . . . . . . . . . . . . . 9-8

9.4 References..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-8
 NUREG-1437, Supplement 29 xii July 2007

Figures

2-1 Location of PNPS, 50-mi Radius. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2

2-2 Location of PNPS, 6-mi Radius. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3

2-3 Aerial Photograph Showing PNPS Property Boundaries and

Environs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5

2-4 Facility Layout . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6

2-5 PNPS Intake Structure. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8

2-6 PNPS Transmission Line ROW.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-19

2-7 Gulf of Maine Winter Flounder.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-69

2-8 Winter Flounder Abundance Estimates in Northwestern Cape Cod Bay. . . . . 2-69

2-9 NMFS Winter Flounder Abundance in the Gulf of Maine. . . . . . . . . . . . . . . . . 2-70

2-10 MDMF Winter Flounder Abundance in the Gulf of Maine.. . . . . . . . . . . . . . . . 2-70

2-11 Aggregate of Minority Races Population Map. . . . . . . . . . . . . . . . . . . . . . . . 2-117

2-12 Low-Income Population Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-119

2-13 Expanded Facility Layout.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-126

4-1 Equivalent Adult Summary of Entrained and Impinged Winter Flounder

from PNPS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-25
July 2007 xiii NUREG-1437, Supplement 29

Tables

2-1 PNPS Transmission Line ROWs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-20

2-2 Effluent Limitations - NPDES Permit for PNPS. . . . . . . . . . . . . . . . . . . . . . . . 2-24

2-3 Effluent Limitations - MDEP Groundwater Discharge Permit for PNPS 

Wastewater Treatment Facility. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-25

2-4 Anadromous Marine Threatened or Endangered Species. . . . . . . . . . . . . . . . 2-84

2-5 Federally Listed Terrestrial and Freshwater Aquatic Species Potentially 

Occurring in the Vicinity of PNPS and the Associated Transmission 

Line ROW. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-93

2-6 Pilgrim Nuclear Power Station Permanent Employee Residence Information

by County and Town/City.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-101

2-7 Housing Units and Housing Units Vacant (Available) by County During

1990 and 2000. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-102

2-8 Selected Plymouth County Public Water Supply Systems and Capacities 

in 2003. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-103

2-9 Barnstable County Public Water Supply Systems and Capacities in 2003.. . 2-104

2-10 Traffic Counts for Roads in the Vicinity of PNPS. . . . . . . . . . . . . . . . . . . . . . 2-106

2-11 Land Use in Plymouth County, 1999. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-109

2-12 Land Use in Barnstable County, 1999. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-110

2-13 Population Growth in Plymouth and Barnstable Counties - 1980 to 2020. . . 2-113

2-14 Percentage of Minority and Low-income Individuals in the 50-mile Radius

Study Area and Threshold Criteria for Identifying Minority and Low-income

Populations at the Block Group Level. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-115

2-15 Block Groups Exceeding Thresholds for Minority and Low-income 

Populations in Counties Within a 50-mile Radius of PNPS. . . . . . . . . . . . . . 2-116

2-16 Employment Trends: Number of Employees by Industry Section 1990

and 2000. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-120

2-17 PNPS Contributions to Town of Plymouth Property Tax Revenues. . . . . . . . 2-123

3-1 Category 1 Issues for Refurbishment Evaluation.. . . . . . . . . . . . . . . . . . . . . . . 3-2

3-2 Category 2 Issues for Refurbishment Evaluation.. . . . . . . . . . . . . . . . . . . . . . . 3-3

4-1 Category 1 Issues Applicable to the Operation of the PNPS Cooling System 

During the Renewal Term. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2

4-2 Category 2 Issues Applicable to the Operation of the PNPS Cooling System

During the Renewal Term. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10

4-3 Species Entrained or Impinged During the Operating History of PNPS. . . . . . 4-15 |

4-4 Number of Eggs and Larvae Entrained for Six Species of Fish at PNPS from |

1980 to 2005. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-19

4-5 Equivalent Adult Losses of Winter Flounder. . . . . . . . . . . . . . . . . . . . . . . . . . 4-25 |

4-6 Annual Extrapolated Totals for Typical Dominants Found on the PNPS Intake |

Screens, 1980 - 2005. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-30
Tables

 NUREG-1437, Supplement 29 xiv July 2007

| 4-7 Category 1 Issues Applicable to the PNPS Transmission Lines During the

Renewal Term. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-44

| 4-8 Category 2 and Uncategorized Issues Applicable to the PNPS Transmission 

Lines During the Renewal Term. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-47

| 4-9 Category 1 Issues Applicable to Radiological Impacts of Normal Operations

During the Renewal Term. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-50

| 4-10 Category 1 Issues Applicable to Socioeconomics During the Renewal Term. 4-51

| 4-11 Environmental Justice and GEIS Category 2 Issues Applicable to

Socioeconomics During the Renewal Term.. . . . . . . . . . . . . . . . . . . . . . . . . . 4-53

| 4-12 Category 1 Issues Applicable to Groundwater Use and Quality During the

Renewal Term. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-61

| 4-13 Category 2 Issues Applicable to Threatened or Endangered Species 

During the Renewal Term. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-62

5-1 Category 1 Issue Applicable to Postulated Accidents During the Renewal

Term. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3

5-2 Category 2 Issue Applicable to Postulated Accidents During the Renewal

Term. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4

| 5-3 PNPS Core Damage Frequency. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6

5-4 Breakdown of Population Dose by Containment Release Mode. . . . . . . . . . . . 5-8

6-1 Category 1 Issues Applicable to the Uranium Fuel Cycle and Solid Waste

Management During the Renewal Term. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2

7-1 Category 1 Issues Applicable to the Decommissioning of PNPS Following the

Renewal Term. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-2

8-1 Summary of Environmental Impacts of the No-Action Alternative. . . . . . . . . . . 8-6

8-2 Summary of Environmental Impacts of Coal-Fired Generation at an

Alternate Greenfield Site Using Closed-Cycle Cooling. . . . . . . . . . . . . . . . . . 8-19

8-3 Summary of Environmental Impacts of Coal-Fired Generation at the

PNPS Site with Once-Through Cooling System. . . . . . . . . . . . . . . . . . . . . . . 8-21

8-4 Summary of Environmental Impacts of Natural Gas-Fired Generation at the

PNPS Site and an Alternate Greenfield Site Using Closed-Cycle Cooling. . . . 8-29

8-5 Summary of Environmental Impacts of Natural Gas-Fired Generation at the

PNPS Site with Once-Through Cooling. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-32

8-6 Summary of Environmental Impacts of New Nuclear Power Generation at 

an Alternate Greenfield Site Using Closed-Cycle Cooling. . . . . . . . . . . . . . . . 8-37

8-7 Summary of Environmental Impacts of a New Nuclear Power Plant Sited 

at an Alternate Greenfield Site with Once-Through Cooling. . . . . . . . . . . . . . 8-38
Tables

July 2007 xv NUREG-1437, Supplement 29

8-8 Summary of Environmental Impacts of 350 MW(e) of Natural Gas-Fired 

Generation, 250 MW(e) from Wind Generation, and 115 MW(e) 

from DSM Measures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-46

9-1 Summary of Environmental Significance of Licence Renewal, the No Action 

Alternative, and Alternative Methods of Generation. .. . . . . . . . . . . . . . . . . . . 9-10
(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

 NUREG-1437, Supplement 29 xvi July 2007

Executive Summary

By letter dated January 25, 2006, Entergy Nuclear Operations, Inc. (Entergy) submitted an

application to the U.S. Nuclear Regulatory Commission (NRC) to renew the operating license

(OL) for Pilgrim Nuclear Power Station (PNPS) for an additional 20-year period. If the OL is

renewed, State regulatory agencies and PNPS will ultimately decide whether the plant will

continue to operate based on factors such as the need for power or other matters within the

State’s jurisdiction or the purview of the owners. If the OL is not renewed, then the plant must

| be shut down on or before the expiration date of the current OL, which is June 8, 2012.

The NRC has implemented Section 102 of the National Environmental Policy Act of 1969, as

amended (NEPA) (42 USC 4321), in Title 10 of the Code of Federal Regulations (CFR), Part 51

(10 CFR Part 51). In 10 CFR 51.20(b)(2), the Commission requires preparation of an

environmental impact statement (EIS) or a supplement to an EIS for renewal of a reactor OL. 

In addition, 10 CFR 51.95(c) states that the EIS prepared at the OL renewal stage will be a

supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear

Plants (GEIS), NUREG-1437, Volumes 1 and 2.

(a)

Upon acceptance of the PNPS application, the NRC began the environmental review process

described in 10 CFR Part 51 by publishing a notice of intent to prepare an EIS and conduct

| scoping. The staff visited the PNPS site in May 2006 and held two public scoping meetings on

| May 17, 2006. In the preparation of the draft supplemental environmental impact statement

(SEIS) for PNPS, the staff reviewed the PNPS Environmental Report (ER) and compared it to

the GEIS, consulted with other agencies, conducted an independent review of the issues

following the guidance set forth in NUREG-1555, Supplement 1, the Standard Review Plans for

Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal,

and considered the public comments received during the scoping process. The public

comments received during the scoping process that were considered to be within the scope of

| the environmental review are provided in Appendix A, Part 1, of this SEIS.

| The draft SEIS was published in December, 2006. The NRC held two public meetings in

Plymouth, Massachusetts in January 2007, to describe the preliminary results of the NRC

environmental review, to answer questions, and to provide members of the public with

| information to assist them in formulating comments on the draft SEIS. When the comment

| period ended, the staff considered and addressed all of the comments received. These

| comments are addressed in Appendix A, Part II of this SEIS. 

| This SEIS includes the NRC staff’s analysis that considers and weighs the environmental effects

of the proposed action, the environmental impacts of alternatives to the proposed action, and
Executive Summary

July 2007 xvii NUREG-1437, Supplement 29

mitigation measures for reducing or avoiding adverse effects. It also includes the staff’s

recommendation regarding the proposed action.

The Commission has adopted the following statement of purpose and need for license renewal

from the GEIS:

The purpose and need for the proposed action (renewal of an operating license) is to provide

an option that allows for power generation capability beyond the term of a current nuclear

power plant operating license to meet future system generating needs, as such needs may

be determined by state, utility, and, where authorized, Federal (other than NRC)

decisionmakers.

The evaluation criterion for the staff’s environmental review, as defined in 10 CFR 51.95(c)(4)

and the GEIS, is to determine:

. . . whether or not the adverse environmental impacts of license renewal are so great that

preserving the option of license renewal for energy planning decisionmakers would be

unreasonable.

Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that

there are factors, in addition to license renewal, that will ultimately determine whether an existing

nuclear power plant continues to operate beyond the period of the current OL.

NRC regulations [10 CFR 51.95(c)(2)] contain the following statement regarding the content of

SEISs prepared at the license renewal stage:

The supplemental environmental impact statement for license renewal is not required to

include discussion of need for power or the economic costs and economic benefits of the

proposed action or of alternatives to the proposed action except insofar as such benefits and

costs are either essential for a determination regarding the inclusion of an alternative in the

range of alternatives considered or relevant to mitigation. In addition, the supplemental

environmental impact statement prepared at the license renewal stage need not discuss

other issues not related to the environmental effects of the proposed action and the

alternatives, or any aspect of the storage of spent fuel for the facility within the scope of the

generic determination in § 51.23(a) [“Temporary storage of spent fuel after cessation of

reactor operation–generic determination of no significant environmental impact”] and in

accordance with § 51.23(b).

The GEIS contains the results of a systematic evaluation of the consequences of renewing an

OL and operating a nuclear power plant for an additional 20 years. It evaluates
Executive Summary

 NUREG-1437, Supplement 29 xviii July 2007

92 environmental issues using the NRC’s three-level standard of significance—SMALL,

MODERATE, or LARGE—developed using the Council on Environmental Quality guidelines. 

The following definitions of the three significance levels are set forth in footnotes to Table B-1 of

10 CFR Part 51, Subpart A, Appendix B:

SMALL - Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

MODERATE - Environmental effects are sufficient to alter noticeably, but not to

destabilize, important attributes of the resource.

LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.

For 69 of the 92 issues considered in the GEIS, the analysis in the GEIS reached the following

conclusions:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system

or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to

the impacts (except for collective off-site radiological impacts from the fuel cycle and

from high-level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures

are not likely to be sufficiently beneficial to warrant implementation.

These 69 issues were identified in the GEIS as Category 1 issues. In the absence of new and

significant information, the staff relied on conclusions, as amplified by supporting information in

the GEIS, for issues designated as Category 1 in Table B-1 of 10 CFR Part 51, Subpart A,

Appendix B.

Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2

issues requiring analysis in a plant-specific supplement to the GEIS. The remaining two issues,

environmental justice and chronic effects of electromagnetic fields, were not categorized. 

Environmental justice was not evaluated on a generic basis and must be addressed in a plantspecific supplement to the GEIS. Information on the chronic effects of electromagnetic fields

was not conclusive at the time the GEIS was prepared.
Executive Summary

July 2007 xix NUREG-1437, Supplement 29

This SEIS documents the staff’s consideration of all 92 environmental issues identified in the |

GEIS. The staff considered the environmental impacts associated with alternatives to license

renewal and compared the environmental impacts of license renewal and the alternatives. The

alternatives to license renewal that were considered include the no-action alternative (not

renewing the OL for PNPS) and alternative methods of power generation. Based on projections

made by the U.S. Department of Energy’s Energy Information Administration (DOE/EIA), coal

and gas-fired generation appear to be the most likely power-generation alternatives if the power

from PNPS is replaced. These alternatives are evaluated assuming that the replacement power

generation plant is located at either the PNPS site or some other unspecified alternate location.

Entergy and the staff have established independent processes for identifying and evaluating the

significance of any new information on the environmental impacts of license renewal. Neither

Entergy nor the staff has identified information that is both new and significant related to

Category 1 issues that would call into question the conclusions in the GEIS. Therefore, the staff

relies upon the conclusions of the GEIS for all of the Category 1 issues that are applicable to

PNPS. However, the staff has identified the need for an essential fish habitat (EFH)

consultation. NRC conducted an EFH consultation with the National Marine Fisheries Service |

(NMFS). NMFS has concluded the EFH consultation; such documentation is included in |

Appendix E of this SEIS. In addition, the staff considered the potential new issue of effects on |

aquatic habitat due to operation of the cooling system. The staff concluded that this issue, while |

new, would not be significant. |

PNPS’s license renewal application presents an analysis of the Category 2 issues plus

environmental justice and chronic effects from electromagnetic fields. The staff has reviewed

the PNPS analysis for each issue and has conducted an independent review of each issue. Six

Category 2 issues are not applicable, because they are related to plant design features or site

characteristics not found at PNPS. Four Category 2 issues are not discussed in this SEIS, |

because they are specifically related to refurbishment. PNPS has stated that its evaluation of

structures and components, as required by 10 CFR 54.21, did not identify any major plant

refurbishment activities or modifications as necessary to support the continued operation of

PNPS for the license renewal period. In addition, any replacement of components or additional

inspection activities are within the bounds of normal plant operation, and are not expected to

affect the environment outside of the bounds of the plant operations evaluated in the U.S.

Atomic Energy Commission’s 1972 Final Environmental Statement Related to Operation of

PNPS.

Eleven Category 2 issues related to operational impacts and postulated accidents during the

renewal term, as well as environmental justice and chronic effects of electromagnetic fields, are

discussed in detail in this SEIS. Five of the Category 2 issues and environmental justice apply to |

both refurbishment and to operation during the renewal term and are only discussed in this SEIS

in relation to operation during the renewal term. For the 11 Category 2 issues and
Executive Summary

 NUREG-1437, Supplement 29 xx July 2007

environmental justice, the staff concludes that the potential environmental effects are of SMALL

and SMALL to MODERATE significance in the context of the standards set forth in the GEIS. A

MODERATE impact was determined based on entrainment of the local population of winter

| flounder (Pseudopleuronectes americanus) and a MODERATE impact was determined based on

| impingement of the Jones River population of rainbow smelt (Osmerus mordax). The staff

| concluded that the potential site-specific impacts of the cooling intake system due to entrainment

| (local winter flounder population) and impingement (Jones River rainbow smelt) would be

| MODERATE. For all other marine aquatic species, the staff concluded that potential impacts

| due to entrainment and impingement would be SMALL to MODERATE. Additional mitigation to

| minimize the impacts of entrainment and impingement may be justified. EPA Region I is

| currently in the process of reviewing the National Pollutant Discharge Elimination System permit

| renewal application for PNPS. It is expected that this evaluation would evaluate the need for

| and feasibility of any additional mitigation measures.

|

| The staff also determined that appropriate Federal health agencies have not reached a

consensus on the existence of chronic adverse effects from electromagnetic fields. Therefore,

no further evaluation of this issue is required. For severe accident mitigation alternatives

(SAMAs), the staff concludes that a reasonable, comprehensive effort was made to identify and

evaluate SAMAs. Based on its review of the SAMAs for PNPS and the plant improvements

already made, the staff concludes that Entergy identified five potentially cost-beneficial SAMAs.

The staff concludes that two additional SAMAs are potentially cost-beneficial. However, these

SAMAs do not relate to adequate managing of the effects of aging during the period of extended

operation. Therefore, they do not need to be implemented as part of the license renewal

pursuant to 10 CFR Part 54.

Cumulative impacts of past, present, and reasonably foreseeable future actions were

considered, regardless of what agency (Federal or non-Federal) or person undertakes such

other actions. For purposes of this analysis, the staff concluded that the cumulative impacts

resulting from the incremental contribution of PNPS operation and maintenance of the

transmission line right-of-way would be SMALL for all resources with the exception of marine

aquatic resources, which would experience SMALL to MODERATE cumulative impacts.

| If the PNPS operating license is not renewed and the unit ceases operation on or before the

| expiration of its current operating license, then the adverse impacts of likely alternatives would

not be smaller than those associated with continued operation of PNPS. The impacts may, in

fact, be greater in some areas.

| The recommendation of the NRC staff is that the Commission determine that the adverse

environmental impacts of license renewal for PNPS are not so great that preserving the option of

license renewal for energy planning decisionmakers would be unreasonable. This

recommendation is based on (1) the analysis and findings in the GEIS; (2) the ER submitted by
Executive Summary

July 2007 xxi NUREG-1437, Supplement 29

Entergy; (3) consultations with other Federal, State, and local agencies; (4) the staff’s own

independent review; and (5) the staff’s consideration of public comments. |
 NUREG-1437, Supplement 29 xxii July 2007

Abbreviations/Acronyms

E degree(s)

ìm micron(s)

ac acre(s)

AC alternating current

ACC averted cleanup and decontamination costs

ADS automatic depressurization system

AEC U.S. Atomic Energy Commission

ALARA as low as reasonably achievable

| AOC averted off-site property damage costs

AOE averted occupational exposure

| AOG augmented off-gas

| AOSC averted on-site cost

APE averted public exposure

ASME American Society of Mechanical Engineers

ASMFC Atlantic States Marine Fisheries Commission

ATWS anticipated transient without scram

BA biological assessment

| BRW boiling water reactor

BTU British thermal unit(s)

BWROG boiling water reactor owners group

C Celsius

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CAPB collapsed accident progression bins

CCDP conditional core damage probabilities

CDF core damage frequency

CDS Comprehensive Demonstration Study

CET containment event tree

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

cfs cubic foot (feet) per second

Ci curie(s)

cm centimeter(s)

CO carbon monoxide

CO2 carbon dioxide

COE cost of enhancement

CST condensate storage tanks

CWA Clean Water Act
Abbreviations/Acronyms

July 2007 xxiii NUREG-1437, Supplement 29

DBA design-basis accidents |

DC direct current

DCH direct containment heating

delta T change in temperature

DFO Department of Fisheries and Oceans

DMR discharge monitoring report

DO dissolved oxygen

DOE U.S. Department of Energy

DSM demand side management |

DTV direct torus vent

EA environmental assessment

ECCS emergency core cooling system

EDG emergency diesel generator

EEZ exclusive economic zone

EFH essential fish habitat

EIA Energy Information Administration (of DOE)

EIS environmental impact statement

ELF-EMF extremely low frequency-electromagnetic field

EN-EV environmental review and evaluation procedure

Entergy Entergy Nuclear Operations, Inc.

EOP emergency operating procedure

EPA U.S. Environmental Protection Agency

EPH extractable petroleum hydrocarbons

EPRI Elecrtical Power Research Institute

ER Environmental Report

ESA Endangered Species Act of 1976, as amended

ETE evacuation time estimate

F Fahrenheit

FES Final Environmental Statement |

FIVE fire-induced vulnerability evaluation

FMP fishery management plan

fps foot (feet) per second

FR Federal Register

FSAR Final Safety Analysis Report |

ft foot (feet)

FWS U.S. Fish and Wildlife Service

fy fiscal year
Abbreviations/Acronyms

 NUREG-1437, Supplement 29 xxiv July 2007

GL generic letter

GARM Groundfish Assessment Review Meeting 

GEIS Generic Environmental Impact Statement for License Renewal of Nuclear Plants,

NUREG-1437

| GIS geographic information system

gpm gallon(s) per minute

HAPC habitat area of particular concern

HCLPF high confidence low probability of failure

HLW high-level waste

| hp horsepower

HPCI high pressure coolant injection

ICRP International Commission on Radiological Protection

in. inch(es)

IPE individual plant examination

IPEEE individual plant examination external events

| ISLOCA interfacing system LOCA

km kilometer(s)

kV kilovolt(s)

kW kilowatt(s)

kWh kilowatt hour(s)

L liter(s)

LLRWSF low level radwaste storage facility 

LOCA loss of coolant accident

| LOOP loss of off-site power

LPCI low pressure coolant injection

m meter(s)

m/s meter(s) per second

mA milliampere(s)

MA DEM Massachusetts Department of Environmental Management

MAAP modular accident analysis program

MACCS2 MELCOR Accident Consequence Code System 2

MAFMC Mid-Atlantic Fishery Management Council

MassGIS Massachusetts Geographic Information System

MBDS Massachusetts Bay Disposal Site

MCC motor control centers

MDEP Massachusetts Department of Environmental Protection
Abbreviations/Acronyms

July 2007 xxv NUREG-1437, Supplement 29

MDFW Massachusetts Division of Fisheries and Wildlife

MDMF Massachusetts Division of Marine Fisheries

MDPH Massachusetts Department of Public Health

MEOEA Massachusetts Executive Office for Environmental Affairs

mg/L milligram(s) per liter

MHC Massachusetts Historical Commission

mi mile(s)

min minute(s) |

MISER Massachusetts Institute for Social and Environmental Research

mL milliliter(s)

MLW mean low water

mm millimeter(s)

mrem millirem(s)

MRI Marine Research, Inc.

MSA Magnuson-Stevens Act |

MSIV main steam isolation valve

MSL mean sea level

MTU metric ton of uranium |

MWd megawatt-days |

MW(e) megawatt(s) electric

MW(h) megawatt hour(s)

MWRA Massachusetts Water Resource Authority

MW(t) megawatt(s) thermal

NAFO Northwest Atlantic Fisheries Organization

NAS National Academy of Sciences

NEFMC New England Fishery Management Council

NEFSC Northeast Fisheries Science Center

NEPA National Environmental Policy Act of 1969, as amended

NESC National Electric Safety Code

NHESP Massachusetts Natural Heritage and Endangered Species Program

NHPA National Historic Preservation Act

NIEHS National Institute of Environmental Health Sciences

NMFS National Marine Fisheries Service

NO2 nitrogen dioxide

NOx nitrogen oxide(s) 

NOAA National Oceanic and Atmospheric Administration

NOV notice of violation

NPDES National Pollutant Discharge Elimination System

NPSH net positive suction head

NRC U.S. Nuclear Regulatory Commission
Abbreviations/Acronyms

 NUREG-1437, Supplement 29 xxvi July 2007

OCPC Old Colony Planning Council

ODCM Offsite Dose Calculation Manual

OL operating license

PAH polycyclic aromatic hydrocarbon

PCB polychloronated biphenyl

PDS plant damage state

PGA peak ground acceleration

PILOT payments in lieu of taxes

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

PM10 particulate matter, 10 microns or less in diameter

PNPS Pilgrim Nuclear Power Station

ppm parts per million

ppt parts per thousand

PSA probabilistic safety assessment

psi pound(s) per square inch

| RAI request for additional information

RAMAS risk analysis management alternative system

RBCCW reactor building closed cooling water

RCIC reactor coolant injection cooling

| RCRA Resource Conservation and Recovery Act

REMP radiological environmental monitoring program

REWD Radioactive Effluent and Waste Disposal Report

RHR residual heat removal 

ROW right-of-way

RPC replacement power costs

RPV reactor pressure valve

RRW risk reduction worth

s second(s)

SAFE Stock Assessment and Fishery Evaluation 

SAMA severe accident mitigation alternative

| SAR Safety Analysis Report

SARC Stock Assessment Review Committee 

SBO station blackout

SCR selective catalytic reduction

SEIS supplemental environmental impact statement

SER Safety Evaluation Report

SGTS standby gas treatment system

SLC standby liquid control
Abbreviations/Acronyms

July 2007 xxvii NUREG-1437, Supplement 29

SMHS Southeastern Massachusetts Health Study

SO2 sulfur dioxide

SOx sulfur oxide(s)

SPRA seismic probabilistic risk assessment

SRV steam release valve

SSB spawning stock biomass

SSW salt service water

Sv sievert(s)

TBCCW turbine building closed cooling water 

TDS total dissolved solids

TPH total petroleum hydrocarbons

TRC total residual chlorine

U.S. United States

USACE U.S. Army Corps of Engineers |

USC United States Code

USCB U.S. Census Bureau

USI unresolved safety issue

V volt(s)

VDC volts direct current

VIMS Virginia Institute of Marine Science

yr year(s)

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

July 2007 1-1 NUREG-1437, Supplement 29

1.0 Introduction

Under the U.S. Nuclear Regulatory Commission’s (NRC’s) environmental protection regulations

in Title 10 of the Code of Federal Regulations (CFR) Part 51, which implement the National

Environmental Policy Act of 1969, as amended (NEPA), renewal of a nuclear power plant

operating license (OL) requires the preparation of an environmental impact statement (EIS). In

preparing the EIS, the NRC staff is required first to issue the statement in draft form for public

comment, and then issue a final statement after considering public comments on the draft. To

support the preparation of the EIS, the staff prepared a Generic Environmental Impact

Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2

(NRC 1996; 1999).(a) The GEIS is intended to (1) provide an understanding of the types and

severity of environmental impacts that may occur as a result of license renewal of nuclear power

plants under 10 CFR Part 54, (2) identify and assess the impacts that are expected to be

generic to license renewal, and (3) support 10 CFR Part 51 to define the number and scope of

issues that need to be addressed by the applicants in plant-by-plant renewal proceedings. Use

of the GEIS guides the preparation of complete plant-specific information in support of the OL

renewal process.

Entergy Nuclear Operations, Inc. (Entergy), a subsidiary of Entergy Corporation, operates

Pilgrim Nuclear Power Station (PNPS) in Plymouth, Massachusetts under OL DPR-35, which

was issued by the NRC. This OL will expire on June 8, 2012. On January 25, 2006, Entergy

submitted an application to the NRC to renew the PNPS OL for an additional 20 years under 10

CFR Part 54 (Entergy 2006a). Entergy is a licensee for the purposes of its current OL and an

applicant for the renewal of the OL. Pursuant to 10 CFR 54.23 and 51.53(c), Entergy submitted

an Environmental Report (ER) (Entergy 2006b) in which Entergy analyzed the environmental

impacts associated with the proposed license renewal action, considered alternatives to the

proposed action, and evaluated mitigation measures for reducing adverse environmental

effects.

This report is the facility-specific supplement to the GEIS (the supplemental EIS [SEIS]) for the |

PNPS license renewal application. This SEIS is a supplement to the GEIS because it relies, in |

part, on the findings of the GEIS. The staff also prepared a separate safety evaluation report in |

accordance with 10 CFR Part 54.

1.1 Report Contents

The following sections of this introduction (1) describe the background for the preparation of this |

SEIS, including the development of the GEIS and the process used by the staff to assess the |

environmental impacts associated with license renewal, (2) describe the proposed Federal
Introduction

NUREG-1437, Supplement 29 1-2 July 2007

action to renew the PNPS OL, (3) discuss the purpose and need for the proposed action, and

(4) present the status of Entergy's compliance with environmental quality standards and

requirements that have been imposed by Federal, State, regional, and local agencies that are

responsible for environmental protection.

| The ensuing chapters of this SEIS closely parallel the contents and organization of the GEIS. 

Chapter 2 describes the site, power plant, and interactions of the plant with the environment. 

Chapters 3 and 4, respectively, discuss the potential environmental impacts of plant refurbishment and plant operation during the renewal term. Chapter 5 contains an evaluation of potential

environmental impacts of plant accidents and includes consideration of severe accident

mitigation alternatives. Chapter 6 discusses the uranium fuel cycle and solid waste management. Chapter 7 discusses decommissioning, and Chapter 8 discusses alternatives to license

renewal. Finally, Chapter 9 summarizes the findings of the preceding chapters and draws

conclusions about the adverse impacts that cannot be avoided; the relationship between shortterm uses of man’s environment and the maintenance and enhancement of long-term

productivity; and the irreversible or irretrievable commitment of resources. Chapter 9 also

presents the staff’s preliminary recommendation with respect to the proposed license renewal

action.

| Additional information is included in the appendices. Appendix A contains public comments

related to the environmental review for license renewal and staff responses to those comments. 

Appendices B through G, respectively, include the following:

 C the preparers of the supplement (Appendix B),

 C the chronology of the NRC staff’s environmental review correspondence related to this

| SEIS (Appendix C),

| C the organizations contacted during the development of this SEIS (Appendix D),

 C Entergy's compliance status in Table E-1 (this appendix also contains copies of

consultation correspondence prepared and sent during the evaluation process)

(Appendix E),

 C GEIS environmental issues that are not applicable to PNPS (Appendix F), and

 C NRC staff evaluation of severe accident mitigation alternatives (SAMAs) (Appendix G).
Introduction

July 2007 1-3 NUREG-1437, Supplement 29

1.2 Background

The following sections discuss use of the GEIS, which examines the possible environmental |

impacts that could occur as a result of renewing individual nuclear power plant OLs under 

10 CFR Part 54. The established license renewal evaluation process supports the thorough |

evaluation of the impacts of OL renewal.

1.2.1 Generic Environmental Impact Statement

The NRC initiated a generic assessment of the environmental impacts associated with the

license renewal term to improve the efficiency of the license renewal process by documenting

the assessment results and codifying the results in the Commission’s regulations. This

assessment is provided in the GEIS, which serves as the principal reference for all nuclear

power plant license renewal EISs.

The GEIS documents the results of the systematic approach that was taken to evaluate the

environmental consequences of renewing the licenses of individual nuclear power plants and

operating them for an additional 20 years. For each potential environmental issue, the GEIS

(1) describes the activity that affects the environment, (2) identifies the population or resource

that is affected, (3) assesses the nature and magnitude of the impact on the affected population

or resource, (4) characterizes the significance of the effect for both beneficial and adverse

effects, (5) determines whether the results of the analysis apply to all plants, and (6) considers

whether additional mitigation measures would be warranted for impacts that would have the

same significance level for all plants.

The NRC’s standard of significance for impacts was established using the Council on

Environmental Quality (CEQ) terminology for “significantly” (40 CFR 1508.27, which requires

consideration of both “context” and “intensity”). Using the CEQ terminology, the NRC

established three significance levels – SMALL, MODERATE, or LARGE. The definitions of the

three significance levels are set forth in the footnotes to Table B-1 of 10 CFR Part 51, Subpart

A, Appendix B, as follows:

SMALL – Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

MODERATE – Environmental effects are sufficient to alter noticeably, but not to

destabilize, important attributes of the resource.

LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.
Introduction

NUREG-1437, Supplement 29 1-4 July 2007

The GEIS assigns a significance level to each environmental issue, assuming that ongoing

mitigation measures would continue.

The GEIS includes a determination of whether the analysis of the environmental issue could be

applied to all plants and whether additional mitigation measures would be warranted. Issues

are assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1

issues are those that meet all of the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply either

to all plants or, for some issues, to plants having a specific type of cooling system or other

specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to the

impacts (except for collective off-site radiological impacts from the fuel cycle and from highlevel waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the analysis,

and it has been determined that additional plant-specific mitigation measures are likely not

to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

| required in this SEIS unless new and significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria of Category 1;

therefore, additional plant-specific review for these issues is required.

In the GEIS, the staff assessed 92 environmental issues and determined that 69 qualified as

Category 1 issues, 21 qualified as Category 2 issues, and 2 issues were not categorized. The

two issues not categorized are environmental justice and chronic effects of electromagnetic

fields. Environmental justice was not evaluated on a generic basis and must be addressed in a

plant-specific supplement to the GEIS. Information on the chronic effects of electromagnetic

fields was not conclusive at the time the GEIS was prepared. 

Of the 92 issues, 11 are related only to refurbishment, 6 are related only to decommissioning,

67 apply only to operation during the renewal term, and 8 apply to both refurbishment and

operation during the renewal term. A summary of the findings for all 92 issues in the GEIS is

codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B.

The NRC staff has identified a new issue that was not previously addressed in the GEIS related

| to essential fish habitat (EFH). The consultation requirements of Section 305(b) of the

Magnuson-Stevens Fishery Conservation and Management Act, as amended by the
Introduction

July 2007 1-5 NUREG-1437, Supplement 29

Sustainable Fisheries Act of 1996, provide that Federal agencies must consult with the |

Secretary of Commerce on all actions or proposed actions authorized, funded, or undertaken by

the agency that may adversely affect EFH. NRC conducted an EFH consultation with the |

National Marine Fisheries Service (NMFS). NMFS has concluded the EFH consultation; such |

documentation is included in Appendix E of this SEIS. Another new issue (effects on aquatic |

habitat) was identified but was determined not to be significant. |

1.2.2 License Renewal Evaluation Process

An applicant seeking to renew its OL is required to submit an ER as part of its application. The

license renewal evaluation process involves careful review of the applicant’s ER and assurance

that all new and potentially significant information not already addressed in or available during

the GEIS evaluation is identified and assessed to verify the environmental impacts of the |

proposed license renewal.

In accordance with 10 CFR 51.53(c)(2) and (3), the ER submitted by the applicant must:

 C provide an analysis of the Category 2 issues in Table B-1 of 10 CFR Part 51, Subpart A,

Appendix B in accordance with 10 CFR 51.53(c)(3)(ii) and

 C discuss actions to mitigate any adverse impacts associated with the proposed action

and environmental impacts of alternatives to the proposed action.

In accordance with 10 CFR 51.53(c)(2), the ER does not need to:

 C consider the economic benefits and costs of the proposed action and alternatives to the

proposed action except insofar as such benefits and costs are either (1) essential for

making a determination regarding the inclusion of an alternative in the range of

alternatives considered or (2) relevant to mitigation,

 C consider the need for power and other issues not related to the environmental effects of

the proposed action and the alternatives,

 C discuss any aspect of the storage of spent fuel within the scope of the generic

determination in 10 CFR 51.23(a) in accordance with 10 CFR 51.23(b), or

 C contain an analysis of any Category 1 issue unless there is significant new information

on a specific issue — this is pursuant to 10 CFR 51.23(c)(3)(iii) and (iv).

New and significant information is (1) information that identifies a significant environmental

issue not covered in the GEIS and codified in Table B-1 of 10 CFR Part 51, Subpart A,
Introduction

NUREG-1437, Supplement 29 1-6 July 2007

Appendix B or (2) information that was not considered in the analyses summarized in the GEIS

and that leads to an impact finding that is different from the finding presented in the GEIS and

codified in 10 CFR Part 51.

In preparing to submit its application to renew the PNPS OL, Entergy developed a process to

ensure that (1) information not addressed in or available during the GEIS evaluation regarding

the environmental impacts of license renewal for PNPS would be properly reviewed before

submitting the ER and (2) such new and potentially significant information related to renewal of

| the license for PNPS would be identified and assessed during the NRC’s review. Entergy

reviewed the Category 1 issues that appear in Table B-1 of 10 CFR Part 51, Subpart A,

Appendix B, to verify that the conclusions of the GEIS remained valid with respect to PNPS. 

This review was performed by personnel from Entergy and its support organization who were

familiar with NEPA issues and the scientific disciplines involved in the preparation of a license

renewal ER.

The NRC staff also has a process for identifying new and significant information. That process

is described in detail in Standard Review Plans for Environmental Reviews for Nuclear Power

Plants, Supplement 1: Operating License Renewal, NUREG-1555, Supplement 1 (NRC 2000). 

The search for new information includes (1) review of an applicant’s ER and the process for

discovering and evaluating the significance of new information; (2) review of records of public

comments; (3) review of environmental quality standards and regulations; (4) coordination with

Federal, State, and local environmental protection and resource agencies; and (5) review of the

technical literature. New information discovered by the staff is evaluated for significance using

the criteria set forth in the GEIS. For Category 1 issues where new and significant information

is identified, reconsideration of the conclusions for those issues is limited in scope to the

assessment of the relevant new and significant information; the scope of the assessment does

not include other facets of the issue that are not affected by the new information.

Chapters 3 through 7 discuss the environmental issues considered in the GEIS that are

applicable to PNPS. At the beginning of the discussion of each set of issues, there is a table

that identifies the issues to be addressed and lists the sections in the GEIS where the issue is

discussed. Category 1 and Category 2 issues are listed in separate tables. For Category 1

issues for which there is no new and significant information, the table is followed by a set of

short paragraphs that state the GEIS conclusion codified in Table B-1 of 10 CFR Part 51,

Subpart A, Appendix B, followed by the staff’s analysis and conclusion. For Category 2 issues,

in addition to the list of GEIS sections where the issue is discussed, the tables list the

| subparagraph of 10 CFR 51.53(c)(3)(ii) that describes the analysis required and the SEIS

| sections where the analysis is presented. The SEIS sections that discuss the Category 2

issues are presented immediately following the table.
Introduction

July 2007 1-7 NUREG-1437, Supplement 29

The NRC prepares an independent analysis of the environmental impacts of license renewal

and compares these impacts with the environmental impacts of alternatives. The evaluation of

the Entergy license renewal application began with the publication of a notice of acceptance for

docketing and notice of opportunity for a hearing in the Federal Register (FR) (71 FR 15222;

NRC 2006a) on March 27, 2006. The staff published a notice of intent to prepare an EIS and

conduct scoping (71 FR 19554; NRC 2006b) on April 14, 2006. Two public scoping meetings

were held on May 17, 2006, in Plymouth, Massachusetts. Comments received during the

scoping period were summarized in the Environmental Impact Statement Scoping Process:

Summary Report - Pilgrim Nuclear Power Station (NRC 2006c) dated September 26, 2006. 

Comments that are applicable to this environmental review are presented in Part 1 of 

Appendix A. |

The staff followed the review guidance contained in NUREG-1555, Supplement 1 (NRC 2000). 

The staff and contractor retained to assist the staff visited the PNPS Site on May 1 through 

May 5, 2006, to gather information and to become familiar with the site and its environs. The

staff also reviewed the comments received during scoping, and consulted with Federal, State,

regional, and local agencies. A list of the organizations consulted is provided in Appendix D. 

Other documents related to PNPS were reviewed and are referenced within this SEIS. |

This SEIS presents the staff’s analysis that considers and weighs the environmental effects of |

the proposed renewal of the OL for PNPS, the environmental impacts of alternatives to license

renewal, and mitigation measures available for avoiding adverse environmental effects. 

Chapter 9, “Summary and Conclusions,” provides the NRC staff’s preliminary recommendation

to the Commission on whether or not the adverse environmental impacts of license renewal are

so great that preserving the option of license renewal for energy-planning decisionmakers would

be unreasonable.

On December 8, 2006 the NRC published the Notice of Availability of the draft SEIS. A 75-day |

comment period began on the date of publication of the U.S. Environmental Protection Agency |

Notice of Filing of the draft SEIS to allow members of the public to comment on the preliminary |

results of the NRC staff’s review. The comment period ended on February 28, 2007. During |

the comment period, two public meetings were held in Plymouth, Massachusetts on January 24, |

2007. During these meetings, the NRC staff described the preliminary results of the NRC |

environmental review and answered questions related to the environmental review to provide |

members of the public with information to assist them in formulating their comments. |

Comments made during the 75-day comment period, including those made at the two public |

meetings, are presented in Appendix A, Part 2, of this SEIS. |
Introduction

NUREG-1437, Supplement 29 1-8 July 2007

1.3 The Proposed Federal Action

The proposed Federal action is renewal of the OL for PNPS. The PNPS facility is located in

eastern Massachusetts on the western shore of Cape Cod Bay, approximately 38 miles (mi)

southwest of Boston, Massachusetts, and 44 mi east of Providence, Rhode Island. The plant

has one General Electric-designed boiling water reactor with a design power level of 1,998

megawatts thermal (MW[t]). In 2003, PNPS implemented a Thermal Power Optimization of 1.5

percent to achieve the current electrical rating of 715 megawatts electric (MW[e]). Plant cooling

is provided by a once-through heat dissipation system that withdraws cooling water from and

discharges it to Cape Cod Bay. PNPS produces electricity to supply the needs of more than

| 550,000 homes. The current OL for PNPS expires on June 8, 2012. By letter dated January 25,

2006, Entergy submitted an application to the NRC (Entergy 2006a) to renew this OL for an

additional 20 years of operation (i.e., until June 8, 2032).

1.4 The Purpose and Need for the Proposed Action

Although a licensee must have a renewed license to operate a reactor beyond the term of the

existing OL, the possession of that license is just one of a number of conditions that must be met

for the licensee to continue plant operation during the term of the renewed license. Once an OL

is renewed, State regulatory agencies and the owners of the plant will ultimately decide whether

the plant will continue to operate based on factors such as the need for power or other matters

within the State’s jurisdiction or the purview of the owners.

Thus, for license renewal reviews, the NRC has adopted the following definition of purpose and

need (GEIS Section 1.3):

The purpose and need for the proposed action (renewal of an operating license) is to

provide an option that allows for power generation capability beyond the term of a current

nuclear power plant operating license to meet future system generating needs, as such

needs may be determined by State, utility, and where authorized, Federal (other than NRC)

decision makers.

The purpose and need for the proposed action (renewal of an operating license) is to provide an

option that allows for power generation capability beyond the term of a current nuclear power

plant operating license to meet future system generating needs, as such needs may be

determined by State, utility, and where authorized, Federal (other than NRC) decision makers.

This definition of purpose and need reflects the Commission’s recognition that, unless there are

findings in the safety review required by the Atomic Energy Act of 1954, as amended or findings

in the NEPA environmental analysis that would lead the NRC to reject a license renewal

application, the NRC does not have a role in the energy-planning decisions of state regulators

and utility officials as to whether a particular nuclear power plant should continue to operate. 
Introduction

July 2007 1-9 NUREG-1437, Supplement 29

From the perspective of the licensee and the state regulatory authority, the purpose of renewing

an OL is to maintain the availability of the nuclear plant to meet system energy requirements

beyond the current term of the plant’s license.

1.5 Compliance and Consultations

Entergy is required to hold certain Federal, State, and local environmental permits, as well as

meet relevant Federal and State statutory requirements. In its ER, Entergy provided a list of the

authorizations from Federal, State, and local authorities for current operations as well as

environmental approvals and consultations associated with PNPS license renewal. 

Authorizations and consultations relevant to the proposed OL renewal action are included in

Appendix E. 

The staff has reviewed the list and consulted with the appropriate Federal, State, and local

agencies to identify any compliance or permit issues or significant environmental issues of

concern to the reviewing agencies. These agencies did not identify any new and significant

environmental issues. However, as of the publication of this SEIS, NRC is in consultation with |

the NMFS regarding threatened and endangered species, and NMFS concluded the EFH |

consultation. The ER states that Entergy is in compliance with applicable environmental |

standards and requirements for PNPS. The staff has not identified any environmental issues

that are both new and significant.

1.6 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.”

40 CFR Part 1508. Code of Federal Regulations, Title 40, Protection of Environment, Part 1508,

“Terminology and Index.”

Atomic Energy Act of 1954, as amended, 42 USC 2011, et seq.

Entergy Nuclear Operations, Inc. (Entergy). 2006a. License Renewal Application, Pilgrim

Nuclear Power Station, Docket No. 50-293, Facility Operating License Number DPR-35, |

Plymouth, Massachusetts.
Introduction

NUREG-1437, Supplement 29 1-10 July 2007

Entergy Nuclear Operations, Inc. (Entergy). 2006b. Applicant’s Environmental Report –

| Operating License Renewal Stage, Pilgrim Nuclear Power Station. Docket Number 50-293,

Plymouth, Massachusetts.

National Environmental Policy Act of 1969, as amended (NEPA) 42 USC 4321, et seq.

Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for

| License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, DC.

Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants Main Report, “Section 6.3 – Transportation, Table 9.1,

Summary of findings on NEPA issues for license renewal of nuclear power plants,” Final Report. 

| NUREG-1437, Volume 1, Addendum 1, Washington, DC.

Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental

Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1555,

| Supplement 1, Washington, DC.

Nuclear Regulatory Commission (NRC). 2006a. “Notice of Acceptance for Docketing of the

Application and Notice of Opportunity for a Hearing Regarding Renewal of Facility Operating

| License Number DPR-35 and for an Additional 20-Year Period.” Federal Register: Volume 71,

| Number 58, pgs. 15222-15223. March 27, 2006.

Nuclear Regulatory Commission (NRC). 2006b. “Notice of Intent to Prepare an Environmental

| Impact Statement and Conduct Scoping Process.” Federal Register: Volume 71, Number 72,

| pgs. 19554-19556. April 14, 2006.

Nuclear Regulatory Commission (NRC). 2006c. Environmental Impact Statement Scoping

Process: Summary Report – Pilgrim Nuclear Power Station, Plymouth, Massachusetts. 

| Washington, DC. September 26, 2006.




























Plant and the Environment

July 2007 2-29 NUREG-1437, Supplement 29

of ocean circulation, and wind-induced motion. Tidal fluctuations largely control this exchange.

The intertidal volume represents approximately 9.3 percent of the mean volume of the bay. The

total bay flushing rate is approximately 7.2 percent per day, which corresponds to a mean

residence time in Cape Cod Bay of 13.9 days (Stone and Webster 1975, in ENSR 2000).

Ocean currents in the vicinity of PNPS are generally toward the south and are part of the largescale, counterclockwise circulation pattern within Massachusetts Bay. In contrast, tidal currents

tend to rotate clockwise, completing one revolution per tide cycle (EG&G 1995, in ENSR 2000).

Tide heights in Massachusetts Bay are predominantly semidiurnal with a typical range of 9.1 ft. 

The maximum tidal range at spring phase is 10.6 ft. At PNPS, the estimated average yearly

maximum astronomical high tide is 11.7 ft MLW, and the estimated average yearly minimum

astronomical low tide is 2.3 ft MLW (Stone and Webster 1975, in ENSR 2000).

Water temperatures in Cape Cod Bay fluctuate seasonally and due to processes such as

upwelling, downwelling, and turbulence. Seasonal temperature variations are significantly

greater near the surface of the bay than on the bottom, although seasonal climatic changes

produce temperature stratification during the summer months. Generally, during the summer

and early fall, bay temperatures exhibit a two-layer structure in which a very strong temperature

gradient exists at the interface of the layers, with temperatures decreasing with increasing water

depth. More gradual temperature changes generally occur over the entire depth of the water

column within this two-layer structure (Stone and Webster 1975, in ENSR 2000).

Water temperature measurements have been collected by the Massachusetts Water Resource

Authority (MWRA) in Boston Harbor, Massachusetts Bay, and Cape Cod Bay from 1989

through 2004. Over the 15-year period, temperatures have remained fairly consistent, ranging

from approximately 2 degrees Celsius (EC) (35.6EF) (in mid-winter) to 22EC (71.6EF) (in |

mid-summer) in the near-surface water and approximately 3EC (37.4EF) (in mid-winter) to |

approximately 12EC (53.6EF) (in mid-summer) in the near-bottom water (Libby et al. 2006). |

Large fluctuations during the summer are typical, resulting from upwelling/downwelling

fluctuations as well as short-lived wind-mixing events (Libby et al. 2006).

Salinity becomes vertically uniform throughout the water column during late winter. As the

snow melts in the spring and surface water runoff increases, the fresh water enters the bay at

the surface, and because it is less dense than saltwater, the fresh water stays at the surface. |

As a result of the relative decrease in surface water salinity, a density gradient develops. At the

same time the additional solar warming increases the surface temperature and further

enhances the density gradient (Libby et al. 2006).

Dissolved oxygen (DO) concentrations in the water column of Cape Cod Bay are highest during

the winter and early spring when oxygen is well mixed throughout the water column. DO

measurements have been collected throughout the Massachusetts/Cape Cod Bay system since
Plant and the Environment 

 NUREG-1437, Supplement 29 2-30 July 2007

1992 by the MWRA (Libby et al. 2006). Monitoring results from this program indicate that the

DO varies significantly throughout the year, with values in 2004 ranging from approximately 

11 mg/L in March 2004 to a low of approximately 7.5 mg/L in Cape Cod Bay during early fall

(Libby et al. 2006). In general, the DO at the bottom is 1 to 2 mg/L less than at the surface

throughout the year (Galya et al. 1997 in ENSR 2000). This general cycle of mid-winter highs

and early-fall lows has been repeated during each of the monitoring years and suggests a fairly

regular pattern of steady decline through the period of increased algal production and a

subsequent increase during destratification and reduced algal production (Libby et al. 2006).

2.2.5.2 Chemical Contaminants near PNPS

At the site audit in May of 2006, the NRC staff was informed that analytical data for surface

| water and sediment have not been collected regularly by Entergy or its predecessor, Boston

Edison, at the PNPS facility. However, sediment has been collected and analyzed in support of 

| a dredging permit application. Such data were collected from the cooling water intake

embayment at PNPS on four occasions between October 1992 and July 1996. These 

analytical data are available in the report Maintenance Dredging of Pilgrim Nuclear Power

Station Intake Channel Report (BSC Group 1996). 

In 1992 and 1994, sediment samples were collected and analyzed for several physical and

chemical parameters. Eight inorganics (cadmium, chromium, copper, lead, mercury, nickel,

sodium, and zinc), the chloride ion, volatile organics, and total petroleum hydrocarbons were

detected at relatively low concentrations based on comparison to MDEP dredging material

classification guidelines. PAHs, pesticides, and PCBs were not detected in any sediment

sample. Samples were also analyzed for radionuclides, and results indicated that the

concentrations detected would not pose any significant risk. Results of this sampling indicated

that sediment dredged from the PNPS intake embayment would be suitable for disposal at the

Massachusetts Bay Disposal Site (MBDS) without bioassay or bioaccumulation testing of the

samples (BSC Group 1996).

Sediment samples from the PNPS site were collected in 1996 to determine the environmental

impacts of proposed dredge spoils on the marine benthic populations using toxicological and

bioaccumulation tests. For comparison, control sediment samples were collected from a

contaminant-free area of the Hampton Harbor, and reference sediment samples were collected

outside the MBDS. Toxicological studies indicated that the PNPS intake embayment sediment

| had no impact on the survival of the mysid shrimp Mysidopsis bahia, tidewater silverside

minnow (Menidia beryllina), the polychaete worm Nereis virens, or the bivalve clam Macoma

nasuta.
Plant and the Environment

July 2007 2-31 NUREG-1437, Supplement 29

These tests indicated that sediment from the intake embayment would have a significant impact |

on the survival of the amphipod Ampelisca abdita and the development of the larval stage of the |

blue mussel (Mytilus edulis). Bioaccumulation tests found no significant uptake of any of the |

parameters tested (cadmium, cobalt, cobalt-60, and mercury) in either Macoma nasuta or |

Nereis virens after exposure to the PNPS intake embayment sediment for 28 days (BSC Group |

1996).

A follow-up study on the January 1996 toxicological and bioaccumulation study was conducted

in July 1996 to assess potential acute impacts to the marine benthic populations exposed to

dredged sediment from the PNPS intake embayment. Toxicological studies indicated that the |

sediment had a significant effect on the survival of the amphipod in only one location after 10 |

days exposure and that the observed toxicity in the previous tests may have resulted from |

ammonia levels unrelated to PNPS operations (BSC Group 1996). |

Data are also available to evaluate overall contaminant distribution in Massachusetts Bay. As

part of a study conducted by Shea et al. (1991), sediment chemical contaminant data from a

total of 18 studies were compared. The studies included analytical results of metals, PAHs,

PCBs, pesticides, and radionuclides in Massachusetts Bay sediments. The study concluded

that Massachusetts Bay sediments were no more contaminated than those of other urban

estuarine and coastal regions on the east coast, and that based on comparison of the observed

data to the National Oceanic and Atmospheric Administration (NOAA) sediment toxicity effects |

levels, the sediments in Massachusetts Bay are healthy (Shea et al. 1991).

2.2.5.3 Biological Communities

The marine biological communities in the waters of Cape Cod Bay surrounding PNPS include |

fish, pelagic invertebrates, plankton, benthic invertebrates, marine aquatic plants, marine

mammals, and Federally listed marine species (including some marine mammals and sea

turtles). |

2.2.5.3.1 Fish

The species composition of the fish community found in western Cape Cod Bay reflects a

transition between the Gulf of Maine and the Mid-Atlantic Bight (Lawton et al. 1995 in 

ENSR 2000). Due to the warm water intrusion from the Cape Cod Canal into the cold waters

from the Gulf of Maine current, Cape Cod Bay maintains a seasonally diverse composition of

finfish. Cape Cod serves as the southern boundary for several northern Atlantic fish species

and the northern boundary for several fish species that inhabit the warmer waters south of

Cape Cod, resulting in a wide variety of fish species (ENSR 2000). PNPS is situated on an
Plant and the Environment 

 NUREG-1437, Supplement 29 2-32 July 2007

open part of the coast and the biota in the vicinity of the station is more typical of marine than of

estuarine environments (ENSR 2000).

Monitoring

Marine finfish populations in the vicinity of PNPS have been monitored since the initiation of

station operations to determine if the station has had any effect on local populations. These

studies have been conducted by independent researchers, State agencies, and consultants

under contract with PNPS or its parent companies (Boston Edison, Entergy). These studies

have been conducted in response to the NPDES permitting requirements, in response to

advisory committee concerns, or due to PNPS concerns only. The results of these studies are

published at least annually through the Marine Ecology Reports or are issued as special

reports.

A variety of methods has been employed to sample the fish populations that inhabit the waters

in the vicinity of the station. These methods have included:

| • Bottom trawls

• Gill nets

• Haul seines

• Diver surveys

• Recreational creel surveys

• Ichthyoplankton surveys

• Impingement and entrainment monitoring

Bottom trawling gear was used to sample demersal fish species inhabiting inshore waters, gill

nets were set to sample pelagic species, and haul seining was employed to sample other

inshore species. In addition, visual transects were surveyed by divers in complex habitat areas

that could not be surveyed with typical sampling equipment in order to assess habitat-seeking

fish species such as the tautog (Tautoga onitis) and cunner (Tautogolabrus adspersus).

Recreational creel surveys also were conducted to assess the sport fisheries adjacent to PNPS. 

In addition, ichthyoplankton studies were initiated in 1974 to determine the presence and extent

of early-life stages of local fish populations and assess possible detrimental effects from PNPS. 

Impingement and entrainment sampling has been conducted at least once weekly since the

initiation of station operations.

Important Fish Species 

| A discussion of the ecology, life history, status, and trends of the important fish species in the

area surrounding PNPS follows. These species include commercially or recreationally valuable
Plant and the Environment

July 2007 2-33 NUREG-1437, Supplement 29

species, species that are critical to the potentially affected ecosystem, and species for which

essential fish habitat (EFH) has been designated in the vicinity of PNPS. These species are:

• Alewife (Alosa pseudoharenqus)

• American plaice (Hippoglossoides platessoides) 

• Atlantic butterfish (Peprilus triacanthus)

• Atlantic cod (Gadus morhua)

• Atlantic halibut (Hippoglossus hippoglossus)

• Atlantic herring (Clupea harengus) 

• Atlantic mackerel (Scomber scombrus)

• Atlantic menhaden (Brevoortia tyrannus)

• Atlantic sand lance (Ammodytes americanus)

• Atlantic silverside (Menidia menidia)

• Atlantic tomcod (Microgadus tomcod)

• Black sea bass (Centropristus striata)

• Bluefin tuna (Thunnus thynnus)

• Bluefish (Pomatomus saltatrix)

• Cunner (Tautogolabrus adspersus)

• Fourbeard rockling (Enchelyopus cimbrius)

• Fourspot flounder (Paralichthyus oblongus)

• Haddock (Melanogrammus aeglefinus) 

• Little skate (Leurcoraja erinacea)

• Monkfish (Lophius americanus) 

• Ocean pout (Macrozoarces americanus)

• Offshore hake (Mercluccius albidius)

• Pollock (Pollachius virens)

• Rainbow smelt (Osmerus mordax)

• Redfish (Sebastes fasciatus)

• Red hake (Urophycis chuss)

• Rock gunnel (Pholis gunnellus)

• Scup (Stenotomus chrysops)

• Silver hake / whiting (Merluccius bilinearis) 

• Smooth skate (Malacoraja senta)

• Spiny dogfish (Squalus acanthias)

• Summer flounder (Paralicthys dentatus)

• Tautog (Tautoga onitis)

• Thorny skate (Amblyraja radiata)

• Tilefish (Lopholatilus chamaeleonticeps)

• White hake (Urophycis tenuis)

• Windowpane flounder (Scopthalmus aquosus) 

• Winter flounder (Pseudopleuronectes americanus)
Plant and the Environment 

 NUREG-1437, Supplement 29 2-34 July 2007

• Winter skate (Leurcoraja ocellata)

• Witch flounder (Glyptocephalus cynoglossus)

• Yellowtail flounder (Pleuronectes ferruginea)

An EFH assessment is provided in Appendix E to meet the consultation requirements according

| to the Magnuson-Stevens Fishery Conservation and Management Act. By letter dated January

| 23, 2007, NMFS concluded the EFH consultation with NRC regarding PNPS license renewal

| (see Appendix E).

An important component of the analysis in this SEIS is a determination of stock status. The

status of a stock relates to two primary factors: the rate of removal of fish from the population

(also known as the exploitation rate) and the current stock size or biomass. The exploitation

rate is the proportion of the stock that is caught and removed from the population. If that

proportion exceeds a sustainability threshold determined by fishery scientists, then overfishing

of that stock is occurring (NEFSC 2004). The current stock size is typically defined by either

| the spawning stock biomass (SSB) or the total stock biomass. If the stock's total biomass falls

below the biomass sustainability threshold for that species, then the stock is considered to be in

an overfished condition (NEFSC 2004). If a stock is considered to be in an overfished condition

| (i.e., a biomass level that is less than a biomass threshold level), then NMFS develops plans for

rebuilding and sustaining the stock (NEFSC 2004).

Pelagic Species

Alewife (Alosa pseudoharengus)

The alewife is an anadromous species common in New England (Mullen et al. 1986, 

in ENSR 2000), and in the area of PNPS. The species is historically one of the most

commercially important fish species in Massachusetts (Belding 1921, in ENSR 2000).

Spawning occurs in freshwater rivers and streams in the area of PNPS from the middle of April

to early June (Belding 1921, in ENSR 2000). Spawning occurs at water temperatures between

| 16 and 19 C (60.8EF and 66.2EF) (Kocik 1998, in ENSR 2000). The eggs adhere to the river o

bottoms until they harden and then become pelagic. The adults become sexually mature and

begin migrating to rivers and streams to spawn when they are four or five years old (Marcy

1969, in ENSR 2000). Alewives are important forage fish in the ocean, as well as in freshwater

during their migration and spawning activities (ENSR 2000). The species is planktivorous,

feeding mainly on diatoms, algae, and small crustaceans (ENSR 2000). The alewife is

common in Cape Cod Bay, and is one of the most commonly impinged species at PNPS

(ENSR 2000). Alewife larvae and juveniles have been collected in the PNPS entrainment

sampling. Juveniles and/or adults have been consistently collected in the PNPS impingement 
Plant and the Environment

July 2007 2-35 NUREG-1437, Supplement 29

sampling program. Over the last 25 years (1980 to 2005), alewives have had the third highest |

number of individuals impinged at PNPS, based on annual extrapolated totals (Normandeau |

2006b). |

Atlantic butterfish (Peprilus triacanthus)

The Atlantic butterfish is a small bony pelagic fish that forms loose schools, living near the

water surface (Schrieber 1973; Dery 1988b; Brodziak 1995, in Cross et al. 1999). The

butterfish has been commercially fished since the late 1800s (Murawski and Waring 1979, 

in Cross et al. 1999). All life stages, including eggs, larvae, juveniles, and adults are pelagic

(Cross et al. 1999). Adult butterfish become sexually mature at the age of one year 

(Overholtz 2000c). Spawning season varies depending on location and water temperature. In

the Gulf of Maine, spawning begins in May to June, peaks in July, and ends in August 

(Bigelow and Schroeder 1953, in Cross et al. 1999). Spawning occurs offshore, at

temperatures above 15 C (59EF) (Colton 1972, in Cross et al. 1999). Adult butterfish prey on |

o

small fish, squid, and crustaceans, and in turn are preyed upon by many species, including

silver hake (Merluccius bilinearis), bluefish (Pomatomus saltatrix), swordfish (Loligo pealei), and

longfin squid (Xiphias gladius) (ENSR 2000). The butterfish is short-lived, rarely living to more

than three years of age (ENSR 2000).

The butterfish is found throughout the eastern coast of the U.S. and Canada, from Florida to

Newfoundland. It is most commonly found from Cape Hatteras to the Gulf of Maine 

(Bigelow and Schroeder 1953, in ENSR 2000). In summer, the butterfish can be found over the

entire continental shelf from sheltered bays and estuaries, over substrates of sand, rock, or

mud, to a depth of 200 meters (m) (656 ft) (Cross et al. 1999). The butterfish migrates annually

in response to seasonal changes in water temperature. During the summer, they migrate

inshore into southern New England and Gulf of Maine waters, and in winter they migrate to the

edge of the continental shelf in the Mid-Atlantic Bight (Cross et al. 1999). 

The butterfish is managed as a single stock unit (Brodziak 1995, in Cross et al. 1999). The

species is managed under the Mid-Atlantic Fishery Management Council's (MAFMC) Atlantic

Mackerel, Squid, and Butterfish Plan (Overholtz 2000c). An assessment in 2004 determined

that overfishing was not occurring (NMFS 2004a). However, fishing mortality was near the

overfishing definition, with the discards estimated at twice the amount of landings. Because of |

this, the stock assessment report recommended that measures be implemented to reduce

mortality due to discards (NMFS 2004a). Eggs and larvae of the Atlantic butterfish have been

collected in the PNPS entrainment sampling. Juveniles and/or adults have been observed in |

the PNPS impingement sampling program. 
Plant and the Environment 

 NUREG-1437, Supplement 29 2-36 July 2007

Atlantic herring (Clupea harengus)

The Atlantic herring is a coastal pelagic, schooling species found on both sides of the Atlantic

Ocean (Stevenson and Scott 2005). Atlantic herring have been an important commercial

species in New England for 400 years (Anthony and Waring 1980, in ENSR 2000). In recent

years, large-scale fisheries for adult herring have developed in the western Gulf of Maine, on

Georges Bank, and on the Scotian Shelf (ENSR 2000). 

The Atlantic herring lays eggs on the bottom, in gravel, rock, or shell substrates. The eggs

adhere to the bottom in layers and form beds (Bigelow and Schroeder 1953; Mansueti and

Hardy 1967, in ENSR 2000). As juveniles, Atlantic herring form large aggregations in coastal

areas. Herring in the Gulf of Maine reach sexual maturity at an age of about three years

(Stevenson and Scott 2005). Spawning occurs in high energy environments with strong tidal

action (Iles and Sinclair 1982, in Stevenson and Scott 2005). Spawning occurs in water below

| 15 C, at water depths between 20 and 80 m (66 to 262 ft) (NEFMC 1998a, in ENSR 2000). In o

the Gulf of Maine and Georges Bank, spawning occurs from July to December (Stevenson and

Scott 2005). Both the larvae and juveniles feed on zooplankton, including copepods 

(ENSR 2000). The Atlantic herring of all life stages are preyed upon by other fishes, including

cod (Gadus morhua), pollock (Pollachius virens), haddock (Melanogrammus aeglefinus), silver

hake, mackerel (Scomber scombrus), dogfish (Squalus acanthias), and squid

(Hildenbrand 1963; Bigelow and Schroeder 1953, in ENSR 2000), as well as marine mammals

and birds. Adult Atlantic herring feed on zooplankton, and capture prey by direct, predatory 

snapping action (Blaxter and Holliday 1963, in ENSR 2000). Atlantic herring become sexually

mature between the ages of three and four years (Reid et al. 1999b).

In the western Atlantic, herring inhabit the continental shelf from Labrador to Cape Hatteras. In

the U.S., herring are managed as a single stock, and a separate stock located further north is

managed by Canada (Stevenson and Scott 2005). There is an annual migration of adult

Atlantic herring from summer feeding areas along the Maine coast to southern New England

(Stevenson and Scott 2005). The adults live in water at depths of 20 to 130 m (66 to 427 ft),

| and at temperatures less than 10 C (50EF) (NEFMC 1998a, in ENSR 2000). Trawl surveys in o

Massachusetts identified large catches of adult herring in Cape Cod Bay in the fall 

(Stevenson and Scott 2005).

Although the herring is managed as a single stock unit in the U.S., there may actually be

separate Georges Bank and Gulf of Maine stocks (Stevenson and Scott 2005). The fishery is

managed under an interstate fishery management plan (FMP) adopted by the Atlantic States

Marine Fisheries Commission (ASMFC) in coordination with the New England Fishery

Management Council (NEFMC) (Overholtz 2000a). Trawl survey data collected in 2003

determined that the herring biomass was stable and increasing over time (NEFMC 2004).
Plant and the Environment

July 2007 2-37 NUREG-1437, Supplement 29

While the stock as a whole is considered to be under-utilized, the population within the Gulf of

Maine is heavily exploited and being over-harvested (Stevenson and Scott 2005), but the |

overall stock was considered to be at sustainable levels at the time of 2006 ASMFC report (i.e., |

the SSB and/or total stock biomass are considered to be at levels greater than sustainable

biomass thresholds, while the exploitation or fishing pressure is less than the threshold of

sustainable fishing pressure) (ASMFC 2006). Atlantic herring eggs, larvae, and juveniles have

been collected in the PNPS entrainment sampling. Juveniles and/or adults have been

consistently collected in the PNPS impingement sampling program. Over the last 25 years they

have been one of the numerically dominant impinged species. 

Atlantic mackerel (Scomber scombrus)

The Atlantic mackerel is a pelagic, schooling species found in the northwest Atlantic between

Labrador and North Carolina (Overholtz 2000b). Both the eggs and larvae of the species are

pelagic, and transition from drifting to free swimming when they reach a size of 30 to 50

millimeters (mm) (1 to 2 in.) (Sette 1943, in Studholme et al. 1999). The Atlantic mackerel 

becomes sexually mature by the age of three years (O'Brien et al. 1993, in Studholme et al. |

1999). Spawning occurs at two distinct times of the year; a southern population spawns in April

and May, and a northern population spawns in June and July (ENSR 2000). Spawning takes |

place in the upper portion of the water column, in shoreward areas, at temperatures above 10 C

o

(50EF) (ENSR 2000). Cape Cod Bay is reported to be an important spawning area in the |

months from May to August (Studholme et al. 1999). The adult mackerel can feed both by filter

feeding and by preying on individuals. The prey consists of plankton such as amphipods,

euphausiids, shrimp, crab larvae, small squid, and fish eggs (Scott and Scott 1988, in ENSR

2000).

Mackerel are found in both cold and temperate continental shelf areas, and form large schools

near the surface (Collette and Nauen 1983, in ENSR 2000). The mackerel perform annual

migrations, with movement generally northeast and inshore in the spring, and offshore to

deeper water in the winter (ENSR 2000). Migration is closely related to seasonal temperature

changes, as the mackerel prefers to live in waters with temperatures of 6 to 15 C (42.8 to 59EF) |

o

(Overholtz and Anderson 1976, in Studholme et al. 1999). Both juveniles and adults have |

been caught in trawl surveys in Cape Cod Bay. Juveniles were primarily found in the fall, while

adults were identified in the spring (Studholme et al. 1999). 

There are two separate spawning populations in the northwestern Atlantic, but all mackerel are

considered to be a single stock and are managed as a single stock (Sette 1943; 

Anderson 1982; MAFMC 1994, in Studholme et al. 1999). The mackerel stock reached low

biomass levels in the 1970s due to heavy exploitation by distant water fleets (NMFS 2006a).

Since 1983, the species has been managed under the MAFMC Atlantic Mackerel, Squid, and
Plant and the Environment 

 NUREG-1437, Supplement 29 2-38 July 2007

Butterfish Plan (Overholtz 2000b), and biomass levels had improved as of the mid 1990s

(Anderson 1995, in Studholme et al. 1999). The current ASMFC report states the stock is

considered to be at sustainable levels (i.e., the SSB and/or total stock biomass are considered

to be at levels greater than sustainable biomass thresholds, while the exploitation or fishing

pressure is less than the threshold of sustainable fishing pressure) (NMFS 2006a). Eggs and

larvae of the Atlantic mackerel have been consistently collected in the PNPS entrainment

sampling and are one of the numerically dominant species in the entrainment collections.

Juveniles and/or adults have also been observed in the PNPS impingement sampling program. 

Atlantic menhaden (Brevoortia tyrannus)

The Atlantic menhaden is a migratory fish species found in coastal and estuarine waters from

Nova Scotia to Florida. Menhaden is a schooling fish species and serves as an important

| forage fish to larger predators (Rogers and Van den Avyle 1989). The menhaden is one of the

most commercially important fish species along the Atlantic Coast, and is used for fish meal,

fish oil, and bait for other species (VIMS 2006). The species becomes sexually mature at the

| age of three years, and spawns from March to May and September to October (VIMS 2006).

The larvae live in brackish or freshwater areas, and when they become juveniles, they migrate

south in schools (VIMS 2006). The status of the population is healthy, with stable stock size

and high biomass (VIMS 2006). The current ASMFC report indicates the Atlantic menhaden

population is considered to not be in an overfished condition, and overfishing is not occurring 

(ASMFC 2006). 

Atlantic menhaden eggs, larvae, and juveniles have been consistently collected in the PNPS

entrainment sampling and are one of the numerically dominant species in the entrainment

| collections. Juveniles and/or adults have been consistently collected in the PNPS impingement

sampling program. Over the last 25 years they have had the second highest impingement rate.

Atlantic silverside (Menidia menidia)

The Atlantic silverside is found through the western Atlantic Ocean, and generally associates in

large schools. The habitat includes shallow water with sand or gravel substrate. The species

typically preys on small crustaceans, including copepods, shrimp, amphipods, and cladocerans

(ENSR 2000). Silversides are an important forage fish in the diet of several other fish species,

including bluefish, striped bass, cunner, and Atlantic cod (Bayliff 1950, in ENSR 2000).

Spawning occurs in the late spring and early summer, mostly in shallow water where eggs and

milt are deposited in strands that cling to vegetation (ENSR 2000). The silverside only live for

about one year (ENSR 2000). The Atlantic silverside is the most commonly impinged fish at

PNPS, and had the highest catch rate in Massachusetts Division of Marine Fisheries (MDMF)

beach haul seines conducted in western Cape Cod Bay (ENSR 2000, Kelly et al. 1992). 
Plant and the Environment

July 2007 2-39 NUREG-1437, Supplement 29

Atlantic silverside eggs, larvae, and juveniles have been collected in the PNPS entrainment

sampling. Juveniles and/or adults have been consistently collected in the PNPS impingement |

sampling program. Over the last 25 years they have had the highest impingement rate. |

Black sea bass (Centropristis striata)

The black sea bass is a temperate species found in structured habitats of the continental shelf,

such as reefs and shipwrecks (Steimle et al. 1999d). Eggs and larvae of the black sea bass

are pelagic and are found in spawning areas on the continental shelf (Steimle et al. 1999d). As

juveniles, the species moves inshore, where they form nurseries in estuaries 

(Able and Fahay 1998, in Steimle et al. 1999d). Juveniles mature as females, and then change

to males as they grow larger (Lavenda 1949, in Steimle et al. 1999d). Juveniles begin to

mature at one year of age, with most of the adults of this age being females (Mercer 1978, 

in Steimle et al. 1999d). Spawning occurs on the inner continental shelf, in water depths of 20

to 50 m (66 to 164 ft), between the Chesapeake Bay and Long Island (Steimle et al. 1999d).

Larvae have been reported in Cape Cod Bay, but these are interpreted to have been spawned

in Buzzards Bay and moved through the Cape Cod Canal (MAFMC 1996b, in

Steimle et al. 1999d). Spawning in Massachusetts coastal waters occurs on sandy bottoms

broken by rocky ledges (Kolek 1990; MAFMC 1996b, in Steimle et al. 1999d). Larval black sea

bass probably prey on zooplankton (Steimle et al. 1999d). The juveniles are visual predators 

that feed on benthic crustaceans and small fish (Richards 1963; Allen et al. 1978; Werme 1981,

in Steimle et al. 1999d). 

The black sea bass in the western Atlantic occurs from southern Nova Scotia and Bay of Fundy

south to Florida, and into the Gulf of Mexico (Steimle et al. 1999d). The population in the U.S.

is managed as three separate stocks, including the Gulf of Mexico, the southern stock (south of

Cape Hatteras), and the northern stock (north of Cape Hatteras) (Steimle et al. 1999d). The

species is primarily a warm water fish, and begins to migrate offshore to depths of 30 to 240 m

(98 to 787 ft) as bottom water temperatures reach 7 C (44.6EF) (Steimle et al. 1999d). The |

o

species lives in benthic areas where structures such as reefs provide shelter (Steimle et al.

1999d). Trawl surveys in Massachusetts in the spring found abundant juvenile populations

south and west of Cape Cod, with a few juveniles collected in Cape Cod Bay (Steimle et al.

1999b).

The fishery for the black sea bass is managed under the MAFMC Summer Flounder, Scup, and

Black Sea Bass FMP (Shepherd 2000a). As of 1997, the black sea bass population was

considered to be over-exploited (NMFS 1997, in Steimle et al. 1999d). However, the 2004

Stock Assessment Summary (NMFS 2004b) concluded that the species is not overfished and

that overfishing was not occurring. This was attributed to the fact that commercial landings

were limited by quotas, while recreational landings were similar to long-term averages 
Plant and the Environment 

 NUREG-1437, Supplement 29 2-40 July 2007

| (NMFS 2004b). In 2006, the NMFS determined that the overfishing status could not be

determined (NMFS 2006b). The 2006 ASMFC report, indicates the black sea bass population

| is considered to be overfished, while the overfishing status is not known (ASMFC 2006). Black

sea bass larvae have been collected in the PNPS entrainment sampling. Juveniles and/or

| adults have been observed in the PNPS impingement sampling program. 

Bluefin tuna (Thunnus thynnus)

The bluefin tuna is found in two separate populations in the eastern and western Atlantic Ocean

(Buck 1995). The species is among the largest bony fish in the Atlantic Ocean and can reach

sizes of up to 1200 pounds (ENSR 2000). Bluefin tuna in the western Atlantic become sexually

mature at the age of about eight years (NMFS 2005c). The prey of the bluefin tuna includes

mackerel, herring, whiting (Merluccius bilinearis), and squid (Buck 1995).

The range of the bluefin tuna in the western Atlantic Ocean is from Newfoundland to Brazil

(Buck 1995). The western Atlantic population is managed as a single stock unit (Buck 1995).

Bluefin tuna primarily live in the upper 100 to 200 m (328 to 656 ft) of the water column in the

open ocean (NMFS 1999). The bluefin tuna migrates extensively. Following spawning in the

Gulf of Mexico area in spring and early summer, the species migrates north along the U.S.

coast to waters off of Canada (Buck 1995). 

The latest stock assessment for the bluefin tuna was conducted in 2001. This assessment

determined that the SSB had declined about 80 percent between 1970 and the late 1980s, and

had then leveled off (NMFS 2005c). In 2001, the stock of the bluefin tuna was determined to be

overfished, and overfishing was continuing (NMFS 2001d). No life stages of the bluefin tuna

have ever been observed in the PNPS entrainment or impingement sampling.

Bluefish (Pomatomus saltatrix)

Bluefish is a migratory, pelagic species found in temperate coastal zones throughout the world

(Shepherd 2000b). Bluefish are very common along the east coast of the U.S., and are very

popular among recreational fishermen, with recreational landings regularly exceeding

commercial catches (NMFS 2005b). Bluefish reach sexual maturity at the age of two years

(Deuel 1964, in Shepherd and Packer 2006, ENSR 2000). Spawning occurs in the area from

New York south to Florida (Shepherd and Packer 2006). Spawning was previously thought to

occur at two distinct times of year, with one population spawning in the spring and one in the

summer (ENSR 2000). However, recent studies suggest that there is a single spawning

season from spring to summer, but that there is high mortality among the young in the middle of

the event, making it appear as two separate events in population studies 

(Shepherd and Packer 2006). Bluefish eggs and larvae are buoyant and live within surface
Plant and the Environment

July 2007 2-41 NUREG-1437, Supplement 29

waters, only within open oceanic waters (Able and Fahay 1998, in Shepherd and Packer 2006).

The larvae feed on surface plankton until they reach juvenile stage, and then migrate to coastal

nursery areas to feed on other fish species (Kendall and Walford 1979, in ENSR 2000; |

Shepherd and Packer 2006). Adult bluefish are voracious predators, and prey on squid,

shrimp, crabs, alewives, menhaden, silver hake, butterfish and smaller bluefish (ENSR 2000).

Within the western Atlantic, bluefish are found from Maine to Florida, migrating northward in the

spring and southward in the fall (ENSR 2000). Adults live in a variety of locations, including the

open ocean, bays, and estuaries. In Massachusetts coastal areas, adults are found in water

depths of between 6 and 25 m (20 to 82 ft), and temperatures from 10 to 20 C (50 to 68EF) |

o

(Shepherd and Packer 2006). Bluefish migrate in response to temperature changes in order to

remain in water with temperatures above 14 to 16 C (57.2 to 60.8 EF) (Bigelow and Schroeder |

o

1953, in Shepherd and Packer 2006). They live in southern New England waters in spring and

summer, and migrate to waters off of the southeastern U.S. in autumn (Shepherd and Packer

2006).

Bluefish are managed as a single stock unit (Fahay et al. 1999b; Shepherd and Packer 2006). 

The population of bluefish has varied widely through time, but appears to have declined

significantly since the early 1980s (Fahay et al. 1999b). The Bluefish FMP was implemented in

2000 by the MAFMC and the ASMFC (Shepherd 2000b; NMFS 2005b). However, as of the |

2006 stock assessment, the stock was considered to be at sustainable levels (i.e., the SSB |

and/or total stock biomass are considered to be at levels greater than sustainable biomass

thresholds, while the exploitation or fishing pressure is less than the threshold of sustainable

fishing pressure) (NMFS 2005b; ASMFC 2006). Bluefish juveniles and adults are reported to

have been observed in the vicinity of PNPS (ENSR 2000). No life stages of the bluefish have 

ever been observed in the PNPS entrainment sampling. Juveniles and/or adults have been

observed in the PNPS impingement sampling program.

Pollock (Pollachius virens)

The pollock is a bentho-pelagic fish found on both sides of the Atlantic Ocean (Mayo 2004).

Pollock live throughout the water column (McGlade 1984, in ENSR 2000). Pollock are

commercially important, but were primarily taken only as bycatch until the 1980s, at which time

commercial fishing of the species began (Mayo 1998b, in ENSR 2000). Pollock eggs and

larvae are pelagic until the larvae reach an age of about three to four months. At that time, the

small juveniles migrate inshore and inhabit rocky subtidal and intertidal zones. At the end of

their second year, the juveniles move offshore, where they remain through their adult life

(Cargnelli et al. 1999e). Adults reach sexual maturity between the ages of three and six years

(Mayo 1998b, in ENSR 2000), but the age and size at maturity has been decreasing, possibly

due to size-selective overfishing (Cargnelli et al. 1999e). 
Plant and the Environment 

 NUREG-1437, Supplement 29 2-42 July 2007

The western Gulf of Maine, including Massachusetts Bay, is one of the principle spawning sites

for pollock (Cargnelli, et al. 1999e). Spawning in the Gulf of Maine occurs from November to

| February (Steele 1963; Colton and Marak 1969, in Cargnelli, et al. 1999e), at water

| temperatures from 4.5 to 6 C (40.1 to 42.8EF) (Cargnelli et al. 1999e). Eggs are spawned on o

hard substrates in water depths between 10 and 365 m (33 to 1198 ft) (NEFMC 1998a, in

ENSR 2000). Larvae living in near-surface waters feed on larval copepods, while juvenile

pollock feed on crustaceans and fish, including young Atlantic herring (Steele 1963; Cargnelli et

al. 1999e; Ojeda and Dearborn 1991). The primary food for adults is krill and Atlantic herring

(Cargnelli et al. 1999e). 

The most common locations for pollock in the northwestern Atlantic include the Scotian Shelf

and the Gulf of Maine (Mayo 2004). Pollock migrate between these locations considerably,

| resulting in the three areas being managed as a single stock unit (Cargnelli et al. 1999e).

Adults live in a wide range of temperatures and depths, but are most frequently found in water

| depths from 100 to 125 m (328 to 410 ft), and temperatures of 0 to 14 C (32 to 57.2EF) (Hardy o

1978). There is no obvious preference for bottom type (Scott 1982a in Cargnelli et al. 1999e).

Pollock is a schooling species, but does not have substantial migration, except for small

movements related to temperature change (Hardy 1978).

The U.S. portion of the pollock fishery is managed under the NEFMC Northeast Multispecies

FMP (Mayo 2004). Commercial landings and stock size of pollock in the Gulf of Maine and

Georges Bank decreased substantially through the late 1980s, and reached historic lows in

1996 (Cargnelli et al 1999e). However, an assessment conducted in 2004 concluded that the

stock is considered to be at sustainable levels (i.e., the SSB and/or total stock biomass are

considered to be at levels greater than sustainable biomass thresholds, while the exploitation or

| fishing pressure is less than the threshold of sustainable fishing pressure) (Mayo et al. 2005b).

Eggs and larvae of the pollock have been collected in the PNPS entrainment sampling. 

Juveniles and/or adults have also been observed in the PNPS impingement sampling program. 

Rainbow smelt (Osmerus mordax)

The rainbow smelt is an anadromous fish, rarely found more than 1 mi from shore or deeper

than 6 m (20 ft). Smelt are cold water fish (ENSR 2000). Information on the smelt’s

| temperature preference is limited, but available data indicate they prefer water temperatures

| cooler than 15EC (59EF) in the freshwater habitat of Lake Michigan (ENSR 2000). In addition to

marine populations found from Labrador to Virginia, there are landlocked populations in New

England lakes, the Maritime Provinces, and the Great Lakes. The center of abundance for

marine populations is the southern Maritime Provinces of Canada and Maine, and the southern

limit of large populations is Massachusetts (Lee et al. 1980; Clayton et al. 1978, in ENSR 2000).

The rainbow smelt is a schooling fish and serves a vital role in the ecological food web as a
Plant and the Environment

July 2007 2-43 NUREG-1437, Supplement 29

forage fish preyed upon by both marine and freshwater predators (Buckley 1989, in

ENSR 2000). Although adult smelt are found in deeper waters outside of estuaries during the

summer, the species gathers in harbors and brackish estuaries in the fall. 

The principal spawning ground of smelt in the Plymouth area is the Jones River (Lawton et al. |

1990). Jones River, located several miles north of PNPS, has its headwaters in Pembroke, |

Kingston, and Plympton before it empties into Plymouth Harbor (Lawton et al. 1990). Spawning |

of the demersal, adhesive eggs begins when water temperatures increase to around 4.4EC |

(40EF), usually in March. Peak egg production occurs at water temperatures of 10 to 13.9EC |

(50 to 57EF), and spawning is completed by May (Buckley 1989, in ENSR 2000). Lawton et al.

(1990) also observed in the Jones River population that spawning was concluded in early May |

and that the smelt emigrated from the spawning ground when water temperature reached 16EC

(60.8EF). A qualitative comparison of data collected in 2004 by the MDMF indicated that the

smelt population, when compared to population data from previous seasons, had a relatively |

poor run in the four rivers sampled, including the Jones River (Chase 2006a). Sexual maturity

typically occurs during the second winter (McKenzie 1964, in ENSR 2000). In the Jones River |

population, two-year-old fish made up approximately 88 percent of the spawning run (Lawton et

al. 1990). |

Sea-run smelt populations declined throughout the western North Atlantic during the 1990s |

(Lawton and Boardman 1999). In the late 1980s and early 1990s a decline of rainbow smelt

was observed in the spawning runs of the Jones River. The depressed spawning numbers

made the rainbow smelt a species of special concern to MDMF (Lawton et al. 1990). In 2004,

the NMFS designated the rainbow smelt as a species of concern due to habitat degradation,

structural impediments to spawning habitat, and recreational and commercial fishing pressures

(NOAA Fisheries 2004). NOAA Fisheries (2004) reports that there has been a region-wide

decline in smelt populations over the last two decades. According to the MDMF, populations

are still at depressed levels (Chase 2006b). Eggs and larvae of the rainbow smelt have been

collected in the PNPS entrainment sampling. Juveniles and/or adults have been consistently

collected in the PNPS impingement sampling program. Over the last 25 years they have had

the fourth highest impingement rate.

Redfish (Sebastes spp.)

Redfish is a common name used to describe several species of fish such as the Acadian

redfish (Sebastes fasciatus) and the golden redfish (S. norvegicus). Redfish have been

commercially fished in the U.S. since the 1930s (Pikanowski et al 1999). The two species are

difficult to distinguish, and are managed as a single fishery (Templeman 1959; Mayo 1980, in

Pikanowski et al. 1999). Eggs are fertilized internally, and the females give birth to larvae

(Pikanowski et al. 1999). The new larvae live in the upper 10 m (33 ft) of the water column, and
Plant and the Environment 

 NUREG-1437, Supplement 29 2-44 July 2007

then live within the thermocline [10 to 30 m (33 to 98 ft)] when they become larger 

(Kelly and Barker 1961a, in Pikanowski et al. 1999). Juveniles are also pelagic until the fall of

their first year, at which time they migrate to the bottom (Kelly and Barker 1961b, in 

Pikanowski et al 1999). Adults become sexually mature at an age of about five to six years

(Mayo 2000). The demersal adults typically live within 3 to 7 m (10 to 23 ft) from the bottom

(Atkinson 1989, in Pikanowski et al 1999). Very little is known about redfish spawning. 

Fertilization probably occurs in February to April (Ni and Templeman 1985, in Pikanowski et al

1999), and larvae are released throughout the range where the adults are found, in spring and

summer (Steele 1957; Kelly and Wolf 1959; Kelly et al 1972; Kenchington 1984, in 

Pikanowski et al 1999). The larvae feed on copepods, euphausiids, and fish and invertebrate

eggs (Marak 1973, in Pikanowski et al 1999). Juvenile and adult redfish prey on euphausiids,

mysids, and bathypelagic fish (Pikanowski et al 1999). 

| Acadian redfish range from New Jersey to Iceland in the western Atlantic (Pikanowski et al.

1999). Acadian redfish can be found within shallow waters in the Gulf of Maine, but redfish are

most common at depths of 128 to 366 m (420 to 1200 ft), and have been found as deep as

592 m (1950 ft) (Kelly and Barker 1961a, in Pikanowski et al. 1999). The redfish does not

migrate latitudinally (Murawski 1973, in Pikanowski et al. 1999). The preferred temperature

range is from 3 to 7 C (37.4 to 44.6EF) (Kelly et al. 1972, in Pikanowski et al. 1999). Redfish o

| are found in areas of silt, mud, or sandy bottom substrates (Pikanowski et al. 1999). Larvae

were identified in the Gulf of Maine from April to September, while juveniles and adults were

found in the Gulf of Maine in all seasons (Pikanowski et al. 1999). Substantial numbers were

reported to have been observed in Massachusetts Bay (NMFS 2001b).

The U.S. fishery for redfish is managed under the NEFMC Northeast Multispecies FMP 

(Mayo 2000). Redfish were not classified as overfished or approaching an overfished condition

in 1997 (NMFS 1997, in Pikanowski 1999). In 2001, a stock assessment concluded that the

stock was overfished at that time, but that overfishing was not occurring (NMFS 2001b). The

most recent assessment, in 2004, concluded that the stock is considered to be at sustainable

levels (i.e., the SSB and/or total stock biomass are considered to be at levels greater than

sustainable biomass thresholds, while the exploitation or fishing pressure is less than the

threshold of sustainable fishing pressure) (Mayo et al. 2005c). Larvae of one of the redfish

species (Sebastes norvegicus) have been collected in the PNPS entrainment sampling. No life

stages have been observed in the PNPS impingement sampling program.

Spiny dogfish (Squalus acanthias)

The spiny dogfish is the most abundant shark in the western North Atlantic (McMillan and

Morse 1999). The spiny dogfish bears live young in litters numbering from 2 to 15 pups (NOAA

1998, in ENSR 2000). The adult spiny dogfish is a voracious and opportunistic predator, and is
Plant and the Environment

July 2007 2-45 NUREG-1437, Supplement 29

reported to prey on a variety of fish, mollusks, and crustaceans. The species travels in large

packs, and attacks schools of fish, including cod, haddock, capelin (Osmerus villosus),

mackerel, herring, and sand lance (Ammodytes americanus) (McMillan and Morse 1999).

Spiny dogfish are known to live up to 35 to 40 years of age (Nammack et al. 1985, in McMillan

and Morse 1999).

The range of spiny dogfish in the western North Atlantic is from Labrador to Florida. In the

spring and autumn, the species is common in coastal waters, including estuaries and closed

bays, between North Carolina and southern New England (Rago et al. 1994, in McMillan and

Morse 1999). Spiny dogfish migrate annually, in schools, from winter habitat on the edge of the

continental shelf to summer grounds in the Gulf of Maine and Georges Bank. Trawl surveys |

conducted in Massachusetts identified an abundance of adult spiny dogfish within Cape Cod

Bay in the spring. Both juveniles and adults were abundant within Cape Cod Bay in the fall

(McMillan and Morse 1999).

The spiny dogfish is the target of a commercial fishery within U.S. waters, with a large increase |

in activity beginning in 1996 (McMillan and Morse 1999). The population in U.S. waters is

managed as a single unit (McMillan and Morse 1999) and is managed under a FMP developed

by MAFMC and NEFMC (Sosebee 2000b). The stock was classified as overfished in 1998, due

to an increase in commercial landings by a factor of six from 1991 to 1998 (MAFMC 1998, in

McMillan and Morse 1999). It was also classified as overfished in 2003, although overfishing

was not occurring (NMFS 2003b). The stock assessment summary for 2006 concluded that the |

species is not overfished, and that overfishing is not occurring (NMFS 2006b). However, most |

recently, the 2006 ASMFC Stock Status Overview (ASMFC 2006) indicated that the stock is |

overfished, although overfishing is not occurring. Juveniles and/or adult spiny dogfish have

been observed in the PNPS impingement sampling program. They have not been detected in

the PNPS entrainment sampling program.

Demersal Species

American plaice (Hippoglossoides platessoides)

The American plaice is a benthic, right-eyed flounder that exists in deeper waters of the

continental shelf on both sides of the North Atlantic (Cooper and Chapleau 1998, in ENSR

2000). The American plaice is the most abundant flatfish species in the western North Atlantic,

and became important as a commercial species in the Gulf of Maine after 1975 

(Johnson 2004). Both the eggs and larvae of the American plaice are pelagic, and are found in

shallow surface waters, including in southern New England and Cape Cod Bay (ENSR 2000).

Adults are primarily benthic, but are known to migrate off of the bottom at night to prey on

non-benthic species (DFO 1989, in Johnson 2004). The American plaice reaches sexual
Plant and the Environment 

 NUREG-1437, Supplement 29 2-46 July 2007

| maturity at an age of two to four years (O'Brien 2000, in Johnson 2004). Spawning occurs

| between the months of March and May, in water temperatures between 3 to 6 C (37.4 to

o

| 42.8EF) (Johnson 2004). The Gulf of Maine and Georges Bank are considered to be areas of

maximum spawning for the species (Johnson 2004). Larvae prey on plankton, diatoms, and

copepods found in surface water layers. As larvae turn into juveniles, they feed on small

crustaceans, polycheates, and cumaceans (Bigelow and Schroeder 1953, in Johnson 2004).

Benthic crustaceans, mollusks, and small forage fish species make up the diet of the adults.

The range of the American plaice in the western North Atlantic includes the area from southern

Labrador to Rhode Island. The species inhabits mostly deep waters, in depths ranging from 90

to 250 m (295 to 820 ft) (O'Brien 1998, in ENSR 2000), and they do not normally occur in water

shallower than 25 to 35 m (82 to 115 ft) (O'Brien 2000, in Johnson 2004). Both juveniles and

adults live and spawn on a variety of substrates, including fine sand, sand, and gravel, in water

| temperatures below 17 C (62.6EF) (NEFMC 1998a, in ENSR 2000). The American plaice does

o

not migrate substantially. Results from tagging studies have found that most recaptured

individuals were found within 30 mi from the tagging site, even as long as seven years later 

(DFO 1989, in Johnson 2004).

The American plaice is managed as a single stock unit (Johnson et al. 1999b). The American

plaice fishery is managed under the NEFMC Northeast Multispecies FMP (O'Brien 2000).

American plaice populations in the western Atlantic have declined dramatically since the early

1980s (Johnson 2004). The reasons for this are unknown, but may be attributed to

| temperature changes (Morgan 1992, in Johnson 2004), pollution (Nagler and Cyr 1997, in

Johnson 2004), or overfishing (Nagler et al. 1999, in Johnson 2004). Northeast stock

assessment reports through 2001 determined that the species is overfished, and that

| overfishing is occurring in the Gulf of Maine/Georges Bank stock (O'Brien et al. 2002, in

Johnson 2004; NMFS 2001a). However, an updated assessment in 2005 concluded that the

species was overfished, but overfishing was no longer occurring (O'Brien et al. 2005). In 2005,

an analysis of juvenile populations resulted in a proposal for the potential designation of Habitat

Area of Particular Concern (HAPC) for the American plaice, including areas within Cape Cod

Bay, adjacent to PNPS (Crawford et al. 2005). Eggs and larvae of the American plaice have

been collected in the PNPS entrainment sampling. Juveniles and/or adults have also been

observed in the PNPS impingement sampling program. 

Atlantic cod (Gadus morhua)

The Atlantic cod is a demersal fish found on both sides of the Atlantic Ocean 

(Mayo and O'Brien 2000, in Fahay et al. 1999a). As the cod become juveniles and adults, they

are able to withstand deeper, colder, and more saline water, and become more widely

distributed (Fahay et al. 1999a). Some studies have shown that juveniles tend to prefer shallow
Plant and the Environment

July 2007 2-47 NUREG-1437, Supplement 29

areas with cobble substrates, in order to avoid predation (Gotceitas and Brown 1993, in 

Fahay et al. 1999a). The average age and size of cod at maturity has changed through time,

with adults reaching maturity at smaller size and younger age. In 1959, median age at maturity

was reported to be 5.4 years (males) and 6.2 years (females), and by 1994 the ages were

reported to be between 1.7 years (males) and 2.3 years (females) (Lough 2004). This trend is

attributed to harvesting of the adult cod (Fahay et al. 1999a). Peak spawning within

Massachusetts Bay occurs in January and February (Lough 2004). Juveniles and younger

adults tend to consume pelagic and benthic invertebrates, while adult cod also feed on both

crustaceans and other fish, including sand lance, cancer crabs (Cancer spp.), and herring

(Lough 2004). Eggs and larvae are subject to being preyed upon by planktivorous fish,

including Atlantic herring and Atlantic mackerel, and juveniles can be preyed upon by

piscivorous fish such as dogfish, silver hake, sculpin, and larger cod

(Edwards and Bowman 1979, in Fahay et al. 1999a). 

The Atlantic cod is distributed throughout the western North Atlantic Ocean from Greenland to

Cape Hatteras, with the highest densities in the U.S. being highest on Georges Bank and the

western Gulf of Maine (Lough 2004). There are two separate stocks of cod within U.S. waters:

a stock within the Gulf of Maine and a second stock at Georges Bank and southward 

(Mayo and O'Brien 2000). Within the temperate part of their range, including offshore New

England, cod are non-migratory, and only make minor seasonal movements in response to

temperature changes. At the extremes of their range, including Labrador and south of the

Chesapeake, the cod migrate annually (Fahay et al. 1999a). Cod are generally found in areas |

over rough bottoms with water depths from 10 to 150 m (33 to 492 ft), and at temperatures |

between 0 and 10 C (32 and 50EF) (ENSR 2000). All stages of cod are reported to be common |

o

in Cape Cod Bay (Fahay et al. 1999a). Adult cod are reported to be abundant in the western

portion of Cape Cod Bay in the spring (Fahay et al. 1999a), and occur in large numbers

throughout Cape Cod Bay in the fall (Lough 2004).

Commercial and recreational fisheries for cod in the U.S. are managed under the NEFMC

Northeast Multispecies FMP (Mayo and O'Brien 2000). The status of the Gulf of Maine stock

indicates that the cod is possibly in an overfished condition. Annual landings have declined

since 1991, and the stock is considered depressed and overexploited (Fahay et al. 1999a). In

2001, NMFS reported that the Gulf of Maine stock was not overfished, but that overfishing was

occurring, and recommended further management actions to enhance spawning potential and

the rate of recovery of the stock (NMFS 2001b, in Fahay et al. 1999a). Additional assessments

were conducted in 2002 and 2005, and concluded that the stock was in an overfished condition,

and that overfishing was still occurring (Mayo and Col 2005a). In 2005, an analysis of juvenile

populations resulted in a proposal for the potential designation of HAPCs for the Atlantic cod,

including areas within Cape Cod Bay, adjacent to PNPS (Crawford et al. 2005). Eggs and

larvae of the Atlantic cod have been collected in the PNPS entrainment sampling. Juveniles

and/or adults have also been observed in the PNPS impingement sampling program.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-48 July 2007

| Atlantic halibut (Hippoglossus hippoglossus)

The Atlantic halibut, the largest flatfish species, is found on both sides of the North Atlantic

Ocean, as well as in the Arctic Ocean (Cargnelli et al. 1999c). The halibut supported a U.S.

commercial fishery beginning in the early 1800s, but the fishery had collapsed by the 1940s

(Cargenelli et al. 1999c). The eggs of the halibut are bathypelagic, suspended within the water

column at a depth of 54 to 200 m (175 to 656 ft) (Scott and Scott 1988; Blaxter et al. 1983, in

Cargenelli et al. 1999c). Larvae are pelagic and live within this zone until they reach juvenile

stage, at which time they transform into flatfish and migrate to the bottom (BMLSS 1997/8, in

ENSR 2000). The age of maturity for halibut is approximately 10 years (Cargnelli et al. 1999c). 

The Atlantic halibut in the Gulf of Maine and Georges Bank spawns over rough or rocky bottom

substrates on the slopes of the continental shelf, or on offshore banks, at depths greater than

183 m (600 ft) (Scott and Scott 1988, in Cargnelli et al. 1999c). Spawning is reported to occur

in late fall or spring, with peak spawning between November and December (NEFMC 1998a, in

ENSR 2000). However, spawning is thought to no longer occur in the Gulf of Maine 

(Cargnelli et al. 1999c). The diet of the Atlantic halibut changes through its lifespan. Juveniles

and smaller adults prey mostly on invertebrates, including annelids and crustaceans. As they 

grow larger, the adults prey primarily on other fish (Kohler 1967, in Cargnelli et al. 1999c). In

the Gulf of Maine, the primary prey is squid, crabs, silver hake, northern sand lance, ocean pout

(Macrozoarces americanus), and alewife (Cargnelli et al. 1999c). 

The range of the western North Atlantic halibut is from Labrador to Long Island

(Cargnelli et al. 1999c). In U.S. waters, their abundance is greatest in the Georges Bank,

Nantucket Shoals, Stellwagen Bank, and off the coast of Maine and Massachusetts 

(Cargnelli et al. 1999c). However, only 18 halibut, all juveniles, were captured in trawl surveys

in Massachusetts between 1978 and 1997 (Cargenelli et al. 1999c). Juveniles live within their

nursery areas until the age of three to four years, and after that time perform annual migrations 

(Stobo et al. 1988, in Cargnelli et al. 1999c). The species lives at depths of 100 to 700 m 

(328 to 2297 ft), with most commercial catches made at 200 to 300 m (656 to 984 ft) 

(Scott and Scott 1988, in Cargnelli et al. 1999c). The species is found in areas with substrates

of sand, gravel, and clay (NEFMC 1998a, in ENSR 2000), and at temperatures from -0.5 to

| 13.6 C (31.1 to 56.5EF) (Mahon 1997, in Cargnelli et al. 1999c).

o

The Atlantic halibut population was considered to be in an overfished condition in the late 1990s

(NMFS 1997, in Cargnelli et al. 1999c). It was designated as a species of concern in 2004, and

no directed fishing mortality is permitted until the stock is rebuilt (Cargnelli et al. 1999c). In a

2004 stock assessment, it was determined that the stock was overfished, but that there were 

not enough data upon which to determine whether overfishing was occurring 
Plant and the Environment

July 2007 2-49 NUREG-1437, Supplement 29

(Brodziak and Col 2005). No life stages of the Atlantic halibut have ever been observed in the

PNPS entrainment or impingement sampling. 

Atlantic sand lance (Ammodytes americanus)

The Atlantic sand lance is found in the western North Atlantic from Cape Hatteras north to

Labrador, Hudson Bay, and western Greenland (Fisheries and Oceans Canada 2006). The

species is small (rarely over 6 in. long) and forms schools consisting of thousands of

individuals. The species is not directly fished for commercial purposes, but it is an important

bait fish in fisheries such as those in the Stellwagen Bank area. Spawning occurs in the winter,

with females releasing over 20,000 eggs that settle and attach to the sandy substrate. Larval |

sand lance are pelagic and drift with tides and currents for approximately two months. The

species becomes sexually mature at an age of two years and may live to about five years of |

age (Provincetown Center for Coastal Studies 2006). |

Sand lance is an important prey species for many demersal fish species and the endangered fin

whale (Balaenoptera physalus) and humpback whale (Megaptera novaengliae) (Winters 1983).

Sand lance typically live in shallow water less than 90 m (295 ft) deep, along the coast or above

offshore banks, and in areas with sand or gravel substrates. The species burrows into the sand

in the intertidal zone, allowing it to be harvested by persons on foot, with shovels, to be used as

bait (Fisheries and Oceans Canada 2006). Larvae of the Atlantic sand lance are frequently

observed in the PNPS entrainment sampling and are periodically observed in the impingement 

sampling (Normandeau 2006a, Normandeau 2006b). Eggs and larvae of the Atlantic sand |

lance have been collected in the PNPS entrainment sampling. Juveniles and/or adults have

been observed in the PNPS impingement sampling program. |

Atlantic tomcod (Microgadus tomcod)

The Atlantic tomcod is a demersal, anadromous species found from southern Labrador to

Virginia. Eggs of the species form globules that sink to the bottom, and only develop in fresh or

brackish water. Spawning occurs from November to February, in estuaries north of the Hudson

River (Stewart and Auster 1987). After hatching, the larvae float to the surface and are swept

out to estuaries, where they develop into juveniles. The species generally lives in brackish or

fresh water at depths shallower than 10 m (33 ft) in coastal areas, and has been found in

landlocked lakes in Canada (Fishbase 2006). Atlantic tomcod feed principally on small

crustaceans and to a lesser extent on polychaete worms, mollusks, and fish

(Bigelow and Schroeder 1953 in Stewart and Auster 1987).

The species was an important commercial species in the 1800s in Massachusetts, but was not

targeted in the 20 century (Stewart and Auster 1987). Currently, the species is the target of a

th
Plant and the Environment 

 NUREG-1437, Supplement 29 2-50 July 2007

minor commercial fishery and is also fished recreationally (Fishbase 2006). Atlantic tomcod

| larvae have been observed in the PNPS entrainment sampling (Normandeau 2006a). Juveniles

| and/or adults are one of the numerically dominant species collected as part of the PNPS

| impingement sampling (Normandeau 2006b).

| Cunner (Tautogolabrus adspersus)

The cunner is a marine species that is common along the western North Atlantic coast from

Labrador to the Chesapeake Bay. Cunner become sexually mature at the age of two years

(Serchuk and Cole 1974, in ENSR 2000). Cunner spawn from late spring to summer in water

| temperatures between 12 to 22 C (53.6 to 71.6EF). In Cape Cod Bay, cunner spawning occurs o

primarily from late March through mid July (MRI 1992, in ENSR 2000). Cunner commonly

spawn in pairs or groups, depending on the conditions (Wicklund 1970, Pottle and Green 1979;

in ENSR 2000). The species forages on a variety of benthic invertebrates, predominantly blue

mussels (Mytilus edulis), barnacles, soft shell clams, amphipods, shrimp, and small lobsters. 

Cunner are associated with rocky subtidal environments such as that found in the vicinity of

PNPS. The cunner typically lives in rocky areas that are covered with algae, and among pilings

and shipwrecks that can provide shelter (ENSR 2000). Because of this association with shelter

in shallow water, the intake breakwaters and discharge jetties at PNPS provide a high-relief,

structurally complex habitat for the cunner (ENSR 2000). Additionally, two nearby areas,

Rocky Point and White Horse Beach, provide habitat important for settlement of cunner larvae,

although these areas do not appear to be as important to recruitment success as the discharge

| area (Lawton et al. 2000). Cunner are found primarily between 3 and 10 m (9.8 and 32.8 ft)

| deep, but have been caught as deep as 150 m (492 ft) on Georges Bank (ENSR 2000).

Cunner are year-round residents, and do not migrate except for movements to deeper water

during deep freezes (Green and Farwell 1971, in ENSR 2000). Because the species does not

migrate long distances, population trends may be an indicator of local stressors (ENSR 2000).

| The PNPS area provides cunner spawning and nursery grounds due to the breakwater walls

| creating an ideal habitat; therefore, cunner have a high incidence of entrainment and

impingement at PNPS relative to other species (Lawton et al. 2000). 

Cunner eggs and larvae are commonly found in the entrainment samples, and adult cunner are

frequently found in the impingement collections. The species was the focus of investigative

programs at PNPS from 1990 to 1997, because of the relatively high incidence of eggs and

| larvae entrained. Based on the results of these studies, it appears that PNPS has a minor 

effect on recruitment success to the local cunner population (Lawton et al. 2000). Eggs and

larvae of the cunner have been consistently collected in the PNPS entrainment sampling and

| are one of the numerically dominant species in the entrainment collections. Juveniles and/or

adults have also been observed in the PNPS impingement sampling program. 
Plant and the Environment

July 2007 2-51 NUREG-1437, Supplement 29

Fourbeard rockling (Enchelyopus cimbrius) |

The fourbeard rockling is a demersal fish found from the northern Gulf of Mexico to

Newfoundland, Greenland, and throughout the northeast Atlantic coast of Europe. The species

typically spawns in waters less than 140 m (459 ft) deep. Adults feed on flatfish, amphipods,

decapods, copepods, and small crustaceans (Census of Marine Life 2006). The species |

reaches a maximum age of about nine years (Deree 1999). 

The species is a sedentary bottom dweller, living on mud or muddy sand substrates on the

continental slope (Census of Marine Life 2006; Bigelow and Schroeder 1953, in Deree 1999). 

The typical depth range for the species is from 20 to 650 m (66 to 2132 ft) 

(Census of Marine Life 2006). Fourbeard rockling eggs and larvae are frequently observed in

the PNPS entrainment sampling (Normandeau 2006a). Fourbeard rockling have also been |

collected as part of the PNPS impingement sampling; however, this only occurred during 1998

(Normandeau 2006b). |

Fourspot flounder (Paralichthyus oblongus)

The fourspot flounder is a benthic species found along the western Atlantic coast from Georges

Bank to South Carolina (Gulf of Maine Research Institute 2006). The eggs are buoyant, but the

larvae complete transformation and move to the bottom within 3 months of hatching

(Gulf of Maine Research Institute 2006). Spawning occurs from May to mid-July 

(Census of Marine Life 2006). The species’ habitat includes bays and sounds, at water depths |

up to 275 m (902 ft) (Robins et al. 1986).

Fourspot flounder eggs and larvae have been observed in the PNPS entrainment sampling

(Normandeau 2006a). Fourspot flounder have also been periodically collected as part of the |

PNPS impingement sampling (Normandeau 2006b). Eggs and larvae of the fourspot flounder |

have been collected in the PNPS entrainment sampling. Juveniles and/or adults have been |

observed in the PNPS impingement sampling program. 

Haddock (Melanogrammus aeglefinus)

The haddock is a demersal gadoid species found on both sides of the North Atlantic 

(Brown 2000). Eggs, larvae, and juveniles all live within the upper part of the water column until

the juveniles reach a size of 3 to 10 cm (1 to 4 in.) (Brodziak 2005). At that time, juveniles

travel to the bottom, locate suitable habitat, and become demersal (Klein-MacPhee 2002, in |

Brodziak 2005). Spawning varies by location and time of year, with spawning generally

occurring from February to May in the Gulf of Maine. The largest spawning area in U.S. waters

is Georges Bank, and for the Gulf of Maine stock, spawning occurs at the Jeffrey's Ledge and
Plant and the Environment 

 NUREG-1437, Supplement 29 2-52 July 2007

Stellwagen Bank areas (Brodziak 2005). Spawning can occur over substrates of various types,

including rock, gravel, sand, or mud (Klein-MacPhee 2002, in Brodziak 2005). The size and

age at maturity vary by location and population density, and have also been decreasing through

time (Cargnelli et al. 1999a). Spawning in the Gulf of Maine peaks from February to April

(Bigelow and Schroeder 1953, in Cargnelli et al. 1999a). The diet of haddock changes through

their life cycle. Larvae and small juveniles feed on phytoplankton, copepods, and invertebrate

eggs suspended in the water column. Once juveniles move to the bottom, they primarily eat

small crustaceans, polychaetes, and small fish. As adults, the haddock feed primarily on

benthic organisms such as echinoderms, crustaceans, polychaetes, and mollusks 

(Brodziak 2005).

The haddock is distributed throughout the western North Atlantic Ocean from Cape May, New

Jersey to Newfoundland (Brodziak 2005). Haddock are generally found at depths of between

| 45 and 135 m (147 to 443 ft), and at temperatures between 2 and 10 C (35.6 to 50EF) (Brown o

2000). The preferred bottom types include gravel, pebbles, and smooth hard sand, and this

preference appears to result in the location of primary spawning areas on Georges Bank, and in 

isolated locations within the Gulf of Maine (Lough and Bolz 1989; Colton 1972, in 

Cargenelli et al. 1999a). Data suggest that larvae drift with currents from Canadian waters as

far south as Cape Cod, and then live a portion of their life in this area (Colton and Temple 1961,

in Cargnelli et al. 1999a). Haddock are not migratory, with only minor movements shoreward in

summer, and to deeper water in winter (Brodziak 2005). In inshore trawl surveys, juveniles

were found in Cape Cod Bay in low numbers in autumn, but were not found in the bay in spring.

| Adults were not found in the bay (Cargnelli et al. 1999a; GOMCML 2006).

Six separate haddock stocks have been identified in the western North Atlantic, with two stocks

recognized in U.S. waters in the Gulf of Maine and Georges Bank (Brodziak 2005). The U.S.

| fishery for haddock is managed under the NEFMC Northeast Multispecies FMP (Brown 2000).

| The Gulf of Maine stock was overfished as of 2004 (NMFS 2001a; Brodziak 2005). However,

numbers of haddock in the Gulf of Maine have increased since they reached their lowest levels

in the early 1990s, and the age structure has broadened as well. In a 2004 assessment, the

| determination was made that the stock was overfished, but overfishing was not occurring

(Brodziak and Traver 2005). Similarly, the Georges Bank stock, although still in an overfished

condition, had rebounded substantially due to fishery management measures (Brodziak 2005).

However, in 2005, an analysis of juvenile populations resulted in a proposal for the potential

designation of HAPCs for the haddock, including areas within Cape Cod Bay, adjacent to PNPS

(Crawford et al. 2005). Eggs and larvae of the haddock have been collected in the PNPS

entrainment sampling. Juveniles and/or adults have not been observed in the PNPS

impingement sampling program. 
Plant and the Environment

July 2007 2-53 NUREG-1437, Supplement 29

Little skate (Leucoraja erinacea)

The little skate is a dominant species among the demersal fish community in the western North

Atlantic (Bigelow and Schoeder 1953, in Packer et al. 2003b). The little skate is often confused

with the larger winter skate due to similarity in appearance, but the little skate is far more

common (McEachran and Musick 1975, in Packer et al. 2003b). Skates are fished

commercially, but with no distinction among the seven species (Packer et al. 2003b). Most |

commercial use of skates, including the little skate, is for lobster bait (Sosebee 2000c). Eggs of

all skates are encapsulated in a leathery capsule that rests on the bottom (Sosebee 2000c;

Packer et al. 2003b). The eggs hatch fully developed, so there is no larval stage 

(Sosebee 2000c; McEachran 2002, in Packer et al. 2003b). Adults are estimated to reach

sexual maturity at the age of four years (NMFS 2000, in Packer et al. 2003b). Spawning may

occur at any time during the year, with a peak in southern New England from July to September

(Bigelow and Schroeder 1953, in Packer et al. 2003b). The major prey reported for the little

skate in the Gulf of Maine area includes decapod crustaceans, amphipods, and polycheates.

(McEachran 1973; McEachran et al. 1976, in Packer et al. 2003b).

The little skate is most commonly found on the Georges Bank, and in the northern section of

the Mid-Atlantic Bight (McEachran and Musick 1975, in Packer et al. 2003b). The little skate is

found through the year in these areas, including the entire range of temperatures that occur in

those areas (McEachran and Musick 1975, in Packer et al. 2003b). Skates have been landed

as bycatch in New England since the late 1960s, but were not directly targeted as a fishery until

the 1980s. There is no stock differentiation among the skate species. Little skate have a |

reported depth range of 0 to 137 m (0 to 450 ft), with most being found less than about 100 m

(328 ft) deep (Bigelow and Schroeder 1953; McEachran and Musick 1975, in 

Packer et al. 2003b). The corresponding water temperature ranges from 1 to 21 C (33.8 to |

o

69.8EF) (Bigelow and Schroeder 1953; Tyler 1971; McEachran and Musick 1975, in Packer et |

al. 2003b). Little skates typically prefer sandy or gravelly substrates (Bigelow and Schroeder

1953, in Packer et al. 2003b), and are known to bury themselves in depressions during the day

(Michalopouloos 1990, in Packer et al. 2003b). Skates do not migrate substantially, but |

generally move offshore in summer and early autumn and onshore during winter and spring

(Sosebee 2000c). Bottom trawl surveys found juvenile little skates in heavy concentrations

nearshore in Cape Cod Bay in the spring (Packer et al. 20003b). Adults were also found in

Cape Cod Bay during the spring, summer, and fall (Packer et al. 2003b). Little skate

abundance has increased since the early 1980s, and as of 2000 was at its highest numbers

since 1975 (Sosebee 2000c). According to a 2000 stock assessment, the little skate was not |

overfished, and overfishing was not occurring (NMFS 2000, in Packer et al. 2003b). No life |

stages of the little skate have ever been observed in the PNPS entrainment sampling. 

Juveniles and/or adults have been observed in the PNPS impingement sampling program.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-54 July 2007

Monkfish (Lophius americanus)

The common name used for this species in commercial fishing is monkfish, but the name

recognized by the American Fisheries Society is goosefish (Steimle et al. 1999c). The

monkfish is a solitary, bottom-dwelling angler fish occurring all along the eastern coast of the

U.S. (primarily north of Cape Hatteras) and Canada up to Newfoundland (Steimle et al. 1999c). 

Eggs are buoyant, and are laid in rafts that may be up to 6 to 12 m (20 to 39 ft) long

(Steimle et al. 1999c). Larvae and juveniles are also pelagic, and eventually descend to the

bottom to live their adult lifespan as benthic fish (NOAA 1998, in ENSR 2000). Once they have

settled to the bottom, juveniles prefer a substrate of sand-shell mix, algae-covered rocks, hard

| sand, pebbly gravel, or mud, with water temperatures below 15 C (59EF) (NEFMC 1998a, in o

ENSR 2000). Adults spend most of their lives resting on the bottom in depressions within

sandy sediment (Steimle et al. 1999c). The monkfish becomes sexually mature between the

ages of four and five years (Wood 1982, in Steimle et al. 1999c). Spawning occurs in locations

including inshore shoals and offshore surface water, in temperatures below 18 C (64.4EF), in o

| the months of May and June within the Gulf of Maine (Scott and Scott 1988; Hartley 1995, in

Steimle et al. 1999c). The larvae feed on zooplankton, including copepods and crustacean

| larvae, while juveniles eat smaller fish (including sand lance), shrimp, and squid

(Bigelow and Schroeder 1953, in Steimle et al. 1999c). Adults eat a variety of benthic and

pelagic species, sea birds, and even younger monkfish, and capture prey with an ambush or

sudden rush (Steimle et al. 1999c). The age span of the monkfish ranges from 9 years for

males to 12 years for females. 

Monkfish are found throughout the continental shelf in waters shallower than 668 m (2192 ft).

They are most commonly found in shallow waters of the Gulf of Maine during the summer

| (Steimle et al. 1999c). Although the monkfish population appears to exist as only one distinct

stock, it is managed as two separate stocks, one north and one south of the Georges Bank

(Steimle et al. 1999c; NEFMC 2006a). Adult monkfish generally inhabit waters from 70 to 

100 m (230 to 328 ft) deep, and may also be found in inshore areas or at depths greater than

800 m (2625 ft) (Richards 2000). The monkfish are found in temperatures ranging from 0 to

24 C (32 to 75.2EF), most abundantly between 4 to 14 C (39.2 to 57.2EF) (Steimle et al. o o

| 1999c). The monkfish has annual migrations in search of spawning habitat and food. Monkfish

were not extensively fished commercially until the 1970s. Since that time, harvests have

increased and stock numbers have declined dramatically (Idoine 1995, in Steimle et al. 1999c). 

In 2000, the Monkfish FMP was developed by the NEFMC and MAFMC (NEFMC 2006b).

Neither stock was considered to be overfished based on a stock assessment performed in 2004

(NMFS 2005a), but a 2006 assessment has concluded that both stocks are overfished (NEFMC

2006b). Eggs and larvae of the monkfish have been collected in the PNPS entrainment

sampling. Juveniles and/or adults have also been observed in the PNPS impingement

sampling program. 
Plant and the Environment

July 2007 2-55 NUREG-1437, Supplement 29

Ocean pout (Macrozoarces americanus)

The ocean pout is also known as eel pout or muttonfish. It is a bottom-dwelling, cool-temperate

species that lives on the western North Atlantic continental shelf from Labrador to Virginia

(Steimle et al. 1999b). The species lays eggs in nests, which it then guards until they hatch

(Steimle et al. 1999b). Both the larvae and adults are demersal, and are not known to form

schools (Steimle et al. 1999b). The ocean pout spawns in areas with hard bottom substrates, |

including artificial reefs or in rock crevices, in late summer through the early winter 

(Steimle et al. 1999b). Spawning peaks in the months of September and October 

(NEFMC 1998a, in ENSR 2000). Spawning occurs at depths of less than 50 m (164 ft), and

temperatures of 10 C (50EF) or less (Clark and Livingstone 1982, in Steimle et al. 1999b). |

o

There are differing reports on how the ocean pout feeds. According to a report by MacDonald

(1983, in Steimle et al. 1999b), ocean pout feed by sorting through mouthfuls of sediment for

fauna contained within the sediment, and do not appear to visually follow prey or leave the

bottom to feed. However, Auster (1985, in Steimle et al. 1999b) reported that ocean pout hide 

within sediment depressions to wait for prey to swim or drift by. The prey is reported to consist

of echinoderms, crustaceans, and other benthic invertebrates (Anderson 1994, in ENSR 2000).

The range of the ocean pout on the continental shelf extends from Labrador to Delaware. It is

managed as two separate stocks, a northern stock in the Gulf of Maine and a southern stock in

Cape Cod Bay, Georges Bank, and south to Delaware (Wigley 2000a). However, studies

suggest that there are up to five separate stocks, including one confined to the Gulf of Maine

and Cape Cod Bay (Orach-Meza 1975, in Steimle et al. 1999b). The ocean pout does not

migrate, although it moves seasonally within a limited region (Bigelow and Schroeder 1953, in

Steimle et al. 1999b). The ocean pout lives at depths from 15 to 80 m (50 to 262 ft) 

(Wigley 2000a) and in water temperatures below 10 C (50EF) (NEFMC 1998a, in ENSR 2000). o

The ocean pout typically live and feed in areas with soft or sandy substrates, and move to rocky

areas to spawn (Wigley 2000a). Juvenile ocean pout were reported to be commonly found in

saline water (greater than 25 parts per thousand [ppt]) in many estuaries and coastal areas, |

including Cape Cod Bay, throughout the year (Jury et al. 1994, in Steimle et al. 1999b). |

Of the two managed stocks, only the southern stock, which includes Cape Cod Bay, is

commercially fished (Wigley 1998, in Steimle et al. 1999b). The population of ocean pout has

varied considerably, with high levels in the 1960s, low levels in the 1970s, and record high

levels again in the 1980s (Steimle et al. 1999b). The ocean pout are managed under the |

NEFMC’s Northeast Multispecies FMP (Wigley 2000a). Although there is no clear trend, the |

population is considered to be fully exploited (Wigley 1998, in Steimle et al. 1999b). In a 2004

assessment, the stock was found to be overfished, but overfishing was not occurring at that

time (Wigley and Col 2005b). In 2005, an analysis of juvenile populations resulted in a proposal

for the potential designation of HAPCs for the ocean pout, including areas within Cape Cod
Plant and the Environment 

 NUREG-1437, Supplement 29 2-56 July 2007

Bay, adjacent to PNPS (Crawford et al. 2005). The ocean pout has not been observed in the

PNPS entrainment sampling. Juveniles and/or adults have been observed in the PNPS

impingement sampling program.

| Offshore hake (Merluccius albidus)

| Offshore hake are found throughout the continental shelf and slope of the northwestern Atlantic

from the Scotian Shelf to the Gulf of Mexico. The species has often been confused with the

silver hake, which it resembles, resulting in a lack of research and fishery data specific to the

species (Chang et al. 1999c). The offshore hake has mostly been fished as bycatch of the

silver hake fishery (Chang et al. 1999c). Very little information exists on the early life stages,

growth, or ages of the species (Chang et al. 1999c). Eggs and larvae are pelagic, and

have been found off of Massachusetts from the months of April to July (Marak 1967, in

Chang et al. 1999c). Juvenile offshore hake feed on small fish, shrimp, and other crustaceans,

while adults eat other fish, including lantern fishes, sardines, and anchovies 

(Chang et al. 1999c). 

| In the northwestern Atlantic, the offshore hake is most commonly found along the outer edge of

the Scotian Shelf (Chang et al. 1999c). Offshore hake in the Georges Bank-New England-MidAtlantic area are considered to be a single stock (Chang et al. 1999c). No information is

available on migration of the offshore hake. The species appears to live at depths ranging from

70 to 640 m (230 to 2100 ft), with a concentration found at about 200 m (656 ft), throughout the

year (Chang et al. 1999c). Larvae are reported to be abundant in continental shelf waters of

the Gulf of Maine during the months of August and September. However, juveniles and adults

were reported to be only rarely found within the Gulf of Maine (Chang et al. 1999c).

There is no directed fishery for offshore hake, so there has been no evaluation of the status of

the stock (Chang et al. 1999c). No life stages of the offshore hake have ever been observed in

the PNPS entrainment or impingement sampling.

Red hake (Urophycis chuss)

Red hake is a demersal species inhabiting bottom waters, ranging from Nova Scotia to North

Carolina in the western North Atlantic continental slope (Cohen et al. 1990, in ENSR 2000).

Both the eggs and larvae of the red hake are pelagic, occurring in surface waters less than

| 10 C (50EF) (eggs) and 19 C (66.2EF) (larvae) (NEFMC 1998a, in ENSR 2000). Shelter is an

o o

| important habitat requirement for red hake (Steiner et al. 1982, in Steimle et al. 1999a). When

the fish become juveniles, they migrate to shallower waters along the coast, and live among

shell litter or live scallop beds (Cohen et al. 1990; NEFMC 1998a, in ENSR 2000). Adult red

hake typically live in areas with soft sediment bottoms and less commonly near gravel or rock
Plant and the Environment

July 2007 2-57 NUREG-1437, Supplement 29

bottoms (Steimle et al. 1999a). Adults become mature at an age of about 1.5 years (Steimle et

al. 1999a). The adults migrate in the spring to shallow waters for spawning, which can take

place between May and November, with peaks in June and July (Sosebee 1998; NEFMC

1998a, in ENSR 2000). Spawning occurs in temperatures of 5 to 10 C (41 to 50EF) (Steimle et |

o

al. 1999a), within depressions in muddy or sandy substrates (NEFMC 1998a, in ENSR 2000).

The primary spawning grounds include the southern edge of Georges Bank, and shallow areas

off of the southern New England coast (Sosebee 1998, in ENSR 2000). Larvae feed mainly on

copepods and other micro-crustaceans (Steimle et al. 1999a). Juvenile red hake feed primarily

on crustaceans such as amphipods and shrimp, and the adults feed on amphipods and shrimp,

as well as squid, herring, flatfish, and mackerel (Cohen et al. 1990, in ENSR 2000).

Red hake are most commonly found between Georges Bank and New Jersey 

(Sosebee 1998, in Steimle et al. 1999a). Red hake migrate extensively due to seasonal and

temperature variations. During winter, they live offshore in water greater than 100 m (328 ft)

deep, but in summer, red hake migrate into shallow coastal water and estuaries of the Gulf of

Maine, and live in water less than 10 m (33 ft) deep (Steimle et al. 1999a). Red hake generally

live in bottom waters over a substrate of mud or sand (Cohen et al. 1990; NEFMC 1998a, in

ENSR 2000). In the spring and summer, red hake undergo seasonal migration from offshore

deeper water to nearshore shallow waters (Sosebee 1998, in ENSR 2000).

Two stocks are recognized for management of the red hake, a northern stock from the Gulf of

Maine to northern Georges Bank and a southern stock from Georges Bank to the Mid-Atlantic

Bight (Sosebee 1998, in Steimle et al. 1999a; Brodziak 2001b). The red hake fishery is

managed under the Northeast Multispecies FMP under the "nonregulated multispecies" |

category (Brodziak 2001b). Both the northern and southern stocks were considered

underexploited as recently as 1998. In 2001, the stock appeared to be healthy, and yields

could be increased (Brodziak 2001b). Eggs and larvae of the red hake have been collected in

the PNPS entrainment sampling. Juveniles and/or adults have also been observed in the

PNPS impingement sampling program. 

Rock gunnel (Pholis gunnellus)

The rock gunnel is a demersal species found on both sides of the Atlantic, with the population

in the western Atlantic ranging from Labrador to Delaware Bay (Robins et. al 1986). In warm

months, the species lives in shallow coastal waters, and is often stranded in tide pools

(Biomes Marine Biology Center 2006). In winter, the species migrates to offshore waters up to

100 m (328 ft) deep (Census of Marine Life 2006). The habitat consists of areas with rocky or

shell fragment substrates where the species finds shelter, and feeds on worms and small

crustaceans (Biomes Marine Biology Center 2006). The spawning season occurs from 

November to January (Census of Marine Life 2006). The species is not the target of
Plant and the Environment 

 NUREG-1437, Supplement 29 2-58 July 2007

commercial fisheries. Rock gunnel larvae have been observed in the PNPS entrainment

| sampling (Normandeau 2006a). Rock gunnel have also been periodically collected as part of

| the PNPS impingement sampling (Normandeau 2006b). 

Scup (Stenotomus chrysops)

The scup is a demersal, temperate fish found in the western Atlantic (Steimle et al. 1999f). 

Scup are fished both commercially and recreationally, although both types of landings have

declined (MAFMC 1996a, in Steimle et al. 1999f). Both eggs and larvae are pelagic, and the

larvae become demersal in shoal areas in early July (Able and Fahay 1998, in

Steimle et al. 1999f). The adults can occupy a variety of benthic habitats, from open water to

structured areas (Steimle et al. 1999f). Adult scup become sexually mature by the age of three

years (Gabriel 1998, in Steimle et al. 1999f). Southern New England, including Massachusetts

Bay, is considered to be a primary spawning area for scup (Steimle et al. 1999f). Scup spawn

in shallow shoal waters less than 10 m (33 ft) deep until late June, and then move to deeper

water (MAFMC 1996a, in Steimle et al. 1999f). Both juvenile and adult scup are benthic

feeders. Adults eat small crustaceans, polychaetes, mollusks, small squid, detritus, insect

larvae, sand dollars, and small fish (Bigelow and Schroeder 1953; Morse 1978; Sedberry 1983,

in Steimle et al. 1999f). 

The scup is known to occur in the western Atlantic from the Bay of Fundy to Florida, but is most

commonly found from Massachusetts to South Carolina (Steimle et al. 1999f). Adults are

abundant in schools in the Mid-Atlantic Bight from spring to fall, and live in areas with bottom

substrates ranging from open sandy bottoms to mussel beds, reefs, or rocks 

| (Steimle et al. 1999f). The temperature range for scup is from 6 to 27 C (42.8 to 80.6EF) o

(Neville and Talbot 1964, in Steimle et al. 1999f). Smaller scup are frequently found in bays

and estuaries, but larger adult scup usually live in deeper water ranging from 70 to 180 m (230

to 590 ft) (Steimle et al. 1999f). Larval scup were reported in Cape Cod Bay in May through

| September, in water temperatures of 14 to 22 C (52.7 to 71.6EF) (MAFMC 1996a, in Steimle et o

al. 1999f). 

Some researchers have considered the population in the Mid-Atlantic Bight area to be two

separate stocks, but it is now considered to be a single stock (Pierce 1981; Mayo 1982, in

Steimle et al. 1999f; Terceiro 2001a). The fishery is managed under the Summer Flounder,

Scup, and Black Sea Bass FMP (Terceiro 2001a). In the late 1990s, the Mid-Atlantic Bight

stock was considered overfished because the biomass was at near record low levels 

(Gabriel 1998; NMFS 1997, in Steimle et al. 1999f). However, a 2002 stock assessment

concluded that the stock is not overfished and that the status with respect to overfishing could

not be evaluated (NMFS 2002a). This report noted that this conclusion was based on

anomalously high abundance estimates in 2002, compared to 2001, and that the sudden
Plant and the Environment

July 2007 2-59 NUREG-1437, Supplement 29

increase created uncertainty in the data (NMFS 2002a). The 2006 ASMFC report considers the

scup population to be overfished, while the overfishing status is not known (ASMFC 2006).

Eggs and larvae of the scup have been collected in the PNPS entrainment sampling. Juveniles

and/or adults have also been observed in the PNPS impingement sampling program. 

Silver hake / Whiting (Merluccius bilinearis)

Silver hake, also known as whiting, is a demersal fish that lives in a range from Nova Scotia to

South Carolina (Bigelow and Schroeder 1953; NEFMC 1998a, in ENSR 2000), and is most

abundant from Nova Scotia to New Jersey (Lock and Packer 2004). Silver hake eggs and

larvae are pelagic, existing in the water column at depths between 50 and 150 m (164 to 492 ft)

(NEFMC 1998a, in ENSR 2000). As larvae mature into juveniles, they settle to the bottom

(Lock and Packer 2004). As adults, silver hake are found in water ranging from shallow to

depths greater than 400 m (1312 ft) (Dery 1988a; Bolles and Begg 2000, in

Lock and Packer 2004). Silver hake become sexually mature between the ages of two and

three years (Mayo 1998a, in ENSR 2000). The adults spawn over a variety of substrates in the

Gulf of Maine, Georges Bank, and the southern New England area south of Martha's Vineyard 

(Lock and Packer 2004). Spawning within the Gulf of Maine generally begins in June, with a

peak in July to August (Lock and Packer 2004). Juvenile silver hake feed mainly on

crustaceans (Cohen et al. 1990, in ENSR 2000), and the adults feed on both fish and pelagic

invertebrates, such as shrimp and squid (Mayo 1998a, in ENSR 2000). Silver hake is a |

dominant predator species on the continental shelf in the northwestern Atlantic, and its large |

biomass and high consumption affect help to regulate the ecosystem (Bowman 1984; |

Garrison and Link 2000, in Lock and Packer 2004). 

Silver hake spend the winter in deep waters of the Gulf of Maine and outer continental shelf,

and then migrate annually to shallow offshore waters in the spring (Mayo 1998a, in |

ENSR 2000). Adults tend to live in cool bottom water at temperatures lower than 13 C

o

(55.4EF), and with a variety of substrates (NEFMC 1998a, in ENSR 2000). The migration of |

silver hake is seasonal. The northern stock moves to the deep basins of the Gulf of Maine

during the winter, and migrates into nearshore waters in the Gulf of Maine in the spring and

summer (Lock and Packer 2004). Trawl surveys conducted for silver hake in 1999 identified

concentrations of silver hake in Cape Cod Bay in spring and autumn (Reid et al. 1999a, in |

Lock and Packer 2004). A summary of annual NMFS Bottom Trawl Survey data identified

substantial numbers of silver hake in Cape Cod Bay during the fall every year between 1979

and 2003, but found a more limited number in the bay during the spring in those years

(GOMCML 2006).

Silver hake in the U.S. are divided into northern (Gulf of Maine to northern Georges Bank) and

southern (Georges Bank to Cape Hatteras) stocks for management purposes (NEFMC 2003).
Plant and the Environment 

 NUREG-1437, Supplement 29 2-60 July 2007

The silver hake fishery is managed under the NEFMC Northeast Multispecies FMP under the

"nonregulated multispecies" category (Brodziak 2001a). Based on data presented in the 2006

Assessment Summary Report, neither the northern nor southern stock of the silver hake is in

an overfished condition, and overfishing is not occurring (NMFS 2006a). The northern stock is

at a high biomass level (Lock and Packer 2004). The southern stock was reported to be

overfished in 2001 (NMFS 2001a), and although not currently overfished, the southern stock

still has a low biomass level resulting from this overfishing in 1998-2000 (NEFMC 2003). Eggs

and larvae of the silver hake have been collected in the PNPS entrainment sampling. Juveniles

and/or adults have also been observed in the PNPS impingement sampling program. 

Smooth skate (Malacoraja senta)

The smooth skate occurs along the Atlantic coast of North America from the Gulf of 

| St. Lawrence and the Labrador Shelf to South Carolina (Bigelow and Schroeder 1953;

McEachran 1973; McEachran and Musick 1975, in Packer et al. 2003d). It is one of seven

| species of skates found throughout the northwestern Atlantic (Sosebee 2000c). Skates are

| fished commercially, but with no distinction among the seven species (Packer et al. 2003d).

Most commercial use of skates, including the smooth skate, is for lobster bait (Sosebee 2000c). 

Little information is known of the life history of the smooth skate (Packer et al. 2003d). Eggs of

all skates are known to be encapsulated in a leathery capsule that rests on the bottom

(Sosebee 2000c; Packer et al. 2003d). The eggs hatch fully developed, so there is no larval

stage (Sosebee 2000c; also McEachran 2002, in Packer et al. 2003d). Females with fully

| formed egg capsules are found in both summer and winter (McEachran 2002, in 

Packer et al. 2003d), but no other information on spawning times or locations is available. The

primary food source for the smooth skate is epifaunal crustaceans, with decapod shrimps and

mysids also being important (McEachran 1973; McEachran et al. 1976; Bowman et al. 2000;

McEachran 2002, in Packer et al. 2003d).

The Gulf of Maine is reported to be the center of abundance for the smooth skate (Bigelow and

Schroeder 1953; McEachran and Musick 1975; McEachran 2002, in Packer et al. 2003d),

including Massachusetts Bay (Collette and Hartel 1988, in Packer et al. 2003d). Skates have

been landed as bycatch in New England since the late 1960s, but were not directly targeted

| until the 1980s. There is no stock differentiation among the skate species.

The water depth range for the smooth skate is from 31 to 874 m (102 to 2867 ft), with most

being found from 110 to 457 m (361 to 1499 ft) (McEachran and Musick 1975; 

McEachran 2002, in Packer et al. 2003d). The temperature range of the species is from 2 to

| 13 C (35.6 to 55.4EF) for juveniles and adults, with most found between temperatures of 4 to o

| 8

oC (39.2 to 46.4 EF) (Packer et al. 2003d). The smooth skate is found mostly on bottom

substrates of soft mud and fine sediments (Bigelow and Schroeder 1953; McEachran and
Plant and the Environment

July 2007 2-61 NUREG-1437, Supplement 29

Musick 1975; Scott 1982a, in Packer et al. 2003d). Skates do not migrate substantially, but do

generally move offshore in summer and early autumn, and onshore during winter and spring

(Sosebee 2000c). No seasonal trends in abundance were identified by McEachran and Musick

(1975, in Packer et al. 2003d). Inshore trawl surveys in Massachusetts identified juveniles in

both the spring and fall near Cape Cod Bay (Packer et al. 2003d).

In the 2000 stock assessment, the smooth skate was considered to be overfished (NMFS 2000, |

in Packer et al. 2003d). However, the 2002 assessment determined that the species was not in |

an overfished condition at that time (NMFS 2002b, in Packer et al. 2003d). No life stages of the

smooth skate have ever been observed in the PNPS entrainment or impingement sampling.

Summer flounder (Paralicthys dentatus) |

The summer flounder, also known as fluke, inhabits shallow estuarine waters and the outer

continental shelf from Nova Scotia to Florida (Packer et al. 1999). The species is important

along the east coast both as a commercial and recreational fishing resource, with recreational

landings exceeding commercial landings in some years (Packer et al. 1999). Both eggs and

larvae of the species are buoyant and pelagic. Eggs are most abundant in the western North

Atlantic in October and November, and larvae are most abundant from October to December

(Able et al. 1990, in Packer et al. 1999). The larvae are transported toward coastal areas by

the prevailing water currents, and development of post-larvae and juveniles occurs primarily

within bays and estuarine areas (ENSR 2000). Sexual maturity is reached by the age of two

years (Morse 1981, in Packer et al. 1999). The timing of spawning varies by location. In

southern New England and the Mid-Atlantic, spawning occurs primarily in September 

(Berrien and Sibunka 1999, in Packer et al. 1999). Spawning occurs in open ocean areas of

the shelf (Packer et al. 1999), in waters ranging from 30 to 200 m (98 to 656 ft) deep |

(ENSR 2000). The timing of spawning appears to coincide with the maximum production of

autumn plankton, which is the primary food source for larvae (Morse 1981, in

Packer et al. 1999). Juvenile summer flounder feed upon crustaceans and polychaetes, and as

they grow larger they begin to feed more on fish (Packer et al. 1999). Adults are opportunistic

feeders, preying mostly on fish and crustaceans (Packer et al. 1999). Species preyed upon

include windowpane flounder, winter flounder, Atlantic menhaden, red hake, silver hake, scup,

Atlantic silverside, and bluefish, among others (Packer et al. 1999). 

Although found all along the east cost, the primary center of abundance for the summer

flounder is the area from Cape Cod to Cape Hatteras (Packer et al. 1999). Adult summer

flounder in Massachusetts migrate inshore in May, and migrate to offshore waters in late fall

(Packer et al. 1999). Inshore trawl surveys in Massachusetts found seasonal variation in the

depths and temperatures at which adults were caught. In the spring, adults were found at

depths from 0 to 360 m (0 to 1181 ft), at temperatures between 8 to 16 C (46.4 to 60.8EF). In |

o
Plant and the Environment 

 NUREG-1437, Supplement 29 2-62 July 2007

the summer and autumn, the species was found almost entirely at depths shallower than 100 m

| (328 ft), in water between 15 to 28 C (59 to 82.4EF). In the winter, the species is found in o

| deeper locations, greater than 70 m (230 ft), in temperatures between 5 to 11 C (41 to 51.8EF) o

(Sissenwine et al. 1979, in Packer et al. 1999). The shoal waters of Cape Cod Bay, including

estuaries and harbors, are considered to be critically important habitat for the species (Packer

et al. 1999). 

The species is managed as a single stock, although it is possible that different stocks exist, with

some information suggesting different stocks north and south of Cape Hatteras 

| (Packer et al. 1999). The fishery is managed under the summer flounder, scup, and black sea

| bass FMP (Terceiro 2001b). As of 1999, the stock was considered to be at a medium level of

its historical abundance and was over-exploited (Terciero 1995; NMFS 1997, in

Packer et al. 1999). More recently, total stock biomass is reported to have increased

substantially since 1989 (NMFS 2005b). The 2006 ASMFC report indicates the stock is not

currently considered to be overfished, but overfishing is occurring (NMFS 2005b, 

ASMFC 2006). Eggs and larvae of the summer flounder have been collected in the PNPS

entrainment sampling. Juveniles and/or adults have also been observed in the PNPS

impingement sampling program. 

Tautog (Tautoga onitis)

The tautog is an inshore species ranging from Nova Scotia to South Carolina, and is popular for

recreational fishing from Cape Cod south to Delaware (MDMF 2006). The eggs of the tautog

| are buoyant, and hatch within two days. Within four days after hatching, the pelagic larvae

begin feeding on plankton. Juvenile and adult tautog feed on shallow water invertebrates, and

have flat, grinding teeth that allow them to open the shells of mussels. Spawning in

Massachusetts occurs in June, in inshore waters containing eelgrass beds, at water

temperatures of 62 to 70 F (17 to 21 C). The species becomes sexually mature at an age of o o

about three to four years, and can live to be 35 years of age (MDMF 2006).

The species lives in inshore areas at water depths of less than 60 ft deep, including rocky areas

around breakwaters and pilings along the coast (Robins et al. 1986). Adults do not undertake

long migrations, but feed inshore in spring and move offshore to waters 50 to 150 ft deep in

winter (MDMF 2006).

Until recently, population levels were considered to have remained relatively stable since

colonial times, as the species was not commercially fished. In the early 1980s, a commercial

fishery developed, and recreational landings increased substantially as well. By the early

| 1990s, the average size of landed tautog was much smaller, which led to State fishery

restrictions (MDMF 2006). In a 2004 assessment, tautog were considered to be overfished and
Plant and the Environment

July 2007 2-63 NUREG-1437, Supplement 29

believed to be at low population levels (NEFSC 1998, in Normandeau 2006a). Tautog eggs |

and larvae have been observed in the PNPS entrainment sampling (Normandeau 2006a). |

Tautog have been periodically collected as part of the PNPS impingement sampling |

(Normandeau 2006b). |

Thorny skate (Amblyraja radiata)

The thorny skate occurs on both sides of the Atlantic Ocean (Packer et al. 2003c), and is one of

seven species of skates found throughout the western North Atlantic (Sosebee 2000c). Skates

are fished commercially, but with no distinction among the seven species (Packer et al. 2003c). |

Most commercial use of skates is for lobster bait, but two skates (including the thorny skate) are

used for human consumption (Packer et al. 2003c). Eggs of all skates are known to be

encapsulated in a leathery capsule that rests on the bottom (Sosebee 2000c; Packer et al.

2003c). The eggs hatch fully developed, so there is no larval stage (Sosebee 2000c; also

McEachran 2002, in Packer et al. 2003c). Based on the capture of females with fully formed

egg capsules, spawning is thought to occur throughout the year, but with a peak during the

summer (Templeman 1982a; McEachran 2002, in Packer et al. 2003c). The primary prey for the

thorny skate is fish, including haddock, sand lance, and redfish (Templeman 1982b, in Packer et

al. 2003c). Thorny skates may live up to 20 years (Templeman 1984, in Packer et al. 2003c).

In the western Atlantic, the thorny skate ranges from Greenland to South Carolina, and it is one

of the most common skates found within the Gulf of Maine (McEachran and Musick 1975, in

Packer et al. 2003c). Skates have been landed as bycatch in New England since the late

1960s, but were not directly targeted as a fishery until the 1980s. There is no stock |

differentiation among the skate species. The water depth of the thorny skate habitat can range |

from 18 to 1200 m (59 to 3937 ft) (McEachran 2002, in Packer et al. 2003c). Trawl surveys in

the Gulf of Maine found most adults in the range from 71 to 300 m (233 to 984 ft), and at

temperatures between 4 and 9 C (39.2 and 48.2EF) (Packer et al. 2003c). The species can be |

o

found over a variety of substrates, including sand, gravel, broken shell, pebbles, and soft mud

(Bigelow and Schroeder 1953, in Packer et al. 2003c). Skates do not migrate substantially, but

do generally move offshore in summer and early autumn, and onshore during winter and spring

(Sosebee 2000c).

The abundance of thorny skate is reported to be near historic lows, with a population of about 10

to 15 percent of the peak population in the early 1970s (Sosebee 2000c). The thorny skate was

first designated as a species of concern in 2004 (NMFS 2004c). In a 2000 stock assessment,

the thorny skate was considered to be overfished (NMFS 2000, in

Packer et al. 2003c). No life stages of the thorny skate have ever been observed in the PNPS

entrainment or impingement sampling.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-64 July 2007

Tilefish (Lopholatilus chamaeleonticeps)

Tilefish, also known as golden tilefish, is a burrowing fish that inhabits the outer continental shelf

from Nova Scotia to South America (Nitschke 2000). The tilefish began supporting a fishery in

the U.S. in 1879 (Steimle et al. 1999e). Tilefish eggs and larvae are buoyant and pelagic, and

are found over the outer continental shelf in the Mid-Atlantic Bight (Steimle et al. 1999e). As

they grow into juveniles, the tilefish descend to the bottom and occupy existing shelters or

burrows (Able et al. 1982; Freeman and Turner 1977, in Steimle et al. 1999e). As adults, the

tilefish either occupy existing shelter such as rocks or boulders, or dig their own burrows. The

burrowing habits of the tilefish are reported to modify significantly the topography of the outer

continental shelf (Able et al. 1982, in Steimle et al. 1999e). The adults become sexually mature

at an age of five to seven years (Grimes et al. 1988, in Steimle et al. 1999e). Information on

| spawning is sparse and is pair-specific, as male and female pairs are observed to share burrows

(Grimes et al. 1988, in Steimle et al. 1999e). Tilefish are reported to eat a large variety of

benthic and pelagic prey, including crabs, conger eels, bivalve mollusks, polycheates, and many

types of fish (Dooley 1978, in Steimle et al. 1999e).

They occupy submarine canyons, and are restricted to depths of 80 to 540 m (262 to 1772 ft)

| deep, in waters between 8 and 17 C (46.4 and 62.6EF) (Bigelow and Schroeder 1953; Freeman o

| and Turner 1977; Dooley 1978, in Steimle et al. 1999e). The tilefish does not appear to undergo

| any major migration (Freeman and Turner 1977; Grimes et al. 1986, in Steimle et al. 1999e). In

1999, Steimle et al. (1999e) summarized a variety of surveys to identify tilefish. In these reports,

tilefish were only identified in offshore areas, including submarine canyons. No tilefish in any life

stage were reported in Massachusetts Bay or the Gulf of Maine (Steimle et al. 1999e).

Tilefish are most commonly found from southern New England to the Mid-Atlantic region

(Nitschke 2000). The species is managed as two separate stocks, with one occurring in the MidAtlantic Bight and the other south of Cape Hatteras and into the Gulf of Mexico 

(Steimle et al. 1999e). The tilefish fishery established in 1879 was eliminated by a mass

mortality of tilefish between Nantucket and Maryland in 1882. This event killed an estimated 1.5

billion tilefish (Bigelow and Schroeder 1953, Dooley 1978, in Steimle et al. 1999e). The fishery

recovered by 1915, and has remained active ever since. In 1986, it was estimated that the

effects of fishing had been drastic, reducing stock size by a half to two-thirds 

(Turner 1986, in Steimle et al. 1999e). However, a 2005 stock assessment determined the

stock is considered to be at sustainable levels (i.e., the SSB and/or total stock biomass are

considered to be at levels greater than sustainable biomass thresholds, while the exploitation or

fishing pressure is less than the threshold of sustainable fishing pressure) (NMFS 2005b). No

life stages of the tilefish have ever been observed in the PNPS entrainment or impingement

sampling.
Plant and the Environment

July 2007 2-65 NUREG-1437, Supplement 29

White hake (Urophycis tenuis)

The white hake occurs from the Gulf of St. Lawrence to the Mid-Atlantic Bight, and at depths

from shallow estuaries to deep submarine canyons (Chang et al. 1999a). The species generally |

inhabits bottom waters, with either muddy or fine-grained sand substrates (Sosebee 2000a).

The eggs, larvae, and early juvenile stages of the white hake are pelagic (Chang et al. 1999a),

and are found in surface waters of the Gulf of Maine, Georges Bank, and southern New England

(NEFMC 1998a, in ENSR 2000). White hake reach sexual maturity at an age of about 1.5 years

(Chang et al. 1999a). The white hake spawning grounds are centered on the Gulf of 

St. Lawrence, the southern Georges Bank, and Mid-Atlantic Bight. However, the use of the Gulf |

of Maine as a spawning ground is reported to be negligible (Fahay and Able 1989, in Chang et

al. 1999a). Spawning occurs in shallow water over mud or fine-grained sand substrates.

Juvenile white hake feed mainly on polychaetes, shrimp, and other crustaceans, while the adults

feed primarily on crustaceans and other fish, including juvenile white hake (Langston et al. 1994, |

in Chang et al. 1999a).

White hake are distributed from the Gulf of St. Lawrence to Cape Hatteras, with the highest

concentrations in the Gulf of St. Lawrence, southern edge of the Grand Bank, Scotian Shelf,

Gulf of Maine, and Georges Bank (Chang et al. 1999a). White hake live at depths of 5 to 325 m

(16 to 1066 ft), usually at temperatures below 14 C (57.2EF) (NEFMC 1998a, Sosebee 1998, in |

o

ENSR 2000). Migration of adults occurs annually, with adults moving to shallower waters in the

spring to spawn, and then moving offshore in the autumn. A summary of annual NMFS Bottom

Trawl Survey data identified no white hake in Cape Cod Bay during the fall between 1979 and

2003, and only a few limited occurrences in the bay during the spring in those years

(GOMCML 2006).

The white hake fishery is managed under the NEFMC Northeast Multispecies FMP 

(Sosebee 2000a). Within U.S. waters, the Gulf of Maine and Georges Bank populations are

managed as separate stocks (Chang et al. 1999a). The populations of white hake in both areas

has fluctuated without a consistent trend, but neither stock was considered to be overfished in

1999 (Chang et al. 1999a). In 2005, the stock was considered to be overfished, and overfishing

was occurring (Sosebee 2005). In 2005, an analysis of juvenile populations resulted in a

proposal for the potential designation of HAPCs for the white hake, including areas within Cape

Cod Bay, adjacent to PNPS (Crawford et al. 2005). Eggs and larvae of the white hake have

been collected in the PNPS entrainment sampling. Juveniles and/or adults have also been

observed in the PNPS impingement sampling program.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-66 July 2007

Windowpane flounder (Scopthalmus aquosus)

| Windowpane flounder is a left-eyed, benthic flatfish species that inhabits estuaries, nearshore

waters, and the continental shelf in the western North Atlantic (Chang et al. 1999b). The

windowpane is not itself a target of commercial fishing, but it is caught as a bycatch in other

groundfish fisheries (Chang et al. 1999b). Both the eggs and larvae are pelagic, and exist in

| surface waters cooler than 20 C (68EF) (NEFMC 1998a, in ENSR 2000). Sexual maturity is o

reached at ages of three to four years (O'Brien et al. 1993). The windowpane flounder prefers a

soft substrate for spawning, and generally spawns between April and December, with peak

spawning activity in July and August on Georges Bank and in May in the Mid-Atlantic (NEFMC

1998a; Hendrickson 1998, in ENSR 2000). Spawning occurs in water temperatures from 6 to

| 21 C (42.8 to 69.8EF) (Bigelow and Schroeder 1953, in Chang et al. 1999b). The prey for the o

windowpane flounder is small benthic invertebrates, including polychaete worms and amphipods.

The species may also prey on small forage bony fish species (Langton and Bowman 1981, in

ENSR 2000).

The distribution of windowpane flounder includes the northwestern continental shelf in the Gulf

of Maine, Georges Bank, southern New England and the Mid-Atlantic south to Florida 

(NEFMC 1998a; Robins and Ray 1986; Hendrickson 1998, in ENSR 2000). South of Cape Cod,

the windowpane lives in bays and estuaries, including the Chesapeake Bay and Delaware Bay,

but north of Cape Cod, it lives in nearshore waters and is not documented within estuaries

| (Chang et al. 1999b). The species lives at shallow depths from 1 to 75 m (3 to 246 ft), and lives

within soft muddy and fine sand substrates (NEFMC 1998a, in ENSR 2000). Juveniles living in

shallow waters tend to move to deeper waters as they mature (Chang et al. 1999b). In studies

in Massachusetts, juveniles were most abundant in inshore waters at depths of less than 20 m

| (66 ft), at water temperatures between 5 to 12 C (41 to 53.6EF) in the spring, and between 12 to

o

| 19 C (53.6 to 66.2EF) in the fall (Chang et al. 1999b). o

| The windowpane flounder is managed as two separate stocks, a Gulf of Maine/Georges Bank

| stock and a southern New England/Mid-Atlantic Bight stock (Chang et al. 1999b). The

| windowpane flounder fishery is managed under the Northeast Multispecies FMP (Hendrickson

2000b). In the late 1990s, the stock in the Gulf of Maine/Georges Bank stock was considered to

| be fully exploited (Hendrickson 1998, in Chang et al. 1999b). In the 2004 assessment, it was

| concluded that the stock was at sustainable levels (i.e., the SSB and/or total stock biomass are

considered to be at levels greater than sustainable biomass thresholds, while the exploitation or

fishing pressure is less than the threshold of sustainable fishing pressure) (Hendrickson 2005).

However, in 2005, an analysis of juvenile populations resulted in a proposal for the potential

| designation of HAPCs for the windowpane flounder, though none were within Cape Cod Bay,

| (Crawford et al. 2005). Eggs and larvae of the windowpane flounder have been collected in the 
Plant and the Environment

July 2007 2-67 NUREG-1437, Supplement 29

PNPS entrainment sampling. Juveniles and/or adults have also been observed in the PNPS

impingement sampling program.

Winter flounder (Pseudopleuronectes americanus)

The winter flounder is a right-eyed flatfish species commonly found along the Atlantic coast from

Labrador to Georgia. The winter flounder commonly inhabits estuarine and coastal waters, but

may be found as deep as 128 m (420 ft) (Bulloch 1986). The various life stages of winter |

flounder can generally be found in areas where the bottom habitat has a substrate of mud, sand,

or gravel (NEFMC 1998b). Winter flounder eggs are demersal, adhesive, and stick together in

clusters. Hatching may occur in 2 to 3 weeks, depending upon the water temperature (Bulloch

1986, Pereira et al. 1999). Larvae are initially planktonic but as metamorphosis continues, they

settle to the bottom. Winter flounder have multiple larval stages, which are defined differently by |

different authors. For the purposes of this SEIS, there are four larval stages as defined in ENSR |

and MRI (2005). Newly metamorphosed young-of-the-year fish take up residence in shallow |

water. Winter flounder typically mature at three to four years. Spawning takes place at night

over sandy bottoms in shallow estuaries starting in mid December and ending in May, with a

peak in the February to March time frame. Spawning occurs at water temperatures between 34 |

and 50 F, with the optimum temperature around 40 F (Bulloch 1986). o o

Pereira et al. (1999) describes winter flounder as omnivorous or opportunistic feeders,

consuming a wide variety of prey, with polychaetes and amphipods making up the majority of

their diet. Typically adult winter flounder migrate inshore in the fall and early winter and spawn in

late winter and early spring; they then may leave inshore areas if the water temperature exceeds

15 C (59EF), although there may be exceptions to this due to water temperature and food |

o

availability (Pereira et al. 1999). Winter flounder may move significant distances

(Pereira et al. 1999). However, they also can exhibit a high degree of fidelity and, in general,

their movement patterns are localized (Nitschke et al. 2000). Studies done by PNPS have

shown that winter flounder in the area immediately surrounding PNPS (i.e., in Plymouth Outer

Harbor) have relatively localized movements and are basically confined to inshore waters

(Lawton et al. 1999), resulting in highly localized populations (Lawton et al. 2000). 

Winter flounder are managed as three distinct stocks: Gulf of Maine, Southern New England/

Mid-Atlantic, and Georges Bank (Pereira et al. 1999). Winter flounder in the local area

surrounding PNPS would be considered part of the Gulf of Maine stock. According to Nitschke

et al. (2000), the commercial landings of the winter flounder Gulf of Maine stock has continued

to trend downward, and the stock is at a low biomass level and is considered to be

overexploited. However, more recent data (through 2001) from the 36th Northeast Regional

Stock Assessment Workshop (NMFS 2003a) indicate that the stock is not overfished and that

overfishing is not occurring. The Northeast Fisheries Science Center (NEFSC) (NMFS 2003a)
Plant and the Environment 

 NUREG-1437, Supplement 29 2-68 July 2007

also states that recruitment to the stock has been near or above average since 1995. The 2005

Groundfish Assessment Review Meeting (GARM) also concluded, that based on 2004 data, the

Gulf of Maine winter flounder stock is not overfished and overfishing is not occurring. The SSB

| has also been steadily increasing (Figure 2-7); however, there is a high degree of uncertainty

| associated with these estimates (NEFSC 2005). 

| These estimates of the status of the Gulf of Marine Stock contrast with data from the local

| population (MRI 2006). Annual abundance estimates of winter flounder in western Cape Cod

| Bay have declined in recent years (Figure 2-8). The authors hypothesize that the low numbers,

particularly those associated with the 2005 data, may be partially due to natural and fishinginduced mortalities that precipitated a decline in the strong 1997 and 1998 year classes. Based

on a review of other resource assessments (NEFSC and MDMF abundance indices)

(Figures 2-9 and 2-10), the decline in eastern Cape Cod Bay may not just be local to the PNPS 

area (MRI 2006). Eggs and larvae of the winter flounder have been consistently collected in the

PNPS entrainment sampling and are one of the numerically dominant species in the entrainment

collections. Juveniles and/or adults also have been consistently collected in the PNPS

impingement sampling program. Over the last 25 years winter flounder has been one of the

numerically dominant impinged species.

Winter skate (Leucoraja ocellata)

The winter skate is one of seven species of skates found throughout the western North Atlantic

(Sosebee 2000c). The winter skate is often confused with the little skate due to similarity in

appearance, but the winter skate is not as abundant (McEachran and Musick 1975, in 

| Packer et al. 2003a). Skates are fished commercially, but with no distinction among the seven

species (Packer et al. 2003a). Most commercial use of skates is for lobster bait, but two skates

(including the winter skate) are used for human consumption (Packer et al. 2003a). Little

information on the life history of the winter skate exists. Eggs of all skates are known to be

encapsulated in a leathery capsule that rests on the bottom (Sosebee 2000c;

Packer et al. 2003a). The eggs hatch fully developed, so there is no larval stage 

(Sosebee 2000c; McEachran 2002, in Packer et al. 2003a). Off of Nova Scotia and in the Gulf

| of Maine, spawning occurs during summer and fall (Bigelow and Schroeder 1953, in Packer et

al. 2003a). The predominant food source for winter skates is polychaetes and amphipods, with

additional feeding upon decapods, isopods, bivalves, and fish (McEachran 1973, in 

Packer et al. 2003a). Fish species that are prey for the winter skate include smaller skates,

eels, alewives, blueback herring, menhaden, smelt, sand lance, chub mackerel 

(Scomber japonicus), butterfish, cunners, and silver hake (Bigelow and Schroeder 1953, in

Packer et al. 2003a).
Plant and the Environment

July 2007 2-69 NUREG-1437, Supplement 29

Figure 2-7. Gulf of Maine Winter Flounder

Spawning stock biomass (SSB) estimates during 1982 to 2004 reported in GARM (2005) and

MSY

the total biomass that produces the maximum sustainable yield for the fishery (B ) |

(As provided in: NEFMC 2006b) |

Figure 2-8. Winter Flounder Abundance Estimates in Northwestern Cape Cod Bay |

(As provided in: MRI 2006)
Plant and the Environment 

 NUREG-1437, Supplement 29 2-70 July 2007

|

| Figure 2-9. NMFS Winter Flounder Abundance in the Gulf of Maine 

| (As provided in: Normandeau 2006a)

|

Figure 2-10. MDMF Winter Flounder Abundance in the Gulf of Maine 

| (Recreated from: Normandeau 2006a)
Plant and the Environment

July 2007 2-71 NUREG-1437, Supplement 29

The winter skate is most commonly found on the Georges Bank and in the northern section of

the Mid-Atlantic Bight (McEachran and Musick 1975; in Packer et al. 2003a). Skates have been

landed as bycatch in New England since the late 1960s, but were not directly targeted as a

fishery until the 1980s. There is no stock differentiation among the skate species. Winter |

skates in the Gulf of Maine primarily live at depths of 46 to 64 m (151 to 210 ft) (Bigelow and

Schroeder 1953; McEachran 2002, in Packer et al. 2003a). The species can live in a variety of

water temperatures, and are reported near the Massachusetts coast in water from 1 to 20 C

o

(33.8 to 68EF) (Bigelow and Schroeder 1953; in Packer et al. 2003a). The species prefers |

sandy and gravel bottom substrates (Scott 1982a, in Packer et al. 2003a). Skates do not migrate

substantially, but do generally move offshore in summer and early autumn and onshore during

winter and spring (Sosebee 2000c).

In 2001, NMFS determined that the winter skate was in an overfished condition, and that

overfishing was occurring (NMFS 2001c). In 2002, a new assessment resulted in a change of

the status to not overfished (NMFS 2002b, in Packer et al. 2003a). No life stages of the winter

skate have ever been observed in the PNPS entrainment sampling. Juveniles and/or adults

have been observed in the PNPS impingement sampling program.

Witch flounder (Glyptocephalus cynoglossus)

The witch flounder is a deep-water, right-eyed flatfish that occurs on both sides of the Atlantic |

Ocean (Wigley et al. 2003). Prior to the 1980s, witch flounder was not targeted and was landed

mostly as bycatch (Wigley 2000b). Eggs are released on the bottom, but are pelagic and rise to

the surface. Larvae are also pelagic, and the species descend to the bottom as juveniles at the

age of 4 to 12 months (Bigelow and Schroeder 1953; Evseenko and Nevinsky 1975, in Cargnelli

et al. 1999d). Sexual maturity is reached at various ages, with a range of from five to nine years

(Beacham 1983, in Cargnelli et al. 1999d). Spawning occurs from March to November, with

peak spawning during the summer, at temperatures from 0 to 10 C (32 to 50EF) |

o

(Bigelow and Schroeder 1953, in Cargnelli et al. 1999d). The western and northern areas of the

Gulf of Maine are reported to be the most active spawning areas for the species 

(Burnett et al. 1992, in Cargnelli et al. 1999d). The primary prey for the witch flounder are

polychaetes and crustaceans, with additional contribution from mollusks and echinoderms

(Cargnelli et al. 1999d).

In U.S. waters, the witch flounder is common in the Gulf of Maine and lives in deeper areas of

the Georges Bank and along the continental shelf as far south as Cape Hatteras 

(Cargnelli et al. 1999d). The witch flounder lives in deep water, down to depths of 1500 m (4921

ft), in water about 2 to 9 C (35.6 to 48.2EF) (Lange and Lux 1978; Scott 1982b, in Cargnelli et |

o

al. 1999d). The witch flounder is associated with mud, silt, and clay substrates, and is rarely

found on any other bottom types (Powles and Kohler 1970; Martin and Drewry 1978; Scott |
Plant and the Environment 

 NUREG-1437, Supplement 29 2-72 July 2007

1982a, in Cargnelli et al. 1999d). All life stages of witch flounder are common in Massachusetts

| Bay. Eggs were found to be abundant in Massachusetts Bay in the months of May and June

| (Cargnelli et al. 1999d). Bottom trawl surveys and inshore surveys found the greatest

concentrations of juveniles on Stellwagen Bank in Massachusetts Bay. Adults were found in the

highest concentrations in Massachusetts Bay in the autumn, including some catches in Cape

Cod Bay (Cargnelli et al. 1999d).

The species is managed as a single stock under the NEFMC Northeast Multispecies FMP

(NEFMC 1993, in Cargnelli et al. 1999d; Wigley and Col 2005a). The stock extends from the

northern Gulf of Maine to southwestern Georges Bank (NMFS 2003b). As of 1997, the witch

flounder stock was reported to be in an overfished condition (NMFS 1997). In 2003, the stock

was reported to not be overfished, but overfishing was occurring (NMFS 2003b, Wigley et al.

2003). Eggs and larvae of the witch flounder have been collected in the PNPS entrainment

sampling. No life stages have been observed in the PNPS impingement sampling program.

Yellowtail flounder (Pleuronectes ferruginea)

The yellowtail flounder is a right-eyed, benthic flatfish that is an important commercial species

(Cadrin 2000b). Both the eggs and larvae of the yellowtail flounder reside in the water column,

and are found between mid March and July, peaking between April and June. Larvae may drift

| in surface waters before developing into juveniles, and dropping to the bottom 

(Overholtz and Cadrin 1998, in ENSR 2000). The median age for sexual maturity is about 2.6

years for females off of Cape Cod (O'Brien et al. 1993, in Johnson et al. 1999a). Spawning

occurs in the Gulf of Maine, Georges Bank, and southern New England shelf during the spring

and summer months (Overholtz and Cadrin 1998; NEFMC 1998a, in ENSR 2000). Adult

yellowtail flounder feed on small benthic invertebrates such as polychaete worms, isopods,

shrimp, and amphipods, and also can feed on small forage fish species 

(Cooper and Chapleau 1998, in ENSR 2000).

The yellowtail flounder ranges from Labrador to the Chesapeake Bay, and is most abundant in

the western Georges Bank, western Gulf of Maine, east of Cape Cod, and southern New

England (Johnson et al. 1999a). Mark-and-recapture studies have shown that yellowtail flounder

do not migrate, other than minor movements between shallow and deeper water in response to

seasonal temperature variation (Royce et al. 1959; Lux 1964, in Johnson et al. 1999a).

Yellowtail flounder typically live at depths of between 37 to 87 m (121 to 285 ft), with substrates

| of mud or sand (Cooper and Chapleau 1998; Overholtz and Cadrin 1998, in ENSR 2000).

| Adults live in waters ranging from 2 to 12 C (35.6 to 53.6EF) (Johnson et al. 1999a). In a MDMF o

bottom-trawl survey, both adults and juveniles were found to concentrate seasonally in coastal

waters from northwestern Cape Cod Bay to Ipswich Bay. Juveniles were found to migrate

inshore in Cape Cod Bay in the fall (Johnson et al. 1999a).
Plant and the Environment

July 2007 2-73 NUREG-1437, Supplement 29

In the U.S., the populations are managed as four separate stocks, including southern New

England, Georges Bank, Cape Cod, and Mid-Atlantic Bight (Johnson et al. 1999a). The |

yellowtail flounder fishery is managed under the NEFMC Northeast Multispecies FMP 

(Cadrin 2000b). Yellowtail flounder has been a major constituent of the commercial fishery since

the early 1930s. Population data evaluated by Johnson et al. (1999a) for all four stocks showed

significant variation through time, with increases and decreases occurring throughout the 1960s

through the 1990s. The Cape Cod/Gulf of Maine stock was considered to be at low biomass

and overexploited in 2001 (Cadrin et al. 2005). In 2005, an analysis of juvenile populations

resulted in a proposal for the potential designation of HAPCs for the yellowtail flounder, though

none were within Cape Cod Bay, (Crawford et al. 2005). Eggs and larvae of the yellowtail |

flounder have been collected in the PNPS entrainment sampling. Juveniles and/or adults have

also been observed in the PNPS impingement sampling program.

2.2.5.3.2 Pelagic Invertebrates

Longfin squid (Loligo pealei)

The longfin squid is a schooling species, which is distributed in the waters of the continental

shelf and slope from Newfoundland to the Gulf of Venezuela (Cadrin 2000a, in ENSR 2000).

During late autumn to winter, longfin squid migrate to warmer waters along the edge of the

continental shelf (Cadrin 2000a, in ENSR 2000). During the spring and early summer, the

species moves inshore to spawn (Cadrin 2000a, in ENSR 2000). The species is known to

spawn year round, which varies seasonally and geographically (Brodziak and Macy 1996; |

Hatfield and Cadrin 2002, in Jacobson 2005). Males can grow to reach more than 40 cm |

(16 in.) in dorsal-mantle length, even though the majority of squid collected in the commercial

fishery are smaller than 30 cm (12 in.) long (Cadrin 2000a). Food habits of longfin squid depend

on size; small individuals consume planktonic organisms (Vovk 1972; Tibbetts 1977, in Cargnelli

et al. 1999g) whereas larger individuals consume crustaceans and small fish (Vinogradov and

Noskov 1979, in Cargnelli et al. 1999g). Seasonal and inshore/offshore variances in the diets of

longfin squid were demonstrated by Maurer and Bowman (1985, in Cargnelli et al. 1999g). 

Longfin squid are typically observed in waters with temperatures of at least 9°C (48.2EF) (Lange |

and Sissenwine 1980, in Cargnelli et al. 1999g). 

Overfishing of longfin squid is an important issue due to the fact that the species recruits to the

population and to the spawning stock in the same year (Cadrin 2000a). During 1998, the stock

was reported to be approaching an overfished condition and overfishing was also occurring

(Cadrin 2000a). Based on data presented in the 2002 Assessment Status Summary, the stock

is not in an overfished condition, and overfishing is not occurring (NMFS 2002c). The longfin

squid has not been observed in the PNPS entrainment sampling program. It has been collected

within the impingement sampling program.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-74 July 2007

Shortfin squid (Illex illecebrosus)

The shortfin squid is highly migratory and is found primarily in the offshore waters of the

| continental shelf and slope from Florida to Labrador (Hendrickson and Holmes 2004).

Individuals experience an extensive spawning migration to warmer waters south of Cape

| Hatteras during the autumn (Hendrickson and Holmes 2004). Peak spawning occurs during the

winter, and larvae and juveniles drift northward in the warm waters of the Gulf Stream

| (Hendrickson 2000a in ENSR 2000). The squid that spawned throughout the winter migrate

| during late spring onto the continental shelf (Hendrickson 2000a in ENSR 2000). Shortfin squid

live for approximately one year and grow rapidly during the first few months of existence 

(NOAA 1998). Shortfin squid can reach dorsal-mantle lengths up to 35 cm (14 in.), even though

the majority of squid collected in the commercial fishery are smaller than 25 cm (10 in.)

| (Hendrickson and Holmes 2004). The diet of shortfin squid typically consists of fish and

crustaceans (Squires 1957; Froerman 1984; Mauer and Bowman 1985; Dawe 1988, in Cargnelli

et al. 1999h). 

Data collected during 1994 to 1998 demonstrated that the stock was probably not in an

overfished condition (Hendrickson 2000a). Based on data presented in the 2003 Advisory

Report, the stock did not experience overfishing during 1999 to 2002 (NMFS 2003b). However,

according to the 2005 Assessment Summary, the current stock was not able to be evaluated

due to the lack of reliable data for determining stock biomass and fishing mortality rate

(NMFS 2006a). The shortfin squid has not been observed in the PNPS entrainment or

impingement sampling program. 

2.2.5.3.3 Plankton

Phytoplankton

The western Cape Cod Bay phytoplankton community, including the surrounding area of PNPS,

seems to be more similar to the Gulf of Maine (to the north of Cape Cod) than to the

communities located south of the Cape (ENSR 2000). In the 1970s, two studies were performed

to identify the phytoplankton communities in the PNPS surrounding area (ENSR 2000). Various

samples were taken from the intake and discharge areas of PNPS and from a station positioned

1000 ft (305 meters) offshore during 1971 (ENSR 2000). A widespread study was also

conducted to identify phytoplankton entrained at the plant between 1973 and 1975 (Toner 1984,

in ENSR 2000). The samples gathered at the discharge were examined to determine the

onshore species composition and then compared to populations collected monthly at various

distances offshore (i.e., 0.25, 0.5, and 1 mi) between December 1974 and February 1975

(ENSR 2000). The 1971 onshore samples consisted of 46 species of phytoplankton and three

unidentifiable taxa (ENSR 2000). The offshore samples collected in 1974/1975 included 73
Plant and the Environment

July 2007 2-75 NUREG-1437, Supplement 29

taxa, with 50 identified to the species level (ENSR 2000). No significant difference in species

composition was detected between the onshore and offshore samples.

Based on these two studies, diatoms appear to be the most abundant taxa throughout the year

(Marshall 1978 in ENSR 2000). These studies have also demonstrated a seasonal pattern in the

phytoplankton communities adjacent to PNPS (ENSR 2000).

Phytoplankton density peaks were observed, which included two annual peaks, one in February

to March (11 million cells/L) referred to as the spring bloom, and a second peak was noted in

July (1 to 2 million cells/L) (ENSR 2000). The December/January densities were the lowest

noted, followed by April (ENSR 2000). These results are somewhat confirmed by Thomas et al. 

(2003) who used satellite-based imaging of the Gulf of Maine to evaluate chlorophyll levels,

detected both a spring and fall bloom. Thomas et al. (2003) also determined that seasonal

cycles in chlorophyll are dependent upon the relationship of tidal mixing, bathymetry, and

residual circulation with the most dominant seasonal cycles occurring in deeper basins. 

Zooplankton

New England zooplankton studies have focused on the Gulf of Maine and the Georges Bank

area southeast of Cape Cod (ENSR 2000). The effects of the Cape Cod Canal on the copepods

of Buzzards Bay and Cape Cod Bay were examined (Ankaru 1964, in ENSR 2000). During |

1970 and 1971, the samples collected from Cape Cod Bay in the surrounding area of PNPS

demonstrated a zooplankton community that was minimal during the winter months, followed by

increasing densities in the summer (ENSR 2000). Copepods, which included Pseudocalanus

elongates, Temora longicornus, and Acartia clause, dominated the zooplankton community

throughout this study (Stone and Webster 1975 in ENSR 2000). This study demonstrated

seasonal cycles for zooplankton abundances, attaining maximum densities in August and

minimum densities in January and February (ENSR 2000) (Figure 2-2).

2.2.5.3.4 Benthic Invertebrates |

Habitats found within the area of PNPS include both rocky and sandy intertidal and rocky and

sandy subtidal areas (ENSR 2000). Surveys of all four habitat types were included in the

long-term benthic monitoring program at PNPS (1974 to 1991), with sampling transects located

at Rocky Point, in the vicinity of the discharge canal, near White Horse Beach, and near |

Manomet Point (Davis and McGrath 1984; SAIC 1992 in ENSR 2000). 

The sandy intertidal areas close to PNPS, while limited, are typically composed of coarse gravel

overlying finer sands in a fairly high-energy environment (ENSR 2000). Interstitial organisms or

larger, mobile organisms, such as hermit crabs, participate in the limited faunal colonization
Plant and the Environment 

 NUREG-1437, Supplement 29 2-76 July 2007

(ENSR 2000). A discussion follows of monitoring studies for the other three habitat types: rocky

intertidal, rocky subtidal, and sandy subtidal (ENSR 2000).

The rocky intertidal habitat is composed of large boulders interspersed with smaller rocks and

patches of cobble, gravel, and coarse sand (ENSR 2000). The fauna in this zone are adjusted

to the extreme conditions associated with the tidal cycles, including the physical stresses of

temperature fluctuations, desiccation, and ice scouring (ENSR 2000). Populations also are

controlled by predation and competition for space (Menge 1976 in ENSR 2000). Rocky intertidal

samples were taken from late 1971 through mid 1979 (ENSR 2000). The barnacle Balanus

balanus is common throughout the area and is the primary macrofaunal organism in the upper

rocky intertidal zone (ENSR 2000). The gastropods Littorina littorea and L. obtusata 

are also frequent in this habitat. In the middle and lower intertidal zones, the blue mussel and

macroalgae replaced barnacles (ENSR 2000). Asterias spp. and the carnivorous gastropod

Nucella lapillus are regular predators of sessile species in this zone (ENSR 2000). The

holdfasts of the macroalgae supply a habitat for small polychaetes, mollusks, and amphipods,

including the sabellid polychaete Fabricia sabella and the amphipods Hyale nilsoni and

Caprella penantis (Davis and McGrath 1984 in ENSR 2000). Faunal densities typically ranged

| from 10 to 10 individuals/m (929 to 9290 individuals/ft ) (ENSR 2000). 4 5 2 2

The most heavily studied benthic habitat in the PNPS area is the rocky subtidal habitat 

(ENSR 2000). Sampling started in 1971 and continued through 1991 at Rocky Point, near the

discharge and Manomet Point. Crustaceans were the biggest taxonomic group collected in the

samples (ENSR 2000). The main crustaceans included 34 species of amphipods and also 30

species each of polychaetes and mollusks (ENSR 2000). Twelve percent of the total fauna was

represented by nemerteans, echinoderms, and anemones (ENSR 2000). The dominant 15

species represented 90 to 98 percent of the observed fauna at each of the three stations and

between 40 and 80 species represented the remaining 2 to 10 percent (ENSR 2000). Total

faunal densities in the rocky subtidal habitat fluctuated widely from 1983 through 1991, mainly

| because of periodic mass settlements of blue mussel (Mytilus edulis) (ENSR 2000). Densities

| still demonstrated a seasonal pattern and a long-term cyclic pattern even without blue mussel

| data (ENSR 2000). The data reveal a seasonal pattern of low diversity in the spring followed by

higher values in the fall (ENSR 2000). Rocky Point typically had the highest diversity, even

though Manomet Point samples had very similar results (ENSR 2000).

Sandy subtidal habitat is extensive all through western Cape Cod Bay (ENSR 2000). The area

immediately surrounding PNPS is predominantly sand, although just to the north in the Rocky

Point area, rock ledges and boulders are found (ENSR 2000).
Plant and the Environment

July 2007 2-77 NUREG-1437, Supplement 29

At White Horse Beach and close to the discharge area at PNPS, transects of sandy subtidal

locations were established (ENSR 2000). Two sites were established at each of the sampling

locations, one located at the 3 m (10 ft) depth and the other at the 9 m (30 ft) depth |

(ENSR 2000). Quantitative sampling was performed at these locations from 1971 through 

1979 (ENSR 2000). Amphipods Acanthohaustorius millsi and Protohaustorius deichmannae

were the most prevalent species reported, regularly resulting in 75 percent of the total individuals

in a sample (ENSR 2000). The sevenspine bay shrimp (Crangon septemspinosus), the northern |

moon snail (Lunatia heros), and the sand dollar Echinarachnius parma were other species

reported in this environment (ENSR 2000). These species, while prevalent and dispersed |

throughout the area, were not present in significant quantities (ENSR 2000). Davis and McGrath

(1984 in ENSR 2000) demonstrated that faunal densities ranged from 10

3 4 to 10 individuals/m2

(93 to 929 individuals / ft ) at both the 3 m (10 ft) and 9.1 m (30 ft) depths; these densities are |

2

approximately an order of magnitude lower than those found at the rocky subtidal stations.

In addition to the benthic species described above, there are several species of benthic |

macroinvertebrates, which are found in the area and are considered to be important to the |

benthic community of western Cape Cod Bay. These include the American lobster 

(Homarus americanus), Atlantic sea scallop (Placopecten magellanicus), surf clam 

(Spisula solidissima), and ocean quahog (Arctica islandica). Discussions of the ecology, life

history, and status of these species follow.

American lobster (Homarus americanus)

The American lobster is a large, mobile, benthic macroinvertebrate of the sublittoral zone (ENSR

2000). It is a marine crustacean that occurs in a wide range of habitats along the continental

shelf and upper slope of the western North Atlantic from Labrador to Cape Hatteras (ENSR

2000). The primary depth range is from the sublittoral fringe to 50 m (164 ft), but lobster may be

fished out to depths of 700 m (2297 ft) (ENSR 2000). Off the coast of Newfoundland to Maine,

the largest numbers of this species occur near the middle of this range, where ambient bottom

water temperatures typically range from -2.2 to 23.9EC (28 to 75EF) (McLeese and Wilder 1958 |

in ENSR 2000). Changes in temperature initiate seasonal migrations to offshore waters in the

fall and inshore waters in the spring (McLeese and Wilder 1958 in ENSR 2000) to reach

temperatures for proper synchrony of molting and reproductive cycles (Harding 1992 in ENSR

2000). 

The majority of lobster populations hatch from mid June through September (Perkins 1972, in

ENSR 2000). The typical hatching process of lobsters was documented by Sherman and Lewis

(1967) as occurring from June through August as water temperatures range from 54 to 59EF

(12.2 to 15EC) (ENSR 2000). The early larval stages I, II, and III are planktonic, lasting from 6 to

8 weeks, and stage IV postlarvae, also planktonic, metamorphose into adult shape and start to
Plant and the Environment 

 NUREG-1437, Supplement 29 2-78 July 2007

demonstrate actions that result in the lobster settling to the bottom (ENSR 2000). The newly 

settled juveniles reside in burrows, steadily adjusting to life on the surface of the substrate

(ENSR 2000).

Various special studies relating to the lobster have been performed within the PNPS area due to

the commercial importance of this species (ENSR 2000). Results of studies performed from

1974 to 1977 on the seasonal occurrence, abundance, and distribution of larval lobsters

proposed that a major percentage of the larval lobsters discovered in Cape Cod Bay in June

may have traveled through the Cape Cod Canal due to the warmer temperatures favorable to

hatching (ENSR 2000). Matthiessen (1984) proposes that the Cape Cod Canal may be a major

source of recruitment to the Cape Cod Bay lobster stocks due to the intricate dispersal patterns

(ENSR 2000). From 1970 to 1977, in the PNPS area, a tag and retrieval study was performed to

examine the movement and growth of sublegal, sexually immature lobsters that were captured

and released (Lawton et al. 1984, in ENSR 2000). Examination of the data implied that

movement of this population was very restricted, since 71 percent of the returns were recaptured

on the ledges where they had initially been released (ENSR 2000). The remaining 29 percent

had moved from 4.8 to 45 km (3.0 to 28 mi), in various directions such as northwest towards

Boston and east southeast through the Cape Cod Bay (ENSR 2000). Comparable research

implied that there was a moderate seasonal movement to inshore waters in the spring and

offshore waters in the fall, but not as great as the migrations of larger, sexually mature

individuals (Lawton et al.1984 in ENSR 2000). 

The second largest U.S. lobster fishery is the Massachusetts lobster fishery, accounting for

about 28 percent of the U.S. landings (Estrella and Morissey 1997, in ENSR 2000).

Predominantly during the months of March and November, the lobster is prevalent in western

Cape Cod Bay and enhances an important commercial fishery in the PNPS area

(Lawton et al. 1984, in ENSR 2000). The most economically valuable fishery in Massachusetts

territorial waters is the commercial lobster fishery in the PNPS area (ENSR 2000). American

lobster larvae have been collected in the PNPS entrainment sampling. Juveniles and/or adults

have been observed in the PNPS impingement sampling program.

Atlantic sea scallop (Placopecten magellanicus)

The Atlantic sea scallop is a bivalve distributed along the northwestern North Atlantic shelf

between the Gulf of St. Lawrence and Cape Hatteras (Hart and Chute 2004). North of Cape

Cod, the sea scallop is generally found at depths of less than 20 m (65 ft) on hard substrates of

cobble, shell litter, or coarse gravel/sand (NEFMC 1998a; Lai and Rago 1998, in ENSR 2000).

Some sea scallops begin reaching sexual maturity at age 2; however, most do not reach sexual

maturity until age 3 (Hart and Chute 2004). Spawning season begins in May and extends

through October. Peak spawning activity depends on location. Spawning peaks between May
Plant and the Environment

July 2007 2-79 NUREG-1437, Supplement 29

and June in the mid Atlantic and in September and October in Georges Bank, usually in water

temperatures below 16EC (60.8EF) (NEFMC 1998a). Scallops spawn as many as one million |

eggs per year, depending on the size of the female (MacKenzie 1979, in Hart and Chute 2004). |

Eggs are not buoyant and remain on the substrate until hatching into free swimming larvae

(NEFMC 1998a). Larvae occupy pelagic waters and bottom habitats of gravel, shell litter, algae,

or sedentary benthic infauna (NEFMC 1998a). Sea scallops are suspension filter feeders, and

their diet typically consists of phytoplankton and microzooplankton (Hart and Chute 2004). 

The Atlantic sea scallop supports one of the most valued shellfish fisheries in the U.S. 

(Hart and Chute 2004). Based on the 2004 stock assessment, the stock in the area appears to

be healthy with recent landings data being the highest on record and recruitment to the stock

being above average (NEFSC 2004). No life stages of the Atlantic sea scallop have ever been

observed in the PNPS entrainment or impingement sampling.

Cancer crabs (Cancer spp.)

Two species of cancer crabs found in Massachusetts are the rock crab (Cancer irroratus) and

the Jonah crab (C. borealis). Both species are distributed from Nova Scotia to the southeastern

U.S. (Estrella undated). All species of cancer crabs share similar life history characteristics. 

Eggs undergo a development period of several weeks, and after hatching, the larvae are

planktonic. The larvae advance through six stages of successive increases in size by molting, a

process which take several weeks. Once the larvae reach the first crab stage (first instar), they

sink to the bottom and begin their benthic phase. Both species become sexually mature within

one to two years. Mating occurs while they are in the soft-shell molt condition, usually in winter

(CRWQCB 2004). |

Rock crabs exist in rocky habitats, but can be displaced onto sandy habitat by shelter-space

competition with Jonah crabs and the American lobster (Estrella undated). Rock crabs are

found in intertidal habitats north of Cape Cod, and in progressively deeper water farther south

along the Atlantic coast (Gosner 1978). Jonah crabs live in exposed locations on rocky coasts,

but can also be found on muddy bottom substrates in deeper waters. Both species are

commercially fished within Massachusetts, and the Commonwealth places restrictions on

landings from December 1 to March 31, which includes the rock crab’s molting period. The

population of rock crabs within Massachusetts is at or below its median population for the past

24 years, while the Jonah crab population is considered to be stable (Estrella undated). Cancer

crabs are frequently observed in the PNPS impingement monitoring program 

(Normandeau 2006b). Cancer crabs have been collected as part of the PNPS impingement |

monitoring program; however, they have not been observed in the PNPS entrainment monitoring

program.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-80 July 2007

Sevenspine bay shrimp (Sand shrimp) (Crangon septemspinous )

The sevenspine bay shrimp, also known as the sand shrimp, is an ecologically important species

of coastal and estuarine waters of the western Atlantic. The range of the species extends from

the northern Gulf of St. Lawrence to Florida (Squires 1996 in Locke et. al 2005). The species

lives in shallow subtidal areas up to 90 m (295 ft) deep, and up to the low tide line (Gosner

1978). The species prefers sandy bottoms and eelgrass beds, but mostly lives at the sedimentwater interface, as opposed to burrowing (Gosner 1978).

| Sevenspine bay shrimp are the numerically dominant invertebrate species collected as part of

| the PNPS impingement sampling (Normandeau 2006b). They have not been collected as part

| of the entrainment sampling at PNPS (Normandeau 2006b).

Ocean quahog (Arctica islandica)

The ocean quahog is a bivalve mollusk distributed from Newfoundland to Cape Hatteras at

depths of up to 256 m (840 ft). In the Gulf of Maine region, they are found in relatively

nearshore waters (Weinberg 2001). They are among the longest lived and slowest growing of

marine bivalves and may reach an age of 225 years (Cargnelli et al.1999f). Similar to surf

clams, they are planktivorous, siphon feeders and are preyed upon by moon snails, boring

snails, and predatory fish such as haddock and cod. (Cargnelli et al.1999f). Estimates for

attaining sexual maturity have ranged from 9 to 13 years (Cargnelli et al.1999f). No life stages

of the ocean quahog have ever been observed in the PNPS entrainment or impingement

sampling.

Surf clam (Spisula solidissima)

The surf clam is a bivalve mollusk that is distributed in waters of the western North Atlantic from

the Gulf of St. Lawrence to Cape Hatteras (Cargnelli et al.1999b). Surf clams inhabit sandy

bottom habitats and are most common at depths of 8 to 66 m (26 to 217 ft) in the turbulent areas

beyond the breaker zone (Cargnelli et al. 1999b). Surf clams are planktivorous, siphon feeders

including diatoms and ciliates (Cargnelli et al.1999b). They are preyed upon by moon snails,

boring snails, and predatory fish such as haddock and cod. Surf clams are capable of

reproduction in their first year of life, although they may not reach full maturity until the second

year (Weinberg 2000). Water currents in areas where planktonic surf clam larvae live are

important in determining eventual patterns of distribution and settlement for developing juveniles

(ENSR 2000). Based on the 2003 stock assessment, the stock throughout the entire Exclusive

Economic Zone (EEZ) is not overfished and overfishing is not occurring (NMFS 2003b). No life

stages of the surf clam have ever been observed in the PNPS entrainment or impingement

sampling.
Plant and the Environment

July 2007 2-81 NUREG-1437, Supplement 29

2.2.5.3.5 Marine Aquatic Plants

The marine environment in the vicinity of PNPS is typical of shallow, exposed areas in western

Cape Cod Bay and is characterized by sand and gravel interspersed with large rocks and

boulders. Several surveys of macroalgae have been conducted at PNPS and have included

intertidal (through 1978) and subtidal (through 1991) qualitative and quantitative sampling.

In the intertidal zone, qualitative sampling was performed for four years, beginning in October

1974, at four locations: Rocky Point, northwest of the PNPS discharge canal, White Horse

Beach, and Manomet Point. At each station, a 6-in.-wide transect extending from the mean high

to the mean low water levels was established. A total of 137 species was recorded, including

two cyanophyta, 40 chlorophyta, 48 phaeophyta, and 47 rhodophyta. The number of species

per station over the sampling period ranged from a low of 97 at Manomet Point to a high of 111

at the station discharge. Species richness generally ranged between 60 and 70 representative

taxa each year, with a greater number of species recorded after the first year of sampling. The

dominant algae at all elevations were the brown fucoids Ascophyllum nodosum and Fucus

vesiculosus. The greatest cover by Ascophyllum was at the Manomet Point and Rocky Point

station, whereas Fucus was more common at the discharge location. Five species were

recorded only at the discharge location: Enteromorpha aragonensis, Bryopsis plumosa, Codium

fragile, Gracilaria follifera, and Soliera tenera. These species are known to prefer the warmer

waters south of Cape Cod, and their presence at this location was probably a consequence of

the thermal discharge (ENSR 2000).

In the subtidal zone, the long-term benthic monitoring program at PNPS (1974 to 1991) included

surveys of subtidal macroalgae at three sampling sites: Rocky Point, near the PNPS discharge

canal, and Manomet Point (Grocki 1984; SAIC 1992). Over 112 species of algae were identified

from the samples taken over the course of the monitoring program. The subtidal macrophytes

are dominated by the rhodophyta or red algae. There are no reports of eelgrass (Zostera

marina) in the immediate vicinity of PNPS. Irish moss (Chondrus crispus) is the dominant

subtidal macrophyte in Cape Cod Bay and is the chief component of the subtidal flora near

PNPS. Depending on depth, Irish moss covers up to 90 percent of the available substrate,

attaining a maximum density between MLW and 4.3 m (14 ft) below MLW. |

Irish moss is a benthic, marine red alga found from New Jersey to Labrador, with highest

abundances near the center of this range. It inhabits rocky substrates from below MLW to a

depth of 38 m (125 ft), with maximum densities in the PNPS area occurring between MLW and a

depth of 6 m (19.7 ft). The lower limits of its distribution are controlled by light, water

transparency, availability of substrate, and competition for space. It is euryhaline, occurring in

salinities between 8 and 40 ppt, and it is a dominant component of the subtidal flora in the

vicinity of PNPS (ENSR 2000).
Plant and the Environment 

 NUREG-1437, Supplement 29 2-82 July 2007

| The PNPS thermal discharge is located in the middle of an Irish moss commercial bed. The

immediate area of the discharge is denuded; just beyond the denuded area is an area of stunted

or sparse growth of Irish moss. Through 1998, the largest affected area ever observed was in

1997. This included denuded areas as well as areas of stunted or sparse growth, covered about

| 1.1 ac (ENSR 2000).

Irish moss is an important commercial species that has been harvested along the western shore

| of Cape Cod Bay since the 1800s (ENSR 2000). The seaweed is harvested as a source of

carrageenan, a hydrocolloid unique for its jellying, suspension, and viscosity properties. 

Carrageenan is widely used as a suspending and thickening agent in the brewing, baking,

pharmaceutical, and dairy industries. The harvesting season extends from early June through

August, with peak harvest usually occurring in July. However, since the 1990s, harvesting of

Irish moss has been virtually nonexistent in the Plymouth area (Lawton et al.1992).

At greater depths, Irish moss density decreases and phyllophora (Phyllophora brodiaei and

P. membranifolia) become the dominant macrophytes. Lamineria sp., Corrallina officinalis,

Polydesrotundus sp., and Lithothamnion sp. are the remaining conspicuous representatives of

the subtidal algal flora. Epiphytic species include the rhodophytes Ceramium rubrum,

Cystoclonium purpureum, and Spermothamnion repens. The warm-water species Gracilaria

tikvahiae has been recorded on several occasions, primarily in the area of the discharge canal. 

No life stages of the Irish moss have been observed in the impingement monitoring; however,

| spores have been observed in the entrainment sampling (ENSR 2000).

2.2.5.3.6 Marine Mammals

A variety of marine mammals may occur within Cape Cod Bay for at least a part of their life

cycle. All marine mammals are protected under the Marine Mammal Protection Act (MMPA) of

| 1972, as amended. The MMPA prohibits, with certain exceptions, the direct or indirect taking of

marine mammals. Several of these marine mammals species are Federally listed whales, which

are additionally protected under the Endangered Species Act of 1976, as amended (ESA). Such

| species are discussed further in Section 2.2.5.3.7 as well as in the biological assessment

| provided in Appendix E. The Section 7 consultation with NMFS is ongoing.

|

The two major groups of marine mammals that may occur within Cape Cod Bay include the

cetaceans (whales, dolphins, and porpoises) and pinnipeds (seals, sea lions, and walruses). 

| Among the non-Federally listed whale species that may occur in this area are beluga whale

(Delphinapterus leucas), killer whale (Orcinus orca), minke whale (Balaenoptera acutorostrata),

| and long-finned pilot whale (Globicephala melaena) (Provincetown Center for Coastal Studies
Plant and the Environment

July 2007 2-83 NUREG-1437, Supplement 29

2006, Short and Michelin 2006). Of these four species only the long-finned pilot whale and the |

minke whale are seen with any regularity in the Gulf of Maine, which includes Cape Cod Bay |

(Provincetown Center for Coastal Studies 2006, Short and Michelin 2006).

Non-Federally listed dolphin and porpoise species that may occur in this area include the whitebeaked dolphin (Lagenorhynchus albirostris), Atlantic white-sided dolphin (L. acutus), common

dolphin (Delphinus delphis), bottlenose dolphin (Tursiops truncatus), Risso’s dolphin (Grampus 

griseus), striped dolphin (Stenella coeruleoalba), and the harbor porpoise |

(Phocoena phocoena) (Provincetown Center for Coastal Studies 2006). Of these seven |

species, only the Atlantic white-sided dolphin and the harbor porpoise are regularly observed in

the Gulf of Maine (Provincetown Center for Coastal Studies 2006). Both of these species are |

also commonly observed in Cape Cod Bay (Short and Michelin 2006).

Sea lions and walruses are not found in Gulf of Maine; thus, the only pinnipeds potentially found

in Cape Cod Bay would be the true seals. Five species of seals have been observed in the Gulf

of Maine. These include harbor seals (Phoca vitulina), gray seals (Halichoerus grypus), harp

seals (P. groenlandica), hooded seals (Cystophora cristata), and ringed seals (P. hispida)

(Provincetown Center for Coastal Studies 2006). Both the gray seal and the harbor seal are |

commonly observed in Cape Cod Bay (Short and Michelin 2006).

There are no known occurrences of PNPS operations affecting any marine mammals.

2.2.5.3.7 Federally Listed Anadromous and Marine Species |

This section provides information on marine aquatic species that are protected by Federal and

State laws. Protected aquatic species that occur in freshwater habitats on the mainland, as well

as birds that forage in the marine environment, are discussed as terrestrial resources in Section

2.2.6.2. Protected marine species include those that are Federally protected under the ESA,

and managed by the U.S. Fish and Wildlife Service (FWS) and/or the NMFS. Also included are

marine species listed as endangered, threatened, or special concern species by the

Commonwealth of Massachusetts. Eleven Federally and/or State-listed marine species could

occur in Cape Cod Bay in the vicinity of PNPS, including five whales, four sea turtles, and two

fishes (NMFS 2006c; NHESP 2006a). These listed marine aquatic species that have the |

potential to occur in the vicinity of the PNPS site are presented in Table 2-4. 

Four listed species of sea turtle may occur in Cape Cod Bay: loggerhead (Caretta caretta),

Kemp’s ridley (Lepidochelys kempii), leatherback (Dermochelys coriacea), and green (Chelonia

mydas) turtles. The leatherback and Kemp’s ridley turtles are listed as endangered. The green

turtle is listed as endangered in its breeding populations in Florida and threatened in other areas

of the U.S. The loggerhead turtle is listed as threatened.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-84 July 2007

| Table 2-4. Anadromous and Marine Threatened or Endangered Species

Scientific Name Common Name Federal Status Massachusetts

Status

TURTLES

Caretta caretta loggerhead turtle Threatened Threatened

Chelonia mydas green turtle Threatened (endangered in FL) Threatened

Dermochelys coriacea leatherback turtle Endangered Endangered

Lepidochelys kempii Kemp’s ridley turtle Endangered Endangered

W HALES

Balaenoptera borealis sei whale Endangered Endangered

Balaenoptera physalus fin whale Endangered Endangered

Eubalaena glacialis North Atlantic 

right whale

Endangered Endangered

Megaptera novaengliae humpback whale Endangered Endangered

Physeter catadon sperm whale Endangered Endangered (a)

FISH

Acipenser brevirostrum shortnose sturgeon Endangered Endangered

Acipenser oxyrinchus Atlantic sturgeon not listed Endangered

| The sperm whale has two accepted scientific names: Physeter catadon and P. macrocephalus.

(a)

Source: FW S 2006b

Sea turtles are only rarely found along the Massachusetts coast, and are primarily limited to

| individual juvenile "wanderers" (Prescott 2000 in Entergy 2006a). Many sea turtle species

migrate north in summer months, and may be found in Cape Cod Bay. Loggerhead turtles

inhabit neritic habitats in nearshore coastal areas, including bays, sounds, and estuaries in

Massachusetts (NMFS 2006d). Kemp’s ridley turtles can live in water temperatures as low as

| 11 C (51.8 F) and may be present in New England waters from June 1 to November 30, when o o

| water temperatures exceed 16 C (60.8 F) (NMFS 2006c). Leatherback turtles are expected to

o o

be present in New England waters in the summer months (NMFS 2006c). Green sea turtles are

| expected to be present in New England waters only sporadically (NMFS 2006c).

In late fall and winter, sea turtles still present in the bay may become cold-stunned and wash

| ashore (Entergy 2006a). This typically includes fewer than 20 sea turtles in any given year. The

largest incident recorded was in the winter of 1999 to 2000, when a total of 277 sea turtles were

| found on Cape Cod beaches (Entergy 2006a). In 2003, the total number of turtles found

stranded was 89 (Mass Audubon 2003 in Entergy 2006a). Records have been maintained on
Plant and the Environment

July 2007 2-85 NUREG-1437, Supplement 29

turtle strandings in Massachusetts for 25 years, and in that time, only one sea turtle was |

stranded in the Plymouth area (Entergy 2006a). This incident occurred in November 2003, when

a small (approximately 50 pounds) loggerhead turtle was stranded on Priscilla Beach

approximately 0.63 mi south of PNPS (Prescott 2005 in Entergy 2006a). |

Six different species of great whales migrate along the Massachusetts coast, with the largest

number sighted in the spring on Stellwagen Bank off of the tip of Cape Cod (Entergy 2006a).

The most common species seen in this area are minke, fin, and humpback whales (Entergy |

2006a). Of the six species, three endangered great whale species are found seasonally in New

England waters and have been documented in Cape Cod Bay: the North Atlantic right whale

(Eubalaena glacialis), humpback whale, and fin whale. In addition, two other endangered

species, the sei whale (B. borealis) and sperm whale (Physter catodon), are known to migrate in

New England waters off of the coast of Massachusetts.

Right whales may be found in Massachusetts and Cape Cod Bays throughout the year 

(Brown et al. 2002, in Short and Michelin 2006), and Cape Cod Bay has been designated as

critical habitat for the species (Entergy 2006a). Right whales have been documented in the

nearshore waters of Massachusetts from December through June, and are likely to be present in

Cape Cod Bay from December 15 to April 15 (NMFS 2006c). North Atlantic right whales are the

most critically endangered whale species in the Atlantic with population estimates of

approximately 300 individuals. Humpback whales may be found off of the coast of

Massachusetts during the period from March 15 to November 30 (NMFS 2006c). Humpback

whales are documented in the Stellwagen Bank area from mid April to November, with a peak

abundance in May and June (CETAP 1982, in Short and Michelin 2006). Fin whales are the

most frequently sighted endangered whale species found in Massachusetts and Cape Cod Bays

(EPA 1993 in, Short and Michelin 2006). Sei whales are only rarely sighted in Massachusetts

and Cape Cod Bays (EPA 1993, in Short and Michelin 2006). Sperm whales may be seasonally

present in New England waters, but are typically found in deeper offshore waters (NMFS 2006c).

Although these species have been documented in Cape Cod Bay and/or coastal Massachusetts

waters, no whales have been observed in the shallow waters off PNPS or in the intake and

discharge areas by Boston Edison or Entergy biologists since biological monitoring began in the |

late 1960s (Entergy 2006a).

Two species of fish are State-listed as endangered in Massachusetts: the shortnose sturgeon

(Acipenser brevirostrum) and the Atlantic sturgeon (A. oxyrinchus). The shortnose sturgeon is

also Federally listed as endangered by the FWS. 

The shortnose sturgeon is much smaller than the Atlantic sturgeon, rarely exceeding 3 ft in

length. It is often confused with the Atlantic sturgeon, but the two species can be distinguished
Plant and the Environment 

 NUREG-1437, Supplement 29 2-86 July 2007

by comparing the widths of the mouth. The shortnose sturgeon has a much wider mouth than

the Atlantic sturgeon. The shortnose sturgeon is amphidromous, which indicates that the fish

spawns in freshwater, but regularly enters marine and freshwater habitats during its lifespan. 

The shortnose sturgeon spawns in fast-flowing, rocky rivers in April and May. There are three

known shortnose sturgeon populations in Massachusetts: one in the Merrimack River in

northeastern Massachusetts and two in the Connecticut River in the western portion of the state. 

There are no known occurrences of the shortnose sturgeon in Plymouth or the surrounding area

(NHESP 2006b).

The Atlantic sturgeon is a very large anadromous fish that averages 6 to 9 ft in length, but can

exceed a length of 13 ft and a weight of 800 pounds. Spawning occurs generally in rocky, fastflowing rivers in May and June, slightly later than the shortnose sturgeon. Populations of Atlantic

sturgeon have been documented in the Merrimack and Taunton Rivers in eastern

Massachusetts; however, none have been observed in the Plymouth area (NHESP 2006b). 

2.2.6 Terrestrial and Freshwater Aquatic Resources

The PNPS site is located within and near the western border of the Atlantic Coastal Pine Barrens

ecoregion, which extends in Massachusetts from Plymouth to the tip of Cape Cod and the

islands of Martha’s Vineyard and Nantucket. The site is in an area of transition between this

ecoregion and the Northeastern Coastal Zone ecoregion, which extends to the north and west

and has a more irregular topography that includes hills and concentrations of glacial lakes. The

coarse-grained, nutrient-poor soils of the area currently support temperate mixed broadleaf and

coniferous forests dominated by oak and pine, similar to the forests that existed in the area

historically (EPA 2006a). Thirteen sub-ecoregions have been delineated within Massachusetts.

The PNPS site is within the Cape Cod/Long Island sub-ecoregion, which is characterized by

terminal glacial moraines and outwash plains, coastal deposits, elevations less than 200 ft, a

moderate maritime climate, and typical vegetation of stunted oak and pine forests 

(Swain and Kearsley 2001).

The vegetation communities that occur in the Massachusetts sub-ecoregions have been

classified into 105 community types (Swain and Kearsley 2001). These natural communities

have been mapped by the Massachusetts Office of Geographic and Environmental Information

using interpretation of aerial photography flown in the spring of 1999 and 2000 in conjunction

with field information from local ecologists and community information from the NHESP of the

Massachusetts Division of Fisheries and Wildlife (MDFW). The community maps are available

online from the Massachusetts Geographic Information System (MassGIS 2006). These 

natural community maps of the site and vicinity provide information on a local scale about the

vegetation communities and, indirectly, the animals they support, which may include both

common and rare species.
Plant and the Environment

July 2007 2-87 NUREG-1437, Supplement 29

Among the natural communities monitored and mapped by the NHESP are vernal pools, which

are small, shallow ponds that are seasonally to semi-permanently flooded basin depressions

characterized by annual or semi-annual periods of dryness and a lack of fish. NHESP has a |

program to identify potential vernal pools and to certify, based on official guidelines, those shown

by field data to function as vernal pools (MassGIS 2006). Review of the data layer for certified

vernal pools indicated there are none present within the PNPS site or along the transmission line

ROW.

2.2.6.1 Description of Site Terrestrial and Freshwater Aquatic Environments

An aerial photograph of the PNPS facility and its environs is shown in Figure 2-3. The

approximately 140-ac PNPS site includes a central developed area that contains the generating

facilities, switchyard, warehouses, office buildings, and parking lots. Prior to construction of

PNPS, the developed area was occupied by a private estate. The surrounding areas to the

north, west, and south are mainly undeveloped and wooded. The western shoreline of Cape

Cod Bay forms the northern and eastern boundaries of the site. From the shoreline to the most

inland boundary of the site along Rocky Hill Road (approximately in bands that parallel the

shoreline), at least six natural community types occur: coastal beach, marine intertidal rocky

shore, maritime erosional cliff, maritime shrubland, maritime oak-holly forest, and coastal forest. 

The maritime shrubland, maritime forest, and coastal forest communities grade into each other

and into more upland forests (Swain and Kearsley 2001; MassGIS 2006). 

A coastal beach community occurs in the intertidal zone along the shoreline north and south of

the developed area of the site. The beach substrate is sand, gravel, and scattered rocks, which

supports only sparse, non-vascular plants (algae) in this high-energy environment affected by

waves and tides. An area of marine intertidal rocky shore community, which also supports algae

and lacks vascular plants, occurs along a portion of the intake embayment shoreline (Swain and

Kearsley 2001; MassGIS 2006). The riprap covering the man-made banks of the intake

embayment, the breakwaters, and the discharge canal provides similar habitat. An area of

sandy beach also occurs at the western end of the intake embayment.

Along the shoreline to the north and south of the developed areas, bluffs and cliffs rise 10 to 40

ft above the beach. In the northern segment of the shoreline, the cliffs immediately above the

beach have been classified as a maritime erosional cliff community. The unconsolidated cliff

face is eroding and is within the salt spray zone. Consequently, the vegetation of this

community is very sparse but may include poison ivy (Toxicodendron radicans), Virginia creeper

(Parthenocissus quinquefolia), bayberry (Myrica pennsylvanica), sweet fern (Comptonia

peregrina), and greenbrier (Smilax rotundifolia) (Swain and Kearsley 2001; MassGIS 2006).
Plant and the Environment 

 NUREG-1437, Supplement 29 2-88 July 2007

Located inland and above the beach, bluffs, and cliffs along the entire undeveloped shoreline of

the site is a narrow zone of maritime shrubland community. This community receives storm salt

spray and is dominated by dense patches of shrubs consisting of species such as black

huckleberry (Gaylussacia baccata), bayberry, red cedar (Juniperus virginiana), black cherry

(Prunus serotina), beach plum (P. maritima), chokeberry (Aronia melanocarpa), lowbush

blueberry (Vaccinium angustifolium), and bearberry (Arctostaphylos uva-ursi). Also, greenbrier

and poison ivy often grow in dense patches or cover other plants (Swain and Kearsley 2001;

MassGIS 2006).

The maritime shrubland develops a tree canopy as it transitions inland into a maritime oak-holly

forest community, which is a mixed deciduous/evergreen forest within the coastal salt spray

zone behind the bluffs. The trees in this community tend to be short relative to interior forests

| (i.e., less than 10 m [30 ft] tall) with tops that are sculpted by winds and salt spray. Common

overstory species include the scarlet oak (Quercus coccinea), black oak (Q. velutina), other oaks

(Q. spp.), American holly (Ilex opaca), sassafras (Sassafras albidum), black gum

(Nyssa sylvatica), black cherry, and red maple (Acer rubrum). The pitch pine (Pinus rigida) and

red cedar also occur in this community. Vines such as greenbrier and poison ivy, Virginia

creeper and/or grape (Vitis aestivalis) may be dense, especially near openings. Shrubs include

bayberry, winged sumac (Rhus copallinum), and sweet pepperbush (Clethra alnifolia). The

herbaceous layer is highly variable and may include grasses and sedges 

(Swain and Kearsley 2001; MassGIS 2006).

Moving inland, the trees increase in height, and the forest transitions to a coastal forest

community that covers the majority of the wooded area of the site and is dominated by mixed

oaks. The coastal forest is sheltered from direct daily maritime influences because it is not in

the daily salt spray zone, but it receives wind and salt during storms. The climate in which this

community occurs is moderated by being near the ocean, with warmer winters and cooler

summers, as well as more fog and precipitation, than more inland areas. Historically, fire was

often an important factor in coastal forests. The dominant oaks in this community are scarlet

oak and black oak. Other trees in this community include white oak (Q. alba), chestnut oak 

| (Q. prinus), shagbark hickory (Carya ovata), red maple, sassafras, gray birch 

(Betula populifolia), beech (Fagus grandifolia), black cherry, quaking aspen 

| (Populus tremuloides), white pine (P. strobus), and pitch pine (MassGIS 2006; 

Swain and Kearsley 2001; AEC 1974). Although its natural range is well to the south, the black

locust (Robinia pseudoacacia) also is present in site forests as a result of its historical planting

as a source for fence posts and its subsequent escape from cultivation (AEC 1974). The dense

understory includes a low shrub heath layer dominated by lowbush blueberries 

(Vaccinium pallidum) and black huckleberry. Other shrubs present include arrowwood

| (Viburnum dentatum), sweet pepperbush, staghorn sumac (R. typhina), and winged sumac. The

herbaceous layer is typically sparse, with bracken fern (Pteridium aquilinum), wintergreen
Plant and the Environment

July 2007 2-89 NUREG-1437, Supplement 29

(Gaultheria procumbens), and wild sarsaparilla (Aralia nudicaulis) often present, as well as little

blue-stem grass (Schizachyrium scoparius) and bearberry beneath canopy openings. Common

vines in this community include poison ivy, Virginia creeper, grape, and greenbriers 

(Entergy 2002c; MassGIS 2006; Swain and Kearsley 2001; AEC 1974).

Isolated forested wetlands are present at several locations on the site, principally south and

southeast of the developed area. The dominant species in the canopy of these moist areas is

the red maple, with greenbrier, cattail (Typha latifolia), rush (Juncus spp.), and bulrush

(Scirpus cyperinus) in the understory. A small, seasonal wetland also is located in a depression

within the mixed oak forest at the northern end of the site. Non-native invasive plants that occur

on the site include Japanese honeysuckle (Lonicera japonica) and multiflora rose 

(Rosa multiflora) (AEC 1974).

Entergy also owns over 1530 ac of undeveloped land located predominantly across Rocky Hill

Road south of the 140-ac PNPS site (Figure 2-3). The majority of this property (the Entergy

Woodlands) has been placed in a forest land trust and is being managed under a Forest

Management Plan (Entergy 2002c) approved by the Massachusetts Department of

Environmental Management (MA DEM 2003). This Entergy Woodlands property encompasses

the northern end of the Pine Hills, a north-south oriented ridge of low hills approximately 4 mi

long (AEC 1972). The area is characterized by sandy to fairly rocky, well-drained soils and flat

to steeply sloped, wooded terrain. Typical forest in the area is dominated by pitch pine and

mixed oaks, with a component of white pine that is slowly recovering from repeated forest fires in

the past. Typical plant species include those listed above for the on-site forest. Historically,

much of the area was cleared for agriculture. Although the forest has regenerated, there are

several remaining abandoned fields in varying stages of succession to forest. There also are

several small, seasonal wetlands on the property (Entergy 2002c).

Wildlife species in the vicinity of PNPS are typical of those found in eastern Massachusetts. The

predominant habitats at the site are those provided by the shoreline and the forested uplands

and wetlands. Many wildlife species are highly mobile, moving between and utilizing habitats

provided by multiple vegetation communities. In addition, many non-resident birds migrate along

the coastline and, as a result, briefly utilize site habitats for food and shelter during migration.

Wildlife that utilize the shoreline habitat at the site primarily are birds, many of which are

migratory and occur in the area in either summer or winter. Birds that may use the shoreline

habitats at the site include shorebirds such as the willet (Catoptrophorus semipalmatus), dunlin

(Calidris alpina), purple sandpiper (C. maritima), piping plover (Charadrius melodus), and

sanderling (Calidris alba); waterfowl such as the great cormorant (Phalacrocorax carbo), brant

(Branta bernicla), and sea ducks, including the common eider (Somateria mollissima), king eider
Plant and the Environment 

 NUREG-1437, Supplement 29 2-90 July 2007

(S. spectabilis), oldsquaw (Clangula hyemalis), harlequin duck (Histrionicus histrionicus), whitewinged scoter (Melanitta deglandi), black scoter (M. nigra), and surf scoter 

(M. pespicillata); wading birds such as the black-crowned night heron (Nycticorax nycticorax)

and snowy egret (Egretta thula); and seabirds such as the herring gull (Larus argentatus), ringbilled gull (L. delawarensis), and greater black-backed gull (L. marinus) (Peterson 1980). A

marine mammal that may occur here is the harbor seal, which potentially may utilize the rocky

shoreline habitat of the site for basking.

Wildlife that utilize the shrub and forest habitats at the site include birds, mammals, reptiles, and

amphibians. Birds that occur in site forests include both migratory species and permanent

| residents. Migratory species that forage and breed in forest habitats such as those at the site

include the broad-winged hawk (Buteo platypterus), gray catbird (Dumetella carolinensis), wood

thrush (Hylocichla mustelina), red-eyed vireo (Vireo olivaceous), black-and-white warbler 

(Mniotilta varia), yellow warbler (Dendroica petechia), American redstart (Setophaga ruticilla),

common yellowthroat (Geothlypis trichas), ovenbird (Seiurus aurocapillus), and scarlet tanager

(Piranga olivacea). Resident species that may breed in forest habitats on the site and forage

there throughout the year include the red-tailed hawk (B. jamaicensis), sharp-shinned hawk

(Accipiter striatus), screech owl (Otus asio), great-horned owl (Bubo virginianus), ruffed grouse

(Bonasa umbellus), wild turkey (Meleagris gallopavo), cardinal (Cardinalis cardinalis), blackcapped chickadee (Parus atricapillus), swamp sparrow (Melospiza georgiana), American robin

(Turdus migratorius), cedar waxwing (Bombycilla cedrorum), downy woodpecker 

(Picoides pubescens), American crow (Corvus brachyrhynchos), blue jay (Cyanocitta cristata),

and dark-eyed junco (Junco hyemalis) (Peterson 1980; Entergy 2006a).

Mammals likely to occur in the terrestrial forest, shrubland, and/or wetland habitats at the site

include the white-tailed deer (Odocoileus virginianus), raccoon (Procyon lotor), opossum

(Didelphis virginiana), striped skunk (Mephitis mephitis), New England cottontail 

(Sylvilagus transitionalis), gray squirrel (Sciurus carolinensis), woodchuck (Marmota monax),

white-footed mouse (Peromyscus leucopus), and woodland vole (Microtus pinetorum) 

(AEC 1972;AEC 1974; Entergy 2006a; Whitaker 1980). Reptiles that commonly occur in these

habitat types include the eastern hognose snake (Heterodon platirhinos), eastern garter snake

(Thamnophis sirtalis), northern black racer (Coluber constrictor), northern ringneck snake

(Diadophis punctatus), and eastern box turtle (Terrapene carolina). Amphibians likely to occur in

these habitats at the site include the American toad (Bufo americanus), Fowler’s toad 

(B. woodhousii), spotted salamander (Ambystoma maculatum), and redback salamander

(Plethodon cinereus) (AEC 1974; Conant and Collins 1998; Entergy 2006a).
Plant and the Environment

July 2007 2-91 NUREG-1437, Supplement 29

2.2.6.2 Transmission Line ROW

Section 2.1.7 describes the two 345-kV transmission lines that connect PNPS to the electrical

transmission system. The two lines share a single 300-ft-wide transmission line ROW that

connects the PNPS switchyard with the power grid at the Snake Hill Road substation

approximately 7 mi to the southwest (Entergy 2006a; AEC 1972). Within the PNPS site

property, the transmission line ROW extends southeast from the switchyard, then turns south

and crosses Rocky Hill Road before reaching the station access road. This on-site segment of

the ROW passes through the coastal forest community and crosses the wooded deciduous

wetland community located south of the main parking lot. After crossing Rocky Hill Road, the

ROW enters the Entergy Woodlands property. It extends approximately 1 mi south within the

woodland before turning south-southwest along the southeastern boundary of the property for

another 2/3 mi. The ROW then turns farther west, leaves the Entergy Woodlands, and crosses

the Pine Hills as it continues approximately southwest over 5 mi to the Snake Hill Road

substation. Entergy does not own, operate, or maintain the PNPS-to-Snake Hill Road

transmission lines or ROW. The lines and ROWs are owned and maintained by NSTAR Electric

and Gas Corporation, which provides electricity and natural gas to businesses and residents in

eastern Massachusetts (Entergy 2006a; NSTAR 2006).

The transmission line ROW does not cross any state or federal parks, wildlife refuges, or wildlife

management areas (Entergy 2006a), nor does it cross any major lakes, ponds, or streams. 

Approximately 1.3 mi of the corridor at its southern end are within Myles Standish State Forest. 

The largest water feature traversed by the corridor is a medium-sized creek (approximately 8 ft

wide and 1 ft deep) next to Old Sandwich Road. Dense riparian vegetation, including shrubs

and small trees, is present beneath the transmission lines in the low-lying floodplain along the

stream in this area. The predominant vegetation community through which the corridor passes

is dry upland forest dominated by mixed oaks and pitch pine. This community supports the

typical inland forest species of plants and animals discussed earlier. 

NSTAR maintains the transmission line ROW in accordance with a Vegetation Management

Plan (NSTAR 2006) approved by the Massachusetts Department of Agricultural Resources and

the NHESP. Under this plan, NSTAR maintains the PNPS ROW from the station to the Snake

Hill Road substation, as well as the rest of their system, using an integrated vegetation

management program. This program integrates the selective use of herbicides approved in

Massachusetts for use in sensitive areas with the use of cultural methods (i.e., selective

mechanical removal of targeted vegetation by hand-cutting or mowing) and biological methods |

(i.e., encouraging development of stable communities of low-growing plants) to restore and

maintain habitat and control invasive species in the ROW. Herbicides are used to manage |

vegetation by foliar treatment (spraying diluted herbicide on the foliage and stems of targeted

vegetation), low-pressure basal treatment (applying herbicides, diluted in mineral oil to the lower
Plant and the Environment 

 NUREG-1437, Supplement 29 2-92 July 2007

12 to 18 in. of the main stem of the target plants), and cut-stump treatments (applying herbicides

to newly cut surfaces of mechanically cut stumps). Additionally, tree growth regulators are

utilized to slow or regulate the growth of a tree, which minimizes clearance pruning and/or tree

removal (NSTAR 2006). The program encourages the development of natural communities of

low-growing woody shrubs and herbaceous plants while avoiding adverse environmental impacts

and controlling tall-growing trees and undesirable shrub species that would interfere with

operation of the transmission lines (NSTAR 2006). NSTAR’s environmental personnel review

work plans with maintenance crews and consult with local town conservation committees to

ensure that wetland areas and sensitive plant communities are protected prior to conducting

vegetation management (Entergy 2006a).

2.2.6.3 Rare Terrestrial and Freshwater Aquatic Species

| Rare species include those Federally listed as endangered or threatened, as well as those listed

as endangered, threatened, or special concern species by the Commonwealth of

Massachusetts. Determination of listing status and protection of Federally listed terrestrial and

freshwater aquatic species are within the jurisdiction of the FWS. The NHESP of the MDFW

maintains a listing of rare species occurrences by town. PNPS and its transmission corridor are

within the Town of Plymouth. Occurrences of 77 rare species listed by the FWS and/or the

Commonwealth of Massachusetts have been recorded in the Town of Plymouth and are

| presented in Table 2-5. A subset of these species occurs or has a greater potential to occur on

the PNPS site or in the transmission line ROW. The names of these species are indicated in

bold in Table 2-5.

The Federally listed species identified by FWS (FWS 2006a) as potentially occurring in the

PNPS vicinity were the piping plover (Charadrius melodus), roseate tern (Sterna dougallii), bald

eagle (Haliaeetus leucocephalus), and northern red-bellied cooter (Pseudemys rubriventris),

| which was formerly known as the Plymouth redbelly turtle (P. rubriventris bangsi).

The piping plover is a small, stocky shorebird that is Federally listed as threatened in areas

outside the Great Lakes watershed and is State-listed as threatened in Massachusetts. The

Atlantic Coast population of the piping plover nests from Newfoundland south to North Carolina

and winters from North Carolina to Florida, the Gulf of Mexico, and the West Indies. Other

populations nest along rivers of the northern Great Plains and along the shores of the Great

| Lakes. The piping plover requires coastal beaches for nesting that are sandy, relatively flat, and

free of vegetation. Their population has declined significantly over the past 50 years, due

principally to habitat loss from development and beach disturbance (NHESP 1990). The piping

plover is known to occur along Plymouth Beach just north of PNPS (FWS 2006a), and it may

move through the PNPS site while foraging along the shoreline and during northward migration

in spring or southward migration in late summer (NHESP 1990).
Plant and the Environment

July 2007 2-93 NUREG-1437, Supplement 29

Table 2-5. Federally Listed Terrestrial and Freshwater Aquatic Species 

Potentially Occurring in the Vicinity of PNPS and the 

Associated Transmission Line ROW

Federal State

Scientific Name Common Name Status Status (a) (a) (b) (c)

Mammals

Synaptomys cooperi southern bog lemming SC

Birds

Ammodramus savannarum grasshopper sparrow T

Bartramia longicauda upland sandpiper E

Charadrius melodus piping plover (PS : LT) T

1

Gavia immer common loon SC

Haliaeetus leucocephalus bald eagle E |

Ixobrychus exilis least bittern E

Parula americana northern parula T

Pooecetes gramineus vesper sparrow T

Sterna antillarum least tern SC

Sterna dougallii roseate tern (PS : LE) E

3

Sterna hirundo common tern SC

Sterna paradisaea Arctic tern SC

Tyto alba barn owl SC

Reptiles

Pseudemys rubriventris northern red-bellied cooter LE E

4

Terrapene carolina eastern box turtle SC

Amphibians

Hemidactylium scutatum four-toed salamander SC

Fish

Lampetra appendix American brook lamprey T

Notropis bifrenatus bridle shiner SC

Insects

Cicindela purpurea purple tiger beetle SC

Abagrotis nefascia coastal heathland cutworm SC

Acronicta albarufa barrens daggermoth T
Plant and the Environment 

 NUREG-1437, Supplement 29 2-94 July 2007

Table 2-5. (contd)

Federal State

Scientific Name Common Name Status Status (b) (C)

Apamea inebriata drunk apamea moth SC

Callophrys irus frosted elfin SC

Catocala herodias gerhardi Gerhard's underwing moth SC

Catocala pretiosa pretiosa precious underwing moth E

Chaetaglaea cerata wax sallow moth SC

Cicinnus melsheimeri Melsheimer's sack bearer T

Cingilia catenaria chain dot geometer SC

Erynnis persius persius Persius duskywing E

Hemaris gracilis slender clearwing sphinx moth SC

Hemileuca maia barrens buckmoth SC

Hypomecis buchholzaria Buchholz's gray E

Itame sp. pine barrens itame SC

Lithophane viridipallens pale green pinion moth SC

Metarranthis pilosaria coastal swamp metarranthis moth SC

Papaipema sulphurata water-willow stem borer T

Psectraglaea carnosa pink sallow SC

Zale sp. pine barrens zale SC

Zanclognatha martha pine barrens zanclognatha T

Anax longipes comet darner SC

Enallagma daeckii attenuated bluet SC

Enallagma laterale New England bluet SC

Enallagma pictum scarlet bluet T

Enallagma recurvatum pine barrens bluet T

Mussels

Alasmidonta heterodon dwarf wedgemussel LE E

Alasmidonta undulata triangle floater SC

Leptodea ochracea tidewater mucket SC

Ligumia nasuta eastern pondmussel SC

Strophitus undulatus creeper SC
Plant and the Environment

July 2007 2-95 NUREG-1437, Supplement 29

Table 2-5. (contd)

Federal State

Scientific Name Common Name Status Status (b) (C)

Vascular Plants

Calamagrostis pickeringii reed bentgrass E

Carex striata W alter's sedge E

Conioselinum chinense hemlock parsley SC

Corema conradii broom crowberry SC

Dichanthelium wrightianum W right's panic-grass SC

Eupatorium leucolepis var. novae-angliae New England boneset E

Helianthemum dumosum bushy rockrose SC

Isoetes acadiensis Acadian quillwort E

Lachnanthes caroliana redroot SC

Liatris scariosa var. novae-angliae New England blazing star SC

Linum intercursum sandplain flax SC

Lipocarpha micrantha dwarf bulrush T

Mertensia maritima oysterleaf E

Myriophyllum pinnatum pinnate water-milfoil SC

Ophioglossum pusillum adder's-tongue fern T

Polygonum puritanorum pondshore knotweed SC

Potamogeton confervoides algae-like pondweed T

Rhynchospora inundata inundated horned-sedge T

Rhynchospora nitens short-beaked bald-sedge T

Rhynchospora scirpoides long-beaked bald-sedge SC

Rhynchospora torreyana Torrey's beak-sedge E

Sabatia kennedyana Plymouth gentian SC

Sagittaria teres terete arrowhead SC

Spartina cynosuroides salt reedgrass T

Sphenopholis pensylvanica swamp oats T

Utricularia resupinata resupinate bladderwort T

Utricularia subulata subulate bladderwort SC
Plant and the Environment 

 NUREG-1437, Supplement 29 2-96 July 2007

Table 2-5. (contd)

 Species names in bold indicate those with a greater potential to occur on the PNPS site or (a)

transmission line ROW based on the possible presence of suitable habitat.

LE: Listed endangered; LT: Listed threatened (b)

PDL: Proposed for delisting

(PS): Partial status: listing status in only a portion of the species's range, as specified:

Piping plover status in Great Lakes region is endangered; populations elsewhere are threatened 1 

Bald eagle status is threatened in the conterminous (lower 48) U.S. 

2 

Roseate tern status is endangered for the northeast U.S. nesting population; status is threatened 3 

elsewhere in the Western Hemisphere 

Status applies to population 1.

4 

 E: Endangered (c)

T: Threatened

SC: Special concern

Sources: NHESP (2006a) and FW S (2006b)

The roseate tern is a pale gray seabird with a black cap and underparts tinged with pink. Its

northeastern U.S. nesting population is Federally listed as endangered, and it is State-listed as

endangered in Massachusetts. The northeastern population breeds from Nova Scotia to Long

Island and winters from the Caribbean to the coast of South America. The roseate tern nests in

Massachusetts on coastal beaches, islands, and inshore beaches. It prefers dense herbaceous

cover such as beach grass and seaside goldenrod, and it is a colonial nester that is always

found with the common tern (Sterna paradisaea). The northeastern U.S. population has

declined precipitously, approximately 70 percent since 1935, due to factors such as alteration of

nesting habitats, displacement from nesting areas by gulls, erosion, flooding, and human

predation on their wintering grounds (NHESP 1988). The roseate tern is known to occur along

Plymouth Beach just north of PNPS (FWS 2006a), and it may pass through the PNPS site

during northward migration in late spring or southward migration in early fall (NHESP 1988).

| On June 28, 2007 the bald eagle was removed from the Federal list of threatened and

| endangered species (FWS 2007). It is State-listed as endangered in Massachusetts. The bald

eagle occurs in Massachusetts primarily in winter, but nesting also occurs in certain areas near

the coast or large inland water bodies. Bald eagle populations declined due to habitat loss,

human predation, and the eggshell-thinning effects of organochlorine pesticides in the food web. 

With regulatory protection and the banning of organochlorine pesticide use, bald eagle

populations have increased. Wintering bald eagles occasionally occur in the area of PNPS

(FWS 2006a), and in 2005 juveniles and adults were observed at Plimoth Plantation,

approximately 2 mi southwest of PNPS (Entergy 2006a).
Plant and the Environment

July 2007 2-97 NUREG-1437, Supplement 29

The Massachusetts population of the northern red-bellied cooter is both Federally and Statelisted as endangered. The Massachusetts population currently is considered a disjunct

population of the species, which is a freshwater aquatic turtle whose primary range extends from

New Jersey south to North Carolina and inland to West Virginia. The isolated Massachusetts

population formerly was considered a distinct subspecies, which is why it is listed by the FWS as

the Plymouth redbelly turtle. The endangered Massachusetts population of the northern redbellied cooter inhabits freshwater ponds that have abundant aquatic vegetation. Sandy soil with

an open canopy on land surrounding the ponds is required for successful nesting (NHESP

1995b). In accordance with the ESA, the FWS has identified and designated critical habitat for

the red-bellied cooter (at 50 CFR 17.95) in the site vicinity. Critical habitat is habitat that is

considered essential to the conservation of the species and that may require special

management considerations or protection (FWS 1980). Approximately 1400 ft of the

transmission line ROW, near its southern end and adjacent to the boundary of Myles Standish

State Forest, crosses the southeastern tip of the area designated as critical habitat for the redbellied cooter. The ponds encompassed in this critical habitat area are located west of the

Jordan Road Tap-to-Snake Hill Road Substation segment of the ROW. |

In addition to the four Federally listed species discussed above, a fifth species that is both

Federally and State-listed as endangered and has the potential to occur in the Town of Plymouth

is the dwarf wedgemussel (Alasmidonta heterodon). This mussel inhabits well-oxygenated

rivers and streams with sand, muddy sand, and gravel bottoms, slow to moderate currents, and

little silt deposition. Such habitats do not occur on the PNPS site or in the 

transmission line ROW. In addition, the dwarf wedgemussel may no longer exist in the state. 

The last known Massachusetts population was extirpated by 1988 (NHESP 1991). Therefore,

this species is not considered to have the potential to occur in the study area.

There are approximately 73 additional species within the Town of Plymouth that are State-listed

as endangered, threatened, or of special concern in Massachusetts (Table 2-5). Approximately

22 of the State-listed species (names bolded in the table) potentially could utilize habitats

available on the PNPS site or the transmission line ROW based on their preferred habitat

characteristics; however, their presence has not been confirmed. The Massachusetts NHESP 

has mapped Priority Habitats for State-Protected Rare Species based on occurrence and

population records maintained in the NHESP database, and it also has mapped Estimated

Habitats for Rare Wildlife for use with the Massachusetts Wetland Protection Act Regulations

(310 CMR 10) (NHESP 2005).

No priority habitats have been mapped within the PNPS site for species currently listed as rare

by the Commonwealth of Massachusetts. An area of priority habitat for a previously State-listed

species of special concern, the spotted turtle (Clemmys guttata), was mapped in the northern

end of the PNPS property. This area also was designated as an Estimated Habitat for Rare
Plant and the Environment 

 NUREG-1437, Supplement 29 2-98 July 2007

Wildlife. However, the spotted turtle was deleted from the State list of rare species in May 2006

based on occurrence records that have demonstrated the turtle to be more common and

widespread in Massachusetts than previously known and on the significant areas of habitat that

have been protected since its listing in 1986 (NHESP 2006b). Consequently, there currently are

no state-listed rare species with designated habitat on the PNPS site. The transmission line

ROW does not cross any Priority Habitats for State-Protected Rare Species or Estimated

Habitats for Rare Wildlife (NHESP 2005).

2.2.7 Radiological Impacts

A radiological environmental monitoring program (REMP) has been conducted around the PNPS

site since August 1968 (AEC 1974). Licensed operations at PNPS began in 1972. The REMP is

conducted to monitor the radiation and radioactivity released to the environment as a result of

| PNPS operation. 

The results of measurements of radiological releases and environmental monitoring are

summarized in two annual reports: the PNPS Radiological Environmental Monitoring Program

Report (Entergy 2006b) and the PNPS Radioactive Effluent and Waste Disposal (REWD) Report

(Entergy 2006c). The Offsite Dose Calculation Manual (ODCM) specifies the limits for all

radiological releases (Entergy 2003c). These limits are designed to meet Federal standards and

requirements for all radiological releases including ambient radiation. 

The REMP consists of taking radiation measurements and collecting samples from the

environment at a variety of locations surrounding the PNPS site, analyzing them for radioactivity

content, and interpreting the results. Sampling locations are chosen based on meteorological

factors, pre-operational planning, and results of land-use surveys. A number of locations in

areas unlikely to be affected by plant operations are selected as controls. With emphasis on the

critical radiation exposure pathways to humans, samples from the aquatic, atmospheric, and

terrestrial environments are collected. These samples include, but are not limited to: air, soil,

seawater, shellfish, lobster, fishes, cranberries, vegetables, and forage.

Thermoluminescent dosimeters are placed in the environment to measure gamma radiation

levels. The thermoluminescent dosimeters are processed and the environmental samples are

analyzed to measure the very low levels of radiation and radioactivity present in the environment

as a result of the PNPS operation and other natural and man-made sources (Entergy 2006b).

Results from the 5-year period 2001 through 2005 indicate that the radiation and radioactivity in

the environmental media monitored around the plant are well within applicable regulatory limits

and are not significantly higher than pre-operational levels 

(Entergy 2002a, 2003a, 2004a, 2005a, 2006b).
Plant and the Environment

July 2007 2-99 NUREG-1437, Supplement 29

In addition to monitoring radioactivity in environmental media, Entergy annually assesses doses

to the maximally-exposed individuals from gaseous and liquid effluents based on actual liquid

and gaseous effluent release data (Entergy 2006c). Calculations are performed at several

locations using the plant effluent release data, on-site meteorological data, and appropriate

pathways identified in the ODCM (Entergy 2003c). A summary of the calculated maximum |

doses to individuals in the vicinity of PNPS from liquid and gaseous effluents for 2005 follows:

• No liquid effluents containing radioactivity were discharged during the calendar year 2005, so

there is no associated contribution to radiation dose (Entergy 2006c). 

• The maximum total body dose from noble gases in gaseous effluents was 0.075 mrem from

gamma radiation, which is 0.75 percent of the 10 mrem gamma dose design objective

specified in 10 CFR Part 50, Appendix I, and 1.6 mrem from beta radiation, which is 8.0 |

percent of the 20 mrem beta dose design objective (Entergy 2006c).

• The critical organ dose from gaseous effluents because of iodines, tritium, and particulates

with half-lives greater than 8 days was 3.2 mrem, which is 21 percent of the 15 mrem dose

design objective (Entergy 2006c).

• As a result of current water management practices that emphasize reprocessing and reuse

rather than release, PNPS had liquid radioactive effluent releases in some years and some

years it had none. For example, while liquid radioactive waste releases were reported for

each year from 2001 through 2003, there were no liquid effluent releases made during 2004

or 2005. During this 5-year period, the maximum annual total body dose from liquid effluents

occurred in 2003. It was 0.003 mrem, which is 0.1 percent of the 3 mrem design objective

specified in 10 CFR Part 50, Appendix I. The maximum critical organ dose during this period |

also occurred in 2003. It was 0.008 mrem, which is 0.08 percent of the 10 mrem design

objective specified in 10 CFR Part 50, Appendix I. |

In all cases, doses were well below the limits as defined in the ODCM and confirm that PNPS is

operating in compliance with 10 CFR Part 50, Appendix I, 10 CFR Part 20, and 

40 CFR Part 190.

No significant changes to the radioactive effluent releases or exposures from PNPS operations

during the license renewal term are expected, and therefore, the impacts to the environment are

not expected to change.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-100 July 2007

2.2.8 Socioeconomic Factors

2.2.8.1 Housing

Approximately 80 percent of the permanent PNPS work force resides in Plymouth (63 percent)

and Barnstable (19.5 percent) counties in southeastern Massachusetts, which is the fastest

growing region in the state (Entergy 2006a). PNPS employs approximately 700 personnel,

including Entergy employees normally on-site (or at off-site training facilities) and contractor

employees. During refueling and maintenance outages, typically lasting 30 days, there are an

additional 900 workers on-site. Maintenance outages usually occur every 24 months. There are

no plans to add additional employees at the site. The residences of the PNPS employees are

shown in Table 2-6 by State and county and, for Plymouth and Barnstable counties, by city or

town in Table 2-6. 

Data on total housing units in the region are shown by county for 1990 and 2000 in Table 2-7

together with the numbers of occupied units, and vacant units available for sale or rent. The

Massachusetts counties shown had a total of 1,377,360 housing units in 2000, an increase of

7.1 percent since 1990. Occupied units in the region totaled 1,278,641 units in 2000, an

increase of 10 percent since 1990. The number of vacant units for sale or rent in 2000 was

22,421, a decline of 44 percent over the number of vacant units for sale or rent in 1990. In the

context of the scale of southeastern Massachusetts’ housing market, however, accommodating

the plant’s approximately 700 employees has not been a problem; they would represent only

0.05 percent of the occupied units in 2000. Accommodating the additional plant workers during

the periods of biennial maintenance outages, when an additional 900 workers are on site, is

facilitated by the region’s extensive seasonal accommodations, as well as the 22,421 units in

year 2000 that were available as vacant for sale and rent.
Plant and the Environment

July 2007 2-101 NUREG-1437, Supplement 29

Table 2-6. Pilgrim Nuclear Power Station Permanent Employee 

Residence Information by County and Town/City

County and Town/City PNPS Employees

PLYMOUTH COUNTY (MASSACHUSETTS)

Abington

Bridgewater

Brockton

Carver

Duxbury

East Bridgewater

Halifax

Hanover

Hanson

Hingham

Kingston

Lakeville 

Marion

Marshfield

Middleboro

Norwell

Pembroke

Plymouth

Plympton

3

 9

5

25

19

5

 10

9

5

7

21

2

1

27

13

3

 18

223

2

Rochester

Rockland

Scituate

W areham

W est Bridgewater

W hitman

8

3

6

14

1

 5

Total 444

BARNSTABLE COUNTY (MASSACHUSETTS)

Barnstable

Bourne

Brewster

Chatham

Dennis

Falmouth

Harwich

Mashpee

Sandwich

Yarmouth

21

 25

1

1

6

9

4

13

53

4

Total 137
Plant and the Environment 

 NUREG-1437, Supplement 29 2-102 July 2007

Table 2-6. (contd)

County and Town/City PNPS Employees

OTHER COUNTIES

Norfolk (Massachusetts) 57

Bristol (Massachusetts) 43

Middlesex (Massachusetts) 6

Suffolk (Massachusetts) 6

W orcester (Massachusetts)

Providence (Rhode Island)

New London (Connecticut)

Manatee (Florida)

Cheshire (New Hampshire)

Oswego (New York)

 Total

3

3

1

1

1

1

122

Source: Entergy 2006a

Table 2-7. Housing Units and Housing Units Vacant (Available) 

by County During 1990 and 2000

1990 2000

Approximate Percentage

Change

Barnstable County

Housing Units 135,192 147,083 8.8

Occupied Units 77,586 94,822 22.2

Vacant Units 5,675 2,712 -52.2

Plymouth County

Housing Units 168,555 181,524 7.7

Occupied Units 149,519 168,361 12.6

Vacant Units 5,229 2,436 -53.4

Sources: USBC, 1990 and 2000
Plant and the Environment

July 2007 2-103 NUREG-1437, Supplement 29

2.2.8.2 Public Services

2.2.8.2.1 Water Supply 

Most of the PNPS employees reside in Plymouth and Barnstable counties; with almost one-third

residing in the Town of Plymouth. With the exception of Scituate, Abington-Rockland (which

obtain their drinking water from both groundwater and surface water), and Brockton (which

obtains its drinking water from surface water only), all of the communities in Plymouth County,

including the Town of Plymouth, obtain their municipal water supply from groundwater sources

(Entergy 2006a). Table 2-8 provides public water supply information for selected Plymouth

County water systems, including average consumption and authorized withdrawal volume for the

year 2003. Average daily consumption rates exceed the authorized withdrawal limits (capacities)

for two of the water systems listed on Table 2-8. Those communities purchase water from

communities with excess capacity to meet the residual demand. Overall, the region has excess

capacity and has been able to meet total demand (MDEP 2004). In the Town of Plymouth, the

Plymouth-Carver aquifer has sufficient water for existing and projected demand (Town of

Plymouth 2006a).

Table 2-8. Selected Plymouth County Public W ater Supply Systems and Capacities in 2003

Water System Average Consumption (mgd) Authorized Withdrawal Volume

(Capacity mgd)

Duxbury W ater Department 1.35 1.85

Halifax Water Department 0.49 0.68

Kingston Water Department 1.39 1.56

Marshfield W ater Department 2.90 3.3

Middleborough W ater Department 1.53 3.03

Pembroke W ater Division 1.33 1.26

Plymouth Water Division 4.61 6.36

Plymouth Water Co. 0.26 0.22

Sources: MDEP 2004 and Entergy 2005c
Plant and the Environment 

 NUREG-1437, Supplement 29 2-104 July 2007

Groundwater is the only source of drinking water for most of the communities in Barnstable

County (Cape Cod Commission 2003). Table 2-9 provides public water supply information,

including average consumption and authorized withdrawal volume for the year 2003, for

Barnstable County water systems serving the areas where the majority of the PNPS employees

that live in Barnstable County reside. Three of the water systems had average consumption

levels slightly in excess of authorized withdrawals. The water systems can buy or sell water to

each other in order to meet demand (MDEP 2004). To ensure a sustainable supply of highquality drinking water, the Cape Cod Commission has identified potential public water supply

areas and minimum performance standards designed to protect those areas 

(Cape Cod Commission 2003).

Table 2-9. Barnstable County Public W ater Supply Systems and Capacities in 2003

Water System Average Consumption (mgd) Authorized Withdrawal Volume

(Capacity mgd)

Barnstable Fire District 0.54 0.66

Barnstable Water Company 2.57 3.42

Bourne Water District 1.17 1.40

Buzzards Bay W ater District 0.46 0.53

COMM W ater Department 2.74 3.57

Cotuit W ater Department 0.49 0.48

Mashpee W ater Department 1.26 1.30

North Sagamore Water District 0.51 0.48

Sandwich Water District 1.67 2.64

South Sagamore Water District 0.10 0.09

Sources: MDEP 2004 and Entergy 2005c

2.2.8.2.2 Education

Public school systems in Plymouth County are organized by township, with 27 separate school

districts in the county. The Town of Plymouth Public Schools serve over 8800 students 

(Town of Plymouth 2004c) and rely on a 2004 operating budget of over $70.9 million in

expenditures (Town of Plymouth 2004c). School population projections provided by the town

indicate a growth by 2010 of 130 students (to 8930 or 1.5 percent over 2004 levels) and to 9413

in 2020 (a growth of 613 or 7 percent over 2004 levels) (Urbanomics 2006).
Plant and the Environment

July 2007 2-105 NUREG-1437, Supplement 29

2.2.8.2.3 Transportation

Figures 2-1 and 2-2 show the PNPS site and highways within a 50-mi radius and a 6-mi radius of

PNPS. At the larger regional scale, the major highways serving PNPS are: 

(1) Route 3, a four-lane divided highway that generally parallels the coast from Boston

to Cape Cod;

(2) I-495, an outer ring road for Boston that extends southeast towards Cape Cod; and

(3) Route 44, much of which has recently been improved to four lanes, that extends

west from Plymouth to I-495. 

Local road access to PNPS is via Rocky Hill Road or Power House Road (formerly known as

Edison Access Road). These are both two-lane paved roads with the latter owned and

maintained by Entergy. Rocky Hill Road intersects with Route 3A approximately 1.5 mi west of

PNPS, and Power House Road intersects with Route 3A approximately 1.5 mi south of PNPS

and 2.5 mi east of the Rocky Hill Road intersection with Route 3A. 

Route 3A generally parallels the coast in the Town of Plymouth, providing access to both Rocky

Hill Road and Power House Road from downtown Plymouth. Route 3A also connects with Route

3 near downtown Plymouth, and again close to the boundary with Barnstable County and Cape

Cod. Route 3 is the major north-south highway in the Town of Plymouth and is used by the

PNPS employees traveling south from the towns of Marshfield, Duxbury, Kingston and

Pembroke. Employees traveling north to PNPS would likely use either Route 3A to Power

House Road or Route 3 to Clark Road/Beaver Dam Road, which intersects Route 3A

approximately one-quarter mi east of Power House Road. Employees traveling east to PNPS

would use Route 44 to Routes 3 or 3A. 

The level of service determination for the intersection of Route 3A and Beaver Dam Road/White

Horse Road is C, which describes operations with moderate delay 

(Vanasse & Associates 2001, in Entergy 2006a). Table 2-10 provides available daily traffic

counts for roads in the vicinity of PNPS from the Massachusetts Highway Department.

Old Colony Planning Council (OCPC), at the request of the Town of Plymouth Department of

Public Works, recently conducted a traffic study of Rocky Hill Road (OCPC 2006b). This road

generally follows the coastline and serves residences both east and west of PNPS. The study

was initiated because of safety concerns of residents: specifically, several sharp curves, |

changes in grade, and limited sight distances, especially in the segment west of PNPS. 
Plant and the Environment 

 NUREG-1437, Supplement 29 2-106 July 2007

Table 2-10. Traffic Counts for Roads in the Vicinity of PNPS

Route

No.

Route Location Estimated Average

Daily Traffic Volume

Year

3 North of Clark Road* 30,500 1992

3A North of Beaver Dam Road 14,400 2003

3A South of Rocky Hill Road 13,000 1995

3A South of Route 44 12,700 1998

44 East of Route 3 17,677 1990

* Beaver Dam Road is the continuation of Clark Road north of the intersection with Sandwich Road. 

Source: Entergy 2006a

The road is narrow (25 ft), with two 12-ft lanes, without shoulders and with limited (2 to 2.5 ft)

width for pedestrians. Traffic volumes counted in August 2005 indicate higher volumes at the

western end of the road near its intersection with Route 3A. Here, average 24-hour volumes

were 4372 vehicles with an a.m. peak of 274 per hour and p.m. peak of 354 per hour. Volumes

east of PNPS are much lower, with a 24-hour average of 2360 vehicles, an a.m. peak of 154, 

and p.m. peak of 198. The OCPC traffic study notes that the road has adequate capacity for the

highest volumes recorded. (OCPC cites the Institute of Transportation Engineers,

Transportation Planning Handbook, that in excess of 10,000 vehicles per arterial lane usually

indicates a need for more capacity.)

The study notes that average speeds exceed the posted 30 miles per hour and that several

locations have substandard sight distances. The report makes several recommendations,

| including: speed warning signs at the curve in the vicinity of 209 to 222 Rocky Hill Road;

constructing or widening shoulders; speed humps; and an increase in police speed enforcement.

The report makes no mention of PNPS as a specific factor in its safety analysis. Truck traffic

accessing the plant is directed by Entergy to use Power House Lane rather than Rocky Hill

Road. 

2.2.8.3 Off-site Land Use

PNPS is located in the Town of Plymouth. Current land use surrounding PNPS is predominantly

residential, with the population concentrated toward Cape Cod Bay (See Figure 2-3). The

communities of Priscilla Beach and White Horse Beach are located along the shoreline directly

to the southeast of the site; they are in the Town of Plymouth R-20SL/Small Lot Residential
Plant and the Environment

(c) The R-20SL zoning district has a minimum lot size of 20,000 ft (Small Lot Residential). The R-25 2

district has a minimum lot size of 25,000 ft (Medium Lot Residential) (Town of Plymouth 2004c). 2

July 2007 2-107 NUREG-1437, Supplement 29

zone . The Bay Shore Drive neighborhood along the shoreline to the northwest is zoned R-25/ |

(c)

Residential . The nearest population centers are Manomet to the southeast (approximately 0.5 |

(c)

mi) and Plymouth to the west (approximately 2 mi). Low density residential development and

areas of vacant land/open space are located south of the PNPS site, inland from the shoreline. 

This area is the northern part of the Pine Hills, a north-south oriented ridge of low hills that

contain the highest elevations in the town. The current zoning scheme in the Town of Plymouth

is designed to guide growth in keeping with the land use objectives presented in the Master Plan

(Town of Plymouth 2006a). Based on the zoning currently in place, the future land uses planned

for the areas surrounding the site are large lot and medium lot residential, including the Entergy

woodlands property, which is zoned for large lot residential development. Future land use for

the PNPS site itself is industrial.

The Town of Plymouth has the largest land area of the 26 towns and one city that make up

Plymouth County; it is also the largest town in the state, as well as the oldest (incorporated in

1620). The area within the vicinity of PNPS (i.e., within a 6-mi radius of the site) is located

entirely in Plymouth County and almost completely in the Town of Plymouth. The Town of |

Plymouth has 65,920 ac of land. Based on 2004 land use data provided in the Master Plan |

(Town of Plymouth 2006a), 29 percent of the Town of Plymouth is developed: 21 percent is |

residential, just over 4 percent is commercial and industrial, and 4 percent is occupied by

nonprofit uses. Seventy-one percent of the Town of Plymouth is undeveloped. Publicly owned |

property and protected open space occupy 36 percent of the town. Myles Standish State Forest,

a 12,500-ac recreation area owned by the Commonwealth of Massachusetts, represents

approximately half of the publicly owned property in Plymouth. Properties privately held in

Chapter 61, 61A, and 61B uses (currently utilized for forestry, agriculture, and outdoor

recreation, respectively) occupy 23 percent of Plymouth. Almost all of the agricultural land in the

town is used for cranberry production. Nearly 12 percent of land in the town is vacant. 

Land use in the Town of Plymouth is regulated by the town, primarily through zoning and |

preservation incentives. The Town of Plymouth Master Plan (Town of Plymouth 2006a) provides

a vision for the future and a framework for both preservation and growth. The characteristics

identified by local residents as most important to preserve are small town character, natural

resources, historic heritage, and open space. The Master Plan encourages smart growth, which

emphasizes development within or near growth areas (primarily “village centers”) and away from

preservation areas that Plymouth intends to protect for environmental, scenic, cultural,

recreational, and fiscal reasons. Plymouth has implemented village center zoning in which the

existing mixed uses of a village (residential, commercial, and civic) are preserved and new
Plant and the Environment 

 NUREG-1437, Supplement 29 2-108 July 2007

construction encouraged that is compatible with the village setting. Six village centers have

been identified in the town; PNPS lies between the Plymouth Center and Manomet Village

Centers.

Approximately 80 percent of the permanent PNPS work force resides in Plymouth County 

| (63 percent) and Barnstable County (19.5 percent) in southeastern Massachusetts, which is the

fastest growing region in the state (Entergy 2006a). Sprawl, in the form of large-lot, low-density

residential development that consumes open space and costs more in town services than it

returns in property taxes, is a critical issue facing towns in southeastern Massachusetts. In the

Town of Plymouth, for example, most of the new housing constructed since 1980 has been

single family homes, of which 58 percent have been built outside the villages and 82 percent

have been built in large lot zoning districts. Average land consumption per single family unit has

almost doubled from an average lot size of 0.6 to 1.0 ac. In Fiscal Year (FY) 2001, the average

cost to service a single family home in the town’s rural areas exceeded $8600, more than double

the cost of servicing a higher density home in the older village centers (Town of Plymouth,

2006a). In Barnstable County, more than 15,000 ac of open land (nearly 6 percent of the land

on Cape Cod) was converted to development during the 1990s and the number of housing units

| increased by approximately 17,000 (Cape Cod Commission 2003).

Vision 2020 is a partnership for southeastern Massachusetts, which includes Plymouth County

as well as neighboring Bristol County and southern Norfolk County. It is a regional growth

management initiative addressing the rapid growth and change occurring in the area between

Boston, Cape Cod, and Rhode Island (OCPC 2000). Vision 2020 is charged with preparing an

overall growth and development strategy for southeastern Massachusetts. The project identifies

strategies and incentives to (1) encourage compact development and minimize sprawl; (2)

preserve and enhance farmland, natural resources and open space; (3) protect historical

resources; and (4) encourage economic development that is beneficial to the region. 

2.2.8.3.1 Plymouth County

Plymouth County occupies an area of 661 square mi and is located in the Boston-CambridgeQuincy, Massachusetts-New Hampshire metropolitan area (USCB 2006b). Land use in the

county is primarily forest (51 percent) and residential (22 percent). Agriculture and open land

each occupy 8 percent of the county land area. Industrial and commercial (3 percent) are minor

land uses. Table 2-11 provides the acreage and percent of total for each land use category in

Plymouth County.
Plant and the Environment

July 2007 2-109 NUREG-1437, Supplement 29

Table 2-11. Land Use in Plymouth County, 1999

Land Use

Acres Percent of Total

Residential 96,467 21.9

Commercial 5,892 1.3

Industrial 7,706 1.7

Recreation 7,108 1.6

Transportation 5,069 1.2

Agriculture 37,454 8.5

Forest 223,861 50.8

Open Land 37,423 8.5

W ater 19,756 4.5

Total 440,735 100

Source: MEOEA 2003

Control of land use in Plymouth County rests with the individual towns, which have zoning

authority for the lands within their boundaries. OCPC is the regional planning agency |

responsible for overall coordination of planning in 11 of the communities in Plymouth County,

including the Town of Plymouth. The Council was formed in response to a growing need of local

communities to be able to address the many issues that cross over local boundaries such as air

quality, water supply and quality, transportation, and economic development. The Regional

Land Use and Transportation Policy Plan published in October 2000 (OCPC 2000) provides

regional land use policies designed to guide future growth into priority development areas;

encourage compact, mixed-use community centers; protect outlying areas more suitable to

natural resource protection, agricultural, open space and recreation uses, and water supply

protection; and increase housing diversity.

In the late 1990s, the Massachusetts Executive Office of Environmental Affairs developed buildout analyses for all the towns and cities in the state, which projected the additional housing units

and commercial and industrial space that would be built if the community were to fully develop its

land. The build-out study for the Town of Plymouth estimates that 29,043 developable acres are

available as of 1999, which represents 44 percent of the total town land area. The study

projects a doubling of residential units (from 21,250 to 41,147) and population (from 51,701 to

105,424) at build-out (Town of Plymouth 2006a).
Plant and the Environment 

 NUREG-1437, Supplement 29 2-110 July 2007

2.2.8.3.2 Barnstable County

Barnstable County, which comprises the towns of Cape Cod, has a separate Regional Policy

Plan that is both a planning and a regulatory document (Cape Cod Commission 2003). The

Regional Policy Plan develops a growth policy for Cape Cod, identifies key resources of regional

importance, and provides the framework for town local comprehensive planning efforts. Its

purpose is to guide development on Cape Cod and protect its resources. The Regional Policy

Plan is required by the Cape Cod Commission Act of 1990, which calls for an update to the plan

every 5 years.

| Barnstable County has a land area of 396 square mi and is located in the Town of Barnstable,

Massachusetts metropolitan area (USCB 2006a). The county, located southeast of and

adjacent to Plymouth County, includes the 15 coastal towns that make up the Cape Cod

peninsula. The major land uses in Barnstable County are forest (40 percent), residential 

(29 percent), and open land (16 percent). The remaining 15 percent of the county is occupied

by water (5 percent) and other land uses. Table 2-12 identifies the acres in each land use

category in Barnstable County and the percent of the total land area that each category

occupies.

Table 2-12. Land Use in Barnstable County, 1999

Land Use Acres Percent of Total

Residential 78,049 29.4

Commercial 4,756 1.8

Industrial 3,308 1.2

Recreation 9,344 3.5

Transportation 4,753 1.8

Agriculture 4,195 1.6

Forest 106,250 40.0

Open Land 41,569 15.6

W ater 13,492 5.1

Total 265,717 100

Source: MEOEA 2003
Plant and the Environment

July 2007 2-111 NUREG-1437, Supplement 29

Barnstable County has a county legislative body with the power to enact ordinances. The county

is the regional government for Cape Cod (Barnstable County 2006). The Cape Cod

Commission, a department of the county, is the regional planning and land use regulatory

agency for Barnstable County. The Commission was established in response to an

unprecedented growth boom in the 1980s. The Commission’s purpose is to prepare and

oversee implementation of a regional land use policy plan for all of Cape Cod, review and

regulate Developments of Regional Impact, and recommend designation of certain areas as

Districts of Critical Planning Concern. Barnstable County adopted the latest update of the Cape

Cod Commission’s Regional Policy Plan in 2002, which was revised in 2003 (Cape Cod

Commission 2003). The Regional Policy Plan includes broad goals that set the direction for the

future of the county as well as more detailed Minimum Performance Standards that future

development on Cape Cod is required to meet. As in Plymouth County, the towns in Barnstable

County guide land use through local zoning bylaws. The Regional Policy Plan provides a growth

policy in which development is redirected toward existing village centers and other developed

areas and away from outlying areas in order to preserve open space, natural resources, and

scenic landscapes.

As of 2000, Barnstable County has 76,973 ac available for development, approximately 31

percent of the land on Cape Cod. A build-out analysis conducted in 2000 by the Cape Cod

Commission and the Massachusetts Executive Office of Environmental Affairs determined that

Barnstable County could add 37,000 housing units and at least 50,000 people at build-out, which

would likely be reached within 30 years (Cape Cod Commission 2003).

2.2.8.4 Visual Aesthetics and Noise

The PNPS plant structures can be seen from Cape Cod Bay, from approximately northnorthwest to southeast. Most visible is the 330-ft-tall main stack, with its alternating white and

red stripes and aviation lights. For boaters on the bay, the stack serves a useful navigational

purpose as a notable landmark. From the land side, PNPS is relatively well screened by natural

vegetation from viewers on Rocky Hill Road, the closest public thoroughfare. Motorists traveling

on Rocky Hill Road pass two former entrance gates and the main entrance drive to the plant at

Power House Road. Overhead transmission lines pass over local roads on their way to connect

to the regional grid. Viewers from other vantage spots, such as Priscilla and White Horse

Beaches, would see only the plant’s stack.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-112 July 2007

2.2.8.5 Demography

2.2.8.5.1 Regional Population

U.S. Census Bureau (USCB) year 2000 data and geographic information system (GIS) software

| (ArcView®) were used by the applicant to determine the demographic characteristics in the

| vicinity of PNPS. Census data reveal that approximately 285,547 people live within 20 mi of

PNPS, with a population density of 422 persons per square mi within 20 mi of PNPS and,

applying the GEIS sparseness index, falls into the least sparse category, Category 4 (having

greater than or equal to 120 persons per square mile within 20 mi). This calculation corrects for

the area within the radius that is water (Entergy 2006a).

USCB data indicate approximately 4,629,116 people live within 50 mi of PNPS. This equates to

a population density of 1167 persons per square mi within 50 mi. Applying the GEIS proximity

index, PNPS is classified as Category 4 proximity (having greater than or equal to 190 persons

per square mi within 50 mi). According to the GEIS sparseness and proximity matrix, PNPS

ranks of sparseness Category 4 and proximity Category 4 result in the conclusion that PNPS is

located in a "high" population area. All or parts of 15 counties (Figure 2-1) and the cities of

Boston, Massachusetts, and Providence, Rhode Island, are located within 50 mi of PNPS.

In 2000, Plymouth County and Barnstable County had a combined total population of 695,052

(USCB 2006a, USCB 2006b). Plymouth County extends to metropolitan Boston and comprises

26 towns and one city. Barnstable County is made up of 15 towns on Cape Cod. From 1970 to

2000, Plymouth County had an average annual growth rate of 1.4 percent and Barnstable

County had an average annual growth rate of 4.3 percent. Both Plymouth and Barnstable

counties have been growing at a rate faster than that of Massachusetts as a whole. From 1970

to 2000, Massachusetts's average annual population growth rate was 0.39 percent 

(Entergy 2006a).

Table 2-13 shows estimated populations and annual growth rates through 2020 for the two

counties with the greatest potential to be socioeconomically affected by license renewal

activities. The proposed license renewal term is through 2032; however, the Massachusetts

Institute for Social and Economic Research (MISER) projections extend only through 2020.

Plymouth, while representing the larger of the two counties in terms of population, is projected to

grow at a much slower rate than Barnstable over the period to 2020. Plymouth is projected to

grow a total of 16.5 percent over 2000 to 2030, compared to Barnstable’s 50.6 percent.
Plant and the Environment

July 2007 2-113 NUREG-1437, Supplement 29

Table 2-13. Population Growth in Plymouth and Barnstable Counties - 1980 to 2020

Plymouth County Barnstable County

Population

Annual Growth

Percent Population (a)

Annual Growth

Percent(a)

1970 333,314 - 96,656 -

1

1980 405,437 2.16 147,925 5.3 1

1990 435,276 0.7 186,605 2.6 1

2000 472,822. 0.9 222,230 1.9 1

2010 496,053 0.5 257,844 1.6 2

2020 517,644 0.4 299,035 1.6 2

2030 551,005 0.6 334,766 1.2 3

(a) Annual percent growth rate is calculated over the previous decade.

Sources: (1) USCB 1995, (2) MISER 2003, (3) Entergy 2006a

2.2.8.5.2 Transient Population

Coastal areas of Plymouth and Barnstable counties experience major increases in their summer

populations because of the area’s attraction as a vacation destination. This is reflected in the

number of “vacant for seasonal use” housing units reported in the U.S. Census. For Barnstable

County the 2000 Census reports 47,610 units vacant for seasonal use 

(91 percent of all vacant units and 32.4 percent of all housing units). In Plymouth County, |

vacant for seasonal use units in 2000 totaled 8865 (67 percent of all vacant units or 4.9 percent

of all housing units). In addition, there are numerous hotels, motels and guest houses that serve |

the tourist/vacation population. The Town Manager of Plymouth reported that the summer

population of the town increased to approximately 86,000, from a year-round population of

55,000, i.e., a 56 percent increase (Sylvia 2006). Other indicators of significant seasonal activity

are the number of registered boats in Plymouth harbor. The statistics for 2004 indicate that

there were 655 moorings in the harbor, 5000 visiting boats that logged in, and an estimated

11,000 boats launched at the boat ramp (Town of Plymouth 2004c).

2.2.8.5.3 Minority and Low-Income Populations

Executive Order 12898 (59 FR 7629), Federal Actions to Address Environmental Justice in

Minority Populations and Low-Income Populations, refers to a Federal policy that requires

Federal agencies to identify and address, as appropriate, disproportionately high and adverse

human health or environmental effects of its actions on minority and low-income populations.

Although the Executive Order is not mandatory for independent agencies, the NRC has
Plant and the Environment 

 NUREG-1437, Supplement 29 2-114 July 2007

voluntarily committed to undertake environmental justice reviews and in 2004, the Commission

issued a final Policy Statement on the Treatment of Environmental Justice Matters in NRC

Regulatory and Licensing Actions (NRC 2004a).

The guidance requires determining the existence of minority and low-income populations within

50-mi radius of the site and the use of the state as the geographic area for comparative analysis.

According to the guidance, a qualified minority population exists in a census block group (a

| USCB-designated area smaller than a census tract), if the percentage of each minority and

aggregated minority category within the census block group exceeds the corresponding

percentage of minorities in the state of which it is a part by 20 percentage points, or the

corresponding percentage of minorities within the census block group is at least 50 percent. A

qualified low-income population exists if the percentage of low-income population within a

census block group exceeds the corresponding percentage of low-income population in the state

of which it is a part by 20 percent, or if the corresponding percentage of low-income population

within a census block group is at least 50 percent.

Using the ArcView® GIS software to combine USCB Topologically Integrated Geographic

Encoding and Referencing System (TIGER) line data with USCB 2000 census data to determine

minority and low-income characteristics (at the block-group level) within the 50-mi radius of the

PNPS site, it was determined that the 50-mi radius includes 3863 block groups in a two-state

area, with the largest portion of that area (89 percent) located in Massachusetts and a smaller

portion (11 percent) in Rhode Island.

2.2.8.5.4 Minority Populations

The NRC Environmental Justice guidance defines a "minority" population as the racial

| categories: American Indian or Alaskan Native, Asian, Native Hawaiian or Pacific Islander,

Black races, other races, more than 2 races, and the aggregate of all minority races.

Hispanic ethnicity is also defined as a minority population category (NRC 2004b, in 

Entergy 2006a). Hispanic ethnicity is not defined by the USCB as a racial category and,

therefore, it is possible to have both white Hispanics and non-white Hispanics (e.g. Black

Hispanic, Asian Hispanic). For the purposes of aggregation, a minority population that combines

both minority races and Hispanic ethnicity can be defined as all non-white and multiple races

plus white Hispanics. 

Using 2000 census data, the percentage of the total population in Massachusetts and Rhode

Island that belong to each minority category was determined (Table 2-14). This information was

then used to calculate minimum thresholds for each minority category. Any block group with a

minority category percentage that exceeded the minimum threshold listed in Table 2-14 was

defined as a “minority population.”


Plant and the Environment

July 2007 2-117 NUREG-1437, Supplement 29

Figure 2-11. Aggregate of Minority Races Population Map (Source: Entergy 2006a)
Plant and the Environment 

 NUREG-1437, Supplement 29 2-118 July 2007

2.2.8.5.5 Low-Income Populations

NRC guidance defines “low-income” by using USCB statistical poverty thresholds for the year

1999 (NRC 2004b). Low-income populations within the 50-mi radius of PNPS were identified

using information on both the number of individuals and number of households below the

poverty level in Massachusetts and Rhode Island and block groups within the environmental

impact site (50-mi radius). The USCB values for the number of individuals and households

below the poverty level in Massachusetts was 9.3 percent and 9.8 percent, respectively 

(Table 2-14). The number of individuals and households below the poverty level in Rhode Island

was 11.9 percent and 12.4 percent, respectively.

The low-income populations within the 50-mi radius were identified using the “greater than 20

percent” criterion (Table 2-14). The number and percentage of block groups that exceeded

these thresholds are included in Table 2-15. The locations of these low income populations are

shown in Figure 2-12.

Low-income “individual” populations exist in 190 block groups in Massachusetts and 79 in Rhode

Island. Low-income populations based on the number of “households” exist in 179 block groups

in Massachusetts and 74 block groups in Rhode Island. 

No low-income populations were identified within a 6-mi radius of PNPS. The nearest lowincome population occurring within a 50-mi radius was in northwest Plymouth County in

Brockton where thresholds for both low-income individuals and households were exceeded. 

These populations are approximately 25 mi northwest of the PNPS site. Other low-income

populations within 50 mi of PNPS were clustered near Boston and in Bristol County, near the

communities of Fall River and New Bedford, Massachusetts and in Providence County, Rhode

Island. 
Plant and the Environment

July 2007 2-119 NUREG-1437, Supplement 29

Figure 2-12. Low-Income Population Map (Source: Entergy 2006a)
Plant and the Environment 

 NUREG-1437, Supplement 29 2-120 July 2007

2.2.8.6 Economy

2.2.8.6.1 Employment 

The 10-mi radius surrounding PNPS mostly includes the town of Plymouth; however, small

sections of the towns of Carver, Kingston, Plympton, Duxbury and Marshfield are also 

within this radius. Employment trends data provided by the OCPC is shown in Table 2-16. 

(The OCPC region includes Plymouth, Kingston and Plympton, among other towns as it extends

to the northeast, but does not include Carver, Duxbury and Marshfield.) Plymouth is seen to

have increased its employment by 19 percent over the 1990s, greater than the OCPC total

employment increase of 11.4 percent over the period.

Services are by far the largest industry sector in Plymouth, accounting for 38 percent of

employment in 2000, followed by Trade (22 percent) and Government (16 percent). In the

OCPC region, Trade dominates with 32 percent, followed by Services (28 percent) and

Government (15.5 percent). Employment projections by OCPC see employment in Plymouth

increasing to 22,810 by 2025, a 19 percent growth over employment in 2000. The OCPC region

is expected to grow at a similar rate of 19.8 percent over the period.

Table 2-16. Employment Trends: Number of Employees by Industry Sector 1990 and 2000

Industry/

Year Plymouth Kingston Plympton OCPC Region

1990 2000 1990 2000 1990 2000 1990 2000

Agriculture 253 190 22 53 7 30 864 1,096

Government 2416 3,041 506 531 Conf. 99 16,883 19,274

Construction 562 702 93 187 38 45 6,158 6,197

Manufacturing 1,856 1,500 232 287 273 12 14,622 12,740

TCPU 1,551 1,480 806 95 Conf. Conf. 7,619 6,618

Trade 3,890 4,225 2,413 3,060 35 29 35,993 39,940

FIRE 1,023 472 116 146 Conf. 8 4,746 3,296

Services 4,503 7,279 468 959 45 36 24,436 34,578

Total Jobs 16,054 19,100 4,656 5,318 398 267 111,321 123,978

TCPU: Transportation, Communications, and Public Utilities.

FIRE: Finance, Insurance and Real Estate.

Conf.: Data suppressed due to confidentiality.

Source: OCPC 2006a 
Plant and the Environment

(d) Employment estimates obtained during interview with Town of Carver officials on May 4, 2006.

July 2007 2-121 NUREG-1437, Supplement 29

The OCPC report Keeping Our Region Competitive (OCPC 2006a) provides data on large

employers in the region. In Plymouth, it cites two large manufacturing employers and one

hospital:

• Pixley-Richards, Inc. (plastic molds) with 200 estimated employees;

• Tech-Etch (shielding products) with 130 estimated employees; and

• Jordan Hospital with 800 estimated employees.

The only other large employer noted in the OCPC report among the nearby towns is L. Knife &

Son, a wholesale liquor distributor in Kingston with 500 estimated employees. Interviews with

local officials indicated that government was often the largest local employer, although officials

from the following towns also noted: Independence Mall and R.S. Means (cost estimating) in |

Kingston; Battelle (engineers) in Duxbury; and two supermarkets, two retail stores, and several

restaurants in Marshfield. It should also be noted that Entergy is one of Plymouth’s largest |

employers. |

|

Another industry of some note to the coastal towns is commercial and recreational fishing and

boating. The mooring data from Plymouth’s Harbor Master was noted under Section 2.2.8.5.2,

Transient Populations, with 655 moorings in the harbor, 5000 visiting boats logged in, and an

estimated 11,000 boats launched at the boat ramp. The Harbor Master also reports: 50 fishing |

boats and 14 charter boats using Plymouth wharves; 712 shell fishing permits; and that

Plymouth has one of the State’s top five lobster landings (Town of Plymouth 2004c). In addition,

active draggers, gill-netters and other commercial boats work from the harbor. Other important

recreational activities include whale watching, party fishing and sport fishing boats. Similar

commercial and recreational activities occur in the Towns of Kingston, Duxbury, and Marshfield

including: shell fishing, aquaculture farming, lobstering, charter boats, and recreational marinas. |

2.2.8.6.2 Migrant Farm Labor

Although agriculture is not a large employment sector in the region, interviews with Plymouth

town officials and those of surrounding towns indicated that the extensive cranberry bogs in the

area were among the largest cranberry producers in the country. This agricultural activity is

particularly significant in Plymouth and Carver, where several hundred seasonal workers were

likely to be hired each year, in addition to the 200 to 300 workers at three processing plants in

Carver, which operate 6 to 9 months a year . |

(d)
Plant and the Environment 

 NUREG-1437, Supplement 29 2-122 July 2007

2.2.8.6.3 Taxes

PNPS pays annual property taxes to the Town of Plymouth. Taxes fund the Town of Plymouth's

operations, the school system, public works, the Town General Fund, and the police and fire

departments (MA DOR 2002 in Entergy 2006a).

In 1998, the Commonwealth of Massachusetts deregulated its utility industry. As a result, the

Massachusetts legislature changed property tax assessment methodologies for utilities from net

book value to fair market value. In 1999, Boston Edison Company sold PNPS to Entergy

Corporation for significantly less than the assessed values at that time. Consequently, property

taxes paid to the Town of Plymouth for PNPS have declined from pre-1999 payments. Boston

Edison's parent, NSTAR, retained ownership of all transmission functions and facilities and

continues to pay property taxes to the Town of Plymouth for those facilities. As part of the utility

industry, the transmission facilities are also subject to the new property tax assessment

methodologies, with the effect that NSTAR will pay reduced property taxes to the Town of

Plymouth.

In FY 2004 (ending June 30, 2004), the Town of Plymouth collected $86.4 million in property

| taxes, of which $72.2 million were from real estate taxes (Town of Plymouth 2004a). Total town

revenues in that year were $126.96 million, implying that real estate taxes accounted for 57.7

percent of total town revenues.

Entergy paid $1.58 million in property taxes (real and personal property) in the Town's FY 2001

and $1.34 million for FY 2006. Additional data on Entergy’s property tax payments from the

| “Top Ten Property Taxpayers” in Plymouth over the years 2000-2006 are shown in Table 2-17.

Boston Edison’s payments are also shown, although these are for all its transmission facilities,

etc., not only those associated with the PNPS transmission lines.

Subsequent to the state’s deregulation law and Entergy’s purchase of PNPS, the Town of

Plymouth and Entergy agreed to payments in lieu of taxes (PILOT) of $1 million annually with

the potential for payments to increase should Entergy make capital improvements or substantial

| additions to the plant. The agreement continues through 2012, and would be renegotiated in the

| event of license renewal (Entergy 2006a). However, in April 2007, the Town of Plymouth

| reached a new five-year PILOT agreement with Entergy that increases Entergy’s annual

| payment to an estimated $8.49 million in FY2008 (Town of Plymouth 2007a). The payments

| decline thereafter, reaching an estimated $6.79 million in FY2012. The agreement includes a

| reopener provision in the event that PNPS’ current license is renewed. In addition, in order to

ameliorate the deregulation impacts on the Town of Plymouth’s revenues, the Massachusetts

legislature required NSTAR to make PILOT payments to the Town of Plymouth until the end of

PNPS' current license in 2012. NSTAR payments have been reduced from over $15 million in
Plant and the Environment

July 2007 2-123 NUREG-1437, Supplement 29

2001 to $12 million in 2006, and thereafter will decline to $1 million in 2007 and continue at that

level through 2012. This is a significant reduction from the $15 million in tax revenues previously

received by the town from Boston Edison Company. 

Until 1999, PNPS' property taxes provided approximately 22 percent of the Town of Plymouth's

total property tax revenues. In FY 2007, PNPS is expected to pay only about 2 percent of the |

total property taxes received by the Town of Plymouth. However, in FY2008 under the new |

PILOT agreement, the PNPS payment is expected to increase to about 9 percent of total |

property taxes revenues (Town of Plymouth 2007b). |

Table 2-17. PNPS Contributions to Town of Plymouth Property Tax Revenues 

Year Town of Plymouth

Total Property

Tax Revenues

($millions)

Property Tax Paid by Entergy Property Tax Paid by Boston

Edison/NSTAR*

($millions)

Percent of Total

Property Taxes

(%)

($millions)

Percent of Total

Property Taxes

(%)

2000 71.83 - - 15.35 21.37

2001 75.17 1.58 2.10 15.28 20.34

2002 76.38 2.01 2.63 13.03 17.05

2003 78.71 1.59 2.03 13.03 16.56

2004 86.57 1.53 1.77 13.03 15.05

2005 87.54 1.40 1.60 13.03 14.88

2006 93.48 1.34 1.43 12.03 12.87

*NSTAR, the parent company of Boston Edison, retained ownership of all transmission functions and facilities and

continues to pay property taxes to the Town of Plymouth.

Source: Town of Plymouth 2006b

2.2.9 Historic and Archaeological Resources

This section presents a brief summary of the region’s cultural background and a description of |

known historic and archaeological resources at the PNPS site and its immediate vicinity. The

information presented was collected from area repositories, the Massachusetts Historical

Commission (MHC), and the applicant’s Environmental Report (Entergy 2006a). |
Plant and the Environment 

 NUREG-1437, Supplement 29 2-124 July 2007

2.2.9.1 Cultural Background 

Native Americans first settled in southern New England following the recession of the Wisconsin

glacier approximately 10,000 years before present. Little information is available concerning the

population or subsistence strategies of these earliest groups, perhaps because the earliest sites

have been inundated by gradually rising sea levels or destroyed by development 

(Anderson and Gillam 2000). Over the following several thousand years prehistoric people in

this region gradually adapted to a slowly warming environment, although environmental change

was periodically more abrupt (McWeeney 1999; ENSR 2000). As the environment changed, so

did the available resource base and the tool kit utilized to exploit those resources. During the

most recent portion of prehistory, beginning a few thousand years before the present,

indigenous populations began to settle in semi-permanent villages based in part on agriculture

and fishing and to use pottery for both food preparation and storage.

Historically attested groups such as the Wampanoag inhabited the region at the time of

European contact during the 17th century. Documentary evidence indicates that the 17th

century Wampanoag would spend the warmer months of the year living along the coast to fish

and grow a variety of crops and the winter months inland where hunting and gathering would be

more abundant (Hasenstab 1999). Contact with Europeans led to a dramatic population

decrease due to lack of immunity to disease and later political conflicts and war led to additional

depopulation and displacement.

Among the separatists leaving England seeking religious autonomy during the 17th century was

a group, eventually known as the Pilgrims, which ultimately established a colony in Plymouth,

Massachusetts, a few miles northwest of PNPS in 1620. These colonists initially found survival

very difficult and were famously assisted by members of the Wampanoag. Additional groups

settled the region swelling the population to 7000 by the time Plymouth joined the Province of

Massachusetts Bay in 1691. 

During the 18th and 19th centuries regional populations dramatically increased. The primary

economic engines of the region were agriculture and maritime-industries, which were replaced

by tourism during the 20th century.

2.2.9.2 Historic and Archaeological Resources at the PNPS Site

2.2.9.2.1 Previously Identified Resources

The MHC houses the state's archaeological site files and information on historic resources such

as buildings and houses, including available information concerning the National or State

Register eligibility status of these resources. The NRC staff visited the MHC and collected site

| files on five archaeological sites located within or nearby the PNPS property. The first of these
Plant and the Environment

July 2007 2-125 NUREG-1437, Supplement 29

sites, listed as Manomet Site (MHC No. 19-PL-68), is described as being located "left of [the]

access road to PNPS off Route 3A" (Turner 1976), apparently at the edge of the wetland area |

immediately south of the station (Figure 2-13). No additional information was provided on this

site except that it was prehistoric and was investigated in 1972 by Dr. James Deetz of Brown

University. The second of these sites, listed as Forges Field P4 (MHC No. 19-PL-816),

consisted of two prehistoric artifacts collected from the ground surface within "highly disturbed

powerline corridor" (Donahue-Putnam 1997), several thousand feet southwest of PNPS. The

remaining three sites were discovered within a mile of the transmission line ROW, southwest of

PNPS, and were also prehistoric.

A review of the MHC files to identify above-ground cultural resources in Plymouth County

revealed 109 resources listed on the National Register of Historic Places (Entergy 2006a).

Within the Town of Plymouth there are 21 historic locations listed on the National Register

and/or State Register of Historic Places (Entergy 2006a). None of these sites are located within

the boundaries of the PNPS site or the associated transmission line ROW. 

In 1972, in advance of construction of the station, an archaeological survey was conducted of |

the 517 ac parcel of land on which the PNPS facility and the Jordan Road transmission line were |

proposed (AEC 1974). This survey was conducted by the Archaeological Research Department

of Plimoth Plantation and the Brown University Department of Anthropology. This survey

identified a total of 25 archaeological sites: 24 historic sites and one prehistoric site. The 24

historic sites were determined to not be significant and no further work was recommended. The

one prehistoric site was the subject of a more intensive investigation, which concluded that the

site was not eligible for listing (AEC 1974). This more intensive archaeological survey,

conducted by the two previously mentioned groups in collaboration with the Massachusetts

Archaeological Society, further concluded that the land around the proposed power station site

showed no evidence of prehistoric occupation. It appears that this prehistoric site is Manomet

Site (MHC No. 19-PL-68), described above. A search at the MHC and the Massachusetts

Archaeological Society failed to locate any documentation of the 1972 surveys.

2.2.9.2.2 Results of Walkover Survey

The NRC staff performed an informal walkover survey of the PNPS property during the site

audit, including the power block area, the former recreation area, the Entergy Woodlands area,

and a portion of the transmission line ROW. During this walkover it was observed that the power

block area has been extensively disturbed and graded while much of the former recreation area,

woodlands, and transmission ROW appear to have been only minimally disturbed. All of the

buildings and structures that comprise the station have been constructed since the early 1970s.

A surface scattering of late 19th century to early 20th century domestic refuse such as bottles

and ceramics was observed on the east side of the access road to the former recreation area. 

Plant and the Environment

July 2007 2-127 NUREG-1437, Supplement 29

The topography in the vicinity of these remains suggests gravel or sand mining and the area

may have also been used as a dump site. NRC staff examined two potential historic resources

in the woodlands area: a concrete and cinder block house foundation, apparently dating to the

early 20th century; and a granite quarrying site (Benjamin 2006).

2.2.9.2.3 Potential Archaeological Resources

Due to disturbances associated with site preparation and construction of the station, the power

block area has no potential for archaeological resources. There is the potential for |

archaeological resources to be present in the former recreation area, the woodlands area, and |

within the transmission line corridor. These areas appear to have been only minimally disturbed

and are comprised of landforms that may have been attractive during prehistory for varied

resource exploitation. A review of historic maps dating from 1879 (Walker 1879), 1895

(USGenNet.org 2006), and 1903 (Richards 1903) show very sparse development in the former |

recreation area, the woodlands area, and within the transmission line corridor, but there is the

potential for the presence of historic resources, particularly in light of the resources observed in

the former recreation area and woodlands area during the walkover described above. 

2.2.10 Related Federal Project Activities and Consultations

The NRC staff reviewed the possibility that activities of other Federal agencies might impact the

renewal of the OL for PNPS. Any such activities could result in cumulative environmental

impacts and the possible need for the Federal agency to become a cooperating agency for

preparation of this SEIS.

The NRC staff has reviewed local Federally owned facilities and Federally permitted industrial

facilities in the local area near Plymouth and Cape Cod Bay, and has determined that there are

no Federal project activities that would make it desirable for another Federal agency to become

a cooperating agency for preparing this SEIS. The only proposed Federal project in the local |

area is dredging for the Plymouth Harbor Federal Navigation Project by the U.S. Army Corps of

Engineers (USACE 2006). Pending applications for Federal permits in the area include the |

filling of 26 ac within Plymouth Bay by the Town of Plymouth, the construction of a pile- |

supported, fixed pier and floating docks in the Federal anchorage in Plymouth Harbor, dredging |

to reestablish the entrance to Ellisville Harbor in Plymouth, and the ability to retain and maintain

the Cordage Park Marina in Plymouth Bay (USACE 2006). The Mirant Canal Station power |

plant in Sandwich, on Cape Cod Canal, is the nearest power facility that extracts and discharges

cooling water under a Federally issued NPDES permit (EPA 2006b).

An additional Federal action in the area is the proposed implementation of NMFS’s Ship Strike

Reduction Strategy to reduce vessel strikes to the endangered North Atlantic right whale. 

Implementation of this strategy would involve establishment of a Seasonal Management Area in
Plant and the Environment 

 NUREG-1437, Supplement 29 2-128 July 2007

Cape Cod Bay in the winter and spring, routing measures in Cape Cod Bay to deflect major

vessel traffic away from right whale aggregations, and the establishment of as-needed Dynamic

Management Areas when whales are sighted (NOAA 2006).

| NRC is required under Section 102(c) of NEPA to consult with and obtain the comments of any

Federal agency that has jurisdiction by law or special expertise with respect to any

| environmental impact involved. NRC consulted with EPA, NMFS, and FWS. Consultation

| correspondence is included in Appendix E. Additionally, EPA and NMFS submitted written

| comments; their comments are addressed in Appendix.

2.3 References

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for

Protection Against Radiation.”

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, Appendix I, “Numerical

Guides for Design Objectives and Limiting Conditions for Operations to Meet the Criterion ‘As

Low As is Reasonably Achievable’ for Radiological Material in Light-Water-Cooled Nuclear

Power Reactor Effluents.”

| 40 CFR Part 82. Code of Federal Regulations, Title 40, Protection of Environment, Part 82,

| “Protection of Stratospheric Ozone.”

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190,

“Environmental Radiation Protection Standards for Nuclear Power Operations.”

| 40 CFR Part 260. Code of Federal Regulations, Title 40, Protection of Environment, Part 260,

| “Hazardous Waste Management System: General.”

| 40 CFR Part 261. Code of Federal Regulations, Title 40, Protection of Environment, Part 261,

| “Identification and Listing of Hazardous Waste.”

| 40 CFR Part 273. Code of Federal Regulations, Title 40, Protection of Environment, Part 273,

| ”Standards for Universal Waste Management.” 

| 40 CFR Part 370. Code of Federal Regulations, Part 370, “Hazardous Chemical Reporting:

| Community RIght-to-Know.”

50 CFR Part 17. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 17,

“Endangered and Threatened Wildlife and Plants.”
Plant and the Environment

July 2007 2-129 NUREG-1437, Supplement 29

310 CMR 10.00. Code of Massachusetts Regulations, Title 310, Department of Environmental |

Protection, Section 10, “Wetlands Protection.” |

310 CMR 30.1000. Code of Massachusetts Regulations, Title 310, Department of |

Environmental Protection, Section 30.1000, “Standards for Universal Waste Management.” |

310 CMR 30.000. Code of Massachusetts Regulations, Title 310, Department of Environmental

Protection, Section 30, “Hazardous Waste Regulations.” |

310 CMR 50.00. Code of Massachusetts Regulations, Title 310, Department of Environmental |

Protection, Part 50, “Toxics Use Reduction.” |

Able, K.W., and M.P. Fahay. 1998. The first year in the life of estuarine fishes in the Middle

Atlantic Bight. Rutgers University Press. New Brunswick, NJ, pg. 342. |

Able, K.W., C.B. Grimes, R.A. Copper, and J.R. Uzmann. 1982. Burrow construction and

behavior of tilefish, Lopholatilus chamaeleonticeps, in the Hudson Submarine Canyon. 

Environmental Biology Fishes 7: pgs. 199-205. |

Able, K.W., R.E. Matheson, W.W. Morse, M.P. Fahay, and G. Shepherd. 1990. Patterns of

summer flounder Paralichthys dentatus early life history in the Mid-Atlantic Bight and New Jersey

estuaries. Fisheries Bulletin (U.S.) 88: pgs. 1-12. |

Allen, D.M., J.P. Clymer, III, and S.S. Herman. 1978. Fishes of Hereford Inlet estuary, southern

New Jersey. Lehigh University Department of Biology, Center for Marine Environmental Studies |

and the Wetlands Institute, pg. 138. |

Anderson, David and J. Christopher Gillam. 2000. "Paleoindian Colonization of the Americas:

Implications from an Examination of Physiography, Demography, and Artifact Distribution."

American Antiquity 65(1): pgs. 43-66. |

Anderson, E.D. 1982. Status of the northwest Atlantic mackerel stock – 1981. U.S. National |

Marine Fisheries Service, Northeast Fishery Science Center Woods Hole Laboratory Reference |

Document 81-38: pg. 38. |

Anderson, E.D. 1995. Atlantic mackerel, in Conservation and Utilization Division, Northeast

Fisheries Science Center ed. Status of fishery resources off the northeastern United States for

1994, pgs. 100-101. NOAATechnical Memorandum NMFS-NE-108. |
Plant and the Environment 

 NUREG-1437, Supplement 29 2-130 July 2007

Anderson, M.E. 1994. Summary report: Fish Spotting Overflights in western Cape Cod Bay in

1993. Marine ecology studies related to operation of Pilgrim Station, Semi-annual report

| Number 43, January 1993-December 1993, pg. 4.

| Ankaru, M. 1964. Influence of the Cape Cod Canal on the Hydrography and on the Copepods in

| Buzzards Bay and Cape Cod Bay, Massachusetts. I. Hydrography and Distribution of Copepods.

| Limnology and Oceanography 9: pgs. 46-60.

Anthony, V.C., and G.T. Waring. 1980. A review of the herring fisheries, their assessment, and

management in the Georges Bank-Gulf of Maine area. Proceedings of the Alaska herring

| symposium, February, 19-21 1980, Anchorage, Alaska, pgs. 115-178.

Atkinson, D.B. 1989. Diel movements of beaked redfish and the implications of these for

| stratified random bottom trawl estimates of biomass and abundance. North American Journal of

| Fisheries Management 9: pgs. 163-170.

Atlantic States Marine Fisheries Commission (ASMFC). 2006. ASMFC Stock Status Overview,

August 2006.

Atomic Energy Commission (AEC). 1972. Final Environmental Statement related to operation

of Pilgrim Nuclear Power Station. Boston Edison Company, May 1972.

Atomic Energy Commission (AEC). 1974. Final Environmental Statement related to the

proposed Pilgrim Nuclear Power Station Unit 2. Boston Edison Company, September 1974. 

Auster, P.J. 1985. Some observations of fish orientation to current direction and effects on

| predator-prey interactions. Northwest Atlantic Fisheries Organization (NAFO) Scientific Council

| Studies 8: pgs. 53-55.

Barnstable County. 2006. History and the Role of County Government on Cape Cod. 

Accessed at: http://www.barnstablecounty.org/historyBC.htm on September 6, 2006.

Bayliff, W.H. 1950. The Life History of the Silverside, Menidia menidia. Chesapeake Biological

| Laboratory, Publication Number 90.

Beacham, T.D. 1983. Variability in size and age at sexual maturity of witch flounder,

Glyptocephalus cynoglossus, in the Canadian Maritimes region of the northwest Atlantic Ocean.

| Canadian Field Naturalist 97, pgs. 409-422.

Belding, D.L. 1921. A report upon the Alewife Fisheries of Massachusetts. Division of Marine

| Fisheries and Game, Department of Conservation, Boston, Massachusetts.

Benjamin Forestry Services. May 24, 2006. Facility Map.
Plant and the Environment

July 2007 2-131 NUREG-1437, Supplement 29

Berrien, P., and Sibunka, J. 1999. Distribution patterns of fish eggs in the United States

northeast continental shelf ecosystem 1977-1987. NOAA Technical Report NMFS 145, pg. 310. |

Bigelow, H.B., and W.C. Schroeder. 1953. Fishes of the Gulf of Maine. U.S. Fish and Wildlife |

Service, Fisheries Bulletin 53, pg. 577. |

Biomes Marine Biology Center. 2006. Rock Gunnel Fact Sheet. Accessed at:

http://www.biomescenter.com/rockgunnel_fs.htm on September 28, 2006.

Blaxter, J.H.S., D. Danielssen, E. Mokness, and V. Oiestad. 1983. Description of the early

development of the halibut, Hippoglossus hippoglossus and attempts to rear the larvae past first

feeding. Marine Biology 73: pgs. 99-107. |

Blaxter, J.S., and F.T. Holliday. 1963. The behavior and physiology of herring and other

clupeids. Advances in Marine Biology 1: pgs. 261-393. |

BMLSS. 1997 and 1998. Accessed at:

http://ourworld.compuserve.com/homepages/BLMSS/halibut2.htm on August 8, 2006. 

Bolles, K.L., and G.A. Begg. 2000. Distinction between silver hake (Merluccius bilinearis)

stocks in U.S. waters based on whole otolith morphometrics. Fisheries Bulletin (U.S.) 98: pgs. |

451-462. 

Boston Edison. 1999. Pilgrim Station Site Characterization Report. Prepared for Entergy

Corporation 1999. Revision 0. Boston Edison, Plymouth, Massachusetts.

Bowman, R.E. 1984. Food of silver hake (Merluccius bilinearis). Fisheries Bulletin (U.S.) 82, |

pgs. 21-35. |

Bowman, R.E., C.E. Stillwell, W.L. Michaels, and M.D. Grosslein. 2000. Food of the Northwest

Atlantic fishes and two common species of squid. NOAA Technical Memo NMFS-NE-155, |

pg. 138. |

Bridges, W.L. and R.D. Anderson. 1984. A brief survey of Pilgrim Nuclear Power Plant effects

upon the marine aquatic environment. Ecology and Biology of Western Cape Cod Bay,

Massachusetts. Lecture Notes on Coastal and Estuarine Studies, 11, Eds. J.D. Davis and D.

Merriman, pgs. 263-277. Springer-Verlag. |

Brodziak, J. 1995. Atlantic Butterfish. In Conservation and Utilization Division, Northeast

Fisheries Science Center, eds., Status of fishery resources off the northeastern United States for

1994, pgs. 102-103. NOAA Technical Memo NMFS-F/NEC-108. |

Brodziak, J. 2001a. Silver Hake. Accessed at:

http://www.nefsc.nmfs.gov/sos/spsyn/pg/silverhake/silverhake.pdf on August 8, 2006.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-132 July 2007

Brodziak, J. 2001b. Red Hake. January 2001. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/pg/redhake/ accessed on August 8, 2006.

Brodziak, J., and L. Col. 2005. Atlantic Halibut. In Assessment of 19 Northeast groundfish

stocks through 2004 2005 Groundfish Assessment Review Meeting (2005 GARM), Northeast

Fisheries Science Center, Woods Hole, Massachusetts, 15-19 August 2005, Northeast Fisheries

Science Center Reference Document 05-13. Accessed at:

http://www.nefsc.noaa.gov/nefsc/publications/crd/cdr0513 on August 8, 2006.

Brodziak, J., and M. Traver. 2005. Gulf of Maine Haddock. In Assessment of 19 Northeast

groundfish stocks through 2004 2005 Groundfish Assessment Review Meeting (2005 GARM),

Northeast Fisheries Science Center, Woods Hole, Massachusetts, 15-19 August 2005,

Northeast Fisheries Science Center Reference Document 05-13. Accessed at:

http://www.nefsc.noaa.gov/nefsc/publications/crd/cdr0513, on August 8, 2006.

Brodziak, J.K.T., and W.K. Macy. 1996. Growth of long-finned squid, Loligo pealei, in the

| northwest Atlantic Fisheries Bulletin (U.S.) 94: pgs. 212-236.

Brodziak, J.K.T. 2005. Essential Fish Habitat Source Document: Haddock, Melanogrammus

aeglefinus, Life History and Habitat Characteristics. NOAA Technical Memorandum NMFS-NE196, December 2005. 

Brown, M.W., O. Nichols, M.K. Marx, and J.N. Ciano. 2002. Surveillance monitoring and

management of North Atlantic right whales (Eubalaena glacialis) in Cape Cod Bay,

Massachusetts, 2002. Final Report to Division of Marine Fisheries, Commonwealth of

| Massachusetts, and Massachusetts Environmental Trust, September 2002, pg. 28.

Brown, R. 2000. Haddock. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/pg/haddock/ on August 8, 2006.

BSC Group, Inc. 1996. Supporting Information for Department of the Army Permit,

Maintenance Dredging of Pilgrim Nuclear Power Station Intake Canal. Prepared for Boston

Edison Company, September 13, 1996.

Buck, E.H. 1995. Atlantic Bluefin Tuna: International Management of a Shared Resource, CRS

Report for Congress, 95-367 ENR. Accessed at:

http://www.ncseonline.org/NLE/CRSreports/Marine/mar-5.cfm on August 8, 2006. 

Buckley, J. 1989. Species Profile: Life Histories and Environmental Requirements of Coastal

Fishes and Invertebrates (North Atlantic). Rainbow Smelt. USFWS Biological Report 82

(11.106).

Bulloch, D. K. 1986. Marine Gamefish of the Middle Atlantic. Special Publication # 13 of the

American Littoral Society.
Plant and the Environment

July 2007 2-133 NUREG-1437, Supplement 29

Burnett, J, M.R. Ross, and S.H. Clark. 1992. Several biological aspects of the witch flounder

(Glyptocephalus cynoglossus (L.)) in the Gulf of Maine-Georges Bank region. Journal of |

Northwest Atlantic Fisheries Science. Volume 12: pgs. 15-25. |

Cadrin, S.X. 2000a. Longfin Inshore Squid. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/iv/lfsquid/ on August 8, 2006.

Cadrin, S.X. 2000b. Yellowtail Flounder. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/fldrs/yellotail/ on August 8, 2006. 

Cadrin, S.X., and J. King. 2002. Stock assessment of yellowtail flounder in the Cape Cod-Gulf

of Maine area. Northeast Fisheries Science Center Reference Document 03-03. |

Cadrin, S.X., C.M. Legault, and J. King. 2005. Cape-Cod-Gulf of Maine Yellowtail Flounder. In

Assessment of 19 Northeast groundfish stocks through 2004 2005 Groundfish Assessment

Review Meeting (2005 GARM), Northeast Fisheries Science Center, Woods Hole,

Massachusetts, 15-19 August 2005. Northeast Fisheries Science Center Reference Document

05-13. Accessed at: http://www.nefsc.noaa.gov/nefsc/publications/crd/cdr0513 on August 8,

2006.

California Regional Water Quality Control Board (CRWQCB). 2004. Cancer Crabs. Accessed |

at: http://www.swrcb.ca.gov/rwqcb3/facilities.dukeenergy/cancercra\bs.pdf on September 28,

2006.

Cape Cod Commission. 2003. Cape Cod Regional Policy Plan, Barnstable County,

Massachusetts. Revised July 2003, effective September 10, 2003. Barnstable, Massachusetts.

Cargnelli, L.M., S.J., Griesbach, P.L. Berrien, W.W. Morse, and D.L. Johnson. 1999a. Essential

Fish Habitat Source Document: Haddock, Melanogrammus aeglefinus, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-128. September 1999. 

Cargnelli, L.M., S.J. Griesbach, D.B. Packer, and E. Weissberger. 1999b. Essential Fish

Habitat Source Document: Atlantic Surfclam, Spisula solidissima, Life History and Habitat

Characteristics. U. S. Department of Commerce, National Oceanic and Atmospheric

Administration, National Marine Fisheries Service, Northeast Region, Northeast Fisheries

Science Center, Woods Hole, Massachusetts. NOAA Technical Memorandum NMFS-NE-142.

September 1999.

Cargnelli, L.M., S.J., Griesbach, and W.W. Morse. 1999c. Essential Fish Habitat Source

Document: Atlantic Halibut, Hippoglossus hippoglosus, Life History and Habitat Characteristics.

NOAA Technical Memorandum NMFS-NE-125. September 1999. 
Plant and the Environment 

 NUREG-1437, Supplement 29 2-134 July 2007

Cargnelli, L.M., S.J., Griesbach, D.B. Packer, P.L. Berrien, W.W. Morse, and D.L. Johnson.

1999d. Essential Fish Habitat Source Document: Witch Flounder, Glyptocephalus cynoglossus,

Life History and Habitat Characteristics. NOAA Technical Memorandum NMFS-NE-139.

September 1999. 

Cargnelli, L.M., S.J., Griesbach, D.B. Packer, P.L. Berrien, D.L. Johnson, and W.W. Morse.

1999e. Essential Fish Habitat Source Document: Pollock, Pollachius virens, Life History and

Habitat Characteristics. NOAA Technical Memorandum NMFS-NE-131. September 1999.

Cargnelli, L.M., S.J. Griesbach, D.B. Packer, and E. Weissberger. 1999f. Essential Fish Habitat

Source Document: Ocean quahog, Artica islandica, Life History and Habitat Characteristics. U.

S. Department of Commerce, National Oceanic and Atmospheric Administration, National

Marine Fisheries Service, Northeast Region, Northeast Fisheries Science Center, Woods Hole,

Massachusetts. NOAA Technical Memorandum NMFS-NE-148. September 1999.

Cargnelli, L.M., S.J., Griesbach, C. McBride, C.A. Zetlin, and W.W. Morse. 1999g. Essential

Fish Habitat Source Document: Longfin Inshore Squid, Loligo pealeii, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-146. September 1999. 

Cargnelli, L.M., S.J., Griesbach, and C.A. Zetlin. 1999h. Essential Fish Habitat Source

Document: Northern Shortfin Inshore Squid, Illex illecebrosus, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-147. September 1999. 

Census of Marine Life in the Gulf of Maine. 2006. Fishes. Accessed at:

http://www.usm.maine.edu/gulfofmaine-census/Docs/Reference on September 28, 2006. 

CETAP. 1982. A characterization of marine mammals and turtles in the mid- and north Atlantic

areas of the U.S. outer continental shelf. Cetacean and Turtle Assessment Program, University

of Rhode Island, Final Report #AA551-DT8-48 to the Bureau of Land Management, Washington,

| DC, pg. 538.

Chang, S., W.W. Morse, and P.L. Berrien. 1999a. Essential Fish Habitat Source Document:

White Hake, Urophycis tenuis, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-136. September 1999. 

Chang, S., P.L. Berrien, D.L. Johnson, and W.W. Morse. 1999b. Essential Fish Habitat Source

Document: Windowpane, Scophthalmus aqusos, Life History and Habitat Characteristics. NOAA

Technical Memorandum NMFS-NE-137. September 1999. 

Chang, S., P.L. Berrien, D.L. Johnson, and C.A. Zetlin. 1999c. Essential Fish Habitat Source

Document: Offshore Hake, Merluccius albidus, Life History and Habitat Characteristics. NOAA

Technical Memorandum NMFS-NE-130. September 1999. 
Plant and the Environment

July 2007 2-135 NUREG-1437, Supplement 29

Chase, B. 2006a. Final Report for 2004 Season; Population Indices of Rainbow Smelt

(Osmerus mordax) Spawning Runs in Massachusetts. Massachusetts Division of Marine

Fisheries. February 2006. 

Chase, B. 2006b. Massachusetts Division of Marine Fisheries, Information regarding Rainbow

Smelt (Osmerus mordax) Jones River Population, August 16, 2006.

Clark, S.H., and R. Livingstone Jr. 1982. Ocean Pout, Macrozoarces americanus. In Grosslein,

M.D., and T.R. Azarovitz eds., Fish Distribution, pgs. 76-79, MESA New York Bight Atlas |

Monograph 15,New York Sea Grant Institute. Albany,New York.

Clayton, G.R., C.F. Cole, S.A. Murawski, and J.D. Parrish. 1978. Common Marine Fishes of

Coastal Massachusetts. University of Massachusetts, Institute of Environmental Publications. R76-16.

Coastal Zone Management Act of 1972 (CZMA) 16 USC 1451, et seq.

Cohen, D.M., T. Inada, T. Iwamoto, and N. Scialabba. 1990. FAO species catalogue, Volume |

10, Gadiform fishes of the world (Order Gadiformes), An annotated and illustrated catalogue of |

cods, hakes, grenadiers and other gadiform fishes known to date. FAO Fisheries Synopsis 125, |

 pg. 442. |

Collette, B.B., and C.E. Nauen. 1983. FAO species catalogue, Volume 2, Scombrids of the |

world, An annotated and illustrated catalogue of tunas, mackerels, bonitos and related species

known to date. FAO Fisheries Synopsis Number 125, Volume 2: Food and Agriculture |

Organization of the United Nations, Rome, Italy, pg. 137. |

Collette, B.B., and K.E. Hartel. 1988. Annotated list of fishes of Massachusetts Bay. NOAA 

Technical Memorandum NMFS-F/NEC-51, pg. 70. |

Colton, J.B., Jr. 1972. Temperature trends and the distribution of groundfish in continental shelf

waters, Nova Scotia to Long Island. Fisheries Bulletin 70, pgs. 637-658. |

Colton, J.B., Jr., and R.F. Temple. 1961. The enigma of Georges Bank spawning. Limnol.

Oceanogr. 6: pgs. 280-291. |

Colton, J.B., Jr., and R.R. Marak. 1969. Guide for identifying the common planktonic fish eggs

and larvae of continental shelf waters, Cape Sable to Block Island. U.S.Bureau of Commercial |

Fisheries, Biological Laboratory. Woods Hole Laboratory. Reference Number 69-9, pg. 43. |

Conant, R. and J.T. Collins. 1998. A Field Guide to Reptiles and Amphibians, Eastern and

Central North America, Third Edition, Expanded. Houghton Mifflin Co., Boston, Massachusetts.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-136 July 2007

Cooper, J.A., and F. Chapleau. 1998. Monophyly and intrarelationships of the family

| Pleuronectidae (Pleuronectiformes), with a revised classification. Fisheries Bulletin 96(4):

| pgs. 686-726.

Crawford, J., R. Fleming, J. Smith, and K. Larade. 2005. Candidate HAPC Proposal to the New

England Fishery Management Council (NEFMC), Habitat Areas of Particular Concern: A MultiSpecies Approach for Juveniles of Eight Overfished Species. May 12, 2005. Accessed at

http://www.nefmc.org/habitat/habitat.html on August 8, 2006.

Cross, J.N., C.A. Zetlin, P.L. Berrien, D.L. Johnson, and C. McBride. 1999. Essential Fish

Habitat Source Document: Butterfish, Peprilus triacanthus, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-145. September 1999.

Davis, J.D. and R.A. McGrath. 1984. Some Aspects of nearshore benthic macrofauna in

western Cape Cod Bay. In: Observations on the Ecology and Biology of Western Cape Cod

| Bay, Massachusetts. Lecture Notes on Coastal and Estuarine Studies, Volume 11, Eds. J.D.

| Davis and D. Merriman, pgs. 77-102. Springer-Verlag.

Dawe, E.G. 1988. Length-weight relationships for short-finned squid in Newfoundland and the

| effect of diet on condition and growth. Transactions of the American Fisheries Society 177: 

| pgs. 591-599.

Department of Fisheries and Oceans (DFO). 1989. Communications Directorate, Ottawa,

Ontario. Accessed at http://www.mi.mun.ca/mi%2Dnet/fishdeve/plaice.htm on August 8, 2006. 

Deree, H.L. 1999. Age and growth, dietary habits, and parasitism of the fourbeard rockling,

| Enchelyopus cimbrius, from the Gulf of Maine. Fisheries Bulletin 97: pgs. 39–52.

Dery, L.M. 1988a. Silver hake (Merluccius bilinearis). Age determination methods for

| Northwest Atlantic species, pgs. 41-44. NOAA Technical Memorandum NMFS-72. 

Dery, L.M. 1988b. Butterfish. Peprilus triacanthus. In J. Penttila and L.M. Dery, eds., Age

| Determination methods for northwest Atlantic species, pgs. 85-92. NOAA Technical Report

| NMFS-72.

Deuel, D.G. 1964. Evidence of spawning of tagged bluefish, Underwat. Nat., 2(2): 24. 

Donahue-Putnam, Barbara. 1997. Form D – Archaeological Survey, Prehistoric Archaeological

Sites. MHCNumber 19-PL-816, Massachusetts Historical Commission.

Dooley, J.K. 1978. Systematics and biology of the tilefishes (Perciformes: Brackiostegidae and

| Malacanthidae), with descriptions of two new species. NOAA Technical Report NMFS Circ. 411,

| pg. 78.
Plant and the Environment

July 2007 2-137 NUREG-1437, Supplement 29

Edwards, R.L., and R.E. Bowman. 1979. Food consumed by continental shelf fishes. In

Clepper, H, ed., Predator-prey systems in fish communities and their role in fisheries

management. Sport Fishing Institute, Washington, DC, pgs. 387-406. |

EG&G. 1995. Pilgrim Nuclear Power Station cooling water discharge bottom temperature

study. August 1994. Final report to Boston Edison Company, Plymouth, Massachusetts. Pg. 83. |

and appendices A-C.

Endangered Species Act of 1973 (ESA) 16 USC 1531, et seq.

ENSR. March 2000. Redacted Version 316 Demonstration Report – Pilgrim Nuclear Power

Station.

ENSR and MRI 2005. Study of Winter Flounder Larval Transport in Coastal Cape Cod Bay and |

Entrainment at Pilgrim Nuclear Power Station, Spring 2004. Contained in Marine Ecology |

Studies, Pilgrim Nuclear Power Station, Report No. 65, January 2004 - December 2004. |

Environmental Protection Group, Entergy Nuclear-Pilgrim Station. April 30, 2005. |

Entergy Nuclear Operations, Inc. (Entergy). 2002a. Radiological Environmental Monitoring

Program Report, January 1 through December 31, 2001, May 2002.

Entergy Nuclear Operations, Inc. (Entergy). 2002b. Radiological Effluent and Waste Disposal

Report, January 1 through December 31, 2001.

Entergy Nuclear Operations, Inc. (Entergy). 2002c. Forest Management Plan for Entergy

Woodlands, Plymouth, Massachusetts. Prepared for Entergy by Benjamin Forestry Services,

South Easton, MA and submitted to the Massachusetts Dept. of Environmental Management,

Division of Forests and Parks, Boston, Massachusetts. September 12, 2002.

Entergy Nuclear Operations, Inc. (Entergy). 2003a. Radiological Environmental Monitoring

Program Report, January 1 through December 31, 2002, May 2003.

Entergy Nuclear Operations, Inc. (Entergy). 2003b. Radiological Effluent and Waste Disposal

Report, January 1 through December 31, 2002. 

Entergy Nuclear Operations, Inc. (Entergy). 2003c. Pilgrim Nuclear Power Station Offsite Dose

Calculation Manual, Rev.9, Plymouth, Massachusetts. October 6, 2003.

Entergy Nuclear Operations, Inc. (Entergy). 2004a. Radiological Environmental Monitoring

Program Report, January 1 through December 31, 2003, May 2004.

Entergy Nuclear Operations, Inc. (Entergy). 2004b. Radiological Effluent and Waste Disposal

Report, January 1 through December 31, 2003.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-138 July 2007

Entergy Nuclear Operations, Inc. (Entergy). 2005a. Radiological Environmental Monitoring

Program Report, January 1 through December 31, 2004, May 2005.

Entergy Nuclear Operations, Inc. (Entergy). 2005b. Radiological Effluent and Waste Disposal

Report, January 1 through December 31, 2004. 

Entergy Nuclear Operations, Inc. (Entergy). 2005c. Authorized Withdrawal Volume. February

25, 2005.

|

| Entergy Nuclear Operations, Inc. (Entergy). 2006a. Applicant’s Environmental Report –

Operating License Renewal Stage, Pilgrim Nuclear Power Station. DocketNumber 50-293,

Plymouth, Massachusetts.

Entergy Nuclear Operations, Inc. (Entergy). 2006b. Radiological Environmental Monitoring

Program Report, January 1 through December 31, 2005, May 2006.

Entergy Nuclear Operations, Inc. (Entergy). 2006c. Radiological Effluent and Waste Disposal

Report, January 1 through December 31, 2005. 

Entergy Nuclear Operations, Inc. (Entergy). 2006d. Discharge Monitoring Reports for Pilgrim

Nuclear Power Station, NPDES Permit Number MA0003557 (Federal) and Number 359 (State). 

April 2005 to March 2006. Plymouth, Massachusetts.

Entergy Nuclear Operations, Inc. (Entergy). 2006e. Groundwater Permit Discharge Monitoring

Report, Groundwater Discharge Permit SE #2-389, Pilgrim Nuclear Power Station. January

2005 to March 2006. Plymouth, Massachusetts.

Entergy Nuclear Operations, Inc. (Entergy). 2006f. License Renewal Application Amendment 6,

| Pilgrim Nuclear Power Station, Docket Number 50-293, Plymouth, Massachusetts, August 22,

2006.

| Entergy Nuclear Operations, Inc. (Entergy). 2006g. Entergy Nuclear Waste Minimization Plan. 

| Revision 0. July 2006.

Environmental Protection Agency (EPA). 1993. Assessment of Potential Impact of the MWRA

Outfall on Endangered Species. Boston, Massachusetts.

Environmental Protection Agency (EPA). 1994. Modification of Authorization to Discharge

Under the National Pollutant Discharge Elimination System. Federal Permit Number

MA0003557. Water Management Division, EPA Region I, Boston, Massachusetts.

Environmental Protection Agency (EPA). 2003. Annual Report on Air Quality in New England,

2003.
Plant and the Environment

July 2007 2-139 NUREG-1437, Supplement 29

Environmental Protection Agency (EPA). 2004. Ground-level Ozone, Ozone Designations. |

Accessed at: http://www.epa.gov/ozonedesignations/part81r8c.pdf on April 25, 2007 |

Environmental Protection Agency (EPA). 2006a. Level III Ecoregions of the Conterminous

United States. June 2006.

Environmental Protection Agency (EPA). 2006b. NPDES Fact Sheet, Mirant Canal Station Draft

NPDES Permit. Accessed at: http://www.epa.gov/NE/npdes/mirantcanal/index.html on

September 28, 2006.

Environmental Protection Agency (EPA) 2007. Implementation of the Decision in Riverkeeper, |

Inc. v EPA, Remanding the Cooling Water Intake Structures Phase II Regulation. Accessed at: |

www.epa.gov/waterscience/316b/phase2/implementation-200703.pdf on May 2, 2007. |

Estrella, B.T. Undated. Synopsis of Crustacean Resources in Massachusetts Waters.

Massachusetts Division of Marine Fisheries. Accessed at:

http://www.mass.gov/czm/oceanmanagement/taskforce/pdf/estrella.pdf on September 28, 2006.

Estrella, B.T. and T.D. Morissey. 1997. Seasonal movement of offshore American lobster,

Homarus americanus, tagged along the eastern shore of Cape Cod, Massachusetts. Fishery

Bulletin 95: pgs. 466-476. |

Evseenko, S.A., and M.M. Nevinsky. 1975. Spawning and development of the witch flounder,

Glyptocephalus cynoglossus L. In the northwest Atlantic, International Commission for the |

Northwest Atlantic Fisheries (ICNAF) Research Bulletin Number 11, pgs. 111-123. |

Executive Order 12898. “Federal Actions to Address Environmental Justice in Minority

Populations and Low-Income Population.” February 16, 1994, Federal Register, Volume 59, |

Number 32, Washington, DC |

Fahay, M.P., and K.W. Able. 1989. White hake, Urophycis tenuis, in the Gulf of Maine:

spawning seasonality, habitat use, and growth in young of the year and relationships of the

Scotian Shelf population. Canadian Journal of Zoology 67: pgs. 1715-1724. |

Fahay, M.P., P.L. Berrien, D.L. Johnson, and W.W. Morse. 1999a. Essential Fish Habitat

Source Document: Atlantic Cod, Gadus morhua, Life History and Habitat Characteristics. 

NOAA Technical Memorandum NMFS-NE-124. September 1999.

Fahay, M.P., P.L. Berrien, D.L. Johnson, and W.W. Morse. 1999b. Essential Fish Habitat

Source Document: Bluefish, Pomatomus saltatrix, Life History and Habitat Characteristics.

NOAA Technical Memorandum NMFS-NE-124. September 1999. 

Federal Water Pollution Control Act of 1977. 33 USC 1326, et seq. (also known as the Clean

Water Act [CWA]).
Plant and the Environment 

 NUREG-1437, Supplement 29 2-140 July 2007

Fish and Wildlife Service (FWS). 1980. Endangered and Threatened Wildlife and Plants;

Listing as Endangered with Critical Habitat for the Plymouth Red-Bellied Turtle in

| Massachusetts, Final Rule. 50 CFR Part 17, Federal Register, Volume 45, Number 65, Pgs.

| 21828 – 21833. April 2, 1980. 

Fish and Wildlife Service (FWS). 2006a. Letter from Michael J. Amaral, Endangered Species

Specialist, New England Field Office, US FWS, to Rani Franovich, NRC. Response to April 25,

2006 letter from NRC requesting information on protected, proposed, and candidate species and

critical habitat in the vicinity of PNPS and its transmission line right-of-way. May 23, 2006.

Fish and Wildlife Service (FWS). 2006b. USFWS Threatened and Endangered Species

System (TESS), Listings and Occurrences for Massachusetts. Accessed at:

www.ecos.fws.gov/tess_public on August 8, 2006.

| Fish and Wildlife Service (FWS). 2007. Bald Eagle Soars Off Endangered Species List. 

| Accessed at: www.fws.gov/migratorybirds/baldeagle.htm on July 1, 2007.

Fishbase.org. 2006. Atlantic tomcod. Accessed at:

http://www.fishbase.org/Summary/SpeciesSummary.php?id=316 on September 28, 2006.

Fisheries and Oceans Canada. 2006. Sand Lance. Accessed at: 

http://www.dfo-mpo.gc.ca/zone/underwater_sousmarin/SandLance/sandlanc_e.htm on

September 28, 2006.

Freeman, B.L., and S.C. Turner. 1977. Biological and fisheries data on tilefish, Lopholatilus

| chamaeleonticeps Goode and Beane, from the South Atlantic Bight, U.S. National Marine

| Fisheries Service, Northwest Fisheries Center Sandy Hook Laboratory Technical Service Report

| Number 5, pg. 41. 

Froerman, Y.M. 1984. Feeding spectrum and trophic relationships of short-finned squid (Illex

| illecebrosus) in the Northwest Atlantic. Northwest Atlantic Fisheries Organization Scientific

| Council.

Gabriel, W.L. 1998. Scup, in S.H. Clark, ed., Status of the fishery resources off the

| northeastern United States for 199., pgs. 90-91. NOAA Technical Memorandum NMFS-NE-115. 

Galya et al. 1997. Massachusetts Water Resources Authority Outfall Monitoring Overview

| Report: 1996. MWRA Environmental Quality Department Technical Report Series 97-8. pg. 57. 

Garrison, L.P., and J.S. Link. 2000. Diets of five hake species in the northeast United States

| continental shelf system, Marine Ecology Progress Series 204: pgs. 243-255.

Gosner, K.L. 1978. A Field Guide to the Atlantic Seashore from the Bay of Fundy to Cape

Hatteras. Peterson Guides, Houghton Mifflin Company, Boston, Massachusetts.
Plant and the Environment

July 2007 2-141 NUREG-1437, Supplement 29

Gotceitas, V. and J.A. Brown. 1993. Substrate selection by juvenile cod (Gadus morhua): effects

of predation risk. Oecologia 93: pgs 31-37. |

Green, J.M., and M. Farwell. 1971. Winter habits of the Cunner, Tautogolabrus adspersus, in

Newfoundland. Canadian Journal of Zoology 49: pgs. 1497-1499. |

Grimes, G.B., C.F. Idelberger, K.W. Able, and S.C. Turner. 1988. The reproductive biology of

tilefish, Lopholatilus chamaeleonticeps Goode and Beane, from the United States Mid-Atlantic

Bight, and the effects of fishing on the breeding system. Fisheries Bulletin (U.S.) 86: |

pgs. 745-762. |

Grimes, G.B., K.W. Able, and R.S. Jones. 1986. Tilefish, Lopholatilus chamaeleonticeps,

habitat, behavior, and community structure in Mid-Atlantic and southern New England waters. 

Environmental Biology of Fishes 15: pgs. 273-292. |

Grocki, W. 1984. Algal investigations in the vicinity of Plymouth, Massachusetts. In:

Observations on the Ecology and Biology of Western Cape Cod Bay, Massachusetts. Lecture

Notes on Coastal and Estuarine Studies. Volume 11, Eds. J.D. Davis and D. Merriman. |

pgs. 19-47. |

Gulf of Maine Census of Marine Life (GOMCML). 2006. Dynamac Atlas of the Gulf of Maine.

Accessed at http://gmbis.iris.usm.maine.edu/products.asp on September 28, 2006.

Gulf of Maine Research Institute. 2006. Four-spotted Flounder. Accessed at:

http://www.gma.org/fogm/Paralichthys_oblongus.htm on September 28, 2006.

Harding, G.C. 1992. American Lobster (Homarus americanus Milne Edwards): A Discussion

Paper on their Environmental Requirements and the Know Anthropogenic Effects on their

Populations. Canadian Technical Report of Fisheries and Aquatic Sciences 1887. pg. 16. |

Hardy, J.D., Jr. 1978. Development of fishes of the Mid-Atlantic Bight: An atlas of egg, larval,

and juvenile stages. Volume 2 Anguillidae through Syngnathidae. U.S. Fish Wildlife Service. |

Biological Service Program. FWS/OBS-78/12, pg. 458. |

|

Hart, D.R. and A.S. Chute. 2004. Essential Fish Habitat Source Document: Sea Scallop,

Placopecten magellanicus, Life History and Habitat Characteristics. U. S. Department of

Commerce, NOAA, NMFS, Northeast Region, Northeast Fisheries Science Center, Woods Hole,

Massachusetts. NOAA Technical Memorandum NMFS-NE-189. September 2004.

Hartley, D.L. 1995. The population biology of the goosefish, Lophius americanus, in the Gulf of

Maine. M.S. Thesis, University of Massachusetts, Amherst, Massachusetts. pg.142. |

Hatfield, E.M.C., and S.X. Cadrin. 2002. Geographic and temporal patterns in size and maturity

of the longfin inshore squid (Loligo pealeii) off the northeastern United States. Fisheries Bulletin |

(U.S.) 100: pgs. 200-213. |
Plant and the Environment 

 NUREG-1437, Supplement 29 2-142 July 2007

Hasenstab, R.J . 1999. “Fishing, Farming, and Finding the Village Sites: Centering Late

Woodland New England Algonquians.” In The Archaeological Northeast, M.A.E. Levine, K.S.

Sassaman, and M. Nassaney, eds. 139-53. New York: Bergin & Garvey.

Hendrickson, L. 1998. Windowpane. In S.H. Clark, ed., Status of the fishery resources off the

| northeastern United States for 1998. pgs. 85-87. NOAA Technical Memorandum NMFS-NE115. 

| Hendrickson, L. 2000a. Northern Shortfin Squid, January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/iv/sfsquid/ on August 17, 2006.

| Hendrickson, L. 2000b. Windowpane Flounder. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/fldrs/window/ on August 8, 2006.

| Hendrickson, L., and E.M. Holmes. 2004. Essential Fish Habitat Source Document: Northern

| Shortfin Squid, Illex illecebrosus, Life History and Habitat Characteristics. NOAA Technical

| Memorandum NMFS-NE-191. November 2004. 

Hendrickson, L. 2005. Gulf of Maine/Georges Bank Windowpane Flounder. In Assessment of

19 Northeast groundfish stocks through 2004 2005 Groundfish Assessment Review Meeting

(2005 GARM), Northeast Fisheries Science Center, Woods Hole, Massachusetts. 15-19 August

| 2005. Northeast Fisheries Science Center Reference Document 05-13, Accessed at

http://www.nefsc.noaa.gov/nefsc/publications/crd/cdr0513 on August 8, 2006.

Hildenbrand, S.F. 1963. Family Clupeidae, in Fishes of the Western North Atlantic, Sears

| Foundation Marine Research Memorandum 1(3). pgs. 257-385, 397-442, 452-454. Accessed at

http://www.nmfs.noaa.gov/pr/species/mammals/ on August 8, 2006.

Idoine, J. 1995. Goosefish, in Conservation and Utilization Division, Northeast Fisheries

Science Center. eds., Status of Fishery Resources off the northeastern United States for 1994. 

| pgs. 82-83. NOAA Technical Memorandum NMFS-NE-108. 

|

Iles, T.D., and M. Sinclair. 1982. Atlantic herring stock discreteness and abundance. Science

| 215: pgs. 627-633. 

Jacobson, L.D. 2005. Essential Fish Habitat Source Document: Longfin Inshore Squid, Loligo

pealeii, Life History and Habitat Characteristics. NOAA Technical Memorandum. NMFS-NE-193.

August 2005.

Johnson, D.L. 2004. Essential Fish Habitat Source Document: American Plaice,

Hippoglossoides platessoides, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-187. August 2004. 
Plant and the Environment

July 2007 2-143 NUREG-1437, Supplement 29

Johnson, D.L., W.W. Morse, P.L. Berrien, and J.J. Vitaliano. 1999a. Essential Fish Habitat |

Source Document: Yellowtail Flounder, Limanda ferruginea, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-140. September 1999. 

Johnson, D.L., P.L. Berrien, W.W. Morse, and J.J. Vitaliano. 1999b. Essential Fish Habitat

Source Document: American Plaice, Hippoglossoides platessoides, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-123. September 1999. 

Jury, S.H., J.D. Field, S.L. Stone, D.M. Nelson, and M.E. Monaco. 1994. Distribution and

abundance of fishes and invertebrates in North Atlantic estuaries. ELMR Report Number 13, |

NOAA/NOS Strategic Environmental Assessments Division, Silver Spring, Maryland, pg. 221. |

Kelly, B., R. Lawton, V. Malkoski, S. Correia, and M. Borgatti. 1992. Final Report on Haul-Seine

Survey and Impact Assessment of Pilgrim Station on Shore-Zone Fishes, 1981-1991. 

Massachusetts Division of Marine Fisheries. December 30, 1992. Pilgrim Nuclear Power Station

Marine Environmental Monitoring Program Report Series Number 6. Boston Edison Company. |

Kelly, G.F., and Barker, A.M. 1961a. Observations on the behavior, growth, and migration of

redfish at Eastport, Maine. International Commission for the Northwest Atlantic Fisheries |

(ICNAF) Special Publication 3, pgs. 263-275. |

Kelly, G.F., and Barker, A.M. 1961b. Vertical distribution of young redfish in the Gulf of Maine.

ICNAF Special Publication 3: pgs. 220-233. |

Kelly, G.F., and R.S. Wolf . 1959. Age and growth of the redfish (Sebastes marinus) in the Gulf

of Maine. Fisheries Bulletin (US) 60, pgs. 1-31. |

Kelly, G.F., P.M. Earl, J.D. Kaylor, F.E. Lux, H.R. McAvoy, and E.D. McRae. 1972. Redfish.

U.S. National Marine Fisheries Service, Fish Facts 1, pg. 18. |

Kenchington, T.J. 1984. Population structures and management of the redfishes (Sebastes

spp.: Scorpeanidae) of the Scotian Shelf (Microform). Ph.D. dissertation, Dalhousie University, |

Halifax, Nova Scotia. 

Kendall, A.W. Jr., and L.A. Walford. 1979. Sources and distribution of bluefish, Pomatus

saltatrix, larvae and juveniles off the east coast of the United States. U.S. National Marine

Fisheries Service. Fisheries Bulletin 77(1): pgs. 213-227. |

Klein-MacPhee, G. 2002. Haddock/ Melanogrammus aeglefinus Linnaeus 1758. Collette, B.B.,

and G. Klein-MacPhee, eds., Bigelow and Schroeder’s fishes of the Gulf of Maine. 3rd Edition.

Washington, DC, Smithsonian Institution Press, pgs. 235-242. |

Kocik, J. 1998. River Herring: Status of Fisheries Resources off Northeastern United States for

1998. Accessed at www.whoi.edu/sos/spsyn/af/herring.html on August 8, 2006.

|
Plant and the Environment 

 NUREG-1437, Supplement 29 2-144 July 2007

| Kohler, A.C. 1967. Size at maturity, spawning season, and food of Atlantic halibut. Journal of

| the Fisheries Research Board of Canada 24: pgs. 53-66.

Kolek, D. 1990. Homing of black sea bass, Centropristis striata, in Nantucket Sound with

comments on seasonal distribution, growth rates, and fisheries of the species. Massachusetts

| Division of Marine Fisheries. Pocassett, Massachusetts, pg. 12. 

Lai, H. and P. Rago. 1998. Sea scallops: Status of Fisheries Resources off Northeastern

United States for 1998. Accessed at: http://www.whoi.edu/sos/spsyn/iv/scallop.html on August

8, 2006.

Lange, A.M.T. and M.P. Sissenwine. 1980. Biological considerations relevant to the

| management of squid (Loligo pealei and Illex illecebrosus) of the northwest Atlantic Marine

| Fisheries Review 42(7-8): pgs. 23-38. 

Lange, A.M.T., and F.E. Lux. 1978. Review of the other flounder stocks (winter flounder,

American Plaice, witch flounder, and windowpane flounder) off the northeast United States.

| August 1978. National Marine Fisheries Center. Northeast Fisheries Center, Woods Hole

| Laboratory Reference Document Number 78-44: pg. 19.

| Langston, R.W., and R.E. Bowman 1981, Food of eight Northwest Atlantic Pleuronectiform

| Fishes, NOAA Technical Report NMFS SSRF-749, U.S. Department of Commerce.

|

Langston, R.W., J.B. Pearce, and J.A. Gibson, eds. 1994. Selected living resources, habitat

conditions, and human perturbations of the Gulf of Maine: Environmental and Ecological

| considerations for fishery management. NOAA Technical Memorandum NMFS-NE-106, pg. 70.

Lavenda, N. 1949. Sexual differences and normal protogynous hermaphroditism in the Atlantic

| sea bass, Centropristes striatus. Copeia 1949 (3): pgs. 185-194. 

Lawton, R., B. Kelly, P. Nitschke, J. Boardman, and V. Malkoski. 2000. Final Report Studies

(1991-1997) and Impact Assessment of Pilgrim Station on Cunner in Western Cape Cod Bay.

Massachusetts Division of Marine Fisheries. January 2000. Pilgrim Nuclear Power Station

| Marine Environmental Monitoring Program Report Series Number 9. Entergy. January 2000. 

Lawton, R., V. Malkoski, B. Kelly, P. Brady and M. Borgatti. 1992. Final report on Irish Moss

(Chondrus crispus) harvesting along the Plymouth shoreline and impact assessment of Pilgrim

Station on the fishery 1971-1982. Pilgrim Nuclear Power Station Marine Environmental

| Monitoring Program Report Series Number 5. Pg. 37.

Lawton, R., V. Malkoski, B. Kelly, and J. Chisholm. 1995. Final report on bottom trawl survey

(1970-1982) and impact assessment of the thermal discharge from Pilgrim Station on

groundfish. Pilgrim Nuclear Power Station Marine Environmental Monitoring Program Report

| Series Number 7, pg. 56.
Plant and the Environment

July 2007 2-145 NUREG-1437, Supplement 29

Lawton, R., and J. Boardman. 1999. Final Report on Rainbow Smelt (Osmerus mordax)

Restoration Efforts in the Jones River 1994-1999. Department of Fisheries, Wildlife, and

Environmental Law Enforcement, MDMF. Pocasset, Massachusetts. June 1990: Pilgrim

Nuclear Power Station Marine Environmental Monitoring Program Report Series Number 8.

Entergy. 1999. 

Lawton, R., B. Kelly, J. Boardman, and V. Malkoski. 1999. Annual Report on Assessment and

Mitigation of Impact of the Pilgrim Nuclear Power Station on Finfish Populations in Western

Cape Cod Bay. Project Report Number 66 (January to December 1998). Massachusetts |

Department of Fisheries, Wildlife, and Environmental Law Enforcement, Division of Marine

Fisheries. Boston, Massachusetts. April 1999. Marine Ecology Studies Related to Operation of

Pilgrim Station. Semi-annual Report Number 53, Report Period: January 1998 through |

December 1998. Regulatory Affairs Department, Boston Edison Company, Plymouth,

Massachusetts. April 30, 1999. 

Lawton, R., P. Brady, C. Sheehan, S. Correia, and M. Borgatti. 1990. Final Report on

Spawning Sea-run Rainbow Smelt (Osmerus mordax) in the Jones River and Impact

Assessment of Pilgrim Station on the Population (1979-1981). Department of Fisheries, Wildlife,

and Environmental Law Enforcement, MDMF. Sandwich, Massachusetts. June 1990. Pilgrim

Nuclear Power Station Marine Environmental Monitoring Program Report Series Number 4. |

Boston Edison. 1990. 

Lawton, R., V. Malkoski, B. Kelly, J. Boardman, M. Camisa. 2000. Final Report: Winter

Flounder (Psedopleuronectes americanus) Studies (1993-1999) in Relation to Impact

Assessment of Pilgrim Station on the Local Population. Department of Fisheries, Wildlife, and

Environmental Law Enforcement, Massachusetts Division of Marine Fisheries. Pocasset,

Massachusetts. March 2000. Pilgrim Nuclear Power Station Marine Environmental Monitoring

Program Report Series Number 10. Entergy. March 2000. |

Lawton, R.P., P. Brady, C. Sheehan, W. Sides, E. Kouloheras, M. Borgatti, and V. Malkoski.

1984. The recreational fishery at Pilgrim shorefront, In: Observations on the Ecology and

Biology of Western Cape Cod Bay, Massachusetts. Lecture Notes on Coastal and Estuarine

Studies, Volume 11, Eds. J.D. Davis and D. Merriman, pgs. 231-240. |

Lee, D.S., C.R. Gilbert, C.H. Hocutt, R.E. Jenkins, D.E. McAllister, and J.R. Stauffer. 1980.

Atlas of North American Freshwater Fishes. North Carolina State Museum of Natural History.

Libby P.S., W.R. Geyer, A.A. Keller, A.D. Mansfield, J.T. Turner, D. Borkman, and C.A. Oviatt. 

2006. 2004 Annual Water Column Monitoring Report. Boston: Massachusetts Water

Resources Authority Report ENQUAD 2006-15, pg. 177. |

Lock, M.C., and D.B. Packer. 2004. Essential Fish Habitat Source Document: Silver Hake,

Merluccius bilinearis, Life History and Habitat Characteristics. NOAA Technical Memorandum

NMFS-NE-186, August 2004. 
Plant and the Environment 

 NUREG-1437, Supplement 29 2-146 July 2007

Locke, A., G.J. Klassen, R. Bernier, and V. Joseph. 2005. Life history of the sand shrimp,

Crangon septemspinosa Say, in a southern Gulf of St. Lawrence estuary. Journal Shellfisheries

Research. August 2005.

Lough, R.G. 2004. Essential Fish Habitat Source Document: Atlantic Cod, Gadus morhua, Life

History and Habitat Characteristics. NOAA Technical Memorandum NMFS-NE-190, 

November 2004. 

Lough, R.G., and G.R. Bolz. 1989. The movement of cod and haddock larvae onto the shoals

| of Georges Bank. Journal of Fish Biology 35 (Supplement A): pgs. 71-79. 

Lux, F.E. 1964. Landings, fishing effort, and apparent abundance in the yellowtail flounder

| fishery. ICNAF Research Bulletin 1: pgs. 5-21.

MacDonald, J.S. 1983. Laboratory observations of feeding behavior of the ocean pout

(Macrozoarces americanus) and winter flounder (Pseudopleuronectes americanus) with

| reference to niche overlap of natural populations. Canadian Journal of Zoology 61: 

| pgs. 539-546. 

MacKenzie, C.L., Jr. 1979. Biological and fisheries data on sea scallop, Placopecten

| magellanicus (Gmelin) Nation Marine Fisheries Service, Northeast Fisheries Center Sandy Hook

| Laboratory Technical Service Report Number 19, pg. 34 as cited in: Hart, D.R. and A.S. Chute.

2004. Essential Fish Habitat Source Document: Sea Scallop, Placopecten magellanicus, Life

History and Habitat Characteristics. U. S. Department of Commerce, National Oceanic and

Atmospheric Administration, National Marine Fisheries Service, Northeast Region, Northeast

Fisheries Science Center, Woods Hole, Massachusetts. NOAA Technical Memorandum NMFSNE-189. September 2004.

Mahon, R. 1997. Demersal fish assemblages from the Scotian Shelf and Bay of Fundy, based

| on trawl survey data (1970-1993). Canadian Manuscript Report of Fisheries and Aquatic

| Sciences 2426, pg. 38.

Mansueti, A.J., and J.D. Hardy. 1967. Development of fishes of the Chesapeake Bay region: an

atlas of egg, larval, and juvenile stages. Part I. Natural Resources Institute, University of

| Maryland Press, College Park pg 202. 

Marak, R.R. 1967. Eggs and early larval stages of the offshore hake, Merluccius albidus, 

| Transactions of the American Fisheries Society 96: pgs. 227-228. 

Marak, R.R. 1973. Food and feeding of larval redfish in the Gulf of Maine. J.H.S. Baxter, ed.,

| The early life history of fish, pgs. 267-275. 

Marcy, B.C., Jr. 1969. Age determination from scales of Alosa pseudoharengus and Alosa

| aestivalis in Connecticut waters. Transactions of the American Fisheries Society 98: 

| pgs. 621-630.
Plant and the Environment

July 2007 2-147 NUREG-1437, Supplement 29

Marine Mammal Protection Act of 1972, as amended 16 USC 1361 et seq. |

Marine Research, Inc. (MRI). 1992. Ichthyoplankton Entrainment Monitoring at Pilgrim Nuclear |

Power Station, January to December 1991 (Volume 2). Marine Ecology Studies Related to |

Operation of Pilgrim Station. Final Report. Boston Edison Company.

Marine Research, Inc. (MRI). 2006. Winter Flounder Area-Swept Estimate Western Cape Cod

Bay 2005. Marine Ecology Studies Pilgrim Nuclear Power Station Report Number 67. January |

to December 2005. Environmental Protection Group, Entergy Nuclear-Pilgrim Station, Plymouth |

Massachusetts. April 30, 2006.

Marshall, H.G. 1978. Phytoplankton distribution along the eastern coast of the USA. Part II,

Seasonal assemblages north of Cape Hatteras, North Carolina. Marine Biology 45:

pgs. 203-208. |

Martin, F.D., and G.E. Drewry. 1978. Development, of fishes of the Mid-Atlantic Bight: An atlas

of egg, larval, and juvenile stages,Volume 6, Stromateidae through Ogcocephalidae, U.S. Fish

Wildlife Service Office of Biological Services. FWS/OBS 78/12, pg. 416. |

Mass Audubon. 2003. Natural History: Sea Turtles on Cape Cod. Accessed at:

http://www.massaudubon.org/Nature_Connection/Sanctuaries/wellfleet/seaturtles.php on

 August 8, 2006.

Massachusetts Department of Environmental Management (MA DEM). 2003. Certificate for

Chapter 61/Chapter 61A Forest Lands.

Massachusetts Department of Environmental Protection (MDEP). 1999. Groundwater

Discharge Permit, SE #2-389, Pilgrim Power Station Wastewater Treatment Facility. MDEP

Southeast Regional Office, Lakeville, Massachusetts.

Massachusetts Department of Environmental Protection (MDEP). 2004. 2003 Public Water

Supply Annual Statistical Report. Bureau of Resource Protection - Drinking Water Program. 

Boston, Massachusetts.

Massachusetts Department of Environmental Protection (MDEP). 2005. Commonwealth of

Massachusetts. 2004 Air Quality Report, Lawrence, Massachusetts, 2005.

Massachusetts Department of Revenue (MA DOR). 2002. At a Glance Report for Plymouth (As

of 4/16/02), Boston, Massachusetts.

Massachusetts Division of Marine Fisheries (MDMF). 2006. Species Profiles, Tautog. 

Accessed at: http://www.mass.gov/dfwele/dmf/recreationalfishing/tautog.htm on

September 28, 2006.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-148 July 2007

Massachusetts Executive Office of Environmental Affairs (MEOEA). 2003. Massachusetts

Geographic Information System, Land Use Summary Statistics – September 2003. Accessed at

http://www.mass.gov/mgis/landuse_stats.htm on September 6, 2006.

Massachusetts Geographic Information System (MassGIS). 2006. Office of Geographic and

Environmental Information, Commonwealth of Massachusetts Executive Office of Environmental

Affairs. Accessed at: www.mass.gov/mgis/natveg.htm on September 28, 2006.

Massachusetts Institute for Social and Economic Research (MISER). 2003. MISER Population

Projections for Massachusetts 2010 and 2020. University of Massachusetts, Amherst,

Massachusetts. Accessed at: http://www.umass.edu/miser/population/miserproj.html on

May 5, 2006.

| Mathiessen, G. 1984. The seasonal occurrence and distribution of larval lobsters in Cape Cod

| Bay. In: Observations on the Ecology and Biology of Western Cape Cod Bay, Massachusetts.

| Lecture Notes 

|

Maurer, R.O. and R.E. Bowman. 1985. Food consumption of squids (Illex illecebrosus and

| Loligo pealei) off the northeastern United States. Northwest Atlantic Fisheries Organization

| (NAFO) Scientific Council Reports 9: pgs. 117-124. 

Mayo, R. 2000. Redfish. January 2000. Accessed at

http://www.nefsc.noaa.gov/sos/spsyn/pg/redfish/ on August 8, 2006. 

Mayo, R. 2004. Pollock. Accessed at: http://www.nefsc.noaa.gov/sos/spsyn/pg/pollock.html on

August 8, 2006.

Mayo, R., and L. O’Brien. 2000. Atlantic Cod. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/pg/cod/ on August 8, 2006.

Mayo, R.K. 1980. Exploitation of redfish. Sebastes marinus (L.), in the Gulf of Maine-Georges

| Bank region, with particular reference to the 1971 year-class. Journal of Northwest Atlantic

| Fisheries Science 1: pgs. 21-37.

Mayo, R.K. 1982. An assessment of the scup, Stenotomus chrysops (L), population in the

southern New England and Middle Atlantic regions, National Marine Fisheries Service, Northeast

| Fisheries Center Woods Hole Laboratory Reference Document Number 82-46, pg. 61.

Mayo, R.K. 1998a . Silver Hake: Status of Fisheries Resources off Northeastern United States

for 1998. Accessed at: http://www.whoi.edu/sos/spsyn/pg/silver.html on August 8, 2006.

| Mayo, R.K. 1998b. Pollock: Status of Fisheries Resources off Northeastern United States for

1998. Accessed at: http://www.whoi.edu/sos/spsyn/pg/pollock.html on August 8, 2006.
Plant and the Environment

July 2007 2-149 NUREG-1437, Supplement 29

Mayo, R.K., and L. Col. 2005a. Gulf of Maine Cod, in Assessment of 19 Northeast groundfish

stocks through 2004-2005 Groundfish Assessment Review Meeting (2005 GARM), Northeast

Fisheries Science Center, Woods Hole, Massachusetts, 15-19 August 2005, Northeast Fisheries

Science Center Reference Document 05-13, Accessed at:

http://www.nefsc.noaa.gov/nefsc/publications/crd/cdr0513 on August 8, 2006.

Mayo, R.K., L. Col, and M. Traver. 2005b. Georges Bank/Gulf of Maine Pollock, in Assessment |

of 19 Northeast groundfish stocks through 2004-2005 Groundfish Assessment Review Meeting

(2005 GARM), Northeast Fisheries Science Center, Woods Hole, Massachusetts, 15-19 August

2005, Northeast Fisheries Science Center Reference Document 05-13. Accessed at:

http://www.nefsc.noaa.gov/nefsc/publications/crd/cdr0513 on August 8, 2006.

Mayo, R.K., J. Brodziak, M. Travel, and L. Col. 2005c. Gulf of Maine/Georges Bank Acadian

Redfish, in Assessment of 19 Northeast groundfish stocks through 2004-2005 Groundfish

Assessment Review Meeting (2005 GARM), Northeast Fisheries Science Center, Woods Hole,

Massachusetts. 15-19 August 2005, Northeast Fisheries Science Center Reference Document

05-13. Accessed at: http://www.nefsc.noaa.gov/nefsc/publications/crd/cdr0513 on August 8,

2006.

McEachran, J.D. 1973. Biology of seven species of skates (Pisces: Rajidae). Ph.D.

dissertation, College of William and Mary, Williamsburg, Virginia, pg. 127. |

McEachran, J.D., and J.A. Musick. 1975. Distribution and relative abundance of seven species

of skates (Pisces: Rajidae) which occur between Nova Scotia and Cape Hatteras. Fisheries |

Bulletin (U.S.) 73: pgs. 110-136. |

McEachran, J.D., D.F. Boesch, and J.A. Musick. 1976. Food division within two sympatric

species-pairs of skates (Pisces: Rajidae). Marine Biology 35: pgs. 301-317. |

|

McEachran, J.D. 2002. Skates, Family Rajidae. In B.B. Collette and G. Klein-MacPhee, eds.,

Bigelow and Schroeder’s fishes of the Gulf of Maine. 3rd edition, p. 60-75. Smithsonian

Institution Press, Washington, DC, pg. 748. |

McGlade, J.M. 1984. The influence of Gulf Stream Gyre activity on recruitment variability in

Pollock (Pollachius virens), p. 30-40, in R.I. Perry and K.T. Frank, eds., Environmental effects on

recruitment to Canadian Atlantic Fish Stocks. Canadian Technical Report of Fisheries and |

Aquatic Sciences , pgs. 1556-65. |

McKensie, R.A. 1964. Smelt Life History and Fishery in the Miracmichi River, New Brunswick. |

Bulletin of the Fisheries Research Board of Canada. 144, pg. 77. |

McLeese, D.W., D.G. Wilder. 1958. The Activity and Catch ability of the Lobster (Homarus

americanus) in Relation to Temperature. Journal of the Fisheries Research Board of Canada |

Bulletin 147: pgs. 1-69. |
Plant and the Environment 

 NUREG-1437, Supplement 29 2-150 July 2007

McMillan, D.G., and W.W. Morse. 1999. Essential Fish Habitat Source Document: Spiny

Dogfish, Squalus acanthias, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-150. September 1999. 

McWeeney, Lucinda. 1999. "A Review of Late Pleistocene and Holocene Climate Changes in

Southern New England," Bulletin of the Archaeological Society of Connecticut, 62:3-18.

Menge, B.A. 1976. Organization of the New England Rocky Intertidal Community and Role of

Predation, Competition, and Environmental Heterogeneity. Ecological Monographs 46: 

| pgs. 355-393. 

Mercer, L.P. 1978. The reproductive biology and population dynamics of black sea bass,

| Centropristis striata, Ph.D. dissertation, College of William and Mary, Williamsburg, Virginia, 

| pg. 195.

Michalopoulos, C. 1990. A field study on the ecology and behavior of the winter skate

(Leucoraja ocellata) and little skate (Leucoraja erinacea) off outer Cape Cod, Massachusetts.

| M.S. Thesis, Southeastern Massachusetts University, North Dartmouth, Massachusetts, pg. 71.

Mid-Atlantic Fishery Management Council (MAFMC). 1994. Amendment #5 to the Fishery

Management Plan for the Atlantic mackerel, squid, and butterfish fisheries. November 1994, 

| pg. 146.

Mid-Atlantic Fishery Management Council (MAFMC). 1996a. Amendment 8 to the summer

flounder Fishery Management Plan: Fishery Management Plan and final environmental impact

| statement for the scup bass fishery. January 1996, pg. 162.

Mid-Atlantic Fishery Management Council (MAFMC). 1996b. Amendment 9 to the summer

flounder Fishery Management Plan: Fishery Management Plan and draft environmental impact

| statement for the black sea bass fishery. June 1996, pg. 152. 

Mid-Atlantic Fishery Management Council (MAFMC). 1998. Spiny dogfish Fishery Management

| Plan Draft. August 1998, pg. 225. 

Morgan, M.J. 1992. Low-temperature tolerance of American plaice in relation to declines in

| abundance. Transactions of the American Fisheries Society 121: pgs. 399-402.

|

Morse, W. 1978. Biological and fisheries data on scup, Stenotomus chrysops (Linnaeus). U.S. 

National Marine Fisheries Service, Northeast Fisheries Center Sandy Hook Laboratory Technical

| Service Report Number 12, pg. 41.

| Morse, W.W. 1981. Reproduction of the summer flounder (Paralichthys dentatus (L)). Journal

| of Fish Biology 19: pgs. 189-203.
Plant and the Environment

July 2007 2-151 NUREG-1437, Supplement 29

Mullen, D.M, C.W. Fay, and J.R. Moring. 1986. Species Profiles: Life Histories and

Environmental Requirements of Coastal Fisheries and Invertebrates (North Atlantic):

Alewife/Blueback Herring. U.S. Fish and Wildlife Service Biological Report 82 (11.56). U.S. Army

Corps of Engineers TR EL-82-4, pg. 21. |

Murawski, S.A . 1973. Climate change and marine fish distributions: Forecasting from historical

analogy. Transactions of the American Fisheries Society 122, pgs. 647-657. |

Murawski, S.A., and G.T. Waring. 1979. A population assessment of butterfish, Peprilus

triacanthus in the northwest Atlantic Ocean. Transactions of the American Fisheries Society 108: |

pgs. 427-439. |

Nagler, J.J., and D.G. Cyr. 1997. Exposure of male American plaice (Hippoglossoides

platessoides) to contaminated sediments decreases the hatching success of their progeny. 

Environmental Toxicology and Chemistry. 16: pgs. 1733-1738. |

Nagler, J.J., B.A. Adams, and D.G. Cyr. 1999. Egg production, fertility, and hatch success of

American plaice held in captivity. Transactions of the American Fisheries Society 128: |

pgs. 727-736. |

Nammack, M.F., J.A. Musick, and J.A. Colvocoresses. 1985. Life history of spiny dogfish off

the northeastern United States. Transactions of the American Fisheries Society 114, pgs. 367- |

376. 

National Marine Fisheries Service (NMFS). 1997. Report to Congress, Status of fisheries of the

United States: Report on the status of fisheries of the United States, September 1997. 

|

National Marine Fisheries Service (NMFS). 1999. Highly Migratory Species Management

Division 1999, Final Fishery Management Plan for Atlantic Tuna, Swordfish, and Sharks,

Including the Revised Final Environmental Impact Statement, the Final Regulatory Impact

Review, the Final Regulatory Flexibility Analysis, and the Final Social Impact Assessment. 

April 1999. 

National Marine Fisheries Service (NMFS). 2000. 30th Northeast Regional Stock Assessment

Workshop (30th SAW), Stock Assessment Review Committee (SARC) consensus summary of

assessments. Northeast Fisheries Science Center Reference Document 00-03, pg. 477. |

National Marine Fisheries Service (NMFS). 2001a. 32nd Northeast Regional Stock Assessment

Workshop (32nd SAW). April 2001.

National Marine Fisheries Service (NMFS). 2001b. 33rd Northeast Regional Stock Assessment

Workshop (33rd SAW). December 2001. 

National Marine Fisheries Service (NMFS). 2001c. Report to Congress, Status of fisheries of

the United States: Report on the status of fisheries of the United States.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-152 July 2007

National Marine Fisheries Service (NMFS). 2001d. Stock Assessment and Fishery Evaluation

for Atlantic Highly Migratory Species, March 2001.

National Marine Fisheries Service (NMFS). 2002a. 35th Northeast Regional Stock Assessment

Workshop (35th SAW). September 2002. 

National Marine Fisheries Service (NMFS). 2002b. Annual report to Congress on the status of

| U.S. fisheries – 2001. U.S. Department of Commerce. NOAA, NMFS, Silver Spring, Maryland,

| pg. 142.

National Marine Fisheries Service (NMFS). 2002c. 34th Northeast Regional Stock Assessment

Workshop (34th SAW). April 2002.

National Marine Fisheries Service (NMFS). 2003a. Report of the 36 Northeast Regional Stock th

Assessment Workshop (36 SAW). Public Review Workshop, U.S. Department of Commerce. 

th

National Marine Fisheries Service (NMFS). 2003b. 37th Northeast Regional Stock Assessment

Workshop (37th SAW). September 2003. 

National Marine Fisheries Service (NMFS). 2004a. 38th Northeast Regional Stock Assessment

Workshop (38th SAW). January 2004. 

National Marine Fisheries Service (NMFS). 2004b. 39th Northeast Regional Stock Assessment

Workshop (39th SAW). Assessment Summary Report (CRD 04-10a) and Assessment Report

(CRD 04-10b). July 2004.

| National Marine Fisheries Service (NMFS). 2004c. Proactive Conservation Program, Species of

Concern in the Northeast Region (Maine through Virginia).

National Marine Fisheries Service (NMFS). 2005a. 40th Northeast Regional Stock Assessment

Workshop (40th SAW). April 2005.

National Marine Fisheries Service (NMFS). 2005b. 41st Northeast Regional Stock Assessment

Workshop (41st SAW). August 2005. 

National Marine Fisheries Service (NMFS). 2005c. Atlantic Tunas, Information from 2005 Draft

Consolidated Atlantic HMS FMP. Accessed at http://www.nmfs.noaa.gov/sfa/hms on 

August 8, 2006.

National Marine Fisheries Service (NMFS). 2006a. 42nd Northeast Regional Stock Assessment

Workshop (42nd SAW). January 2006. 

National Marine Fisheries Service (NMFS). 2006b. 43rd Northeast Regional Stock Assessment

Workshop (43rd SAW). July 2006.
Plant and the Environment

July 2007 2-153 NUREG-1437, Supplement 29

National Marine Fisheries Service (NMFS). 2006c. Letter in Response to Request for

Information on Essential Fish Habitat and Protected Species. June 8, 2006.

National Marine Fisheries Service (NMFS). 2006d. Loggerhead Turtle, Summary from NOAA

Fisheries, Office of Protected Resources. Accessed at:

http://www.nmfs.noaa.gov/pr/species/turtles/loggerhead.htm on August 28, 2006.

National Oceanic and Atmospheric Administration (NOAA). 1998. Status of the Fishery

Resources off the Northeastern United States. Stephen Clark, Editor. NOAA Technical

Memorandum NMFS-NE-115. Resource Evaluation and Assessment Division. Northeast

Fisheries Science Center.

National Oceanic and Atmospheric Administration (NOAA). 2004. Local Climatological Data -

Annual Summary With Comparative Data - Boston, Massachusetts, ISSN 0198-2419.

National Oceanic and Atmospheric Administration (NOAA). 2006. Environmental Impact

Statement to Implement the Operational Measures of the North Atlantic Right Whale Ship Strike

Reduction Strategy. Draft. July 2006. National Oceanic and Atmospheric Administration

National Marine Fisheries Service Office of Protected Resources.

Natural Heritage and Endangered Species Program (NHESP). 1988. Massachusetts Rare and

Endangered Wildlife: Roseate Tern, Sterns dougallii. Rare species fact sheet. Accessed at:

www.mass.gov/dfwele/dfw/nhesp/nhspecies.htm on August 28, 2006.

Natural Heritage and Endangered Species Program (NHESP). 1990. Massachusetts

Threatened Species: Piping Plover, Charadrius melodus. Rare species fact sheet, Accessed

at: www.mass.gov/dfwele/dfw/nhesp/nhspecies.htm on August 28, 2006.

Natural Heritage and Endangered Species Program (NHESP). 1991. Massachusetts

Endangered Wildlife: Dwarf Wedge Mussel (Alasmidonta heterodon). Rare species fact sheet,

Accessed at: www.mass.gov/dfwele/dfw/nhesp/nhspecies.htm on August 28, 2006.

Natural Heritage and Endangered Species Program (NHESP). 1995a. Massachusetts

Endangered Species: Bald Eagle, Haliaeetus leucocephalus (Linnaeus). Rare species fact

sheet. Accessed at: www.mass.gov/dfwele/dfw/nhesp/nhspecies.htm on August 28, 2006.

Natural Heritage and Endangered Species Program (NHESP). 1995b. Massachusetts

Endangered Species: Plymouth Redbelly Turtle, Pseudemys rubriventris. Rare species fact

sheet. Accessed at: www.mass.gov/dfwele/dfw/nhesp/nhspecies.htm on August 28, 2006.

Natural Heritage and Endangered Species Program (NHESP). 2005. NHESP Priority Habitats

of Rare Species and NHESP Estimated Habitats of Rare Wildlife Datalayers. July 2005.

Accessed at: www.mass.gov/mgis/laylist.htm#consres on August 28, 2006. 
Plant and the Environment 

 NUREG-1437, Supplement 29 2-154 July 2007

Natural Heritage and Endangered Species Program (NHESP). 2006a. Rare Plants and Animals,

Official State Rare Species List, Town of Plymouth. August 28, 2006. Accessed at:

www.mass.gov/dfwele/dfw/nhesp/nhrarelinks.htm on August 28, 2006.

Natural Heritage and Endangered Species Program (NHESP). 2006b. Changes to the

Massachusetts List of Endangered, Threatened, & Special Concern Species. May 24 2006. 

Accessed at: www.mass.gov/dfwele/dfw/nhesp/listchange42406.pdf and

www.mass.gov/dfwele/dfw/nhesp/heritage2.htm, on August 2, 2006.

|

Neville, W.C., and G.B. Talbot. 1964. The fishery for scup with special reference to fluctuations

| in yield and their causes, U.S. Fish Wildlife Service. Special Scientific Report on Fisheries.

| Number 459, pg. 61. 

|

New England Fishery Management Council (NEFMC). 1993. Final Amendment #5 to the

Northeast Multispecies Fishery Management Plan incorporating the supplemental environmental

| impact statement, Volume 1, September 1993 

New England Fishery Management Council (NEFMC). 1998a. Essential Fish Habitat,

Volume 1.

New England Fishery Management Council (NEFMC). 1998b . Essential fish habitat description

for Winter flounder (Pleuronectes americanus). NEFMC EFH Amendment, October, 7 1998.

|

| New England Fishery Management Council (NEFMC). 2003. Whiting Plan Development Team

(PDT) Report 2003 Small Mesh Fish Multispecies Stock Assessment and Fishery Evaluation

(SAFE) Report. October 16, 2003.

|

New England Fishery Management Council (NEFMC). 2004. Herring PDT/TC Report, Stock

Assessment and Fishery Evaluation (SAFE) Report. May 5, 2004.

New England Fishery Management Council (NEFMC). 2006a. Monkfish Fishery Management

Plan, Annual Specifications for the 2006 Fishing Year, Incorporating Stock Assessment and

Fishery Evaluation (SAFE) Report for the 2004 Fishing Year and the Environmental Assessment

and Regulatory Impact Review. February 13, 2006.

New England Fishery Management Council (NEFMC). 2006b. Framework Adjustment 42 to the

Northeast Multispecies Fishery Management Plan and Framework Adjustment 3 to the Monkfish

Fishery Management Plan, including an Environmental Assessment, Regulatory Impact Review,

and Initial Regulatory Flexibility Analysis. April 21 2006.

Ni, I-H, and W. Templeman. 1985. Reproductive cycles of redfishes (Sebastes) in southern

| Newfoundland waters. Journal of Northwest Atlantic Fisheries Science 6, pgs. 57-63.

Nitschke, P. 2000. Tilefish. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/og/tile/ on August 8, 2006. 
Plant and the Environment

July 2007 2-155 NUREG-1437, Supplement 29

Nitschke P., R. Brown, and L. Hendrickson. 2000. Status of Fisheries Resources off

Northeastern United States – Winter Flounder. Updated January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/fldrs/winter/ on August 8, 2006. 

Normandeau Associates (Normandeau). 2006a. Ichthyoplankton Entrainment Monitoring at

Pilgrim Nuclear Power Station; January to December 2005. Marine Ecology Studies, Pilgrim |

Nuclear Power Station, Report Number 67, April 30, 2006. Environmental Protection Group, |

Entergy Nuclear – Pilgrim Station, Plymouth, Massachusetts.

Normandeau Associates (Normandeau). 2006b. Impingement of Organisms on the Intake

Screens at Pilgrim Nuclear Power Station; January to December 2005. Marine Ecology Studies, |

Pilgrim Nuclear Power Station, Report Number 67, April 30, 2006. Environmental Protection |

Group, Entergy Nuclear – Pilgrim Station, Plymouth, Massachusetts.

Northeast Fisheries Science Center (NEFSC). 1998. Report of the 27 Northeast Regional |

th

Stock Assessment Workshop (27th SAW). Stock Assessment Review Committee (SARC) |

consensus summary of assessments. US Department of Commerce, National Oceanic and |

Atmospheric Administration, National Marine Fisheries Service, Northeast Region, Northeast |

Fisheries Science Center Reference Document 98-15. |

Northeast Fisheries Science Center (NEFSC). 2004. 39th Northeast Regional Stock |

Assessment Workshop (39th SAW) assessment summary report. US Department of Commerce, |

National Oceanic and Atmospheric Administration, National Marine Fisheries Service, Northeast |

Region, Northeast Fisheries Science Center, Woods Hole, Massachusetts. NEFSC Reference |

Document 04-10a. July 2004. |

Northeast Fisheries Science Center (NEFSC). 2005. Assessment of 19 Northeast Groundfish

Stocks through 2004. 2005 Groundfish Assessment Review Meeting (2005 GARM), Northeast

Fisheries Science Center, Woods Hole, Massachusetts. 15-19 August 2005. NEFSC Reference

Document 05-13. September 2005.

NSTAR Gas and Electric Corporation (NSTAR). 2006. 2006 Vegetation Management Plan,

including Five-Year Vegetation Management Plan: 2003-2007.

|

Nuclear Regulatory Commission (NRC). 2004a. “Policy Statement on the Treatment of

Environmental Justice Matters in NRC Regulatory and Licensing Actions.” Federal Register,

Volume 69, p52040-52048. Washington DC, August 24, 2004. |

Nuclear Regulatory Commission (NRC). 2004b. Procedural Guidance for Preparing

Environmental Assessments and Considering Environmental Issues, NRR Office

InstructionNumber LIC-203, Revision 1. May 24, 2004.

|

O’Brien, L. 1998. American plaice: Status of Fisheries Resources off Northeastern United

States for 1998. Accessed at: http://www.whoi.edu/sos/spsyn/pg/plaice.html on August 8, 2006.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-156 July 2007

O’Brien, L., C. Esteves, and L. Col. 2002. H. Gulf of Maine-Georges Bank American plaice, in

Assessment of 20 northeast groundfish stocks through 2001: a report of the groundfish

assessment review meeting (GARM). Northeast Fisheries Science Center. Woods Hole,

| Massachusetts. October 8-11, 2002, NEFSC Reference Document 02-16, pgs. 171-194.

O’Brien, L. 2000. American Plaice. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/fldrs/plaice/ on August 8, 2006.

O’Brien, L., J. Burnett, and L. Col . 2005. Gulf of Maine/Georges Bank American Plaice, in

Assessment of 19 Northeast groundfish stocks through 2004 2005 Groundfish Assessment

Review Meeting (2005 GARM). Northeast Fisheries Science Center. Woods Hole,

Massachusetts. 15-19 August 2005, Northeast Fisheries Science Center Reference Document

05-13. Accessed at: http://www.nefsc.noaa.gov/nefsc/publications/crd/cdr0513 on August 8,

2006.

O’Brien, L., J. Burnett, and R.K. Mayo. 1993. Maturation of nineteen species of finfish off the

| northeast coast of the United States 1985-1990. NOAA Technical Report NMFS 113, pg. 66.

Ojeda, F.P., and J.H. Dearborn. 1991. Feeding ecology of benthic mobile predators:

experimental analyses of their influence in rocky intertidal communities of the Gulf of Maine. 

| Journal of Experimental Marine Biology and Ecology. 149: pgs. 13-44.

Old Colony Planning Council (OCPC). 2000. Regional Policy Plan: A Guide for Shaping Our

Communities and the OCPC Region. October 2000, Brockton, Massachusetts.

Old Colony Planning Council (OCPC). 2006a. Keeping Our Region Competitive. Brockton,

Massachusetts. June 2006.

Old Colony Planning Council (OCPC). 2006b. Rocky Hill Road Traffic Study. Prepared for

Town of Plymouth, Department of Public Works. Brockton, Massachusetts. January 2006.

|

Orach-Meza, F.L. 1975. Distribution and abundance of ocean pout, Macrozoarces americanus,

(Bloch and Schneider) 1801 in the western North Atlantic Ocean. M.S. Thesis,University of

| Rhode Island, Kingston, Rhode Island, pg. 143.

Overholtz, W. 2000a. Atlantic Herring. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/pp/herring/ on August 8, 2006.

Overholtz, W. 2000b. Atlantic Mackerel. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/pp/mackerel/ on August 8, 2006.

Overholtz, W. 2000c. Butterfish. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/op/butter/ on August 8, 2006.
Plant and the Environment

July 2007 2-157 NUREG-1437, Supplement 29

Overholtz, W., and S.X. Cadrin. 1998. Yellowtail flounder: Status of Fisheries Resources off |

Northeastern United States for 1998. Accessed at

http://www.whoi.edu/sos/spsyn/pg/yellotail.html on August 8, 2006. 

Overholtz, W.J., and E.D. Anderson. 1976. Relationship between mackerel catches, water

temperatures, and vessel velocity during USA spring bottom trawl surveys in SA 5-6. ICNAF

Res. Doc. 76/XIII/170, pg. 7. |

Packer, D.B., C.A. Zetlin, and J.J. Vitaliano. 2003a. Essential Fish Habitat Source Document:

Winter Skate, Leucoraja ocellata, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-179. March 2003.

Packer, D.B., C.A. Zetlin, and J.J. Vitaliano. 2003b . Essential Fish Habitat Source Document:

Little Skate, Leucoraja erinacea, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-175, March 2003. 

Packer, D.B., C.A. Zetlin, and J.J. Vitaliano. 2003c. Essential Fish Habitat Source Document:

Thorny Skate, Amblyraja radiata, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-178. March 2003. 

Packer, D.B., C.A. Zetlin, and J.J. Vitaliano. 2003d. Essential Fish Habitat Source Document:

Smooth Skate, Malacoraja senta, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-177. March 2003. 

Packer, D.B., S.J. Griesbach, P.L. Berrien, C.A. Zetlin, D.L. Johnson, and W.W. Morse. 1999.

Essential Fish Habitat Source Document: Summer Flounder, Paralichthys dentatus, Life History

and Habitat Characteristics. NOAA Technical Memorandum NMFS-NE-151, September 1999.

|

Pereira, J. J, R. Goldberg, J.J. Ziskowski, P.L. Berrien, W.W. Morse, and D.L. Johnson. 1999. 

Essential Fish Habitat Source Document: Winter Flounder, Psedopleuronectes americanus, Life

History and Habitat Characteristics. U. S. Department of Commerce. NOAA, NMFS, Northeast

Region, Northeast Fisheries Science Center, Woods Hole, Massachusetts. September 1999.

Perkins, H.C. 1972. Developmental rates at various temperatures of embryos of the northern

lobster (Homarus americanus Milne-Edwards). Fishery Bulletin 70: pgs. 95-99. |

Peterson, R. T. 1980. A Field Guide to the Birds, Fourth Edition. Houghton Mifflin Co., Boston.

Pierce, D.E. 1981. Scup, Stenotomus chrysops (Linnaeus), of southeastern Massachusetts

waters – growth and yield, fisheries, and management. M.S. Thesis, Southeastern

Massachusetts University, North Dartmouth, Massachusetts, pg. 173. |

Pikanowski, R.A., W.W. Morse, P.L. Berrien, D.L., Johnson, and D.G. McMillan. 1999. 

Essential Fish Habitat Source Document: Redfish, Sebastes spp. , Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-132. September 1999. 
Plant and the Environment 

 NUREG-1437, Supplement 29 2-158 July 2007

Pottle, R.A., and J.M. Green. 1979. Field Observations on the Reproductive Behavior of the

| Cunner, Tautogolabrus adspersus in Newfoundland. Canadian Journal of Zoology 57: 

| pgs. 247-256.

Powles, P.M., and A.C. Kohler. 1970. Depth distribution of various stages of witch flounder,

| Glyptocephalus cynoglossus, off Nova Scotia and in the Gulf of St. Lawrence. Journal of the

| Fisheries Research Board of Canada 27, pgs. 2053-2062. 

Prescott, R. 2000. Sea Turtles in New England Waters. In Conservation Perspectives, the online journal of the Massachusetts Chapter of the Society for Conservation Biology, October,

2000. Accessed at: http://www.masscb.org/epublications/october2000/seaturtle.html on

August 8, 2006.

| Prescott, R. 2005. Email correspondence with J. Brochu, Entergy, January 15, 2005. 

| Provincetown Center for Coastal Studies. 2006. Sand Lance (Ammodytes americanus).

| Accessed at: http://www.coastalstudies.org/what-we-do/stellwagen-bank/fish_bony.htm on

| September 28, 2006.

Rago, J.P., K. Sosebee, J. Brodziak, and E.D. Anderson. 1994. Distribution and dynamics of

| northwest Atlantic spiny dogfish (Squalus acanthias). Northeast Fisheries Science Center

| Reference Document 94-19.

RAM Environmental. 1998. Immediate Response Action Completion Statement and

Documentation Supporting A-2 Response Action Outcome Statement, Transformer Oil Release,

Boston Edison Company, Pilgrim Nuclear Power Plant. Plymouth, Massachusetts.

Reid, R., F. Almeida, and C. Zetlin. 1999a. Essential fish habitat source document: Fishery

independent surveys, data sources, and methods. NOAA Technical Memorandum NMFS-NE-

| 122, pg. 39. 

Reid, R.F., L.M. Cargnelli, S.J. Griesbach, D.B. Packer, D.L. Johnson, C.A. Zetlin, W.W. Morse,

and P.L. Berrien. 1999b. Essential Fish Habitat Source Document: Atlantic Herring, Clupea

harengus, Life History and Habitat Characteristics. NOAA Technical Memorandum NMFS-NE126, September 1999. 

Richards, A. 2000. Goosefish. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/pg/redfish/ on August 8, 2006.

Richards, L. J. 1903. New Topographical Atlas of Surveys Plymouth County. The L. J.

Richards Co. Cartographers & Publishers, Springfield, Massachusetts.

Richards, S.W. 1963. The demersal fish population of Long Island Sound II, Food of the

| juveniles from a sand-shell locality (Station 1). Bulletin of the Bingham Oceanographic

| Collection. 18: pgs. 32-72. 

Plant and the Environment 

 NUREG-1437, Supplement 29 2-160 July 2007

Shepherd, G. 2000b. Bluefish. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/op/bluefish/ on August 8, 2006.

Shepherd, G.R., and D.B. Packer. 2006. Essential Fish Habitat Source Document: Bluefish,

Pomatomus saltatrix, Life History and Habitat Characteristics. NOAA Technical Memorandum

NMFS-NE-198, June 2006. 

Sherman, K., and R.D. Lewis. 1967. Seasonal Occurrence of Larval Lobsters in Coastal

| Waters of Central Maine. Procedures of the National Shellfish Association. 57: pgs. 27-30.

Short, L.M., and D. Michelin. 2006. Summary of Marine Mammal Observations During 2005

Surveys for MWRA Harbor and Outfall Monitoring Project, ReportNumber 2006-04. Submitted by

Battelle to Massachusetts Water Resources Authority, March 7, 2006.

Sissenwine, M.P., R.R. Lewis, and R.K. Mayo. 1979. The spatial and seasonal distribution of

summer flounder (Paralichthys dentatus) based on research vessel bottom trawl surveys. U.S.

| National Marine Fisheries Service Northeast Fisheries Center. Woods Hole Laboratory.

| Reference Document 79-55, pg. 101.

Sosebee, K.A. 1998. Red Hake. S.H. Clark, ed., Status of fishery resources off the

| northeastern United States for 1998, pgs. 64-66. NOAA Technical Memorandum NMFS-NE115.

Sosebee, K.A. 2000a. White Hake. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/og/hake/ on August 8, 2006.

Sosebee, K.A. 2000b. Spiny Dogfish. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/op/dogfish/ on August 8, 2006.

Sosebee, K.A. 2000c. Skates. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/op/skate/ on August 8, 2006..

Sosebee, K.A. 2005. Georges Bank/Gulf of Maine White Hake. Assessment of 19 Northeast

groundfish stocks through 2004 2005 Groundfish Assessment Review Meeting (2005 GARM),

Northeast Fisheries Science Center. Woods Hole, Massachusetts, 15-19 August 2005.

Northeast Fisheries Science Center Reference Document 05-13. Accessed at

http://www.nefsc.noaa.gov/nefsc/publications/crd/cdr0513 on August 28, 2006.

| Squires, H.J. 1957. Squid, Illex illecebrosus, in the Newfoundland fishing area. Journal of the

| Fisheries Research Board of Canada 14: pgs. 693-728.

Squires, H. J. 1996. Decapod crustaceans of Newfoundland, Labrador and the Canadian

| eastern Arctic. Canadian Technical Report of Fisheries and Aquatic Sciences 2359, pg. 234.
Plant and the Environment

July 2007 2-161 NUREG-1437, Supplement 29

Steele, D.H. 1957. The redfish (Sebastes marinus L.) in the western Gulf of St. Lawrence.

Journal of the Fisheries Research Board of Canada 14, pgs. 899-924. |

Steele, D.H. 1963. Pollock (Pollachius virens (L.)) in the Bay of Fundy. Journal of the Fisheries |

Research Board of Canada 20: pgs. 1267-1314. |

Steimle, F.W., W.W. Morse, P.L. Berrien, and D.L. Johnson. 1999a. Essential Fish Habitat |

Source Document: Red Hake, Urophycis chuss, Life History and Habitat Characteristics. NOAA

Technical Memorandum NMFS-NE-133. September 1999. 

Steimle, F.W., W.W. Morse, P.L. Berrien, D.L. Johnson, and C.A. Zetlin. 1999b. Essential Fish |

Habitat Source Document: Ocean Pout, Macrozoarces americanus, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-129. September 1999. 

Steimle, F.W., W.W. Morse, and D.L. Johnson. 1999c. Essential Fish Habitat Source |

Document: Goosefish, Lophius americanus, Life History and Habitat Characteristics. NOAA

Technical Memorandum NMFS-NE-127. September 1999. 

Steimle, F.W., C.A. Zetlin, P.L. Berrien, and S. Chang. 1999d. Essential Fish Habitat Source |

Document: Black Sea Bass, Centropristis striata, Life History and Habitat Characteristics .

NOAA Technical Memorandum NMFS-NE-143. September 1999. 

Steimle, F.W., C.A. Zetlin, P.L. Berrien, D.L. Johnson, and S. Chang. 1999e . Essential Fish |

Habitat Source Document: Tilefish, Lopholatilus chamaeleonticeps, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-152. September 1999. 

Steimle, F.W., C.A. Zetlin, P.L. Berrien, D.L. Johnson, and S. Chang. 1999f. Essential Fish |

Habitat Source Document: Scup, Stenotomus chrysops, Life History and Habitat Characteristics.

NOAA Technical Memorandum NMFS-NE-149. September 1999.

Steiner, W.W., J.J. Luczkovich, and B.L. Olla. 1982. Activity, shelter usage, growth and

recruitment of juvenile red hake, Urophycis chuss. Marine Ecology Progress Series 7: |

pgs. 125-135. |

Stevenson, D.K., and M.L. Scott. 2005. Essential Fish Habitat Source Document: Atlantic

Herring, Clupea harengus, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-192. July 2005. 

|

Stewart, L.L, and P.J. Auster. 1987. Species Profiles: Life Histories and Environmental

Requirements of Coastal Fishes and Invertebrates (North Atlantic), Atlantic Tomcod. U.S. Fish

and Wildlife Service Biological Report 82 (11.76). August 1987.

Stobo, W.T., J.D. Neilson, and P.G. Simpson. 1988. Movements of Atlantic halibut

(Hippoglosus hippoglossus) in the Canadian North Atlantic. Canadian Journal of Fisheries and |

Aquatic Sciences 45: pgs. 484-491. |

Plant and the Environment

July 2007 2-163 NUREG-1437, Supplement 29

Toner, R.C. 1984. Phytoplankton of western Cape Cod Bay. Observations on the Ecology and |

Biology of Western Cape Cod Bay, Massachusetts. Lecture Notes on Coastal and Estuarine

Studies. Volume 11, Eds. J.D. Davis and D. Merriman, pgs. 65-76. |

|

Town of Plymouth. 2004a . Annual Report of the Town of Plymouth, Massachusetts for the Year

Ending December 31, 2003. Plymouth, Massachusetts.

Town of Plymouth. 2004b. Water bills for Entergy Nuclear Generation Co, Pilgrim Nuclear

Station for billing period October 29, 2003 to May 3, 2004. Plymouth, Massachusetts.

Town of Plymouth. 2004c. Plymouth Code, Chapter 205, Zoning Bylaw, Table 5, Dated 07-15-

2004. Town of Plymouth, Massachusetts. Accessed at: http://www.plymouthma.gov/Public_Documents/PlymouthMA_TownClerk/Bylaws/S00A06AE9.-1/Ch205Table5.pdf on

September 1, 2006.

Town of Plymouth. 2006a. Town of Plymouth, Massachusetts, Master Plan, 2005-2025. |

Plymouth Planning Board and Master Plan Committee, Plymouth, Massachusetts.

Town of Plymouth. 2006b. Top Ten Taxpayers, FY 2000-2006. Records provided by Bruce |

Mille, Finance Director, Town of Plymouth, Massachusetts.

|

Town of Plymouth. 2007a. Press release dated April 24, 2007 concerning new PILOT |

agreement reached with Entergy Corporation. Accessed at: http://www.plymouth- |

ma.gov/Public_Documents/PlymouthMA_BBoard/00E9C346-000F8513.pdf on April 25, 2007. |

|

Town of Plymouth. 2007b. Town of Plymouth Fiscal Year 2008 Budget Primer; Budget |

Presentation January 16, 2007. Accessed at: http:///www.plymouth- |

ma.gov/Public_Documents/PlymouthMA_Finance/Fy2008%20Budget%20Info/FY%202008%20B |

OS%20Budget%20Presentation%20January%2007.pdf on April 25, 2007. |

Turner, J. 1976. Form D – Archaeological Survey, Prehistoric Archaeological Sites, MHC

Number 19-PL-68. Massachusetts Historical Commission. |

Turner, S.C. 1986. Population dynamics of, and impact of fishing on, tilefish, Lopholatilus

chamaeleonticeps, in the Middle Atlantic-southern New England region during the 1970s and

early 1980s. Ph.D. dissertation, Rutgers University, New Brunswick, New Jersey, pg. 289. |

Tyler, A.V. 1971 . Periodic and resident components in communities of Atlantic fishes. Journal |

of the Fisheries Research Board of Canada 28: pgs. 935-946. |

U.S. Army Corps of Engineers, New England District (USACE). 2006. Update Report for

Massachusetts. Accessed at: http://www.nae.usace.army.mil. on June 23, 2006.

U.S. Census Bureau (USCB). 1990. Census of Population and Housing 1990, Summary Tape

File 3, Tables H001 and H006. Accessed at: http://factfinder.census.gov on May 5, 2006.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-164 July 2007

U.S. Census Bureau (USCB). 1995. Population of Counties by Decennial Census: 1900 to

1990. Compiled and edited by Richard L. Forstall, Population Division, USCB, Washington, DC. 

Accessed at: http://www.census.gov/population/cencounts/ma190090.txt on May 5, 2006.

U.S. Census Bureau (USCB). 2000. Census of Population and Housing 2000, Summary File 3,

Tables H1, H6 and H8. Accessed at: http://factfinder.census.gov on May 5, 2006.

U.S. Census Bureau (USCB). 2006a. State & County Quick Facts, Barnstable County,

Massachusetts. Accessed at: http://quickfacts.census.gov/qfd/states/25/25001.html on

September 6, 2006.

U.S. Census Bureau (USCB). 2006b. State & County Quick Facts, Plymouth County,

Massachusetts. Accessed at: http://quickfacts.census.gov/qfd/states/25/25023.html on

September 6, 2006.

USGenNet.org. Originally published by Rand McNally Corp. as “Plymouth County

Massachusetts 1895”, in The New 11 x 14 Atlas of the World. Accessed at: USGenNet.org on

April 7, 2006. 

Urbanomics. 2006. Projections of school populations, Town of Plymouth, Massachusetts, Draft

tables provided by L. Hartman, Director of Planning and Development, Town of Plymouth,

Massachusetts.

Vanasse & Associates, Inc. 2001. Traffic Data Technical Data Phased Review Document:

Phase III, The Pinehills, Plymouth, Massachusetts, Volume II, Appendix E. Andover,

Massachusetts.

Vinogradov, V.I. and A.S. Noskov. 1979. Feeding of short-finned squid, Illex illecebrosus, and

| longfinned squid, Loligo pealei, off Nova Scotia and New England 1974-75. International

| Commission 

Virginia Institute of Marine Science (VIMS). 2006. Fisheries Ecosystem Monitoring and

Assessment Project. Accessed at:

http://www.fisheries.vims.edu/femap/fish%20pages/Atlantic%20Menhaden.htm. on 

September 9, 2006.

Vovk, A.N. 1972. Method of determining maturing stages in gonads of the squid Loligo pealei.

| Zool. ZH 51: pgs. 127-132. Canadian Department of Fisheries and Ocean, Marine Services,

| Translation. 3304. 

Walker, Geo. H. & Co. 1879. Atlas of Plymouth County Massachusetts Compiled from Recent

and Actual Surveys and Records. Geo. H. Walker & Co, 61 Hanover Street, Boston,

Massachusetts.
Plant and the Environment

July 2007 2-165 NUREG-1437, Supplement 29

Weinberg, J. 2000. Status of Fisheries Resources off Northeastern United States-Atlantic

Surfclam. Revised: January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/iv/surfclam, August 8, 2006.

Weinberg, J. 2001. Status of Fisheries Resources off Northeastern United States-Ocean

Quahog. Revised: June 2001. Accessed at: http://www.nefsc.noaa.gov/sos/spsyn/iv/quahog,

August 8, 2006.

Werme, C.E. 1981. Resource partitioning in a salt marsh fish community. Ph.D. dissertation,

Boston University, Boston, Massachusetts, pg. 132. |

Whitaker, J.O. 1980. The Audubon Society Field Guide to North American Mammals. Alfred A.

Knopf, New York.

Wicklund, R.I. 1970. Observations on the spawning of the Cunner in waters of Northern New

Jersey. Chesapeake Sciences 11: pg. 137. |

Wigley, S. 1998. Ocean pout. S.H. Clark, ed., Status of the fishery resources off the

northeastern United States for 1998, pgs. 94-95. NOAA Technical Memorandum |

NMFS-NE-115. 

Wigley, S., and L. Col. 2005a. Witch Flounder. Assessment of 19 Northeast groundfish stocks

through 2004 2005 Groundfish Assessment Review Meeting (2005 GARM), Northeast Fisheries

Science Center, Woods Hole, Massachusetts, 15-19 August 2005. Northeast Fisheries Science

Center Reference Document 05-13. Accessed at:

http://www.nefsc.noaa.gov/nefsc/publications/crd/cdr0513 on August 8, 2006.

Wigley, S., and L. Col. 2005b. Ocean Pout. Assessment of 19 Northeast groundfish stocks

through 2004 2005 Groundfish Assessment Review Meeting (2005 GARM), Northeast Fisheries

Science Center, Woods Hole, Massachusetts. 15-19 August 2005. Northeast Fisheries Science

Center Reference Document 05-13. Accessed at:

http://www.nefsc.noaa.gov/nefsc/publications/crd/cdr0513 on August 8, 2006.

Wigley, S.E. 2000a. Ocean Pout. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/og/pout/ on August 8, 2006.

Wigley, S.E. 2000b. Witch Flounder. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/fldrs/witch/ on August 8, 2006.

Wigley, S.E., Brodziak, J.K.T., and L. Col. 2003. Assessment of the Gulf of Maine and

Georges Bank witch flounder stock for 2003. A Report of the 37th Northeast Regional Stock

Assessment Workshop, September 2003.
Plant and the Environment 

 NUREG-1437, Supplement 29 2-166 July 2007

Winters, G.H. 1983. Analysis of the Biological and Demographic Parameters of the Northern

Sand Lance, Ammodytes dubius, from the Newfoundland Grand Bank. Canadian Journal of

| Fisheries and Aquatic Sciences 40: pgs. 409-419. 

| Wood, P.W., Jr. 1982. Goosefish, Lophius americanus. In M.D. Grosslein and T.R. Azarovitz,

| eds. Fish distribution. p. 67-70, MESA New York Bight Atlas Monograph 15, New York Sea

| Grant Institute. Albany, New York. 

World Book Encyclopedia. Massachusetts Climate. Chicago, Illinois, 2006.
(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

July 2007 3-1 NUREG-1437, Supplement 29

3.0 Environmental Impacts of Refurbishment

Environmental issues associated with refurbishment activities are discussed in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437,

Volumes 1 and 2 (NRC 1996; 1999).(a) The GEIS includes a determination of whether the

analysis of the environmental issues could be applied to all plants and whether additional

mitigation measures would be warranted. Issues are then assigned a Category 1 or a

Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of

the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system

or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to

the impacts (except for collective off-site radiological impacts from the fuel cycle and

from high-level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures

are likely not to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

required in this Supplemental Environmental Impact Statement unless new and significant |

information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1;

therefore, additional plant-specific review of these issues is required.

License renewal actions may require refurbishment activities for the extended plant life. These

actions may have an impact on the environment that requires evaluation, depending on the type

of action and the plant-specific design. Environmental issues associated with refurbishment

that were determined to be Category 1 issues are listed in Table 3-1.

Environmental issues related to refurbishment considered in the GEIS for which these conclusions could not be reached for all plants, or for specific classes of plants, are Category 2 issues. 

These are listed in Table 3-2.
Environmental Impacts of Refurbishment

NUREG-1437, Supplement 29 3-2 July 2007

Table 3-1. Category 1 Issues for Refurbishment Evaluation

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Impacts of refurbishment on surface water quality 3.4.1

Impacts of refurbishment on surface water use 3.4.1

AQUATIC ECOLOGY (FOR ALL PLANTS)

Refurbishment 3.5

GROUND-WATER USE AND QUALITY

Impacts of refurbishment on ground-water use and quality 3.4.2

LAND USE

On-site land use 3.2

HUMAN HEALTH

Radiation exposures to the public during refurbishment 3.8.1

Occupational radiation exposures during refurbishment 3.8.2

SOCIOECONOMICS

Public services: public safety, social services, and tourism and recreation 3.7.4; 3.7.4.3; 3.7.4.4;

3.7.4.6

Aesthetic impacts (refurbishment) 3.7.8

Category 1 and Category 2 issues related to refurbishment that are not applicable to Pilgrim

Nuclear Power Station (PNPS) because they are related to plant design features or site

characteristics not found at PNPS are listed in Appendix F.

The potential environmental effects of refurbishment actions would be identified, and the

analysis would be summarized within this section, if such actions were planned. Entergy

Nuclear Operations, Inc. (Entergy) indicated that it has performed an evaluation of structures

and components pursuant to Title 10 of the Code of Federal Regulations (CFR), Part 54,

Section 54.21 to identify activities that are necessary to continue operation of PNPS during the

requested 20-year period of extended operation. These activities include replacement of certain

components as well as new inspection activities, and are described in the Environmental Report

(Entergy 2006).
Environmental Impacts of Refurbishment

July 2007 3-3 NUREG-1437, Supplement 29

Table 3-2. Category 2 Issues for Refurbishment Evaluation

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1

GEIS

Sections

10 CFR 51.53

(c)(3)(ii)

Subparagraph

TERRESTRIAL RESOURCES

Refurbishment impacts 3.6 E

THREATENED OR ENDANGERED SPECIES (FOR ALL PLANTS)

Threatened or endangered species 3.9 E

AIR QUALITY

Air quality during refurbishment (nonattainment and

maintenance areas)

3.3 F

SOCIOECONOMICS

Housing impacts 3.7.2 I

Public services: public utilities 3.7.4.5 I

Public services, education (refurbishment) 3.7.4.1 I

Off-site land use (refurbishment) 3.7.5 I

Public services, transportation 3.7.4.2 J

Historic and archaeological resources 3.7.7 K

ENVIRONMENTAL JUSTICE

Environmental justice Not

addressed(a)

Not 

addressed(a)

(a) Guidance related to environmental justice was not in place at the time the GEIS and the associated revision to

10 CFR Part 51 were prepared. If an applicant plans to undertake refurbishment activities for license renewal,

environmental justice must be addressed in the applicant’s environmental report and the staff’s environmental

impact statement. The Commission issued a Final Policy Statement on the Treatment of Environmental

Justice Matters in NRC Regulatory and Licensing Actions in 2004 (NRC 2004). 

However, Entergy stated that the replacement of these components and the additional

inspection activities are within the bounds of normal plant component replacement and

inspections; therefore, they are not expected to affect the environment outside the bounds of

plant operations as evaluated in the final environmental statement (AEC 1972). In addition,

Entergy's evaluation of structures and components as required by 10 CFR 54.21 did not identify

any major plant refurbishment activities or modifications necessary to support the continued

operation of PNPS beyond the end of the existing operating licenses. Therefore, refurbishment

is not considered in this Supplemental Environmental Impact Statement. |
Environmental Impacts of Refurbishment

NUREG-1437, Supplement 29 3-4 July 2007

3.1 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.”

Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to Operation

| of Pilgrim Nuclear Power Station, Boston Edison Company. Docket Number 50-293,

| Washington, DC.

Entergy Nuclear Operations, Inc. (Entergy). 2006. Applicant’s Environmental Report –

| Operating License Renewal Stage, Pilgrim Nuclear Power Station. Docket Number 50-293, 

Plymouth, Massachusetts.

Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for

| License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, DC.

Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1,

Summary of findings on NEPA issues for license renewal of nuclear power plants,” Final Report. 

| NUREG-1437, Volume 1, Addendum 1, Washington, DC.

Nuclear Regulatory Commission (NRC). 2004. “Policy Statement on the Treatment of

Environmental Justice Matters in NRC Regulatory and Licensing Actions,” Final. Federal

| Register: Volume 69, Number 163, pgs. 52040-52048. August 24, 2004.
(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hearafter, all

references to the “GEIS” include the GEIS and its Addendum 1. 

July 2007 4-1 NUREG-1437, Supplement 29

4.0 Environmental Impacts of Operation

Environmental issues associated with operation of a nuclear power plant during the renewal

term are discussed in the Generic Environmental Impact Statement for License Renewal of

Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996, 1999).(a) The GEIS

includes a determination of whether the analysis of the environmental issues could be applied to

all plants and whether additional mitigation measures would be warranted. Issues are then

assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 issues

are those that meet all of the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system

or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to

the impacts (except for collective off-site radiological impacts from the fuel cycle and

from high-level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures

are likely not to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

required unless new and significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1, and

therefore, additional plant-specific review of these issues is required.

This chapter addresses the issues related to operation during the renewal term that are listed in

Table B-1 of Title 10 of the Code of Federal Regulations (CFR) Part 51, Subpart A, Appendix B

and are applicable to Pilgrim Nuclear Power Station (PNPS). Section 4.1 addresses issues

applicable to the PNPS cooling system. Section 4.2 addresses issues related to transmission

lines and on-site land use. Section 4.3 addresses the radiological impacts of normal operation,

and Section 4.4 addresses issues related to the socioeconomic impacts of normal operation

during the renewal term. Section 4.5 addresses issues related to groundwater use and quality,

while Section 4.6 discusses the impacts of renewal-term operations on threatened and

endangered species. Section 4.7 addresses potential new information that was raised during

the scoping period, and Section 4.8 discusses cumulative impacts. The results of the

evaluation of environmental issues related to operation during the renewal term are summarized
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-2 July 2007

in Section 4.9. Finally, Section 4.10 lists the references for Chapter 4. Category 1 and

Category 2 issues that are not applicable to PNPS because they are related to plant design

features or site characteristics not found at PNPS are listed in Appendix F.

4.1 Cooling System 

Category 1 issues in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, that are applicable to

PNPS cooling system operation during the renewal term are listed in Table 4-1. Entergy

Nuclear Operations, Inc. (Entergy) stated in its Environmental Report (ER) (Entergy 2006a) that

it is not aware of any new and significant information associated with the renewal of the PNPS

operating license (OL). The U.S. Nuclear Regulatory Commission (NRC) staff has not identified

any new and significant information during its independent review of the Entergy ER, the staff’s

| site visit, the scoping process, evaluation of other available information, or consideration of

| public comments. For all of the Category 1 issues, the staff concluded in the GEIS that the

impacts would be SMALL, and additional plant-specific mitigation measures are not likely to be

sufficiently beneficial to be warranted.

Table 4-1. Category 1 Issues Applicable to the Operation of the PNPS 

Cooling System During the Renewal Term

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Altered current patterns at intake and discharge structures 4.2.1.2.1

Altered salinity gradients 4.2.1.2.2

Temperature effects on sediment transport capacity 4.2.1.2.3

Scouring caused by discharged cooling water 4.2.1.2.3

Discharge of chlorine or other biocides 4.2.1.2.4

Discharge of other metals in wastewater 4.2.1.2.4

Water use conflicts (plants with once-through cooling systems) 4.2.1.3
Environmental Impacts of Operation

July 2007 4-3 NUREG-1437, Supplement 29

Table 4-1. (contd)

AQUATIC ECOLOGY (FOR ALL PLANTS)

Accumulation of contaminants in sediments or biota 4.2.1.2.4

Entrainment of phytoplankton and zooplankton 4.2.2.1.1

Cold shock 4.2.2.1.5

Thermal plume barrier to migrating fish 4.2.2.1.6

Distribution of aquatic organisms 4.2.2.1.6

Gas supersaturation (gas bubble disease) 4.2.2.1.8

Low dissolved oxygen in the discharge 4.2.2.1.9

Losses from predation, parasitism, and disease among organisms

exposed to sublethal stresses

4.2.2.1.10

Stimulation of nuisance organisms 4.2.2.1.11

Human Health

Noise 4.3.7

A brief description of the staff’s review and the GEIS conclusions, as codified in Table B-1, for

each of these Category 1 issues follows:

 C Altered current patterns at intake and discharge structures. Based on information in the

GEIS, the Commission found that: 

Altered current patterns have not been found to be a problem at operating nuclear

power plants and are not expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, evaluation of other available |

information, or consideration of public comments. Therefore, the staff concludes that there |

would be no impacts of altered current patterns at intake and discharge structures during the

renewal term beyond those discussed in the GEIS.
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-4 July 2007

• Altered salinity gradients. Based on information in the GEIS, the Commission found that:

Salinity gradients have not been found to be a problem at operating nuclear power

plants and are not expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, evaluation of other available

| information, or consideration of public comments. Therefore, the staff concludes that there

would be no impacts of altered salinity gradients during the renewal term beyond those

discussed in the GEIS.

 C Temperature effects on sediment transport capacity. Based on information in the GEIS,

the Commission found that:

These effects have not been found to be a problem at operating nuclear power

plants and are not expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, evaluation of other available

| information, or consideration of public comments. Therefore, the staff concludes that there

would be no impacts of temperature effects on sediment transport capacity during the

renewal term beyond those discussed in the GEIS.

 C Scouring caused by discharged cooling water. Based on information in the GEIS, the

Commission found that:

Scouring has not been found to be a problem at most operating nuclear power

plants and has caused only localized effects at a few plants. It is not expected to be

a problem during the license renewal term.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, its review of monitoring

| programs, evaluation of other available information, or consideration of public comments. 

Therefore, the staff concludes that there would be no impacts regarding sediment

transportation due to scouring caused by discharged cooling water during the renewal term

beyond those discussed in the GEIS.

| Scouring also affects submerged aquatic vegetation in the immediate vicinity of the

discharge at PNPS. Such minor, localized effects of scouring are discussed in Section

4.1.3.
Environmental Impacts of Operation

July 2007 4-5 NUREG-1437, Supplement 29

 C Discharge of chlorine or other biocides. Based on information in the GEIS, the

Commission found that:

Effects are not a concern among regulatory and resource agencies, and are not

expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, evaluation of other available |

information including the National Pollutant Discharge Elimination System (NPDES) permit

for PNPS, discussion with the U.S. Environmental Protection Agency (EPA) NPDES |

compliance office, or consideration of public comments. To evaluate the potential impacts |

to water quality, the staff evaluated the discharge data presented in the applicant’s April

2005 to March 2006 monthly Discharge Monitoring Reports (DMRs) for the PNPS facility. 

During this time period, an effluent limitation was outside of the permit requirement on three

occasions. One exceedence was for total suspended solids. On one occasion in January |

2006 and another in February 2006, there was a problem with the screenwash

dechlorination system (outfall 003) in which chlorine was detected in the screenwash

sluiceway. In each instance, one of the dechlorination pumps was not pumping adequately. 

One pump was repaired and the other replaced, and the system was restored to normal

operation. Although exceedences of the chlorine permit limits have been observed at

PNPS, no notices of violation have been issued by the Commonwealth. The staff has |

determined that there would be no significant impacts of discharge of chlorine or other

biocides during the renewal term beyond those discussed in the GEIS.

 C Discharge of other metals in wastewater. Based on information in the GEIS, the

Commission found that:

These discharges have not been found to be a problem at operating nuclear power

plants with cooling-tower-based heat dissipation systems and have been

satisfactorily mitigated at other plants. They are not expected to be a problem

during the license renewal term.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, evaluation of other available |

information including the NPDES permit for PNPS, or consideration of public comments. |

Therefore, the staff concludes that there would be no impacts of discharges of other metals

in wastewater during the renewal term beyond those discussed in the GEIS.
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-6 July 2007

 C Water-use conflicts (plants with once-through cooling systems). Based on information in

the GEIS, the Commission found that:

These conflicts have not been found to be a problem at operating nuclear power

plants with once-through heat dissipation systems.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, evaluation of other available

| information, or consideration of public comments. Therefore, the staff concludes that there

would be no impacts of water-use conflicts for plants with once-through cooling systems

during the renewal term beyond those discussed in the GEIS. 

 C Accumulation of contaminants in sediments or biota. Based on information in the GEIS,

the Commission found that:

Accumulation of contaminants has been a concern at a few nuclear power plants

but has been satisfactorily mitigated by replacing copper alloy condenser tubes with

those of another metal. It is not expected to be a problem during the license

renewal term.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, evaluation of available

| information, or consideration of public comments. Therefore, the staff concludes that there

would be no impacts of accumulation of contaminants in sediments or biota during the

renewal term beyond those discussed in the GEIS.

 C Entrainment of phytoplankton and zooplankton. Based on information in the GEIS, the

Commission found that:

Entrainment of phytoplankton and zooplankton has not been found to be a problem

at operating nuclear power plants and is not expected to be a problem during the

license renewal term.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, review of monitoring programs,

| evaluation of other available information, or consideration of public comments. Therefore,

the staff concludes that there would be no impacts of entrainment of phytoplankton and

zooplankton during the renewal term beyond those discussed in the GEIS.
Environmental Impacts of Operation

July 2007 4-7 NUREG-1437, Supplement 29

 C Cold shock. Based on information in the GEIS, the Commission found that:

Cold shock has been satisfactorily mitigated at operating nuclear plants with oncethrough cooling systems, has not endangered fish populations or been found to be

a problem at operating nuclear power plants with cooling towers or cooling ponds,

and is not expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, evaluation of other available |

information, or consideration of public comments. Therefore, the staff concludes that there |

would be no impacts of cold shock during the renewal term beyond those discussed in the

GEIS.

 C Thermal plume barrier to migrating fish. Based on information in the GEIS, the

Commission found that:

Thermal plumes have not been found to be a problem at operating nuclear power

plants and are not expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, evaluation of other available |

information, or consideration of public comments. Therefore, the staff concludes that there |

would be no impacts of thermal plume barriers to migrating fish during the renewal term

beyond those discussed in the GEIS.

 C Distribution of aquatic organisms. Based on information in the GEIS, the Commission

found that:

Thermal discharge may have localized effects but is not expected to affect the

larger geographical distribution of aquatic organisms.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, review of monitoring programs, |

evaluation of other available information, or consideration of public comments. Therefore, |

the staff concludes that there would be no impacts on larger geographical distribution of |

aquatic organisms during the renewal term beyond those discussed in the GEIS. Minor, |

localized effects of thermal discharge on submerged aquatic vegetation are discussed in |

Section 4.1.3. |
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-8 July 2007

 C Gas supersaturation (gas bubble disease). Based on information in the GEIS, the

Commission found that:

Gas supersaturation was a concern at a small number of operating nuclear power

plants with once-through cooling systems but has been satisfactorily mitigated. It

has not been found to be a problem at operating nuclear power plants with cooling

towers or cooling ponds and is not expected to be a problem during the license

renewal term.

Several incidents of gas bubble disease occurred at PNPS in the mid 1970s (Lawton et al:,

1986). In response to these incidents, a fish barrier net was installed in the discharge canal

to lessen the magnitude of the mortality events, should supersaturated conditions occur in

the discharge. There have been no additional incidents of gas bubble disease since that

time, and the fish barrier net has been removed from the discharge canal and is currently

stored on site.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, review of monitoring programs,

| evaluation of other available information, or consideration of public comments. Therefore,

the staff concludes that there would be no impacts of gas supersaturation during the

renewal term beyond those discussed in the GEIS. 

 C Low dissolved oxygen in the discharge. Based on information in the GEIS, the

Commission found that:

Low dissolved oxygen has been a concern at one nuclear power plant with a oncethrough cooling system but has been effectively mitigated. It has not been found to

be a problem at operating nuclear power plants with cooling towers or cooling

ponds and is not expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, review of monitoring programs,

| evaluation of other available information, or consideration of public comments. Therefore,

the staff concludes that there would be no impacts of low dissolved oxygen during the

renewal term beyond those discussed in the GEIS.
Environmental Impacts of Operation

July 2007 4-9 NUREG-1437, Supplement 29

 C Losses from predation, parasitism, and disease among organisms exposed to sublethal

stresses. Based on information in the GEIS, the Commission found that:

These types of losses have not been found to be a problem at operating nuclear

power plants and are not expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, evaluation of other available |

information, or consideration of public comments. Therefore, the staff concludes that there |

would be no impacts of losses from predation, parasitism, and disease among organisms

exposed to sub-lethal stresses during the renewal term beyond those discussed in the

GEIS.

 C Stimulation of nuisance organisms. Based on information in the GEIS, the Commission

found that:

Stimulation of nuisance organisms has been satisfactorily mitigated at the single

nuclear power plant with a once-through cooling system where previously it was a

problem. It has not been found to be a problem at operating nuclear power plants

with cooling towers or cooling ponds and is not expected to be a problem during the

license renewal term.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, evaluation of other available |

information, or consideration of public comments. Therefore, the staff concludes that there |

would be no impacts of stimulation of nuisance organisms during the renewal term beyond

those discussed in the GEIS.

 C Noise. Based on information in the GEIS, the Commission found that:

Noise has not been found to be a problem at operating plants and is not expected to

be a problem at any plant during the license renewal term.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, evaluation of other available |

information, or consideration of public comments. Therefore, the staff concludes that there |

would be no impacts of noise during the license renewal term beyond those discussed in the

GEIS.
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-10 July 2007

The Category 2 issues related to cooling system operation during the renewal term that are

applicable to PNPS are discussed in the sections that follow, and are listed in Table 4-2.

Additionally, PNPS operations are not expected to affect any marine mammals. 

Table 4-2. Category 2 Issues Applicable to the Operation of the 

PNPS Cooling System During the Renewal Term

ISSUE—10 CFR Part 51, Subpart A, Appendix

B, Table B-1

GEIS

Sections

10 CFR

51.53(c)(3)(ii)

Subparagraph

SEIS

Section

AQUATIC ECOLOGY

(FOR PLANTS WITH ONCE-THROUGH AND COOLING POND HEAT-DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in early life stages 4.2.2.1.2 B 4.1.1

Impingement of fish and shellfish 4.2.2.1.3 B 4.1.2

Heat shock 4.2.2.1.4 B 4.1.3

4.1.1 Entrainment of Fish and Shellfish in Early Life Stages

For plants with once-through cooling systems such as PNPS, entrainment of fish and shellfish in

early life stages into nuclear power plant cooling water systems is considered a Category 2

| issue, thus requiring a site-specific assessment for the license renewal review. The staff 

reviewed the PNPS ER, visited the site, consulted with Federal and State resource agencies,

| reviewed the applicant's existing NPDES permit and existing literature related to fish and

| shellfish populations of Cape Cod Bay, and considered public comments with particular regard

to entrainment studies conducted at the PNPS.

Section 316(b) of the Clean Water Act of 1977 (CWA), common name of the Federal Water

Pollution Control Act, requires that the location, design, construction, and capacity of cooling

water intake structures reflect the best technology available for minimizing adverse

environmental impacts (33 U.S.C. 1326). Entrainment of fish and shellfish into the cooling water

| system is a potential adverse environmental impact that can be minimized by the use of best

| technology available. Licensees may be required as part of the NPDES permit renewal to alter

| the intake structure, redesign the cooling system, modify facility operation, or take other

| mitigative measures. Licensees must comply with Section 316(b) of the CWA. However, EPA’s

| 316(b) Phase II Rule has been suspended and compliance with the rule is currently based on

| EPA’s best professional judgment.
Environmental Impacts of Operation

July 2007 4-11 NUREG-1437, Supplement 29

4.1.1.1 Environmental Monitoring

The potential impacts to the marine environment have been actively monitored since the station

first went on line in 1972. The majority of the monitoring program has been conducted in

response to requests of Massachusetts Department of Environmental Protection (MDEP) and |

the environmental monitoring and permitting requirements of the facility’s NPDES permit from

the EPA. As of the writing of this Supplemental Environmental Impact Statement (SEIS), a total

of 67 semi-annual reports has been developed by the owners of PNPS addressing all aspects of

the nearshore environment surrounding PNPS, including impingement, entrainment, marine

fisheries, plankton, aquatic plants, the benthic community, temperature and oceanographic

studies, and mitigation strategies. The 316 demonstration report (ENSR 2000) contains a

detailed overview of the studies that were performed through 1999. 

Marine algal studies were conducted periodically from the mid 1970s, up through the late

1990s, primarily to evaluate impacts of the thermal discharge on algal species, in particular Irish

moss (Chondrus crispus). Studies of the benthic fauna, including the American lobster

(Homarus americanus), were conducted from the early 1970s up through the late 1980s, while

plankton studies were conducted primarily in the mid 1970s. Several temperature and

oceanographic studies have also been conducted by the applicant throughout the operating

history of PNPS. Thermal plume studies have included dye studies, boat-based thermal plume

surveys, and aerial infrared surveys. These studies were used as input to develop a thermal

plume model. Several studies of the current structure and velocities in the immediate area

surrounding PNPS have also been conducted by the applicant, universities, and Federal

government agencies (ENSR 2000).

Monitoring of marine fisheries in the area surrounding PNPS has taken place since the early

1970s. Many of these studies were performed by the Massachusetts Division of Marine

Fisheries (MDMF) and have included overflights of the nearshore environment; diving surveys;

sampling including bottom trawling, gill netting, and haul seining; and recreational creel surveys

(ENSR 2000). In addition, several species-specific studies have been performed to evaluate

impacts to winter flounder (Pseudopleuronectes americanus), cunner 

(Tautogolabrus adspersus), and rainbow smelt (Osmerus mordax).

For the past 11 years, annual area-swept surveys have been conducted in the form of trawls to |

assess the population status of the winter flounder stock in northwestern Cape Cod Bay, as this

species is very important to commercial and recreational fishermen in the area and the waters

around PNPS serve as a spawning, nursery, and feeding grounds (MRI 2005a). The studies

were initially conducted by the MDMF. More recently, the work has been conducted by Marine

Research, Inc. (MRI) under contract to PNPS. The target approach for each of these surveys

is at least 84 tows, of at least 30 minutes in duration (MRI 2005a). 
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-12 July 2007

For the 2005 sampling event, 75 tows were completed between mid April and early May,

resulting in a total catch of 4206 winter flounder. Population size (expressed as instantaneous

absolute abundance) was determined using an area/density approach. After accounting for

efficiency of the sampling gear, estimates of winter flounder abundance in the study area were

| approximately 126,000 adults and 230,000 total winter flounder (MRI 2005a). These 2005

| abundance estimates were less than 50 percent of the corresponding means for the 1995-2004

| time series. However, this decline may be due, in part, to the natural and fishing induced

| decline in the strong 1997 and 1998 year classes (MRI 2005a). 

| Larval transport studies were conducted in May 2000, May 2002, and May to June 2004 for the

purposes of determining the flux of winter flounder larvae moving along the coast and the flux of

winter flounder larvae entering PNPS through entrainment (ENSR and MRI 2005). The studies

| consisted of larval sampling at five offshore locations in Cape Cod Bay and entrainment

sampling in the discharge canal. Water velocity measurements were also conducted at various

| locations to correlate larval density with water movements. Sampling in 2004 included two

| larval-sampling surveys conducted on May 26-27 and June 3-4 (ENSR and MRI 2005). 

In 2000, entrainment rates up to 5 percent were observed for stage 4 winter flounder larvae

while the entrainment rates for all other larvae were less than 1 percent (ENSR and MRI 2000).

| Of the four surveys conducted for the 2002 winter flounder entrainment study, stage 4 larval

| entrainment rates were 4 percent in one survey and less than 1 percent in another, and the

entrainment rate for the other two surveys could not be calculated due to the fact that no stage

| 4 larvae were collected in the open water stations. Two of the surveys also showed relatively

high entrainment rates for stage 3 larvae (26 percent and 3 percent), whereas the remainder of

| the larval stages had an entrainment rate of less than 1 percent(ENSR and MRI 2002). The

2000 and 2002 reports state that the periodic high entrainment rates observed for stages 3 and

4 larvae were likely due to difficulties in collecting the stages 3 and 4 larvae, as these larval

| stages generally are associated with the bottom sediments (ENSR and MRI 2000, 2002). For

| example, the 2002 study included an evaluation of larval sampling methods that found that

| densities of stage 3 larvae in samples from a bottom sled were 10 times higher than in net

| samples from higher in the water column. However, the bottom sled was not used for the

| sampling to calculate entrainment rates in 2000 and 2002. As a result, the stages 3 and 4 larval

| transport values calculated for the bay in those years may underestimate actual values by

| approximately an order of magnitude and may similarly overestimate the percentages of stage 3

| and 4 larvae entrained (ENSR and MRI 2000, 2002).

|

| The surveys used plankton nets to sample the water column from two layers, surface to mid-

| depth and mid-depth to near-bottom. In addition, a bottom sled rigged with a net was used to

| sample the epibenthic layer closer to the bottom than the other nets could be towed. During the

| first survey, the sled was damaged in the third of four sampling events. As a result, bottom
Environmental Impacts of Operation

July 2007 4-13 NUREG-1437, Supplement 29

samples were not obtained for two of the four sampling locations in the third event, and no |

bottom samples were collected with the sled in the fourth sampling event. When calculating |

larval transport, the net samples from the mid-depth to near-bottom interval were used for the |

deepest water column interval in place of these missing sled data. Because stage 4 larvae tend |

to remain near the bottom, the sled samples routinely yielded the highest counts of these larvae. |

Consequently, the reduced bottom sled samples in the first survey likely resulted in an |

underestimation of the density of stage 4 larvae in the bay and an overestimation of entrainment |

when the estimated larval transport was used to calculate the percentage entrained (based on |

the number of larvae entrained in a day divided by the number of larvae carried past PNPS in |

the net longshore current). The sled was repaired and used to collect bottom samples at all |

stations and in all events of the second survey one week later. The second survey collected |

almost 14 times as many stage 4 larvae in the bay as the first survey, resulting in a percentage |

entrained of 0.44 (ENSR and MRI 2005). |

Results from the most recent entrainment sampling in 2004 indicate that PNPS likely entrains a |

small percentage (less than 2 percent) of stages 1, 2, and 3 winter flounder larvae |

(ENSR and MRI 2005). Results for stage 4 winter flounder larvae were mixed, with one of the

surveys indicating almost a 20-percent entrainment rate and the other survey indicating less |

than 1 percent entrainment. The report discussing the results of the 2004 study |

(ENSR and MRI 2005) attributed the exceptionally high percentage of stage 4 larvae collected |

in the first survey to difficulties with the sampling equipment in conjunction with the benthic |

lifestyle of stage 4 larvae. |

|

According to the authors, the results of the 2004 study were similar to those of 2000 and 2002 |

in indicating that overall there appeared to be a consistent net flow of water and winter flounder |

larvae to the south in near shore waters off PNPS. They also concluded that less than 0.1

percent of the net volumetric flow of water in western Cape Cod Bay offshore of PNPS and |

within 6 mi of the shoreline passes through PNPS, and they estimated that the amount of winter |

flounder larvae in northwestern Cape Cod Bay entrained by PNPS is less than 1.3 percent of |

the net larval transport (ENSR and MRI 2005).

Through the early years of operation of the PNPS, cunner have had relatively high entrainment

rates based on comparisons to other species entrained at PNPS. A tagging study was initiated

in 1990 to evaluate the absolute abundance of this species in the PNPS area, as the near shore 

waters around the plant serve as spawning, nursery, and adult feeding grounds. The data,

although not conclusive, indicated that the PNPS has a minor effect on recruitment success to

the local population (Lawton et al. 2000a). 

Rainbow smelt have periodically had high impingement rates throughout the history of PNPS

based on comparison to other species impinged at the plant. After a large impingement event in
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-14 July 2007

1978, a study was initiated to obtain site-specific population data in order to assess impacts on

the local smelt population. This study was focused on the Jones River, which is the principal

spawning ground for smelt in the Plymouth area. This study evaluated egg production,

| population structure and size, as well as the degree of parasitic infestation in the stock. Based

| on this study, the spawning stock abundance for the Jones River population was calculated to

have been 4.18 x 106 | adult smelt in 1981. Comparison of these population data to impingement

data at PNPS indicated that PNPS had reduced the Jones River spawning population by less

than 1 percent (Lawton et al. 1990). The Jones River spawning run along with other runs in the

western North Atlantic have been depressed for many years. According to the MDMF, the

Jones River population is still at depressed levels (Chase 2006).

4.1.1.2 Entrainment Monitoring

Entrainment sampling was initiated in 1974 and was initially conducted twice per month from

January to February and from October to December and conducted weekly from March through

September. During these events, sampling was conducted in triplicate. Beginning in 1994, the

sampling program was modified to focus on better temporal coverage. During the January to

February and October to December time periods, samples are collected every other week on

three separate days for a total of approximately six samples per month. During the March

through September time frame, three separate samples have been collected every week for a

| total of approximately 12 samples per month (Normandeau 2006a).

| Entrainment sampling is conducted by suspending a 60-centimeter (cm) (2-ft) diameter plankton

net (with flowmeter) in the discharge canal approximately 30 meters (m) (98 ft) from the

headwall. Typically a standard mesh of 0.333 millimeters (mm) [0.013 inches (in.)] is used, with

the exception of the late March through late May time period, when a 0.202-mm (0.007-in.)

mesh is used to capture early stage larval winter flounder. The sampling period typically

ranges from 8 to 30 minutes depending upon the tide; the higher tide requiring a longer interval

due to lower discharge stream velocities. The target is to sample a minimum quantity of 100 m3

(3531 ft3) of water. Upon termination of the sampling period, samples are preserved in 10

| percent formalin prior to laboratory identification and enumeration (Normandeau 2006a).

| Sixty-three different fish species have been collected over the last 30 years of entrainment

| monitoring at PNPS (Table 4-3) (Normandeau 2006a). Additionally, Irish moss spores have

been identified in entrainment samples.

In this area of Cape Cod Bay, there are three primary spawning seasons: winter to early spring,

late spring to early summer, and late summer to autumn. Many of the species that spawn

during the winter to early spring period have demersal, adhesive eggs that are not normally

entrained, and as a result, more species are typically represented by larvae than by 
Environmental Impacts of Operation

July 2007 4-15 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-16 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Environmental Impacts of Operation

July 2007 4-17 NUREG-1437, Supplement 29

eggs during this time period (Normandeau 2006a). During the 2005 winter to early spring |

season (generally January to April), egg collections are dominated by Atlantic cod (Gadus

morhua), while larvae collections are dominated by the sand lance (Ammodytes americanus)

(Normandeau 2006a). In 2004, the sand lance also dominated the larvae collection while the |

egg collection was dominated by American plaice (Hippoglossoides platessoides), followed by

Atlantic cod (MRI 2005b).

The late spring to early summer season is typically the most active reproductive period among

the temperate fishes in the PNPS area (Normandeau 2006a). In both the 2004 and 2005 late |

spring to early summer seasons (May to July), the egg species were dominated by tautog

(Tautoga onitis), cunner, and yellowtail founder (Pleuronectes ferruginea), while the larvae were |

dominated by winter flounder (MRI 2005a; Normandeau 2006a). |

The late summer to early autumn season in the PNPS area typically shows a decline in overall

ichthyoplankton density and number of species collected (Normandeau 2006a). The 2004 and |

2005 late summer to early autumn seasons (August to December) are dominated by tautog,

cunner, and yellowtail flounder eggs, closely followed by fourspot flounder 

(Paralichthyus oblongus) and windowpane flounder (Scopthalmus aquosus) eggs |

(MRI 2005b; Normandeau 2006a). In 2005, the larval collections were dominated by fourbeard |

rockling (Enchelyopus cimbrius), whereas 2004 larval collections were dominated by cunner |

with the fourbeard rockling showing a much lower entrainment percentage than in 2005 |

(MRI 2005b; Normandeau 2006a). |

According to Entergy (2006b), ichthyoplankton densities obtained in 2005 are consistent with |

the data from the 1975 to 2004 time series, with the exception of Atlantic cod and Atlantic

mackerel (Scomber scrombrus) eggs and larval winter flounder and rock gunnel 

(Pholis gunnellus). Both the Atlantic cod egg and larval winter flounder abundance estimates

appear to have increasing long-term trends, whereas Atlantic mackerel egg and larval rock

gunnel estimates appear to be relatively low compared to historic data (Normandeau 2006a). |

Periodically since PNPS began operation, there have been periods when the rate of |

entrainment of fish eggs and larvae was unusually high relative to historical levels. Reporting of |

these periods of exceptionally high entrainment is required by the facility’s NPDES permit. |

Identification of these occurrences was thought to be necessary so that it could be determined |

whether high ichthyoplankton entrainment rates were being caused by conditions that are |

attributable to operation of PNPS or attributable to naturally occurring high population levels in |

the bay (i.e., during spawning season) (Normandeau 2006a). These periods of high |

entrainment levels can contribute a large proportion of the overall annual entrainment numbers |

for certain species. For example, during the 2005 sampling season, there were 54 separate

occasions when entrainment levels were unusually high as defined by comparison to historical |
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-18 July 2007

data sets. These included a total of 12 species of eggs and larvae, including American plaice,

| Atlantic menhaden, Atlantic herring (Clupea harengus), sand lance, seasnail (Liparis atlanticus),

winter flounder, radiated shanny (Ulcaria subbifurcata), cunner, fourbeard rockling, tautog,

| Atlantic mackerel, and red hake (Urophycis chuss) (Normandeau 2006a). 

| Table 4-4 presents ichthyoplankton entrainment data for six species of fish that are of concern

in this area (cunner, Atlantic mackerel, Atlantic menhaden, Atlantic herring, Atlantic cod, and

| winter flounder). There is a high level of variability in the degree of entrainment from year to

| year. This is also true for many other fish species entrained at PNPS (Normandeau 2006a). 

Cunner larval abundance as of 2005 continues to be below the 1981 to 2004 time series

average; however, no overall trends in the entrainment collections are apparent 

| (Normandeau 2006a). 

There were high entrainment densities of Atlantic mackerel eggs from the mid 1980s to mid

| 1990s, but no clear trends are apparent over the last decade (Normandeau 2006a). Abundance

indices of mackerel larvae in the entrainment collections have dropped since 1995

| (Normandeau 2006a). 

For the Atlantic menhaden, the abundance index of eggs entrained at PNPS appears to have

| dropped, but there was a significant amount of variability (Normandeau 2006a). Abundance of

larval menhaden has varied significantly over the last few years with 2004 having the lowest

abundance on record and 2005 having a relatively high abundance (compared to the last five

| years) (Normandeau 2006a). The overall stock appears to be healthy (ASMFC 2006a).

| No trends are apparent in Atlantic herring larvae entrainment data (Normandeau 2006a). 

| However, the overall stock appears to be healthy (ASMFC 2006a). 

For Atlantic cod, there are no clear trends in the abundance index of eggs and larvae. 

However, there has been an increase in stock biomass and spawning biomass observed since

| the late 1990s (Normandeau 2006a). 
Table 4-4. Number of Eggs and Larvae Entrained for Six Species of Fish at PNPS from 1980 to 2005

Winter Flounder Cunner

Number of Larvae Entrained Number of Larvae Entrained

Year

Number of EggsEntrained Stage 1 Stage 2 Stage 3 Stage 4 

Total Larvae

Entrained

Number of Eggs

Entrained Stage 1 Stage 2 Stage 3

Total Larvae

Entrained

1980 3,513,717 8,694,456 12,714,822 7,317,129 0 28,726,407 3,257,891,776 76,282,260 40,480,032 4,229,248 120,991,5401981 9,674,954 7,606,942 19,133,121 3,073,126 43,304 29,856,493 6,576,294,915 316,245,739 256,567,950 3,508,876 576,322,5651982 7,001,776 2,706,834 6,724,795 11,583,134 425,011 21,439,774 2,010,779,150 6,351,445 3,187,760 597,356 10,136,5611983 1,305,735 1,933,453 2,246,172 7,558,534 260,350 11,998,509 5,895,329,347 10,961,646 27,571,530 3,955,802 42,488,9781984 341,424 248,082 0 7,570,145 516,247 8,334,474 1,766,764,864 0 176,682 1,029,352 1,206,0341985 32,717,535 1,039,001 2,312,789 8,025,452 130,786 11,508,028 2,021,886,071 17,182,039 20,392,615 2,307,617 398822711986 5,118,035 5,397,403 5,783,669 3,963,747 77,005 15,221,824 1,493,653,289 4,419,092 22,197,318 297,368 26,913,7781987 20,857,334 0 437,608 3,088,405 0 3,526,013 4,465,564,080 40,247,222 314,474 248,738 40,810,4341988 3,494,771 1,995,968 1,656,376 15,079,960 511,009 19,243,313 1,539,089,318 2,290,972 2,624,077 2,461,452 7,376,5011989 6,423,987 1,668,823 5,755,240 2,224,675 39,114 9,687,852 4,469,416,004 34,100,052 15,224,141 2,863,938 52,188,1311990 48,501 643,683 1,155,404 6,846,718 33,002 8,678,807 1,336,048,112 65,705,970 62,378,298 44,014,528 172,098,7961991 1,217,178 3,471,022 3,908,488 5,188,056 37,717 12,605,283 675,000,390 5,790,172 3,701,490 7,243,966 16,735,6281992 4,124,308 873,660 876,914 7,034,690 26,192 8,811,456 2,174,661,078 0 1,186,819 1,605,055 2,791,8741993 3,078,941 1,595,700 3,540,750 4,934,952 88,617 10,160,019 3,235,317,207 148,674 7,178,133 7,923,303 15,250,1101994 2,530,707 1,034,617 6,433,716 13,060,373 172,606 20,701,312 1,558,253,667 0 5,545,977 4,440,095 9,986,0721995 2,766,716 1,632,907 2,820,023 8,826,496 375,857 13,655,283 4,116,491,874 7,961,638 29,910,748 9,257,792 47,130,1781996 4,896,687 504,810 5,818,499 11,329,855 995,127 18,648,291 2,807,124,109 3,765,455 8,094,509 5,558,849 17,418,8131997 3,609,393 2,225,634 9,537,788 41,484,016 2,126,280 55,373,718 1,718,289,720 6,444,923 51,895,511 41,294,559 99,634,9931998 1,035,001 3,111,891 20,282,772 58,546,916 4,904,482 86,846,061 4,341,664,826 104,908,332 211,248,501 54,060,618 370,217,4511999 1,409,453 2,031,988 588,974 1,936,648 123,103 4,680,713 1,717,578,656 36,934,878 11,960,388 7,510,427 56,405,6932000 1,693,672 33,482 170,475 5,391,088 0 5,595,045 1,349,685,330 22,411,361 39,293,994 1,388,620 63,093,9752001 330,283 4,638,546 13,093,697 37,019,304 263,144 55,014,691 2,744,377,803 1,044,260 34,542,919 35,707,859 71,295,0382002 28,637 1,389,319 6,911,151 14,802,848 1,232,865 24,336,183 580,954,607 537,068 4,771,751 10,257,985 15,566,8042003 1,977,333 722,030 480,190 2,966,524 76,394 4,245,138 759,226,058 352,721 1,783,511 1,865,231 4,001,4632004 246,468 159,859 10,431,901 49,597,823 1,988,421 62,178,004 1,452,433,321 462,728 7,927,232 8,369,181 16,759,1412005 243,151 158,986 7,470,964 20,441,584 4,277,092 32,348,626 816,334,983 820,862 10,225,681 5,504,981 16,551,524

July 2007 4-19 NUREG-1437, Supplement 29

Environmental Impacts of Operation
Table 4-4. (contd)

Atlantic Mackerel Atlantic Menhaden Atlantic Herring Atlantic Cod

Year Total Number Entrained Total Number Entrained Total Number Entrained Total Number Entrained 

Eggs Larvae Eggs Larvae Eggsa Larvae Eggs Larvae

1980 81,599,432 22,293,108 16,468,408 12,060,791 NA 1,068,466 20,388,850 1,450,5221981 183,959,791 320,135,596 3,473,080 40,076,799 NA 2,471,492 11,620,588 2,173,0761982 108,234,931 9,388,143 365,091,471 1,845,849 NA 732,857 2,582,984 222,7211983 148,616,621 41,333,673 869,580 1,227,190 NA 5,880,315 9,349,728 142,1361984 22,486,619 78,315 4,751,607 0 NA 468,840 11,726,579 587,0541985 1,867,648,438 45,711,343 41,131,470 9,190,654 NA 1,580,435 5,071,151 1,441,4421986 219,488,066 58,333,520 21,112,802 3,654,854 NA 1,811,101 2,788,767 1,035,9871987 71,222,294 215,561 311,687 1,560,529 NA 5,142,045 5,623,282 122,5791988 2,663,608,568 3,401,489 9,273,771 2,713,857 NA 639,089 2,747,034 254,2391989 4,673,915,938 65,562,469 11,212,165 4,411,807 NA 911,487 3,395,726 119,4361990 2,313,416,455 4,627,282 7,057,041 3,263,718 NA 2,079,483 2,406,536 1,566,2911991 479,761,865 66,009,482 5,744,115 512,319 NA 1,280,273 3,668,649 239,7461992 377,610,764 8,086,393 392,533 1,117,881 NA 3,970,208 2,819,673 469,7131993 1,801,378,418 8,325,789 947,815,345 11,833,443 NA 2,098,952 1,268,748 446,4891994 520,917,221 3,419,299 10,221,752 2,361,834 NA 16,351,765 3,119,312 1,904,5191995 1,767,609,278 197,689,693 3,280,481 12,419,886 NA 43,247,883 2,549,370 602,5941996 1,507,370,682 70,947,053 4,861,265 8,660,874 NA 9,265,826 8,542,922 2,369,2551997 316,969,390 25,778,062 48,899,715 48,283,152 NA 24,445,056 1,800,711 1,101,1181998 530,017,006 56,622,648 44,730,447 33,280,806 NA 4,026,783 4,971,621 735,3011999 34,498,141 483,595 14,395,648 19,324,314 NA 11,379,446 1,932,894 464,1252000 619,863,003 16,496,664 882,086 809,127 NA 12,306,502 18,525,824 325,0952001 150,613,190 4,868,686 4,025,648 1,251,898 NA 4,062,977 6,869,977 4,215,6422002 280,852,511 3,704,444 14,464,446 5,164,308 NA 3,468,890 4,698,000 1,299,3932003 314,571,725 2,790,425 6,027,864 5,364,766 NA 1,045,853 7,032,420 2,114,9302004 70,227,928 10,894,804 613,682 176,011 NA 4,722,708 5,231,113 1,550,0522005 85,750,499 2,782,044 1,402,677 17,566,121 NA 9,860,824 14,966,375 950,164

(a) Data are not reported for entrainment of Atlantic Herring eggs, as this species is a riverine spawner

Source: Entergy 2006b. 

NUREG-1437, Supplement 29 4-20 July 2007

Environmental Impacts of Operation
Environmental Impacts of Operation

July 2007 4-21 NUREG-1437, Supplement 29

For winter flounder, larval abundance in 2005 was slightly lower than the 1981 to 2004 time

series data (Normandeau 2006a), while the number of eggs entrained in 2005 was almost |

identical to that entrained in 2004 but significantly less than the quantities entrained in 2003 and

in the 1991 to 2000 time series average (Normandeau 2006a). |

In addition to ichthyoplankton, periodically American lobster larvae are also entrained at PNPS. 

In 2005, 32 lobster larvae were found in the entrainment samples. This is the highest number of

lobster larvae collected in a single year. In fact, up until 2005, only 46 larvae had been

collected at PNPS since monitoring began in 1974 (Normandeau 2006a). Apparent causes of |

the high entrainment for lobsters in 2005 are unclear, but could be due to the implementation of

a security zone around the plant and, hence, a reduction in lobster fishing pressure

(Normandeau 2006a). |

4.1.1.3 Assessment of Entrainment Impact 

The staff reviewed the PNPS ER, visited the site, consulted with Federal and State resource |

agencies, reviewed the applicant’s existing NPDES permit and existing literature related to fish |

and shellfish populations of Cape Cod Bay, and considered public comments with particular |

regard to entrainment studies conducted at the PNPS. NRC staff also consulted with Federal |

and State resource agencies that issue permits required for operation of PNPS (EPA,

Massachusetts Coastal Zone Management Office), or that have responsibility for biological

resources potentially affected by operation of PNPS (MDMF, National Marine Fisheries Service

[NMFS]) (Earth Tech 2006a; Earth Tech 2006b). 

The 316 demonstration report concludes that impingement and entrainment have caused no

adverse impacts to any representative important species population or to the integrity of the

aquatic ecosystem of Cape Cod Bay (ENSR 2000). However, EPA Region 1, in discussions

with the NRC staff, indicated that there was some debate over the conclusions of the report.

The 316 demonstration report evaluated impacts on essential fish habitat (EFH) and

representative important species including: 

• Irish moss (Chondrus crispus)

• American lobster (Homarus americanus)

• Winter flounder (Pseudopleuronectes

americanus)

• Rainbow smelt (Osmerus mordax)

• Cunner (Tautogolabrus adspersus)

• Alewife (Alosa pseudoharenqus)

• Atlantic silverside (Menidia menidia)

• Atlantic cod (Gadus morhua)

• Haddock (Melanogrammus aeglefinus)

• Pollock (Pollachius virens)

• Silver hake / whiting (Merluccius bilinearis)

• Red hake (Urophycis chuss)

• White hake (Urophycis tenuis)

• Yellowtail flounder (Pleuronectes ferruginea)

• Windowpane flounder (Scopthalmus

aquosus)

• American plaice (Hippoglossoides

platessoides)

• Ocean pout (Macrozoarces americanus)

• Atlantic halibut (Hippoglossus hippoglossus)
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-22 July 2007

• Atlantic sea scallop (Placopecten

magellanicus) 

C Atlantic herring (Clupea harengus)

C Monkfish (Lophius americanus)

C Bluefish (Pomatomus salatrix)

C Longfin squid (Loligo pealei)

C Shortfin squid (Illex illecbrosus)

C Atlantic butterfish (Peprilus triacanthus)

C Atlantic mackerel (Scomber scombrus)

C Summer flounder (Paralicthys dentatus)

C Scup (Stenotomus chrysops)

C Surf clam (Spisula solidissima)

C Spiny dogfish (Squalus acanthias)

C Bluefin tuna (Thunnus thynnus)

| With the exception of the winter flounder, ENSR (2000) estimated that losses due to

| entrainment at PNPS were less than 1 percent of the adult population in western Cape Cod Bay

| of five of these species: cunner, Atlantic mackerel, rainbow smelt, alewife and Atlantic

| silverside. ENSR (2000) estimated that entrainment effects on the remaining species also were

| minor. Since the publication of the 316 report in 2000, Entergy has continued to evaluate in

detail the effects of entrainment and impingement on six species: cunner, Atlantic mackerel,

| Atlantic menhaden, Atlantic herring, Atlantic cod, and winter flounder. Winter flounder, herring,

| and cod were selected because they are commercially and recreationally important in the area,

| while cunner, mackerel, and menhaden were selected because they historically have had high

| entrainment and impingement rates (Normandeau 2006a).

|

Entergy commonly uses the equivalent adult procedure (Goodyear 1978) to evaluate effects of

entrainment and impingement on local fish populations. This methodology applies estimated

survival rates to eggs and larvae that have been lost to entrainment and impingement to

| calculate the number of adult fish that might have been recruited to the local populations

| (Normandeau 2006a). Many assumptions are included in the equivalent adult procedure, and

| uncertainty is inherent in the process. For example, it is conservatively assumed that no eggs

| or larvae survive entrainment, that the fish population is in equilibrium (each female replaced 

| only herself and one male), and that no density-dependent compensation (increased survival

| and fecundity) occurs among unaffected individuals as a result of reduced competition

| (Normandeau 2006a). 

|

| For cunner, the numbers of equivalent adults lost to entrainment have been well below the

| mean for the 1980 to 2004 time series over the last four years and have declined in comparison

| to historical data (Normandeau 2006a). There is no management of the cunner fishery;

| consequently, landings data and stock status information are limited. Based on an analysis by

| Normandeau (2006a), cunner appear to be abundant in the vicinity of PNPS, and the loss to the

| local adult population due to entrainment by PNPS appears to be less than 1 percent. 

Atlantic mackerel equivalent adult numbers tend to follow the same trend as cunner

| (Normandeau 2006a). The loss to the local population due to entrainment and impingement by

| PNPS appears to be less than 1 percent (Normandeau 2006a). As of the 1999 stock

assessment, the spawning stock biomass (SSB) was believed to be at historically high levels
Environmental Impacts of Operation

July 2007 4-23 NUREG-1437, Supplement 29

(Normandeau 2006a). Based on the 2006 stock assessment, the northwest Atlantic mackerel |

stock is considered to be healthy (NEFSC 2006).

For Atlantic menhaden, there is significant variability in year-to-year numbers of eggs and larvae |

entrained (Normandeau 2006a). The Atlantic menhaden stock is considered to be healthy |

(ASMFC 2006a), and based on the 2005 Pilgrim monitoring data, the loss to the stock due to |

entrainment by PNPS appears to be less than 1 percent (Normandeau 2006a). |

The number of Atlantic herring equivalent adults lost to entrainment increased in 2005, |

exceeding the 25-year mean for the first time since 2000 (Normandeau 2006a). The Atlantic |

herring stock is considered to be healthy (ASMFC 2006a), and based on the 2005 Pilgrim |

monitoring data, the loss to the stock due to entrainment by PNPS appears to be significantly

less than 1 percent (Normandeau 2006a). |

Atlantic cod entrainment losses of equivalent adults in recent years (2001 to 2005) have been |

above the 25-year mean (Normandeau 2006a). Less recent stock assessments have indicated |

that the stock is depressed (Fahay et. al. 1999). However, Normandeau (2006a) concluded that |

the numbers of equivalent adults entrained at PNPS are low relative to recent landings

information for the Cape Cod Bay area. 

The winter flounder is a species of significant commercial and recreational value in the area and

has been intensively studied at PNPS. The 316 demonstration report (ENSR 2000) utilized

three procedures to evaluate the significance of entrainment losses on the local population: the |

Stone and Webster model, equivalent adult analysis, and the Risk Analysis Management

Alternative System (RAMAS) model. ENSR (2000) concluded that the conditional mortality from |

entrainment is uncertain but is less than 5 percent.

The Stone and Webster Model is a life cycle model used to evaluate potential PNPS effects on |

the winter flounder population in Cape Cod Bay. The model was used to simulate the |

population over a 40-year period under two scenarios: without the presence of PNPS, and with |

the presence of PNPS and its associated mortality due to entrainment and impingement. Based |

on comparison of the results, a 3 percent reduction in the adult winter flounder population in |

Cape Cod Bay was conservatively predicted (ENSR 2000). |

Figure 4-1 presents a summary of the numbers of equivalent adult winter flounder estimated to |

have been removed from the local stock over the last 25 years as a result of entrainment and |

impingement of eggs and larvae at PNPS. As can be seen from this figure, the numbers of |

equivalent adult winter flounder potentially removed from the local stock over the last two years |

are the second and third highest levels observed at PNPS. This contrasts with near record low

levels observed in 1999, 2000, and 2003. 
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-24 July 2007

Comparison of the equivalent adult numbers to the area-swept population estimates may

| provide an indication of effects on the local stock of winter flounder. Normandeau (2006a)

compared recent estimates of the loss of age 3 adults (age at which flounder become sexually

| mature) using the equivalent adult method to the total numbers of adult winter flounder in the

| area derived from the area-swept population estimates. As can be seen from Table 4-5, the

| predicted losses from the local stock due to entrainment and impingement at PNPS as a

| percentage of the estimated number of adults range from less than 0.5 percent to approximately

12 percent. 

An estimate of the potential loss of the 2003 year class due to entrainment and impingement will

| be estimated upon conducting the 2006 area-swept surveys, results of which were not available

| to the NRC staff at the time of the preparation of this SEIS. However, an estimate of the

potential losses can be derived by comparing the equivalent adult loss to the average of the

| numbers estimated by the area-swept surveys. Based on the 2005 entrainment and

| impingement data, there was a loss of 29,852 equivalent adult fish. Comparison of this estimate

to the average area-swept estimate for the last three years indicates a 16.4 percent take of the

| local population (Normandeau 2006a). 

| The loss estimates presented in Table 4-5 contrast with other estimates. For instance the

RAMAS model was also run as an alternative means of assessing effects to the local winter

| flounder population from entrainment and impingement. This analysis indicated that stock

reductions ranging from 2.3 to 5.2 percent might occur as a result of entrainment at PNPS

| (Normandeau 2006a).

Based on the larval transport studies described in Section 4.1.1.1, the amount of winter flounder

| larvae (based on all four larval stages combined) in northwestern Cape Cod Bay entrained by

PNPS is estimated at less than 1 percent of the net larval transport (ENSR and MRI 2005). 

Estimates of loss due to entrainment of stages 3 and 4 larvae have ranged up to 20 percent of

the net larval transport for those stages; however, there were several methodological difficulties,

as discussed in Section 4.1.1.1, which impart a high degree of uncertainty to these estimates

(ENSR and MRI 2005).
Environmental Impacts of Operation

July 2007 4-25 NUREG-1437, Supplement 29

Figure 4-1. Equivalent Adult Summary of Entrained and Impinged Winter 

Flounder from PNPS (Source: Normandeau 2006a) |

Table 4-5. Equivalent Adult Losses of Winter Flounder |

Year Predicted Numbers of Year Trawl Estimated Numbers Predicted |

Entrainment/ Age 3 Adults Lost Data of Adults in Age 3 Adults Lost |

Impingement Due to Collected Western Cape Cod as Percent of |

Data Collected Entrainment and |

Impingement* |

Bay** Estimated Number

of Adults |

1997 27,398 2000 464,176 5.9 |

1998 48,483 2001 400,182 12.1 |

1999 1,615 2002 476,263 0.3 |

2000 2,275 2003 262,604 0.9 |

2001 16,883 2004 157,532 10.7 |

2002 12,450 2005 126,117 9.9 |

 *Numbers of age 3 adults predicted based on the equivalent adult approach. Values shown are |

averages of results from the different procedures used to estimate equivalent adult numbers. |

**Estimated abundance of adults (age 3 and older and >280 mm total length) based on area-swept |

surveys by trawl in spring. |

Source of values: Adapted from Normandeau 2006a |
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-26 July 2007

Geographical range of the local winter flounder population is a key consideration in evaluating

the extent of impacts of entrainment at PNPS. Winter flounder in the PNPS area are managed

as the Gulf of Maine stock complex; however, more localized populations may exist, as adults

| express a high degree of spawning site fidelity, and spawning populations can be highly

localized (Nitschke et al. 2000, Lawton et al. 1999a, Lawton et al. 2000b). 

| According to the Atlantic States Marine Fisheries Commission (ASMFC) (2006a), the Gulf of

Maine winter flounder population is healthy. The 2003 Regional Stock Assessment noted that

recruitment to the stock has been near or above average since 1995 (NEFSC 2003). The 2005

stock assessment (NEFSC 2005) concluded that the stock is not overfished and overfishing is

not currently occurring, but also noted that there is considerable uncertainty in the current

estimates of fish mortality and SSB. This contrasts with data collected by MDMF and the NMFS

that indicate a sharp decline in stock abundance over the last several years (as measured by

| catch per unit effort) (Figures 2-9 and 2-10).

| The area-swept data for winter flounder (MRI 2005a), which are collected in northwestern Cape

Cod Bay in the waters surrounding PNPS, can provide an estimate of the status of local stocks. 

As can be seen from Figure 2-9, the annual abundance estimates have steadily decreased from

2002. These data also track the NMFS and MDMF data noted above, perhaps suggesting that

| the decline observed in Cape Cod Bay is not exclusive to the PNPS area 

(MRI 2005a).

An independent analysis conducted by Szal (2005), a biologist with MDEP, calculated the

entrainment loss of adult winter flounder, using age 4 equivalent adults and local population

estimates from the area-swept surveys. The average loss of age 4 equivalent adults over the

10-year period ending in 2004 was approximately 6 percent. The maximum loss of age 4

equivalent adults over this time period was observed in 2004 and estimated to be 20 percent

(Szal 2005).

Stocks of rainbow smelt in Massachusetts are significantly depressed compared to historical

levels (Chase 2006). However, entrainment of rainbow smelt eggs is not expected to be a

| significant concern at PNPS because rainbow smelt are riverine spawners, and eggs reaching

| the bay and PNPS would not be viable due to ambient salinity levels surrounding PNPS that are

| greater than lethal tolerance levels of the eggs (ENSR 2000). Based on an analysis of data

from the 1970s, entrainment of smelt larvae at PNPS would account for significantly less than 1

percent of the local smelt population (ENSR 2000). Even considering recent declines in the

| Jones River population, the impacts of entrainment on rainbow smelt populations would likely be

minimal (ENSR 2000). 
Environmental Impacts of Operation

July 2007 4-27 NUREG-1437, Supplement 29

4.1.1.4 Summary of Entrainment Impacts

Due to the lack of recent information describing the status of several local populations, it is |

difficult to quantify entrainment impacts. Effects of entrainment on winter flounder likely affect

only the local population. Historical data have indicated no clear correlation between

entrainment rates at PNPS and Gulf of Maine stock trends. However, available data indicate

that there are high levels of larval entrainment at PNPS, with particular concern being the high

larval entrainment rates for late-stage larvae (stages 3 and 4). Based on the decline of the local

population, the percentage take of the local population, and the considerable uncertainties in

the stock status, the staff’s conclusion is that continued operation of PNPS would have a

MODERATE impact on the local winter flounder population due to entrainment over the course

of the license renewal term. However, the staff has concluded that continued operation of

PNPS during the renewal term would have a SMALL to MODERATE impact on the overall Gulf

of Maine winter flounder stock as well as on all other marine aquatic resources due to

entrainment. 

Due to the potential for impacts on marine aquatic resources in Cape Cod Bay over the course

of the license renewal term, additional mitigation measures may further reduce entrainment

impacts. Section 4.1.4 of this SEIS discusses the potential mitigation measures that may be

applicable to PNPS. Additionally, EPA’s evaluation of the PNPS NPDES permit renewal |

application would likely address any applicable site-specific mitigation measure that may reduce |

entrainment impacts. 

4.1.2 Impingement of Fish and Shellfish

For plants with once-through cooling systems, such as PNPS, impingement of fish and shellfish

on traveling screens is considered a Category 2 issue, thus requiring a site-specific assessment |

for license renewal review. To assess impingement impacts the staff independently reviewed |

the PNPS ER, visited the site, consulted with Federal and State resource agencies, reviewed

the applicant's existing NPDES permit and existing literature related to fish and shellfish

populations of Cape Cod Bay, and considered public comments. |

Section 316(b) of the Clean Water Act of 1977 (CWA), common name of the Federal Water |

Pollution Control Act, requires that the location, design, construction, and capacity of cooling |

water intake structures reflect the best technology available for minimizing adverse |

environmental impacts (33 U.S.C. 1326). Entrainment of fish and shellfish into the cooling water |

system is a potential adverse environmental impact that can be minimized by the use of best |

technology available. Licensees may be required as part of the NPDES permit renewal to alter |

the intake structure, redesign the cooling system, modify facility operation, or take other |

mitigative measures. Licensees must comply with Section 316(b) of the CWA. However, EPA’s |

316(b) Phase II Rule has been suspended and compliance with the rule is based on EPA’s best |
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-28 July 2007

| professional judgment. Entergy is currently conducting a Comprehensive Demonstration Study

| (CDS) as part of the 316(b) evaluation. This study is due to the EPA by January 2008. 

4.1.2.1 Impingement Monitoring

Impingement sampling consists of monitoring three scheduled screen-wash periods each week

throughout the year. The screens are not continuously turned. However, in general they are

turned for 8 hours prior to conducting the impingement sampling. If the screens were turned

prior to sampling, a 60-minute sample is obtained. If the screens were not turned prior to arrival

| of the sampling crew, a 30-minute sample is scheduled (Normandeau 2006b). While the

screens are turning, low- and high-pressure sprays continuously rinse debris and organisms off

the screens into a sluiceway, which is sampled by inserting a stainless steel collection basket

into the sluiceway entrance adjacent to the traveling screens. Fish are considered to be alive if

| opercular movement is noted and there are no obvious signs of injury. However, Entergy has

| not conducted any latent mortality studies. Living fauna are noted and measured for total length

and then returned to the sluiceway. Dead or injured specimens are preserved for later analysis

| in the lab (Normandeau 2006b).

After being rinsed off of the screens and being washed into the east sluiceway, all debris and

organisms are diverted via a seamless concrete sluiceway into the intake embayment,

approximately 300 feet (ft) from the screens. A re-impingement study was attempted in the

early 1980s, but due to methodological difficulties, the study was never completed. During

storm events, a portion or all of the flow from the screens is diverted to the discharge canal via

the west sluiceway.

Impingement rates are calculated by dividing the number of individuals of a given species that

are collected by the number of hours in the collection period. If impingement rates of greater

than 20 fish per hour are noted, additional samples are collected. If impingement rates continue

to be elevated after the second sampling period then the plant operator is notified and advised

| to leave the screens operating until further notice (Normandeau 2006b).

Since 1980, a total of 73 species of fish has been collected in the impingement sampling 

| (Table 4-3) (Normandeau 2006b). In 2005, impingement samples were collected for a total of

440 hours spread out over the entire year. Over 300,000 fish consisting of 38 species were

| collected (Normandeau 2006b). Atlantic menhaden, Atlantic silverside (Menidia menidia),

rainbow smelt, winter flounder, and Atlantic tomcod (Microgadus tomcod) accounted for 98

| percent of the annual total of impinged fish (Normandeau 2006b). Atlantic menhaden were the

most dominant at 97 percent, followed by Atlantic silverside (3.8 percent), rainbow smelt (1.3

| percent), and winter flounder (1.2 percent) (Normandeau 2006b). Approximately 23,000

invertebrates representing 18 taxa were also collected. Sevenspine bay shrimp (Crangon

septemspinosa) was the dominant taxon, followed by cancer crabs (Cancer spp.) and then
Environmental Impacts of Operation

July 2007 4-29 NUREG-1437, Supplement 29

American lobster (Normandeau 2006b). |

Atlantic menhaden impingement rates in 2005 were 25 times greater than the historical mean |

(Table 4-6). Impingement rates for Atlantic silversides in 2005 were similar to the historical |

mean. Winter flounder and rainbow smelt were impinged at rates of almost 3 times and 2 times,

respectively, their historical means (Table 4-6). Impingement rates for winter flounder have |

been steadily increasing since the late 1990s (Normandeau 2006b). There was a sharp drop in |

rainbow smelt impingement rates in 2000, but other than that, impingement rates have

remained at relatively consistent levels since the 1990s. Impingement data for the Atlantic

tomcod in 2005 were approximately six times greater than the historical mean and is the second |

highest impingement rate in the history of PNPS (Normandeau 2006b). |

In 2005, there were 19 impingement events (greater than 20 fish impinged per hour). In the |

majority of these events, Atlantic menhaden and Atlantic silversides were the primary species

impinged (Normandeau 2006b). |

Generally, the smaller the amount of time an organism is impinged on a screen, the lower its |

probability of survival. In 2005, survival of impinged organisms was higher during the 60-minute |

samples than during the 30-minute samples. This trend is consistent with previous years

(Normandeau 2006b). Survival of the Atlantic menhaden was low during both the 60-minute |

samples (27 percent) and the 30-minute samples (18 percent). The Atlantic silverside had a

much greater difference in survival between the 60-minute samples and the 30-minute samples

(62 percent versus 15 percent). Winter flounder survival averaged 96 percent when collected

during the 60-minute samples, while survival was approximately 77 percent during the 30-

minute samples. There was also a significant difference for the rainbow smelt, with 53 percent

survival based on the 60-minute samples and no survival based on the 30-minute samples

(Normandeau 2006b). Survival for the Atlantic tomcod ranges from 35 percent for the 30- |

minute samples to 63 percent for the 60-minute samples. It is likely that the difference in |

survival rates between the 30 and 60-minute samples is due to the duration of screen rotation |

prior to initiation of sampling activities, as described earlier in this section. Lower impingement |

survival rates would be expected in the 30-minute samples as organisms may be impinged on |

the screen for a longer time period prior to being washed into the sluiceway. |

|

4.1.2.2 Assessment of Impingement Impact

To evaluate the impact of these impingement losses, the NRC staff conducted an independent

analysis and evaluated the conclusions of the 316 demonstration report (ENSR 2000), the |

PNPS ER (Entergy 2006a), and recent monitoring reports developed by Entergy in fulfillment of |

NPDES permit requirements. The 316 demonstration report (ENSR 2000) evaluated |
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-30 July 2007

|

Table 4-6. Annual Extrapolated Totals for Typical Dominants Found on the PNPS Intake Screens, 1980-2005. |

Source: Normandeau 2006b.
Environmental Impacts of Operation

July 2007 4-31 NUREG-1437, Supplement 29

impacts on representative important species and EFH. ENSR (2000) estimated that losses due |

to impingement from PNPS were less than 1 percent of the population for each of these |

species, with the exception of cunner and rainbow smelt. |

The 316 demonstration report also concluded that impingement caused no adverse impacts to |

any representative important species population or to the integrity of the aquatic ecosystem of

Cape Cod Bay (ENSR 2000). However, EPA Region 1, in discussions with NRC staff, indicated

that there was some debate over the conclusions of the report. 

The Atlantic menhaden and the Atlantic silverside have been the two most frequently impinged |

organisms at PNPS and have been consistently collected since PNPS went on line (Table 4-6). |

Atlantic menhaden were impinged in record numbers at PNPS in 2005, 25 times the long-term

average. In 2005, Atlantic silversides were impinged at a rate equal to the long-term mean. |

Menhaden travel in dense schools, and juveniles and adults are frequently attracted to intake

embayments and discharge canals. Other coastal New England power stations have observed |

several large year classes of Atlantic menhaden since 1999 (Normandeau 2006b). The Atlantic |

menhaden stock is considered to be healthy with stable stock size and high biomass. |

Information on the stock status for the Atlantic silverside is not available; however, it is a |

species with high levels of reproduction in near-coastal environments such as the area |

surrounding PNPS. |

Atlantic menhaden is considered to be a single unit stock that undergoes extensive seasonal |

migrations north and south along the east coast of the United States. Schools of large |

menhaden have been scarce in the New England region since the early 1990s. Summer 2005 |

was noteworthy because it was the first time in 12 years that adult menhaden were abundant |

north of Long Island Sound. Several New England states recorded significant menhaden-for- |

bait landings for the first time in over a decade. In the spring of 2005, the purse-seine bait |

fishery in Massachusetts landed the highest quantity of menhaden since 1995 (ASMFC 2006b). |

The historical maximum menhaden impingement rate at PNPS in 2005 coincided with this |

notable increase in menhaden landings in Massachusetts, and both phenomena appear to |

result from the presence of abundant numbers of menhaden in Massachusetts coastal waters in |

2005. |

|

Subsequent analyses indicate that the various sources of menhaden mortality have not resulted |

in observable effects on menhaden abundance in Massachusetts waters. An evaluation of the |

current status of the stock by the ASMFC concluded that the estimated Atlantic menhaden |

fishing mortality rate and population fecundity have values typically considered to indicate a |

healthy stock (ASMFC 2006b). The Atlantic menhaden stock status was classified as healthy, |

not overfished, and rebuilt as of December 2006 (ASMFC 2006c). Also in 2006, the Population |

Dynamics Branch of the NMFS reported significant catches of large menhaden in fish traps in |

Massachusetts by mid May, and purse-seine catches for bait were reported off Massachusetts |
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-32 July 2007

| in late May (NMFS 2007). These observations were considered noteworthy by NMFS because

| (1) 2006 was the second consecutive year in which adult menhaden were reported to be

| abundant in nearshore waters of southern New England and (2) May was relatively early in the

| calendar year for adult menhaden to occur in New England waters, especially north of Cape

| Cod (NMFS 2007). These lines of evidence indicate that the elevated numbers of menhaden

| impinged at PNPS in 2005 were in proportion to the regional increase in numbers and that the

| incremental mortality associated with impingement at PNPS has not contributed to a significant

| reduction in menhaden numbers locally or within the larger east coast population. 

|

| The Atlantic tomcod is also a species that has been collected consistently at PNPS since the

| plant first went on line, although it is typically impinged at rates much less than those observed

| for the Atlantic silverside and Atlantic menhaden (Table 4-6). However, in 2005, the

impingement rate for the Atlantic tomcod increased by approximately five times its long-term

| average (Table 4-6). Population data are not available to evaluate the potential effects of

| Atlantic tomcod impingement by PNPS; however, ENSR (2000) concluded that it is unlikely that

PNPS is having a significant effect on the Atlantic tomcod. 

In 2005, winter flounder were impinged at a rate approximately 2.5 times the long-term mean of

| 917 fish (Table 4-6). Over the last decade, the numbers of winter flounder impinged at PNPS

| have generally increased (Normandeau 2006b). With the exception of 2005, comparison of the

number of impinged fish to the number of fish estimated by the area-swept surveys indicates a

| loss to the local population of less than 1 percent. However, such a loss of winter flounder

| juveniles and adults through impingement may be contributing to population declines. 

For the cunner, impingement losses were estimated to be less than 3 percent; however, as

shown by Lawton et al. (2000a), population numbers in the vicinity of PNPS are high. 

For the rainbow smelt, ENSR (2000) estimated that there would be less than a 1 percent impact

to the local population from PNPS impingement, based on the 1980 spawning run, the most

| recent estimate of spawning stock size in the Jones River. Taking into account state-wide

declines in the stock and the lack of any recent information on the Jones River spawning run,

| ENSR (2000) estimated that impacts due to PNPS impingement could range up to 2.5 percent

| (ENSR 2000). However, the rainbow smelt impinged at PNPS also may have been spawned in

rivers or streams other than the Jones River, which is the principal spawning run in the

Plymouth area and the vicinity of PNPS. At least 12 rivers and streams between Boston Harbor

and the Cape Cod Canal have been reported to potentially support rainbow smelt spawning

runs (MDMF 2004). After the eggs hatch in the streams, the larvae drift downstream to

| estuaries. As larvae develop into juveniles and adults, the smelt move into waters of increasing

salinity, spending most of their time in nearshore waters, including lower estuaries, harbors, and

| bays. Smelt move into slightly deeper and cooler waters during summer (MDMF 2006). Thus,

populations from different spawning runs may mix in Cape Cod Bay, and the rainbow smelt
Environmental Impacts of Operation

July 2007 4-33 NUREG-1437, Supplement 29

present in the bay and impinged at PNPS may have been hatched in rivers or streams other |

than the Jones River. However, the proximity of PNPS to the Jones River makes this river the |

likely origin of a major proportion of the impinged rainbow smelt. The MDMF has recently |

initiated a sampling program to determine the population indices of rainbow smelt by monitoring

runs in four rivers, including the Jones River. Data collected to date indicate that the Jones

River population has a low degree of spawning activity. Recent data on population size are not

available, as only the first year’s data of a multi-year monitoring effort have been analyzed to

date (Chase 2006). Thus, considerable uncertainty exists regarding the potential impacts to

rainbow smelt populations in the area.

4.1.2.3 Summary of Impingement Impacts 

Due to the lack of recent information describing the status of several local populations, it is |

difficult to quantify impingement impacts. Effects of impingement on rainbow smelt likely affect

only the Jones River population. Based on the decline of that population, the uncertainty of the

stock’s status, impingement rates, and the low impingement survivability of rainbow smelt, the

staff’s conclusion is that continued operation of PNPS would have a MODERATE impact on the

Jones River population of rainbow smelt due to impingement over the course of the license |

renewal term. However, the staff has concluded continued operation of PNPS during the

renewal term would have SMALL to MODERATE impacts on other marine aquatic resources

due to impingement.

Due to the uncertainty associated with local population abundance estimates and potential

impingement impacts on the local populations, implementation of mitigation measures may

further reduce impingement impacts. A discussion of potentially applicable mitigation measures

is presented in Section 4.1.4. Additionally, EPA’s evaluation of the PNPS NPDES permit |

renewal application would likely address any applicable site-specific mitigation measures that |

may reduce impingement impacts.

4.1.3 Heat Shock

For plants with once-through cooling systems, the effects of heat shock are listed as a Category

2 issue and require plant-specific evaluation for license renewal review. The NRC identified

impacts on fish and shellfish resources resulting from heat shock as a Category 2 issue

because of continuing concerns about thermal discharge effects and the possible need to

modify thermal discharges in the future in response to changing environmental conditions 

(NRC 1996). Information considered includes: (1) the type of cooling system (whether

once-through or closed-cycle) and (2) evidence of a CWA Section 316(a) variance or equivalent

State documentation. To perform this evaluation, the staff reviewed the ER, visited the PNPS

site, reviewed the facility's 316 demonstration report (ENSR 2000), reviewed the applicant's

NPDES permit, and considered public comments. |
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-34 July 2007

Section 316(a) of the CWA establishes a process by which a discharger can demonstrate that

the established thermal discharge limitations are more stringent than necessary to protect

balanced, indigenous populations of fish and wildlife and obtain facility-specific thermal

discharge limits (33 USC 1326). The applicant has provided EPA with Section 316(a)

demonstrations that address compliance with the thermal effluent limitations of the NPDES

permit and environmental impacts of the thermal discharge. The NPDES permit (EPA 1994)

states that "the thermal plumes from the station: (1) shall not deleteriously interfere with the

natural movements, reproductive cycles, or migratory pathways of the indigenous populations

within the water body segment; and (2) shall have minimal contact with the surrounding

shorelines.” In order to obtain information to assess compliance with these requirements, there

has been an extensive program of monitoring of the coastal environmental near the PNPS site

since the beginning of design/construction in the late 1960s (EG&G 1995).

A combined Section 316(a) and (b) demonstration report for PNPS was submitted to EPA

Region 1 in 1975 and 1977 by the Boston Edison Company (Stone & Webster 1975, 1977), was

accepted by EPA, and was used in determining facility-specific NPDES discharge temperature

limits (Entergy 2006a). That initial Section 316 demonstration was based on engineering,

hydrological, and ecological data from a 3-year pre-operational period 

| (1969 to 1972) and a 5-year post-operational period (1972 to 1976). The report predicted that

station operations would not result in long-term thermal impacts to the aquatic environment

(ENSR 2000). Based on that report and ongoing ecological monitoring programs, EPA has

| issued and renewed the NPDES permit for PNPS for over 30 years and has determined that

thermal discharges from PNPS are sufficiently protective of the aquatic community of Cape Cod

Bay to satisfy alternative thermal effluent limitations under Section 316(a) of the CWA 

(ENSR 2000; Entergy 2006a).

In recent years, EPA Region 1 has required all NPDES permittees affected by Section 316 to

submit new 316(a) and (b) demonstrations. A new 316 demonstration report for PNPS was

prepared in 2000 (ENSR 2000), which updated the previous report based on approximately 25

years of additional engineering, hydrological, and biological data related to PNPS operations

and conditions in the aquatic environment of western Cape Cod Bay. EPA Region 1 currently is

reviewing an Entergy application for renewal of the NPDES permit for PNPS, including the

newest combined 316 demonstration report (Entergy 2006a). In the interim, Entergy has

continued biological monitoring. The Thermal Discharge Fish Surveillance Program involves

periodic visual inspections of the discharge canal during times of fish migration in order to

determine the presence of fish and their condition.

Previous investigations to characterize the extent of the thermal plume included studies that

focused on collecting ambient temperature measurements and studies that used the measured

temperature data to develop predictive models of temperature changes in the plume under a

variety of operating and ambient conditions. These investigations have characterized the
Environmental Impacts of Operation

July 2007 4-35 NUREG-1437, Supplement 29

dimensions of the thermal plume and assessed biological impacts potentially associated with

the plume. Two of the most detailed thermal investigations at PNPS were a 1974 study by the

Massachusetts Institute of Technology, which focused on characterizing the plume based on

surface water temperature measurements (ENSR 2000), and a 1994 study by EG&G (1995), 

which focused on bottom water temperature measurements to characterize the benthic thermal

plume and validate mathematical models to predict bottom plume characteristics (ENSR 2000).

The 1974 study, which included one-day temperature surveys in July, August, and November

1973, found that the thermal plume is largest during high tide, and that during high tide the

plume is detached from the bottom and is essentially confined to the surface layer. The depth

of the plume was found to be relatively shallow, with depths ranging from 3 to 8 ft at high tide. 

The temperature difference (delta T) between ambient water and the thermal plume was found

to cover a larger area when ambient temperatures were higher. For example, water with a delta |

T of 3EC (37.4EF) covered approximately 216 acres (ac) in August when the ambient

temperature was 17.0EC (62.6EF), but only 14 ac in November when the ambient temperature |

was 8.5EC (47.3EF). The area of the plume also was found to decrease rapidly with increasing |

depth, as expected due to the buoyancy of the plume. Throughout the tidal cycle, the smallest

surface areas with elevated temperatures occurred between low water slack tide and peak flood

tide, and the largest areas occurred between high water slack tide and peak ebb tide (ENSR

2000). 

The 1994 study (EG&G 1995) measured the bottom temperature patterns based on time series

measurements at 59 locations in the immediate vicinity of the PNPS discharge. The results of

this investigation were consistent with the 1974 study of the surface plume: the plume extended

through the water column to the bottom during periods of low tide but was mainly confined to the

surface layer during high tide. At the bottom, similar to the surface, the smallest temperature |

increment measured (1EC or 33.8EF) covered the largest area (up to 1.2 ac), and water with

higher temperatures relative to ambient covered much smaller areas. For example, the highest |

delta T measured, 9EC (48.2EF), covered less than 0.13 ac of the bottom (ENSR 2000, EG&G

1995).

At low tide, the turbulent discharge plume is well mixed vertically as it leaves the canal, due in

part to the significant downward momentum of the discharge as it spills from the mouth of the

discharge canal. The plume remains in contact with the bottom at low tide for up to several

hundred meters offshore. At the surface, the plume spreads by mixing with the ambient water,

while at the bottom the core temperature of the plume drops and its width narrows with distance

offshore. As a result, elevated temperatures are present at low tide over a limited area of the

bottom near the discharge canal (EG&G 1995). At high tide, the discharge has a much lower

velocity and no downward momentum. As a result, the thermal discharge plume separates from

the bottom almost immediately upon leaving the discharge canal (EG&G 1995).
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-36 July 2007

During the measurement period (26 to 29 August 1994) of the benthic thermal plume study,

conditions were relatively calm, warm, and favorable for upwelling. Ambient bottom

| temperatures were relatively cold (16 to 17EC or 60.8 to 62.6EF), and the currents were weak

and dominated by tidal fluctuations. Under these conditions, the areas of the sea floor in

contact with elevated temperatures due to the heated discharge water were relatively small

(EG&G 1995). The conclusions of the 1995 report (EG&G 1995) included the following:

• The discharge plume is in contact with the bottom of the bay for significant distances from

shore only during the low tide half of the tidal cycle (i.e., when the tide is below mean sea

level). Consequently, benthic organisms are exposed to alternating periods of ambient and

elevated water temperatures.

• The maximum extent of the area of the bottom contacted by the plume and the highest

temperatures occur at slack water around low tide.

• The plume begins to expand outward along the bottom about three hours before low tide,

reaches 75 percent of its maximum area by about one hour before low tide, and declines

rapidly to less than 50 percent of maximum area about one hour after low tide.

• The maximum offshore extent of the benthic thermal plume at low tide, based on the area of

| 1EC (34EF) temperature elevation, did not exceed 170 m (558 ft) from the mouth of the

discharge canal, and its width did not exceed 40 m (131 ft) at a distance of 80 m (262 ft)

offshore.

| • The maximum bottom area covered by the 1EC (33.8EF) temperature elevation was about

1.2 ac, and higher temperatures were restricted to smaller areas. The smaller areas of

higher temperatures approximately coincide with the areas with denuded or stunted benthic

macroalgae (i.e., Irish moss).

• During high tide, there was no discernible temperature increase at any location, even within

50 m of the mouth of the discharge canal.

Because the benthic thermal plume study involved measurements taken over a short period of

time and the temperatures and extent of the plume were strongly affected by ambient

temperatures, the report (EG&G 1995) also considered the potential for more extreme thermal

plume characteristics under worst case conditions. It concluded that extreme bottom

temperatures and plume areas could result from a prolonged period of unusually warm weather,

spring tide conditions in which the lowest water level can be nearly 1 m (3 ft) below mean water

level (MLW), and conditions favorable for downwelling could be produced by warm winds from

the north or northeast in summer. The combination of these conditions potentially could result

| in peak discharge temperatures in excess of 38EC (100.4EF). Given the uncertainty in the area
Environmental Impacts of Operation

July 2007 4-37 NUREG-1437, Supplement 29

measurements of the study, it was estimated that these conditions potentially could result in the

thermal plume contacting the bottom over an area about four to seven times the area measured

in the study (EG&G 1995).

An additional source of heated water discharge at PNPS is backwashing operations. Thermal

backwashing is a commonly used method for control of biofouling in the condenser tubes and

intake structures of power plants. Condenser tubes at PNPS are cleaned by backwashing on a

1- to 2-week interval, depending on the degree of biofouling. Because the plant electrical

generation must be reduced during backwashing, the procedure usually is conducted during

off-peak hours. The method involves reversing the flow of heated water so that organisms

fouling the condenser tubes and intake structure are killed by the elevated temperatures. The

process results in the flow of heated water out of the intake structure and into the intake

embayment. The thermal backwashing process generally occurs for approximately 45 to 60

minutes and produces elevated water temperatures averaging approximately 37.8EC (100EF). |

A thermal survey to determine the effects of backwashing operations at PNPS found that the

procedure caused a relatively thin thermal plume, averaging 3 to 5 ft in depth, that spread

rapidly from the intake structure across the western end of the intake embayment and along the

outer breakwater. The plume completely dissipated within a few hours (Normandeau 1977). |

The biological impacts of the PNPS thermal discharge have been evaluated by several

monitoring programs encompassing both pre-operational and post-operational periods. These |

programs have included fish, benthic invertebrates, and benthic microalgae monitoring. Fish |

monitoring programs have included methods such as bottom trawling to sample demersal fish

populations inhabiting inshore bottom waters, haul seining to sample inshore fish populations,

and gill netting to sample pelagic fish inhabiting the water column of the bay. In complex habitat

areas unsuitable for survey with sampling equipment, visual transects were surveyed by divers

in order to assess habitat-seeking fish species such as the tautog and cunner. Recreational

creel surveys were used to assess the sport fishery in the vicinity of PNPS (ENSR 2000). 

Heat shock to fish may occur when the water temperature meets or exceeds the thermal

tolerance of fish species; duration of exposure to high water temperature is also a factor

contributing to heat shock. Fish thermoregulate behaviorally by avoiding extreme temperatures

and seeking optimal temperatures (Beyers and Rice 2002). Therefore, fish in the bay typically

can avoid adverse effects from the thermal plume. The fish monitoring results indicate that the

thermal plume excludes several fish species from a relatively small area of habitat near the

discharge. However, fish mortality resulting from the thermal plume has been rare. Of the

notable fish mortality incidents recorded since PNPS began operation, only two were

considered to have been caused by thermal stress (heat shock) from exposure to high

temperatures in the plume. Approximately 3000 Atlantic menhaden were killed in August 1975,

and 2300 clupeids (schooling fish such as menhaden, sardines, and shad) died in August 1978. 

Such incidents have not been observed since 1978, confirming the rarity of fish mortality from
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-38 July 2007

heat shock at PNPS. In addition, finfish surveys conducted as part of the Thermal Discharge

Fish Surveillance Program, provided no evidence of adverse impacts on populations resulting

from the thermal plume. The area of the plume does not provide unique habitat, and adequate

habitat exists in the vicinity in Cape Cod Bay for fish displaced from the area of the plume

(ENSR 2000).

The benthic monitoring programs, which include several studies that have been performed in

the vicinity of PNPS since 1973, have focused on invertebrates and macroalgae, particularly the

Irish moss and the American lobster. Although benthic invertebrates and macroalgae are less

mobile than fish and many are sessile, the relatively small bottom area in contact with the

thermal plume at low tide minimizes the potential effects on populations. The episodes of high

bottom temperatures during low tide are likely to be partially responsible for the observed effects

on benthic organisms in the area near the discharge. The high velocity of the discharge at low

tide, which is strong enough to scour the bottom in the area near the discharge, also is likely to

affect the biota. At high tide, the plume has essentially no effect on benthic biota because the

heated discharge water does not displace the denser, colder, ambient water that remains near

the bottom (EG&G 1995). The results of the monitoring programs indicate that the thermal

plume has had relatively insignificant impacts on benthic species in the vicinity of PNPS. 

Visual observations of bottom transects conducted periodically from 1973 to 1998 to assess

Irish moss abundance and density found that the plume does not impact Irish moss coverage,

| except in small areas (ENSR 2000). Scouring due to water currents has been hypothesized to

cause greater stress to algal colonization than the elevated temperatures of the thermal plume. 

The observed denuded areas were attributed to scouring of the substrate, while areas where

growth of Irish moss was stunted or sparse were attributed to elevated temperatures 

(ENSR 2000). A multi-year (1981 to 1998) benthic assessment confirmed that the impacts on

Irish moss in the area of the thermal plume were minimal due to the relatively small area

affected (ENSR 2000). Impacts on other submerged aquatic vegetation, such as eelgrass

(Zostera marina), are expected to be smaller than those on Irish moss because there are no

| known areas in the immediate vicinity of PNPS covered by submerged aquatic vegetation other

than Irish moss.

Lobster populations were surveyed using research and commercial trap catch data through

1993. The data did not indicate measurable impacts from the thermal plume or the current

created by the effluent, and the program was discontinued. Based on the bottom temperature

| study results (EG&G 1995) and the thermal tolerance threshold (30.5EC or 86.9EF) of the

American lobster, it has been estimated that the loss of bottom habitat for the lobster during

periods of highest ambient water temperature (late summer to early fall) would be less than

about 0.12 ac.
Environmental Impacts of Operation

(b) It should be noted that the NRC cannot impose mitigation requirements on the applicant. The Atomic

Safety and Licensing Appeal Board, in the “Yellow Creek” case determined that EPA has sole

jurisdiction over the regulation of water quality with respect to the withdrawal and discharge of waters

for nuclear power stations, and that the NRC is prohibited from placing any restrictions or

requirements upon the licensees of those facilities with regards to water quality (Tennessee Valley

Authority [Yellow Creek Nuclear Plant, Units 1 and 2], ALAB-515, 8 NRC 702, 712-13 [1978]).

July 2007 4-39 NUREG-1437, Supplement 29

The staff has reviewed the available information, including that provided by the applicant, the

staff's site visit, the Commonwealth, the 316(a) demonstration, public comments received, and |

other public sources. The staff evaluated the potential impacts to aquatic resources due to heat

shock during continued operation during the renewal period. The staff concluded that the

potential impacts to marine resources due to heat shock during the renewal term would be

SMALL. 

During the course of the SEIS preparation, the staff identified potential mitigation measures (as |

described in Section 4) for the continued operation of PNPS during the license renewal period. |

However, the NRC staff concluded that none of the mitigation measures considered would be |

beneficial enough to reduce the significance of heat shock impacts to northwestern Cape Cod |

Bay. |

4.1.4 Potential Mitigation Measures

The staff has identified a variety of measures that could mitigate potential impacts resulting from

continued operation of the PNPS cooling water system.(b) These could include: 

• Automated chlorine monitoring

• Behavioral barriers

• Diversion devices

• Alternative intake systems 

• Alternative intake screen systems 

• Closed-cycle systems 

• Variable-speed pumps

• Cooling water flow adjustments

• Scheduled outages 

• Movement of fish return

• Habitat restoration

• Fish stocking

The NRC staff has not conducted an analysis of each of these measures relative to their

applicability to PNPS. This discussion is meant to provide only a brief overview of these |
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-40 July 2007

technologies. ENSR (2000) conducted an analysis of several of these technologies in the

316(b) demonstration report as required by Section 316 of the Clean Water Act. It is expected

that a more thorough analysis of the costs and benefits of these technologies would be included

as part of the 316(b) CDS currently being conducted by PNPS in support of the NPDES permit

| renewal. Additionally, EPA’s evaluation of the PNPS NPDES permit renewal application would

| likely address any applicable site-specific mitigation measures that may reduce entrainment and

| impingement impacts. It should be noted that EPA’s Phase II Rule should be considered

| suspended and compliance with the rule is based on EPA’s best professional judgment (EPA

| 2007).

An automated chlorine monitoring system would allow for continuous monitoring of chlorine

levels in the service water and/or condenser cooling water systems. This system could also

include a warning system to alert the PNPS operator whenever equipment malfunctions or when

chlorine concentrations deviate from preset limits.

Behavioral barriers are designed to cause fish to actively avoid entry into an area. These may

include sound, light, or air bubbles (Clay 1995). Sound barriers, which would be located at an

intake structure, would include low-frequency, infra-wave sound; pneumatic or mechanically

generated low-frequency sounds; or transducer-generated sound. Light barriers may emit

| either a constant or strobe-type beam of light. Air bubble curtains produce a continuous, dense

| chain of bubbles. These barrier types may deter some species of fish from entering the intake

structure. ENSR (2000) determined that, of the behavioral barriers evaluated, light barriers

| would be the most effective. According to ENSR (2000), several studies have shown that some

| fish species are repelled by light while others are attracted to light and can be guided away from

| areas to be avoided. Therefore, additional analysis of the potential effectiveness of light

| barriers in altering the behavior of the fish species of principal concern at PNPS would be

| needed. In addition, this technology is still considered to be experimental in nature and would

| be effective only on species and/or life stages that can actively respond to a stimulus 

| (i.e., not fish eggs, early larval life stages, or other planktonic organisms).

| Diversion devices, the most commonly used barriers, are physical structures, such as louvers,

barrier nets, or chains and cables, that are designed to guide fish away from a certain area,

such as the intake (Clay 1995). Louvers consist of a series of evenly spaced vertical slats that

create localized turbulence that fish can detect and actively avoid. Louvers typically have a

smaller spacing between the slats or bars than a standard trash rack. Barrier nets are simply

nets placed across an intake channel to prevent fish from access to an intake structure. The

design of a barrier net system has to finely balance the mesh size with the intake
Environmental Impacts of Operation

(c) EPA has suggested the Gunderboom fabric barrier as a potential mitigation measure. However,

NRC staff does not consider it as a viable option because it could present safety issues at intakes of

nuclear power plants.

July 2007 4-41 NUREG-1437, Supplement 29

requirements.(c) Chains or cables may be vertically hung in an intake structure to form a

physical and visible barrier to fish. However, similar to barrier nets, they may alter hydraulic

flow patterns in an intake (ENSR 2000). These types of structures also only affect those

organisms that can actively respond and would not impact entrainment or impingement of fish

eggs, larvae, or other planktonic organisms. Implementation of a biological surveillance |

program potentially could increase the effectiveness of barrier nets or other diversion devices. |

Such a program might identify the presence of large numbers of fish susceptible to being |

attracted to the thermal plume and discharge canal in time to allow the deployment of the most |

effective devices. |

|

Another type of mitigation measure may be an alternative intake system. An alternate surface

water intake system could include an offshore intake structure with a velocity cap. Vertical

placement of the offshore intake within the water column would be a major factor in

impingement and entrainment reduction. For example, ENSR (2000) conducted an evaluation

of this type of structure and determined that it would result in lower fish impingement but an

increased entrainment rate, especially for winter flounder as later stages of winter flounder

larvae (stages 3 and 4) tend to settle on the bottom substrate. The Seabrook Nuclear Power

Station utilizes a similar structure; however, the intake structure opening is at mid-depth. Based

on analysis by Salia et al. (1997), the losses due to entrainment at this facility are less than the

losses observed at other facilities. Groundwater could also be potentially used as a cooling

water source. According to EPA Region 1, the Keyspan North Point Station is currently

conducting a pilot study to evaluate the feasibility of using offshore groundwater extraction as a

cooling water source (Earth Tech 2006a).

Alternative intake screen systems may include Ristroph traveling screens, wedgewire screens, |

and/or fine-mesh screens. Ristroph screens are traveling screens fitted with fish buckets that

collect fish and lift them out of the water where they are gently sluiced away prior to debris

removal with a high-pressure spray. They have been approved as the best technology available |

in several states (Siemens 2006). Recent studies have shown survival of species exceeding 95 |

percent when using the Ristroph screen (EPRI 2006). Wedgewire screens are constructed of

wire of triangular cross sections so that the surface of the screen is smooth while the screen

openings widen inwards (ENSR 2000). This type of screen has been widely used for

hydropower diversion structures and has been shown to essentially eliminate impingement and

reduce larval entrainment (ENSR 2000). Fine-mesh screens are simply wire screens with the

mesh sized to minimize the ichthyoplankton entrainment. As reported in ENSR (2000), fine-
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-42 July 2007

| mesh screens have not been proven effective at reducing winter flounder larvae entrainment

losses. However, as with any screen, smaller mesh could result in more clogging and fouling

problems. 

Closed-cycle systems recycling cooling water in a closed piping system and utilize evaporative

cooling (such as is in a cooling tower or pond) as a means of dissipating the heat from the

condensers. Cooling towers could include wet, hybrid, or dry towers. Wet and hybrid cooling

towers would still require withdrawal of water from the bay to make up for water losses due to

blowdown and evaporation. However, the water withdrawal rate would be significantly lower

than the current once-through cooling system. A dry cooling tower utilizes ambient air to

dissipate heat, essentially acting as an automobile radiator (ENSR 2000). No make-up water is

required for this type of system as the steam is condensed in a closed cycle. However, this 

results in lower plant efficiency, thus requiring more fuel to produce the same amount of

electricity (ENSR 2000). 

Adjustments to the flow of cooling water through the plant is another type of mitigation strategy

that may be applicable to PNPS. This could include the use of variable speed pumps, cooling

water bypass flow, or rotating the existing screens more often or continuously. Variable-speed

pumps would reduce the intake flow during periods of peak entrainment or impingement. These

have been shown to be effective at reducing impingement and entrainment, but by reducing the

amount of cooling water moving through the system, power generating efficiency may decrease,

and the thermal plume may increase in size (ENSR 2000). Cooling water bypass flow would

reduce the cooling water flow rate through the condensers and add a corresponding amount of

bypass flow into the discharge canal (ENSR 2000). This alternative assumes that mortality in

| the discharge canal would be less than the condensers. It may reduce entrainment but not

impingement (ENSR 2000). 

| A mitigation strategy related to the cooling system would be to rotate the existing screens more

| often or on a continual basis. This would increase the survival of impinged organisms and may

| reduce impingement rates for some species, but it would have little impact on the impingement

rate or entrainment. 

Another potential mitigation strategy may be to schedule outages for performing regular

| inspection, maintenance, and refueling during the peak spawning seasons of specific fish

species such as the winter flounder, Atlantic menhaden, or rainbow smelt. 

Movement of the fish-return sluiceway discharge point may also provide some mitigation

| benefits as impinged fish are currently returned to the intake embayment where potentially

stunned, disoriented, or injured fish may not be able to actively avoid reentering the intake

structure. 
Environmental Impacts of Operation

July 2007 4-43 NUREG-1437, Supplement 29

Habitat restoration and fish stocking are also potential mitigation strategies for some species. |

However, these are compensatory measures as opposed to preventive measures, which are the

preferred mitigation strategies of Federal and State resource agencies. Several studies have

been funded by the applicant over the last few years to evaluate these options. A monitoring

program has been conducted by the applicant to assess the feasibility of improving the local

winter flounder stock by releasing young-of-the-year flounder into the Plymouth area. No

genetic studies have been conducted to determine if released hatchery fish breed with the wild

stock. Up to 25,000 fish, ranging from 26 to 34 mm (1 to 1.3 in.) in length have been released |

into Plymouth Harbor on an annual basis since 2001. Post-release sampling has indicated that

the released fish do survive and grow well when released earlier in the season (MRI 2006). 

The NRC staff has not found evidence indicating that this pilot program has substantially offset

impacts from continued operation of PNPS to the local winter flounder population. If expanded,

this stocking program may have a beneficial impact on the local winter flounder population.

The applicant also provided funding to the MDMF for a limited stocking of rainbow smelt eggs

and habitat enhancement in the Jones River as a means to enhance production of rainbow

smelt in this critical spawning ground (Lawton and Boardman 1999b). Stocking of young-of-theyear fish or eggs may be a proven mitigation strategy; however, both the EPA and MDMF have |

stated that re-stocking is not a preferred mitigation measure (Earth Tech 2006a). |

4.2 Transmission Lines

The two transmission lines that connect PNPS with the transmission system share a single

transmission line right-of-way (ROW) (Figure 2-6). For the purpose of this review, the |

transmission line ROW, which extends from the PNPS switchyard to the Snake Hill Road

substation, has a length of approximately 7.2 mi and occupies approximately 260 ac. Ongoing

surveillance and maintenance of PNPS transmission lines and ROW ensure continued

conformance to transmission line design standards. NSTAR Gas and Electric Corporation’s

(NSTAR’s) Vegetation Management Plan (NSTAR 2006) integrates the selective use of

herbicides approved in Massachusetts for use in sensitive areas with the use of mechanical

methods (i.e., selective removal of targeted vegetation by hand cutting or mowing) and

biological methods (i.e., encouraging development of stable communities of low-growing plants)

to restore and maintain habitat and control invasive species in the transmission line ROW. The

transmission line ROW maintenance practices employed by NSTAR, which comply with all

State and Federal regulations, encourage the development of stable communities of

low-growing native plants that provide wildlife habitat and support biodiversity while controlling

tall-growing trees and undesirable shrub species that would interfere with the operation of the

transmission lines. In addition, NSTAR follows a program developed in coordination with and

approved by the Natural Heritage and Endangered Species Program (NHESP) to protect rare

species (i.e., turtles) and priority habitats that may be present in the transmission line ROW
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-44 July 2007

(NSTAR 2006).

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to

transmission lines from PNPS are listed in Table 4-7. Entergy stated in its ER that it is not

aware of any new and significant information associated with the renewal of the PNPS OL. The

NRC staff has not identified any new and significant information during its independent review of

the Entergy ER, the site visit, the scoping process, or evaluation of other available information. 

Therefore, the staff concludes that there would be no impacts related to these issues beyond

those discussed in the GEIS. For all of those issues, the staff concluded in the 

GEIS that the impacts would be SMALL, and additional facility-specific mitigation measures are

not likely to be sufficiently beneficial to be warranted.

| Table 4-7. Category 1 Issues Applicable to the PNPS Transmission Lines 

During the Renewal Term

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

TERRESTRIAL RESOURCES

Power line right-of-way management (cutting and herbicide application) 4.5.6.1

Bird collisions with power lines 4.5.6.2

Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops,

honeybees, wildlife, livestock)

4.5.6.3

Floodplains and wetland on power line right-of-way 4.5.7

AIR QUALITY

Air quality effects of transmission lines 4.5.2

LAND USE

On-site land use 3.2

Power line right-of-way 4.5.3

A brief description of the staff's review and GEIS conclusions, as codified in Table B-1, for each

of these issues follows:

 C Power line right-of-way management (cutting and herbicide application). Based on

information in the GEIS, the Commission found that:
Environmental Impacts of Operation

July 2007 4-45 NUREG-1437, Supplement 29

The impacts of right-of-way maintenance on wildlife are expected to be of small

significance at all sites.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, consultation with the U.S. Fish

and Wildlife Service (FWS) and the Massachusetts Division of Fisheries and Wildlife

(MDFW), evaluation of other information, or consideration of public comments. Therefore, |

the staff concludes that there would be no impacts of power line right-of-way maintenance

on wildlife during the renewal term beyond those discussed in the GEIS.

 C Bird collisions with power lines. Based on information in the GEIS, the Commission

found that: 

Impacts are expected to be of small significance at all sites.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, consultation with the FWS and

MDFW, evaluation of other information, or consideration of public comments. Therefore, the |

staff concludes that there would be no impacts of bird collisions with power lines during the

renewal term beyond those discussed in the GEIS.

 C Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops,

honeybees, wildlife, livestock). Based on information in the GEIS, the Commission

found that:

No significant impacts of electromagnetic fields on terrestrial flora and fauna have

been identified. Such effects are not expected to be a problem during the license

renewal term.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, evaluation of other information, |

or consideration of public comments. Therefore, the staff concludes that there would be no |

impacts of electromagnetic fields on flora and fauna during the renewal term beyond those

discussed in the GEIS.

 C Floodplains and wetlands on power line right of way. Based on information in the GEIS, the

Commission found that:
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-46 July 2007

Periodic vegetation control is necessary in forested wetlands underneath power lines

and can be achieved with minimal damage to the wetland. No significant impact is

expected at any nuclear power plant during the license renewal term.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, consultation with the FWS and

| MDFW, evaluation of other information, or consideration of public comments. Therefore, the

staff concludes that there would be no impacts of power line ROW maintenance on

floodplains and wetlands during the renewal term beyond those discussed in the GEIS.

 C Air quality effects of transmission lines. Based on the information in the GEIS, the

Commission found that:

Production of ozone and oxides of nitrogen is insignificant and does not contribute

measurably to ambient levels of these gases.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, evaluation of other information,

| or consideration of public comments. Therefore, the staff concludes that there would be no

air quality impacts of transmission lines during the renewal term beyond those discussed in

the GEIS.

 C On-site land use. Based on the information in the GEIS, the Commission found that:

Projected on-site land use changes required during ... the renewal period would be a

small fraction of any nuclear power plant site and would involve land that is

controlled by the applicant.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, evaluation of other information,

| or consideration of public comments. Therefore, the staff concludes that there would be no

on-site land use impacts during the renewal term beyond those discussed in the GEIS.

• Power line right of way. Based on information in the GEIS, the Commission found that:

Ongoing use of power line ROWs would continue with no change in restrictions. The

effects of these restrictions are of small significance.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, evaluation of other information,
Environmental Impacts of Operation

July 2007 4-47 NUREG-1437, Supplement 29

or consideration of public comments. Therefore, the staff concludes that there would be no |

impacts of power line ROWs on land use during the renewal term beyond those discussed

in the GEIS.

There is one Category 2 issue related to transmission lines. An additional issue related to

transmission lines (chronic effects) was left uncategorized in the GEIS (NRC 1996) and is being

treated as a Category 2 issue in this SEIS. These issues are listed in Table 4-8 and are |

discussed in Sections 4.2.1 and 4.2.2.

Table 4-8. Category 2 and Uncategorized Issues Applicable to the PNPS |

Transmission Lines During the Renewal Term

ISSUE—10 CFR Part 51, Subpart A, |

Appendix B, Table B-1

GEIS

Sections |

10 CFR |

51.53(c)(3)(ii) |

Subparagraph |

SEIS

Section

HUMAN HEALTH

Electromagnetic fields, acute effects 

(electric shock)

4.5.4.1 H 4.2.1

Electromagnetic fields, chronic effects 4.5.4.2 NA 4.2.2

4.2.1 Electromagnetic Fields-Acute Effects

Based on the GEIS, the Commission found that electric shock resulting from direct access to

energized conductors or from induced charges in metallic structures has not been found to be a

problem at most operating plants and generally is not expected to be a problem during the

license renewal term. However, site-specific review is required to determine the significance of |

the electric shock potential along the portions of the transmission lines that are within the scope

of this SEIS. 

In the GEIS (NRC 1996), the staff found that without a review of the conformance of each

nuclear plant transmission line with National Electrical Safety Code (NESC 1997) criteria, it was

not possible to determine the significance of the electric shock potential. Evaluation of

individual plant transmission lines is necessary because the issue of electric shock safety was

not addressed in the licensing process for some plants. For other plants, land use in the vicinity

of transmission lines may have changed, or power distribution companies may have chosen to

upgrade line voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), the applicant must provide an

assessment of the potential shock hazard if the transmission lines that were constructed for the

specific purpose of connecting the plant to the transmission system do not meet the

recommendations of the NESC for preventing electric shock from induced currents.
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-48 July 2007

The PNPS transmission lines were constructed to the NESC specifications and industry

guidance in effect at the time the lines were constructed. PNPS transmission facilities and

ROW, which are owned and operated by NSTAR, are maintained to ensure continued

compliance with the standards and guidance in effect when they were constructed. In 1977,

after the lines were constructed, a new criterion was added to the NESC that established

minimum vertical clearances to the ground for power lines with voltages exceeding 98 kilovolts

(kV). This criterion states that the clearance must limit the steady-state induced current to 5 

milliamperes (mA) if the largest anticipated truck, vehicle, or equipment were short-circuited to

the ground.

The PNPS is connected to the electric grid via two 345-kV lines. As part of their license renewal

application, Entergy (2006a) reviewed these transmission lines for compliance with the 1977

NESC criterion. Because the two lines share the same towers, Entergy performed an analysis

on a limiting case in which both lines operated together and, as a conservative assumption,

were located at the minimum clearance distance (28 ft) allowed by the Commonwealth of

Massachusetts for 345-kV lines. All spans on the lines exceed this minimum 

clearance distance, and NSTAR conducts surveillance and maintenance activities to ensure

that the ground clearances do not change (Entergy 2006a).

The electric field strength beneath these lines was calculated by NSTAR using the Electric

Power Research Institute (EPRI) code, ENVIRO (NSTAR 2001, in Entergy 2006a). Entergy

used methods described in EPRI's Transmission Line Reference Book (EPRI 1982, in Entergy

2006a) to calculate the induced current based on the distribution of the electric field strength. 

The analysis assumed a vehicle of the maximum size allowed by the Commonwealth of

Massachusetts, which is a tractor-trailer 60 ft long, 8 ft wide, and 13.5 ft high. This analysis

determined that the combined effect of the two lines would result in a maximum induced current

of 4.5 mA, below the NESC 5-mA criterion. Therefore, the transmission lines comply with the

NESC provisions for preventing electric shock from induced current (Entergy 2006a). 

The staff has reviewed the available information, including the applicant's evaluation and

| computational results, the site visit, the scoping process, and other public sources including

| public comments received. Based on this information, the staff evaluated the potential impacts

of electric shock resulting from operation of PNPS and its associated transmission lines. It is

the staff's conclusion that the potential impacts of electric shock during the renewal term would

| be SMALL, and no additional mitigation would be warranted.
Environmental Impacts of Operation

July 2007 4-49 NUREG-1437, Supplement 29

4.2.2 Electromagnetic Fields-Chronic Effects

In the GEIS, the chronic effects of 60 hertz electromagnetic fields from power lines were not

designated as Category 1 or 2, and will not be until a scientific consensus is reached on the

health implications of these fields.

The potential for chronic effects from these fields continues to be studied and is not known at

this time. The National Institute of Environmental Health Sciences (NIEHS) directs related

research through the U.S. Department of Energy (DOE). The 1999 report of the NIEHS and

DOE Working Group (Portier and Wolfe 1999) contains the following conclusion:

The NIEHS concludes that ELF-EMF (extremely low frequency-electromagnetic field)

exposure cannot be recognized as entirely safe because of weak scientific evidence that

exposure may pose a leukemia hazard. In our opinion, this finding is insufficient to warrant

aggressive regulatory concern. However, because virtually everyone in the United States

uses electricity and therefore is routinely exposed to ELF-EMF, passive regulatory action is

warranted such as a continued emphasis on educating both the public and the regulated

community on means aimed at reducing exposures. The NIEHS does not believe that other

cancers or non-cancer health outcomes provide sufficient evidence of a risk to currently

warrant concern.

This statement is not sufficient to cause the staff to change its position with respect to the

chronic effects of electromagnetic fields. The staff considers the GEIS finding of "not

applicable" still appropriate and continues to follow developments on this issue.

4.3 Radiological Impacts of Normal Operations

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to

PNPS in regard to radiological impacts are listed in Table 4-9. Entergy stated in its ER |

(Entergy 2006a) that it has not identified any new and significant information concerning |

impacts related to these issues with respect to the renewal of the PNPS operating license. The

staff did not identify any additional new and significant information during its independent review |

of the PNPS ER, the site visit, the scoping process, evaluation of other available information, or |

consideration of public comments. Therefore, the staff concludes that there are no impacts |

related to these issues beyond those discussed in the GEIS. For these issues, the staff

concluded in the GEIS that the impacts are SMALL, and additional plant-specific mitigation

measures are not likely to be sufficiently beneficial to be warranted.
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-50 July 2007

| Table 4-9. Category 1 Issues Applicable to Radiological Impacts of 

Normal Operations During the Renewal Term

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

HUMAN HEALTH

Radiation exposures to public (license renewal term) 4.6.2

Occupational radiation exposures (license renewal term) 4.6.3

A brief description of the staff’s review and the GEIS conclusions, as codified in Table B-1, for

each of these issues follows:

 C Radiation exposures to public (license renewal term). Based on information in the GEIS,

the Commission found that: 

Radiation doses to the public will continue at current levels associated with normal

operations.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, evaluation of other available

| information, or consideration of public comments. Therefore, the staff concludes that there

would be no impacts of radiation exposures to the public during the renewal term beyond

those discussed in the GEIS. However, the staff did receive a number of comments on this

issue during the scoping process. The staff’s evaluation of this information is presented in

Section 4.7.

 C Occupational radiation exposures (license renewal term). Based on information in the

GEIS, the Commission found that:

Projected maximum occupational doses during the license renewal term are within

the range of doses experienced during normal operations and normal maintenance

outages, and would be below regulatory limits.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the staff's site visit, the scoping process, evaluation of other

| available information, or consideration of public comments. Therefore, the staff concludes

that there would be no impacts of occupational radiation exposures during the renewal term

beyond those discussed in the GEIS. 

There are no Category 2 issues related to radiological impacts of routine operations.

4.4 Socioeconomic Impacts of Plant Operations During the
Environmental Impacts of Operation

July 2007 4-51 NUREG-1437, Supplement 29

License Renewal Period

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to

socioeconomic impacts during the renewal term are listed in Table 4-10. Entergy stated in its |

ER (Entergy 2006a) that it is not aware of any new and significant information associated with

the renewal of the PNPS operating license. The staff has not identified any new and significant

information during its independent review of the PNPS ER, the site visit, the scoping process, or

its evaluation of other available information. Therefore, the staff concludes that there are no

impacts related to these issues beyond those discussed in the GEIS (NRC 1996). For these

issues, the staff concluded in the GEIS that the impacts are SMALL, and additional

plant-specific mitigation measures are not likely to be sufficiently beneficial to be warranted.

Table 4-10. Category 1 Issues Applicable to Socioeconomics During the Renewal Term |

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

SOCIOECONOMICS

Public services: public safety, social services, and tourism and recreation 4.7.3; 4.7.3.3; 4.7.3.4;

4.7.3.6

Public services: education (license renewal term) 4.7.3.1

Aesthetic impacts (license renewal term) 4.7.6

Aesthetic impacts of transmission lines (license renewal term) 4.5.8

A brief description of the staff’s review and the GEIS conclusions, as codified in Table B-1, for

each of these issues follows:

 C Public services: public safety, social services, and tourism and recreation. Based

on information in the GEIS, the Commission found that:

Impacts to public safety, social services, and tourism and recreation are

expected to be of small significance at all sites.

The staff has not identified any new and significant information during its independent

review of the PNPS ER, the site visit, the scoping process, evaluation of other available |

information, or consideration of public comments. Therefore, the staff concludes that |

there would be no impacts on public safety, social services, and tourism and recreation

during the renewal termbeyond those discussed in the GEIS.
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-52 July 2007

 C Public services: education (license renewal term). Based on information in the

GEIS, the Commission found that:

Only impacts of small significance are expected.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, evaluation of other available

| information, or consideration of public comments. Therefore, the staff concludes that

there would be no impacts on education during the renewal term beyond those

discussed in the GEIS.

 C Aesthetic impacts (license renewal term). Based on information in the GEIS, the

Commission found that:

No significant impacts are expected during the license renewal term.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, evaluation of other available

| information, or consideration of public comments. Therefore, the staff concludes that

there would be no aesthetic impacts during the renewal term beyond those discussed in

the GEIS.

 C Aesthetic impacts of transmission lines (license renewal term). Based on

information in the GEIS, the Commission found that:

No significant impacts are expected during the license renewal term.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, evaluation of other available

| information, or consideration of public comments. Therefore, the staff concludes that

there would be no aesthetic impacts of transmission lines during the renewal term

beyond those discussed in the GEIS.

| Table 4-11 lists the five Category 2 socioeconomic issues which require plant-specific analysis,

as well as environmental justice, which was not addressed in the GEIS.
Environmental Impacts of Operation

July 2007 4-53 NUREG-1437, Supplement 29

Table 4-11. Environmental Justice and GEIS Category 2 Issues |

Applicable to Socioeconomics During the Renewal Term

ISSUE—10 CFR Part 51, Subpart A,

Appendix B, Table B-1

GEIS 

Sections

10 CFR 51.53(c)(3)(ii)

Subparagraph

SEIS

Section

SOCIOECONOMICS

Housing impacts 4.7.1 I 4.4.1

Public services: public utilities 4.7.3.5 I 4.4.2

Off-site land use (license renewal

term)

4.7.4 I 4.4.3

Public Services, transportation 4.7.3.2 J 4.4.4

Historic and archaeological resources 4.7.7 K 4.4.5

Environmental Justice Not addressed(a) Not addressed(a) 4.4.6

(a) Guidance related to environmental justice was not in place at the time the GEIS and the associated revision

to 10 CFR Part 51 were prepared. Therefore, environmental justice must be addressed in the staff’s

supplemental environmental impact statement (NRC 2004b)

4.4.1 Housing Impacts During Operations

10 CFR Part 51, Subpart A, Appendix B, Table B-1 states that impacts on housing availability

are expected to be of small significance at plants located in a high-population area where

growth-control measures are not in effect. The PNPS site is located in a high-population area

and Plymouth County is not subject to growth-control measures that would limit housing

development. Based on the NRC criteria, Entergy expects housing impacts to be SMALL during

continued operations (Entergy 2006a).

Small impacts result when no discernible change in housing availability occurs, changes in

rental rates and housing values are similar to those occurring statewide, and no housing

construction or conversion is required to meet new demand (NRC 1996). The GEIS assumes

that an additional staff of 60 permanent per unit workers might be needed during the license

renewal period to perform routine maintenance and other activities. Entergy plans no increase in

employment during the license renewal term.

Section 2.2.8.1 discusses housing conditions in the region and notes the locations of residences

for the approximately 700 employees of PNPS. Plymouth and Barnstable counties experienced

substantial growth in housing units over the period of 1990 to 2000. Plymouth’s number of |

occupied housing units increased by 12.6 percent and Barnstable by 22.2 percent over the

decade. Section 2.2.8.5 stated the growth rate of Plymouth and Barnstable counties to |

be 8.6 percent and 19.0 percent, respectively, from 1990 to 2000. Both of these counties’ 

growth rates are higher than Massachusetts’ rate as a whole (5.5 percent). Projected

population data indicates these rates will continue in these counties in the future.
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-54 July 2007

The staff reviewed the available information relative to housing impacts and PNPS ER. Based

on this review, the staff concludes that the impact on housing during the license renewal period

would be SMALL, and additional mitigation is not warranted.

4.4.2 Public Services: Public Utility Impacts During Operations

Impacts on public utility services are considered SMALL if there is little or no change in the

ability of the system to respond to the level of demand, and thus there is no need to add capital

facilities. Impacts are considered MODERATE if overtaxing of service capabilities occurs during

periods of peak demand. Impacts are considered LARGE if existing levels of service (e.g.,

water or sewer services) are substantially degraded and additional capacity is needed to meet

ongoing demands for services. The GEIS indicates that, in the absence of new and significant

information to the contrary, the only impacts on public utilities that could be significant are

impacts on public water supplies (NRC 1996).

Analysis of impacts on the public water supply system considered both facility demand and

facility-related population growth. PNPS purchases water from the Town of Plymouth Water

Division. This water is used as potable water and reactor make-up water at the facility. As

described in Section 2.2.2, PNPS estimated annual consumption of water obtained from the

Town of Plymouth public water supply system to be 39.1 million gallons per year for a

non-outage year. This usage represents approximately 2.3 percent of the town's total yearly

consumption. No refurbishment or new construction activities are associated with the PNPS

license renewal and PNPS water usage is not expected to change during the license renewal

term. Therefore, the impact on the local water supply would not be expected to change. 

Entergy plans no increase in employment at PNPS during the license renewal term 

(Entergy 2006a). Therefore, facility-related population growth is not expected, and there would

be no significant impact on the region's water supplies.

The Plymouth-Carver aquifer, which is the source of potable water for the Town of Plymouth

public water supply system, has sufficient water for existing and projected demand. The town

has measures in effect to limit development in order to prevent excess water withdrawal 

(Town of Plymouth 2006).

The staff has reviewed the available information, including actual water use records for PNPS

and water use and water supply capacities for the major public water supply systems in the

region. Based on this information, the staff concludes that the potential impacts of PNPS during

the license renewal period on public water supplies are SMALL and that no additional mitigation

measures are warranted.
Environmental Impacts of Operation

(d) Interview with Town of Plymouth officials on May 2, 2006.

July 2007 4-55 NUREG-1437, Supplement 29

4.4.3 Off-site Land Use During Operations

Off-site land use during the license renewal term is a Category 2 issue. Table B-1 of 10 CFR 51

Subpart A, Appendix B notes that "significant changes in land use may be associated with

population and tax revenue changes resulting from license renewal."

Section 4.7.4 of the GEIS defines the magnitude of land-use changes as a result of plant

operation during the license renewal term as follows:

SMALL - Little new development and minimal changes to an area's land-use pattern.

MODERATE - Considerable new development and some changes to the land-use pattern.

LARGE - Large-scale new development and major changes in the land-use pattern.

The Town of Plymouth Conservation Commission has expressed concern that the breakwaters

associated with the PNPS intake and discharge structures may have contributed to erosion of

the shoreline in the Priscilla Beach community, located southeast of the facility along Cape Cod

Bay, resulting in a cobble rather than sand beach(d). The Massachusetts Office of Coastal Zone

Management’s Shoreline Change Project provides data on changes in the location of the state’s

shoreline over time (MOCZM 2006). The Shoreline Change Project presents long and shortterm shoreline change rates at 40 m (131 ft) intervals along the Massachusetts coast,

classifying change in the location of the shoreline as either negative (erosion) or positive

(accretion). The shoreline change data were derived from analyses of historical maps and

aerial photographs spanning the time period from the mid-1800s to 1994. The staff examined

shoreline change data from 32 transects covering the shoreline from the southern breakwater at

PNPS southeast to the Priscilla Beach/White Horse Rocks area, for a total of 4200 ft. For the

first time period studied, 1866 to 1951, most of this segment of shoreline experienced accretion

(gain). The second time period, 1951 to 1978, saw erosion (loss) over many segments of this

shoreline, with the greatest rate of erosion occurring in the portion farthest away from

(southeast of) PNPS. Some segments experienced accretion. During the third time period

studied, 1987 to 1994, more segments experienced erosion than accretion but not in any

particular pattern or trend (i.e., some areas that experienced erosion in the second period

experienced accretion during the third period and for others the opposite occurred). The

segments with the greatest erosion rates during the second period (i.e., those farthest away

from PNPS) experienced accretion or a slower rate of erosion during the third time period. 

Based on the review of this data, no detectable trend of erosion associated with the PNPS

facility was observed.
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-56 July 2007

Tax revenue can affect land use because it enables local jurisdictions to be able to provide the

public services (e.g., transportation and utilities) necessary to support development. 

Section 4.7.4.1 of the GEIS states that the assessment of tax-driven land-use impacts during

the license renewal term should consider (1) the size of the plant's payments relative to the

community's total revenues, (2) the nature of the community's existing land-use pattern, and

(3) the extent to which the community already has public services in place to support and guide

development. If the plant's tax payments are projected to be small relative to the community's

total revenue, tax-driven land-use changes during the plant's license renewal term would be

small, especially where the community has pre-established patterns of development and has

provided adequate public services to support and guide development. Section 4.7.2.1 of the

GEIS states that if tax payments by the plant owner are less than 10 percent of the taxing

jurisdictions revenue, the significance level would be small. If the plant's tax payments are

projected to be medium to large relative to the community's total revenue, new tax-driven landuse changes would be moderate. If the plant’s tax payments are projected to be a dominant

source of the community’s total revenue, new tax-driven land-use changes would be large. This

would be especially true where the community has no pre-established pattern of development or

has not provided adequate public services to support and guide development.

PNPS pays annual property taxes to the Town of Plymouth. As discussed in Section 2.2.8.6,

property taxes paid to the Town of Plymouth for PNPS have declined since 1998 when the

Commonwealth of Massachusetts deregulated its utility industry, and in 1999 when Boston

Edison Company sold PNPS to Entergy Corporation for significantly less than the assessed

value. Subsequent to the State's deregulation law and Entergy's purchase of PNPS, the Town

of Plymouth and Entergy agreed to payments in lieu of taxes of $1 million annually with the

potential for payments to increase should Entergy make capital improvements or substantial

| additions to the facility. The agreement continues through 2012. It would be renegotiated in the

| event of license renewal (Entergy 2006a). However, in April 2007, the Town of Plymouth

| reached a new five-year PILOT agreement with Entergy that increases Entergy’s annual

| payment to an estimated $8.49 million in FY2008 (Town of Plymouth 2007). The payments

| decline thereafter, reaching an estimated $6.79 million in FY 2012. The agreement includes a

| reopener provision in the event that PNPS’ current license is renewed. In addition, the

Massachusetts legislature has required the owners and operators of the transmission lines

(NSTAR) to make payments to the Town of Plymouth until the end of the current PNPS license

in 2012. NSTAR payments will decline from $12 million in 2006 to $1 million in 2007, and

continue annually at that amount through 2012. Until 1999, PNPS property taxes provided

approximately 22 percent of the Town of Plymouth's total property tax revenues or about 17

| percent of the town’s total revenues. In FY2007, Entergy and NSTAR PILOT payments

associated with PNPS represent only about 1.5 percent of the total property revenues received

| by the Town of Plymouth. In FY2008, under the new PILOT agreement with Entergy, the PNPS

| payments are expected to represent about 6 percent of the town’s total revenues.
Environmental Impacts of Operation

July 2007 4-57 NUREG-1437, Supplement 29

No refurbishment or new construction activities are associated with the PNPS license renewal. 

Therefore, the Entergy FY2012 estimated PILOT payment of $6.79 million per year to the Town |

of Plymouth would not be expected to increase substantially (e.g., enough to raise it to 10

percent of the town's total revenues) as a result of the renegotiation that would occur at license

renewal. Based on this analysis, tax payments for PNPS are expected to remain at less than 10

percent of the Town of Plymouth's total revenues over the license renewal term. Therefore, the

staff concludes that the tax-related land use impacts would remain SMALL.

4.4.4 Public Services: Transportation Impacts During Operations

Table B-1, 10 CFR Part 51 states: "Transportation impacts (level of service) of highway traffic

generated... during the term of the renewed license are generally expected to be of small

significance. However, the increase in traffic associated with additional workers and the local

road and traffic control conditions may lead to impacts of moderate or large significance at

some sites." All applicants are required by 10 CFR 51.53(c)(3)(ii)(J) to assess the impacts of

highway traffic generated by the proposed project on the level of service of local highways

during the term of the renewed license. 

Section 2.2.8.1 addressed existing transportation conditions in the vicinity of PNPS and found

no serious substandard conditions in the highway network. The possible exception is Rocky Hill

Road, which suffers from some safety issues associated with limited sight distances, tight

curves, and no shoulders. The recent Old Colony Planning Council study of this highway makes

specific recommendations for the town to improve safety on this local roadway (OCPC 2006).

The study did not cite PNPS as contributing to these problems. Currently, PNPS truck traffic is |

directed to use Power House Road to access the plant. With no increase in personnel |

anticipated during the relicensing period, any changes in future transportation conditions in the

area would not be attributable to PNPS.

The staff has reviewed the available information on traffic and transportation conditions and the

potential effects of relicensing. Based on this information, the staff concludes that the potential

impacts of relicensing on transportation are SMALL and no additional mitigation is needed.

4.4.5 Historic and Archaeological Resources 

The National Historic Preservation Act (NHPA) requires that Federal agencies take into account

the effects of their undertakings on historic properties. The historic preservation review process

mandated by Section 106 of the NHPA is outlined in regulations issued by the Advisory Council

on Historic Preservation at 36 CFR Part 800. Renewal of an operating license is an undertaking

that could potentially affect historic properties. Therefore, according to the NHPA, the NRC is to

make a reasonable effort to identify historic properties in the areas of potential effects. If no

historic properties are present or affected, the NRC is required to notify the State 
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-58 July 2007

Historic Preservation Officer before proceeding. If it is determined that historic properties are

present, the NRC is required to assess and resolve possible adverse effects of the undertaking.

4.4.5.1 Site Specific Cultural Resources Information

A review of the Massachusetts Historical Commission (MHC) files shows that there are no

National Register eligible or listed archaeological or historic above ground resources identified

| on the PNPS site. As noted in Section 2.2.9.2, an archaeological survey of a 517-ac portion of

the PNPS site, including the area where the station and the transmission line were constructed,

identified 25 archaeological sites (24 historic and one prehistoric), all of which were eventually

determined to be ineligible for listing on the National Register (AEC 1972). This testing also

concluded that there is no evidence of prehistoric occupation in the area around the station

(AEC 1972). 

There is potential for archaeological resources to be present on other portions of the PNPS site

| that have not been surveyed (i.e., in the former recreation area, the woodlands area, and within

the transmission line corridor). One example reported by Entergy (2006a) is a possible cellar

described by local informants as having been located and subsequently destroyed by

| construction of Power House Road. In addition, a small number of historic artifacts and two

possible historic sites were observed by the NRC staff during the site visit (Section 2.2.9.2).

| As noted in Section 2.2.9.2, 21 National Register and/or State Register listed historic resources

| have been identified within the Town of Plymouth. However, none are located within the

| boundaries of the PNPS site (Entergy 2006a). 

4.4.5.2 Conclusions

A 1990 Environmental Assessment conducted by the NRC reported that operations at the

PNPS site had not disturbed the integrity of local historic sites in the Town of Plymouth 

| (NRC 1990). In a 2005 correspondence between the MHC and Entergy it was further

determined that no National Register eligible historic or archaeological resources on the PNPS

site would likely be impacted through continuing operations at the station (Entergy 2006a).

No new facilities, service roads or transmission lines are proposed for the PNPS site as part of

this operating license renewal, nor are refurbishment activities proposed. Additionally, Entergy

has an environmental review and evaluation procedure (EN-EV-115) in place to identify and

assess the effects of its activities upon cultural resources (Entergy 2006d). Therefore, the

potential for National Register eligible historic or archaeological resources to be impacted by

renewal of this operating license is SMALL. Based on this conclusion, there would be no need

to review mitigation measures. 
Environmental Impacts of Operation

(e) The Commission policy statement on environmental justice matters defines “minority” as American

Indian or Alaskan Native; Asian; Native Hawaiian or other Pacific Islander; Black races; or Hispanic

ethnicity. “Other” races and multi-racial individuals may be considered as separate minorities 

(NRC 2004b).

July 2007 4-59 NUREG-1437, Supplement 29

4.4.6 Environmental Justice

Environmental justice refers to a Federal policy that requires Federal agencies to identify and

address, as appropriate, disproportionately high and adverse human health or environmental

effects of its actions on minority(e) or low-income populations. The memorandum accompanying |

Executive Order 12898 (59 FR 7629) directs Federal executive agencies to consider

environmental justice under the National Environmental Policy Act of 1969 (NEPA). The

Council on Environmental Quality has provided guidance for addressing environmental justice

(CEQ 1997a). Although the Executive Order is not mandatory for independent agencies, the |

NRC has voluntarily committed to undertake environmental justice reviews. Specific guidance

is provided in the NRC Office of Nuclear Reactor Regulation Office Instruction LIC-203,

Procedural Guidance for Preparing Environmental Assessments and Considering

Environmental Issues Rev. 1 (NRC 2004a). In 2004, the Commission issued a final Policy

Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing

Actions (NRC 2004b).

The scope of the review, as defined in NRC guidance (NRC 2004a), includes identification of

impacts on minority and low-income populations, the location and significance of any 

environmental impacts during operations on populations that are particularly sensitive, and

information pertaining to mitigation. It also includes evaluation of whether these impacts are

likely to be disproportionately high and adverse.

The staff identified minority and low-income populations within the 50-mi radius of the site. A

minority population exists in a census block group if the percentage of each minority and

aggregated minority category within the census block group exceeds the corresponding

percentage of minorities in the state of which it is a part by 20 percentage points, or the

corresponding percentage of minorities within the census block group is at least 50 percent. A

low-income population exists if the percentage of low-income population within a census block

group exceeds the corresponding percentage of low-income population in the state of which it is

a part by 20 percentage points, or if the corresponding percentage of low-income population

within a census block group is at least 50 percent.
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-60 July 2007

For the PNPS review, the staff examined the geographic distribution of minority and low-income

populations within 50 mi of the site, employing the 2000 Census for low-income and minority

populations (USCB 2000). The analysis was supplemented by field inquiries to the planning

department and local officials in the towns in Plymouth County proximate to PNPS. 

4.4.6.1 Minority Populations

The percent of each minority group and of minorities in aggregate was calculated for each of the

3863 block groups within 50 mi of PNPS and compared to the corresponding State’s minority

threshold percentages to determine whether environmental justice-defined minority populations

exist.

Massachusetts, with approximately 83 percent of the block groups, accounts for 514 block

groups defined as minority communities, with the remaining 17 percent of block groups in

Rhode Island accounting for 137 block groups defined as minority communities (aggregating all

| minority racial groups and Hispanic populations). The location of these minority block groups is

| shown in Figure 2-11.

| No minority communities were located within a 6-mi radius of PNPS. The nearest

concentrations of minority groups to PNPS were in Brockton, approximately 25 mi to the

| northwest. Other minority communities were located in or near Boston, Massachusetts, and

Providence, Rhode Island.

4.4.6.2 Low-Income Populations

NRC guidance defines “low-income” by using U.S. Census Bureau (USCB) statistical poverty

| thresholds (NRC 2004a). The same approach to defining low-income environmental justice

thresholds is used for minorities (i.e., where the low-income population of the census block

group exceeds 50 percent, or where the percentage of persons below the poverty level in a

| census block group is 20 percentage points or more than the state’s percentage of low-income

persons).

In Massachusetts, of the 3204 block groups within 50 mi of PNPS, low-income populations exist

in 190 block groups, and in Rhode Island, 79 of the 659 block groups in the study area were

defined as low-income.

No low-income populations were identified within the 6-mi radius of PNPS. The nearest lowincome population occurring within the 50-mi radius was in northwest Plymouth County in

| Brockton. This population is approximately 25 mi northwest of the PNPS site. Other lowincome populations within 50 mi of PNPS were clustered near Boston and in Bristol County,

near the communities of Fall River and New Bedford, Massachusetts and in Providence County,

| Rhode Island. The location of these low-income block groups is shown in Figure 2-12.
Environmental Impacts of Operation

July 2007 4-61 NUREG-1437, Supplement 29

With the locations of minority and low-income populations identified, the staff proceeded to

evaluate whether any of the environmental impacts of the proposed action could affect these

populations in a disproportionately high and adverse manner. The pathways through which the |

environmental impacts associated with the PNPS license renewal can affect human populations

are discussed in each topical section. The staff evaluated whether minority and low-income

populations could be disproportionately affected by these impacts. The staff found no unusual

resource dependencies or practices, such as subsistence agriculture, hunting, or fishing that

would be affected and, in turn, adversely affect minority and low-income populations. In

addition, the staff did not identify any location-dependent disproportionately high and adverse

impacts affecting these minority and low-income populations. The staff concludes that off-site

impacts from PNPS on minority and low-income populations would be SMALL, and no special

mitigation actions are warranted.

4.5 Ground-Water Use and Quality

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to

PNPS groundwater use and quality are listed in Table 4-12. Entergy stated in its ER that it is |

not aware of any new and significant information associated with the renewal of the PNPS OL

(Entergy 2006a). The staff has not identified any new and significant information during its

independent review of the PNPS ER, the staff's site visit, the scoping process, its evaluation of |

other available information, or consideration of public comments. Therefore, the staff concludes |

that there would be no impacts related to these issues beyond those discussed in the GEIS. |

For these issues, the GEIS concluded that the impacts would be SMALL, and additional plant |

specific mitigation measures are not likely to be sufficiently beneficial to be warranted.

Table 4-12. Category 1 Issues Applicable to Groundwater Use and Quality During the Renewal Term |

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1

GEIS

Sections

GROUND-WATER USE AND QUALITY

Ground-water use conflicts (potable and service water; plants that use <100 gpm) 4.8.1.1

Ground-water quality degradation (saltwater intrusion) 4.8.2.1
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-62 July 2007

A brief description of the staff’s review and the GEIS conclusions, as codified in Table B-1,

10 CFR 51, follows.

 C Ground-water use conflicts (potable and service water; plants that use <100 gpm). 

Based on information in the GEIS, the Commission found that:

Plants using less than 100 gpm are not expected to cause any ground-water use

conflicts.

As discussed in Section 2.2.2, PNPS groundwater use is less than 100 gpm. The staff has

not identified any new and significant information during its independent review of the PNPS

| ER, the site visit, the scoping process, evaluation of other available information, or

| consideration of public comments. Therefore, the staff concludes that there would be no

groundwater use conflicts during the renewal term beyond those discussed in the GEIS.

 C Ground-water quality degradation (saltwater intrusion). Based on information in the

GEIS, the Commission found that:

Nuclear power plants do not contribute significantly to saltwater intrusion.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER, the site visit, the scoping process, evaluation of other available

| information, or consideration of public comments. Therefore, the staff concludes that there

would be no groundwater quality degradation impacts associated with saltwater intrusion

during the renewal term beyond those discussed in the GEIS.

There are no Category 2 issues related to groundwater use and quality for PNPS. 

4.6 Threatened or Endangered Species

Threatened or endangered species are listed as a Category 2 issue in 10 CFR Part 51,

| Subpart A, Appendix B, Table B-1. This issue is listed in Table 4-13.

| Table 4-13. Category 2 Issue Applicable to Threatened or Endangered Species During the Renewal term

ISSUE—10 CFR Part 51, Subpart A,

Appendix B, Table B-1

GEIS

Section

10 CFR 51.53(c)(3)(ii)

Subparagraph

SEIS

Section

THREATENED OR ENDANGERED SPECIES (FOR ALL PLANTS)

Threatened or endangered species 4.1 E 4.6
Environmental Impacts of Operation

July 2007 4-63 NUREG-1437, Supplement 29

This issue requires consultation with appropriate agencies to determine whether threatened or

endangered species are present and whether they would be adversely affected by continued

operation of the nuclear facility during the license renewal term. The presence of threatened or

endangered species in the vicinity of the PNPS site is discussed in Sections 2.2.5.3.7 and |

2.2.6.2. On April 25, 2006, the staff contacted the FWS and NMFS to request information on |

threatened and endangered species and the impacts of license renewal (NRC 2006b). In

response, on May 23, 2006, the FWS provided additional information regarding Federally listed

species that have been observed or may occur in the vicinity of PNPS and its associated

transmission line ROW, as well as the concerns that the FWS have regarding those species

(FWS 2006). The FWS implied in this letter that formal consultation is not required. NMFS

responded on June 28, 2006, with a listing of marine species that were potentially affected by

PNPS operations (NMFS 2006). The staff has prepared a biological assessment (BA) that

documents its review, and the BA has been transmitted to NMFS for their concurrence. The BA

is provided in Appendix E of this SEIS. The staff has not received a response from NMFS, upon |

publishing of this Final SEIS. |

4.6.1 Marine Aquatic Species

As described in Section 2.2.5.3.6, there are ten Federally listed endangered or threatened

marine aquatic species with some potential to occur in the vicinity of the PNPS. Four species of

sea turtle Federally listed as endangered or threatened may occur in Cape Cod Bay. The

loggerhead (Caretta caretta), Kemp’s ridley (Lepidochelys kempi), leatherback (Dermochelys

coriacea), and green (Chelonia mydas) turtles have all been observed within Cape Cod Bay, but |

none have been documented at the PNPS site. Throughout the operation of the plant, there |

have been no incidents of turtles being impinged on the screens, nor have any ever been

observed in the intake embayment or discharge canal (Entergy 2006a). |

Three Federally endangered great whale species are found seasonally in New England waters

and have been documented in Cape Cod Bay: North Atlantic right whale (Eubalaena glacialis), |

humpback whale (Megaptera novaeangliae), and fin whale (Balaenoptera physalus). In |

addition, two other species, sei whale (B. borealis) and sperm whale (Physter catadon), are |

known to migrate in New England waters off of the coast of Massachusetts. Cape Cod Bay is

designated as a critical habitat for the North Atlantic right whale. Although these species are

documented in Cape Cod Bay and/or coastal Massachusetts waters, no whales have been

observed in the shallow waters off PNPS or in the intake and discharge areas by applicant

biologists since biological monitoring began at PNPS in the late 1960s (Entergy 2006a).

The range of the endangered shortnose sturgeon (Acipenser brevirostrum) includes the PNPS

area; however, there are no known occurrences of the shortnose sturgeon in Plymouth or the 

surrounding area (NHESP 2006). Shortnose sturgeon have never been observed in Cape Cod 
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-64 July 2007

| Bay near PNPS, or in the facility intake and discharge areas during the duration of the

| ecological monitoring studies since the plant first came on line (Entergy 2006a).

The staff concludes that continued operation of PNPS during the license renewal term is not

likely to adversely affect any Federally listed marine aquatic species. Thus, the staff concludes

that the impact on threatened or endangered marine aquatic species from an additional 20

| years of operation would be SMALL, and no additional mitigation would be warranted. The

staff’s findings were documented in the BA (Appendix E) that has been forwarded to the NMFS

| for concurrence. The staff has not received a response from NMFS, upon publishing of this

| Final SEIS.

4.6.2 Terrestrial and Freshwater Aquatic Species

| No Federally or State-listed threatened or endangered terrestrial species have been observed

on the PNPS site or the transmission line ROW. Five species with a Federal listing status of

endangered or threatened have been identified in the Town of Plymouth. The FWS (2006)

identified four Federally listed species as potentially occurring in the PNPS vicinity or the

transmission line ROW: the piping plover (Charadrius melodus), roseate tern (Sterna dougallii),

bald eagle (Haliaeetus leucocephalus), and population 1 of the northern red-bellied cooter

(Pseudemys rubriventris). The fifth Federally listed species, the dwarf wedgemussel

(Alasmidonta heterodon), does not have habitat or the potential to occur in these area.

Although these three Federally listed birds occur in the vicinity of the facility, they are not

dependent on habitats within the facility and are unlikely to be affected by facility operations. 

The piping plover is known to occur along Plymouth Beach just north of the PNPS (FWS 2006)

and may move through the PNPS site while foraging along the shoreline and during migration

(NHESP 1990). The piping plover has made a dramatic recovery in Massachusetts during the

period that PNPS has been operating. The Massachusetts population increased from 139

breeding pairs in 1986 to over 500 breeding pairs in 1999, and now represents one-third of the

entire Atlantic coast population (NHESP 1990). The roseate tern also is known to occur along

Plymouth Beach just north of PNPS (FWS 2006), and it may pass over the PNPS site during

migration (NHESP 1988). The roseate tern population in Massachusetts has been slowly

| increasing, from 1600 breeding pairs in 1978 to 1810 breeding pairs in 1999 (NHESP 2005). 

Wintering bald eagles occasionally occur in the area of the PNPS (FWS 2006), and in 2005,

juveniles and adults were observed at Plimoth Plantation, approximately 2 mi northwest of

PNPS (Entergy 2006a). The bald eagle breeding population in Massachusetts has been

recovering slowly, and in 2002 there were 12 breeding pairs producing approximately 15 chicks

| annually (NHESP 2005). Thus, there is no evidence that these species have been adversely

affected by previous operation of the PNPS facility. Given that no expansion of existing facilities
Environmental Impacts of Operation

July 2007 4-65 NUREG-1437, Supplement 29

or disturbance of additional land is anticipated, these species are unlikely to be adversely

affected during the renewal period (FWS 2006).

The northern red-bellied cooter is the only Federally listed species for which an area in the

vicinity of PNPS and the transmission line ROW has been designated by FWS as critical

habitat. Approximately 1400 ft of the transmission line ROW, near its southern end and

adjacent to the boundary of Myles Standish State Forest, crosses the southeastern tip of an

area containing numerous ponds that was designated as critical habitat (at 50 CFR 17.95) for

the northern red-bellied cooter (FWS 1980) (Figure 2-6). The specific habitats used by the

northern red-bellied cooter, which consist of ponds with abundant vegetation and areas of

sandy soil on nearby land for nesting (NHESP 1995), do not occur within the transmission line

ROW. The FWS concurred that the area of critical habitat crossed by the transmission line

ROW does not provide the specific habitat needs of the northern red-bellied cooter 

(FWS 2006). The FWS noted that this area of the habitat was considered critical based on its

value as a buffer against activities that may degrade water quality and quantity within ponds

occupied by the turtle, and that the turtle potentially could traverse the ROW. The closest pond

where the red-bellied cooter has been observed historically, Crooked Pond (50 CFR 17.95), is

separated from the transmission line ROW by approximately 1500 ft of forested land. The

second closest pond where the turtle has been observed, Island Pond (50 CFR 17.95), is

separated from the ROW by approximately 1800 ft of forested land, residences, and roadway

(Long Pond Road) (FWS 1980).

In addition to the Vegetation Management Plan, NSTAR follows a program, developed in

coordination with and approved by the NHESP, to protect the northern red-bellied cooter and

other turtles that may be present in the transmission line ROW during maintenance activities

(NSTAR 2006). The northern red-bellied cooter has never been observed by NSTAR, Entergy,

or Boston Edison biologists in this transmission line ROW, and no other Federally or State-listed

endangered or threatened species is known or believed to occur in this transmission line ROW. 

Given that no expansion of existing facilities or disturbance of additional land associated with

the transmission line ROW is anticipated, this species is unlikely to be adversely affected during

the renewal period (FWS 2006).

Approximately 22 other rare species listed by the Commonwealth of Massachusetts may have

the potential to occur on the PNPS site or transmission line ROW based on the possible

presence of suitable habitat. However, because no expansion of existing facilities or

disturbance of additional land associated with the transmission line ROW is anticipated, if these

species were to occur in this area, it is unlikely that they would be adversely affected during the

renewal period. 

The staff reviewed information from the site audit, Entergy’s ER, other reports, information from |

the FWS and NHESP, and public comments received. The staff concluded that the impacts on |

Federally or State-listed terrestrial endangered, threatened, proposed, or candidate species of
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-66 July 2007

an additional 20 years of operation and maintenance of PNPS and associated transmission

| lines and ROW would be SMALL, and no additional mitigation would be warranted. Because

formal consultation is not required by the FWS, a BA was not developed to evaluate the

potential impacts of continued operation of PNPS on Federally listed terrestrial and freshwater

| aquatic species (FWS 2006).

4.7 Evaluation of New and Potentially Significant

Information on Impacts of Operations During the

Renewal Term

The NRC staff reviewed the discussion of environmental impacts in the GEIS and conducted its

| own independent review (including public comments received) to identify new and significant

information on environmental issues listed in 10 CFR Part 51, Subpart A, Appendix B, Table 

B-1, related to PNPS during the renewal term. Processes for identification and evaluation of

new and significant information are described in Section 1.2.2. Issues that were raised during

| scoping and public comment periods or through the staff’s independent review of other available

information are examined here to determine whether they represent new and significant

information.

| Of the 92 issues identified in the GEIS, the potential impact to aquatic habitat was not included. 

| The consultation requirements of Section 305(b)of the Magnuson-Stevens Fishery Conservation

| and Management Act, as amended by the Sustainable Fisheries Act of 1996, provide that

| Federal agencies must consult with the Secretary of Commerce on all actions or proposed

| actions authorized, funded, or undertaken by the agency that may adversely affect EFH. 

| Therefore, concurrent with issuance of the draft SEIS, the staff requested initiation of an EFH

| consultation with the NMFS. The EFH Assessment to support this consultation and NMFS’s

| correspondence concluding consultation are presented in Appendix E of this SEIS.

|

| A member of the public submitted a comment on the draft SEIS regarding the effects of

| continued operation of PNPS on aquatic habitat other than that designated as EFH. This

| comment, provided below, was determined to be a new and potentially significant issue.

|

| In the same way that there is concern for the EFH for fisheries determined by NOAA

| [National Oceanic and Atmospheric Administration] to require Management Plans

| pursu[ant] to the Magnuson-Stevens Act, so too should there be concern for the habitats

| essential to fish species that are experiencing precipitous population decline such as the

| Rainbow smelt, Alewife and Blueback herring, among others – the cumulative impact

| resulting from the plant impingement and entrainment on water quality, temperature and

| population abundance on these fish, and thus on long term survivability, was not

| adequately examined.

|
Environmental Impacts of Operation

July 2007 4-67 NUREG-1437, Supplement 29

In response to the comment, the staff evaluated the potential impacts to aquatic habitat in this |

section of the SEIS. The aquatic habitat in the vicinity of PNPS is described in Section 2.2.5.1. |

The PNPS cooling water system is described in section 2.1.3. |

|

Although the comment specifically expressed “concern for the habitats essential to fish species

that are experiencing precipitous population decline,” the staff decided that the potential impacts

on aquatic habitats throughout the entire local aquatic ecosystem should be addressed. Similar

to the method used by the staff to assess EFH, the staff applied the use of four metrics

(impingement, entrainment, discharge impacts, and food web impacts) in the assessment of

impacts on aquatic habitat. Based on this analysis, the staff has determined that continued

operation of the PNPS cooling water system would affect the aquatic habitat in the vicinity of

PNPS. However, this impact would be of SMALL significance, and ample aquatic habitat is

available in the immediate area and unaffected by PNPS operations.

As discussed in Section 4.3, radiation exposure issues for the license renewal term are

Category 1 issues. During the scoping process and during the public comment period, |

members of the public (1) expressed concern about the possible impacts on human health (e.g.,

cancer) from exposure to radiation from Pilgrim's effluents and (2) cited a number of documents

to support their concerns. The NRC reviewed these documents for potential new and significant

information regarding the Category 1 radiation exposure issues. 

Cancer is not rare; in fact, cancer is very common in the U.S. population. According to the |

American Cancer Society, more than a half million Americans die from cancer each year, an

average of more than 1500 people a day (ACS 2005). There are many possible causes and

risk factors for cancer, including radiation exposure. 

Although radiation may cause cancers at high doses and high dose rates, currently there are no

data that unequivocally establish the occurrence of cancer following exposure to doses below

10,000 millirem (mrem), received at low dose rates. However, radiation protection experts

conservatively assume that any amount of radiation may pose some risk of causing cancer or a

severe hereditary effect, and that the risk is higher for higher radiation exposures. Therefore, a

linear, no-threshold dose-response model is used to describe the relationship between radiation

dose and risks such as cancer induction. Simply stated, any increase in dose, no matter how

small, results in an incremental increase in health risks. This theory is accepted by the NRC as

a conservative model for estimating health risks from radiation exposure, recognizing that the

model probably overestimates those risks. According to the health risk estimates in

International Commission on Radiological Protection Publication 60 (ICRP 1990), the risk of

radiation exposure causing cancer is very low at doses below 10 mrem per year (mrem/yr).

Thousands of studies have been performed on the biological effects of radiation exposure. 

None of the scientifically valid studies show human health effects at acute doses less than |

10,000 mrem. Based on a consensus of the conclusions of national and international experts
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-68 July 2007

such as the National Council on Radiation Protection and Measurements and the International

Commission on Radiological Protection (ICRP), NRC and EPA have established conservative

dose limits for the protection of human health. In 40 CFR Part 190, EPA set a limit of 25

mrem/yr to the whole body of a member of the public from the entire nuclear fuel cycle,

including nuclear power plants. NRC established dose design objectives in 10 CFR Part 50,

Appendix I, to implement the EPA standards for radiological effluents from nuclear power plants.

In spring 2006, the National Research Council of the National Academies published, "Health

| Risks from Exposure to Low Levels of Ionizing Radiation, BEIR VII Phase 2" (NAS 2006). A

| prepublication version of the report was made public in June 2005. A number of comments

suggested that this report includes new and significant information that supports the concern

about the possible impacts on human health from exposure to radiation from PNPS effluents. 

The major conclusion of the BEIR VII report is that current scientific evidence is consistent with

the hypothesis that there is a linear, no threshold dose response relationship between exposure

to ionizing radiation and the development of cancer in humans. This conclusion is consistent

with the radiological protection model that the NRC uses to develop its regulations. Therefore,

the NRC’s regulations continue to adequately protect public health and safety and the

| environment. None of the findings in the BEIR VII report warrant immediate changes to the

| NRC regulations (NRC 2005). The BEIR VII report does not say there is no safe level of

exposure to radiation; it does not address "safe versus not safe." It does continue to support

the conclusion that there is some amount of cancer risk associated with any amount of radiation

exposure and that the risk increases with exposure and exposure rate. It does conclude that

the risk of cancer induction at the dose levels in the NRC’s and EPA’s radiation standards is

very small. Similar conclusions have been made in all of the associated BEIR reports since

| 1972 - BEIR I, III, and V (NAS 1972, NAS 1980, NAS 1990). 

Since the BEIR VII findings are consistent with the prior BEIR studies, which were previously

reviewed and found consistent with the bases of the current NRC regulations, the NRC staff

concludes that the BEIR VII Phase 2 report does not constitute new and significant information.

With regard to the potential human health effect of PNPS effluents, as discussed in Sections

2.1.4 and 2.2.7 of this SEIS, Entergy monitors the amounts of radionuclides released in the

effluents from Pilgrim to ensure compliance with these NRC regulations. Entergy also conducts

an environmental radiological monitoring program to confirm the expected levels of radioactive

| materials in the area around PNPS. Based on recent effluent release reports 

| (Entergy 2002, 2003, 2004, 2005, 2006c) the NRC staff expects the releases of radioactive

material from Pilgrim to be well within regulations during the license renewal period and less

| than 10 mrem/yr to the maximally exposed member of the public. By comparison, the average

| dose of radiation in the United States from all sources including natural background and medical

| sources is approximately 360 mrem/yr (NRC 2007). Therefore, the additional dose to the
Environmental Impacts of Operation

(f) Personal communication between Richard L. Emch, Jr., Senior Project Manager, Office of Nuclear

Reactor Regulation, NRC; Charles R. Flynn, Senior Health Physicist, Earth Tech USA, (NRC

Contractor); Susanne K. Condon, Director, Bureau of Environmental Health Assessment, Assistant

Commissioner, MDPH; and Robert Walker, Director, Radiation Control Program, MDPH; May 3,

2006.

July 2007 4-69 NUREG-1437, Supplement 29

maximally exposed member of the public from PNPS operations is less than 3 percent of the |

average annual background and medical dose to a member of the general public. |

The NRC inspects Entergy's radiological effluent and environmental radiological monitoring

programs at PNPS. In addition, Massachusetts Department of Public Health (MDPH) conducts

environmental radiological monitoring around PNPS. As part of the Pilgrim site audit, the NRC

staff met with officials of the MDPH to discuss the results of the MDPH radiological

environmental monitoring program around Pilgrim. MDPH indicated that the results of the

MDPH monitoring program have been consistent with the results from Entergy’s monitoring

program.(f) |

With regard to the possibility of a causal relationship between PNPS effluents and human

health, authors of various reports have suggested that statistical associations support a cause- |

and-effect relationship between cancer rates and reactor operations. While it is true that cancer |

rates vary among locations, it is very difficult to ascribe the cause of a cluster of cancers to

some local environmental exposure, such as radiation from a nuclear power facility. Statistical

association alone does not prove causation, and well-established scientific methods must be

used to determine that for two things that appear to be associated over time, it can be

concluded that one causes the other. For example, a person could say, “In the winter I wear

boots, and in the winter I get colds.” While there is a strong statistical association between

wearing boots and getting colds, it would be inappropriate to say that wearing boots causes

colds.

The scientific community adheres to several principles of good science that must be employed

before a cause-and-effect claim can be made. These principles include: whether the study can

be replicated; whether it has considered all the data or was selective (e.g., in the population or

in the years studied); whether it evaluated all possible explanations for the observations;

whether the data was valid and reliable; and whether its conclusions were subjected to

independent peer review, evaluation, and confirmation. 

A number of studies that conformed to these principles have been performed to examine the

health effects around nuclear power facilities:
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-70 July 2007

• National Cancer Institute – In 1990, at the request of Congress, the National Cancer

Institute conducted a study of cancer mortality rates around 52 nuclear power plants and 10

other nuclear facilities. The study covered the period from 1950 to 1984 and evaluated the

change in mortality rates before and during facility operations. The study concluded there

was no evidence that nuclear facilities may be linked causally with excess deaths from

leukemia or from other cancers in populations living nearby (NCI 1990 in NRC 2006a). 

• University of Pittsburgh – Investigators from the University of Pittsburgh found no link

between radiation released during the 1979 accident at the Three Mile Island nuclear station

and cancer deaths among nearby residents. For 20 years, their study followed over 32,000

people who lived within 8 kilometers (5 mi) of the facility at the time of the accident 

(UOP 2000 in NRC 2006a).

• Connecticut Academy of Sciences and Engineering – In January 2001, the Connecticut

Academy of Sciences and Engineering issued a report on a study around the Haddam Neck

Nuclear Power Plant in Connecticut and concluded that radiation emissions were so low as

to be negligible (CASE 2001 in NRC 2006a). 

• American Cancer Society – In 2004, the American Cancer Society concluded that although

reports about cancer clusters in some communities have raised public concern, studies

show that clusters do not occur more often near nuclear plants than they do by chance

elsewhere in the population. Likewise, there is no evidence that links the isotope strontium90 with increases in breast cancer, prostate cancer, or childhood cancer rates. Radiation

emissions from nuclear power plants are closely controlled and involve negligible levels of

exposure for nearby communities (ACS 2001 in NRC 2006a). 

• Florida Bureau of Environmental Epidemiology – In 2001, the Florida Bureau of

Environmental Epidemiology reviewed claims that there are striking increases in cancer

rates in southeastern Florida counties caused by increased radiation exposures from

nuclear power plants. However, using the same data to reconstruct the calculations on

which the claims were based, Florida officials were not able to identify unusually high rates

of cancers in these counties compared with the rest of the state of Florida and the nation

(FDOH 2001 in NRC 2006a).

• Illinois Public Health Department – In 2000, the Illinois Public Health Department compared

childhood cancer statistics for counties with nuclear power plants to similar counties without

nuclear plants and found no statistically significant difference (IPDH 2000, in NRC 2006a).

In summary, there are no studies to date that are widely accepted by the scientific community

that show a correlation between radiation dose from nuclear power facilities and cancer to the

general public. The amount of radioactive material released from nuclear power facilities is well

measured, well monitored, and known to be very small. The doses of radiation that are
Environmental Impacts of Operation

July 2007 4-71 NUREG-1437, Supplement 29

received by members of the public as a result of exposure to nuclear power facilities are so low

that resulting cancers have not been observed and would not be expected.

The scoping and public comments included citations that discussed the potential for impacts on |

human health from exposure to radiation from PNPS effluents. In these comments, a number of |

commenters expressed concern that operation of PNPS results in excess cancers in the

population around the plant site. Commenters cited the following documents in support of these

concerns:

• Clapp, R.W., Cobb, S., Chan, C.K., and B. Walker, 1987, Leukemia near Massachusetts |

nuclear power plant, Lancet (Dec 5): pgs. 1324-1325. |

• Clapp, R.W., 1992, Statement before the Southeastern Massachusetts Health Study Review |

Committee. |

• Clapp, R.W., 2006a, Analysis of 1974-1989 Massachusetts Cancer Registry for Leukemia |

and Thyroid Cancer, personal communication with Pilgrim Watch. |

• Clapp, R.W., 2006b, Analysis of 1998-2002 Massachusetts Cancer Registry for Leukemia |

and Thyroid Cancer, personal communication with Pilgrim Watch. |

• England, R.W., and E. Mitchell, 1987, Estimates of Environmental Accumulations of |

Radioactivity Resulting from Routine Operation of New England Nuclear Power Plants |

(1973-1984). A Report of the Nuclear Emission Research project, Whitemore School of |

Business and Economics, University of New Hampshire, Durham, New Hampshire. |

• Knorr, R.S., and M.S. Morris, 1996, The Southeastern Massachusetts Health Study |

(published in the Archives of Environmental Health, Volume 51, pg.266, July through August |

1996) |

• Land, W.T., unknown date, Meteorological Analysis of Radiation Releases for the Coastal |

Areas of the State of Massachusetts for June 3rd to June 20th 1982. |

• Morris, M.S., and R.S. Knorr, Southeastern Massachusetts Health Study. Final Report. |

Boston, MA: Bureau of Environmental Health Assessment, Massachusetts Department of |

Public Health; 1990. |

• National Research Council of the National Academies, 2006, Health Risks from Exposure to |

Low Levels of Ionizing Radiation, BEIR VII, Phase 2, Committee to Assess Health Effects |

from Exposure to Low Levels of Ionizing Radiation, National Academies Press, Washington, |

DC, pg. 406. |
Environmental Impacts of Operation

(g) This comment can be found in the Agency (ADAMS) under Accession No. ML070660326. It can also

be found in Appendix A of this document.

NUREG-1437, Supplement 29 4-72 July 2007

| • Russ, A., C. Burns, S. Tuler, and O. Taylor. 2006. Health Risks of Ionizing Radiation: An

| Overview of Epidemiological Studies. Community-Based Hazard Management, The George

| Perkins Marsh Institute. Clark University, Worcester, Massachusetts.

| Many of these comments referred to the Southeastern Massachusetts Health Study (SMHS). 

| The SMHS was conducted by investigators from the MDPH to determine if communities near

| PNPS in Plymouth, Massachusetts, had elevated leukemia incidence rates associated with

| radioactive plant discharges (Hoffman et al. 1992). The SMHS states that the “data support a

| finding of association between exposure potential to Pilgrim emissions and the risk of leukemia

| in adult cases diagnosed before 1984.” The final report, released to the public in October 1990,

| found a two- to four-fold increase in the risk of leukemia among residents of certain towns within

a 20-mi radius from the plant (Morris and Knorr 1990). 

| Six years after issuing the SMHS report, the authors published a paper in the Archives of

| Environmental Health about the SMHS (Knorr and Morris 1996). More recently, through the

public comment process on PNPS’s draft SEIS, the authors further clarified(g) | their position

| stating that: 

| “The MDPH report specifically states that it is not possible to reach definitive conclusions

| regarding cause and effect but that the results should be followed up to clarify their

| public health implications. This conclusion is consistent with that stated by the peer

| reviewers. While the findings of the study may not support a causal relationship, the

| NRC arguments in the Supplemental Impact Statement ignore the principal MDPH and

| peer review conclusions that the findings cannot be dismissed and that further attention

| to the possible risks associated with the power plant may be warranted”.

| The peer reviews (Sever et al. 1993; Hoffman et al. 1992; NRC NUREG/BR-0125 1992)

focused on several issues that do not support a causal relationship. The first issue is

temporality. There is a latency period of several years between radiation exposure and

leukemia incidence, and the short duration of the increased incidence of leukemia reported in

the study is inconsistent with the increase being radiation induced. The elevated incidence

disappeared just when it would have been approaching a maximum if it had been caused by

radiation exposure from PNPS. Second, the results of the study are inconsistent with the

results of the large body of evidence from studies conducted before and after the SMHS that are

widely accepted within the scientific community. Some of those studies, including the BEIR VII

report are discussed above; none of them showed an increase in leukemia incidence from low

radiation doses or proximity to nuclear power plants. Third, the level of radioactive material

released from PNPS and the resulting estimated doses met NRC’s rules and are well within
Environmental Impacts of Operation

July 2007 4-73 NUREG-1437, Supplement 29

NRC’s radiation standards. The SMHS did not actually estimate doses based on plant effluent

reports, but inferred that the doses to members of the public were much higher near the plant

than at distances in the range of 20 mi. This inference is not correct; there is almost no

difference (i.e., the last 5 years of effluent release reports show that the dose to the maximally

exposed person from PNPS operations is less than 3 percent of the average dose to the

general public 20-mi away) (Entergy 2002, 2003, 2004, 2005, 2006c; NRC 2007). Finally, the |

SMHS concluded that two-thirds of the leukemia cases near the plants were caused by

radiation. If this conclusion were true, the combined total of the radiation induced leukemia

cases and the normally expected number of non-radiation induced leukemia cases would have

been much higher than observed. 

NRC has considered the relevant information in these citations and concludes that the SMHS |

does not demonstrate a causal relationship between the PNPS effluents and the potential effect |

of excess cancers in the areas around the site. With regard to the rest of these citations, NRC |

finds that they also fail to overturn the large body of evidence from widely accepted studies

within the scientific community that find that the potential for this causality is not scientifically

plausible.

In the GEIS, radiation exposure to the public during the license renewal term was considered a

Category 1 issue (see Chapter 1 and Section 4.3 for a discussion of Category 1 issues and

radiological impacts from normal operations). The GEIS concluded that the risk to the public

from continued operation of a nuclear plant would not increase during the license renewal term.

Doses to members of the public from PNPS emissions were specifically evaluated in Appendix

E of the GEIS and were found to be well within the regulatory limits.

In summary, NRC's dose limits are conservative and supported by the EPA and international

agencies such as: ICRP, United Nations Scientific Committee on the Effects of Atomic

Radiation, and the European Commission on Radiation Protection. Review and evaluation of

new studies and analyses of the health effects of radiation exposure is an ongoing process at

the NRC. The scientifically defensible epidemiological studies on the biological effects of

ionizing radiation provide solid evidence that the current regulatory standards are protective of

human health. Entergy has demonstrated that releases from PNPS during the renewal period

are expected to be below regulatory limits (Entergy 2002, 2003, 2004, 2005, 2006c).

The NRC staff has reviewed the information within the documents referenced by the

commenters and finds that the information fails to demonstrate that the GEIS (as codified in |

10 CFR Part 51, Subpart A, Appendix B, Table B-1) regarding the human health impact of |

radiation exposure resulting from the operation of PNPS is incorrect. 

The staff concludes that the information provided during the scoping process was not new and

significant with respect to the findings of the GEIS.
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-74 July 2007

4.8 Cumulative Impacts

The staff considered the potential for cumulative impacts of operations of PNPS during the

renewal term. For the purposes of this analysis, past actions are those related to the resources

at and since the time of the plant licensing and construction, present actions are those related to

the resources at the time of current operation of the power plant, and future actions are

considered to be those that are reasonably foreseeable through the end of plant operation. 

Therefore, the analysis considers potential impacts through the end of the current license term

as well as the 20-year renewal license term. The geographical area over which past, present,

and future actions would occur is dependent on the resource evaluated and is described below

for each resource.

| The impacts of the proposed action, as described in previous sections of Chapter 4, are

combined with other past, present, and reasonably foreseeable future actions at PNPS

regardless of what agency (Federal or non-Federal) or person undertakes such other actions. 

These combined impacts are defined as “cumulative” in 40 CFR 1508.7 and include individually

| minor but collectively significant actions taking place over a period of time (CEQ 1997b). It is

possible that an impact that may be SMALL by itself could result in a MODERATE or LARGE

impact when considered in combination with the impacts of other actions on the affected

resource. Likewise, if a resource is regionally declining or imperiled, even a SMALL individual

impact could be important if it contributes to or accelerates the overall resource decline.

4.8.1 Cumulative Impacts on Marine Aquatic Resources

For the purposes of this analysis, the geographic area considered for impingement impacts on

| marine aquatic resources includes the Plymouth/Kingston/Duxbury areas and western Cape

Cod Bay. As discussed in Section 4.1, the staff found no new and significant information that

would indicate that the conclusions regarding any of the marine aquatic resources in the vicinity

of PNPS are inconsistent with the conclusions in the GEIS (NRC 1996). The staff has

| determined that the combined effects of entrainment and impingement would likely have

| MODERATE cumulative impacts on the local winter flounder population and on the Jones River

| population of rainbow smelt. Entrainment and impingement combined would likely have SMALL

| to MODERATE cumulative impacts on other marine aquatic species and habitat.

There is a variety of natural and anthropogenic factors that may influence biota in the area

surrounding PNPS, including fishing mortality, entrainment and impingement from PNPS and

| other water intakes, heat shock from PNPS and other thermal dischargers, contaminants,

environmental changes associated with regional increases in water temperature, habitat

| modification and loss, protected areas, and predator-prey interactions. In addition, changes to

| water and sediment quality from runoff, urbanization, and industrial activities may act as

stressors on the biological environment. To evaluate the impacts of these other stressors on
Environmental Impacts of Operation

July 2007 4-75 NUREG-1437, Supplement 29

biological communities in the area and in turn, be able to elucidate the cumulative impacts of

PNPS’s cooling system on the aquatic resources of Cape Cod Bay, the staff consulted with

State and Federal resource agencies, reviewed the applicants ER and other environmental

reports, conducted an independent search for other potential stressors in Cape Cod Bay, and |

considered public comments. |

Other activities that may affect marine aquatic resources in Cape Cod Bay include periodic

maintenance dredging, continued urbanization and development, and construction of new overwater or near-water structures, such as docks, and shoreline stabilization measures, such as

sheet pile walls, rip-rap, or other hard structures. For instance, it is likely that the harbors and

channels in the Plymouth/Kingston/Duxbury areas would require some dredging. However,

based on discussions with plant personnel, there are no plans for dredging of the intake

embayment or discharge canal at PNPS.

Cumulative impacts on the aquatic food web potentially could include reductions in the

abundance of important phytoplankton and zooplankton species in the vicinity due to their

entrainment in the cooling systems or from exposure to the heated discharges. This could

potentially lead to effects on other species in the food web. However, based upon the review

conducted by the NRC staff, there is no evidence that the operation of the PNPS cooling system

has had an impact on phytoplankton or zooplankton communities, or any resultant effects on

the aquatic food web, in Cape Cod Bay.

Impacts to fish and other macrobiota may include entrainment of small life stages, impingement |

of juvenile or adult forms, toxicity due to exposure to chemicals associated with the cooling

water discharge, or physiological or behavioral changes associated with exposure to the

discharge thermal plume. As discussed in Section 4.1, PNPS has a large degree of

ichthyoplankton entrainment and impingement (based on absolute numbers); however, this

impact was determined to be of moderate significance only for local populations of the winter

flounder. Because entrainment would have a MODERATE impact on the local winter flounder

population, cumulative impacts to the local winter flounder population would also be

MODERATE. Regarding rainbow smelt, due to high impingement rates, very low impingement

survivability, and declining population trends based on best available data for the Jones River

population, NRC staff concluded that cumulative impacts on the Jones River population of

rainbow smelt would be MODERATE. |

|

Cumulative impacts on the marine aquatic food web also could potentially occur as a result of |

reductions in the prey base of higher-trophic-level predators. If major reductions in Cape Cod |

Bay populations of forage fish, such as rainbow smelt, alewife, herring, menhaden, and |

silverside, resulted from mortality due to entrainment and/or impingement at PNPS, then |

predatory fish, as well as some bird species, dependent on these prey populations might be |

adversely affected. Although populations of some forage species, such as the rainbow smelt, |

have declined relative to historical levels, stocks of most forage species are relatively healthy. |
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-76 July 2007

| Predators typically are highly mobile, consume a variety of prey, and can adjust their prey

| selection based on availability. Thus, adverse effects on predator populations are unlikely in the

| absence of cumulative reductions in the populations of multiple forage species in the region.

| The review of fisheries impacts conducted by the NRC staff did not indicate that the operation of

| the PNPS cooling system has had a cumulative impact on the community of forage fish in Cape

| Cod Bay or the predatory species that depend upon them.

Other large-volume water intakes in Cape Cod Bay may also have a potentially significant

impact on aquatic resources. There are no other large-volume water intakes in the immediate

vicinity of PNPS; however, the Mirant Canal Station on Cape Cod Canal is another generating

| facility that withdraws water from and discharges water to Cape Cod Bay. 

Other sources of potentially significant impacts to aquatic resources include fishing pressure

(both commercial and recreational) and indirect impacts via loss of habitat (e.g., as a result of

| dredging, siltation, etc.). Cape Cod Bay and the Gulf of Maine support significant commercial

and recreational fisheries for many of the fish and invertebrate species potentially affected by

PNPS. Commercial and recreational fishing pressure may contribute to reduced stock sizes in

Cape Cod Bay. Impingement and entrainment impacts from PNPS may also contribute to

reduced stock sizes, in turn lowering the catch per unit effort for both commercial and

| recreational fishing. With the exception of winter flounder and rainbow smelt, most of the fish

| stocks potentially affected by PNPS are considered to be healthy or the levels of take by PNPS

are very minimal. 

| However, fishery regulations and protected areas may have beneficial impacts on fish and

| shellfish populations due to reduced fishing pressure in local areas. In fact, the PNPS exclusion

| zone in Cape Cod Bay has likely reduced fishing pressure on the American lobster and possibly

| other species relative to the fishing pressure in the area adjacent to PNPS before

| implementation of that security measure. An additional contributor to beneficial impacts is

| NMFS’s Ship Strike Reduction Strategy, which is designed to reduce vessel strikes of the

| endangered North Atlantic right whale; implementation of the Strategy’s measures would have

| positive effects on the North Atlantic right whale population in Cape Cod Bay.

Potential future environmental impacts include the loss of sensitive habitats, including coastal

marshes and submerged aquatic vegetation; continued non-point source impacts on the bay

from stormwater runoff and contaminated groundwater; and fishing mortality.

As described in Chapter 2, operation of the PNPS cooling system has not had a detectable

effect on water quality in Cape Cod Bay, and the staff determined that the impacts of continued

operation of the cooling water system on water quality would be classified as SMALL. Given the

large assimilative capacity of Cape Cod Bay and the fact that PNPS withdraws a relatively small

percentage of the net volumetric flow of water - generally less than 0.1 percent 
Environmental Impacts of Operation

July 2007 4-77 NUREG-1437, Supplement 29

(ENSR and MRI 2005), the cumulative impact of continued operation of the PNPS cooling

system on water quality would be SMALL. It is also expected that operation of the PNPS |

cooling system would not appreciably contribute to the cumulative impacts on the surface water

supply. 

Potential or proposed projects in the area that may impact aquatic habitat include: dredging for

the Plymouth Harbor Federal Navigation Project by the U.S. Army Corps of Engineers; the filling

of 26 ac within Plymouth Bay by the Town of Plymouth; the construction of a pile-supported,

fixed pier and floating docks in the Federal anchorage in Plymouth Harbor; dredging to

reestablish the entrance to Ellisville Harbor in Plymouth; and the ability to retain and maintain

the Cordage Park Marina in Plymouth Bay (USACE 2006). 

There is a potential for MODERATE cumulative impacts on local populations of winter flounder

and rainbow smelt, but the cumulative impacts of continued operation of PNPS on other marine

aquatic resources is expected to be SMALL to MODERATE.

4.8.2 Cumulative Impacts on Terrestrial and Freshwater Resources

This section analyzes past, present, and future actions that could result in adverse cumulative

impacts to terrestrial resources such as wildlife populations, the size and distribution of habitat

areas, and aquatic resources such as streams, wetlands and floodplains. For purposes of this

cumulative effects analysis, the geographic area considered in the evaluation includes the Town

of Plymouth, which contains the PNPS site and its associated transmission line ROW.

The transmission line ROW does not cross any State or Federal parks, wildlife refuges, or

wildlife management areas (Entergy 2006a), nor does it cross any major lakes, ponds, or

streams but does cross one small stream. NSTAR, the owner of the transmission lines, follows

ROW management procedures that were found to be protective of sensitive ecological |

resources, including wildlife habitat, wetlands, and floodplains. The maintenance procedures

minimize disturbance of wildlife and wetlands and prevent potential off-site effects, such as

erosion, on surrounding areas with other land uses.

Maintenance and operation of the transmission system are not expected to destabilize or

noticeably alter the existing terrestrial or freshwater aquatic environment. Likewise, operation of

PNPS is not likely to have a detectable effect on terrestrial or freshwater aquatic species

located in the vicinity of the PNPS site or the transmission line ROW. No other Federal or nonFederal activities have been identified that would have an adverse effect on terrestrial and

freshwater aquatic species in the area. The staff concludes that the incremental contribution to

cumulative impacts on terrestrial and freshwater aquatic resources resulting from continued

operation of PNPS and its associated transmission line ROW would be SMALL, and that no

additional mitigation would be warranted.

4.8.3 Cumulative Human Health Impacts
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-78 July 2007

The EPA and NRC have developed radiological dose limits for protection of the public and

workers to address the cumulative impact of acute and long-term exposure to radiation and

radioactive material. These dose limits are codified in 40 CFR Part 190 and 10 CFR Part 20. 

For the purpose of this analysis, the area within a 50-mi radius of the PNPS site was included. 

As stated in Section 2.2.7, a radiological environmental monitoring program (REMP) has been

conducted around the PNPS site since 1968 with the results presented annually in the PNPS

| REMP Report (Entergy 2002, 2003, 2004, 2005, 2006c). Although no other nuclear fuel cycle

operations are located within the subject area, the REMP measures radiation and radioactive

materials from all sources, including natural background. Monitoring results for the 5-year

period from 2001 through 2005 were reviewed as part of the cumulative impacts assessment. 

Additionally, in Sections 2.2.7 and 4.3, the staff concluded that impacts of radiation exposure to

the public and workers (occupational) from operation of PNPS during the renewal term would be

SMALL. Therefore, the monitoring program and staff's conclusion considered cumulative

impacts. The NRC and the Commonwealth of Massachusetts would regulate any future

actions in the vicinity of the PNPS site that could contribute to cumulative radiological impacts.

The staff determined that the electric field induced currents from the PNPS transmission lines

are well below the National Electrical Safety Code (NESC) recommendations for preventing

electric shock from induced currents. Therefore, the PNPS transmission lines do not detectably

affect the overall potential for electric shock from induced currents within the analysis area. 

With respect to chronic effects of electromagnetic fields, although the NRC staff considers the

GEIS finding of “not applicable” to be appropriate in regard to PNPS, the PNPS transmission

lines are not likely to detectably contribute to regional exposure to extremely low frequency

electromagnetic fields (ELF-EMFs). The PNPS transmission lines pass through a sparsely

populated, rural area with very few residences or businesses close enough to the lines to have

detectable ELF-EMFs.

Therefore, the staff concludes that cumulative radiological impacts of continued operations of

PNPS would be SMALL, and that no further mitigation measures are warranted.

4.8.4 Cumulative Socioeconomic Impacts

The continued operation of PNPS is not likely to result in significant cumulative impacts for any

of the socioeconomic impact measures assessed in Section 4.4 of this SEIS (public services,

housing, and off-site land use). This is because operating expenditures, staffing levels, and

local tax payments during renewal would be similar to those during the current license period. 

Similarly, the proposed action is not likely to result in significant cumulative impacts on historic

and archaeological resources.

When combined with the impact of other potential activities likely to occur in the area

surrounding the plant, socioeconomic impacts resulting from PNPS license renewal would not

produce an incremental change in any of the impact measures used. The staff therefore

determined that the impacts on employment, personal income, housing, local public services,
Environmental Impacts of Operation

July 2007 4-79 NUREG-1437, Supplement 29

utilities, and education occurring in the local socioeconomic environment as a result of license

renewal activities, in addition to the impacts of other potential economic activity in the area,

would be SMALL. The staff determined that the impact on off-site land use would be SMALL

because no refurbishment activities are planned at PNPS, and no new incremental changes to

plant-related tax payments are expected that could influence land use by fostering considerable

growth. The impacts of license renewal on transportation and environmental justice would also

be SMALL. There are no reasonably foreseeable scenarios that would alter these conclusions

in regard to cumulative impacts.

There are no archeological or historic above ground resources eligible for listing on the National

Register of Historic Places identified on the PNPS site. The staff has concluded that the

impacts of license renewal on historic and archaeological resources would be SMALL. The

continued operation and maintenance of the PNPS site and the transmission line corridor would

not be expected to impact any properties beyond the site or transmission corridor boundaries. 

Therefore, the contribution to a cumulative impact on historic and archaeological resources

would be negligible.

Based on this analysis, the staff concludes that the cumulative impact to socioeconomic

resources resulting from continued operation of PNPS during the license renewal period would

be SMALL, and no additional mitigation measures are warranted.

4.8.5 Cumulative Impacts on Groundwater Use and Quality

PNPS groundwater use is less than 100 gpm. The Town of Plymouth public water supply

system, which provides water to PNPS for its potable and reactor make-up water needs, obtains

its water from local groundwater. There are no operable groundwater production wells at

PNPS. The applicant is not proposing an increase in demand of groundwater well usage during

the renewal period. As demand for water supplies increases in the vicinity of PNPS, additional

withdrawals of groundwater may be involved to satisfy the water needs of other water users in

the region. However, Entergy does not anticipate a need for additional workers during the

license renewal period. Renewal of the PNPS OL would not increase the population of the

two-county area where most of the existing PNPS employees currently live and, therefore,

would not increase the demand for groundwater. 

On the basis of this analysis, the staff concludes that the cumulative impact to groundwater

resources during the license renewal period would be SMALL and no additional mitigation

measures would be warranted. |

4.8.6 Cumulative Impacts on Threatened and Endangered Species

The geographic area considered in the analysis of potential cumulative impacts to threatened or

endangered species includes the Town of Plymouth, which contains the PNPS site and its
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-80 July 2007

associated transmission line ROW, and the waters of Cape Cod Bay in the vicinity of the PNPS

site. As discussed in Sections 2.2.5 and 2.2.6, a number of threatened or endangered species

could occur within this area, including both terrestrial and aquatic species. The staff's findings,

presented in the Biological Assessment [for marine aquatic species only (see Appendix E)] and

in Section 4.6, are that continued operation of PNPS and maintenance of its associated

transmission line ROW during the license renewal term would have no effect, or would not likely

adversely affect, any Federally listed species or any designated critical habitat. No other

Federal or non Federal activities have been identified that would have an adverse effect on any

Federally threatened or endangered species in the area. However, NMFS’s Ship Strike

Reduction Strategy is designed to reduce vessel strikes of the endangered North Atlantic right

whale; implementation of the Strategy’s measures would have positive effects on the North

| Atlantic right whale in Cape Cod Bay. Therefore, the staff concludes that the contribution of

PNPS operations to cumulative impacts on Federally protected species or designated critical

| habitat would be SMALL, and no additional mitigation would be warranted.

4.8.7 Conclusions Regarding Cumulative Impacts

The NRC staff considered the potential impacts resulting from the operation of PNPS and

| maintenance of the transmission line ROW since PNPS was constructed and went on line

through the end of the license renewal term and resulting from other past, present, and future

actions in the vicinity of PNPS. The staff’s determination is that the cumulative impacts resulting

from the incremental contribution of PNPS operation and maintenance of transmission line

ROW would be SMALL for all resources with the exception of marine aquatic species, which

would experience SMALL to MODERATE cumulative impacts.

4.9 Summary of Impacts of Operations During the

Renewal Term

Neither Entergy nor the NRC staff is aware of information that is both new and significant

related to any of the applicable Category 1 issues associated with the PNPS operation during

the renewal term. Consequently, the staff concludes that the environmental impacts associated

with these issues are bounded by the impacts described in the GEIS. For each of these issues,

the GEIS concluded that the impacts would be SMALL and that additional plant-specific

mitigation measures are not likely to be sufficiently beneficial to warrant implementation.

Plant-specific environmental evaluations were conducted for 11 Category 2 issues applicable to

PNPS operation during the renewal term and for environmental justice and chronic effects of

electromagnetic fields. For 8 issues and environmental justice, the staff concluded that the

potential environmental impact of renewal term operations of PNPS would be of SMALL

significance in the context of the standards set forth in the GEIS and that additional mitigation

| would not be warranted. For impacts on the local winter flounder population due to entrainment,

the staff’s conclusion is that the impacts would be MODERATE. Also, impacts on the Jones
Environmental Impacts of Operation

July 2007 4-81 NUREG-1437, Supplement 29

River population of rainbow smelt due to impingement would be MODERATE. Impacts due to

entrainment and impingement on other marine fish and shellfish resources would be SMALL to |

MODERATE. Impacts on marine mammals and aquatic habitat would be SMALL. Potential |

mitigation measures are discussed in Section 4.1.4. In addition, the staff determined that a

consensus has not been reached by appropriate Federal health agencies regarding chronic

adverse effects from electromagnetic fields. Therefore, the staff did not conduct an evaluation

of this issue.

Cumulative impacts of past, present, and reasonably foreseeable future actions were

considered, regardless of what agency (Federal or non-Federal) or person undertakes such

other actions. The staff concluded that cumulative impacts of PNPS license renewal would be

SMALL for all potentially affected resources, with the exceptions of the local winter flounder

population and rainbow smelt population, for which impacts would be MODERATE, and other

marine aquatic species, for which impacts would be SMALL to MODERATE. 

4.10 References

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for

Protection Against Radiation."

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 20, "Domestic Licensing

of Production and Utilization Facilities.”

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property,

Part 800, “Protection of Historic Properties.”

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190,

“Environmental Radiation Protection Standards for Nuclear Power Operation.”

American Cancer Society (ACS). 2001. 1998 Facts & Figures. Environmental Cancer Risks.

Accessed at: http://www.cancer.org/statistics/cff98/enviromental.html on August 28, 2006.

American Cancer Society (ACS). 2005. Cancer Facts and Figures, 2005.

Atlantic States Marine Fisheries Commission (ASMFC). 2006a. ASMFC Stock Status |

Overview. Atlantic States Marine Fisheries Commission. August 2006. 
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-82 July 2007

| Atlantic States Marine Fisheries Commission (ASMFC). 2006b. 2006 Stock Assessment

Report for Atlantic Menhaden. Prepared by the Atlantic Menhaden Technical Committee for the

| Atlantic Menhaden Management Board. September 2006. Accessed at:

http://www.asmfc.org/speciesDocuments/menhaden/reports/stockAssessments/2006StockAsse

ssment Report.pdf on April 13. 2007.

| Atlantic States Marine Fisheries Commission (ASMFC). 2006c. ASFMC Stock Status

| Overview. December 2006. Accessed at:

http://www.asmfc.org/speciesDocuments/asmfcStockStatusPacket.pdf on April 13, 2007.

Atomic Energy Commission (AEC). 1972. Final Environmental Statement related to operation

of Pilgrim Nuclear Power Station, Boston Edison Company, May 1972.

Beyers, D.W. and J.A. Rice. 2002. Evaluating Stress in Fish Using Bioenergetics-Based

Stressor-Response Models. Chapter 8 in Biological Indicators of Aquatic Ecosystem Stress,

S.M Adams, ed. American Fisheries Society.

Chase, B. 2006. Massachusetts Division of Marine Fisheries. August 16, 2006.

Clapp, R.W., Cobb, S., Chan, C.K., and B. Walker, 1987. Leukemia near Massachusetts

| nuclear power plant, Lancet (December 5): pgs. 1324-1325.

Clapp, R.W., 1992. Statement before the Southeastern Massachusetts Health Study Review

Committee.

| Clapp, R.W., 2006a. Analysis of 1974-1989 Massachusetts Cancer Registry for Leukemia and

Thyroid Cancer.

| Clapp, R.W., 2006b. Analysis of 1998-2002 Massachusetts Cancer Registry for Leukemia and

Thyroid Cancer.

Clay, C.H. 1995. Design of Fishways and Other Fish Facilities. 2nd Edition. CRC Press, Inc. 

Connecticut Academy of Science and Engineering (CASE). 2001. Bulletin of the Connecticut

Academy of Science and Engineering, Volume 16.2. Spring 2001.

| Council on Environmental Quality (CEQ). 1997a. Environmental Justice: Guidance Under the

| National Environmental Policy Act. Executive Office of the President, Washington, DC.

| Council on Environmental Quality (CEQ). 1997b. Considering Cumulative Impacts Under the

| National Environmental Policy Act. Executive Office of the President, Washington, DC.

January 1997.
Environmental Impacts of Operation

July 2007 4-83 NUREG-1437, Supplement 29

Earth Tech. 2006a. Meeting minutes for site audit meeting with EPA Region 1, Massachusetts

Coastal Zone Management, Department of Environmental Protection, and Division of Marine

Fisheries. May 3, 2006.

Earth Tech. 2006b. Meeting minutes for meeting with National Marine Fisheries Service. |

May 16, 2006. |

EG&G Global Environmental and Ocean Services. (EG&G). 1995. Pilgrim Nuclear Power

Station Cooling Water Discharge Bottom Temperature Study, August, 1994. Final Report to

Boston Edison Company, Plymouth, Massachusetts, June 1995.

Electric Power Research Institute (EPRI). 1982. Transmission Line Reference Book: 345kV

and Above. 2nd Edition. Palo Alto , California. 1982. |

Electric Power Research Institute (EPRI). 2006. Laboratory Evaluation of Modified Ristroph |

Traveling Screens for Protecting Fish at Cooling Water Intakes. Report - Product Number

000000000001013238, June 2006. Accessed at:

http://www.epri.com/OrderableitemDesc.asp?product_id=000000000001013238&search

on August 10, 2006.
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-84 July 2007

England, R.W., and E. Mitchell. 1987. Estimates of Environmental Accumulations of

Radioactivity Resulting from Routine Operation of New England Nuclear Power Plants (1973-

1984), A Report of the Nuclear Emission Research project, Whitemore School of Business and

Economics, University of New Hampshire, Durham, New Hampshire.

ENSR Corporation (ENSR). 2000. Redacted Version, 316 Demonstration Report - Pilgrim

Nuclear Power Station. Prepared by Entergy Nuclear Generation Company. March 2000.

ENSR Corporation (ENSR) and Marine Research, Inc. (MRI). 2000. Study of Winter Flounder

Larval Transport in Coastal Cape Cod Bay and Entrainment at Pilgrim Nuclear Power Station. 

Prepared for Entergy Nuclear Generating Company. Document Number 8734-188-300. 

November 2000.

ENSR Corporation (ENSR) and Marine Research, Inc. (MRI). 2002. Study of Winter Flounder

Larval Transport in Coastal Cape Cod Bay and Entrainment at Pilgrim Nuclear Power Station. 

Prepared for Entergy Nuclear Generating Company. Document Number 08734-737-600. 

December 2002.

ENSR Corporation (ENSR) and Marine Research, Inc. (MRI). 2005. Study of Winter Flounder

Larval Transport in Coastal Cape Cod Bay and Entrainment at Pilgrim Nuclear Power Station,

Spring 2004. Contained in Marine Ecology Studies, Pilgrim Nuclear Power Station, Report

| Number 65, January 2004 through December 2004. Environmental Protection Group, Enter

Nuclear-Pilgrim Station. April 30, 2005. 

|

| Entergy Nuclear Operations, Inc. (Entergy). 2002. Radiological Effluent and Waste Disposal

| Report, January 1 through December 31, 2001.

|

| Entergy Nuclear Operations, Inc. (Entergy). 2003. Radiological Effluent and Waste Disposal

| Report, January 1 through December 31, 2002.

| Entergy Nuclear Operations, Inc. (Entergy). 2004. Radiological Effluent and Waste Disposal

| Report, January 1 through December 31, 2003.

| Entergy Nuclear Operations, Inc. (Entergy). 2005. Radiological Effluent and Waste Disposal

| Report, January 1 through December 31, 2004.

Entergy Nuclear Operations, Inc. (Entergy). 2006a. Applicant’s Environmental report,

| Operating License Renewal Stage, Pilgrim Nuclear Power Station, Docket Number 50-293,

| License Number DPR-35. January 2006.
Environmental Impacts of Operation

July 2007 4-85 NUREG-1437, Supplement 29

Entergy Nuclear Operations, Inc. (Entergy). 2006b. Marine Ecology Studies, Pilgrim Nuclear

Power Station, Report Number 67, January through December, 2005. Environmental Protection |

Group, Entergy Nuclear-Pilgrim Station. April 30, 2006.

Entergy Nuclear Operations, Inc. (Entergy). 2006c. Radiological Effluent and Waste Disposal |

Report, January 1 through December 31, 2005. |

Entergy Nuclear Operations, Inc. (Entergy). 2006d. Environmental Reviews and Evaluations, |

EN-EV-115. May 2, 2006.

Environmental Protection Agency (EPA). 1994. Modification of Authorization to Discharge

Under the National Pollutant Discharge Elimination System. Federal Permit Number

MA0003557. Modification No. 1. Issued August 30, 1994. Water Management Division, EPA |

Region I, Boston, Massachusetts.

|

Environmental Protection Agency (EPA). 2004. “National Pollutant Discharge Elimination |

System - Final Regulations to Establish Requirements for Cooling Water Intake Structures at

Phase II Existing Facilities, Final Rule.” Federal Register, Volume 69, Number 131, |

pgs. 51575 - 41624. Washington DC July 9, 2004. |

Environmental Protection Agency (EPA). 2007. Implementation of the Decision in Riverkeeper |

Inc. v. EPA, Remanding the Cooling Water Intake Structures Phase II Regulations. March 20, |

2007. |

Executive Order 12898. “Federal Actions to Address Environmental Justice in Minority

Populations and Low-Income Populations.” Federal Register, Volume 59, Number 32, |

Washington DC, February 16, 1994. |

Fahay, M.P., P.L. Berrien, D.L. Johnson, and W.W. Morse. 1999. Essential Fish Habitat

Source Document: Atlantic Cod, Gadus morhua, Life History and Habitat Characteristics. 

NOAA Technical Memorandum NMFS-NE-124. September 1999a. 

Federal Water Pollution Control Act of 1977. 33 USC 1326, et seq. [Also known as the Clean

Water Act (CWA)].

Fish and Wildlife Service (FWS). 1980. Endangered and Threatened Wildlife and Plants; Listing

as Endangered with Critical Habitat for the Plymouth Red-Bellied Turtle in Massachusetts, Final

Rule. 50 CFR Part 17, Federal Register, Volume 45, Number 65, |

pgs. 21828 – 21833. April 2, 1980. |

Fish and Wildlife Service (FWS). 2006. Letter from Michael J. Amaral, Endangered Species

Specialist, New England Field Office, US FWS, to Rani Franovich, NRC. Response to April 25,
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-86 July 2007

2006 letter from NRC requesting information on protected, proposed, and candidate species

and critical habitat in the vicinity of PNPS and its transmission line right-of-way. May 23, 2006.

Florida Department of Health (FDOH). 2001. Report Concerning Cancer Rate in Southeastern

Florida. Bureau of Environmental Epidemiology, Division of Environmental Health. Tallahassee,

Florida. July 17, 2001.

Goodyear, C.P. 1978. Entrainment Impact Estimates Using the Equivalent Adult Approach. 

U.S. Fish and Wildlife Service. FWS/OBS-78/65, July 1978. 

Hoffman, D., J.L. Lyon, F. Masse, H. Pastides, D. Sandler, and D. Trichopoulos. 1992. A

review of the Southeastern Massachusetts Health Study, submitted to the Commissioner of

Public Health, October 1992.

| Illinois Public Department of Health (IPDH). 2000. Health and Hazardous Substances Registry

Newsletter, Illinois Department of Public Health, Division of Epidemiologic Studies, Illinois

Department of Public Health. Springfield, Illinois. Fall 2000.

International Commission on Radiological Protection (ICRP). 1990. Recommendations of the

International Commission on Radiological Protection - Annals of the ICRP, Volume 21/1-3. 

Publication 60: 1990.

Knorr, R.S., and M.S. Morris. 1996. “The Southeastern Massachusetts Health Study.” Archives

| of Environmental Health. 51: pg. 266.

Land, W.T., unknown date. Meteorological Analysis of Radiation Releases for the Coastal

Areas of the State of Massachusetts for June 3rd to June 20th 1982.

Lawton, R.P., C. Sheehan, T. Currier, P. Brady, M. Borgatti, V. Malkoski, and S. Correia. 1986.

Final Report on Dissolved Gas Saturations in the Inshore Marine Waters of Cape Cod Bay and

Incidents of Gas Bubble Disease at Pilgrim Nuclear Power Station, 1973-1985. Pilgrim Nuclear

| Power Station Marine Environmental Monitoring Program Report Series Number 1. Boston

Edison Company.

Lawton, R., P. Brady, C. Sheehan, S. Correia, and M. Borgatti. 1990. Final Report on

Spawning Sea-Run Rainbow Smelt (Osmerus mordax) in the Jones River and Impact

Assessment of Pilgrim Station on the Population, 1979-1981. Pilgrim Nuclear Power Station

| Marine Environmental Monitoring Program Report Series Number 4. Boston Edison Company.

Lawton, R., B. Kelly, J. Boardman, and V. Malkoski. 1999a. Annual Report on Assessment and

Mitigation of Impact of the Pilgrim Nuclear Power Station on Finfish Populations in Western

| Cape Cod Bay. Project Report Number 66 (January through December 1998). Massachusetts
Environmental Impacts of Operation

July 2007 4-87 NUREG-1437, Supplement 29

Department of Fisheries, Wildlife, and Environmental Law Enforcement, Division of Marine

Fisheries. Boston, Massachusetts. April 1999. Marine Ecology Studies Related to Operation of

Pilgrim Station. Semi-annual Report Number 53, Report Period: January 1998 through |

December 1998. Regulatory Affairs Department, Boston Edison Company, Plymouth,

Massachusetts. April 30, 1999. 

Lawton, R. and J. Boardman. 1999b. Final Report on Rainbow Smelt (Osmerus mordax)

Restoration Efforts in the Jones River, 1994-1999. Pilgrim Nuclear Power Station Marine

Environmental Monitoring Program Report Series Number 8. Entergy Nuclear Generation |

Company. 

Lawton, R, B. Kelly, P. Nitschke, J. Boardman, and V. Malkoski. 2000a. Final Report , Studies

(1990-1997) and Impact Assessment of Pilgrim Station on Cunner in Western Cape Cod Bay.

Pilgrim Nuclear Power Station Marine Environmental Monitoring Program Report Series

Number 9. Entergy. January 2000. |

Lawton, R., V. Malkoski, B. Kelly, J. Boardman, M. Camisa. 2000b. Final Report: Winter

Flounder (Psedopleuronectes americanus) Studies (1993-1999) in Relation to Impact

Assessment of Pilgrim Station on the Local Population. Department of Fisheries, Wildlife, and

Environmental Law Enforcement, Massachusetts Division of Marine Fisheries. Pocasset, |

Massachusetts. March 2000. Pilgrim Nuclear Power Station Marine Environmental Monitoring

Program Report Series Number 10. Entergy. March 2000. |

Marine Research, Inc. (MRI). 2005a. Winter Flounder Area-Swept Estimate, Western Cape

Cod Bay 2005. Contained in Marine Ecology Studies, Pilgrim Nuclear Power Station, Report

Number 67, January through December, 2005. Environmental Protection Group, Entergy |

Nuclear-Pilgrim Station. April 30, 2006.

Marine Research, Inc. (MRI). 2005b. Ichthyoplankton Entrainment Monitoring at Pilgrim

Nuclear Power Station, January through December 2004. Marine Ecology Studies, Pilgrim |

Nuclear Power Station, Report Number 65, January through December, 2004. Environmental |

Protection Group, Entergy Nuclear-Pilgrim Station. April 30, 2005.

Marine Research, Inc. (MRI). 2006. Hatchery Production Study, Young-of-the-Year Winter

Flounder Post-Release Collections, 2000-2005. Marine Ecology Studies, Pilgrim Nuclear Power

Station, Report Number 67, January through December, 2005. Environmental Protection |

Group, Entergy Nuclear-Pilgrim Station. April 30, 2006.

Massachusetts Office of Coastal Zone Management (MOCZM). 2006. Shoreline Change |

Project, Shoreline Change Browser. Accessed at: |

http://maps.massgis.state.ma.us/coastlinechange/pages/main.jsp on September 13, 2006. |
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-88 July 2007

| Massachusetts Division of Marine Fisheries (MDMF). 2004. A Survey of Anadromous Fish

| Passage in Coastal Massachusetts: Part 3. South Shore. Technical Report TR-16. May 2004.

|

| Massachusetts Division of Marine Fisheries (MDMF). 2006. Species Profile: Rainbow Smelt. 

| Accessed at http://www.mass.gov/dfwele/dmf/recreationalfishing/smelt.htm on April 26, 2007.

| Morris, M.S. and R.S. Knorr. 1990. Southeastern Massachusetts Health Study. Final Report.

Bureau of Environmental Health Assessment, Massachusetts Department of Public Health,

Boston, Massachusetts.

National Academy of Sciences (NAS). 1972. The Effects on Populations of Exposure to Low

Levels of Ionizing Radiation – BEIR I. Advisory Committee on the Biological Effects of Ionizing

Radiation. Washington, DC.

National Academy of Sciences (NAS). 1980. The Effects on Populations of Exposure to Low

Levels of Ionizing Radiation – BEIR III. Committee on the Biological Effects of Ionizing

Radiation. Division of Medical Sciences. National Research Council. National Academy Press. 

Washington, DC.

National Academy of Sciences (NAS). 1990. Health Effects of Exposure to Low Levels of

Ionizing Radiation – BEIR V. Board on Radiation Effects Research, Commission on Life

| Sciences. National Research Council. National Academy Press. Washington, DC.

| National Academy of Sciences (NAS). 2006. Health Effects of Exposure to Low Levels of

| Ionizing Radiation – BEIR VII. Board on Radiation Effects Research, Commission on Life

| Sciences. National Research Council. National Academy Press. Washington, DC.

National Cancer Institute (NCI). 1990. Cancer in Populations Living Near Nuclear Facilities.

Bethesda, Maryland.

National Electrical Safety Code (NESC). 1997. Institute of Electrical and Electric Engineers,

New York.

|

| National Environmental Policy Act of 1696, as amended (NEPA). 42 USC 4321 et seq.

National Historic Preservation Act of 1966, as amended (NHPA). 16 USC 470, et seq.

National Institute of Environmental Health Sciences (NIEHS). 1999. “NIEHS Report on Health

Effects from Exposure to Power Line Frequency and Electric and Magnetic Fields.” Publication

| Number 99-4493, Research Triangle Park, North Carolina.
Environmental Impacts of Operation

July 2007 4-89 NUREG-1437, Supplement 29

National Marine Fisheries Service (NMFS). 2006. Letter in Response to Request for

Information on Essential Fish Habitat and Protected Species. June 8, 2006.

National Marine Fisheries Service (NMFS). 2007. Forecast for the 2007 Gulf and Atlantic |

Menhaden Purse-Seine Fisheries and Review of the 2006 Fishing Season. Population

Dynamics Branch, MNFS-Beaufort, National Oceanic and Atmospheric Administration. 

Accessed at: http://www.st.nmfs.gov/st1/market_news/menhaden_forecast_2007.pdf 

on April 13, 2007.

|

Natural Heritage and Endangered Species Program (NHESP). 1988. Massachusetts Rare and

Endangered Wildlife: Roseate Tern, Sterna dougallii. Rare species fact sheet. Accessed at: |

www.mass.gov/dfwele/dfw/nhesp/nhspecies.htm on August 8, 2006.

Natural Heritage and Endangered Species Program (NHESP). 1990. Massachusetts

Threatened Species: Piping Plover, Charadrius melodus. Rare species fact sheet. Accessed |

at: www.mass.gov/dfwele/dfw/nhesp/nhspecies.htm on August 8, 2006.

Natural Heritage and Endangered Species Program (NHESP). 1995. Massachusetts

Endangered Species: Plymouth Redbelly Turtle, Pseudemys rubriventris. Rare species fact

sheet. Accessed at: www.mass.gov/dfwele/dfw/nhesp/nhspecies.htm on August 8, 2006. |

Natural Heritage and Endangered Species Program (NHESP). April 2005. Species

Conservation. Rare species fact sheet. Accessed at:

www.mass.gov/dfwele/dfw/nhesp/nhspecies.htm on August 8, 2006.

Natural Heritage and Endangered Species Program (NHESP). 2006. Changes to the

Massachusetts List of Endangered, Threatened, & Special Concern Species. May 24 2006. |

Accessed at: www.mass.gov/dfwele/dfw/nhesp/heritage2.htm on August 2, 2006.

|

Nitschke P., R. Brown, and L. Hendrickson. 2000. Status of Fisheries Resources off

Northeastern United States – Winter Flounder. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/fldrs/winter/ on August 8 2006. 

Normandeau Associates, Inc. 1977. (Normandeau). Thermal Surveys of Backwashing

Operations at Pilgrim Station during July 1977. August 1977. Conducted for Boston Edison

Company, Boston, Massachusetts. 

Normandeau Associates. 2006a. (Normandeau). Ichthyoplankton Entrainment Monitoring at

Pilgrim Nuclear Power Station, January through December 2005. Marine Ecology Studies, |

Pilgrim Nuclear Power Station, Report Number 67, January through December, 2005. |

Environmental Protection Group, Entergy Nuclear-Pilgrim Station. April 30, 2006.
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-90 July 2007

Normandeau Associates. 2006b. (Normandeau). Impingement of Organisms on the Intake

| Screens at Pilgrim Nuclear Power Station, January through December 2005. Marine Ecology

| Studies, Pilgrim Nuclear Power Station, Report Number 67, January through December, 2005. 

Environmental Protection Group, Entergy Nuclear-Pilgrim Station. April 30, 2006

Northeast Fisheries Science Center (NEFSC) 2003. A Report of the 36th | Northeast Regional

Stock Assessment Workshop (36th | SAW): Public Review Workshop. Northeast Fisheries

| Science Center, Woods Hole, Massachusetts. Reference Document 03-04. February 2003.

Northeast Fisheries Science Center (NEFSC). 2005. Assessment of 19 Northeast Groundfish

Stocks through 2004. 2005 Groundfish Assessment Review Meeting (2005 GARM), Northeast

Fisheries Science Center, Woods Hole, Massachusetts. 15-19 August 2005. NEFSC Reference

Document 05-13. September 2005.

Northeast Fisheries Science Center (NEFSC). 2006. Stock Assessment Report Part A: Silver

Hake, Atlantic Mackerel and Northern Shortfin Squid. 42nd Northeast Regional Stock

Assessment Workshop (42nd SAW). National Marine Fisheries Service. Northeast Fisheries

Science Center. NEFSC Reference Document 06-09a. May 2006.

NSTAR Gas and Electric Corporation (NSTAR). 2001. ENVIRO printouts. April 21, 2001.

NSTAR Gas and Electric Corporation (NSTAR). 2006. 2006 Vegetation Management Plan,

including Five-Year Vegetation Management Plan: 2003-2007.

Nuclear Regulatory Commission (NRC). 1990. Environmental Assessment by the Office of

Nuclear Reactor Regulation Relating to the Change in Expiration Date of Facility Operating

| Licence Number DPR-35 Boston Edison Company for the Pilgrim Nuclear Power Station,

| Docket Number 50-239, Washington, DC.

| Nuclear Regulatory Commission (NRC). 1992. NUREG/BR-0125, Volume 3, Number 1, March.

| Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for

| License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, DC.

Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1,

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report.” 

| NUREG-1437, Volume 1, Addendum 1, Washington, DC.

Nuclear Regulatory Commission (NRC). 2001. “Procedural Guidance for Preparing

Environmental Assessments and Considering Environmental Issues.” Appendix D to NRC

| Office Instruction LIC-203. Washington, DC June 21, 2001.
Environmental Impacts of Operation

July 2007 4-91 NUREG-1437, Supplement 29

Nuclear Regulatory Commission (NRC). 2004a. “Procedural Guidance for Preparing

Environmental Assessments and Considering Environmental Issues.” Revision 1. Appendix D

to NRR Office Instruction LIC-203. Washington, DC. |

Nuclear Regulatory Commission (NRC). 2004b. “Policy Statement on the Treatment of |

Environmental Justice Matters in NRC Regulatory and Licensing Actions.” Federal Register,

Volume 69, pgs. 52040–52048. Washington, DC. |

Nuclear Regulatory Commission (NRC). 2005. Commission Papers (Secy 05-0202). |

Accessed at: http://www.nrc.gov/reading-rm/doc-collections/commission/secys/2005/secy2005- |

0202/2005-0202 scy.html on May 9, 2007. |

Nuclear Regulatory Commission (NRC). 2006a. Backgrounder on Radiation Protection and the |

“Tooth Fairy” Issue. Accessed at: http://www.nrc.gov/reading-rm/doc-collections/factsheets/tooth-fairy.html#8 on October 20, 2006.

|

Nuclear Regulatory Commission (NRC). 2006b. Letter to Michael Bartlett, Field Supervisor, |

U.S. Fish and Wildlife Service, Concord, NH: Request for a list of protected species within the

area under evaluation for the Pilgrim Nuclear Power Station License Renewal Application

Review. April 25, 2006.

Nuclear Regulatory Commission (NRC). 2007. Fact sheet on Biological Effects of Radiation. |

Accessed at: http://www.nrc.gov/reading-rm/doc-collections/bio-effects-radiation.html on May 9, |

2007. |

Old Colony Planning Council (OCPC). 2000. Regional Policy Plan: A Guide for Shaping Our

Communities and the OCPC Region. Brockton, Massachusetts.

Portier, C.J., and M.S. Wolfe, eds. 1999. Assessment of Health Effects from Exposure to

Power-Line Frequency Electric and Magnetic Field. Working Group Report, National Institute of

Environmental Health Sciences of the National Institutes of Health, pg. 508. |

Russ, A., C. Burns, S. Tuler, and O. Taylor. 2006. Health Risks of Ionizing Radiation: An |

Overview of Epidemiological Studies. Community-Based Hazard Management, The George |

Perkins Marsh Institute. Clark University, Worcester, Massachusetts. Accessed at: |

http://www.clarku.edu/departments/marsh/projects/community/EpiOverviewFinal.pdf |

on April 27, 2007. |

Saila, S.B., E. Lorda, J.D. Miller, R.A. Sher, and W.H. Howell. 1997. Equivalent Adult

Estimates for Losses of Fish Eggs, Larvae, and Juveniles at Seabrook Station with Use of

Fuzzy Logic to Represent Parametric Uncertainty. North American Journal of Fisheries

Management, Volume 17, pgs. 811-825. |
Environmental Impacts of Operation

NUREG-1437, Supplement 29 4-92 July 2007

Sever, L.E., Baker, D.A., Gilbert, E.S., and J.A. Mahaffey. 1993. Cancer Increase Study

Methodology: A review and discussion of the “Southeastern Massachusetts Health Study 1978-

1986”, prepared for the Bonneville Power Administration by Battelle Memorial Institute, Pacific

Northwest Laboratory.

Siemens. 2006. Rex Modified Ristroph Fish Handling Traveling Screen. Accessed at:

http://www.usfilter.com/en/Product+Lines/Headworks_and_Intake_Systems/Headworks on

August 10, 2006.

Stone and Webster Engineering Corporation (Stone & Webster). 1975. 316 Demonstration,

Pilgrim Nuclear Power Station – Units 1 and 2. Prepared for Boston Edison Company, Boston,

Massachusetts.

Stone and Webster Engineering Corporation (Stone & Webster). 1977. Supplemental

Assessment in Support of the 316 Demonstration, Pilgrim Nuclear Power Station – Units 1 and

2. Prepared for Boston Edison Company, Boston, Massachusetts.

Szal, G.M. 2005. Pilgrim Nuclear Power Station: Review of Intake and Discharge Effects to

Finfish. December 5, 2005. Appendix G of the South Shore Water Quality Assessment Report. 

Town of Plymouth. 2006. Annual Report of the Town of Plymouth, Massachusetts for the Year

Ending December 31, 2005. Plymouth, Massachusetts.

Town of Plymouth. 2007. Press release dated April 24, 2007 concerning new PILOT

agreement reached with Entergy Corporation. Accessed at: http://www.plymouthma.gov/Public_Documents/PlymouthMA_BBoard/00E9C346-000F8513.pdf on April 25, 2007.

|

University of Pittsburgh. (UOP). 2000. "Mortality among the Residents of the Three Mile Island

| Accident Area: 1979-1992." Environmental Health Perspectives, Volume 108, Number 6, 

June 2000.

| U.S. Army Corps of Engineers (USACE), New England District. 2006. Update Report for

| Massachusetts. Accessed at: http://www.nae.usace.army.mil on June 23, 2006.

U.S. Census Bureau (USCB). 2000. Census of Population and Housing 2000, Summary File 3,

| Tables H1, H6 and H8. Accessed at: http://factfinder.census.gov on May 5, 2006.
The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all (a)

references to the “GEIS” include the GEIS and Addendum 1.

July 2007 5-1 NUREG-1437, Supplement 29

5.0 Environmental Impacts of Postulated Accidents

Environmental issues associated with postulated accidents are discussed in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437,

Volumes 1 and 2 (NRC 1996, 1999). The GEIS includes a determination of whether the

(a)

analysis of the environmental issue could be applied to all plants and whether additional

mitigation measures would be warranted. Issues are then assigned a Category 1 or a

Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of

the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system

or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to

the impacts (except for collective off-site radiological impacts from the fuel cycle and

from high-level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures

are likely not to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

required unless new and significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1:

therefore, additional plant-specific review of these issues is required.

This chapter describes the environmental impacts from postulated accidents that might occur

during the license renewal term.

5.1 Postulated Plant Accidents

Two classes of accidents are evaluated in the GEIS. These are design-basis accidents and

severe accidents, as discussed below. 
Environmental Impacts of Postulated Accidents

NUREG-1437, Supplement 29 5-2 July 2007

5.1.1 Design-Basis Accidents

In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear

power facility, an applicant for an initial operating license (OL) must submit a Safety Analysis

Report (SAR) as part of its application. The SAR presents the design criteria and design

information for the proposed reactor and comprehensive data on the proposed site. The SAR

also discusses various hypothetical accident situations and the safety features that are provided

to prevent and mitigate accidents. The NRC staff reviews the application to determine whether

the plant design meets the Commission’s regulations and requirements and includes, in part,

the nuclear plant design and its anticipated response to an accident.

Design-basis accidents (DBAs) are those accidents that both the licensee and the NRC staff

evaluate to ensure that the plant can withstand normal and abnormal transients, and a broad

spectrum of postulated accidents, without undue hazard to the health and safety of the public.

A number of these postulated accidents are not expected to occur during the life of the plant,

but are evaluated to establish the design basis for the preventive and mitigative safety systems

of the facility. The acceptance criteria for DBAs are described in Title 10 of the Code of Federal

Regulations Part 50 and Part 100 (10 CFR Part 50 and 10 CFR Part 100).

The environmental impacts of DBAs are evaluated during the initial licensing process, and the

ability of the plant to withstand these accidents is demonstrated to be acceptable before

issuance of the OL. The results of these evaluations are found in license documentation such

as the applicant’s Final Safety Analysis Report (FSAR), the NRC staff’s Safety Evaluation

Report (SER), the Final Environmental Statement (FES), and Section 5.1 of this Supplemental

Environmental Impact Statement (SEIS). A licensee is required to maintain the acceptable

design and performance criteria throughout the life of the plant, including any extended-life

operation. The consequences for these events are evaluated for the hypothetical maximally

exposed individual; as such, changes in the plant environment will not affect these evaluations.

Because of the requirements that continuous acceptability of the consequences and aging

management programs be in effect for license renewal, the environmental impacts as

calculated for DBAs should not differ significantly from initial licensing assessments over the life

of the plant, including the license renewal period. Accordingly, the design of the plant relative to

DBAs during the extended period is considered to remain acceptable, and the environmental

impacts of those accidents were not examined further in the GEIS.

The Commission has determined that the environmental impacts of DBAs are of SMALL

significance for all plants because the plants were designed to successfully withstand these

accidents. Therefore, for the purposes of license renewal, DBAs are designated as a

Category 1 issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. The early resolution of

the DBAs makes them a part of the current licensing basis of the plant; the current licensing 
Environmental Impacts of Postulated Accidents

July 2007 5-3 NUREG-1437, Supplement 29

basis of the plant is to be maintained by the licensee under its current license and, therefore,

under the provisions of 10 CFR 54.30, is not subject to review under license renewal. This

issue, applicable to Pilgrim Nuclear Power Station (PNPS), is listed in Table 5-1. 

Table 5-1. Category 1 Issue Applicable to Postulated Accidents During the Renewal Term

ISSUE–10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

POSTULATED ACCIDENTS

Design-basis accidents 5.3.2; 5.5.1

Based on information in the GEIS, the Commission found that:

The NRC staff has concluded that the environmental impacts of design-basis

accidents are of small significance for all plants.

Entergy Nuclear Operations, Inc. (Entergy) stated in its Environmental Report (ER) 

(Entergy 2006a) that it is not aware of any new and significant information associated with the

renewal of the PNPS OL. The NRC staff has not identified any new and significant information

during its independent review of the PNPS ER, the site visit, the scoping process, evaluation of |

other available information, or consideration of public comments. Therefore, the NRC staff |

concludes that there are no impacts related to DBAs beyond those discussed in the GEIS.

5.1.2 Severe Accidents 

Severe nuclear accidents are those that are more severe than DBAs because they could result

in substantial damage to the reactor core, regardless of off-site consequences. In the GEIS,

the NRC staff assessed the impacts of severe accidents using the results of existing analyses

and site-specific information to conservatively predict the environmental impacts of severe

accidents for each plant during the renewal period.

Severe accidents initiated by external phenomena, such as tornadoes, floods, earthquakes,

fires, and sabotage, traditionally have not been discussed in quantitative terms in FESs and

were not specifically considered for the PNPS site in the GEIS. However, in the GEIS, the NRC |

staff did evaluate existing impact assessments performed by the NRC and by the industry at

44 nuclear plants in the United States and concluded that the risk from beyond-design-basis

earthquakes at existing nuclear power plants is SMALL. The GEIS for license renewal |

performed a discretionary analysis of terrorist acts in connection with license renewal, and |

concluded that the core damage and radiological release from such acts would be no worse |

than the damage and release expected from internally initiated events. In the GEIS, the |

Commission concludes that the risk from sabotage and beyond design-basis earthquakes at |
Environmental Impacts of Postulated Accidents

NUREG-1437, Supplement 29 5-4 July 2007

| existing nuclear power plants is small and, additionally, that the risks from other external events

| are adequately addressed by a generic consideration of internally initiated sever accidents

(GEIS, Vol. 1, p-5-18) . 

Based on information in the GEIS, the Commission found that:

The probability weighted consequences of atmospheric releases, fallout onto

open bodies of water, releases to groundwater, and societal and economic

impacts from severe accidents are small for all plants. However, alternatives to

mitigate severe accidents must be considered for all plants that have not

considered such alternatives.

Therefore, the Commission has designated mitigation of severe accidents as a Category 2

issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. This issue, applicable to PNPS, is

listed in Table 5-2.

Table 5-2. Category 2 Issue Applicable to Postulated Accidents During the Renewal Term

ISSUE–10 CFR Part 51, Subpart A,

Appendix B, Table B-1

GEIS

Sections

10 CFR 51.53(c)(3)(ii)

Subparagraph

SEIS

Section

POSTULATED ACCIDENTS

Severe accidents 5.3.3; 5.3.3.2; 

5.3.3.3; 5.3.3.4; 

5.3.3.5; 5.4; 5.5.2

L 5.2

The NRC staff has not identified any new and significant information with regard to the

consequences from severe accidents during its independent review of the PNPS ER 

| (Entergy 2006a), the site visit, the scoping process, evaluation of other available information, or

| consideration of public comments. Therefore, the NRC staff concludes that there are no

impacts of severe accidents beyond those discussed in the GEIS. However, in accordance with

10 CFR 51.53(c)(3)(ii)(L), the NRC staff has reviewed severe accident mitigation alternatives

(SAMAs) for PNPS. The results of its review are discussed in Section 5.2.
Environmental Impacts of Postulated Accidents

July 2007 5-5 NUREG-1437, Supplement 29

5.2 Severe Accident Mitigation Alternatives

Section 51.53(c)(3)(ii)(L) of 10 CFR requires that license renewal applicants consider

alternatives to mitigate severe accidents if the staff has not previously evaluated SAMAs for the

applicant's plant in an environmental impact statement (EIS) or related supplement or in an

environmental assessment. The purpose of this consideration is to ensure that plant changes

(i.e., hardware, procedures, and training) with the potential for improving severe accident safety

performance are identified and evaluated. SAMAs have not been previously considered for

PNPS; therefore, the remainder of Chapter 5 addresses those alternatives.

5.2.1 Introduction

This section presents a summary of the SAMA evaluation for PNPS conducted by Entergy and

described in the ER, and the NRC's review of this evaluation. The details of the review are

described in the NRC staff evaluation that was prepared with contract assistance from

Information Systems Laboratories, Inc. The entire SAMA evaluation for PNPS is presented in |

Appendix G.

The SAMA evaluation for PNPS was conducted with a four-step approach. In the first step

Entergy quantified the level of risk associated with potential reactor accidents using the

plant-specific probabilistic safety assessment (PSA) and other risk models. In the second step

Entergy examined the major risk contributors and identified possible ways (i.e., SAMAs) of

reducing that risk. Common ways of reducing risk are changes to components, systems,

procedures, and training. Entergy initially identified 281 potential SAMAs for PNPS. Entergy

screened out 222 SAMAs from further consideration because they are not applicable at PNPS

due to design differences, have already been implemented at PNPS, or are addressed by a

similar SAMA. The remaining 59 SAMAs were subjected to further evaluation. In the third step

Entergy estimated the benefits and the costs associated with each of the remaining SAMAs.

Estimates were made of how much each SAMA could reduce risk. Those estimates were

developed in terms of dollars in accordance with NRC guidance for performing regulatory

analyses (NRC 1997). The cost of implementing the proposed SAMAs was also estimated.

Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were

compared to determine whether the SAMA was cost-beneficial, meaning the benefits of the

SAMA were greater than the cost (a positive cost-benefit). Entergy found five SAMAs to be

potentially cost-beneficial (Entergy 2006a). However, in response to NRC staff inquiries

regarding estimated benefits for certain SAMAs and lower cost alternatives, Entergy identified

two additional potentially cost-beneficial SAMAs (Entergy 2006b and 2006c). The potentially

cost-beneficial SAMAs do not relate to adequately managing the effects of aging during the

period of extended operation; therefore, they need not be implemented as part of license

renewal pursuant to 10 CFR Part 54. Entergy's SAMA analyses and the NRC's review are

discussed in more detail below.
Environmental Impacts of Postulated Accidents

NUREG-1437, Supplement 29 5-6 July 2007

5.2.2 Estimate of Risk

Entergy submitted an assessment of SAMAs for PNPS as part of the ER (Entergy 2006a). This

assessment was based on the most recent PNPS PSA available at that time, a plant-specific

off-site consequence analysis performed using the MELCOR Accident Consequence Code

System 2 (MACCS2) computer program, and insights from the PNPS Individual Plant

Examination (IPE) (BEC 1992) and Individual Plant Examination of External Events (IPEEE)

(BEC 1994).

The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is

approximately 6.4 x 10 per year. This CDF is based on the risk assessment for internally- -6

initiated events. Entergy did not include the contribution to risk from external events within the

PNPS risk estimates; however, it did account for the potential risk reduction benefits associated

with external events by increasing the estimated benefits for internal events by a factor of five. 

The breakdown of CDF by initiating event is provided in Table 5-3.

Table 5-3. PNPS Core Damage Frequency

Initiating Event

CDF

(Per Year)

Percent Contribution

to CDF

Loss of direct current (DC) power buses 3.1 x 10 48 -6

| Loss of off-site power 1.3 x 10 20 -6

Loss of alternating current (AC) power buses 8.8 x 10 14 -7

Loss of salt service water 3.9 x 10 6

-7

Transients 3.6 x 10 6

-7

Loss of coolant accidents 1.8 x 10 3

-7

Station blackout 1.5 x 10 2

-7

Anticipated transient without scram 5.3 x 10 1

-8

Interfacing system loss-of-coolant accident (LOCA) 3.6 x 10 <1 -8

Internal flooding 1.3 x 10 <1 -8

Total CDF (from internal events) 6.4 x 10 100 -6
Environmental Impacts of Postulated Accidents

July 2007 5-7 NUREG-1437, Supplement 29

As shown in Table 5-3, events initiated by loss of DC buses and loss of off-site power are the

dominant contributors to CDF. Station blackout (SBO) sequences contribute 1.5 x 10 per year -7

(about 2 percent of the total internal events CDF), while anticipated transient without scram

(ATWS) sequences are insignificant contributors to CDF (5.3 x 10 per year). 

-8

In the ER, Entergy estimated the dose to the population within 50 miles of the PNPS site to be

approximately 0.136 person-sievert (Sv) (13.6 person-roentgen equivalents, man [person-rem]) |

per year. The breakdown of the total population dose by containment release mode is

summarized in Table 5-4. Containment failures within the late time frame (greater than 7.5

hours following event initiation) dominate the population dose risk at PNPS.

The NRC staff has reviewed Entergy's data and evaluation methods and concludes that the

quality of the risk analyses is adequate to support an assessment of the risk reduction potential

for candidate SAMAs. Accordingly, the staff based its assessment of off-site risk on the CDFs

and off-site doses reported by Entergy.

5.2.3 Potential Plant Improvements

Once the dominant contributors to plant risk were identified, Entergy searched for ways to

reduce that risk. In identifying and evaluating potential SAMAs, Entergy considered insights

from the plant-specific PSA, and SAMA analyses performed for other operating plants that have

submitted license renewal applications. Entergy identified 281 potential risk-reducing

improvements (SAMAs) to plant components, systems, procedures and training.

Entergy removed 222 SAMAs from further consideration because they are not applicable at

PNPS due to design differences, have already been implemented at PNPS, or are addressed

by a similar SAMA. A detailed cost-benefit analysis was performed for each of the 59

remaining SAMAs.

The staff concludes that Entergy used a systematic and comprehensive process for identifying

potential plant improvements for PNPS, and that the set of potential plant improvements

identified by Entergy is reasonably comprehensive and, therefore, acceptable. 
Environmental Impacts of Postulated Accidents

NUREG-1437, Supplement 29 5-8 July 2007

Table 5-4. Breakdown of Population Dose by Containment Release Mode

Containment Release Mode

Population Dose

(Person-Rem Per Year) Percent Contribution 1

Late Containment Failure 12.7 93

Early Containment Failure 0.7 5

Containment Bypass 0.2 2

Intact Containment negligible negligible

Total 13.6 100

 One person-rem = 0.01 person-Sv 1

5.2.4 Evaluation of Risk Reduction and Costs of Improvements

Entergy evaluated the risk-reduction potential of the remaining 59 SAMAs. The majority of the

SAMA evaluations were performed in a bounding fashion in that the SAMA was assumed to

completely eliminate the risk associated with the proposed enhancement.

Entergy estimated the costs of implementing the 59 candidate SAMAs through the application

of engineering judgement, and use of other licensees’ estimates for similar improvements. The

cost estimates conservatively did not include the cost of replacement power during extended

outages required to implement the modifications, nor did they include contingency costs

associated with unforeseen implementation obstacles.

The staff reviewed Entergy’s bases for calculating the risk reduction for the various plant

improvements and concludes that the rationale and assumptions for estimating risk reduction

are reasonable and somewhat conservative (i.e., the estimated risk reduction is similar to or

somewhat higher than what would actually be realized). Accordingly, the staff based its

estimates of averted risk for the various SAMAs on Entergy’s risk reduction estimates.

The staff reviewed the bases for the applicant’s cost estimates. For certain improvements, the

staff also compared the cost estimates to estimates developed elsewhere for similar

improvements, including estimates developed as part of other licensees’ analyses of SAMAs for

operating reactors and advanced light-water reactors. The staff found the cost estimates to be

consistent with estimates provided in support of other plants’ analyses.

The staff concludes that the risk reduction and the cost estimates provided by Entergy are

sufficient and appropriate for use in the SAMA evaluation.
Environmental Impacts of Postulated Accidents

July 2007 5-9 NUREG-1437, Supplement 29

5.2.5 Cost-Benefit Comparison

The cost-benefit analysis performed by Entergy was based primarily on NUREG/BR-0184 

(NRC 1997) and was executed consistent with this guidance. NUREG/BR-0058 has recently

been revised to reflect the agency’s revised policy on discount rates. Revision 4 of

NUREG/BR-0058 states that two sets of estimates should be developed – one at three percent

and one at seven percent (NRC 2004). Entergy provided both sets of estimates 

(Entergy 2006a).

Entergy identified five potentially cost-beneficial SAMAs in the baseline analysis contained in

the ER (using a seven percent discount rate, and considering the combined impact of both

external events and uncertainties). The potentially cost-beneficial SAMAs are:

C SAMA 30 – install key-locked control switches to enable AC bus cross-ties and modify

procedures to enhance the reliability of the AC power system.

C SAMA 34 – modify plant procedures to use DC bus cross-ties to enhance the reliability

of the DC power system.

C SAMA 56 – install additional fuses in panel C7 to enable the direct torus vent (DTV)

valve function during loss of containment heat removal accident sequences.

C SAMA 57 – modify plant procedures to allow use of the diesel fire pump hydro turbine in

the event that emergency diesel generator (EDG) A fails or fuel oil transfer pump P141A is unavailable.

C SAMA 58 – modify plant procedures to allow alternately feeding B1 loads via B3 when

A3 is available, and alternately feeding B2 loads via B4 when A4 is available.

In response to a request for additional information, Entergy provided a revised assessment

based on a modified multiplier for external events and a separate accounting of uncertainties

(Entergy 2006b). The revised assessment resulted in identification of the same potentially costbeneficial SAMAs. No additional SAMAs were identified when the benefits were evaluated

using a three percent discount rate, or when the benefits were increased by a factor of 1.6 to

account for uncertainties. However, in response to additional NRC staff inquiries regarding

estimated benefits for certain SAMAs and lower cost alternatives, Entergy identified two

additional potentially cost-beneficial SAMAs (Entergy 2006b and 2006c):
Environmental Impacts of Postulated Accidents

NUREG-1437, Supplement 29 5-10 July 2007

| C Control containment venting with a narrow pressure band (SAMA 53), and

C Use the security diesel generator to extend the life of the 125 volt DC batteries 

(a new SAMA). 

The staff concludes that, with the exception of the potentially cost-beneficial SAMAs discussed

above, the costs of the SAMAs evaluated would be higher than the associated benefits.

5.2.6 Conclusions

The staff reviewed Entergy’s analysis and concluded that the methods used and the

implementation of those methods were sound. The treatment of SAMA benefits and costs

support the general conclusion that the SAMA evaluations performed by Entergy are

reasonable and sufficient for the license renewal submittal. Although the treatment of SAMAs

for external events was somewhat limited by the unavailability of an external event PSA, the

likelihood of there being cost-beneficial enhancements in this area was minimized by

improvements that have been realized as a result of the IPEEE process, and increasing the

estimated SAMA benefits for internal events by a factor of five to account for potential benefits

in external events.

Based on its review of the SAMA analysis, the staff concurs with Entergy’s identification of

areas in which risk can be further reduced in a cost-beneficial manner through the

implementation of all or a subset of potentially cost-beneficial SAMAs. Given the potential for

cost-beneficial risk reduction, the staff considers that further evaluation of these SAMAs by

Entergy is warranted. However, none of the potentially cost-beneficial SAMAs relate to

adequately managing the effects of aging during the period of extended operation. Therefore,

they need not be implemented as part of the license renewal pursuant to 10 CFR Part 54.

5.3 References

| 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, Appendix I,

| “Numerical Guides for Design Objectives and Limiting Conditions for Operations to Meet the

| Criterion ‘As Low As Reasonably Achievable’ for Radiological Material in Light-Water-Cooled

| Nuclear Power Reactor Effluents.”

|

| 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

| Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

|

| 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

| Renewal of Operating Licenses for Nuclear Power Plants.”

|
Environmental Impacts of Postulated Accidents

July 2007 5-11 NUREG-1437, Supplement 29

10 CFR Part 73. Code of Federal Regulations, Title 10, Energy, Part 73, “Physical Protection |

of Plants and Materials.” |

|

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor Site |

Criteria.” |

|

Boston Edison Company (BEC). 1992. Letter from E. T. Boulette, BEC to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: Response to Generic Letter 88-20,

Individual Plant Examination for Severe Accident Vulnerabilities. September 30, 1992.

Boston Edison Company (BEC). 1994. Letter from E. T. Boulette, BEC to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: Response to Generic Letter 88-20,

Supplement 4 Individual Plant Examination of External Events for Severe Accident

Vulnerabilities. June 30, 1994.

Entergy Nuclear Operations, Inc. 2006a. Applicant’s Environmental Report–Operating License

Renewal Stage, Pilgrim Nuclear Power Station, Docket Number 50-293, Plymouth, |

Massachusetts. |

Entergy Nuclear Operations, Inc. 2006b. Letter from Stephen J. Bethay, Entergy to NRC

Document Control Desk. Subject: License Renewal Application Amendment 4: Response to

Request for Additional Information Regarding Severe Accident Mitigation Alternatives for

Pilgrim Nuclear Power Station (TAC No. MC9676), July 5, 2006.

Entergy Nuclear Operations, Inc. 2006c. Letter from Stephen J. Bethay, Entergy to NRC

Document Control Desk. Subject: License Renewal Application Amendment 7, August 30,

2006.

Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, DC. |

Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation

Handbook. NUREG/BR-0184, Washington, DC. |

Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants Main Report. “Section 6.3 – Transportation, Table 9.1,

Summary of findings on NEPA issues for license renewal of nuclear power plants,” Final |

Report. NUREG-1437, Volume 1, Addendum 1, Washington DC. |

Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S.

Nuclear Regulatory Commission. NUREG/BR-0058, Revision 4, Washington, DC. |

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

July 2007 6-1 NUREG-1437, Supplement 29

6.0 Environmental Impacts of the Uranium

Fuel Cycle and Solid Waste Management

Environmental issues associated with the uranium fuel cycle and solid waste management are

discussed in the Generic Environmental Impact Statement for License Renewal of Nuclear

Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999.)(a) The GEIS includes a

determination of whether the analysis of the environmental issue could be applied to all plants

and whether additional mitigation measures would be warranted. Issues are then assigned a

Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 issues are those

that meet all of the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply either

to all plants or, for some issues, to plants having a specific type of cooling system or other

specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to the

impacts (except for collective off-site radiological impacts from the fuel cycle and from highlevel waste [HLW] and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the analysis,

and it has been determined that additional plant-specific mitigation measures are likely not

to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

required unless new and significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1;

therefore, additional plant-specific review of these issues is required.

This chapter addresses the issues that are related to the uranium fuel cycle and solid waste

management during the license renewal term that are listed in Table B-1 of Title 10 of the Code

of Federal Regulations (CFR) Part 51, Subpart A, Appendix B, and are applicable to Pilgrim

Nuclear Power Station (PNPS). The generic potential impacts of the radiological and

nonradiological environmental impacts of the uranium fuel cycle and transportation of nuclear

fuel and wastes are described in detail in the GEIS based, in part, on the generic impacts

provided in 10 CFR 51.51(b), Table S-3, “Table of Uranium Fuel Cycle Environmental Data,”

and in 10 CFR 51.52(c), Table S-4, “Environmental Impact of Transportation of Fuel and Waste 
Fuel Cycle

NUREG-1437, Supplement 29 6-2 July 2007

to and from One Light-Water-Cooled Nuclear Power Reactor.” The U.S. Nuclear Regulatory

Commission (NRC) staff also addresses the impacts from radon-222 and technetium-99 in the

GEIS. 

6.1 The Uranium Fuel Cycle

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to

PNPS from the uranium fuel cycle and solid waste management are listed in Table 6-1. 

Table 6-1. Category 1 Issues Applicable to the Uranium Fuel Cycle 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

Off-site radiological impacts (individual effects from other than the

disposal of spent fuel and high level waste)

6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3;

6.2.4

Off-site radiological impacts (collective effects) 6.2.2.1; 6.2.3; 6.2.4

Off-site radiological impacts (spent fuel and high level waste disposal) 6.2.2.1; 6.2.2.2; 6.2.3; 6.2.4

| Nonradiological impacts of the uranium fuel cycle 6.2.2.6; 6.2.2.7; 6.2.9.8; 

6.2.2.9; 6.2.3; 6.2.4

Low-level waste storage and disposal 6.2.2.2; 6.4.2; 6.4.3

Mixed waste storage and disposal 6.4.5

On-site spent fuel 6.4.6

Nonradiological waste 6.5

Transportation 6.3; Addendum 1

Entergy stated in its Environmental Report (ER) (Entergy 2006) that it is not aware of any new

and significant information associated with the renewal of the PNPS operating license. The

staff has not identified any new and significant information during its independent review of the

| PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of other available

| information, or consideration of public comments. Therefore, the staff concludes that there are

no impacts related to these issues beyond those discussed in the GEIS. For these issues, the

staff concluded in the GEIS that the impacts are SMALL except for the collective off-site

radiological impacts from the fuel cycle and from HLW and spent fuel disposal, as discussed

below, and that additional plant-specific mitigation measures are not likely to be sufficiently

beneficial to be warranted. 
Fuel Cycle

July 2007 6-3 NUREG-1437, Supplement 29

A brief description of the staff review and the GEIS conclusions, as codified in Table B-1,

10 CFR Part 51, for each of these issues follows:

C Off-site radiological impacts (individual effects from other than the disposal of spent fuel and

high level waste). Based on information in the GEIS, the Commission found that: 

Off-site impacts of the uranium fuel cycle have been considered by the 

Commission in Table S-3 of this part (10 CFR 51.51[b]). Based on 

information in the GEIS, impacts on individuals from radioactive gaseous 

and liquid releases including radon-222 and technetium-99 are small.

The staff has not identified any new and significant information during its independent

review of the PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of |

other available information, or consideration of public comments. Therefore, the staff |

concludes that there would be no off-site radiological impacts of the uranium fuel cycle

during the renewal term beyond those discussed in the GEIS. 

C Off-site radiological impacts (collective effects). Based on information in the GEIS, the

Commission found that:

The 100 year environmental dose commitment to the U.S. population from the

fuel cycle, high level waste and spent fuel disposal excepted, is calculated to be

about 14,800 person rem, or 12 cancer fatalities, for each additional 20-year

power reactor operating term. Much of this, especially the contribution of radon

releases from mines and tailing piles, consists of tiny doses summed over large

populations. This same dose calculation can theoretically be extended to include

many tiny doses over additional thousands of years as well as doses outside the

U.S. The result of such a calculation would be thousands of cancer fatalities

from the fuel cycle, but this result assumes that even tiny doses have some

statistical adverse health effect which will not ever be mitigated (for example no

cancer cure in the next one thousand years), and that these doses projected over

thousands of years are meaningful. However, these assumptions are

questionable. In particular, science cannot rule out the possibility that there will

be no cancer fatalities from these tiny doses. For perspective, the doses are

very small fractions of regulatory limits and even smaller fractions of natural

background exposure to the same populations.

Nevertheless, despite all of the uncertainty, some judgement as to the regulatory

NEPA (National Environmental Policy Act of 1969, as amended) implications of

these matters should be made and it makes no sense to repeat the same

judgement in every case. Even taking the uncertainties into account, the

Commission concludes that these impacts are acceptable in that these impacts
Fuel Cycle

NUREG-1437, Supplement 29 6-4 July 2007

would not be sufficiently large to require the NEPA conclusion, for any plant, that

the option of extended operation under 10 CFR Part 54 should be eliminated. 

Accordingly, while the Commission has not assigned a single level of significance

for the collective effects of the fuel cycle, this issue is considered Category 1.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER (Entergy 2006), the staffs site visit, the scoping process, evaluation

| of other available information, or consideration of public comments. Therefore, the staff

concludes that there would be no off-site radiological impacts (collective effects) from the

uranium fuel cycle during the renewal term beyond those discussed in the GEIS. 

C Off-site radiological impacts (spent fuel and high level waste disposal). Based on

information in the GEIS, the Commission found that:

For the high level waste and spent fuel disposal component of the fuel cycle,

there are no current regulatory limits for off-site releases of radionuclides for the

current candidate repository site. However, if we assume that limits are

developed along the lines of the 1995 National Academy of Sciences (NAS)

report, “Technical Bases for Yucca Mountain Standards” (NAS 1995), and that in

accordance with the Commission’s Waste Confidence Decision, 10 CFR 51.23, a

repository can and likely will be developed at some site which will comply with

such limits, peak doses to virtually all individuals will be 100 millirem per year or

less. However, while the Commission has reasonable confidence that these

assumptions will prove correct, there is considerable uncertainty since the limits

are yet to be developed, no repository application has been completed or

reviewed, and uncertainty is inherent in the models used to evaluate possible

pathways to the human environment. The NAS report indicated that 100 millirem

per year should be considered as a starting point for limits for individual doses,

but notes that some measure of consensus exists among national and

international bodies that the limits should be a fraction of the 100 millirem per

year. The lifetime individual risk from 100 millirem annual dose limit is about 3

× 10-3.

Estimating cumulative doses to populations over thousands of years is more

problematic. The likelihood and consequences of events that could seriously

compromise the integrity of a deep geologic repository were evaluated by the

Department of Energy in the “Final Environmental Impact Statement: 

Management of Commercially Generated Radioactive Waste,” October 1980

(DOE 1980). The evaluation estimated the 70-year whole-body dose

commitment to the maximum individual and to the regional population resulting

from several modes of breaching a reference repository in the year of closure,
Fuel Cycle

July 2007 6-5 NUREG-1437, Supplement 29

after 1,000 years, after 100,000 years, and after 100,000,000 years. Subsequently, the NRC and other federal agencies have expended considerable effort

to develop models for the design and for the licensing of a high level waste

repository, especially for the candidate repository at Yucca Mountain. More

meaningful estimates of doses to population may be possible in the future as

more is understood about the performance of the proposed Yucca Mountain

repository. Such estimates would involve very great uncertainty, especially with

respect to cumulative population doses over thousands of years. The standard

proposed by the NAS is a limit on maximum individual dose. The relationship of

potential new regulatory requirements, based on the NAS report, and cumulative

population impacts has not been determined, although the report articulates the

view that protection of individuals will adequately protect the population for a

repository at Yucca Mountain. However, EPA’s (U.S. Environmental Protection

Agency’s) generic repository standards in 40 CFR Part 191 generally provide an

indication of the order of magnitude of cumulative risk to population that could

result from the licensing of a Yucca Mountain repository, assuming the ultimate

standards will be within the range of standards now under consideration. The

standards in 40 CFR Part 191 protect the population by imposing “containment

requirements” that limit the cumulative amount of radioactive material released

over 10,000 years. Reporting performance standards that will be required by

EPA are expected to result in releases and associated health consequences in

the range between 10 and 100 premature cancer deaths with an upper limit of

1,000 premature cancer deaths world-wide for a 100,000 metric tonne repository.

Nevertheless, despite all of the uncertainty, some judgement as to the regulatory

NEPA implications of these matters should be made and it makes no sense to

repeat the same judgement in every case. Even taking the uncertainties into

account, the Commission concludes that these impacts are acceptable in that

these impacts would not be sufficiently large to require the NEPA conclusion, for

any plant, that the option of extended operation under 10 CFR Part 54 should be

eliminated. Accordingly, while the Commission has not assigned a single level of

significance for the impacts of spent fuel and high level waste disposal, this issue

is considered Category 1.

On February 15, 2002, based on a recommendation by the Secretary of the Department of

Energy, the President recommended the Yucca Mountain site for the development of a

repository for the geologic disposal of spent nuclear fuel and HLW. The U.S. Congress

approved this recommendation on July 9, 2002, in Joint Resolution 87, which designated

Yucca Mountain as the repository for spent nuclear waste. On July 23, 2002, the President

signed Joint Resolution 87 into law; Public Law 107-200, 116 Stat. 735 (2002) designates

Yucca Mountain as the repository for spent nuclear waste. This development does not
Fuel Cycle

NUREG-1437, Supplement 29 6-6 July 2007

represent new and significant information with respect to the off-site radiological impacts

from license renewal related to disposal of spent nuclear fuel and HLW.

The EPA developed Yucca Mountain-specific repository standards, which were

subsequently adopted by the NRC in 10 CFR Part 63. In an opinion, issued July 9, 2004,

the U.S. Court of Appeals for the District of Columbia Circuit (the Court) vacated EPA's

radiation protection standards for the candidate repository, which required compliance with

certain dose limits over a 10,000 year period. The Court's decision also vacated the

compliance period in NRC's licensing criteria for the candidate repository in 10 CFR Part 63.

Therefore, for the HLW and spent fuel disposal component of the fuel cycle, there is some

uncertainty with respect to regulatory limits for off-site releases of radioactive nuclides for

the current candidate repository site. However, prior to promulgation of the affected

provisions of the Commission's regulations, it was assumed that limits would be developed

in line with the 1995 NAS report, Technical Bases for Yucca Mountain Standards (NAS

1995), and that in accordance with the Commission's Waste Confidence Decision, 10 CFR

51.23, a repository that would comply with such limits could and likely would be developed

at some site. Peak doses to virtually all individuals would be 100 mrem per year or less.

Despite the current uncertainty with respect to these rules, some judgment as to the 1969

NEPA implications of off-site radiological impacts of spent fuel and HLW disposal should be

made. The staff concludes that these impacts are acceptable in that the impacts would not

be sufficiently large to require the NEPA conclusion that the option of extended operation

under 10 CFR Part 54 should be eliminated.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of

| other available information, or consideration of public comments. Therefore, the staff

concludes that there would be no off-site radiological impacts related to spent fuel and HLW

disposal during the renewal term beyond those discussed in the GEIS.

C Nonradiological impacts of the uranium fuel cycle. Based on information in the GEIS, the

Commission found that: 

The nonradiological impacts of the uranium fuel cycle resulting from the 

renewal of an operating license for any plant are found to be small.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER (Entergy 2006), the staffs site visit, the scoping process, evaluation

| of other available information, or consideration of public comments. Therefore, the staff
Fuel Cycle

July 2007 6-7 NUREG-1437, Supplement 29

concludes that there would be no nonradiological impacts of the uranium fuel cycle during

the renewal term beyond those discussed in the GEIS. 

C Low-level waste storage and disposal. Based on information in the GEIS, the Commission

found that:

The comprehensive regulatory controls that are in place and the low public

doses being achieved at reactors ensure that the radiological impacts to the

environment will remain small during the term of a renewed license. The

maximum additional on-site land that may be required for low-level waste

storage during the term of a renewed license and associated impacts will be

small. Nonradiological impacts on air and water will be negligible. The

radiological and nonradiological environmental impacts of long-term disposal

of low-level waste from any individual plant at licensed sites are small. In

addition, the Commission concludes that there is reasonable assurance that

sufficient low-level waste disposal capacity will be made available when

needed for facilities to be decommissioned consistent with NRC

decommissioning requirements.

The staff has not identified any new and significant information during its independent

review of the PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of |

other available information, or consideration of public comments. Therefore, the staff |

concludes that there would be no impacts of low-level waste storage and disposal

associated with the renewal term beyond those discussed in the GEIS.

C Mixed waste storage and disposal. Based on information in the GEIS, the Commission

found that:

The comprehensive regulatory controls and the facilities and procedures that

are in place ensure proper handling and storage, as well as negligible doses

and exposure to toxic materials for the public and the environment at all plants. 

License renewal will not increase the small, continuing risk to human health

and the environment posed by mixed waste at all plants. The radiological and

nonradiological environmental impacts of long-term disposal of mixed waste

from any individual plant at licensed sites are small. In addition, the

Commission concludes that there is reasonable assurance that sufficient mixed

waste disposal capacity will be made available when needed for facilities to be

decommissioned consistent with NRC decommissioning requirements.

The staff has not identified any new and significant information during its independent review of

the PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of other available |

information, or consideration of public comments. Therefore, the staff concludes that there |
Fuel Cycle

NUREG-1437, Supplement 29 6-8 July 2007

would be no impacts of mixed waste storage and disposal associated with the renewal term

beyond those discussed in the GEIS.

C On-site spent fuel. Based on information in the GEIS, the Commission found that:

The expected increase in the volume of spent fuel from an additional 20 years

of operation can be safely accommodated on-site with small environmental

effects through dry or pool storage at all plants if a permanent repository or

monitored retrievable storage is not available.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of

| other available information, or consideration of public comments. Therefore, the staff

concludes that there would be no impacts of on-site spent fuel associated with license

renewal beyond those discussed in the GEIS. 

C Nonradiological waste. Based on information in the GEIS, the Commission found that:

No changes to generating systems are anticipated for license renewal. 

Facilities and procedures are in place to ensure continued proper handling

and disposal at all plants.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of

| other available information, or consideration of public comments. Therefore, the staff

concludes that there would be no nonradiological waste impacts during the renewal term

beyond those discussed in the GEIS.

C Transportation. Based on information contained in the GEIS, the Commission found that:

The impacts of transporting spent fuel enriched up to 5 percent uranium-235

with average burnup for the peak rod to current levels approved by NRC up

to 62,000 MWd/MTU (megawatt-days per metric ton of uranium) and the

cumulative impacts of transporting high-level waste to a single repository,

such as Yucca Mountain, Nevada are found to be consistent with the impact

values contained in 10 CFR 51.52(c), Summary Table S-4 – Environmental

Impact of Transportation of Fuel and Waste to and from One Light-WaterCooled Nuclear Power Reactor. If fuel enrichment or burnup conditions are

not met, the applicant must submit an assessment of the implications for the

environmental impact values reported in § 51.52.
Fuel Cycle

July 2007 6-9 NUREG-1437, Supplement 29

PNPS meets the fuel-enrichment and burnup conditions set forth in Addendum 1 to the

GEIS. The staff has not identified any new and significant information during its

independent review of the PNPS ER (Entergy 2006), the site visit, the scoping process,

evaluation of other available information, or consideration of public comments. Therefore, |

the staff concludes that there would be no impacts of transportation associated with license

renewal beyond those discussed in the GEIS. 

There are no Category 2 issues for the uranium fuel cycle and solid waste management.

6.2 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.”

10 CFR Part 63. Code of Federal Regulations, Title 10, Energy, Part 63, “Disposal of HighLevel Radioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada.” 

40 CFR Part 191. Code of Federal Regulations, Title 40, Protection of Environment, Part 191,

“Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear

Fuel, High-Level and Transuranic Radioactive Waste.”

Department of Energy (DOE). 1980. Final Environmental Impact Statement: Management of

Commercially Generated Radioactive Waste. DOE/EIS-0046F, Washington, DC. |

Entergy Nuclear Operations, Inc. (Entergy). 2006. Applicant’s Environmental Report –

Operating License Renewal Stage Pilgrim Nuclear Power Station. Docket Number 50-293, |

Plymouth, Massachusetts.

Joint Resolution 87, 2002. Public Law 107-200, 116 Stat 735.

National Academy of Sciences (NAS). 1995. Technical Bases for Yucca Mountain Standards. 

Washington, DC. |

National Environmental Policy Act of 1969, as amended (NEPA) 42 USC 4321, et seq.

Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, DC. |
Fuel Cycle

NUREG-1437, Supplement 29 6-10 July 2007

Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1,

Summary of findings on NEPA issues for license renewal of nuclear power plants,” Final Report. 

| NUREG-1437, Volume 1, Addendum 1, Washington, DC.
(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

July 2007 7-1 NUREG-1437, Supplement 29

7.0 Environmental Impacts of Decommissioning

Environmental impacts from the activities associated with the decommissioning of any reactor

before or at the end of an initial or renewed license are evaluated in the Generic Environmental

Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the

Decommissioning of Nuclear Power Reactors, NUREG-0586, Supplement 1 (NRC 2002). The

staff's evaluation of the environmental impacts of decommissioning presented in NUREG-0586,

Supplement 1 identifies a range of impacts for each environmental issue. 

The incremental environmental impacts associated with decommissioning activities resulting

from continued plant operation during the renewal term are discussed in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437,

Volumes 1 and 2 (NRC 1996; 1999)(a). The GEIS includes a determination of whether the

analysis of the environmental issue could be applied to all plants and whether additional

mitigation measures would be warranted. Issues were then assigned a Category 1 or a

Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of

the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system or

other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to

the impacts (except for collective off-site radiological impacts from the fuel cycle and from

high level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures are

likely not to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

required unless new and significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1;

therefore, additional plant-specific review of these issues is required. There are no Category 2

issues related to decommissioning.
Environmental Impacts of Decommissioning

NUREG-1437, Supplement 29 7-2 July 2007

7.1 Decommissioning

Category 1 issues in Table B-1 of Title 10 of the Code of Federal Regulations (CFR) Part 51,

Subpart A, Appendix B that are applicable to Pilgrim Nuclear Power Station (PNPS)

decommissioning following the renewal term are listed in Table 7-1. Entergy Nuclear

Operations, Inc. (Entergy) stated in its Environmental Report (ER) (Entergy 2006) that it is

aware of no new and significant information regarding the environmental impacts of PNPS

license renewal. The staff has not identified any new and significant information during its

| independent review of the PNPS ER (Entergy 2006), the site visit, the scoping process,

| evaluation of other available information, or consideration of public comments. Therefore, the

staff concludes that there are no impacts related to these issues beyond those discussed in the

GEIS. For all of these issues, the staff concluded in the GEIS that the impacts are SMALL, and

additional plant-specific mitigation measures are not likely to be sufficiently beneficial to be

warranted.

Table 7-1. Category 1 Issues Applicable to the Decommissioning of PNPS

Following the Renewal Term

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section

DECOMMISSIONING

Radiation doses 7.3.1

Waste management 7.3.2

Air quality 7.3.3

Water quality 7.3.4

Ecological resources 7.3.5

Socioeconomic impacts 7.3.7

A brief description of the staff’s review and the GEIS conclusions, as codified in Table B-1, 

10 CFR Part 51, for each of the issues follows:

C Radiation doses. Based on information in the GEIS, the Commission found that:

Doses to the public will be well below applicable regulatory standards regardless

of which decommissioning method is used. Occupational doses would increase

no more than 1 man-rem caused by buildup of long-lived radionuclides during the

license renewal term.

The staff has not identified any new and significant information during its independent

| review of the PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of

| other available information, or consideration of public comments. Therefore, the staff
Environmental Impacts of Decommissioning

July 2007 7-3 NUREG-1437, Supplement 29

concludes that there would be no radiation dose impacts associated with decommissioning

following the license renewal term beyond those discussed in the GEIS.

C Waste management. Based on information in the GEIS, the Commission found that:

Decommissioning at the end of a 20-year license renewal period would generate no

more solid wastes than at the end of the current license term. No increase in the

quantities of Class C or greater than Class C wastes would be expected.

The staff has not identified any new and significant information during its independent review of

the PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of other available |

information, or consideration of public comments. Therefore, the staff concludes that there |

would be no impacts from solid waste associated with decommissioning following the license

renewal term beyond those discussed in the GEIS.

C Air quality. Based on information in the GEIS, the Commission found that:

Air quality impacts of decommissioning are expected to be negligible either at the

end of the current operating term or at the end of the license renewal term.

The staff has not identified any new and significant information during its independent review of

the PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of other available |

information, or consideration of public comments. Therefore, the staff concludes that there |

would be no impacts on air quality associated with decommissioning following the license

renewal term beyond those discussed in the GEIS.

C Water quality. Based on information in the GEIS, the Commission found that:

The potential for significant water quality impacts from erosion or spills is no

greater whether decommissioning occurs after a 20-year license renewal period

or after the original 40-year operation period, and measures are readily available

to avoid such impacts.

The staff has not identified any new and significant information during its independent review of

the PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of other available |

information, or consideration of public comments. Therefore, the staff concludes that there |

would be no impacts on water quality associated with decommissioning following the license

renewal term beyond those discussed in the GEIS.
Environmental Impacts of Decommissioning

NUREG-1437, Supplement 29 7-4 July 2007

C Ecological resources. Based on information in the GEIS, the Commission found that:

Decommissioning after either the initial operating period or after a 20-year

license renewal period is not expected to have any direct ecological impacts.

The staff has not identified any new and significant information during its independent review of

| the PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of other available

| information, or consideration of public comments. Therefore, the staff concludes that there

would be no impacts on ecological resources associated with decommissioning following the

license renewal term beyond those discussed in the GEIS.

C Socioeconomic Impacts. Based on information in the GEIS, the Commission found that:

Decommissioning would have some short-term socioeconomic impacts. The

impacts would not be increased by delaying decommissioning until the end of a

20-year relicense period, but they might be decreased by population and

economic growth.

The staff has not identified any new and significant information during its independent review of

| the PNPS ER (Entergy 2006), the site visit, the scoping process, evaluation of other available

| information, or consideration of public comments. Therefore, the staff concludes that there

would be no socioeconomic impacts associated with decommissioning following the license

renewal term beyond those discussed in the GEIS.

7.2 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

Entergy Nuclear Generation Company (Entergy). 2006. Applicant’s Environmental Report –

| Operating License Renewal Stage Pilgrim Nuclear Power Station. Docket Number 50-293,

Plymouth, Massachusetts.

Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for

| License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, DC.

Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1,

Summary of findings on NEPA issues for license renewal of nuclear power plants,” Final Report. 

| NUREG-1437, Volume 1, Addendum 1, Washington, DC.
Environmental Impacts of Decommissioning

July 2007 7-5 NUREG-1437, Supplement 29

Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement on

Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of

Nuclear Power Reactors. NUREG-0586, Supplement 1, Volumes 1 and 2, Washington, DC. |

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

July 2007 8-1 NUREG-1437, Supplement 29

8.0 Environmental Impacts of Alternatives to 

License Renewal

This chapter examines the potential environmental impacts associated with denying the renewal

of an operating license (OL) (i.e., the no-action alternative); the potential environmental impacts

from electric generating sources other than Pilgrim Nuclear Power Station (PNPS); the

possibility of purchasing electric power from other sources to replace power generated by

PNPS and the associated environmental impacts; the potential environmental impacts from a

combination of generating and conservation measures; and other generation alternatives that

were deemed unsuitable for replacement of power generated by PNPS. The environmental

impacts are evaluated using the U.S. Nuclear Regulatory Commission’s (NRC’s) three-level

standard of significance—SMALL, MODERATE, or LARGE—developed using the Council on

Environmental Quality guidelines and set forth in the footnotes to Table B-1 of Title 10 of the

Code of Federal Regulations (CFR) Part 51, Subpart A, Appendix B:

SMALL - Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

MODERATE - Environmental effects are sufficient to alter noticeably, but not to destabilize

important attributes of the resource.

LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.

The impact categories evaluated in this chapter are the same as those used in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437,

Volumes 1 and 2 (NRC 1996, 1999) , with the additional impact categories of environmental |

(a)

justice and transportation.

8.1 No-action Alternative

The NRC's regulations implementing the National Environmental Policy Act of 1969, as

amended (NEPA) specify that the no-action alternative be discussed in an NRC environmental

impact statement (EIS) [see 10 CFR Part 51, Subpart A, Appendix A(4)]. For license renewal,

the no-action alternative refers to a scenario in which the NRC would not renew the OL for

PNPS and Entergy Nuclear Operations, Inc. (Entergy) would then cease plant operations by the

end of the current license and initiate decommissioning of the plant.
Environmental Impacts of License Renewal

| (b) Appendix J of NUREG-0586 Supplement 1 discusses the socioeconomic impacts of plant closure, but

the results of the analysis in Appendix J are not incorporated in the analysis presented in the main

body of the NUREG.

NUREG-1437, Supplement 29 8-2 July 2007

Entergy will be required to shut down PNPS and comply with NRC decommissioning

requirements in 10 CFR 50.82 whether or not the OL is renewed. If the PNPS OL is renewed,

shutdown of the facility and decommissioning activities will not be avoided, but will be

postponed for up to an additional 20 years.

The environmental impacts associated with decommissioning, following a license renewal

period of up to 20 years or following the no-action alternative, would be bounded by the

| discussion of impacts in Chapter 7 of the GEIS, Chapter 7 of this supplemental EIS (SEIS), and

the Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities,

NUREG 0586, Supplement 1 (NRC 2002). The impacts of decommissioning after 60 years of

operation are not expected to be significantly different from those occurring after 40 years of

operation.

Impacts from the decision to permanently cease operations are not considered in

| NUREG-0586, Supplement 1 . Therefore, immediate impacts that occur between plant (b)

shutdown and the beginning of decommissioning are considered here. These impacts will

occur when the unit shuts down regardless of whether the license is renewed or not and are

discussed below, with the results presented in Table 8-1, which is presented at the end of this

section (Section 8.1). Plant shutdown will result in a net reduction in power production capacity. 

The power not generated by PNPS during the license renewal term would likely be replaced by

(1) power supplied by other independent producers using generating technologies that will differ

from that employed at PNPS, (2) demand-side management (DSM) and energy conservation,

or (3) some combination of these options. The environmental impacts of these options are

discussed in Section 8.2.

8.1.1 Land Use

In Chapter 4, the staff concluded that the impacts of continued plant operation on land use

would be SMALL. On-site land use will not be affected immediately by the cessation of

operations. Plant structures and other facilities are likely to remain in place until

decommissioning. In the near term the transmission line associated with PNPS will likely be

retained until final disposition of the dormant facility and site are ascertained. In the long term,

it is possible that the transmission lines that extend from the on-site switch yard to

interconnections at Jordan and Snake Hill Roads will be removed at which point maintenance of

the right-of-way (ROW) will discontinue and the ROW will revert to the conditions found in 
Environmental Impacts of License Renewal

July 2007 8-3 NUREG-1437, Supplement 29

adjacent areas. Also, as a result of plant shutdown, there would be a reduction in uranium

mining activity positively impacting approximately 715 acres (ac). Therefore, the staff

concludes that the impacts on land use from plant shutdown would be SMALL.

8.1.2 Ecology

In Chapter 4 of this SEIS, the NRC staff concluded that the ecological impacts of continued |

plant operation ranged from SMALL to MODERATE. Cessation of operations will be

accompanied by elimination of the cooling water intake flow and the facility's thermal plume.

The environmental impacts to aquatic species, including threatened and endangered species,

associated with these changes are generally positive. The impacts of plant closure on the

terrestrial ecosystem range between negative and positive depending on final disposition of the

Entergy Woodlands area across which the PNPS transmission lines run. Currently, there is an

active management program on that property that preserves habitat and controls invasive

species. Cessation of that program would produce negative impact. Therefore, the staff

concludes that overall ecological impacts from shutdown of the plant would be SMALL.

8.1.3 Water Use and Quality–Surface Water

In Chapter 4 of this SEIS, the NRC staff concluded that impacts of continued plant operation on |

surface water use and quality were SMALL. When the plant stops operating there will be an

immediate reduction in the consumptive use of water because of the elimination of the cooling

water intake and in the amount of heat discharged to Cape Cod Bay. Therefore, the staff

concludes that the impacts on surface water use and quality from plant shutdown would be

SMALL.

8.1.4 Water Use and Quality–Groundwater

In Chapter 4, the staff determined that the facility does not utilize on-site groundwater

resources. In addition, impacts of continued subsurface discharge of treated sanitary wastes

by the facility were determined to be SMALL. When the plant stops operating, there will be an

immediate reduction in discharge of treated sanitary waste. Therefore, the staff concludes that

groundwater quality impacts from shutdown of the plant would be SMALL.

8.1.5 Air Quality

In Chapter 4, the staff found the impacts of continued plant operation on air quality to be

SMALL. When the plant stops operating, there will be a reduction in emissions from activities

related to plant operation such as use of diesel generators and workers transportation. 

Therefore, the staff concludes that the impact on air quality from shutdown of the plant would

be SMALL.
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-4 July 2007

8.1.6 Waste

The impacts of waste generated by continued plant operation are discussed in Chapter 6. The

impacts of low-level and mixed waste from plant operation are characterized as SMALL. When

the plant stops operating, the plant will stop generating high-level waste and generation of lowlevel and mixed waste associated with plant operation and maintenance will be reduced. 

Therefore, the staff concludes that the impact of waste generated after shutdown of the plant

would be SMALL.

8.1.7 Human Health

| In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of continued plant

operation on human health were SMALL. After the cessation of operations, the amount of

radioactive material released to the environment in gaseous and liquid forms will be reduced. 

Therefore, the staff concludes that the impact of shutdown of the plant on human health would

be SMALL. In addition, the variety of potential accidents at the plant will be reduced to a limited

| set associated with shutdown events and fuel handling. In Chapter 5 of this SEIS, the NRC

staff concluded that the impacts of accidents during operation were SMALL. Therefore, the

staff concludes that the impacts of potential accidents following shutdown of the plant would be

SMALL.

8.1.8 Socioeconomics

In Chapter 4, the NRC staff concluded that the socioeconomic impacts of continued plant

operation would be SMALL. But, should the plant shutdown, there would be immediate

socioeconomic impacts due to the loss of jobs (approximately 700) and there may also be an

immediate reduction in property tax revenues for Plymouth Township. These impacts may,

however, be offset as a result of the projected regional economic growth. The NRC staff

concludes that the socioeconomic impacts of plant shutdown would be MODERATE. See

Appendix J to NUREG-0586, Supplement 1 (NRC 2002), for additional discussion of the

potential impacts of plant shutdown.

8.1.9 Socioeconomics (Transportation)

In Chapter 4, the staff concluded that the impacts of continued plant operation on transportation

would be SMALL. Cessation of operations will be accompanied by reduced traffic in the vicinity

of the plant. Most of the reduction will be associated with a reduction in plant workforce, but

there will also be a reduction in shipment of maintenance materials to and from the plant.

Therefore, the staff concludes that the impacts of plant closure on transportation would be

SMALL.
Environmental Impacts of License Renewal

July 2007 8-5 NUREG-1437, Supplement 29

8.1.10 Aesthetics

In Chapter 4, the staff concluded that the aesthetic impacts of continued plant operation would

be SMALL. Plant structures and other facilities are likely to remain in place until

decommissioning. Upon decommissioning the number of on-site structures would be reduced.

Therefore, the staff concludes that the aesthetic impacts of plant closure would be SMALL.

8.1.11 Historic and Archaeological Resources

In Chapter 4, the staff concluded that the impacts of continued plant operation on historic and

archaeological resources would be SMALL. On-site land use will not be affected immediately

by the cessation of operations. Plant structures and other facilities are likely to remain in place

until decommissioning. The transmission lines associated with the project may ultimately be

removed once the facility stops operating and, should this occur, maintenance of the

transmission line ROW will cease. Therefore, the staff concludes that the impacts on historic

and archaeological resources from plant shutdown would be SMALL.

8.1.12 Environmental Justice

In Chapter 4, the staff concluded that the environmental justice impact of continued operation of

the plant would be SMALL because continued operation of the plant would not have a

disproportionately high and adverse impact on minority and low-income populations. Shutdown

of the plant likewise is not expected to disproportionately impact minority and low-income

populations. The staff concludes that the environmental justice impacts of plant shutdown

would be SMALL. See Appendix J to NUREG-0586, Supplement 1 (NRC 2002), for additional

discussion of these impacts.
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-6 July 2007

Table 8-1. Summary of Environmental Impacts of the No-action Alternative

Impact Category Impact Comment

Land Use SMALL Impacts are expected to be SMALL because plant

shutdown is expected to result in few changes to off-site

and on-site land use, and transition to alternate uses is

expected over an extended timeframe.

Ecology SMALL Small negative impacts to terrestrial ecology of

conservation management of transmission corridor

ceases. Moderate positive impacts to local winter

flounder populations.

W ater Use and QualitySurface WaterSMALL Impacts are expected to be SMALL because surface

water intake and discharges will decrease. 

W ater Use and QualityGroundwaterSMALL Impacts are expected to be SMALL because

groundwater discharges will decrease.

Air Quality SMALL Impacts are expected to be SMALL because discharges

related to plant operation and worker transportation will

decrease. 

W aste SMALL Impacts are expected to be SMALL because generation

of high-level waste will stop, and generation of low-level

and mixed waste will decrease.

Human Health SMALL Impacts are expected to be SMALL because radiological

doses to workers and members of the public, which are

within regulatory limits, will be reduced.

Socioeconomics MODERATE Impacts are expected to be MODERATE because of a

decrease in employment and tax revenues.

Socioeconomics

(Transportation)

SMALL Impacts are expected to be SMALL because the

decrease in employment would reduce traffic.

Aesthetics SMALL Impacts are expected to SMALL because plant

structures will remain for an extended period. 

Historic and Archaeological

Resources

SMALL Impacts are expected to be SMALL because shutdown

of the plant will not change land use.

Environmental Justice SMALL Impacts are expected to be SMALL because there are

no disproportionate impacts to minority or low income

populations.
Environmental Impacts of License Renewal

(c) A greenfield site is assumed to be an undeveloped site with no previous construction. |

(d) A baseload plant normally operates to supply all or part of the minimum continuous load of a system |

and consequently produces electricity at an essentially constant rate. Nuclear power plants are

commonly used for baseload generation; and generally run near full load.

July 2007 8-7 NUREG-1437, Supplement 29

8.2 Alternative Energy Sources

This section discusses the environmental impacts associated with developing alternative

sources of electric power to replace power generated by PNPS under the assumption that the

OL for PNPS is not renewed. The order of alternative energy sources presented in this section

does not imply which alternative would be most likely to occur or which is expected to have the

least environmental impacts.

The following central generating station alternatives are considered in detail:

 C coal-fired generation at an alternate greenfield site (Section 8.2.1), |

(c)

 C natural gas-fired generation at either the PNPS site or an alternate greenfield

site (Section 8.2.2), and

 C nuclear generation at an alternate greenfield site (Section 8.2.3).

The alternative of importing power to replace power generated at PNPS is discussed in Section

8.2.4. Other power generation alternatives and conservation alternatives considered by the

staff are discussed in Section 8.2.5. Section 8.2.6 discusses the environmental impacts of a

combination of generation and conservation alternatives.

Each year the Energy Information Administration (EIA), a component of the U.S. Department of

Energy (DOE), issues an Annual Energy Outlook. In its Annual Energy Outlook 2006 with

Projections to 2030, EIA projects that natural gas-fired plants will account for approximately 40

percent of new electric generating capacity between the years 2004 and 2030 

(DOE/EIA2006a). This technology is designed primarily to supply peak and intermediate

electric generating capacity, but combined-cycle gas-fired systems can also be used to meet

baseload requirements. Coal-fired plants are projected by EIA to account for approximately |

(d)

50 percent of new capacity additions during this period. Coal-fired plants are generally used to

meet baseload requirements. Renewable energy sources, primarily wind, biomass gasification,

and municipal solid waste units, are projected by EIA to account for 8 percent of capacity

additions.

EIA’s projections of technologies are based on the assumption that providers of new generating

capacity will seek to minimize cost while meeting applicable environmental requirements. 
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-8 July 2007

According to EIA, advanced coal-fired and advanced combined-cycle generating facilities are

expected to be approximately competitive with each other in 2015, on a total evaluated cost of

production basis, while advanced coal-burning facilities are expected to gain a competitive edge

by 2030 (DOE/EIA 2006a). EIA projects that oil-fired plants will account for little or none of the

new generating capacity additions in the United States (U.S.) during the 2004 to 2030 time

frame because of high fuel costs (DOE/EIA 2006a). EIA also projects that about 6 gigawatts of

new nuclear power generating capacity will be constructed prior to 2020 when the Energy

Policy Act of 2005 tax credits expire (DOE/EIA 2006a). NRC established a reactor licensing

program organization to manage reactor and site licensing applications (NRC 2001). Several

site licensing applications are currently under review by the NRC and nuclear operating

companies have announced their intention to submit reactor license applications beginning in

late 2007. NRC has announced plans to reorganize the agency to further prepare for the

industry’s announced interest in licensing and building new nuclear plants (NRC 2006). Thus, a

| new nuclear plant alternative for replacing power generated by PNPS is considered in this SEIS

and resulting impacts are presented in Section 8.2.3.

Since PNPS has a gross electric output of 715 megawatts electric [MW(e)], the staff evaluated

coal, natural gas, and new nuclear alternatives having comparable capabilities. As discussed

further below, siting a 715 MW(e) alternative technology depends, in part, on the land area

available at PNPS. If the available land at PNPS is inadequate to support a particular

technology, the analysis addresses impacts under the assumption that the new generating

capacity is built at a hypothetical greenfield site. For technologies that can be constructed at

PNPS, the analysis considers impacts at both PNPS and at a greenfield site. The location of

the hypothetical greenfield site is not specified herein.

Since PNPS began operating in 1972, the era of regulated utilities generating power for

distribution within their service territories has largely passed. Today New England in general,

and Massachusetts in particular, obtain most electric power from independent power producers

that operate generating facilities throughout and beyond the region. Thus, both appropriate

market conditions as well as siting opportunities would have to be present for one of the

alternative technologies evaluated in Section 8.2 to actually be developed.

While the greenfield site considered here need not be situated within the New England region,

the availability of transmission line capacity to deliver the output of an alternative technology to

current PNPS customers could significantly constrain siting choices. Based on a recent DOE

Report (DOE/EIA 2006b) it appears that transmission line constraints currently occur within

both New England and adjoining New York State. According to the DOE, new projects are

expected to ease transmission line congestion in New England, though continued growth in

demand and the retirement of older facilities will result in a need to consider investments in both

new generating and transmission line capacity (DOE/EIA 2006b). Finally, the feasibility of

finding a greenfield site and obtaining approvals to construct either a coal-fired or nuclear
Environmental Impacts of License Renewal

(e) Heat rate is a measure of generating station thermal efficiency. In English units, it is generally |

expressed in British thermal units (BTUs) per net kilowatt-hour (kW h). It is computed by dividing the

total BTU content of the fuel burned for electric generation by the resulting kW h generation.

(f) The capacity factor is the ratio of electricity generated, for the period of time considered, to the energy

that could have been generated at continuous full-power operation during the same period. |

July 2007 8-9 NUREG-1437, Supplement 29

facility there by 2012, when the PNPS OL expires, is questionable. This difficulty is not

addressed in Section 8.2, but rather it is assumed that power would be obtained from various

sources in the interim while one of the alternate technologies is constructed and comes on-line. 

In contrast, it may be possible for a gas-fired facility to be operational by 2012 at either the

PNPS site or at a greenfield location.

8.2.1 Coal-Fired Generation

The assumptions and numerical values used in Section 8.2.1 are based on the staff’s

independent assessment and on information provided by Entergy in the PNPS Environmental

Report (ER) (Entergy 2006). Where information from the PNPS ER was used, it was

independently reviewed by the staff and compared to environmental impact information in the

GEIS. Impacts of a coal-fired alternative evaluated by the staff assume that the new plant

would have a gross electrical capacity of 715 MW(e); this differs somewhat from the

assumption made in the ER. Furthermore, while the PNPS OL renewal period is only 20 years,

the impact of operating a coal-fired alternative for a full 40 years is considered, since 40 years

is the expected operating life of a new coal-fired plant.

There is insufficient land area at PNPS to support operations of a 715 gross MW(e) coal-fired

alternative. Therefore, the coal-fired alternative is analyzed only for a greenfield site. Based on

Table 8-1 of the GEIS, a pulverized coal-fired facility requires approximately 1.7 ac of land per

MW(e). To replace PNPS with a coal-fired facility a 1215 ac parcel would be needed while only

140 ac are available at PNPS. It is unrealistic to think that a pulverized coal-fired facility with

associated coal yard, waste disposal area, and transportation systems could be accommodated

at PNPS. It should be noted that several of the newer coal utilization technologies (e.g., |

Integrated Gasification Combined Cycle [IGCC]) could be accommodated on smaller sites than |

estimated here. However, these alternate technologies would still involve transportation of fuel

to the power plant and that facet of coal combustion which involves construction of either a new

rail line or coal pier, is not compatible with conditions of the PNPS site.

The coal-fired plant would consume approximately 2.18 million tons per year of pulverized

bituminous coal with an ash content of approximately 8.2 percent. Entergy assumes a heat 

rate of 10,200 BTU/kWh and a capacity factor of 0.85 in the ER (Entergy 2006). After |

(e) (f)

combustion, 99.9 percent of the ash would be collected and disposed of at the plant site. In 
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-10 July 2007

addition, approximately 77,700 tons of scrubber sludge would also be disposed on-site based

on annual lime usage of approximately 26,300 tons. Lime is used in the scrubbing process for

con 2trol of sulfur dioxide (SO ) emissions.

Coal and lime would be delivered to the generating station site by either rail or barge. If

deliveries were by rail, then a rail spur would be constructed to bring coal onto the site from a

main rail line. Should waterborne delivery prove feasible, a receiving dock would be

constructed for berthing either barges or colliers alongside the facility. Development of a coalfired facility at an alternate site would also necessitate the construction of a transmission line to

connect the new plant to the regional transmission system.

8.2.1.1 Closed-Cycle Cooling System

For purposes of this section, the staff assumed that a coal-fired plant located at an alternate

site would use a closed-cycle cooling system.

The overall impacts of the coal-fired generating system are discussed in the following sections

and summarized in Table 8-2, at the end of this section (Section 8.2.1.1). The implications of

constructing a new coal-fired plant at an alternate greenfield site will depend on the actual

location of that site; however, as presented below, a general evaluation of impacts is possible.

C Land Use

Construction of a 715 gross MW(e) pulverized coal-fired alternative at a greenfield site

could impact up to 1215 ac of land (NRC 1996). Additional land would be needed to bring a

rail spur onto the greenfield site and, as well, for a transmission line to deliver the plant’s

output to the nearest transmission inter-tie. Depending on the length of transmission line

and rail line routing, this alternative would result in MODERATE to LARGE land-use impacts

at and in the vicinity of the greenfield site.

Additionally, land use changes would occur at an undetermined coal mining area where

approximately 24 square miles (mi ) would be affected for mining coal and disposing of 2

mining wastes to support a 715 MW(e) coal-fired power plant [the GEIS estimates that

approximately 34 mi would be disturbed for a 1000 MW(e) coal-fired plant (NRC 1996)] 2

C Ecology

Siting a coal-fired plant at a greenfield site would introduce construction and operating

impacts. Ecological resources would be altered due to the need to convert roughly 1215 ac

of land to industrial use (generating facilities, coal storage, ash and scrubber sludge

disposal). Even if some of the site had been previously disturbed, it is expected that
Environmental Impacts of License Renewal

July 2007 8-11 NUREG-1437, Supplement 29

impacts of developing a 1215 ac area would include wildlife habitat loss, reduced

productivity, habitat fragmentation, and reduction in on-site biological diversity.

Use of a nearby surface water resource to provide cooling tower make-up would have some

impact on local aquatic resources. Construction and maintenance of a transmission line

and rail spur would incrementally add to the terrestrial ecological impacts. Overall, the staff

concludes that ecological impacts at an alternate site would be MODERATE to LARGE. 

• Water Use and Quality

Surface Water 

For the coal-fired alternative at a greenfield site, impacts to surface waters would result from

withdrawal of water for various operating needs of the facility. These operating needs would

include cooling tower make-up and possibly auxiliary cooling for equipment and potable

water requirements.

Discharges to surface water could result from cooling tower blowdown, coal pile runoff, and

runoff from coal ash and scrubber byproduct disposal areas. Both the use of surface

waters and runoff to surface waters would be regulated by the State [or U.S. Environmental

Protection Agency (EPA) in the case of a facility built in Massachusetts] within which the

facility is located. Consequently, it can be expected that a coal-fired facility at a greenfield

site would comply with requirements of a discharge permit and would legally be obligated to

meet water quality standards. Overall, the staff concludes that the potential impacts to

surface water resources and water quality would be SMALL to MODERATE. The impact

level would importantly depend on the discharge volume and characteristics of the receiving

water body.

Groundwater

Groundwater use at an alternate site for potable water purposes could potentially occur. It

is also possible that other plant requirements could be met with groundwater depending on

site-specific hydrogeologic conditions. Potential impacts to groundwater quality may occur

as a result of on-site coal storage and on-site disposal of ash and scrubber sludge. In all

cases, it is expected that a coal-fired facility would be obligated to comply with a

groundwater use and discharge permit issued by the State within which the facility is

located. Therefore, the staff concludes that the potential impacts to groundwater resources

would be SMALL to MODERATE.
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-12 July 2007

C Air Quality

The air quality impacts of a pulverized coal-fired facility vary considerably from those of a

compa x x rable nuclear plant, due to emissions of sulfur oxides (SO ), nitrogen oxides (NO ),

particulates, carbon monoxide (CO), hazardous air pollutants (e.g., mercury) and naturally

occurring radioactive materials.

PNPS is located in Plymouth County, Massachusetts which has been designated an

attainment area (i.e., meets the National Ambient Air Quality Standards promulgated by

EPA 2 2 and found in 40 CFR Part 50 for CO, NO , lead, and SO ). In addition, Plymouth

County is in attainment of the Federal standards for particulate air pollution [less than

10 10 2.5 (PM ) and less than 2.5 (PM ) microns (ìm)]. However, Plymouth County, as part of

the Boston-Lawrence-Worcester ozone non-attainment area, does not meet the Federal 

8-hour standard for ozone.

The EPA has various regulatory requirements for visibility protection in 40 CFR Part 51,

Subpart P, including a specific requirement for review of any major stationary source in an

area designated as attainment or unclassified under the Clean Air Act (CAA). These

requirements could apply to the coal-fired alternative depending on the attainment status of

the region within which the alternative is located. As noted above, the Plymouth County

vicinity is in attainment of all Federal criteria pollutants except ozone.

A new coal-fired generating plant located in Massachusetts would need a prevention of

significant deterioration permit issued under Title 1, Part C, of the CAA. The project would

also need an operating permit under Title V of the CAA. The plant would be required to

comply with the new source performance standards for such plants as set forth in

| 40 CFR Part 60 Subpart D(a). The standards establish limits for particulate matter and

opaci 2 X ty (40 CFR 60.42a), SO (40 CFR 60.43a), and NO (40 CFR 60.44a).

Section 169A of the CAA (42 USC 7401) establishes a national goal of preventing future

and remedying existing impairment of visibility in mandatory Class I Federal areas when

impairment results from man-made air pollution. EPA issued a regional haze rule on July 1,

1999 [64 FR 35714 (EPA 1999)]. The rule specifies that for each mandatory Class I federal

area located within a state, the State must establish goals that provide for reasonable

progress towards achieving natural visibility conditions. The reasonable progress goals

must provide for an improvement in visibility for the most impaired days over the period of

the implementation plan and ensure no degradation in visibility for the least impaired days

over the same period (40 CFR 51.308[d][1]). If a coal-fired plant were located close to a

mandatory Class I area (there are none in Massachusetts), additional air pollution control

requirements could be imposed.
Environmental Impacts of License Renewal

July 2007 8-13 NUREG-1437, Supplement 29

In 1998, the EPA issued a rule requiring 22 eastern states, including Massachusetts, to

x x revise their state implementation plans to reduce NO emissions. NO emissions contribute

x

to violations of the national ambient air quality standard for ozone. The total amount of NO

which can be emitted by each of the 22 states in the year 2007 ozone season (May 1 to 

September 30) is set out at 40 CFR 51.121(e). For Massachusetts, the amount is 85,296

tons.

EPA issued the Clean Air Interstate Rule (CAIR) in May 2005 [70 FR 25162 (EPA 2005)]. 

CA 2IR provides a Federal framework requiring certain states to reduce emissions of SO and

Nox. EPA anticipates that states will achieve this reduction primarily by limiting emissions

from the power generation sector. CAIR covers 28 eastern states and any new fossil-fired

power plant sited in Massachusetts would be subject to the CAIR limitations.

Air quality impacts for various pollutants are as follows:

Sulfur oxides emissions. Entergy indicates in its ER that a coal-fired plant would use a

hydrated lime-wet scrubbing system for flue gas desulfurization (Entergy 2006). A new

coal-fired power plant would be subject to the requirements in Title IV of the CAA. Title IV

was enacted x x to reduce emissions of SO and NO , the two principal precursors of acid rain,

by restricting emissions of these pollutants from power plants. Title IV caps aggregate

annual x x power plant SO emissions and imposes controls on SO emissions through a

system x of marketable allowances. EPA issues one allowance for each ton of SO that a unit

is allowed to emit.

New x units do not receive allowances, but are required to have allowances to cover their SO

emissions. Owners of new units must, therefore, acquire allowances from owners of other

power p xlants or reduce SO emissions at other power plants they own. Allowances can be

banked for use in future years. Thus, a new coal-fired power plant would not add to net

x x regional SO emissions, although it might contribute to the local SO burden.

Regardless x, SO emissions would be greater for the coal alternative than the OL renewal

alternative. The staff estimates that with using the hydrated lime-wet scrubbing system to

cont xrol SO emissions, the stack emissions of this constituent from a new 715 MW(e) coalfired facility would be approximately 1428 tons per year.

Nitrogen oxides emissions. Section 407 of the CAA establishes technology-based emission

x x limitations for NO emissions. The market-based allowance system used for SO emissions

x

is not used for NO emissions. A new coal-fired power plant would be subject to the new

source performance standards for such plants at 40 CFR 60.44a(d)(1). 
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-14 July 2007

This regulation, issued September 16, 1998 [63 FR 49453 (EPA 1998)], limits the discharge

o 2f any gases that contain nitrogen oxides (expressed as NO ) in excess of 200 nanograms

per joule of gross energy output (1.6 pound/MWh), based on a 30-day rolling average.

The x staff estimates that using the technology referenced in Entergy’s ER [NO burners with

overfire ai xr and selective catalytic reduction (SCR)] the total annual NO emissions for a new

coal-f xired power plant would be approximately 522 tons. This level of NO emissions would

be greater than for the OL renewal alternative since a nuclear power plant releases almost

no NOx during normal operations.

Particulate emissions. The staff estimates that the total annual stack emissions would

include 89 tons of filterable total suspended particulates and 21 tons of particulate matter

hav 10 ing an aerodynamic diameter less than or equal to 10 ìm (PM ) (40 CFR 50.6). As

indicated in the PNPS ER, fabric filters or electrostatic precipitators would be used for

particulate control. In addition to flue emissions, coal-handling equipment would introduce

fugitive particulate emissions from coal piles, reclamation equipment, conveyors, and other

sources. Particulate emissions would be greater under the coal alternative than the OL

renewal alternative. Fugitive dust would also be generated during the construction of a

coal-fired plant and construction vehicles and motorized equipment would further contribute

to construction phase air emissions.

Carbon monoxide emissions. The staff estimates that the total CO emissions from coal

combustion would be approximately 544 tons per year. This level of emission is greater

than would occur under the OL renewal alternative.

Hazardous air pollutants including mercury. In December 2000, the EPA issued regulatory

findings on emissions of hazardous air pollutants from electric utility steam-generating units

| (EPA 2000b). EPA determined that coal- and oil-fired electric utility steam-generating units

are significant emitters of hazardous air pollutants. Coal-fired power plants were found by

EPA to emit arsenic, beryllium, cadmium, chromium, dioxins, hydrogen chloride, hydrogen

fluoride, lead, manganese, and mercury (EPA 2000b). EPA concluded that mercury is the

hazardous air pollutant of greatest concern. EPA found that (1) there is a link between coal

consumption and mercury emissions; (2) electric utility steam-generating units are the

largest domestic source of mercury emissions; and (3) certain segments of the U.S. 

population (e.g., the developing fetus and subsistence fish-eating populations) are believed

to be at potential risk of adverse health effects due to mercury exposures resulting from

consumption of contaminated fish (EPA 2000b). Accordingly, EPA added coal- and oil-fired

electric utility steam-generating units to the list of source categories under Section 112(c) of

the CAA for which emission standards for hazardous air pollutants will be issued 

(EPA 2000b).
Environmental Impacts of License Renewal

July 2007 8-15 NUREG-1437, Supplement 29

Uranium and thorium. Coal contains uranium and thorium. Uranium concentrations are

generally in the range of 1 to 10 parts per million (ppm). Thorium concentrations are

generally about 2.5 times greater than uranium concentrations (Gabbard 1993). One

estimate is that a typical coal-fired plant released roughly 5.2 tons of uranium and 12.8 tons

of thorium in 1982 (Gabbard 1993). The population dose equivalent from the uranium and

thorium releases and daughter products produced by the decay of these isotopes has been

calculated to be significantly higher than that from nuclear power plants (Gabbard 1993).

Carbon diox 2ide. A coal-fired plant would also have unregulated carbon dioxide (CO )

emissions that could contribute to global warming. The level of emissions from a coal-fired

plant would be greater than the OL renewal alternative.

Summary. The GEIS analysis did not quantify emissions from coal-fired power plants, but

implied that air impacts would be substantial. The GEIS also mentioned global warming

x x from unregulated carbon dioxide emissions and acid rain from SO and NO emissions as

potential impacts (NRC 1996). Adverse human health effects such as cancer and

emphysema have been associated with the products of coal combustion. The appropriate |

characterization of air impacts from coal-fired generation would be MODERATE. The |

impacts would be clearly noticeable, but would not destabilize air quality. 

C Waste

Coal combustion generates waste in the form of ash and scrubber sludge. A 715 gross

MW(e) coal-fired plant would generate approximately 222,000 tons of such waste annually

for 40 years. The waste would be disposed on-site, accounting for approximately 142 ac of

land area over the 40-year plant life. Impacts of on-site waste disposal to groundwater and

surface water could extend beyond the operating life of the plant if leachate and runoff from

the waste storage area occurs. Waste disposal could noticeably affect land use and |

groundwater quality, but with appropriate management and monitoring, it would not

destabilize any resources. After waste site closure and revegetation, the land could be |

available for other uses.

In May 2000, the EPA issued a “Notice of Regulatory Determination on Wastes From the

Combustion of Fossil Fuels [65 FR 32214 (EPA 2000a)]. EPA concluded that some form of

national regulation is warranted to address coal combustion waste products because: 

(a) the composition of these wastes could present danger to human health and the

environment under certain conditions; (b) EPA has identified 11 documented cases of

proven damages to human health and the environment by improper management of these

wastes in landfills and surface impoundments; (c) present disposal practices are such that,

in 1995, these wastes were being managed in 40 percent to 70 percent of landfills and

surface impoundments without reasonable controls in place, particularly in the area of

groundwater monitoring; and (d) EPA identified gaps in state oversight of coal combustion
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-16 July 2007

wastes. Accordingly, EPA announced its intention to issue regulations for disposal of coal

combustion waste under subtitle D of the Resource Conservation and Recovery Act

(RCRA). In addition to the waste streams generated during plant operations, considerable

debris would be generated during construction of a coal fired facility.

For all of the preceding reasons, the appropriate characterization of impacts from the waste

generated by a coal-fired facility (construction and operating phases) is MODERATE; the

impacts would be clearly noticeable, but would not destabilize any important resource.

C Human Health

Coal-fired power generation introduces risks to workers from fuel and limestone mining,

from fuel and lime/limestone transportation, and from disposal of coal combustion waste. In

addition, there are public health risks from inhalation of stack emissions that can be

widespread and difficult to quantify. The coal alternative also introduces the risk of coal-pile

fires and attendant inhalation risks.

In the GEIS, the staff stated that there could be human health impacts (cancer and 

emphysema) from inhalation of toxins and particulates, but it did not identify the significance

of these impacts (NRC 1996). In addition, the discharges of uranium and thorium from

coal-fired plants can potentially produce radiological doses in excess of those arising from

nuclear power plant operations (Gabbard 1993).

Regulatory agencies, including EPA and State agencies, set air emission standards and

requirements based on human health impacts. These agencies also impose site-specific

emission limits as needed to protect human health. As discussed previously, EPA has

recently concluded that certain segments of the U.S. population (e.g., the developing fetus

and subsistence fish-eating populations) are believed to be at potential risk of adverse

health effects due to mercury exposures from sources such as coal-fired power plants. 

However, in the absence of more quantitative data, human health impacts from radiological

doses and inhaling toxins and particulates generated by burning coal are characterized as

SMALL.

C Socioeconomics

Construction of a coal-fired facility at an alternative greenfield site would take approximately

four years. The work force would be expected to vary between 800 and 2000 workers

during the 4-year construction period (NRC 1996). During construction, the surrounding

communities would experience demands on housing and public services that could have

MODERATE impacts unless some of the work force is composed of local residents. After

construction, the host community would be impacted by the loss of the construction jobs.
Environmental Impacts of License Renewal

July 2007 8-17 NUREG-1437, Supplement 29

However, this loss would be offset by the approximately 200 permanent jobs associated

with the new facility. Socioeconomic impacts would be greater if the facility were

constructed at a rural location than if it were constructed in a more developed area. The

staff considers the most appropriate characterization of non-transportation socioeconomic

impacts of developing a new greenfield site to be MODERATE to LARGE.

During the 4-year construction period of the coal-fired unit, up to 2000 construction workers

would be working at the site. The addition of these workers would increase traffic on

highways and local roads that lead to the construction site. The impact of this additional

traffic could have a MODERATE impact on nearby roadways, particularly if the greenfield

site is an a rural area.

Impacts associated with plant operating personnel commuting to work are considered

SMALL. The number of plant operating personnel at a new coal-fired facility would be

approximately 200. For rail transportation of coal and lime to the greenfield site, impacts

are likely to range from MODERATE to LARGE. On average, approximately one 70-car

train load per day would deliver coal to the new generating station and one 10-car train load

per week would deliver lime to the facility. Should deliveries of coal be accomplished via

barge, approximately two barges per week would deliver fuel to the facility. Overall,

transportation impacts of coal and lime delivery would be MODERATE to LARGE.

C Aesthetics

The boiler house and associated air pollution control equipment at a new coal-fired facility

could be up to 200 feet (ft) in height and a typical exhaust stack would be somewhere in the

range of 400 to 600 ft high. Cooling tower(s) could be either of the mechanical

(approximately 75 ft tall) or natural draft type (approximately 400 ft tall). The new

generating facility and the plume generated by its cooling towers(s) would be visible from a

considerable distance. Additionally, the facility would be noticeable at night due to its 

24-hour operating schedule and the need for on-site safety lighting.

Beyond near site aesthetic impacts, development of a new coal-fired facility at a greenfield

site would entail construction of a new transmission line and a new rail spur to bring coal

and lime to the plant. The rail spur and transmission line could extend a considerable

distance off-site to tie-in points with existing rail and transmission systems. The visual

intrusion of these two linear elements, particularly the transmission line, could be significant.

Consequently, the overall aesthetic impacts of a new coal-fired facility at a greenfield site

are expected to be MODERATE to LARGE.

Coal-fired generation would introduce mechanical sources of noise that would be audible

off-site. Sources contributing to total noise produced by plant operation are classified as

continuous or intermittent. Continuous sources include the mechanical equipment
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-18 July 2007

associated with normal plant operations. Intermittent sources include the equipment related

to coal handling, solid-waste disposal, on-site activities related to coal and lime delivery, use

of outside loudspeakers, and the commuting of plant employees. The incremental noise

impacts of a coal-fired plant at a greenfield site are considered to be MODERATE.

Noise impacts associated with rail delivery of coal and lime to a greenfield site would be

most significant for residents living along the new rail spur leading to the plant. Since this is

a new generating station site, these residents would not have experienced previous rail

noise. Although noise from passing trains significantly raises noise levels near the rail

corridor, the short duration of the noise reduces impact. Nevertheless, the impact of noise

on residents in the vicinity of the facility and the rail line is considered MODERATE.

C Historic and Archaeological Resources

Before construction at an alternate greenfield site, studies would likely be needed to

identify, evaluate, and address mitigation of the potential impacts of new plant construction

on cultural resources. The studies would likely be needed for all areas of potential

disturbance at the proposed plant site and along associated corridors where new

construction would occur (e.g., roads, transmission corridors, rail lines, or other ROWs). 

Historic and archaeological resource impacts can generally be effectively managed and,

therefore, are considered SMALL.

C Environmental Justice

Impacts of constructing a coal-fired facility at an alternate greenfield site would depend

upon the site chosen and the nearby population distribution. It is expected that these

impacts are likely to be SMALL to MODERATE.
Environmental Impacts of License Renewal

July 2007 8-19 NUREG-1437, Supplement 29

Table 8-2. Summary of Environmental Impacts of Coal-Fired Generation at an Alternate Greenfield Site

Using Closed-Cycle Cooling

Alternate Greenfield Site

Impact Category Impact Comments

Land Use MODERATE

to LARGE

Uses approximately 1215 ac, for plant, offices,

parking, transmission line, and rail spur;

additional land impacts for coal and limestone

mining.

Ecology MODERATE

to LARGE 

Impact depends on location and ecology of the

site, surface water body used for cooling tower

make-up and discharge, and transmission line

route, potential habitat loss and fragmentation,

reduced productivity and biological diversity.

W ater Use and Quality-Surface

W ater

SMALL to

MODERATE

Impact will depend on the volume of water

withdrawn and discharged and the characteristics

of the surface water body.

W ater Use and QualityGroundwaterSMALL to

MODERATE

Impact will depend on the volume of water

withdrawn and discharged and the characteristics

of the aquifers.

Air Quality MODERATE • Sulfur oxides

(Estimated 1428 tons/yr)

• Nitrogen oxides

(Estimated 522 tons/yr)

• Particulates

(Estimated 89 tons/yr of total suspended

particulates)

10 (Estimated 21 tons/yr of PM )

• Carbon Monoxide

(Estimated 544 tons/yr)

 

Small amounts of mercury and other hazardous

air pollutants and naturally occurring radioactive

materials - mainly uranium and thorium.
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-20 July 2007

Table 8-2. (contd)

Alternate Greenfield Site

Impact Category Impact Comments

W aste MODERATE Total volume of approximately 220,000 tons/yr

requiring approximately 142 ac for disposal over

40-year life of plant.

Human Health SMALL Impacts are uncertain but considered SMALL in

the absence of more quantitative data.

Socioeconomics MODERATE

to LARGE 

Construction impacts depend on location, but

could be LARGE if plant is located in a rural area.

Socioeconomics (Transportation) MODERATE

to LARGE 

Transportation impacts associated with construction workers and coal and lime shipments.

For rail transportation of coal and lime, the impact

is considered MODERATE to LARGE. For barge

transportation, the impact is considered

MODERATE.

Aesthetics MODERATE

to LARGE

Impacts from boiler house, cooling tower, and

new transmission line.

Historic and Archeological

Resources

SMALL Alternate location would necessitate cultural

resource studies.

Environmental Justice SMALL to

MODERATE 

Impacts will vary depending on population

distribution and makeup at the site.

8.2.1.2 Once-Through Cooling System

This section discusses the environmental impacts of constructing a coal-fired generating station

at a greenfield site using once-through cooling. The impacts (SMALL, MODERATE, or LARGE)

of this option are approximately the same as the impacts for a coal-fired plant using the
Environmental Impacts of License Renewal

July 2007 8-21 NUREG-1437, Supplement 29

closed-cycle system, with the exception of land use, aesthetics, ecology, and water use. For

land use and aesthetics, the impacts would be less, while for ecology and water use the

impacts would be greater. Table 8-3 summarizes the incremental differences.

Table 8-3. Summary of Environmental Impacts of Coal-Fired Generation at the PNPS 

Site with Once-Through Cooling System

Impact Category Change in Impacts from

Closed-Cycle Cooling System

Land Use Impacts may be less (e.g., through elimination of

cooling towers) or greater (e.g., if a reservoir is

required).

Ecology Impact would depend on ecology at the site.

Possible impacts associated with entrainment of

fish and shellfish in early life stages, impingement

of fish and shellfish, and heat shock.

W ater Use and Quality-Surface W ater Increased water withdrawal leading to possible

water-use conflicts; thermal load higher than with

closed-cycle cooling.

W ater Use and Quality-Groundwater No change.

Air Quality No change.

W aste No change.

Human Health No change.

|

Socioeconomics No change.

Socioeconomics (Transportation) No change.

Aesthetics Elimination of cooling towers and plume.

Historic and Archaeological Resources No change.

Environmental Justice No change.

8.2.2 Natural Gas-Fired Generation

The environmental impacts of constructing a natural gas-fired alternative are examined in this

section for both the PNPS site and an alternate greenfield site. The staff assumed that a gasfired plant at the PNPS site could have either a closed or open-cycle cooling system.
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-22 July 2007

The assumptions and numerical values used in Section 8.2.2 are based on the staff’s

independent assessment and on information provided by Entergy in the PNPS ER 

(Entergy 2006). Where information from the PNPS ER was used, it was independently

reviewed by the staff and compared to environmental impact information in the GEIS. Impacts

of a gas-fired alternative evaluated by the staff assume that the new plant would have a gross

electrical capacity of 715 MW(e); this differs from the assumption made in the ER.

Entergy assumed that a replacement natural gas-fired plant would use combined-cycle

technology (Entergy 2006). Furthermore, Entergy, uses a standard-sized gas-fired combinedcycle plant with a net capacity of 585 MW(e) in their analysis. The staff considers the

combined-cycle technology to be a reasonable choice for the gas-fired replacement system but

that the capacity selected by Entergy underestimates impacts of this technology. 

Consequently, the staff has evaluated impacts of a hypothetical 715 gross MW(e) gas-fired

combined-cycle facility which would essentially fully replace the capacity lost if the PNPS OL is

denied. While this approach may be hypothetical, air emissions calculated for a 715 MW(e)

gas-fired facility better represent, in the staff’s opinion, the implications of denying the PNPS

OL.

The staff has assumed that approximately 50 ac would be needed to construct a new gas-fired

plant at either the PNPS site or at an alternate greenfield site. This would include land for the

power block and associated infrastructure. Since the PNPS site is not served by a natural gas

supply and the nearest significant gas supply line is approximately 5 to 6 mi from the site, it will

be necessary to construct a tie-in to that line from the PNPS site. Proximity to a natural gas

supply will also be a factor in the selection of a greenfield location for the gas-fired alternative.

Some of the existing infrastructure at PNPS can be used to serve operations of the gas-fired

alternative. Most significantly this would include the transmission lines that currently carry

electric power from the plant to the regional distribution system. At an alternate greenfield site,

new transmission lines would need to be constructed.

In performing the impact analysis in Section 8.2.2 the staff reviewed information provided by

Entergy, environmental information in the GEIS, and data available in the technical literature.

Although the OL renewal period is only 20 years, the impact of operating the natural gas-fired

| alternative for 40 years is considered (as a reasonable projection of a natural gas-fired plant’s

| operating life).

8.2.2.1 Closed-Cycle Cooling System

The overall impacts of the natural gas-fired system using closed-cycle cooling are discussed

below and summarized in Table 8-4, at the end of this section (Section 8.2.2.1). The extent of

impacts at an alternate greenfield site will depend on the actual location of the selected site.
Environmental Impacts of License Renewal

July 2007 8-23 NUREG-1437, Supplement 29

C Land Use

For siting at PNPS, existing facilities and infrastructure would be used to the extent

practicable, limiting the amount of new construction that would be required. Specifically, the

staff assumed that the natural gas-fired replacement plant would use the switchyard,

offices, and transmission line ROW. Much of the land that would be used has been

previously disturbed. At PNPS, the staff assumed that approximately 50 ac would be

needed for the plant and associated infrastructure including cooling tower. There would be

an additional temporary impact of up to approximately 10 ac for construction of a gas

pipeline from the Plymouth tie-in to the PNPS site.

For construction at an alternate site, the staff assumed that 50 ac would also be needed for

the plant and associated infrastructure (NRC 1996). In addition, land would be needed for

construction of a transmission line and for a new gas line to supply fuel to the facility.

Regardless of where the plant is built, additional land would be required for natural gas

wells and collection stations. In the GEIS, the staff estimated that 3600 ac would be

needed for gas wells and collection stations to support a 1000 MW(e) plant or about 2600

ac for a 715 MW(e) facility (NRC 1996). Overall, land-use impacts of the gas-fired 

alternative would be MODERATE at the PNPS site and MODERATE to LARGE at a

greenfield site.

C Ecology

The use of cooling towers would be expected to reduce aquatic ecological impacts below

those currently being experienced at PNPS. With regard to terrestrial ecological impacts of

building a gas-fired alternative, though the site is well built-out for the existing nuclear plant,

additional land clearing would be necessary. This could entail some loss of natural habitat

with a corresponding impact to terrestrial species. Also, bringing a natural gas pipeline onto

the PNPS site may result in some further disturbance to undeveloped areas but it is

expected that most of the pipeline construction would be in roadway ROW and, therefore,

would not be expected to impact terrestrial species. Overall, given that closed-cycle cooling

would be implemented for this alternative, the ecological impacts of developing a gas-fired

facility at the PNPS site are considered SMALL.

Ecological impacts at an alternate site would depend on the nature of the land converted to

energy generation and the possible need for a new gas pipeline and/or electric transmission

line. Construction of a transmission line and a gas pipeline would be expected to have

temporary ecological impacts. Ecological impacts at the plant site and along utility

easements could include impacts to threatened or endangered species, wildlife habitat loss

and reduced productivity, habitat fragmentation, and a local reduction in biological diversity. 
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-24 July 2007

Some aquatic ecological impacts would also be expected due to withdrawal of surface water for

cooling tower makeup. Overall, the ecological impacts of developing a gas-fired facility at a

greenfield site are considered MODERATE.

C Water Use and Quality

Surface Water

The natural gas-fired facility described by Entergy in the ER would include a heat-recovery

boiler, using waste heat from gas turbines to generate steam. The steam would then turn a

turbine-generator. The net result would be an overall reduction in the amount of waste heat

that would need to be discharged to the environment in comparison to an equivalent

capacity nuclear plant. In addition, since a closed-cycle cooling system would be employed

under this alternative, the rate at which water would be withdrawn from Cape Cod Bay, for

cooling purposes, would be significantly reduced.

Plant discharges would consist mostly of cooling tower blowdown, with the discharge having

a higher temperature and increased concentration of dissolved solids relative to Cape Cod

Bay; there would also be intermittent low concentrations of biocides (e.g., chlorine) in the

discharge stream. In addition to the cooling tower blowdown, process waste streams could

be discharged as well. However, all discharges would be regulated through a Federally

issued National Pollutant Discharge Elimination System (NPDES) permit. Finally, some

erosion and sedimentation would probably occur during construction (NRC 1996). Overall,

the water quality impacts of implementing the natural gas-fired alternative at the PNPS site

are considered SMALL due to the relatively low water withdrawal from Cape Cod Bay.

A natural gas-fired plant at an alternate greenfield site is also assumed to use a closedcycle cooling system. The staff assumed that surface water would be used for cooling

tower make-up and that the withdrawal rate of make-up water would be small compared to

an open-cycle system. The impact on surface waters would depend on the volume of water

needed for make-up and the characteristics of the receiving water body. Intake from, and

discharge to, any surface body of water would be regulated by a Federal or State issued

discharge permit. The impacts would be SMALL. Water-quality impacts from

sedimentation during construction have been characterized in the GEIS as SMALL. 

Groundwater

At the PNPS site, groundwater supplied by the Town of Plymouth would continue to be used

for potable water purposes and for certain plant operations requiring fresh water. However,

the quantity of groundwater required will be reduced under the gas-fired alternative since

the level of staffing would be less than that for current operations. Also, sanitary wastes
Environmental Impacts of License Renewal

July 2007 8-25 NUREG-1437, Supplement 29

would continue to be discharged to groundwater, as is currently the case at PNPS, but at a

reduced rate. At an alternate site, groundwater could be used for general plant operations

and for potable water purposes as well. Any groundwater withdrawal would require a permit

from the local permitting authority and impacts on groundwater would depend on the volume

required and characteristics of the water source. Overall impacts to groundwater of a gasfired alternative at either the PNPS site or an alternate greenfield site would be SMALL.

C Air Quality

Natural gas is a relatively clean-burning fuel. A new gas-fired generating plant located in

New England would likely need a prevention of significant deterioration permit and an

operating permit under the CAA. A new combined-cycle natural gas power plant would also

be subject to the new source performance standards for such units at 40 CFR Part 60,

Subparts Da and GG. These regulations establish emission limits for particulates, opacity,

SOx x., and NO

In 1998, EPA issued a rule requiring 22 eastern states, including Massachusetts, to revise

x x their state implementation plans to reduce NO emissions. NO emissions contribute to

violations of the National Ambient Air Quality Standard (40 CFR 50.9) for ozone. The total

amount of nitrogen oxides which can be emitted by each of the 22 states in the year 2007

ozone season (May 1 - September 30) is set out in 40 CFR 51.121(e). For Massachusetts,

the amount is 85,296 tons.

EPA has various regulatory requirements for visibility protection in 40 CFR 51, Subpart P,

including a specific requirement for review of any new major stationary source in an area

designated attainment or unclassified under the CAA. Plymouth County has a nonattainment status for ozone but attains the National Ambient Air Quality Standards for other

air pollutants. The air quality status of an alternate greenfield site would depend on where

that site is located.

Section 169A of the CAA establishes a national goal of preventing future and remedying

existing impairment of visibility in mandatory Class I Federal areas when impairment results

from man-made air pollution. EPA issued a new regional haze rule on July 1, 1999 

(64 FR 35714 [EPA 1999]). The rule specifies that for each mandatory Class I Federal area |

located within a state, the State must establish goals that provide for reasonable progress

towards achieving natural visibility conditions. The reasonable progress goals must provide

for an improvement in visibility for the most impaired days over the period of the

implementation plan and ensure no degradation in visibility for the least-impaired days over

the same period [40 CFR 51.308(d)(1)]. 
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-26 July 2007

If a natural gas-fired plant were located close to a mandatory Class I area, additional air

pollution control requirements could be imposed. There are no designated Class I areas in

Massachusetts. However, EPA’s regional haze rule could apply to an alternate greenfield

site, depending on where that site is located.

EPA issued the Clean Air Interstate Rule (CAIR) in May 2005 [70 FR 25162 (EPA 2005)]. 

CA 2IR provides a Federal framework requiring certain states to reduce emissions of SO and

Nox. EPA anticipates that states will achieve this reduction primarily by limiting emissions

from the power generation sector. CAIR covers 28 eastern states and any new fossil-fired

power plant sited in Massachusetts would be subject to the CAIR limitations.

The staff projects the following emissions for the natural gas-fired alternative:

SOx - 56 tons/yr

Nox - 180 tons/yr

CO - 38 tons/yr

PM10 - 31 tons/yr 

A 2 natural gas-fired plant would also have unregulated CO emissions that could contribute

to global warming. In December 2000, EPA issued regulatory findings on emissions of

hazardous air pollutants from electric utility steam-generating units (EPA 2000b). Natural

gas-fired power plants were found by EPA to emit arsenic, formaldehyde, and nickel (EPA

2000b). Unlike coal and oil-fired plants, EPA did not determine that emissions of hazardous

air pollutants from natural gas-fired power plants should be regulated under Section 112 of

the CAA.

The projected emissions would likely be the same whether the gas-fired facility were

operated at PNPS or at an alternate greenfield site. Impacts from the above emissions

would be clearly noticeable, but would not be sufficient to destabilize air resources overall.

Construction activities either at PNPS or an alternate greenfield site would result in

temporary fugitive dust emissions. Fugitive dust emissions would also occur along the

construction route for new gas lines (at either site) or along the route of a new transmission

line (greenfield site only). Exhaust emissions would also come from vehicles and motorized

equipment used during the construction process.

The overall air quality impact of a new natural gas-fired plant sited at PNPS or at an

alternate greenfield site is considered MODERATE.
Environmental Impacts of License Renewal

July 2007 8-27 NUREG-1437, Supplement 29

• Waste

There w xill be spent SCR catalyst from NO emissions control and small amounts of solidwaste products (i.e., ash) from burning natural gas fuel. In the GEIS, the staff concluded

that waste generation from gas-fired technology would be minimal (NRC 1996). Gas firing

results in very few combustion by-products because of the clean nature of the fuel. Wastegeneration impacts would be so minor that they would not noticeably alter any important

resource attribute. Construction-related debris would be generated during construction

activities.

In the winter, it may become necessary for a replacement baseload natural-gas fired plant

to operate on fuel oil due to lack of gas supply. Oil combustion generates waste in the form

of ash, and equipment for controlling air pollution generates additional ash and scrubber

sludge. The amount of ash and sludge generated would depend on the type and quantity of

fuel oil combusted (e.g. use of Number 2 fuel oil does not produce appreciable ash).

Overall, the waste impacts would be SMALL for a natural gas-fired plant sited at PNPS or at

an alternate greenfield site.

C Human Health

In Table 8-2 of the GEIS, the staff identifies cancer and emphysema as potential health

x

risks from gas-fired plants (NRC 1996). The risk may be attributable to NO emissions that

con xtribute to ozone formation, which in turn contribute to health risks. NO emissions from

any x gas-fired plant would be regulated. For a plant sited in Massachusetts, NO emissions

would be regulated by the Massachusetts Department of Environmental Protection. Human

health effects from gas-fired operations are not expected to be detectable and, therefore,

the impacts on human health of the natural gas-fired alternative sited at either PNPS or an

alternate greenfield site are considered SMALL.

C Socioeconomics

Construction of a natural gas-fired plant would take approximately 3 years. Peak

employment would be approximately 600 workers (NRC 1996). The staff assumed that

construction would take place while PNPS continues operation and would be completed by

the time it permanently ceases operations. During construction, the communities

surrounding the PNPS site would experience demands on housing and public services that

could have MODERATE impacts. After construction, nearby communities could be

impacted by the loss of jobs. The current PNPS work force (700 workers) would decline

through a decommissioning period to a minimal maintenance size. 
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-28 July 2007

The gas-fired plant would introduce a replacement tax base at PNPS or a new tax based on

an alternate greenfield site and approximately 150 new permanent jobs.

In the GEIS (NRC 1996), the staff concluded that socioeconomic impacts from constructing

a natural gas-fired plant would not be very noticeable and that the small operational work

force would have the lowest socioeconomic impacts of any nonrenewable technology. 

Compared to the coal-fired and nuclear alternatives, the smaller size of the construction

work force, the shorter construction time frame, and the relatively small operations work

force would mitigate socioeconomic impacts. For these reasons, socioeconomic impacts

associated with construction and operation of a natural gas-fired power plant would be

SMALL to MODERATE for siting at PNPS or at an alternate greenfield site.

Transportation impacts associated with construction and operating personnel commuting to

the plant site would depend on the population density and transportation infrastructure in the

vicinity of the site. The impacts can be classified as SMALL to MODERATE for siting at

PNPS and MODERATE at an alternate greenfield site, particularly if the greenfield site is in

a rural area.

 C Aesthetics

If the gas-fired facility was built at the PNPS site, the turbine buildings (approximately 100 ft

tall) and exhaust stacks (approximately 125 ft tall) would be visible during daylight hours

from the immediately adjacent properties. The cooling tower plume can be expected to be

visible from the surrounding vicinity including, at times, the Town of Plymouth. Noise and

light from the plant would be detectable in the immediate area. Overall, the aesthetic

impacts associated with the gas-fired facility at PNPS are categorized as MODERATE.

At an alternate greenfield site, the buildings, cooling towers, cooling tower plumes, and the

associated transmission line and gas pipeline would be visible off-site. The visual impact of

a new transmission line could be especially significant at a greenfield site. Aesthetic

impacts would be mitigated if the plant were located in an industrial area adjacent to other

power plants. Overall, aesthetic impacts associated with an alternate greenfield site are

categorized as MODERATE to LARGE. The most significant contributor to the aesthetic

impacts is the new transmission line.

C Historic and Archaeological Resources

Before construction at PNPS or an alternate greenfield site, studies would likely be needed

to identify, evaluate, and address mitigation of the potential impacts of new plant

construction on cultural resources. The studies would likely be needed for all areas of

potential disturbance at the proposed plant site and along associated corridors where new
Environmental Impacts of License Renewal

July 2007 8-29 NUREG-1437, Supplement 29

construction would occur (e.g., roads, transmission and pipeline corridors, or other ROWs). 

Impacts to cultural resources can be effectively managed under current laws and

regulations and are likely to be SMALL.

C Environmental Justice

No environmental pathways or locations have been identified that would result in disproportionately high and adverse environmental impacts on minority and low-income

populations if a replacement natural gas-fired plant were built at the PNPS site. Some

impacts on housing availability and prices during construction might occur, but it is not

expected this would disproportionately affect minority and low-income populations. Closure

of PNPS would result in a decrease in employment of approximately 550 operating

employees (700 existing jobs versus 150 replacement jobs). This loss could possibly be

offset by general economic growth in the eastern Massachusetts area and the loss is not

expected to disproportionately impact low income or minority populations. Overall, impacts

of terminating PNPS operations and replacing its output with a gas-fired facility at the same

site are expected to be SMALL. Impacts at an alternate greenfield site would depend upon

the site chosen and the nearby population distribution, but are likely to also be SMALL.

Table 8-4. Summary of Environmental Impacts of Natural Gas-Fired Generation at

the PNPS Site and an Alternate Greenfield Site Using Closed-Cycle Cooling

PNPS Site Alternate Greenfield Site

Impact Category Impact Comments Impact Comments

Land Use MODERATE 50 ac for power block, |

cooling tower(s), offices,

roads, parking areas. 

Additional temporary

impact of approximately

10 ac for construction of

underground gas

pipeline.

MODERATE

to LARGE

50 ac for power block,

cooling towers, offices,

roads, and parking

areas. Additional area

for electric and gas

transmission lines.

|

Ecology SMALL Reduces water

withdrawal from Bay but

uses some undeveloped

area at current PNPS.

MODERATE Impact depends on

location and ecology of

the site, surface water

body used for make-up

and transmission and

pipeline routes.
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-30 July 2007

Table 8-4. (contd)

PNPS Site Alternate Greenfield Site

Impact Category

Impact Comments Impact Comments

W ater Use and

Quality-Surface

W ater

SMALL Uses a closed-cycle

cooling system with

natural gas-fired

combined-cycle units. 

This would result in

relatively low water

withdrawals.

SMALL Impact depends on

volume of water,

withdrawal and

discharge, and

characteristics of

surface water body.

W ater Use and

QualityGroundwater

SMALL Uses little groundwater

beyond current potable

water needs.

SMALL Impact depends on

volume of water

withdrawal.

Air Quality MODERATE • Sulfur oxides

(56 tons/yr)

• Nitrogen oxides 

 (180 tons/yr)

• Carbon monoxide 

 (38 tons/yr)

10 • PM particulates 

 (31 tons/yr)

Some hazardous air

pollutants. 

MODERATE Same emissions as

PNPS site.

|

W aste SMALL Small amount of ash

produced.

SMALL Same waste produced

as at the PNPS site. 

Human Health SMALL Impacts considered to be

minor.

SMALL Impacts considered to

be minor. 

Socioeconomics SMALL to

MODERATE

During construction,

impacts would be

MODERATE. Up to 600

additional workers during

the peak of the 3-year

construction period,

followed by reduction

from current PNPS work

force of 700 to 150; tax

base preserved. Impacts

during operation would be

SMALL.

SMALL to

MODERATE

During construction,

impacts would be

SMALL to

MODERATE. Up to

600 additional workers

during the peak of the

3-year construction

period. 

|
Environmental Impacts of License Renewal

July 2007 8-31 NUREG-1437, Supplement 29

Table 8-4. (contd)

PNPS Site Alternate Greenfield Site

Impact Category

Impact Comments Impact Comments

Socioeconomics

(Transportation)

SMALL to

MODERATE

Transportation impacts

associated with

construction workers.

MODERATE Transportation impacts

associated with

construction workers.

Aesthetics MODERATE Aesthetic impact due to

impact of new plant and

cooling towers.

MODERATE

to LARGE

Potential impacts would

be from the new plant,

cooling towers, and

new transmission line.

Historic and

Archeological

Resources

SMALL Potential impacts can

likely be effectively

managed. 

SMALL Potential impacts can

likely be effectively

managed. 

Environmental

Justice

SMALL Impacts on minority and

low-income communities

should be similar to those

experienced by the

population as a whole. 

SMALL Approximately same as

for PNPS site.

8.2.2.2 Once-Through Cooling System

This section discusses the environmental impacts of constructing a natural gas-fired facility at

the PNPS site using once-through cooling. The impacts of this option are generally the same as

the impacts for a natural gas-fired plant using the closed-cycle system with some exceptions.

The principal exceptions are that ecological and water quality impacts of once-through cooling

would be greater than for closed-cycle cooling. Also, the aesthetic impacts of the cooling tower

plume would be eliminated for the once-through cooling scenario. Table 8-5 summarizes the

differences.

8.2.3 Nuclear Power Generation

Since 1997, the NRC has certified four new standard designs for nuclear power plants under 

10 CFR Part 52, Subpart B. These designs are the 1300 MW(e) U.S. Advanced Boiling Water

Reactor (10 CFR 52, Appendix A), the 1300 MW(e) System 80+ Design (10 CFR 52, 

Appendix B), the 600 MW(e) AP600 Design (10 CFR 52, Appendix C) and the 1000 MW(e)

AP1000 Design (10 CFR Part 52, Appendix D). All of these plants are light-water reactors. |

Although no applications for a construction permit or a combined license based on these

certified designs have been submitted to NRC, the submission of the design certification
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-32 July 2007

applications indicates continuing interest in the possibility of licensing new nuclear power plants. 

In addition, recent escalation in prices of natural gas and oil have made new nuclear power plant

construction more attractive from a cost standpoint.

Table 8-5. Summary of Environmental Impacts of Natural Gas-Fired Generation at the

PNPS Site with Once-Through Cooling

Impact Category

Change in Impacts from

Closed-Cycle Cooling System

Land Use Impacts may be less through elimination of cooling towers.

Ecology Potentially greater impacts associated with entrainment of fish

and shellfish in early life stages, impingement of fish and

shellfish, and heat shock.

| W ater Use and Quality-Surface Water Increased water withdrawal leading to higher thermal load than

with closed-cycle cooling.

W ater Use and Quality-Groundwater No change.

Air Quality No change.

W aste No change.

Human Health No change.

Socioeconomics No change.

Socioeconomics (Transportation) No change.

Aesthetics Elimination of cooling towers reduces visual impacts.

Historic and Archaeological

Resources

No change.

Environmental Justice No change.

As a result of the increased interest in new nuclear facilities, construction of a nuclear power

plant at a greenfield site is considered in this section. The staff assumed that the new nuclear

plant would have a 40-year lifetime. Consideration of a new nuclear generating plant at the

PNPS site is not addressed in this section due to the lack of sufficient on-site area to support

construction of a new generating station, with associated cooling towers, while maintaining

operation of the existing plant.
Environmental Impacts of License Renewal

July 2007 8-33 NUREG-1437, Supplement 29

NRC has summarized environmental data associated with the uranium fuel cycle in Table S-3 of

10 CFR 51.51. The impacts shown in Table S-3 are representative of the impacts that would be

associated with a replacement nuclear power plant built to one of the certified designs, sited at a

greenfield site. The impacts shown in Table S-3 are for a 1000 MW(e) reactor and would need

to be adjusted to reflect impacts of a new 715 MW(e) nuclear facility. The environmental

impacts associated with transporting fuel and waste to and from a light-water cooled nuclear

power reactor are summarized in Table S-4 of 10 CFR 51.52. The summary of NRC’s findings

on NEPA issues for license renewal of nuclear power plants in Table B-1 of 10 CFR 51

Subpart A, Appendix B, is also relevant, although not directly applicable, for consideration of

environmental impacts associated with the operation of a replacement nuclear power plant.

Additional environmental impact information for a replacement nuclear power plant using closedcycle cooling is presented in Section 8.2.3.1 and in Section 8.2.3.2 for the once-through cooling

scenario.

8.2.3.1 Closed-Cycle Cooling System

The impacts of constructing a nuclear generating station at a greenfield site using closed-cycle

cooling are discussed in this section and summarized in Table 8-6, at the end of this section

(Section 8.2.3.1). It should be noted, however, that the scale of impacts at the greenfield site

will depend largely on characteristics of the site actually selected for the project. 

C Land Use

Land-use impacts at a greenfield site would be significant since the new nuclear plant, with

its associated closed-cycle cooling system, would entail development on approximately 350

ac of land area. In addition, property would be needed to construct a transmission line from

the greenfield site to the nearest tie-in with the regional transmission system. Also, it may be

necessary to construct a rail spur or pier at the alternate site to bring in equipment during

construction. Depending particularly on transmission line routing, siting a new nuclear plant

at an alternate greenfield site could result in MODERATE to LARGE land-use impacts.

C Ecology

Ecological impacts at an alternate site would result from both construction and operation of

the replacement nuclear facility. Even assuming siting at a previously disturbed location, the

terrestrial ecological impacts could include wildlife habitat loss, reduced productivity, habitat

fragmentation, and a local reduction in biological diversity. Construction of a transmission

line would further exacerbate terrestrial impacts but would be highly dependent on the length

of line and the specific habitat conditions in that particular locale. 
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-34 July 2007

Drawing on a local surface water body for cooling tower make-up could have adverse

aquatic resource impacts. Additional impacts could occur from the discharge of cooling

tower blow-down to the surface water body. Overall, ecological impacts at an alternate site

are expected to range from MODERATE to LARGE with the principal issue likely to be the

| loss of habitat resulting from on-site and off-site construction. 

C Water Use and Quality

Surface Water

Construction and operation of a nuclear facility on a greenfield site could potentially impact

water use and quality in several ways. Construction of the plant would entail significant

disruption to the greenfield site resulting in potential soil erosion and sediment discharge to

adjoining waterways. In addition, construction activities involve substantial use of diesel

driven equipment and lubricants and cleaning agents. While construction activities are

regulated under various Federal and State stormwater management programs, some

potential will exist for release of contaminants to nearby surface water bodies. 

During operation, the facility’s cooling tower(s) would draw on a local surface water resource

for make-up of evaporative losses. In addition, other plant systems may use surface waters

for supplemental cooling and plant potable water needs. These may also be obtained from a

surface water body. Discharges to surface waters from plant operations would also occur.

These could include cooling tower blowdown and possibly treated process and sanitary

wastes.

All withdrawals from and discharges to surface waters would be regulated by Federal and

State programs designed to protect water quality. The staff concludes that impacts to water

quality of construction and operation at a greenfield site, would be SMALL.

Groundwater

It is possible that groundwater could be used as a source of potable water for a nuclear plant

developed at a greenfield site and, depending on hydrogeologic conditions at the site,

possibly as a source of water for general plant purposes. In addition, process and sanitary

wastes could be discharged to groundwater after receiving the appropriate level of treatment.

Discharges to, and withdrawals from, groundwaters are regulated by Federal and State

environmental agencies under programs designed to protect such resources. Thus, the

impacts of operating a nuclear facility on groundwater resources at a greenfield site are

expected to be SMALL. 
Environmental Impacts of License Renewal

July 2007 8-35 NUREG-1437, Supplement 29

C Air Quality

Construction of a new nuclear plant sited at an alternate site would result in fugitive

emissions during the construction process. Exhaust emissions would also come from

vehicles and motorized equipment used during the construction process. An operating

nuclear plant would have minor air emissions associated with diesel generators and other

minor intermittent sources. Overall, air emissions and associated impacts resulting from

operation of a nuclear facility at an alternate greenfield site are considered SMALL.

C Waste

Siting a nuclear plant at an alternate greenfield site would not alter radwaste generation rates

currently occurring at PNPS. The waste impacts associated with operation of a nuclear

power plant are set out in Table B-1 of 10 CFR 51, Subpart A, Appendix B. However,

considerable debris would be generated during construction of the new facility, resulting in

the need to dispose of the material at an appropriate off-site disposal facility. Overall, waste

impacts of constructing and operating a nuclear facility at an alternate greenfield site are

considered SMALL.

C Human Health

Human health impacts for an operating nuclear power plant are set out in 10 CFR 51

Subpart A, Appendix B, Table B-1. Overall, the staff concludes that human health impacts at

an alternate greenfield site would be SMALL.

C Socioeconomics

The construction period peak work force associated with construction of a new nuclear

power plant is currently unquantified (NRC 1996). In the absence of quantitative data, the

staff assumed a construction period of 6 years and a peak work force of up to 2500 for a 715

gross MW(e) nuclear facility at a greenfield site. 

The communities around the greenfield site would have to absorb the impacts of the large,

temporary construction work force and a permanent work force of approximately 700 that

would operate the 715 MW(e) nuclear facility. In the GEIS (NRC 1996), the staff indicated

that socioeconomic impacts of the temporary and permanent work forces would be larger at

a rural site than at an urban site because more of the peak construction work force would

need to move into the area to work. 
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-36 July 2007

Consequently, the staff concludes that socioeconomic impacts of constructing and operating

a nuclear facility at a greenfield site would range from MODERATE to LARGE depending on

specific conditions at the greenfield location. 

Transportation-related impacts associated with construction workers commuting to an

alternate greenfield site are site dependent, but could be MODERATE. Transportation

impacts related to commuting of plant operating personnel would also be site dependent, but

typically are characterized as SMALL to MODERATE.

C Aesthetics

Developing a greenfield site for a 715 MW(e) nuclear facility would result in aesthetic

impacts at that site from the new structures associated with the plant including buildings,

cooling towers, and the plume associated with the cooling towers. There would also be a

potentially significant aesthetic impact from construction of a new transmission line to

connect to the new plant to the regional transmission network.

Noise and light due to construction and plant operations would be detectable off-site. The

impact of noise and light would be mitigated if the plant is located in an industrial area

adjacent to other power plants. Overall, the aesthetic impacts associated with locating a new

nuclear facility at a greenfield site can be categorized as MODERATE to LARGE. The

greatest contributors to this categorization are the aesthetic impacts of cooling tower plumes

and the new transmission line. 

C Historic and Archaeological Resources

A cultural resource inventory would be needed before construction could begin at a

greenfield site if that property has not been previously surveyed. Other lands, if any, that are

acquired to support the plant would also likely need an inventory of field cultural resources,

identification and recording of existing historic and archaeological resources, and possible

mitigation of adverse effects from subsequent ground-disturbing actions related to plant

construction. Impacts to cultural resources can be effectively managed under current law,

and are likely to be SMALL.

C Environmental Justice

Whether or not there would be disproportionate impacts to minority and low income

populations resulting from construction and operation of a nuclear facility at a greenfield site

would depend upon the site chosen and the nearby population distribution. Under a wide

range of site circumstances, it is expected that the impacts would range from SMALL to

MODERATE.
Environmental Impacts of License Renewal

July 2007 8-37 NUREG-1437, Supplement 29

Table 8-6. Summary of Environmental Impacts of New Nuclear Power Generation at 

an Alternate Greenfield Site Using Closed-Cycle Cooling

Alternate Greenfield Site

Impact Category Impact Comments

Land Use MODERATE

to LARGE

Approximately 350 ac required on-site, plus additional land

for transmission line.

Ecology MODERATE

to LARGE

Impact depends on location and ecology of the site, surface

water body used for intake and discharge, and transmission

line route; potential habitat loss and fragmentation; reduced

productivity and biological diversity.

W ater Use and QualitySurface waterSMALL Impact will depend on the volume of water withdrawn and

discharged and the characteristics of the surface water body.

W ater Use and QualityGroundwaterSMALL Impact will depend on the volume of water withdrawn and

discharged and the characteristics of the local aquifers.

Air Quality SMALL Emissions from new nuclear plant expected to be minor.

W aste SMALL Debris waste will be generated during construction, and

would be disposed at an appropriate off-site facility.

Human Health SMALL Human health impacts for nuclear facility considered small.

Socioeconomics MODERATE

to LARGE 

Construction impacts depend on location. Impacts at a rural

location could be LARGE. 

Socioeconomics

(Transportation)

SMALL to

MODERATE

Transportation impacts of construction workers could be |

MODERATE. Transportation impacts of commuting plant

personnel could be SMALL to MODERATE.

Aesthetics MODERATE

to LARGE

Greatest impact is from cooling towers and new transmission

line.

Historic and

Archeological

Resources

SMALL Any potential impacts can likely be effectively managed. 

Environmental Justice SMALL to

MODERATE 

Impacts will vary depending on population distribution and

make-up at the greenfield site. 
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-38 July 2007

8.2.3.2 Once-Through Cooling System

This section discusses the environmental impacts of constructing a replacement nuclear power

plant at a greenfield site using once-through cooling. While many impacts (SMALL,

MODERATE, or LARGE) of this option are generally the same as the impacts for a nuclear

power plant using a closed-cycle system, there are environmental differences between the two

cooling system alternatives. Table 8-7 summarizes the incremental differences.

Table 8-7. Summary of Environmental Impacts of a New Nuclear Power Plant Sited at an Alternate

Greenfield Site with Once-Through Cooling

Impact Category

Change in Impacts from

Closed-Cycle Cooling System

Land Use Impacts may be less (through elimination of

cooling towers).

Ecology Impacts would depend on ecology at the site. 

Potential impacts associated with entrainment of

fish and shellfish in early life stages, impingement

of fish and shellfish, and heat shock.

W ater Use and Quality-Surface W ater Increased water withdrawal leading to possible

water-use conflicts. Thermal load higher than with

closed-cycle cooling.

W ater Use and Quality-Groundwater No change.

Air Quality No change.

W aste No change.

Human Health No change.

Socioeconomics No change.

Socioeconomics (Transportation) No change.

Aesthetics Elimination of cooling towers and plume will

reduce visual impacts.

Historic and Archaeological Resources No change.

Environmental Justice No change.
Environmental Impacts of License Renewal

July 2007 8-39 NUREG-1437, Supplement 29

8.2.4 Purchased Electrical Power

If available, purchased power could potentially obviate the need to renew the PNPS OL.

However, while the concept of purchasing power is plausible, replacing the 715 MW(e) of

capacity that would be lost if the PNPS OL were not renewed with purchased power, without any

new generating facilities being built, is not a likely scenario. This is a result of the growing

demand for power in New England and the fact that many of the region’s power plants are close

to retirement (DOE/EIA 2006a). As a result, DOE has stated that to meet demand, the region

will have to invest in both new local generating capacity and new transmission capacity to bring

purchased power into the area. 

If power to replace PNPS capacity were to be purchased from sources within the U.S., the

generating technology would likely be one of those described in this SEIS and in the GEIS |

(probably coal, natural gas, or nuclear). The description of the environmental impacts of other

technologies in Chapter 8 of the GEIS is representative of the impacts of purchasing electrical

power from a domestic source. Thus, the environmental impacts of imported power would still

occur, but would be located elsewhere within the region or nation. 

Beyond U.S. sources of purchased power, imported power from Canada or Mexico is unlikely to

be available for replacement of PNPS capacity. In Canada, approximately 25 percent of the

energy consumed within the country comes from renewable energy sources, principally

hydropower (DOE/EIA 2005). Canada’s output of electricity from nuclear power is projected to

remain more or less flat between 2010 (114 billion kWh) and 2025 (112 billion kWh) 

(DOE/EIA 2005). EIA projects that total gross U.S. imports of electricity from Canada and

Mexico will decrease from 42.3 billion kWh in 2010 to 29.4 billion kWh in year 2020 and to 26.9

billion kWh in year 2030 (DOE/EIA 2006a). Over the same period there is essentially no firm

power projected to be exported from the U.S. to either Canada or Mexico. Consequently, it is

unlikely that electricity imported from Canada or Mexico would be able to replace the PNPS lost

capacity.

8.2.5 Other Alternatives

Other generation technologies considered by NRC are discussed in the following paragraphs.

8.2.5.1 Oil-Fired Generation

The EIA projects that oil-fired plants will account for very little of the new generating capacity in

the U.S. during the 2004 to 2030 time frame because of continually rising fuel costs 

(DOE/EIA 2006a). Thus, an oil-fired replacement for the capacity that would be lost if PNPS

ceases operation is not considered further in this SEIS.
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-40 July 2007

8.2.5.2 Wind Power

Wind power, by itself, is not suitable for large base load capacity. As discussed in Section 8.3.1

of the GEIS, wind has a high degree of intermittency, and average annual capacity factors for

wind plants are relatively low (on the order of 30 percent). Wind power, in conjunction with

energy storage mechanisms, might serve as a means of providing base load power. However,

current energy storage technologies are too expensive for wind power to serve as a large base

load generator.

As a renewable resource, most regions of the U.S. have been classified according to wind power

classes, which are based on typical wind speeds. These classes range from Class 1 (the

lowest) to Class 7 (the highest). In general, at 50 meters (m) (approximately 164 ft), regions

classified as being in wind power Class 4 or higher can be useful for generating wind power with

large turbines. Some locations in the Class 3 category could also generate useful energy based

| on wind speeds at 80 m (262 ft) rather than at 50 m (164 ft) because of possibly high wind

shears. Given the advances in technology, a number of locations in the Class 3 areas may be

suitable for utility-scale wind development.

Massachusetts has wind resources consistent with utility-scale production. Excellent-tooutstanding wind resources can be found on the northern part of Cape Cod and good-toexcellent areas are found along the southern part of Cape Cod and along the shore of Martha's

Vineyard and Nantucket. In western Massachusetts, excellent wind resources can be found

along ridgelines of the Berkshires (DOE/NREL 2003).

| As of July 31, 2006 there were 10,039 MW(e) of installed wind energy capacity in the U.S. Of

this capacity, only about three MW(e) is installed in Massachusetts. However, several wind

energy projects are in the planning stages within the Commonwealth including Berkshire Wind

Farm [15 MW(e)], Hoosac Wind [30 MW(e)], and Cape Wind [468 MW(e)] (AWEA 2006). Cape

Wind planned for Nantucket Sound is the largest wind energy project contemplated for

Massachusetts. Cape Wind would take advantage of the strong prevailing winds occurring

along the New England coastline. 

Construction of a new 715 MW(e) generating facility using New England’s available wind

resources would disturb a significant land area. A reliable 715 MW(e) wind generating facility

would require placement of generators with two or three times as much capacity as the PNPS

facility, which operates with capacity factors over 85 percent typically, and in some years with

capacity factors of over 95 percent. Several thousand acres of land would be needed for the

alternate wind farm and the land would have to be situated in Class 3 or better wind resource

areas of Massachusetts or elsewhere in New England. Given the extensive land requirements

and the variability of energy output, developing a wind facility to replace PNPS is not considered

to be reasonable.
Environmental Impacts of License Renewal

July 2007 8-41 NUREG-1437, Supplement 29

8.2.5.3 Solar Power

Solar technologies use the sun's energy and light to provide heat and cooling, light, hot water,

and electricity for homes, businesses, and industry. In the GEIS, the staff noted that by its

nature, solar power is intermittent. Therefore, solar power by itself is not suitable for base load

capacity and is not a feasible alternative to license renewal of PNPS. The average capacity

factor of photovoltaic cells is about 25 percent, and the capacity factor for solar thermal systems

is about 25 to 40 percent. Solar power, in conjunction with energy storage mechanisms, might

serve as a means of providing base load power. However, current energy storage technologies

are too expensive to permit solar power to serve as a large base load generator. Therefore,

solar power technologies (photovoltaic and thermal) cannot currently compete with conventional

fossil-fueled technologies in grid-connected applications, due to high costs per kilowatt of

capacity (NRC 1996).

There may be significant impacts to natural resources (wildlife habitat, land use, and aesthetic

impacts) from construction of solar-generating facilities. As stated in the GEIS, land requirements are high at 35,000 ac per 1000 MW(e) for photovoltaic and approximately 14,000 ac per

1000 MW(e) for solar thermal systems. Neither type of solar electric system would fit at the

PNPS site, and both would have large environmental impacts at a greenfield site.

The PNPS site receives approximately 3 to 3.5 kWh of solar radiation per square meter per day,

compared to 6 to 8 kWh of solar radiation per square meter per day in areas of the western

U.S., such as California, which are most promising for solar technologies. Because of the

natural resource impacts (land and ecological), the area’s relatively low rate of solar radiation,

and high cost, solar power is not deemed a feasible baseload alternative to renewal of the PNPS

OL. Some solar power may substitute for electric power in rooftop and building applications.

Implementation of non-rooftop solar generation on a scale large enough to replace PNPS would

likely result in LARGE environmental impacts.

8.2.5.4 Hydropower

In Section 8.3.4 of the GEIS, the staff points out hydropower’s percentage of U.S. generating

capacity is expected to decline because hydroelectric facilities have become difficult to site as a

result of public concern about flooding, destruction of natural habitat, and alteration of natural

river courses. 

The staff estimated in the GEIS that land requirements for hydroelectric power are

approximately 1 million ac per 1000 MW(e). Due to the relatively low amount of undeveloped

hydropower resource in Massachusetts and elsewhere in New England, and the large land use 
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-42 July 2007

and related environmental and ecological resource impacts associated with siting hydroelectric

facilities large enough to replace PNPS, the staff concludes that hydropower is not a feasible

alternative to PNPS OL renewal.

8.2.5.5 Geothermal Energy

Geothermal energy has an average capacity factor of 90 percent and can be used for baseload

power where available. However, geothermal technology is not widely used as baseload

generation due to the limited geographical availability of the resource and immature status of the

technology (NRC 1996). As illustrated by Figure 8.4 in the GEIS, geothermal plants are most

likely to be sited in the western continental U.S., Alaska, and Hawaii where hydrothermal

reservoirs are prevalent. There is no feasible eastern location for geothermal capacity to serve

as an alternative to PNPS. The staff concludes that geothermal energy is not a feasible

alternative to renewal of the PNPS OL.

8.2.5.6 Wood Waste

The use of wood waste to generate electricity is largely limited to those states with significant

wood resources, such as California, Maine, Georgia, Minnesota, Oregon, Washington, and

Michigan. Electric power is generated in these states by the pulp, paper, and paperboard

industries, which consume wood and wood waste for energy, benefitting from the use of waste

materials that could otherwise represent a disposal problem.

A wood-burning facility can provide baseload power and operate with an average annual

capacity factor of around 70 to 80 percent and with 20 to 25 percent efficiency (NRC 1996).

However, the fuels required are variable and site-specific. A significant barrier to the use of

wood waste to generate electricity is the high delivered-fuel cost and high construction cost per

MW of generating capacity. The larger wood-waste power plants are only 40 to 50 MW(e) in

size. Estimates in the GEIS suggest that the overall level of construction impact per MW of

installed capacity should be approximately the same as that for a coal-fired plant, although

facilities using wood waste for fuel would be built at smaller scales. Like coal-fired plants, woodwaste plants require large areas for fuel storage and processing and involve the same type of

combustion equipment.

Due to uncertainties associated with obtaining sufficient wood and wood waste to fuel a base

load generating facility, ecological impacts of large-scale timber cutting (e.g., soil erosion and

loss of wildlife habitat), and low efficiency, the staff has determined that wood waste is not a

feasible alternative to renewing the PNPS OL.
Environmental Impacts of License Renewal

July 2007 8-43 NUREG-1437, Supplement 29

8.2.5.7 Municipal Solid Waste

Municipal waste combustors incinerate the waste and use the resultant heat to generate

steam, hot water, or electricity. The combustion process can reduce the volume of waste by up

to 90 percent and the weight of the waste by up to 75 percent. Municipal waste combustors use

two basic types of technologies: mass burn and refuse-derived fuel. Mass burning technologies

are most commonly used in the U.S. These technologies process raw municipal solid waste “as |

is,” with little or no sizing, shredding, or separation before combustion. Growth in the municipal

waste combustion industry slowed dramatically during the 1990s after rapid growth during the

1980s. The slower growth was due to three primary factors: (1) the Tax Reform Act of 1986,

which made capital-intensive projects such as municipal waste combustion facilities more

expensive relative to less capital-intensive waste disposal alternative such as landfills; (2) the

1994 Supreme Court decision (C&A Carbone, Inc. v. Town of Clarkstown), which struck down

local flow control ordinances that required waste to be delivered to specific municipal waste

combustion facilities rather than landfills that may have had lower fees; and (3) increasingly

stringent environmental regulations that increased the capital cost necessary to construct and

maintain municipal waste combustion facilities (DOE/EIA 2006a).

The decision to burn municipal waste to generate energy is usually driven by the need for an

alternative to landfills rather than by energy considerations. The use of landfills as a waste

disposal option is likely to increase in the near term; however, it is unlikely that many landfills will

begin converting waste to energy because of unfavorable economics, particularly with electricity

prices declining in real terms. EIA projects that between 2004 and 2030, the average price of

electricity in constant dollars (2004) will rise in the near term, then decline and finally rise steadily

resulting in a net modest decline over the entire study period (DOE/EIA 2006a).

Municipal solid waste combustors generate an ash residue that is buried in landfills. The ash

residue is composed of bottom ash and fly ash. Bottom ash refers to that portion of the

unburned waste that falls to the bottom of the grate or furnace. Fly ash represents the small

particles that rise from the furnace during the combustion process. Fly ash is generally removed

from flue-gases using fabric filters and/or scrubbers.

Currently there are approximately 89 waste-to-energy plants operating in the U.S. These plants

generate approximately 2700 MW(e), or an average of approximately 30 MW(e) per plant (IWSA

2006), much smaller than needed to replace the 715 MW(e) of PNPS.

The initial capital costs for municipal solid-waste plants are greater than for comparable steamturbine technology at wood-waste facilities. This is due to the need for specialized wasteseparation and -handling equipment for municipal solid waste (NRC 1996). Furthermore,

estimates in the GEIS suggest that the overall level of construction impact from a waste-fired

plant should be approximately the same as that for a coal-fired plant. Additionally, waste-fired

plants have the same or greater operational impacts (including impacts on the aquatic
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-44 July 2007

environment, air, and waste disposal). Some of these impacts would be moderate, but still

larger than the environmental effects of license renewal of PNPS. Therefore, municipal solid

waste would not be a feasible alternative to renewal of the PNPS OL, particularly at the scale

required. 

8.2.5.8 Other Biomass-Derived Fuels

In addition to wood and municipal solid-waste fuels, there are several other concepts for fueling

electric generators, including burning crops, converting crops to a liquid fuel such as ethanol,

and gasifying crops (including wood waste). In the GEIS, the staff points out that none of these

technologies has progressed to the point of being competitive on a large scale, or of being

reliable enough to replace a baseload plant such as PNPS. For these reasons, such fuels do

not offer a feasible alternative to renewal of the PNPS OL.

8.2.5.9 Fuel Cells

Fuel cells work without combustion and its environmental side effects. Power is produced

electrochemically by passing a hydrogen-rich fuel over an anode and air over a cathode and

separating the 2 two by an electrolyte. The only by-products are heat, water, and CO . Hydrogen

fuel can come from a variety of hydrocarbon resources by subjecting them to steam under

pressure. Natural gas is typically used as the source of hydrogen.

Phosphoric acid fuel cells are generally considered first-generation technology. These fuel cells

are commercially available at a cost of approximately $4500 per kW of installed capacity

(DOE/NETL 2005). Higher-temperature second-generation fuel cells achieve higher fuel-toelectricity and thermal efficiencies. The higher temperatures contribute to improved efficiencies

and give the second-generation fuel cells the capability to generate steam for cogeneration and

combined-cycle operations.

The DOE has an initiative to reduce fuel cell costs to as low as $400 per kW of installed

capacity. For comparison, the installed capacity cost for a natural gas-fired combined-cycle

plant is about $456 per kW (DOE/NETL 2005). As market acceptance and manufacturing

capacity increase, natural gas fuel cells plants in the 50- to 100-MW(e) range are expected to

become available. At the present time, however, fuel cells are not economically competitive with

other alternatives for base-load electricity generation. Fuels cells are, consequently, not a

feasible alternative to renewal of the PNPS OL.
Environmental Impacts of License Renewal

July 2007 8-45 NUREG-1437, Supplement 29

8.2.5.10 Delayed Retirement

According to Entergy, delaying the retirement of existing plants they own would be unlikely to off

set the loss of 715 MW(e) of PNPS capacity over the 20 year OL renewal period 

(Entergy 2006). Also, as stated by DOE (August 2006), New England depends on a number of

older plants that are close to retirement. Thus, delaying retirement of older facilities is not

considered to be a viable alternative to the reliable base load capacity of PNPS.

8.2.5.11 Conservation

Massachusetts, as have most other New England states, has initiated state-wide programs to

reduce both peak demands and daily energy usage (Commonwealth of Massachusetts 2004).

On a state-wide basis, energy savings ascribed to the Massachusetts Energy Efficiency

Programs were estimated to be 241 million kWh in 2002 (Commonwealth of Massachusetts

2004). However, demand-side energy consumption reductions are incorporated in State and

Federal load forecasts and continue to show an increase in energy demand, both nationally and

for New England, over the next several decades (DOE/EIA 2006a). Thus, conservation alone

cannot be used as an alternative to the PNPS facility; and demand-side management cannot be

considered a reasonable alternative to replacement of the entire output of PNPS. 

8.2.6 Combination of Alternatives

There are numerous possible combinations of alternatives that can be considered to replace the

715 gross MW(e) capacity of PNPS. However, many of these combinations would not be

realistic based on the economics of developing central electric generating stations. For

instance, it would be possible to consider a reduced scale coal or nuclear alternative to PNPS in

combination with a technology based on renewable resources. However, the economics of

owning and operating coal and nuclear plants largely preclude construction of intermediate size

or small units. Thus, any realistic combination of alternatives would not include reduced scale

coal or nuclear facilities.

It would, however, be plausible to consider a gas-fired system to replace a portion of PNPS

output since gas-fired facilities are modular in nature and can be developed economically at

output capacities well below 715 MW(e). The scale of a gas-fired system that would be installed

at PNPS as part of a strategy to replace its 715 MW(e) output would be heavily dependent upon

the generating capacity that could realistically be picked up by new systems based on renewable

resources and by conservation. As presented in Section 8.2.5.11, conservation by means of

Demand Side Management (DSM) would appear to offer only a modest opportunity to replace |

some of PNPS output. Thus, a combination that considers a reduced scale gas-fired system

together with conservation would not have impacts significantly different than those presented in

Section 8.2.2 for a full scale gas-fired replacement, because conservation could not be

reasonably assumed to replace much of the PNPS output.
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-46 July 2007

Therefore, the combination considered herein, for illustrative purposes, is to replace the output

of PNPS with 350 MW(e) of gas-fired capacity at the PNPS site, 250 MW(e) of renewable wind

capacity at upland locations in New England, and only 115 MW(e) of conservation derived from

DSM programs. Table 8-8 contains a summary of the environmental impacts of this assumed

combination of alternatives.

Table 8-8. Summary of Environmental Impacts of 350 MW (e) of Natural Gas-Fired Generation, 250

MW (e) from W ind Generation, and 115 MW (e) from DSM Measures

PNPS Site Wind Farm Site

Impact

Category Impact Comments Impact Comments

Land Use MODERATE 30 ac for power block,

offices, roads, and parking

areas. Additional impact of

10 ac for construction of an

underground gas pipeline.

LARGE 1500 ac for wind farm

exclusive of

transmission lines. 

Ecology SMALL Uses some undeveloped

area at PNPS for cooling

tower.

LARGE Impact depends on location and ecology of the

site, but significant

habitat disruption likely.

W ater Use and

Quality-Surface

W ater

SMALL Uses cooling towers. MODERATE May impact natural

drainage patterns of

1500 ac site.

W ater Use and

QualityGroundwater

SMALL Uses less potable water than

PNPS.

SMALL Significant ground water

use not anticipated. 

Air Quality MODERATE Natural Gas-Fired Units at

PNPS

• Sulfur oxides

(10 tons/yr)

• Nitrogen oxides

(148 tons/yr)

• Carbon Monoxide

(141 tons/yr)

10 • PM particulates

(324 tons/yr)

Some hazardous air

pollutants.

SMALL None during operation.

Fugitive dust during

construction. 
Environmental Impacts of License Renewal

July 2007 8-47 NUREG-1437, Supplement 29

Table 8-8. (contd)

PNPS Site Wind Farm Site

Impact

Category Impact Comments Impact Comments

W aste SMALL Small amount of ash

produced from gas-fired

plant.

SMALL No significant waste

streams. 

Human Health SMALL Impacts considered to be

minor.

SMALL None.

Socioeconomics SMALL to

MODERATE

During construction, impacts

would be MODERATE. Up

to 500 additional workers

during the peak of the 2-3-

year construction period,

followed by reduction from

current PNPS work force of

700; tax base reduced. 

 MODERATE Construction impacts

depend on location, but

could be significant

since location is

probably a rural area.

Socioeconomics

(Transportation)

MODERATE Transportation impacts

associated with construction

workers.

MODERATE Potential impacts

associated with 

construction workers at

a rural greenfield

location. 

Aesthetics MODERATE MODERATE aesthetic

impacts due to impacts of

cooling tower plumes. 

LARGE Significant impact from

wind generators and

transmission line at a

rural site.

Historic and

Archeological

Resources

SMALL Any potential impacts at

PNPS can likely be

effectively managed. 

SMALL to

LARGE

Large area disturbed

with potential significant

impact to resources

depending on site

location.

Environmental

Justice

SMALL Impacts on minority and lowincome communities should

be similar to those

experienced by the

population as a whole. 

SMALL to

LARGE

Impacts vary depending

on population

distribution and makeup

at rural site. 
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-48 July 2007

8.3 Summary of Alternatives Considered

The environmental impacts of the proposed action, renewal of the PNPS OL, are SMALL or

MODERATE for all impact categories, except for collective off-site radiological impacts from the

fuel cycle and from high-level waste (HLW) and spent fuel disposal. Collective off-site

radiological impacts from the fuel cycle and from HLW and spent fuel disposal were not

assigned a single significance level but were determined by the Commission to be Category 1

issues nonetheless. The alternative actions, i.e., no-action alternative (discussed in Section

8.1), new generation alternatives (from coal, natural gas, and nuclear; discussed in Sections

8.2.1 through 8.2.3, respectively), purchased electrical power (discussed in Section 8.2.4),

alternative technologies (discussed in Section 8.2.5), and the combination of alternatives

(discussed in Section 8.2.6) were considered.

The no-action alternative would require the replacement of electrical generating capacity by

(1) DSM and energy conservation, (2) power purchased from other electricity providers, 

(3) generating alternatives other than PNPS, or (4) some combination of these options. For

each of the new generation alternatives (coal, natural gas, and nuclear), the environmental

impacts would not be less than the impacts of license renewal, and in most cases would likely be

greater. For example, the land-disturbance impacts resulting from construction of any new

facility would be greater than the impacts of continued operation of PNPS. The impacts of

electrical power purchased outside the New England region would still occur, but would occur

elsewhere as well. Alternative technologies are not considered feasible at this time and it is very

unlikely that the environmental impacts of any reasonable combination of generation and

conservation options could be reduced to the level of impacts associated with renewal of the

PNPS OL.

In conclusion, the staff has determined that the alternative actions, including the no-action

alternative, may have environmental effects in at least some impact categories that reach

MODERATE or LARGE significance.
Environmental Impacts of License Renewal

July 2007 8-49 NUREG-1437, Supplement 29

8.4 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of |

Production and Utilization Facilities.”

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental |

Protection Regulations for Domestic Licensing and Related Functions.”

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Early Site Permits; |

Standard Design Certifications; and Combined Licenses for Nuclear Power Plants.”

40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, |

“National Primary and Secondary Ambient Air Quality Standards.”

40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51, |

“Requirements for Preparation, Adoption, and Submittal of Implementation Plans.”

40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, |

“Standards of Performance for New Stationary Sources.”

American Wind Energy Association. (AWEA). 2006. Wind Project Database. Accessed at:

http://www.awea.org/projects/massachusetts.html on October 12 ,2006.

Clean Air Act of 1970, as amended (CAA), 42 USC 7401, et seq.

C & A Carbone, Inc. v. Town of Clarkstown, New York, 511 U.S. 383, (U.S. Supreme Court

1994).

Commonwealth of Massachusetts. 2004. 2002 Energy Efficiency Activities, A report by the

Division of Energy Resources. Summer 2004.

Department of Energy, National Renewable Energy Laboratory (DOE/NREL). 2003. |

Massachusetts Wind Resource Map. Energy Efficiency and Renewable Energy, Wind and

Hydropower Technologies Program. Accessed at:

http://www..eere.energy.gov/windandhydro/windpoweringamerica/wind_maps.asp 

on April 26, 2006.

Department of Energy, National Energy Technology Laboratory (DOE/NETL). 2005. 2005 |

Office of Fossil Energy Fuel Cell Program Annual Report. September.

Department of Energy, Energy Information Administration (DOE/EIA). 2005. International

Energy Outlook 2005. USDOE/EIA-0484(2005). Washington, DC. Accessed at:

http://www.eia.doe.gov/oiaf/ieo/index.html on April 21, 2006.
Environmental Impacts of License Renewal

NUREG-1437, Supplement 29 8-50 July 2007

Department of Energy, Energy Information Administration (DOE/EIA). 2006a. “Annual Energy

Outlook 2006 with Projections to 2030,” February 2006. 

Department of Energy, Energy Information Administration (DOE/EIA). 2006b. “National Electric

Transmission Study. August 2006.

Entergy Nuclear Operations, Inc. (Entergy). 2006. Applicant’s Environmental Report –

| Operating License Renewal Stage, Pilgrim Nuclear Power Station. Docket Number 50-293, 

Plymouth, Massachusetts.

Environmental Protection Agency (EPA). 1998. "Revision of Standards of Performance for

Nitrogen Oxide Emissions From New Fossil-Fuel Fired Steam Generating Units; Revisions to

Reporting Requirements for Standards of Performance for New Fossil-Fuel Fired Steam

| Generating Units, Final Rule.” Federal Register Volume 63, pgs. 49442-49455. Washington,

| DC September 16, 1998.

Environmental Protection Agency (EPA). 1999. "Regional Haze Regulations, Final Rule."

| Federal Register Volume 64, pgs. 35714-3577. Washington, DC July 1, 1999.

Environmental Protection Agency (EPA). 2000a. “Notice of Regulatory Determination on

| Wastes from the Combustion of Fossil Fuels.” Federal Register Volume 65, pgs. 32214-32237. 

| Washington, DC May 22, 2000.

Environmental Protection Agency (EPA). 2000b. “Regulatory Finding on the Emissions of

Hazardous Air Pollutants from Electric Utility Steam Generating Units.” Federal Register

| Volume 65, pgs. 79825-79831. Washington, DC December 20, 2000.

Environmental Protection Agency (EPA). 2005. “Rule to Reduce Interstate Transport of Fine

| Particulate Matter and Ozone (Clean Air Interstate Rule).” Federal Register. Volume 70, 

| pg. 25162. Washington, DC May 12, 2005.

Gabbard, Alex. 1993. “Coal Combustion: Nuclear Resource or Danger.” Oak Ridge National

Laboratory Review. Oak Ridge National Laboratory: Oak Ridge, Tennessee. Summer/Fall

1993. Accessed at: http://www.ornl.gov/ORNLReview/rev26-34/text/colmain.html on September

19, 2006.

Integrated Waste Services Association (IWSA). Energy Overview. Accessed at:

http://www.wte.org/energy on September 19, 2006.

National Environmental Policy Act of 1969, as amended (NEPA), 42 USC 4321, et seq.
Environmental Impacts of License Renewal

July 2007 8-51 NUREG-1437, Supplement 29

Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, DC.

Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants: Main Report “Section 6.3--Transportation, Table 9.1

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report.”

NUREG-1437, Volume 1, Addendum 1, Washington, DC.

Nuclear Regulatory Commission (NRC). 2001. “NRC Organizes Future Licensing Project

Organization.” Press Release Number 01-035, March 30, 2001. |

Nuclear Regulatory Commission (NRC). 2002. Final Generic Environmental Impact Statement

on Decommissioning of Nuclear Facilities. NUREG-0586, Supplement 1. Washington, DC.

Nuclear Regulatory Commission (NRC). 2006. “NRC Establishing Office of Near Reactors,

Additional Region II Deputy Regional Administrator.” Press Release Number 06-096, July 24,

2006. 

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

July 2007 9-1 NUREG-1437, Supplement 29

9.0 Summary and Conclusions

By letter dated January 25, 2006, Entergy Nuclear Operations, Inc. (Entergy) submitted an

application to the U.S. Nuclear Regulatory Commission (NRC) to renew the operating license

(OL) for Pilgrim Nuclear Power Station (PNPS) for an additional 20-year period (Entergy 2006a). 

If the OL is renewed, State and Federal (other than NRC) regulatory agencies and Entergy

would ultimately decide whether the plant will continue to operate based on factors such as the

need for power, power availability from other sources, regulatory mandates, or other matters

within the agencies’ jurisdictions or the purview of the owners. If the OL is not renewed, then

the plant must be shut down at or before the expiration of the current OL, which expires on June

8, 2012.

Section 102 of the National Environmental Policy Act of 1969, as amended (NEPA) 

(42 USC 4321), directs that an environmental impact statement (EIS) is required for major

Federal actions that significantly affect the quality of the human environment. The NRC has

implemented Section 102 of NEPA in Title 10 of the Code of Federal Regulations (CFR) 

Part 51. Part 51 identifies licensing and regulatory actions that require an EIS. In

10 CFR 51.20(b)(2), NRC requires preparation of an EIS or a supplement to an EIS for renewal

of a reactor OL; 10 CFR 51.95(c) states that the EIS prepared at the OL renewal stage will be a

supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear

Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999).(a)

Upon acceptance of the PNPS application, the NRC began the environmental review process

described in 10 CFR Part 51 by publishing a notice of intent to prepare an EIS and conduct

scoping (NRC 2006a; 71 FR 19554) on April 14, 2006. The staff visited the PNPS site in March

2006 and held public scoping meetings on May 17, 2006, in Plymouth, Massachusetts (NRC

2006b). The staff reviewed the PNPS Environmental Report (ER) (Entergy 2006b) and

compared it to the GEIS, consulted with other agencies, and conducted an independent review

of the issues following the guidance set forth in NUREG-1555, Supplement 1, the Standard

Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating

License Renewal (NRC 2000). The staff also considered the public comments received during

the scoping process for preparation of the draft Supplemental Environmental Impact Statement |

(SEIS) for PNPS. The public comments received during the scoping process that were

considered to be within the scope of the environmental review are provided in Appendix A, 

Part 1, of this SEIS. |

The draft SEIS was published and distributed for public comment on December 8, 2006. The |

staff held two public meetings in Plymouth, Massachusetts, in January 2007 to describe the |

results of the NRC environmental review, answer questions, and to provide members of the |

public with information to assist them in formulating their comments on the draft SEIS. The |
Summary and Conclusions

DRAFT NUREG-1437, Supplement 29 9-2 July 2007

| comment period ended on February 28, 2007. Comments made during the 75-day comment

| period, including those made at the two public meetings, are presented in Appendix A, Part 2, of

| this SEIS.

| This SEIS includes the NRC staff’s analysis that considers and weighs the environmental

effects of the proposed action (including cumulative impacts), the environmental impacts of

alternatives to the proposed action, and mitigation measures available for reducing or avoiding

| adverse effects. This SEIS also includes the staff’s recommendation regarding the proposed

action.

The NRC has adopted the following statement of purpose and need for license renewal from the

GEIS:

The purpose and need for the proposed action (renewal of an operating license) is to

provide an option that allows for power generation capability beyond the term of a

current nuclear power plant operating license to meet future system generating needs,

as such needs may be determined by State, utility, and, where authorized, Federal

(other than NRC) decisionmakers.

The evaluation criterion for the staff’s environmental review, as defined in 10 CFR 51.95(c)(4)

and the GEIS, is to determine:

. . . whether or not the adverse environmental impacts of license renewal are so great

that preserving the option of license renewal for energy planning decisionmakers would

be unreasonable.

Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that

there are factors, in addition to license renewal, that would contribute to NRC’s ultimate

determination of whether an existing nuclear power plant continues to operate beyond the

period of the current OL.

NRC regulations [10 CFR 51.95(c)(2)] contain the following statement regarding the content of

SEISs prepared at the license renewal stage:

The supplemental environmental impact statement for license renewal is not required to

include discussion of need for power or the economic costs and economic benefits of

the proposed action or of alternatives to the proposed action except insofar as such

benefits and costs are either essential for a determination regarding the inclusion of an

alternative in the range of alternatives considered or relevant to mitigation. In addition,

the supplemental environmental impact statement prepared at the license renewal stage

need not discuss other issues not related to the environmental effects of the proposed
Summary and Conclusions

(b) The title of 10 CFR 51.23 is “Temporary storage of spent fuel after cessation of reactor |

operations–generic determination of no significant environmental impact.” |

July 2007 9-3 NUREG-1437, Supplement 29

action and the alternatives, or any aspect of the storage of spent fuel for the facility

within the scope of the generic determination in § 51.23(a) and in accordance with

§ 51.23(b).(b) |

The GEIS contains the results of a systematic evaluation of the consequences of renewing an

OL and operating a nuclear power plant for an additional 20 years. It evaluates 92

environmental issues using the NRC’s three-level standard of significance—SMALL,

MODERATE, or LARGE—developed using the Council on Environmental Quality guidelines. 

The following definitions of the three significance levels are set forth in the footnotes to 

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B:

SMALL - Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

MODERATE - Environmental effects are sufficient to alter noticeably, but not to

destabilize, important attributes of the resource.

LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.

For 69 of the 92 issues considered in the GEIS, the staff analysis in the GEIS shows the

following:

(1) The environmental impacts associated with the issue have been determined to apply either

to all plants or, for some issues, to plants having a specific type of cooling system or other

specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to the

impacts (except for collective off-site radiological impacts from the fuel cycle and from highlevel waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the analysis,

and it has been determined that additional plant-specific mitigation measures are likely not

to be sufficiently beneficial to warrant implementation.

These 69 issues were identified in the GEIS as Category 1 issues. In the absence of new and

significant information, the staff relied on conclusions as amplified by supporting information in
Summary and Conclusions

DRAFT NUREG-1437, Supplement 29 9-4 July 2007

the GEIS for issues designated Category 1 in Table B-1 of 10 CFR Part 51, Subpart A,

Appendix B. 

Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2

issues requiring analysis in a plant-specific supplement to the GEIS. The remaining two issues,

environmental justice and chronic effects of electromagnetic fields, were not categorized. 

Environmental justice was not evaluated on a generic basis and must also be addressed in a

plant-specific supplement to the GEIS. Information on the chronic effects of electromagnetic

fields was not conclusive at the time the GEIS was prepared.

| This SEIS documents the staff’s consideration of all 92 environmental issues identified in the

| GEIS and one new issue (aquatic habitat) identified in a public comment. The staff considered

the environmental impacts associated with alternatives to license renewal and compared the

environmental impacts of license renewal and the alternatives. The alternatives to license

renewal that were considered include the no-action alternative (not renewing the OL for PNPS),

alternative methods of power generation, and conservation. These alternatives were evaluated

assuming that the replacement power generation plant is located at either the PNPS site or

some other unspecified location.

9.1 Environmental Impacts of the Proposed Action - License

Renewal

Entergy and the staff have established independent processes for identifying and evaluating the

significance of any new information on the environmental impacts of license renewal. Neither

Entergy nor the staff has identified information that is both new and significant related to

Category 1 issues that would call into question the conclusions in the GEIS. With the exception

of the requirement for an essential fish habitat (EFH) consultation (see Appendix E for the EFH

assessment), the staff has not identified any new issue applicable to PNPS that has a

significant environmental impact. Therefore, the staff relies upon the conclusions of the GEIS

for all Category 1 issues that are applicable to PNPS.

Entergy’s license renewal application presents an analysis of the Category 2 issues that are

applicable to PNPS, plus environmental justice and chronic effects from electromagnetic fields. 

The staff has reviewed the Entergy analysis for each issue and has conducted an independent

review of each issue plus environmental justice and chronic effects from electromagnetic fields. 

Six Category 2 issues are not applicable because they are related to plant design features or

| site characteristics not found at PNPS. Four Category 2 issues are not discussed in this SEIS

| because they are specifically related to refurbishment. Entergy has stated that its evaluation of

structures and components, as required by 10 CFR 54.21, did not identify any major plant

refurbishment activities or modifications as necessary to support the continued operation of
Summary and Conclusions

July 2007 9-5 NUREG-1437, Supplement 29

PNPS for the license renewal period (Entergy 2006b). In addition, any replacement of |

components or additional inspection activities are within the bounds of normal plant component

replacement and, therefore, are not expected to affect the environment outside of the bounds of

the plant operations evaluated in the Final Environmental Statement Related to Operation of

Pilgrim Nuclear Generating Station (AEC 1972).

Eleven Category 2 issues (including 10 Category 2 issues plus the severe accident mitigation

alternatives (SAMAs) issue from Chapter 5) related to operational impacts and postulated

accidents during the renewal term, as well as environmental justice and chronic effects of

electromagnetic fields, are discussed in detail in this SEIS. Five of the Category 2 issues and |

environmental justice apply both to refurbishment and to operation during the renewal term and

are only discussed in this SEIS in relation to operation during the renewal term. For eight of the |

Category 2 issues and environmental justice, the staff concludes that the potential

environmental effects would be of SMALL significance in the context of the standards set forth

in the GEIS. For entrainment of the local winter flounder (Pseudopleuronectes americanus)

population and impingement of Jones River population of rainbow smelt (Osmerus mordax), the

NRC staff concludes that the potential environmental impacts would be MODERATE. For all

other marine aquatic species, the staff concludes that potential environmental impacts due to

entrainment and impingement would be SMALL to MODERATE. In addition, the staff

determined that appropriate Federal health agencies have not reached a consensus on the

existence of chronic adverse effects from electromagnetic fields. Therefore, no further

evaluation of this issue is required. For SAMAs, the staff concludes that a reasonable, |

comprehensive effort was made to identify and evaluate SAMAs. Based on its review of the

SAMAs for PNPS, and the plant improvements already made, the staff concludes that Entergy

identified five potentially cost-beneficial SAMAs. The staff concludes that two additional SAMAs

are potentially cost-beneficial. However, these SAMAs do not relate to adequately managing

the effects of aging during the period of extended operation. Therefore, they need not be

implemented as part of license renewal pursuant to 10 CFR Part 54.

In addition to considering the 92 issues listed in the GEIS, the staff considered a potential issue |

associated with aquatic habitat. The staff concludes that this issue, while new, is not significant. |

Cumulative impacts of past, present, and reasonably foreseeable future actions were

considered, regardless of what agency (Federal or non-Federal) or person undertakes such

other actions. The staff concludes that cumulative impacts of PNPS license renewal would be

SMALL for most potentially affected resources, with the exception of the local winter flounder

population and the Jones River population of rainbow smelt, for which impacts would be

MODERATE. Overall, the cumulative impacts on marine aquatic resources within the Cape

Cod Bay ecosystem would be SMALL to MODERATE.
Summary and Conclusions

DRAFT NUREG-1437, Supplement 29 9-6 July 2007

Mitigation measures were considered for each Category 2 issue. For most issues, current

measures to mitigate the environmental impacts of plant operation were found to be adequate. 

However, due to the potential for impacts to marine aquatic resources, additional mitigation

measures for the cooling system components and operations may further reduce entrainment

| and impingement impacts. It is expected that any additional mitigation measures would be

| evaluated in the U.S. Environmental Protection Agency’s review of Entergy’s National Pollutant

| Discharge Elimination System permit renewal application.

The following sections discuss unavoidable adverse impacts, irreversible or irretrievable

commitments of resources, and the relationship between local short-term use of the

environment and long-term productivity.

9.1.1 Unavoidable Adverse Impacts

An environmental review conducted at the license renewal stage differs from the review

conducted in support of a construction permit because the plant is in existence at the license

renewal stage and has operated for a number of years. As a result, adverse impacts associated

with the initial construction have been avoided, have been mitigated, or have already occurred. 

The environmental impacts to be evaluated for license renewal are those associated with

refurbishment and continued operation during the renewal term.

Most adverse impacts of continued operation identified would be of SMALL significance with the

exception of impacts of the cooling system, which would have MODERATE impacts on the local

population of winter flounder and rainbow smelt, and SMALL to MODERATE impacts on other

marine aquatic species. The adverse impacts of likely alternatives if PNPS ceases operation at

or before the expiration of the current OL would not be smaller than those associated with

continued operation of this unit, and they may be greater for some impact categories in some

locations.

9.1.2 Irreversible or Irretrievable Resource Commitments

The commitment of resources related to construction and operation of PNPS during the current

license period was made when the plant was built. The resource commitments to be

| considered in this SEIS are associated with continued operation of the plant for an additional 20

years. These resources include materials and equipment required for plant maintenance and

operation, the nuclear fuel used by the reactors, and ultimately, permanent off-site storage

space for the spent fuel assemblies.

The most significant resource commitments related to operation during the renewal term are the

fuel and the permanent storage space. PNPS replaces a portion of its fuel assemblies during

every refueling outage, which occurs on a 24-month cycle (Entergy 2006b).
Summary and Conclusions

July 2007 9-7 NUREG-1437, Supplement 29

The likely power generation alternatives if PNPS ceases operation on or before the expiration of

the current OLs would require a commitment of resources for construction of the replacement

plants as well as for fuel to run the plants.

9.1.3 Short-Term Use Versus Long-Term Productivity

An initial balance between short-term use and long-term productivity of the environment at

PNPS was set when the plant was approved and construction began. That balance is now well

established. Renewal of the OL for PNPS and continued operation of the plant would not alter

the existing balance, but may postpone the availability of the site for other uses. Denial of the

application to renew the OL would lead to shutdown of the plant and would alter the balance in

a manner that depends on subsequent uses of the site.

9.2 Relative Significance of the Environmental Impacts of

License Renewal and Alternatives

The proposed action is renewal of the OL for PNPS. Chapter 2 describes the site, power plant,

and interactions of the plant with the environment. As noted in Chapter 3, no refurbishment and

no refurbishment impacts are expected at PNPS. Chapters 4 through 7 discuss environmental

issues associated with renewal of the OL. Environmental issues associated with the no-action

alternative and alternatives involving power generation and use reduction are discussed in

Chapter 8.

The significance of the environmental impacts from the proposed action (approval of the

application for renewal of the OL), the no-action alternative (denial of the application),

alternatives involving coal, gas, or nuclear-fired generating capacity at an unspecified greenfield

site, gas-fired generation of power at PNPS, and a combination of alternatives are compared in

Table 9-1. Continued use of once-through cooling is assumed for PNPS. All fossil fueled |

alternatives presented in Table 9-1 are assumed to use closed-cycle cooling systems. In the |

evaluation of the nuclear, gas, and coal-fired generation alternatives, substitution of once- |

through cooling for closed-cycle cooling would result in greater environmental impacts related to |

water use and aquatic ecology. However, land use and aesthetic impacts are somewhat |

reduced with once-through cooling. |

Table 9-1 shows that the significance of the plant-specific environmental effects of the proposed

action would be SMALL for all impact categories except for the following:

• entrainment and impingement of the local winter flounder population and Jones River

population of rainbow smelt, respectively, for which MODERATE levels of significance were |
Summary and Conclusions

DRAFT NUREG-1437, Supplement 29 9-8 July 2007

assigned, and entrainment and impingement of the other marine aquatic species, for which

SMALL to MODERATE levels of significance were assigned (see Chapter 4);

• collective offsite radiological impacts from the fuel cycle and from high-level radioactive

waste, for which a single significance level was not assigned (see Chapter 6); and 

• spent fuel disposal, for which a single significance level was not assigned (see Chapter 6). 

Cumulative impacts on the proposed action would be SMALL with the exception of impacts to

| marine aquatic resources, which may experience SMALL to MODERATE cumulative impacts. 

The alternative actions, excluding the no-action alternative, may have environmental effects in

at least some impact categories that reach MODERATE or LARGE significance.

9.3 Staff Conclusions and Recommendations

Based on (1) the analysis and findings in the GEIS (NRC 1996), (2) the ER submitted by

Entergy, (3) consultations with Federal, State, and local agencies, (4) the staff’s own

independent review, and (5) the staff’s consideration of public comments received, the

| recommendation of the staff is that the Commission determine that the adverse environmental

impacts of license renewal for PNPS are not so great that preserving the option of license

renewal for energy planning decisionmakers would be unreasonable.

9.4 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.”

Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to Operation

| of Pilgrim Nuclear Generating Station, Docket Number 50-293, Washington, DC.

| Clean Water Act of 1977 (CWA) 33 USC 1326, et seq.

Entergy Nuclear Operations, Inc. (Entergy). 2006a. License Renewal Application, Pilgrim

| Nuclear Power Station, Docket Number 50-293, Facility Operating License Number DPR-35. 

Plymouth, Massachusetts.

Entergy Nuclear Operations, Inc. (Entergy). 2006b. Applicant’s Environmental Report –

| Operating License Renewal Stage, Pilgrim Nuclear Power Station. Docket Number 50-293, 

Plymouth, Massachusetts.
Summary and Conclusions

July 2007 9-9 NUREG-1437, Supplement 29

National Environmental Policy Act of 1969, as amended (NEPA), 42 USC 4321, et seq. |

Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, DC. |

Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants: Main Report, Section 6.3, Transportation, Table 9.1,

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report. 

NUREG-1437, Volume 1, Addendum 1, Washington, DC. |

Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental

Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1555,

Supplement 1, Washington, DC. |

Nuclear Regulatory Commission (NRC). 2006a. “Notice of Acceptance for Docketing of the

Application and Notice of Opportunity for a Hearing Regarding Renewal of Facility Operating

License No. DPR-35 and for an Additional 20-Year Period.” Federal Register Volume 71, |

pgs. 15222-15223. March 27, 2006. |

Nuclear Regulatory Commission (NRC). 2006b. “Notice of Intent to Prepare an Environmental

Impact Statement and Conduct Scoping Process.” Federal Register Volume 71, 

pgs. 19554-19556. April 14, 2006. |
Table 9-1. Summary of Environmental Significance of License Renewal, the No Action Alternative, and Alternative Methods of Generation

Proposed Action

No Action

Alternative

Coal-Fired

Generation(a) Natural-Gas-Fired Generation(a)

New Nuclear

Generation(a)

Combination of

Alternatives

Impact Category License Renewal

Denial ofRenewal

Alternate

Greenfield Site PNPS Site

Alternate

Greenfield

Site

Alternate

Greenfield

Site

Gas-Fired at PNPS Site(a),

Wind Farm, Conservation

Land Use SMALL SMALL MODERATE 

to LARGE

MODERATE MODERATE to

LARGE

MODERATE toLARGE

MODERATE to LARGE

Ecology SMALL to

MODERATE

SMALL MODERATE

 to LARGE

SMALL MODERATE MODERATE to

LARGE

SMALL to LARGE

Water Use and QualitySurface Water SMALL SMALL SMALL to MODERATE SMALL SMALL SMALL SMALL to MODERATEWater Use and QualityGroundwater SMALL SMALL SMALL to MODERATE SMALL SMALL SMALL SMALLAir Quality SMALL SMALL MODERATE MODERATE MODERATE SMALL SMALL to 

MODERATE

Waste SMALL SMALL MODERATE SMALL SMALL SMALL SMALLHuman Health | SMALL(b) SMALL SMALL SMALL SMALL SMALL SMALLSocio-economics | SMALL MODERATE MODERATE

 to LARGE

SMALL toMODERATE

SMALL toMODERATE

MODERATE toLARGE

SMALL to MODERATE |

Transportation | SMALL SMALL MODERATE

 to LARGE

SMALL toMODERATE

 MODERATE SMALL to

MODERATE

MODERATE

Aesthetics SMALL SMALL MODERATE

 to LARGE

MODERATE MODERATE to

LARGE

MODERATE toLARGE

MODERATE to LARGE

Historic and ArchaeologicalResources

SMALL SMALL SMALL SMALL SMALL SMALL SMALL to 

LARGE

Environmental Justice

SMALL SMALL SMALL to

MODERATE

SMALL SMALL SMALL to

MODERATE 

SMALL to LARGE

(a) Analyses based on use of a closed-cycle cooling system. |(b) Except for collective off-site radiological impacts from the fuel cycle and from high-level waste and spent-fuel disposal, for which a significance level was not assigned. |

See Chapter 6 for details.

Summary and Conclusions

NUREG-1437, Supplement 29 9-10 July 2007
BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(9-2004)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

 (Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

NUREG-1437, Supplement 29

Vol 1

3. DATE REPORT PUBLISHED

MONTH

July

YEAR

2007

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

Generic Environmental Impact Statement for License Renewal of Nuclear Plants,

Supplement 29

Regarding Pilgrim Nuclear Power Station

Final Report - Appendices

5. AUTHOR(S)

See Appendix B of report.

6. TYPE OF REPORT

Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

Division of License Renewal

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, 

Same as 8. above

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

 Docket No. 50-293

11. ABSTRACT (200 words or less)

This supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted by

Entergy Nuclear Operations, Inc. (Entergy), a subsidiary of Entergy Corporation, to the NRC to renew the OL for Pilgrim Nuclear

Power Station (PNPS) for an additional 20 years under 10CFR Part54. This SEIS includes the NRC staff's analysis that

considers and weighs the environmental impacts of the proposed action, the environmental impacts of alternatives to the

proposed action, and mitigation measures available for reducing or avoiding adverse impacts. It also includes the staff's

recommendation regarding the proposed action.

The NRC staff's recommendation is that the Commission determine that the adverse environmental impacts of license renewal

for PNPS are not so great that preserving the option of license renewal for energy-planning decisionmakers would be

unreasonable. This recommendation is based on (1) the analysis and findings in the GEIS; (2)the Environmental Report

submitted by Entergy; (3) consultations with Federal, State, and local agencies; (4) the staff's own independent review; and (5)

the staff's consideration of public comments.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

Pilgrim Nuclear Power Station

Supplement to the Generic Environmental Impact Statement 

GEIS

29

NUREG 1437, Supplement 29

National Environmental Policy Act 

NEPA 

License Renewal

PNPS

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

(This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commision

Washington, D.C. 20555-0001
Printed

on recycled

paper

Federal Recycling Program
 NUREG-1437, Supplement 29 

 Vol. 2 

Generic Environmental 

Impact Statement for 

License Renewal of 

Nuclear Plants 

Supplement 29 

Regarding 

Pilgrim Nuclear Power Station 

Final Report – Appendices 

U.S. Nuclear Regulatory Commission 

Office of Nuclear Reactor Regulation 

Washington, DC 20555-0001
AVAILABILITY OF REFERENCE MATERIALS

IN NRC PUBLICATIONS

NRC Reference Material

As of November 1999, you may electronically access

NUREG-series publications and other NRC records at

NRC’s Public Electronic Reading Room at

http://www.nrc.gov/reading-rm.html.

Publicly released records include, to name a few,

NUREG-series publications; Federal Register notices;

applicant, licensee, and vendor documents and

correspondence; NRC correspondence and internal

memoranda; bulletins and information notices;

inspection and investigative reports; licensee event

reports; and Commission papers and their attachments.

NRC publications in the NUREG series, NRC

regulations, and Title 10, Energy, in the Code of

Federal Regulations may also be purchased from one

of these two sources.

1. The Superintendent of Documents

 U.S. Government Printing Office

 Mail Stop SSOP

 Washington, DC 20402–0001

 Internet: bookstore.gpo.gov

 Telephone: 202-512-1800

 Fax: 202-512-2250

2. The National Technical Information Service

 Springfield, VA 22161–0002

 www.ntis.gov 

 1–800–553–6847 or, locally, 703–605–6000

A single copy of each NRC draft report for comment is

available free, to the extent of supply, upon written

request as follows:

Address: U.S. Nuclear Regulatory Commission 

 Office of Administration

 Mail, Distribution and Messenger Team 

 Washington, DC 20555-0001

E-mail: DISTRIBUTION@nrc.gov 

Facsimile: 301–415–2289 

Some publications in the NUREG series that are 

posted at NRC’s Web site address

http://www.nrc.gov/reading-rm/doc-collections/nuregs

are updated periodically and may differ from the last

printed version. Although references to material found

on a Web site bear the date the material was accessed,

the material available on the date cited may

subsequently be removed from the site.

Non-NRC Reference Material

Documents available from public and special technical

libraries include all open literature items, such as

books, journal articles, and transactions, Federal

Register notices, Federal and State legislation, and

congressional reports. Such documents as theses,

dissertations, foreign reports and translations, and

non-NRC conference proceedings may be purchased

from their sponsoring organization.

Copies of industry codes and standards used in a

substantive manner in the NRC regulatory process are

maintained at—

The NRC Technical Library 

Two White Flint North

11545 Rockville Pike

Rockville, MD 20852–2738

These standards are available in the library for

reference use by the public. Codes and standards are

usually copyrighted and may be purchased from the

originating organization or, if they are American

National Standards, from—

American National Standards Institute

11 West 42nd Street

New York, NY 10036–8002

www.ansi.org 

212–642–4900

Legally binding regulatory requirements are stated

only in laws; NRC regulations; licenses, including

technical specifications; or orders, not in 

NUREG-series publications. The views expressed

in contractor-prepared publications in this series are

not necessarily those of the NRC.

The NUREG series comprises (1) technical and

administrative reports and books prepared by the

staff (NUREG–XXXX) or agency contractors

(NUREG/CR–XXXX), (2) proceedings of

conferences (NUREG/CP–XXXX), (3) reports

resulting from international agreements

(NUREG/IA–XXXX), (4) brochures

(NUREG/BR–XXXX), and (5) compilations of legal

decisions and orders of the Commission and Atomic

and Safety Licensing Boards and of Directors’

decisions under Section 2.206 of NRC’s regulations

(NUREG–0750).
 NUREG-1437, Supplement 29 

 Vol. 2 

 

 

 

Generic Environmental 

Impact Statement for 

License Renewal of 

Nuclear Plants 

Supplement 29 

Regarding 

Pilgrim Nuclear Power Station 

Final Report – Appendices 

Manuscript Completed: July 2007 

Date Published: July 2007 

Division of License Renewal 

Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

(a) Environmental effects are not detectable or are so minor that they will neither destabilize nor

noticeably alter any important attribute of the resource.

(b) Environmental effects are sufficient to alter noticeably but not to destabilize important attributes of the

resource.

July 2007 iii NUREG-1437, Supplement 29

Abstract

The U.S. Nuclear Regulatory Commission (NRC) considered the environmental impacts of

renewing nuclear power plant operating licenses (OLs) for a 20-year period in its Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437,

Volumes 1 and 2, and codified the results in 10 CFR Part 51. In the GEIS (and its

Addendum 1), the staff identified 92 environmental issues and reached generic conclusions

related to environmental impacts for 69 of these issues that apply to all plants or to plants with

specific design or site characteristics. Additional plant-specific review is required for the

remaining 23 issues. These plant-specific reviews are to be included in a supplement to the

GEIS.

This supplemental environmental impact statement (SEIS) has been prepared in response to |

an application submitted by Entergy Nuclear Operations, Inc. (Entergy), a subsidiary of Entergy

Corporation, to the NRC to renew the OL for Pilgrim Nuclear Power Station (PNPS) for an

additional 20 years under 10 CFR Part 54. This SEIS includes the NRC staff’s analysis that |

considers and weighs the environmental impacts of the proposed action, the environmental

impacts of alternatives to the proposed action, and mitigation measures available for reducing

or avoiding adverse impacts. It also includes the staff’s recommendation regarding the |

proposed action.

Regarding the 69 issues for which the GEIS reached generic conclusions, neither Entergy nor

the staff has identified information that is both new and significant for any issue that applies to

PNPS. In addition, the staff determined that information provided during the scoping process

was not new and significant with respect to the conclusions in the GEIS. Therefore, the staff

concludes that the impacts of renewing the OL for PNPS would not be greater than impacts

identified for these issues in the GEIS. For each of these issues, the staff’s conclusion in the

GEIS is that the impact would be of SMALL significance (except for collective off-site |

(a)

radiological impacts from the fuel cycle and high-level waste and spent fuel, which were not

assigned a single significance level).

Regarding the remaining 23 issues, those that apply to PNPS are addressed in this SEIS. For |

each applicable issue, the staff concludes that the significance of the potential environmental

impacts of renewal of the OL would be SMALL, with the exception of marine aquatic resources. |

Due to entrainment and impingement, the continued operation of the cooling water system

would have MODERATE impacts on the local winter flounder (Pseudopleuronectes (b)

americanus) population, and the Jones River population of rainbow smelt (Osmerus mordax).
Abstract

NUREG-1437, Supplement 29 iv July 2007

Continued operation of the cooling water system would have SMALL to MODERATE

| impingement and entrainment impacts on other marine aquatic species as well. Cumulative

| impacts on the local winter flounder population and Jones River population of rainbow smelt

would be MODERATE, and cumulative impacts on other marine aquatic species would be

SMALL to MODERATE.

| The NRC staff’s recommendation is that the Commission determine that the adverse

environmental impacts of license renewal for PNPS are not so great that preserving the option

of license renewal for energy-planning decisionmakers would be unreasonable. This

recommendation is based on (1) the analysis and findings in the GEIS; (2) the Environmental

Report submitted by Entergy; (3) consultations with Federal, State, and local agencies; (4) the

| staff’s own independent review; and (5) the staff’s consideration of public comments.

Paperwork Reduction Act Statement

This NUREG does not contain information collection requirements and, therefore, is not

subject to the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et

seq.).

Public Protection Notification

The NRC may not conduct or sponsor, and a person is not required to respond to, a request

for information or an information collection requirement unless the requesting document

displays a currently valid OMB control number.
July 2007 v NUREG-1437, Supplement 29

Contents

Abstract.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii |

Tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vi |

Abbreviations/Acronyms. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii |

Appendix A Comments Received on the Environmental Review.. . . . . . . . . . . . . A-1

Appendix B Contributors to the Supplement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1

Appendix C Chronology of NRC Staff Environmental Review Correspondence |

Related to Entergy Nuclear Operations, Inc.’s Application for

License Renewal of Pilgrim Nuclear Power Station. . . . . . . . . . . . . . C-1

Appendix D Organizations Contacted. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-1

Appendix E Pilgrim Nuclear Power Station Compliance Status and |

Consultation Correspondence. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1

Appendix F GEIS Environmental Issues Not Applicable to Pilgrim Nuclear 

Power Station. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . F-1

Appendix G U.S. Nuclear Regulatory Commission Staff Evaluation of Severe 

Accident Mitigation Alternatives for Pilgrim Nuclear Power Station. G-1 |
vi

Tables

G-1 PNPS Core Damage Frequency. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . G-3

G-2 Breakdown of Population Dose by Containment Release Mode. .. . . . . . . . . . . . . . . . G-4

| G-3 PNPS PSA Historical Summary. ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . G-6

G-4 SAMA Cost/Benefit Screening Analysis for PNPS. .. . . . . . . . . . . . . . . . . . . . . . . . . . G-27
July 2007 vii NUREG-1437, Supplement 29

Abbreviations/Acronyms

E degree(s)

ìm micron(s)

ac acre(s)

AC alternating current

ACC averted cleanup and decontamination costs

ADS automatic depressurization system

AEC U.S. Atomic Energy Commission

ALARA as low as reasonably achievable

AOC averted off-site property damage costs |

AOE averted occupational exposure

AOG augmented off-gas |

AOSC averted on-site cost |

APE averted public exposure

ASME American Society of Mechanical Engineers

ASMFC Atlantic States Marine Fisheries Commission

ATWS anticipated transient without scram

BA biological assessment

BRW boiling water reactor |

BTU British thermal unit(s)

BWROG boiling water reactor owners group

C Celsius

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CAPB collapsed accident progression bins

CCDP conditional core damage probabilities

CDF core damage frequency

CDS Comprehensive Demonstration Study

CET containment event tree

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

cfs cubic foot (feet) per second

Ci curie(s)

cm centimeter(s)

CO carbon monoxide

CO2 carbon dioxide

COE cost of enhancement

CST condensate storage tanks

CWA Clean Water Act
Abbreviations/Acronyms

viii

| DBA design-basis accidents

DC direct current

DCH direct containment heating

delta T change in temperature

DFO Department of Fisheries and Oceans

DMR discharge monitoring report

DO dissolved oxygen

DOE U.S. Department of Energy

| DSM demand side management

DTV direct torus vent

EA environmental assessment

ECCS emergency core cooling system

EDG emergency diesel generator

EEZ exclusive economic zone

EFH essential fish habitat

EIA Energy Information Administration (of DOE)

EIS environmental impact statement

ELF-EMF extremely low frequency-electromagnetic field

EN-EV environmental review and evaluation procedure

Entergy Entergy Nuclear Operations, Inc.

EOP emergency operating procedure

EPA U.S. Environmental Protection Agency

EPH extractable petroleum hydrocarbons

EPRI Elecrtical Power Research Institute

ER Environmental Report

ESA Endangered Species Act of 1976, as amended

ETE evacuation time estimate

F Fahrenheit

| FES Final Environmental Statement

FIVE fire-induced vulnerability evaluation

FMP fishery management plan

fps foot (feet) per second

FR Federal Register

| FSAR Final Safety Analysis Report

ft foot (feet)

FWS U.S. Fish and Wildlife Service

fy fiscal year
Abbreviations/Acronyms

July 2007 ix NUREG-1437, Supplement 29

GL generic letter

GARM Groundfish Assessment Review Meeting 

GEIS Generic Environmental Impact Statement for License Renewal of Nuclear Plants,

NUREG-1437

GIS geographic information system |

gpm gallon(s) per minute

HAPC habitat area of particular concern

HCLPF high confidence low probability of failure

HLW high-level waste

hp horsepower |

HPCI high pressure coolant injection

ICRP International Commission on Radiological Protection

in. inch(es)

IPE individual plant examination

IPEEE individual plant examination external events

ISLOCA interfacing system LOCA |

km kilometer(s)

kV kilovolt(s)

kW kilowatt(s)

kWh kilowatt hour(s)

L liter(s)

LLRWSF low level radwaste storage facility 

LOCA loss of coolant accident

LOOP loss of off-site power |

LPCI low pressure coolant injection

m meter(s)

m/s meter(s) per second

mA milliampere(s)

MA DEM Massachusetts Department of Environmental Management

MAAP modular accident analysis program

MACCS2 MELCOR Accident Consequence Code System 2

MAFMC Mid-Atlantic Fishery Management Council

MassGIS Massachusetts Geographic Information System

MBDS Massachusetts Bay Disposal Site

MCC motor control centers

MDEP Massachusetts Department of Environmental Protection
Abbreviations/Acronyms

x

MDFW Massachusetts Division of Fisheries and Wildlife

MDMF Massachusetts Division of Marine Fisheries

MDPH Massachusetts Department of Public Health

MEOEA Massachusetts Executive Office for Environmental Affairs

mg/L milligram(s) per liter

MHC Massachusetts Historical Commission

mi mile(s)

| min minute(s)

MISER Massachusetts Institute for Social and Environmental Research

mL milliliter(s)

MLW mean low water

mm millimeter(s)

mrem millirem(s)

MRI Marine Research, Inc.

| MSA Magnuson-Stevens Act

MSIV main steam isolation valve

MSL mean sea level

| MTU metric ton of uranium

| MWd megawatt-days

MW(e) megawatt(s) electric

MW(h) megawatt hour(s)

MWRA Massachusetts Water Resource Authority

MW(t) megawatt(s) thermal

NAFO Northwest Atlantic Fisheries Organization

NAS National Academy of Sciences

NEFMC New England Fishery Management Council

NEFSC Northeast Fisheries Science Center

NEPA National Environmental Policy Act of 1969, as amended

NESC National Electric Safety Code

NHESP Massachusetts Natural Heritage and Endangered Species Program

NHPA National Historic Preservation Act

NIEHS National Institute of Environmental Health Sciences

NMFS National Marine Fisheries Service

NO2 nitrogen dioxide

NOx nitrogen oxide(s) 

NOAA National Oceanic and Atmospheric Administration

NOV notice of violation

NPDES National Pollutant Discharge Elimination System

NPSH net positive suction head

NRC U.S. Nuclear Regulatory Commission
Abbreviations/Acronyms

July 2007 xi NUREG-1437, Supplement 29

OCPC Old Colony Planning Council

ODCM Offsite Dose Calculation Manual

OL operating license

PAH polycyclic aromatic hydrocarbon

PCB polychloronated biphenyl

PDS plant damage state

PGA peak ground acceleration

PILOT payments in lieu of taxes

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

PM10 particulate matter, 10 microns or less in diameter

PNPS Pilgrim Nuclear Power Station

ppm parts per million

ppt parts per thousand

PSA probabilistic safety assessment

psi pound(s) per square inch

RAI request for additional information |

RAMAS risk analysis management alternative system

RBCCW reactor building closed cooling water

RCIC reactor coolant injection cooling

RCRA Resource Conservation and Recovery Act |

REMP radiological environmental monitoring program

REWD Radioactive Effluent and Waste Disposal Report

RHR residual heat removal 

ROW right-of-way

RPC replacement power costs

RPV reactor pressure valve

RRW risk reduction worth

s second(s)

SAFE Stock Assessment and Fishery Evaluation 

SAMA severe accident mitigation alternative

SAR Safety Analysis Report |

SARC Stock Assessment Review Committee 

SBO station blackout

SCR selective catalytic reduction

SEIS supplemental environmental impact statement

SER Safety Evaluation Report

SGTS standby gas treatment system

SLC standby liquid control
Abbreviations/Acronyms

xii

SMHS Southeastern Massachusetts Health Study

SO2 sulfur dioxide

SOx sulfur oxide(s)

SPRA seismic probabilistic risk assessment

SRV steam release valve

SSB spawning stock biomass

SSW salt service water

Sv sievert(s)

TBCCW turbine building closed cooling water 

TDS total dissolved solids

TPH total petroleum hydrocarbons

TRC total residual chlorine

U.S. United States

| USACE U.S. Army Corps of Engineers

USC United States Code

USCB U.S. Census Bureau

USI unresolved safety issue

V volt(s)

VDC volts direct current

VIMS Virginia Institute of Marine Science

yr year(s)
Appendix A

Comments Received on the Environmental Review

July 2007 A-1 NUREG-1437, Supplement 29

Appendix A

Comments Received on the Environmental Review

Part I - Comments Received During Scoping

On April 14, 2006, the U.S. Nuclear Regulatory Commissions (NRC) published a Notice of

Intent in the Federal Register (Volume 71, page 19554) to notify the public of the staff’s intent

to prepare a plant-specific supplement to the Generic Environmental Impact Statement for

License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2, regarding the

renewal application for the Pilgrim Nuclear Power Station (PNPS) operating license. The plantspecific supplement to the GEIS will be prepared in accordance with the National Environmental

Policy Act of 1969, as amended (NEPA), Council on Environmental Quality (CEQ) guidelines,

and Title 10 of the Code of Federal Regulations (CFR) Part 51. As outlined by NEPA, the NRC

initiated the scoping process with the issuance of the Federal Register Notice of Intent. The

NRC invited the applicant; Federal, State, local, and tribal government agencies; local

organizations; and individuals to participate in the scoping process by providing oral comments

at the scheduled public meetings and/or submitting written suggestions and comments no later

than June 16, 2006. 

The scoping process included two public scoping meetings, which were held at the Radisson

Hotel Plymouth Harbor Ballroom, 180 Water Street, Plymouth, Massachusetts, on May 17,

2006. The NRC issued press releases, placed local newspaper ads, and distributed flyers

locally. Approximately 160 people attended the meetings. Both sessions began with NRC staff

members providing a brief overview of the license renewal process and the NEPA process. 

Following the NRC’s prepared statements, the meetings were open for public comments. 

Thirty-three attendees provided either oral comments or written statements that were recorded

and transcribed by a certified court reporter. The transcripts of the meetings can be found as

an attachment to the meeting summary, which was issued on July 13, 2006. The meeting

summary is available for public inspection in the NRC Public Document Room (PDR), located at

One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852, or from the NRC’s

Agencywide Documents Access and Management System (ADAMS). The ADAMS Public

Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams/webbased.html. The meeting summary as well as all written comments can be found in ADAMS

under Accession Nos. ML061700040 and ML062400368, respectively. In addition to the

comments received during the public meetings, six comment letters and one e-mail message

were received by the NRC in response to the Notice of Intent.

At the conclusion of the scoping period, the NRC staff and its contractor reviewed the transcripts and all written material to identify specific comments and issues. Each set of comments

from a given commenter was given a unique identifier (Commenter ID), so that each set of
Appendix A

NUREG-1437, Supplement 29 A-2 July 2007

comments from a commenter could be traced back to the transcript or letter by which the

comments were submitted. Several commenters submitted comments through multiple sources

(e.g., afternoon and evening scoping meetings, and/or written comments). Table A.1 identifies

the individuals who provided comments applicable to the environmental review and the

Commenter ID associated with each person’s set(s) of comments. For oral comments, the

individuals are listed in the order in which they spoke at the public meeting. 

Specific comments were categorized and consolidated by topic. Comments with similar specific

objectives were combined to capture the common essential issues raised by the commenters. 

The comments fall into one of the following general groups:

 C Specific comments that address environmental issues within the purview of the

NRC environmental regulations related to license renewal. These comments

address Category 1 or Category 2 issues or issues that were not addressed in

the GEIS. They also address alternatives and related federal actions.

 C General comments (1) in support of or opposed to nuclear power or license

renewal or (2) on the renewal process, the NRC’s regulations, and the regulatory

process. These comments may or may not be specifically related to the PNPS

license renewal application.

 C Questions that do not provide new information.

 C Specific comments that address issues that do not fall within or are specifically

excluded from the purview of NRC environmental regulations related to license

renewal. These comments typically address issues such as the need for power,

emergency preparedness, security, current operational safety issues, and safety

issues related to operation during the renewal period.

Comments applicable to this environmental review and the NRC staff’s responses are

summarized in this appendix. The parenthetical identifier after each comment refers to the

comment set (Commenter ID). This information, which was extracted from the PNPS Scoping

Summary Report, is provided for the convenience of those interested in the scoping comments

applicable to this environmental review. The comments that are general or outside the scope of

the environmental review for PNPS are not included here. More detail regarding the disposition

of general or inapplicable comments can be found in the scoping summary report. The ADAMS

accession number for the PNPS Scoping Summary Report is ML062710517.
Appendix A

July 2007 A-3 NUREG-1437, Supplement 29

Table A-1. Individuals Providing Comments During Scoping Comment Period

Commenter

ID

Commenter Affiliation (If Stated) Comment Source 

 PNPS-A Mary Lampert Town of Duxbury Nuclear Advisory Committee Afternoon Scoping Meeting

 PNPS-B Keith Maxwell Local Resident Afternoon Scoping Meeting

 PNPS-C Corwne Young District Representative for Congressman Bill Afternoon Scoping Meeting

Delahunt

 PNPS-D Mark Sylvia Town Manager, Plymouth Afternoon Scoping Meeting

 PNPS-E Alba Thompson Citizen, Plymouth Afternoon Scoping Meeting

 PNPS-F Joyce McMahon Massachusetts Affordable Reliable Electricity Afternoon Scoping Meeting

Alliance (Mass AREA)

 PNPS-G Pine du Bois Jones River Watershed Association Afternoon Scoping Meeting

 PNPS-H Robert Ruddock Associated Industries in Massachusetts (AIM) Afternoon Scoping Meeting

 PNPS-I Jim O’Connell Citizen, Chatham Afternoon Scoping Meeting

 PNPS-J Frank Collins Precinct Six Town Meeting Member Afternoon Scoping Meeting

 PNPS-K Rick Anderson Carpenters Local 624 Afternoon Scoping Meeting

 PNPS-L Andre Martecchini Selectman from the Town of Duxbury Evening Scoping Meeting

 PNPS-M Mary Lampert Massachusetts Public Interest Research Group Evening Scoping Meeting

(Mass PIRG)

 PNPS-N Mary Lampert Pilgrim Watch Evening Scoping Meeting

 PNPS-O Mary Ellen Burns Town Meeting Representative, Precinct 13, W. Evening Scoping Meeting

Plymouth

 PNPS-P Jeff Berger Chairman, Nuclear Matters Committee, Town of Evening Scoping Meeting

Plymouth

 PNPS-Q Becky Chin Vice Chairman, Duxbury Nuclear Advisory Evening Scoping Meeting

Committee

 PNPS-R Peter Curley Local Resident Evening Scoping Meeting

 PNPS-S Joyce Mahon Communications Director, Mass AREA Evening Scoping Meeting

 PNPS-T Arthur Powers Local Resident Evening Scoping Meeting

 PNPS-U Leonard Curcuru Local Resident, Mass AREA Member Evening Scoping Meeting

 PNPS-V William Stone Local Resident Evening Scoping Meeting

 PNPS-X Sandra Woods Local Resident Evening Scoping Meeting 

 PNPS-Y Janet Humes Local Resident Evening Scoping Meeting

 PNPS-Z Bob Smith Local Resident Evening Scoping Meeting

 PNPS-AA Jerry Benezra Local Resident Evening Scoping Meeting

 PNPS-AB Tom Belcher Written Comments

 PNPS-AC Mary Lampert Pilgrim Watch Written Comments

 PNPS-AD Frank Gorkey Energy Advocate, Mass PIRG Written Comments

 PNPS-AE Sheila Hollis Attorney for Town of Plymouth Written Comments
Appendix A

NUREG-1437, Supplement 29 A-4 July 2007

 Table A-1. (contd)

Commenter

ID

Commenter Affiliation (If Stated) Comment Source 

 PNPS-AF Rebecca Chin Vice Chairman, Duxbury Nuclear Advisory Written Comments

Committee

 PNPS-AG Elizabeth Huggins Director, Office of Environmental Review, U.S. Written Comments

Environmental Protection Agency

 PNPS-AH Diane Curran Harmon, Curran, Spielberg & Eisenberg, LLP; ForWritten Comments

the Office of the Massachusetts Attorney

General

Comments in this section are grouped in the following categories:

A.1.1 Comments Concerning Water Quality

A.1.2 Comments Concerning Aquatic Ecology

A.1.3 Comments Concerning Socioeconomic Impacts

A.1.4 Comments Concerning Human Health

A.1.5 Comments Concerning Uranium Fuel Cycle and Waste Management

A.1.6 Comments Concerning Postulated Accidents

A.1.7 Comments Concerning Alternative Energy Sources

A.1.8 Comments Concerning Monitoring Programs

A.1 Comments and Responses

A.1.1 Comments Concerning Water Quality

Comment: Given the plant's coastal location, the importance of the coastal waters to the

region's economy, and the use of the coastal water for recreational purposes, it is essential to

confirm that Pilgrim will not violate applicable water quality standards during the renewal period

and jeopardize aquatic life or the health of those using the waters. (PNPS-AE)

Comment: This plant has been over here for 20 years, the water had been coming, the water

has been going, and there has got to be a heck of a lot more water in that ocean out there than

what they are putting out every day to filter it out. (PNPS-T)

Response: The comments are related to water quality issues. Water quality, water use, and

other water issues were evaluated in the GEIS and determined to be Category 1 issues. The
Appendix A

July 2007 A-5 NUREG-1437, Supplement 29

comments provide no new and significant information on water quality; therefore, the comments

will not be evaluated further. Water quality will be discussed in Chapters 2 and 4 of the SEIS.

Comment: Marine impact is a huge area and it doesn't make any sense to say, well, let's not

consider it because they have made an application to EPA for their water discharge permit,

which is overdue, so, hence, they can rely on 1996 data that they have provided and got a

permit back then. We are talking about 2012. It would be like myself saying, you know, I've

applied for a license to drive so, therefore, I have the right to drive and nobody should question

me, so that doesn't make any sense. (PNPS-A)

Comment: In the ER, Entergy claims to be in "continued compliance with applicable [Clean

Water Act "CWA"] standards." Entergy states that the plant received water quality certifications

from the relevant Massachusetts authorities in the early 1970s (as set forth in Attachment A to

the ER) and the National Pollutant Discharge Elimination System ("NPDES") permit for Pilgrim

reflects continued compliance with relevant CWA standards, excerpts of which are also

included in Attachment A. The NPDES permit included in Attachment A, however, appears to

have expired in 1996. While Entergy states elsewhere in the ER that USEPA Region I, the

NPDES permitting authority for Massachusetts, is reviewing an Entergy application for renewal

of the NPDES permit with respect to Pilgrim (see ER, Chapter 4.2.5), Entergy should be

required to provide further evidence (besides excerpts from Attachment A) documenting its

alleged continued compliance with the CWA standards and/or the conclusions of USEPA

Region I regarding the plant's continued compliance with appropriate CWA standards. (PNPSAE)

Comment: EPA is currently reviewing Entergy's application for issuance of its NPDES permit.

While we encourage the NRC to fully analyze the issues described in this letter in its EIS for the

twin purposes of satisfying NEPA and supporting appropriate licensing decisions under the

Atomic Energy Act and NRC regulations, the EIS should not draw conclusions regarding

whether changes to the plant operations or existing NPDES permit conditions would be

necessary or appropriate to satisfy the Clean Water Act, as responsibility for those

determinations rests with the EPA. (PNPS-AG)

Response: The comments are noted. The NRC does not have authority over matters

concerning discharge permits or compliance with the Clean Water Act. To operate PNPS, NRC

regulations require Entergy to comply with the Clean Water Act and its associated requirements

imposed by the USEPA Region I, as part of the NPDES permit. The SEIS will evaluate the

impacts related to impingement and entrainment of organisms, discharges to the aquatic

environment, the thermal plume, and other potential or actual aquatic impacts. In addition, the

status of PNPS's NPDES permit application will be discussed in Chapters 2 and 4 of the SEIS.
Appendix A

NUREG-1437, Supplement 29 A-6 July 2007

Comment: In the past, Pilgrim Station has needed to dredge the areas in front of its cooling

water intake to prevent siltation from interfering with plant operations. The dredged material

must then be disposed of or used in an appropriate way. There have been issues, however,

regarding contamination of that dredged material, presumably as a result of the plant's

wastewater discharges. While these issues were resolved for past dredging, it would be

appropriate for the EIS to assess whether the facility will have future dredging needs and what

environmental issues would be associated with any such dredging. The U.S. Army Corps of

Engineers and EPA are both likely to have information on this topic in their files. (PNPS-AG)

Response: The comment is noted. The impacts of dredging will be evaluated and

incorporated, as appropriate, in Chapters 2 and/or 4 of the SEIS.

Comment: There are no monitoring wells to test for radioactive contaminated water flowing

off-site. The water on-site is not used for drinking; therefore the facility is not required by

regulation to have monitoring wells.

However radioactive waste is buried onsite and leaks from buried pipes and tanks and from

other components can leak into the ground and migrate, as occurred at Braidwood and other

sites discussed in Pilgrim Watch’s Motion to Intervene. Absent monitoring wells, there is no

reasonable assurance that radioactive material will not, or has not, migrated into Cape Cod

Bay, Duxbury Bay, Kingston Bay and/or Plymouth Bay. Pilgrim’s original Environmental Impact

Statement makes it clear that wells must be placed along the shoreline of Cape Cod Bay. 

Surface topography is such that drainage from the Station is seaward and surface water will not

leave the property otherwise. Subsurface water follows the surface topography, resulting in

overall movement of water toward the Bay.

Also they should be placed at any other appropriate on-site locations [such as property along

and off the Access Road] to protect workers, inadvertent intruders and prevent buried

radionuclides from being uncovered and airborne and affecting the neighborhood. (PNPS-AC)

Comment: The potential for tritium leaks at the Pilgrim plant poses a unique hazard to the

public health of the residents if the Town and neighboring areas because the Town and it's

neighbor, Carver, Massachusetts, rely almost totally on the Plymouth-Carver aquifer (the

"Aquifer") for drinking water, and the Aquifer partially supplies neighboring communities as well. 

The Aquifer covers approximately 140 square miles in area with an estimated 500 billion gallons

of potable water. Composed of saturated glacial sand and gravel, the Aquifer ranges in depth

from 20 feet to over 200 feet. The Aquifer is designated by the Environmental Protection

Agency as a "Sole Source Aquifer" - that is, one which provides at least fifty percent of the

water supply given to a community - it is the second largest Aquifer in Massachusetts and one

of only 70 Sole Source Aquifers in the United States.
Appendix A

July 2007 A-7 NUREG-1437, Supplement 29

Of course, while the Aquifer has large reserves, it is not a closed system. The Aquifer is

recharged through the natural seepage of precipitation, septic system discharges, and

agricultural water. Accordingly, any leakage of tritiated water from the Pilgrim plant into the

groundwater could infiltrate the Aquifer, and thereby contaminate the drinking water supplies for

the Town as well as for the heavy agricultural use of the Aquifer, with potentially serious health

implications for those consuming the water or the farm products grown with it.

The Aging Management Plan for Pilgrim provides that underground pipes and tanks will be

inspected when excavated during maintenance and that a focused inspection will be performed

within ten years unless an opportunistic inspection occurs within this period. However, in light

of the increasing frequency of leakage events at analogous nuclear plants in recent years, a

more frequent and thorough inspection of all components that contain radioactive water at the

Pilgrim plant is warranted to avoid the risk of leakages going undetected and to better

safeguard the public health of the residents of the Town and neighboring areas. (PNPS-AE)

Comment: A number of leaks in recent years from underground pipes and tanks releasing

tritiated water from spent fuel pools into the groundwater gives rise to concerns about the

potential for the similar release if radioactive materials at the Pilgrim plant. Leaks from a spent

fuel pool are not uncommon. Indeed, there were leaks reported from three nuclear power

plants in 2005. The Indian Point plant in New York (also owned by Entergy) experienced a

tritium leakage into groundwater likely due to a crack in the spent fuel pool concrete support. 

The Braidwood nuclear power station in Illinois also has leaking tritium and its owners, Exelon

Nuclear, recently agreed to a court order to force it to begin clean-up. The NRC also was

informed that the spent fuel pool at the Connecticut Yankee plant in Haddam, Connecticut was

leaking into the ground at the rate of several gallons per day. Other instances of groundwater

contamination have been reported at nuclear facilities in Arizona, California, and Florida. The

NRC itself has acknowledged the severity of the problem associated with tritium contamination

of groundwater associated with equipment degradation and is assessing what changes, if any,

are needed to the agency's rules and regulations to better protect the public health and safety. 

(PNPS-AE)

Comment: Older plants, such as Pilgrim, are more likely to experience corrosion and leakage

problems that can result in the release of amounts of radioactive materials into the

groundwater. Exposure to radiation from any such leaks represents a threat to human health

and it is a violation of NRC regulations. Adequate inspection and monitoring of and systems

and components that carry radioactive water should be a critical part of Pilgrim's Aging

Management Plan to minimize the likelihood of leakage and associated danger to the safety

and welfare of the public. (PNPS-AE)

Response: Although NRC regulations require licensees to make surveys, as necessary, to

evaluate the potential hazard of radioactive material released in order to assess doses to
Appendix A

NUREG-1437, Supplement 29 A-8 July 2007

members of the public and workers, recent discoveries of releases at other plants indicate that

undetected leakage to groundwater from facility structures, systems, or components can occur

resulting in unmonitored and unassessed exposure pathways to members of the public.

The NRC has identified several instances of unintended tritium releases, and all available

information shows no threat to the public. Nonetheless, the NRC is inspecting each of these

events to identify the cause, verify the impact on public health and safety, and review licensee

plans to remediate the event. The NRC also established a lessons learned task force to

address inadvertent, unmonitored liquid radioactive releases from U.S. commercial nuclear

power plants. This task force reviewed previous incidents to identify lessons learned from

these events and determine what, if any, changes are needed to the regulatory program. 

Detailed information and updates on these liquid releases can be found on the NRC public

website at http://www.nrc.gov/reactors/operating/ops-experience/grndwtr-contam-tritium.htm.

These comments provide no new and significant information and, therefore, will not be

evaluated further.

A.1.2 Comments Concerning Aquatic Ecology

Comment: And also, I would hope that you and EPA DEP would work together to come up

with a number of how many fish, what is it, per acre, can be damaged, as opposed to a more

general statement of what is or is not acceptable. (PNPS-A)

Comment: EPA recommends that the EIS use documented impacts to the marine environment

from the thirty-four years that Pilgrim Station has been in operation to evaluate the direct,

indirect, and cumulative impacts associated with the requested twenty year license extension. 

(PNPS-AG)

Comment: It also affects the plant life in the sea that supports nursery habitats. We are

seeing, through Kingston, Duxbury, Plymouth bays, that our eel grass beds are vanishing. We

don't necessarily know the reason why and we are not in a position to blame the nuclear power

station, but I can say that those kinds of impacts are real, are logical and should be looked at

and addressed with a great deal of diligence, especially in view of what Mary was saying

before. (PNPS-G)

Comment: I'm sure the NRC doesn't know, if they are not from this area, but most of the

people in the room do know that there is a northeast fishing crisis going on, the fishermen

cannot go fishing, there is no cod, there is no haddock, there is no flounder out there.

And this has nothing to do with the nuclear power plant, it has to do with the management of

the species but, anyway, we thought we would try and develop the means to replace the fish in
Appendix A

July 2007 A-9 NUREG-1437, Supplement 29

the oceans, to allow the fishermen to go fishing for more than 50, or 48 or 30 days a year,

which is what they are at right now. (PNPS-I)

Comment: And when they proposed the building of the plant, Boston Edison funded a study

and it was funded by Boston Edison and carried out by the Division of Marine Fisheries, and

they studied what impact the warmer water had on lobsters for a period of three years before

the plant opening and probably about three years after it opened, and the conclusion of that

study was that lobsters came in a little earlier in the spring and stayed there a little later in the

fall, with the warm water. (PNPS-J)

Comment: The area of marine and environmental concerns, the Town of Duxbury and I know

the Town of Plymouth, we have a thriving, and aquaculture and marine fisheries business going

on, and not to mention the recreational sailing, and fishing and everything. We are very

concerned. As we see today, we've had to close the bay, up and down the coast, because of

the flooding and rain. What is the effect of the heat of the discharge that's being dumped into

the bay? How does that effect our environment for our marine industries? (PNPS-L)

Response: The comments are related to aquatic ecology. Aquatic ecology issues will be

discussed in Chapters 2 and 4 of the SEIS.

Comment: To identify species of interest, the EIS should determine the presence of particular

species within general proximity of the project location. The EIS should include species for

which Essential Fish Habitat under the Magnuson-Stevens Act is listed near the proposed

project location. The EIS should cross-reference this list with NOAA's ECOMON and MARMAP

datasets with information from stations around the project area. A final list of species of interest

should be developed in consultation with EPA, NMFS, and Massachusetts Department of

Marine Fisheries. The EIS should also assess any potential impacts to endangered species

from Pilgrims Station's operations. (PNPS-AG)

Comment: The EIS should address relevant issues under other applicable laws, such as

compliance with the Endangered Species Act, the essential fish habitat provisions of the

Magnuson-Stevens Act, and the Coastal Zone Management Act. (PNPS-AG)

Response: In order to determine the potential species of interest to be evaluated in the SEIS,

the NRC has consulted with the US Environmental Protection Agency (USEPA), US Fish and

Wildlife Service (USFWS), National Marine Fisheries Service (NMFS), and Massachusetts

Department of Marine Fisheries (MA DMF). These agencies have provided information on

specific species of interest that should be addressed in the impact assessment. Regarding the

essential fish habitat provisions of the Magnuson-Stevens Act, NRC has consulted with the

Habitat Protection Division of the NMFS. Based on discussions with the NMFS and review of

the databases described in the comment, a list of species to be addressed in the analysis will
Appendix A

NUREG-1437, Supplement 29 A-10 July 2007

be developed and discussed in the Essential Fish Habitat Assessment and in Chapter 4 of the

SEIS.

Regarding endangered species, the NRC has consulted with the US FWS and the NMFSProtection Resources Division regarding potential impacts to terrestrial and aquatic species.

The results of this assessment will be reported in a Biological Assessment (as required by

Section 7 of the Endangered Species Act) and in Chapter 4 of the SEIS.

To evaluate the effects of the proposed action as it relates to the Coastal Zone Management

Act, the NRC has consulted with the Massachusetts Office of Coastal Zone Management (MA

CZM). The analysis of PNPS’s Coastal Zone Management Federal Consistency Certification

will be addressed in Chapters 2 and 4 of the SEIS.

Comment: Other issues were mitigation, adding, you know, fish to the bay to make up for

those that happen to get chopped up in the system, do they breed with native stock? Does that

make a difference? (PNPS-A)

Comment: Evaluation of the effectiveness of various mitigation strategies needs to be

performed with stakeholder input. Stocking: We understand that Entergy has contracted with a

Cape Cod company to provide substitute stock into Cape Cod Bay. However, we understand

that these are a different genetic grouping and that they do not breed with the native stocks. If

this is the case, then this method does not solve the problem. An analysis of this issue is

required. (PNPS-AC)

Comment: The applicant supports an on-going winter flounder hatchery study and claims that

the hatchery activities for winter flounder are providing stock enhancement that can be relied

upon as an effective form of mitigation for entrainment losses of the wild winter flounder

population. If this remains a reasonably feasible option for Pilgrim Station, the EIS should

explore this issue more fully. At present, we are not aware of convincing evidence that the

stocked fish survive to reproduce in these habitats. Moreover, there has not been a study of

the potential impacts of hatchery-related fish on the native population. The genetic and

behavioral implications should also be studied in order to determine if this hatchery is a true

mitigation mechanism for winter flounder or simply another ecological disturbance. (PNPS-AG)

Comment: Entergy, the owners of the plant, is also involved in a number of valuable

environmental initiatives, perhaps one of the most interesting is that they did a great deal of

study in the waters of Cape Cod and the indigenous fish populations. That result, excuse me,

that resulted in their working with Llennoco, a fish hatchery in Chatham, down on the Cape,

which every year hatches, rears and releases 25,000 winter flounder into Plymouth Harbor for

the benefit of the state and the local fishing industry. Entergy also contributes a large amount
Appendix A

July 2007 A-11 NUREG-1437, Supplement 29

of money, in the form of grants, to several local environmental groups working with aquatic and

other environmental issues. (PNPS-F)

Comment: One of the previous speakers concerns was that the fish that were added back,

she was wondering whether they were normal and we find, and seven years of experience has

proven, that they are normal, just like the every day fish, the young of the native fish that are

out there now. Not only did we find that they were normal but we found out that they flourish

out there ... And I'm again oversimplifying but we found that now that we found we can do it, we

can also do it with cod and we can do it with haddock. In other words, we are on the verge of

actually being able to make a difference and we are doing this because Entergy actually helped

us, they supported us and helped us build this pilot facility for their own reasons, I'm sure. 

(PNPS-I)

Response: The comments are related to mitigation of potential impacts to winter flounder

populations through the addition of hatchery-reared fish to the local population. This issue will

be discussed in Chapter 4 of the SEIS.

Comment: As far as impingement goes, fish that are smacked against the grate and then

removed, have they been permanently damaged so that they do not have a survival affect, has

that been studied? Would we be better off having a grate at the mouth of the canal that might

decrease the number of fish impinged or increase their survivorability and, at the same time,

have a security effect by catching any explosive that a bad guy wanted to put up the intake

canal? (PNPS-A)

Comment: And I think you should look carefully at a memo prepared by Jerry Szal, S-Z-A-L, of

the DEP, specifically on the marine effect of Pilgrim on our environment, the once through

cooling system. In it, he mentions some very important items. One is it appropriate to average

the temperature discharge or is it more important to be required to have an instantaneous

discharge so the maximum number is always adhered to? (PNPS-A)

Comment: And I think that what Mary Lampert said about adjusting the screening and the

intake makes a lot of sense in term of trying to mitigate further the ongoing damage in the

intake structure to those populations. (PNPS-G)

Comment: Impingement: Because impinged fish from the intake screens are shunted back

into the intake, there is a concern that these fish, weakened from impingement, will simply be

re-impinged. Permitting and resource agencies should consider requiring an assessment of reimpingement rates to select species of concern. These studies should also assess the need to

re-locate the discharge point for impinged fish in order to minimize re-impingement. (PNPSAC)
Appendix A

NUREG-1437, Supplement 29 A-12 July 2007

Comment: Discharge Effects Thermal Discharge: Discharge temperature is now averaged

over an hour; instantaneous measurement should be required.

Thermal backwash: In summary, during a thermal backwash, about 155,000 gpm of heated

water (F) is sent into the intake embayment for a period of about 1.5-2 hrs. Studies to evaluate

potential impacts of the thermal backwash have not been performed to the knowledge of DEP’s

Gerry Szal. >105 (PNPS-AC)

Comment: Wet Land refurbishment or other unrelated environmental measure: These

measures are all well and good but do not address the issue at hand. See following

attachment, Marine Attachment Pilgrim Nuclear Power Station: review of intake and discharge

effects to finfish - Technical Memorandum For The Record, Gerald M. Szal [Department

Environmental Protection, MA.], August 30, 2005. (PNPS-AC)

Comment: Pilgrim Station operations have resulted in a range of impacts to marine life in

Cape Cod Bay. Because the facility annually entrains large quantities of fish eggs and larvae

and impinges large quantities of juvenile and adult fish, we recommend that the EIS pay

particular attention to this impact of the plant's cooling system, especially with respect to winter

flounder, Atlantic cod, and rainbow smelt. Winter flounder is a species of particular interest due

to its commercial, recreational and ecological importance. Estimated of winter flounder age -3

adult equivalent losses due to entrainment and impingement as reported by Pilgrim in annual

monitoring reports have ranged from <1% of the Cape Cod Bay population to almost 30% of

the population annually. Entrainment and impingement losses of Atlantic cod and rainbow

smelt are of particular concern as well. Atlantic cod have historically supported a large

commercial fishery in New England, but their numbers have declined to the point that

commercial fishing for this species has almost been completely eliminated in Massachusetts

Bay. The EIS should discuss entrainment and impingement losses of Atlantic cod at Pilgrim

Station within the context of a collapsed commercial fishery. Pilgrim Station also impinges

rainbow smelt, whose numbers have plummeted due to problems such as the loss of spawning

habitat. It is our understanding that Rainbow smelt are now being studies for potential listing as

a threatened or endangered species under the Endangered Species Act. The entrainment and

impingement losses of this species at Pilgrim Station should be assessed within that context. 

(PNPS-AG)

Comment: Pilgrim station currently controls macro-fouling by periodically re-routing heated

condenser cooling water back through the system and out through each intake embayment

separately. This process, called thermal backwashing, is preformed about four to five times per

year at full thermal load and three to four times per year at 50% thermal load. Backwashing

both sides of each condenser can take up to four hours within one day and the temperature

may reach as high as 120F. EPA encourages the NRC to include an evaluation of the impacts

of the thermal backwash on aquatic organisms in the EIS. (PNPS-AG)
Appendix A

July 2007 A-13 NUREG-1437, Supplement 29

Comment: It should also be noted that two fish kill events resulting from gas bubble disease

occurred in the Station's discharge canal during the 1970's. Subsequently, Pilgrim was

required to install a barrier net in the discharge canal to prevent fish from entering and residing

there. However, in 1996 Pilgrim was allowed to remove the net because no significant fish kill

events had occurred for some time. There also have been no documented large fish kill events

since the net was removed. Nevertheless, there is a risk that a large year class of menhaden,

for example, will detect the thermal plume of Pilgrim Station and possibly take residence in the

plume or canal. This would once again subject fish to gas bubble disease. The EIS should

consider options for preventing this impact when a strong year class is projected, including the

possibility of requiring that Pilgrim Station deploy a barrier net during appropriate periods to

reduce impacts and implement a biological surveillance program to effectively determine when

the impact minimization measures should be triggered. (PNPS-AG)

Comment: EPA is concerned about repeated impingement events at Pilgrim Station. Historic

data for Pilgrim shows high impingement numbers for several fish species including Atlantic

silversides, Atlantic menhaden, blueback herring, grubby, alewife, Atlantic cod, and rainbow

smelt. The majority of rainbow smelt impinged at Pilgrim Station are believed to have

originated from the nearby Jones River population. However, without quantitative evaluation of

the size of the Jones River population, it is not possible to fully assess the impact of Pilgrim

Station The EIS should assess the potential impacts of impingement on all native fish species

affected, as well as provide a discussion of potential measures that can be taken to reduce

these impacts. (PNPS-AG)

Comment: This EIS should assess Pilgrim Station's current fish return system and document

any problems with it. We currently recognize at least three shortcomings of the current fish

return system that contribute to an increase on impingement mortality at Pilgrim. First,

chlorinated service water from the intake is de-chlorinated and used to spray fish and debris

from screens. There have been several documented occasions when the de-chlorination

system failed to operate correctly and fish were subjected to a chlorinated salt-water spray. 

Second, the screens are normally only rotated once every 8- hour shift, thereby increasing the

length of time that fish are held against the screens. Third, fish are returned back to the intake

embayment of the Station, about 100 yards upstream of the intake structure, which may result

in high re-impinging rates.

In response to these three issues, we believe the EIS should discuss the benefits of installing a

chlorine measuring and malfunction system, evaluate the feasibility of continuous screen

rotation and assess re-impingement rates and whether there may be a more appropriate

relocation point for the fish return. In addition, the EIS should evaluate other options for

improving the fish return system to minimize impingement mortality. (PNPS-AG)
Appendix A

NUREG-1437, Supplement 29 A-14 July 2007

Comment: The EIS should discuss reasonable alternative ways to reduce impingement,

impingement mortality, entrainment and thermal discharges at the Pilgrim Station. Specifically,

EPA supports thorough evaluation of (1) alternative protection technologies including

substratum intake structure, various screening technologies (including wedgewire screens, finemesh barrier nets or screens (e.g., "Gunderbooms")), cooling towers, variable speed pumps,

and fish return system upgrades; (2) alternative operational schemes including seasonal flow

restrictions, continuous screen operation, scheduling plant outages to minimize environmental

impacts and the installation of a chlorine measuring and malfunction notification system; and (3)

potential mitigation measures. In assessing these alternatives, the EIS should not only

evaluate their environmental ramifications, but should also address the nuclear power plant

safety implications of the alternatives. (PNPS-AG)

Comment: The EIS should also assess the effects of the thermal plume on the marine

environment, including effects on water quality and marine organisms. This analysis should

consider possible acute and chronic effects to marine organisms, such as causing mortality,

habitat avoidance, interrupted spawning, or increased prediction of threats, based on an

evaluation of the temperatures at which effects on health and behavior of the relevant

organisms may occur. Possible ecological effects should be considered (e.g., has warm water

attracted non-native species that drive out the native species). Effects on the benthic

community, including physical effects from scouring by the discharge, should also be

addressed. Adverse benthic effects have been documented in the past, primarily from

scouring, over an area of one to two acres. (PNPS-AG)

Comment: Pilgrim Station discharges a maximum of 510 million gallons per day (MGD) of

heated non-contact condenser cooling water to Cape Cod Bay. Pilgrim's current National

Pollutant Discharge Elimination System (NPDES) permit specifies a maximum daily

temperature limit of 102F. The EIS should assess the scope of the thermal plume across the

tidal cycle in terms of area and depth of the water body impacted, the amount of heat added to

the water (in British Thermal Units) and the extent to which the discharge alters ambient water

temperatures. (PNPS-AG)

Comment: Several other fish species, besides winter flounder, also suffer substantial

entrainment losses at the Pilgrim facility. These include cunner, mackerel, menhaden, Atlantic

cod and Atlantic herring. The EIS should assess the potential impacts of entrainment on all the

native fish species affected, along with means to reduce these impacts, including the use of the

alternate cooling water intake system technologies discussed below. (PNPS-AG)

Comment: In addition, we recommend that the EIS explore alternative modes of operation that

would avoid and minimize environmental impacts associated with the current mode of

operation. These impacts include effects on water quality and marine life from the facility’s
Appendix A

July 2007 A-15 NUREG-1437, Supplement 29

pollutant discharges (e.g., any discharges of heat, chemicals, radionuclides, etc.) and

withdrawals of water from Cape Cod Bay for cooling. (PNPS-AG)

Comment: There is apparently significant influence by the plant on the bay area, people that

are familiar with the area do say that it is relatively barren. The problem that results from that

and the raising of the temperature is that there are various impacts on the ecosystem that we

are seeing today, for instance, in the ongoing concern about red tide. If our bay temperature

rises, like, for instance, Mt. Hope Bay where Brayton Point, the Cole Power Station, has

significantly raised the temperature of the bay, there is a lot of changing of the population to

fish, the aquatic life in the system. We lose fish, like sturgeon, we lose the larger fish that we

ourselves depend on for our survival and begin to have problems with algae, we begin to have

problems with low oxygen levels. (PNPS-G)

Comment: We believe that you have to do much, much, much more examination of the impact

of the heated water going into the bay than has been done and you have to do much, much

more than have a hatchery for winter flounder. (PNPS-G)

Comment: Finally, the Pilgrim Plant's cooling system causes significant damage to the

environment of Cape Cod Bay. Pilgrim uses a once through cooling system, taking in nearly

one half billion gallons of water a day and setting it into the bay at 25 or more degrees hotter.

An additional 20 years of operations at Pilgrim, using this cooling system, could kill billions of

aquatic plants and animals, this cooling system also violates Chapter 316B of the Federal

Clean Water Act which requires the plant to use the best available technology to minimize

environmental impact.

We believe that the plant must be held to the highest standards under the Clean Water Act and

a closed cycle cooling system should be installed as soon as possible, and certainly before the

license extension is granted. (PNPS-M)

Comment: Thermal discharge temperature is now averaged, there should be a cap and

required instantaneous measurement. (PNPS-N)

Comment: The second comment from DEP was because impinged fish from the intake

screens are shunted back into the intake, there is concern that these fish, weakened from

impingement, will simply be reimpinged. Permitting the resource, permitting resource agencies

should consider requiring an assessment of reimpingement rates to select species of concern. 

These studies should also assess the need to relocate the discharge point for impinged fish in

order to minimize reimpingement. (PNPS-N)
Appendix A

NUREG-1437, Supplement 29 A-16 July 2007

Response: The comments, in general, express concern regarding the impacts on aquatic

organisms resulting from operation of the existing PNPS once-through cooling system. To

operate PNPS, NRC Regulations require Entergy to comply with the Clean Water Act and its

associated requirements imposed by USEPA Region I, as part of the NPDES permit. The SEIS

will evaluate the impacts related to impingement and entrainment of organisms, discharges to

the aquatic environment, the thermal plume, and other potential or actual aquatic impacts.

Additionally, a brief discussion of potential mitigation measures to limit impingement and

entrainment impacts will be presented in Chapter 4 of the SEIS.

Comment: Marine impact can not be assessed at present because definite numbers have not

been set on what constitutes “significant impact.” A yardstick has to be firmly established for

each species (plant and animal) with appropriate federal, state and independent partners and

rationales provided to the public.

For example: There appear to be many methods used to determine impact, each with

drawbacks. It must be determined before going forward with the re-licensing process what

methods provide the most reliable estimates of impact, with a detailed rationale; a requirement

that these methods are followed by the licensee unless better methods are established and

independently approved.

We understand that no policy statement regarding losses on a square mile basis has been

issued by any state or federal agency. NRC must in its review process determine what percent

loss is a significant detriment to any population [figure depending on population], with a detailed

rationale. (PNPS-AC)

Response: This comment relates to aquatic ecology and the determination of significant

impact. The NRC developed a three-level standard of significance (Small, Moderate, Large) for

assessing environmental issues. These levels of significance were established using the

Council of Environmental Quality’s regulations (40 CFR 1508.27) to systematically evaluate the

consequences of likely environmental impacts of renewing the operating license for a nuclear

power plant for an additional 20 years. Significance indicates the importance of likely

environmental impacts and is determined by considering two variables: context and intensity.

| Context is the geographic, biophysical and social context in which the effects will occur, or in

the case of license renewal, the environment surrounding the facility. Intensity refers to the

severity of the impact.

Comment: Winter Flounder: DEP’s Gerry Szal recommended that resource agencies, in

concert with the permitting agencies, should consider further evaluation of the intake effects to

winter flounder. If effects are found to be substantial, these agencies should determine what

steps need to be taken to reduce the impacts of the facility on the winter flounder population. 

(PNPS-AC)
Appendix A

July 2007 A-17 NUREG-1437, Supplement 29

Comment: Intake Effects Entrainment: Winter Flounder - methods used by Entergy to

determine impact. 

1. Equivalent adult method: "researchers conducting this work have assumed an otter trawl

efficiency of 50%, but the actual efficiency may be much lower (or higher), which would alter the

number of fish in the study area per square mile and the apparent impact. Second, entrainment

sampling results are quite variable. Third, it is difficult to determine the accuracy, and therefore,

the applicability, of the survival matrix used in estimating equivalent adults."

Whether or not these levels of impact are a "significant" detriment to the population, and will

result in slowing the return to much higher population densities, is currently unknown and a

policy statement regarding losses on a square mile basis has not been issued by any of the

state or federal agencies. EPA Region 1 has stated in the past that population impacts of 5%

or greater are typically of concern. However, to DEP’s Gerry Szal’s knowledge, the geographic

bounds of this particular population have not been agreed upon by state or federal agencies.

2. 2nd method - estimate the percentage of the total larval population passing in front of the

facility that is entrained.

3. The third method used by the facility to evaluate impact was the RAMAS (Risk Analysis

Management Alternative System; Ferson, 1993) winter flounder model. It was used from 1999-

2001 to further evaluate the effects of the facility on the Cape Cod Bay winter flounder

population. Results suggested that stock reductions from 2.3 to 5.2% might occur as the direct

result of entrainment at the facility.

It should be determined and agreed upon by NRC, appropriate state agencies and independent

analysts what method or methods actually provide accurate information needed to assess

impact. (PNPS-AC)

Comment: Rainbow Smelt: "Brad Chase, DMF (pers. comm. to G. Szal, August 29, 2005)

estimates that there has been a sharp decline in the rainbow smelt population in the Jones

River since the time when the Lawton, et al. (1990), studies were conducted. Unfortunately,

without a quantitative evaluation of the rainbow smelt population size in the Jones River, Mr.

Chase felt it was not possible to assess the potential impact of Pilgrim’s impingement events on

the Jones River smelt population." Until studies performed by the state and the Jones River

Watershed Association, we should not finalize a re-licensing decision. (PNPS-AC)

Comment: In addition, the Town is concerned about the economic impact of an accident, as

well as routine operations at the plant, on commercial fisheries in the area. The local

population of winter flounder, in particular, is of significant concern because it provides an

important commercial fishery and because the area around the plant serves as spawning,
Appendix A

NUREG-1437, Supplement 29 A-18 July 2007

nursery, and feeding grounds for the species. A moderate or severe accident at the plant

would have a deleterious effect on the flounder population, and therefore commercial fishery in

the region. While the ER concludes that plant operations "have not had a significant effect on

local and regional populations of fish and shellfish," (ER, Chapter 2.2.5) the Town submits that

additional evaluation of the intake effects to winter flounder are warranted to assess accurately

the long-term implications on this species of continued operations at Pilgrim during the renewal

period. (PNPS-AE)

Comment: In the past, Entergy has used the following three methods to evaluate the Station's

entrainment impacts to the local winter flounder population: (1) the "equivalent adult" method;

(2) estimating the percentage of the total larval population passing by the facility that is

entrained; and (3) the RAMAS (Risk Analysis Management Alternative System: winter flounder

model. We believe these three methods, and others as appropriate, should be discussed in the

EIS based on coordination with the EPA and other interested state and federal agencies. In

coordination with EPA and other interested resource agencies, the EIS should include an

analysis of the accuracy and applicability of these methods. (PNPS-AG)

Comment: What we have learned, over time, and I was trained as a psychologist, I was not

trained as an environmentalist, so we had a lot of learning to do and what we learned, over

time, was that the importance of the Jones River, as the largest river in Cape Cod Bay, relates

to the larger Gulf of Maine ecosystem, and the Gulf of Maine is one of those very few and rare

systems in the world, globally, that provide us with all of our ocean fish. What we are learning

is that if the Jones River's fish populations are lost, then the Gulf of Maine health is impacted. 

(PNPS-G)

Comment: The Jones River, being the largest river in Cape Cod Bay, is important to the

ecosystem, not only to itself, but to the bay and to the entire Gulf of Maine. What we have

noticed in the Jones River is that the fish are diminishing and while it is true that Pilgrim and

Entergy have contributed to our work, that contribution has not overcome what we believe is a

growing lessening of the populations of fish, particularly herring and smelt, in the system. 

Herring and smelt have both a history of entrainment at the plant. (PNPS-G)

Comment: DEP stated that the resource agencies, in concert with the permitting agencies,

should consider further evaluation of the intake effects to winter flounder. If effects are found to

be substantial, these agencies should determine what steps should be taken next. They

particularly pointed out that winter flounder that is dumped in from a Chatham laboratory, that

we heard from this afternoon, that these are fish that go in, but they are different, genetically,

and they don't breed with the current stock. (PNPS-G)

Comment: Rainbow smelt, as you heard today, they are considering putting on the

endangered species list because of their low numbers in the Jones River Watershed. There
Appendix A

July 2007 A-19 NUREG-1437, Supplement 29

should be a policy statement regarding losses on a square mile basis, this has not been done

by any federal agency and, if you don't have a real standard, then what are you doing? Also,

there appear to be many methods used to determine impact, each with drawbacks. What

methods would provide the most reliable results? This should be clearly stated in the analysis

provided. (PNPS-N)

Response: The comments are related to the potential impacts of continued operation of the

plant on winter flounder, rainbow smelt, and other aquatic species populations. Assessment of

these species, in addition to other aquatic organisms, will be presented in Chapters 2 and 4 of

the SEIS.

A.1.3 Comments Concerning Socioeconomic Impacts

Comment: When the plant came on line in 1972, it was equal in value to all the other

assessed property in the Town of Plymouth, so it effectively halved our tax rate. We were the

next town, that was South of Boston, that was probably going to experience some strong

growth and, coupled by our large land area, 103 square miles, and relatively cheap land prices,

and dirt cheap real estate prices, the savings that, at that time, the Boston Edison Plant brought

us was soon surpassed by the demands of the burgeoning population on the infrastructure ...

We built new elementary schools, new high schools, new middle schools, a lot of roads were

developed, some at the expense of developers and often they were maintained at the expense

of the town. We're in a position now that we are dependent on the town for a significant portion

of our tax, the plant, rather, for a significant portion of our tax revenue. (PNPS-J)

Response: The comment is related to the socioeconomic impacts specific to PNPS.

Socioeconomic impacts such as taxes, employment, and land use are Category 2 issues.

These issues will be addressed in Chapters 2 and 4 of the SEIS.

Comment: Speaking of work, Pilgrim is also an important source of jobs, there is more than

700 permanent, full time employees, most of whom live in Plymouth and the surrounding

communities. Indeed, Pilgrim supports the local economy to the tune of $135 million a year in

local economic activity. (PNPS-F)

Response: The comment is noted. Socioeconomic issues specific to the plant are Category 2

issues and will be discussed in Chapter 4 of the SEIS.

Comment: The Town was founded in 1620 by the Pilgrims escaping religious persecution in

England and is known as "America's Hometown." As such, the Town is the cornerstone of

American freedom and values. Every year thousands of visitors come to the Town to visit not

only Plymouth Rock, but also the other historical sites in and around the Plymouth area.

Typically, tourists travel not only to the Town, but also to Boston or out to Cape Cod and other
Appendix A

NUREG-1437, Supplement 29 A-20 July 2007

coastal areas. In 2003, for example, travel expenditures for Plymouth County were $353 million

(excluding payroll, state tax and local tax receipts), with the Town receiving a significant portion

of those amounts. The contribution of tourism to the health of the local economy, therefore, is

central. (PNPS-AE)

Response: The comment is related to socioeconomic impacts, specifically tourism, recreation,

or historic appeal. Public services involving tourism and recreation were evaluated in the GEIS

and were determined to be Category 1 issues. Historic and archaeological resources and

socioeconomic issues were evaluated in the GEIS and were determined to be Category 2

issues and will be addressed in Chapters 2 and 4 of the SEIS, as appropriate.

Comment: The total population within a 50-mile radius of PNPS was estimated by Entergy for

the year 2032 by combining total resident population projections with transient population data

from Massachusetts and Rhode Island...

The region is expected to add 465,000 people by 2030. The region will be aging with a

dramatic spike in the over 55 population. The largest population increases are expected in

urban centers such as Boston and Cambridge and in a half-dozen suburban towns, such as

Plymouth and Weymouth with very large housing developments on the horizon. (MAPC Metro

Future projections brief #1)

According to the report the area south of Boston is expected to grow faster in population and

jobs than any other section of Greater Boston through the year 2030. Jobs are important

because they factor into projecting the transient population.

Communities south of Boston will grow 13%. Plymouth is expected to add the most, about

10,000 residents - a population jump over 20%.

The population is expanding because there is more open land and large projects are planned in

Plymouth and on the Weymouth Navel Air Station land ---located just off Route 3, the

evacuation route for Duxbury and Marshfield. (PNPS-AC)

Response: Socioeconomic issues, including demographics, that are considered to be

Category 2 issues, will be addressed as appropriate in Chapters 2 and 4 of the SEIS.

A.1.4 Comments Concerning Human Health

Comment: We hope you will also be looking at the new information, since `72, of health

impacts in our communities. There has been a case controlled study of adult leukemia, there

has been review that has been done of the cancer, of the Massachusetts Cancer Registry,

since it started in `82, showing a consistent rise in thyroid and leukemia cancers in the seven
Appendix A

July 2007 A-21 NUREG-1437, Supplement 29

towns that the meteorological `82 study said would be most likely to be impacted. And also,

you would consider, in your health analysis, the projected demographic changes, from 2012

forward, of a one in three people in this area over 55 and tie that to the BEIR VII which indicates

that older and very young people are more susceptible to damage. (PNPS-A)

Comment: ...there is new and significant information supporting our contention that twenty

additional years of “normal” operations will be harmful to public health. Pilgrim releases

radiation as part of its standard operations. Radiation-linked diseases are documented in

communities around Pilgrim. This fact and projected demographic data indicate that this

population will be at an increased risk. The National Academy of Sciences (NAS) latest report

on low-dose radiation risk, Health Risks from Exposure to Low Levels of Ionizing Radiation:

BEIR VII Phase 2 (June, 2005) concluded that no amount of radiation is safe. The documented

radionuclide releases from Pilgrim in the past have long half-lives and bio-accumulate in the

environment. We submit that if the Applicant disputes a causal link between the radiation

released by Pilgrim and the cancers seen in its neighboring towns, the current systems in place

to monitor releases are inadequate and must be improved. We further submit that if the NRC

or State disputes elevated radiation-linked diseases rates or a causal connection that they have

not taken into account the unreliability of Pilgrim’s monitoring data and reports.

Mitigation ER must consider if Pilgrim is allowed to continue operations:

• Reduction of allowable radioactive emissions into our air and water so that the

biological impact is no greater than that allowed from the releases from a chemical

plant licensed today and allowable dose reduced to be in synch with current scientific

knowledge on the effects of low-dose radiation on health, National Academy of

Sciences’ Biological Effects of Ionizing Radiation, BEIR VII report.

• Verification of releases by combination radiation and weather monitors – computer

linked to state and local authorities – at all points where radiation is released from

Pilgrim and at appropriate off-site locations in the seven most impacted towns and on

Cape Cod. (PNPS-AC)

Comment: The National Academies Committee to Assess Health Risks from Exposure to Low

Levels of Ionizing Radiation, the National Research Council, published Health Risks from

Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2 in 2005. Drawing upon new

data in both epidemiologic and experimental research, they concluded that no amount of

radiation is safe. There is a linear no threshold response to radiation, and exposure to low

levels of radiation is approximately three-times more dangerous than previously thought. BEIR

VII: Health Risks from Exposure to Low Levels of Ionizing Radiation, Report in Brief, June 2005.

Therefore it is not surprising that radiation-linked disease rates are higher than expected in

communities exposed to Pilgrim’s past releases.
Appendix A

NUREG-1437, Supplement 29 A-22 July 2007

A summary of cancer deaths estimated at NRC’s permissible dose release is provided in the

BEIR VII Report. The report shows the number of cancer cases and deaths expected to result

in 100,000 persons (with an age distribution similar to that of the entire U.S. population)

exposed to 100mSv per year over a 70 year lifetime. On average, assuming a sex and age

distribution similar to that of the entire U.S. population, the BEIR VII lifetime risk model predicts

approximately one individual in 100 persons would be expected to develop cancer (solid cancer

or leukemia) and approximately one in 175 would be expected to die from cancer from a the

permissible dose of 100 mSv.

Lower doses would produce proportionately lower risks. For example one in 1000 would

develop cancer from an exposure to 10 mSv. This new report validates concerns raised by us

and helps explain the radiation-linked disease observed near Pilgrim NPS. When the standards

were set by the NRC for permissible release of off-site radiation, low levels of radiation were

considered harmless. However, the BEIR VII report now reveals that any exposure is

potentially dangerous. Therefore it is not surprising that radiation-linked disease rates are

higher than expected in communities exposed to Pilgrim’s past radiological releases.

This new information is particularly relevant to the issue of re-licensing Pilgrim because twenty

additional years of exposure will harm an already damaged population. Both BEIR VII and

previous nuclear worker studies show that the health effects of radiation are cumulative. 

Effects of Radiation and Chemical Exposures on Cancer Mortality Among Rocketdyne Workers:

A Review of Three Cohort Studies. Morgenstern, H and Ritz, B., Journal: Occupational

Medicine: State of the Art Reviews, Vol. 16, No. 2, April-June 2001, pages 219-238. And as

shown previously, there is a growing and aging population in the area immediately surrounding

the plant. This population has already been harmed by the effects of radiation from Pilgrim and

as a result is more susceptible to even permissible levels of off-site radiation. An additional

twenty years of operations would put a group that is already damaged at further risk. (PNPSAC)

Comment: In its Final Environmental Impact Statement, the 1972 owners of Pilgrim stated in

the Summary of Environmental Impacts and Effects, Chapter 5-c. that, “The effluents from the

facility, if operated as described by the Applicant and in accordance with the technical

specifications and rules and regulations of the Commission, will not endanger the public health

or the natural environs of the station.” Final Environmental Impact Statement, Pilgrim Nuclear

Power Station, Boston Edison Company, Docket 50-293, 5-c, p. iii, US Atomic Energy

Commission Division of Radiological and Environmental Protection, (May 1972). In its current

Application, Appendix E, Applicant states “Very low levels of radioactivity may be released in

plant effluents if they meet the limits specified in NRC’s regulations. These releases are closely

monitored and evaluated for compliance with the NRC restrictions in accordance with the PNPS

Offsite Dose Calculation Manual.” ER Appendix E.3.2.3.1. Essentially the same was stated

regarding solid and gaseous releases. Therefore the assumption is that there will be no danger
Appendix A

July 2007 A-23 NUREG-1437, Supplement 29

to public health from routine releases since they will be monitored and will not exceed federal

limits. However, despite this confidence written into the Application, we bring forward new and

significant information that demonstrates that there has already been documented radiation

linked disease in the communities near PNPS. In addition, a recent report was published by the

National Academy of Sciences that demonstrates that there is no safe dose of radiation for

humans. (PNPS-AC)

Comment: Epidemiological studies of cancer rates in the communities around Pilgrim show an

increase of radiation-linked disease that can be attributed to past operations of the plant. The

demographics of the population immediately surrounding the plant, including its age and

geographical distribution, make this population more susceptible to more radiation-linked

damage than was contemplated when the plant was licensed.

If Pilgrim is allowed to continue operations this should only be allowed under the following

conditions so that public health would be better protected.

• Reduction of allowable radioactive emissions into our air and water so that the

biological impact is no greater than that allowed from the releases from a chemical

plant licensed today and limits that are in synch with BEIR VII.

• Verification of releases by radiation and weather monitors computer linked to state

and local authorities at all points where radiation is released from Pilgrim and at

appropriate off-site locations - appropriate sites chosen by meteorological analyses.

(PNPS-AC)

Comment: Health Impact: Projected age distributions will affect the expected health impact to

the population from radiation exposure – both routine and above routine. This must be

analyzed – the licensee’s filing failed to do so.

By 2030, (1) in (3) people will be over the age of 55, compared to 1 in 5 now.

We know from new research that radiation affects the most vulnerable – the young and the old.

This makes intuitive sense – for example, the older we get, the more vulnerable we become

and this is borne out by research. (PNPS-AC)

Comment: The population directly abutting Pilgrim is increasing substantially and the

population is older and thus more susceptible to radiation damage. Changing demographics in

communities impacted by Pilgrim are such that the dose effect on the population will be far

greater than originally anticipated when the plant was licensed – a larger/denser population and

older population.
Appendix A

NUREG-1437, Supplement 29 A-24 July 2007

When Pilgrim was licensed and built in 1972, its location was in an area that was remote and

undeveloped. The population around the plant has changed drastically in the last 30 years, and

this aging plant is now located in the fastest growing region in Massachusetts. In Pilgrim’s

backyard, Pine Hills, the largest housing development in New England, is under construction. 

The build-out includes 2,877 homes on 3,060 acres, and Pine Hills, Inc. is actively trying to

acquire more land to build in this area. The distance from Pilgrim to Pine Hills is < 3 1⁄2 miles.

The current Pine Hills household size is 1.95 people per building. Based on these numbers,

there will soon be 5,850 people living just a few miles from this nuclear plant.

The region is expected to add 465,000 people by 2030 and this group will be aging with a

dramatic spike in the over 55 population. The largest population increases are expected in

urban centers such as Boston and Cambridge and in a half-dozen suburban towns, such as

Plymouth and Weymouth which have very large housing developments on the horizon. The

Boston Metropolitan Area Planning Council Report on Population and Employment Projections

2010 -2030, http://www.mapc.org/2006 projections.html. The methodology used by MAPC is

described in the report. (see Exhibit F-1). According to the report the area south of Boston is

expected to grow faster in population and jobs than any other section of Greater Boston

through the year 2030. Communities south of Boston will grow 13% and Plymouth is expected

to add the most, about 10,000 residents a population jump of over 20%. By 2030, 1 in 3 people

will be over the age of 55, compared to 1 in 5 now. This is relevant to any analysis of health

impacts, as studies have shown an increased sensitivity to low levels of ionizing radiation in

older populations. Greater Sensitivity to Ionizing Radiation At Older Age: follow-up of workers

at Oak Ridge National Laboratory through 1990. Richardson, D.B. and Wing, S. Int. J.

Epidemiol., 1999, 28:428-436; The Hanford Data: Issues of Age at Exposure and Dose.

Stewart, A.M., Kneale, G.W., PSR Quarterly Vol. 3, No. 3 (Sept. 1993) 3:101-111; and

Leukaemia near nuclear power plant in Massachusetts, Richard Clapp, Sidney Cobb, C. K.

Chan, Bailus Walker, 924 , Lancet, 1987. (PNPS-AC)

Comment: There is new information since Pilgrim began operations in 1972 that shows

increases in radiation-linked diseases in the communities around Pilgrim. The increases were

in part attributed to operating with defective fuel; operating without the off-gas treatment system

in the first years; poor management and practices culminating in the releases in June 1982 that

coincided with weather conditions that held the releases over the area. Southeastern

Massachusetts Health Study 1978-1986, Morris, Martha and Knorr, Robert, Commonwealth of

Massachusetts Executive office of Human Services, Department of Public Health, 1990 and

Meteorological Analysis of Radiation Releases For the Coastal Areas of The State of

Massachusetts For June 3rd to June 20th, 1982, William T. Land. (PNPS-AC)

Comment: The cancers found in the communities around the power station initially were

studied by Dr. Sidney Cobb and Dr. Richard Clapp and their results were published in a peer

reviewed journal in 1987. They included elevated rates of Myelogenous Leukemia – a type of
Appendix A

July 2007 A-25 NUREG-1437, Supplement 29

cancer most likely to be triggered by exposure to radiation. This led to a case control study

carried out by the Massachusetts Department of Public Health that showed a four fold increase

in adult Leukemia between 1978 and 1983. The report stated "a dose-response relationship

was observed in that the relative risk of leukemia increased as the potential for exposure to

plant emissions also increased.” (PNPS-AC)

Comment: The Southeastern Massachusetts Health Study was conducted, peer reviewed, and

made public during the Dukakis Administration. However, there was a complete about face in

November 1990 when Governor Weld took office that has continued through successive

Massachusetts Republican Administrations. December 1990, Governor Weld sent his

Executive Secretary to accompany Pilgrim’s Vice President, Ralph Bird, and Pilgrim’s Health

Physicist, Tom Sowden, to visit Massachusetts’ Interim Commissioner of Public Health, David

Mulligan. At that meeting Pilgrim presented their “wish list” and obviously they had the

Governor’s blessing. Pilgrim, the implicated industry, would be allowed to appoint a second

peer review panel to re-review the Southeastern Massachusetts Health Study; and, until the

industry’s peer review panel decided whether the study was credible all the study’s

recommendations would be put on hold. The second peer review panel could find nothing

wrong with the study’s methodology. The re-review panel stated clearly in their report, Review

of the Southeastern Massachusetts Health Study by Hoffman, Lyon, Masse, Pastides, Sandler,

Trichopoulos, submitted to the Commissioner of Public Health, October 1992 in the Executive

Summary that, “The [original SMHS] study team adhered to generally accepted epidemiologic

principles...” and “the findings of the SMHS cannot be readily dismissed on the basis of

methodology errors or proven biases...” But somehow they just couldn’t believe it - given

Pilgrim’s emissions. However for emissions data, the re-review committee relied on data

collected and provided by Pilgrim - not surprisingly it indicated that Pilgrim hardly emitted any

radiation – and one offsite monitor located in South Boston, well outside the EPZ and outside

the geographic area likely to pick up routine emissions.

The story gets worse. Massachusetts Department of Public Health allowed Pilgrim, the

implicated industry, to provide all the sound bites, press releases and public announcements

about the re-reviews’ findings and refused to let their employees, who conducted the original

study, speak to the press. No subsequent studies have been performed. MDPH has chosen to

protect the industry’s health over the public’s health. Once again, we see political science used

to re-write real science on behalf of industry. At the May 17, 2006 NRC Public Environmental

Scoping Meeting, an NRC official stated that they had visited MDPH and were told by MDPH’s

Suzanne Condon and the department that there were no negative impacts from PNPS’s

operations. Our message to you is that MDPH’s statements are politically-driven and have little

to no resemblance to fact.

Evidence of radiation-linked disease continued. In a statement before the Southeastern

Massachusetts Health Study Review Committee [June 26, 1992] Dr. Richard W. Clapp, the
Appendix A

NUREG-1437, Supplement 29 A-26 July 2007

founder and former director of the Massachusetts Cancer Registry and Professor of

Environmental Health at Boston University School of Public Health, presented a graphical

assessment of the pattern of leukemia and thyroid cancer in the towns closest to Pilgrim during

the period 1982-1989. Analysis of 1974-1989 Massachusetts Cancer Registry for Leukemia &

Thyroid Cancer, Dr. Richard Clapp, DSc, MPH (2006), personal communication.

The incidence of leukemia peaked in 1982 and subsequently declined until 1986. Then there

was a second, smaller peak in 1987 and 1988 while declined in 1989. The number of cases

exceeded the number expected in 1982-85 and 1987-88. The second graph depicts the pattern

of thyroid cancer in the same set of towns. It shows a peak in the years 1987-1988. These

patterns of cancer incidence are consistent with the predicted health effects of the radiation

released in the early 1980s.

The graph shows the predicted health effects. A statistically significant increase in childhood

leukemia was noted in communities near Pilgrim, too. Although Massachusetts Department of

Public Health recommended a state sponsored case controlled childhood leukemia study, it was

not done.

The Massachusetts Cancer Registry also shows, for the years 1998-2002, a continuing

increase of leukemia and thyroid cancer in the towns around PNPS. Specifically, there were 83

cases of leukemia reported to the Massachusetts Cancer Registry (MCR), where 72.9 would

have been expected based on statewide rates. This results in a Standardized Incidence Ratio

(SIR) of 114 (95% conf. int. = 91-143). In addition, there was excess thyroid cancer in these

same towns for the same time period. The thyroid cancer SIR was 122 (95% conf. int. = 96-

155). In other words, leukemia was 14% elevated over the statewide rate and thyroid cancer

was 22% elevated. Neither of these calculations were statistically significantly elevated by the

usual convention (P <.05), but there were more cases than expected nevertheless. This means

there is a continuing excess of these two radiation-related cancers in the population, as there

was in the 1980s. Analysis of 1998-2002 Massachusetts Cancer Registry for Leukemia &

Thyroid Cancer, Dr. Richard Clapp, 2006, personal communication.

Prostate cancer and multiple myeloma, both radiation-linked diseases, are also elevated and

statistically significant for the years 1998-2002 in the seven towns most likely to be impacted

near Pilgrim (Carver, Duxbury, Kingston, Marshfield, Pembroke, Plymouth, and Plympton). 

Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2 (2006).

Occupational Radiation Studies, Chapter 8, National Academies Press, 2006. Specifically, data

from the Massachusetts Cancer Registry indicates 613 cases of prostate cancer vs. 513.5

expected, SIR=119 (95% C.I.=110-129); multiple myeloma: 47 cases vs. 31.7 expected,

SIR=148 (95% C.I.=108-198). Analysis of 1998-2002 Massachusetts Cancer Registry for

Leukemia & Thyroid Cancer, Dr. Richard Clapp, 2006, personal communication. (PNPS-AC)
Appendix A

July 2007 A-27 NUREG-1437, Supplement 29

Comment: The population of the Town is approximately 14,000 families, with tens of

thousands of children who would be highly vulnerable to a radioactive leak or other event which

could expose them to radioactive material above federally acceptable levels. In addition, there

is a sizable retirement community, many members of which also would be vulnerable to

overexposure to radioactive material. (PNPS-AE)

Comment: Given that the population in and around the Town has increased dramatically in the

last 30 years, the radiological dose effect on the population will be far more significant than

originally anticipated. When the plant was built in the 1970s, Plymouth was a quiet rural

community with a small population that grew seasonally with tourism. Today, Plymouth's yearround population has more than tripled and it has become a year-round "city." Pilgrim now is

located in the fastest growing region of Massachusetts, which raises considerable implications

for postulated radiological dose effects. (PNPS-AE)

Comment: We have heard various studies have been performed and I would like to make sure

that the scope does take into account an examination of various studies of cancer. I know I

have anecdotally seen, in Duxbury, people with breast cancer, with various types of cancers,

that I'm not sure, and I don't know the answer, and I'm not accusing anyone of anything, but I

would like to make sure that if there is any evidence that does link health effects from radiation

to these various cancers, that be studied and, if there is obviously a causal effect, that, to me,

would be grounds for not relicensing the plant. (PNPS-L)

Comment: We urge the NRC to consider, in depth, all the significant environmental impacts

which we believe are grounds for denying the relicense of the plant. The National Academy of

Sciences BEIR VII report, biological effects of ionizing radiation, June, 2005, stated that there is

no safe dose of radiation. Pilgrim emits radiation daily and these radiation releases have been

linked to increased rates of leukemia and thyroid cancers in the towns around Pilgrim. 

(PNPS-M)

Comment: Another piece of new information is the BEIR VII report which found exposure to

low level radiation at least three times more damaging than heretofore thought. Also, we have,

as new information, the demographic changes projected from 2012 to 2032 of a one out of

three being over 55 and older people are susceptible to radiation damage than younger. Also,

the BEIR VII report pointed out the synergistic effect of radiation with other toxins, each

magnifying the other's mischief, if you will, and no one can doubt the fact that, between 2012

and 2032, there will be more, not less, pollution. (PNPS-N)

Comment: Health is another issue that should be considered on a site specific basis, again

because of new and significant information. There have been studies of health damage in this

community, there were studies done by Dr. Sidney Cobb and Dr. Richard Clapp in the `70s,

there was a case controlled leukemia study showing a fourfold increase the closer you lived or
Appendix A

NUREG-1437, Supplement 29 A-28 July 2007

worked to Pilgrim. Then there has been a statistical or simply significant increase in thyroid

cancer and leukemia in all seven impacted communities because both Pembroke and Plympton

are effected by the sea breeze effect and get these emissions. (PNPS-N)

Comment: We do need to find out whether there is any statistically significant amount of

radiation in the communities surrounding this plant and we need to find out whether there is any

relationship between that and incidents of cancer that are statistically significant in being higher

than should normally be expected. I have a certain kind of cancer and so do the four people

that live next to me on my street, we need to find out why. I'm not casting dispersions on the

plant or suggesting that it's cause, that it's the cause of this, but we do need to find out what the

cause is. (PNPS-P)

Comment: I heard a lot about thyroid cancer, ...and I would be interested to see if, on those

studies, they also did genetic studies ...I wonder how much of it is genetic and how much of it is

environmental too, so I would like to see, on those studies, if they also followed that up with

genetics too. (PNPS-X)

Comment: I'm interested in what kind of epidemiological studies have been conducted on

cancer rates related specifically to Pilgrim, as well as other areas with nuclear plants, and I'm

hoping somebody can help distribute that information. (PNPS-Y)

Response: The comments are related to human health issues. Human health issues were

evaluated in the GEIS and were determined to be Category 1 issues. The GEIS evaluated

radiation exposures to the public for all plants including PNPS, and concluded that the impact

was small. During the plant-specific environmental review of PNPS, the NRC will determine

whether there is any new and significant information bearing on the previous analysis in the

GEIS. The information provided by the comments will be reviewed as part of that search.

Human health effects from radiation exposure due to operation of the plant during the renewal

period will be addressed in Chapter 2 and 4 of the SEIS. In addition, evaluation of new studies

and analyses of the health effects of radiation exposure is an ongoing effort at the NRC.

In spring 2006, the National Research Council of the National Academies published, "Health

Risks from Exposure to Low Levels of Ionizing Radiation, BEIR VII Phase 2." A prepublication

version of the report was made public in June 2005. The major conclusion of the report is that

current scientific evidence is consistent with the hypothesis that there is a linear, no threshold

dose response relationship between exposure to ionizing radiation and the development of

cancer in humans. This conclusion is consistent with the system of radiological protection that

the NRC uses to develop its regulations. Therefore, the NRC’s regulations continue to be

adequately protective of public health and safety and the environment. None of the findings in

the BEIR VII report warrant changes to the NRC regulations. The BEIR VII report does not say

there is no safe level of exposure to radiation; it does not address "safe versus not safe." It
Appendix A

July 2007 A-29 NUREG-1437, Supplement 29

does continue to support the conclusion that there is some amount of cancer risk associated

with any amount of radiation exposure and that the risk increases with exposure and exposure

rate. It does conclude that the risk of cancer induction at the dose levels in the NRC’s and

EPA’s radiation standards is very small. Similar conclusions have been made in all of the

associated BEIR reports since 1972 (BEIR I, III, and V); the BEIR VII report does not constitute

new and significant information.

A.1.5 Comments Concerning Uranium Fuel Cycle and Waste Management

Comment: The other item, of course, is waste, that supposedly it's off the table but I think,

quite clearly, you cannot have a severe accident mitigation analysis without including what

could happen by accident, and accidents can happen, to the spent fuel pool. That seems like a

logical place to pull the issue of spent waste, high level waste, into the SAMA, and I hope also

that you would consider and analyze buried waste that was allowed to be buried on site until

1981. I assume that when it was allowed to be buried, there was an assumption and analyses

of the time that it would remain stable, until the license ended in 2012 and decommissioning

would begin. What will another 20 years do to it? Will it remain stable for another 20 years? Do

you even know what is buried there, what the packaging is, etcetera? There should be a

complete inventory of what's there, curies, volume, packaging, a map where it is and whether

the six feet of soil is still over it, and whether you would recommend, for mitigation, monitoring

wells so we can see whether it is going into the bay, which is the only other place it can go

because of the topography. (PNPS-A)

Comment: According to Entergy, the facility will run out of space in its spent fuel pool by 2012

and there are no prospects for off-site storage in the foreseeable future. The ER states simply

and cryptically with respect to spent fuel storage during the 20-year renewal period: "[t]he spent

fuel assemblies are then stored for a period of time in the spent fuel pool in the reactor building

and may later be transferred to dry storage, if needed, at an onsite interim spent fuel storage

installation provided necessary regulatory approvals are obtained. Thus, a significant amount

of "hot" spent fuel will remain in the spent fuel pool at Pilgrim, which represents a long-term risk

to the Town that is not adequately addressed in the license renewal application. (PNPS-AE)

Comment: On-site storage of spent fuel assembles which, already densely [packed in the

cooling pool, will be increased by fifty percent during the renewal period. The spent fuel will

remain on-site longer than was anticipated and is more vulnerable than previously known to

accidental fires and malicious attacks. The Pilgrim plant operator recently has stated that "[the

plant] will run out of space in 2012. This was never intended to be a repository for any length of

time." Accordingly, the ER should address the likely impacts of on-site storage in the years to

come. (PNPS-AE)
Appendix A

NUREG-1437, Supplement 29 A-30 July 2007

Comment: Even if present plans for establishing a federal waste repository at Yucca

Mountain move forward on schedule, that facility would reach maximum capacity long before a

relicensed Pilgrim stops generating its waste. Plant owners and the NRC need to have a clear

and safe plan for storage of radioactive waste before the extension is granted. (PNPS-M)

Comment: Over 1.2 million pounds of high level radioactive nuclear waste is stored on site at

the Pilgrim Plant, this waste poses a risk to the health of humans and ecosystems for centuries

to come, but there are currently no clear disposal options outside of the state. (PNPS-M)

Comment: ...on spent fuel, that this should be considered in this relicensing process because

there is significant new information which is the standard, the new information that is significant

is that excluding spent fuel from the review was based on a feeling there would be off site

options. However, we know there are no off site options in any period of time that we will be

talking about in the license extension. (PNPS-N)

Comment: The Waste Confidence Act, which exists and was the underpinning of why spent

fuel is not looked at, does not hold water, so the new information is Yucca is not going to

happen any time soon, reprocessing is not going to happen any time soon, nor is the Gashuti

Indian Tribe place going to happen any time soon, so we'll be here. Therefore, we must be told

beforehand what the options will be for safer storage. The Town of Duxbury, on two occasions,

has stated that we want safer interim storage, meaning low density pool storage, and secured,

hardened dry cast storage until there is an off site option. (PNPS-N)

Comment: The radioactive waste problem was another issue which the nuclear energy

industry would have to solve in the future. When the plant was originally commissioned, we

were promised that this was a problem that would be resolved. This problem has not been

solved, the radioactive waste produced by Pilgrim sits on the site of the plant and will continue

to increase in quantity for another 20 years if the plant is relicensed. Maybe it could be shipped

to Yucca Mountain in Nevada where it would have to remain safely contained for over a million

years. Take a trip to Las Vegas and ask the officials there if they have faith in the nuclear

industry. (PNPS-Z)

Response: On-site storage of spent nuclear fuel is a Category 1 issue. The safety and

environmental effects of long-term storage of spent fuel on-site have been evaluated by the

NRC and, as set forth in the Waste Confidence Rule (10 CFR 51.23), the NRC generically

determined that such storage could be accomplished without significant environmental impact. 

In the Waste Confidence Rule, the Commission determined that spent fuel can be stored onsite for at least 30 years beyond the plants life, including license renewal. At or before the end

of that period, the fuel would be moved to a permanent repository. The GEIS, NUREG-1437 is

based upon the assumption that storage of the spent fuel on-site is not permanent. The plant-
Appendix A

July 2007 A-31 NUREG-1437, Supplement 29

specific supplement to the GEIS that will be prepared regarding license renewal for PNPS will

be based on the same assumption.

Comment: In 2008, North Carolina has stated they will not be taking waste from

Massachusetts. We are not a member of any compact state. There was a determination that

we were not going to be a low level radioactive waste site, so what would the future be, having

both high level waste and low level waste, which isn't necessarily low in toxicity or longevity, onsite? What should we be doing for that? (PNPS-A)

Comment: Waste containers and forms will not last as long as some waste remains

hazardous. Therefore, we want to know what Entergy’s plans are for storing LLRW; monitoring

the releases; and what are the "acceptable" public radiation exposures and health risks. 

(PNPS-AC)

Comment: LLRW should be looked at on a site specific basis because of new and significant

information since Pilgrim's initial license, 1972.

• Pilgrim had offsite options in1972 and reasonably expected them to continue. Not so,

now. Barnwell S.C. announced that it will close to Massachusetts generators June 20,

2008.

• Massachusetts is not a member of any compact; in order to join Massachusetts would

have to agree to be a host community; Massachusetts indicated clearly in the mid

1990’s that it would not be a host community.

• Texas may open, no guarantees, and if it does open there is no assurance that nonTexas Compact members will be able to send their waste there and if allowed whether

fees would be prohibitive. The Massachusetts Department of Public Health Radiation

Control stated, “As a result of the above, on July 1, 2008 Massachusetts generators will

have no treatment option other than decay onsite unless Texas opens a new LLRW site

for Class B and C wastes. Texas has not decided yet whether non Texas compact

members may use their site.”

• Terrorism or acts of malice were not considered a threat in 1972. Not so, post 9/11 -

nuclear facilities/materials are known to be attractive targets.

• Pilgrim is located on Cape Cod Bay and the property slopes towards the Bay so that

any leaking contaminants from waste storage facilities will flow towards and eventually

into the Bay. There are no monitoring wells lining the shoreline.
Appendix A

NUREG-1437, Supplement 29 A-32 July 2007

• The undisputed recognition of global warming is new and brings with it increased

severity of coastal storms, erosion, and increased sea levels. Hence this must be

factored into on-site waste storage options.

• PNPS is located on the coast -- a salt corrosive environment on concrete and waste

packaging must be analyzed.

Storage of LLRW is important for our community’s health and safety because there is nothing

low level about the waste. Waste is characterized “high” or “low” depending on where it comes

from, how it is generated, not according to its’ toxicity and longevity. Our community’s health

has been compromised by radiation exposure – discussed above.

We deserve to know what the LLRW storage plans are before the application is decided; so

that the re-licensing decision does not prejudge any LLRW storage decision. (PNPS-AC)

Comment: The Licensee’s filing discusses Low Level Radioactive Waste in Appendix E,

Applicant’s Environmental Report Operating Renewal Stage Pilgrim Nuclear Power Station,

Chapter, 3.23. The discussion covers a brief overview of what they do with waste now. The

application makes one mention of low level radioactive waste which does not bear on the

subject- Applicant’s Environmental Report 6.4.2 “land required to dispose of spent nuclear fuel

and low-level radioactive wastes generated as a result of plant operations.” What is not

discussed, but needs to be analyzed, is what Entergy plans to do with LLRW from 2012-2032. 

(PNPS-AC)

Comment: The environmental impacts of so-called “low level” radioactive waste storage,

2012-2032, should be analyzed in a site specific SEIS. Because: there is no guarantee that

offsite options will exist after June, 2008; Pilgrim’s coastal location is not suitable for waste

storage - a salt corrosive environment; increased intensity and frequency of storms predicted

for the future; topography is such that contaminants that have leaked will migrate/flow towards

and perhaps into Cape Cod Bay; the threat of terrorism. All of these factors could work

together to increase the probability that stored nuclear wastes could contaminate the

environment and endanger public health and safety. (PNPS-AC)

Response: The comments are related to the environmental impacts associated with the

uranium fuel cycle and Low Level Radioactive Waste Management (LLRW), which were

evaluated in the GEIS and determined to be Category 1 issues. The GEIS evaluated impacts

associated with the uranium fuel cycle and LLRW management for all plants including PNPS,

and determined that the impact was small. During the plant-specific environmental review of

PNPS, the NRC will determine whether or not there is any new and significant information

bearing on the previous analysis in the GEIS.
Appendix A

July 2007 A-33 NUREG-1437, Supplement 29

Comment: The Aging Management Program does not include an analysis of the potential

contamination from buried waste onsite. We understand that until 1981 so-called low-level

radioactive waste was allowed to be buried at reactor sites. We asked the NRC if Pilgrim

buried waste on-site up until that date and were informed by Cliff Anderson that they did not.

However, there have been persistent rumors that waste indeed had been buried onsite and we

request that this be investigated.

Cliff Anderson, Branch Chief, USNRC, Region I, May 31, 2006 sent to us the following email. 

The licensee for the Pilgrim station did not conduct any burials of radioactive material prior to

1981 in accordance with the former NRC regulation 10 CFR 20.304, which governed such

burials at that time. Notwithstanding, the Pilgrim station did conduct an "alternate disposal"

under 10 CFR 20.302 (now cited as 10 CFR 20.2002). That disposal option was requested per

10 CFR 20.302 in a letter, dated January 15, 1993, from Boston Edison Company, and

consisted of on-site disposal (i.e., burial) of soil that contained residual contamination from

several events. (The events are described in licensee event reports (LERs) 77-29, 82-19 and

88-26.) The licensed material covered by the request included 79,000 cubic feet of excavated

construction soil that contained a total radionuclide inventory of 0.636 millicuries of cobalt-60

and Cesium-137. The NRC staff approved the request by letter dated May 4, 1993, with the

provision that the NRC Safety Evaluation (SE), enclosed with the May 4, 1993 letter, be

permanently incorporated in the Offsite Dose Calculation Manual.

The NRC SE concluded the maximum dose from the disposal area would be less than 0.1

millirem/year during the year of disposal; and that doses during subsequent years through the

time of site decommissioning would be less than 0.01 mrem/year. The total dose was well

within the staff's guideline of 1 millirem per year, and is a small fraction of the 300 millirem

received annually by a member of the public from natural background sources of radioactivity.

The location of the LLRW and the burial method are described in the NRC SE enclosed with

the May 4, 1993 letter. The NRC found the disposal location acceptable because of its distance

from wetlands and Cape Cod Bay, and because any surface runoff would be entirely within the

Pilgrim owner controlled area. We are forwarding the NRC SE to you by regular mail (USPS).

The results of NRC inspection of this area were described in NRC Integrated Inspection Report

1999-01, which also will be forwarded by USPS mail.

The onsite spill and burial information is maintained in the licensee's 10 CFR50.75(g) file in

accordance with regulatory requirements. Such residual contamination is acceptable per the

rule and, as noted above, the public dose consequences are negligible in comparison with the

dose from natural background radiation.

Pilgrim Watch has not received the NRC SE or the NRC Integrated Inspection Report 1999-01. 

These documents should be reviewed by the ER and made public. Regarding the material
Appendix A

NUREG-1437, Supplement 29 A-34 July 2007

buried referred to by Cliff Anderson we assume that when permission was granted to bury the

waste that it was assumed that decommissioning would occur in 2012 and the contamination

would be cleaned up; so-called “low-level” waste was indeed low level in its health impact; and

the Radiological Environmental Monitoring Program would detect offsite contamination at levels

of concern. However these assumptions are no longer tenable if the application is approved.

Cliff Anderson ignored the burial onsite of contaminated materials from the 1987-1990 repairs

for which we believe there is no official record; these burials are well known. Those burials

must be responsibly dealt with - monitored and remediated, not continue to be ignored for an

additional 30 years.

Decommissioning, if the application is approved, will not begin until 2032 or later. We assume

that the licensee and NRC determined that burying waste onsite would not harm the

environment based on a definite time frame – a 40 year license. What would happen after 60

years was not considered nor analyzed. It needs to be to provide reasonable assurance that

public health and safety will not be negatively impacted. For example erosion of the top soil will

be affected by the passage of time, increasing frequency and severity of coastal storms; and

the topography of the site that slants down into Cape Cod Bay. Migration of contaminants

underground is currently not monitored. Migration of contaminants from so-called low level

waste has happened at other sites - for example, at Barnwell SC, TVA, Hanford and Starmet.

Hence there is no reason to believe that the same could not happen here. (PNPS-AC)

Response: The comment is related to the environmental impacts associated with Low Level

Radioactive Waste Management (LLRW), which were evaluated in the GEIS and determined to

be Category 1 issues. As part of the environmental review of PNPS, the NRC will determine

whether or not there is any new and significant information bearing on the previous analysis in

the GEIS. This determination will include a review and evaluation of this comment submitted

during the scoping period.

A.1.6 Comments Concerning Postulated Accidents

Comment: We know assessments, number one, are low and, more importantly, we know that

a piece of property, like a business, the businesses on Court Street, are not only the value of

the bricks and the roof but the value of a business. The value of this area involves its tourist

appeal, historical value, etcetera, etcetera, and none of those inputs have been put into the

model in the SAMA. (PNPS-A)

Comment: For the SAMA, I hope that you will look at mitigation means to diminish the effect

on the public. I think somehow, in reading it, and I don't mean to, you know, sound flip, but it

seems to be more mitigating the damage to the licensee's pocketbook. That you would look,

for example, in the economic damage, that they only seem to consider, they have put, they
Appendix A

July 2007 A-35 NUREG-1437, Supplement 29

have two buckets, farm wells and non-farm, but they don't differentiate for business, for

example, and what you see there is a determination of valuation based on assessed value, in a

county, divided by the population. (PNPS-A)

Comment: The Town also would lose travel expenditures associated with travelers on their

way to Cape Cod, Nantucket, and Martha's Vineyard; travel through Plymouth County is

necessary to reach those destinations. Travel to those areas clearly would be restricted in the

event of a severe accident at Pilgrim (taking into account that winds often blow toward Cape

Cod at the islands), reducing travel expenditures not only in the Town but also in surrounding

areas. The loss of economic infrastructure and tourism should be considered in the SAMA

analysis to ensure that "realistic" mitigation alternatives are explored, taking such factors into

account. (PNPS-AE)

Comment: The economic model used in the SAMA analysis does not take into account the

loss of economic activity in the Town as an economic cost of a moderate or severe accident at

Pilgrim. The tourism sector is critically important to the economic vitality of the Town and

Plymouth County. A multitude of historical sited (e.g., Plymouth Rock, the Mayflower, Plymouth

Plantation) are located in close proximity to Pilgrim and attract thousands of visitors to the area. 

Assuming appropriate clean-up and decontamination of these sites, it is unlikely that tourism

would every fully recover after a severe accident, which would be devastating for the Town's

economy. (PNPS-AE)

Response: The comments are related to the impacts of postulated accidents, including design

basis and severe accidents. The environmental impacts of design basis accidents is located in

Chapter 5 of the GEIS, which contains a detailed discussion of the possible environmental

effects of postulated accidents, including socioeconomic impacts. The Commission concluded

that consideration of design basis and severe accidents are Category 1 issues. However,

alternatives to mitigate severe accidents must be considered for all plants that have not

considered such alternatives. The applicant provided a severe accident mitigation alternatives

(SAMA) analysis as part of the license renewal application for PNPS. The NRC staff’s review of

the SAMA analysis will be discussed in Chapter 5 and Appendix G of the plant-specific SEIS for

PNPS.

Comment: Adding a filter to the direct Torus vent system, they come up with that it would cost

$3 million and it would only reduce the amount of radiation released by half but, somehow, it's

not worthwhile. And so I think that that really speaks to the community and I hope it speaks to

you that the emphasis does not seem to be on mitigating effect public health, safety and

property, but rather to protect their own wallets. (PNPS-A)

Comment: The Direct Torus Vent System (DTVS) was installed because it was recognized

that there was something like a 90% probability of that containment failing. In order to protect
Appendix A

NUREG-1437, Supplement 29 A-36 July 2007

the Mark I containment from a total rupture it was determined necessary to vent any high

pressure buildup. The DTVS does not have a filter; therefore unfiltered material will be vented

into the neighborhoods. The DTVS provides reason to add additional monitoring to better

assess what was released after its use. (PNPS-AC)

Comment: The faulty SAMA analysis used by Entergy in the Environmental Report caused it

to wrongly dismiss mitigation alternatives such as adding a filter to the Direct Torus Vent. The

purpose of a SAMA review is to ensure that any plant changes that have a potential for

significantly improving severe accident safety performance are identified and addressed. Duke

Energy Corp., supra at 5. For its SAMA analysis, the Pilgrim Environmental Report explains

that, “A cost benefit analysis was performed on each of the remaining SAMA candidates. If the

implementation cost of a SAMA candidate was determined to be greater than the potential

benefit (i.e. there was a negative net value) the SAMA candidate was considered not to be cost

beneficial and was not retained as a potential enhancement. . . “The benefit of implementing a

SAMA candidate was estimated in terms of averted consequences.” One example of how a

poorly performed SAMA analysis can lead to erroneous conclusions is the ER’s look at the

costs and benefits of installing a Direct Torus Vent filter at Pilgrim.

The Direct Torus Vent System (DTVS) is a method to relieve the high pressure which is

generated during a severe accident. In 1986, Harold Denton, then the NRC's top safety official,

told an industry trade group that the "Mark I containment, especially being smaller with lower

design pressure, in spite of the suppression pool, if you look at the WASH 1400 safety study,

you'll find something like a 90% probability of that containment failing." Hazards of Boiling

Water Reactors in the United States, Paul Gunter, Nuclear Information Resource Service,

Washington, D.C. (March 1996). In order to protect the Mark I containment from a total rupture

it was determined necessary to vent a high pressure buildup. As a result, an industry

workgroup designed and installed the "Direct Torus Vent System" at all Mark I reactors,

including Pilgrim. Operated from the control room, the vent is a reinforced pipe installed in the

torus and designed to release radioactive high pressure steam generated in a severe accident

by allowing the unfiltered release directly to the atmosphere through the 300 foot vent stack.

Use of the vent discharges steam and radioactive material directly to the atmosphere bypassing

the standby gas treatment system (SBGTS) filters normally used to process releases via the

containment ventilation pathway. There is no radiation monitor on the pipe and valves that

comprise the DTV line. William J. Raymond, Senior Resident Inspector, Pilgrim Nuclear Power

Station, USNRC, Region I, Branch 5, email correspondence, May 11, 2006.

In response to a question posed by the Town of Plymouth at a public meeting on June 21, 1990

about the decontamination factors for the torus pool of various isotopes, the NRC

spokesperson responded that, “Except for the noble gases (consisting of the isotopes of Xenon

and Krypton), which are not retained in the pool to any significant degree, the suppression pool

is highly effective in scrubbing out and retaining particulate and volatile fission products.
Appendix A

July 2007 A-37 NUREG-1437, Supplement 29

Calculations as well as tests indicate that the suppression pool would be expected to have a

realistic decontamination factor (DF) for particulate and volatile fission products of about 100,

depending upon the accident sequence and the temperature of the water. This means that

about 1% of the particulate and volatile radioactivity entering the pool would be released to the

atmosphere, and about 99% would be retained within the pool.” Although the NRC spokesman

appeared to dismiss this as a trivial release, Dr. Frank von Hippel analyzed the applicant’s

response and stated that there is an internal contradiction in what we are being told. “The NRC

believes that the release from a severe core-melt accident would be reduced [by the

suppression pool] by a factor of one hundred. This is considerably more optimistic than

estimated in the NRC's first study on the subject. WASH-1400, The Reactor Safety Study,

WASH-1400 (1975). Also known as The Rasmussen Report. Also, the contention is that the

reduction by a filtration system would have zero benefit. Here the contenders seem to be

assuming that a factor of one hundred equals 100%. That is false. Even a release of on the

order of 1 percent of the core's radioactive iodine and cesium would be a very severe event.”

Frank Von Hippel, Program of Science and Global Security, Princeton University, e-mail

correspondence, March, 19, 2006.

In its Environmental Report, Entergy analyzes the benefits of installing a filter to the torus vent

in the course of reviewing possible severe accident mitigation alternatives. The Pilgrim ER

states, “Filtered Vent: This analysis case was used to evaluate the change in plant risk from

installing a filtered containment vent to provide fission product scrubbing. A bounding analysis

was performed by reducing the successful torus venting accident progression source terms by

a factor of 2 to reflect the additional filtered capability. Reducing the releases from the vent

path resulted in no benefit. This analysis case was used to model the benefit of phase II

SAMAs 2 and 19.” (E.2-5). The Report then states, “Basis for Conclusion: Successful torus

venting accident progressions source terms are reduced by a factor of 2 to reflect the additional

filtered capability. The cost of implementing SAMA at Peach Bottom was estimated to be $3

million. Therefore this SAMA is not cost effective for [Pilgrim].” (E.2-24). (emphasis added) In

other words, as they show in Table E.2-1, Entergy has determined that in return for a cost of

$3,000,000.00, there will be no (0.00%) benefit to public health and safety.

It is not clear to Petitioners how it is possible to find zero (0.00%) benefit from installing a filter

that would reduce by a factor of two the radioactive venting to the public in the case of a severe

accident. Unfiltered venting has been judged unsafe by all regulatory agencies outside the

United States. David C. Dixon, Pilgrim Direct Torus Vent System, Presentation to

Massachusetts Joint Committee on Energy (February 27, 1990). In its analysis of several risk

contributors to Core Damage Frequency in Chapter E.1, the disposition of those events in Table

E.1-3 frequently included “venting via DTV path to reduce containment pressure.” In other

words, a filter in the torus vent could reduce the impact in many possible severe accidents. The

only conclusion to draw from the outcome of the DTV filter SAMA analysis is that, as discussed

above, Entergy has used the MACCS2 code to downplay the health and economic costs of
Appendix A

NUREG-1437, Supplement 29 A-38 July 2007

severe accidents and used the Probabilistic Safety Analysis (PSA) model to make the benefits

of mitigation appear to be zero.

We respectfully request the ER to include a review of Entergy’s analysis. In addition we

request the studies that NRC is currently depending to support NRC’s assertion that the release

from a severe core melt accident would be reduced by a factor of one hundred. This is

considerably more optimistic than estimated in NRC’s first study on the subject (WASH-1400,

1975). Last, if the NRC agrees with Entergy’s analysis that a filter’s benefit is not worth the cost

to present to the public both NRC’s and Entergy’s complete calculations and supporting studies.

(PNPS-AC)

Comment: My comments tonight are on the direct Torus vent system that Pilgrim, as a Mark

One boiling water reactor, was built with a faulty containment system and, in order to protect

that containment from total rupture, it was determined it was necessary to vent any high

pressure build up.

So the result was the direct Torus vent system was installed at Pilgrim, as well as all Mark One

reactors, this system is an extension of the containment ventilation system installed as a plant

upgrade in the 1980s, but it bypasses the standby gas treatment system filters normally used to

process releases via the containment ventilation pathway. Operated from the control room, the

vent is a reinforced pipe installed in the Torus and designed to release radioactive, high

pressure steam generated in a severe accident by allowing the unfiltered release directly to the

atmosphere through a 300 foot vent stack. There is no radiation monitor on the pipe and valves

that compromise the direct Torus vent line. So venting can result in a significant radioactive

release, even a release on the order of one percent of the core's radioactive iodine and cesium

would be a very severe event. Reactor operators now have the option, by direct action, to

expose the public and the environment to unknown amounts of harmful radiation in order to

save containment. The purpose of the containment is to provide a barrier between the lethal

radiation inside the reactor and the public.

As a result of the GE design deficiency, the original idea for a passive containment system has

been dangerously compromised and given over to human control with all its associated risks of

error and technical failure. We want indirect venting, that is allowing the steamer air to escape

only after it's passed through filters. The wet well pool will not scrub out or eliminate highly

radioactive fission products. Unfiltered venting has been judged unsafe by all regulatory

agencies outside the United States, the only advantage of direct venting is saving money for the

industry at the expense of the population. (PNPS-Q)

Comment: The EPA has an acceptable standard for exposure but, in the real world, there is

no safe level of exposure to radiation. Under the severe accident mitigation analysis, Pilgrim's

application stated that a filter would reduce by half the amount of radiation that would be
Appendix A

July 2007 A-39 NUREG-1437, Supplement 29

released in an accident. I think half is a major benefit for public health and safety. The

consequences should be calculated and compared with the cost of the filtration system and

mitigation should be focused on the protection of public health, safety and the regional

economy, not a cost benefit for a multi billion dollar industry trying to save dollars. (PNPS-Q)

Comment: The Pilgrim site is located on the western shore of Cape Cod Bay in the Town of

Plymouth, Plymouth County, Massachusetts (the "Town"). As such, the Town is in direct

proximity to any nuclear incidents that may occur. With a current estimated population of

approximately 59,000, an incident at Pilgrim that emits radioactive material could have

devastating impacts on the health of the Town residents. In addition, the Town economy is

heavily reliant on tourism. Any nuclear incident would deal a severe blow to tourism and the

related economy for the years to come and have a potentially ruinous effect on the local

economy. Thus, the Town urges the Commission to fully review all aspects of the Pilgrim plant

to assure that the citizens of Plymouth and surrounding areas are fully protected from negative

or dangerous environmental impacts associated with the plant's relicensing. (PNPS-AE)

Response: The comments are related to the impacts of design basis accidents and severe

accidents. The impacts of design basis accidents and severe accidents were evaluated in the

GEIS and determined to be small for all plants; therefore, they are Category 1 issues.

However, alternatives to mitigate severe accidents must be considered for all plants that have

not considered such alternatives. During the plant-specific environmental review of PNPS, the

NRC will determine whether there is any new and significant information bearing on the

previous analysis in the GEIS. Chapter 5.1.2 of the plant-specific SEIS for PNPS will address

severe accidents. The applicant provided a severe accident mitigation alternatives (SAMA)

analysis as part of the license renewal application for PNPS. The NRC staff’s review of the

SAMA analysis will be discussed in Chapter 5 and Appendix G of the plant-specific SEIS for

PNPS.

Comment: The Environmental Report included in Entergy's license renewal application sets

forth a flawed SAMA analysis that misstates the consequences of a severe accident at Pilgrim.

Specifically, the SAMA analysis uses inaccurate input data that underestimated the economic

consequences of severe accidents at the plant. (PNPS-AE)

Response: The comment is related to the severe accident mitigation alternatives analysis.

This analysis will be discussed in Chapter 5 and Appendix G of the SEIS.

Comment: ...the National Academy of Sciences' study on the vulnerability of spent fuel storage

and they stated, unequivocally, that reactors designed like Pilgrim, Mark One BWRs, that have

the pool high up in the attic, if you will, of the reactor building, are the most vulnerable to loss of

water, whether by accident or attack, and there would be a consequence, fire, in a dense pool
Appendix A

NUREG-1437, Supplement 29 A-40 July 2007

that could not be put out and could contaminate 500 miles. Therefore, for at least these two

pieces of new and significant information, it should be considered. (PNPS-AC)

Comment: The SAMA analysis fails to address the environmental impacts of the on-site

storage of spent fuel assemblies which will be significantly increased during the renewal period;

it does not contemplate a severe accident in the spent fuel pool, but should. (PNPS-AE)

Comment: The ER should address the risk of an accidental spent fuel fire at the plant. The

risk of fire is increased because the spent fuel is densely packed in "high-density" storage

racks. In the event that water in the fuel pool were lost (due to an intentional attack on the

plant, for example), cooling of the fuel assemblies would be inhibited and the assemblies could

ignite rapidly and spread within the pool, leading to a significant atmospheric release of

radioactive isotopes with great threat to public health and the environment. (PNPS-AE)

Comment: The Attorney General seeks consideration in the Supplemental GEIS of the

environmental impacts of a severe accident in the Pilgrim fuel pool, including accidents caused

by equipment failures, natural disasters, and intentional malicious acts. The Attorney General

also seeks consideration of a reasonable array of alternatives for avoiding or mitigating the

impacts of a severe pool fire, including combined low-density pool storage and dry storage of

spent fuel. (PNPS-AH)

Comment: The Environmental Report is inadequate because it fails to address the

environmental impacts of the on-site storage of spent fuel assemblies which, already densely

packed in the cooling pool, will be increased by fifty percent during the renewal period. A

severe accident in the spent fuel pool should have been considered in Applicant’s SAMA review

just as accidents involving other aspects of the uranium fuel cycle were. Applicant has included

other accidents involving the Uranium Fuel Cycle in its SAMA analysis demonstrating it agrees

that these are within the Scope of these proceedings. In addition, new information shows spent

fuel will remain on-site longer than was anticipated and is more vulnerable than previously

known to accidental fires and acts of malice and insanity. The ER should address Severe

Accident Mitigation Alternatives that would substantially reduce the risks and the consequences

associated with on-site spent fuel storage.

Mitigation strategies include: requiring low density pool storage and secured (hardened) dry

cask storage. These measures are requested by the Massachusetts Attorney General in his

petition to intervene and by the Town of Duxbury at Annual Town Meeting, 2005 and 2004. 

Other strategies were analyzed by Dr. Gordon Thompson and found not to be effective.

Reconfiguring the assemblies in the pool will yield a small reduction in risk; however it will do no

good if there is partial drainage of water or if debris blocks air flow in a drained pool. The

National Academy of Sciences recommended installing a spray cooling system and specified

that the system must be capable of operation even when the pool is drained (which would result
Appendix A

July 2007 A-41 NUREG-1437, Supplement 29

in high radiation fields and limit worker access to the pool) and the pool or overlying building,

including equipment attached to the roof or walls, are severely damaged.” NAS Safety and

Security Report, supra at 6 and 57. This is unlikely to be achievable at Pilgrim and once

ignition had occurred, spraying water into the pool would feed the fire through the exothermic

steam-zirconium reaction. A massive and probably impractical flow of water would be needed

to overcome the effect. Doing nothing, as is the present situation, must be weighed against the

consequences.

The Massachusetts Attorney General’s Request for a Hearing and Petition for Leave to

Intervene includes a report on the potential consequences of a spent fuel pool fire at Pilgrim by

Jan Beyea, PhD., May 25, 2006... 

Beyea stated that, “releases lower than 10% of the Cesium-137 inventory, even releases too

low to justify remediation, could have costs associated with loss in property value in the range

of 10 to 100 billion dollars (Beyea, page 8)... 

Beyea notes that the cancer estimates . . . are lower limits, because they only include cancers

from Cesium-137. This approximation ignores shorter isotopes in the fresh fuel in the pool,

especially Cesium-134 (Benjamin 2003), page 11. Beyea goes on to say that, “Releases from

Pilgrim headed initially out to sea will remain tightly concentrated due to turbulence until winds

blow the puffs back over land (Zagar et al.), (Angevine et al., 2006). This can lead to hot spots

of radioactivity in unexpected locations (Angevine et al. 2004). Beyea, p.11. Therefore

dismissing radiation blowing out to sea is inappropriate. Reduction of turbulence on transport

from Pilgrim across the water to Boston should also be studied, according to Beyea’s analysis.

The program CALPUFF (Scire et al. 2000) has the capability to account for reduced turbulence

over ocean water and could be used in sensitivity studies to see how important the

phenomenon is at Pilgrim... 

It is assumed that an area exists around the "main portion" of plume, where potential property

buyers would be concerned about residual risk. (The main portion of the plume is defined as

the area where remediation or demolition takes place.) Outside the main plume, contamination

would still be measurable. Lack of trust in statements by government would translate into loss

in property values. All things being equal, persons would wish to live as far away from

contaminated areas as possible. 

A spent fuel accident is conservatively estimated to cost from $105 to $488 billion dollars and

result in 8,000 – 24,000 latent cancers from exposure to Cesium-137. Exposure to other

radionuclides and other resultant diseases, reproductive disorders and birth defects will up the

toll. 
Appendix A

NUREG-1437, Supplement 29 A-42 July 2007

Currently casks cost about 1 to 2 million dollars per cask. Pilgrim has approximately 440 tons

of fuel on-site which would cost about $71 million dollars to place into dry cask storage. In

addition, the licensee will incur the costs of moving the fuel out of the pool as it fills anyway, and

will ultimately need to put the fuel in dry casks for transfer to a long term repository when one

becomes available. The probability of a spent fuel fire increases yearly with the increase in

spent fuel densely packed in the pool, and with the risk of ever more sophisticated acts of

terrorism increasing. A rough cost/benefit look at moving spent fuel into secured dry cask

storage shows that this mitigation makes economic sense. Although in its ER, Entergy has

made vague statements about transferring spent fuel assemblies to dry cask storage in the

future, it has not outlined how and when this will happen. In a statement to Cape Cod Times,

Pilgrim spokesman David Tarantino has stated that Entergy plans to move assemblies out of

the spent fuel pools to dry casks only on an as-needed basis, to free up space in the pool for

newer spent fuel. This, and the application’s silence on the issue of future spent fuel storage,

make clear that Entergy has no intention of reconfiguring its pool to low density storage in the

future. It also makes it unlikely that the plant will take the initiative to store spent fuel in secured

dry cask storage as soon as possible. It is up to the NRC assure that the public’s interests are

protected and the vote of the Town of Duxbury that re-licensing be opposed unless Safer

storage of spent radioactive fuel rods is required until all spent rods are moved offsite - low

density pool storage and hardened dispersed dry cask storage. 

A plant-specific assessment of the vulnerability of the spent fuel pool to fires caused by

accident or acts of malice is mandated by the NEPA requirement to consider all of the

environmental impacts of the re-licensing and by the 9th Circuit Court’s decision. In addition,

NRC Regulations (10 CFR 51.53(c) (ii) (L)) call for consideration of severe accident mitigation

alternatives on a plant specific basis if the plant has not already done so. The spent fuel pool,

although a Category 1 issue for the purposes of normal operations, should have been included

in the Category 2 SAMA analysis of severe accidents in the Applicant’s Environmental Report. 

There is also new information since the Generic Environmental Impact Statement was prepared

that demonstrates the spent fuel is likely to remain on-site longer than anticipated, and is more

vulnerable to fires than had been known. 

Also, it is irrelevant whether the Applicant would have decided on mitigation or not. It is the

analysis, or “hard look” that is required by NEPA. “While NEPA does not require agencies to

select particular options, it is intended to ‘foster both informed decision-making and informed

public participation, and thus to ensure the agency does not act upon incomplete information,

only to regret its decision after it is too late to correct’ (citing Louisiana Energy Services

(Claiborne Enrichment Center), CLI-98-3, 47 NRC 77, 88 (1998)).” . . . “if ‘further analysis’ is

called for, that in itself is a valid and meaningful remedy under NEPA.” Duke Energy Corp.,

supra at13. ... 
Appendix A

July 2007 A-43 NUREG-1437, Supplement 29

Given the catastrophic impact to human health and the environment if the spent fuel pool

experiences loss of water due to accident or terrorist attack, and the benefit that could be

achieved at a relatively reasonable cost to the plant operator, mitigation of the existing

vulnerability should at least be considered before the license is renewed. (PNPS-AC)

Response: On-site storage of spent nuclear fuel including spent fuel pool accidents is a

Category 1 issue. The NRC staff’s review of the SAMA analyses will be discussed in Chapter 5

and Appendix G of the SEIS. These comments provide no new and significant information and,

therefore, will not be evaluated further.

Comment: First item. We know that realistic plume modeling assumptions and wind weather

data are key to forecasting and implementing appropriate and effective emergency response

plants and to assess damage afterwards. We hope you will look and compare, for this

particular site, whether Class A models or Class B models would be the most appropriate way

to detect plume dispersion and whether to compare multiple meteorological towers,

appropriately located in sites in the community, would give a more accurate picture, in our

coastal environment with a varied terrain, than relying simply on the tower on site. (PNPS-A)

Comment: Multidimensional plume dispersion models, Class B Models; and multiple

meteorological towers placed in the seven surrounding towns impacted by the sea breeze effect

that were identified by Dr. J.D. Spengler [Carver, Duxbury, Kingston, Pembroke, Plymouth,

Plympton] and towers located appropriately on Cape Cod in consideration of the site specific

meteorological analysis of Cape Cod performed for the Commonwealth by Dr. Bruce Eagan. 

Realistic modeling assumptions and meteorological data are the key to forecasting and

implementing appropriate and effective emergency response plans and assessing damage

afterwards.

Currently, Pilgrim uses Class A plume transport models and relies on weather information from

their onsite meteorological tower. Neither provides accurate data.

The Class A plume models used incorrectly assumes a steady-state, straight-line plume

transport; although actual wind and weather conditions are variable and complex affected by

sea and lake breezes, terrain, location/clustering of buildings, and variable precipitation.

Pilgrim should use complex Class B models now and from 2012-2032 if the license is extended. 

The on-site Met Tower only tells us what the wind direction is onsite but not what happens to

the plume as it travels offsite. Therefore Pilgrim should use data from multiple weather stations

now and from 2012-2032, if the license is extended. (PNPS-AC)
Appendix A

NUREG-1437, Supplement 29 A-44 July 2007

Response: These comments raise questions regarding the adequacy of various input data and

assumptions (i.e. meteorological data) used in the MACCS2 off-site consequence analysis.

The MACCS2 analysis will be addressed in Chapter 5 of the SEIS.

Comment: Pilgrim is located on the coast and the wind is highly variable due to the Sea

Breeze Effect, terrain, buildings, and variation in precipitation/fog patches. Therefore planning

must be for the entire radius – not simply for those inside one imaginary “relatively narrow

plume.” (PNPS-AC)

Comment: In light of NRC and EPA’s Guidance about the use of refined variable trajectory

modeling techniques to provide for more realistic, accurate modeling predictions and site

specific meteorological studies demonstrating the complexity of weather at this site. Pilgrim

should update to Class B models and multiple weather stations. (PNPS-AC)

Comment: A straight line Gaussian model is not applicable here and the applicant should not

rely on weather input data simply from that obtained onsite. By relying on the steady-state,

straight –line Gaussian model to construct a “key hole” planners are likely to make the wrong

call - send citizens into a plume; tell folks to stay put when should evacuate; or tell them to

evacuate when should shelter. Class B models must be required if a license extension is

granted for 2012-2032. Computerized combination weather-radiation monitors are readily

available and also must be required. (PNPS-AC)

Comment: The meteorological input to the modeling tool used by Entergy to characterize

weather conditions, and therefore the radiological consequences from a severe accident at the

Pilgrim plant, are inaccurate.

While Pilgrim's Meteorological Monitoring System currently meets applicable Commission

requirements, the ER's straight-line Gaussian plume model to estimate the location and

magnitude of predicted radionuclide concentrations and resultant doses received from a

postulated plant accident is inappropriate for the Pilgrim station. With the Gaussian plume

model, the speed and direction of prospectively lethal clouds are determined by the initial wind

speed and the direction at the time of release and do not account for variable atmospheric

conditions, whether in time or in space. Further, the model does not consider terrain effects,

which can significantly affect wind patterns and dispersion/ Variable wind conditions over time

and space, likely in the coastal, hilly terrain are surrounding the Town, makes the resultant

predictions of the movement of lethal airborne materials based on just onsite meteorological

data, with simplistic straight line air quality dispersion models, severely unreliable for evacuation

planning purposes. (PNPS-AE)

Response: Emergency planning decisions at Pilgrim would be based on the Pilgrim

Emergency Plan. 10 CFR Part 50.47 requires that the Emergency Plan provide adequate
Appendix A

July 2007 A-45 NUREG-1437, Supplement 29

methods, systems, and equipment for assessing and monitoring actual or potential off-site

consequences of a radiological emergency condition. The Pilgrim Emergency Plan, including

meteorological and dose projection capabilities, has been reviewed by the NRC and found to

meet all regulatory requirements. The comments provide no new and significant information,

and are not within the scope of license renewal under 10 CFR Part 51 and Part 54. Therefore,

they will not be evaluated further. 

Comment: The assumptions in the models used by the applicant and the input data put into

those models do not provide credible conclusions regarding emergency response outcomes in

a severe accident. Nor is there reasonable assurance that the assumptions used by FEMA in

this area have any credibility. The MACCS2 emergency planning model requires the user to

input the time when notification is given to emergency response officials to initiate protective

actions for the surrounding population; the time at which evacuation begins after notification is

received; and the effective evacuation speed. However, the model assumes that the population

is out of danger once crossing the 10-mile boundary. This will not be true in a severe accident

such as a core melt and/or a spent fuel pool accident that leads to a zirconium fire. Safety and

Security of Commercial Spent Nuclear Fuel Storage Public Report, National Academy of

Sciences, 3 (April, 2005).

In addition, the model does not consider those who cannot evacuate and must shelter.

Protective actions involve both evacuation and sheltering. Under some circumstances

evacuation will not be possible for all or a portion of the affected population. The elderly often

require transportation assistance because they are infirm, cannot drive themselves or have only

one car per household that may not be available in an emergency.

The applicant’s evacuation time input data is from, Pilgrim Station Evacuation Time Estimates

and Traffic Management Plan Update, Revision 5, (November 1998). However later data is

available. KLD prepared a later report for Entergy, Pilgrim Nuclear Power Station Development

of Evacuation Time Estimates, KLD TR-382, Revision 6, (October 2004). The newer KLD study

relies on newer census data and newer roadway geometric data. The most recent data

available should be used as source material to get the most accurate estimates.

Many of the assumptions and study estimates in the applicant’s source, Pilgrim Station

Evacuation Time Estimates and Traffic Management Plan Update, Revision 5, (November

1998) are faulty. For example, voluntary evacuation from within the EPZ was estimated to be

50% within a 2-5 mile ring around the reactor, excluding the “key-hole;” and 25% in the annular

ring between the 5-mile boundary of the circle and the 10-mile EPZ boundary. Shadow

evacuation was not considered. Special Events, such as the July 4th celebration, were not

considered. Evacuation time estimates for the EPZ was performed for, “Off-season mid-week,

mid-day in good weather; and summer mid-week, mid-day, good weather.” Using the above

false assumptions, the study describes unrealistically low evacuation time estimates. Clearly
Appendix A

NUREG-1437, Supplement 29 A-46 July 2007

there is no guarantee that an accident will not occur on holidays, during the commuter rush

hour, on summer week-ends, or in bad weather. Emergency planning and a severe accident

analysis should assume the worst case scenario. (PNPS-AC)

Response: The commenter raises questions regarding the adequacy of various input data and

assumptions used in the MACCS2 off-site consequence analysis, including: estimated times to

notify emergency response officials and to initiate and complete evacuation, the portion of the

population that does not evacuate, the impacts of a “shadow evacuation” in which persons

outside the evacuation zone voluntarily evacuate, and the impact of transient population. The

MACCS2 analysis will be addressed in Chapter 5 of the SEIS.

The commenter also states that the severe accident analysis should assume the worst case

scenario. The staff disagrees. As stated in the Commission’s Policy Statement on Use of

Probabilistic Risk Assessment Methods in Nuclear Regulatory Activities, PRA evaluations in

support of regulatory decisions should be as realistic as practicable. Similarly, the Regulatory

Analysis Guidelines of the NRC call for the use of best estimate values. Reliance on best

estimate rather than worst case assumptions in the SAMA analysis is consistent with this

guidance.

Comment: The sea breeze phenomena are observed at the Pilgrim site. A sea breeze is a

localized wind that blows from the sea to the land. It is caused by the temperature difference

when the sea surface is colder than the adjacent land. Therefore, it usually occurs on relatively

calm, sunny, spring and summer days. Depending on topography, intensity of solar heating

and pressure gradients, a sea breeze front can penetrate inland from 1(.5 miles) to 15 km (9

miles). It can occur throughout the year but it occurs most frequently during the spring and

summer months. On average Pilgrim experiences about 45 sea breeze days during these two

seasons.

Typically onshore component commences about 10:00 AM and can persist to about 4 PM. The

wind direction changes during the day veering from the north around through the southeast

quadrant by late afternoon. The intensity of the sea breeze can be measured by the wind

speed and distance of inland penetration. The intensity of the sea breeze circulation depends

upon solar radiation (which is influenced by cloud cover), sea water temperature, and strength

of the gradient wind flow. The intensity and effective inland penetration of the sea breeze front

in the near environment of the Pilgrim site are not well characterized. (PNPS-AC)

Comment: Coast line orientation and topography strongly influence wind patterns (the

frequency, direction, and strength of onshore winds). Predominantly in the summer and spring,

a sea breeze onshore component is observed along the Massachusetts coast. The dominant

sea breeze components are east and east-southeast for Boston-Logan, easterly for Plymouth,

northeast and east-northeast for the Canal site, and east and east-southeast for the Pilgrim
Appendix A

July 2007 A-47 NUREG-1437, Supplement 29

plant. This finding suggests that the wind speed and direction at one coastal site would not be

used as a surrogate for other coastal sites. (PNPS-AC)

Comment: The meteorological sites available provide limited ability to fully characterize or

model the sea breeze circulation in the vicinity of the Pilgrim Nuclear Power Plant.

Physical modeling of coastal sea breeze circulation patterns is limited by both the number of

meteorological sites in the vicinity of the Pilgrim Plant and the number of parameters monitored. 

William T. Land, Meteorological Analysis of Radiation Releases For the Coastal Areas of the

State of Massachusetts for June 3rd to June 20th 1982 A listing of probable causes resulting in

radiation concentration within the microclimate would include (in order of importance):

1. ONSHORE WINDS: Winds from the east and north moving radiation back toward the land

away from the coast.

2. WIDESPREAD RAINFALL; Rain which could keep radiation in the lower stratosphere and

washout radiation into the ecosystems, food chair and water supplies.

3. COOL DESCENDING AIR; Air which would prohibit radiation from lifting into high altitude

winds which would in turn carry the contaminants at the 18,000 foot level safely out to sea.

4. AIR POLLUTION: Pollution which would give added nuclei for radiation to adhere to thereby

increasing its ability to stay at lower stratospheric levels.

5. FOG: Fog which would give additional hydroscopic nuclei for both pollution and radiation to

coalesce upon.

6. AIR STAGNATION: Stagnation with little or no wind, haze and temperature inversions which

in turn have the ability to trap radiation close to the surface. (PNPS-AC)

Comment: Winds along the coast of Massachusetts, and therefore the Town, are significantly

affected by the sea breeze effect, which is critically important in estimating contaminant

exposures in coastal areas. During moderate to strong wind conditions, such as those

associated with coastal storms, approaching warm fronts, or after the passage of cold fronts,

the wind direction throughout the region should be fairly uniform as would be depicted from one

of Entergy's meteorological towers. However, abrupt wind direct shifts and wind speed

changes can occur during the passage of such large-scale weather systems throughout the

region. When wind speed starts to get lighter (e.g., below 5-10 mph), and depending upon the

time of day and season, the terrain also will affect regional wind patterns in a more pronounced

manor. During the spring and summer months whenever day-to-day large-scale regional
Appendix A

NUREG-1437, Supplement 29 A-48 July 2007

weather influences are absent (storms and fronts), strong temperature contrasts between the

warmer land and the colder Cape Cod Bay can result in sea breeze conditions on sunny, fair

weather days. At times, sea breeze influences can penetrate miles inland. Weaker land

breezes also can occur during other times, particularly at night, when the land surface is colder

than the water body surface. Shifting wind patterns (including temporary stagnations,

recirculation, and wind flow reversals) can occur during these daily sea and land breeze

conditions, and can persist for several hours. Any shifting wind patter away from Pilgrim could

produce a different plume trajectory (and resultant concentrations and radiological doses at

specific locations) than what the application depicts. (PNPS-AE)

Response: These comments raise questions regarding the adequacy of various input data and

assumptions (i.e. meteorological data) used in the MACCS2 off-site consequence analysis.

The MACCS2 analysis will be addressed in Chapter 5 of the SEIS.

A.1.7 Comments Concerning Alternative Energy Sources

Comment: ...wind power, solar power, fuel, gas, gas fuel, as far as bringing it into Fall River,

bringing it into Boston Harbor, all of these things are not something that anybody wants to

have...The fact is that we have to have alternative energy and if nuclear is not the safest, then I

think we have to find out what's better and, as we have proposed just about everything, we

have had situations that have caused us to get more and more limited. I don't think we can

protect ourselves from just about anything that we are dealing with. (PNPS-V)

Comment: And I think that when we are talking about fossil fuels, we have to consider that

there is a risk in everything, there is a risk in everything in our environment. (PNPS-V)

Comment: We have gone from the point where we were heating our homes with firewood, and

we went to coal, we didn't like that, we went to oil. We are now into the nuclear age and, as far

as its concerned, I would just like to know and I think perhaps people from some of the, some

of the people who are providing studies is what are the alternatives? (PNPS-V)

Comment: Let's have a wind farm out in Nantucket Sound, you are not going to have any

problems there. There is no NRC to oversee a wind farm because there is no problem with a

wind farm as serious as the problem that exists with the radioactive substances that we are

using today in these reactors. (PNPS-Z)

Response: The comments are related to the environmental impacts of alternatives to license

renewal at PNPS. The GEIS included a discussion of alternative energy sources.

Environmental impacts associated with various reasonable alternatives to renewal of the PNPS

operating license will be evaluated in Chapter 8 of the SEIS.
Appendix A

July 2007 A-49 NUREG-1437, Supplement 29

A.1.8 Comments Concerning Monitoring Programs

Comment: I hope, in that, you will also be looking at the necessity in the future, and actually

now, for better monitoring to assess whether the current environmental monitoring program

reports are reliable and accurate, whether, instead, we need to include more sampling to have

another look at where control and indicator stations are place and also to consider, in the

future, whether it's appropriate to have the licensee get the samples, and have their own labs

analyze the samples and to provide the reports, whether a system would better protect health

and public safety, for 2012-2032, what would you advise? (PNPS-A)

Comment: High School Monitoring Project - This system consists of radiological and

meteorological monitoring systems at each of seven high schools [3 in Plymouth; 1 each in

Carver, Kingston, Duxbury and Marshfield]. These on-line monitoring stations are connected by

modem to each other and to MDPH.

Deficiencies:

• This program was initiated by the Governor’s Council on Radiation Protection solely

as a teaching device for the students, not as a monitoring device to protect public

health and safety. They recognized that this important job could not be left to a

changing collection of teachers, students or janitors, working part-time and not trained

technicians.

• It is overly optimistic to assume that the schools are all coincidentally placed in the

most favorable locations in regard to population density and meteorological conditions.

• The High School monitors, like the Sage, have poor sensitivity to low energy gamma

and beta. To be protective of public health they should measure gamma, beta and

alpha radiation, at both the high and low energy levels. For example Iodine-125 is at

the 60 KeV and most iodine’s are less than 100 KeV.

• Calibration and testing of equipment is not adequately and consistently performed. 

(PNPS-AC)

Comment: The ER must analyze the accuracy and reliability of Pilgrim’s monitoring and

reporting in order to accurately assess what impact Pilgrim actually has had on the environment

and is likely to have in the future.

We contend that in order to have any reasonable assurance that public health and safety will be

protected 2012-2032, the following changes in the monitoring program must occur.
Appendix A

NUREG-1437, Supplement 29 A-50 July 2007

Environmental monitoring program must be changed as follows:

• Control stations actually placed outside the area of Pilgrim’s influence - outside

Emergency Planning Zone [EPZ] communities;

• Number and type of samples expanded;

• Split samples provided to an in independent source;

• Analysis and reports performed by an independent laboratory, not one owned by the

applicant;

• Monitoring wells installed to test for groundwater contamination and migration placed

onsite, especially along the edge of Cape Cod Bay. Monitoring air emissions modified

to include:

• Off-site releases - upgrade equipment by installing combination weather/ radiation

detection and measurement devices, fix-mounted to provide real-time measurements,

placed in appropriate locations as determined by a site-specific meteorological study;

• On-site monitors upgraded.

Multidimensional plume dispersion models, Class B Models; and multiple meteorological towers

placed in the seven surrounding towns [Carver, Duxbury, Kingston, Pembroke, Plymouth, and

Plympton] and on Cape Cod according to site specific meteorological analysis performed, for

example, for the Commonwealth by Dr. J.D. Spengler and Dr. Bruce Eagan. (PNPS-AC)

Comment: Radiation detectors are located at exit points from the plant to measure gaseous

radioactive effluents. These detectors monitor the gross gamma radiation of gaseous effluents

as they pass by. These readings are monitored and recorded in the control room, and when

the radiation level approaches release limits, either the effluents can be diverted to another

system for further processing, or the power level of the reactor can be reduced in order to

reduce the amounts of radioactivity produced. The radiation detectors are sensitive only to the

total amount of radiation impinging on them, they don’t differentiate between one isotope and

another, since there are substantial assumptions regarding short half-lives of isotopes entering

the systems. One fundamental limitation to measuring gamma radiation levels exiting the plant

ventilation systems is that a small perturbation in the total amount of radiation detected, since

the decay rate is so much lower compared to short half-life isotopes. In this way, a leak of long

half-life isotope could go undetected by a radiation detector. The use of chemical and gamma

spectrographic analysis is designed to augment the stack radiation monitoring program. 

(PNPS-AC)
Appendix A

July 2007 A-51 NUREG-1437, Supplement 29

Comment: Periodic sampling and analysis techniques are employed to determine the relative

abundance of various isotopes that are being released. This is very important since the

biological action and possible impact is quite different for different isotopes. The way this is

carried out is that radioactive effluent is sampled by systems that employ filters and charcoal to

draw air through them. After a given period of time, the contents of the filters and charcoal are

analyzed by measuring the radioactive decay rate as a function of disintegration energy. Since

isotopes decay by emitting radiation of characteristic energies, the amount of a given isotope

present in the sample can be estimated by the magnitude of the number of disintegrations at

characteristic energies. The uncertainties associated with this method are that in general

isotopes emit a spectrum of radiation frequencies, and in a case where there are a large

number of unknown isotopes present in the sample, the energy peaks can overlap for different

species and it may not be possible to assay many isotopes with any accuracy. Another

problem that can occur is that the efficiency of the charcoal absorber is strongly a function of

relative humidity, so in cases of high humidity, the amount of a given isotope present in the

charcoal may not at all reflect the concentrations in the sampled effluent. Detectors used to

perform these measurements have non-uniform responses to different energy peaks, and

calibration of these sensitive instruments should be conducted frequently. Finally, the raw

measurements from these instruments are entered into equations to estimate actual release

rates, so the associated uncertainties may be quite high. (PNPS-AC)

Comment: Off-site monitors to measure airborne emission of radionuclides from Pilgrim

include: the Sage System consisting of 14 real-time monitors installed on the edge of Pilgrim’s

property; thermoluminescent docimeters (TLD’s) placed in locations 0 to >15 km from Pilgrim;

real-time monitors placed in a few schools for the sole purpose of educating students.

Sage System [Computerized “Ring” Monitors] – Deficiencies

• The Sage System does not provide any significant protection to the citizens of

Southeastern Massachusetts. The “NRC Draft Report For Comment On Findings On

Issues Of Off-site Emergency preparedness For the Pilgrim Nuclear Power Station

[NUREG-1438], issued May 1991, expressly noted that MDPH installed this system,

“even though fixed offsite monitors are no longer endorsed by the NRC...”[ page 2-

159].

• Under the agreement with Boston Edison Company [BECO], the previous licensee,

the monitors were installed less than a quarter of a mile from the plant. Yet, the NRC

has found that monitors closer than 1000 meters [about 2/3 of a mile] would provably

provide inaccurate readings in the event of an accident.

• The agreement included 22 potential monitoring sites, but only 14 have been

installed. Again this is contrary to NRC research on real time monitoring, which
Appendix A

NUREG-1437, Supplement 29 A-52 July 2007

concluded that using as few as 14 monitors would grossly underestimate the radiation

from narrow emission plumes.

• The monitors are only in a small quadrant behind the plant. Therefore, there is no

effective monitoring in the directions of Scituate, Marshfield, Duxbury, Kingston, or

much of Plymouth [including the Gurnet, Saquish neck at the end of Duxbury r Beach.

• There are no monitors on Cape Cod. The Cape is across open water -- nothing to

break up a plume.

• The placement of the Sage monitors effectively ignores the results of wind analysis

done by the Harvard School of Public health, under the direction of Dr. J.D. Spengler

and Dr. G.J. Keeler, May 12, 1988 that described the variability of coastal winds and

that the sea breeze effect brought winds inland > 10 miles. Also a true ring of

monitors is feasible. At Seabrook NPS, the Citizens Monitoring Network is installing

monitors on buoys at sea.

• The Sage monitors do not measure high and low let alpha and beta radiation.

• The placement of the Sage monitors effectively ignores the results of wind analysis

done by the Harvard School of Public health, under the direction of Dr. J.D. Spengler

and Dr. G.J. Keeler, May 12, 1988 that described the variability of coastal winds and

that the sea breeze effect brought winds inland > 10 miles. Also a true ring of

monitors is feasible. At Seabrook NPS, the Citizens Monitoring Network is installing

monitors on buoys at sea.

• The Sage System lacks software to make sense out of the computer data arriving at

Massachusetts Department of Public Health [MDPH]. The data has not been

systematically graphed, charted or reported to the public. (PNPS-AC)

Comment: Plutonium historically have been found in Duxbury Bay sediment samples; Entergy

has attributed the Plutonium to either weapons testing, cross-contamination from their lab’s

glassware or simply lost the sample.

It seems far more likely that the plutonium is from Pilgrim which is visible from Duxbury - rather

than from a Chinese bomb launched thousands of miles away. It would be coincidental if the

beaker used to test the sample at Entergy’s own lab just happened to be improperly cleaned

and just happened to be contaminated with Plutonium. It seems coincidental that the next

years’ plutonium sample happened to get lost. This is one reason Petitioners believe that the

Applicant should not be responsible for its own environmental testing – the samples should be

sent to an independent lab. (PNPS-AC)
Appendix A

July 2007 A-53 NUREG-1437, Supplement 29

Comment: Beginning in July 2002 Pilgrim began to use Entergy's J.A. Fitzpatrick

Environmental Laboratory for analysis of environmental samples. Petitioners contend, and are

prepared to demonstrate to the ASLB, that results can vary considerably depending on who

analyzes the data and reports the findings. A clear conflict of interest is present when the

applicant’s own company both analyzes the data and reports the results. (PNPS-AC)

Comment: The Radiological Environmental Monitoring Program reports can not be relied upon

to produce accurate data. The Applicant collects the samples to determine Pilgrim’s

radiological impact on the general public. The “control stations” are too close to the reactor; in

actuality, they are indicator stations. Fewer sample media and numbers now are taken than

before; fewer are required. Since July 2002, the Applicant’s own laboratory analyzes the

samples for radioactivity. Reports for the NRC and public are prepared by the Applicant,

Entergy. Finally high deposition of radiation found is attributed by Entergy to sources other than

Pilgrim. (PNPS-AC)

Comment: The environmental sampling media collected in the vicinity of PNPS and at distant

locations included air particulate filters, charcoal cartridges, seawater, shellfish, Irish moss,

American lobster, fishes, sediment, milk, cranberries, vegetation, and animal forage.”

The sampling locations are divided into two classes, indicator and control. Indicator locations

are those that are expected to show effects from Pilgrim operations. The REMP states that

while the indicator locations are typically within a few kilometers of the plant, the control stations

should be located so as to be outside the influence of Pilgrim Station. However, many control

stations are too close to Pilgrim - within sight of the reactor and within the official Emergency

Planning Zone Communities, [10 miles or 16 kilometers]. In reality they are indicator stations.

If radiation is above expected in a sample collected from a "control station" it is attributed to

weapons fallout, not Pilgrim. Also the location of the “control stations” ignores the fact that

radioactive particulates released to the air from the stack, will be carried by the wind some

distance and deposited some distance from the reactor site –in the control locations. (PNPSAC)

Comment: Milk, a key indicator, is no longer sampled. Prior to 2000, milk samples were

obtained from an indicator station, Plymouth County Farm, and from a control station located in

Whitman. Plymouth County Farm stopped milking cows and since that time Entergy has

claimed that they could not identify any additional milk animals within 5 kilometers [3.1 miles] of

Pilgrim. Petitioners contend that milk samples > 5 kilometers could be indicator stations.

Additionally there are farms nearby. Plymouth Plantation is about 3 and 1⁄2 miles from Pilgrim

and has a farm with lactating cows and goats. The oldest operating dairy farm in the Northeast

is located in Duxbury. Entergy’s claim that Plymouth Plantation can not provide sufficient milk

has not been proven. Exactly how much is required, at minimum, for each test? We request

this information to verify with independent laboratories. (PNPS-AC)
Appendix A

NUREG-1437, Supplement 29 A-54 July 2007

Comment: In regard to terrestrial sampling, routine collection and analysis of soil samples was

discontinued; instead they claim that if air sampling showed an early indication of any potential

deposition of radioactivity, follow-up soil sampling could be performed on an as-needed basis.

However, this assumes that the air monitoring is reliable and accurate.

In the area of marine sampling, the following changes were made.

• A sample of the surface layer of sediment is collected, as opposed to specialized

depth-incremental sampling to 30 cm and subdividing cores into 2 cm increments.

• Standard LLD levels of about 150 to 180 pCikg were established for sediment, as

opposed to the specialized LLDs of 50 pCi/kg.

• Specialized analysis of sediment for plutonium isotopes was removed.

• Sampling of Irish moss, shellfish, and fish was rescheduled to a semiannual period,

as opposed to a specialized quarterly sampling interval.

• Analysis of only the edible portions of shellfish (mussels and clams), as opposed to

specialized additional analysis of the shell portions.

• Standard LLD levels of 130 to 260 pCVkg were established for edible portions of

shellfish, as opposed to specialized LLDs of 5 pCVkg.

Petitioners contend that what was discontinued has resulted in the loss of important data that is

required, "to assess the impact of Pilgrim Station on the environment and on the general

public." And what was discontinued appears to be connected to elevations of radioisotopes in

the environment found in previous years. (PNPS-AC)

Comment: I believe we have very, very little data monitoring radiation in the area. There may

be occasional radiation monitors at the plant but, for instance, in Duxbury, we don't have any

radiation detectors, so I think I hear people say that even during, if we had any kind of an event,

it would be very important for us to know where, if there is a radiation release, where is it going

and is it in fact in Duxbury, or is it in Carver or is it in Plymouth? So I think, as one of the

mitigation things that I would like to very strongly request, is that radiation monitors be put

throughout the area, and many of them. And it would be, I think, in Pilgrim's interest to have

that because if, as I think they claim, that radiation is not being disseminated around, that would

certainly prove their point. If there is nothing being measured, then that's great for all of us to

know. (PNPS-L)
Appendix A

July 2007 A-55 NUREG-1437, Supplement 29

Comment: And third, in assessing health, you would look at, as BEIR VII said, to

bioaccumulation and the cumulative effect of health impact by looking at what is documented in

the REMPs of how much radiation has been released, and also pay special attention to what

was stated by Mass. Department of Public Health in a public meeting that Senator Kerry held,

that there is no reason, I can provide the exact quote later, no reason to trust what the licensee

has put into their reports of what has been emitted and "they have emitted far too much than

they should have" including, for example, transgeneric elements such as neptunium. (PNPS-A)

Comment: The effects of radiation exposure are cumulative. Some types of nuclear power

plant emissions stay radioactive for a long time and, because they can enter biological food

chains, those materials can accumulate in the environment and adversely affect public health. 

“If radioactive emissions persist for years, decades or even centuries within the environment,

then even modest reductions in annual discharges may not be sufficient to prevent an

environmental build up of those materials over time.” Estimates of Environmental

Accumulations of radioactivity Resulting from Routine Operation of New England Nuclear

Power Plants (1973-84), Dr. Richard W. England, Mr. Eric Mitchell, p.4, A Report of the Nuclear

Emission Research Project, Whittemore School of Business and Economics, University of New

Hampshire, Durham, N.H., August 1987.

It is known for example that the following radionuclides have been released from Pilgrim into

neighboring communities: plutonium 239 (half life 24,400 years); neptunium 236 or 237 (half life

ranging from 120,000 years -2.1 million years); cesium 137 (half life 30.2 years); strontium 90

(half life 28.5 years); tritium (half life 12.3 years), and xenon (half life 9.17 hours). Xenon

transforms after its emission into cesium 135, which persists almost indefinitely in the

environment. Examples of previous releases have been reported in the Annual Radiological

Environmental Monitoring Program Reports [REMP]. These releases include substances that

will remain active in the local environment for the foreseeable future and should be taken into

account when actual on-going doses to the public are evaluated. (PNPS-AC)

Comment: We would like to submit that if Applicant, NRC or current MDPH spokespersons

dispute a causal link between the radiation released by Pilgrim and the cancers seen in its

neighboring towns, the current systems in place to monitor releases are inadequate and must

be improved if re-licensing is to be considered. The Comments to the Southeastern

Massachusetts Leukemia Study made by Dr. Richard Clapp illustrate this point: I would like to

reiterate a point that Drs. Knorr and Morris [Massachusetts Department of Public Health

epidemiologists, authors of the Southeastern Massachusetts Health Study] made to you in one

of their memoranda, e.g., that the emissions data provided by the utility are not reliable. I have

had numerous discussions with individuals in the Department of Public health as well as

colleagues who previously worked in a job monitoring worker exposure to Pilgrim contractors in

the mid-1970’s. From these discussions, I am convinced that the actual emissions were

considerably worse than what has appeared in public documents and has been available to
Appendix A

NUREG-1437, Supplement 29 A-56 July 2007

researchers to date. In particular, there were transuranic isotopes released that should never

have been emitted to the general environment.” Richard C. Clapp, MPH,Sc,D., Statement

before the Southeastern Massachusetts health Study Review Committee, (June 26, 1992). In

the years since that statement was made, the quality of the environmental monitoring by Pilgrim

has, if anything, decreased. (PNPS-AC)

Comment: The public can not be required to prove a causal link between the radiation

released and the statistically significant increase in cancers if there is no effective monitoring

system in place to measure those releases nor can the Applicant claim that a causal link does

not exist.

As stated previously, the system in place to monitor off-site radiological releases at Pilgrim is

inadequate. Although there are documented increases in radiation-linked cancers in the

communities around the plant, this aging plant does not use monitors which would allow state

or federal authorities to confidently measure radiation releases. Some of the deficiencies of the

monitoring system currently used by Pilgrim are described in the following section, as well as

needed improvements that need to be made to the Pilgrim environmental monitoring program. 

(PNPS-AC)

Comment: Pilgrim began operations in 1972 with defective fuel. The Massachusetts

Department of Public Health’s Southeastern Massachusetts Health Study 1978-1986 stated,

“Pilgrim, which began operations in 1972, had a history of emissions during the 1970s that were

above currently acceptable EPA guidelines as a result of a fuel rod problem.” Southeastern

Massachusetts Health Study 1978-1986, Morris M.S., Knorr R.S., Executive Summary,

Massachusetts Department of Health (October, 1990).

In the March 2005 and April 2006 Pilgrim SALP (Systematic Assessment of License

Performance, performed by the NRC) Reports, NRC Resident Inspector, William Raymond,

stated that Pilgrim operated in 2004 and 2005 with defective radioactive fuel – that is, fuel with

perforated cladding. We do not have information one way or another whether defective fuel

was used in other previous years. Fuel cladding provides the first barrier to prevent radiation

from getting out and harming workers and the public. Degraded fuel is an on going issue for

the industry. NRC Commissioner Merrifield has admitted nearly 1/3 reactors now have failed

fuel, and the trend is increasing, not decreasing. Briefing on Nuclear Fuel Performance,

Transcript, p.4, (February 24, 2005), http://www.nrc.gov.

Use of degraded fuel will increase exposure to both the public and workers. For example,

according to the NRC, “a plant operating with 0.125 percent pin-hole fuel cladding defects

showed a general five-fold increase in whole-body radiation exposure rates in some areas of

the plant when compared to a sister plant with high-integrity fuel (<0.01 percent leaks). Around

certain plant systems the degraded fuel may elevate radiation exposure rates even more.”
Appendix A

July 2007 A-57 NUREG-1437, Supplement 29

United States Nuclear Regulatory Commission, Information Notice No. 87-39, Control Of Hot

Particle Contamination At Nuclear plants, (August 21, 1987). (PNPS-AC)

Comment: If radioactivity is discovered that could be attributed to Pilgrim, the response is to

attribute the contamination to other sources and/or request NRC to change the monitoring

requirements.

Example, Milk: Milk historically showed elevated levels of contamination. However as

mentioned above milk is no longer tested, although lactating animals are available in the area at

Plymouth Plantation approximately less than 5 miles away and at a dairy farm in Duxbury,

within the Emergency Planning Zone.

Previously milk was tested in farms near Pilgrim and at a control station in Whitman, 22 miles

away. The Radiological Environmental Monitoring Program Report (REMP) for 1980 noted that,

at the farms around Pilgrim, “the measured average concentration of both Cesium-137 and Sr90 were respectively 10,000 and 1,000,000 times in excess of the concentrations expected to

be present...” and went on to say that this “is unquestionably due to atmosphere testing.” The

effort to blame the increase on “atmosphere fallout” ignores a critical fact – no similar increase

was experienced at the control station in Whitman.

The 1982 REMP report stated that the highest mean value occurred at the Kings Residence,

located < 5 miles from Pilgrim, in late June 1982. There were concentrations greater than

1,000,000 times in excess of the concentration expected. The report, written by Tom Sowden

[who continues to work in this area at PNPS] stated,

It is not uncommon to find marked increase of Cs-137 associated with the cow’s pregnancy,

and this was most likely the cause.

However the large animal expert at Tufts Veterinarian School was of a different opinion. He

stated that,

Cows normally do not lactate during pregnancy. And, an animal can not produce Cs-137 on

their own. It (Cs-137) must be introduced into the cows system from an environmental source. 

The cow would have to ingest it in some way.” (PNPS-AC)

Comment: TLD’s - Thermoluminescent dosimeters placed in offsite locations ranging from 1

km (.6 miles) to > 15 km (9.3 miles) to measure gamma radiation levels. These devices are

passive in as much as they must be in place for a period of time [3 months] and then brought

back to the laboratory to determine the amount of radiation the device received at that location

for that period of time.
Appendix A

NUREG-1437, Supplement 29 A-58 July 2007

Deficiencies TLD’s

• TLD’s provide only an average figure, and increases of potential significance can be

masked by lower than average readings during other parts of the month. Biological

impact occurs on a daily basis.

• TLD’s can only read to a maximum threshold, that is, like a film badge they can only

read so high.

 • TLD’s do not read high or low let alpha and beta.

• Dr. Hoffman, at Penn State, did an analysis of TLD’s and concluded they provided

poor sensitivity to Zenon 133. He said it took about 85 hours at maximum

concentration before anything showed up and that even then the amount was

underestimated by a factor of around 20. (PNPS-AC)

Comment: Entergy states that "[v]ery low levels of radioactivity may be released in plant

effluents if they meet the limits specified by NRC's regulations. These releases are closely

monitored and evaluated for compliance with the NRC restrictions in accordance with the PNPS

Offsite Dose Calculation Model." This implies that there will be no danger to public health from

routine releases since they will be monitored and will not exceed federal limits. However, the

system in place to monitor radiological releases at Pilgrim is inadequate and could result in a

health hazards to residents in the Town and neighboring areas. (PNPS-AE)

Comment: These communities are also downwind from the Camel Electric Plant and there has

been significant pesticide use in the agriculture. So, we have been exposed and will continue to

be exposed to a multiplicity of toxins that will work together. Also, no one denied the fact that

1982, when Pilgrim had a severe accident of blowing its filters, that that damaging effect is still

here. Many of what never should been released radionuclides, with long half lives, are still in

our environment. (PNPS-N)

Response: The comments relate to monitoring of radiological effluents at Pilgrim. As required

by NRC regulations, the amounts of radioactive isotopes released from Pilgrim in liquid and

gaseous effluents are constantly monitored and recorded by Entergy. The meteorological

conditions at the site also are constantly monitored and recorded. Health physics experts from

NRC’s Region I office routinely inspect these monitoring programs to ensure that they are being

properly implemented. All of this information is fed into calculational models that estimate the

amount of radiation dose a member of the public might receive. The calculational models are in

the ODCM and have been reviewed and approved by the NRC. These models include

estimates of dose from internally deposited radioactive isotopes as well as direct radiation

exposure. In addition, Entergy conducts an environmental radiological monitoring program in
Appendix A

July 2007 A-59 NUREG-1437, Supplement 29

the area around Pilgrim. This program has also been reviewed and approved by the NRC and

is inspected by the health physics experts from NRC’s Region I office. In addition, changes to

the program, such as the decision to suspend milk sampling because a large enough sample

size is not available, are also reviewed by the NRC as part of the inspection program. The

environmental radiological monitoring program samples and measures the amount of

radioactive isotopes in the air, water, soil, agricultural products, shoreline sediments, and

aquatic biota and measures direct radiation from the plant using thermoluminescent dosimeters

(TLDs). The NRC finds the use of TLDs for the purpose of routine monitoring around nuclear

power plants to be acceptable. This program confirms that the levels of radioactive isotopes in

the environment that are predicted by the computer dose models. This program will also

identify any radionuclides that may be accumulating in the environment around Pilgrim. 

Licensees also must participate in an interlaboratory comparison program, which provides an

independent check of the accuracy and precision of environmental measurements. The

quality assurance laboratories for J.A. Fitzpatrick Laboratory are Analytics, Incorporated in

Atlanta, Georgia, and the U.S. Department of Commerce’s National Institute of Standards and

Technology in Gaithersburg, Maryland. Also, the Massachusetts Department of Public Health

conducts an environmental radiological monitoring program around Pilgrim.

As part of the review of the license renewal application for Pilgrim, the NRC will review the

annual radiological effluent reports and the annual environmental radiological monitoring reports

for the last several years at Pilgrim. All of these reports are available to the public on the NRC’s

ADAMS document retrieval system. The NRC will also review information from the

Commonwealth’s monitoring program.

While Pilgrim may have experienced significant fuel defects and released transuranic

radioisotopes earlier in plant operation, NRC believes that the recent effluent reports are the

best source of information to help estimate the amount of each type and total amount of

radioactive materials that will be released from the plant during the license renewal period. 

Chapters 2 and 4 of the SEIS will address NRC’s assessment of the radiological effluents and

impacts that are expected during the license renewal period.

Comment: The EIS should also catalogue other (i.e., non-thermal) pollutant discharges by

Pilgrim Station and assess their environmental effects. These other pollutants may include

chlorine or other biocides, copper, radionuclide, metals, or other contaminants. Again, EPA has

information on some of these pollutants in its NPDES permit files, but the NRC could update

this information as needed and likely has more information regarding radionuclides or better

access to such information than EPA does. (PNPS-AG)

Response: The National Pollutant Discharge Elimination System (NPDES) permit, which is

issued by EPA, designates the chemicals, such as biocides and metals, and the amounts of
Appendix A

NUREG-1437, Supplement 29 A-60 July 2007

those chemicals that are allowed to be released by Pilgrim. NRC will review the NPDES permit

as part of its evaluation of the potential environmental impacts of license renewal for the

purposes of NEPA. These impacts will be discussed in Chapters 2 and 4 of the SEIS. In

addition, Chapters 2 and 4 of the SEIS will include NRC’s assessment of radiological effluents

and impacts that are expected during the license renewal period.

| Part II. Comments Received on the Draft SEIS

|

| Pursuant to 10 CFR Part 51, the staff transmitted the Generic Environmental Impact Statement

| for License Renewal of Nuclear Plants, Regarding Pilgrim Nuclear Power Station, Draft Report

| for Comment (NUREG-1437, Supplement 29, referred to as the draft SEIS) to Federal, State,

| Native American Tribal, and local government agencies as well as interested members of the

| public. As part of the process to solicit public comments on the DSEIS, the staff:

|

| • placed a copy of the DSEIS in the NRC’s electronic Public Document Room, its license

| renewal website, Plymouth Public Library, Duxbury Free Library and Kingston Public

| Library, 

|

| • sent copies of the DSEIS to the applicant, members of the public who requested copies,

| and certain Federal, State, Native American Tribal, and local agencies,

|

| • published a notice of availability of the DSEIS in the Federal Register on

| December 14, 2006, (71 FR 75280),

|

| • issued press releases and public announcements such as advertisements in local

| newspapers and postings in public places announcing the issuance of the DSEIS, the

| public meetings, and instructions on how to comment on the DSEIS,

|

| • held public meetings in Plymouth, Massachusetts, on January 24, 2007, to describe the

| results of the environmental review and answer related questions,

|

| • established an e-mail address to receive comments on the DSEIS through the Internet.

|

| During the DSEIS comment period, the staff received a total of 21 written sets of comments. 

| Eighteen commenters spoke during the public meetings. The staff reviewed the public meeting

| transcripts and the comment letters that are part of the docket file for the application, all of

| which are available in the NRC’s Agencywide Documents Access Management System

| (ADAMS). ADAMS is accessible at http://www.nrc.gov/reading-rm/adams.html. The ADAMS

| accession number for the public meeting summary, which includes the complete meeting

| transcripts, is ML070590260. Appendix A, Part II, Section A.2, contains a summary of the
Appendix A

July 2007 A-61 NUREG-1437, Supplement 29

comments and the staff’s responses. Appendix A, Part II, Section A.3, contains the comment |

letters and a summary of the transcripts. |

|

Each comment identified by the staff was assigned a specific commenter identifier (marker). |

That identifier is typed in the letter’s margin at the beginning of the comment discussion. |

|

Table A-2. Individuals Providing Comments During Public Meetings and Comment Period |

|

|

Commenter |

ID |

Commenter Affiliation (If Stated) Comment Source |

PNPS-D-A Sherwood Martinelli Stakeholder for Pilgrim Nuclear Reactor Written Comments |

PNPS-D-B Joan Bartlett Local resident Written Comments |

PNPS-D-C Lilias Cingolani Local Resident Afternoon Public Meeting |

PNPS-D-D Mary Lampert Pilgrim Watch Afternoon Public Meeting |

PNPS-D-E Joyce McMahon Massachusetts Affordable Reliable Electric |

Alliance |

Afternoon Public Meeting |

PNPS-D-F Robert Ruddock Associated Industries of Massachusetts Afternoon Public Meeting |

PNPS-D-G Rebecca Chin Former Chairman of the Duxbury Board of |

Health |

Afternoon Public Meeting |

PNPS-D-H John Stobierski South Shore Chamber of Commerce Afternoon Public Meeting |

PNPS-D-I Pine duBois Jones River Watershed Association Afternoon Public Meeting |

PNPS-D-J Ben Morgan Local Resident Afternoon Public Meeting |

PNPS-D-K Heidi Mayo Local Resident Afternoon Public Meeting |

PNPS-D-L Arthur Gast Former Member Nuclear Matters |

Committee |

Afternoon Public Meeting |

PNPS-D-M Mary Lampert Pilgrim Watch Afternoon Public Meeting |

PNPS-D-N Bob Haynes Massachusetts AFL-CIO Evening Public Meeting |

PNPS-D-O Gary Sullivan Pilgrim Nuclear Power Plant Evening Public Meeting |

PNPS-D-P Joyce McMahon Massachusetts Affordable Reliable Electric |

Alliance |

Evening Public Meeting |

PNPS-D-Q Mary Lampert Pilgrim Watch Evening Public Meeting |

PNPS-D-R Bill Harris Local Business Owner Evening Public Meeting |

PNPS-D-S Brian Thurber Clean Water Action Evening Public Meeting |

PNPS-D-T Michael Scherer Normandeau Associates Evening Public Meeting |

|
Appendix A

NUREG-1437, Supplement 29 A-62 July 2007

| Table A-2. (Contd)

|

|

| Commenter

| ID

| Commenter Affiliation (If Stated) Comment Source

| PNPS-D-U Richard Rothstein Plymouth Resident Evening Public Meeting

| PNPS-D-V Bill Stone Plymouth Resident Evening Public Meeting

| PNPS-D-W Kevin Craig Evening Public Meeting

| PNPS-D-X Rebecca Hall Previous Plymouth Resident Written Comments

| PNPS-D-Y Malcom MacNaught Duxbury Resident Written Comments

| PNPS-D-Z Heidi Mayo Local Resident Written Comments

| PNPS-D-AA Lilias Cingolani Local Resident Written Comments

| PNPS-D-BB Joseph A. Marino Local Resident Written Comments

| PNPS-D-CC Rebecca Chin Former Chairman of the Duxbury Board of

| Health

| Written Comments

| PNPS-D-DD Millie Morrisson Duxbury MA Nuclear Advisory Committee Written Comments

| PNPS-D-EE Mary Lampert Pilgrim Watch Written Comments

| PNPS-D-FF Frank Gorke Environment Massachusetts Written Comments

| PNPS-D-GG Alyssa Schuren Toxics Action Center Written Comments

| PNPS-D-HH Martha Coakley Massachusetts Attorney General Written Comments

| PNPS-D-II Robert S. Knorr Massachusetts Department of Public

| Health

| Written Comments

| PNPS-D-JJ Paul E. McCormack Local Resident Written Comments

| PNPS-D-KK Brian Thurber Clean Water Action Written Comments

| PNPS-D-LL Diana Woebcke Massachusetts Resident Written Comments

| PNPS-D-MM Stephen J. Bethay Entergy Nuclear Operations, Inc. Written Comments |

| PNPS-D-NN Pine duBois Jones River Watershed Association Written Comments

| PNPS-D-OO Robert W. Varney Regional Administrator, USEPA Region I Written Comments

| PNPS-D-PP Mary Osborn Written Comments

|

|

|
Appendix A

July 2007 A-63 NUREG-1437, Supplement 29

A.2 Comments and Responses |

|

Comments and responses in this section are grouped in the following categories: |

|

A.2.1 Comments Concerning the License Renewal Process A-63 |

A.2.2 Comments in Support of License Renewal at Pilgrim Nuclear |

Power Station A-69 |

A.2.3 Comments in Opposition of License Renewal at Pilgrim |

Nuclear Power Station A-72 |

A.2.4 Comments Concerning Surface-Water Quality, Hydrology, |

Groundwater, and Uses Issues A-75 |

A.2.5 Comments Concerning Aquatic Ecology, Terrestrial Ecology, |

General Ecology, and Threatened and Endangered Species Issues A-77 |

A.2.6 Comments Concerning Human Health Issues A-112 |

A.2.7 Comments Concerning Socioeconomic Issues A-125 |

A.2.8 Comments Concerning Land Use Issues A-127 |

A.2.9 Comments Concerning Postulated Accidents A-129 |

A.2.10 Comments Concerning Uranium Fuel Cycle and Waste |

Management Issues A-140 |

A.2.11 Comments Concerning Alternatives A-161 |

A.2.12 Comments Concerning Editorial Issues A-166 |

A.2.13 Comments Concerning Decommissioning Issues A-183 |

A.2.14 Comments Outside the Scope of the Environmental Review |

for License Renewal: Safeguards and Security; Operational |

Safety; Aging Management; Need for Power; and Energy Costs A-185 |

|

|

A.2.1 Comments Concerning the License Renewal Process |

|

Comment: And I want to say, you know, that this is a wonderful opportunity, this civic |

engagement, the opportunity to speak in public about things that are so important to us and for |

somebody that has represented workers for 30 years here in the Commonwealth of |

Massachusetts, this is a good example, a good relationship with the company, and the union |

and the workers, doing good work for the community, so please relicense the Pilgrim Nuclear |

Power Station for the benefit of the community. Thank you very much. (PNPS-D-N) |

|

Response: This comment is supportive of the license renewal process but do not provide any |

new information. Therefore, no changes have been made to the SEIS. |

|

|
Appendix A

NUREG-1437, Supplement 29 A-64 July 2007

| Comment: I'm going to try to limit my comments to what the NRC has done, what the staff

| have done specifically about the generic environmental impact statement because I don't think

| that this is an issue of whether the plant should be open or closed in the future, I think it's an

| issue of whether this statement has been adequately prepared, and whether all the issues have

| been adequately studied and whether there should be additional work done in terms of

| protecting the plant, so let's try to keep it at that level. 

|

| I don't get this thing that's repeated often in the study which is there is no new information. It's

| repeated in several sections that specifically concern me because I see new information and

| the two sections of the report where I don't see acknowledgment of new and significant

| information that concern me is, one, the section that deals with the environmental impact of the

| fuel cycle's radioactive waste and the second section is the environmental impact postulated

| accidents. There are fixable issues here, even given the new information that I believe exists,

| but what the NRC needs to do, I believe, is expose these issues and then force resolution of the

| issues. (PNPS-D-W)

|

| Response: The NRC staff determines whether an issue is new and significant after a thorough

| evaluation of the issue. New and significant information would involve an environmental issue

| that was not covered in the generic environmental impact statement for license renewal (GEIS)

| or codified in NRC’s regulations. It could also be information that was considered in the

| analyses summarized in the GEIS but that leads to a finding of environmental impact that is

| different from the finding presented in the GEIS (and codified in 10 CFR Part 51).

|

| In addition, a number of issues are specifically precluded from consideration in the

| environmental review process. Two of these issues are the operational issues that require 

| separate National Environmental Policy Act (NEPA) reviews (such as an independent spent fuel

| storage installation and site-specific spent fuel storage and disposal). The fact that these issues

| are outside of the scope of the PNPS SEIS does not mean that they are not being or have not

| been evaluated. They have or will be evaluated in a separate action. The Nuclear Waste Policy

| Act (NWPA) establishes the Federal government’s responsibility to provide a place for the

| permanent disposal of high-level radioactive waste and spent nuclear fuel and the generators’

| responsibility to bear the costs of permanent disposal. The NWPA authorizes and requires the

| U.S. Department of Energy (DOE) to locate and build a permanent repository and an interim

| storage facility and develop a transportation system to safely link nuclear plants to the

| repository and interim storage facility. Until a permanent disposal facility is operational, the

| NRC’s Waste Confidence Rule, found in 10 CFR 51.23, states that “the Commission has made

| a generic determination that, if necessary, spent fuel generated in any reactor can be stored

| safely and without significant environmental impacts for at least 30 years beyond the licensed

| life for operation (which may include the term of a revised or renewed license) of that reactor at

| its spent fuel storage basin or at either onsite or offsite independent spent fuel storage

| installations. Further, the Commission believes there is reasonable assurance that at least one
Appendix A

July 2007 A-65 NUREG-1437, Supplement 29

mined geologic repository will be available within the first quarter of the twenty-first century, and |

sufficient repository capacity will be available within 30 years beyond the licensed life for |

operation of any reactor to dispose of the commercial high-level waste and spent fuel |

originating in such reactor and generated up to that time.” |

|

In response to the second portion of the comment, the PNPS SEIS does address postulated |

accidents. However, incidents resulting from terrorist attacks are not considered postulated |

accidents and are outside the scope of the environmental review. The NRC and other Federal |

agencies have heightened vigilance and implemented initiatives to evaluate and respond to |

possible threats posed by terrorists, including the use of aircraft against commercial nuclear |

power facilities and independent spent fuel storage installations. |

|

Comment: Evacuation Plans have been removed from Kingston Public Library—the only |

documents relative to nuclear power are the NRC newsletters. This is not acceptable. (PNPS- |

D-NN) |

|

Response: The comment is noted. In lieu of maintaining emergency public information at the |

Kingston’s town library, Entergy has opted to distribute emergency public information, including |

evacuation plans, using the following methods: |

|

1. Emergency Public Information Calendar |

|

The Emergency Public Information Calendar is distributed annually by direct mail to |

residents within the 10-mile EPZ. The calendars include informational cards, which can be |

filled out by individuals who need special assistance. A list of such individuals, e.g., |

hearing-impaired, handicapped, or physically impaired, is maintained by the Kingston |

Emergency Management Director. |

|

2. Emergency Public Information Placard |

|

To ensure the transient population is made aware of emergency information, the |

Emergency Public Information Placard is posted in public and recreational areas such as |

parks, campgrounds, beaches, marinas and tourist attractions. Some specific locations in |

the Town of Kinston where Emergency Public Information Placards are being maintained |

include the following locations: (1) Stop & Shop/Summer Hill Plaza; (2) Hannaford |

Supermarket & Pharmacy/Kingsbury Plaza ; (3) Camp Norse; (4) Camp Mishannock; (5) |

Town Landing; (6) Gray’s Beach; (7) Fire/EMS Station — Pembroke Street; (8) Fire/EMS |

Station — Smith Lane; (9) Emergency Operations Center (EOC); (10) Town House; (11) |

Police Station; (12) Independence Mall (Management Office); (13) Department of Streets, |

Trees & Parks; (14) Senior Center; and (15) Post Office. |

|
Appendix A

NUREG-1437, Supplement 29 A-66 July 2007

| 3. Verizon Plymouth/Marshfield/Duxbury/Kinqston/Carver/Plympton Telephone Directory

|

| The Verizon Plymouth/Marshfield/Duxbury/Kingston/Carver/Plympton telephone directory 

| includes an emergency information notice for the permanent and transient populations.

|

| The above excerpt was taken from Part G, Public Information in the Town of Kingston

| Radiological Emergency Response Plan for Pilgrim Nuclear Power Station (revision 12, dated

| 07/2006).

|

| Comment: Raw data and original reports are needed to provide independent evaluation of the

| conclusions reached by the staff. JRWA was not provided with monitoring data and reports, and

| found it was dissatisfied with the synopsis of data provided in the SEIS. When multiple reports

| were available, general data reporting did not seem to agree (i.e. Szal and Pilgrim Report #61).

| We request that raw data and the monitoring reports required by the NPDES permit be made

| available. We request that these documents be on deposit at local libraries, and/or that they be

| made available on-line. JRWA does not present itself as an expert on any of these matters.

| However, we were limited in our ability to get assistance for review and investigation given that

| we only had the conclusions of others to evaluate. Although the SEIS is instructive, conclusions

| made are impossible to evaluate without the benefit of the original material. As studies and

| reports are produced, we request a public repository contain information, monitoring data and

| environmental impact assessments of whatever nature, relative to PNPS. (PNPS-D-NN)

|

| Response: All raw data and original reports that were used in the preparation of the SEIS are

| referenced in the SEIS and/or the Site Audit Summary Report, which can be found in the NRC's

| Agencywide Documents Access and Management System (ADAMS) under Accession No.

| ML06270305.

|

| Comment: Finally, the Staff should confirm that under NEPA, the Staff is precluded from

| issuing a permit for renewed operation of the Pilgrim nuclear power plant unless and until the

| results of the rulemaking proceeding have been taken into account in the Pilgrim license

| renewal case. (PNPS-D-HH)

|

| Response: The comment is related to the Massachusetts Attorney General (MassAG) petition

| for rulemaking regarding the evaluation of environmental impacts of severe spent fuel pool

| accidents. Information regarding the MassAG’s rulemaking petition, can be found at the

| following NRC website: 

| http://ruleforum.llnl.gov/cgi-bin/rulemake?source=prm5110&st=petitions-a. Currently, on site

| spent fuel storage is considered a Category 1 issue, which was evaluated in the GEIS, 
Appendix A

July 2007 A-67 NUREG-1437, Supplement 29

NUREG-1437. In addition, the NRC staff did not find any new and significant information that |

would call the Category 1 issue, raised by the MassAG, into question. Therefore, no changes |

have been made to the SEIS. |

|

NEPA does not preclude the NRC from renewing an operating license while a petition for |

rulemaking is pending. While this petition for rulemaking is under review by the Commission, it |

is the NRC’s policy to continue the license renewal process, as set forth in 10 CFR Parts 51 |

and 54. If the Commission decides to change or rescind regulations regarding the review of |

on-site spent fuel pool storage during the license renewal review, as a result of the rulemaking |

petition, affected licensees would have to comply. Until such direction from the Commission is |

given to the staff, no changes to the license renewal process will be implemented. Therefore, |

no changes have been made to the SEIS. |

|

Comment: ...the conclusion that the impacts are small, excepting for two species of fish, I feel |

result from two parts, one, by ignoring and misinterpreting new and significant information; |

second, by assuming the rules that were largely put in place in the 1970s currently and in the |

future are protected of public health and safety, are being followed to the T by the licensee and |

the NRC is assuring that it is. (PNPS-D-D) |

|

Comment: NRC’s conclusion results from ignoring new and significant information pertaining |

to Pilgrim that has occurred since NUREG – 1437 (GEIS) was written in 1996; and incorrectly |

assuming current NRC regulations are being met by the licensee and that the regulations, |

themselves, reflect current realities and are protective of public health and safety. |

(PNPS-D-EE) |

|

Response: These comments disagree with the staff’s analysis approach and relates to the |

search for new and significant information during the environmental review. The environmental |

review was conducted in accordance with NUREG-1555, Supplement 1, Environmental |

Standard Review Plan Supplement 1: Operating License Renewal and the 10 Code of Federal |

Regulations Part 51. |

|

The NRC staff collected and reviewed information provided by the following: Entergy, various |

federal and state agencies, and mandated public comment periods. The staff reviewed the |

information collected to determine if there was any new and significant information related to |

NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear |

Plants, Category 1, Category 2, or noncategorized issues applicable to PNPS. During the |

course of the environmental review, no new and significant information was identified for any |

Category 1, 2 , or noncategorized issues applicable to the Pilgrim site. This comment provides |

no new and significant information; therefore, no changes have been made to the SEIS. |

|

|
Appendix A

NUREG-1437, Supplement 29 A-68 July 2007

| Comment: When management at Pilgrim and other plants have been unable to meet safety

| criteria and 10 CFR rules, they have been granted exclusions, or the NRC issues general issue

| notices that then excuse all reactors from solving a given issue...there are currently 1,000's of

| these in existence. (PNPS-D-A)

|

| Response: The comment is related to the ability of licensees to request exemptions of various

| NRC licensing requirements. 10 CFR Part 50.12, provides the NRC requirements on how

| licensees may obtain an exemption. The comment provides no new and significant information. 

| Therefore, no changes have been made to the SEIS. 

|

| Comment: I don’t understand why the NRC doesn’t require a license extension to be

| contingent on updating the plant to today’s available technology instead of a patch work

| approach. (PNPS-D-Y)

|

| Response: It is assumed that this comment is in reference to the PNPS cooling system. NRC

| regulations require Entergy to comply with the Clean Water Act and the associated

| requirements imposed by USEPA Region I as part of their NPDES permit. However, NRC does

| not have delegated authority under the Clean Water Act to mandate mitigation measures

| associated with aquatic matters, specifically mitigation measures associated with PNPS's once-

| through cooling system. NRC, through development of the SEIS, analyzes the potential impacts

| of extending the plant’s operating license. Therefore, making a license extension contingent on

| updating the plant to today’s best technology available is outside the scope of the SEIS.

|

| A.2.2 Comments in Support of License Renewal at Pilgrim Nuclear Power

| Station

|

| Comment: Mass AREA and its members fully support a license extension for the Pilgrim

| Nuclear Power Plan. On a typical day, Pilgrim provides seven to nine percent of the

| Commonwealth's electricity. Without it, Massachusetts and the region as a whole could face

| power supply shortages, including rolling blackouts, a lot sooner than predicted of next year.

|

| Perhaps one of the most important issues that led Mass AREA to support a license extension

| for Pilgrim is the fact that the plant operates safely and continuously earns the NRC's highest

| safety rating of green. We also know that NRC staffers are on-site at the plant each and every

| day overseeing operations and helping to maintain a safe and secure environment.

|

| The production and distribution of electricity, whatever the source, is inherently a challenging

| safety issues, yet nuclear power has proven safe. In 50 years of commercial operations, there

| has never been a radiological death at any U.S. nuclear plant. (PNPS-D-E, PNPS-D-P)

|

|
Appendix A

July 2007 A-69 NUREG-1437, Supplement 29

Comment: Opponents of the Pilgrim Power Plant often say we will be better off if the |

generator was decommissioned. However, the baseload power that would replace Pilgrim |

would most likely come from sources that are more expensive, far more polluting or both. At |

this time, wind and other renewable energy technologies simply can not generate the massive |

baseload power that would be needed were Pilgrim to cease operations. Moreover, the |

electricity that Pilgrim supplies is created without generating any greenhouse gas emissions |

and therefore it does not contribute to global warming. |

|

Pilgrim also mitigates the production of hundreds of tons of sulfur dioxide and nitrogen oxides, |

chemicals which are harmful to human health, especially among children and the elderly, these |

health and environmental benefits alone are enough argument for renewing Pilgrim's license to |

produce power. (PNPS-D-E, PNPS-D-P) |

|

Comment: In summary, Mass AREA has weighed all of the environmental, economic and |

energy supply traits of Pilgrim, particularly its long record of safety, and concluded that the |

Pilgrim Nuclear Power Plant is vital to the region, state and local economy for three reasons, its |

environmentally sound operations, its economic contribution to the local community through the |

provision of jobs and purchase of goods and services and its provision of reliable, low cost |

electricity. Mass AREA encourages the NRC to grant Entergy's Pilgrim station an extension of |

its license so that it can continue to safely operate for an additional 20 years. (PNPS-D-E, |

PNPS-D-P) |

|

Comment: In addition, the critical role Pilgrim plays in supply and diversity, its role in producing |

electricity without air pollutants and laudatory, no pollution contributes to the state's goal of |

reducing greenhouse gas emissions. Achieving these goals will have some cost impacts on all |

consumers, but it's great to know that Pilgrim station provides economical electricity without a |

carbon footprint. Pilgrim also contributes to meeting and sustaining the electricity supply, as our |

demand grows on average of about two percent a year compounded. (PNPS-D-F) |

|

Comment: With that as context, AIM believes that the draft environmental impact statement |

adequately complies with the requirements of the act, AIM urges the commission to adopt the |

recommendation of the report to continue consideration of relicensing. Given Pilgrim's positive |

contributions to the reliability, supply and cost of electricity in this state and its significant |

environmental benefit, we also would urge the commission to in fact relicense this plant. |

(PNPS-D-F) |

|

Comment: I am here representing the South Shore Chamber of Commerce, which is an |

independent association of 2,000 businesses, including health care and educational institutions |

and nonprofit organizations in the communities from Boston to Plymouth, we are the largest |

chamber of commerce in Massachusetts. We are an association of business people who are |

committed to the economic health and the quality of life of the communities that we serve. |
Appendix A

NUREG-1437, Supplement 29 A-70 July 2007

| After evaluating the plant and its contributions to our region, its economic impact, the

| employment base, its environmental record, the addition, the very critical addition that it makes

| to a diverse and reliable energy supply and the plant's presence and overall contributions to the

| quality of life in our region, our leadership voted, after a health discussion, voted and voted

| unanimously to encourage the Nuclear Regulatory Commission to approve in a timely fashion

| the full relicensing of the nuclear power plant.

|

| We are pleased to have this safe, secure, reliable source of power and its significant beneficial

| contributor to the employment base and to the overall economic well being as part of our region

| and we thank you very much. (PNPS-D-H)

|

| Comment: I support Entergy's intention to apply for an extension of its NRC operating license

| beyond the current 2012 expiration date. My reasons are, one, this is hardly a new or dramatic

| change, it's the very same plant that's been operating quietly, safely and efficiently, largely out

| of view, having no massive cooling tower or towering smokestack, which some people want to

| change, for 33 years without major incident, the plant appears to be well managed and

| maintained and protected. (PNPS-D-L)

|

| Comment: Three, it produces no discharge of carbon dioxide greenhouse gas, nitrous oxide

| orange plume like the oil-fired plant down on the canal, sulfur oxide precursors of acid rain or

| mercury emission to enter the seafood chain as from coal-fired plants. Radioactive discharge

| from vent stacks is negligible to nonexistent, as measured by on-site monitors meeting

| regulatory requirements. No shipment and unloading of heavy fuel, oil or LNG impacts our local

| area. (PNPS-D-L)

|

| Comment: From a regional economic jobs and quality of life standpoint, we need both the

| electricity and the jobs that Pilgrim Nuclear plant provides. If we know that the plant is safe,

| which it is, if we know the workers are experienced and skilled, which they are, if we know these

| workers need these good jobs, which certainly they do, if we know the power is produced at low

| cost and is indispensable to our grid, which is true, if we know the contribution Pilgrim makes to

| the state's economy are immeasurable and irreplaceable, which they are --. I lost my fourth

| page. Then there are no reasons why the Pilgrim Nuclear Power Plant should be denied license

| renewal but rather a host of reasons why it should be allowed to continue being a key focal

| point of our energy and economic future. (PNPS-D-N)

|

| Comment: In my opinion, this is a no-brainer, jobs are so important. We represent not only the

| workers at Pilgrim Power Station, we represent workers at fossil plants up in Cambridge, up in

| Everett, in South Boston, in Charlestown, in Weymouth and I could tell you the training that the

| people receive down at Pilgrim to run that plant is second to none, I have never seen anything

| like it. (PNPS-D-O)

|
Appendix A

July 2007 A-71 NUREG-1437, Supplement 29

Comment: So I just want to say, in closing, I think we have an obligation to our society and the |

fact that this power is needed on the grid. I think we have an obligation to the community that it |

serves and the fact that the people that work there thrive in the community. This plant exudes |

community involvement, I mean you cannot get a better example of how a business is helping a |

community. (PNPS-D-O) |

|

Comment: I support relicensing of Plymouth station, nuclear power is the only viable long-term |

solution to our energy needs. It's cost effective, it's reliable, it's clean. Plymouth station is one of |

the largest local employers, it's one of the largest local industries, the majority of Plymouth |

station employees live in the county. In addition to protecting land, making sizable charitable |

donations to local nonprofits, Entergy and Entergy employees pay taxes, taxes and fees that go |

to the local operating budget, the local schools, the local police and fire. |

|

Payroll at Entergy or payroll at the station is $55 million between permanent employees and |

contractors, that's $55 million injected into the local and surrounding economy, that's $55 million |

going into local shops, local restaurants and most important, our local housing market. |

Plymouth station is a valuable part of the local and surrounding community, I support the |

relicensing of Plymouth station. (PNPS-D-R) |

|

Comment: I do look at it as, and I've listened to a number of people, Pilgrim has produced |

jobs, the people that work at Pilgrim are our neighbors, we have been living with them for 35 |

years, there has been no issues. We do have cost effective power, they live beside us, what's |

the problem? (PNPS-D-V) |

|

Comment: The people who built Pilgrim have done a better job, for example, that the |

Russians. The people who maintain Pilgrim have done a better job than anywhere else, I think |

we have to recognize it. (PNPS-D-V) |

|

Comment: I think we are dealing with obvious technological advancements, we are dealing |

with people who care about how the energy is produced, who live beside the plant, who live in |

our neighborhoods and I think we need to recognize that Pilgrim should be relicensed. |

(PNPS-D-V) |

|

Comment: And as a resident of Plymouth, I know of no environmental problems that Pilgrim |

has created, according to what I've read from Mass DEP, the Federal EPA or the NRC. |

(PNPS-D-V) |

|

Response: These comments are noted. The comments are supportive of license renewal at |

PNPS, and are general in nature. The comments provide no new information. Therefore, no |

changes have been made to the SEIS. |

|
Appendix A

NUREG-1437, Supplement 29 A-72 July 2007

| A.2.3 Comments in Opposition of License Renewal at Pilgrim Nuclear

| Power Station

|

| Comment: I feel, in the long run, fission-based power is not the answer and I personally do not

| want to see nuclear power plants' lives extended any more than they have to be. (PNPS-D-C)

|

| Comment: I've always been interested in Pilgrim, but common sense tells me it's time to start

| phasing out of this type of electrical source. (PNPS-D-C)

|

| Comment: I hope you will thoughtfully consider the arguments I have presented and take the

| bold step of refusing to relicence the Pilgrim Nuclear Power Station. (PNPS-D-DD)

|

| Comment: And so, by continuing to ignore the realities, what we are doing is depriving

| ourselves in the future of a cleaner, safer and cheaper source of energy for ourselves and for

| the generations down the pipe. (PNPS-D-Q)

|

| Comment: Given the many unanswered or inadequately answered, inadequately answered

| concerns about the environmental and public health impacts of extending the life of this plant,

| we respectfully ask that the commission deny the relicensing of the nuclear power plant. We

| strongly believe that this plant does not deserve another 20 years of operation and the South

| Shore and the rest of Massachusetts definitely does not deserve another 20 years of the

| impacts from this plant. (PNPS-D-S)

|

| Comment: I am against the re-licensing of Pilgrim in 2008. (PNPS-D-X)

|

| Comment: Presently, and for decades, Pilgrim has been a dark shadow of legitimate concern

| in the region. Everyone knows in his/her heart that Pilgrim is the wrong energy choice for our

| future. (PNPS-D-X)

|

| Comment: Members of the Nuclear Industry, certain non-profit organizations, members of

| certain universities long associated with DOE (MIT), and various departments and facilities

| associated with the government of the United States of America have in fact and deed through

| private meetings and quietly orchestrated work groups conspired to force funding into, and

| create a scenario whereby Nuclear is forced on America as the only workable option to resolve

| Global Warming, as it witnessed by the program Nuclear Power 2010/GNEP as will be proved

| by all the underlying documents that unveil the steps implemented over a period of over eight

| years by the afore mentioned individuals and groups to position nuclear as the favorite horse in

| a wrongful attempt to give nuclear energy a rebirth both here in America, and abroad. In short,

| we have an orchestrated RICO like attempt to not only prop up a failing industry, but to extort

| money from both rate payers, and the American tax payers with the help of every level of our 
Appendix A

July 2007 A-73 NUREG-1437, Supplement 29

American Government up through and including President George Bush who was bought off |

with overly generous donations to his campaign war chest. (PNPS-D-A) |

|

Comment: These comments are alleged specifically against not just the Pilgrim plant, and in |

opposition of the relicensing of this failing facility, but as much as possible are a condemnation |

of and a verified complaint against every nuclear reactor in America, a verified complaint |

against the nuclear industry, and further, and allegation against the Nuclear Regulatory |

Commission itself who has implemented a plan that places company profits ahead of human |

health and safety, as well as the being and protection of our environment. (PNPS-D-A) |

|

Comment: The DOE, NRC, NEI, various assorted federal laboratories and George W. Bush, |

as well as key members of his staff have in fact and deed colluded with all key players within |

the nuclear power industry to artificially prop up, and renew a failing industry here in America |

and abroad in a wrongful attempt to extort money from both rate payers, and American Tax |

payers in direct violation of the RICO Act (Title 18, United States Code, Sections 1961-1968) |

and specifically, 1962(c). (PNPS-D-A) |

|

Response: The comments are noted. The comments oppose nuclear power in general as well |

as the license renewal at PNPS, but do not provide any new and significant information. |

Therefore, no changes have been made to the SEIS. |

|

Comment: Generically the Draft EIS is environmentally racist, fashioned in such a way as to |

mitigate and or eliminate from consideration in the license renewal process any and every |

element, of the Pilgrim Nuclear Reactor specifically, and all license renewals in generally, that |

negatively impacts the community (community and those within it are in fact and deed an |

environment unique unto itself, and occupied by members of the animal kingdom, specifically |

human beings) being forced to accept the ongoing operation of this unsafe, and fatally flawed |

reactor, and specifically attempts to ignore A) the environmental impacts associated with the |

physical degradation of the reactor and it's component parts, B) refuses to properly factor in the |

cumulative effects of the environmental degradation from continued operation of the plant past |

it's date of license expiration, and C) wrongfully tries to remove from the consideration process |

of re licensing serious safety and security issues at the plant that present very real and |

imminent dangers to both human health and the environment. Further, the reactor itself, and all |

reactors in the American fleet are no longer the reactors that were originally licensed by the |

NRC. (PNPS-D-A) |

|

Comment: In general, the Pilgrim plant suffers from the same persistent problems of safety, |

security and storage as the nuclear industry in general. Even within the narrow scope of this |

review of the impacts of relicensure, there is ample evidence for denying the extension. Daily |

radiation releases, the vast amounts of radioactive waste stored on site at the plant, damaged |
Appendix A

NUREG-1437, Supplement 29 A-74 July 2007

| fisheries, and the risk of a terrorist attack are just some of the compelling reasons for letting the

| plant be decommissioned at the end of its planned lifespan - in 2012. 

|

| Given the many unanswered or inadequately answered questions about the environmental and

| public health impacts of extending the life of this plant, we respectfully ask that this commission

| approach the re-licensing of the Pilgrim nuclear plant with great caution and take into account

| the many concerns raised by the opponents of re-licensing. We are confident that, taking the

| entire picture into account, there will be ample grounds for denying relicensure. (PNPS-D-FF,

| PNPS-D-GG, PNPS-D-KK)

|

| Comment: The three signatories strongly support the comments submitted by Pilgrim Watch.

| We concur that the draft Environmental Impact Statement ignores new and significant

| information and relies on incorrect assumptions about Nuclear Regulatory Commission (NRC)

| regulations as they relate to environmental and public health impacts. (PNPS-D-FF,

| PNPS-D-GG, PNPS-D-KK)

|

| Comment: Please be advised that I support and concur with the comments submitted by

| Pilgrim Watch dated February 5, 2007, regarding the above captioned matter on the

| re-licensing of the Pilgrim Nuclear Power Facility. (PNPS-D-PP)

|

| Comment: We strongly support the efforts and comments of Pilgrim Watch and the Office of

| the Attorney General of Massachusetts, among other groups opposed to relicensing of the

| Pilgrim Nuclear Power Plant.

|

| We concur with conclusions that the draft environmental impact statement ignores new and

| significant information and relies on incorrect assumptions about NRC regulations, as they

| relate to environmental and public health impacts. The Pilgrim plant suffers from the same

| persistent problems of safety, security and storage as the nuclear industry in general. 

|

| Even within the narrow scope of this review of the impacts of relicensure, there are significant

| impacts that should be grounds for denying the extension. Daily radiation releases, the vast

| amounts of radioactive waste stored indefinitely on-site at the plant, damaged fisheries and the

| risk of a terrorist attack are just some of the compelling reasons for letting the plant be

| decommissioned at the end of its planned life span in 2012. (PNPS-D-S)

|

| Response: These comments are noted. The comments oppose nuclear power in general as

| well as license renewal at PNPS, but do not provide any new information. Therefore, no

| changes have been made to the SEIS.

|

|
Appendix A

July 2007 A-75 NUREG-1437, Supplement 29

A.2.4 Comments Concerning Surface-Water Quality, Hydrology, |

Groundwater and Uses Issues |

|

Comment: Testing Silver Lake - it provides drinking water to Brockton. There is no indication |

that the lake has been tested for radionuclides; and Brockton adds an environmental justice |

dimension, due to its economic profile. (PNPS-D-EE) |

|

Comment: I do want to point out that at the ten mile limit is Silver Lake which supplies ten |

million gallons a day to the Brockton water supply system in the City of Brockton, which is a |

social justice community, and I do not believe there has been monitoring of Silver Lake, |

although I could be wrong, regarding emissions and those kinds of long-term impacts. |

(PNPS-D-I) |

|

Comment: JRWA briefly reviewed other aspects of the report, including 2.2.8.2 Public |

Services. The "Selected Plymouth County Public Water Supply Systems and Capacities in |

2003" ignores the largest water supply in the county, the surface water reservoir at Silver Lake. |

Silver Lake is 640 acres, and is just beyond the 10 mile EPZ in the towns of Kingston, |

Pembroke, Plympton and Halifax. It is the primary water supply for nearly 100,000 users in |

Brockton and Whitman. At this time an average of about 10 million gallons a day are piped to |

those communities. Brockton qualifies as a social justice community. Silver Lake should be |

regularly monitored for radiological pollution. (PNPS-D-NN) |

|

Comment: USGS performed water quality analysis of regional drinking water wells in 2005 in |

response to an EPA general program. The presence of Strontium was included in the analysis, |

and results were provided by weight-without discussion of radioactivity. The highest levels of |

Strontium in the region were found in the Kingston Millgate well. Discussion with USGS |

confirmed that the level was high, and that no lab notes provided a further description regarding |

any analysis for radioactive Strontium-90. JRWA believes that off-site sampling of groundwater |

should be included to assess impacts from past and present radioactive venting of gases at |

Pilgrim. Radiological monitoring does not include this human and environmental exposure |

pathway. Ingestion of Strontium-90 is tolerated at MUCH lower doses than airborne exposure. |

(PNPS-D-NN) |

|

Comment: JRWA believes that off -site sampling of regional groundwater should be included |

to assess impacts from past and present radioactive venting of gases at Pilgrim. Radiological |

monitoring does not include this type of sampling and the exposure pathway to residents of the |

area is direct. Dangerous levels of dosing are entirely possible, and have the potential to be |

long lasting. In the USGS testing, only a few representative wells were sampled and analyzed. |

(PNPS-D-NN) |

|

|
Appendix A

NUREG-1437, Supplement 29 A-76 July 2007

| Comment: The Millgate well is supplied by groundwater which, if not used in drinking water

| distribution, will ultimately flow to the Jones River. Groundwater in areas of Plymouth flows to

| Cape Cod Bay. JRWA requests that PILGRIM and NRC test for the presence of Strontium-90 in

| regional groundwater. (PNPS-D-NN)

|

| Response: During the environmental review, the NRC evaluated the existing radiological

| monitoring program and other sampling data for PNPS. The Radiological Environmental

| Monitoring Program (REMP), defined in the Offsite Dose Calculation Manual (ODCM), includes

| direct radiological monitoring, as well as, radiological analysis of air emissions, surface water,

| and terrestrial and aquatic biota. The locations of these samples have been selected to

| evaluate potential impacts in a wide area, in all directions from the plant, including the area

| referenced by the commenters. Radiological analyses of these samples have not detected any

| radionuclides that could be attributed to facility operations, or that could have resulted from

| airborne emissions.

|

| Although the REMP does not include sampling of groundwater, sampling and radiological

| analysis of three groundwater wells near PNPS was performed for a different purpose in 1999. 

| These samples did not identify any radionuclides that could have been due to direct releases

| from the facility, or from airborne emissions.

|

| Based on the lack of facility-related radionuclides, including Strontium-90, in the groundwater

| samples close to PNPS, or in the surface water and air emissions samples located northwest of

| the facility, NRC concludes that it is unlikely that groundwater or surface water resources in this

| northwest area have been affected, and therefore, impacts during the relicensing period are

| unlikely.

|

| Currently, the ODCM does not require groundwater monitoring, specifically because

| groundwater at the site discharges directly to Cape Cod Bay. In addition, the ODCM does not

| require sampling of Silver Lake, because it requires sampling of surface water bodies that are

| closer to the facility and, therefore, more likely to be impacted. Nonetheless, the ODCM does

| require that NRC review the sampling locations annually and modify them as necessary. These

| comments are noted, but provide no new and significant information. Therefore, no changes

| have been made to the SEIS.

|

| Comment: Page 2-10, Line 38 - Based on the PNPS NPDES Permit and Table 2-2 of the

| PNPS DSEIS, there are no temperature limitations on the service water. Therefore, the

| sentence "The permitted change in temperature across the service water is 5 to 10°F." is

| incorrect and should be deleted. (PNPS-D-MM)

|

|
Appendix A

July 2007 A-77 NUREG-1437, Supplement 29

Response: The text in Section 2.1.3. has been modified in response to this comment. |

|

Comment: Page 2-23, Line 33 - The sentence "Notes: For the majority of outfalls, the pH shall |

not be greater than or less than 0.5 standard units of the influent." is inaccurate. Only four |

outfalls have the "0.5" limit while one outfall has no pH limit, and five outfalls have pH values |

that range from 6.0 to 8.5. Therefore, the majority of the outfalls do not have the "0.5" value. |

(PNPS-D-MM) |

|

Response: The note associated with the table was modified accordingly. |

|

A.2.5 Comments Concerning Aquatic Ecology, Terrestrial Ecology, |

General Ecology, and Threatened and Endangered Species Issues |

|

Comment: Cape Cod Bay is an ocean sanctuary under Massachusetts state law, that wasn't |

mentioned in the report. It is a violation of state law that anything effect a habitat and I think that |

would mean that the fish species considerations has to be broadened and it certainly has to |

include such species as shad and a the American Eel, and perhaps even the Sand Tiger Shark |

which again wasn't mentioned in the report but is not only becoming more of a species of |

special concern, it also is becoming more frequent in our waters or it appears to be so. |

(PNPS-D-I) |

|

Response: Chapter 123A, Section 16, of the General Laws of Massachusetts notes that |

operation and maintenance of existing municipal, commercial, or industrial facilities and |

discharges that are approved and licensed by appropriate federal and state agencies are |

permitted activities in ocean sanctuaries. Although the proposed action may affect the habitat; |

as long as the action is permitted by the Commonwealth, it is allowable under state law. |

Additional text will be added to Section 2.2.5.3 noting that Cape Cod Bay has been designated |

as an Ocean Sanctuary by the Commonwealth of Massachusetts. However, this does not |

affect the list of important and rare marine species, identified in this section, that warrant |

evaluation in the SEIS. |

|

Comment: Page 4-22 - Figure 4-1 does not represent "the loss of adults from the local stock," |

it is the "numbers of equivalent adult winter flounder estimated from entrainment and |

impingement data at PNPS." It should be made clear that the equivalent adult method yields a |

hypothetical estimate not an actual measurement. (PNPS-D-MM) |

|

Response: The comment is noted and the edits suggested by the commenter have been |

incorporated into the text that describes Figure 4-1. |

|

|
Appendix A

NUREG-1437, Supplement 29 A-78 July 2007

| Comment: We are starting to see a lot less native species and a lot more altered species and

| this is not good for use in the long run, we are also seeing entrained in the system the

| American Lobster, this is a commercial fishery also and that deserves more attention, I believe,

| than in the report. (PNPS-D-I)

|

| Response: The NRC staff has not identified a decline in species diversity or abundance in

| Cape Cod Bay due to operation of PNPS. The American lobster was discussed as an

| important benthic invertebrate species in Section 2.2.5.3.4, and entrainment, impingement, and

| thermal effects on the lobster were evaluated in Section 4.1. The comment provides no new

| and significant information; therefore, no changes have been made to the SEIS.

|

| Comment: Page 4-15, Line 14, 19-20, and 21 - Regarding " ... significant events .. ," and

| ".,.high entrainment events can contribute a significant percentage of the overall annual

| entrainment numbers for certain species. " This statement(s) is misleading because - although

| its obvious that high ichthyoplankton densities in close proximity to the CWIS are expected to

| increase the annual entrainment numbers - it has not been determined that these are "events,"

| or that they are anything more than natural fluctuations, when compared with the long-term

| data set. Use of the word "significant" is improper because it is in quotes yet it is not used at all

| in the pertinent section of the referenced Annual Report, and it is not statistically appropriate.

| This statement is not a basis for determining a trend or establishing that an impact exists, so its

| relevance is unclear. (PNPS-D-MM)

|

| Response: Section 4.1.1.2 has been edited to note that these events are exceptionally high

| (as stated in the PNPS NPDES permit) as opposed to significant.

|

| Comment: I also have questions regarding some terminology. On page 47 of the PNPS

| Supplement 29 Draft it states: "The service water system is continuously chlorinated in order to

| control nuisance biological organisms in the service water discharge." I think it is vitally

| important to define here what a "nuisance biological organism" is and also regard definitively

| how this organism operates solely inside the confines of the PNPS ecosystem. This unidentified

| organism could play a vital part in the survival of this particular diverse marine ecosystem. 

| (PNPS-D-LL)

|

| Response: The nuisance biological organisms referred to are biofouling organisms (such as

| mollusks, barnacles and other invertebrates, algae, and bacteria) that attach themselves to

| facility surfaces exposed to water. Biocides such as chlorine are used to control their growth

| within the facility, but discharges of biocides outside of power plants have been found not to

| have significant impacts. The discharge of chlorine and other biocides has been determined to

| be a Categoty 1 issue for license renewal for all nuclear plants. Section 2.1.3 has been

| modified in response to this comment.

| .
Appendix A

July 2007 A-79 NUREG-1437, Supplement 29

Comment: Essential Fish Habitat was evaluated for many species. JRWA is concerned that |

the staff conclusion is not substantiated and should be reconsidered. The staff concludes |

[E-105] that "Continued operation of the PNPS cooling water system was determined to have a |

minimal adverse effect on EFH for 17 species, a less than substantial adverse effect on EFH for |

8 species, and a substantial adverse effect on EFH for 7 species".... (emphasis added) And |

goes on to conclude: "Within the overall Cape Cod Bay ecosystem, ...continued operation of |

the PNPS cooling water system would have a minimal adverse effect on EFH." |

|

We believe this is a wholly unsubstantiated conclusion because the staff has not evaluated the |

cumulative impact of fish loss to the general fishery. In our view, because Rainbow smelt, |

Alewife, Atlantic menhaden, Atlantic mackerel, Atlantic silverside, Blueback herring and winter |

flounder are important prey for Striped bass and Atlantic cod (as examples), the loss of |

sufficient populations of these smaller fish will ultimately impact on the population of the more |

valued Striped bass and cod-and therefore is a matter of great concern, that should not be |

dismissed. Many of the fish suffering large losses are now highlighted for dangerously low |

population levels (river herring, smelt, and menhaden) in the region although no NMFS |

management plan yet exists. (PNPS-D-NN) |

|

Response: The commenter notes the potential for cumulative impacts associated with |

operation of the PNPS cooling water system as a result, in particular, of reduced prey |

populations. The EFH Assessment considered impacts to prey of EFH species as one of the |

metrics used in determining the degree of impact to EFH. The NRC staff also evaluated the |

potential for cumulative impacts in Section 4.8.1 of the DSEIS. The comment provides no new |

or significant information; therefore, no changes have been made to the SEIS. |

|

Comment: In the same way that there is concern for the EFH for fisheries determined by |

NOAA to require Management Plans pursuits to the Magnuson-Stevens Act, so too should |

there be concern for the habitats essential to fish species that are experiencing precipitous |

population decline such as the Rainbow smelt, Alewife and Blueback herring, among others-- |

the cumulative impact resulting from the plant impingement and entrainment on water quality, |

temperature and population abundance on these fish, and thus on long term survivability, was |

not adequately examined. (PNPS-D-NN) |

|

Response: As described in Section 2.2.5.3.1, the SEIS identified a group of important fish |

species for evaluation as representatives of the potentially affected fish community in Cape Cod |

Bay. These included species that are commercially or recreationally valuable, species critical to |

the ecosystem, and species for which essential fish habitat (EFH) has been designated in the |

vicinity. The rainbow smelt was among the important species evaluated throughout Section 4.1 |

but does not have designated EFH. The blueback herring and alewife are very similar and are |

often referred to collectively as “river herring.” Neither species was determined to have EFH in |

the vicinity of PNPS, but both are commonly impinged at PNPS, with greater numbers of |
Appendix A

NUREG-1437, Supplement 29 A-80 July 2007

| alewife being affected. Although only the alewife was chosen as one of the important species

| for evaluation, it provides a conservative representation of potential impacts on the blueback

| herring due to their similar life histories and habitats. Due to limitations associated with each

| method of assessing fish populations and the significance of impacts, multiple methods were

| considered as lines of evidence in arriving at conclusions based on the weight of the available

| evidence. The basis for the conclusions regarding the species evaluated are described in

| Sections 4.1.1 and 4.1.2. The level of significance of impacts was assessed based on the

| three-level system (small, moderate, or large) developed by NRC and in accordance with the

| Council on Environmental Quality's regulations (40 CFR 1508.27) requiring the assessment to

| consider the context and intensity of the impact. Cumulative impacts from multiple factors were

| considered in the assessment and discussed in Section 4.8. The comment provides no new

| and significant information. However, this new issue of aquatic habitat (other than designated

| EFH) has been added to the SEIS and is discussed in Section 4.7.

|

| Comment: Blueback herring spawn in the Jones River during the same general period as the

| alewife, preferring slightly colder and moving water. The spawning migration begins about in

| April for river herring and extends into June. The run seems to include fish of all age classes so

| it is difficult to determine without additional study at what the age the fish are spawning. 

| Blueback herring have different habitat requirements, at least in the river, yet they were not

| discussed in the SEIS. However, Marine Ecology Studies Related to the Operation of Pilgrim

| Station; Annual Report #61 for the year 2002, show that blueback herring were the dominate

| species impinged in November that year and fifth in rank for the year (Table 5). Yet this

| species is not evaluated in the SEIS. (PNPS-D-NN)

|

| Response: As described in Section 2.2.5.3.1, the SEIS identified a group of important fish

| species for evaluation as representatives of the potentially affected fish community in Cape

| Code Bay. These included species that are commercially or recreationally valuable, species

| critical to the ecosystem, and species for which essential fish habitat (EFH) has been

| designated in the vicinity. The blueback herring and alewife are very similar and are often

| referred to collectively as “river herring.” Neither species was determined to have EFH in the

| vicinity of PNPS, and both are commonly impinged at PNPS, with greater numbers of alewife

| being affected. Although blueback herring have different habitat requirements in the river, the

| habitat in the immediate vicinity of PNPS, which is marine, is the same as for the alewife. 

| Although only the alewife was chosen as one of the important species for evaluation, it provides

| a conservative representation of potential impacts on the blueback herring. The comment

| provides no new and significant information; therefore, no changes have been made to the

| SEIS in response to this comment.

|

| Comment: That PNPS is supporting hatchery release of winter flounder, is not itself sufficient

| to address all the impacts to fish and aquatic organisms. In fact, hatchery fish may not even be

| good mitigation for winter flounder, as over time the genetic pool of the species may become so
Appendix A

July 2007 A-81 NUREG-1437, Supplement 29

narrow as to threaten the ability of the Cape Cod Bay flounder to adapt, or overcome adversity. |

A hatchery mitigation and release plan cannot become a license to kill flounder, nor can a |

program for growing winter flounder for release into the wild address the impacts to the other |

species of fish, such as Rainbow smelt, Alewife, Blueback herring and Atlantic mackerel or |

menhaden. It should be required that PNPS assist these populations of concern by correcting |

its flawed intake structure and assist in habitat restoration activities in the region. (PNPS-D-NN) |

|

Response: NRC’s regulations require the staff to analyze potential impacts of renewing the |

plant’s operating license and of alternatives to license renewal. Section 4.1.4 provides an |

overview of potential mitigation measures to minimize adverse impacts to marine aquatic |

resources. Therefore, a detailed evaluation of the potential feasibility of each of these |

measures was not conducted. Requiring modifications to the intake structure and/or requiring |

habitat restoration activities are beyond NRC’s regulatory authority but would be within EPA’s |

authority under the Clean Water Act. This comment provides no new and significant |

information; therefore, no changes have been made to the SEIS. |

|

Comment: The DSEIS at page 4-38 indicates that NRC staff have not found that the pilot |

flounder stocking "has substantially offset impacts from continued operation of PNPS to the |

local winter flounder population." The DSEIS also does not provide any new information or |

evidence to suggest that hatchery fish can persist in the environment and recruit to the adult |

population. Thus, the DSEIS appears to lack support for the assertion that if the current winter |

flounder stocking program is expanded, that it "may have a beneficial impact" on the local |

population (DSEIS page 4-38). If the continuance or expansion of the stocking program |

remains a reasonably foreseeable option for Pilgrim Station, we recommend that the FSEIS |

more fully explore whether stocked fish survive to reproduce and the potential impacts of |

hatchery-reared fish on the native population. (PNPS-D-OO) |

|

Comment: Winter Flounder, as previous speakers have talked about, have been deemed a |

moderate, I think I have the right terminology, a moderate impact instead of a small impact, |

meaning that there has been some mortality associated with Pilgrim's activities. |

|

So about eight years ago people from Pilgrim and myself had worked on how to possibly make |

that a small impact, meaning how do you deal with this problem of killing Winter Flounder or |

impinging Winter Flounder? Basically, since eight years ago, we've been taking adult Winter |

Flounder that are natural wild stocks and spawning them. And in that process, we've basically |

reproduced 33 millimeter hatchery fish, which would be the same as a wild fish, and placed it |

out into our harbors very close to us right now, and done studies to see how they survive and if |

it is possible to replenish the stocks by use of hatcheries for mitigation. |

|

And over the past eight years, we have compiled a whole bunch of data, nothing seems to be |

negative, everything seems to be showing that, at a larger scale, you could make this problem |
Appendix A

NUREG-1437, Supplement 29 A-82 July 2007

| mitigated by the use of hatcheries, making it a small impact that Entergy has or even a no

| impact with Winter Flounder, I know nothing about the other ones. Basically, I can support that

| idea with the idea that aquaculture of hatcheries have been used for decades with replacing fish

| stocks, this has, we have seen this work with shellfish in Massachusetts and all kinds of other

| fisheries around the world. 

|

| The potential benefit to this being used as a mitigation tool would be to the community, giving

| jobs to the hatchery and also giving more fish for the fishermen to catch. In conclusion, I

| basically believe that Pilgrim could have no impact on the Winter Flounder population, in my

| mind, by use of hatcheries and that the benefits could really be to the communities, to the

| fishermen and also for jobs. I think that if we, if the number of hatchery released fish was

| increased, that they wouldn't have a problem to augment any potential problem associated with

| Winter Flounder. (PNPS-D-J)

|

| Response: NRC staff reviewed the results of the winter flounder hatchery pilot program. Data

| contained within these results were not sufficient to determine whether a larger-scale hatchery

| program would benefit the local winter flounder population or the community. Requiring habitat

| restoration activities is beyond the NRC’s regulatory authority but would fall under the EPA’s

| authority under the Clean Water Act. This comment provides no new and significant

| information; therefore, no changes have been made to the SEIS.

|

| Comment: There appear to be many methods used to determine impact, each with

| drawbacks. It must be determined before going forward with the re-licensing process what

| methods provide the most reliable estimates of impact, with a detailed rationale; a requirement

| that these methods are followed by the licensee unless better methods are established and

| independently approved. 

|

| We understand that there has been no policy statement regarding losses on a square mile

| basis by any state or federal agency. NRC should in its review process determine what percent

| loss is a significant detriment to any population [figure depending on population], with a detailed

| rationale. 

|

| Entrainment: Winter Flounder - methods used by Entergy to determine impact

|

| 1. Equivalent adult method: "researchers conducting this work have assumed an otter trawl

| efficiency of 50%, but the actual efficiency may be much lower (or higher), which would alter the

| number of fish in the study area per square mile and the apparent impact. Second, entrainment

| sampling results are quite variable. Third, it is difficult to determine the accuracy, and therefore,

| the applicability, of the survival matrix used in estimating equivalent adults."

|

|
Appendix A

July 2007 A-83 NUREG-1437, Supplement 29

Whether or not these levels of impact are a "significant" detriment to the population, and will |

result in slowing the return to much higher population densities, is currently unknown and a |

policy statement regarding losses on a square mile basis has not been issued by any of the |

state or federal agencies. EPA Region I has stated in the past that population impacts of 5% or |

greater are typically of concern. However, to DEP's and Pilgrim Watch's knowledge, the |

geographic bounds of this particular population have not been agreed upon by state or federal |

agencies. |

|

2. 2nd method - estimate the percentage of the total larval population passing in front of the |

facility that is entrained. |

|

3. The third method used by the facility to evaluate impact was the RAMAS (Risk Analysis |

Management Alternative System; Ferson, 1993) winter flounder model. It was used from |

1999-2001 to further evaluate the effects of the facility on the Cape Cod Bay winter flounder |

population. Results suggested that stock reductions from 2.3 to 5.2% might occur as the direct |

result of entrainment at the facility. |

|

It should be determined and agreed upon by NRC, appropriate state agencies and independent |

analysts what method or methods actually provide accurate information needed to assess more |

accurately impact before the license is approved. |

|

4. An analysis of Backwash effects has not been performed to the best of our knowledge. |

|

4.1.4 Potential Mitigation Measures: 12 measures are listed; however "The NRC staff has not |

conducted an analysis of each of these measures relative to their applicability to PNPS... It is |

expected that a more thorough analysis of the costs and benefits of these technologies would |

be conducted as part of the 316(b) CDS currently being conducted by PNPS in support of the |

NPDES permit renewal. |

|

" Missing from the list is thermal discharge - allowable maximum temperature of the water |

discharged and its measurement. Discharge temperature is now averaged over an hour; |

instantaneous measurement should be required. We are told that instantaneous releases have |

been over the allowable limit. Those reading do not appear on the record because they can be |

countered by a lower release - a way to cook the books and the fish that happen to be |

swimming by at the wrong time. |

|

5. Cape Cod Bay is an Ocean Sanctuary. Therefore greater consideration of a wider range of |

species needs to be analyzed further. (PNPS-D-EE) |

|

|
Appendix A

NUREG-1437, Supplement 29 A-84 July 2007

| Comment: The staff concludes that cumulative impacts of PNPS license renewal would be

| SMALL for most potentially affected resources, with the exception of the local winter flounder

| population and Jones River population of rainbow smelt, for which impacts would be

| MODERATE (p.9-5).

|

| Methods used to Assess Impact: How did NRC come to their conclusion when marine impact

| can not be assessed at present because definite numbers have not been set on what

| constitutes "significant impact." A yardstick has to be firmly established for each species (plant

| and animal) with appropriate federal, state and independent partners and rationales provided to

| the public; and Thermal backwash as not considered. During a thermal backwash, about

| 155,000 gpm of heated water (>105 F) is sent into the intake embayment for a period of about o

| 1.5-2 hrs. Studies to evaluate potential impacts of the thermal backwash have not been

| performed. (PNPS-D-EE)

|

| Response: The issues raised in these comments include (1) methods for determining impact

| to the winter flounder population, (2) analysis of thermal effects, (3) designation of Cape Cod

| Bay as an Ocean Sanctuary, and (4) classification of impacts.

|

| Regarding (1), NRC staff met with representatives of State and Federal agencies prior to

| development of the SEIS to discuss methods of evaluating impacts on marine populations. Due

| to limitations associated with each method of assessing winter flounder populations and

| impacts, multiple methods can be used to evaluate status and trends of these populations.

| Multiple methods were therefore considered as lines of evidence in arriving at conclusions

| stated in Section 4.1 of the SEIS.

|

| Regarding (2), thermal backwashing operations and their effects are described in Section 4.1.3.

| The analysis of thermal impacts was based on measured temperatures within the bay itself, the

| extent of the plume throughout the tidal cycle, and minimal effects documented by the biological

| monitoring programs in the affected area. USEPA Region I administers the NPDES permitting

| process in Massachusetts, and the NRC does not have authority over matters concerning

| discharge permits and measurement methods for temperature or other discharge parameters.

|

| Regarding (3), Chapter 132A, Section 16 of the General Laws of Massachusetts notes that

| operation and maintenance of existing municipal, commercial, or industrial facilities and

| discharges that are approved and licensed by appropriate Federal and State agencies are

| permitted activities in ocean sanctuaries. Although the proposed action may affect the habitat,

| as long as the action is permitted by the Commonwealth or EPA, it is allowable under state law. 

| Additional text has been added to Section 2.2.5.1 noting that Cape Cod Bay has been

| designated as an Ocean Sanctuary by the Commonwealth of Massachusetts. The three criteria
Appendix A

July 2007 A-85 NUREG-1437, Supplement 29

used to determine the important fish species analyzed in the SEIS were commercially or |

recreationally importance; species for which EFH has been designated, and species that are |

considered to be critical to the local ecosystem. |

|

Regarding (4), the level of significance of impacts was assessed based on the three-level |

system (small, moderate, or large) developed by NRC and in accordance with the Council on |

Environmental Quality's regulations (40 CFR 1508.27) requiring the assessment to consider the |

context and intensity of the impact. |

|

Aside from the additional text added to Section 2.2.5.1, no other changes have been made to |

the SEIS in response to these comments. |

|

Comment: JRWA believes that there is sufficient evidence provided through the [2004-2006] |

DMF study on rainbow smelt to conclude that the population of smelt is significantly reduced |

and therefore continued impingement at equivalent rates under an extended license as |

evidenced over the past thirty years at the plant will have a SIGNIFICANT impact on this |

species. (PNPS-D-NN) |

|

Comment: In 2004 the National Marine Fisheries Service (NOAA) listed Osmerus mordax as a |

Species of Concern Designation. The fishery is closed by regulation from March 15 to June |

th

15 to protect spawning fish. The PNPS has consistently impinged adult fish and entrained |

th

eggs and larvae. Impinged fish have low survivability, and has occurred every year with some |

dominant years. NMFS apparently does not yet have an assessment of the impact of PNPS on |

the population of rainbow smelt. |

|

JRWA is very concerned about the decline in smelt population in the Jones River. Formerly the |

Jones sponsored the largest smelt run in Massachusetts, [DMF Report 1928], and now it is a |

mere shadow of that past. Significant impingement events have periodically occurred at PNPS |

and can be directly associated as a cause of the decline in the Jones. The essential habitat for |

this population of rainbow smelt is very likely Cape Cod Bay, with PNPS as the largest negative |

influence. Smelt generally live less than 1 mile from shore and in water less than 19 ft. deep. |

Given that an estimated 76% of the species is preyed upon annually by other fish and birds |

(NOAA.gov information sheet), loss of this food source could have a significant impact on other |

species. While the SEIS and staff report a potential MODERATE cumulative impact on the |

smelt, there is no reasonable discussion that this impact would have on a broader range of |

species. |

|

JRWA is of the opinion that the present low population numbers of rainbow smelt, the |

designation of Special Concern by NMFS, and the ongoing impingement of adults as well as |

entrainment of eggs and larvae, including occasional dominant species impingement events at |

PNPS, is sufficient reason for NRC to determine that continued operation of the once through |
Appendix A

NUREG-1437, Supplement 29 A-86 July 2007

| cooling as now configured will have a SIGNIFICANT and potentially catastrophic impact on the

| remaining population - and that this impact is NOT acceptable. (PNPS-D-NN)

|

| Response: The NRC staff determined in the DSEIS that there would be a moderate impact to

| the Jones River population of rainbow smelt from re-licensing of the plant. The basis for this

| determination is: 1) the high impingement rate of rainbow smelt at PNPS, 2) the low survivability

| of impinged rainbow smelt at PNPS, 3) proximity of the Jones River to PNPS, 4) the unknown

| status of the Jones River population, and 5) the uncertainty regarding the spawning run origins

| of rainbow smelt impinged at PNPS. Based on the data available, NRC acknowledges that

| continued operation of PNPS does have an impact on the Jones River population of rainbow

| smelt and may be contributing to the declines observed in the Jones River population. 

| However, there may also be other factors such as habitat low which are contributing to

| population declines. Due to the lack of data on population status, there is much uncertainty

| regarding the potential impacts of continued operation of PNPS. However, based on the

| available data, NRC staff does not have any information that indicates that continued operation

| of PNPS would have a “potentially catastrophic impact on the remaining population,” and thus,

| the moderate determination stands. The loss of rainbow smelt as a food source for other

| organisms is addressed in the cumulative impact section (Section 4.8.1). Sections 4.1.2.2 and

| 4.8.1 have been revised in response to these comments.

|

| Comment: If the chlorination and hypochlorination occurs around the time when fish are

| spawning to produce offspring, (Spring, Summer, Fall), and this time period lasts for 2 hours

| per day, with time through the plant of 5-10 minutes, then the amount of liquid chlorination

| effecting the fish population in Cape Cod Bay could be greater than what studies have shown.

| No study is definite and there is no data present in the report regarding the effect (long or short

| term) of chlorination to the marine aquatic ecosystem. This, I feel, is an important consideration

| evaluation of PNPS and it's relationship to the marine aquatic ecosystem. There should be

| further data collected and reported as to how much chlorination and chlorine is discharged into

| Cape Cod Bay. (PNPS-D-LL)

|

| Comment: The DSEIS (DSEIS page 4-35) lists an automated chlorine monitoring and warning

| system for the service water and/or condenser cooling water systems as a means to possibly

| mitigate for a portion of the potential impacts of the continued operation of Pilgrim Station. EPA

| recommends that improvements to the screenwash system be included in this discussion

| because chlorine exceedences occurred when there were problems with the screenwash

| dechlorination system. EPA also recommends that the FSEIS include an evaluation of the

| potential for reduced impacts associated with the installation of an automated chlorine

| monitoring system that includes a malfunction notification component. (PNPS-D-OO)

|

| Response: As discussed in Section 2.2.3.1, Entergy is required to monitor chlorine levels

| (measured as total residual oxidants) in its cooling water and service water discharges as a
Appendix A

July 2007 A-87 NUREG-1437, Supplement 29

condition of its NPDES permit. As discussed in Section 4.1, discharge of chlorine or other |

biocides is a Category 1 issue determined in the GEIS to have small impacts. The NRC staff |

reviewed recent discharge data (2005-2006) and determined that the two exceedances of |

chlorine permit limits during this period occurred when one of the dechlorination pumps was not |

pumping adequately. Improvement to the screenwash dechlorination system, such as an |

automated chlorine monitoring system, is briefly discussed as a potential mitigation measure |

though its potential to further reduce impacts would be limited due to the minimal impacts |

associated with the current system. The intent of the mitigation measures section (Section |

4.1.4) is to provide a general overview of the potential measures that may be applicable to |

PNPS. Thus, a detailed discussion of the effectiveness of installing an automated chlorine |

monitoring system that includes a malfunction notification component is outside the scope of |

this analysis. The staff concluded that "there would be no significant impacts of discharge of |

chlorine or other biocides during the renewal term beyond those discussed in the GEIS." This |

comment provides no new and significant information; therefore, no changes have been made |

to the SEIS. |

|

Comment: EPA does not believe that the cooling water bypass flow mitigation measure |

discussed in the DSEIS (DSEIS page 4-37) should be presented as a measure to mitigate for |

impingement and entrainment impacts since the intake flow at the CWIS remains unchanged. |

(PNPS-D-OO) |

|

Response: The intent of the mitigation measures section (Section 4.1.4 of the DSEIS) was to |

provide a general overview of the potential mitigation measures that may be applicable to |

PNPS. The option of a cooling water bypass flow was previously presented in the PNPS 316(b) |

study (ENSR 2000). As stated in the DSEIS, the cooling water bypass flow mitigation measure |

is not likely to reduce impingement but entrainment effects may be reduced because fewer |

organisms would pass through the condensers. Section 4.1.4 has been revised in response to |

this comment; however, the NRC staff still considers the cooling water bypass flow as a |

potential mitigation measure. |

|

Comment: I'm concerned about the method of approach in monitoring, I would like to talk to |

Earth Tech a little bit more about this, but I understand that a lot of the monitoring happens post |

sweeping of the screens and I think there is probably an impingement and an entrainment |

factor that happens when we are not looking and that there needs to be --. I at least need more |

understanding of that and a complete listing of the 77 species that are impinged and the 66 |

species that are entrained so that I can help evaluate what these impacts are going to be. |

(PNPS-D-I) |

|

Response: Monitoring requirements are defined in the NPDES permit, which is issued by |

USEPA Region I. The NRC has no regulatory authority regarding the conditions set in the |

NPDES permit. A table has been added to Section 4.1 of the SEIS that lists the species that |
Appendix A

NUREG-1437, Supplement 29 A-88 July 2007

| have been entrained and or impinged at PNPS during its operating history. Based on the

| information reviewed by NRC staff, 73 different species have been impinged over the operating

| history of the plant, while 63 different species have been entrained.

|

| Comment: The DSEIS (DSEIS page 4-25) indicates that a reimpingement study during the

| 80's was never completed. Also, the DSEIS (DSEIS page 4-37) lists moving the fish return

| sluiceway discharge point as a mitigation measure to avoid reimpingement. We recommend

| that this section of the FSEIS be expanded to include a discussion of the effectiveness of

| physical and operational modifications to the fish return system including more frequent or

| continual screen rotation. (PNPS-D-OO)

|

| Comment: Mitigating aquatic population loss is different from requiring mitigation of water

| quality impacts, which the NRC staff state is beyond its jurisdiction to regulate. However, direct

| kill rate of species is distinct from water quality degradation that impairs habitat and as a result,

| affects fish. Here we must address the systematic damage to species that, over time, results in

| a loss in the environment that could significantly impair the ability of other species to

| survive-and thus NRC should require mitigation. At this time we know that Rainbow smelt, river

| herring, Atlantic mackerel, winter flounder, Atlantic cod and other fish impacted by the plant are

| troubled by declining numbers, while some, like the cod, have FMP, others are listed as Special

| Concern. Impacts of the Pilgrim plant upon these species should be avoided, and if they are

| not, those impacts must be mitigated so as to not lose important fish populations.

| (PNPS-D-NN)

|

| Comment: EPA's scoping comments noted that the majority of rainbow smelt impinged at

| Pilgrim Station are believed to have originated from the nearby Jones River population and that

| without quantification of the size of that population it is not possible to fully assess the relative

| impact of Pilgrim Station's operations on rainbow smelt. The DSEIS (DSEIS page 4-27)

| indicates that "considerable uncertainty exists regarding potential impacts to rainbow smelt

| populations." The DSEIS discusses mitigation measures that could be implemented to reduce

| impingement event impacts at Pilgrim Station (DSEIS page 4-36) with what appears to be

| limited analysis of whether they would be effective and to what degree they could be expected

| to reduce impacts. EPA recommends that the FSEIS expand on that analysis. (PNPS-D-OO)

|

| Comment: EPA agrees with the final conclusion in Section 4.1.2.3 of the DSEIS that the

| "continued operation of PNPS would have a MODERATE impact on the Jones River population

| of rainbow smelt due to impingement over the course of the license renewal term" and "SMALL

| to MODERATE impacts on other marine aquatic resources due to impingement." EPA

| recommends that the FSEIS evaluate further mitigation options for these impingement impacts.

| (PNPS-D-OO)

|

|
Appendix A

July 2007 A-89 NUREG-1437, Supplement 29

Comment: Given the staff conclusion that plant operations are likely to have Significant |

impacts on the EFH for American plaice, Atlantic cod, Atlantic mackerel, red hake, whiting, |

windowpane flounder, and winter flounder, and given the tenuous sustainability of many of |

these species, PNPS should not be re-licensed without significant upgrades to its cooling |

system and substantial mitigation efforts to help restore areas, such as salt marshes and |

spawning habitats in the Cape Cod Bay region that can help boost survivability of PNPS |

affected species. (PNPS-D-NN) |

|

Comment: I hope as stated in the PNPS Supplement 29 discussion of potential mitigating |

measures does more than "only provide a brief overview of technologies." These technologies |

provide solutions to the problems regarding the continued use of PNPS as a power source and |

should be thoughtfully considered. (PNPS-D-LL) |

|

Comment: The evaluation of alternative mitigation measures and cooling water intake |

structure technologies in the DSEIS (DSEIS pages 4-34 through 4-38) is limited to a listing of |

various measures. We recommend that this analysis evaluate the benefits of such systems as |

well as their engineering feasibility and associated adverse impacts, if any. (PNPS-D-OO) |

|

Comment: Based on the information presented, and given the three tiered NRC classification |

system (i.e., Small, Moderate, Large), we agree with NRC's conclusion in Section 4.1,1.4 of the |

DSEIS, Summary of Entrainment Impacts, that the "continued operation of the PNPS would |

have a MODERATE impact on the local winter flounder population due to entrainment over the |

course of the license renewal term" and "a SMALL to MODERATE impact on the overall Gulf of |

Maine winter flounder stock as well as on all other marine aquatic resources due to |

entrainment." These conclusions about the level of impact appear justified by the entrainment |

data collected to date. We recommend that the FSEIS include a more comprehensive |

evaluation of the effectiveness and engineering feasibility of measures to mitigate this |

entrainment impact, including retrofitting the once-through cooling water system with |

closed-cycle cooling technology. (PNPS-D-OO) |

|

Response: Section 4.1.4. provides an overview of potential mitigation measures to minimize |

adverse impacts to marine resources. Therefore, a detailed evaluation of the potential |

feasibility of each of these measures including mitigating aquatic population loss, to address |

impacts associated with PNPS’s cooling system was not conducted and is considered to be |

beyond NRC’s regulatory authority but would fall within EPA’s authority under the CWA. In the |

SEIS, the NRC did consider the direct kill rate of species when evaluating the impact on aquatic |

species. These comments provide no new and significant information; therefore, no changes |

have been made to the SEIS in response to these comments. |

|

Comment: Page xxi, Lines 17-18 - The sentence "Additional mitigation to minimize the impacts |

of entrainment and impingement may be justified." should be deleted. In addition to mitigation |
Appendix A

NUREG-1437, Supplement 29 A-90 July 2007

| already being addressed in the last sentence of this paragraph, with the EPA recognized as the

| regulating authority, the NRC is not known to have been delegated authority under the Clean

| Water Act to make recommendations regarding mitigation measures associated with "aquatic

| matters". (PNPS-D-MM)

|

| Response: NRC recognizes that it does not have delegated authority under the Clean Water

| Act to mandate mitigation measures associated with "aquatic matters" and that USEPA, Region

| I is currently evaluating Entergy’s NPDES permit renewal application for PNPS. The NRC's

| responsibilities during the environmental review of license renewal are to determine and

| document the environmental effects of operating a nuclear power plant for an additional 20

| years, as outlined in 10 CFR Parts 52 and 54. The text referred to in the comment is a

| conclusion drawn from the technical review of the available information during the

| environmental review. The text was not intended to serve as a recommendation or a mandate

| regarding mitigation measures; therefore, no changes have been made to the SEIS.

|

| Comment: In addition, I believe that our marine aquatic resources are being compromised by

| the intake design of the PNPS. (PNPS-D-DD)

|

| Comment: As far as the impact analysis, we do continue to be extremely concerned about the

| fisheries that inhabit Cape Cod Bay and in particularly the estuary of the Jones River which are

| in sever decline. We have concerns about the methods and approach and the limitations of the

| approach in the document, although I do admit that I found the document extremely interesting

| and informative reading. However, because the populations of herring, Alewife, Rainbow Smelt,

| Shad, American Eel are all in severe decline in the Jones River and elsewhere on the Atlantic

| Coast region, I believe that even the assessment of moderate impact is inaccurate, and that

| continued impingement and entrainment of these types of species on the Pilgrim intake screens

| is severe. (PNPS-D-I)

|

| Response: The comments, in general, are in opposition of license renewal at PNPS based on

| concerns regarding PNPS's once-through cooling system. As part of the NEPA process, NRC

| has evaluated the impacts related to impingement and entrainment of aquatic organisms, the

| thermal plume, and other potential or actual aquatic impacts. The NRC's conclusions regarding

| these impacts, as well as potential mitigation measures, are presented in Chapter 4 of the

| SEIS. These comments provide no new information, and no changes have been made to the

| SEIS.

|

| Comment: On page 4-35, the DSEIS indicates that "ENSR (2000) determined that, of the

| behavioral barriers evaluated, light barriers would be the most effective as several studies have

| shown that some fish species are attracted to light." This statement should be clarified since an

| effective barrier would typically repel, not attract, fish. (PNPS-D-OO)

|
Appendix A

July 2007 A-91 NUREG-1437, Supplement 29

Response: Section 4.1.4 has been clarified to note that the effectiveness of light barriers as a |

deterrent has been contradictory; in some studies fish are attracted to light, while in other |

studies fish are repelled by light. |

|

Comment: Habitat restoration and fish stocking justify the loss of viable fish and may not solve |

the lessening of the fish population due to PNPS cooling systems operations. Of the 35 species |

listed in Supplement 29, as effected by either entrainment and or impingement or both, 16 |

appear to be listed as possible fish consumed by humans. The effects on the fish by |

chlorination, heat shock and normal discharge of waste as the result of proximity to PNPS could |

potentially reach human population as the result of consuming the fish listed. |

|

These fish include: Mackerel, Black Sea Bass, Bluefin Tuna, Blue Fish, Pollock, Atlantic Cod, |

Haddock, Monkfish, Summer Flounder, Winter Flounder, Yellow Tail and Long Fin Squid. |

Again, the concern here is human consumption and the possible deleterious effects. |

(PNPS-D-LL) |

|

Response: The discharge of chlorine and other biocides and the accumulation of |

contaminants by biota (such as from heavy metals in condenser cooling water discharges) have |

been determined to be Category 1 issues for license renewal for all nuclear plants. The effects |

of heat shock on fish is a Category 2 issue specifically evaluated in Section 4.1.3. The comment |

provides no new and significant information. Therefore, no changes have been made to the |

SEIS in response to this comment. |

|

Comment: Page 2-7, Lines 38-40; Page E-60, Line 17-20 - The sentence "The mixture is used |

to ensure the total residual chlorine discharge concentration does not exceed a maximum daily |

concentration of 0.10 parts per million (ppm) and an average monthly concentration of 0.5 ppm |

in the service water discharge." is incorrect. The Condenser Cooling Water NPDES Permit total |

residual chlorine limitations are "0.10" maximum daily and "0.1" average monthly. The Plant |

Service Cooling Water NPDES Permit total residual chlorine limitations are "1.0" maximum daily |

and "0.5" average monthly. (PNPS-D-MM) |

|

Response: Section 2.1.3 has been changed in response to this comment. |

|

Comment: Terminology needs be explained. Such key language as "significant", "moderate", |

"less than substantial", "minimal adverse" need qualifying definitions in order to understand the |

implications of the SEIS. (PNPS-D-NN) |

|

Response: Section 1.2.1 of the DSEIS explains the basis for the NRC's standard of |

significance and defines the three-level system for classifying the significance of impacts (small, |

moderate, or large) based on consideration of their context and intensity. The other |

terminology noted in the comment (minimal adverse, less than substantial) was employed in |
Appendix A

NUREG-1437, Supplement 29 A-92 July 2007

| classifying impacts in the Essential Fish Habitat Assessment included in Appendix E and is

| based on NMFS guidance. The comment provides no new and significant information. 

| Therefore, no changes have been made to the SEIS in response to this comment. 

|

| Comment: We also note the discussion in the DSEIS at page 4-27 which states, "Although the

| loss of winter flounder juveniles and adults through impingement may be contributing to

| population declines, the level of impact is considered to be minimal when compared to the

| potential entrainment impacts." We suggest that this comparison is inappropriate and that

| instead of comparing the two types of impact (entrainment and impingement) that may

| contribute to population declines, they both be considered together in the cumulative impact

| discussion. (PNPS-D-OO)

|

| Response: Sections 4.1.2.2 and 4.8.1 have been changed in response to this comment.

|

| Comment: Section 4.1.2.1 of the DSEIS explains that 97% of the over 300,000 fish impinged

| during 2005 were Atlantic menhaden and that their survival was low (18 and 27%). In addition,

| there were 19 impingement events (>20 fish/hr) in 2005 which consisted primarily of Atlantic

| menhaden and Atlantic silversides. Even though the DSEIS acknowledges that "menhaden is

| one of the most commercially important fish species along the Atlantic Coast" (DSEIS page 

| 2-37), there is little discussion regarding the impact of the impingement losses in Section

| 4.1.2.2 other than relying on ENSR reports and general statements such as "[t]he Atlantic

| menhaden stock is considered to be healthy with stable stock size and high biomass."

| Furthermore, although the DSEIS recognizes that "due to the lack of recent information

| describing the status of several local populations, it is difficult to quantify impingement impacts,"

| it concludes that "impacts on marine aquatic species other than the Jones River population of

| rainbow smelt would be minor." EPA recommends that the FSEIS expand on this discussion of

| impingement impacts more fully explain the basis for the conclusion that the impacts would be

| more. (PNPS-D-OO)

|

| Response: Sections 4.1.2.2 and 4.1.2.3 were modified to address this comment.

|

| Comment: Page 2-30, Lines 22-24 - Suggest changing the sentence "However, these tests

| indicated that sediment from the intake embayment would have a significant impact on the

| survival of the amphipod (Ampelisca abdita), and the development of the larval stage of the

| blue mussel (Mytilus edulis)." to "Although unrelated to PNPS operations, these tests indicated

| that sediment from the intake embayment would have a significant impact on the survival of the

| amphipod (Ampelisca abdita) and the development of the larval stage of the blue mussel

| (Mytilus edulis)." (PNPS-D-MM)

|

|
Appendix A

July 2007 A-93 NUREG-1437, Supplement 29

Response: The NRC staff reviewed the toxicity testing results and edited Section 2.2.5.2 to |

clarify that the followup testing indicated that toxicity to the amphipod Ampelisca abdita and |

larvae of the blue mussel (Mytilus edulis) appeared to be limited to a single location and may |

have resulted from ammonia. Ammonia is a naturally occurring chemical in sediment that can |

be toxic to invertebrates. |

|

Comment: Sand Tiger Shark (Odontaspis Taurus). This animal is not mentioned in the SEIS, |

which we bring attention to here, as it is designated by NMFS as a Species of Concern |

Designation, and it has been caught and tagged over the past two years in the Jones River |

estuary. From evidence of the fish caught, we know that the sand tiger feeds on striped bass, |

and we know that Striped bass feed on smelt, herring and menhaden, etc. |

|

We are concerned as we have stated above, that the SEIS has so segmented its analysis of |

the impact on fisheries as to lose sight on the general and cumulative impact upon the web of |

fish in the food chain. Ecosystem analysis requires that the operation is evaluated against |

broad impacts to Cape Cod Bay populations and habitats as well as upon the 66 or species of |

fish impinged and entrained by plant operations. We do not know enough about Cape Cod Bay |

and its dependent species to be confident in the assessment that MODERATE impacts on |

smelt and winter flounder are only that, and can be ignored. (PNPS-D-NN) |

|

Response: As described in Section 2.2.5.3.1, the SEIS identified a group of important fish |

species for evaluation as representatives of the potentially affected fish community in western |

Cape Cod Bay. These included species that are commercially or recreationally valuable, |

species critical to the ecosystem, and species for which essential fish habitat (EFH) has been |

designated in the vicinity. The sand tiger shark was determined not to meet these criteria and |

has never been reported to have been entrained or impinged at PNPS. In addition, although |

the sand tiger shark is designated as a species of concern by the NMFS (NOAA Fisheries |

2004), it is an opportunistic feeder and therefore it may prey on many different fish species. |

Potential food chain effects were considered in the assessment, as discussed in Section 4.8 on |

Cumulative Effects and in the EFH Assessment (Appendix E). Due to limitations associated |

with each method of assessing fish populations and the significance of impacts, multiple |

methods were considered as lines of evidence in arriving at conclusions based on the weight of |

the available evidence. The NRC staff met with representatives of State and Federal agencies |

prior to development of the SEIS to discuss methods of evaluating impacts to marine fish |

populations. Multiple methods can be used to evaluate status and trends of these populations. |

The basis for the conclusions regarding the species evaluated are described in Sections 4.1.1 |

and 4.1.2. Section 4.8.1 has been revised in response to this comment. |

|

|
Appendix A

NUREG-1437, Supplement 29 A-94 July 2007

| Comment: In addition, JRWA is concerned that other species, especially the Jones River the

| Alewife and Blueback Herring have not been fully evaluated, and are being severely impacted

| by plant operations. Annually hundreds, and at times tens of thousands of this fish are

| impinged, and have been found in the plant cooling system, including in the spring prior to

| spawning. In 1995 the Alewife was the dominant fish impinged, while the Rainbow smelt have

| been dominant at least two years. (PNPS-D-NN)

|

| Response: As described in Section 2.2.5.3.1, the SEIS identified a group of important fish

| species for evaluation as representatives of the potentially affected fish community in Cape Cod

| Bay. These included species that are commercially or recreationally valuable, species critical to

| the ecosystem, and species for which essential fish habitat (EFH) has been designated in the

| vicinity. Neither blueback herring or alewife (collectively known as river herring) were

| determined to have EFH in the vicinity of PNPS, and both are commonly impinged at PNPS,

| with greater numbers of alewife being affected. The fishery for these two species has recently

| been closed in Massachusetts. Based on NRC staff conversations with MADMF, the fishery is

| declining, but overall population data are unavailable. However, the level of take of these

| species by PNPS is relatively small. Over the last 25 years the annual average of alewife

| impinged is 2000 fish; however, there were five large impingement events (greater than 1000

| fish) during this time frame. The median of the last 25 years would be 262 impinged fish per

| year. The alewife was chosen as one of the important species for evaluation, and it provides a

| conservative representation of potential impacts on the blueback herring due to their similar life

| histories and habitats. There is not an apparent relationship between alewife impingement

| numbers in recent years and current alewife counts in the Jones River.

|

| NRC staff evaluated the available data and determined that there are differences in

| impingement rates for individual species throughout the year. This is especially true of

| anadromous fish that have distance runs that pass within the vicinity of PNPS. The staff

| realizes that alewife and blueback herring are impinged in the spring prior to spawning. This

| was taken into consideration when developing the impact determination. It should also be

| noted that most data available for analysis of impingement impacts are not differentiated by

| season. The comment provides no new and significant information. Therefore, no changes

| have been made to the SEIS in response to this comment.

|

| Comment: The following fish species were considered those suffering the greatest numerical

| losses due to impingement over the last 11 years of monitoring at Pilgrim (Environmental

| Protection Group 2005):
Appendix A

July 2007 A-95 NUREG-1437, Supplement 29

|

Table 1 |

|

Year Atlantic silverside Atlantic menhaden blueback herring grubby rainbow smelt alewife |

1994 36,498 58 269 1,094 9,464 123 |

1995 13,085 1,560 1,244 648 2,191 39,884 |

1996 16,615 2,168 2,462 1,347 3,728 216 |

1997 6,303 1,329 424 405 1,978 317 |

1998 6,773 1,423 134 335 1,656 158 |

1999 8,577 42,686 550 628 875 610 |

2000 25,665 34,354 5,919 1,105 13 2,443 |

2001 4,987 3,599 229 517 879 1,618 |

2002 4,430 53,304 943 1,087 335 334 |

2003 23,149 119,041 1,968 237 532 438 |

2004 13,107 10,431 2,046 2,257 1,092 145 |

|

Of particular interest are the rainbow smelt. These fish are an anadromous species and smelt |

impinged at Pilgrim most probably come from the Jones River population. Although there are |

two other rainbow smelt runs (Town Brook and Eel River) in the Plymouth/Kinston/Duxbury Bay |

area they are apparently quite small in comparison to that from the Jones River (based on pers. |

comm., Brad Chase, MA Division of Marine Fisheries [DMF] to Gerald Szal, DEP). Rainbow |

smelt are not known to reproduce elsewhere in streams entering Cape Cod Bay or in streams |

elsewhere on Cape Cod. (PNPS-D-NN) |

|

Response: The comments provide no new and significant information, and no changes have |

been made to the SEIS in response to this comment. |

|

Comment: The moderate impact finding on Winter Flounder was based largely on what's |

called the equivalent adult model which takes numbers of eggs and larvae that pass through |

the plant and predicts how many adults would, could result from those based on many |

assumptions on their mortality rate. It's a screening tool and it's not designed to estimate |

mortality rates. |

|

In 2000, 2002 and 2004 I was involved in what we call a larval transport study designed to |

measure how many Winter Flounder actually flow past the station in a typical spawning season, |

and based on that study, we estimated that much less than one percent of the Winter Flounder |

larvae passing the station are actually entrained, so I would urge you to focus on that more than |

the equivalent adult model. (PNPS-D-T) |

|

Response: The equivalent adult model and results from the larval transport study were both |

considered as part of the weight of evidence in determining that there was a potential for a |

moderate impact to local populations of winter flounder. This comment does not provide new |
Appendix A

NUREG-1437, Supplement 29 A-96 July 2007

| and significant information, and therefore, no changes have been made to the SEIS in response

| to this comment.

|

| Comment: Page 4-21, Lines 27-28 - " ... there were several methodological difficulties, which

| impart a high degree of uncertainty to these estimates." The Larval Transport Studies provide a

| direct method of measuring 'percent entrainment' of winter flounder at PNPS using larval

| densities from the plant and from Cape Cod Bay, obtained simultaneously. The obvious benefit

| to this approach is that it eliminates the reliance on hypothetical models (and their inherent

| uncertainties) and instead, uses real time field data collected at the site. The key challenge is to

| ensure that using a net to sample larvae close to the bottom (larval stages 3 and 4) does not

| underestimate the actual number of larvae present in the bay. As with many field studies, new

| techniques were employed to address this difficulty and they were not completely successful. 

|

| There was no problem with the stage 3 and 4 larval densities obtained from sampling in the

| discharge canal, which collects all larval stages with equal efficiency. To determine 'percent

| entrainment' these values were then divided by the number sampled in the bay. As a result, it

| was apparent that the few elevated entrainment values for stage 3 and 4 larvae obtained in

| 2002 and 2004 were due to low numbers of stages 3 and 4 collected in the bay (i.e. under

| sampling larvae close to the bottom). However, this discrepancy does not cause a high degree

| of uncertainty and it does not detract from the key conclusion that the amount of winter flounder

| larvae in northwest Cape Cod Bay entrained by PNPS is estimated (from direct measurement)

| to be less than 1 % of the net larval transport. (PNPS-D-MM)

|

| Comment: Larval transport studies were conducted in 2000, 2002, and 2004 for the purpose of

| comparing the percentage of winter flounder moving by Pilgrim Station to that which is

| entrained through Pilgrim Station’s cooling system. Page 4-12 of the DSEIS presents 2004

| data that indicates a 20 percent entrainment rate of stage 4 winter flounder for one survey and

| less than 1 percent in another survey. The DSEIS indicates that the authors of the studies

| “emphasized that the higher rate may have been a result of some methodological difficulties

| such as lost sampling gear, resulting in no sample collection from several survey locations.” 

| We note that the DSEIS does not appear to include data to support these conclusions and we

| recommend that an expanded explanation of the higher entrainment rate be provided in the

| FSEIS. (PNPS-D-OO)

|

| Response: In response to these comments, additional discussion regarding the larval

| transport studies has been added to Section 4.1.1.1 in the SEIS.

|

| Comment: The DSEIS (DSEIS page 4-13) discusses the 2000 and 2002 larval transport data

| and adds that these “reports state that the periodic high entrainment rates observed for stages

| 3 and 4 larvae were likely due to difficulties in collecting the stages 3 and 4 larvae, as these

| larval stages generally are associated with the bottom sediments.” It is our understanding that
Appendix A

July 2007 A-97 NUREG-1437, Supplement 29

stage 3 winter flounder are found in the water column. In addition, one of the two surveys in |

2004 shows a stage 4 larval entrainment rate of 20 percent. We recommend that the |

discussion in the FSEIS reflect the entire data set. (PNPS-D-OO) |

|

Response: The DSEIS incorporated all of the results from the larval transport studies |

(including the 2004 data) in reaching the conclusion that there is a potential for a moderate |

impact to local populations of the winter flounder. This comment does not provide additional |

information and therefore no edits to the SEIS are necessary. |

|

Comment: Page 4-21, Lines 2-7 - Regarding "Normandeau (2006a) compared recent |

estimates of the loss of age 3 adults ... " referring to Table 4-4 references Normandeau as the |

source, and discusses the estimated percent loss of adults as if this terminology is used in the |

2005 Annual Report referenced. However, the headers (description of data columns) presented |

in Table 4-4 are quite different from those in the reference document. One is also incorrect; the |

Area-Swept survey should be all adult winter flounder (those equal to or longer than 280 mm |

TL) not just age-3 fish. Please duplicate the entire table as it appeared in the original source, or |

eliminate the citation altogether. (PNPS-D-MM) |

|

Response: The NRC staff has revised the table, which is now Table 4-5, in response to this |

comment. Column headings and footnotes have been edited to more accurately describe the |

associated data and clarify its basis. |

|

Comment: Finally, although winter flounder is the only fish present in category 2 and subject |

to review, it appears data and collection of data might be altered to gain more accurate |

representation of how many larvae, eggs and fish are adversely effected by PNPS cooling |

system. Less than 1% appears to be a general category to place all the fish in various stages |

collected for analysis. Perhaps better technology could result in more accurate data. |

(PNPS-D-LL) |

|

Response: The NRC evaluated a number of aquatic species as part of the environmental |

review, as described in Chapter 2 and 4 of the SEIS, including winter flounder. These important |

fish and marine mammal species were identified as representative of the potentially effected |

aquatic community of Western Cape Cod Bay. The list included commercially or recreationally |

valuable species, species critical to the ecosystem, and species for which EFH has been |

designated by NMFS. |

|

NRC, through development of the SEIS, analyzes the potential impacts of renewing the plant's |

operating license. NRC does not have regulatory authority to impose fish monitoring |

requirements or implementation of the best technology available. EPA has such regulatory |
Appendix A

NUREG-1437, Supplement 29 A-98 July 2007

| authority under the Clean Water Act. Consequently, recommendations for the facilities

| monitoring program are beyond the scope of the SEIS. Therefore, no changes to the SEIS

| were made in response to this comment.

|

| Comment: Page 4-12, Lines 16-17 - Regarding "The abundance estimates in 2005 were <50%

| of the 1995-2004 time series. " This sentence, given without any perspective, may lead to the

| wrong conclusion about the status of winter flounder in Cape Cod Bay. The 2006 estimate of

| immature winter flounder was the fourth highest over the 12-year monitoring series, indicating

| that an ample amount of recruitment is occurring, which propagates the population in the

| vicinity of PNPS. (PNPS-D-MM)

|

| Response: Section 4.1.1.1 has been revised in response to this comment. The conclusions in

| the SEIS are based on the latest data available to the NRC staff (PNPS Marine Ecology Studies

| Report No. 67, 2006).

|

| Comment: Section 4.1.1.4 of the DSEIS "concludes that the impact of entrainment on marine

| aquatic species other than the winter flounder population would be minor." However, it does not

| appear that this conclusion is fully supported in the DSEIS and EPA encourages a closer

| evaluation of measures to mitigate the adverse impacts of the once-through cooling system.

| Without effective mitigation measures to reduce entrainment, several fish species will be

| adversely affected. The DSEIS (DSEIS page E-l 05) acknowledges this impact by indicating

| that the continued operation of the Pilgrim Station cooling water system would have a

| "substantial adverse effect on EFH for 7 species" in the vicinity of Pilgrim Station. 

| (PNPS-D-OO)

|

| Response: Section 4.1.4 provides an overview of potential mitigation measures to minimize

| adverse impacts to marine resources. Therefore, a detailed evaluation of the potential

| feasibility of each of these measures to address impacts associated with PNPS was not

| conducted. Requiring implementation of such mitigation measures is beyond NRC’s regulatory

| authority but would fall within EPA’s authority under the CWA. Section 4.1.1.4 has been

| changed in response to the comment. 

|

| Comment: Also, EPA's scoping comments suggested that the DSEIS should include the

| consideration of a biological surveillance program to address impacts to fish. This measure

| does not appear to be analyzed in the DSEIS and EPA continues to recommend that this

| impact minimization option be more fully explored in the FSEIS. (PNPS-D-OO)

|

| Response: The USEPA Region I scoping comment referred to in this comment recommended

| evaluation of the possibility of implementing a biological surveillance program to determine

| when impact mitigation measures such as barrier nets should be deployed. The program would

| be intended to identify the presence of large populations of fish susceptible to being attracted to
Appendix A

July 2007 A-99 NUREG-1437, Supplement 29

the thermal plume and discharge canal. The intent of Section 4.1.4, Potential Mitigation |

Measures, is to provide a general overview of the potential mitigation measures that may be |

applicable to PNPS. Thus, a detailed discussion of the effectiveness of implementing a |

biological surveillance program in conjunction with diversion devices is outside the scope of this |

analysis. Section 4.1.4 has been changed in response to this comment. |

|

Comment: Page 2-30, Lines 8-9 - On page 2-11 (lines 30-32) it is stated that "The sediments |

were described as having relatively low concentrations of the chemical parameters tested |

polychlorinated biphenyls (PCBs), polycyclic aromatic hydrocarbons (PAHs), pesticides, .. .". |

However, Page 2-30 (lines 8-9) states "PAHs, pesticides, and PCBs were not detected in any |

sediment sample." These statements appear to contradict each other. (PNPS-D-MM) |

|

Response: The first discussion refers generally to the wide range of chemicals tested as |

having relatively low concentrations, and it lists PCBs, PAHs, pesticides, petroleum |

hydrocarbons, and heavy metals as the tested chemicals. However, PAHs, pesticides, and |

PCBs were not detected at all while low concentrations of petroleum hydrocarbons and heavy |

metals were detected in sediment samples. The second discussion, more specifically states |

that PAHs, pesticides, and PCBs were not detected in the samples. The first discussion in |

Section 2.1.3 has been changed in response to this comment. |

|

Comment: Page 2-28, Lines 1-2 - Suggest deleting the first sentence that starts with "Water |

depths ... ", and replace with 'Water depths in the vicinity of PNPS are typically 10 ft and up to |

120 ft within 5 miles off shore of the site." (PNPS-D-MM) |

|

Response: Section 2.2.5.1 has been revised in response to this comment. |

|

Comment: EPA's scoping comments requested an update of the analyses of thermal plume |

impacts in light of current information and it appears that the DSEIS only provides a summary |

of existing data from 1995 and 2000 reports. EPA recommends that the FSEIS provide more |

recent data if they are available. (PNPS-D-OO) |

|

Response: The assessment of thermal impacts in the SEIS was based on the most recent |

data available. Although more recent data are desirable, it is unlikely that the characteristics of |

the thermal plume have changed significantly since the studies cited in Section 4.1.3 were |

performed. The comment provides no new and significant information. Therefore, no changes |

have been made to the SEIS in response to this comment. |

|

Comment: I also feel the occurrence of heat shock as a category 2 issue should be thoroughly |

examined and data taken as to how fish are effected by this occurrence. (PNPS-D-LL) |

|

|
Appendix A

NUREG-1437, Supplement 29 A-100 July 2007

| Comment: In addition, I think that there needs to be some consideration given to the facts of

| global warming ... 

|

| I think, in general, the ocean is getting a little warmer, certainly the bay is getting warmer, and I

| believe that it is in part getting warmer not only because of global influences but because there

| is a continual daily thermal discharge of superheated water from the plant as a result of the

| cooling function. And that the documents do not consider the impact of that general warming

| upon the bay, upon the essential fish habitat and upon the species that live there, and I think

| this was a flaw in the supplement and I believe that it should be corrected in the final, that the

| warming of the bay water has to be considered. 

|

| What was considered was the shock to the species, in terms of the discharge and I believe that

| the report basically says, well, a fish can swim away from superheated water, and while I

| believe that's true, I think if the general warming pattern is there, then we are kind of --. Like us

| in this room, we are sort of all stuck with the environment that we happen to be in at the

| moment and if you can't get out of it, you have to suffer the result. That is what's happening to

| our marine fisheries, and there is a bigger impact than locally to Pilgrim or locally to the Jones

| River, and we have to pay attention to that and we cannot delay that attention any longer,

| anymore than we can delay the attention given to some of the other concerns. (PNPS-D-I)

|

| Response: The analysis of thermal impacts in Section 4.1.3 was based on measured

| temperature differences within the bay, the extent of the plume throughout the tidal cycle, and

| the minimal effects documented by the biological monitoring programs in the affected area. It

| should be noted that the water leaving the plant is not superheated. Superheated water is

| water that has been heated above its boiling point under pressure that prevents it from

| vaporizing. The maximum permitted temperature of the condenser cooling water at the outfall

| is 102°F, less than half the boiling point temperature. Thermal plume studies found that water

| temperatures measurably exceeded ambient water temperatures in a localized area within

| Cape Cod Bay near PNPS. However, any incremental contribution of heat to the bay from the

| discharged cooling water would be negligible in the comparison to regional and global

| influences on water temperatures in the bay. These comments provide no new and significant

| information; therefore, no changes have been made to the SEIS in response to these

| comments.

|

| Comment: There are details about sediment collected and analyzed from Mass Bay area.

| "Metals, PAH's, PCB's, pesticides and radionuclides" were found and identified, however, the

| conclusion of the data stated, " Mass Bay sediment were no more contaminated than those of

| other urban estuaries." They were concluded as being "healthy" and of no concern. I

| understand the comparative analysis of this data as beneficial to the understanding of the

| sediment collected in Mass Bay. However, I feel the presence of toxins in the sediment should

| also be taken into account and evaluated as such. Describing the results of analysis as
Appendix A

July 2007 A-101 NUREG-1437, Supplement 29

"healthy" due to their presence in "other urban coastal regions on the East Coast" seems to be |

faulty analysis and again, data should be analyzed and concluded on the basis of how these |

chemicals relate and effect the surrounding ecosystem. The effect can not be dismissed |

because other coastal estuaries exhibit similar toxins in the sediment. (PNPS-D-LL) |

|

Response: The text did not state that the sediment was healthy because of the comparison to |

other coastal regions on the east coast, as suggested in the comment. The effect was not |

dismissed based on comparison to other coastal estuaries. Instead, the text states that |

determination that the sediment was healthy was based on a comparison of the contaminant |

concentrations in the sediment to sediment toxicity effects levels from the U.S. National |

Oceanographic and Atmospheric Administration (NOAA). The study was a general assessment |

that was not directly related to evaluation of PNPS operations. However, the conclusion that |

the sediments were no more contaminated than other coastal regions provides information |

suggesting that PNPS has not had a measurable effect on the sediment, and the comparison to |

NOAA standards indicates that neither PNPS nor the widespread industrialization near |

Massachusetts Bay has resulted in sediment contamination that exceeds toxic levels. This |

comment provides no new and significant information; therefore, no changes have been made |

to the SEIS in response to this comment. |

|

Comment: EPA's scoping comments asked that the DSEIS contain a discussion of future |

dredging needs for the facility. The DSEIS at page 4-69 explains that the applicant doesn't plan |

to dredge. However, the DSEIS at page E-63 explains that dredging occurred in 1982 and |

1990. While the applicant may have no plans to dredge at this point in time, EPA recommends |

that the FSEIS reflect that dredging of portions of the facility over the relicensing term may be |

likely given the past dredging history of the facility. (PNPS-D-OO) |

|

Response: NEPA is designed to evaluate reasonably foreseeable actions. Since the last |

dredging action occurred over 17 years ago and did not have the intended outcome of bringing |

cooler water into the cooling system, Entergy has stated that they do not intend to dredge in the |

future. Therefore, NRC does not believe that future dredging of portions of the facility is a |

reasonably foreseeable action that needs further evaluation. This comment provides no new |

and significant information; therefore, no changes have been made to the SEIS in response to |

this comment. |

|

Comment: ...it's my opinion, and we will comment this way, that there should be no relicensing |

certainly without considerable modification to the intake and discharge structure that provided |

cooling water to the plant. (PNPS-D-I) |

|

|
Appendix A

NUREG-1437, Supplement 29 A-102 July 2007

| Comment: Also, I hope there is careful consideration regarding, 

|

| "Entrainment of fish and shellfish in early life stages into nuclear power plant cooling water

| system" as "considered a category 2 issue, thus requiring a site specific assessment for the

| license renewal review."

|

| It is also clearly stated in supplement 29, "section 316 (b) of the clean water act (CWA) requires

| the location, design, construction and capacity of cooling water intake structures reflect the best

| technology available for minimizing adverse environmental impacts." Important data will be the

| result of the Entergy study regarding PNPS cooling systems. Especially in light of the EPA

| 316(b) regulations. (PNPS-D-LL)

|

| Comment: PNPS is obligated as a co-habiter of it's surrounding Cape Cod Bay ecosystem to

| make necessary improvements to the cooling system as it currently operates. Some of the best

| solutions for improvement to Aquatic Marine Populations and Cape Cod Bay waters from the

| list seem to be the following (as outlined in Supplement 29).

|

| • Automated chlorine monitoring 

| • Alternative intake systems 

| • Alternative intake screen systems 

| • Variable speed pumps 

| • Closed cycle system 

|

| If a closed cycle system includes changes in the use of water from Cape Cod Bay to another

| source not associated with the surrounding environment, then this would solve the problems

| associated with entrainment, impingement and pollution of chlorine into Cape Cod Bay. Further,

| if alternative intake systems refers to another source of water for cooling and again another

| source for disposing of the chlorinated water, then this would solve the problem of entrainment,

| impingement and pollution to Cape Cod Bay. (PNPS-D-LL)

|

| Comment: I am very pleased with the policy of PNPS and the governmental policy as follows:

|

| "Entrainment of fish and shellfish into the cooling water system is a potential adverse

| environmental impact that could be minimized by use of the best available technology."

|

| "Licenses are required to demonstrate compliance with the phase 2 requirements at the time of

| renewal of their NPDES permit." (PNPS-D-LL)

|

| Comment: Pages 4-34 thru 4-38, Section 4.1.4 - Discussion of these alternatives and their

| possible application at PNPS should be left to the 316(b) process currently underway. 

| (PNPS-D-MM)
Appendix A

July 2007 A-103 NUREG-1437, Supplement 29

Comment: Pages 4-34 thru 4-38, Section 4.1.4 - The NRC is not known to have been |

delegated authority under the Clean Water Act to make recommendations regarding mitigation |

measures associated with "aquatic matters". In addition, 316(b) is associated with numerical |

performance standards and does not define "impact'. Mitigation measures in the future, if any, |

will be developed and jointly agreed upon between USEPA Region I and Entergy as part of the |

316(b) compliance process. (PNPS-D-MM) |

|

Comment: JRWA is concerned that the adverse environmental impact from impingement and |

entrainment at PNPS of fish and aquatic organisms that depend on Cape Cod Bay and the |

Jones River estuary is so severe as to require a change to the once-through cooling system, or |

a halt to plant operations. No re-licensing should occur without change to a closed-loop cooling |

system or better available technology. Further, the evidence suggests that impacts to fisheries |

over the past thirty years have been instrumental in causing declines in fish species |

populations-especially Rainbow smelt, Alewife, Blueback Herring, as well as winter flounder and |

others-and therefore, substantial increase in mitigation strategies must be required. |

(PNPS-D-NN) |

|

Comment: As soon as the best method can be determined, and prior to any extension of |

permit or license for operation, the salt water intake and discharge for the once-through cooling |

system at Pilgrim Nuclear Power Station must be retrofitted to avoid if possible, and mitigate |

where as necessary, adverse impacts to the aquatic populations of Cape Cod Bay and its |

regional estuarine systems. The SEIS and other reports describe now caused by impingement |

and entrainment of aquatic life forms at levels that adversely impact the Cape Cod Bay |

Sanctuary through unacceptable reduction in fish populations, especially populations of |

Rainbow smelt, Alewife, Blueback herring, winter flounder, Atlantic mackerel, Atlantic cod, and |

other fish important to the ecosystem function and balance of the bay as a whole, and to the |

Jones River in particular. (PNPS-D-NN) |

|

Comment: Retrofits to the intake and discharge structure should be required to avoid fish kills. |

(PNPS-D-NN) |

|

Response: The comments, in general, express concern regarding PNPS's once-through |

cooling system. NRC has evaluated the impacts related to impingement and entrainment of |

aquatic organisms, the thermal plume, and other potential or actual aquatic impacts. The NRC's |

conclusions regarding these impacts, as well as potential mitigation measures, are presented in |

Chapter 4 of the SEIS. |

|

NRC does not have the regulatory authority under the CWA to require changes to the PNPS |

cooling water system. Entergy cannot operate the cooling water system without a NPDES |

permit, which is issued by USEPA Region I. In the absence of USEPA Region I requirements, |

NRC has not included retro-fitting PNPS to closed-cycle cooling in Chapter 8, Alternatives. |
Appendix A

NUREG-1437, Supplement 29 A-104 July 2007

| Instead, closed-cycle cooling is addressed in Chapter 4 as part of the potential mitigation

| measures associated with the PNPS cooling system. These comments provide no new and

| significant information; therefore, no changes have been made to the SEIS in response to these

| comments.

|

| Comment: The DSEIS analysis of closed-cycle cooling in Chapter 8.0 (the environmental

| impacts of alternatives to license renewal) considers the impacts of closed-cycle cooling

| associated with the construction of a new nuclear generating station at a greenfield site. In

| addition to considerations of closed-cycle cooling at a greenfield site, EPA recommends that the

| analysis of alternatives be expanded to include an evaluation of a retrofit of the existing Pilgrim

| Station facility to closed-cycle cooling. (PNPS-D-OO)

|

| Response: Chapter 8.0 presented an analysis of alternatives that are potentially available to

| replace the generating capacity that would be lost if the PNPS OL were not renewed. The focus

| in that section was on alternative energy producing facilities that could reasonably be expected

| to operate as base load generating stations since PNPS typically operates at a capacity factor

| over 90%. 

|

| It is the case, as the comment notes, that one of the base-load systems considered in Chapter

| 8.0, was a nuclear plant operating with closed-cycle cooling at a greenfield site. The purpose in

| doing so was to present a general assessment of the implications of developing an integrated

| power complex (energy source, transmission lines, auxiliary facilities, and cooling tower) to

| replace the output of PNPS. In that context, the broad scale benefits and impacts of the cooling

| system portion of the integrated generating station complex could be readily stated. The

| objective of the analysis was not, however, to present the detailed cost and benefits of a power

| plant cooling system at a hypothetical greenfield site. 

|

| NRC does not have delegated authority under the Clean Water Act to mandate mitigation

| measures associated with "aquatic matters", specifically mitigation measures associated with

| PNPS's once-through cooling system. PNPS's once-through cooling system is currently being

| evaluated by USEPA Region I as a part of Entergy’s NPDES permit renewal. USEPA Region I

| has not issued any guidance regarding potential requirements for retro-fit of PNPS to

| closed-cycle cooling. In the absence of requirements or guidance, NRC has determined that

| retro-fitting PNPS to closed-cycle cooling is not a reasonably foreseeable action and has not

| included this option in Chapter 8, Alternatives. Instead, closed-cycle cooling is addressed in

| Chapter 4 as part of the potential mitigation measures associated with the PNPS cooling

| system. In conclusion, no changes have been made to the SEIS.

|

| Comment: Bald Eagles, red-bellied cooters, roseate terns, piping plovers, barn owls, arctic

| terns, least terns, vesper sparrows, northern parula and common tern all reside or have once

| resided in and around the PNPS area. They are also federally listed as endangered threatened
Appendix A

July 2007 A-105 NUREG-1437, Supplement 29

species and depend on the PNPS area and surrounding area for survival. As early as 2005 |

juvenile Bald Eagles were observed at Plymouth Plantation and "wintering Bald Eagles |

occasionally occur in the area of PNPS. |

|

Further "1400 feet of the transmission line ROW near it's southern and adjacent to the |

boundary of Myles Standish State Forest is designated critical habitat for the red bellied cooter. |

(Critical habitat is habitat that is considered essential to the conservation of the species and |

may require special management)." |

|

These species are under the care of our federal government and PNPS is required to protect |

the place they live. If the PNPS site interfere with their viability and health, any problems caused |

by the operation of PNPS needs to be resolved immediately. (PNPS-D-LL) |

|

Response: The SEIS evaluated the potential for adverse effects on all threatened or |

endangered species, including all species referenced in the above comment, potentially |

occurring in the vicinity of PNPS and its transmission line ROW, in Section 4.6. NRC consulted |

with the U.S. Fish and Wildlife Service under Section 7 of the Endangered Species Act of 1973, |

as amended, regarding listed species within their jurisdiction. The conclusion of the staff was |

that impacts on such species during the renewal period would be small. On May 23, 2006, |

FWS concurred with NRC’s conclusion and informally concluded the consultation. The |

comment provides no new and significant information; therefore, no changes have been made |

to the SEIS in response to this comment. |

|

Comment: Page E-89, Lines 5-10 - states "Continued operation of PNPS may also have the |

potential to affect prey items of various life stages of the red hake, as several prey items of the |

red hake (zooplankton, squid, herring, flatfish species, and mackerel) have been commonly |

reported in the impingement and entrainment sampling program at PNPS. |

|

Red hake like Atlantic cod frequent deeper waters further offshore than those around PNPS. |

This is supported by the 13-year trawl survey conducted by the Massachusetts Division of |

Marine Fisheries (Lawton et al. 1995). Red hake were not among the top six taxa collected in |

that study that involved 1,322 bottom tows between 1970 and 1982. Red hake also prefer softer |

bottoms composed of mud and sand (Collette and Klein-MacPhee 2002) than is prevalent |

around PNPS. |

|

Red hake larvae, juveniles and adults are opportunistic feeders that prey on a wide variety of |

taxa (Luczkovich and Olla 1983, Bowman et al. 2000). Their prey changes seasonally and |

throughout their life history (Steimle et al. 1999). Larval red hake prey on cope pods and other |

microcrustaceans, whereas juveniles consume chaetognaths (arrow worms) and small benthic |

and pelagic crustaceans including amphipods, decapods, mysids, euphausiids, and copepods. |

Adult red hake prey on crustaceans, an assortment of fish species such as haddock, silver |
Appendix A

NUREG-1437, Supplement 29 A-106 July 2007

| hake, sand lance and mackerel, and squid (Steimle et al. 1999). The dominance of these prey

| items changes seasonally, for example "Copepods are important in the fall and winter; arrow

| worms are eaten in the spring and summer" (Collette and Klein-MacPhee 2002).

|

| It is unlikely that red hake would be indirectly affected by entrainment of planktonic organisms

| such as zooplankton that provide food for larger invertebrate prey and small fish - studies have

| shown that these lower trophic level organisms typically survive entrainment. In studies at

| PNPS zooplankton entrained generally showed high survival rates ranging from 95% to 100%

| at most operating conditions (Bridges and Anderson 1984). Larger invertebrates like squid are

| impinged at PNPS but the annual number is not large. The estimated annual average number

| of squid impinged is only 81 animals over the 26-year period from 1980 - 2005. Squid spawn

| year round, grow rapidly, and are short lived (Cadrin 2000). Therefore the impingement of small

| numbers of these animals is not expected to impact the food supply for red hake.

|

| Atlantic herring eggs are not entrained at PNPS because they are demersal and adhere to the

| substrate when spawned. While herring larvae are entrained they originate primarily outside

| Cape Cod Bay and those entrained originate from a large pool of larvae distributed throughout

| the Gulf of Maine and Georges Bank and not a localized population (ENSR 2000, Normandeau

| 2006). Assessment of the potential effects of larval entrainment indicate that equivalent adult

| losses amount to about 0.007% of the regional spawning stock biomass. While herring are

| impinged on the PNPS intake screens the annual estimated number averages only 1,179 fish

| (1980 - 2004, Normandeau 2006).

|

| Atlantic mackerel eggs and larvae are entrained by the circulating water system and juveniles

| and adult are occasionally impinged on the intake screens at PNPS. Analyses suggest that the

| number of age-1 fish that might reasonably be expected to result from the numbers of eggs and

| larvae entrained had they all died are equivalent to 0.2% of the local mackerel landings.

| Ichthyoplankton have also been widely shown to survive entrainment by circulating water

| systems at power stations including PNPS (MRI 1978, 1982, Ecological Analysts 1981, EPRI

| 2000, LMS 2001). Atlantic mackerel are swift swimmers and they are not often impinged at

| PNPS. They occurred in samples during only six years from 1980 - 2005 with an average of five

| individuals annually. In any event, neither entrainment, nor impingement results in the removal

| of plants and animals from the ecosystem. Thus, even those plants and animals that do not

| survive passage through the Station settle to the bottom where they provide food for benthic

| invertebrates that in turn provide food for red hake.

|

| Based on their preference for deeper waters and soft bottom and varied diet it is unlikely that

| the continued operation of PNPS will have a 'substantial adverse effect' on the essential fish

| habitat of red hake. (PNPS-D-MM)

|

|
Appendix A

July 2007 A-107 NUREG-1437, Supplement 29

Comment: Page E-99, Lines 8-13 - states "Continued operation of PNPS may also have the |

potential to affect prey items of the winter flounder, as they have been described as omnivores |

preying on a variety of fish and invertebrate species, many of which have been commonly |

reported in the impingement and entrainment sampling program at PNPS." |

|

Winter flounder is a widely distributed species that is found over a variety of sediment types |

including mud, sand, cobble, and rocks (Pereira et al. 1999). They are among the more |

abundant larvae entrain at PNPS and typically occur on the intake screens (mean occurrence of |

917 fish from 1980-2004; Normandeau 2006). |

|

Winter flounder are opportunistic feeders that prey on a wide variety of taxa. Larvae feed on |

abundant forms of phytoplankton and zooplankton such as diatoms, rotifers, dinoflagellates, |

and copepods (Pearcy 1962, Klein-MacPhee 1978, MRI 1979, 1983). Juveniles are |

"euryphagus"; 27 organisms representing 7 phyla having been identified in their stomachs by |

Pearcy 1962 (see also Klein-MacPhee 1978). Adult winter flounder are described as |

omnivorous "eating whatever is available" (Klein-MacPhee 1978). Chief prey items include |

polychaete worms, anthozoans, isopods and amphipod shrimp. They also prey on small crabs, |

squid, bivalves and other taxa small enough to be consumed with their small mouth (Bowman et |

al. 2000). MacPhee (1969) reported that the most important category of food in a winter |

flounder's diet depends on the type of bottom on which a fish resides. |

|

The DSEIS suggests that winter flounder essential fish habitat will be adversely affected by |

continued operation of PNPS because a variety of fish and invertebrate species are entrained |

and/or impinged. This is unreasonable because all life stages of winter flounder are |

opportunistic feeders that prey on a wide variety of taxa. It is unlikely that flounder would be |

directly or indirectly affected by entrainment of planktonic organisms such as phytoplankton and |

zooplankton - studies have shown that these lower trophic level organisms typically survive |

entrainment. Zooplankton entrained at PNPS generally showed high survival rates ranging from |

95% to 100% at most operating conditions (Bridges and Anderson 1984). Very small fish are |

entrained by the circulating water system at PNPS but they have been widely shown to survive |

entrainment by circulating water systems at other power stations (Ecological Analysts 1981, |

EPRI 2000, LMS 2001). Small fish are also impinged on the intake screens at PNPS but many |

of them have been shown to survive (MRI1984, Normandeau 2006). In any event, neither |

entrainment nor impingement results in the removal of animals from the ecosystem. Thus, even |

those animals that do not survive passage through the PNPS circulating water system remain |

available as food for flounder as well as other animals that are known to become prey for winter |

flounder. |

|

Based on their wide geographic range and varied diet and given that prey are not removed as a |

result of entrainment and impingement it is unlikely that the continued operation of PNPS will |

have a ‘substantial adverse effect' on the essential fish habitat of this species. (PNPS-D-MM) |
Appendix A

NUREG-1437, Supplement 29 A-108 July 2007

| Comment: Page E-73, Lines 38-39 - The DSEIS states" Eggs and larvae of the American

| plaice dominated entrainment studies at PNPS ... "

|

| As widely reported in the fisheries literature adult and juvenile American plaice prefer

| moderately deep water and are found near shore only in colder waters in the northern Gulf of

| Maine approximately 250 miles north of Pilgrim Nuclear Power Station (PNPS) and on

| northward to Newfoundland and Greenland (Collette and Klein-MacPhee 2002). "Adults have

| never been caught in less than 18 m of water in the Gulf of Maine, and their preferred depth off

| the coast of Maine is 100-119 meters" (Sherman et al. 1993). This is far deeper than the 5 to

| 10 meter depths near PNPS. This reported distribution is consistent with local collections

| conducted by the Massachusetts Division of Marine Fisheries as no American plaice were taken

| in 13 years of their bottom trawl survey in the waters around PNPS (1970 -1982; Lawton et al.

| 1995). The Division of Marine Fisheries completed 1 ,322 trawl tows over that period of time

| using methods and equipment that would have been expected to capture American plaice were

| they present in the area. Plaice also were only rarely collected in more recent intensive spring

| bottom trawl sampling around PNPS from 1995 through 2006 and only two individuals were

| impinged at PNPS in the 27 years between 1980 and 2006 (Normandeau 2006). These data

| strongly suggest that PNPS is not located within essential fish habitat for adult and juvenile

| plaice. 

|

| The DSEIS suggests that American plaice eggs dominate entrainment studies at PNPS. This

| statement represents a misunderstanding of the PNPS entrainment data. Plaice spawn pelagic

| eggs primarily between March and May at a time of year when most fish spawn demersal

| adhesive eggs. They therefore account for a relatively high percentage of fish eggs only at that

| time of year although small numbers of them are entrained; typical monthly mean densities

| average less than 3 eggs per 100 m of water. To state that eggs and larvae of the American 3

| plaice dominated entrainment studies at PNPS is misleading since such densities are small,

| particularly when compared to species that produce pelagic eggs at other times of the year.

|

| The DSEIS also states that American plaice larvae dominate entrainment studies at PNPS. 

| This is incorrect. Thirteen species of fish larvae typically account for 95% of the larvae

| entrained at PNPS on an annual basis and plaice is not included among those species.

| Monthly mean densities typically range between 0.1 and 2.1 larvae per 100 m3 of water during

| months when they occur at all and they occur only during the months of March through August

| when several years are considered together. In 2004, for example, they appeared only in April

| and May. 

|

| Finally, irrespective of the numbers of American plaice eggs and larvae collected at PNPS,

| entrainment of American plaice egg and larval life stages represents a mere fraction of those

| life stages present in the larger pool of plaice distributed throughout the Gulf of Maine and

| Georges Bank, not from a localized population inside Cape Cod Bay (ENSR 2000).
Appendix A

July 2007 A-109 NUREG-1437, Supplement 29

Ichthyoplankton collections from Cape Cod Bay (Scherer 1984) indicate that early stage |

American plaice eggs are most common at the mouth of the Bay well to the north of PNPS and |

consistent with their preference for colder, northern waters. For these reasons, it is unlikely that |

the continued operation of PNPS, including entrainment of American plaice eggs and larvae, |

will have a 'substantial adverse effect' on the essential fish habitat of this species. |

(PNPS-D-MM) |

|

Comment: Page E-77, Lines 33-34 - states "Continued operation of PNPS may also have the |

potential to affect prey items of adult mackerel as several of its prey items (small squid and fish |

eggs) are commonly reported in the impingement and entrainment sampling program at PNPS." |

|

Atlantic Mackerel adults are rarely found in the vicinity of PNPS since they are "fish of the open |

sea" and not "directly dependent either on the coastline or on the bottom in any way at any |

stage in their lives" (Collette and Klein-MacPhee 2002). Estimated total numbers impinged |

annually total five individuals over the 1980-2005 time period consistent with their preference for |

open ocean. |

|

The DSEIS suggests that essential fish habitat for adult mackerel will be adversely affected by |

PNPS because squid and fish eggs are entrained and impinged. That conclusion is unrealistic |

because adult Atlantic mackerel consume a wide variety of prey including euphausiid, pandalid, |

and crangonid shrimp, arrow worms or chaetognaths, pelagic polychaetes, squid, copepods, |

amphipods, and a variety of fish species (Bowman et al. 2000, Collette and Klein-MacPhee |

2002). They are opportunistic feeders -- "Practically all floating animals that are neither too |

large nor too small regularly serve to nourish mackerel" (Collette and Klein-MacPhee 2002). |

|

Squid are impinged at PNPS but the annual number is not large. The estimated annual |

average number of squid impinged was only 81 animals over the 26-year period from 1980 - |

2005. Squid spawn year round, grow rapidly, and are short lived (Cadrin 2000). Therefore, the |

impingement of small numbers of these animals is not expected to impact the food supply for |

mackerel. Fish eggs are entrained at PNPS and many of them are expected to survive (MRI |

1978, 1982, Ecological Analysts 1981, EPRI 2000, LMS 2001). In any event, neither |

entrainment nor impingement results in the removal of plants and animals from the ecosystem. |

Thus, even those plants and animals that do not survive passage through the PNPS circulating |

water system remain available as food for other animals that are known to become prey for |

adult mackerel. |

|

Based on the wide geographical range of adult mackerel, their primarily offshore distribution |

and varied diet, it is unlikely that the continued operation of PNPS will have a 'substantial |

adverse effect' on the essential fish habitat of this species. (PNPS-D-MM) |

|

|
Appendix A

NUREG-1437, Supplement 29 A-110 July 2007

| Comment: Page E-96, Lines 37-40 - states "Continued operation of PNPS may also have the

| potential to affect prey items of adult whiting, as several prey items of the whiting (small fish

| and squid) have been commonly reported in the impingement and entrainment sampling

| program at PNPS. Continued PNPS operations may have a substantial adverse effect on EFH

| for the whiting." 

|

| Whiting or silver hake are a wide ranging species utilizing the entire water column over the

| course of the day. They are not among the more abundant species of fish eggs and larvae

| entrained at PNPS and they appear on the intake screens only sporadically. Silver hake eggs

| were collected each year from 1999 to 2006; however, they were one of fourteen species that

| contributed less than 1 % to the annual egg collections during these years. Larvae were

| collected in 1999 to 2003, 2005, and 2006; however, they were one of thirty-eight species that

| contributed at most 7% to the annual larvae collections during these years (Normandeau 2006).

| Numbers of silver hake impinged annually averaged only 35 fish between 1980 and 2006

| (Normandeau 2006). These observations are consistent with the reported distribution of the

| species which includes North American continental shelf waters from North Carolina to

| Newfoundland (Bigelow and Schroeder 1953) and suggest that silver hake are not in any way

| localized around PNPS. 

|

| The DSEIS suggests that whiting essential fish habitat will be adversely affected by PNPS

| because small fish and squid are entrained and/or impinged. This is unreasonable because

| adult and juvenile silver hake prey on a wide variety of taxa including many species of fish such

| as anchovies, hake, herring, mackerel, menhaden, alewives, sand lance, and silversides. They

| also feed on crustaceans and squid (Bowman et al. 2000, Collette and Klein-MacPhee 2002).

| They are opportunistic feeders and their diet varies with season and location (Lock and Parker

| 2004).

|

| There is no information available on entrainment of small squid at PNPS. Larger juvenile and

| adult individuals are impinged at PNPS but the annual estimated total is not large. The

| estimated annual number of squid impinged averaged 81 over the 26-year period from 1980 -

| 2005. Squid spawn year round, grow rapidly, and are short lived (Cadrin 2000) therefore

| impingement of such a small number of animals is not expected to affect the ability of silver

| hake to find adequate food. Very small fish are entrained by the circulating water system at

| PNPS but they have also been widely shown to survive entrainment by circulating water

| systems at other power stations (Ecological Analysts 1981, EPRI 2000, LMS 2001). Small fish

| are also impinged on the intake screens at PNPS but many of them have been shown to

| survive (MRI 1984, Normandeau 2006). In any event, neither entrainment, nor impingement

| results in the removal of animals from the ecosystem. Thus, even those animals that do not

| survive passage through the Station's circulating water system remain available as food for

| other animals that are known to become prey for adult whiting. 

|
Appendix A

July 2007 A-111 NUREG-1437, Supplement 29

Based on their wide geographical range and varied diet and given that prey are not removed as |

a result of entrainment and impingement it is unlikely that the continued operation of PNPS will |

have a 'substantial adverse effect' on the essential fish habitat of this species. (PNPS-D-MM) |

|

Comment: Page 74, Lines 1-5 - states "Continued operation of PNPS may also have the |

potential to affect prey items of various life stages of the American plaice either through |

entrainment of phytoplankton, zooplankton, or ichthyoplankton, or via impingement of small |

forage fish species." |

|

The National Marine Fisheries Service designates essential fish habitat using 10 minute |

squares of latitude and longitude. The size of each block varies with latitude but they are |

approximately 10 nautical miles on each side or approximately 100 square nautical miles in |

area. Such large blocks of habitat are of limited consequence in the open ocean but in coastal |

areas like Plymouth near shore blocks are designated as EFH even though a species preferred |

habitat is in deep water well removed from shore. That is notably the case for American plaice, |

which are rarely found in the immediate vicinity of PNPS because their habitat preference is |

moderately deep water. They utilize relatively shallow water only in the northern Gulf of Maine, |

Newfoundland and Greenland (Sherman et al. 1993, Collette and Klein-MacPhee 2002). |

Fisheries studies around PNPS as well as entrainment sampling at the site support these |

observations. |

|

The diet of the juvenile and adult life stages of American plaice consists of a wide variety of |

invertebrate taxa, particularly benthic invertebrates including brittle stars, sand dollars, |

polychaetes, shrimp, and bivalves (Bowman et al. 2000). American plaice are opportunistic |

feeders - ''They prey on practically any bottom-living animals that are small enough for them to |

devour" (Collette and Klein-MacPhee 2002). Their diet varies and shifts over time in response |

to relative abundance of prey items and to where they are located. For example, in southern |

New England they eat large quantities of amphipods, Crangon shrimp, polychaetes, and |

bivalves while on Georges Bank they consume primarily star fish, brittle stars, and sand dollars |

(Collette and Klein-MacPhee 2002). They occasionally eat small fish such as sand lance (Pitt |

1967) but that does not appear to be an important part of their diet. |

|

The primary contributors to the diet of American plaice are not directly affected by impingement |

at PNPS because many of the invertebrates they prey upon occur on the bottom where they are |

not subject to impingement. It is unlikely that they would be indirectly affected by entrainment of |

planktonic organisms such as phytoplankton and zooplankton that provide food for larger |

invertebrate prey - studies have shown that these lower trophic level organisms typically survive |

entrainment. At PNPS "the combined effects of heat and chlorine had no effect on survival |

rates" of entrained phytoplankton at temperatures below 17C (Bridges and Anderson 1984). |

The majority of productivity studies with entrained phytoplankton at PNPS indicated that |

productivity increased following entrainment (MRI 1978). Studies at other New England power |
Appendix A

NUREG-1437, Supplement 29 A-112 July 2007

| stations indicate that the ability of phytoplankton to carry out photosynthesis is not adversely

| affected by entrainment (MRI 1980). Zooplankton entrained at PNPS generally showed high

| survival rates ranging from 95% to 100% at most operating conditions (Bridges and Anderson

| 1984). Ichthyoplankton have also been widely shown to survive entrainment by circulating water

| systems at power stations including PNPS (MRI 1978, 1982, Ecological Analysts 1981, EPRI

| 2000, LMS 2001). In any event, neither entrainment, nor impingement results in the removal of

| plants and animals from the ecosystem. Thus, even those plants and animals that do not

| survive passage through the Station settle to the bottom where they provide food for benthic

| invertebrates that in turn provide food for American plaice. 

|

| Based upon the information above, continued operation of PNPS will not have a 'substantial

| adverse effect' on the essential fish habitat of the American plaice. Thus, it is erroneous for the

| DSEIS, in Appendix E, to suggest a potential food web or habitat impact. Plaice frequent deep

| water well removed from PNPS, their food supply is diverse and unlikely to be affected either

| directly or indirectly by entrainment or impingement. (PNPS-D-MM)

|

| Comment: Page E-75, Lines 36-40 - states "Continued operation of PNPS may also have the

| potential to affect prey items of juvenile and adult life stages of the Atlantic cod as several prey

| items of the Atlantic cod (sand lance and herring) have been commonly reported in the

| impingement and entrainment sampling program at PNPS. 

|

| The National Marine Fisheries Service designates essential fish habitat using 10 minute

| squares of latitude and longitude. The size of each block varies with latitude but they are

| approximately 10 nautical miles on each side or approximately 100 square nautical miles in

| area. Such large blocks of habitat are of limited consequence in the open ocean but in coastal

| areas like Plymouth near shore blocks are designated as EFH even though a species preferred

| habitat is in deep water well removed from shore. That is notably the case for Atlantic cod. Cod

| juveniles and adults are typically found in deeper waters further offshore than those around

| PNPS (Collette and Klein-MacPhee 2002). While young fish are more common in coastal

| waters they move to deeper waters as they age and mature (Cote et al. 2003). This information

| is supported by the 13-year trawl survey conducted by the Massachusetts Division of Marine

| Fisheries from 1970 to 1982 (Lawton et at. 1995); cod were not among the top six taxa

| accounting for the majority of the catch in 1,322 bottom samples.

|

| Regardless, diet of juvenile and adult Atlantic cod has been extensively studied throughout its

| range and they are known to eat a broad array of taxa (see for example Bowman et at. 2000,

| Collette and Klein-MacPhee 2002, Link and Garrison 2002). Their diet varies and shifts over

| seasons and years in response to relative abundance of prey items. For example, "Cod will

| pursue and gorge on squids anytime they are available." and "Any shellfish a cod encounters

| that can be swallowed whole is likely to be consumed." (Collette and Klein-MacPhee 2002).

| Fish, crabs, lobster, shellfish such as scallops, mussels and clams, squid, sea stars, sea
Appendix A

July 2007 A-113 NUREG-1437, Supplement 29

urchins, sea cucumbers, and shrimp are readily found in their stomachs. While fish are most |

often encountered in their stomachs they feed on a wide variety of species including Atlantic |

herring, Atlantic mackerel, sand lance, silver hake, redfish, and flounder. |

|

The DSEIS states that continued entrainment and impingement of sand lance and herring will |

have a 'substantial adverse effect' on the essential fish habitat of the Atlantic cod. Sand lance |

eggs are not entrained at PNPS because they are demersal and adhere to the bottom. Atlantic |

herring eggs are not entrained at PNPS because they are demersal and adhere to the |

substrate when spawned. While herring larvae are entrained they originate primarily outside |

Cape Cod Bay and those entrained originate from a large pool of larvae distributed throughout |

the Gulf of Maine and Georges Bank and not a localized population (ENSR 2000, Normandeau |

2006). Assessment of the potential effects of larval entrainment indicate that equivalent adult |

losses amount to about 0.007% of the regional spawning stock biomass. While herring are |

impinged on the PNPS intake screens the annual estimated number averages only 1,179 fish |

(1980-2004, Normandeau 2006). Sand lance are also occasionally impinged but they are |

uncommon, an annual average of only 53 fish being recorded over the 1980-2005 time period |

(Normandeau 2006). |

|

Fish and invertebrates entrained and impinged on the intake screens at PNPS are not removed |

from the near shore waters of northwestern Cape Cod Bay. Small organisms that do not survive |

drift to the bottom where they contribute to the nutrition of local benthic organisms. Larger |

animals that may not survive entrainment or impingement are still consumed by scavengers |

such as crabs, lobsters, and fish; these in turn can be eaten by any cod that stray in the vicinity |

of PNPS. It is unlikely therefore that the continued operation of PNPS will have a 'substantial |

adverse effect' on the essential fish habitat of this species. (PNPS-D-MM) |

|

Comment: Page E-97, Lines 35-39 - states "Continued operation of PNPS may also have the |

potential to affect prey items of the windowpane flounder, as one of its prey items (small fish) |

has been commonly reported in the impingement and entrainment sampling program at PNPS." |

|

The DSEIS suggests that windowpane essential fish habitat will be adversely affected by |

continued operation of PNPS because small fish are entrained and/or impinged. This is unlikely |

because windowpane are widely distributed over muddy sediments throughout the Gulf of |

Maine (Chang et a!. 1999) and juveniles and adults are opportunistic feeders. They prey on a |

wide variety of taxa consisting chiefly on fish but also crustaceans. They also consume an |

assortment of other taxa including arrow worms, squids, mollusks, and polychaetes (Bowman et |

al. 2000). |

|

Very small fish are entrained by the circulating water system at PNPS but they have been |

widely shown to survive entrainment by circulating water systems at other power stations |

(Ecological Analysts 1981, EPRI 2000, LMS 2001). Small fish are also impinged on the intake |
Appendix A

NUREG-1437, Supplement 29 A-114 July 2007

| screens at PNPS but many of them have been shown to survive (MRI 1984, Normandeau

| 2006). In any event, neither entrainment nor impingement results in the removal of animals

| from the ecosystem. Thus, even those animals that do not survive passage through the

| Station's circulating water system remain available as food for other animals that are known to

| become prey for windowpane. 

|

| Based on their ubiquitous distribution throughout New England waters and their varied diet and

| given that prey biomass is not removed as a result of entrainment and impingement it is unlikely

| that the continued operation of PNPS will have a ''substantial l adverse effect' on the essential

| fish habitat of windowpane. (PNPS-D-MM)

|

| Response: The comments are noted, and generally concern Essential Fish Habitat (EFH).

| NRC staff does not determine the presence of EFH; rather, the National Marine Fisheries

| Service (NMFS) designates EFH for individual species. The EFH Assessment focuses on

| potential impacts on designated EFH in the vicinity of PNPS while the SEIS evaluates impacts

| on the marine ecosystem and its components. The EFH Assessment has been submitted to

| the NMFS, and the EFH consultation has been concluded by letter dated January 23, 2007

| (ADAMS Accession No: ML070360071). Therefore, the EFH Assessment included in Appendix

| E is considered a final document, and no changes have been made.

|

| A.2.6 Comments Concerning Human Health Issues

|

| Comment: Then they go to the BEIR 7 report and say there is nothing really new or significant

| there to change our determination. The reality is that what they didn't say is what the BEIR 7

| report had to say on the incidents of cancer being a third higher than they previously thought. 

|

| What they didn't say was the BEIR 7, speaking specifically to the greater effect of low dose

| radiation exposure on women and children, over 30 percent higher in woman. What they didn't

| say is the new information on effect on workers, if they receive the maximum allowable dos,

| where NRC had said one out of eight would get cancer, now BIER 7, one out of four. All these

| things are clearly significant. What they didn't say in the draft was the BEIR 7 talked about

| health effects other than cancer that can be expected from low dose radiation exposure such as

| heart disease and stroke. (PNPS-D-D)

|

| Comment: The NRC staff improperly concluded the cumulative impacts would be small, the

| analysis was improper for the following reasons. First, they ignored or misinterpreted new and

| significant information pertaining to Pilgrim that has occurred since the generic environmental

| impact statement was written in 1996. For example, the health impact was determined to be

| small because they misinterpreted that National Academy's BEIR 7 by saying the recent report

| was very, didn't differ, differed very little from the previous.

|
Appendix A

July 2007 A-115 NUREG-1437, Supplement 29

In fact, it stated that the incidents of cancer would be a third higher than previously thought, that |

women were 37.5 percent more likely to get cancer, that workers exposed to the allowable |

maximum dose, one in four would get cancer. (PNPS-D-Q) |

|

Comment: Many radioactive elements seriously damage the molecular composition of living |

cells as the elements decompose and given off high energy particles/ radiation. Thousands of |

Japanese are still dying from the effects of our nuclear bombs (as are their descendents) due to |

genetic damage from the same radiation. (Why should human life, or, rather ALL life, on earth |

be placed in jeopardy in order to produce electricity ?) (PNPS-D-AA) |

|

Comment: Then the NRC goes on in the draft to cite various studies that supposedly say there |

is no association between exposure and living and being near a reactor. |

|

What they did was cherry-pick studies that were the industry's and government's equivalent of |

the tobacco scientists. What they failed to do is to look at all the recent research that is out |

there, and I would refer you, and I will in writing, to Clark University's Marsh Institute that has |

collected all research that is done on this area. (PNPS-D-D) |

|

Comment: NRC staff cite cherry-picked health studies done by the nuclear industry's |

equivalent of "tobacco scientists" that supposedly, though mistakenly, demonstrate that there is |

no correlation between radiation dose from nuclear facilities and cancer to the general public |

and ignoring those studies that do show a correlation. |

|

One Example: NRC highlights the University of Pittsburgh study that "found" no link between |

the radiation released during TMI's 1979 accident and cancer deaths among nearby residents. |

The DSEIS failed to mention a later study by Dr. Steven Wing, associate professor of |

epidemiology at the UNC-CH School of Public Health, who led a study of cancer cases within |

10 miles of the facility from 1975 to 1985. He and colleagues conclude that following the March |

28, 1979 accident, lung cancer and leukemia rates were two to 10 times higher downwind of the |

Three Mile Island (TMI) reactor than upwind. |

|

For a comprehensive review of new and significant studies that indeed show a correlation |

between radiation dose from nuclear facilities and negative health effects in the general public, |

see: BEIR VII and Clark University's Marsh Institute, Health Risks of Ionizing Radiation -an |

overview of epidemiology studies, March 2006. |

http://www.clarku.edu/departments/marsh/projects/community/EpiOverviewFinal.pdf |

(PNPS-D-EE) |

|

Comment: This was recommended back in 1990, we are talking about the future until 2032, so |

you can play your games and not analyze the real, the new and significant information that is |

out there, take your cherry-picked, tobacco science equivalent studies and continue pretending, |
Appendix A

NUREG-1437, Supplement 29 A-116 July 2007

| and also looking at acceptable dose to a mythical, mythical 30 year old healthy guy and not the

| effect that it should be on those who are most sensitive, which BEIR 7 points out are the young,

| the old and the sick. I think that's what I have to say about health. (PNPS-D-D)

|

| Comment: The NRC draft concluded that there was nothing new or significant and the impacts

| from radiation on health would be small, they did this by misinterpreting and ignoring important

| significant information that pertains specifically here. Very basically, they ignored new and

| significant research that shows radiation's effects are cumulative and they affect the most

| vulnerable, the old, the young and the sick. (PNPS-D-D, PNPS-D-EE)

|

| Comment: Standards, allowable releases: NRC's misrepresents the impact of radiation

| released from Pilgrim by inappropriately using the "standard man' or "reference man" as its

| basis for calculating risk and health effects. The so-called standard man is fully matured and

| healthy. BEIR VII states that risks for females and children are much larger than for a 'standard

| man.' That would cause the calculations for risks using the NRC's 'standard man' to be much

| lower than actually experienced by a population at risk unless the population at risk is

| composed totally of 'standard men.' The population of Plymouth County has 51.3% women and

| many children [7% under 5; 26% under 18] who are not correctly considered in the risk

| calculations (US Census data, 2000). Additionally, we know from new research that radiation

| affects the most vulnerable - the sick (discussed above), the young and the old. This makes

| intuitive sense - for example, the older we get, the more vulnerable we become and this is

| borne out by research. By 2030, (1) in (3) people will be over the age of 55, compared to 1 in 5

| now. (PNPS-D-EE)

|

| Comment: Demographics: Communities south of Boston will grow 13% and Plymouth is

| expected to add the most, about 10,000 residents - a population jump of over 20%. By 2030, 1

| in 3 people will be over the age of 55, compared to 1 in 5 now. This is relevant to any analysis

| of health impacts, as new and significant studies have shown an increased sensitivity to low

| levels of ionizing radiation in older populations. (PNPS-D-EE)

|

| Response: Based on their reading of studies such as the BEIR VII report, the SMHS, and the

| Clark study, commenters concluded that the NRC staff’s assessment of the impact of radiation

| dose from the operation of PNPS during the license renewal period is flawed. The commenters

| suggested that NRC and EPA dose standards are too high and do not account for differences in

| dose impact on the young, the elderly, and women.

|

| The assessment in Section 4.7 explains the basis for the NRC staff’s conclusion that the impact

| from radiation exposure to the public is SMALL. The NRC staff concludes the impact is SMALL

| because doses to members of the public from PNPS effluents are well within the NRC and EPA 
Appendix A

July 2007 A-117 NUREG-1437, Supplement 29

radiation dose standards. The doses are also much smaller than the doses that members of |

the public receive from other sources of radiation such as natural background radiation and |

medical procedures. |

|

The dose standards were set conservatively by NRC and EPA based on the conclusions and |

recommendations of numerous national and international expert panels. These dose standards |

are based on the linear-no-threshold dose response model described in the BEIR VII (and in |

the Clark study). |

|

The dose standards were set conservatively by NRC and EPA in part to account for the |

potential uncertainties noted by the commenters. The information and the studies put forth by |

the commenters did not change the NRC staff’s bases or conclusions. Section 4.7 has been |

revised to clarify the bases for the NRC’s radiation dose standards. |

|

Comment: Also, they ignored in the draft the continued pattern of increased radiation-linked |

diseases. A look at the cancer registry by the former founder and Director of the Massachusetts |

Cancer Registry and a professor at Boston University has seen a continued increase, elevated |

levels, of thyroid cancer, leukemia, multiple myeloma, prostate, to name a few. (PNPS-D-Q) |

|

Comment: Additionally, the Massachusetts Cancer Registry for the years 1998 through 2002 |

shows a continuing increase of leukemia and thyroid cancer around here. No one knows exactly |

how much radioactive iodine has been and is being released from Pilgrim because there is not |

adequate monitoring or reporting, we don't know, I mean we do know that large releases were |

measured in the '70s and '80s but today no one knows what's coming out of the plant. If this |

plant is relicensed as is, we will never know, the least we should have is adequate real-time |

monitoring and reporting displayed in all communities as part of the public record. (PNPS-D-K) |

|

Comment: No verifiable health impact has been detected or certified to have resulted from the |

plant's presence or operations. I'll just add to this our committee had Dr. Sid Nuremberg and |

the head of nuclear medicine at the hospital, came in with boxes of supporting evidence to say |

while there were spots of cancer in the town, the type of cancer caused by nuclear radiation is |

virtually nonpresent. (PNPS-D-L) |

|

Comment: I believe that Pilgrim and the cancer rates in the region are related. (PNPS-D-X) |

|

Comment: By 2032, during the licensing period, the population is expected, one in three, to be |

over 55, it's one in five now, therefore a more vulnerable population will be in this area. Second, |

they ignored the radiation-linked diseases that are in this area. The former founder and director |

of the Mass Cancer Registry has done an analysis, year to year, of cancer statistics in the |

seven communities that are likely to be impacted which was determined from a state study on |

health impact. They have seen, every single year, either statistically significant or elevated rates |
Appendix A

NUREG-1437, Supplement 29 A-118 July 2007

| of leukemia, rates of thyroid cancer until this very day, this was ignored. Also ignored was the

| fact of elevations in prostate and multiple myeloma from 1999 to '02. Therefore, again, a

| population that is sensitive. (PNPS-D-D)

|

| Comment: The Massachusetts Cancer Registry also shows, for the years 1998-2002, a

| continuing increase of leukemia and thyroid cancer in the towns around PNPS. Specifically,

| there were 83 cases of leukemia reported to the Massachusetts Cancer Registry (MCR), where

| 72.9 would have been expected based on statewide rates. This results in a Standardized

| Incidence Ratio (SIR) of 114 (95% conf. int. = 91-143). In addition, there was excess thyroid

| cancer in these same towns for the same time period. The thyroid cancer SIR was 122 (95%

| conf. int. = 96-155). In other words, leukemia was 14% elevated over the statewide rate and

| thyroid cancer was 22% elevated. Neither of these calculations were statistically significantly

| elevated by the usual convention (P<.05), but there were more cases than expected

| nevertheless. This means there is a continuing excess of these two radiation-related cancers in

| the population, as there was in the 1980s.

|

| Prostate cancer and multiple myeloma, both radiation-linked diseases, are also elevated and

| statistically significant for the years 1998-2002 in the seven towns most likely to be impacted

| near Pilgrim (Carver, Duxbury, Kingston, Marshfield, Pembroke, Plymouth, and Plympton). The

| seven towns listed are those that a meteorological analysis done by Dr. Spengler and Dr.

| Keeler for Massachusetts Department of Public Health indicated are most impacted by the sea

| breeze effect. 

|

| These new and significant site-specific studies show that the area is a damaged, sensitive

| population, and consequently less able to tolerate additional assaults. (PNPS-D-EE)

|

| Comment: I would like to address the issue of Pilgrim's impact on public health, I think the

| commission has a responsibility to look at site-specific information on this issue. Thyroid cancer

| and thyroid disease are clearly radiation-linked, radioactive iodine released from reactors is

| drawn into the thyroid, often resulting in cancer and thyroid disease. Examples of widespread

| increases in thyroid cancer has occurred in the communities around Chernobyl, and Marshall

| Islands and Hanford, another example of this type of increase occurred right here near Pilgrim. 

|

| As a result of radiation releases in the early and mid '70s and some really big ones in June of

| 1982, cases of thyroid cancer and leukemia in the surrounding area were significantly elevated.

| Recognizing the effect of Iodine 131 on the thyroid, the NRC has implemented the Potassium

| Iodide Program. I have a box in my cellar for my family but I don't need it, since they weren't

| offering back in 1982 and now I don't have a thyroid anymore. So the draft statement that there

| have been no health effects here is very incorrect. 

|

|
Appendix A

July 2007 A-119 NUREG-1437, Supplement 29

In his report to the Southeastern Massachusetts Health Study Review Committee in 1992, Dr. |

Richard Clapp, former director of the Massachusetts Cancer Registry, presented a graphical |

assessment showing elevated cases of leukemia and thyroid cancer in the towns closest to |

Pilgrim during the period of '82 to '89, a second graph depicted the pattern of thyroid cancer in |

the same set of towns, it shows a peak in the years 1987 and 1988, the year I was diagnosed. |

These patterns of cancer incidents are consistent with the predicted health effects of the |

radiation released in the early 1980s. |

|

Since the NRC recognizes the dangers of Iodine 131 to our health and Pilgrim has indeed had |

a negative impact on public health, this case should require a site-specific review as part of the |

renewal process. (PNPS-D-K) |

|

Comment: Thyroid cancer and thyroid disease are clearly radiation-linked. Radioactive iodine |

released from reactors is drawn into the thyroid often resulting in cancer and thyroid disease. |

|

Examples of widespread increases in thyroid cancers occurred in communities around |

Chernobyl, Marshall Islands, and Hanford. |

|

Another example of this type of increase occurred near Pilgrim. As a result of radiation releases |

in the early and mid 1970s, and some big ones in June of 1982, cases of thyroid cancer and |

leukemia in the surrounding area were significantly elevated. |

|

Recognizing the effect of I131 on the thyroid, the NRC implemented the Potassium Iodide (KI) |

program. |

|

The Draft Statement (SEIS) that there have been no health effects here is very incorrect. In his |

report to the Southeastern Massachusetts Health Study Review Committee [June 26, 1992] Dr. |

Richard W. Clapp, former director of the Massachusetts Cancer Registry, presented a graphical |

assessment showing elevated cases of leukemia and thyroid cancer in the towns closest to |

Pilgrim during the period 1982-1989. A second graph depicted the pattern of thyroid cancer in |

the same set of towns. It shows a peak in the years 1987-1988 - the year I was diagnosed. |

These patterns of cancer incidence are consistent with the predicted health effects of the |

radiation released in the early 1980s. |

|

Additionally the Massachusetts Cancer Registry for the years 1998-2002, shows a continuing |

increase of leukemia and thyroid cancer around here. |

|

No one knows exactly how much radioactive iodine has been, and is being released from |

Pilgrim - Because there is not adequate monitoring and reporting. We do know that large |

releases were measured in the '70s and '80s but today no one knows what's coming out of |
Appendix A

NUREG-1437, Supplement 29 A-120 July 2007

| Pilgrim. If this plant is relicensed "as is" we will never know. The least we should have is

| adequate, real-time monitoring and reporting displayed in all communities as part of the public

| record. 

|

| Since the NRC recognizes the dangers of I131 to our health, and Pilgrim has indeed had a

| negative impact on public health, this case should require a site-specific review as part of the

| renewal process. (PNPS-D-Z)

|

| Response: These comments refer to data from the Massachusetts Cancer Registry and

| evaluations of data by people such as Dr. Richard Clapp, former Director of the registry, and

| concluded that the data showed elevated levels of cancer in the towns near PNPS. Section 4.7

| of the SEIS addresses Dr. Clapp’s evaluations. Section 4.7 discusses the fact that the doses to

| members of the public are well below NRC and EPA radiation protection standards. Section

| 4.7 also discusses the large body of evaluations and recommendations from national and

| international expert groups upon which NRC bases estimates of radiation risk. Finally, Section

| 4.7 discusses the difference between identifying statistical relationships in health statistics and

| showing a causal relationship. The information presented by the commenters failed to

| demonstrate a causal relationship; therefore, the NRC staff’s conclusions in Sections 4.3 and

| 4.7 did not change. Section 4.7 was revised to clarify the basis for NRC’s conclusions.

|

| Comment: They also ignored looking further at the Southeastern Massachusetts Health Study.

| They didn't ignore it, they simply misrepresented it, which is quite shameful, I might add. The

| Southeastern Massachusetts Health Study stated, was a study done by the Mass Department

| of Public Health on adult leukemia and found a, concluded a fourfold increase the closer you

| lived or if you worked at the reactor. Then there was a re-review, a second peer review panel,

| politically appointed so that Boston Edison, the then owner, could appoint half the panel and

| approve the half. 

|

| However, the draft says that the NRC considered the relevant information in the re-review --

| they didn't use that word -- and concludes that the peer reviews and even the authors now

| agree that the study does not demonstrate a casual relationship between Pilgrim effluents and

| the potential effect of cancers in the areas around the state. So, I called the principle author of

| the study and I said did you talk to them? He said no, I never talked to them, I stand by this

| study, as did Boston Edison's own peer review panel, hand-picked, that said the results can not

| be discarded because of methodological weaknesses.

|

| And I said, well, what about the Assistant Commissioner, Suzanne Condon? What did she say?

| And I have e-mails to this effect, oh, she said the department stands by these studies, this

| particular study, and then went on further, the association between leukemia and the proximity

| to Pilgrim was unexpectedly strong and this raised biological plausibility of the study, the study

| results could not be dismissed. (PNPS-D-D)
Appendix A

July 2007 A-121 NUREG-1437, Supplement 29

Comment: I believe the NRC's EIS minimizes the health risks of radiation releases from the |

plant. I feel the 1990 DPH publication mischaracterized the study of increased cancer |

incidences in South Eastern Massachusetts. (PNPS-D-D) |

|

Comment: Mischaracterizing Massachusetts Department of Public Health's Southeastern |

Massachusetts Health Study (SMHS): SMHS is a case control study that found a four-fold |

increase in adult leukemia. Boston Edison (BECO), the owner of Pilgrim at the time, cut a |

political deal which allowed BECO, the implicated industry, to appoint a second peer review |

panel to re-review the study and write a report. The NRC Staff in the DSEIS misinterpret the |

second re-review peer group and state in the DSEIS, |

|

...with regard to the SMHS, NRC has considered the relevant information in these citations and |

concludes that the peer reviews and even the authors now agree that the SMHS does not |

demonstrate a causal relationship between the PNPS effluents and the potential effect of |

excess cancers in the areas around the site. |

|

a) The authors of the study [Dr. Robert S. Knorr, Director, Environmental Epidemiology |

Program Center for Environmental Health, MDPH] never spoke to the NRC staff on this issue ; |

additionally Suzanne Condon, Associate Commissioner MDPH stated that, "the only |

conversations she ever had about our study and/or cancer rates with the NRC always |

emphasized that we continue to stand by our original conclusions." |

|

The author of the SMHS study continued by pointing out that the re-review panel concluded: |

|

The [original SMHS] study team adhered to generally accepted epidemiological principles.." and |

"the findings of the SMHS cannot be readily dismissed on the basis of methodological errors or |

proven biases...;" and |

|

The association found between leukemia and proximity to the Pilgrim nuclear facility was |

unexpectedly strong and, this raised concern regarding the biologic plausibility of the study. |

...because the study results could not be dismissed, further study may be warranted, including |

expanding case finding and including children. |

|

The NRC's statement that the MDPH indicated that the findings demonstrated cause and effect |

is incorrect. The MDPH report specifically states that it is not possible to reach definitive |

conclusions regarding cause and effect but that the results should be followed up to clarify their |

public health implications. This conclusion is consistent with that stated by the peer reviewers. |

While the findings of the study may not support a causal relationship, the NRC arguments in |

their Supplemental Impact Statement ignore the principal MDPH and peer review conclusions |

that the findings cannot be dismissed. (PNPS-D-EE) |

|
Appendix A

NUREG-1437, Supplement 29 A-122 July 2007

| Comment: The NRC DSEIS concludes that the health impact is and will continue to be small

| by mischaracterizing the Southeastern Massachusetts Health Study. The DSEIS states that the

| authors of the Southeastern Massachusetts Health Study have stated that the study shows both

| a statistical association and a cause and effect relationship between leukemia incidents around

| the nuclear power plant and exposure to effluents from the plant.

|

| The final report released to the public in October of 1990 found a two to fourfold increase of

| leukemia among residents of certain towns within a 20 mile radius of the plant, the draft goes

| on to cite peer reviews from a second re-review peer group that did not support the casual

| relationship. However, the peer review panel referred to in the draft was appointed by Boston

| Edison's request, the owner of Pilgrim at the time, and contrary to accepted scientific practice,

| half of the re-review panel members were appointed by MDPD and the other half by Boston

| Edison, the company directly impacted and implicated by the study's findings.

|

| In the executive summary of its report though, the second peer review panel concluded that the

| findings can not be readily dismissed on a basis of methodological errors or proven biases, the

| association found between leukemia and the proximity to the Pilgrim nuclear facility was

| unexpectedly strong and this raised concern regarding the biological plausibility of the study.

| However, because the study's results could not be dismissed, further study may be warranted,

| including expanding the case finding and including children. 

|

| The study noted that Boston Edison admitted higher than average releases in the early days

| due to poor fuel or damage rods and lack of filtration systems, the study researchers also knew

| that a number of possible points were not monitored and the monitors on even the main stack

| did not measure all types of radiation, that significant radiation had been reported in shellfish,

| milk and vegetation near the plant. The re-review panel member schooled in monitoring was a

| Boston Edison employee who discounted any unmonitored releases and blamed the too high

| radiation levels in milk and vegetation on bomb testing in China. 

|

| The panel also claimed that if Pilgrim had released significant levels of radiation, it would have

| been detectable on large numbers of monitors throughout Eastern Massachusetts. However,

| the Boston Edison appointee was questioned on this and he conceded that, in 1970, there

| existed only three monitors, one at Pilgrim, another at MIT Cambridge keeping track of MIT's

| reactor and a third in South Boston keeping tabs on DuPont. These had the same lack of 

| sensitivity as Pilgrim's and were too far away to realistically have been expected to detect

| Pilgrim's emissions.

|

| The inescapable conclusion is that, both in the 1970s and now, no one really knows how much

| radiation Pilgrim emitted. The re-review panel effectively admitted as much, suggesting that

| there should be an independent evaluation of the potential radiation exposure from the Pilgrim

| plant and from other sources. The study was even more explicit, it recommended that a system
Appendix A

July 2007 A-123 NUREG-1437, Supplement 29

of real-time monitoring and radio nucleotide emissions be implemented so that reliable and |

timely data are available by which exposure can be assessed more precisely. |

|

The re-review panel's statement in the study's conclusion is contradicted by the fact that the |

death rates for the study have remained close to the state average exemplifies the how to lie |

with statistics problem. The re-review panel looked at death rates for Plymouth County as a |

whole, the Southeastern Mass study found an increased risk in those, to those in a much |

smaller, more concentrated area likely, within the likely to be impacted geographic area. The |

re-review panel's executive summary admitted that there have been other reports of observed |

cancer increases that are inconsistent with predictions based on mathematical modeling and |

radio biology theory. |

|

In 1990, the Southeastern Mass findings was not based on mathematical models or estimates |

of radiation releases, rather it was focused on what really happened to real people. The NRC's |

impact statement ignores the principle Mass Department of Public health and peer review |

conclusions that the findings can not be dismissed and that further attention to the possible |

risks associated with the power plant may be warranted, including expanding case findings and |

including children. (PNPS-D-G) |

|

Comment: The comments provided specifically address section 4.7 ("Evaluation of New and |

Potentially Significant Information on Impacts of Operation during the Renewal Term), pages |

4.65-4.66. This section discusses the Southeastern Massachusetts Health Study (SMHS) that |

was conducted by the Massachusetts Department of Public (MDPH). |

|

On page 4.66, beginning on line 5 text reads "...with regard to the SMHS, NRC has considered |

the relevant information in these citations and concludes that the peer reviews and even the |

authors now agree that the SMHS does not demonstrate a causal relationship between the |

PNPS effluents and the potential effect of excess cancers in the areas around the site." The |

MDPH believes this statement is neither a correct summarization of the peer reviews nor the |

author's published or unpublished opinions. The correct summarization of the second peer |

review panel would be that: |

|

1. The findings cannot be readily dismissed on the basis of methodological errors or proven |

biases; |

|

2. The association found between leukemia and proximity to the Pilgrim nuclear facility was |

unexpectedly strong and, this raised concern regarding the biologic plausibility of the study; and |

|

3.However, because the study results could not be dismissed, further study may be warranted, |

including expanding case finding and including children. (PNPS-D-II) |

|
Appendix A

NUREG-1437, Supplement 29 A-124 July 2007

| Comment: The specific statement in the draft report found on page 4-66, lines 7-8, "the SMHS

| does not demonstrate a causal relationship between the PNPS effluents and the potential effect

| of excess cancers in the areas around the site", is specifically not correct for the following

| reasons. The MDPH report specifically states that it is not possible to reach definitive

| conclusions regarding cause and effect but that the results should be followed up to clarify their

| public health implications. This conclusion is consistent with that stated by the peer reviewers.

| While the findings of the study may not support a causal relationship, the NRC arguments in the

| Supplemental Impact Statement ignore the principal MDPH and peer review conclusions that

| the findings cannot be dismissed and that further attention to the possible risks associated with

| the power plant may be warranted. (PNPS-D-II)

|

| Comment: They also misinterpreted the Southeastern Massachusetts Health Study, the state

| study that found a fourfold increase in adult leukemia. And I understand they now appreciate

| that they misquoted or misunderstood and will be going back to DPH, the authors of that study

| and the assistant commission have held, have stated equivocally, and I will include their e-mails

| and correspondence in my written testimony, that they stand behind that study. (PNPS-D-Q)

|

| Response: These comments address the Southeastern Massachusetts Health Study

| conducted by the Massachusetts Department of Public Health. The study is discussed in

| Section 4.7 and Section 4.7 has been revised in response to these comments.

|

| Comment: Background radiation: The NRC staff attempts to minimize the impact of the

| reported amount of radiation released from Pilgrim by stating it is but a small per-cent of

| background radiation. They incorrectly claim that, "The average dose of approximately 360

| mrem/yr from natural background and medical sources of radiation (NRC 2005)." That number

| is a national average - not applicable here. The soil in Plymouth and surrounding towns is

| largely sand containing very little uranium, thorium and radium. We are not Denver, Colorado,

| for example. (PNPS-D-EE)

|

| Response: Background radiation levels vary across the U.S. and even from one house to the

| next and from one person to another. This variation is due to the large range of potential

| differences in the different components that comprise it. Potential differences include the levels

| of naturally occurring radioactive materials in the near-surface soils, variations in the

| construction materials for residences and workplace, differences in elevations, and medical

| procedures.

|

| The National Commission on Radiological Protection addresses the difference in the natural

| radiation background across the U.S. in their NCRP Report Number 94, “Exposure of the

| Population in the United States and Canada from Natural Background Radiation”. This report
Appendix A

July 2007 A-125 NUREG-1437, Supplement 29

presents data summarizing the available information on the levels of natural radiation in the |

environment, the consequent average exposures, and radiation doses to the population and, |

wherever possible, the distribution, or at least the variability, of these factors. |

|

NRC uses the average value of the background radiation levels to put doses from the plant’s |

operations in perspective. Although the background varies, it is much larger than the dose |

resulting from PNPS operations. Section 4.7 has been revised to clarify the statement on |

background radiation levels. |

Comment: With the June 1982 blow out of filters and subsequent radiation releases as an |

excellent example of "accidental radiation releases" at alarming levels and with horrific varieties |

of radionuclides - human health effects are inevitable and I would expect to find visible effects |

of radiation damage to the flora and fauna of the surrounding areas of Pilgrim facility - such as |

that occurring for the past 28 years around Three Mile Island ... Not only concern for flora and |

fauna - but for all editables! Thus increasing the risks for concerns. (PNPS-D-PP) |

|

Comment: It is known for example that the following radionuclides have been released from |

Pilgrim into neighboring communities: plutonium 239 (half life 24,400 years); neptunium 236 or |

237 (half life ranging from 120,000years -2.1 million years); cesium 137 (half life 30.2 years); |

strontium 90 (half life 28.5 years); tritium (half life 12.3 years), and xenon (half life 9.17 hours). |

Xenon transforms after its emission into cesium 135, which persists almost indefinitely in the |

environment. Examples of previous releases have been reported in the Annual Radiological |

Environmental Monitoring Program Reports [REMP]. |

|

These releases include substances that will remain active in the local environment for the |

foreseeable future and should have been taken into account when actual on-going doses to the |

public are evaluated. (PNPS-D-EE) |

|

Comment: I am also very concerned with any release of radioactive effluent into the |

environment and need to ask how the dosage suggested on page 140 translates to lamens |

terms. Also, because this release of radioactive effluents has not changed and "the impact to |

the environment has not changed," how is this impact determined? How much is too much? |

How much radioactive effluence is OK? Who makes this determination? (PNPS-D-LL) |

|

Comment: What about the radioactive GASES given off such as XENON 137 which decays |

into CESIUM 137 (half life of 30 years)? What about water around nuclear reactors where |

tritium has been absorbed... Tritium is absorbed by living cells and can stay in the body from 1 |

to 25 years....causing cellular defects such as tumors, retardation, etc. etc. It is also taken up |

by plants, not just animals like us. You say, perhaps..."Well, there is danger in all forms of |

energy....." but the danger doesn't persist for centuries! What about XENON 135 that decays |

into CESIUM 135 (half life - 3 MILLION years)? Etc., etc., etc. Nuclear power is NOT cheap. |

(PNPS-D-AA) |
Appendix A

NUREG-1437, Supplement 29 A-126 July 2007

| Response: There are numerous NRC regulations in place to ensure that the licensees

| maintain adequate control over radioactive effluents. Most notable are 10 CFR Part 20,

| Standards for Projection Against Radiation and 10 CFR Part 50, Appendix I, Numerical Guides

| for Design Objectives and Limiting Conditions for Operations to Meet the Criterion “As Low As

| Is Reasonably Achievable” (ALARA) for Radioactive Material in Light-Water-Cooled Nuclear

| Power Reactor Effluents. These regulations provide standards and requirements for the control

| of radioactive materials to limit radiation exposure to occupational workers and members of the

| public and impacts to the environment. Also, the regulations contain provisions which require

| the licensee to maintain exposures to the ALARA standards.

|

| As required by NRC regulations, the amounts of radioactive isotopes released from Pilgrim in

| liquid and gaseous effluents are constantly monitored and recorded by Entergy. The

| meteorological conditions at the site also are constantly monitored and recorded. Health

| physics experts from NRC's Region I office routinely inspect these monitoring programs to

| ensure that they are being properly implemented. All of this information is fed into calculational

| models that estimate the amount of radiation dose a member of the public might receive. These

| models include estimates of dose from internally deposited radioactive isotopes as well as

| direct radiation exposure. In addition, Entergy conducts an environmental radiological

| monitoring program in the area around Pilgrim. This program has also been reviewed and

| approved by the NRC and is inspected by the health physics experts from NRC's Region I

| office. The environmental radiological monitoring program samples and measures the amount

| of radioactive isotopes in the air, water, soil, agricultural products, shoreline sediments, and

| aquatic biota and measures direct radiation from the plant using thermoluminescent dosimeters

| (TLDs). This program confirms the levels of radioactive isotopes in the environment that are

| predicted by the computer dose models. This program will also identify any radionuclides that

| may be accumulating in the environment around Pilgrim. Also, the Massachusetts Department

| of Public Health conducts an environmental radiological monitoring program around Pilgrim.

| While Pilgrim may have experienced significant fuel defects and released transuranic

| radioisotopes earlier in plant operation, NRC believes that the recent effluent reports are the

| best source of information to help estimate the amount of each type and total amount of

| radioactive materials that will be released from the plant during the license renewal period. 

|

| Chapters 2 and 4 of the SEIS include the staff’s assessments of radiological effluents and

| impacts that are expected during the license renewal period at PNPS. These comments

| provided no new information. Therefore, no changes have been made to the SEIS.

|

| Comment: Bio-Accumulation of Radionuclides in the Environment from 1972-2032 -ignored 

|

| The effects of radiation exposure are cumulative; this is ignored by NRC staff in the Draft.

| Some types of nuclear power plant emissions stay radioactive for a long time and, because

| they can enter biological food chains, those materials can accumulate in the environment and
Appendix A

July 2007 A-127 NUREG-1437, Supplement 29

adversely affect public health. "If radioactive emissions persist for years, decades or even |

centuries within the environment, then even modest reductions in annual discharges may not be |

sufficient to prevent an environmental build up of those materials over time." Estimates of |

Environmental Accumulations of radioactivity Resulting from Routine Operation of New England |

Nuclear Power Plants (1973-84), Dr. Richard W. England,, Mr. Eric Mitchell, p.4, A Report of |

the Nuclear Emission Research Project, Whittemore School of Business and Economics, |

University of New Hampshire, Durham, N.H., August 1987. (PNPS-D-EE) |

|

Response: The Pilgrim Radiological Effluent and Waste Disposal Reports and Radiological |

Environmental Monitoring Program Reports for 2002-2006 are considered to be representative |

of facility operations during the renewal period. Any gradual buildup of radioactive materials in |

soils, sediment, and subsequent incorporation into plants or bioaccumulation in fish or |

mammals from past and current operations would have been reported in the Environmental |

Monitoring Program Reports. These data show that all plant operational releases of |

radionuclides are monitored, releases are below the regulatory limits established for safe |

operations, and accumulation of radionuclides in environmental media or in the food chain have |

not been significant. The comment provided no new information. Therefore, no changes have |

been made to the SEIS. |

|

Comment: I believe the high levels of mercury in my body are related to Pilgrim. (PNPS-D-X) |

|

Response: The Commonwealth of Massachusetts does not require PNPS to monitor mercury |

in any gaseous or liquid effluents. The NRC staff would not expect mercury to be part of the |

effluents released from PNPS. |

|

This comment provides no new information; therefore, no changes have been made to the |

SEIS. |

|

A.2.7 Comments Concerning Socioeconomic Issues |

|

Comment: I can also tell you that the majority of my members that work at that plant live |

around the plant, which says something. They are proud of what they do there and they feel |

completely safe with themselves and their family, that is quite a statement. Over 85 percent of |

them live in Plymouth and Barnstable County. (PNPS-D-O) |

|

Response: The DSEIS in Section 2.2.8.1 notes the location of Entergy's approximately 700 |

employees by county and town/city (Table 2-6). As shown in the data provided by Entergy, 80 |

percent of the PNPS permanent workforce lives in Plymouth or Barnstable counties. This |

comment provides no new and significant information. Therefore, no changes have been made |

to the SEIS. |

|
Appendix A

NUREG-1437, Supplement 29 A-128 July 2007

| Comment: Page 2-123, Lines 1-14 - NPS (Entergy) should be listed as one of the largest

| employers. With over 700 employees, it would be the second largest employer in Plymouth per

| the numbers listed in this section. (PNPS-D-MM)

|

| Response: The DSEIS, in Section 2.2.8.1 notes the location of Entergy's approximately 700

| employees by county and town/city. Section 2.2.8.6.1 further discusses employment in the

| Plymouth area citing Old Colony Planning Council data. The text in Section 2.2.8.6.1 has been

| changed to specifically note that Entergy is one of the town’s largest employers.

| Comment: Speaking of work, Pilgrim is also an important source of jobs, it has more than 700

| permanent full-time employees, most of whom live in Plymouth and the surrounding

| communities, indeed Pilgrim supports the local economy to the tune of $135 million in local

| economic activity. Though the draft environmental impact statement noted a moderate

| socioeconomic impact should the plant cease operations, we believe those who would lose their

| jobs would face a large economic and financial loss. (PNPS-D-E, PNPS-D-P)

|

| Comment: I think we need to keep our children near us in Massachusetts, our grandchildren

| near us, and we now are dealing with the slow down, if you will, on the redevelopment of power

| plants. I am concerned about the workers who do work at the plant, we do have 400 or 500

| families, I would be very sorry to see them go. (PNPS-D-V)

|

| Response: The DSEIS, in Section 8.1.8 notes that closure of PNPS would have Moderate

| socioeconomic impacts. This statement does not deny that direct and indirect effects to

| employees, etc. could be Large; rather, the statement attempts to place the potential

| consequences of closure within the context of the regional economy. In the context of projected

| employment in Plymouth town in 2010 (Old Colony Planning Council [OCPC], Comprehensive

| Economic Development Strategy: Keeping Our Region Competitive, 2006), the loss of 700

| employees would represent 3.4 percent of employment in the town, or 0.5 percent in the larger

| OCPC region. Moreover, OCPC projects employment growth in both the region and the town

| will exceed 19 percent over the period 2000-2025. In this context the direct loss of the PNPS

| employment is likely to be moderate and relatively temporary in the context of the region's

| anticipated growth. These comments provide no new and significant information. Therefore,

| no changes have been made to the SEIS.

|

| Comment: Page 2-124, Lines 32-33 - Entergy has a PILOT (payment in lieu of taxes)

| arrangement with the Town of Plymouth which was signed on March 5, 2002 and became

| effective for FY 2003, not 2007 as stated. It is NSTAR which has payments of $1 million which

| begin in 2007, not Entergy. Refer to 2nd paragraph of Section 2.7 in the PNPS Environmental

| Report. (PNPS-D-MM)

|

| Comment: Page 2-124, Lines 3 and 23-24 - Entergy has a PILOT (payment in lieu of taxes)

| arrangement with the Town of Plymouth. (PNPS-D-MM)

|
Appendix A

July 2007 A-129 NUREG-1437, Supplement 29

Response: The text in Section 2.2.8.6.3 has been changed to more accurately reflect the |

Entergy PILOT arrangement with the Town of Plymouth (ADAMS Accession No. |

ML063260173). |

|

Comment: The collusion between member corporations of the nuclear industry, their lobbying |

arm NEI, and members of the United States government have in fact and deed negatively |

impacted upon the quality of this comment filers life, negatively impacted the true value of real |

estate value of statement filer, and put said filer in a situation of grave financial risk should a |

nuclear incident occur at any nuclear facility in America, as a result of the wrongful passage of, |

and extension of the Price Anderson Act that limits the financial liability of the owners of Nuclear |

Power Reactors here in America. (PNPS-D-A) |

|

Comment: Further, said application, and subsequent Draft EIS rely upon out dated and no |

longer accurate data and assumptions, since the human inhabitation within the area of impact |

surrounding the Pilgrim Nuclear Power Plant has dramatically changed since the original grant |

of license for said facility. (PNPS-D-A) |

|

Comment: I believe there will be more investment in Plymouth, if Pilgrim is stopped. |

(PNPS-D-X) |

|

Response: The DSEIS provides current socioeconomic data in Section 2.2.8, including data |

on housing, public services, land use, demography, and the economy. Investment in the |

Plymouth area may be gauged by the recent growth of population, housing and jobs. The US |

Census reports a population growth of 8.6 percent in Plymouth county in the 1990s and 19.9 |

percent in Barnstable county; these rates of growth substantially exceed the 5.5 percent in the |

state as a whole during this period. Similarly, occupied housing units increased in Plymouth by |

12.6 percent and in Barnstable by 22.2 percent, compared to the state's growth of 8.7 percent. |

Growth of employment reported by Old Colony Planning Council (OCPC) for Plymouth town |

over the 1990s was 18.6 percent, and in the OCPC region was 11.4 percent (Old Colony |

Planning Council, Comprehensive Economic Development Strategy: Keeping Our Region |

Competitive, 2006). This compares to a growth of 4.4 percent for the state as a whole over the |

same period. Moreover, projections for employment in the OCPC region are strong, with a |

projected 19.3 percent growth for Plymouth over 2000-2025 and 19.8 percent for the OCPC |

region. In terms of value of housing, median house values in Plymouth county increased by |

14.9 percent over 1990-2000, compared to the state's 14.5 percent. Thus, there is no evidence |

to support the assertion that PNPS has depressed growth and/or values in its region over the |

past decade or more. These comments provide no new and significant information. Therefore, |

no changes have been made to the SEIS. |

|

|
Appendix A

NUREG-1437, Supplement 29 A-130 July 2007

| A.2.8 Comments Concerning Land Use Issues

|

| Comment: Page 4-51, Line 8 - Entergy has a PILOT (payment in lieu of taxes) arrangement

| with the Town of Plymouth which was signed on March 5, 2002 and became effective for FY

| 2003, not 2007 as stated. It is NST AR which has payments of $1 million which begin in 2007,

| not Entergy. Refer to 2nd paragraph of Section 2.7 in the PNPS Environmental Report. 

| (PNPS-D-MM)

|

| Comment: Page 4-51, Lines 15-17 - NSTAR payments are not payments made by PNPS, but

| are as the result of deregulation. (PNPS-D-MM)

|

| Comment: Page 2-20, Lines 31-32; Page 4-51, Line 1 - Entergy has a PILOT (payment in lieu

| of taxes) arrangement with the Town of Plymouth. (PNPS-D-MM)

|

| Response: The text has been changed to more accurately reflect the Entergy PILOT

| arrangement with the Town of Plymouth. (See ADAMS Accession No. ML063260173)

|

| Comment: Page 2-128, Line 29; Page 2-129, Lines 5 and 9; Page 4-52, Line 34 - The

| "recreation area" has been closed to the public since shortly after 9/11/2001 but limited use is

| allowed to employees of PNPS. It is no longer referred to as a nature area and the trails, etc.

| are not currently maintained as a recreation area. (PNPS-D-MM)

|

| Comment: Page 2-4, Lines 12-14 - The "nature area" has been closed to the public since

| shortly after 9/11/2001 but limited use is allowed to employees of PNPS. It is no longer referred

| to as a nature area and the trails, etc. are not currently maintained as a nature area. 

| (PNPS-D-MM)

|

| Response: The text in Sections 2.1.1, 2.2.9.2.2, 2.2.9.2.3, and 4.4.5.1 has been modified to

| reflect the changes in the use of the “natural area” and “recreation area”.

|

| Comment: Page 2-21, Lines 27-28 - This should also state that PNPS received certification

| from the Commonwealth of Massachusetts Office of Coastal Zone Management (letter dated

| 7/11/06), instead of only that the certification was filed. (PNPS-D-MM)

|

| Response: Section 2.2.1 has been modified to reflect receipt of certification from the

| Massachusetts Office of Coastal Zone Management (ADAMS Accession No. ML062090362).

| Also, a copy of this letter can be found in Appendix E of this SEIS.

|

| Comment: I am writing to request that part of the negotiations between Entergy and the Town

| of Plymouth include the preservation of the Entergy land so that - for safety reasons - no more

| development will take place near the plant.
Appendix A

July 2007 A-131 NUREG-1437, Supplement 29

The approximately 1600 acres of land now owned by Entergy has been preserved by the |

owners of Pilgrim Nuclear Power Plant since it received its license in 1972. I would suggest that |

continued preservation of the land be formalized into a Conservation Restriction as part of the |

re-licensing negotiations. |

|

850 people living just a few miles from the nuclear plant. For safety and evacuation reasons the |

1600 acres Entergy owns should remain as open space. (PNPS-D-B) |

|

Comment: When Pilgrim was licensed and built in 1972, its location was in an area that was |

remote and undeveloped. At the project planning stage, the initial site chosen by Boston Edison |

at the Quincy Naval Air Station was rejected because the area was too heavily populated. The |

ultimate site in Plymouth was chosen because it was a sparsely populated area. |

|

However, the population around the plant has changed drastically in the last 30 years, and this |

aging plant is now located in the fastest growing region in Massachusetts. In Pilgrim's backyard, |

Pinehills, the largest housing development in New England, is under construction. The build-out |

includes 2,877 homes on 3,060 acres, and Pinehills is actively trying to acquire more land to |

build in this area. The distance from Pilgrim to Pinehills is about 3 1⁄2 miles. The current Pinehills |

household size is 1.95 people per building. Based on these numbers, there will soon be 5,850 |

people living just a few miles from the nuclear plant. For safety and evacuation reasons the |

1600 acres Entergy owns should remain as open space. (PNPS-D-B) |

|

Response: As discussed in Section 2.2.1 of the DSEIS, the majority of the over 1530 ac |

undeveloped tract owned by Entergy has been placed in a forest land trust under Chapter 61 of |

the General Laws of Massachusetts, Classification and Taxation of Forest Lands and Forest |

Products. Any arrangements to preserve the land in its current state are a matter between |

Entergy and the Town of Plymouth, and not within the purview of this SEIS. However, as part |

of the new PILOT agreement Entergy has agreed to continue to protect this undeveloped tract |

(ADAMS Accession No. ML063260173). These comments provide no new and significant |

information. Therefore, no changes have been made to the SEIS. |

|

Comment: Page 2-21, Lines 13-14 and Page 2-92, Lines 16, 18-19 - There are contradictory |

statements regarding the transmission ROW (right of way) crossing state parks, etc. Page 2-21 |

(lines 13-14) indicates the ROW is within the Myles Standish State Forest while Page 2-92 (line |

16) indicates the ROW "does not cross any state or federal parks" and lines 18-19 (Page 2-92) |

has the same wording as Page 2-21 (lines 13-14). (PNPS-D-MM) |

|

Response: The statements are not contradictory. Miles Standish State Forest is not a state |

park. State forests and state parks are separate entities and generally are not managed for the |

same uses. The comment provides no new and significant information. Therefore, no changes |

have been made to the SEIS. |

|
Appendix A

NUREG-1437, Supplement 29 A-132 July 2007

| A.2.9 Comments Concerning Postulated Accidents

|

| Comment: NRC's DSEIS is inadequate in that the NRC staff mistakenly concluded the

| Applicant's SAMA Analysis was "sound." The SAMA analysis was faulty in that Entergy entered

| partial and selective data into the model and thereby underestimated consequences to make

| mitigation alternatives, such as the Direct Torus Vent System, appear not cost effective The

| purpose of a SAMA review is to ensure that any plant changes that have a potential for

| significantly improving severe accident safety performance are properly analyzed identified and

| addressed. One example of how a poorly performed SAMA analysis can lead to erroneous

| conclusions is the Pilgrim Environmental Report's look at the costs and benefits of installing a

| Direct Torus Vent filter at Pilgrim. 

|

| The Direct Torus Vent System (DTVS) is a method to relieve the high pressure which is

| generated during a severe accident.

|

| In 1986, it was determined that the Mark I containment, especially being smaller with lower

| design pressure, in spite of the suppression pool, has a 90% probability of that containment

| failing. The purpose of the containment is to provide a barrier between the lethal radiation inside

| the reactor and the public. In order to protect the Mark I containment from a total rupture it was

| determined necessary to vent high pressure buildup. As a result, the "Direct Torus Vent

| System" at all Mark I reactors, including Pilgrim, was installed. Operated from the control room,

| the vent is a reinforced pipe installed in the torus and designed to release radioactive high

| pressure steam generated in a severe accident by allowing the unfiltered release directly to the

| atmosphere through the 300 foot vent stack. Use of the vent discharges steam and radioactive

| material directly to the atmosphere bypassing the standby gas treatment system (SBGTS)

| filters normally used to process releases via the containment ventilation pathway. There is no

| radiation monitor on the pipe and valves that comprise the DTV line. Operators now have the

| option by direct action to expose the public and the environment to unknown amounts of

| harmful radiation. 

|

| As a result of Pilgrim's design deficiency, the original idea for a passive containment system

| has been dangerously compromised and given over to human control with all its associated

| risks of error and technical failure. 

|

| There appears to be an internal contradiction in what we are being told. "The NRC believes that

| the release from a severe core-melt accident would be reduced [by the suppression pool] by a

| factor of one hundred. This is considerably more optimistic than estimated in the NRC's first

| study on the subject. Also, the contention is that the reduction by a filtration system would have

| zero benefit. Here the contenders seem to be assuming that a factor of one hundred equals

| 100%. That is false. Even a release of 1 percent of the core's radioactive iodine and cesium

| would be a very severe event.

|
Appendix A

July 2007 A-133 NUREG-1437, Supplement 29

In its Environmental Report, Entergy analyzes the benefits of installing a filter to the torus vent |

in the course of reviewing possible severe accident mitigation alternatives. |

|

Their Report states, this analysis case was used to evaluate the change in plant risk from |

installing a filtered containment vent to provide fission product scrubbing. A bounding analysis |

was performed by reducing the successful torus venting accident progression source terms by |

a factor of 2 to reflect the additional filtered capability. Reducing the releases from the vent path |

resulted in no benefit." The Report then states, "Basis for Conclusion: Successful torus venting |

accident progressions source terms are reduced by a factor of 2 to reflect the additional filtered |

capability. The cost of implementing SAMA at Peach Bottom was estimated to be $3 million. |

Therefore this SAMA is not cost effective for [Pilgrim]." Entergy has determined that in return for |

a cost of $3 million, there will be no benefit to public health and safety. |

|

How it is possible to find zero benefit from installing a filter that would reduce by a factor of two |

the radioactive venting to the public in the case of a severe accident? |

|

Unfiltered venting has been judged unsafe by all regulatory agencies outside the United States. |

In its analysis of several risk contributors to Core Damage Frequency, the disposition of those |

events frequently included "venting via DTV path to reduce containment pressure." In other |

words, a filter in the torus vent could reduce the impact in many possible severe accidents. The |

only conclusion to draw from the outcome of the DTV filter SAMA analysis is that, Entergy has |

used the MACCS2 code to downplay the health and economic costs of severe accidents and |

used the Probabilistic Safety Analysis (PSA) model to make the benefits of mitigation appear to |

be zero. |

|

NRC staff reviewed Entergy's analysis and concluded that the methods used and |

implementation of those methods was sound. And "the costs of SAMAs evaluated would be |

higher than the associated benefits. 5.2.5. The NRC staff is wrong to accept Entergy's SAMA |

analysis in the application. The SAMA analysis included in the Pilgrim Environmental Report is |

incomplete. |

|

Not only does the probabilistic modeling for severe accidents artificially make consequences |

appear insignificant, but the Applicant has used incomplete and incorrect input parameters into |

the MACCS2 code. |

|

The direct torus vent filter as an example of how this cost benefit equation might have been |

skewed in favor of no mitigation "While NEPA does not require agencies to select particular |

options, it is intended to 'foster both informed decision-making and informed public participation, |

and thus to ensure the agency does not act upon incomplete information, only to regret its |

decision after it is too late to correct' It then said "if 'further analysis' is called for, that in itself is |
Appendix A

NUREG-1437, Supplement 29 A-134 July 2007

| a valid and meaningful remedy under NEPA." The Applicant has drastically under counted the

| costs of a severe accident, and this could have led it to erroneously reject mitigation

| alternatives. Further analysis is called for. 

|

| EPA has acceptable standards for exposure, in the real world; there is no safe level of exposure

| to radiation. 

|

| In conclusion, the danger of NRC rubber stamping Entergy's SAMA in the DSEIS - accepting

| the licensee's minimization of consequences that make the cost of adding a filter to the Direct

| Torus Vent seem unnecessarily high/ not cost effective when it is obvious that the mitigation of

| installing the filter could indeed serve to protect public health and safety. I repeat, unfiltered

| venting has been judged unsafe by all regulatory agencies outside the United States.

| (PNPS-D-CC)

|

| Comment: The applicant has drastically undercounted the cost of severe accident and this

| could have led it to erroneously reject mitigation alternatives, further analysis if called for. The

| EPA has acceptable standards for exposure, in the real world there is no safe level of exposure

| to radiation. 

|

| In conclusion, the danger of NRC rubber stamping the Entergy's SAMA in the DSEIS, accepting

| the licensee's minimization of consequences that make the cost of adding a filter to the direct

| torus vent seem unnecessarily high or not cost effective when it is obvious that the mitigation of

| installing the filter could indeed serve to protect the public health and safety, I repeat unfiltered

| venting has been judged unsafe by all regulatory agencies outside of the United States.

| (PNPS-D-F)

|

| Comment: My second comment is on the DSEIS, that the NRC staff mistakenly concluded that

| the applicant's SAMA analysis was sound, that the faulty SAMA analysis used by Entergy in the

| environmental report caused it to wrongly dismiss mitigation alternatives such as adding a filter

| to the direct torus vent. The purpose of a SAMA review is to ensure that any plant changes that

| have a potential for significantly improving severe accident safety performance are identified

| and addressed, one example of how a poorly performed SAMA analysis can lead to erroneous

| conclusions is the Pilgrim environmental reports look at the cost and benefits of installing a

| direct torus vent filter at Pilgrim. 

|

| The direct torus vent system is a method to relieve high pressure which is generated during an

| accident review, severe accident, excuse me. In 1986 it was determined that the Mark I

| containment, especially being smaller with lower design pressure, in spite of a suppression

| pool, has a 90 percent probability of that containment failing. The purpose of the containment is

| to provide a barrier between the lethal radiation inside the reactor and the public. In order to
Appendix A

July 2007 A-135 NUREG-1437, Supplement 29

protect the Mark I containment from total rupture, it was determined necessary to vent high |

pressure build-up. As a result, the direct torus vent system to all Mark I reactors, including |

Pilgrim, was installed. |

|

Operated from the control room, the vent is a reinforced pipe installed in the torus and designed |

to release radioactive high pressure steam generated in a severe accident by allowing the |

unfiltered releases directly to the atmosphere through a 300-foot vent stack. Use of the vent |

discharges steam and radioactive material directly into the atmosphere, bypassing the standby |

gas treatment system filters normally used to process releases via the containment ventilation |

pathway. There is no radiation monitor on the pipe and valves that compromise the direct torus |

vent line and operators now have the option to direct action to expose the public and the |

environment to unknown amounts of harmful radiation. |

|

As a result of Pilgrim's design deficiency, the original idea for a passive containment system |

has been dangerously compromised and given over to human control with all its associated |

risks of error and technical failure. There appears to be an internal contradiction in what we are |

being told, the NRC believes that the release from a severe core melt accident would be |

reduced by a factor of 100, this is considerably more optimistic than estimated in the NRC's first |

study on the subject. |

|

As the contention is that the reduction of a filtration system would have zero benefit, here the |

contenders seem to be assuming that a factor of 100 equals 100 percent and that's false, even |

a release of 1 percent of the core's radioactive iodine and cesium would be a very severe event. |

|

In its environmental report, Entergy analyzes the benefits on installing a filter to the torus vent in |

the course of reviewing possible severe accident mitigation alternatives, their report states this |

analysis case was used to evaluate the change in plant risk from installing a filtered |

containment vent to provide fission product scrubbing. A bounding analysis was performed by |

reducing the successful torus venting accident progression source terms by a factor of two to |

reflect the additional filtered capacity and capability. |

|

Reducing the releases from the vent path resulted in no benefit, according to the state report, |

the basis for conclusion that successful torus venting accident progression source terms are |

reduced by a factor of two to reflect the additional filtered capability, the cost of implementing |

SAMA at Peach Bottom was estimated a $3 million. Therefore, this SAMA is not cost effective |

|

for Pilgrim. Entergy has determined that, in return for a cost of $3 million, there will be no |

benefit to public health or safety. |

|

How is it possible to find zero benefit from installing a filter that would reduce by a factor of two |

the radioactive venting to the public in a case of a severe accident? Unfiltered venting has been |

judged unsafe by all regulatory agencies outside the United States. In its analysis of several risk |
Appendix A

NUREG-1437, Supplement 29 A-136 July 2007

| contributors to core damage frequency, the disposition of those events frequently included

| venting via the direct torus vent path to reduce containment pressure. In other words, a filter in

| the torus vent would reduce the impact in many possible severe accidents. 

|

| The only conclusion to draw from the outcome of the direct torus vent filter SAMA analysis is

| that Entergy has used the MACCS II code to downplay the health and economic cost of severe

| accidents and use the probabilistic safety analysis model to make the benefits of mitigation

| appear to be zero. NRC staff reviewed Entergy's analysis and concluded that the methods used

| in the implementation of those methods were sound, the costs of SAMA's evaluation would be

| higher than the associated benefits in 2.2, in 5.2.5. The NRC staff is wrong to accept Entergy's

| SAMA analysis in this application. 

|

| The SAMA analysis included in the Pilgrim environmental report is incomplete, not only does

| the probabilistic modeling for severe accidents artificially make consequences appear

| insignificant but the application has used incomplete and incorrect input parameters to the

| MACCS II code. The direct or torus vent filter is an example of how this cost/benefit equation

| might have been skewed in favor of no mitigation. (PNPS-D-F)

|

| Comment: The faulty SAMA analysis used by Entergy in the Environmental Report, and

| accepted by NRC in the DSEIS, caused it to wrongly dismiss mitigation alternatives such as

| adding a filter to the Direct Torus Vent. (PNPS-D-EE)

|

| Comment: And so because of the problems with the severe accident mitigation analysis, what

| it does is falsely minimize consequences so the cost of mitigation seems not necessary, as

| described for the direct torus vent system, and we could go through many other mitigations that

| should be relooked at, but the key is you have to do an honest analysis to begin with, which

| was never done. (PNPS-D-M)

|

| Response: The NRC staff review of the SAMAs for PNPS is described in detail in Appendix G

| of the SEIS. The scope of the review specifically included the risk and economic impacts of

| severe accidents at PNPS given the existing plant configuration, the estimated effectiveness of

| each candidate SAMA in reducing risk and economic impacts (i.e., the estimated benefits), and

| the estimated implementation cost for each SAMA. As a result of the staff’s review, numerous

| portions of the licensee’s analysis were revised and/or supplemented, and several additional

| potentially cost-beneficial SAMAs were identified.

|

| The addition of a filtered vent was incorrectly reported in the ER to have zero benefit. This error

| was subsequently identified and a revised analysis was included in Amendment 4 to the LRA 

| (ADAMS Accession No. ML061930418). The analysis indicates that this improvement has no

| impact on core damage frequency but could reduce off-site dose by about 20 percent. (The

| dose reduction is limited due to the fact that the gases entering the filter would have already

| been passed through and been scrubbed by the suppression pool, and that some containment
Appendix A

July 2007 A-137 NUREG-1437, Supplement 29

failure modes, such as containment liner melt-through, would bypass the filter.) The estimated |

implementation costs are substantially greater than the estimated dollar benefit. Thus, this |

improvement is not cost-beneficial. The comments do not provide any new and significant |

information. Therefore, no changes have been made to the SEIS. |

|

Comment: "The Commission has determined that impacts of DBAs are small significance for |

all plants because the plants were designed to successfully withstand these accidents." |

|

NRC staff obviously forgot about the near-miss at Davis Besse NPS - the reactor with a hole in |

its head. NRC staff incorrectly assumes that: NRC regulations are sufficiently stringent; that |

regulations are followed by licensees and manufacturers; and that there is sufficient NRC |

oversight and enforcement action when regulations are not met. |

|

What was not taken into account? |

• Spent fuel pool accident can cause/lead to a reactor core accident and vice versa -the |

interplay was ignored and not analyzed; |

• Human error; |

• The effects of an aging work force; |

• The bathtub curve of aging - trouble occurs in all mechanical components in their early and |

later stages - Pilgrim will be in the "late stage" from 2012-2032; |

• The use of counterfeit and substandard parts; |

• The potential leakage of contaminated water offsite; |

• The Aging Management Plan failure to adequately monitor for corrosion in the drywell liner; |

• Wiring Coating- missing from the list of passive equipment is testing /re-qualifying the EQ |

rating, although the miles of wiring at Pilgrim is tested with the active components they |

interconnect -these wires are required to perform under harsh conditions (fire, high |

temperature, and high moisture). As the wiring ages its ability to still meet the original |

qualification tests is an interesting, though overlooked, challenge. A good comparison, |

consider what is happen in the City of Boston. The aging Nstar electric system is failing. |

How many of those failures are just old wires with rubber coating turned brittle and cracked? |

The power flows until the manhole explodes. Turing on a pump is like turning on your lights; |

it does not test the wiring coating, the EQ, only the metal of the wire. |

|

Engineering Review of Operating Transients: Pilgrim in 1994 had already exceeded the 40-year |

design standards for 6 kinds of events that put stress on the reactor before license expiration, |

according to a February 24, 1994 NRC Inspection Report -we are considering adding an |

additional 20 years. |

|

|
Appendix A

NUREG-1437, Supplement 29 A-138 July 2007

| Transient Design Cycles Cycles to-date Projected Cycles

| Description 40 years 21 years 40 years

|

| Startup 120 187 368

| Power Increase 120 133 264

| T/G Trips 40 26 49

| Other Scrams 147 134 346

| Loss of FW Pumps 10 26 64

| SR Valve Blowdown 2 13 23

|

| • Replacement parts – difficult, if not impossible, to find from 2012-2032

|

| Example - The Patriot Ledger Reported, February 25, 2003, Broken pump shuts Pilgrim power

| plant - Engineers traced the pump problem to a defective part in the generator that powers the

| pump motor, Tarantino said. A 12-inch-wide ''slip ring'' in the motor and generator had failed...

| The motor and generator together are about the size of an automobile... Workers are replacing

| the rotor in the generator... It took until Sunday to get the part because Pilgrim ''was built in the

| 1960s and went on line in 1972,'' Tarantino said. ''In some cases it's becoming difficult to find

| replacement parts because the technology has changed.'' 

|

| Replacement parts in a global economy can come from anywhere in the world. This presents

| serious QA issues, not analyzed. (PNPS-D-EE)

|

| Response: The license renewal review assumed the safety design basis of the plant will be

| maintained and the plant will continue to meet all NRC regulations. Therefore, NRC's license

| renewal review does not re-exam the design basis of the plant. The license renewal safety

| review focuses on programs to manage aging. Safety matters related to aging are addressed

| as a part of the NRC safety review for the license renewal, which is conducted separately, and

| is documented in an NRC staff Safety Evaluation Report. However, the NRC routinely

| searches for and examines new information that could affect the safety design basis of nuclear

| power plants including information to determine if changes in the design basis are needed

| generically or for an individual plant. If any revisions to the design basis for PNPS are

| determined to be necessary, those revisions would become part of the PNPS design basis

| during the license renewal period. The comment provides no new and significant information. 

| Therefore, no changes were made to the SEIS. 

|

| Comment: The applicant is required to analyze severe accident mitigation alternatives. The

| NRC staff concluded in their review of Entergy's analysis that the methods were sound and, 

| although the treatment of SAMAs for external events was somewhat limited by the unavailability

| of an external event PSA, the likelihood of there being cost-beneficial enhancements in this
Appendix A

July 2007 A-139 NUREG-1437, Supplement 29

area was minimized by improvements that have been realized as a result of the IPEEE process, |

and increasing the estimated SAMA benefits by a factor of five to account for potential benefits |

in external events. |

|

Question: Where did "5" come from; what is the rational, none is given; what should it have |

been? Five is obviously pulled out of the air. It assumes that there is no difference between |

events caused externally than internally - there is no rational basis for that assumption. |

Consequences of NRC rubber-stamping the faulty SAMA Analysis (PNPS-D-EE) |

|

Response: A candidate SAMA could reduce the risk from both internal and external events, |

even though the SAMA may have been identified based on consideration of internal events. |

SAMA benefits in internal events are determined by quantifying the internal events PRA with |

and without credit for the SAMA. However, when external event risk has been assessed using |

screening methods (e.g., fire screening or seismic margins approaches) rather than a |

probabilistic risk assessment (i.e., fire and seismic PRAs), direct quantification of the SAMA |

benefits in external events is not practical. In such cases, and in the case of PNPS, a simplified |

approach has been taken in which the estimated internal events benefits for the SAMA are |

multiplied by a factor representing relative contribution of internal events and external events to |

the total core damage frequency for the plant. This implicitly assumes that each SAMA would |

offer the same percentage risk reduction in external events as it offers in internal events. The |

basis for the factor of 5 multiplier used to account for potential SAMA benefits in external events |

at PNPS is described in Section G.2.2 of Appendix G to the SEIS. This comment provides no |

new and significant information. Therefore, no changes have been made to the SEIS. |

Comment: "The staff reviewed Entergy's analysis and concluded that the methods used and |

implementation of those methods was sound." And "the costs of SAMAs evaluated would be |

higher than the associated benefits. The NRC staff is wrong to accept Entergy's SAMA analysis |

in the application - see Pilgrim Watch's Motion to Intervene, Contention 3. |

|

Criticism: The Applicant's Environmental Report inadequately accounts for off-site health |

exposure and economic costs in its SAMA analysis of severe accidents. By using probabilistic |

modeling and incorrectly inputting certain parameters into the modeling software [such as |

meteorology, demographic data, economic data, emergency response data], Entergy has |

downplayed the consequences of a severe accident at Pilgrim and this has caused it to draw |

incorrect conclusions about the costs versus benefits of possible mitigation alternatives. |

|

Examples: Economic data - Nowhere in the assessment of the economic costs of a severe |

accident does the model account for the loss of economic activity in Plymouth County. The |

valuations include only the assessed value of the property, ignoring business value. The fact |

that the building is an on-going business with inventory, equipment, and income generation |

capability is not taken into account. Tourism is ignored which is mystifying because the staff |

looked into and mentions historic and archaeological resources as a variable in their alternative |

analysis, section 8, and description of the site (section 2.2.9). |
Appendix A

NUREG-1437, Supplement 29 A-140 July 2007

| Evacuation Delay time: Entergy assumes that the longest likely delay before residents begin to

| evacuate is 2 hours. This assumption is incorrect for the simple reason that notice of the

| evacuation could take longer than 2 hours to reach people. The sirens only can be heard

| outside, if an accident occurs when residents are inside, during the night for instance, they are

| unlikely to be notified within 2 hours. The peak population in the EPZ approximates 100,000.

| How is it conceivably possible to spread the word if the sirens are down over approximately 150

| square miles when the public is engaged in a variety of activities? What about those who can

| not hear the sirens inside?

|

| Evacuation Speed: Entergy assumes the evacuation speed will be from 3 hours 35 minutes to 6

| hours 30 minutes However, to arrive at this number, the applicant falsely assumes that: the

| public is out of danger once they cross the 10 mile boundary but in a severe accident harmful

| levels of radiation (and thus evacuation) will extend beyond 10 miles; they assume no one

| beyond 10 miles will evacuate, leaving roads clear when we know the "shadow evacuation" will

| occur and a "cork will effectively be placed in the bottle" trapping those near the core; and they

| assume transportation providers from well outside the zone will come and whisk folks away

| within this small frame-period. How did the NRC staff buy into this? (PNPS-D-EE)

|

| Comment: This moves into the severe accident mitigation analysis which the draft decided

| was, the analysis was sound which, again, if you really looked at it, you could not come up with

| that conclusion and I hope they will look at it more seriously again. The licensee, the applicant,

| used the MACCS II code, they are not restricted, by the way, of only using that code, but what

| is important is what goes in, what are the variables, the input data, because obviously that

| would effect the analysis of what the consequences are and the input data clearly is lacking. 

| (PNPS-D-M)

|

| Comment: Evacuation speed, again, a very unrealistic time was put into the formula because

| it had faulty emergency planning assumptions, they overlooked, for example, the shadow

| evacuation. There is an assumption that everybody outside whatever the zone is going to stay

| home and go about their business, we know, from Three Mile Island, we know from telephone

| surveys that were done after that people outside the ten miles, people close to Boston will be

| hitting the road, putting a cork, so to speak, in the bottle, so that people here are not going to

| be able to get out in the timely manner that was assumed. (PNPS-D-M)

|

| Comment: Not also considered properly were two emergency planning variables, one,

| evacuation delay time which is, in English, notification. They stated that the public would be

| notified, at max, within six hours, that makes assumptions which aren't true, that sirens can be

| heard inside the houses, which they can not be heard inside. What about an accident

| happening at night? What about the fact that some sirens are not going to operate? You cannot

| expect part of the fire or police department and DPW to cover over 125 square miles to notify

| people who are doing different things, clearly this is just, that people will be ready to get out of

| here in six hours is unrealistic. (PNPS-D-M)
Appendix A

July 2007 A-141 NUREG-1437, Supplement 29

|

Comment: We also know that there is nothing magic about the ten miles, so the evacuation |

speed is how long it's going to take to get from, let's say, my house in Duxbury to just a little bit |

past the magic ten miles in Marshfield. Again, we know from the Sandia National Labs studies, |

we know from study, after study, after study that there is nothing magic about the ten miles so |

to assume the consequences end at that point and we can call an evacuation successful once |

you cross the ten miles is patently absurd. (PNPS-D-M) |

|

Comment: For economic data, they put in the average property value of farm and non-farm |

property, they did not look at, for example, the added value of an ongoing business enterprise, |

clearly a manufacturing plant is valued at far more than the bricks and mortar that go into it. In |

doing an analysis of alternative sources of energy, there was an analysis of historic, you know, |

value of the area and what the impact would be, but it is not in the SAMA analysis for Pilgrim. |

Clearly because this area has such great historic value, also clearly because of our beautiful |

seaside location, that impacts and raises the values of our property. Tourism is here because, |

not to come to these meetings, obviously, but because of the history that's here, because of the |

seaside location and that would be gone and has to be factored in. (PNPS-D-M) |

|

Comment: Now I know some of the commenters had referred to, and I'm not going to get too |

technically jargonny here, but Class A and Class B air quality dispersion models, and these are |

modeling concepts that the NRC developed back in the `70s and `80s time frame. I'll just say |

that the MACCS II code is more like a Class A model, very simplistic, assumes straight winds, |

any given hour, and can be applied pretty quickly, and the Class type B models were never |

really fully implemented for use because they are quite cumbersome, expensive numerical |

models, needed a mainframe computer probably about half the size of this room. |

|

The good news is that, since the early 1980s, that modeling techniques have been advanced |

and models are a little simpler to apply, you can use some of these complex models now, |

variable trajectory wind flow models on a PC. An example of these types of models can be |

found in 40CFR, Part 51, Appendix W, that's the OCPA's guideline and air quality models, and |

an example of a model that can be found there is the Cal-Puf model which can be applied for |

shoreline complex wind flow environments, such as those that exist in the Pilgrim region. |

|

And I realize this is not part of nuclear emergency preparedness planning, in terms of the |

relicensing, but those kinds of models can also be applied and adapted for use for operational |

studies and accident analysis studies, including the SAMA type of studies too. And I brought up |

that model in particular because the NRC's contract, Earth Tech, was the, some of my |

colleagues who had worked at Earth Tech were involved with the development of that Cal-Puf |

model, so I know the folks from Earth Tech know what I'm talking about here. (PNPS-D-U) |

|

|
Appendix A

NUREG-1437, Supplement 29 A-142 July 2007

| Comment: I'm going to limit my comments tonight briefly just to the adequacy of

| meteorological databases and models that were used for the off-site consequence analysis that

| was discussed in Chapter 5 of the supplement EIS. You'll note that in the appendices, that

| Appendix A, I believe, that contained comments from the scoping meeting, public scoping

| meeting, that took place last summer, there were a number of questions and issues raised

| about the adequacy of the MACCS II software code that was used for doing the air quality

| analyses, meteorological analyses for use in the studies.

|

| And I guess the response to those comments indicated that this would be addressed or

| discussed in Chapter 5, although I didn't see any simple or extensive discussion in Chapter 5, it

| just gave the results, so I would like to see Chapter 5 or somewhere in the appendices in the

| SEIS give a more in depth discussion of justifying the use of that type of code for purposes of

| the modeling and dose calculations for the off-site consequence analysis that went into the

| cost/benefit studies. (PNPS-D-U)

|

| Comment: Pilgrim's monitoring reports and dose calculation models are neither reliable nor

| accurate. Example: dose calculation models assume that a radioactive plume will move in a

| straight line when, in fact, wind in our coastal communities is highly variable affected by the sea

| breeze effect, topography, and buildings. Wind direction is measured by the meteorological

| tower on the reactor building. It only tells where the wind in blowing on site not what happens to

| it offsite. There are no real-time weather and radiation monitors appropriately placed in

| surrounding communities to measure alpha, beta and gamma radiation. Environmental

| sampling for radiation in the environment is limited; and the samples are analyzed and reports

| prepared by Entergy's own laboratory. (PNPS-D-EE)

|

| Comment: I'd just like to close to say that I would like to see NRC come up to speed, such as

| other federal agencies have had in the last decade or so, and use realistic, accurate modeling

| techniques for a number of different applications. And I think the sooner this is done, the more

| credible and realistic the analyses will be and that will only help promote and advance perhaps

| the advent of even newer reactor technologies down the road, so things don't get delayed due

| to questionable analyses. (PNPS-D-U)

|

| Response: Section G.2.3 has been added in response to these comments.

|

| A.2.10 Comments Concerning Uranium Fuel Cycle and Waste Management

| Issues

|

| Comment: Page 2-12, Lines 19-20 - Fission products are not "normally" released from the fuel

| rods. However, on rare occasions, a small defect in a fuel rod can occur which allows small

| amounts of fission products to be released to the reactor coolant. (PNPS-D-MM)

|
Appendix A

July 2007 A-143 NUREG-1437, Supplement 29

Response: Minor quantities of fission products are released from fuel rods to the reactor |

coolant during reactor operation. The fission products are captured and removed by various |

liquid and gaseous radwaste processing systems and become part of the radwaste stream that |

must be managed for proper handling and disposal. Consequently, only a small fraction of the |

fission products that enter the reactor coolant are actually available for release to the |

environment. Given the capture and processing of fission products by in-plant systems, many |

reactor facilities are able to operate, under normal circumstances, in a mode that results in |

essentially zero environmental release of liquid borne fission products and inconsequential |

levels of gaseous fission products. Monitoring of plant operations enables regulatory agencies |

and plant operators to determine if environmental releases are occurring and to assess the |

magnitude and implications of the releases should they be observed. |

|

The specific text referred to by the commenter actually states that "... under normal operating |

procedures ..." This statement was not intended to suggest that radioactivce products are |

"normally" released from the fuel rods. This comment provides no new and significant |

information. Therefore, no changes have been made to the SEIS. |

|

Comment: I presume there will have to be a complete failure of a containment pond before the |

NRC and in particular Congress provides a permanent depository for the spent rods as |

promised 40 years ago. (PNPS-D-Y) |

|

Comment: The tailings from mines, the water and chemicals used, spent rods etc., etc..... are |

all dangerously radioactive. Where does the radioactive waste go? To Bangkok? To Sri Lanka? |

To the bottom of the ocean? Who transports it, who pays them? Nuclear power is NOT cheap! |

(PNPS-D-AA) |

|

Comment: EVERY 1000 megawatt nuclear power plant produces 30 TONS OF |

RADIOACTICVE WASTER PER YEAR. Does Pilgrim Nuclear use dry storage casks? cooling |

pools? They're still "tight" and "safe"? For how long? and then what? Are the trucks or ships or |

railroads and proper containers now being designed and built to move the radioactive wastes to |

_____________________(wherever) .....did you say YUCCA Mountain?? Oh, yes, YUCCA |

Mountain. Well, that's better than under the sand dunes of Cape Cod, thank you. NUCLEAR |

POWER IS NOT CHEAP! (PNPS-D-AA) |

|

Comment: What's wrong? What about the generation of half-again as much spent fuel and |

so-called low-level waste? There is new and significant information indicating that there will |

NOT be an offsite storage solution anytime soon - not within NRC's stated estimates. The staff |

simply ignored reality and rests its case on the now outdated Waste Confidence Rule. |

(PNPS-D-EE) |

|

Comment: My concern has to do with the spent fuel which is stored onsite. |

|
Appendix A

NUREG-1437, Supplement 29 A-144 July 2007

| Although the Commission found that the site can safely accommodate the on site storage of the

| additional volume of spent fuel, it seems to have operated under the assumption that there will

| be a permanent repository developed in some remote part of the United States. Given that such

| a storage site needs to be in some remote, stable part of the United States, I do not understand

| how the Commission can think that the permanent storage of spent fuel in Plymouth, which is

| not as remote and is not as geographically as sites such as Yucca Mountain, Nevada. 

|

| When the Plymouth Nuclear Plant was first approved, the working assumption was that only

| temporary storage of spent fuel would be required on site. Given that during the past 30+ years,

| no fuel has been shipped off-site, a prudent person would have to look at the storage as

| permanent. As such, the Plymouth on site storage should be looked at as if permanent and the

| requirements should be as strict as those used in choosing a "permanent repository". I do not

| think that the Plymouth site would qualify. 

|

| At the least, the NRC should insist that the operator treat the spent fuel storage as permanent

| and provide the safest type of storage possible. At this time, I do not believe that pool storage is

| the "safest" means for a permanent storage. (PNPS-D-JJ)

|

| Comment: The next area was nonaccident view to radioactive waste. Again, small impact, how

| can there be a small impact? Because, number one, when you are looking at spent fuel, it is

| assuming there is validity to the fantasy of the Nuclear Waste Confidence Act, that somehow

| Yucca is going to be there, or a radioactive waste fairy is going to come or God knows what

| they are assuming. But we know reality and one of the NRC commissioners was quoted in all

| the papers yesterday, Commissioner Merrifield, that he has no confidence in Yucca and that

| we, essence, should start again from zero. So, without looking at and providing a plan of what

| people are going to do with this high level waste, how can one say then that there is no impact?

| (PNPS-D-M)

|

| Comment: You have no safe or secure area to store the radioactive wastes generated by your

| nuclear power plants. As my Amish neighbors have repeatedly stated at the local meetings

| near Three Mile Island for 28 years , "You built a house without an out-house!" (PNPS-D-PP)

|

| Comment: The second reason that the draft found small impacts results from incorrectly

| assuming the current NRC regulations, many of which are written in the 1970s are, a, they are

| being met by the licensee, and that these regulations themselves reflect current realities and

| are indeed protective of public health and safety, so they more or less put us in a catch-22. An

| example is that the draft found spent fuel that would be half again, as much generated over the

| relicensing period was of small impact because of the assumption that this stuff will have

| someplace to go.

|

| Even Ed McGaffigan, a Commissioner of the NRC, said Monday the Yucca Mountain program

| is deeply flawed and that folks better start looking someplace else. (PNPS-D-Q)
Appendix A

July 2007 A-145 NUREG-1437, Supplement 29

Comment: And the answer to this question has always been that it's satisfactorily addressed in |

these kinds of studies on a national level with scenarios that deploy off-site storage. So we just |

get it out of Pilgrim, off-site storage facilities and the possibility down the road of a yet to be |

determined Yucca Mountain Site, which we heard discussed earlier, but I think there is new and |

significant information that hasn't been taken into account that sort of nullifies these answers |

and these ways of sort of pushing the issues aside. |

|

First, we heard earlier about Yucca Mountain, it's not going to open as predicted for the |

disposal of the waste and I believe somebody said that one of the NRC commissioners is now |

acknowledging that. I think that's pretty new information in my mind. Certainly, if it ever does |

open, it isn't going to open as predicted, it's going to be a long period off which means you are |

going to have more and more waste stored up and it's going to have to stay on-site, I believe. |

(PNPS-D-W) |

|

Response: Onsite storage of spent nuclear fuel is a Category 1 issue. The safety and |

environmental effects of long-term storage of spent fuel onsite has been evaluated by the NRC, |

and, as set forth in the Waste Confidence Rule. The NRC's Waste Confidence Rule, found in |

10 CFR 51.23, states: The Commission has made a generic determination that, if necessary, |

spent fuel generated in any reactor can be stored safely and without significant environmental |

impacts for at least 30 years beyond the licensed life for operation (which may include the term |

of a revised or renewed license) of that reactor at its spent fuel storage basin or at either onsite |

or offsite independent spent fuel storage installations. Further, the Commission believes there is |

reasonable assurance that at least one mined geologic repository will be available within the |

first quarter of the twenty-first century, and sufficient repository capacity will be available within |

30 years beyond the licensed life for operation of any reactor to dispose of the commercial |

high-level waste and spent fuel originating in such reactor and generated up to that time. In its |

Statement of Considerations for the 1990 update of the Waste Confidence Rule (55 FR 38,472 |

[September 18, 1990]), the Commission addressed the impacts of the disposal of spent fuel |

discharged from the current fleet of reactors operating under existing and renewed licenses and |

from a new generation of operating reactors. The rule was last reviewed by the Commission in |

1999 when it reaffirmed the findings in the rule (64 FR 68,005 [December 6, 1999]). |

|

With respect to Yucca Mountain specifically, for over two decades, research has been |

conducted to determine whether a site near Yucca Mountain, Nevada, is suitable for safely |

isolating highly radioactive nuclear waste. Four major steps - site characterization, site |

approval, licensing review, and construction- have to be completed before operation of the |

proposed high-level waste repository could occur. The first step, site characterization, including |

excavation of exploratory tunnels and testing of groundwater, has been completed. The result |

of the characterization study was documented by the development of an environmental impact |

statement (EIS). A draft EIS was published in 1999 and a supplemental EIS in 2001. The final |

EIS was published along with a site recommendation in 2002. |

|
Appendix A

NUREG-1437, Supplement 29 A-146 July 2007

| The second step is site approval. Following publication of the final EIS and the U.S. Department

| of Energy's (DOE's) determination that the site is scientifically suitable for a geologic repository,

| President Bush recommended the Yucca Mountain, Nevada, site for development as a geologic

| repository. On July 9, 2002, the U.S. Congress approved this recommendation in Joint

| Resolution 87, which designated Yucca Mountain as the repository for spent nuclear waste. On

| July 23, 2002, the President signed Joint Resolution 87 into law (Public Law 107-200, 116 Stat.

| 735 [2002]).

|

| The DOE is currently focused on the third major step of the process. The DOE is preparing an

| application to obtain a license from the NRC to construct a repository. The NRC is responsible

| for developing the regulations to implement the U.S. Environmental Protection Agency (EPA)

| safety standards and for licensing the repository. After the DOE submits the license application

| to the NRC, the NRC has three years to review the application and could request a fourth year

| from Congress, if needed, to make its determination on licensing.

| If licensed, the final step is construction and operation of the facility. The construction process

| would be conducted by the DOE, which has the responsibility for developing a permanent

| disposal facility for spent fuel and other high-level waste and which would operate the facility. 

|

| These comments provide no new and significant information. Therefore, no changes have

| been made to the SEIS.

|

| Comment: Let's assume, as the Draft does, that Yucca will open -some day off in the future.

| The Draft ignores new and significant information about transportation hazards and shipping

| cask integrity. In fact, they never present the transportation plan for getting the tons of spent

| fuel out of here.

|

| As part of the current plan, DOE proposes up to 24 barges carrying giant high-level radioactive

| waste containers onto Cape Cod Bay, Massachusetts Bay and Boston Harbor bringing

| hundreds of tons of dangerous poisons to densely populated Boston to be transferred from

| there by rail.

|

| Will the public go along? Accidents happen and each barge sized container would hold up to

| 200 times the long-lasting radioactivity given by the Hiroshima atomic bomb. Leakage of even a

| fraction could mean catastrophe. How do you ever recover it?

|

| NRC design criteria for waste transport containers are woefully inadequate. Rather than full

| scale physical testing, scale model tests and computer simulations are all that is required. The

| underwater immersion design criteria test examines the integrity of a slightly damaged

| container submerged under 3 feet of water for 8 hours. An undamaged cask is paper-tested for

| 1 hour submersion under 656 feet of water. If a cask were accidentally immersed under water

| or sunk by terrorists, is it reasonable to assume that the cask was only slightly damaged, or not

| damaged at all? Barge casks weigh well over 100 tons (up to 140 tons), how can NRC assume
Appendix A

July 2007 A-147 NUREG-1437, Supplement 29

that they will be recovered underwater somewhere en route to Boston within 1 hour, or even up |

to 8 hours? Special cranes capable of lifting such a heavy load would have to be located, |

brought in and set up after finding where it went, perhaps in inclement weather. (PNPS-D-EE) |

|

Comment: Is, if you are talking about waste, is transportation. Again, the transportation, God |

knows, let's pretend that there will be a Yucca or there will be someplace to put the stuff, then |

the issue is how is it going to get there? The draft brightly says impact small, how do they know |

it's going to be small? A, what's the plan? I've read the plan in DOE and apparently 24 barges |

are going to South Boston to be put on a railroad to go through like Chicago, does anyone in |

their right mind think this is going to happen when one of the casks per barge has 40 times the |

radiation in the Hiroshima bomb? |

|

Do you think Cohasset, Hingham, Senator Lynch, how about the people in South Boston? He |

will be lynched, but the point being that these issues have not been looked at seriously because |

of my general comment in the beginning, that the draft is playing games by pretending that |

rules, policy that the NRC has are real and that because the plan is there and it's going to |

happen that we don't have to worry about it so it's significance is small. (PNPS-D-M) |

|

Response: The NRC has conducted several transportation studies to evaluate the risk of |

transportation of radioactive material. NUREG-0170 (NRC 1977b), supported NRC's 10 CFR |

Part 71, "Packaging and Transportation of Radioactive Material" rulemaking. Based on this |

study, the Commission concluded that the transportation regulations are adequate to protect |

the public against unreasonable risks from the transport of radioactive materials, including |

spent fuel. The NRC sponsored another study in the 1980s entitled, "Shipping Container |

Response to Severe Highway and Railway Accident Conditions," NUREG/CR-4829 (Fischer et |

al. 1987), or the "Modal Study." Based on the results of this study, the NRC staff concluded that |

NUREG- 0170 overestimated spent fuel accident risks by about a factor of three. In March |

2000, the NRC initiated another spent fuel study, "Reexamination of Spent Fuel Shipment Risk |

Estimates," NUREG/CR-6672 (Sprung et al. 2000). This study focused on risks of a modern |

spent fuel transport campaign from reactor sites to possible interim storage sites and/or |

permanent geologic repositories. This study concluded that accident risks were much less than |

those estimated in NUREG-0170 and that more than 99 percent of transportation accidents are |

not severe enough to damage NRC-certified spent fuel casks. While very severe accidents |

could cause cask damage, the studies show that releases of material would be small and pose |

little risk to the local population/public. The most severe accidents might cause greater |

releases, but their likelihood is so remote that the NRC considers the risk to public health to be |

low. The NRC's regulations for the safe transportation of radioactive materials have evolved |

over the years, e.g., the 2004 revisions to achieve compatibility with International Atomic |

Energy Agency (IAEA) Transportation Safety Standards. However, the basic specifications for |

shipping containers have largely not changed. For instance, Type B shipping containers, such |

as those used for spent fuel, must withstand the effects of a 9-m (30-ft) drop test, puncture, fire, |

and immersion. Basic radiological dose rate limitations have not changed. While some of the |
Appendix A

NUREG-1437, Supplement 29 A-148 July 2007

| details in the regulations have been changed, the NRC staff believes that the basic safety

| standards that determine the performance of shipping containers under normal and hypothetical

| accident conditions have been properly accounted for in the SEIS. Nevertheless, transportation

| of spent fuel is a Category 1 issue. These comments provide no new and significant

| information. Therefore no changes have been made to the SEIS.

|

| Comment: Highly radioactive particles (especially in the gaseous state) are given off into the

| environment in every stage from mining to processing, to producing, to usage in plants, to

| secondary reprocessing and then years of storage - the methodology of STORAGE, of course,

| has not been tested for "centuries" - only theorized. Just WHERE do radioactive "tailings" go ??

| Nuclear power is NOT cheap. (PNPS-D-AA)

|

| Response: Nuclear power facilities have temporary storage for spent fuel in steel-lined

| concrete pools that are filled with water (spent fuel pools). The water acts as a natural barrier

| for radiation from the fuel assemblies and keeps the fuel thermally cool while it decays and

| becomes less radioactive. Because the designers of the nuclear power facilities originally

| anticipated that the spent fuel would be reprocessed, they designed the nuclear facilities to

| store about a decade's worth of used fuel. However, at this time commercial reprocessing is not

| being pursued. If the storage capacity of the spent fuel pool is approached, then licensees may

| consider alternatives, such as above-ground dry storage casks. Another option for storage of

| fuel is in an away-from-reactor interim storage facility. Private Fuel Storage, LLC (PFS), has

| submitted a request to the NRC for a license to build such a privately owned facility on the

| reservation of the Skull Valley Band of Goshute Indians, about 80 kilometers (50 miles)

| southwest of Salt Lake City, Utah. On February 24, 2005, the Atomic Safety and Licensing

| Board (ASLB) completed its review of the proposed spent nuclear fuel storage facility and ruled

| in favor of the PFS. The Commission upheld the ASLB decision in a Memorandum and Order

| dated September 9, 2005, and authorized the NRC staff to issue a license to construct and

| operate the PFS facility.

|

| Uranium tailings are primarily the process waste material from a conventional uranium mill. All

| wastes produced by these fuel fabrication facilities are regulated by the NRC’s Office of Nuclear

| Material Safety and Safeguards to ensure adequate protection of public health and safety. 

| Uranium tailings disposal is part of the fuel cycle and was evaluated in the GEIS as a Category

| 1 issue. This comment provides no new and significant information. Therefore, no changes

| were made to the SEIS.

|

| Comment: So there is a whole host of issues and additional mitigations that need to be

| addressed from this increased risk and the severe impact of terrorists targeting a build up of

| radioactive waste on the site as a result of a lack of places to put it around the country because,

| a, Yucca Mountain isn't going to go on schedule, b, this facility in South Carolina that takes

| many classes of this waste is closing. I think it's closing in 2008, this is the Barnwell, South

| Carolina. (PNPS-D-W)
Appendix A

July 2007 A-149 NUREG-1437, Supplement 29

Comment: Because of the second factor, this second piece of new information which is that |

an announcement has been made that there is going to be a closing of a key facility where this |

radioactive waste is dumped, that's a facility in South Carolina that's capable of taking this |

waste. |

|

This facility takes many classes of this waste, I guess this waste is broken up into four or five |

different classes, there is high level, there's mixed waste, and this plant takes it all or most of it. |

And these GEISs require that the analysis that the NRC accounts for the adverse impacts |

associated with this issue of radioactive waste and if no information is discovered in the GEIS, |

this is my understanding of the way this works, the generic environmental impact statement, |

then the issue is called settled, it's been settled at the national level and we don't have to deal |

with it here at Pilgrim. |

|

So if the issue is local, then it's going to have to be assessed for obvious reasons and mitigated |

in this Pilgrim SEIS, that's my feeling. Either way you look at it, national or local, the issue has |

to be addressed and it wasn't, there was really no mention of this information. Both NRC and |

Entergy in this book kept stating that they are not aware of any new information that would |

effect the Pilgrim environment, I feel that this will effect the Pilgrim environment. What's the |

impact of this new information on this report? The primary impact of this information is that |

Pilgrim needs now to assess how much waste is going to be on-site, with the assumption that |

there is going to be a lack of off-site storage. |

|

The residents need a plan B, I need to know that somebody has thought through this, not to |

say, oh, we'll fix it later, it'll come. There has got to be a place for safe storage of this waste at |

the site, I want to see a plan for it because this could happen. The plan and assessment need |

to be evaluated in this SEIS report, that's my feeling. Furthermore, the quantification of this |

issue needs to be addressed in terms of volumes and curies of radioactive isotypes that will be |

coming out of the plant as a result of decommissioning, even after 2032, if the license were |

extended. |

|

It's not just an issue for the next 20 years, in my feeling, when you put this SEIS report |

together, you've got to think about what happens after decommissioning, assuming that we |

don't have a third renewal. |

|

But if new information comes forward and it applies specifically to Pilgrim, which is what I'm |

contending here is that we've got the closure of these facilities, that's going to affect Pilgrim |

because we are not going to have a place to put this, there is no plan B here, then the issue is |

a Pilgrim issue and either the NRC or Entergy should acknowledge it and deal with it for the |

residents. (PNPS-D-W) |

|

|
Appendix A

NUREG-1437, Supplement 29 A-150 July 2007

| Comment: The same could go for low level waste, low level waste is a misnomer because it is

| everything but the spent fuel and it can have some highly toxic and long-lived radio nucleates in

| it. Entergy is a major producer of this stuff, the new and significant information that was

| overlooked was that Barnwell, South Carolina, which takes our waste, has said by June, '08 the

| door is shut, also they say in the draft that they have confidence that other sites will be built.

| That's baloney, there has been millions of industry money spent to try to find a site in Illinois,

| etcetera, etcetera, etcetera, and no new sites have been built because nobody wants it.

|

| Massachusetts had the beginnings of a search in the '90s and they stopped looking, so what is

| going to happen to this? Again, if it is the plan, if it is not realistically looked at and a plan is not

| put forward, you cannot analyze it and say it's going to be no problem. And so what we will have

| on our eroding coastline on Cape Cod, subject to increasing storms from global warming,

| etcetera, etcetera, etcetera, turning into a high level and low level radioactive waste dump until

| my kids are my age. This has to be analyzed and faced honestly, okay? (PNPS-D-M)

|

| Response: The comments are related to the environmental impacts associated with the

| uranium fuel cycle and Low Level Radioactive Waste Management. Low-level waste storage

| and disposal were evaluated in the GEIS and were determined to be Category 1 issues. The

| impact was determined to be SMALL. The Commission is confident that all nuclear waste

| generated will be handled, stored, and disposed of in a manner that assures public health and

| safety. The comment provides no new and significant information and no changes have been

| made to the SEIS.

|

| Comment: What about depleted uranium ....... Did you forget that 1000's of leaking barrels of

| depleted Uranium have contaminated the underground water supply of Paducah

| Kentucky....where 38,000 cylinders of depleted Uranium await SOME KIND of disposal as well

| as those at enrichment facilities in other states? When will Pilgrim's overly populated cooling

| tower be depopulated and WHERE will the rods be taken....and who will pay for their very

| carefully orchestrated removal and transportation? Nuclear power is NOT cheap. (PNPS-D-AA)

|

| Response: Depleted uranium is defined as uranium having a percentage of uranium-235

| smaller than the 0.7 percent found in natural uranium. It is obtained from spent (used) fuel

| elements or as byproduct tails, or residues, from uranium isotope separation such as through

| gas centrifugation enrichment. The United States Enrichment Corporation (USEC) owned by

| the U.S. Department of Energy, and operated by the USEC, a wholly owned subsidiary of

| USEC Inc. in Paducah Kentucky, is a uranium enrichment facility. The USEC facility is

| governed by NRC regulations 10 CFR 40, 70, 73, 74, and 76. NRC considers depleted

| uranium that has no commercial value to be low level radioactive waste. If the depleted

| uranium has no commercial use, the licensee can transfer the material to DOE or dispose of it

| at a commercial disposal site if it meets the disposal sites requirements. 

|

|
Appendix A

July 2007 A-151 NUREG-1437, Supplement 29

Incidents of leakage that may result (past, present, or future) at the USEC facility in Paducah, |

KY are outside the scope of this license renewal proceeding and would be handled by the NRC |

Office of Nuclear Material Safety and Safeguards, Division of Fuel Cycle Safety and |

Safeguards. Contact information for this office can be found on NRC website, www.nrc.gov. |

This comment provides no new and significant information; therefore, it resulted in no changes |

to the SEIS. |

|

Comment: And just specifically regarding the comment about global warming that I believe |

Joyce McMahon made earlier, I just want to point out that, you know, studies have shown that |

the life cycle of creating electricity from a nuclear power plant is actually greenhouse gas |

intensive because you include the fuel processing. (PNPS-D-S) |

|

Response: The NRC licenses and inspects all commercial nuclear fuel facilities involved in the |

processing and fabrication of uranium ore into reactor fuel, including facilities that enrich |

uranium. Enrichment technology in the United States will likely rely on gaseous centrifuge |

technology that will use 90 percent less energy that the gaseous diffusion technology. |

Enrichment of uranium respective to the uranium fuel cycle process is a Category 1 issue |

addressed in the GEIS. Licensing and operation of a facility would be handled by the NRC |

Office of Nuclear Material Safety and Safeguards, Division of Fuel Cycle Safety and |

Safeguards. Contact information for this office can be found on NRC website, www.nrc.gov. |

This comment provides no new and significant information; therefore, resulted in no changes to |

the SEIS. |

|

Comment: Page 2-16, Line 2 - It is unclear why the High Pressure Coolant Injection System is |

singled out here. A number of systems could conceivably cause steam leakage outside primary |

containment that would be monitored by the reactor building vent system. (PNPS-D-MM) |

|

Response: The comment is noted. The sentence will be revised to indicate that the primary |

containment venting, steam leakage outside the primary containment, hood vents, and high |

pressure coolant injection testing are among the potential sources of low-level radioactive |

contaminants at PNPS. |

|

Comment: But I am happy to see that the NRC has acknowledged something that Pilgrim |

admitted which is that there is, with this radioactive waste, a "irreversible and irretrievable |

resource commitment needed", that's as far as things went in this report or in this application. |

The Pilgrim application for the license renewal lists this commitment that's needed for |

radioactive waste as simply, and I put this in quotes too because it's right in the application, |

"land is required to dispose of spent nuclear fuel and low level radioactive wastes". So this is |

the closest that the applicant's environmental report and the NRC's DSEIS came to addressing |

this issue, which I think has new and significant information. It's very disturbing to me that |

nobody has acknowledged it and made a plan B. (PNPS-D-W) |

|
Appendix A

NUREG-1437, Supplement 29 A-152 July 2007

| Response: The comment is related to waste management and storage issues. Waste

| management issues were evaluated in the GEIS and determined to be a Category 1 issue.

| Onsite storage of spent nuclear fuel is also a Category 1 issue. The safety and environmental

| effects of long-term storage of spent fuel onsite has been evaluated by the NRC, and set forth

| in the Waste Confidence Rule. In the Waste Confidence Rule, the Commission determined that

| spent fuel can be stored onsite for at least 30 years beyond the licensed operating life, which

| may include the term of a renewed license. At or before the end of that period, the fuel would

| be moved to a permanent repository. The GEIS is based upon the assumption that storage of

| the spent fuel onsite is not permanent. The supplement to the GEIS prepared regarding license

| renewal for the Pilgrim Nuclear Power Station, is based on the same assumption. This

| comment provides no new and significant information and, therefore will result in no changes to

| the SEIS.

|

| Comment: The NRC staff incorrectly concluded that there was no new and significant

| information and therefore there would be no impacts of low level waste storage and disposal

| associated with the renewal term. Further the staff mistakenly agrees with the GEIS that,

| "...The maximum additional on-site land that may be required for low-level waste storage during

| the term of a renewed license and associated impacts will be small." And, "...the Commission

| concludes that there is reasonable assurance that sufficient low-level waste disposal capacity

| will be made available when needed for facilities to be decommissioned consistent with NRC

| decommissioning requirement."

|

| The NRC staff did not bother to look at new and significant information pertinent to this site and

| must be required to do so before finalizing the SEIS. 

|

| • Pilgrim is a very large generator of LLRW. In 2003, for example, Pilgrim shipped 59,089

| cubic feet, containing 1,210.000 curies; and stored 4,178.3 cubic feet containing 4,620.000

| curies.

| • Barnwell S.C. announced that it will close to Massachusetts generators June 20, 2008.

| • Massachusetts is not a member of any compact; in order to join Massachusetts would have

| to agree to be a host community; Massachusetts indicated clearly in the mid 1990's that it

| would not be a host community.

| • Texas may open, no guarantees, and if it does open there is no assurance that non-Texas

| Compact members will be able to send their waste there and if allowed whether fees would

| be prohibitive.

| • No sites have been developed anywhere in the country despite millions of dollars spent on

| failed attempts.

| • Terrorism or acts of malice were not considered a threat in 1972. Not so, post 9/11 - nuclear

| facilities/materials are known to be attractive targets.

| • Pilgrim is located on Cape Cod Bay and the property slopes towards the Bay so that any

| leaking contaminants from waste storage facilities will flow towards and eventually into the

| Bay. There are no monitoring wells lining the shoreline. Further the coast is a salt corrosive
Appendix A

July 2007 A-153 NUREG-1437, Supplement 29

environment and its effect on concrete and waste packaging must be analyzed. |

• The undisputed recognition of global warming is new and brings with it increased severity of |

coastal storms, erosion, and increased sea levels. Hence this must be factored into on-site |

waste storage options. |

|

Storage of LLRW is important for our community's health and safety because there is nothing |

low level about the waste. Waste is characterized "high" or "low" depending on where it comes |

from, how it is generated, not according to its' toxicity and longevity. Waste containers and |

forms will not last as long as some waste remains hazardous. Therefore, we want to know what |

Entergy's plans are for storing LLRW; monitoring the releases; and what are the "acceptable" |

public radiation exposures and health risks. |

|

We deserve to know what the LLRW storage plans are before the application is decided; so |

that the re-licensing decision does not prejudge any LLRW storage decision. (PNPS-D-EE) |

|

Comment: Now we might be splitting hairs in terms of the linguistics here, but here at are the |

two issues, one issue, the environmental impact of the fuel cycle's radioactive waste. There has |

always been a question of what's the environmental impact of large amounts of stored |

radioactive waste as a result of Pilgrim's operation from the current license as well as the |

renewed license, and what I'm referring to is the vast amount of harmful waste that's produced, |

excluding the fuel, spent fuel waste and the fuel rods. (PNPS-D-W) |

|

Response: These comments are related to the impacts associated with Low Level Radioactive |

Waste Management (LLW) at PNPS. LLW was evaluated in the GEIS and determined to be a |

Category 1 issue. The NRC staff did not identify any new and significant information during its |

independent review of the Entergy ER, the site visit, the scoping prcess, or the evaluation of |

other available information. Therefore, the NRC staff concludes that there would be no impacts |

regarding LLW beyond those discussed in the GEIS. In addition, the Commission is confident |

that all nuclear waste generated will be handled, stored and disposed of in a manner that |

assures public heath and safety. The comments provide no new and significant information: |

therefore, no changes have been made to the SEIS in response to these comments. |

|

Comment: Further, the "clean liquid waste with abnormally high conductivity" that may or may |

not be "evaluated for controlled release into the circulating water discharge canal through the |

liquid radioactive waste header." (Entergy 2006a). |

|

It is not clear whether the discharge is sent into Cape Cod Bay or a separate enclosed area. |

|

Also, "The liquid wastes are automatically transferred to the chemical waste receiver tanks |

when the sump is filled to a present level. After decay and storage, the chemical liquid wastes |
Appendix A

NUREG-1437, Supplement 29 A-154 July 2007

| are evaluated for discharge or reprocessed" (or released?). (Entergy 2006a). Again, it is not

| clear how the evaluation process works to determine where the waste can be disposed of, in

| the Bay or not. (PNPS-D-LL)

|

| Response: The liquid wastes in question are discharged to the Bay through the liquid

| radioactive waste header. The text in Section 2.1.4.1 describes how the waste is evaluated

| before and during discharge to verify that it meets the radiological limits specified by NRC

| regulations. Also, Section 2.1.4.1 describes how the Radiological Environmental Monitoring

| Program has evaluated these discharges, and confirmed that all liquid discharges were within

| NRC regulatory limits. No changes to the SEIS have been made based on this comment.

|

| Comment: It was far from "sound" in that it ignored a spent fuel pool accident at Pilgrim. The

| NRC staff excused this by misinterpreting prior cases and going to the wrong section of the

| GEIS.

|

| The NRC in Turkey Point concluded that the GEIS exempts spent fuel pools. They did so by

| referring to section 6 of the GEIS , which deals with "The Uranium Fuel Cycle and Solid Waste

| Management" under normal operations, rather than going to section 5 of the GEIS, which deals

| with "Environmental Impacts of Postulated Accidents." Section 5 includes definitions of "severe"

| and "accident" and does not limit these to reactor accidents in any way.

|

| Section 5.2.1 of NUREG 1437 "General Characteristics of Accidents" begins its discussion of

| design basis and severe accidents with a definition of these terms. "The term 'accident' refers

| to any unintentional event outside the normal plant operational envelope that results in a

| release or the potential for release of radioactive materials into the environment . . . 'severe' . .

| .[includes] those involving multiple failures of equipment or function and, therefore, whose

| likelihood is generally lower than design basis accidents but where consequences may be

| higher . . ."

|

| It is their potential for "releases substantially in excess of permissible limits" that makes it

| necessary to consider them in SAMAs. This entire SAMA section focuses on potential

| consequences to determine whether a potential accident is severe or not - not whether the

| source is the reactor core or elsewhere at the plant. (PNPS-D-EE)

|

| Comment: NRC staff failed to mention the new and significant information on potential health

| consequences from a spent fuel pool accident. Conclusions the National Academy of Sciences

| - Safety and Security of Commercial Spent Fuel Storage," National Research Council of the

| National Academy of Sciences, Public Version, April, 2005 Finding 3B - "... a terrorist attack

| that partially or completely drained a spent fuel pool could lead to a propagating zirconium

| cladding fire and the release of large quantities of radioactive materials to the environment.

| Details are provided in the committee's classified report" NAS, p. 6; "Such (zirconium cladding)

| fires would create thermal plumes that could potentially transport radioactive aerosols hundreds
Appendix A

July 2007 A-155 NUREG-1437, Supplement 29

of miles downwind under appropriate atmospheric conditions". NAS, p.50; and "The excess |

cancer estimates ...to between 2,000 and 6,000 cancer deaths" NAS, p. 45. The NAS report |

pertains directly to Pilgrim because it was among the reactors pointed out to be more |

susceptible to damage due to its design placing the pool in the "attic" - vulnerable from three |

sides. (PNPS-D-EE) |

|

Comment: National Academy of Sciences - "Finding 2A: Spent fuel storage facilities cannot be |

dismissed as targets for such attacks because it is not possible to predict the behavior and |

motivations of terrorists, and because of the attractiveness of spent fuel as a terrorist target |

given the well known public dread of radiation...The committee judges that attacks by |

knowledgeable terrorists with access to appropriate technical means are possible." NAS, p.4 |

|

"Terrorists view nuclear power plant facilities as desirable targets because of the large |

inventories of radionuclides they contain. The committee believes that knowledgeable terrorists |

might choose to attack spent fuel pools because: (1) at U.S. commercial nuclear power plants, |

these pools are less well protected structurally than reactor cores; (2) they typically contain |

inventories of medium - and long-lived radionuclides that are several times greater than those in |

individual reactor cores." NAS, p.36 |

|

"A loss-of-pool-coolant event resulting from damage or collapse of the pool could have severe |

consequences. Severe damage of the pool wall could potentially result from several types of |

terrorist attacks, for instance: (1) Attacks with large civilian aircraft; (2) Attacks with high-energy |

weapon; Attacks with explosive charges." NAS, p.49 |

|

"Finding 3B -... a terrorist attack that partially or completely drained a spent fuel pool could lead |

to a propagating zirconium cladding fire and the release of large quantities of radioactive |

materials to the environment. Details are provided in the committee's classified report." NAS, |

p.6 |

|

"Such (zirconium cladding) fires would create thermal plumes that could potentially transport |

radioactive aerosols hundreds of miles downwind under appropriate atmospheric conditions." |

NAS, p.50 |

|

"The excess cancer estimates ...to between 2,000 and 6,000 cancer deaths" p.45 |

|

2) An analysis of spent fuel pool accident at Pilgrim was performed by Dr. Jan Beyea for the |

Massachusetts Attorney General's Motion to Intervene in Pilgrim's re-licensing application. [The |

Massachusetts Attorney General's Request for a Hearing and Petition for Leave to Intervene |

With respect to Entergy Nuclear Operations Inc.'s Application for Renewal of the Pilgrim |

Nuclear Power Plants Operating License and Petition for Backfit Order Requiring New Design |

features to Protect Against Spent Fuel Pool Accidents, Docket No. 50-293, May 26, 2006 |

includes a Report to The Massachusetts Attorney General On The Potential Consequences Of |
Appendix A

NUREG-1437, Supplement 29 A-156 July 2007

| A Spent Fuel Pool Fire At The Pilgrim Or Vermont Yankee Nuclear Plant, Jan Beyea, PhD.,

| May 25, 2006.]

|

| Dr. Jan Beyea's estimated the consequences following the release of Cesium-137 from

| Pilgrim's spent-fuel pool. We recognize that these are conservative estimates because: (1) he

| only considers Cesium-137, other radionuclides would be released; and (2) he only looks at

| latent cancers and not other radiation-linked diseases, reproductive disorders and birth defects.

|

| 10% release C-137 100% release C-137

| Cost (billions) $105-$175 billion $342-$488 Billion

| Latent Cancers 8,000 24,000

|

| 3) Operating with faulty fuel cladding was not taken into account, either - both the probability

| and consequences of postulated accidents may be increased when nuclear plants operate with

| pre-existing fuel cladding failures. Degraded fuel is an on going issue for the industry. NRC

| Commissioner Merrifield has admitted nearly 1/3 reactors now have failed fuel, and the trend is

| increasing, not decreasing. Briefing on Nuclear Fuel Performance, Transcript, p.4, (February

| 24, 2005), http://www.nrc.gov. (PNPS-D-EE)

|

| Comment: NRC staff do not mention, the new and significant site specific report by the

| Massachusetts AGO, Report to The Massachusetts Attorney General On The Potential

| Consequences Of A Spent Fuel Pool Fire At The Pilgrim Or Vermont Yankee Nuclear Plant,

| Jan Beyea, PhD., May 25, in Massachusetts Attorney General's Request for a Hearing and

| Petition for Leave to Intervene With respect to Entergy Nuclear Operations Inc.'s Application for

| Renewal of the Pilgrim Nuclear Power Plants Operating License and Petition for Backfit Order

| Requiring New Design features to Protect Against Spent Fuel Pool Accidents, Docket No.

| 50-293, May 26, 2006. The report estimated the costs and latent cancers of Cesium-137

| releases from Pilgrim’s spent fuel as follows:

|

| 10% release C-137 100% release C-137

| Cost (billions) $105-$175 billion $342-$488 Billion

| Latent Cancers 8,000 24,000

| (PNPS-D-EE)

|

| Comment: The DSEIS's findings ignore new and significant information regarding the dangers

| of spent fuel storage. For example, staff ignored: 

|

| • The National Academy of Sciences Report Safety and Security of Commercial Spent

| Nuclear Fuel Storage Public Report, April 2005; 

| • Dr. Jan Beyea's report for the Massachusetts Attorney General's Motion to Intervene in

| Pilgrim's Re-Licensing Application, May 2006; 

|
Appendix A

July 2007 A-157 NUREG-1437, Supplement 29

• Pilgrim Watch's Motion to Intervene in Pilgrim's Re-Licensing Application, Contention 4, May |

2006; |

• The Massachusetts Attorney General's Petition for Rulemaking, August 2006 that calls, for |

example, for NRC to consider new and significant information showing that the NRC's |

characterization of the environmental impacts of spent fuel storage as insignificant in the |

1996 Generic Environmental Impact Statement for Renewal of Nuclear Plant Licenses |

("License Renewal GEIS") is incorrect; and |

• The fact that NRC's Waste Confidence Rule is fantasy or wishful thinking- there is no |

likelihood that the spent fuel at Pilgrim will leave Plymouth anytime soon or ever. |

|

More basically - there is no storage plan for spent fuel presented in the Application or any |

subsequent study by the NRC review staff so that the onsite storage plan can be analyzed; |

therefore there is no basis for the NRC staff to claim that the environmental impact of storing |

half-again as much until 2032 presents no environmental risk. (PNPS-D-EE) |

|

Comment: The new and significant information is the National Academy of Sciences spent fuel |

vulnerability study where they identified reactors that have the spent fuel pool located in the |

attic of the reactor, as Pilgrim, are especially vulnerable to attack. |

|

This has gone into the dangers of densely packed pools, like Pilgrim, that are inside the main |

reactor building, outside primary containment at the top. In the Massachusetts Attorney |

General's motion to intervene, there is an attachment by Dr. Gordon Thompson, again new and |

significant information, that discusses the danger of a highly, densely packed spent fuel pool, |

fire and what the consequences would be. Again, to remove this from discussion of postulated |

accidents is ludicrous. |

|

Then, by not looking at these issues, you do not come up with then, an analysis of mitigation |

which clearly, for spent fuel, as put forth in the attorney general's motion, would be to analyze |

the effect of having a lightly packed spent fuel pool and putting the rest into secured dry-cask |

storage. Also, an analysis should be required of the recommendations in the National |

Academy's study such as what fact an analysis would be the effect of, reconfiguration of the |

pool? What realistically is the effect of the firehose brigade, etcetera, so we can have a true |

analysis. (PNPS-D-M) |

|

Comment: And what they didn't say when they were talking about health effects in the |

postulated accidents section of the new and significant information presented by the |

Massachusetts Attorney General of the likely health consequences of a spent fuel pool accident |

at Pilgrim, yes, 24,000 cancers expected if there is a complete release of just Cesium 137, |

8,000 if only ten percent of that bad guy is released. |

|

What they didn't say under postulated accidents was a reference to the Sandia National Report, |

the CRAC-II which in 1982 NRC asked them to do for the consequences specifically of a core |
Appendix A

NUREG-1437, Supplement 29 A-158 July 2007

| melt at each reactor and what that study said was that you could expect 3,000 early injuries --

| no, what was it? No, 3,000 fatalities and 30,000 early injuries, that was '82. 

|

| But what they didn't look at was Dr. Edwin Lymon, a Union of Concerned Scientists report done

| on why these figures have to be updated, why they are conservative, new information of why

| this is pertinent now. And so by ignoring or misinterpreting these important factors, they fail

| then to look at significant mitigation that could occur and they ignore the fact that, guess what?

| I don't know how much radiation is coming out of there, Entergy doesn't know and the NRC

| doesn't know, and so an important mitigation step going forward, if you are honest about health

| effects, is to have a requirement or look at to analyze. 

|

| I mean that's what you are supposed to be doing, having combination real-time wind and

| radiation detectors placed in logical areas in off-site communities that provide real-time data on

| this to the state, and to the local communities and to the NRC. Hey they should know too. 

| (PNPS-D-D)

|

| Comment: In the GEIS Section 5 it deals with design-basis and severe accidents with an

| emphasis on releases substantially in excess of permissible limits for normal operations.

| Nowhere in this section is the spent fuel pool excluded nor the reactor core cited as the only

| risk. Therefore, I will argue that you are remiss not to include in the supplement the spent fuel

| pool under postulated accidents. (PNPS-D-D)

|

| Comment: Leaking Spent fuel storage facilities associated with, and a part of the very license

| renewal process now under review. The spent fuel pools are an integral part of the reactor, and

| in fact and deed are routinely used as a part of the reactor fueling and operational process. The

| spent fuel pools in fact and deed are attached too, a part of the whole of a reactor, just as all

| other component parts are, including values, panels, the control room and the core itself. 

| (PNPS-D-A)

|

| Comment: If a application to extend a license is granted, the licensee is not going to be

| forbidden from using and accessing this important part of the process, and in fact and deed a

| reactor cannot continue in operation without a safe, secure, functioning spent fuel area that

| does not threaten the environment, that is not leaking materials (which is a sure sign of wall

| fatigue, and a sign of potentially imminent wall collapse) and present no unacceptable risks to

| human health. The NRC is wrongfully attempting to remove consideration of the spent fuel

| pools at reactor sites to protect first their licensees, secondly the industry's cash flows, and

| lastly the DOE who has failed completely in keeping their promise to the American public in

| safely dealing with and removing waste from nuclear reactor sites. (PNPS-D-A)

|

| Comment: The Draft Supplemental GEIS is inadequate to satisfy the requirements of the

| National Environmental Policy Act ("NEPA") or NRC regulations for the implementation NEPA,

| because it fails to address new and significant information regarding the potentially severe
Appendix A

July 2007 A-159 NUREG-1437, Supplement 29

adverse environmental impacts of continued high-density pool storage of spent fuel at the |

Pilgrim nuclear power plant. (PNPS-D-HH) |

|

Comment: Because, which I find interesting, because they avoided talking about spent fuel, |

avoided talking about terrorism, this helps explain their conclusion that these alternative |

sources of energy, such as wind, solar, gas, etcetera, would have a greater impact, would be |

more expensive, would be all these other things. Clearly, if you look at, if you factor in security, |

if you factor in waste, if you factor in a true analysis of consequence where the attorney |

general, for example, a report to him indicated a specific consequence analysis of a spent fuel |

accident of Pilgrim, that if 100 percent of the cesium 137 was released, it would bring about |

$488 billion in damage. If ten percent of that were released, $105 to $175 billion. If 100 percent |

were released, which is likely in a terrorist attack situation, 24,000 cancers, ten percent, 8,000 |

cancers. (PNPS-D-Q) |

|

Comment: The second issue is involving spent fuel, spent fuel has to be looked at under the |

section of postulated accidents. If you look at the GEIS, the GEIS or whatever, it says, it |

describes in Section 5 explicitly environmental impacts of postulated accidents, they define |

severe, they define accident and they don't limit either to the reactor. They do this, however, in |

Section 6 which deals with exclusively normal operations and that's where they say the spent |

fuel doesn't have to be considered. |

|

So, what does this mean? All the new information that we have about the dangers of spent fuel |

storage at Pilgrim provided by the National Academy of Sciences, indicating that the way the |

fuel is stored at Pilgrim is among the most dangerous in the country, an analysis has to be done |

on the lack of security from an air attack, from water, land and then an analysis of the various |

mitigations to decrease risk such as a requiring a dense, a low density pool, secured dry cask |

storage, what about reconfiguring the pool? What about alternative water, spray water |

systems? This has to be analyzed and put forward. (PNPS-D-Q) |

|

Comment: Second, new and significant information on this issue of the spent fuel pool, the |

original GEIS assessed the fuel pool accident probability and impact or since the original GEIS |

assessed the probability and impact of spent fuel pool impact when it was assessed as a |

leakage that can be managed, the Pilgrim, locally here, fuel rod densities have been increasing |

substantially due to the lack of off-site fuel rod storage and a lack of an approved on-site cask |

storage plan. At the same time, there are credible scientific reports, that are new and I think |

significant, that have been published that essentially state that above ground spent fuel pools |

are the most dangerous method of storage and when they are tightly packed, the danger |

increases. |

|

So the tight packing is new, the reports that this is a danger and the most dangerous form are |

new and the consequences of that packing, which I'll get to right here next, is also new. In |

2005, a National Academy of Science report to Congress, which was a report that was |
Appendix A

NUREG-1437, Supplement 29 A-160 July 2007

| sponsored by the NRC and the Department of Homeland Security, described a scenario with

| the partial loss of pool water where the fuel rod cladding or the casing of the fuel rod catches

| fire. 

|

| The first, this scenario was first described years ago by Sandia National Laboratory which is a

| very famous laboratory, so it's been described by several scientists is my point here but very

| recently by the NAS on behalf of the NRC and the Department of Homeland Security in a report

| to Congress. (PNPS-D-V)

|

| Comment: Both the applicant's environmental report and the NRC's DSEIS have stated there

| is no new and significant information on spent fuel that might impact the environment. There is

| mention at some point, I think the previous speaker to me said that there was mention of

| something about the spent fuel pool and how there could be mitigation measures using dry

| cask storage and the like but, right now, as it begins to become packed, well prior to cask, dry

| cask storage being implemented, it is an increasing danger, the fire that we are referring to. 

|

| So it was also surprising to me that I found out from this report to Congress recently that

| Entergy has begun studying the pool fire scenarios and even they said there is no new and

| significant information on spent fuel. (PNPS-D-W)

|

| Comment: Other credible scientific reports found in the Journal of Science and Global

| Security, for example, have new and significant information of a more specific nature on this

| issue, they explain how a major human and environmental disaster would result from the

| overheating and burning of a protective fuel rod cladding in a densely packed pool. They

| describe how the fire could easily release, result in the release of massive amounts of

| radioactive product, cesium being the worst, and that, in its report that I referred to, to

| Congress, the estimate of cancer deaths from a typical scenario with a cesium release is from

| 2,000 to 6,000 deaths. I would say that's a significant impact. 

|

| A full release would dwarf Chernobyl's release, based on the amount of cesium at Pilgrim. I

| believe it's, our spent fuel pool at Pilgrim has several times the amount of cesium that was in

| existence at Chernobyl and released at Chernobyl. The Massachusetts Attorney General has a

| report, and I think it was referred to by an earlier speaker, that describes the consequences of

| such an accident at Pilgrim, specific to Pilgrim, they are between, in these terms for somewhere

| between a 10 and 100 percent release of the cesium. 

|

| So, if 10 percent is released or 100 percent is released, somewhere in that range, this is the

| range of the consequences in that report for Pilgrim. The cost would be somewhere between

| $105 and $488 billion and the cancers would effect somewhere between 8,000 and 24,000

| people, that's significant. What's the impact of this business of the spent fuel pool and this new

| information on the SEIS report that we are talking about here tonight? Well it would seem that

| this new information raises a red flag, and this information has come forward only in recent
Appendix A

July 2007 A-161 NUREG-1437, Supplement 29

years and it's directly applicable to Pilgrim's densely packed spent fuel pool, and it's going to |

get worse with age, the packing gets more intense. (PNPS-D-W) |

|

Comment: Two, an increase in the density of the pool's fuel rods, three, scientific reports that |

are fairly recent where everybody is beginning to acknowledge the severe human and |

environmental impact posed by an accident in a more densely packed pool, especially the |

above ground type of Pilgrim, I mean that's what's really the problem here. These are fixable |

problems, however, this is not a statement that we've got to shut the plant down tomorrow, |

these are fixable problems, but somebody has got to shine a spotlight on them and make sure |

that we start talking about a plan B, a resolution of these problems. |

|

So I urge you to consider this information for the sake of kids, and my neighbors and the |

citizens not just of Duxbury where I live, but Plymouth, and Kingston, and Marshfield and places |

20 miles beyond where if there was a severe accident, people would be effected for hundreds |

of miles, actually. (PNPS-D-W) |

|

Comment: The second issue, environmental impact of postulated accidents, that's Section 5, |

is that right? Thanks. This involves spent fuel and specifically the above ground pool and, |

again, new and significant information here, no mention of it anywhere. I'm just stunned, |

absolutely stunned. The issue is that, what are the risks associated with a spent fuel pool |

accident? And the answer to this question has always been similar to the first one, that the |

issue has been satisfactorily assessed on a national level with scenarios that assess the |

possibility of some leakage from the spent fuel pool and, as well, the answer always involves |

that there will be, there is some normal amount of density of fuel in the pool and that a leakage |

will result in a manageable scenario. (PNPS-D-W) |

|

Comment: So, summarizing again the second issue of the fuel pool, there is significant and |

new information, from my perspective, as follows, there is an increased probability of a spent |

fuel pool attack from the air, there's two very realistic scenarios that are deployable and that |

hinge on weak points in the building as well as local airstrip safety systems that are inadequate, |

but I won't discuss those, they are security issues. (PNPS-D-W) |

|

Response: On site spent fuel storage is considered a Category 1 issue, which was evaluated |

in the GEIS, NUREG-1437; therefore, accidents would be included within the analysis of the |

Category 1 issue of on site spent fuel storage. The safety and environmental effects of spent |

fuel storage on site have been evaluated by the NRC and, as set forth in the Waste Confidence |

Rule (10 CFR 51.23), the NRC generically determined that such storage could be accomplished |

without significant environmental impacts. In the Waste Confidence Rule, the Commission |

determined that spent fuel can be safely stored onsite for at least 30 years beyond the plants |

life, including license renewal. The GEIS, NUREG-1437, is based upon the assumption that |

storage of the spent fuel on site is not permanent. |

|
Appendix A

NUREG-1437, Supplement 29 A-162 July 2007

| The issue of security and risk from malevolent acts at nuclear power plants is considered out of

| the scope of the environmental review and was addressed in the September 26, 2006, Pilgrim

| Nuclear Power Station Scoping Summary Report (ADAMS Accession No. ML062710517).

| These matters will continue to be addressed through the ongoing regulatory oversight process

| as current and generic regulatory issues that affect all nuclear facilities. Appropriate safeguards

| and security measures have been incorporated into the site security and emergency

| preparedness plans. Any required changes to emergency and safeguards contingency plans

| related to terrorist events will be incorporated and reviewed under the operating license. 

|

| It should be noted that the Massachusetts Attorney General is currently petitioning the NRC for

| rulemaking regarding the evaluation of environmental impacts of severe spent fuel pool

| accidents. Information regarding the Massachusetts Attorney General's rulemaking petition, can

| be found at the following NRC website:

| http://ruleforum.llnl.gov/cgi-bin/rulemake?source=prm5110&st=petitions-a. 

|

| The comments are noted, but do not provide new information. Therefore, no changes have

| been made to the SEIS.

|

| Comment: Draft Supplemental GEIS should incorporate the Commission's decision to

| consider the issues raised by the Attorney General's Scoping Comments and Hearing Request

| in a generic rulemaking proceeding. The Commission initiated the rulemaking proceeding in

| November of 2006 by publishing the Attorney General's August 29, 2006 rulemaking petition in

| the Federal Register for public comment. It is therefore premature for the Draft Supplement

| GEIS to reach any conclusions regarding the environmental impacts of high-density pool

| storage of spent fuel at the Pilgrim nuclear power plant. (PNPS-D-HH)

|

| Comment: As stated in our Scoping Comments, the Supplemental GEIS for the Pilgrim

| nuclear power plant should address the environmental impacts of a severe accident in the

| Pilgrim fuel pool, including accidents caused by equipment failures, natural disasters, and

| intentional malicious acts. The Supplemental GEIS should also consider a reasonable array of

| alternatives for avoiding or mitigating the impacts of a severe pool fire, including combined

| low-density pool storage and dry storage of spent fuel. (PNPS-D-HH)

|

| Comment: We hereby renew the Attorney General's June 15, 2006, comments on the scope

| of the Draft Supplemental GEIS, including our previous request that you consider the technical

| information contained in the Hearing Request which was attached to our Scoping comments.

| Our Scoping Comments were summarily dismissed in the NRC Staff's September 26, 2006,

| scoping decision and ignored in the Draft Supplemental GEIS. (PNPS-D-HH)

|

| Response: The comments are related to the comments provided by the MassAG to the NRC

| during the hearing request and Scoping period regarding the evaluation of environmental

| impacts of a severe spent fuel pool accident. On site spent fuel storage is considered a
Appendix A

July 2007 A-163 NUREG-1437, Supplement 29

Category 1 issue, which was evaluated in the GEIS, NUREG-1437; therefore, accidents would |

be included within the analysis of the Category 1 issue of on site spent fuel storage. The safety |

and environmental effects of spent fuel storage on site have been evaluated by the NRC and, |

as set forth in the Waste Confidence Rule (10 CFR 51.23), the NRC generically determined that |

such storage could be accomplished without significant environmental impacts. In the Waste |

Confidence Rule, the Commission determined that spent fuel can be stored onsite for at least |

30 years beyond the plants life, including license renewal. The GEIS, NUREG-1437, is based |

upon the assumption that storage of the spent fuel on site is not permanent. In addition, the |

NRC staff did not find any new and significant information that would call the Category 1 issue, |

raised by the MassAG, into question. Therefore, they were not evaluated as part of the DSEIS. |

|

The MassAG is currently petitioning the NRC for rulemaking regarding the evaluation of |

environmental impacts of severe spent fuel pool accidents. Information regarding the |

MASSAG's rulemaking petition, can be found at the following NRC website: |

http://ruleforum.llnl.gov/cgi-bin/rulemake?source=prm5110&st=petitions-a |

|

These comments provide no new and significant information. Therefore, no changes have |

been made to the SEIS. |

|

A.2.11 Comments Concerning Alternatives |

|

Comment: One particular point of concern is NRC's conclusion that the alternatives to |

relicensing would have a significantly higher negative impact on the environment than |

relicensing. In Section 8.2.5.11, NRC downplays the potential of using energy efficiency to |

replace Pilgrim's capacity, citing federal and state forecasts that incorporate conservation |

measures and still show rising demand over the next several decades. The assumption that |

energy efficiency cannot reverse the trend of rising demand is incorrect. Efficiency is becoming |

far more widely accepted as an alternative to supply, and New England is poised to ramp up |

efficiency investments significantly. Current regulatory barriers to efficiency will likely begin to |

fall as well - as they did last year in Rhode Island, when the state adopted legislation that will |

require utilities to look at efficiency as a cheaper alternative to supply. The low costs of |

efficiency - approximately 1/3 the cost of wholesale power - are no small reason for newfound |

enthusiasm in the region. [“Energy Efficiency: The Smart Way to Reduce Global Warming |

Pollution in the Northeast.” National Association of the State PIRGS. August 2005.] |

|

In considering the alternatives to relicensing, NRC should consider a scenario with greatly |

expanded energy efficiency investments in the region. As proposed in Section 8.2.6, efficiency |

could be combined with other alternatives to replace Pilgrim's capacity. (PNPS-D-FF, |

PNPS-D-GG, PNPS-D-KK) |

|

Response: As the comment suggests, the NRC did evaluate an alternative that assumed 115 |

MW (e) of PNPS output would be replaced by conservation or energy efficiency measures (see |
Appendix A

NUREG-1437, Supplement 29 A-164 July 2007

| Section 8.2.6 Combination of Alternatives).The NRC's view on this matter is stated in the

| DSEIS Section 1.4 and reads as follows "Although a licensee must have a renewed license to

| operate a reactor beyond the term of the existing OL, the possession of that license is just one

| of a number of conditions that must be met for the licensee to continue plant operation during

| the term of the renewed license. Once an OL is renewed, State regulatory agencies and the

| owners of the plant will ultimately decide whether the plant will continue to operate based on

| factors such as the need for power or other matters within the State's jurisdiction or the purview

| of the owners."

|

| The report cited by the commenter (Energy Efficiency: The Smart Way to Reduce Global

| Warming Pollution in the Northeast, National Association of State PIRGS, August 2005)

| highlights the potential advantages of energy efficiency compared to practices and policies that

| allow energy demand to grow, thus requiring existing and new fossil fuel based facilities. Local

| and regional decision makers may analyze these with other pertinent factors when deciding

| how to best address regional energy needs. The comment is noted. However, the comment

| does not provide any new information and no changes have been made to the SEIS. 

|

| Comment: Please use common sense and plan to shut down Pilgrim Nuclear in five years!

| Just think...........Roughtly 50 square miles of solar arrays can provide enough electricity to meet

| all of the electrical needs of the United States of America! One thing we already have is plenty

| of desert out west and penty of rooftops in our towns, cities and countryside. The Chinese are

| already constructing the basic materials for capture of sunlight. PYRON AND BOEING and

| others are already under contract in other countries to establish colar power collector arrays so

| that Denmark and other countries do not have to rely on nuclear power of the oil giants.

| (Nuclear power is NOT cheap.) (PNPS-D-AA)

|

| Response: The Department of Energy in their Energy Outlook 2006 (page 81) and Energy

| Outlook 2007 (page 85) state that grid connected solar generation will remain at 0.1 percent of

| total US generation through 2030. However, they do state that small-scale customer-sited

| applications will grow rapidly. The Staff's view is that in the long range solar power systems will

| make an important contribution to U.S. energy supplies but that solar systems are not expected

| to be a feasible replacement for the base load output of PNPS. Therefore, no changes have

| been made to the SEIS.

|

| Comment: I am an advocate of nuclear power and am in there midst of putting together a

| program to include the potential of nuclear plants being part of the transition from carbon based

| technologies to hydrogen over the next twenty years. Instead of defending the past and the

| current maybe it would do you folks a great bit of good if you were positioning yourselves

| against your adversaries for the future at the same time speaking their language, How can a no

| - nuke disregard programs eliminating green house gases and creating an overall better

| environment.

|

| For example !!! Nuclear facility production of hydrogen for alternative fuel programs based on

| hydrogen resulting from the process could power all the cars in the future. Not to mention
Appendix A

July 2007 A-165 NUREG-1437, Supplement 29

create an alternative power source for all carbon based proposals. I understand you've lived |

this tale before but maybe it will help with the new ( consumer ) awareness of global warning |

that's supposedly leading the charge to new technologies. |

|

I would like to discuss the potential of the Plymouth facility being the catalyst for the production |

of hydrogen fueling the alternative fuel movement. My background in sensors and respiratory |

protection programs has afforded me a unique view into the suppliers of energy, their curses |

and their opportunities. (PNPS-D-BB) |

|

Response: As noted in the DSEIS Section 8.2.3, the NRC has certified four new standard |

designs for nuclear power plants. Should applications to construct plants, based on these |

certified designs, be approved, additional off-sets of greenhouse gases from combustion of |

fossil fuels would occur. The commenter's suggestion relative to using the nuclear power plants |

to generate hydrogen is not applicable to PNPS which has been designed solely for electric |

generation, and no changes have been made to the SEIS. |

|

Comment: Surely the development of SOLAR CELLS cannot be MORE expensive to develop |

and maintain than the life span of a nuclear power plant. Solar will be "on line", pardon the pun, |

in the next 10 years. |

|

PYRON-SOLAR (San Diego, CA) has teamed up with BOEING-SPECTRALAB to create a solar |

arrray of glass magnifying lenses that gather sunlight and focus it onto a photovoltaic panel |

which creates direct current to split water into hydrogen and oxygen...with a 37 % to 40% |

efficiency! |

|

YES it used a lot of energy to produce this array. BUT it uses the sun for fuel thereafter. And |

sunlight is cheap. SEE: info@pyronsolar.com SEE: www.lionhellas.com. See: |

info@freedomenergysolutions.com There are many more sites to peruse. SOLAR ENERGY IS |

CHEAP, ALONG WITH WIND, WATER AND TIDE. |

|

I could go on and on (the readers of this, if any, probably would agree!) However...... MY |

POINT IS that, yes, the United States has a great deal of electricity generated by nuclear power |

but now with computers, nanotechnology, world-wide research and growth in solar, wind, water, |

and tidal power....once these really get going the world will not need to accumulate the |

tragically dangerous wastes of nuclear power and ,hopefully, NOT those from nuclear weapons! |

(DO TELL, IS THERE A CONNECTION BETWEEN NUCLEAR "POWER" AND NUCLEAR |

WEAPONRY?) |

|

(Hmmmmm.) |

|

The power of the future is not radioactive. It is simple, free and there is no end to it. SUN, |

WINDS, WATER, AND TIDAL POWERS ARE CHEAP, once the initial development price has |

been paid. A great deal of research is underway which continually makes sustainable energy |

sources increasingly "cheap" and increasingly available. (PNPS-D-AA) |

|

|
Appendix A

NUREG-1437, Supplement 29 A-166 July 2007

| Comment: But I feel it's common sense to start the process to truly clean and probably in the

| long run will be cheaper-type energy. The solar array that I just mentioned is 40 percent

| efficient and already solar energy is down to about $2 kilowatt, if my, I'm not sure if I'm right on

| that, but it's been cut in half, it was $4, now it's down to $2 and it's heading for a cheaper and

| cheaper base level. (PNPS-D-C)

|

| Comment: Over in China, there is a country that's already on the New York Stock Exchange

| and they are getting into cheaply making silicon-type -- I don't have my notes with me -- voltaic

| cells and so forth. (PNPS-D-C)

|

| Comment: In California, there is many, many companies, one that comes to my mind is Pyron,

| which is connected with Boeing Spectrolab, and they have made and designed an array of

| glass, magnifying glass, small cubic-type things, I can't explain it, and a 25-foot diameter array

| which focuses the sun's energy onto voltaic-type generators. And it seems to me that, in the

| long run, the world has to turn to materials and processes that do not involve radioactive

| materials which are dangerous, no matter what you say about how they decompose...

| (PNPS-D-C)

|

| Response: As stated in the DSEIS Section 9.3, the NRC Staff's preliminary recommendation

| is that "the adverse environmental impacts of license renewal for PNPS are not so great that

| preserving the option of license renewal for energy planning decision makers would be

| unreasonable." The comments refer to the possibility that there are less expensive energy

| alternatives than continued operation of PNPS. It is the Staff's expectation that regional energy

| planners are in the best position to recognize the economics of PNPS in relationship to those of

| renewable energy alternatives and to then undertake the appropriate course of action in light of

| the energy needs of the Commonwealth. The comments are noted, but do not provide any new

| information and no changes have been made to the SEIS.

|

| Comment: And then also I just want to comment that I was surprised to see the broad-brushed

| conclusion that alternatives to relicensure have moderate to large impacts necessarily, I mean

| that's obvious of course with fossil fuel plants but with alternatives, including renewables but

| especially efficiency and conservation, it's very hard to argue that the impacts would be

| anywhere close to large in terms of negative environmental and health impacts and, when you

| are talking about cost effective, I mean that's obviously the way to go. (PNPS-D-S)

|

| Response: It is correct to say that the DSEIS identified large impacts associated with several

| of the alternatives to PNPS. For instance, land requirements for a coal burning generating

| facility would be extensive and, therefore, impacts to land use and terrestrial ecology would be

| expected to be moderate to large if a coal burning alternative were built (DSEIS Section 8.2.1).

| Furthermore, land requirements for a renewable energy system based on wind power would

| also be substantial resulting in potentially large terrestrial impacts (DSEIS Table 8-8).

|

| However, it is not correct to say that the DSEIS ascribes moderate to large impacts to

| alternatives that involve energy efficiency and conservation measures. The discussion in the

| DSEIS Section 8.2.5.10 addresses conservation. That section questions the viability of

| replacing PNPS by conservation measures in an environment of increasing demand for
Appendix A

July 2007 A-167 NUREG-1437, Supplement 29

electricity but there is no suggestion of negative environmental impacts being associated with |

conservation measures. The comment is noted, but does not provide any new and significant |

information and no changes have been made to the SEIS. |

|

Comment: The alternatives section discussed wind, it dismissed hydro power and although I'm |

not an advocate for damming our rivers and increasing hydropower, I would be curious to see |

an alternatives analysis given to the tidal usage of the Cape Cod Canal. (PNPS-D-I) |

|

Response: Hydropower is discussed in DSEIS Section 8.2.5.4. That section discusses |

conventional hydropower, i.e., energy being derived from rivers that have been dammed to |

create an elevated water surface (a lake) that can potentially be used to drive a turbine. A |

kinetic hydropower turbine relies on natural currents that occur across tidal channels and |

straights. Cape Cod Canal may be a potential site for a kinetic type hydropower development |

though it is expected that the output of such a project would be relatively modest when |

compared to the base load output of PNPS. It appears that the first such project in the U.S. is |

being developed in New York City's East River by Verdant Power |

(http://www.verdantpower.com/initiatives/currentinit.html; |

http://www.msnbc.msn.com/id/18096246/). Currently in a testing phase, the project is designed |

to eventually produce up to 10 MW, or enough electricity for approximately 10,000 homes. |

|

The comment is noted, but does not provide any new and significant information. Therefore, no |

changes have been made to the SEIS. |

|

Comment: The fusion power plants, such as is being built in Europe, probably is a better |

answer in the long run, but it's going to cost billions of dollars. (PNPS-D-C) |

|

Response: The staff did not consider fusion power to be an alternative to PNPS because that |

technology is not sufficiently developed to evaluate its environmental and other implications. |

More information of fusion energy systems can be found in the report of the “U.S. Climate |

Change Technology Program - Technology Options for the Near and Long Term”, August 2005 |

(accessed at www.climatetechnology.gov/library/2005/tech-option). |

|

Furthermore, “Annual Energy Outlook 2007 - With Projections to 2030" does not mention fusion |

technology, which strongly suggests that fusion technology is not expected to make a |

significant contribution to energy supplies prior to 2030. The staff has concluded that a power |

plant generating electricity using fusion as its energy source is not a feasible alternative to |

replace the output of PNPS. |

|

A.2.12 Comments Concerning Editorial Issues |

|

Comment: Page 4-69, Line 2 - Suggest deleting "and" between "may" and "as" to correct a |

typographical error. (PNPS-D-MM) |

|
Appendix A

NUREG-1437, Supplement 29 A-168 July 2007

| Comment: Page 4-55, Line 19 - Suggest changing "Figure 2-13" to "Figure 2-12" since "Figure

| 2-13" shows facility layout and not low-income block groups. (PNPS-D-MM)

|

| Comment: Page 4-55, Line 7 - Suggest changing "percent" to "percentage" to correct a

| typographical error. (PNPS-D-MM)

|

| Comment: Page 4-38, Line 16 - Suggest changing "Figure 2-5" to "Figure 2-6" since "Figure

| 2-5" shows the intake structure and not the transmission ROW (right of way). (PNPS-D-MM)

|

| Comment: Page 4-23, Line 8 - Suggest changing "Figures 2-10 and 2-11" to "Figures 2-9 and

| 2-10" since reference to "Figure 2-11" is incorrect. (PNPS-D-MM)

|

| Comment: Page 2-108, Lines 16, 18, and 28 - Suggest using Town of Plymouth or Plymouth,

| rather than Plymouth Town. (PNPS-D-MM)

|

| Comment: Page 4-54, Line 33 - Suggest changing "Figure 2-12" to "Figure 2-11" since "Figure

| 2-12" shows low-income populations and not minority block groups. (PNPS-D-MM)

|

| Comment: Page 2-26, Line 35 - Line 35 needs to be deleted since it is currently an empty

| space and separates a continuing sentence. (PNPS-D-MM)

|

| Comment: Page 8-47, Line 8 - Suggest changing "powerbock" to power block" to correct

| typographical error. (PNPS-D-MM)

|

| Comment: Page 2-1, Lines 24-25 - Plant nominal ground level is 23 ft. above MSL. Thus most

| major structures are situated at or above 23 ft. MSL. (PNPS-D-MM)

|

| Comment: Page 2-4, Line 5 - The plant is accessed via Power House Road. It is no longer

| called Edison Access Road. (PNPS-D-MM)

|

| Comment: Page 2-7, Line 12 - Suggest deleting the space after "MSL". (PNPS-D-MM)

|

| Comment: Page 2-7, Lines 18-19 - The sentence "Debris and large, impinged organisms are

| removed from the bar racks using mechanical rake." should be changed to read "Debris and

| large, impinged organisms are removed from the bar racks using divers." Since the mechanical

| rake is not currently used. (PNPS-D-MM)

|

| Comment: Page 9-10, Line 17 - Suggest changing "MODERATE" under Natural Gas-Fired

| Generation Alternate Greenfield Site column to "SMALL to MODERATE" since Line 11 of Page

| 8-28 states "SMALL to MODERATE" for siting at PNPS or an alternate Greenfield site". 

| (PNPS-D-MM)

|

| Comment: Page 2-9, Lines 12-14; Page E-60, Lines 33-35 - Suggest changing the sentence

| "Since the chlorination events ... only one pump." to "Condenser chlorination is usually

| conducted only when both circulating water pumps are running." (PNPS-D-MM)
Appendix A

July 2007 A-169 NUREG-1437, Supplement 29

Comment: Page 2-13, Line 30 - The word should be "Thermex", not ''thermix''. |

Page 2-17, Lines 8-10 - These 3 lines are an exact repeat from the previous paragraph (lines |

2-5). (PNPS-D-MM) |

|

Comment: Page 2-17, Line 30 - Typo - "resuse" should be "reuse" (PNPS-D-MM) |

|

Comment: Page 2-21, Line 3 - Suggest deleting the redundant ''the'' in the sentence "The |

Entergy-owned property boundary, including the PNPS site and the woodlands tract, is shown |

in Figure 2-3." (PNPS-D-MM) |

|

Comment: Page 2-22, Line 30 - Suggest changing "and NPDES permit" to "a NPDES permit". |

(PNPS-D-MM) |

|

Comment: Page 2-117, Line 18 - Suggest changing "Figure 2-12" to "Figure 2-11" to |

accurately reflect location of minority populations. Figure 2-12 shows low-income populations |

only. (PNPS-D-MM) |

|

Comment: Page 2-25, Line 19 - Suggest changing "50.751 (g)" to "50.75(g)(1)" to accurately |

reflect the regulatory citation. (PNPS-D-MM) |

|

Comment: Page 2-170, Lines 18-19 - A space should be added between Lines 18 and 19. |

(PNPS-D-MM) |

|

Comment: Page 2-42, Lines 32-34 - The wording "approximately several miles" in the |

sentence "Jones River, located approximately several miles north of PNPS, has its headwaters |

in Pembroke, Kingston, and Plympton before it empties into Plymouth Harbor (Lawton et al. |

1990 in ENSR 2000)." should be reworded. Suggest approximately" be deleted from this |

sentence. (PNPS-D-MM) |

|

Comment: Page 2-50, Lines 31-33 - Suggest inserting the wording "due to the breakwater |

walls providing an ideal habitat' after "grounds" and "therefore" between "habitat and "cunner" |

so that the sentence reads "The PNPS area is a cunner spawning and nursery grounds due to |

the breakwater walls providing an ideal habitat; therefore, cunner have a high incidence of |

entrainment and impingement at PNPS relative to other species (Lawton et al. 2000)." This |

would be a more accurate statement of facts whereas the draft wording could be mis-leading. |

(PNPS-D-MM) |

|

Comment: Page 2-58, Lines 15-17 - Suggest deleting the sentences "Rock gunnel larvae |

have been collected in the PNPS entrainment sampling." and "Juveniles and/or adults have |

also been observed in the PNPS impingement sampling program." since these are repeats of |

the previous two sentences. (PNPS-D-MM) |

|

Comment: Page 2-83, Line 11 - "RWQCB 2004" should be changed to "CRWQCB 2004" to |

accurately reflect "California Regional Water Quality Control Board". (PNPS-D-MM) |

|
Appendix A

NUREG-1437, Supplement 29 A-170 July 2007

| Comment: Page 2-85, Line 22 - Suggest deleting the comma after "Prescott". (PNPS-D-MM)

|

| Comment: Page 2-85, Line 28 - Suggest deleting the "t" after "to". (PNPS-D-MM)

|

| Comment: Page 2-109, Line 18 - Suggest deleting the comma between "Commission" and

| "2003". (PNPS-D-MM)

|

| Comment: Page 2-111, Line 11 - Suggest using Town of Barnstable or Barnstable, rather than

| Barnstable Town. (PNPS-D-MM)

|

| Comment: Page 4-78, Line 17 - Suggest changing "Entergy Cultural Resources Procedure" to

| "Environmental Reviews and Evaluations" to accurately reflect the title of the procedure. 

| (PNPS-D-MM)

|

| Comment: Page 2-126, Line 37 - Suggest changing "Route 3a" to "Route 3A". (PNPS-D-MM)

|

| Comment: Page 2-134, Line 32 - Suggest changing "RWQCB" to "CRWQCB" to accurately

| reflect "California Regional Water Quality Control Board". (PNPS-D-MM)

|

| Comment: Page 2-161, Lines 11-12 - A space should be added between Lines 11 and 12. 

| (PNPS-D-MM)

|

| Comment: Page 2-161, Lines 15-16 - A space should be added between Lines 15 and 16. 

| (PNPS-D-MM)

|

| Comment: Page 2-25, Line 1 - Suggest changing "100 mg/L" to "1000 mg/L" to accurately

| reflect the limitations outlined in the PNPS Groundwater Discharge Permit. (PNPS-D-MM)

|

| Comment: Page G-1, Line 20 - Remove ":" (PNPS-D-MM)

|

| Comment: Page 8-37, Line 21 - Suggest changing "MODERATE" under the Impact Column to

| "SMALL TO MODERATE" since Line 8 of Page 8-36 states "SMALL TO MODERATE".

| (PNPS-D-MM)

|

| Comment: Page 9-10, Line 19 - Suggest changing "MODERATE" under the New Nuclear

| Generation Alternate Greenfield Site column to "SMALL to MODERATE" since Line 8 of Page

| 8-36 states "SMALL to MODERATE". (PNPS-D-MM)

|

| Comment: Page E - Appendix E has three subsections, all labeled Appendix E with no

| subsection designations. Two of these subsections use the same numbering scheme (e.g.

| Section 1.0 on Pages E-22 and E-51). The Appendix E subsections should have unique

| designators such that two different sections of the report do not have the same designator (e.g.

| Appendix E Section 1.0). (PNPS-D-MM)

|

|
Appendix A

July 2007 A-171 NUREG-1437, Supplement 29

Comment: Page 5-3, Line 32 - Suggest deleting "NRC 1996." Footnote on page 5-1 states |

that all GElS references are to the GElS and Addendum 1. (PNPS-D-MM) |

|

Comment: Page 8-30, Line 18 - Suggest changing "MODERATE" for Alternate Greenfield Site |

column to "SMALL to MODERATE" since Line 11 of Page 8-28 states "SMALL to MODERATE" |

for siting at PNPS or an Alternate Greenfield Site. (PNPS-D-MM) |

|

Comment: Page 8-30, Line 14 - Need a space above Line 30. (PNPS-D-MM) |

|

Comment: Page 5-6, Line 30 - Suggest changing "equivalents (person-rem)" to "equivalent |

man (person-rem)". (PNPS-D-MM) |

|

Comment: Page 8-29, Line 29 - Need a space above Line 29. (PNPS-D-MM) |

|

Comment: Page G-8, Line 25 - Suggest inserting "(Entergy 2006b)" after "was evaluated." |

(PNPS-D-MM) |

|

Comment: Page 8-29, Line 28 - Suggest changing "powerbock" to "power block" to correct a |

typographical error. (PNPS-D-MM) |

|

Comment: Page 8-30, Line 19 - Need a space above Line 19. (PNPS-D-MM) |

|

Comment: Page 8-21, Lines 18-19 - Need a space between Lines 18 and 19. (PNPS-D-MM) |

|

Comment: Page G-4, Line 9 - Suggest changing "equivalents (person-rem)" to "equivalent |

man (person-rem)". (PNPS-D-MM) |

|

Comment: Page 4-85, Line 1 - Suggest adding a period after "2006c" to correct a |

typographical error. (PNPS-D-MM) |

|

Comment: Page 5-5, Line 6 - Suggest changing SAMAs to SAMA. (PNPS-D-MM) |

|

Comment: Page G-9, Line 16 and 21 - Suggest inserting "Exchanger Room" after "Heat". |

(PNPS-D-MM) |

|

Comment: Page G-12, Line 29 - Suggest changing "w" to "was". (PNPS-D-MM) |

|

Comment: Page G-13, Line 2 - Suggest changing "one percent increase" to "two percent |

increase". (PNPS-D-MM) |

|

Comment: Page G-16, Line 10 - Suggest inserting "components" after "rugged". |

(PNPS-D-MM) |

|

|
Appendix A

NUREG-1437, Supplement 29 A-172 July 2007

| Comment: Page G-16, Lines 13-14 - Suggest deleting the sentence "One block wall included

| in the list of important faults has a conservatively determined capacity of 1.06 g." This

| information was not included in reference Entergy 2006b and does not belong in this paragraph. 

| (PNPS-D-MM)

|

| Comment: Page G-23, Lines 12-14 - Suggest deletion of "are completely eliminated" from

| assumptions statement since it is redundant. (PNPS-D-MM)

|

| Comment: Page G-28, Line 25 - Suggest adding "benefits and" prior to "costs" since the

| response to RAI 5.e changed both the benefits estimate and the cost for SAMA 27. 

| (PNPS-D-MM)

|

| Comment: Page G-32, Line 23 - Suggest changing "$4.5M" to "$4.6M" since $914,000 x 5 =

| $4,570,000. (PNPS-D-MM)

|

| Comment: Page E-2, Line 9 - The current DOT registration number is No. 053006 550 0050. It

| was issued 5/30/2006 and expires 6/30/2007. (PNPS-D-MM)

|

| Comment: Page E-2, Line 13 - The current Depredation Permit (#MB831184-0) was effective

| on 7/1/2006 and expires 6/30/2007. (PNPS-D-MM)

|

| Comment: Page E-3, Line 12 - The issue and expiration dates need to be updated for

| Materials License 49-0078. The current license was issued May 11, 2006 and expires May 31,

| 2011. (PNPS-D-MM)

|

| Comment: Page E-4, Line 11 - The issue and expiration dates need to be updated for

| Tennessee Radioactive Waste license-for-Delivery T-MA004-L01. The current license number

| is T-MA004-L07, was issued 12/5/2006 and expires 12/31/2007. (PNPS-D-MM)

|

| Comment: Page E-4, Line 5 - The issue and expiration dates need to be updated for South

| Carolina Radioactive Waste Transport Permit 0007-20-1. The current permit number is

| 0007-20-07-X, was issued 12/12/2006 and expires 12/31/2007. (PNPS-D-MM)

|

| Response: These comments are editorial in nature and will be incorporated as appropriate.

|

| Comment: Page 4-86, Lines 13-14 - The "U.S. Census Bureau (USCB) 2001" reference is not

| in the Section 4.0 write-ups. (PNPS-D-A)

|

| Comment: Page G-16, Line 9 - Suggest inserting "(Entergy 2006b)" after "potential SAMAs."

| (PNPS-D-MM) 

|

| Comment: Page G-4, Line 6 - Suggest changing "(NRC 1997b)" to "(NRC 1997a)". 

| (PNPS-D-MM)

|

|
Appendix A

July 2007 A-173 NUREG-1437, Supplement 29

Comment: Page 2-143, Lines 15-16 - The "Hart 2001" reference is not in the Sections 2.0 - |

2.2 write-ups. (PNPS-D-MM) |

|

Comment: Page 2-157, Lines 18-19 - The "New England Fishery Management Council |

(NEFMC) 1999" reference is not in the Sections 2.0 - 2.2 write-ups. (PNPS-D-MM) |

|

Comment: Page 2-150, Lines 21-23 - The "Massachusetts Office of Coastal Zone |

Management 2006" reference is not in the Sections 2.0 - 2.2 write-ups. (PNPS-D-MM) |

|

Comment: Page 2-145, Lines 37-38 - The "Kocik and Brown 2001" reference is not in the |

Sections 2.0 - 2.2 write-ups. (PNPS-D-MM) |

|

Comment: Page 2-144, Lines 19-20 - The "Idoine, J. Undated" reference is not in the Sections |

2.0 - 2.2 write-ups. (PNPS-D-MM) |

|

Comment: Page 2-143, Lines 37 and 40 - Suggest changing "Hendrickson, L. 2000" to |

"Hendrickson, L. 2000a" to match write-ups. (PNPS-D-MM) |

|

Comment: Page 2-155, Lines 31-33 - The "National Marine Fisheries Services (NMFS) 2006e" |

reference is not in the Sections 2.0 - 2.2 write-ups. (PNPS-D-MM) |

|

Comment: Page 2-151, Line 8 - Suggest changing "1998" to "1998b" to match write-ups in the |

DSEIS. (PNPS-D-MM) |

|

Comment: Page 2-161, Lines 5-6 - The "Pava et al. 1997" reference is not in the Sections 2.0 |

- 2.2 write-ups. (PNPS-D-MM) |

|

Comment: Page 2-167, Lines 33-34 - The "Town of Plymouth 2006c" reference is not in the |

Sections 2.0 - 2.2 write-ups. (PNPS-D-MM) |

|

Comment: Page 2-167, Lines 18-20 - The "Toner 1984b" reference is not in the Sections 2.0 - |

2.2 write-ups. (PNPS-D-MM) |

|

Comment: Page 2-166, Lines 5-6 - The "Stevenson 1936" reference is not in the Sections 2.0 |

- 2.2 write-ups. (PNPS-D-MM) |

|

Comment: Page 2-163, Lines 12-14 - The "Salerno et al. 2001" reference is not in the |

Sections 2.0 - 2.2 write-ups. (PNPS-D-MM) |

|

Comment: Page 2-162, Lines 38-39 - Suggest changing "1986a" to "1986" to accurately |

reflect the listing in the Section 2.2.5 write-up. (PNPS-D-MM) |

|

Comment: Page 2-162, Lines 5-7 - The Reid et al. 1999a reference is a repeat of the |

reference shown on Lines 17 - 19. (PNPS-D-MM) |

|
Appendix A

NUREG-1437, Supplement 29 A-174 July 2007

| Comment: Page 2-156, Lines 39-41 - The "Neilson 1986" reference is not in the Sections 2.0 -

| 2.2 write-ups. (PNPS-D-MM)

|

| Comment: Page 2-41, Lines 28-29 - Suggest changing "Cargnelli 1999e" to "Cargnelli, et al.

| 1999e" since the Section 2.3 references does not list a reference only for Cargnelli 1999e. 

| (PNPS-D-MM)

|

| Comment: Page 2-157, Lines 4-6 - The "New England Fishery Management Council (NEFMC)

| 1987" reference is not in the Sections 2.0 - 2.2 write-ups. (PNPS-D-MM)

|

| Comment: Page 2-160, Line 18 - Suggest changing "Cadri" to "Cadrin" to reflect accurate

| spelling. (PNPS-D-MM)

|

| Comment: Page 2-160, Lines 1-3 - The "Olsen and Merriman 1946" reference is not in the

| Sections 2.0 - 2.2 write-ups. (PNPS-D-MM)

|

| Comment: Page 2-159, Lines 1-4 - The "Nuclear Regulatory Commission (NRC) 2006"

| reference is not in the Sections 2.0 - 2.2 write-ups. (PNPS-D-MM)

|

| Comment: Page 2-158, Lines 29-31 - The "Nuclear Regulatory Commission (NRC) 1996"

| reference is not in the Sections 2.0 - 2.2 write-ups. (PNPS-D-MM)

|

| Comment: 2-157, Lines 21-23 - The "New England Fishery Management Council (NEFMC)

| 2003a" reference is not in the Sections 2.0 - 2.2 write-ups. (PNPS-D-MM)

|

| Comment: Page 2-129, Line 26 and 30 - Suggest changing "ACE 2006" to "USACE 2006" to

| accurately reflect the listing in the Section 2.3 References. (PNPS-D-MM)

|

| Comment: Page 2-161, Lines 29-31 - This reference is incorrect. The referred to document is

| email correspondence between Jill Brochu at Entergy and Robert Prescott. It is not available at

| the location noted. Also Robert Preston is employed at the Massachusetts Audubon Society,

| not the Provincetown Center for Coastal Studies. If the reference is for the fish study which has

| somehow been included, Robert Prescott is not the author and the date of 1/15/2005 would be

| incorrect. (PNPS-D-MM)

|

| Comment: Page 2-84, Line 25, Page 2-87, Lines 8 and 14 - Although there are "NHESP

| 2006a" and "NHESP 2006b" listings in the Section 2.3 references, there is no "NHESP 2006"

| listing only. (PNPS-D-MM)

|

| Comment: Page 2-69, Line 19 - Although there are "NEFMC 2006a" and "NEFMC 2006b"

| listings in the Section 2.3 references, there is no "NEFMC 2006" listing only. (PNPS-D-MM)

|

| Comment: Page 2-73, Line 4 - Although there are "Cadrin 2000a" and "Cadrin 2000b" listings

| in the Section 2.3 references, there is no "Cadrin 2000" listing only. (PNPS-D-MM)

|
Appendix A

July 2007 A-175 NUREG-1437, Supplement 29

Comment: Page 2-73, Lines 12 and 21 - Suggest changing "Cooper et al. 1998" to "Cooper |

and Chapleau 1998" to accurately reflect the listing in the Section 2.3 References. |

(PNPS-D-MM) |

|

Comment: Page 2-73, Line 21 - There is no "DFO 1997" listing in the Section 2.3 References. |

(PNPS-D-MM) |

|

Comment: Page 2-74, Line 10 - Suggest changing "Brodziak et al. 1996" to "Brodziak and |

Macy 1996" to accurately reflect the listing in the Section 2.3 References. (PNPS-D-MM) |

|

Comment: Page 2-74, Line 18 - There is no "Cargnelli et al. 1999" listing in the Section 2.3 |

References. (PNPS-D-MM) |

|

Comment: Page 2-74, Lines 32, 34 and 40 - Suggest changing "Hendrickson 2004" to |

"Hendrickson and Holmes 2004" to accurately reflect the listing in the Section 2.3 References. |

(PNPS-D-MM) |

|

Comment: Page 2-76, Line 10 - There is no "Anjaru 1964" listing in the Section 2.3 |

References. (PNPS-D-MM) |

|

Comment: Page 2-78, Line 36 - There is no "Matthiessen 1984" listing in the Section 2.3 |

References. (PNPS-D-MM) |

|

Comment: Page 2-79, Line 39 - Suggest changing "Hart et al. 2004" to "Hart and Chute 2004" |

to accurately reflect the listing in the Section 2.3 References. (PNPS-D-MM) |

|

Comment: Page 2-80, Line 39 - There is no "NEFSC 2004" listing in the Section 2.3 |

References. (PNPS-D-MM) |

|

Comment: Page 2-80, Line 11 - There is no "Hines 1991" listing in the Section 2.3 |

References. (PNPS-D-MM) |

|

Comment: Page 2-67, Line 10 - There is no "Hendrickson 2000b" listing in the Section 2.3 |

References. Although there are two "Hendrickson 2000" listings in the Section 2.3 references, |

neither is listed as "2000b". (PNPS-D-MM) |

|

Comment: Page 2-43, Line 3 - The "McKenzie 1964" reference is not listed in the Section 2.3 |

References. (PNPS-D-MM) |

|

Comment: Page 2-63, Line 18 - The "NFSC 1998" reference is not listed in the Section 2.3 |

References. (PNPS-D-MM) |

|

Comment: Page 2-134, Line 22-23 - The "Cadrin and King 2002" reference is not in the |

Sections 2.0 - 2.2 write-ups. (PNPS-D-MM) |

|
Appendix A

NUREG-1437, Supplement 29 A-176 July 2007

| Comment: Page 2-45, Line 11 - The reference "NMFS 2003" is intended to be either "NFMS

| 2003a" or "NFMS 2003" based on the references listed in the Section 2.3 References.

| (PNPS-D-MM)

|

| Comment: Page 2-49, Line 15 - The reference "Provincetown Center for Coastal Studies

| 2006" should be changed to "Prescott 2005" to accurately reflect the listing in the Section 2.3

| References. (PNPS-D-MM)

|

| Comment: Page 2-54, Line 24 - The "Woods 1982" reference is not listed in the Section 2.3

| References. (PNPS-D-MM)

|

| Comment: Page 2-55, Line 22 - The reference "Steimle 1999b" should be changed to "Steimle

| et al. 1999b" as shown in the Section 2.3 References. (PNPS-D-MM)

|

| Comment: Page 2-83, Line 22 - "Marine Mammal Protection Act (MMPA) of 1972" should be

| listed in the Section 2.3 references to be consistent with other regulatory Acts listed in the

| Section 2.3 References. (PNPS-D-MM)

|

| Comment: Page 2-62, Line 30 - The "Terciero 1995" reference is not listed in the Section 2.3

| references. Moreover the correct spelling ("Terceiro") appears to be that as identified on Page

| 2-167 (lines 1-2 and 3-4). (PNPS-D-MM)

|

| Comment: Page 2-83, Lines 32 and 34, Page 2-84, Lines 1, 3, and 10 - The reference

| "Provincetown Center for Coastal Studies 2006a" should be changed to "Prescott 2005" to

| accurately reflect the listing in the Section 2.3 References. (PNPS-D-MM)

|

| Comment: Page 2-99, Lines 23-25 - The "Entergy 2006a" reference at the end of the

| sentence "This program includes the collection, analysis, and evaluation of data in order to

| assess the radiological impact of PNPS on the environment and on the general public ... " is

| incorrect since the PNPS Environmental Report did not contain such as statement.

| (PNPS-D-MM)

|

| Comment: Page 2-93, Lines 34-35, Page 2-97, Line 31, Page 2-98, Line 3 - Although there

| are "FWS 2006a" and "FWS 2006b" listings in the Section 2.3 references, there is no "FWS

| 2006" listing only. (PNPS-D-MM)

|

| Comment: Page 2-85, Lines 32 and 34, Page 2-125, Line 25 - Suggest changing "Entergy

| 2006" to "Entergy 2006a" to accurately reflect the source and listing in the Section 2.3

| References. (PNPS-D-MM)

|

| Comment: Page 2-66, Line 32 - The "Langton and Bowman 1981" reference is not listed in the

| Section 2.3 References. (PNPS-D-MM)

|

| Comment: Page 2-67, Line 39 and 6 - Suggest changing "Chang et al. 199b" to "Chang et al.

| 1999b". (PNPS-D-MM)
Appendix A

July 2007 A-177 NUREG-1437, Supplement 29

Comment: Page 2-35, Line 38 and Page 2-36, Line 14 - The reference "NEFMC 1998" is |

intended to be either "NEFMC 1998a" or "NEFMC 1998b" based on the references listed in the |

Section 2.3 References. (PNPS-D-MM) |

|

Comment: Page 2-58, Line 32 - The "Morse 1978" reference is not listed in the Section 2.3 |

References. (PNPS-D-MM) |

|

Comment: Page 4-83, Lines 37-38 - The "Nuclear Regulatory Commission (NRC). 1987" |

reference is not in the Section 4.0 write-ups. (PNPS-D-MM) |

|

Comment: Page 4-81, Lines 31-34 - The "National Academy of Sciences (NAS). 1980" |

reference is not in the Section 4.0 write-ups. (PNPS-D-MM) |

|

Comment: Page 4-91, Lines 36-38 - The "National Academy of Sciences (NAS). 1990" |

reference is not in the Section 4.0 write-ups. (PNPS-D-MM) |

|

Comment: Page G-13, Line 14 - There is no "USDA 1998" listing in the Section G.8 |

references (Pages G-38 through G-40). (PNPS-D-MM) |

|

Comment: Page 4-66, Line 26 - Suggest changing "Hoffman 1992" to "Hoffman et al. 1992" to |

accurately reflect the listing in the Section 4.10 References. (PNPS-D-MM) |

|

Comment: Page 4-66, Line 26 - Suggest changing "Sever 1993" to "Sever et al. 1993" to |

accurately reflect the listing in the Section 4.10 References. (PNPS-D-MM) |

|

Comment: Page 4-66, Line 17 - There is no "MPDH 1990" listing in the Section 4.10 |

References. (PNPS-D-MM) |

|

Comment: Page 4-65, Line 3Suggest changing" ... in NRC 2006a ... " to " ... in NRC 2006a)." |

to correct a typographical error. (PNPS-D-MM) |

|

Comment: Page 4-63, Line 6 - There is no "NRC 2005" listing in the Section 4.10 References. |

(PNPS-D-MM) |

|

Comment: Page 4-63, Lines 1-2; Page 4-67, Line 3; Page 4-67, Line 30 - The Entergy |

references utilized in this discussion are incorrect since these references are associated with |

radiological environmental reports and not radioactive effluent release reports which is a |

separate report that deals with doses. (PNPS-D-MM) |

|

Comment: Page 4-62, Line 14 - There is no "BEIR VII 2005" listing in the Section 4.10 |

References. (PNPS-D-MM) |

|

Comment: Page 4-59, Line 22 - There is no "NHESP 2005a" listing only in the Section 4.10 |

References. (PNPS-D-MM) |

|
Appendix A

NUREG-1437, Supplement 29 A-178 July 2007

| Comment: Page 4-58, Line 29 - There is no "NHESP 2006" listing in the Section 4.10

| References. (PNPS-D-MM)

|

| Comment: Page 2-170, Lines 27-29 - Suggest adding "1982." to reflect actual year that

| material was published and to be consistent with how the reference is listed in the Section 2.2

| write-up for the Monkfish (pp. 2-54 to 2-55). (PNPS-D-MM)

|

| Comment: Page 4-82, Lines 36-38 - The "Natural Heritage and Endangered Species Program

| (NHESP). 1995a" reference is not in the Section 4.0 write-ups. (PNPS-D-MM)

|

| Comment: Page 4-81, Lines 27-29 - The "National Academy of Sciences (NAS). 1972"

| reference is not in the Section 4.0 write-ups. (PNPS-D-MM)

|

| Comment: Page 5-10, All - For consistency with the other sections suggest adding 10 CFR 50,

| 10 CFR 51, 10 CFR 54, 10 CFR 73 and 10 CFR 100 to the Section 5.3 References.

| (PNPS-D-MM)

|

| Comment: Page 2-1, Lines 24 and 32 - There is no "Boston Edison Company 1974" reference

| in the Section 2.3 references. (PNPS-D-MM)

|

| Comment: Page 4-84, Lines 11-13 - The "Nuclear Regulatory Commission (NRC). 1996b"

| reference is not in the Section 4.0 write-ups. (PNPS-D-MM)

|

| Comment: Page 4-86, Lines 7-8 - The "U.S. Census Bureau (USCB) 1991" reference is not in

| the Section 4.0 write-ups. (PNPS-D-MM)

|

| Comment: Page 4-13, Line 12, Page 4-21, Line 25 and 28 - Although there are "MRI 2005a"

| and "MRI 2005b" listings in the Section 4.10 references, there is no "MRI 2005" listing only. 

| (PNPS-D-MM)

|

| Comment: Page 4-51, Line 41 - There is no "OCPC 2000" listing in the Section 4.10

| References. (PNPS-D-MM)

|

| Comment: Page 4-84, Lines 36-37 - The "Nuclear Regulatory Commission (NRC). 2006b"

| reference is not in the Section 4.0 write-ups. (PNPS-D-MM)

|

| Comment: Page G-40, Lines 24-25 - The "Nuclear Regulatory Commission (NRC) 2003"

| reference is not in the Sections G.1 - G.7 write-ups (Pages G-1 through G-38). (PNPS-D-MM)

|

| Comment: Page 4-50, Line 4 - There is no "MOCZM 2006" listing in the Section 4.10

| References. (PNPS-D-MM)

|

| Comment: Page 5-4, Line 21 - Suggest changing "(2006a)" to "(Entergy 2006a)" to reflect the

| listing in the Section 5.3 References. (PNPS-D-MM)

|
Appendix A

July 2007 A-179 NUREG-1437, Supplement 29

Comment: Page 8-14, Line 28 - Suggest changing "(USEPA 2000b)" to "(EPA 2000b)" to |

reflect the listing the Section 8.4 References. (PNPS-D-MM) |

|

Comment: Page 4-30, Line 17; Page 4-58, Line 31 - There is no "Entergy 2006" listing only in |

the Section 4.10 References. (PNPS-D-MM) |

|

Comment: Page 4-82, Line 7 - The "National Environmental Policy Act of 1969" reference is |

not in the Section 4.0 write-ups. (PNPS-D-MM) |

|

Comment: Page 4-12, Lines 29 and 33 - Although there are "MRI 2005a" and "MRI 2005b" |

listings in the Section 4.10 references, there is no "MRI 2005" listing only. (PNPS-D-MM) |

|

Comment: Page 2-27, Lines 14-15 - The sentence "Massachusetts was designated as being |

in "moderate nonattainment" of the 8-hour ozone standard in June 2005." should have a |

reference. (PNPS-D-MM) |

|

Comment: Page 2-100, Line 17 - Suggest changing "Entergy 2003" to "Entergy 2003c" to |

accurately reflect the source and listing shown in the Section 2.3 References. (PNPS-D-MM) |

|

Comment: Page 4-13, Lines 2 and 5 - There is no "MRI 2000" listing in the Section 4.10 |

References. (PNPS-D-MM) |

|

Comment: Page 4-12, Line 38 and 40, Page 4-13, Line 5 - There is no "MRI 2002" listing in |

the Section 4.10 References. (PNPS-D-MM) |

|

Comment: Page 4-67, Line 3 - There is no "NRC 2005a" listing in the Section 4.10 |

References. (PNPS-D-MM) |

|

Comment: Page 4-86, Lines 1-2 - The "United Nations Scientific Committee on the Effects of |

Atomic Radiation (UNSCEAR) 2000" reference is not in the Section 4.0 write-ups. |

(PNPS-D-MM) |

|

Comment: Page 4-70, Line 32 - There is no "USACE 2006" listing in the Section 4.10 |

References. (PNPS-D-MM) |

|

Comment: Page 4-12, Lines 21 and 25 - Although there are "MRI 2005a" and "MRI 2005b" |

listings in the Section 4.10 references, there is no "MRI 2005" listing only. (PNPS-D-MM) |

|

Comment: Page 4-77, Lines 28-31 - The "Entergy Nuclear Operations, Inc. (Entergy). 2000" |

reference is not in the Section 4.0 write-ups. (PNPS-D-MM) |

|

Comment: Page 4-78, Lines 4-7 - The "Entergy Nuclear Operations, Inc. (Entergy). 2005b" |

reference is not in the Section 4.0 write-ups. (PNPS-D-MM) |

|

|
Appendix A

NUREG-1437, Supplement 29 A-180 July 2007

| Comment: Page 2-68, Line 21 - The reference "NEFSC 2005" appears to be the source for

| "Figure 2-7"; however "NEFMC 2006" is listed as the source for "Figure 2-7". Therefore, there

| appears to be a discrepancy. (PNPS-D-MM)

|

| Comment: Page 4-85, Lines 6-7 - The "Old Colony Planning Council (OCPC). 2000" reference

| is not in the Section 4.0 write-ups. (PNPS-D-MM)

|

| Response: These comments are editorial in nature and deal specifically with the references

| cited in the DSEIS. The references will be reviewed and these comments will be incorporated

| as appropriate.

|

| Comment: Page E-15, Line 30 - Apparent error "disch temp diff. ranging from 33.8 - 48

| degrees F ... " The typical temperature difference is 26 - 29 degrees F. (PNPS-D-MM)

|

| Comment: Page E-26, Line 9 - Typo "1998 MWt" should be 2028 MWt. (PNPS-D-MM)

|

| Comment: Page E-68, Lines 34-35 - The sentence states "Condenser tubes at PNPS are

| cleaned by backwashing on a 1 to 2-week interval, depending on the degree of bio fouling." is

| incorrect. Thermal backwashing is done 4 to 5 times per year. This process was accurately

| described on Page E-62, 3rd Paragraph, starting at Line 25. (PNPS-D-MM)

|

| Comment: Page E-15, Line 35 - PNPS is not attempting "to offset adverse impacts" by

| stocking 25,000 winter flounder. It is a pilot program intended to determine the feasibility of this

| approach (which could be scaled up as needed). (PNPS-D-MM)

|

| Comment: Page E-43, Line 20 - Suggesting adding the clarification that no sturgeon of any

| type has ever been observed at PNPS; therefore, there has been no chance of

| mis-identification. (PNPS-D-MM)

|

| Comment: Page E-91, Line 15 - There is no "Bowman et al. 2000" listing in the Section 9.0

| References. (PNPS-D-MM)

|

| Comment: Page E-62, Lines 19-20 - Based on the PNPS NPDES Permit and Table 2-2, there

| are no temperature limitations on the service water. Therefore, the sentence "The permitted

| change in temperature across the service water is 5 to 10°F." is incorrect and should be

| deleted. Also, suggest adding another space to separate the sentence from the next sentence. 

| (PNPS-D-MM)

|

| Comment: Page E-60, Lines 17-20 - The sentence "The mixture is used to ensure the total

| residual chlorine discharge concentration does not exceed a maximum daily concentration of

| 0.10 parts per million (ppm) and an average monthly concentration of 0.5 ppm in the service

| water discharge." is incorrect. The Condenser Cooling Water NPDES Permit total residual

| chlorine limitations are "0.10" maximum daily and "0.1" average monthly. The Plant Service 

|

|
Appendix A

July 2007 A-181 NUREG-1437, Supplement 29

Cooling Water NPDES Permit total residual chlorine limitations are "1.0" maximum daily and |

"0.5" average monthly. (PNPS-D-MM) |

|

Comment: Page E-57, Lines 38-39 - The sentence "Debris and large, impinged organisms are |

removed from the bar racks using a mechanical rake." should be changed to read "Debris and |

large, impinged organisms are removed from the bar racks using divers." since the mechanical |

rake is not currently used. (PNPS-D-MM) |

|

Comment: Page E-29, Lines 30-32 - Suggest changing the sentence "Since the chlorination |

events ... only one pump." to "Condenser chlorination is usually conducted only when both |

circulating water pumps are running." (PNPS-D-MM) |

|

Comment: Page E-57, Line 1 - There is no "Lawton et al. 1995" listing in the Section 9.0 |

References. (PNPS-D-MM) |

|

Comment: Page E-52, Lines 38-39 - Suggest changing the first sentence of the paragraph to |

read as follows: "Water depths in the vicinity of PNPS are typically 10ft and up to 120 ft fives |

miles offshore of the site." (PNPS-D-MM) |

|

Comment: Pages E-102 and E-105, Sections 7.0 and 8.0 - The NRC is not known to have |

been delegated authority under the Clean Water Act to make recommendations regarding |

mitigation measures associated with "aquatic matters". In addition, 316(b} is associated with |

numerical performance standards and does not define "impact'. Mitigation measures in the |

future, if any, will be developed and jointly agreed upon between USEPA Region I and Entergy |

as part of the 316(b} compliance process. Therefore, Section 7.0 should be deleted. |

(PNPS-D-MM) |

|

Comment: Page E-112, Line 21; Page E-118, Line 23 - Suggest changing "1999a" to "1999" |

to correct a typographical error and to be consistent with how the reference is shown in the |

Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM) |

|

Comment: Page E-111, Lines 1-2 - Suggest listing all authors for this reference instead of only |

"Galya et al. 1997" to be consistent with other sections References. (PNPS-D-MM) |

|

Comment: Page E-111, Lines 10-12 - The "Grimes et al. 1986" reference is not in the |

Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM) |

|

Comment: Page E-110, Line 31-33 - The "Fahay et al. 1999b" reference is not in the Sections |

1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM) |

|

Comment: Page E-112, Lines 1-5 - The "Hendrickson and Holmes 2004" reference is not in |

the Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM) |

|

Comment: Page E-114, Lines 36-27 - The "Marak 1973" reference is not in the Sections 1.0 - |

8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM) |
Appendix A

NUREG-1437, Supplement 29 A-182 July 2007

| Comment: Page E-112, Lines 29-30 - The "Kelly and Barker 1961 a" reference is not in the

| Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-110, Lines 1-2 - The "Dooley 1978" reference is not in the Sections 1.0 -

| 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-113, Lines 26-29 - The "Lawton et al. 1984" reference is not in the

| Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-114, Lines 33-34 - The "Marak 1967" reference is not in the Sections 1.0 -

| 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-115, Lines 1-4 - The "Marine Research, Inc. (MRI) 2005a" reference is not

| in the Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-115, Line 6 - Suggest inserting "(MRI)" between "Inc." and "2005b" to

| correct a typographical error and to be consistent with how the reference is shown in Sections

| 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-115, Lines 11-14 - The "Marine Research, Inc. (MRI) 2006" reference is

| not in the Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-118, Lines 19-21 - The "Pikanowski et al. 1999" reference is not in the

| Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-108, Lines 35-37 - The "Chang et al. 1999c" reference is not in the

| Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-120, Lines 1-3 - The "Steimle et al. 1999e" reference is not in the Sections

| 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-109, Line 38 - Suggest changing "1988a" to "1998" to correct a

| typographical error so that the reference is consistent with that shown in the Sections 1.0 - 8.0

| write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-110, Lines 35-37 - The "Freeman and Turner 1977" reference is not in the

| Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-112, Lines 32-33 - The "Kelly and Barker 1961 b" reference is not in the

| Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-45, Lines 9-11 - The "Fish and Wildlife Service (FWS) 2006e" reference is

| not in the Sections 1.0 - 6.0 write-ups (Pages E-22 through E-43). (PNPS-D-MM)

|

|
Appendix A

July 2007 A-183 NUREG-1437, Supplement 29

Comment: Page E-81, Line 32 - There is no "Deuel 1964" listing in the Section 9.0 |

References. (PNPS-D-MM) |

|

Comment: Page E-47, Lines 18-19 - This reference is incorrect. The referred to document is |

email correspondence between Jill Brochu at Entergy and Robert Prescott. It is not available at |

the location noted. Also Robert Preston is employed at the Massachusetts Audubon Society, |

not the Provincetown Center for Coastal Studies. (PNPS-D-MM) |

|

Comment: Page E-81, Line 32 - There is no "Shepherd 2000b" listing in the Section 9.0 |

References. (PNPS-D-MM) |

|

Comment: Page E-80, Line 35 - There is no "NMFS 2005c" listing in the Section 9.0 |

References. (PNPS-D-MM) |

|

Comment: Page E-80, Line 8 - There is no "Steimle et al. 1999d" listing in the Section 9.0 |

References. (PNPS-D-MM) |

|

Comment: Page E-73 - Line 19 - There is no "NMFS 2005a" listing in the Section 9.0 |

References. (PNPS-D-MM) |

|

Comment: Page E-67, Line 36 - There is no "EPA 1994" listing in the Section 9.0 References. |

(PNPS-D-MM) |

|

Comment: Page E-37, Lines 19, 20, and 23 - Although there are "FWS 2006a" and "FWS |

2006b" listings in the Section 7.0 references, there is no "FWS 2006" listing only. |

(PNPS-D-MM) |

|

Comment: Page E-85, Lines 8-9 - Suggest changing "NOAA 1998a" to "NOAA 1998" to |

accurately reflect the listing in the Section 9.0 References. (PNPS-D-MM) |

|

Comment: Page E-67, Line 30 - The "Clean Water Act" should be listed in the Section 9.0 |

references to be consistent with other regulatory Acts listed in the Section 9.0 References. |

(PNPS-D-MM) |

|

Comment: Page E-66, Lines 24 and 41 - Suggest changing "Marine Research, Inc. 2005b" to |

"MRI 2005b" to be accurate with the listing in the Section 9.0 References. (PNPS-D-MM) |

|

Comment: Page E-45, Lines 32-34 - The "Mass Audubon 2003" reference is not in the |

Sections 1.0 - 6.0 write-ups (Pages E-22 through E-43). (PNPS-D-MM) |

|

Comment: Page E-45, Lines 36-39 - The "National Marine Fisheries Service (NMFS) 2002" |

reference is not in the Sections 1.0 - 6.0 write-ups (Pages E-22 through E-43). (PNPS-D-MM) |

|

Comment: Page E-63, Line 13 - There is no "BSC Group 1996" listing in the Section 9.0 |

References. (PNPS-D-MM) |
Appendix A

NUREG-1437, Supplement 29 A-184 July 2007

| Comment: Page E-51, Line 32 - The "Endangered Species Act" should be listed in the Section

| 9.0 references to be consistent with other regulatory Acts listed in the Section 9.0 References.

| (PNPS-D-MM)

|

| Comment: Page E-32, Line 11 - There is no "BSC Group 1996" listing in the Section 7.0

| References. (PNPS-D-MM)

|

| Comment: Page E-32, Lines 21-22, 24,and 29 - There is no "Entergy 2006a" listing in the

| Section 7.0 References. (PNPS-D-MM)

|

| Comment: Page E-107, Line 24 - Suggest changing "2000a" to "2000" to correct a

| typographical error and so that the reference is consistent with what is shown in the Sections

| 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-107, Lines 20-22 - The "Burnett et al. 1983" reference is' not in the

| Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-108, Lines 11-16 - The "Cargnelli et al. 1999f" reference is not in the

| Sections 1.0 - 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-106, Lines 1-3 - The "Able et al. 1982" reference is not in the Sections 1.0 -

| 8.0 write-ups (Pages E-51 through E-105). (PNPS-D-MM)

|

| Comment: Page E-28, Line 41; Page E-s 22, 28, 30, 37, and 40 - There is no "ENSR 2002"

| listing in the Section 7.0 References. (PNPS-D-MM)

|

| Comment: Page E-34, Line 18 - Suggest changing the first sentence of the paragraph to read

| as follows: 'Water depths in the vicinity of PNPS are typically 10ft and up to 120 ft fives miles

| offshore of the site." (PNPS-D-MM)

|

| Comment: Page E-104, Line 6 - There is no "EPRI 2006" listing in the Section 9.0 References.

| (PNPS-D-MM)

|

| Comment: Page E-34, Line 28 - There is no "EG&G 1995" listing in the Section 7.0

| References. (PNPS-D-MM)

|

| Comment: Page E-104, Line 5 - There is no "Siemens 2006" listing in the Section 9.0

| References. (PNPS-D-MM)

|

| Comment: Page E-89, Line 1 - Suggest changing "Normandeau 206b" to "Normandeau

| 2006b" to correct a typographical error. (PNPS-D-MM)

|

| Comment: Page E-32, Line 22 - There is no "AEC 1972" listing in the Section 7.0 References.

| Page E-103, Line 37 - There is no "Earth Tech 2006a" listing in the Section 9.0 References.

| (PNPS-D-MM)
Appendix A

July 2007 A-185 NUREG-1437, Supplement 29

Comment: Page E-32, Lines 29-30, and 31 - There is no "NSTAR 2006" listing in the Section |

7.0 References. (PNPS-D-MM) |

|

Comment: Page E-101, Line 26 - Suggest changing "Cooper et a. 1998" to "Cooper and |

Chapleau 1998" to accurately reflect the listing in the Section 9.0 References. (PNPS-D-MM) |

|

Comment: Page E-100, Lines 22-23 - There is no "Burnett et al. 1992" listing in the Section |

9.0 References. (PNPS-D-MM) |

|

Comment: Page E-99, Line 24 - Suggest changing "Scott 1982a" to "Scott 1982" to accurately |

reflect the listing in the Section 9.0 references. (PNPS-D-MM) |

|

Comment: Page E-98, Line 35 - Suggest changing "Pereira 1999" to "Pereira et al. 1999" to |

accurately reflect the listing in the Section 9.0 References. (PNPS-D-MM) |

|

Response: The comments are noted. However, comments regarding Appendix E can not be |

incorporated since this section is for reference only and includes letters and consultations |

previously submitted and finalized. |

|

A.2.13 Comments Concerning Decommissioning Issues |

|

Comment: The staff did not provide information about buried wastes on site - where they were |

located; how deep they were buried; packaging; chemical and radioactive composition of waste. |

We know for example that when Pilgrim blew its filters in 1982, there was considerable |

contamination. During the clean up, waste was buried on the property. Neighbors and |

passer-bys on Rocky Hill Road observed the operation - NRC and Entergy's staff are aware, |

too. The public, NRC officials and Entergy staff also are well aware of burials off the Access |

Road. If the application is approved, decommissioning will not begin until 2032 or later. We |

assume that the licensee and NRC determined that burying waste on site would not harm the |

environment based on a definite time frame - a 40 year license. What would happen after 60 |

years was not considered nor analyzed. It needs to be analyzed to provide reasonable |

assurance that public health and safety will not be negatively impacted. For example erosion of |

the top soil will be affected by the passage of time, increasing frequency and severity of coastal |

storms; and the topography of the site that slants down into Cape Cod Bay. Migration of |

contaminants underground is currently not monitored. Migration of contaminants from so-called |

low level waste has happened at other sites - for example, at Barnwell SC, TVA, Hanford and |

Starmet. Hence there is no reason to believe that the same could not happen here. (PNPS-D- |

EE) |

|

Response: The comment is noted. As part of the environmental site audit for license renewal |

the staff typically reviews records and reports of spills or other occurrences involving the spread |

of hazardous contaminants as it relates to human health and water use and |

quality-groundwater. During its review, the staff did not identify any new and significant |

information within these records that may call the Category 1 issues of human health and water |

use and quality-groundwater into question. Nevertheless, the requirements for keeping these |
Appendix A

NUREG-1437, Supplement 29 A-186 July 2007

| records and retention programs, 10 CFR 50.75(g)(1), are to ensure that these types of areas

| will be identified during plant decommissioning. In addition, these regulations provide

| assurance that any contamination will be appropriately remediated during site

| decommissioning. 

|

| Specifically, at the time of decommissioning, the licensee is required to submit a License

| Termination Plan which contains information on the types and quantities of radioactive

| materials on the site. 

|

| Decommissioning will ensure that all areas of the site, meet the site release criteria specified in

| 10 CFR Part 20 prior to license termination. In addition, environmental impacts from the

| activities associated with the decommissioning of any reactor before or at the end of an initial or

| renewed license are evaluated in the Final Generic Environmental Impact Statement on

| Decommissioning of Nuclear Facilities (NUREG-0586). These decommissioning activities are

| considered Category 1 issues; and therefore, no changes have been made to the SEIS.

|

| Comment: Five years from now, PILGRIM NUCLEAR PLANT will be five years more mature

| than it is now. It is one of the model T's of the nuclear industry. It will be time, then, to put it to

| rest! It will take at least five years to decide just how, indeed, to put it SAFELY to rest so that for

| the next, say 100 to 400 years, it's radioactive reactor parts and wastes and the surrounding 

| earth will not threaten the diverse life forms of southeastern Massachusetts, Cape Cod and

| Massachusetts Bay. Please start deciding. (PNPS -D-AA)

|

| Response: Environmental impacts from the activities associated with the decommissioning of

| any reactor before or at the end of an initial or renewed license are evaluated in the Final

| Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities

| (NUREG-0586). This statement can be found at the beginning of Chapter 7. The findings from

| this GEIS are used to support the findings in the SEIS. The comment provides no additional

| information; therefore, no changes have been made to the SEIS.

|

| A.2.14 Comments Outside the Scope of the Environmental Review for

| License Renewal: Safeguards and Security; Operational Safety;

| Aging Management; Need for Power; and Energy Costs

|

| Safeguards and Security

|

| Comment: Security standards are inadequate at all the nuclear reactors, and the NRC has

| deliberately removed security complaints from the re licensing process, just as they have

| refused to give any serious consideration to a terrorist attack on these vulnerable facilities.

| (PNPS-D-A)

|

| Comment: The possibility of a terrorist attack on Pilgrim goes well beyond mere speculation.

| The 9/11 Commission has documented the fact that nuclear facilities had been among the

| original targets of the al Qaeda terrorists. (PNPS-D-B)

|
Appendix A

July 2007 A-187 NUREG-1437, Supplement 29

Comment: I have read Chairman Dale Klein's recommendation that future nuclear power |

plants should include design improvements to better protect against attack by large aircraft. |

Don't the citizens in our area deserve as much? Today the PNPS is packed with spent fuel rods |

in a structure designed before the 9/11 attacks, with off site storage of spent fuel highly unlikely. |

While the concrete walls may withstand an attack, can you assure us that the ceiling is |

impenetrable? (PNPS-D-DD) |

|

Comment: Risk of sabotage far from "small" - CRAC II Report; NAS Report; MA AGO Motion |

|

The President of the United States, Congress, special commissions all agree that the risk of |

sabotage to our country is considerable and increasing. Nuclear reactors are prime targets |

because of the catastrophic consequences a successful attack would bring. Pilgrim is an |

especially attractive target because of its location in "America's Hometown" - a symbolic target - |

Plymouth is known around the world. Pilgrim is vulnerable to an attack by the air [even a small |

explosive laden helicopter could cause a disaster by targeting the switch-yard, control room, |

intake, not to mention the densely packed spent fuel pool]; sea [a few buoys marking the |

no-enter zone, floating "No Trespassing" signs, provide no real deterrence; and land [onsite |

guards depend on off site forces, it is highly unlikely for them to arrive in sufficient time |

considering that OSRE mock attacks are usually lost in three minutes]; and there are simply not |

enough guards, trained and equipped, to meet the number of attackers and type of equipment |

involved in 9/11. |

|

Examples - new and significant information showing risk far from small: |

|

A. Core Melt - Calculation of Reactor Accident Consequences U.S. Nuclear Power Plants |

(CRAC-2), Sandia National Laboratory, 1982 |

|

A core melt at Pilgrim NPS, calculated by the federal government, would result in a 20 miles |

peak 1st year fatal radius; a 65 miles peak 1st year injury radius; and 23,000 peak cancer |

deaths. |

|

And new information available since the GEIS is a later analysis of the CRAC study by Dr. |

Edward Lyman showing that these estimates are conservative ["Chernobyl on the Hudson? - |

The Health and Economic Impacts of a Terrorist Attack at Indian Point Power Plant," Dr. Edwin |

Lyman, September 2004]. In the report he concluded, |

|

The federal study, CRAC II: |

|

• used census data from 1970; |

• assumed entire 10-mile EPZ would be evacuated within at most six hours after issuance |

order; |

• assumed aggressive medical treatment for all victims of acute radiation exposure in |

developing numbers for early fatalities; |

|
Appendix A

NUREG-1437, Supplement 29 A-188 July 2007

| • used a now obsolete correlation between radiation dose and cancer risk that

| underestimated the risk by a factor of 4 relative to current models; and current models need

| to be recalculated again based on the National Academy's BEIR Vll Report (June 2005) that

| reconfirmed that there is no safe level of radiation, risks are greater than previously thought

| and health risks other than cancer must be considered -such as heart disease and birth

| defects; 

| • sampled only 100 weather sequences out of over eight thousand (an entire year's worth), a

| method that underestimates the peak value over the course of a year by 30%. 

| (PNPS-D-EE)

|

| Comment: While nothing involving terrorism is 100 percent predictable, the often cited vision

| of a 9/11 style aircraft attack is virtually precluded by the design and layout of the critical plant

| elements and surrounding structural supports. Similarly, the notion of a frogman entering

| through the sea water inlet canal and the massive centrifugal cooling water pumps without

| being homogenized is ludicrous. (PNPS-D-L)

|

| Comment: Important to consider, but it was neglected, was the issue of security, there is

| site-specific information that you have to consider.

|

| First, vulnerability, what type of protection do they have? There is no protection from an air

| attack and despite the previous speaker, a helicopter loaded with explosives could cause a

| severe accident targeting spent fuel, targeting the switch yard, targeting the control room, we

| don't have to go on, it's an undisputed fact, they are not built to resist an air attack. Security

| from the water is virtually nonexistent, there are buoys which are floating no trespassing signs,

| period, explosives can be put up into the canal, that is why Homeland Security recommended a

| grate for Millstone, which they turned down. 

|

| Also, from a land attack, there is no effective security, they are dependent upon outside security

| arriving. However, the OSRI mock attacks have demonstrated that a force can do the job, hit

| the target sets in about three minutes, no way the state police, etcetera, are going to get there

| in three minutes. And neglected and what should be included is the spent fuel pool as being a

| serious target and a target of serious consequences, which Section 5 discusses that you focus

| on consequences. (PNPS-D-M)

|

| Comment: I do not need to elaborate on all the ways Terrorists can do harm - but it is easier

| than you'll ever admit and your test drills are phony and unrealistic. (PNPS-D-PP)

|

| Comment: Now, seriously, who here is concerned about a terrorist attacking a wind farm? So

| what if they did? You would never have the consequences that we have here. So, because

| nuclear has been described as cost effective, it's because these true costs are not put into play,

| it is the most heavily subsidized industry. If you describe it as safe, as former speakers had, it's

| because you are not looking at what the consequences of either a reactor accident or of a 

| spent fuel accident, God forbid, would be. And if you are looking at is as safe, I think I've

| already covered that. (PNPS-D-Q)

|

|
Appendix A

July 2007 A-189 NUREG-1437, Supplement 29

Comment: The secondary impact of this new information on the SEIS report is that the |

quantities of radioactive waste are now an attractive target, if they are on-site here, for terrorists |

who are set on spreading dirty bomb contamination that's going to destroy the environment and |

harm the health of our citizens, which is what this environmental impact statement is all about. |

(PNPS-D-W) |

|

Comment: New information, in my opinion, new and significant information never |

acknowledged in here, number one, 9/11 event, the 9/11 event, plus discovery of nuclear facility |

files on computers of fundamental terrorist organizations changes everything for me. I think it |

changes the probability of a, what's referred to in the report as a postulated accident, it changes |

the scenario that's mapped out as a manageable pool leakage to a pool drainage or, at best, |

the elimination of circulation of the water in the pool which has, as you'll see, as you'll hear, |

disastrous consequences. |

|

The national, just to back up to this business about fundamental terrorist organizations, and I'm |

just not talking off the top of my head based on the headlines in the news, the National |

Commission on Terrorist Organizations issued a 2004 staff paper suggesting that al Qaeda |

initially included nuclear power plants among their expanded lists of targets, aside from the |

World Trade Center, the Pentagon, etcetera, for their 9/11 attacks. So this is a national |

commission that was put together after 9/11 that stated this. |

|

This new information, again, changes the whole scenario here, it doesn't take a classified |

intelligence report to figure out how determined individuals could cause these scenarios to take |

place right from our backyard, the Plymouth Municipal Airport or another nonmonitored airstrip |

in the region. I think this is also new information. Again, it's come since the GEIS was |

developed, it's come within just the last few years and it gives us an opportunity to reassess the |

possibility of a sabotage attempt as a higher possibility or a higher probability than was |

originally postulated when people went through these scenarios and said this is not an issue. |

|

Prior to 9/11, the NRC had no way of sort of estimating the likelihood of some sort of sabotage |

at a nuclear facility. As a matter of fact, I'm going to quote from a document, an NRC |

document, "there is no established method ... for quantitatively estimating the likelihood of a |

sabotage event at a nuclear facility". This is from a report from the NRC prior to 9/11, June, |

2001, a briefing on spent fuel three months prior to 9/11. Since then, again, new information. |

We have an attack, we have mention of nuclear facilities in al Qaeda documents and I think |

immediately even a statistician, who knows nothing about terrorism, says, oh, we have a |

probability, we have some probability we can estimate, so this is new information. |

(PNPS-D-W) |

|

Response: The issue of security and risk from malevolent acts at nuclear power plants is |

beyond the scope of license renewal. These matters will continue to be addressed through the |

ongoing regulatory oversight process as current and generic regulatory issues that affect all |

nuclear facilities. Appropriate safeguards and security measures have been incorporated into |

the site security and emergency preparedness plans. Any required changes to emergency and |

safeguards contingency plans related to terrorist events will be incorporated and reviewed |
Appendix A

NUREG-1437, Supplement 29 A-190 July 2007

| under the operating license. [See “Amergen Energy Co, LLC (Oyster Creek Nuclear

| Generating Station), CLI-07-8, 65 NRC-124 (February 26, 2007, ADAMS Accession No.

| ML070570511)]. These comments provide no new information and no changes have been

| made to the SEIS.

|

| Comment: In California it has been ruled that the threat of terrorist attack should be

| considered by the NRC in deciding on the licensing of nuclear facilities. Why don't the citizens

| of Massachusetts deserve the same consideration and protection? I agree with the Union of

| Concerned Scientists in their stand on the realistic revision of security regulations.

| (PNPS-D-DD)

|

| Comment: In addition, we wish to inform you that on January 16, 2007, the U.S. Supreme

| Court denied a petition for review of a decision by the U.S. Court of Appeals for the Ninth Circuit

| that was cited in our Scoping Comments, San Luis Obispo Mothers for Peace v. Nuclear

| Regulatory Commission, 449 F.3d 1016 (9th Cir. 2007). The decision is reported at 2007 U.S.

| LEXIS 1028. (PNPS-D-HH)

|

| Comment: The 9th Circuit Court in California faced the question of whether the NRC needs to

| consider terrorism in licensing decisions under NEPA, they concluded that in fact they did. This

| is an important licensing decision. The industry in California went to appeal to the Supreme

| Court and the Supreme Court decided not to hear it which indicates they gave their blessing to

| the decision. So these two factors, therefore, that being terrorism, security and the spent fuel

| pool under postulated accidents must be considered if you are going to do an honest job. 

| (PNPS-D-D) 

|

| Comment: DSEIS concluded that, "Additionally the NRC regulatory requirements under 10

| CFR Part 73 provides reasonable assurance that the risk of sabotage is small."

| NRC did not consider new and significant information specific to this site; no reasonable person

| would agree that NRC regulatory requirements "provide reasonable assurance that the risk of

| sabotage is small."

|

| Massachusetts listed among top 5 terrorist targets 

|

| In, Arab-American to become first Massachusetts homeland security chief, David Weber,

| Associated Press, January 21, 2007 states, The federal government lists Massachusetts --

| where two of the planes involved in the 9-11 attacks were launched from Logan International

| Airport -- among the five states most likely to be involved in attacks. 

|

| Ninth Circuit Court - San Luis Obispo Mothers for Peace v. Nuclear Regulatory Commission,

| June 21, 2006 contradicts NRC Staff. The court dealt with the question of whether the NRC

| must address impacts of terrorist attacks in licensing decisions under National Environmental

| Policy Act - the court concluded that it did. Although technically the court's decision does not

| have to be applied here, practically it does. The NRC deals with most issues generically.

| Therefore how can NRC turn around and say it applies in California but not in Massachusetts? 

|

|
Appendix A

July 2007 A-191 NUREG-1437, Supplement 29

The Court found that: the risk of a terrorist attack is not too speculative for consideration under |

NEPA; the numeric probability of a terrorist attack need not be precisely quantifiable in order for |

its potential environmental impacts to be considered; the NRC erred by characterizing |

Petitioners' request as a demand for a "worst-case" analysis when Petitioners did not ask the |

NRC to engage in conjecture on the worst-case outcome, but instead sought an analysis of the |

likely range of environmental impacts if an attack occurred;"[t]here is no support for the use of |

security concerns as an excuse from NEPA's requirements. |

|

The US Supreme Court, January 16, 2007, refused to review the Ninth Circuit's ruling that, in |

order to comply with the National Environmental Policy Act (NEPA), the NRC must consider the |

environmental impacts of terrorist attacks before it licenses the new waste storage facility. |

|

The NRC and industry claim that they have invested huge sums to increase security and put in |

place extra measures. It is not logical for the NRC to consider the threat of terrorist attacks |

extremely serious outside the NEPA context but only speculative and theoretical within it. |

|

Bottom line -the ruling stated that agencies must conduct at least an environmental assessment |

for any government-approved project. If that review reveals the likelihood of a significant |

impact, the agency then must prepare a more thorough environmental impact statement. |

Re-licensing Pilgrim is a government-approved project; hence the SEIS logically should |

consider its impact - the draft did not. (PNPS-D-EE) |

|

Comment: The second area of interest I would like to talk about is the section postulated |

accidents and I stated two factors that had to be factored in here, one was the decision of the |

9th Circuit Court in California and also a proper reading of Section 5 of the GEIS. There is new |

and significant information regarding postulated accidents that was not considered. If |

considered, nobody could conclude that the result would be small... (PNPS-D-M) |

|

Comment: Third, they regard the impact as small because they ignored the impact of spent |

fuel in postulated accidents and they ignored terrorism. There are two significant factors that |

require them, before they move forward in this decision, to look at terrorism and also to look at |

the impacts of spent fuel in a postulated accident, one is the 9th Circuit Court decision in |

California that was asked to address the question whether the NRC need consider terrorism on |

licensing decisions under NEPA, they answered yes. This process is a significant licensing |

situation so, therefore, this is a factor that has to be looked at. The Supreme Court was asked |

by the licensee in California to review the case and they refused to do so, meaning they |

concurred. (PNPS-D-Q) |

|

Response: The Ninth Circuit Court of Appeals in San Luis Obispo Mothers for Peace, v. NRC, |

449 F.3d 1016 (Ninth Circuit 2006), upheld the Commission's decision on the Atomic Energy |

Act issues, but, as to the NEPA issues, concluded that "the NRC's determination that NEPA |

does not require a consideration of the environmental impact of terrorist attacks does not satisfy |

reasonableness review," and held that "the EA prepared in reliance on that determination is |

inadequate and fails to comply with NEPA's mandate." San Luis Obispo at 1035. The Supreme |

Court did not take review. Refusal to take review does not evince agreement with the decision |

below. |
Appendix A

NUREG-1437, Supplement 29 A-192 July 2007

| In the recent Commission Memorandum and Order concerning the renewal of the operating

| license for the Oyster Creek Nuclear Generating Station [“Amergen Energy Company, LLC

| (License Renewal for Oyster Creek Nuclear Generating Station),” CLI-07-8, 65 NRC 124 

| (February 26, 2007), ADAMS Accession No. ML070570511], the Commission reaffirmed its

| long-standing position “that NEPA does not require inquiry into the consequences of a

| hypothetical terrorist attack. The Commission "respectfully .... disagrees" with the Ninth Circuit

| Court of Appeals decision, but and will follow the decision of the court as applicable to the

| Diablo Canyon matter. But, as to other proceedings, the Commission continues to believe that

| such inquiry is not required. 

|

| In the Memorandum and Order, the Commission also reached the following conclusions. First,

| terrorist issues are unrelated to “the detrimental effects of aging” and are beyond the scope of

| license renewal. Second, the environmental effect caused by terrorists is simply too far

| removed from the natural or expected consequences of agency action to require a study under

| NEPA. Third, a NEPA-driven review of the risks of terrorism would not be necessary because

| the NRC has undertaken extensive efforts to enhance security at nuclear facilities. These

| ongoing post-9/11 enhancements provide the best vehicle for protecting the public. Fourth,

| substantial practical difficulties impede meaningful NEPA-terrorism review, while the problem of

| protecting sensitive security information in the quintessentially public NEPA and adjudicatory

| process presents additional obstacles. Finally, the GEIS has already performed a discretionary

| analysis of terrorist acts in connection with license renewal and concluded that the damage and

| radiological release from such acts would be no worse than the damage and release to be

| expected from postulated accidents.

|

| Aging Management

|

| Comment: Known structural issues with the reactor, and it's component parts including the

| reactor, it's core, pipes, gauges, valves, control room and all other necessary buildings and

| parts necessary to the questionably safe operation of this experimental technology are

| wrongfully being removed from the re licensing review by claiming they are design flaws

| covered under the original application process. In fact and deed, the reactor now operating at

| the pilgrim facility is not the same reactor approval for original operation. The NRC's own

| internal documents on this, and every nuclear facility in America that are being kept from

| serious public scrutiny show an aging fleet of reactors that are requiring and ever increasing

| amount of maintenance and repairs to keep them limping along. Most disturbing of these

| repairs, is the use of patching of known cracks, fissures and out right structure breaks with the

| use of various welding techniques meant to keep the reactors operating at all costs. Problem

| with this, is two fold. First, much like a boiler, this welds numbering into the thousands, including

| ones in the core itself create new weak points along the outer perimeter of each and every

| seam. Even more disturbing, much of this weld repair is being done blind in the core of the

| reactor itself with unmanned welding machines, with no real way of verify the quality of the job,

| nor providing ways for visual inspect of these weakened inner core areas. Secondly, the

| patches, and the welds that create them are constantly mutating the noise technology

| parameters used to warn human operators of internal core dangers...in short, each patch, each

| weld adds new sets of false signals that have to be figured out and solved as the industry plays

| Russian Roulette with our lives, the NRC content to let us as a community pray that the next
Appendix A

July 2007 A-193 NUREG-1437, Supplement 29

guess, and the one after that, and the one after that is ALWAYS the right one. As George Bush |

has said about Homeland Security as relates to terrorism, we have to be right 100 percent of |

the time...running a reactor under that kind of a mind set and regulatory oversight scenario is |

begging for a cataclysmic nuclear incident here in America. Mathematical modeling lets us |

know, that humans will make errors, it is a foregone conclusion, and eliminating from review the |

physical aging and brittling of these antiquated relics of years gone by, asking communities to |

trust an industry and a regulatory agency with a record of putting profits ahead of safety and |

human health is unacceptable, and it is imperative that every license renewal include as a part |

and parcel of the process a full and complete safety and security assessment. These |

assessments are being asked for by our members of Congress on a case by case basis, and |

time again the requests fall on deaf ears...if in fact, as the industry is claiming, these facilities |

are structurally sound and safe, it would make sense that they would welcome even ask for |

these assessments themselves to assuage public fears. (PNPS-D-A) |

|

Comment: Embattlement concerns of your aging reactor vessels. It is only a matter of time. |

(PNPS-D-PP) |

|

Comment: And I believe that these issues are related to the aging process because they get |

worse as time goes on, the more that the plant operates, the worse they get. I mean one could |

make an argument that these issues are related to the routine operation of the plant, but a |

circuit board that's routinely operating over a period of 20 years and as it heats, and gets hotter, |

and more brittle and eventually will break, something that happens in the spent fuel pool as a |

result of 20 additional years of operation that could increase the probability of an accident |

needs to be addressed because then I call it an aging issue. (PNPS-D-V) |

|

Response: The NRC's environmental review focuses on environmental impacts relevant to the |

extended period of operation requested by the applicant. Safety matters related to aging are |

addressed as a part of the NRC safety review for the license renewal, which is conducted |

separately, and will be documented in an NRC staff Safety Evaluation Report. The safety |

review looks at the applicant's aging management programs for passive long-lived systems, |

structures and components. The Safety Evaluation Report for PNPS was published on June 28, |

2007 and can be accessed in ADAMS at Accession No. ML071410438. The comments provide |

no new information and no changes have been made to the SEIS. |

|

Comment: Again the staff identified no new and significant information and concluded that |

there would be no socioeconomic impacts associated with decommissioning. Example: Leaks |

into Cape Cod Bay could significantly impact our air and water quality - not to mention |

socioeconomic impacts on our fishing and tourist industry and valuation of properties. |

(PNPS-D-EE) |

|

Comment: "The potential for significant water quality impacts from erosion or spills is no |

greater when decommissioning occurs after a 20-year license renewal period or after the |

original 40-year operation period, and measures are readily available to avoid such impacts." |

|

|
Appendix A

NUREG-1437, Supplement 29 A-194 July 2007

| The staff did not identify any new and significant information. If they had looked they would

| have concluded that there are no effective measures currently or in the aging management

| program to avoid impacts.

|

| The staff ignored the points brought forward by Pilgrim Watch in their Motion to Intervene, May

| 2006. Contention 1 asserts that the Aging Management program proposed in the Pilgrim

| application for license renewal is inadequate because (1) it does not provide for adequate

| inspection of all systems and components that may contain radioactively contaminated water

| and (2) there is no adequate monitoring to determine if and when leakage from these areas

| occurs. Some of these systems include underground pipes and tanks which the current aging

| management and inspection programs do not effectively inspect and monitor. NRC staff need

| consider that:

|

| We know that over the last decade a series of events, occurring at a quickening pace and with

| increasing magnitude, have raised serious questions about whether nuclear facilities are in

| compliance with federal regulations governing the release of radioactive materials into the

| environment - leaks have been reported at the majority of reactors. The industry is "addressing"

| the issue by a voluntary reporting program. Public safety requires requirements. 

|

| Exposure to radiation, including tritium, can cause cancer, disease, genetic mutations and birth

| defects. 

|

| Recent discoveries of leaked radioactive water in other nuclear facilities have made it clear that

| current methods for monitoring systems and components such as buried pipes and

| underground tanks are inadequate. In addition, the older the structure in question, the more

| likely it is for leakages to occur.

|

| Pilgrim is specifically vulnerable to undetected leaks in its underground pipes and tanks

| because it has nonconforming pipe fittings and flanges. The United States Government

| Accounting Office reported that PNPS is suspected of having received counterfeit or

| substandard pipe fittings and flanges. This could make leaks of contaminated water more likely.

| There is no evidence in the applicant's filing that a thorough investigation at PNPS has occurred

| to determine precisely which pipe fittings and flanges are substandard and whether they have

| been upgraded to meet standards.

|

| The Aging Management Program at Pilgrim does not provide adequate inspection of systems

| and components such as underground pipes and tanks. Appendix B describes the Aging

| Management Program for buried pipes and tanks. This section says that buried components will

| be inspected when excavated during maintenance, and that a focused inspection will be

| performed within ten years unless an opportunistic inspection occurs within this period - the

| focused inspection described is an untested Ultrasonic Test.

|

| Pilgrim does not have monitoring test wells around, for example, buried pipes and tanks to

| detect leaks.

|

|
Appendix A

July 2007 A-195 NUREG-1437, Supplement 29

The topography of the Pilgrim site is such that, were a leak to develop in an underground pipe |

or tank, the contaminated water would most likely migrate seaward and drain into Cape Cod |

bay. |

|

The only effective way to monitor for such an occurrence would be to have on-site monitoring |

wells located between Pilgrim and the ocean. A suitable array of wells, sampled regularly, could |

be used to test that the inspection program is working properly. (PNPS-D-EE) |

|

Comment: Also, another example would be they are assuming that the regulation that doesn't |

require monitoring wells on-site unless the water is used for drinking is satisfactory. Clearly it is |

not satisfactory and it will not pick up leaks of contaminated water from buried pipes and tanks, |

for example, and the topography of the land is such that leaks, if they are there from either |

buried pipes or tank or from the waste that has been buried on site and denied, goes into the |

bay. (PNPS-D-Q) |

|

Response: The comments concerning aging management of buried piping at PNPS are |

addressed as part of the NRC's safety review for license renewal. During the safety review for |

license renewal, the NRC determines whether aging effects will be adequately managed. The |

Safety Evaluation Report for PNPS was published on June 28, 2007 and can be accessed in |

ADAMS at Accession No. ML071410438. Safety matters related to aging are outside the scope |

of the environmental review. The comments provide no new and significant information: |

therefore, no changes have been made to the SEIS in response to these comments. |

|

Need for Power |

|

Comment: Page 1-8, Lines 10-11 - The number of homes serviced by electricity from PNPS is |

grossly understated. Rather than 13,000 homes, previous estimates by the electrical system |

transmission and distribution operator (NSTAR) identified the number to be about 550,000 |

homes. (PNPS-D-MM) |

|

Response: The comment is noted and Section 1.3 of the SEIS has been revised to reflect this |

comment. |

|

Comment: Blackouts aren't simply an inconvenience or a temporary loss of business, |

blackouts cause death because people who are already frail and infirm can't get heat or cooling |

they need to sustain life. High prices are a danger too as they cause folks to curtail electricity |

use and again result in real life safety concerns and possible harm. Over the past several |

months, there have been a few proposals for new power plants but most are small, still the |

largest proposal, Cape Wind, faces significant opposition and the smaller units have not even |

begun the very long siting process. As such, it becomes even more vital that we maintain our |

current supply, including Pilgrim. (PNPS-D-E, PNPS-D-P) |

|

Comment: Mass AREA and its members are also comforted in the knowledge that Pilgrim's |

owners work diligently with state and local emergency officials, some of their programs include |

giving the local communities radio equipment so that they all operate on the same frequency |

and conducting extensive training sessions to make sure everyone is prepared in the event of |
Appendix A

NUREG-1437, Supplement 29 A-196 July 2007

| an emergency, be in plant-specific or a natural occurrence such as a hurricane or a blizzard.

| The real danger is a scenario that Massachusetts will face if the state does not have enough

| affordable and reliable electricity. (PNPS-D-E, PNPS-D-P)

|

| Comment: Number six, there is no free lunch to fill our national and regional energy needs.

| I've been involved with these alternative energy things that came up and all through the last 30

| years, massive federal funding of alternative energy, coal gasification, shale oil retorting, solar

| energy, wind power or fuel cells have not brought significant power to our electrical grid in over

| 30 years of technological effort. 

|

| Opposition to oil production off-shore and on federal lands with no added refining capacity since

| the mid '70s has left us dependent on insecure foreign sources, and I feel that as much as

| anybody, I was designing refineries back in the '70s and there were no more to design. Failure

| to extend Entergy's operating license leaves the town with problems, if not the responsibility of

| removal of a derelict plant and related transmission lines and equipment.

|

| Questions regarding spent fuel, security and the impact of revenue lost from jobs and support

| revenue disappearing and disposition of the plant's acreage to new uses, condos.

|

| Much of the foregoing is based upon my career-long experience with a multitude of

| technologically advanced industrial plants worldwide of the size, complexity and age at least as

| great as the Pilgrim station. (PNPS-D-L)

|

| Comment: And when you take a look at the new economy here in the Commonwealth of

| Massachusetts, biotechnology, health care, computer technology, developers, all require vast

| amounts of energy to supply the laboratories and the life saving medical equipment, clean

| rooms and data centers. Obviously working families here in this Commonwealth need these

| industries in this new economy to thrive. Massachusetts has gone through a tremendous

| transition in the last ten years from a manufacturing-based economy to this sort of new age

| economy, if you will. (PNPS-D-N)

|

| Comment: We need the energy produced at Pilgrim for our necessities and for those new

| technologies that become staples to our way of life. (PNPS-D-N)

|

| Comment: We need nuclear power here in the Commonwealth, we need Pilgrim for three

| reasons pretty simple to me, as a representative of 400,000 working families in the

| commonwealth. The three reasons are jobs, jobs and jobs. We are talking about losing 700

| good jobs here at the station, including 400 union workers, and I will say about the 400 union

| workers that they are highly trained, highly skilled, incredibly experienced professionals that are

| hard to replicate in this economy and we don't want to lose these good jobs.

|

| These workers keep Pilgrim Nuclear Power Station safe, and productive and to not renew this

| license would be to displace them and that would jeopardize our energy supply, hurt our local

| economy and devastate their families. There is an obviously economic impact, $135 million in 
Appendix A

July 2007 A-197 NUREG-1437, Supplement 29

annual economic activity. A very significant fact is that the Pilgrim plant purchases services |

from more than 75 Massachusetts companies, so you can see that the spread of that economic |

impact is dramatic here. (PNPS-D-N) |

|

Comment: Now it was spoken earlier about the energy situation, especially here in the |

Northeast, and I can tell you that we are, we are very close to being in crisis here in the |

Northeast when it comes to power. With the growth in demand of electricity and the lack of |

generation, I think it would be not only a disservice to the workers and the community that |

would be hurt by this closing or non-renewal but it's a disservice as well to the energy grid and |

the fact that getting alternative energy sources like wind power. I mean if we are having trouble |

with wind power and new alternative sources, we cannot discard a source and a resource like |

Pilgrim Nuclear Power Station. (PNPS-D-O) |

|

Comment: A number of businesses in Massachusetts, as we know and have enjoyed, have |

been engaged in research and development. We also have to think about the simple things, |

such as how do our supermarkets keep our food from spoiling as far as freezers are |

concerned, which run 24 hours a day, all of us enjoy going to the ATM, getting money out 24 |

hours a day, these things have to be run on electricity. We do have a number of hospitals that |

were in contact, they have inordinately high electric bills and most of them are operating, as we |

know, 24/7. (PNPS-D-V) |

|

Comment: And I think we need to deal with the realization in fact of what are we going to do in |

2012 when we have rolling brownouts, when we have them adversely effect hospitals, nursing |

homes, dialysis centers, and places where we buy our food and live our lives? We continue to |

slip because our costs for housing, health care and energy are not being replenished, we have |

to look at our situation realistically. Over 100 years ago, we all dammed up our rivers and that |

was a pretty big economic and environmental impact because we needed to create power to |

create jobs to run our mills, our manufacturing plants, and that's a problem that hasn't really |

hurt us either. (PNPS-D-V) |

|

Comment: I own a company that manages approximately $250 million worth of real estate, my |

concerns, as far as the environment are concerned, is whether or not we are going to be able to |

replace the production, the electrical production, that comes if Plymouth is allowed to go |

off-line. (PNPS-D-V) |

|

Comment: And my greatest concern is that we in the United States continue to slide in |

comparison to other countries. We are looking at and we know from the Wall Street Journal |

that the Chinese are building 80 nuclear power plants, the French are building 20. I would |

rather have my future depend on the United States Nuclear Regulatory Commission than |

thinking about the Republic of Korea or thinking about a third world country developing nuclear |

power. (PNPS-D-V) |

|

Response: The need for power is outside the scope of license renewal pursuant to 10 CFR |

51.95(c)(2). The purpose and need for the proposed action (renewal of an operating license) is |

to provide an option that allows for power generation capability beyond the term of the current |

nuclear power plant operating license to meet future system generating needs, as such needs |
Appendix A

NUREG-1437, Supplement 29 A-198 July 2007

| may be determined by State, utility, and where authorized, Federal (other than NRC) decision

| makers. Since the need for energy is outside the scope of the environmental review, no

| changes have been made to the SEIS.

|

| Energy Costs

|

| Comment: The mining, refining, preparing fuel rods, transporting, set-up, monitoring,

| regulating, storing , etc. are, actually, prohibitingly expensive, and has been supported by

| government funds from the very beginning. Nuclear power is NOT cheap. (PNPS-D-AA)

|

| Comment: From an economic standpoint, since the owners of the plant sell their power

| through long-term contracts and not on the volatile short-term market, the power produced at

| Pilgrim is much lower cost than the regional average. Massachusetts ranks fourth in the nation

| in terms of highest electricity costs, couple that with our high housing and health care costs and

| it becomes even more important to maintain Pilgrim's very reliable, low cost electricity so that

| we don't continue to have an exodus of residents and businesses from our state who can no

| longer afford to live or work here. (PNPS-D-E, PNPS-D-P)

|

| Comment: We think it's essential to put our comments into the proper context. As an earlier

| speaker indicated, Massachusetts has very high electricity costs affecting every consumer,

| residential, commercial and industrial. Electricity has historically been driven, most recently, by

| the shift to generation by natural gas fuels which are costly and which have some concern

| about continued supply. Pilgrim Nuclear Power Station is a very important balance for these

| high costs and for the lack of fuel diversity in our state. (PNPS-D-F)

|

| Comment: The plant produces a significant portion of our area power requirements that would

| otherwise need to be imported at far greater cost and environmental impact by fossil fuel-fired

| and generating plants burning scarce and costly natural gas or coal and oil with their negative

| environmental impacts or importing scarce and expensive Canadian hydro power. (PNPS-D-L)

|

| Comment: We obviously need this power, it's reliable, it's safe, it's low cost. We need the

| Pilgrim Nuclear Power Station. We frequently hear in Massachusetts that we are losing

| population, we are losing jobs, especially young people, to other parts of the country where

| work is more plentiful and cost of living is lower. The consequences of loss of the people and

| loss of jobs means the rest of us need to pick up a higher proportion of those costs here in the

| commonwealth. 

|

| And one of the big costs, one of the big cost drivers in the Commonwealth for families obviously

| is higher energy cost and one way to stem the tide, if you will, is to keep Pilgrim open and in

| operation. Pilgrim provides some of the lowest cost and most reliable power available on our

| grid and another price contributor is the demand for electricity in Massachusetts is growing, but

| new supplies are not. If you are in some of our urban areas, there is a tremendous amount of

| growth taking place, some major buildings being constructed across this commonwealth. 

| (PNPS-D-N)

|

|
Appendix A

July 2007 A-199 NUREG-1437, Supplement 29

Comment: One of my concerns is that Massachusetts is continuing to slip as an economic |

powerhouse, our young people are attracted to other areas. We do know that they are leaving |

because there are lower costs for housing, for health care and for energy costs. Businesses, |

such as mine and others, small and large, remain adversely affected by their monthly electric |

bills. As a number of you are aware, we had deregulation in Massachusetts approximately six |

years ago and our firm has, for example, already taken advantage of every energy efficient |

program and product available for properties that we manage such as dialysis centers, women's |

health centers, breast care facilities, sewerage treatment plants and other residential properties |

that we manage. (PNPS-D-V) |

|

Comment: All of us on the South Shore have enjoyed our way of life and I think we have to |

look at that as actually a result of cheap energy. Deregulation happened for business in 2000. |

In 2006, I've looked at my energy bills, as a businessman, and I'm sorry to say that I've |

watched, as I pay my bill to National Grid, that my kilowatt per hour cost has gone from 6 to 7 |

cents per kilowatt hour, to 2006, it's gone as high as 12 cents per kilowatt hour and, looking at |

the month of January, it's gone from 12 cents per kilowatt hour to 13.82 cents per kilowatt hour, |

that's a 17 percent increase this month. (PNPS-D-V) |

|

Comment: Now none of us probably should be alarmed, but what are we going to do when |

Pilgrim is off-line? As we have heard and as we know, we have had problems approving the |

wind energy program in the, off the coast and I look at Pilgrim as a plant that actually produces |

electricity at a lower kilowatt hour cost to us than a number of other alternatives. We cannot |

even approve a wind energy program when the Dutch have been using it for 800 years, we |

really have a problem and the problem is that we need to get beyond ourselves and we have to |

look at a situation where we have a reasonable cost of producing electricity and we have to be |

honest. (PNPS-D-V) |

|

Response: The comments are noted. The economic costs and benefits of renewing an |

operating license are specifically directed to be outside the scope of license renewal in 10 CFR |

51.95(c)(2). Since the cost of energy is outside the scope of the environmental review, no |

changes have been made to the SEIS. |

|

Miscellaneous Out of Scope |

|

Comment: How many accidents have been hidden from us as members of the stake holder |

community? For instance, I've heard rumors/reports here in the community surrounding Indian |

Point that a huge gaping hole was cut into the fuel pool at Indian Point 2, and that said gash |

leaked over 1,000 gallons of water into the ground on a daily basis for over a year while |

management argued with Under Water Welding on how to handle the problem...true...I am not |

sure, but I have reason to believe the source was/is legitimate enough to raise the issue. |

(PNPS-D-A) |

|

Comment: The NRC, USEPA and other agencies of both state and federal government have |

wrongfully narrowed the scope of environmental issues with Indian Point, and have steadfastly |

refused to consider the cumulative effects of the known environmental problems on both human |

health, and the environment. Further, they have refused to do a qualitative on the cumulative |
Appendix A

NUREG-1437, Supplement 29 A-200 July 2007

| effects of dumping almost one trillion gallons of 100 degree irradiated waster waters back into

| the Hudson on a yearly basis, or too consider the cumulative effects nationwide of over 100

| trillion gallons of heated water being dumped into our water ways. (PNPS-D-A)

|

| Response: On September 20, 2005, the NRC initiated a special inspection into leakage from

| the spent fuel pool area at the Indian Point 2 nuclear power plant. The leakage, discovered in

| early September, was minimal and does not pose any immediate health or safety concerns for

| members of the public or plant workers. 

|

| The NRC Web page, http://www.nrc.gov/reactors/plant-specific-items/indian-point-issues.html,

| provides information to the public on the status of the leak and the NRC's response. This

| comment is outside the scope of the environmental review; therefore, no changes have been

| made to the SEIS.

|

| Comment: Deliberate mis-statements/mis-representations by the NRC and other industry

| affiliations: The NRC has not learned the lessons of Three Mile Island accident - where NRC

| staff knew of leak rate problems for weeks prior to the accident - yet failed to shut down the

| reactor for repairs. The NRC continues with its obfuscations all over the country with similar,

| serious reactor plant problems (Davis-Besse, etc.). At Three Mile Island we are still waiting for

| former President Jimmy Carter to reveal what he has covered-up: The President's Report a/k/a

| the Kemeny Commission Report, .."suppressed the most alarming aspects of that report." ...the

| report, if published in its entirety, would have destroyed the civilian nuclear power industry..."

| See Attachment 1 and 8. Based on this statement alone - you, the NRC, should not relicense

| Pilgrim. We, the people, do not trust the NRC to protect U.S. You lie and believe your own lies.

| You are destroying the industry because of profits before people. At Three Mile Island country

| we have the highest thyroid cancer rate in the country and the only cause is the Three Mile

| Island fallout of 1979. We received Bomb Test Fallout Equivalent doses at TMI and the U.S.

| Government-Ivory Purpose Knows It! (PNPS-D-PP)

|

| Comment: What about Three Mile Island ? It took eleven years to clean up the site and the

| reactor building is still intensely radioactive. (PNPS-D-AA)

|

| Response: Three Mile Island, Unit 2 (TMI-2) operating license was issued on February 8,

| 1978, and commercial operation was declared on December 30, 1978. On March 28, 1979, the

| unit experienced an accident which resulted in severe damage to the reactor core. TMI-2 has

| been in a non-operating status since that time. The licensee has conducted a substantial

| program to defuel the reactor vessel and decontaminate the facility. All spent fuel has been

| removed except for some debris in the nuclear steam supply system. The plant defueling was

| completed in April 1990. TMI-2 has been defueled and decontaminated to the extent the plant

| is in a safe, inherently stable condition suitable for long-term management. This long-term

| management condition is termed post-defueling monitored storage, which was approved in

| 1993. This comment provides no new information, and therefore, no changes have been made

| to the SEIS.

|

|
Appendix A

July 2007 A-201 NUREG-1437, Supplement 29

Comment: Everyone knows about Chernobyl ..."it" happened almost 20 years ago. The |

cement used to cover over the meltdown hole is settling, cracking, disintegrating. Millions of |

people "downwind" throughout Europe have suffered all kinds of medical problems since then. |

What does the future hold? (PNPS-D-AA) |

|

Response: With respect to a Chernobyl-type accident at a U.S. nuclear power plant, U.S. |

reactors have different plant designs, larger shutdown margins, robust containment structures, |

and operational controls to protect them against the combination of errors that led to the |

accident at Chernobyl. Although the NRC has always acknowledged the possibility of major |

accidents, its regulatory requirements provide adequate protection, subject to continuing |

vigilance, including review of new information that may suggest weaknesses. Assessments in |

light of Chernobyl have indicated that the causes of the accident have been adequately dealt |

with in the design of U.S. commercial reactors. The comment does not provide any new or |

significant information. Therefore, no changes have been made to the SEIS. |

|

A.3 Public Meeting Transcript Excerpts |

|

Transcripts of the Afternoon Public Meeting on January 24, 2007, in Plymouth, |

Massachusetts |

|

[Introduction by Mr. Cameron] |

[Presentation by Ms. Williamson] |

[Presentation by Ms. Hurley] |

|

MS. CINGOLANI: Good afternoon. I'm just a local yokel and I don't have much to say except |

that I feel, in the long run, fission-based power is not the answer and I personally do not want to |

see nuclear power plants' lives extended any more than they have to be. The fusion power |

plants, such as is being built in Europe, probably is a better answer in the long run, but it's |

going to cost billions of dollars. Meanwhile, over in China, there is a country that's already on |

the New York Stock Exchange and they are getting into cheaply making silicon-type -- I don't |

have my notes with me -- voltaic cells and so forth. And if China really gets into this, they'll be |

making all the materials they need, all the electricity they can get, they've got over a billion |

people over there. |

|

Meanwhile, in California, there is many, many companies, one that comes to my mind is Pyron, |

which is connected with Boeing Spectrolab, and they have made and designed an array of |

glass, magnifying glass, small cubic-type things, I can't explain it, and a 25-foot diameter array |

which focuses the sun's energy onto voltaic-type generators. And it seems to me that, in the |

long run, the world has to turn to materials and processes that do not involve radioactive |

materials which are dangerous, no matter what you say about how they decompose and blah, |

blah, blah. This stuff has to be stored, it has to be transported. |

|

Anyone here already knows enough, much more than I do, and can argue every point I'm trying |

to make. But I feel it's common sense to start the process to truly clean and probably in the |

long run will be cheaper-type energy. The solar array that I just mentioned is 40 percent |

efficient and already solar energy is down to about $2 a kilowatt, if my, I'm not sure if I'm right |
Appendix A

NUREG-1437, Supplement 29 A-202 July 2007

| on that, but it's been cut in half, it was $4, now it's down to $2 and it's heading for a cheaper

| and cheaper base level. 

|

| And I don't have anything more to say, this is all my personal opinion, and I'm not an expert, but

| I have lived across the bay from Pilgrim since it was built, and I fished outside of it and I even

| drove down there one time, drove right in, I probably can't do it now, walked all around and

| nobody stopped me, but this was roughly 20 years ago, and I took pictures and I also have a

| whole album of pictures I took inside Pilgrim of all their machinery and everything as a project

| for a class I was taking at Bridgewater State College. So I've always been interested in Pilgrim,

| but common sense tells me it's time to start phasing out of this type of electrical source.

|

| MR. CAMERON: Thank you very much, Lilias, we appreciate those comments on alternative

| energy sources. 

|

| And let's go to Mary Lampert now from Pilgrim Watch.

|

| MS. LAMPERT: Good afternoon. 

|

| My students in the dark ages always referred to me as a very tough grader and I think the NRC

| will feel the same. I clearly think you are going to be very, very busy until July because the

| conclusion that the impacts are small, excepting for two species of fish, I feel result from two

| parts, one, by ignoring and misinterpreting new and significant information; second, by

| assuming the rules that were largely put in place in the 1970s currently and in the future are

| protected of public health and safety, are being followed to the T by the licensee and the NRC

| is assuring that it is. Anybody who heard of the Davis Bessey plant with a whole in its head, I

| think I don't have to say anymore. 

|

| Before I start my comments, I think there are two points that have to be brought up, in the GEIS

| Section 5 it deals with design-basis and severe accidents with an emphasis on releases

| substantially in excess of permissible limits for normal operations. Nowhere in this section is

| the spent fuel pool excluded nor the reactor core cited as the only risk. Therefore, I will argue

| that you are remiss not to include in the supplement the spent fuel pool under postulated

| accidents. 

|

| Second, another issue near and dear to citizen's hearts is security and terrorism. The 9th

| Circuit Court in California faced the question of whether the NRC needs to consider terrorism in

| licensing decisions under NEPA, they concluded that in fact they did. This is an important

| licensing decision. The industry in California went to appeal to the Supreme Court and the

| Supreme Court decided not to hear it which indicates they gave their blessing to the decision. 

| So these to factors, therefore, that being terrorism, security and the spent fuel pool under

| postulated accidents must be considered if you are going to do an honest job.

|

| And now I'll try to focus my comments on the areas of major concern to citizens which are

| health, postulated accidents, spent fuel, radioactive waste. The NRC draft concluded that there

| was nothing new or significant and the impacts from radiation on health would be small, they

| did this by misinterpreting and ignoring important significant information that pertains
Appendix A

July 2007 A-203 NUREG-1437, Supplement 29

specifically here. Very basically, they ignored new and significant research that shows |

radiation's effects are cumulative and they effect the most vulnerable, the old, the young and |

the sick. By ignoring this, then they went on to ignore and give significance to important facts |

here. |

|

Demographics. By 2032, during the licensing period, the population is expected, one in three, |

to be over 55, it's one in five now, therefore a more vulnerable population will be in this area. |

Second, they ignored the radiation-linked diseases that are in this area. The former founder |

and director of the Mass Cancer Registry has done an analysis, year to year, of cancer |

statistics in the seven communities that are likely to be impacted which was determined from a |

state study on health impact. They have seen, every single year, either statistically significant |

or elevated rates of leukemia, rates of thyroid cancer until this very day, this was ignored. Also |

ignored was the fact of elevations in prostate and multiple myeloma from 1999 to `02. |

Therefore, again, a population that is sensitive. |

|

They also ignored looking further at the Southeastern Massachusetts Health Study. They didn't |

ignore it, they simply misrepresented it, which is quite shameful, I might add. The Southeastern |

Massachusetts Health Study stated, was a study done by the Mass Department of Public |

Health on adult leukemia and found a, concluded a fourfold increase the closer you lived or if |

you worked at the reactor. Then there was a re-review, a second peer review panel, politically |

appointed so that Boston Edison, the then owner, could appoint half the panel and approve the |

half. |

|

However, the draft says that the NRC considered the relevant information in the re-review -- |

they didn't use that word -- and concludes that the peer reviews and even the authors now |

agree that the study does not demonstrate a causal relationship between Pilgrim effluents and |

the potential effect of cancers in the areas around the state. So, I called the principle author of |

the study and I said did you talk to them? He said no, I never talked to them, I stand by this |

study, as did Boston Edison's own peer review panel, hand-picked, that said the results can not |

be discarded because of methodological weaknesses. |

|

And I said, well, what about the Assistant Commissioner, Suzanne Condon? What did she |

say? And I have e-mails to this effect, oh, she said the department stands by these studies, |

this particular study, and they went on further, the association between leukemia and the |

proximity to Pilgrim was unexpectedly strong and this raised biological plausibility of the study, |

the study results could not be dismissed. Then the NRC goes on in the draft to cite various |

studies that supposedly say there is no association between exposure and living and being near |

a reactor. |

|

What they did was cherry-pick studies that were the industry's and government's equivalent of |

the tobacco scientists. What they failed to do is to look at all the recent research that is out |

there, and I would refer you, and I will in writing, to Clark University's Marsh Institute that has |

collected all research that is done on this area. Then they go to the BEIR 7 report and say |

there is nothing really new or significant there to change our determination. The reality is that |

what they didn't say is what the BEIR 7 report had to say on the incidents of cancer being a |

third higher than they previously thought. |
Appendix A

NUREG-1437, Supplement 29 A-204 July 2007

|

| What they didn't say was the BEIR 7, speaking specifically to the greater effect of low dose

| radiation exposure on women and children, over 30 percent higher in woman. What they didn't

| say is the new information on effect on workers, if they receive the maximum allowable dose,

| where NRC had said one out of eight would get cancer, now BEIR 7, one out of four. All these

| things are clearly significant. What they didn't say in the draft was the BEIR 7 talked about

| health effects other than cancer that can be expected from low dose radiation exposure such as

| heart disease and stroke.

|

| And what they didn't say when they were talking about health effects in the postulated accidents

| section of the new and significant information presented by the Massachusetts Attorney

| General of the likely health consequences of a spent fuel pool accident at Pilgrim, yes, 24,000

| cancers expected if there is a complete release of just Cesium 137, 8,000 if only ten percent of

| that bad guy is released. 

|

| What they didn't say under postulated accidents was a reference to the Sandia National Report,

| the CRAC II which in 1982 NRC asked them to do for the consequences specifically of a core

| melt at each reactor and what that study said was that you could expect 3,000 early injuries --

| no, what was it? No, 3,000 fatalities and 30,000 early injuries, that was `82.

|

| But what they didn't look at was Dr. Edwin Lymon, a Union of Concerned Scientists report done

| on why these figures have to be updated, why they are conservative, new information of why

| this is pertinent now. And so by ignoring or misinterpreting these important factors, they fail

| then to look at significant mitigation that could occur and they ignore the fact that, guess what?

| I don't know how much radiation is coming out of there, Entergy doesn't know and the NRC

| doesn't know, and so an important mitigation step going forward, if you are honest about health

| effects, is to have a requirement or look at to analyze.

|

| I mean that's what you are supposed to be doing, having combination real-time wind and

| radiation detectors placed in logical areas in off-site communities that provide real-time data on

| this to the state, and to the local communities and to the NRC. Hey, they should know too. 

| This was recommended back in 1990, we are talking about the future until 2032, so you can

| play your games and not analyze the real, the new and significant information that is out there,

| take your cherry-picked, tobacco science equivalent studies and continue pretending, and also

| looking at acceptable dose to a mythical, mythical 30 year old healthy guy and not the effect

| that it should be on those who are most sensitive, which BEIR 7 points out are the young, the

| old and the sick. I think that's what I have to say about health. 

|

| Now, do I have time for my other subjects?

|

| MR. CAMERON: Mary, let's go on to other people, if that's--

|

| MS. LAMPERT: Okay.

|

| MR. CAMERON: --fifteen and--
Appendix A

July 2007 A-205 NUREG-1437, Supplement 29

|

MS. LAMPERT: Because I would like to talk about waste and postulated accidents but, thank |

you, I appreciate the position you are in and you are always very courteous and fair to people. |

|

MR. CAMERON: Thank you, Mary, we'll see if we can get back to you. |

|

There is other issues and would you make sure --. You mentioned the Massachusetts Cancer |

Registry and just make sure that the staff has access to a Web site or how to get that |

information. I don't know, they may already know about it, but I just want to make sure that |

they have that in your written comments. And I don't want to get into a discussion of BEIR 7 but |

I noted when Bobbie mentioned it and you mentioned it now that it's not going to be evident to |

people, all people, what exactly BEIR 7 is. And I just want to ask Bobbie to just tell us not about |

the study but what does BEIR stand for and who is that? Oh, Alicia? Okay, beautiful. |

|

MS. WILLIAMSON: Basically, BEIR stands for Biological Effects of Ionizing Radiation, it's a |

study that's conducted by the National Academy of Sciences. It's published, if I'm not mistaken, |

about every three years. Is that correct, Rich? He is our senior health physicist, he is the |

expert on that, but that's correct, Rich? About every three years they publish that? |

|

I might turn it over. |

|

MR. CAMERON: And, Rich, without, if you could just tell us why this is BEIR 7? In other |

words, just who is doing this and why are they doing it, I guess, so people understand. |

|

MR. EMCH: It's called BEIR 7 because there have been seven reports, the first one was BEIR |

1 back in, I don't even remember the exact date, probably somewhere around 1972. The BEIR |

reports that talk about ionizing radiation, which is what we are talking about here, the entire title |

of this BEIR 7 report is "Health Risks from Exposure to Low Levels of Ionizing Radiation, BEIR |

7, Phase II", and each of the, the 1, the 3, the 5 and the 7 all talked about similar issues and |

they've been published at various intervals, probably not three years, since the first one was in |

the mid `70s. They have been published at very intervals over the years and the draft of this |

one came out in 2005 and the final version came out in 2006. |

|

MR. CAMERON: Okay, thank you very much. |

|

And as we heard, the draft supplemental environmental impact statement looks at BEIR 7, and |

you have heard Mary Lampert talk about the study and when Mary and others submit their |

comments, written comments that will be available to people, they'll be discussing BEIR 7 too, |

so just so you know what that acronym is. And let's go to Joyce, this is Joyce McMahon and |

she is from Mass AREA, and then we are going to go to Bob Ruddock, Rebecca Chin and John |

Stobierski. |

|

MS. MCMAHON: Good afternoon. My name is Joyce McMahon and I am the Communications |

Director for the Massachusetts Affordable Reliable Electric Alliance, Mass AREA for short. |

|
Appendix A

NUREG-1437, Supplement 29 A-206 July 2007

| First, let me thank you for taking this opportunity to address the commission, we do appreciate

| your time. Second, I would like to tell you a little bit about Mass AREA and why we felt it was

| important to be here. Mass AREA is a diverse, state-wide group comprised of more than 65

| labor, trade associations, businesses and, with fill disclosure, including Entergy, educators,

| scientists, advocates and community leaders.

|

| During today's sessions, you'll hear from some other Mass AREA members, including the South

| Shore Chamber of Commerce, the Massachusetts AFL-CIO and the Associated Industries of

| Massachusetts. As a group, we are committed to finding clean, low cost and reliable electricity

| solutions that benefit all of Massachusetts, it is an urgent public policy challenge. We came

| together one year ago after several warnings were issued by the Federal Energy Regulatory

| Commission, ISO New England and others that energy supplies will be insufficient to meet peak

| demand as early as 2008 and that energy prices are causing hardship for the region's

| businesses and residents, especially the most vulnerable populations such as the elderly and

| low income.

|

| While Mass AREA's mission is brought in focus to include new electric generation in the form of

| renewable energy resources, improving the transmission infrastructure, developing new natural

| gas supplies and encouraging energy efficiency, Mass AREA and its members fully support a

| license extension for the Pilgrim Nuclear Power Plant. On a typical day, Pilgrim provides seven

| to nine percent of the Commonwealth's electricity. Without it, Massachusetts and the region as

| a whole could face power supply shortages, including rolling blackouts, a lot sooner than

| predicted of next year.

|

| Perhaps one of the most important issues that led Mass AREA to support a license extension

| for Pilgrim is the fact that the plant operates safely and continuously earns the NRC's highest

| safety rating of green. We also know that NRC staffers are on-site at the plant each and every

| day overseeing operations and helping to maintain a safe and secure environment. 

|

| The production and distribution of electricity, whatever the source, is inherently a challenging

| safety issues, yet nuclear power has proven safe. In 50 years of commercial operations, there

| has never been a radiological death at any U.S. nuclear plant.

|

| Mass AREA and its members are also comforted in the knowledge that Pilgrim's owners work

| diligently with state and local emergency officials, some of their programs include giving the

| local communities radio equipment so that they all operate on the same frequency and

| conducting extensive training sessions to make sure everyone is prepared in the event of an

| emergency, be in plant-specific or a natural occurrence such as a hurricane or a blizzard. The

| real danger is a scenario that Massachusetts will face if the state does not have enough

| affordable and reliable electricity.

|

| Blackouts aren't simply an inconvenience or a temporary loss of business, blackouts cause

| death because people who are already frail and infirm can't get heat or cooling they need to

| sustain life. High prices are a danger too as they cause folks to curtail electricity use and again

| result in real life safety concerns and possible harm. Over the past several months, there have
Appendix A

July 2007 A-207 NUREG-1437, Supplement 29

been a few proposals for new power plants but most are small, still the largest proposal, Cape |

Wind, faces significant opposition and the smaller units have not even begun the very long |

siting process. As such, it becomes even more vital that we maintain our current supply, |

including Pilgrim. |

|

Opponents of the Pilgrim Power Plant often say we will be better off if the generator was |

decommissioned. However, the baseload power that would replace Pilgrim would most likely |

come from sources that are more expensive, far more polluting or both. At this time, wind and |

other renewable energy technologies simply can not generate the massive baseload power that |

would be needed were Pilgrim to cease operations. Moreover, the electricity that Pilgrim |

supplies is created without generating any greenhouse gas emissions and therefore it does not |

contribute to global warming. |

Pilgrim also mitigates the production of hundreds of tons of sulfur dioxide and nitrogen oxides, |

chemicals which are harmful to human health, especially among children and the elderly, these |

health and environmental benefits alone are enough argument for renewing Pilgrim's license to |

produce power. |

|

From an economic standpoint, since the owners of the plant sell their power through long-term |

contracts and not on the volatile short-term market, the power produced at Pilgrim is much |

lower cost than the regional average. Massachusetts ranks fourth in the nation in terms of |

highest electricity costs, couple that with our high housing and health care costs and it becomes |

even more important to maintain Pilgrim's very reliable, low cost electricity so that we don't |

continue to have an exodus of residents and businesses from our state who can no longer |

afford to live or work here. |

|

Speaking of work, Pilgrim is also an important source of jobs, it has more than 700 permanent |

full-time employees, most of whom live in Plymouth and the surrounding communities, indeed |

Pilgrim supports the local economy to the tune of $135 million in local economic activity. |

Though the draft environmental impact statement noted a moderate socio economic impact |

should the plant cease operations, we believe those who would lose their jobs would face a |

large economic and financial loss. |

|

In summary, Mass AREA has weighed all of the environmental, economic and energy supply |

traits of Pilgrim, particularly its long record of safety, and concluded that the Pilgrim Nuclear |

Power Plant is vital to the region, state and local economy for three reasons, its environmentally |

sound operations, its economic contribution to the local community through the provision of jobs |

and purchase of goods and services and its provision of reliable, low cost electricity. Mass |

AREA encourages the NRC to grant Entergy's Pilgrim station an extension of its license so that |

it can continue to safely operate for an additional 20 years. |

|

Further, we urge the Atomic Safety and Licensing Board to consider the Pilgrim related matters |

before it as quickly and expediently as possible while the license renewal process takes its |

natural pace. Again, thank you for the opportunity to speak with you today. |

|

|
Appendix A

NUREG-1437, Supplement 29 A-208 July 2007

| MR. CAMERON: Thank you, Joyce. 

|

| Next we have Bob Ruddock. And while he is, just let me note that Alicia pointed out that there

| is a commission paper, which is a staff report to the Nuclear Regulatory Commission, back on

| the tables that address this BEIR 7 issue in more detail, for anybody who wants some more

| information on it. 

|

| MR. RUDDOCK: Good afternoon. My name is Robert Ruddock and I am the General Counsel

| for Associated Industries of Massachusetts. On behalf of AIM, I want to thank the Nuclear

| Regulatory Commission for the opportunity to present our views here this afternoon, for

| conducting this meeting and for the opportunity to provide these comments. 

|

| AIM is a statewide association of employers, more than 7,000 of them are our members, they

| employ roughly 680,000 employees across the commonwealth. The organization's goal is to

| effect public policy to create a positive economic climate for our businesses and for jobs in the

| State of Massachusetts.

|

| We think it's essential to put our comments into the proper context. As an earlier speaker

| indicated, Massachusetts has very high electricity costs affecting every consumer, residential,

| commercial and industrial. Electricity has historically been driven, most recently, by the shift to

| generation by natural gas fuels which are costly and which have some concern about continued

| supply. Pilgrim Nuclear Power Station is a very important balance for these high costs and for

| the lack of fuel diversity in our state.

|

| In addition, the critical role Pilgrim plays in supply and diversity, its role in producing electricity

| without air pollutants and laudatory, no pollution contributes to the state's goal of reducing

| greenhouse gas emissions. Achieving these goals will have some cost impacts on all

| consumers, but it's great to know that Pilgrim station provides economical electricity without a

| carbon footprint. Pilgrim also contributes to meeting and sustaining the electricity supply, as

| our demand grows on average of about two percent a year compounded.

|

| With that as context, AIM believes that the draft environmental impact statement adequately

| complies with the requirements of the act, AIM urges the commission to adopt the

| recommendation of the report to continue consideration of relicensing. Given Pilgrim's positive

| contributions to the reliability, supply and cost of electricity in this state and its significant

| environmental benefit, we also would urge the commission to in fact relicense this plant. 

|

| Thank you again for your attention.

|

| MR. CAMERON: Thank you very much, Bob. 

|

| Next we are going to go to Rebecca. Rebecca Chin is with the Duxbury Nuclear Advisory

| Committee.

|

|
Appendix A

July 2007 A-209 NUREG-1437, Supplement 29

MS. CHIN: Thank you. I'm also a former Chairman of the Duxbury Board of Health, so I would |

like to keep that in context with my first set of comments. |

|

The NRC DSEIS concludes that the health impact is and will continue to be small by |

mischaracterizing the Southeastern Massachusetts Health Study. The DSEIS states that the |

authors of the Southeastern Massachusetts Health Study have stated that the study shows both |

a statistical association and a cause and effect relationship between leukemia incidents around |

the nuclear power plant and exposure to effluents from the plant. |

|

The final report released to the public in October of 1990 found a two to fourfold increase of |

leukemia among residents of certain towns within a 20 mile radius of the plant, the draft goes |

on to cite peer reviews from a second rereview peer group that did not support the causal |

relationship. However, the peer review panel referred to in the draft was appointed by Boston |

Edison's request, the owner of Pilgrim at the time, and contrary to accepted scientific practice, |

half of the rereview panel members were appointed by MDPD and the other half by Boston |

Edison, the company directly impacted and implicated by the study's findings. |

|

In the executive summary of its report though, the second peer review panel concluded that the |

findings can not be readily dismissed on a basis of methodological errors or proven biases, the |

association found between leukemia and the proximity to the Pilgrim nuclear facility was |

unexpectedly strong and this raised concern regarding the biological plausibility of the study. |

However, because the study's results could not be dismissed, further study may be warranted, |

including expanding the case finding and including children. |

|

The study noted that Boston Edison admitted higher than average releases in the early days |

due to poor fuel or damage rods and lack of filtration systems, the study researchers also knew |

that a number of possible points were not monitored and the monitors on even the main stack |

did not measure all types of radiation, that significant radiation had been reported in shellfish, |

milk and vegetation near the plant. The re-review panel member schooled in monitoring was a |

Boston Edison employee who discounted any unmonitored releases and blamed the too high |

radiation levels in milk and vegetation on bomb testing in China. |

|

The panel also claimed that if Pilgrim had released significant levels of radiation, it would have |

been detectable on large numbers of monitors throughout Eastern Massachusetts. However, |

the Boston Edison appointee was questioned on this and he conceded that, in 1970, there |

existed only three monitors, one at Pilgrim, another at MIT Cambridge keeping track of MIT's |

reactor and a third in South Boston keeping tabs on Dupont. These had the same lack of |

sensitivity as Pilgrim's and were too far away to realistically have been expected to detect |

Pilgrim's emissions. |

|

The inescapable conclusion is that, both in the 1970s and now, no one really knows how much |

radiation Pilgrim emitted. The re-review panel effectively admitted as much, suggesting that |

there should be an independent evaluation of the potential radiation exposure from the Pilgrim |

plant and from other sources. The study was even more explicit, it recommended that a system |

of real-time monitoring and radio nucleotide emissions be implemented so that reliable and |
Appendix A

NUREG-1437, Supplement 29 A-210 July 2007

| timely data are available by which exposure can be assessed more precisely.

| The re-review panel's statement in the study's conclusion is contradicted by the fact that the

| death rates for the study have remained close to the state average exemplifies the how to lie

| with statistics problem. The re-review panel looked at death rates for Plymouth County as a

| whole, the Southeastern Mass study found an increased risk in those, to those in a much

| smaller, more concentrated area likely, within the likely to be impacted geographic area. The

| re-review panel's executive summary admitted that there have been other reports of observed

| cancer increases that are inconsistent with predictions based on mathematical modeling and

| radio biology theory.

|

| In 1990, the Southeastern Mass findings was not based on mathematical models or estimates

| of radiation releases, rather it was focused on what really happened to real people. The NRC's

| impact statement ignores the principle Mass Department of Public Health and peer review

| conclusions that the findings can not be dismissed and that further attention to the possible

| risks associated with the power plant may be warranted, including expanding case findings and

| including children.

|

| My second comment is on the DSEIS, that the NRC staff mistakenly concluded that the

| applicant's SAMA analysis was sound, that the faulty SAMA analysis used by Entergy in the

| environmental report caused it to wrongly dismiss mitigation alternatives such as adding a filter

| to the direct torus vent. The purpose of a SAMA review is to ensure that any plant changes that

| have a potential for significantly improving severe accident safety performance are identified

| and addressed, one examples of how a poorly performed SAMA analysis can lead to erroneous

| conclusions is the Pilgrim environmental reports look at the cost and benefits of installing a

| direct torus vent filter at Pilgrim.

|

| The direct torus vent system is a method to relieve high pressure which is generated during an

| accident review, severe accident, excuse me. In 1986 it was determined that the Mark I

| containment, especially being smaller with lower design pressure, in spite of a suppression

| pool, has a 90 percent probability of that containment failing. The purpose of the containment

| is to provide a barrier between the lethal radiation inside the reactor and the public. In order to

| protect the Mark I containment from total rupture, it was determined necessary to vent high

| pressure build-up. As a result, the direct torus vent system to all Mark I reactors, including

| Pilgrim, was installed.

|

| Operated from the control room, the vent is a reinforced pipe installed in the torus and designed

| to release radioactive high pressure steam generated in a severe accident by allowing the

| unfiltered releases directly to the atmosphere through a 300-foot vent stack. Use of the vent

| discharges steam and radioactive material directly into the atmosphere, bypassing the standby

| gas treatment system filters normally used to process releases via the containment ventilation

| pathway. There is no radiation monitor on the pipe and valves that compromise the direct torus

| vent line and operators now have the option to direct action to expose the public and the

| environment to unknown amounts of harmful radiation.

|

|
Appendix A

July 2007 A-211 NUREG-1437, Supplement 29

As a result of Pilgrim's design deficiency, the original idea for a passive containment system |

has been dangerously compromised and given over to human control with all its associated |

risks of error and technical failure. There appears to be an internal contradiction in what we are |

being told, the NRC believes that the release from a severe core melt accident would be |

reduced by a factor of 100, this is considerably more optimistic than estimated in the NRC's first |

study on the subject. |

|

As the contention is that the reduction of a filtration system would have zero benefit, here the |

contenders seem to be assuming that a factor of 100 equals 100 percent and that's false, even |

a release of 1 percent of the core's radioactive iodine and cesium would be a very severe event. |

|

In its environmental report, Entergy analyzes the benefits of installing a filter to the torus vent in |

the course of reviewing possible severe accident mitigation alternatives, their report states this |

analysis case was used to evaluate the change in plant risk from installing a filtered |

containment vent to provide fission product scrubbing. A bounding analysis was performed by |

reducing the successful torus venting accident progression source terms by a factor of two to |

reflect the additional filtered capacity and capability. |

|

Reducing the releases from the vent path resulted in no benefit, according to the state report, |

the basis for conclusion that successful torus venting accident progression source terms are |

reduced by a factor of two to reflect the additional filtered capability, the cost of implementing |

SAMA at Peach Bottom was estimated at $3 million. Therefore, this SAMA is not cost effective |

for Pilgrim. Entergy has determined that, in return for a cost of $3 million, there will be no |

benefit to public health or safety. |

|

How is it possible to find zero benefit from installing a filter that would reduce by a factor of two |

the radioactive venting to the public in a case of a severe accident? Unfiltered venting has |

been judged unsafe by all regulatory agencies outside the United States. In its analysis of |

several risk contributors to core damage frequency, the disposition of those events frequently |

included venting via the direct torus vent path to reduce containment pressure. In other words, |

a filter in the torus vent would reduce the impact in many possible severe accidents. |

|

The only conclusion to draw from the outcome of the direct torus vent filter SAMA analysis is |

that Entergy has used the MACCS II code to downplay the health and economic cost of severe |

accidents and use the probablistic safety analysis model to make the benefits of mitigation |

appear to be zero. NRC staff reviewed Entergy's analysis and concluded that the methods |

used to implementation of those methods of sound, the costs of SAMA's evaluation would be |

higher than the associated benefits in 2.2, in 5.2.5. The NRC staff is wrong to accept Entergy's |

SAMA analysis in this application. |

|

The SAMA analysis included in the Pilgrim environmental report is incomplete, not only does |

the probablistic modeling for severe accidents artificially make consequences appear |

insignificant but the application has used incomplete and incorrect input parameters to the |

MACCS II code. The direct or torus vent filter is an example of how this cost/benefit equation |

might have been skewed in favor of no mitigation. While the NEPA does not require agencies |
Appendix A

NUREG-1437, Supplement 29 A-212 July 2007

| to select particular options, it is intended to foster both informed decision making and inform

| public participation and thus to ensure the agency does not act upon incomplete information

| only to regret its decision later, after it's too late to correct. It then said if further analysis is

| called for, that in itself is valid and meaningful remedy under NEPA. 

| The applicant has drastically undercounted the cost of severe accident and this could have led

| it to erroneously reject mitigation alternatives, further analysis is called for. The EPA has

| acceptable standards for exposure, in the real world there is no safe level of exposure to

| radiation. 

|

| In conclusion, the danger of NRC rubber stamping the Entergy's SAMA in the DSEIS, accepting

| the licensee's minimization of consequences that make the cost of adding a filter to the direct

| torus vent seem unnecessarily high or not cost effective when it is obvious that the mitigation of

| installing the filter could indeed serve to protect the public health and safety, I repeat unfiltered

| venting has been judged unsafe by all regulatory agencies outside of the United States.

|

| MR. CAMERON: Thank you. Thank you very much, Becky. 

|

| And we are going to go now to John Stobierski.

|

| MR. STOBIERSKI: Good afternoon. I would like to thank you, Mr. Cameron, Ms. Williamson

| and Ms. Hurley for your presentations and for running a very good, and informative and fast

| paced meeting, I appreciate it. And I appreciate the presence and the diligence of your

| colleagues as well who are working on the relicensing of the Pilgrim Nuclear Power Plant. I will

| try to be brief and not try your patience. 

|

| My name is John Stobierski, I am here representing the South Shore Chamber of Commerce,

| which is an independent association of 2,000 businesses, including health care and educational

| institutions and nonprofit organizations in the communities from Boston to Plymouth, we are the

| largest chamber of commerce in Massachusetts. We are an association of business people

| who are committed to the economic health and the quality of life of the communities that we

| serve. 

|

| A few months ago, we invited members of our leadership to examine the issues surrounding the

| relicensing of Pilgrim Nuclear Power Plant and whether it was an issue that the chamber should

| get involved with, whether we should weigh in. We reviewed the record of the Pilgrim Nuclear

| Power Plant and its 34 years of operation safely as a neighbor of ours, we examined its

| contribution to the economy of this region, the 500 people that it employees directly, the 130

| contract employees who serve at the plant and the economic offshoots of that employment

| base and of the businesses that do business in this region because of the presence of the

| plant.

|

| And they evaluated the plant in terms of our need as a region, as a growing region, one of the

| few growing areas in the Northeast, the need for diverse and reliable and affordable sources of

| energy. The residents and the employers who are here, who may be moving here as this area

| grows, are deciding whether to make a long-term investment in our region and the status of the
Appendix A

July 2007 A-213 NUREG-1437, Supplement 29

Pilgrim station is very important to those decisions. Recently, a dozen and a half of our board |

members and other leaders of the chamber spent some time at the plant, these are folks from |

construction and engineering and manufacturing and environmental sciences. |

And I'm not going to represent to you that they conducted a thorough, top to bottom survey of |

every last square inch of the plant, but this was not some awed troop of Brownie Scouts either, |

these were skeptical business people who have an investment in this region and want to make |

sure that nothing they do or say jeopardizes the safety or the reputation of their employees, |

their neighbors in the area where they are invested. After evaluating the plant and its |

contributions to our region, its economic impact, the employment base, its environmental |

record, the addition, the very critical addition that it makes to a diverse and reliable energy |

supply and the plant's presence and overall contributions to the quality of life in our region, our |

leadership voted, after a healthy discussion, voted and voted unanimously to encourage the |

Nuclear Regulatory Commission to approve in a timely fashion the full relicensing of the nuclear |

power plant. |

|

We are pleased to have this safe, secure, reliable source of power and its significant beneficial |

contributor to the employment base and to the overall economic well being as part of our region |

and we thank you very much. |

|

MR. CAMERON: Thank you very much, John, for those comments. |

|

We are going to go to Malcolm, Mr. McNaught. Is Malcolm McNaught still here? |

|

Okay, Pine duBois? And Pine is from the Jones River Watershed Association. And then we'll |

go to Ben Morgan and then to Heidi Mayo from Pilgrim Watch. |

|

MS. DUBOIS: Thank you, hi. I am from the Jones River Watershed Association, which the |

Jones River is just a few miles north of here and drains as the largest river into Cape Cod Bay, |

and I'm here to just preview, I guess, my comment that I hope to make in writing prior to the |

deadline with some others who are concerned about the aquatic and marine habitat. And |

although I share concerns of many of the other residents regarding the safety and what we |

were just previously talking about, I'm not going to address those now. |

|

As far as the impact analysis, we do continue to be extremely concerned about the fisheries |

that inhabit Cape Cod Bay and in particularly the estuary of the Jones River which are in sever |

decline. We have concerns about the methods and approach and the limitations of the |

approach in the document, although I do admit that I found the document extremely interesting |

and informative reading. However, because the populations of herring, Alewife, Rainbow |

Smelt, Shad, American Eel are all in severe decline in the Jones River and elsewhere on the |

Atlantic Coast region, I believe that even the assessment of moderate impact is inaccurate, and |

that continued impingement and entrainment of these types of species on the Pilgrim intake |

screens is severe. And that even though I understand from the document that the NPDES |

permit will consider modifications to that intake, it's my opinion, and we will comment this way, |

that there should be no relicensing certainly without considerable modification to the intake and |

discharge structure that provides cooling water to the plant. |
Appendix A

NUREG-1437, Supplement 29 A-214 July 2007

|

| I think this is an extremely significant and difficult proposition, I believe it deserves attention that

| should have been given to it a long time ago. I believe that the monitoring that has been done

| since 1972 certainly has made that clear and I'm sorry that the industry has waited until the

| NPDES renewal to begin to address it. 

|

| In addition, I think that there needs to be some consideration given to the facts of global

| warming, I was interested to read in the report that Pilgrim made an attempt to deepen the

| intake channel because they wanted to get the water cooler and that effort failed.

|

| I think, in general, the ocean is getting a little warmer, certainly the bay is getting warmer, and I

| believe that it is in part getting warmer not only because of global influences but because there

| is a continual daily thermal discharge of superheated water from the plant as a result of the

| cooling function. And that the documents do not consider the impact of that general warming

| upon the bay, upon the essential fish habitat and upon the species that live there, and I think

| this was a flaw in the supplement and I believe that it should be corrected in the final, that the

| warming of the bay waters has to be considered.

|

| What was considered was the shock to the species, in terms of the discharge and I believe that

| the report basically says, well, a fish can swim away from superheated water, and while I

| believe that's true, I think if the general warming pattern is there, then we are kind of --. Like us

| in this room, we are sort of all stuck with the environment that we happen to be in at the

| moment and if you can't get out of it, you have to suffer the result. That is what's happening to

| our marine fisheries, and there is a bigger impact than locally to Pilgrim or locally to the Jones

| River, and we have to pay attention to that and we cannot delay that attention any longer,

| anymore than we can delay the attention given to some of the other concerns.

|

| Cape Cod Bay is an ocean sanctuary under Massachusetts state law, that wasn't mentioned in

| the report. It is a violation of state law that anything effect a habitat and I think that that would

| mean that the fish species considerations has to be broadened and it certainly has to include

| such species as shad and as the American Eel, and perhaps even the Sand Tiger Shark which

| again wasn't mentioned in the report but is not only becoming more of a species of special

| concern, it also is becoming more frequent in our waters or it appears to be so.

|

| Part of my problem is that I, like you, didn't grow up an environmentalist, I became one because

| of staring at the river. So, as you look at these things, you see more and then once you see

| more, you start to see less and that becomes a problem. We are starting to see a lot less

| native species and a lot more altered species and this is not good for us in the long run, we are

| also seeing entrained in the system the American Lobster, this is a commercial fishery also and

| that deserves more attention, I believe, than in the report.

|

| I'm concerned about the method of approach in monitoring, I would like to talk to Earth Tech a

| little bit more about this, but I understand that a lot of the monitoring happens post sweeping of

| the screens and I think there is probably an impingement and an entrainment factor that

| happens when we are not looking and that there needs to be --. I at least need more
Appendix A

July 2007 A-215 NUREG-1437, Supplement 29

understanding of that and a complete listing of the 77 species that are impinged and the 66 |

species that are entrained so that I can help evaluate what these impacts are going to be. |

|

On two other subjects, one was there was an assessment of social justice, I believe, and by |

way of that an assessment of our drinking water supplies, and there was a listing of some |

typical water withdrawals, none of them exceeding two million gallons a day, and I do want to |

point out that at the ten mile limit is Silver Lake which supplies ten million gallons a day to the |

Brockton water supply system in the City of Brockton, which is a social justice community, and I |

do not believe there has been monitoring of Silver Lake, although I could be wrong, regarding |

emissions and those kinds of long-term impacts. |

|

And lastly, the alternatives section discussed wind, it dismissed hydro power and although I'm |

not an advocate for damming our rivers and increasing hydropower, I would be curious to see |

an alternatives analysis given to the tidal usage of the Cape Cod Canal. |

|

Thank you. |

|

MR. CAMERON: Great, thank you. Thank you for those comments, Pine. |

|

And we are going to go to Ben Morgan next, Ben? |

|

MR. MORGAN: Good afternoon. I, like the last speaker, am going to be talking about some |

marine species, pretty much on the Winter Flounder is the only one that I'm an expert on or I |

consider myself an expert on. My name is Ben Morgan, I live in Chatham, I used to be a |

fisherman, now I'm currently an owner of a fish hatchery, the fish hatchery is for Winter |

Flounder. Winter Flounder, as previous speakers have talked about, have been deemed a |

moderate, I think I have the right terminology, a moderate impact instead of a small impact, |

meaning that there has been some mortality associated with Pilgrim's activities. |

|

So about eight years ago people from Pilgrim and myself had worked on how to possibly make |

that a small impact, meaning how do you deal with this problem of killing Winter Flounder or |

impinging Winter Flounder? Basically, since eight years ago, we've been taking adult Winter |

Flounder that are natural wild stocks and spawning them. And in that process, we've basically |

reproduced 33 millimeter hatchery fish, which would be the same as a wild fish, and placed it |

out into our harbors very close to us right now, and done studies to see how they survive and if |

it is possible to replenish the stocks by use of hatcheries for mitigation. |

|

And over the past eight years, we have compiled a whole bunch of data, nothing seems to be |

negative, everything seems to be showing that, at a larger scale, you could make this problem |

mitigated by the use of hatcheries, making it a small impact that Entergy has or even a no |

impact with Winter Flounder, I know nothing about the other ones. Basically, I can support that |

idea with the idea that aquaculture of hatcheries have been used for decades with replacing fish |

stocks, this has, we have seen this work with shellfish in Massachusetts and all kinds of other |

fisheries around the world. |

|
Appendix A

NUREG-1437, Supplement 29 A-216 July 2007

| The potential benefit to this being used as a mitigation tool would be to the community, giving

| jobs to the hatchery and also giving more fish for the fishermen to catch. In conclusion, I

| basically believe that Pilgrim could have no impact on the Winter Flounder population, in my

| mind, by use of hatcheries and that the benefits could really be to the communities, to the

| fishermen and also for jobs. I think that if we, if the number of hatchery released fish was

| increased, that they wouldn't have a problem to augment any potential problem associated with

| Winter Flounder. 

|

| Thank you, have a good day.

|

| MR. CAMERON: Thank you, Ben. 

|

| We are going to go to Heidi, Heidi Mayo, and then to Arthur Gast. Heidi?

|

| MS. MAYO: I would like to address the issue of Pilgrim's impact on public health, I think the

| commission has a responsibility to look at site-specific information on this issue. Thyroid

| cancer and thyroid disease are clearly radiation-linked, radioactive iodine released from

| reactors is drawn into the thyroid, often resulting in cancer and thyroid disease. Examples of

| widespread increases in thyroid cancer has occurred in the communities around Chernobyl, and

| Marshall Islands and Hanford, another example of this type of increase occurred right here near

| Pilgrim.

|

| As a result of radiation releases in the early and mid `70s and some really big ones in June of

| 1982, cases of thyroid cancer and leukemia in the surrounding area were significantly elevated. 

| Recognizing the effect of Iodine 131 on the thyroid, the NRC has implemented the Potassium

| Iodide Program. I have a box in my cellar for my family but I don't need it, since they weren't

| offering back in 1982 and now I don't have a thyroid anymore. So the draft statement that there

| have been no health effects here is very incorrect. 

|

| In his report to the Southeastern Massachusetts Health Study Review Committee in 1992, Dr.

| Richard Clapp, former director of the Massachusetts Cancer Registry, presented a graphical

| assessment showing elevated cases of leukemia and thyroid cancer in the towns closest to

| Pilgrim during the period of `82 to `89, a second graph depicted the pattern of thyroid cancer in

| the same set of towns, it shows a peak in the years 1987 and 1988, the year I was diagnosed. 

| These patterns of cancer incidents are consistent with the predicted health effects of the

| radiation released in the early 1980s.

|

| Additionally, the Massachusetts Cancer Registry for the years 1998 through 2002 shows a

| continuing increase of leukemia and thyroid cancer around here. No one knows exactly how

| much radioactive iodine has been and is being released from Pilgrim because there is not

| adequate monitoring or reporting, we don't know, I mean we do know that large releases were

| measured in the `70s and `80s but today no one knows what's coming out of the plant. If this

| plant is relicensed as is, we will never know, the least we should have is adequate real-time

| monitoring and reporting displayed in all communities as part of the public record. 

|
Appendix A

July 2007 A-217 NUREG-1437, Supplement 29

Since the NRC recognizes the dangers of Iodine 131 to our health and Pilgrim has indeed had |

a negative impact on public health, this case should require a site-specific review as part of the |

renewal process. |

|

Thanks. |

|

MR. CAMERON: Thank you, Heidi. |

|

Arthur? |

|

MR. GAST: I had originally planned to come here tonight, I have a position regarding the |

station, I am a former member of the Nuclear Matters Committee, I was among the group that |

volunteered two years ago when the original committee all, for some reason, all resigned and I |

didn't understand it. I started reading the articles in the paper and letters to the editor from |

some of the employees who are presenting information here today and because I have a |

nuclear, and engineering, and construction and industrial background that goes back 50 years, |

I hate to say because that doesn't make me young, I thought that I ought to come down and |

offer my services to the selectmen to give a little balance to this. |

|

I figured that the replacement committee would all be rabid anti-nuclear people and I was |

wrong, the people who volunteered was probably the finest group any small community in |

America could put together. We had a consulting meteorologist, we had two medical people, |

including the head of nuclear medicine at the local hospital, we had two nuclear engineers who |

had extensive background, including at the plant, who are no longer at the plant, just a |

tremendous number of people with very good experience. |

|

Now I resigned a year ago, January 4, 2006, and I sent the board of selectmen my resignation |

and I offered my own positions because they didn't get into our reports, for reasons I don't want |

to get into now. But here it is, I'll just read it exactly as I sent it to the selectmen a year ago. I |

support Entergy's intention to apply for an extension of its NRC operating license beyond the |

current 2012 expiration date. My reasons are, one, this is hardly a new or dramatic change, it's |

the very same plant that's been operating quietly, safely and efficiently, largely out of view, |

having no massive cooling tower or towering smokestack, which some people want to change, |

for 33 years without major incident, the plant appears to be well managed and maintained and |

protected. |

|

The plant produces a significant portion of our area power requirements that would otherwise |

need to be imported at far greater cost and environmental impact by fossil fuel-fired and |

generating plants burning scarce and costly natural gas or coal and oil with their negative |

environmental impacts or importing scarce and expensive Canadian hydro power. |

|

Three, it produces no discharge of carbon dioxide greenhouse gas, nitrous oxide orange plume |

like the oil-fired plant down on the canal, sulfur oxide precursors of acid rain or mercury |

emission to enter the seafood chain as from coal-fired plants. |

|
Appendix A

NUREG-1437, Supplement 29 A-218 July 2007

| Radioactive discharge from vent stacks is negligible to nonexistent, as measured by on-site

| monitors meeting regulatory requirements. No shipment and unloading of heavy fuel, oil or

| LNG impacts our local area. While nothing involving terrorism is 100 percent predictable, the

| often cited vision of a 9/11 style aircraft attack is virtually precluded by the design and layout of

| the critical plant elements and surrounding structural supports. Similarly, the notion of a

| frogman entering through the sea water inlet canal and the massive centrifugal cooling water

| pumps without being homogenized is ludicrous.

|

| Five, no verifiable health impact has been detected or certified to have resulted from the plant's

| presence or operations. 

|

| I'll just add to this our committee had Dr. Sid Nuremberg and the head of nuclear medicine at

| the hospital, came in with boxes of supporting evidence to say while there were spots of cancer

| in the town, the type of cancer caused by nuclear radiation is virtually nonpresent. 

|

| Number six, there is no free lunch to fill our national and regional energy needs. I've been

| involved with these alternative energy things that came up and all through the last 30 years,

| massive federal funding of alternative energy, coal gassification, shale oil retorting, solar

| energy, wind power or fuel cells have not brought significant power to our electrical grid in over

| 30 years of technological effort.

|

| Opposition to oil production off-shore and on federal lands with no added refining capacity since

| the mid `70s has left us dependent on insecure foreign sources, and I feel that as much as

| anybody, I was designing refineries back in the `70s and there were no more to design. Failure

| to extend Entergy's operating license leaves the town with problems, if not the responsibility of

| removal of a derelict plant and related transmission lines and equipment. 

|

| Questions regarding spent fuel, security and the impact of revenue lost from jobs and support

| revenue disappearing and disposition of the plant's acreage to new uses, condos.

|

| Much of the foregoing is based upon my career-long experience with a multitude of

| technologically advanced industrial plants worldwide of the size, complexity and age at least as

| great as the Pilgrim station. 

|

| Respectfully submitted. That's all I have to say.

|

| MR. CAMERON: Thank you, Arthur. 

|

| Did I get everybody who wanted to speak? I know I went through all the yellow cards, at this

| point. We do have, it's unusual, but we do have the luxury of having some more time, at this

| point, and I don't think we are going to have that luxury tonight. And because Pilgrim Watch is

| the major group concerned, I'm going to ask Mary Lampert whether she could use ten more

| minutes to go over your comments?

|

| MS. LAMPERT: At least.
Appendix A

July 2007 A-219 NUREG-1437, Supplement 29

MR. CAMERON: Okay. Well, there will be some, there will be some limit, but Mary Lampert |

and then I want to ask the NRC staff to address a couple points. |

|

Mary Lampert? |

|

MS. LAMPERT: Yes. I covered health, the second area of interest I would like to talk about is |

the section postulated accidents and I stated two factors that had to be factored in here, one |

was the decision of the 9th Circuit Court in California and also a proper reading of Section 5 of |

the GEIS. There is new and significant information regarding postulated accidents that was not |

considered. If considered, nobody could conclude that the result would be small. Important to |

consider, but it was neglected, was the issue of security, there is site-specific information that |

you have to consider. |

|

First, vulnerability, what type of protection do they have? There is no protection from an air |

attack and despite the previous speaker, a helicopter loaded with explosives could cause a |

severe accident targeting spent fuel, targeting the switch yard, targeting the control room, we |

don't have to go on, it's an undisputed fact, they are not built to resist an air attack. Security |

from the water is virtually nonexistent, there are buoys which are floating no trespassing signs, |

period, explosives can be put up into the canal, that is why Homeland Security recommended a |

grate for Millstone, which they turned down. |

|

Also, from a land attack, there is no effective security, they are dependent upon outside security |

arriving. However, the OSRI mock attacks have demonstrated that a force can do the job, hit |

the target sets in about three minutes, no way the state police, etcetera, are going to get there |

in three minutes. And neglected and what should be included is the spent fuel pool as being a |

serious target and a target of serious consequences, which Section 5 discusses that you focus |

on consequences. The new and significant information is the National Academy of Sciences |

spent fuel vulnerability study where they identified reactors that have the spent fuel pool located |

in the attic of the reactor, as Pilgrim, are especially vulnerable to attack. |

|

This has gone into the dangers of densely packed pools, like Pilgrim, that are inside the main |

reactor building, outside primary containment at the top. In the Massachusetts Attorney |

General's motion to intervene, there is an attachment by Dr. Gordon Thompson, again new and |

significant information, that discusses the danger of a highly, densely packed spent fuel pool, |

fire and what the consequences would be. Again, to remove this from discussion of postulated |

accidents is ludicrous. |

|

Then, by not looking at these issues, you do not come up with then, an analysis of mitigation |

which clearly, for spent fuel, as put forth in the attorney general's motion, would be to analyze |

the effect of having a lightly packed spent fuel pool and putting the rest into secured dry-cask |

storage. Also, an analysis should be required of the recommendations in the National |

Academy's study such as what fact an analysis would be the effect of, reconfiguration of the |

pool? What realistically is the effect of the firehose brigade, etcetera, so we can have a true |

analysis. |

|
Appendix A

NUREG-1437, Supplement 29 A-220 July 2007

| This moves into the severe accident mitigation analysis which the draft decided was, the

| analysis was sound which, again, if you really looked at it, you could not come up with that

| conclusion and I hope they will look at it more seriously again. The licensee, the applicant,

| used the MACCS II code, they are not restricted, by the way, of only using that code, but what

| is important is what goes in, what are the variables, the input data, because obviously that

| would effect the analysis of what the consequences are and the input data clearly is lacking.

|

| For economic data, they put in the average property value of farm and non-farm property, they

| did not look at, for example, the added value of an ongoing business enterprise, clearly a

| manufacturing plant is valued at far more than the bricks and mortar that go into it. In doing an

| analysis of alternative sources of energy, there was an analysis of historic, you know, value of

| the area and what the impact would be, but it is not in the SAMA analysis for Pilgrim. Clearly

| because this area has such great historic value, also clearly because of our beautiful seaside

| location, that impacts and raises the values of our property. Tourism is here because, not to

| come to these meetings, obviously, but because of the history that's here, because of the

| seaside location and that would be gone and has to be factored in.

|

| Not also considered properly were two emergency planning variables, one, evacuation delay

| time which is, in English, notification. They stated that the public would be notified, at max,

| within six hours, that makes assumptions which aren't true, that sirens can be heard inside the

| houses, which they can not be heard inside. What about an accident happening at night? 

| What about the fact that some sirens are not going to operate? You cannot expect part of the

| fire or police department and DPW to cover over 125 square miles to notify people who are

| doing different things, clearly this is just, that people will be ready to get out of here in six hours

| is unrealistic.

|

| Evacuation speed, again, a very unrealistic time was put into the formula because it had faulty

| emergency planning assumptions, they overlooked, for example, the shadow evacuation. 

| There is an assumption that everybody outside whatever the zone is is going to stay home and

| go about their business, we know, from Three Mile Island, we know from telephone surveys that

| were done after that people outside the ten miles, people close to Boston will be hitting the

| road, putting a cork, so to speak, in the bottle, so that people here are not going to be able to

| get out in the timely manner that was assumed.

|

| We also know that there is nothing magic about the ten miles, so the evacuation speed is how

| long it's going to take to get from, let's say, my house in Duxbury to just a little bit past the

| magic ten miles in Marshfield. Again, we know from the Sandia National Labs studies, we know

| from study, after study, after study that there is nothing magic about the ten miles so to assume

| the consequences end at that point and we can call an evacuation successful once you cross

| the ten miles is patently absurd. 

|

| And so because of the problems with the severe accident mitigation analysis, what it does is

| falsely minimize consequences so the cost of mitigation seems not necessary, as described for
Appendix A

July 2007 A-221 NUREG-1437, Supplement 29

the direct torus vent system, and we could go through many other mitigations that should be |

relooked at, but the key is you have to do an honest analysis to begin with, which was never |

done. |

|

The next area was nonaccident view to radioactive waste. Again, small impact, how can there |

be a small impact? Because, number one, when you are looking at spent fuel, it is assuming |

there is validity to the fantasy of the Nuclear Waste Confidence Act, that somehow Yucca is |

going to be there, or a radioactive waste fairy is going to come or God knows what they are |

assuming. But we know reality and one of the NRC commissioners was quoted in all the |

papers yesterday, Commissioner Merrifield, that he has no confidence in Yucca and that we, |

essence, should start again from zero. So, without looking at and providing a plan of what |

people are going to do with this high level waste, how can one say then that there is no impact? |

|

The same could go for low level waste, low level waste is a misnomer because it is everything |

but the spent fuel and it can have some highly toxic and long-lived radio nucleates in it. Entergy |

is a major producer of this stuff, the new and significant information that was overlooked was |

that Barnwell, South Carolina, which takes our waste, has said by June, `08 the door is shut, |

also they say in the draft that they have confidence that other sites will be built. That's baloney, |

there has been millions of industry money spent to try to find a site in Illinois, etcetera, etcetera, |

etcetera, and no new sites have been built because nobody wants it. |

|

Massachusetts had the beginnings of a search in the `90s and they stopped looking, so what is |

going to happen to this? Again, if it is the plan, if it is not realistically looked at and a plan is not |

put forward, you cannot analyze it and say it's going to be no problem. And so what we will |

have on our eroding coastline on Cape Cod, subject to increasing storms from global warming, |

etcetera, etcetera, etcetera, turning into a high level and low level radioactive waste dump until |

my kids are my age. This has to be analyzed and faced honestly, okay? |

|

The next issue that I would bring up-- |

|

MR. CAMERON: Mary, could you just make this the last one? |

|

MS. LAMPERT: Yeah. Is, if you are talking about waste, is transportation. Again, the |

transportation, God knows, let's pretend that there will be a Yucca or there will be someplace to |

put the stuff, then the issue is how is it going to get there? The draft brightly says impact small, |

how do they know it's going to be small? A, what's the plan? I've read the plan in DOE and |

apparently 24 barges are going to South Boston to be put on a railroad to go through like |

Chicago, does anyone in their right mind think this is going to happen when one of the casks |

per barge has 40 times the radiation in the Hiroshima bomb? |

|

Do you think Cohasset, Hingham, Senator Lynch, how about the people in South Boston? He |

will be lynched, but the point being that these issues have not been looked at seriously because |

of my general comment in the beginning, that the draft is playing games by pretending that |
Appendix A

NUREG-1437, Supplement 29 A-222 July 2007

| rules, policy that the NRC has are real and that because the plan is there and it's going to

| happen that we don't have to worry about it so it's significance is small. But we are not dealing

| with, we shouldn't be dealing with fiction but, in reality, when you read this, that's where this

| belongs.

|

| Again, thank you, Chip.

|

| Transcripts of the Evening Public Meeting on January 24, 2007, in Plymouth,

| Massachusetts

|

| [Introduction by Mr. Cameron]

| [Presentation by Ms. Williamson]

| [Presentation by Ms. Hurley]

|

| MR. HAYNES: I'm Bob Haynes, President of the Massachusetts AFL-CIO, I represent 400,000

| working families here in the Commonwealth of Massachusetts and I get to do testimony at the

| statehouse and occasionally at Congress or whatever. 

|

| And I have to say, first of all, you guys are all workers and I've never been at a hearing where

| people ask questions and then people that were sent here to answer them answer them, so I

| congratulate you all. This executive summary, this impact study is a terrific piece of work. It's a

| little too comprehensive for me, but I congratulate you for your good work.

|

| I'll try to be as brief as I can. Obviously I'm here to say that we need this power--

|

| MR. CAMERON: Would it help you, you can come up here and you can just put your notes

| down, it may be easier for you.

|

| MR. HAYNES: We obviously need this power, it's reliable, it's safe, it's low cost. We need the

| Pilgrim Nuclear Power Station. We frequently hear in Massachusetts that we are losing

| population, we are losing jobs, especially young people, to other parts of the country where

| work is more plentiful and cost of living is lower. The consequences of loss of the people and

| loss of jobs means the rest of us need to pick up a higher proportion of those costs here in the

| commonwealth.

|

| And one of the big costs, one of the big cost drivers in the Commonwealth for families obviously

| is higher energy cost and one way to stem the tide, if you will, is to keep Pilgrim open and in

| operation. Pilgrim provides some of the lowest cost and most reliable power available on our

| grid and another price contributor is the demand for electricity in Massachusetts is growing, but

| new supplies are not. If you are in some of our urban areas, there is a tremendous amount of

| growth taking place, some major buildings being constructed across this commonwealth.

|

| And when you take a look at the new economy here in the Commonwealth of Massachusetts,

| biotechnology, health care, computer technology, developers, all require vast amounts of

| energy to supply the laboratories and the life saving medical equipment, clean rooms and data
Appendix A

July 2007 A-223 NUREG-1437, Supplement 29

centers. Obviously working families here in this Commonwealth need these industries in this |

new economy to thrive. Massachusetts has gone through a tremendous transition in the last |

ten years from a manufacturing-based economy to this sort of new age economy, if you will. |

|

We need the energy produced at Pilgrim for our necessities and for those new technologies |

that become staples to our way of life. We need nuclear power here in the Commonwealth, we |

need Pilgrim for three reasons pretty simple to me, as a representative of 400,000 working |

families in the commonwealth. The three reasons are jobs, jobs and jobs. We are talking |

about losing 700 good jobs here at the station, including 400 union workers, and I will say about |

the 400 union workers that they are highly trained, highly skilled, incredibly experienced |

professionals that are hard to replicate in this economy and we don't want to lose these good |

jobs. |

|

These workers keep Pilgrim Nuclear Power Station safe, and productive and to not renew this |

license would be to displace them and that would jeopardize our energy supply, hurt our local |

economy and devastate their families. There is an obviously economic impact, $135 million in |

annual economic activity. A very significant fact is that the Pilgrim plant purchases services |

from more than 75 Massachusetts companies, so you can see that the spread of that economic |

impact is dramatic here. |

|

Let me just close, let me just be as brief as I can here. |

|

From a regional economic jobs and quality of life standpoint, we need both the electricity and |

the jobs that Pilgrim Nuclear plant provides. If we know that the plant is safe, which it is, if we |

know the workers are experienced and skilled, which they are, if we know these workers need |

these good jobs, which certainly they do, if we know the power is produced at low cost and is |

indispensable to our grid, which is true, if we know the contribution Pilgrim makes to the state's |

economy are immeasurable and irreplaceable, which they are --. I lost my fourth page. Then |

there are no reasons why the Pilgrim Nuclear Power Plant should be denied license renewal but |

rather a host of reasons why it should be allowed to continue being a key focal point of our |

energy and economic future. |

|

And I want to say, you know, that this is a wonderful opportunity, this civic engagement, the |

opportunity to speak in public about things that are so important to us and for somebody that |

has represented workers for 30 years here in the Commonwealth of Massachusetts, this is a |

good example, a good relationship with the company, and the union and the workers, doing |

good work for the community, so please relicense the Pilgrim Nuclear Power Station for the |

benefit of the community. Thank you very much. |

|

MR. CAMERON: Thank you. Thank you, Bob, for those comments and also your remarks |

about the meeting. |

|

And we are going to go to Gary, Gary Sullivan. And Gary, why don't you just come right up |

here, thank you. |

|
Appendix A

NUREG-1437, Supplement 29 A-224 July 2007

| MR. SULLIVAN: Thank you. I'll wait until I get to the mic before I say anything. I have no idea

| what that guy was saying on his way up there, but let me just thank him for taking all of my

| speech, President Haynes. 

|

| My name is Gary Sullivan, I represent the workers at Pilgrim Nuclear Power Plant, I'm very

| proud of those workers. I'm going to be very brief here. 

|

| In my opinion, this is a no-brainer, jobs are so important. We represent not only the workers at

| Pilgrim Power Station, we represent workers at fossil plants up in Cambridge, up in Everett, in

| South Boston, in Charlestown, in Weymouth and I could tell you the training that the people

| receive down at Pilgrim to run that plant is second to none, I have never seen anything like it.

|

| I can also tell you that the majority of my members that work at that plant live around the plant,

| which says something. They are proud of what they do there and they feel completely safe with

| themselves and their family, that is quite a statement. Over 85 percent of them live in Plymouth

| and Barnstable County. Now it was spoken earlier about the energy situation, especially here

| in the Northeast, and I can tell you that we are, we are very close to being in crisis here in the

| Northeast when it comes to power.

|

| With the growth in demand of electricity and the lack of generation, I think it would be not only a

| disservice to the workers and the community that would be hurt by this closing or non-renewal

| but it's a disservice as well to the energy grid and the fact that getting alternative energy

| sources like wind power. I mean if we are having trouble with wind power and new alternative

| sources, we cannot discard a source and a resource like Pilgrim Nuclear Power Station. 

|

| So I just want to say, in closing, I think we have an obligation to our society and the fact that

| this power is needed on the grid. I think we have an obligation to the community that it serves

| and the fact that the people that work there thrive in the community. This plant exudes

| community involvement, I mean you cannot get a better example of how a business is helping a

| community. 

|

| So I hope I wasn't too long, that's all I want to say. Thank you for your time and thank you for

| caring enough to be here for this issue.

|

| MR. CAMERON: Thank you. Thank you very much, Gary. 

|

| And we are going to go to Joyce, Joyce McMahon, next.

|

| MS. MCMAHON: Good evening. My name is Joyce McMahon, I am the Director of

| Communications for the Massachusetts Affordable Reliable Electricity Alliance, Mass AREA for

| short. 

|

| First, let me thank you for taking this opportunity to address the commission, we do appreciate

| your time. Second, I would like to tell you a bit about Mass AREA and why we felt it was 
Appendix A

July 2007 A-225 NUREG-1437, Supplement 29

important to be here. Mass AREA is a diverse, state-wide group comprised of more than 65 |

labor, trade associations, businesses, including Entergy, educators, scientists, advocates and |

community leaders. |

|

Earlier today, we heard from some other Mass AREA members, which included the South |

Shore Chamber of Commerce and Massachusetts Associated Industries and tonight we heard |

from some of our labor groups. As a group, we are committed to finding clean, low cost and |

reliable electricity solutions that benefit all of Massachusetts, it is an urgent public policy |

challenge. We came together one year ago after several warnings were issued by the Federal |

Energy Regulatory Commission, ISO New England and others that energy supplies will be |

insufficient to meet peak demand as early as 2008 and that energy prices are causing hardship |

for the region's businesses and residents, especially the most vulnerable such as the elderly |

and low income populations. |

|

While Mass AREA's mission is brought in focus to include new electric generation in the form of |

renewable energy resources, improving the transmission infrastructure, developing new natural |

gas supplies and encouraging energy efficiency, Mass AREA and its members fully support a |

license extension for the Pilgrim Nuclear Power Plant. On a typical day, Pilgrim station provides |

seven to nine percent of the Commonwealth's electricity. Without it, Massachusetts and the |

region as a whole could face power supply shortages, including rolling blackouts, a lot sooner |

than predicted. |

|

Perhaps one of the most important issues that led Mass AREA to support a license extension |

for Pilgrim is the fact that the plant operates safely and continuously earns the NRC's highest |

safety rating of green. We also know that NRC staffers are on-site at the plant each and every |

day overseeing operations and helping to maintain a safe and secure environment. The |

production and distribution of electricity, whatever the source, is inherently a challenging safety |

issue, yet nuclear power has proven safe. In 50 years of commercial operations, there has |

never been a radiological death at any U.S. nuclear plant. |

|

Mass AREA and its members are also comforted in the knowledge that Pilgrim's owners work |

diligently with state and local emergency officials, some of their programs include giving the |

local communities radio equipment so that they all operate on the same frequency and |

conducting extensive training sessions to make sure everyone is prepared in the event of an |

emergency, be it plant-specific or a natural occurrence such as a hurricane or a blizzard. The |

real danger is a scenario that Massachusetts will face if the state does not have enough |

affordable and reliable electricity. |

|

Blackouts aren't simply an inconvenience or a temporary loss of business, blackouts cause |

death because people who are already frail and infirm can't get the heat or cooling they need to |

sustain life. High prices are a danger too as they cause folks to curtail electricity use and again |

result in real life safety concerns and possible harm. |

|

Over the past several months, there have been a few proposals for new power plants but most |

are small, still the largest proposal, Cape Wind, faces significant opposition and the smaller |
Appendix A

NUREG-1437, Supplement 29 A-226 July 2007

| units have not even begun the very long siting process. As such, it becomes even more vital

| that we maintain our current supply, including Pilgrim.

|

| Opponents of the Pilgrim Power Plant often say we would be better off if the generator was

| decommissioned. However, the baseload power that would replace Pilgrim would most likely

| come from sources that are more expensive, far more polluting or both. At this time, wind and

| other renewable energy technologies simply cannot generate the massive baseload power that

| would be needed were Pilgrim to cease operations. Moreover, the electricity that Pilgrim

| supplies is created without generating any greenhouse gas emissions and therefore it does not

| contribute to global warming.

|

| Pilgrim also mitigates the production of hundreds of tons of sulfur dioxide and nitrogen oxides,

| chemicals which are harmful to human health, especially among children and the elderly, these

| health and environmental benefits alone are enough argument for renewing Pilgrim's license to

| produce power. From an economic standpoint, since the owners of the plant sell their power

| through long-term contracts and not on the volatile short-term market, the power produced at

| Pilgrim is much lower cost than the regional average.

|

| Massachusetts ranks fourth in the nation in terms of highest electricity costs, couple that with

| our high housing and health care costs and it becomes even more important to maintain

| Pilgrim's very reliable, low cost electricity so that we don't continue to have an exitus of

| residents and businesses from our state who can no longer afford to live or work here.

|

| Speaking of work, Pilgrim is also an important source of jobs, it has more than 700 permanent

| full-time employees, most of whom live in Plymouth and the surrounding communities, indeed

| Pilgrim supports the local economy to the tune of $135 million annually in local economic

| activity. Though the draft environmental impact statement noted a moderate socio economic

| impact should the plant cease operations, we believe those who would lose their jobs would

| face large economic and financial loss.

|

| In summary, Mass AREA has weighed all of the environmental, economic and energy supply

| traits of Pilgrim, particularly its long record of safety, and concluded that the Pilgrim Nuclear

| Power Plant is vital to the region, state and local community for three reasons. First, its

| environmentally sound operations; second, its economic contribution to the local community

| through the provision of jobs and purchase of goods and services; and third, its provision of

| reliable, low cost electricity. Mass AREA encourages the NRC to grant Entergy's Pilgrim station

| an extension of its license so that it can continue to safely operate for an additional 20 years.

|

| Further, we urge the Atomic Safety and Licensing Board to consider the Pilgrim related matters

| before it as quickly and expediently as possible while the license renewal process takes its

| natural pace. 

|

| Again, thank you for the opportunity to speak with you tonight.

|

| MR. CAMERON: Thank you very much, Joyce, and thank you again. 
Appendix A

July 2007 A-227 NUREG-1437, Supplement 29

|

And we are going to go to Mary Lampert, at this point. |

|

MS. LAMPERT: Yes. The NRC staff improperly concluded the cumulative impacts would be |

small, the analysis was improper for the following reasons. First, they ignored or misinterpreted |

new and significant information pertaining to Pilgrim that has occurred since the generic |

environmental impact statement was written in 1996. For example, the health impact was |

determined to be small because they misinterpreted that National Academy's BEIR 7 by saying |

the recent report was very, didn't differ, differed very little from the previous. |

|

In fact, it stated that the incidents of cancer would be a third higher than previously thought, that |

women were 37.5 percent more likely to get cancer, that workers exposed to the allowable |

maximum dose, one in four would get cancer. Also, they ignored in the draft the continued |

pattern of increased radiation-linked diseases. A look at the cancer registry by the former |

founder and Director of the Massachusetts Cancer Registry and a professor at Boston |

University has seen a continued increase, elevated levels, of thyroid cancer, leukemia, multiple |

myeloma, prostate, to name a few. |

|

They also misinterpreted the Southeastern Massachusetts Health Study, the state study that |

found a fourfold increase in adult leukemia. And I understand they now appreciate that they |

misquoted or misunderstood and will be going back to DPH, the authors of that study and the |

assistant commission have held, have stated equivocally, and I will include their e-mails and |

correspondence in my written testimony, that they stand behind that study. |

|

The second reason that the draft found small impacts results from incorrectly assuming the |

current NRC regulations, many of which are written in the 1970s are, a, they are being met by |

the licensee, and that these regulations themselves reflect current realities and are indeed |

protective of public health and safety, so they more or less put us in a catch-22. An example is |

that the draft found spent fuel that would be half again, as much generated over the relicensing |

period was of small impact because of the assumption that this stuff will have someplace to go. |

Even Ed McGaffigan, a Commissioner of the NRC, said Monday the Yucca Mountain program |

is deeply flawed and that folks better start looking someplace else. Also, another example |

would be they are assuming that the regulation that doesn't require monitoring wells on-site |

unless the water is used for drinking is satisfactory. Clearly it is not satisfactory and it will not |

pick up leaks of contaminated water from buried pipes and tanks, for example, and the |

topography of the land is such that leaks, if they are there from either buried pipes or tank or |

from the waste that has been buried on site and denied, goes into the bay. |

|

Third, they regard the impact as small because they ignored the impact of spent fuel in |

postulated accidents and they ignored terrorism. There are two significant factors that require |

them, before they move forward in this decision, to look at terrorism and also to look at the |

impacts of spent fuel in a postulated accident, one is the 9th Circuit Court decision in California |

that was asked to address the question whether the NRC need consider terrorism on licensing |

decisions under NEPA, they answered yes. This process is a significant licensing situation so, |

therefore, this is a factor that has to be looked at. The Supreme Court was asked by the |
Appendix A

NUREG-1437, Supplement 29 A-228 July 2007

| licensee in California to review the case and they refused to do so, meaning they concurred.

|

| The second issue is involving spent fuel, spent fuel has to be looked at under the section of

| postulated accidents. If you look at the GEIS, the GEIS or whatever, it says, it describes in

| Section 5 explicitly environmental impacts of postulated accidents, they define severe, they

| define accident and they don't limit either to the reactor. They do this, however, in Section 6

| which deals with exclusively normal operations and that's where they say the spent fuel doesn't

| have to be considered.

|

| So, what does this mean? All the new information that we have about the dangers of spent fuel

| storage at Pilgrim provided by the National Academy of Sciences, indicating that the way the

| fuel is stored at Pilgrim is among the most dangerous in the country, an analysis has to be done

| on the lack of security from an air attack, from water, land and then an analysis of the various

| mitigations to decrease risk such as a requiring a dense, a low density pool, secured dry cask

| storage, what about reconfiguring the pool? What about alternative water, spray water

| systems? This has to be analyzed and put forward.

|

| Because, which I find interesting, because they avoided talking about spent fuel, avoided

| talking about terrorism, this helps explain their conclusion that these alternative sources of

| energy, such as wind, solar, gas, etcetera, would have a greater impact, would be more

| expensive, would be all these other things. Clearly, if you look at, if you factor in security, if you

| factor in waste, if you factor in a true analysis of consequence where the attorney general, for

| example, a report to him indicated a specific consequence analysis of a spent fuel accident of

| Pilgrim, that if 100 percent of the cesium 137 was released, it would bring about $488 billion in

| damage. If ten percent of that were released, $105 to $175 billion. If 100 percent were

| released, which is likely in a terrorist attack situation, 24,000 cancers, ten percent, 8,000

| cancers. 

|

| Now, seriously, who here is concerned about a terrorist attacking a wind farm? So what if they

| did? You would never have the consequences that we have here. So, because nuclear has

| been described as cost effective, it's because these true costs are not put into play, it is the

| most heavily subsidized industry. If you describe it as safe, as former speakers had, it's

| because you are not looking at what the consequences of either a reactor accident or of a

| spent fuel accident, God forbid, would be. And if you are looking at is as safe, I think I've

| already covered that.

|

| And so, by continuing to ignore the realities, what we are doing is depriving ourselves in the

| future of a cleaner, safer and cheaper source of energy for ourselves and for the generations

| down the pipe. 

|

| Thank you.

|

| MR. CAMERON: Thank you very much, Mary, thank you. 

|

| Bill Harris?
Appendix A

July 2007 A-229 NUREG-1437, Supplement 29

|

MR. HARRIS: Good evening. I want to talk about the economic impact of Plymouth station. |

My name is Bill Harris, I'm from Duxbury. I'm a local business owner, I'm also a concerned |

citizen. |

|

I support relicensing of Plymouth station, nuclear power is the only viable long-term solution to |

our energy needs. It's cost effective, it's reliable, it's clean. Plymouth station is one of the |

largest local employers, it's one of the largest local industries, the majority of Plymouth station |

employees live in the county. In addition to protecting land, making sizable charitable donations |

to local nonprofits, Entergy and Entergy employees pay taxes, taxes and fees that go to the |

local operating budget, the local schools, the local police and fire. |

|

Payroll at Entergy or payroll at the station is $55 million between permanent employees and |

contractors, that's $55 million injected into the local and surrounding economy, that's $55 million |

going into local shops, local restaurants and most important, our local housing market. |

Plymouth station is a valuable part of the local and surrounding community, I support the |

relicensing of Plymouth station. |

|

MR. CAMERON: Thanks a lot. Thanks, Bill. |

|

How about Brian? Brian Thurber? Brian? |

|

MR. THURBER: Good evening. My name is Brian Thurber and I work as the energy |

coordinator for Clean Water Action, Clean Water Action is a statewide and national |

environmental public health advocacy organization with roughly 33,000 members in |

Massachusetts. Thank you to the commission for the opportunity to provide comment on the |

draft environmental impact statement, my comments will be extremely brief. We strongly |

support the efforts and comments of Pilgrim Watch and the Office of the Attorney General of |

Massachusetts, among other groups opposed to relicensing of the Pilgrim Nuclear Power Plant. |

|

We concur with conclusions that the draft environmental impact statement ignores new and |

significant information and relies on incorrect assumptions about NRC regulations, as they |

relate to environmental and public health impacts. The Pilgrim plant suffers from the same |

persistent problems of safety, security and storage as the nuclear industry in general. |

|

Even within the narrow scope of this review of the impacts of relicensure, there are significant |

impacts that should be grounds for denying the extension. Daily radiation releases, the vast |

amounts of radioactive waste stored indefinitely on-site at the plant, damaged fisheries and the |

risk of a terrorist attack are just some of the compelling reasons for letting the plant be |

decommissioned at the end of its planned life span in 2012. |

|

And just specifically regarding the comment about global warming that I believe Joyce |

McMahon made earlier, I just want to point out that, you know, studies have shown that the life |

cycle of creating electricity from a nuclear power plant is actually greenhouse gas intensive |

because you include the fuel processing. |
Appendix A

NUREG-1437, Supplement 29 A-230 July 2007

|

| And then also I just want to comment that I was surprised to see the broad-brushed conclusion

| that alternatives to relicensure have moderate to large impacts necessarily, I mean that's

| obvious of course with fossil fuel plants but with alternatives, including renewables but

| especially efficiency and conservation, it's very hard to argue that the impacts would be

| anywhere close to large in terms of negative environmental and health impacts and, when you

| are talking about cost effective, I mean that's obviously the way to go.

|

| Given the many unanswered or inadequately answered, inadequately answered concerns about

| the environmental and public health impacts of extending the life of this plant, we respectfully

| ask that the commission deny the relicensing of the nuclear power plant. We strongly believe

| that this plant does not deserve another 20 years of operation and the South Shore and the rest

| of Massachusetts definitely does not deserve another 20 years of the impacts from this plant. 

|

| Thank you.

|

| MR. CAMERON: Thank you, Brian. 

|

| Our next three speakers are Michael Scherer, Richard Rothstein and Bill Stone. And, Michael?

|

| MR. SCHERER: Good evening. My name is Michael Scherer, I am a fish biologist and I was,

| until about a year ago, the President of Marine Research down in Falmouth. 

|

| About a year ago, Marine Research was acquired by a much larger environmental consulting

| company, Normandeau Associates, and I'm now a vice president of that company. I've been

| working on fisheries issues at Pilgrim station for most of my professional career which has

| spanned about 32 years, so I can appreciate the amount of material that needed to be gone

| through to prepare the EIS.

|

| I will prepare detailed comments, but I wanted to offer a couple of short ones tonight and they

| concern the moderate finding that the plant would have a moderate, relicensing could have a

| moderate impact on the Winter Flounder population and also on the smelt population. The

| moderate impact finding on Winter Flounder was based largely on what's called the equivalent

| adult model which takes numbers of eggs and larvae that pass through the plant and predicts

| how many adults would, could result from those based on many assumptions on their mortality

| rate. It's a screening tool and it's not designed to estimate mortality rates.

|

| In 2000, 2002 and 2004 I was involved in what we call a larval transport study designed to

| measure how many Winter Flounder actually flow past the station in a typical spawning season,

| and based on that study, we estimated that much less than one percent of the Winter Flounder 

|

| larvae passing the station are actually entrained, so I would urge you to focus on that more than

| the equivalent adult model. 

|

|
Appendix A

July 2007 A-231 NUREG-1437, Supplement 29

With regard to Rainbow Smelt, the moderate finding was based on numbers impinged, which |

average about roughly 1,500 a year, and all of those fish were attributed to the Jones Rives. |

There are approximately 21 Rainbow Smelt runs between Cape Cod and Boston of varying |

sizes and, since Rainbow Smelt is a coastal species, it seems unreasonable to assume that all |

of them come from that one system. |

|

Thank you. |

|

MR. CAMERON: Thank you very much, Michael. And Richard, Richard Rothstein? |

|

MR. ROTHSTEIN: Good evening. I'm Rich Rothstein, I'm a Plymouth resident and I also am a |

member of the Town of Plymouth Nuclear Matters Advisory Committee, although tonight I'll be |

speaking on my own behalf. |

|

And you've heard comments pro and con about the relicensing and my objective in joining the |

committee two years ago was to try to ensure that whatever decisions are rendered would be |

based on good science and engineering, not hearsay, rumors, innuendos, etcetera. |

|

I'm a board certified consulting meteorologist and have been working in the environmental |

consulting profession for the past 35 years, was heavily involved with the design, licensing and |

operation of nuclear power plants domestically and internationally in the 1970s and became |

heavily involved with nuclear emergency preparedness planning programs following Three Mile |

Island in the early, during the early 1980s time frame. |

|

I'm going to limit my comments tonight briefly just to the adequacy of meteorological databases |

and models that were used for the off-site consequence analysis that was discussed in Chapter |

5 of the supplement EIS. You'll note that in the appendices, that Appendix A, I believe, that |

contained comments from the scoping meeting, public scoping meeting, that took place last |

summer, there were a number of questions and issues raised about the adequacy of the |

MACCS II software code that was used for doing the air quality analyses, meteorological |

analyses for use in the studies. |

|

And I guess the response to those comments indicated that this would be addressed or |

discussed in Chapter 5, although I didn't see any simple or extensive discussion in Chapter 5, it |

just gave the results, so I would like to see Chapter 5 or somewhere in the appendices in the |

SEIS give a more in depth discussion of justifying the use of that type of code for purposes of |

the modeling and dose calculations for the off-site consequence analysis that went into the |

cost/benefit studies. |

|

Now I know some of the commenters had referred to, and I'm not going to get too technically |

jargonny here, but Class A and Class B air quality dispersion models, and these are modeling |

concepts that the NRC developed back in the `70s and `80s time frame. I'll just say that the |

MACCS II code is more like a Class A model, very simplistic, assumes straight winds, any given |
Appendix A

NUREG-1437, Supplement 29 A-232 July 2007

| hour, and can be applied pretty quickly, and the Class type B models were never really fully

| implemented for use because they are quite cumbersome, expensive numerical models,

| needed a mainframe computer probably about half the size of this room.

|

| The good news is that, since the early 1980s, that modeling techniques have been advanced

| and models are a little simpler to apply, you can use some of these complex models now,

| variable trajectory wind flow models on a PC. An example of these types of models can be

| found in 40CFR, Part 51, Appendix W, that's the OCPA's guideline and air quality models, and

| an example of a model that can be found there is the Cal-Puf model which can be applied for

| shoreline complex wind flow environments, such as those that exist in the Pilgrim region.

|

| And I realize this is not part of nuclear emergency preparedness planning, in terms of the

| relicensing, but those kinds of models can also be applied and adapted for use for operational

| studies and accident analysis studies, including the SAMA type of studies too. And I brought up

| that model in particular because the NRC's contract, Earth Tech, was the, some of my

| colleagues who had worked at Earth Tech were involved with the development of that Cal-Puf

| model, so I know the folks from Earth Tech know what I'm talking about here.

|

| I'd just like to close to say that I would like to see NRC come up to speed, such as other federal

| agencies have had in the last decade or so, and use realistic, accurate modeling techniques for

| a number of different applications. And I think the sooner this is done, the more credible and

| realistic the analyses will be and that will only help promote and advance perhaps the advent of

| even newer reactor technologies down the road, so things don't get delayed due to

| questionable analyses. 

|

| Thank you.

|

| MR. CAMERON: Thank you very much, Rich, for those comments. 

|

| And Bill Stone?

|

| MR. STONE: I'm a Plymouth resident and have been for 34 years, my wife and I and my

| children live in the town, my grandchildren live in the town. And as a resident of Plymouth, I

| know of no environmental problems that Pilgrim has created, according to what I've read from

| Mass DEP, the Federal EPA or the NRC. I own a company that manages approximately $250

| million worth of real estate, my concerns, as far as the environment are concerned, is whether

| or not we are going to be able to replace the production, the electrical production, that comes if

| Plymouth is allowed to go off-line.

|

| One of my concerns is that Massachusetts is continuing to slip as an economic powerhouse,

| our young people are attracted to other areas. We do know that they are leaving because there

| are lower costs for housing, for health care and for energy costs. Businesses, such as mine

| and others, small and large, remain adversely affected by their monthly electric bills. As a

| number of you are aware, we had deregulation in Massachusetts approximately six years ago

| and our firm has, for example, already taken advantage of every energy efficient program and
Appendix A

July 2007 A-233 NUREG-1437, Supplement 29

product available for properties that we manage such as dialysis centers, women's health |

centers, breast care facilities, sewerage treatment plants and other residential properties that |

we manage. |

|

A number of businesses in Massachusetts, as we know and have enjoyed, have been engaged |

in research and development. We also have to think about the simple things, such as how do |

our supermarkets keep our food from spoiling as far as freezers are concerned, which run 24 |

hours a day, all of us enjoy going to the ATM, getting money out 24 hours a day, these things |

have to be run on electricity. We do have a number of hospitals that were in contact, they have |

inordinately high electric bills and most of them are operating, as we know, 24/7. |

|

All of us on the South Shore have enjoyed our way of life and I think we have to look at that as |

actually a result of cheap energy. Deregulation happened for business in 2000. In 2006, I've |

looked at my energy bills, as a businessman, and I'm sorry to say that I've watched, as I pay my |

bill to National Grid, that my kilowatt per hour cost has gone from 6 to 7 cents per kilowatt hour, |

to 2006, it's gone as high as 12 cents per kilowatt hour and, looking at the month of January, |

it's gone from 12 cents per kilowatt hour to 13.82 cents per kilowatt hour, that's a 17 percent |

increase this month. |

|

Now none of us probably should be alarmed, but what are we going to do when Pilgrim is off- |

line? As we have heard and as we know, we have had problems approving the wind energy |

program in the, off the coast and I look at Pilgrim as a plant that actually produces electricity at |

a lower kilowatt hour cost to us than a number of other alternatives. We cannot even approve a |

wind energy program when the Dutch have been using it for 800 years, we really have a |

problem and the problem is that we need to get beyond ourselves and we have to look at a |

situation where we have a reasonable cost of producing electricity and we have to be honest. |

|

The most significant accomplishment in Massachusetts, I'm sorry to say, in the last year, is |

young Joe Kennedy appearing on television thanking the, if you will, Communist leader of |

Venezuela, Hugo Chavez, for giving us free oil and lower cost oil to give to our poor and our |

elderly. I think that we really have a problem if that's one of our most significant energy |

accomplishments in Massachusetts. I do look at it as, and I've listened to a number of people, |

Pilgrim has produced jobs, the people that work at Pilgrim are our neighbors, we have been |

living with them for 35 years, there has been no issues. We do have cost effective power, they |

live beside us, what's the problem? |

|

And my greatest concern is that we in the United States continue to slide in comparison to other |

countries. We are looking at and we know from the Wall Street Journal that the Chinese are |

building 80 nuclear power plants, the French are building 20. I would rather have my future |

depend on the United States Nuclear Regulatory Commission than thinking about the Republic |

of Korea or thinking about a third world country developing nuclear power. I know the Nuclear |

Regulatory Commission has been criticized, I'm sorry for that, but obviously it's a great country |

and we can all disagree, but I think we all do finally agree that it is the best country around. |

|

|
Appendix A

NUREG-1437, Supplement 29 A-234 July 2007

| The people who built Pilgrim have done a better job, for example, that the Russians. The

| people who maintain Pilgrim have done a better job than anywhere else, I think we have to

| recognize it. I think we need to keep our children near us in Massachusetts, our grandchildren

| near us, and we now are dealing with the slow down, if you will, on the redevelopment of power

| plants. I am concerned about the workers who do work at the plant, we do have 400 or 500

| families, I would be very sorry to see them go.

|

| And I think we need to deal with the realization in fact of what are we going to do in 2012 when

| we have rolling brownouts, when we have them adversely effect hospitals, nursing homes,

| dialysis centers, and places where we buy our food and live our lives? We continue to slip

| because our costs for housing, health care and energy are not being replenished, we have to

| look at our situation realistically. Over 100 years ago, we all dammed up our rivers and that

| was a pretty big economic and environmental impact because we needed to create power to

| create jobs to run our mills, our manufacturing plants, and that's a problem that hasn't really

| hurt us either.

|

| I think we are dealing with obvious technological advancements, we are dealing with people

| who care about how the energy is produced, who live beside the plant, who live in our

| neighborhoods and I think we need to recognize that Pilgrim should be relicensed. Thank you.

|

| MR. CAMERON: Thank you very much, Bill. 

|

| Our next speaker is Kevin, Kevin Craig?

|

| MR. CRAIG: Thank you to the NRC for the opportunity to talk tonight, I'm going to try to limit

| my comments to what the NRC has done, what the staff have done specifically about the

| generic environmental impact statement because I don't think that this is an issue of whether

| the plant should be open or closed in the future, I think it's an issue of whether this statement

| has been adequately prepared, and whether all the issues have been adequately studied and

| whether there should be additional work done in terms of protecting the plant, so let's try to

| keep it at that level.

|

| I don't get this thing that's repeated often in the study which is there is no new information. It's

| repeated in several sections that specifically concern me because I see new information and

| the two sections of the report where I don't see acknowledgment of new and significant

| information that concern me is, one, the section that deals with the environmental impact of the

| fuel cycle's radioactive waste and the second section is the environmental impact postulated

| accidents. There are fixable issues here, even given the new information that I believe exists,

| but what the NRC needs to do, I believe, is expose these issues and then force resolution of the

| issues.

|

| And I believe that these issues are related to the aging process because they get worse as time

| goes on, the more that the plant operates, the worse they get. I mean one could make an

| argument that these issues are related to the routine operation of the plant, but a circuit board

| that's routinely operating over a period of 20 years and as it heats, and gets hotter, and more
Appendix A

July 2007 A-235 NUREG-1437, Supplement 29

brittle and eventually will break, something that happens in the spent fuel pool as a result of 20 |

additional years of operation that could increase the probability of an accident needs to be |

addressed because then I call it an aging issue. |

|

Now we might be splitting hairs in terms of the linguistics here, but here at are the two issues, |

one issue, the environmental impact of the fuel cycle's radioactive waste. There has always |

been a question of what's the environmental impact of large amounts of stored radioactive |

waste as a result of Pilgrim's operation from the current license as well as the renewed license, |

and what I'm referring to is the vast amount of harmful waste that's produced, excluding the |

fuel, spent fuel waste and the fuel rods. |

|

And the answer to this question has always been that it's satisfactorily addressed in these kinds |

of studies on a national level with scenarios that deploy off-site storage. So we just get it out of |

Pilgrim, off-site storage facilities and the possibility down the road of a yet to be determined |

Yucca Mountain Site, which we heard discussed earlier, but I think there is new and significant |

information that hasn't been taken into account that sort of nullifies these answers and these |

ways of sort of pushing the issues aside. |

|

First, we heard earlier about Yucca Mountain, it's not going to open as predicted for the |

disposal of the waste and I believe somebody said that one of the NRC commissioners is now |

acknowledging that. I think that's pretty new information in my mind. Certainly, if it ever does |

open, it isn't going to open as predicted, it's going to be a long period off which means you are |

going to have more and more waste stored up and it's going to have to stay on-site, I believe. |

Because of the second factor, this second piece of new information which is that an |

announcement has been made that there is going to be a closing of a key facility where this |

radioactive waste is dumped, that's a facility in South Carolina that's capable of taking this |

waste. |

|

This facility takes many classes of this waste, I guess this waste is broken up into four or five |

different classes, there is high level, there's mixed waste, and this plant takes it all or most of it. |

And these GEISs require that the analysis that the NRC accounts for the adverse impacts |

associated with this issue of radioactive waste and if no information is discovered in the GEIS, |

this is my understanding of the way this works, the generic environmental impact statement, |

then the issue is called settled, it's been settled at the national level and we don't have to deal |

with it here at Pilgrim. |

|

But if new information comes forward and it applies specifically to Pilgrim, which is what I'm |

contending here is that we've got the closure of these facilities, that's going to affect Pilgrim |

because we are not going to have a place to put this, there is no plan B here, then the issue is |

a Pilgrim issue and either the NRC or Entergy should acknowledge it and deal with it for the |

residents. |

|

I'm a resident here. By the way, Kevin Craig, I'm sorry, I didn't introduce myself. Kevin Craig, |

resident in Duxbury. I'm a member of the Duxbury Nuclear Advisory Committee, but I'm here |

on behalf of my neighbors and the citizens of this area. |
Appendix A

NUREG-1437, Supplement 29 A-236 July 2007

|

| So if the issue is local, then it's going to have to be assessed for obvious reasons and mitigated

| in this Pilgrim SEIS, that's my feeling. Either way you look at it, national or local, the issue has

| to be addressed and it wasn't, there was really no mention of this information. Both NRC and

| Entergy in this book kept stating that they are not aware of any new information that would

| effect the Pilgrim environment, I feel that this will effect the Pilgrim environment. What's the

| impact of this new information on this report? The primary impact of this information is that

| Pilgrim needs now to assess how much waste is going to be on-site, with the assumption that

| there is going to be a lack of off-site storage.

|

| The residents need a plan B, I need to know that somebody has thought through this, not to

| say, oh, we'll fix it later, it'll come. There has got to be a place for safe storage of this waste at

| the site, I want to see a plan for it because this could happen. The plan and assessment need

| to be evaluated in this SEIS report, that's my feeling. Furthermore, the quantification of this

| issue needs to be addressed in terms of volumes and curies of radioactive isotypes that will be

| coming out of the plant as a result of decommissioning, even after 2032, if the license were

| extended.

|

| It's not just an issue for the next 20 years, in my feeling, when you put this SEIS report

| together, you've got to think about what happens after decommissioning, assuming that we

| don't have a third renewal. The secondary impact of this new information on the SEIS report is

| that the quantities of radioactive waste are now an attractive target, if they are on-site here, for

| terrorists who are set on spreading dirty bomb contamination that's going to destroy the

| environment and harm the health of our citizens, which is what this environmental impact

| statement is all about.

|

| So there is a whole host of issues and additional mitigations that need to be addressed from

| this increased risk and the severe impact of terrorists targeting a build up of radioactive waste

| on the site as a result of a lack of places to put it around the country because, a, Yucca

| Mountain isn't going to go on schedule, b, this facility in South Carolina that takes many classes

| of this waste is closing. I think it's closing in 2008, this is the Barnwell, South Carolina. 

|

| I hope I have my facts right but I'm sure, this is what your job, is to take my facts and then sift

| through them.

|

| But I am happy to see that the NRC has acknowledged something that Pilgrim admitted which

| is that there is, with this radioactive waste, a "irreversible and irretrievable resource commitment

| needed", that's as far as things went in this report or in this application. The Pilgrim application

| for the license renewal lists this commitment that's needed for radioactive waste as simply, and

| I put this in quotes too because it's right in the application, "land is required to dispose of spent

| nuclear fuel and low level radioactive wastes". So this is the closest that the applicant's

| environmental report and the NRC's DSEIS came to addressing this issue, which I think has

| new and significant information. It's very disturbing to me that nobody has acknowledged it and

| made a plan B.

|
Appendix A

July 2007 A-237 NUREG-1437, Supplement 29

The second issue, environmental impact of postulated accidents, that's Section 5, is that right? |

Thanks. This involves spent fuel and specifically the above ground pool and, again, new and |

significant information here, no mention of it anywhere. I'm just stunned, absolutely stunned. |

The issue is that, what are the risks associated with a spent fuel pool accident? And the |

answer to this question has always been similar to the first one, that the issue has been |

satisfactorily assessed on a national level with scenarios that assess the possibility of some |

leakage from the spent fuel pool and, as well, the answer always involves that there will be, |

there is some normal amount of density of fuel in the pool and that a leakage will result in a |

manageable scenario. |

|

New information, in my opinion, new and significant information never acknowledged in here, |

number one, 9/11 event, the 9/11 event, plus discovery of nuclear facility files on computers of |

fundamental terrorist organizations changes everything for me. I think it changes the probability |

of a, what's referred to in the report as a postulated accident, it changes the scenario that's |

mapped out as a manageable pool leakage to a pool drainage or, at best, the elimination of |

circulation of the water in the pool which has, as you'll see, as you'll hear, disastrous |

consequences. |

|

The national, just to back up to this business about fundamental terrorist organizations, and I'm |

just not talking off the top of my head based on the headlines in the news, the National |

Commission on Terrorist Organizations issued a 2004 staff paper suggesting that al Qaeda |

initially included nuclear power plants among their expanded lists of targets, aside from the |

World Trade Center, the Pentagon, etcetera, for their 9/11 attacks. So this is a national |

commission that was put together after 9/11 that stated this. |

|

This new information, again, changes the whole scenario here, it doesn't take a classified |

intelligence report to figure out how determined individuals could cause these scenarios to take |

place right from our backyard, the Plymouth Municipal Airport or another nonmonitored airstrip |

in the region. I think this is also new information. Again, it's come since the GEIS was |

developed, it's come within just the last few years and it gives us an opportunity to reassess the |

possibility of a sabotage attempt as a higher possibility or a higher probability than was |

originally postulated when people went through these scenarios and said this is not an issue. |

|

Prior to 9/11, the NRC had no way of sort of estimating the likelihood of some sort of sabotage |

at a nuclear facility. As a matter of fact, I'm going to quote from a document, an NRC |

document, "there is no established method ... for quantitatively estimating the likelihood of a |

sabotage event at a nuclear facility". This is from a report from the NRC prior to 9/11, June, |

2001, a briefing on spent fuel three months prior to 9/11. Since then, again, new information. |

We have an attack, we have mention of nuclear facilities in al Qaeda documents and I think |

immediately even a statistician, who knows nothing about terrorism, says, oh, we have a |

probability, we have some probability we can estimate, so this is new information. |

|

Second, new and significant information on this issue of the spent fuel pool, the original GEIS |

assessed the fuel pool accident probability and impact or since the original GEIS assessed the |

probability and impact of spent fuel pool impact when it was assessed as a leakage that can be |
Appendix A

NUREG-1437, Supplement 29 A-238 July 2007

| managed, the Pilgrim, locally here, fuel rod densities have been increasing substantially due to

| the lack of off-site fuel rod storage and a lack of an approved on-site cask storage plan. At the

| same time, there are credible scientific reports, that are new and I think significant, that have

| been published that essentially state that above ground spent fuel pools are the most

| dangerous method of storage and when they are tightly packed, the danger increases.

|

| So the tight packing is new, the reports that this is a danger and the most dangerous form are

| new and the consequences of that packing, which I'll get to right here next, is also new. In

| 2005, a National Academy of Science report to Congress, which was a report that was

| sponsored by the NRC and the Department of Homeland Security, described a scenario with

| the partial loss of pool water where the fuel rod cladding or the casing of the fuel rod catches

| fire. 

|

| The first, this scenario was first described years ago by Sandia National Laboratory which is a

| very famous laboratory, so it's been described by several scientists is my point here but very

| recently by the NAS on behalf of the NRC and the Department of Homeland Security in a report

| to Congress.

|

| Other credible scientific reports found in the Journal of Science and Global Security, for

| example, have new and significant information of a more specific nature on this issue, they

| explain how a major human and environmental disaster would result from the overheating and

| burning of a protective fuel rod cladding in a densely packed pool. They describe how the fire

| could easily release, result in the release of massive amounts of radioactive product, cesium

| being the worst, and that, in its report that I referred to, to Congress, the estimate of cancer

| deaths from a typical scenario with a cesium release is from 2,000 to 6,000 deaths. I would say

| that's a significant impact.

|

| A full release would dwarf Chernobyl's release, based on the amount of cesium at Pilgrim. I

| believe it's, our spent fuel pool at Pilgrim has several times the amount of cesium that was in

| existence at Chernobyl and released at Chernobyl. The Massachusetts Attorney General has a

| report, and I think it was referred to by an earlier speaker, that describes the consequences of

| such an accident at Pilgrim, specific to Pilgrim, they are between, in these terms for somewhere

| between a 10 and 100 percent release of the cesium. 

|

| So, if 10 percent is released or 100 percent is released, somewhere in that range, this is the

| range of the consequences in that report for Pilgrim. The cost would be somewhere between

| $105 and $488 billion and the cancers would effect somewhere between 8,000 and 24,000

| people, that's significant. What's the impact of this business of the spent fuel pool and this new

| information on the SEIS report that we are talking about here tonight? Well it would seem that

| this new information raises a red flag, and this information has come forward only in recent

| years and it's directly applicable to Pilgrim's densely packed spent fuel pool, and it's going to

| get worse with age, the packing gets more intense.

|

| Both the applicant's environmental report and the NRC's DSEIS have stated there is no new

| and significant information on spent fuel that might impact the environment. There is mention
Appendix A

July 2007 A-239 NUREG-1437, Supplement 29

at some point, I think the previous speaker to me said that there was mention of something |

about the spent fuel pool and how there could be mitigation measures using dry cask storage |

and the like but, right now, as it begins to become packed, well prior to cask, dry cask storage |

being implemented, it is an increasing danger, the fire that we are referring to. |

|

So it was also surprising to me that I found out from this report to Congress recently that |

Entergy has begun studying the pool fire scenarios and even they said there is no new and |

significant information on spent fuel. |

|

So, summarizing again the second issue of the fuel pool, there is significant and new |

information, from my perspective, as follows, there is an increased probability of a spent fuel |

pool attack from the air, there's two very realistic scenarios that are deployable and that hinge |

on weak points in the building as well as local airstrip safety systems that are inadequate, but I |

won't discuss those, they are security issues. |

|

Two, an increase in the density of the pool's fuel rods, three, scientific reports that are fairly |

recent where everybody is beginning to acknowledge the severe human and environmental |

impact posed by an accident in a more densely packed pool, especially the above ground type |

of Pilgrim, I mean that's what's really the problem here. These are fixable problems, however, |

this is not a statement that we've got to shut the plant down tomorrow, these are fixable |

problems, but somebody has got to shine a spotlight on them and make sure that we start |

talking about a plan B, a resolution of these problems. |

|

So I urge you to consider this information for the sake of kids, and my neighbors and the |

citizens not just of Duxbury where I live, but Plymouth, and Kingston, and Marshfield and places |

20 miles beyond where if there was a severe accident, people would be effected for hundreds |

of miles, actually. |

|

Thank you. |



























































Appendix A

July 2007 A-299 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

PNPS-D-MM
Appendix A

NUREG-1437, Supplement 29 A-300 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-301 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-302 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-303 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-304 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-305 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-306 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-307 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-308 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-309 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-310 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-311 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-312 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-313 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-314 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-315 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-316 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-317 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-318 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-319 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-320 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-321 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-322 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-323 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-324 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-325 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-326 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-327 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-328 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-329 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-330 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-331 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-332 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-333 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-334 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-335 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-336 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-337 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-338 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-339 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-340 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-341 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-342 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-343 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-344 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

Appendix A

NUREG-1437, Supplement 29 A-346 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-347 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-348 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-349 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

NUREG-1437, Supplement 29 A-350 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix A

July 2007 A-351 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

















































Appendix B

Contributors to the Supplement

July 2007 B-1 NUREG-1437, Supplement 29

Appendix B

Contributors to the Supplement

The overall responsibility for the preparation of this supplement was assigned to the Office of

Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (NRC). The statement was

prepared by members of the Office of Nuclear Reactor Regulation with assistance from other

NRC organizations, Earth Tech, Inc. and Information Systems Laboratories, Inc.

Name Affiliation Function or Expertise

Nuclear Regulatory Commission

Alicia Williamson Nuclear Reactor Regulation Environmental Project Manager

Robert Schaaf Nuclear Reactor Regulation Technical Monitor

Rani Franovich Nuclear Reactor Regulation Branch Chief

Christian Jacobs Nuclear Reactor Regulation Project Management Support

Alicia Mullins Nuclear Reactor Regulation Project Management Support

Jason Flemming Nuclear Reactor Regulation Hydrology

Harriet Nash Nuclear Reactor Regulation Ecology

Dennis Logan Nuclear Reactor Regulation Ecology |

Elizabeth W exler Nuclear Reactor Regulation Ecology |

Jennifer Davis Nuclear Reactor Regulation Cultural Resources

Jeffrey Rikhoff Nuclear Reactor Regulation Socioeconomics

Richard Emch Nuclear Reactor Regulation Radiation Protection

Andrew Luu Nuclear Reactor Regulation Radiation Protection

Justin Leous Nuclear Reactor Regulation Alternatives |

Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation Alternatives

Earth Tech

Roberta Hurley Project Manager

John Szeligowski Technical Team Leader, Alternatives

Stephen Duda Lead Biologist

Stephen Dillard Terrestrial Ecology

Charles Flynn Radiation Protection

Andrew Parker Socioeconomics

Susan Provenzano Land Use

Michael Pappalardo Cultural Resources

Michael Spera W ater Quality

Nathan Craig Project Coordinator

Robert Dover Environmental Scientist

Kathleen Garvin Technical Editor

Nicole Spangler Project Management Support
Appendix B

Name Affiliation Function or Expertise

NUREG-1437, Supplement 29 B-2 July 2007

Earth Tech

| Katie Broom Project Management Support

Bonnie Freeman Administrative Support

Information Systems Laboratories

Robert Schimdt Severe Accident Mitigation Alternatives

Kim Green Severe Accident Mitigation Alternatives

Laurie Fleisher Severe Accident Mitigation Alternatives
Appendix C

Chronology of NRC Staff Environmental Review Correspondence

Related to Entergy Nuclear Operations, Inc.’s

Application for License Renewal of

Pilgrim Nuclear Power Station

July 2007 C-1 NUREG-1437, Supplement 29

Appendix C

Chronology of NRC Staff Environmental Review Correspondence

Related to Entergy Nuclear Operations, Inc.’s

Application for License Renewal of

Pilgrim Nuclear Power Station

This appendix contains a chronological listing of correspondence between the U.S. Nuclear

Regulatory Commission (NRC) and Entergy Nuclear Operations, Inc. (Entergy) and other

correspondence related to the NRC staff’s environmental review, under 10 CFR Part 51, of

Entergy’s application for renewal of the Pilgrim Nuclear Power Station (PNPS), operating

license. All documents, with the exception of those containing proprietary information, have

been placed in the Commission’s Public Document Room, at One White Flint North,

11555 Rockville Pike (first floor), Rockville, MD, and are available electronically from the Public

Electronic Reading Room found on the Internet at the following Web address:

<http://www.nrc.gov/reading-rm.html>. From this site, the public can gain access to the NRC’s

Agencywide Documents Access and Management System (ADAMS), which provides text and

image files of NRC’s public documents in the publicly available records component of ADAMS. 

The ADAMS accession number for each document is included below.

January 25, 2006 Letter from Mr. Michael A. Balduzzi, Entergy, to NRC submitting the

application for the renewal of the operating license for PNPS. 

(Accession No. ML060300026).

January 31, 2006 Letter from NRC to Mr. Michael R. Kansler, Entergy, regarding receipt

and availability of the License Renewal Application for PNPS. 

(Accession No. ML060310593).

January 31, 2006 NRC press release announcing the availability of the license renewal

application for PNPS. (Accession No. ML060310043).

February 6, 2006 Federal Register Notice of receipt of application for renewal of Facility

Operating License No. DPR-35 for an additional 20-year period 

(71 FR 6101).

March 21, 2006 Letter from NRC to Mr. Michael Kansler, Entergy, regarding

Determination of Acceptability and Sufficiency for Docketing, Proposed

Review Schedule, and Opportunity for a Hearing regarding the

Application from Entergy for Renewal of the Operating License for PNPS. 

(Accession No. ML060800745).
Appendix C

NUREG-1437, Supplement 29 C-2 July 2007

March 27, 2006 Federal Register Notice of acceptance for docketing of the application

and notice of opportunity for a hearing regarding the application for

license renewal of PNPS (71 FR 15220).

April 7, 2006 Letter from NRC to Mr. Michael R. Kansler, Entergy, regarding Notice Of

Intent to prepare an Environmental Impact Statement and conduct

Scoping Process for License Renewal for the PNPS (TAC NO. MC9676). 

(Accession No. ML061000261).

April 14, 2006 Federal Register Notice of Intent to Prepare an Environmental Impact

Statement and Conduct Scoping Process regarding the application for

license renewal of PNPS (71 FR 19554).

April 21, 2006 Letter from NRC to Mr. Michael Bowland, Mashantucket Tribal Council 

Office regarding request for comments on the PNPS License Renewal

Application Review. (Accession No. ML061170222).

April 21, 2006 Letter from NRC to Ms. Cheryl Andrews-Maltais, Wampanoag Tribe of

Gay Head-Aquinnah, regarding request for comments on the PNPS

License Renewal Application Review. (Accession No. ML061170152).

April 21, 2006 Letter from NRC to Mr. Sachem M. Thomas, Chief, Narragansett Indian

Tribe, regarding request for comments on the PNPS License Renewal

Application Review. (Accession No. ML061170085).

April 21, 2006 Letter from NRC to Ms. Jean McGinnis, Tribe Council, Mohegan Tribe,

regarding request for comments on the PNPS License Renewal

Application Review. (Accession No. ML061160613).

April 25, 2006 Letter from NRC to Mr. Peter Colosi, National Marine Fisheries Service,

regarding request for a list of protected species and essential fish habitat

within the area under evaluation for the PNPS License Renewal

Application Review. (Accession No. ML061160283).

April 25, 2006 Letter from NRC to Mr. Michael Bartlett, U.S. Fish and Wildlife Service,

regarding request for a list of the protected species within the area under

evaluation for the PNPS License Renewal Application Review. 

(Accession No. ML061160303).

May 2, 2006 Letter from NRC to Mr. Don L. Klima, Advisory Council on Historic

Preservation, regarding PNPS License Renewal Application Review. 

(Accession No. ML061240335).
Appendix C

July 2007 C-3 NUREG-1437, Supplement 29

May 11, 2006 Letter from NRC to Ms. Brona Simon, Massachusetts Historical

Commission, regarding the PNPS License Renewal Application Review

(SHPO No. RC36661). (Accession No. ML061310234).

May 22, 2006 Letter from NRC to Mr. Michael Kansler, Entergy, regarding Request for

Additional Information (RAI) pertaining to Severe Accident Mitigation

Alternatives (SAMA) for PNPS (TAC No. MC9676). 

(Accession No. ML061440026).

May 23, 2006 Letter from U.S. Fish and Wildlife Service, providing a response to the

April 25, 2006 NRC staff letter requesting a list of protected species within

the area under evaluation for license renewal of PNPS. 

(Accession No. ML061650016).

May 24, 2006 Letter from Advisory Council of Historic Preservation, Ms. Laura Henley

Dean, providing a response to NRC notice of the PNPS license renewal

application. (Accession No. ML061710601).

June 8, 2006 Letter from National Marine Fisheries Service, Mr. Peter Colosi, providing |

a response to the April 25, 2006 NRC staff letter requesting information

regarding protected species and essential fish habitat within the area

under evaluation for license renewal of PNPS. (Accession No.

ML061710600).

July 5, 2006 Letter from Stephen J. Bethay, Entergy to NRC Document Control Desk. 

Subject: License Renewal Application Amendment 4: Response to

Request for Additional Information Regarding Severe Accident Mitigation

Alternatives for Pilgrim Nuclear Power Station (TAC No. MC9676). 

(Accession No. ML061930418).

July 11, 2006 Letter from CZM, Ms. Susan Snow-Cotter, CZM Federal-Consistency

Review of the Pilgrim Nuclear Power Station Operating

License Renewal; Plymouth. (Accession No. ML062090362).

July 13, 2006 Summary of Public Scoping Meetings Conducted Related to the Review

of the PNPS, License Renewal Application (TAC No. MC9676). 

(Accession No. ML061700055).

July 25, 2006 Letter from NRC to Entergy Regarding Summary of Conference Calls to

Discuss the Severe Accident Mitigation Alternatives Requests for

Additional Information for Pilgrim (Accession No. ML062070295).
Appendix C

NUREG-1437, Supplement 29 C-4 July 2007

July 25, 2006 Letter from NRC to Entergy Regarding Summary of Environmental Site

Audit Related to the Review of the License Renewal Application for

Pilgrim. (Accession No. ML062070305).

July 25, 2006 Summary of Conferences Calls with Entergy Nuclear Operations, Inc., to

Discuss the Severe Accident Mitigation Alternatives Requests for

Additional Information for Pilgrim Nuclear Power Station (TAC NO.

MC9676). (Accession No. ML062070295).

August 23, 2006 Summary of Follow Up Conference Call with Entergy Nuclear Operations,

Inc., to Discuss the Severe Accident Mitigation Alternatives Requests for

Additional Information for Pilgrim Nuclear Power Station (TAC No.

MC9676). (Accession No. ML062360514).

September 26, 2006 Issuance of Environmental Scoping Summary Report Associated with the

Staff's Review of the Application by Entergy Nuclear Operations, Inc., for

Renewal of the Operating License for Pilgrim Nuclear Power Station. 

(Accession No. ML062710517).

October 24, 2006 Summary of Conference Call with Entergy Nuclear Operations, Inc, to

Discuss the Severe Accident Mitigation Alternatives Requests for

Additional Information for Pilgrim Nuclear Power Station. 

(Accession No. ML062890001).

| November 28, 2006 Letter from NRC to Mr. Michael Kansler, Entergy, regarding Request for

| Additional Information pertaining to Severe Accident Mitigation

| Alternatives for PNPS (TAC No. MC9676). 

| (Accession No. ML063280073).

|

| December 8, 2006 Letter from NRC to Mr. Michael Kansler, Entergy, regarding Notice of

| Availability of the draft plant specific Supplement 29 to the Generic

| Environmental Impact Statement for License Renewal of Nuclear Plants

| Regarding Pilgrim Nuclear Power Station (TAC No. 9676). 

| (Accession No. ML063410526).

|

| December 8, 2006 Letter from NRC to U.S. Environmental Protection Agency, Office of

| Federal Activities, NEPA Compliance Division, regarding Notice of

| Availability of the draft plant specific Supplement 29 to the Generic

| Environmental Impact Statement for License Renewal of Nuclear Plants

| Regarding Pilgrim Nuclear Power Station. (Accession No.

| ML063410326).

|
Appendix C

July 2007 C-5 NUREG-1437, Supplement 29

December 8, 2006 Letter from NRC to Mr. Peter D. Colosi, Assistant Regional Administrator |

for Habitat Conservation, National Marine Fisheries Service, Biological |

Assessment and Essential Fish Habitat Assessment for License Renewal |

of Pilgrim Nuclear Power Station. (Accession No. ML063390166). |

|

December 12, 2006 Letter from Stephen J. Bethay, Entergy to NRC Document Control Desk. |

Subject: License Renewal Application Amendment 10: Response to |

Request for Additional Information Regarding Severe Accident Mitigation |

Alternatives for Pilgrim Nuclear Power Station (TAC No. MC9676). |

(Accession No. ML070100410). |

|

December 14, 2006 Federal Register Notice of Availability of the draft plant specific |

Supplement 29 to the Generic Environmental Impact Statement for |

License Renewal of Nuclear Plants Regarding Pilgrim Nuclear Power |

Station (71 FR 75280). (Accession No. ML070330554). |

|

January 5, 2007 Letter from NRC to Ms. Brona Simon, Massachusetts Historical |

Commission, to NRC regarding the Pilgrim Nuclear Power Station |

License Renewal Application Review (SHPO No. RC36661). |

(Accession No. ML063480099). |

|

January 23, 2007 Letter from National Marine Fisheries Service, Mr. Peter D. Colosi, |

providing a response to the December 8, 2006 NRC staff letter regarding |

essential fish habitat within the area under evaluation for license renewal |

of Pilgrim Nuclear Power Station. (Accession No. ML070360071). |

|

February 8, 2007 Letter from Ms. Brona Simon, Massachusetts Historical Commission, to |

NRC regarding the Pilgrim Nuclear Power Station License Renewal |

Application Review (SHPO No. RC36661). |

(Accession No. ML070510463). |

|

March 1, 2007 Summary of Public Meetings on the Draft Supplemental Environmental |

Impact Statement Regarding the Pilgrim Nuclear Power Station, License |

Renewal Review. (Accession No. ML070590260). |

|

Appendix D

Organizations Contacted

July 2007 D-1 NUREG-1437, Supplement 29

Appendix D

Organizations Contacted

During the course of the staff’s independent review of environmental impacts from operations

during the renewal term, the following Federal, State, regional, local, and Native American tribal

agencies were contacted: 

Advisory Council on Historic Preservation, Office of Federal Agency Programs, Washington DC

Barnstable County, Massachusetts

Cape Cod Commission

Duxbury Free Library

Kingston Public Library

Mashantucket Tribal Council Office, Connecticut

Massachusetts Department of Environmental Protection

Massachusetts Department of Public Health

Massachusetts Department of Telecommunications and Energy

Massachusetts Division of Coastal Zone Management

Massachusetts Division of Energy Resources

Massachusetts Division of Fisheries and Wildlife

Massachusetts Division of Marine Fisheries

Massachusetts Environmental Policy Act Office

Massachusetts Historical Comission

Mohegan Tribe, Connecticut

Narrangansett Indian Tribe, Rhode Island
Appendix D

NUREG-1437, Supplement 29 D-2 July 2007

National Oceanic and Atmospheric Administration, National Marine Fisheries Service - Habitat

Conservation Division, Northeast Region

National Oceanic and Atmospheric Administration, National Marine Fisheries Service -

Protected Resource Division, Northeast Region

Old Colony Planning Council

Plymouth County Commissioners

Plymouth County, Massachusetts

Plymouth Public Library

Town of Carver, Massachusetts

Town of Duxbury, Massachusetts

Town of Kingston, Massachusetts

Town of Marshfield, Massachusetts

Town of Plymouth, Massachusetts 

U.S. Fish and Wildlife Service, New Hampshire

U.S. Environmental Protection Agency, Region I

Wampanoag Tribe of Gay Head-Aquinnah, Massachusetts
Appendix E

Pilgrim Nuclear Power Station

Compliance Status and Consultation Correspondence

July 2007 E-1 NUREG-1437, Supplement 29

Appendix E

Pilgrim Nuclear Power Station

Compliance Status and Consultation Correspondence

Correspondence received during the process of evaluation of the application for renewal of the

license for Pilgrim Nuclear Power Station (PNPS) is identified in Table E-1. Copies of the

correspondence are included at the end of this appendix.

The licenses, permits, consultations, and other approvals obtained from Federal, State,

regional, and local authorities for PNPS are listed in Table E-2. 

Table E-1. Consultation Correspondence 

Source Recipient Date of Letter

National Marine Fisheries Service

(M. A. Colligan)

Entergy Nuclear Generation

Company (S. Bethay)

March 4, 2005

U.S. Fish and Wildlife Service

(M. J. Amaral)

Entergy Nuclear Generation

Company (S. Bethay)

March 9, 2005

Massachusetts Historical

Commission (E. S. Johnson)

Entergy Nuclear Generation

Company (S. Bethay)

March 14, 2005

Massachusetts Division of Fisheries

& Wildlife (T. W. French)

Entergy Nuclear Generation

Company (S. Bethay)

April 8, 2005

U.S. Fish and Wildlife Service

(M. J. Amaral)

U.S. Nuclear Regulatory Commission

(R. Franovich)

May 23, 2006

Advisory Council on Historic

Preservation (L. H. Dean)

U.S. Nuclear Regulatory Commission

(R. Franovich)

May 24, 2006

National Marine Fisheries Service

(P. D. Colosi)

U.S. Nuclear Regulatory Commission

(R. Franovich)

June 8, 2006

Massachusetts Office of Coastal

Zone Management (S. Snow-Cotter)

Entergy Nuclear Generation

Company (S. Bethay)

July 11, 2006

U.S. Nuclear Regulatory |

Commission (R. Franovich) |

Entergy Nuclear Operations, Inc.

(Michael R. Kansler)

December 8, 2006

U.S. Nuclear Regulatory |

Commission (R. Franovich) |

U.S. Environmental Protection

Agency 

December 8, 2006

U.S. Nuclear Regulatory |

Commission (Pao-Tsin Kuo) |

National Marine Fisheries Service 

(P. D. Colosi)

December 8, 2006
Appendix E

NUREG-1437, Supplement 29 E-2 July 2007

| Table E-1. (contd)

|

| Source Recipient Date of Letter

| National Marine Fisheries Service

| (P. D. Colosi)

U.S. Nuclear Regulatory Commission

(P. T. Kuo)

January 23, 2007

| Massachusetts Historical

| Commission (B. Simon)

U.S. Nuclear Regulatory Commission

(R. Franovich)

February 8, 2007

| Massachusetts Historical

| Commission (B. Simon)

Entergy Nuclear Generation

Company (S> Bethay)

May 30, 2007
Table E-2. Federal, State, Local, and Regional Licenses, Permits, Consultations, and 

Other Approvals for Pilgrim Nuclear Power Station

Agency Authority Description Number

Issue

Date

Expiration

Date Remarks

NRC 10 CFR Part 50 Operating license DPR-35 09/15/72 06/08/12 Authorizes operationNRC 10 CFR Part 40 and 70 Material license 20-07626-04 02/10/03 02/28/13 Contamination on reactor

components

DOT | 49 CFR 107, Subpart G Registration 053006 550 005O 05/30/06 06/30/07 Radioactive and hazardous

materials shipment

EPA Clean Water Act

(33 USC 1251)

NPDES Permit Federal: MA0003557

Massachusetts: 359

04/29/91 04/29/96 Plant discharges into Cape Cod

Bay. Permit remains in effectpending EPA and Commonwealthaction on renewal applications.

FWS | Migratory Bird Treaty Act

(16 USC 703-712)

DepredationPermit

MB831184-0 07/01/06 06/30/07 Removal of birds, eggs and nests

from utility structures and property

FWS and NMFS Section 7 of the

Endangered Species Act(16 USC 1536)

Consultation Requires a Federal agency to

consult with FWS and NMFSregarding whether a proposedaction would affect endangered orthreatened species

MassachusettsDepartment ofEnvironmentalProtection

Clean Water ActSection 401(16 USC 470f)

Certification Requires a Commonwealth

certification that discharge wouldcomply with Clean Water Actstandards

MassachusettsHistoricalCommission

National HistoricPreservation Act Section 106

Consultation Requires a Federal agency to

consider cultural impacts andconsult with the State HistoricPreservation Officer

July 2007 E-3 NUREG-1437, Supplement 29

Appendix E
Table E-2. (contd)

Agency Authority Description Number

Issue

Date

Expiration

Date Remarks

MassachusettsOffice of CostalZone Management

Federal Costal ZoneManagement Act(16 USC 1451)

Certification Not Applicable 7/11/06 Requires an applicant to provide

certification to the Federal agencythat license renewal would beconsistent with the Federallyapproved state costal zonemanagement plan.

MassachusettsDepartment of PublicHealth

M.G.L. Chapter 111,Section 5N

Material License 07-6262 04/22/03 04/30/08 Containment on reactor

components

MassachusettsDepartment of PublicHealth

M.G.L. Chapter 111,Section 5N

Material License 49-0078 05/11/06 05/31/11 Containment on reactor |

components

MassachusettsDepartment of PublicSafety

M.G.L. Chapter 148,Section 13

Registration Not Applicable Storing flammable materials in

tanks

MassachusettsDepartment ofEnvironmentalProtection

310 CMR 7.02 (11)310 CMR 7.02 (11)(e)

50% FacilityEmission Cap

07/18/05 Emissions from various

combustion sources

MassachusettsDepartment ofEnvironmentalProtection

M.G.L. Chapter 21,Sections 26-53

GroundwaterDischarge Permit

#2-389 04/20/99 04/20/04 Treated effluent discharges to

groundwater from wastewatertreatment facility. Permitadministratively continued pendingreview of application

MassachusettsDepartment ofEnvironmentalProtection

M.G.L. Chapter 21C310 CMR 30

Large QuantityGenerator

MAR000014167 10/06/99 Hazardous waste generation

NUREG-1437, Supplement 29 E-4 July 2007

Appendix E
Table E-2. (contd)

Agency Authority Description Number

Issue

Date

Expiration

Date Remarks

South Carolina |

Department ofHealth andEnvironmentalControl

South CarolinaRadioactive WasteTransportation andDisposal Act (SC ST SEC13-7-110)

RadioactiveWaste TransportPermit

0007-20-07-X 12/12/06 12/31/07 Transportation of radioactive

waste to disposal facility in SouthCarolina

Tennessee |

Department ofEnvironment andConservation

TCA 68-202-206 Radioactive

Waste Licensefor-Delivery

T-MA004-L07 12/05/06 12/31/07 Shipment of radioactive waste to

disposal/processing facility inTennessee

CFR = Code of Federal RegulationsCMR = Code of Massachusetts RegulationsDOT = U.S. Department of TransportationEPA = U.S. Environmental Protection AgencyFWS = U.S. Fish and Wildlife ServiceM.G.L. = Massachusetts General LawsNMFS = National Marine Fisheries ServiceNRC = U.S. Nuclear Regulatory CommissionSC ST = South Carolina StatutesTCA = Tennessee Code AnnotatedUSC = United States Code

Appendix E

July 2007 E-5 NUREG-1437, Supplement 29
Appendix E

NUREG-1437, Supplement 29 E-6 July 2007
Appendix E

July 2007 E-7 NUREG-1437, Supplement 29
Appendix E

NUREG-1437, Supplement 29 E-8 July 2007
Appendix E

July 2007 E-9 NUREG-1437, Supplement 29
Appendix E

NUREG-1437, Supplement 29 E-10 July 2007
Appendix E

July 2007 E-11 NUREG-1437, Supplement 29
Appendix E

NUREG-1437, Supplement 29 E-12 July 2007
Appendix E

July 2007 E-13 NUREG-1437, Supplement 29
Appendix E

NUREG-1437, Supplement 29 E-14 July 2007
Appendix E

July 2007 E-15 NUREG-1437, Supplement 29
Appendix E

NUREG-1437, Supplement 29 E-16 July 2007
Appendix E

July 2007 E-17 NUREG-1437, Supplement 29
Appendix E

NUREG-1437, Supplement 29 E-18 July 2007
Appendix E

July 2007 E-19 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-20 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-21 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-22 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-23 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-24 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-25 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-26 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-27 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-28 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-29 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-30 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-31 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-32 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-33 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-34 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-35 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-36 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-37 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-38 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-39 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-40 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-41 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-42 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-43 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-44 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-45 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-46 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-47 NUREG-1437, Supplement 29

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

NUREG-1437, Supplement 29 E-48 July 2007

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|

|
Appendix E

July 2007 E-49 NUREG-1437, Supplement 29

Appendix E

Biological Assessment for

Pilgrim Nuclear Power Station
Appendix E

NUREG-1437, Supplement 29 E-50 July 2007

This Page Intentionally Left Blank
Appendix E

July 2007 E-51 NUREG-1437, Supplement 29

Biological Assessment

Pilgrim Nuclear Power Station

License Renewal

December 2006

Docket Number

50-293

U.S. Nuclear Regulatory Commission

Rockville, Maryland
Appendix E

NUREG-1437, Supplement 29 E-52 July 2007

Biological Assessment of the Potential Effects on Endangered or

Threatened Species from the Proposed License Renewal for the

Pilgrim Nuclear Power Station

1.0 Introduction

The U.S. Nuclear Regulatory Commission (NRC) issues operating licenses (OLs) for domestic

nuclear power plants in accordance with the provisions of the Atomic Energy Act of 1954, as

amended, and NRC implementing regulations. The purpose and need for this proposed action

(renewal of the OL for Pilgrim Nuclear Power Station [PNPS]) is to provide an option that

permits electric power generation to continue beyond the term of the current nuclear power

plant OL. This would allow future electric generating needs to be met, if the operator and State

regulatory agencies pursue that option.

The NRC is reviewing an application submitted by Entergy Nuclear Operations, Inc. (Entergy)

for the renewal of OL DPR-35 for PNPS for 20 years beyond the current OL expiration date. 

Entergy has prepared an Environmental Report (ER) as part of its application for the renewal of

the PNPS OL. The ER (Entergy 2006) addressed the requirements of the following NRC

regulations:

C Title 10, Energy, Code of Federal Regulations (CFR) Part 54, “Requirements for 

Renewal of Operating Licenses for Nuclear Power Plants,” Section 54.23, Contents of 

application – environmental information (10 CFR 54.23).

C Title 10, Energy, CFR Part 51, “Environmental Protection Regulations for Domestic 

Licensing and Related Regulatory Functions,” Section 51.53, Postconstruction 

environmental reports, Subsection 51.53(C), OL renewal stage [10 CFR 51.53(C)].

C Title 10, Energy, CFR Part 51, “Environmental Protection Regulations for Domestic 

Licensing and Related Regulatory Functions,” Section 51.45, Environmental reports – 

general requirements (10 CFR 51.45).

In addition, the ER addressed the underlying intent of the National Environmental Policy Act of

1969, as amended (NEPA), 42 USC 4321 et seq., and followed the guidance of Supplement 1

to Regulatory Guide 4.2 – Preparation of Supplemental Environmental Reports for Applications

to Renew Nuclear Power Plant Operating Licenses. In the ER, Entergy analyzed the

environmental impacts associated with the proposed license renewal action, considered

alternatives to the proposed action, and evaluated mitigation measures for reducing adverse

environmental effects. The NRC is using the ER and other information as the basis for a 
Appendix E

July 2007 E-53 NUREG-1437, Supplement 29

Supplemental Environmental Impact Statement, a plant-specific supplement to the Generic

Environmental Impact Statement for License Renewal of Nuclear Power Plants, NUREG-1437.

This biological assessment examines the potential effects of the continued operation of PNPS

on ten Federally listed species that could occur within the PNPS site or near the site. This

consultation is pursuant to Section 7(e)(2) of the Endangered Species Act of 1973, as amended

(ESA).

In a letter dated April 25, 2006, the NRC staff requested that the National Marine Fisheries

Service (NMFS) provide lists of Federally listed endangered or threatened species and

information on protected, proposed, and candidate species, as well as any designated critical

habitat, that may be in the vicinity of PNPS (NRC 2006). The project area is defined as the

PNPS site, adjacent areas of Cape Cod Bay, and approximately 7.2 miles (mi) of transmission

line right-of-way (ROW). Cape Cod Bay serves as the source of cooling water for the power

station. In a letter from the NMFS (NMFS 2006a), the NRC was provided with a list of Federally

protected species in the project area. A total of ten aquatic species under NMFS jurisdiction

that are afforded protection under the ESA, were identified as having the potential to inhabit the

project area.

2.0 The Proposed Federal Action

The proposed action is the renewal of the OL for PNPS. PNPS is located in the Town of

Plymouth, Plymouth County, Massachusetts, on the western shore of Cape Cod Bay. The

location of the facility, and the areas within 50-mi and 6-mi radii, are shown in Figures 2-1 and

2-2, respectively. The current OL expires on June 8, 2012. Entergy has submitted an

application to the NRC to renew this license for an additional 20 years of operation, until June 8,

2032.

There would be no major construction, refurbishment, or replacement activities associated with

the license renewal. If the NRC approves the license renewal application, the reactor and

support facilities, including the cooling system, would be expected to continue to be operated

and maintained until the renewed license expires in 2032. Maintenance activities would also

continue to be performed on the transmission lines that connect PNPS to the electric grid,

including inspection, surveillance, and vegetation management within the ROW.
Appendix E

NUREG-1437, Supplement 29 E-54 July 2007

Figure 2-1. Location of PNPS, 50-mile radius
Appendix E

July 2007 E-55 NUREG-1437, Supplement 29

Figure 2-2. PNPS, 6-mile radius
Appendix E

NUREG-1437, Supplement 29 E-56 July 2007

3.0 The Plant and Associated Transmission Line System

3.1 Reactor Systems

The principal facilities present at the PNPS site include the reactor and turbine buildings, an

offgas retention building, a radwaste building, a diesel generator building, an administration

building, the cooling water intake structure, and the main stack. The facility operates a single

reactor unit with a boiling water reactor design and turbine generator manufactured by General

Electric. The facility has a licensed output of 1998 megawatts-thermal and a current electrical

rating of 715 megawatts-electric. The fuel used by the facility is low-enriched uranium dioxide

with maximum enrichment of 4.6 percent by weight uranium-235 (Entergy 2006).

The primary containment for the reactor is a pressure suppression system that contains a

drywell, a pressure suppression chamber, a vent system, isolation valves, and a containment

cooling system connected to the water intake system. This system is enclosed within a

secondary containment structure (Entergy 2006).

3.2 Cooling and Auxiliary Water Systems

The cooling and service water systems at PNPS operate as a once-through cooling system,

with Cape Cod Bay being the water source. Seawater is withdrawn from the bay through an

intake embayment formed by two breakwaters (Figure 3-1). The intake structure consists of

wing walls, a skimmer wall that functions as a submerged baffle, slanted vertical trash racks that

capture large debris, vertical traveling screens to reduce entrainment, fish return sluiceways,

condenser cooling water pumps, and service water pumps (Figure 3-2). The two wing walls are

constructed of concrete, and guide flow into four separate intake bays. Each wing wall extends

from the face of the intake structure at a 45 degree angle, one at a distance of 130 feet (ft) to

the northwest and the other 63 ft to the northeast. The entrance of the intake measures 62 ft

wide at the stop log guide, and extends to the floor of the intake structure at 24 ft below mean

sea level (MSL). The skimmer wall at the front of the intake removes floating debris, with the

bottom of the wall extending to 12 ft below MSL. Fish are able to escape the system by way of

approximately 6 to 12 10-inch (in.) circular openings that are located in the skimmer walls and at

each end of the intake structure. Divers have visually verified that the escape openings are

effective. Bar racks behind the skimmer wall intercept large debris. The racks are constructed

of 3 in. by 3/8 in. rectangular bars, with a 3 in. opening between each bar. Debris and large,

impinged organisms are removed from the bar racks using a mechanical rake.

Located in the seawater pump wells of the intake structure, two vertical, mixed-flow, wet-type

pumps provide a continuous supply of condenser cooling water. Each 1450 horsepower (hp)

pump has a capacity of 155,500 gallons per minute (gpm) (346.5 cubic ft per second [cfs]).
Appendix E

July 2007 E-57 NUREG-1437, Supplement 29

Figure 3-1. Intake System Map
Appendix E

NUREG-1437, Supplement 29 E-58 July 2007

Figure 3-2. PNPS Intake Structure (Source: ENSR 2000)
Appendix E

July 2007 E-59 NUREG-1437, Supplement 29

The water is pumped from the intake structure to the condensers via two buried concrete pipes

measuring 7.5 ft in diameter. Measurements taken at the breakwaters during mid-tide level with

both pumps running indicate that the average intake velocity is 0.05 ft per second (fps). At the

intake, before the screens, the velocity is about 1 fps during all tidal conditions. Through the

traveling screens, the velocity is about 2 fps. The velocity is approximately 0.15 fps near the

end of the east fish-return sluiceway, which is located in the intake embayment just east of the

intake structure.

Located in the central wet well of the intake structure are five service water pumps that supply

the service water system. Generally, four pumps run while one is kept on standby. Each pump

has a capacity of 2500 gpm, providing a combined capacity at normal operation of

approximately 10,000 gpm. The service water system is continuously chlorinated in order to

control nuisance biological organisms in the service water discharge. Diffusers located

downstream of the trash or bar racks deliver a 12 percent sodium hypochlorite and seawater

mixture to each intake bay. The mixture is used to ensure the total residual chlorine discharge

concentration does not exceed a maximum daily concentration of 0.10 parts per million (ppm)

and an average monthly concentration of 0.5 ppm in the service water discharge. 

Chlorination of the main cooling water system also takes place, but not on a continuous basis. 

Hypochlorination events occur during spring, summer, and fall, when the circulating water

system is chlorinated for up to two hours per day (one hour for each pump). A chlorine solution

is added inboard of the trash rack to control fouling. 

From intake to discharge, the travel time for water to move through the system varies from 5 to

10 minutes, depending upon whether one or two intake pumps are in service. The tidal stage

affects pump output, also causing changes in the transit time. In addition to dye dilution studies

conducted in the 1980s, the transit time has been estimated during chlorination events. During

these chlorination events, chlorine is added outboard of the intake screens and monitored

readings are taken in the discharge canal. Residual chlorine is typically detected approximately

5 minutes into the cycle. Since the chlorination events are usually conducted only when both

pumps are running, it has been estimated that the transit time would be twice as fast when

operating only one pump.

Prior to water flowing through either the cooling water pumps or the service water pumps, water

passes through one of four 10-ft-wide traveling screens. The screens work to prevent small

debris and small aquatic organisms from being entrained into the cooling water or service water

systems. Each screen is constructed of 53 segments with 1⁄4 in. by 1⁄2 in. stainless steel wire

mesh. Each segment has a stainless steel lip that is used to lift debris and organisms and direct

them into the fish return sluiceway.
Appendix E

NUREG-1437, Supplement 29 E-60 July 2007

The traveling screens are not operated continuously but are operated during any of the

following scenarios:

• When the difference in water level on each side of the screen reaches a specified

threshold at an alarm set point. The threshold is typically set at 6 in. This level difference

signifies that too much debris has collected on the screen. Level differences are rare,

and usually the result of a storm event.

• When there is an indication that fish are being impinged at a rate exceeding 20 fish per

hour, at which time the traveling screens are turned continuously until the impingement

rate drops below 20 fish per hour for two consecutive sampling events. Each

impingement sampling event is conducted for a minimum of 30 minutes, 3 times per

week.

• During marine life monitoring. The screen wash which occurs during screen rotations, is

scheduled for eight hours prior to each of the three weekly sampling events.

• During hypo-chlorination, which occurs each day for two hours when the main cooling

water system is chlorinated inboard of the trash rack to control fouling.

• Whenever water temperatures are less than 30°Fahrenheit (F).

• At a minimum, once per each 12-hour shift. This usually occurs at the beginning and end

of each shift, and will usually last for a few hours.

On average, the traveling screens rotate 3 to 4 times each day. The screens normally operate

at 5 fps, but can be accelerated to 20 fps during storm events that are causing extreme debris

loading. 

The screens are washed when they are in operation, using a dual-level spray wash. Service

water is used as the source for the spray wash. Sodium thiosulfate is added to the wash water

to remove chlorine and protect organisms returned to the intake embayment. The screens are

washed from the side that faces the approaching flow at the splash housing, which is located

about 46 ft above the bottom of the intake structure. Low pressure spray, about 20 pounds per

square inch (psi), removes light fouling and organisms from the screen. Subsequently, a high

pressure wash, about 100 psi, is applied to remove heavy fouling. The low and high pressure

washes are about 18 to 24 inches apart. The screen rotation rate is kept slow during high

impingement events. 

Impinged fish are washed into a seamless concrete fish-return sluiceway and usually returned

to the intake embayment approximately 300 ft east of the intake structure. The original west

sluiceway was installed in 1972 and was connected to the discharge canal. In 1979, the east
Appendix E

July 2007 E-61 NUREG-1437, Supplement 29

sluiceway was installed and connected to the intake embayment. During storms, the wash is

discharged via the original sluiceway to the discharge canal. An interchangeable baffle plate is

utilized to divert the flow to one sluiceway or the other from the screenhouse. The baffle plate

will direct organisms and debris; however, some water will flow over this structure and into the

alternate sluiceway. The new sluiceway was designed to maintain a minimum 6-in. depth and a

water velocity of less than 8 fps and is covered with galvanized wire screen. Though there are

several turns in the sluiceway, none appear to be greater than 23 degrees. The discharge point

of the east sluiceway is at the mean low water (MLW) level. On occasion, the end of the east

sluiceway has been seen above the water level, causing an actual "free fall" scenario. The west

sluiceway discharge is above the MLW level in the discharge canal.

Under normal operation, seawater is heated in the condensers to approximately 27 to 30°F

above the intake temperature. This is within the plant's NPDES permit, which allows for as

much as a 32°F temperature change. With the cooling water flow being relatively constant at

311,040 gpm (693 cfs) throughout the year, the discharge temperature is almost entirely a

function of the intake water temperature. The permitted change in temperature across the

service water is 5 to 10°F. From the condensers, water flows through a buried concrete

conveyance to the discharge canal. The conveyance consists of 235 ft of 13 ft by 17 ft

reinforced concrete box culvert, followed by 250 ft of a concrete pipe that is 10.5 ft in diameter.

Three to five times each year, the plant is reduced to 50 percent power, and a thermal

backwash is conducted to control biological fouling. During the backwash, water is heated to

about 105°F, and two of the four traveling screens are rotated in reverse, allowing heated, nonchlorinated seawater from the condensers to flow back over the screens and to the intake

embayment. The treatment is maintained for about 35 minutes. Scheduling of the thermal

backwash treatments is coordinated with the highest tide to achieve maximum coverage,

preventing mussels from growing in the upper elevations of the intake structure.

Upon exiting the concrete pipe, discharged water enters a 900-foot-long trapezoidal discharge

canal separated from the intake embayment by a breakwater. The discharge canal is created by

two breakwaters that are oriented perpendicular to the shoreline, one of which is shared with

the intake embayment. The channel sides are sloped at a 2:1 horizontal to vertical ratio. The

bottom is 30 ft wide at an elevation of 0 ft MLW, or 4.8 ft below MSL. The channel bottom

remains at this elevation until it converges with the shore, which has a slope of approximately

40:1 at the channel mouth. At low tide, the water in the discharge canal is several feet higher

than sea level, and the discharge is rapid and turbulent (estimated at 8.1 fps). At high tide, the

velocity is much lower (estimated at 1.4 fps) because the cross sectional area of flow in the

channel is greater. Discharge of the heated water creates a thermal plume in the nearshore

area of PNPS.

Dredging of the discharge canal has never been conducted. The intake embayment has been

dredged twice, once in 1982 and again in the late 1990s. The purpose of dredging in the
Appendix E

NUREG-1437, Supplement 29 E-62 July 2007

1990s, though unsuccessful, was to bring colder water into the cooling water system. Each

dredging event was individually permitted through the U.S. Army Corps of Engineers (USACE). 

The potential dredge material was tested as part of the permit, undergoing chemical, biological,

and radiological analyses (see Section 2.2.5.2). The sediments were described as having

relatively low concentrations of the chemical parameters tested [polychlorinated biphenyls

(PCBs), polycyclic aromatic hydrocarbons (PAHs), pesticides, petroleum hydrocarbons, heavy

metals], and thus considered to be Category One material under the Massachusetts

Department of Environmental Protection (MDEP) dredged material classification guidelines and

being suitable for disposal (BSC Group 1996). Of the three potential categories of dredged

material, a Category One classification has the lowest amount of contaminants. The dredged

material was disposed of in open water, at the Massachusetts Bay Disposal Site, north of

Boston.

3.3 Power Transmission System

The facility is connected to the electric power grid by two transmission lines, referred to as the

342 line and the 355 line (Figure 3-3). The two lines share a single 300-ft-wide transmission

line ROW that extends from the PNPS switchyard approximately 5.0 mi to the Jordan Road Tap,

and then the ROW extends an additional 2.2 mi to the Snake Hill Road substation (Entergy

2006a; AEC 1972) (Figure 2-6). Over its 7.2 mi length, the ROW covers approximately 260 ac. 

The transmission line ROW does not cross any State or Federal parks, wildlife refuges, or

wildlife management areas (Entergy 2006a), nor does it cross any major lakes, ponds, or

streams. However, the transmission line crosses a small stream near Old Sandwich Road.

Entergy does not own, operate, or maintain the PNPS-to-Snake Hill Road transmission ROW or

transmission lines. The lines are owned and maintained by NSTAR, which provides electricity

and natural gas to businesses and residents in eastern Massachusetts (Entergy 2006a; NSTAR

2006). NSTAR maintains the transmission ROW in accordance with a Vegetation Management

Plan (NSTAR 2006) approved by the Massachusetts Department of Agricultural Resources and

the Natural Heritage and Endangered Species Program (NHESP). Under this plan, NSTAR

maintains the PNPS ROW from the station to the Snake Hill Road substation, as well as the rest

of their system, using an integrated vegetation management program. The ROW is managed

by NSTAR to encourage the natural development of low-growing woody shrubs and herbaceous

plant communities while controlling tall growing trees and undesirable shrub species that may

interfere with the operation of the transmission lines. The program is conducted in a manner to

protect wetland areas and sensitive plant communities that are crossed by the ROW, and the

timing of maintenance is scheduled with consideration of the life cycles of species located within

the ROW (Entergy 2006).
Appendix E

July 2007 E-63 NUREG-1437, Supplement 29

Figure 3-3. Transmission Lines
Appendix E

NUREG-1437, Supplement 29 E-64 July 2007

4.0 Aquatic Resources 

Aquatic resources in the vicinity of PNPS are associated with the marine environment within

Cape Cod Bay. The seawater of the bay is the source of the cooling water for the once-through

reactor cooling system of PNPS, as well as service water for the station. The bay also receives

the heated water discharged from the station. There are no other major water bodies on or

adjacent to the PNPS property, and there are no major water bodies crossed or paralleled by

the transmission line ROW.

Cape Cod Bay is a large embayment in southeastern Massachusetts that covers an area of

approximately 365,000 acres (Entergy 2006). The bay is open to the north to the Gulf of Maine,

and is enclosed by the mainland to the west and Cape Cod to the south and east. The volume

of the bay is approximately 36 million acre-ft (4.5 km3

) (Stone and Webster 1975 in ENSR

2000). Circulation patterns within the Gulf of Maine are counter-clockwise, resulting in a 

generally southward flow of cold ocean currents from the Labrador Current along the

Massachusetts coast (Tyrrell 2005).

Water depths in the vicinity of PNPS are typically 10 ft and up to 35 ft several mi offshore of the

site. The nearshore depths to the north of PNPS average approximately 12 ft deep. The

greatest depth, approximately 180 ft, occurs at the mouth of the bay. The bottom of the bay is

primarily mud (Tyrrell 2005), but the sea floor in the vicinity of PNPS is generally sandy, with

depths of approximately 21 ft offshore and to the south of PNPS (ENSR 2000).

The movement of water within Cape Cod Bay is controlled mainly by tidal exchange, ocean

circulation patterns, and wind (Entergy 2006). Ocean currents in the vicinity of the PNPS are

generally toward the south and are part of the large-scale, counterclockwise circulation pattern

within Massachusetts Bay. In contrast, tidal currents tend to rotate clockwise, completing one

revolution per tide cycle (EG&G 1995 in ENSR 2000). Historical investigations of current

velocities in Cape Cod Bay have indicated that net surface velocities range from 1.3 ft/min to as

much as 30.4 ft/min (ENSR 2000).

The aquatic habitat within Cape Cod Bay includes numerous species that are commercially,

recreationally, or ecologically important. The species present in the western portion of Cape

Cod Bay reflects a transition between the aquatic habitats in the Gulf of Maine to the north and

the Mid-Atlantic Bight to the south (Lawton et al. 1995 in ENSR 2000). Cape Cod is

approximately the southern boundary of the ranges of many northern Atlantic fish species and

the northern boundary of the ranges of many warmer water species (ENSR 2000). Because

PNPS is situated on an open part of the coast, and not within an estuary or embayment, the

species in the vicinity of the station are more typical of marine than of estuarine environments

(ENSR 2000).
Appendix E

July 2007 E-65 NUREG-1437, Supplement 29

5.0 Evaluation of Federally Listed Endangered and Threatened

Species

Ten Federally listed marine species could occur in Cape Cod Bay in the vicinity of PNPS. 

These include five whale species, four sea turtle species (NMFS 2006a), and one fish species

(Table 5-1). Protected marine species are those that are Federally protected under the ESA

and listed by the U.S. Fish and Wildlife Service (FWS) and/or the NMFS.

Table 5-1. Marine Aquatic Endangered and Threatened Species

Scientific Name Common Name Federal Status

TURTLES

Caretta caretta loggerhead turtle Threatened

Chelonia mydas green turtle Threatened

(endangered in FL)

Dermochelys coriacea leatherback turtle Endangered

Lepidochelys kempii Kemp’s ridley turtle Endangered

WHALES

Balaenoptera borealis sei whale Endangered

Balaenoptera physalus fin whale Endangered

Eubalaena glacialis North Atlantic right Endangered

Megaptera novaengliae humpback whale Endangered

Physeter catadon sperm whale Endangered

FISH

Acipenser brevirostrum shortnose sturgeon Endangered

Source: FWS 2006b

Many sea turtle species migrate north in summer months, and may be found in Cape Cod Bay

(Prescott 2000 in Entergy 2006). The loggerhead turtle (Caretta caretta) is the most common

visitor to Cape Cod Bay, followed by the leatherback (Dermochelys coriarea), green (Chelonia

mydas), and Kemp’s ridley (Lepidochelys kempii) turtles (Prescott 2000). In late fall and winter,

sea turtles still present in the Bay may become cold-stunned, and wash ashore (Entergy 2006). 

This typically includes fewer than 20 sea turtles in any given year. The largest incident

recorded was in the winter of 1999-2000, when a total of 277 sea turtles were found on Cape

Cod beaches (Entergy 2006). In 2003, the total number of turtles found stranded was 89 (Mass

Audubon 2005 in Entergy 2006). Records have been maintained on turtle strandings in

Massachusetts for 25 years, and in that time, only one sea turtle has been stranded in the

Plymouth area (Entergy 2006). This incident occurred in November 2003, when a small

(approximately 50 pounds) loggerhead sea turtle was stranded on Priscilla Beach approximately 
Appendix E

NUREG-1437, Supplement 29 E-66 July 2007

0.63 mi south of PNPS (Prescott 2005 in Entergy 2006). No impingement of sea turtles has

been observed at PNPS.

Six species of great whales, five of which are federally listed, migrate along the Massachusetts

coast, with the largest number sighted in the spring on Stellwagen Bank off of the tip of Cape

Cod (Entergy 2006). The most common species seen in this area are minke 

(Balaenoptera acutorostrata), fin (B. physalus), and humpback (Megaptera novaengliae) whales

(Entergy 2006). North Atlantic right whales (Eubalaena glacialis) may be found in

Massachusetts and Cape Cod Bays throughout the year (Brown et al. 2002 in Short and

Michelin 2006), and Cape Cod Bay has been designated as critical habitat for the species

(Entergy 2006). Sei whales (B. borealis) are rarely sighted in Massachusetts and Cape Cod

Bays (EPA 1993 in Short and Michelin 2006). Sperm whales (Physeter catadon) are deep

water whale that would not be expected in Cape Cod Bay (Provincetown Center for Coastal

Studies 2006).

The applicant has been monitoring aquatic communities in western Cape Cod Bay since 1969. 

No Federally endangered or threatened species have ever been observed in Cape Cod Bay

near PNPS, or in the facility intake and discharge areas, during the duration of these studies

(Entergy 2006).

Following are detailed discussions of the potential impacts of the proposed action on these ten

Federally listed species.

Loggerhead Turtle (Caretta caretta)

The loggerhead turtle is the most abundant species of sea turtle found in U.S. coastal waters

(NMFS 2006g). The species is Federally listed as threatened throughout its range, which

includes temperate and tropical regions in the Atlantic, Pacific, and Indian Oceans (NMFS

2006g). In the Atlantic, loggerhead turtles are found from Newfoundland to Argentina, with the

primary nesting sites in the U.S. ranging from North Carolina to southwest Florida (NMFS

2006g). The species can live in water temperatures as low as 11o

 Celsius (C) and can be

present in New England waters from June 1 to November 30, when water temperatures exceed

16o

C (NMFS 2006a).

Loggerhead turtles hatch on ocean beaches and immediately swim to offshore areas, where

they feed on floating items (NMFS 2006g). Once in the ocean, loggerheads live within the top 5

meters (m) (15 ft) of the water column and are carried by ocean currents. They live offshore for

a period of 7 to 12 years, at which time the juveniles migrate to nearshore coastal areas,

including bays, sounds, and estuaries in Massachusetts (NMFS 2006g). The species becomes

sexually mature and begins to mate at an age of about 35 years (NMFS 2006g). 
Appendix E

July 2007 E-67 NUREG-1437, Supplement 29

Population estimates are based on studies of the nesting populations, primarily in southeastern

Florida. Based on these studies, the population of loggerheads is thought to be declining

(NMFS 2006g). The primary threats to the species are incidental capture in fishing gear, and

continuing directed harvesting in some areas (NMFS 2006g). The species is protected by

various international agreements. In the U.S., NMFS is the lead agency for the sea turtles in

the marine environment, and FWS has jurisdiction over the nesting beaches. The species was

placed on the endangered species list in 1978, and in 1991, NMFS and FWS finalized a

recovery plan for loggerheads. Critical habitat has not been designated for the loggerhead

turtle (FWS 2006d).

No loggerhead turtle has ever been observed at PNPS. On the basis of this information, and

information previously provided for the aquatic resources in the vicinity of the plant, the staff has

determined that continued operation of PNPS over the 20-year renewal period would have no

effect on the loggerhead turtle.

Kemp’s Ridley Turtle (Lepidochelys kempii)

The Kemp’s ridley turtle is listed as endangered throughout its range, and is the most critically

endangered of the sea turtle species (FWS 2006). The range for the species includes the Gulf

of Mexico and the western Atlantic coast from the Gulf of Mexico to Newfoundland (FWS 2006). 

The primary nesting sites for the species are on the coast of Tamaulipas and Veracruz, Mexico;

some minor nesting has been known to occur in Texas, Florida, South Carolina, and North

Carolina (FWS 2006). The species can live in water temperatures as low as 11o

C, and can be

present in New England waters from June 1 to November 30, when water temperatures exceed

16o

C (NMFS 2006a).

After hatching, the juvenile turtles are dispersed throughout the Gulf of Mexico and Atlantic

Ocean by surficial ocean currents until they reach the age of about two years (FWS 2006b). 

From the age of two years, the turtles live within coastal shallow water habitats (FWS 2006b). 

The Kemp’s ridley turtle was placed on the endangered species list in 1970; critical habitat has

not been designated (FWS 2006b).

Population estimates for the species are based on inventories of nesting sites. The number of

nesting sites declined from over 40,000 in 1947 to a low of 702 in 1985, primarily due to direct

harvesting and entanglement in fishing equipment (FWS 2006b). Nest protection and

implementation of fishery regulations requiring turtle excluder devices have allowed a rebound

of the population, with more than 8,000 nests observed in 2003 (FWS 2006b).

No Kemp’s ridley turtle has ever been observed at PNPS. On the basis of this information, and

information previously provided for the aquatic resources in the vicinity of the plant, the staff has

determined that continued operation of PNPS over the 20-year renewal period would have no

effect on the Kemp’s ridley turtle.
Appendix E

NUREG-1437, Supplement 29 E-68 July 2007

Leatherback Turtle (Dermochelys coriacea)

The leatherback sea turtle is the largest of the sea turtles and can reach a weight of 2,000

pounds (NMFS 2006h). The species is listed as endangered throughout its range, which is

global (NMFS 2006h). In the U.S., leatherback turtles nest in Puerto Rico, the U.S. Virgin

Islands, and southeast Florida, and they have been found along the Atlantic coast as far north

as the Gulf of Maine (NMFS 2006h). Leatherback turtles are expected to be present in New

England waters in the summer months (NMFS 2006a).

Leatherback turtles are pelagic, but have been found to forage in coastal environments (NMFS

2006a). Nesting occurs on sandy beaches in tropical climates, with the largest nesting area

being northern South America and western Africa (NMFS 2006h). The primary prey for the

species is jellyfish (NMFS 2006h). The species is highly migratory, with adults known to nest in

South America and travel as far north as Nova Scotia (NMFS 2006h). 

Information on populations and trends is sparse because the adult females can nest on several

different beaches within one mating season (NMFS 2006h). In the Pacific, available data

suggest a decline of up to 80 percent in nesting populations. Nesting trends on U.S. beaches

have been increasing, but since these are relatively minor nesting grounds, they may not be a

good indicator of overall population trends (NMFS 2006h). The primary threats to the species

are directed harvest of eggs, juveniles, and adults during nesting, as well as incidental capture

in fishing gear (NMFS 2006h). The species is protected by various international agreements. 

The species was listed as endangered under the ESA in 1970 (FWS 2006c). Critical habitat is

designated for the leatherback turtle in locations within the U.S. Virgin Islands (NMFS 2006h).

No leatherback turtle has ever been observed at PNPS. On the basis of this information, and

information previously provided for the aquatic resources in the vicinity of the plant, the staff has

determined that continued operation of PNPS over the 20-year renewal period would have no

effect on the leatherback turtle.

Green Turtle (Chelonia mydas)

The green turtle is listed as endangered in breeding populations in Florida, and as threatened in

other areas of the U.S. (NMFS 2006i). The species’ range is global, including coastal areas in

tropical and subtropical climates (NMFS 2006i). In the U.S., the habitat includes inshore and

nearshore waters from Texas to Massachusetts (NMFS 2006i). The species becomes sexually

mature between the ages of 20 and 50 years, and females nest every 2 to 4 years on the same

beaches where they were born (NMFS 2006i). Nesting in the U.S. occurs in the southeastern

states and peaks in June and July (NMFS 2006i). Green turtles are expected to be present in

New England waters only sporadically (NMFS 2006a).
Appendix E

July 2007 E-69 NUREG-1437, Supplement 29

After hatching, juveniles swim to offshore areas and are pelagic for several years, feeding on

both plants and pelagic animals. As they grow larger, they move to inshore feeding areas, and

feed entirely on sea grass and algae (NMFS 2006i).

Population assessments indicate that there has been a decline of 48 to 65 percent in nesting

populations over the past 100 to 150 years (NMFS 2006i). The principal threats to the species

include harvesting of eggs and adults in nesting areas, harvesting of adults and juveniles in

feeding grounds, and incidental capture in fishing gear (NMFS 2006i). The species is protected

by various international agreements. The species was listed under the ESA in 1978 (FWS

2006a). Critical habitat is designated for the green turtle in one location in Puerto Rico 

(NMFS 2006i).

No green turtle has ever been observed at PNPS. On the basis of this information, and

information previously provided for the aquatic resources in the vicinity of the plant, the staff has

determined that continued operation of PNPS over the 20-year renewal period would have no

effect on the green sea turtle.

North Atlantic Right Whale (Eubalaena glacialis)

The North Atlantic right whale is the rarest of the large whale species, and is Federally listed as

endangered throughout its range. The International Whaling Commission has identified four

categories of right whale habitats, including feeding, calving, nursery, and breeding areas. 

Right whales primarily occur in coastal or shelf waters. During winter, calving occurs in low

latitudes, including the southeastern U.S. In spring and summer, the whales migrate to higher

latitudes, including the New England coast, for feeding and nursing (NMFS 2006b). New

England waters are considered to be a primary feeding ground for the right whale, with the

primary food source being copepods of the genera Calanus and Pseudocalanus (NMFS 2005).

This species was Federally listed as endangered in 1970. In 1994, NMFS designated three

areas as critical habitat for the western population of the North Atlantic right whale, with one of

the areas being Massachusetts Bay and Cape Cod Bay (NMFS 2006b). Right whales have

been documented in the nearshore waters of Massachusetts from December through June, and

are likely to be present in Cape Cod Bay from December 15 to April 15 (NMFS 2006a). Since

studies began 40 years ago, 72 percent of the catalogued population of right whales has been

documented to have visited Cape Cod Bay and Massachusetts Bay (Hamilton and Mayo 1990

in Short and Michelin 2006). The critical habitat for the right whale in Cape Cod Bay begins

approximately 3 mi east of PNPS and extends south and east to the coastline and north beyond

the tip of Cape Cod.

The right whale population within the western North Atlantic is estimated to number less than

300 individuals. A workshop convened by NMFS in 2002 to evaluate data on population trends

concluded that the population was decreasing (Clapham 2002), and the NMFS Office of
Appendix E

NUREG-1437, Supplement 29 E-70 July 2007

Protected Resources website references a recent model that predicts that the species will be

extinct within 200 years (NMFS 2006b). The primary human causes of serious injury and

mortality to the western population of the North Atlantic right whale are ship collisions and

entanglement in fishing gear. Habitat degradation, contamination, and climate and ecosystem

change are also possible threats to the population (NMFS 2005).

On the basis of this information and that previously provided for the aquatic resources in the

vicinity of the plant, the staff has determined that continued operation of PNPS over the 20-year

renewal period would have no effect on the North Atlantic right whale.

Humpback Whale (Megaptera novaengliae)

The humpback whale is Federally listed as endangered throughout its range and was placed on

the endangered species list in 1970 (FWS 2006f). Critical habitat has not been designated for

the humpback whale (FWS 2006f). There are four distinct stocks of humpback whales in U.S.

waters, including a Gulf of Maine stock. The Gulf of Maine stock was reclassified as a separate

stock from the North Atlantic stock following studies that showed that the population had a very

strong fidelity to the Gulf of Maine area, and genetic analyses that showed a substantial

separation of this population from other North Atlantic populations (NMFS 2005). This

information suggested that depletion of the Gulf of Maine subpopulation would not be mitigated

by migration from any of the other areas (NMFS 2005). Humpback whales inhabit shallow

water on continental shelves, with summer ranges close to shore, including major coastal

embayments (NMFS 2005). The Gulf of Maine stock mates and calves in the West Indies in

winter, but there are recent incidents of humpback whale strandings and sightings during this

time in the Chesapeake and Delaware Bays, along the Virginia and North Carolina coasts, and

in the southeastern U.S. (NMFS 2005).

Humpback whales may be found off of the coast of Massachusetts during the period from March

15 to November 30 (NMFS 2006a). Humpback whales are documented in the Stellwagen Bank

area from mid-April to November, with a peak abundance in May and June (CeTap 1982 in

Short and Michelin 2006). The population of humpback whales is known to change through

time in response to the availability of prey. In the 1970s, the population was seen to shift from

its historical location in the Gulf of Maine to more inshore areas, including the Stellwagen Bank. 

This shift was attributed to the collapse of the herring population due to overfishing in the Gulf of

Maine (Anthony and Waring 1980; and Grosslein et al. 1980 in Weinrich et al. 1997). By the 

mid 1990s, the population appeared to have shifted back to Jeffrey’s Ledge in response to

recovery of the herring population in that area (Weinrich et al. 1997).

The number of humpback whales in the North Atlantic population is approximately 11,500

(NMFS 2005), with approximately 900 whales within the Gulf of Maine stock (NMFS 2006f). 

The population data suggest that the Gulf of Maine stock is steadily increasing in size, but there

are not enough data to make a judgment regarding trends in the overall North Atlantic
Appendix E

July 2007 E-71 NUREG-1437, Supplement 29

population (NMFS 2005). Because they inhabit relatively shallow coastal waters, humpback

whales are susceptible to human activities, including subsistence hunting, entanglement in

fishing equipment, ship collisions, disturbance by noise, and possible impacts from pollution and

waste disposal (NMFS 2006f).

On the basis of this information, and information previously provided for the aquatic resources in

the vicinity of the plant, the staff has determined that continued operation of PNPS over the 20-

year renewal period would have no effect on the humpback whale.

Fin Whale (Balaenoptera physalus)

The fin whale is Federally listed as endangered throughout its range (NMFS 2006c) and was

placed on the endangered species list in 1970 (FWS 2006f). Critical habitat has not been

designated for this species (FWS 2006f). Fin whales are common from Cape Hatteras to Nova

Scotia, accounting for 46 percent of all large whale sightings in a study from 1978 to 1982

(CETAP 1982). The fin whale is reported to be the dominant species among cetaceans in all

seasons, based on having the largest population with the largest food requirements (NMFS

2005). Information on the calving, mating, and feeding grounds for fin whales is limited, but

New England waters are known to be a major feeding ground for the species (NMFS 2005). 

Data also suggest that there is substantial site fidelity in Massachusetts Bay and the Gulf of

Maine, with repeated sightings of individuals within the same year and throughout multiple years

(NMFS 2005). Fin whales are the most frequently sighted endangered whale species found in

Massachusetts and Cape Cod Bays (EPA 1993 in Short and Michelin 2006).

The fin whale population in the western North Atlantic is estimated to number approximately

2,814 individuals. There are not enough data upon which to identify population trends at this

time (NMFS 2005). The primary human cause of mortality is ship collisions, with an additional

component from entanglement in fishing gear NMFS 2005).

On the basis of this information, and information previously provided for the aquatic resources in

the vicinity of the plant, the staff has determined that continued operation of PNPS over the 20-

year renewal period would have no effect on the fin whale.

Sei Whale (Balaenoptera borealis)

The sei whale is Federally listed as endangered throughout its range (NMFS 2006e) and was

placed on the endangered species list in 1970 (FWS 2006f). Critical habitat has not been

designated for this species (FWS 2006f). The range of the sei whale covers the area from

Cape Hatteras to Nova Scotia, with a concentration of spring, summer, and fall feeding in the

Georges Bank area (NMFS 2005). Sei whales typically inhabit deep waters of the outer

continental shelf, in areas of water depth of about 2,000 m (6,560 ft) (NMFS 2005). However,

there are reports of episodic incursions into inshore waters, including the southern Gulf of Maine
Appendix E

NUREG-1437, Supplement 29 E-72 July 2007

(Schilling et al. 1993). Sei whales are only rarely sighted in Massachusetts and Cape Cod Bays

(EPA 1993 in Short and Michelin 2006).

The size of sei whale population in the U.S. Atlantic Exclusive Economic Zone is unknown. 

Studies from the 1970s and early 1980s indicated a population of up to 2,248 individuals, but

there are no recent data upon which to base current population trends (NMFS 2005). There are

very few reports of human-caused mortality or injury, and the few that exist are all related to

ship strikes (NMFS 2005).

On the basis of this information, and information previously provided for the aquatic resources in

the vicinity of the plant, the staff has determined that continued operation of PNPS over the 20

year renewal period would have no effect on the sei whale.

Sperm Whale (Physter macrocephalus)

The sperm whale is Federally listed as endangered throughout its range (NMFS 2006d) and

was placed on the endangered species list in 1970 (FWS 2006f). Critical habitat has not been

designated for this species (FWS 2006f). Five different stocks of sperm whales are recognized

in U.S. waters, including a North Atlantic stock. This population is concentrated east and

northeast of Cape Hatteras in the winter, shifts northward to east of Delaware and Virginia in the

spring, and is located offshore of New England in the summer and fall (NMFS 2005). The

sperm whale is primarily found in water greater than 600 m (1970 ft) deep and is rarely found in

water less than 300 m (984 ft) deep (NMFS 2006d). The sperm whale may be seasonally

present in New England waters, but is typically found in deeper offshore waters (NMFS 2006a).

The sperm whale population in the western North Atlantic is estimated to number approximately

4,700 individuals, and the total worldwide population is between 200,000 and 1,500,000

individuals (NMFS 2006d). The sperm whale was extensively hunted between 1800 and 1987,

with an estimate of about 1,000,000 whales taken (NMFS 2006d). Because the sperm whale

inhabits deeper waters farther from shore, they are suspected to be less susceptible than

coastal whale species to human-caused mortality and injury, including ship strikes, fishing, and 

pollutants (NMFS 2006d). There are currently not enough data upon which to determine

population trends (NMFS 2005). 

On the basis of this information, and information previously provided for the aquatic resources in

the vicinity of the plant, the staff has determined that continued operation of PNPS over the 20-

year renewal period would have no effect on the sperm whale.

Shortnose Sturgeon (Acipenser brevirostrum)

The shortnose sturgeon is Federally listed as endangered throughout its range (NMFS 2006j)

and was placed on the endangered species list in 1967 (FWS 2006c). Critical habitat has not
Appendix E

July 2007 E-73 NUREG-1437, Supplement 29

been designated for this species. The shortnose sturgeon is often confused with the Atlantic

sturgeon (Acipenser oxyrinchus), but the two species can be distinguished by comparing the

width of the mouths: the shortnose sturgeon has a much wider mouth than the Atlantic

sturgeon. The shortnose sturgeon is amphidromous, which indicates that the fish spawns in

freshwater but regularly enters marine habitats during its lifespan. The shortnose sturgeon

spawns in fast-flowing, rocky rivers in April and May. There are three known shortnose

sturgeon populations in Massachusetts: one in the Merrimack River in northeastern

Massachusetts and two in the Connecticut River in the western portion of the state. There are

no known occurrences of the shortnose sturgeon in the Town of Plymouth or the surrounding

area (NHESP 2006); no shortnose sturgeon has ever been observed at PNPS. 

On the basis of this information, and information previously provided for the aquatic resources in

the vicinity of the plant, the staff has determined that continued operation of PNPS over the 20-

year renewal period would have no effect on the shortnose sturgeon.

6.0 Conclusions

The staff has identified ten Federally listed endangered or threatened, species that are under

full or partial NMFS jurisdiction, that have a reasonable potential to occur in the vicinity of

PNPS, and, therefore, may be affected by continuing operations of PNPS. In addition, Entergy

has ongoing ecological studies and monitoring systems in place to evaluate the impact of the

facility on aquatic organisms and has not observed any interactions with any Federally

endangered or threatened species.

The NRC staff has evaluated the species that are likely to be present in the vicinity of PNPS,

the known distributions and habitat ranges of those species, the ecological impacts of the

operation of PNPS on the species, and the studies and mitigation measures that Entergy

employs to protect the species. Based on this analysis, the staff has determined that continued

operation of PNPS for an additional 20 years would not have any adverse impact on any

threatened or endangered marine aquatic species.

7.0 References

Anthony, V.C., and G. Waring. 1980. The assessment and management of the Georges Bank

herring fishery, Rapp. P.-V. Reun. Int. Explor. Mer 177: 72-111.

Atomic Energy Act of 1954 42 United States Code (USC) 2011, et seq.
Appendix E

NUREG-1437, Supplement 29 E-74 July 2007

Brown, M.W., O. Nichols, M.K. Marx, and J.N. Ciano. 2002. Surveillance monitoring and

management of North Atlantic right whales (Eubalaena glacialis) in Cape Cod Bay,

Massachusetts, Final Report to Division of Marine Fisheries, Commonwealth of Massachusetts,

and Massachusetts Environmental Trust, September 2002.

CETAP. 1982. A characterization of marine mammals and turtles in the mid- and north Atlantic

areas of the U.S. outer continental shelf, Cetacean and Turtle Assessment Program, University

of Rhode Island, Final Report #AA551-DT8-48 to the Bureau of Land Management,

Washington, D.C., 538 p.

Clapham, P.J., (ed.). 2002. Report of the Working Group on Survival Estimation for North

Atlantic Right Whales, available from the Northeast Fisheries Science Center, Woods Hole,

Massachusetts.

EG&G. 1995. Pilgrim Nuclear Power Station cooling water discharge bottom temperature

study, August 1994, Final report to Boston Edison Company, Plymouth, Massachusetts, 83 p.

Entergy. 2006. Applicant’s Environmental Report, Operating License Renewal Stage, Pilgrim

Nuclear Power Station, Appendix E to License Renewal Application, Docket No. 50-293,

License No. DPR-35, January 2006.

Environmental Protection Agency (EPA). 1993. Assessment of Potential Impact of the MWRA

Outfall on Endangered Species. Boston, MA. As cited in Short, L.M. and D Michelin. 2006. 

Summary of Marine Mammal Observations during 2005 Surveys. Boston: Massachusetts 

Water Resources Authority. Report ENQUAD 2006-04. P17.

Fish and Wildlife Service (FWS). 2006a. Green Sea Turtle Fact Sheet. Accessed at:

http://www.fws.gov/northflorida/SeaTurtles/Turtle%20factsheets/green-sea-turtle.html on

October 10, 2006.

Fish and Wildlife Service (FWS). 2006b. Kemp’s Fact Sheet, Kemp’s Ridley Sea Turtle

Recovery Plan. Accessed at: http://www.fws.gov/kempsridley/kempsfactsheet.html on October

10, 2006.

Fish and Wildlife Service (FWS). 2006c. Leatherback Sea Turtle Fact Sheet. Accessed at: 

http://www.fws.gov/northflorida/SeaTurtles/Turtle%20factsheets/leatherback-sea-turtle.html on

October 10, 2006.

Fish and Wildlife Service (FWS). 2006d. Loggerhead Sea Turtle Fact Sheet. Accessed at: 

http://www.fws.gov/northflorida/SeaTurtles/Turtle%20factsheets/loggerhead-sea-turtle.html on

October 10, 2006.
Appendix E

July 2007 E-75 NUREG-1437, Supplement 29

Fish and Wildlife Service (FWS). 2006e. Species Profile for Shortnose Sturgeon. Accessed at:

http://www.fws.gov//specie sprofile/servlet/gov.doi.species profile.servlets.Species on October

10, 2006.

Fish and Wildlife Service (FWS). 2006f. U.S. Listed Mammal Species Profiles 2, Endangered

Species, US Fish and Wildlife Service. Accessed at:

http://www.fws.gov/endangered/mammals2.html on October 10, 2006.

Grosslein, M.D., R.W. Langton, and M.P. Sissenwhine. 1980. Recent fluctuations in pelagic

fish stocks of the Northwest Atlantic Georges Bank region, in relation to species interactions,

Rapp. P.-V. Reun. Cons. Int. Explor. Mer 177, 377-404.

Hamilton, P.K., and C.A. Mayo. 1990. Population Characteristics of right whales, Eubalaena

glacialis, in Cape Cod Bay and Massachusetts Bay, 1978-1986. In Hammond, P.S., et al., eds.,

Individual Recognition and Estimation of Cetacean population parameters, Report of the

International Whaling Commission, Special Issue 12: 203-208.

Lawton, R.P., B.C. Kelly, V.J. Malkowski, and J. Chisholm. 1995. Annual report on monitoring

to assess impact of the Pilgrim Nuclear Power Station on selected finfish populations in western

Cape Cod Bay, Project Report No. 58 (January to December, 1994), IIIA.i-77. Marine Ecology

Studies Related to Operation of Pilgrim Station, Semi-annual Report No. 45, Boston Edison

Company.

Mass Audubon. 2003. Natural History: Sea Turtles on Cape Cod. Accessed at:

http://www.massaudubon.org/Nature_Connection/Sanctuaries/Wellfleet/seaturtles.php on

October 10, 2006.

National Marine Fisheries Service (NMFS). 2002. U.S. Atlantic and Gulf of Mexico Marine

Stock Assessments – 2002, Accessed at:

http://www.nmfs.noaa.gov/prot_res/PR2/StockAssessment_Program/sars.html#overview on

October 10, 2006.

National Marine Fisheries Service (NMFS). 2005. U.S. Atlantic and Gulf of Mexico Marine

Stock Assessments – 2005, NOAA Technical Memorandum NMFS-NE-194. Accessed at:

http://www.nefsc.noaa.gov/nefsc/publications, on October 10, 2006.

National Marine Fisheries Service (NMFS). 2006a. Letter from P. Colesi, Response to Request

for Information on Essential Fish Habitat and Protected Species, June 8, 2006.

National Marine Fisheries Service (NMFS). 2006b. Right Whale, Summary from NOAA

Fisheries, Office of Protected Resources. Accessed at:

http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/rightwhale on August 16, 2006.
Appendix E

NUREG-1437, Supplement 29 E-76 July 2007

National Marine Fisheries Service (NMFS). 2006c. Finback Whale, Summary from NOAA

Fisheries, Office of Protected Resources. Accessed at:

http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/finbackwhale on August 16, 2006.

National Marine Fisheries Service (NMFS). 2006d. Sperm Whale, Summary from NOAA

Fisheries, Office of Protected Resources. Accessed at:

http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/spermwhale on August 16, 2006.

National Marine Fisheries Service (NMFS). 2006e. Sei Whale, Summary from NOAA

Fisheries, Office of Protected Resources. Accessed at:

http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/seiwhale on August 16, 2006.

National Marine Fisheries Service (NMFS). 2006f. Humpback Whale, Summary from NOAA

Fisheries, Office of Protected Resources. Accessed at:

http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/humpback_whale on August 16,

2006.

National Marine Fisheries Service (NMFS). 2006g. Loggerhead Turtle, Summary from NOAA

Fisheries, Office of Protected Resources. Accessed at:

http://www.nmfs.noaa.gov/pr/species/turtles/loggerhead.htm on August 16, 2006.

National Marine Fisheries Service (NMFS). 2006h. Leatherback Turtle, Summary from NOAA

Fisheries, Office of Protected Resources. Accessed at:

http://www.nmfs.noaa.gov/pr/species/turtles/leatherback.htm on August 28, 2006.

National Marine Fisheries Service (NMFS). 2006i. Green Turtle, Summary from NOAA

Fisheries, Office of Protected Resources. Accessed at:

http://www.nmfs.noaa.gov/pr/species/turtles/green.htm on August 28, 2006.

National Marine Fisheries Service (NMFS). 2006j. Shortnose Sturgeon, Summary from NOAA

Fisheries, Office of Protected Resources. Accessed at:

http://www.nmfs.noaa.gov/pr/species/fish/shortnosesturgeon.htm on August 28, 2006.

Natural Heritage and Endangered Species Program (NHESP). 2006. Changes to the

Massachusetts List of Endangered, Threatened, & Special Concern Species. Accessed at 

www.mass.gov/dfwele/dfw/nhesp/heritage2.htm on May 24, 2006.

Nuclear Regulatory Commission (NRC). 2006. Letter from NRC to the National Marine

Fisheries Service, Requesting Information Regarding Essential Fish Habitat and Protected

Species, April 25, 2006.
Appendix E

July 2007 E-77 NUREG-1437, Supplement 29

Prescott, R. 2000. Sea Turtles in New England Waters. Conservation Perspectives, the on-line

journal of the Massachusetts Chapter of the Society for Conservation Biology. October 2000. 

Accessed at: http://www.masscb.org/epublications/october2000/seaturtle.html on August 28,

2006.

Prescott, R. 2005. January 15, 2005. Provincetown Center for Coastal Studies. 2006. 

Accessed at: http://www.coastalstudies.org on September 28, 2006.

Provincetown Center for Coastal Studies. 2006. Other Species. Accessed at:

http://www.coastalstudies.org/what-we-do/education-programs/whale-watching/large-whales. 

on October 16, 2006.

Schilling, M.R., I. Seipt, M.T. Weinrich, S.E. Frohock, A.E. Kuhlberg, and P.J. Clapham. 1993.

Behavior of individually identified Sei Whales, Balaenoptera borealis, during an episodic influx

into the southern Gulf of Maine in 1986, Fish. Bull., U.S., 90(4):749-755.

Short, L.M., and D. Michelin. 2006. Summary of Marine Mammal Observations During 2005

Surveys for MWRA Harbor and Outfall Monitoring Project, Report No. 2006-04, submitted by

Battelle to Massachusetts Water Resources Authority. March 7, 2006.

Stone and Webster Engineering Corporation. 1975. 316 Demonstration, Pilgrim Nuclear Power

Station – Units 1 and 2. Prepared for Boston Edison Company, Boston, Massachusetts.

Tyrrell, M.C. 2005. Gulf of Maine Habitat Primer, Gulf of Maine Council on the Marine

Environment. Accessed at: http://www.gulfofmaine.org/habitatprimer/ on August 28, 2006.

Weinrich, M., M. Martin, R. Griffiths, J. Bove, and M. Schilling. 1997. A shift in distribution of

humpback whales, Megaptera novaeangliae, in response to prey in the southern Gulf of Maine,

Fishery Bulletin 95: 826-836.
Appendix E

July 2007 E-78 NUREG-1437, Supplement 29

This Page Intentionally Left Blank
Appendix E

NUREG-1437, Supplement 29 E-79 July 2007

Appendix E

Essential Fish Habitat Assessment

Pilgrim Nuclear Power Station
Appendix E

NUREG-1437, Supplement 29 E-80 July 2007

Essential Fish Habitat Assessment

Pilgrim Nuclear Power Station

License Renewal

Docket Number

50-293

U.S. Nuclear Regulatory Commission

Rockville, Maryland

December 2006
Appendix E

July 2007 E-81 NUREG-1437, Supplement 29

Assessment of the Potential Effects on Essential Fish Habitat 

from the Proposed License Renewal for the 

Pilgrim Nuclear Power Station

1.0 Introduction

The U.S. Nuclear Regulatory Commission (NRC) issues licenses for domestic nuclear power

plants in accordance with the provisions of the Atomic Energy Act of 1954, as amended, and

NRC implementing regulations. The NRC is reviewing an application submitted by Entergy

Nuclear Generation Company (the applicant) for the renewal of Operating License (OL) DPR-35

for Pilgrim Nuclear Power Station (PNPS) for 20 years beyond the current operating license

expiration date. The current OL will expire at midnight on June 8, 2012. Entergy has submitted

an application to the NRC to renew this license for an additional 20 years of operation, until

June 8, 2032, and the proposed action evaluated in this assessment is the renewal of the OL.

The 1996 amendments to the Magnuson-Stevens Fishery Conservation and Management Act

(MSA) identified the importance of habitat protection to healthy fisheries. The amendments

known as the Sustainable Fisheries Act, strengthened the governing agencies’ authority to

protect and conserve the habitat of marine, estuarine, and anadromous animals (NEFMC 1999). 

Essential Fish Habitat (EFH) is defined as those waters and substrate necessary for spawning,

breeding, feeding, or growth to maturity (Magnuson-Stevens Act, 16 USC 1801 et seq). 

Identifying EFH is an essential component in the development of Fishery Management Plans

(FMPs) to evaluate the effects of habitat loss or degradation on fishery stocks and take actions

to mitigate such damage. This responsibility was expanded to ensure additional habitat

protection (NMFS 1999). The consultation requirements of Section 305(b) of the MSA provide

that Federal agencies consult with the Secretary of Commerce on all actions, or proposed

actions, authorized, funded, or undertaken by the agency, that may adversely affect EFH.

PNPS is located in the Town of Plymouth, Plymouth County, Massachusetts, on the western

shore of Cape Cod Bay. Cape Cod Bay serves as the source of cooling water for PNPS, and

discharge water is discharged into the bay. Pursuant to the Endangered Species Act, a

biological assessment regarding license renewal of PNPS has been provided to the National

Marine Fisheries Service (NMFS).

On May 16, 2006, NRC staff met with NMFS staff to discuss the EFH consultation process. 

Discussions included a description of the overall re-licensing process and requirements for the

EFH assessment. Additionally a letter was received from the NMFS on June 8, 2006

documenting some of the NMFS’s requirements regarding the EFH assessment. 
Appendix E

NUREG-1437, Supplement 29 E-82 July 2007

2.0 Proposed Federal Action

The proposed action is the renewal of the OL for PNPS. If approved and issued by the NRC,

the renewed OL would allow up to 20 additional years of plant operation beyond the current

licensed operating term. The renewed OL would be issued well in advance of the current OL’s

expiration date and would replace the existing OL. Therefore, if issued, the new PNPS OL

would expire in 2032. No major refurbishment or replacement of important systems, structures,

or components is expected during the 20-year PNPS license renewal term. In addition, no

construction activities are expected to be associated with license renewal. If the NRC renews

the license, the reactors and support facilities, including the cooling system, would be expected

to continue to be operated and maintained until the renewed license expires in 2032.

3.0 Environmental Setting

The location of the facility, the areas within 50-mi and 6-mi radii, are shown in Figures 3-1 and

3-2, respectively. PNPS is located approximately 38 mi southwest of Boston, Massachusetts

and 44 mi east of Providence, Rhode Island. The area within a 6-mi radius of the facility

includes the town of Plymouth. Most of the area within the 6-mi radius is open water within

Cape Cod Bay. 

The facility, shown in Figure 3-3, comprises an area of approximately 140 ac. An additional

1500 ac of adjacent property owned by Entergy is in a forest management trust. One tract of

privately owned land is contained within the Entergy land holdings, but it is located outside of

the NRC-mandated, 1800-foot buffer between the reactor and the nearest residence.

Aquatic resources in the vicinity of PNPS are associated with the marine environment within

Cape Cod Bay. The seawater of the bay is the source of the cooling water for the once-through

reactor cooling system of PNPS, as well as service water for the station. The bay also receives

the heated water discharged from the station. There are no other major water bodies on or

adjacent to the PNPS property, and there are no major water bodies crossed or paralleled by

the transmission line right-of-way.

Cape Cod Bay is a large embayment in southeastern Massachusetts that covers an area of

approximately 365,000 ac (1,477 km2

) (Entergy 2006a). The bay is open to the north, and is

enclosed by the mainland to the west and Cape Cod to the south and east. The volume of the

bay is approximately 36 million acre-feet (4.5 km3

) (Stone and Webster 1975 in ENSR 2000).

Water depths in the vicinity of PNPS are typically 10 ft (3 m) and up to 35 ft (10.7 m) several

miles offshore of the site. The nearshore depths to the north of PNPS average approximately 12

ft (3.7 m) deep. The greatest depth, approximately 180 ft (54.9 m), occurs at the mouth of the

bay.
Appendix E

July 2007 E-83 NUREG-1437, Supplement 29

Figure 3-1. Location of PNPS, 50-mi Radius
Appendix E

NUREG-1437, Supplement 29 E-84 July 2007

Figure 3-2. Location of PNPS, 6-mi Radius 
Appendix E

July 2007 E-85 NUREG-1437, Supplement 29

Figure 3-3. Aerial Photograph Showing PNPS 

Property Boundaries and Environs.
Appendix E

NUREG-1437, Supplement 29 E-86 July 2007

The bottom is mainly unconsolidated sediment, finer in deeper waters than near shore (Bridges

and Anderson 1984 in ENSR 2000). The sea floor in the vicinity of PNPS is generally sandy,

with depths of approximately 21 feet offshore and to the south of PNPS. Two shallow rocky

ledges bracket the PNPS area. One ledge extends northward from Rocky Point near the

northern tip of the PNPS property. The other ledge also extends northward for several hundred

meters from the vicinity of Manomet Point (ENSR 2000, Davis and McGrath 1984).

The movement of water within Cape Cod Bay is controlled mainly by tidal exchange, ocean

circulation patterns, and wind (Entergy 2006a). Ocean currents in the vicinity of PNPS are

generally toward the south and are part of the large-scale, counterclockwise circulation pattern

within Massachusetts Bay. In contrast, tidal currents tend to rotate clockwise, completing one

revolution per tide cycle (EG&G 1995 in ENSR 2000). Historical investigations of current

velocities in Cape Cod Bay have indicated that net surface velocities range from 1.3 ft/min (0.7

cm/sec) to as much as 30.4 ft/min (15.4 cm/sec) (ENSR 2000).

Water temperature measurements have been collected by the Massachusetts Water Resources

Authority (MWRA) in Boston Harbor, Massachusetts Bay, and Cape Cod Bay from 1989 through

2004. Over the 15 year period, temperatures have remained fairly consistent, ranging from

approximately 2°Celsius (C) (in mid-winter) to 22°C (in mid-summer) in the near-surface water

and approximately 3°C (in mid-winter) to approximately 12°C (in mid-summer) in the nearbottom water (Libby et al. 2006). Large fluctuations during the summer are typical, resulting

from upwelling-downwelling fluctuations as well as short-lived wind-mixing events (Libby et al.

2006). 

As reported in ENSR (2000), during 1996 at a mooring in Massachusetts Bay, the salinity at the

bottom of the water column remained relatively consistent at 31-32 parts per thousand (ppt)

throughout the year, while the salinity of the surface waters varied from approximately 28 ppt

from late spring to early fall, to approximately 31 ppt during the remainder of the year. It is

expected that salinities in the immediate nearshore vicinity of PNPS would be similar. 

Dissolved oxygen (DO) concentrations in the water column of Cape Cod Bay are highest during

the winter and early spring when oxygen is well mixed throughout the water column. DO

measurements have been collected throughout the Massachusetts Bay/Cape Cod Bay system

since 1992 by the MWRA (Libby et al. 2006). Monitoring results from this program indicate that

the DO varies significantly throughout the year, with values in 2004 ranging from approximately

11 mg/L in March of 2004 to a low of approximately 7.5 mg/L in Cape Cod Bay during early fall

(Libby et al. 2006). In general, the DO at the bottom is less than at the surface by 1 to 2 mg/L

throughout the year (Galya et al. 1997 in ENSR 2000).

Cape Cod Bay provides habitat for numerous commercially, recreationally, or ecologically

important species. The species present in western Cape Cod Bay reflect a transition between

the aquatic habitats in the Gulf of Maine to the north and the Mid-Atlantic Bight to the south via
Appendix E

July 2007 E-87 NUREG-1437, Supplement 29

the Cape Cod canal (Lawton et al. 1995 in ENSR 2000). Cape Cod is approximately the

southern boundary of the ranges of many northern Atlantic fish species and the northern

boundary of the ranges of many warmer water species (ENSR 2000). Because PNPS is

situated on an open part of the coast, and not within an estuary or embayment, the species in

the vicinity of the station are more typical of marine than of estuarine environments (ENSR

2000).

4.0 The Plant and Cooling Water Systems

This section describes the structures and operations of PNPS.

4.1 Reactor Systems

The principal facilities present at the PNPS site include the reactor and turbine buildings, an

offgas retention building, a radwaste building, a diesel generator building, an administration

building, the cooling water intake structure, and the main stack. The facility operates a single

reactor unit with a boiling water reactor design and turbine generator manufactured by General

Electric. The facility has a licensed output of 1,998 megawatts-thermal and a current electrical

rating of 715 megawatts-electric. The fuel used by the facility is low-enriched uranium dioxide

with maximum enrichment of 4.6 percent by weight uranium-235 (Entergy 2006a).

4.2 Cooling and Auxiliary Water Systems

The cooling and service water systems at PNPS operate as a once-through cooling system,

with Cape Cod Bay being the water source. Seawater is withdrawn from the Bay through an

intake embayment formed by two breakwaters (Figure 4-1). The intake structure consists of

wing walls, a skimmer wall that functions as a submerged baffle, slanted vertical bar racks that

capture large debris, vertical traveling screens to prevent entrainment, fish return sluiceways,

condenser cooling water pumps, and service water pumps (Figure 4-2). The two wing walls are

constructed of concrete and guide flow into four separate intake bays. Each wing wall extends

from the face of the intake structure at a 45 degree angle, one at a distance of 130 ft to the

northwest and the other 63 ft to the northeast. The entrance of the intake measures 62 ft wide at

the stop log guide, and extends to the floor of the intake structure at 24 ft below mean sea level

(MSL). The skimmer wall at the front of the intake removes floating debris, with the bottom of

the wall extending to 12 feet below MSL. Fish are able to escape the system by way of

approximately 6 to12 10-in circular openings that are located in the skimmer walls and at each

end of the intake structure. Divers have visually verified the effectiveness of the escape

openings. Bar racks behind the skimmer wall intercept large debris. The racks are constructed

of 3 in. by 3/8 in. rectangular bars, with a 3 in. opening between each bar. Debris and large,

impinged organisms are removed from the bar racks using a mechanical rake.
Appendix E

NUREG-1437, Supplement 29 E-88 July 2007

Figure 4-1. Intake System Map
Appendix E

July 2007 E-89 NUREG-1437, Supplement 29

Figure 4-2. PNPS Intake Structure (Source: ENSR 2000)
Appendix E

NUREG-1437, Supplement 29 E-90 July 2007

Located in the seawater pump wells of the intake structure, two vertical, mixed-flow, wet-type

pumps provide a continuous supply of condenser cooling water. Each 1450 horsepower (hp)

pump has a capacity of 155,500 gallons per minute (gpm) (346.5 cubic feet per second [cfs]).

The water is pumped from the intake structure to the condensers via two buried concrete pipes

measuring 7.5 ft in diameter. Measurements taken at the breakwaters during mid-tide level with

both pumps running indicate that the average intake velocity is 0.05 ft per second (fps). At the

intake, before the screens, the velocity is about 1 fps during all tidal conditions. Through the

traveling screens, the velocity is about 2 fps. The velocity is approximately 0.15 fps near the

end of the east fish-return sluiceway, which is located in the intake embayment just east of the

intake structure.

Located in the central wet well of the intake structure are five service water pumps that supply

the service water system. Generally, four pumps run while one is kept on standby. Each pump

has a capacity of 2500 gpm, providing a combined capacity at normal operation of

approximately 10,000 gpm. The service water system is continuously chlorinated in order to

control nuisance biological organisms in the service water discharge. Diffusers located

downstream of the bar racks deliver a 12 percent sodium hypochlorite and seawater mixture to

each intake bay. The mixture is used to ensure the total residual chlorine (TRC) discharge

concentration does not exceed a maximum daily concentration of 0.10 parts per million (ppm)

and an average monthly concentration of 0.5 ppm in the service water discharge. 

Chlorination of the main cooling water system also takes place, but not on a continuous basis. 

Hypochlorination events occur during spring, summer, and fall, when the circulating water

system is chlorinated for up to two hours per day (one hour for each pump). A chlorine solution

is added inboard of the trash rack to control fouling. 

From intake to discharge, the travel time for water to move through the system varies from 5 to

10 minutes, depending upon whether one or two intake pumps are in service. The tidal stage

affects pump output, also causing changes in the transit time. In addition to dye dilution studies

conducted in the 1980s, the transit time has been estimated during chlorination events. During

these chlorination events, chlorine is added outboard of the intake screens and monitored

readings are taken in the discharge canal. Residual chlorine is typically detected approximately

five minutes into the cycle. Since the chlorination events are usually conducted only when both

pumps are running, it has been estimated that the transit time would be twice as fast when

operating only one pump.

Prior to water flowing through either the cooling water pumps or the service water pumps, water

passes through one of four 10-ft-wide traveling screens. The screens work to prevent small

debris and small aquatic organisms from being entrained into the cooling water or service water

systems. Each screen is constructed of 53 segments with 1⁄4 in. by 1⁄2 in. stainless steel wire 
Appendix E

July 2007 E-91 NUREG-1437, Supplement 29

mesh. Each segment has a stainless steel lip that is used to lift debris and organisms and direct

them into the fish-return sluiceway.

The traveling screens are not operated continuously but are operated during any of the

following scenarios:

• When the difference in water level on each side of the screen reaches a specified

threshold at an alarm set point. The threshold is typically set at 6 in. This level difference

signifies that too much debris has collected on the screen. Level differences are rare

and usually the result of a storm event.

• When there is an indication that fish are being impinged at a rate exceeding 20 fish per

hour, at which time the traveling screens are turned continuously until the impingement

rate drops below 20 fish per hour for two consecutive sampling events. Each

impingement sampling event is conducted for a minimum of 30 minutes, 3 times per

week.

• During marine life monitoring. The screen wash, which occurs during screen rotations, is

scheduled for eight hours prior to each of the three weekly sampling events.

• During hypo-chlorination, which occurs each day for two hours when the main cooling

water system is chlorinated inboard of the trash rack to control fouling.

• Whenever water temperatures are less than 30°Fahrenheit (F).

• At a minimum, once per each 12-hour shift. This usually occurs at the beginning and end

of each shift, and will usually last for a few hours.

On average, the traveling screens rotate 3 to 4 times each day. The screens normally operate

at 5 fps, but can be accelerated to 20 fps during storm events which are causing extreme debris

loading. 

The screens are washed when they are in operation, using a dual-level spray wash. Service

water is used as the source for the spray wash. Sodium thiosulfate is added to the wash water

to remove chlorine and protect organisms returned to the intake embayment. The screens are

washed from the side that faces the approaching flow at the splash housing, which is located

about 46 ft above the bottom of the intake structure. Low pressure spray, about 20 pounds per

square inch (psi), removes light fouling and organisms from the screen. Subsequently, a high

pressure wash, about 100 psi, is applied to remove heavy fouling. The low and high pressure

washes are about 18 to 24 in. apart. The screen rotation rate is kept slow during high

impingement events. 
Appendix E

NUREG-1437, Supplement 29 E-92 July 2007

Impinged fish are washed into a seamless concrete fish-return sluiceway and usually returned

to the intake embayment approximately 300 ft east of the intake structure. The original west

sluiceway was installed in 1972 and was connected to the discharge canal. In 1979, the east

sluiceway was installed and connected to the intake embayment. During storms, the wash is

discharged via the original sluiceway to the discharge canal. An interchangeable baffle plate is

utilized to divert the flow to one sluiceway or the other from the screenhouse. The baffle plate

will direct organisms and debris; however, some water will flow over this structure and into the

alternate sluiceway. The new sluiceway was designed to maintain a minimum 6-in depth and a

water velocity of less than 8 fps and is covered with galvanized wire screen. Though there are

several turns in the sluiceway, none appear to be greater than 23 degrees. The discharge point

of the east sluiceway is at the mean low water (MLW) level. On occasion, the end of the east

sluiceway has been seen above the water level, causing an actual "free fall" scenario. The west

sluiceway discharge is above the MLW level in the discharge canal.

Under normal operation, seawater is heated in the condensers to approximately 27 to 30°F

above the intake temperature. This is within the plant's National Pollutant Discharge Elimination

System (NPDES) permit, which allows for as much as a 32°F temperature change. With the

cooling water flow being relatively constant at 311,040 gpm (693 cfs) throughout the year, the

discharge temperature is almost entirely a function of the intake water temperature. The

permitted change in temperature across the service water is 5 to 10°F. From the condensers,

water flows through the buried concrete conveyances to the discharge canal. The conveyances

are 235 ft of 13 ft by 17 ft reinforced concrete box culvert, followed by 250 ft of a concrete pipe

that is 10.5 ft in. diameter.

Three to five times each year, the plant is reduced to 50 percent power, and a thermal

backwash is conducted to control biological fouling. During the backwash, water is heated to

about 105°F, and two of the four traveling screens are rotated in reverse, allowing heated, nonchlorinated seawater from the condensers to flow back over the screens and to the intake

embayment. The treatment is maintained for about 35 minutes. Scheduling of the thermal

backwash treatments is coordinated with the highest tide to achieve maximum coverage,

preventing mussels from growing in the upper elevations of the intake structure.

Upon exiting the concrete pipe, discharged water enters a 900-foot-long trapezoidal discharge

canal separated from the intake embayment by a breakwater. The discharge canal is created by

two breakwaters that are oriented perpendicular to the shoreline, one of which is shared with

the intake embayment. The canal sides are sloped at a 2:1 horizontal to vertical ratio. The

bottom is 30 feet wide at an elevation of 0 feet MLW, or 4.8 feet below MSL. The canal bottom

remains at this elevation until it converges with the shore, which has a slope of approximately

40:1 at the canal mouth. At low tide, the water in the discharge canal is several feet higher than

sea level, and the discharge is rapid and turbulent (estimated at 8.1 fps). At high tide, the

velocity is much lower (estimated at 1.4 fps) because the cross sectional area of flow in the
Appendix E

July 2007 E-93 NUREG-1437, Supplement 29

canal is greater. Discharge of the heated water creates a thermal plume in the nearshore area

of PNPS. Dredging of the discharge canal has never been conducted. The intake embayment

has been dredged twice, once in 1982 and again in the late 1990s. The purpose of dredging in

the 1990s, though unsuccessful, was to bring colder water into the cooling water system. Each

dredging event was individually permitted through the U.S. Army Corps of Engineers (USACE). 

The potential dredge material was tested as part of the permit, undergoing chemical, biological,

and radiological analyses (see Section 2.2.5.2). The sediments were described as having

relatively low concentrations of the chemical parameters tested [polychlorinated biphenyls

(PCBs), polycyclic aromatic hydrocarbons (PAHs), pesticides, petroleum hydrocarbons, heavy

metals], and thus considered to be Category One material under the Massachusetts

Department of Environmental Protection (MDEP) dredged material classification guidelines and

being suitable for disposal (BSC Group 1996). Of the three potential categories of dredged

material, a Category One classification has the lowest amount of contaminants. The dredged

material was disposed of in open water, at the Massachusetts Bay Disposal Site, north of

Boston.

5.0 Potential Effects of Plant Operation on Biota and Habitat 

Operation of the PNPS cooling water system has the potential to impact marine species and

habitat. Water removed from Cape Cod Bay contains a variety of aquatic organisms that may

be impinged on plant intake structures or entrained through the plant in the circulating cooling

water system and subjected to thermal, mechanical, chemical, and pressure stresses. In

addition to being removed by the intake, the marine water column in Cape Cod Bay would

experience increased temperatures near the discharge area, and organisms in the bay could be

exposed to elevated water temperatures from the thermal discharge plume. Benthic

invertebrates and macroalgae may also experience physical effects due to scouring of the

bottom substrate by the discharge.

5.1 Impingement

Impingement may occur when aquatic organisms that are drawn into the intake with the cooling

water are trapped against the screens of the intake bays. Impinged organisms may experience

injury or mortality by suffocation, starvation, exhaustion, or abrasion, which can result in fatal

infection. Impingement can affect fish and invertebrate species.

Impingement sampling has been conducted by PNPS since the facility first began operation and

consists of monitoring three scheduled screen wash periods each week throughout the year. 

The screens are not continuously turned. However, in general they are turned for 8 hours prior

to conducting the impingement sampling. If the screens were turned prior to sampling, a 60

minute sample is obtained. If the screens were not turned prior to arrival of the sampling crew,

a 30 minute sample is scheduled (Normandeau Associates 2006b). While the screens are

turning, low and high pressure sprays continuously rinse debris and organisms off the screens
Appendix E

NUREG-1437, Supplement 29 E-94 July 2007

into a sluiceway, which is sampled by inserting a stainless steel collection basket into the

sluiceway adjacent to the traveling screens. Fish are considered to be alive if opercular

movement is noted and there are no obvious signs of injury. Living fauna are noted and

measured for total length and then returned to the sluiceway. Dead or injured specimens are

preserved for later analysis in the lab (Normandeau Associates 2006b).

After being rinsed off of the screens and being washed into the east sluiceway, all debris and

organisms are diverted via a seamless concrete sluiceway into the intake embayment,

approximately 300 ft from the screens. During storm events, a portion or all of the flow from the

screens is diverted to the discharge canal via the west sluiceway. A re-impingement study was

attempted in the early 1980's, but due to methodological difficulties, the study was never

completed. 

Impingement rates are calculated by dividing the number of individuals of a given species that

are collected by the number of hours in the collection period. If impingement rates of greater

than 20 fish per hour are noted, additional samples are collected. If impingement rates continue

to be elevated after the second sampling period, the plant operator is notified and advised to

leave the screens operating until further notice (Normandeau Associates 2006b).

Since 1980, a total of 73 species of fish has been collected in the impingement sampling

(Normandeau Associates 2006b). In 2005, impingement samples were collected for a total of

440 hours spread out over the entire year. Over 300,000 fish consisting of 38 species were

collected (Normandeau Associates 2006b). Atlantic menhaden (Brevoortia tyrannus), Atlantic

silverside (Menidia menidia), rainbow smelt (Osmerus mordax), winter flounder

(Pseudopleuronectus americanus), and Atlantic tomcod (Microgadus tomcod) accounted for 98

percent of the annual total of impinged fish (Normandeau Associates 2006b). Atlantic

menhaden were the most dominant at 97 percent, followed by Atlantic silverside (3.8 percent),

rainbow smelt (1.3 percent) and winter flounder (1.2 percent) (Normandeau Associates 2006b). 

Approximately 23,000 invertebrates representing 18 taxa were also collected. Sevenspine bay

shrimp (Crangon septemspionosus) was the dominant species, followed by cancer crab (Cancer

spp.), and then American lobster (Homarus americanus) (Normandeau Associates 2006b).

Life stages of fish collected in the impingement sampling program may include late stage

larvae, juveniles, and adults; however; the historical data provided in Normandeau Associates

(2006b) do not specify the life stages collected. Therefore, discussion of the potential impacts

to EFH associated with impingement are not specific to individual life stages.

Menhaden impingement rates were significantly greater in 2005 than at any other time in the

history of the station being impinged at a rate 25 times greater than the historical mean. 

Impingement rates for silversides in 2005 were similar to the historical mean. Winter flounder

and rainbow smelt were impinged at rates of almost 3 times and 2 times, respectively, of their

historical means. Impingement rates for winter flounder have been steadily increasing since the
Appendix E

July 2007 E-95 NUREG-1437, Supplement 29

late 1990s (Normandeau Associates 2006b). There was a sharp drop in rainbow smelt

impingement rates in 2000, but other than that, impingement rates have remained at relatively

consistent levels since the 1990s (Normandeau Associates 2006b).

In 2005, there were 19 impingement events (greater than 20 fish per hour). In the majority of

these events, menhaden and silversides were the primary species impinged (Normandeau

Associates 2006b). Impingement off the Atlantic tomcod in 2005 was approximately 6 times

greater than the historical mean and is the second highest impingement rate in the history of

PNPS.

In 2005, survival of impinged organisms was higher during the 60 minute samples than during

the 30 minute samples. This trend is consistent with previous years (Normandeau Associates

2006b). Survival of the Atlantic menhaden was low during both the 60 minute samples (27

percent) and the 30 minute samples (18 percent). The Atlantic silverside had a much greater

difference in survival between the 60 minute samples and the 30 minute samples (62 percent

versus 15 percent, respectively). Winter flounder survival averaged 96 percent when collected

during the 60 minute samples, while survival was approximately 77 percent during the 30

minute samples. There was also a significant difference for the rainbow smelt, with 53 percent

survival based on the 60 minute samples and no survival based on the 30 minute samples

(Normandeau Associates 2006b). Survival for the Atlantic tomcod ranges from 35 percent for

the 30 minute samples to 63 percent for the 60 minute samples.

5.2 Entrainment

Entrainment occurs when smaller objects or organisms pass through the intake screens and

enter the plant’s cooling system with the cooling water. Organisms entrained in the water are

subjected to pressure changes, mechanical damage, toxic exposure from chlorine, and thermal

stress. For the purposes of this EFH assessment, NRC staff assumes 100 percent mortality of

entrained organisms.

Entrainment sampling was initiated by PNPS in 1974 and was initially conducted twice per

month from January to February and from October to December and conducted weekly from

March through September. During these events, sampling was conducted in triplicate. 

Beginning in 1994, the sampling program was modified to focus on better temporal coverage. 

During the January to February and October to December time periods, samples are collected

every other week on three separate days for a total of approximately six samples per month. 

During the March through September time frame, three separate samples have been collected

every week for a total of approximately 12 samples per month (Normandeau Associates 2006a).

Entrainment sampling is usually conducted concurrently with the impingement sampling. 

Entrainment sampling is conducted by suspending a 60 cm (24 in.) diameter plankton net (with

flowmeter) in the discharge canal approximately 30 m from the headwall. Typically a standard

mesh of 0.333 mm (0.013 in.) is used, with the exception of the late March through late May
Appendix E

NUREG-1437, Supplement 29 E-96 July 2007

time period, when a 0.202 mm (0.008 in.) mesh is used to capture early stage larval winter

flounder. The sampling period typically ranges from 8-30 minutes depending upon the tide; the

higher tide requires a longer interval due to lower discharge stream velocities. The target is to

sample a minimum quantity of 100 m3

 of water. Upon termination of the sampling period,

samples are preserved in 10 percent formalin prior to laboratory identification and enumeration

(Normandeau Associates 2006a).

Approximately 60 different fish species have been collected over the last 30 years of

entrainment monitoring at PNPS (Normandeau Associates 2006a). In this area of Cape Cod

Bay, there are three primary spawning seasons observed: winter-early spring, late spring-early

summer, and late summer-autumn. 

Many of the species that spawn during the winter early spring period have demersal, adhesive

eggs that are not normally entrained, and as a result, more species are typically represented by

larvae than by eggs during this time period (Normandeau Associates 2006a). During the 2005

winter-early spring season (generally January to April), egg collections are dominated by

Atlantic cod (Gadus morhya), while larvae collections are dominated by the American sand

lance (Ammodytes americanus) (Normandeau Associates 2006a). In 2004, the sand lance also

dominated the larvae collections while the egg collection were dominated by American plaice

(Hippoglossoides platessoides), followed by Atlantic cod (Marine Research, Inc. 2005b).

The late spring early summer season is typically the most active reproductive period among the

temperate fishes in the PNPS area (Normandeau Associates 2006a). For entrainment

sampling, in both the 2004 and 2005 late spring early summer seasons (May-July), the egg

collections were dominated by tautog (Tautogolabrus adspersus), cunner (Pleuronectes

ferruginea), and yellowtail founder (Pleuronectes ferruginea), while the larvae were dominated

by winter flounder (Marine Research, Inc. 2005a; Normandeau Associates 2006a). 

The late summer-early autumn season in the PNPS area typically shows a decline in overall

ichthyoplankton density and number of species collected (Normandeau Associates, 2006a). 

The 2004 and 2005 late summer-early autumn seasons (August-December) were dominated by

tautog, cunner, and yellowtail eggs, closely followed by fourspot flounder 

(Paralichthyus oblongus) and windowpane flounder (Scopthalmus aquosus) eggs (Marine

Research, Inc. 2005b; Normandeau Associates 2006a). In 2005, the larval collections were

dominated by fourbeard rockling (Enchelyopus cimbrius), whereas in 2004 larval collections

were dominated by cunner, with the fourbeard rockling showing a much lower percentage than

in 2004 (Marine Research, Inc. 2005b; Normandeau Associates 2006a). 

According to Entergy (2006b), ichthyoplankton densities obtained in 2005 are consistent with

the data from the 1975-2004 time series, with the exception of Atlantic cod and Atlantic

mackerel eggs and larval winter flounder and rock gunnel (Pholis gunnellus). Both the Atlantic

cod eggs and larval winter flounder abundance estimates appear to have increased over long
Appendix E

July 2007 E-97 NUREG-1437, Supplement 29

term trends, whereas Atlantic mackerel eggs and larval rock gunnel appear to be relatively low

compared to historic data (Normandeau Associates 2006a). 

Periodically through the life of the facility, there have been periods when the rate of entrainment

is significantly elevated. Reporting of these “significant” events is required by the facility

NPDES permit. Identification of these events was thought to be necessary so that it could be

determined whether high ichthyoplankton entrainment rates were being caused by conditions in

the vicinity of Rocky Point that are attributable to operation of PNPS, or whether they were

attributable to naturally occurring high population levels in the bay (i.e., during spawning

season) (Normandeau Associates 2006a) . These high entrainment events can contribute a

significant percentage of the overall annual entrainment numbers for certain species. For

example, during the 2005 sampling season, there were 54 separate high entrainment events, as

defined by comparison to historical data sets. These included a total of 12 species of eggs and

larvae, including American plaice, Atlantic menhaden, Atlantic herring, American sand lance,

seasnail (Liparis atlanticus), winter flounder, radiated shanny (Ulvaria subbifurcata), cunner,

fourbeard rockling, tautog, Atlantic mackerel, and lumped hake (Normandeau Associates

2006a).

5.3 Thermal Effects

Aquatic organisms are potentially impacted by the thermal plume associated with PNPS

discharge of heated cooling water. Contact with heated discharge water may induce heat shock

in animals. Alternatively, organisms that have acclimated to the thermal discharge may

experience cold shock during plant shut down. The effects may occur to organisms within the

water column or to bottom-dwelling organisms within the vicinity of PNPS (ENSR 2000).

Section 316(a) of the Clean Water Act (CWA) establishes a process by which a discharger can

demonstrate that the established thermal discharge limitations are more stringent than

necessary to protect balanced, indigenous populations of fish and wildlife and obtain

facility-specific thermal discharge limits (33 USC 1326). The applicant has provided U.S.

Environmental Protection Agency (EPA) with Section 316(a) demonstrations that address

compliance with the thermal effluent limitations of the NPDES permit and environmental impacts

of the thermal discharge. The NPDES permit (EPA 1994) states that "the thermal plumes from

the station: (1) shall not deleteriously interfere with the natural movements, reproductive cycles,

or migratory pathways of the indigenous populations within the water body segment; and (2)

shall have minimal contact with the surrounding shorelines. To assess compliance with these

requirements, there has been an extensive monitoring program of the coastal environmental

near the PNPS site since the beginning of design/construction in the late 1960s (EG&G 1995).

A combined Section 316(a) and (b) demonstration report for PNPS was submitted to EPA

Region 1 in 1975 and 1977 by the Boston Edison Company (Stone & Webster 1975, Stone &

Webster 1977), was accepted by EPA, and was used in determining facility-specific NPDES
Appendix E

NUREG-1437, Supplement 29 E-98 July 2007

discharge temperature limits (Entergy 2006a). That initial Section 316 demonstration report was

based on engineering, hydrological, and ecological data from a 3-year pre-operational period

(1969-1972) and a 5-year post-operational period (1972-1976). It predicted that station

operations would not result in long-term thermal impacts to the aquatic environment (ENSR

2000). Based on that report and ongoing ecological monitoring programs, EPA has issued and

renewed NPDES permits for PNPS for over 30 years and has determined that thermal

discharges from PNPS are sufficiently protective of the aquatic community of Cape Cod Bay to

satisfy alternative thermal effluent limitations under Section 316(a) of the CWA (ENSR 2000,

Entergy 2006a).

In recent years, EPA Region 1 has required all NPDES permittees affected by Section 316 to

submit new Section 316(a) and (b) demonstrations. A new Section 316 demonstration report for

PNPS was prepared in 2000 (ENSR 2000), which updated the previous report based on

approximately 25 years of additional engineering, hydrological, and biological data related to

PNPS operations and conditions in the aquatic environment of western Cape Cod Bay. EPA

Region 1 currently is reviewing an Entergy application for renewal of the NPDES permit for

PNPS, including the newest combined Section 316 demonstration report (Entergy 2006a). In

the interim, Entergy has continued biological monitoring. The Thermal Discharge Fish

Surveillance Program involves periodic visual inspections of the discharge canal during times of

fish migration in order to determine the presence of fish and their condition.

Studies have demonstrated that the thermal plume does cause finfish to avoid the area of the

plume. The plume also does not cause significant mortality, with only two individuals identified

as killed as a result of heat shock in the mid 1970s. Similar studies of the thermal plume

impacts on benthic organisms found no effects. Research trap catch data specifically collected

to evaluate the impact on the American lobster did not identify any measurable difference in the

presence of the species before or during plant operation (ENSR 2000).

An additional source of heated water discharge at PNPS is backwashing operations. Thermal

backwashing is a commonly used method for control of biofouling in the condenser tubes and

intake structures of power plants. Condenser tubes at PNPS are cleaned by backwashing on a

1- to 2-week interval, depending on the degree of biofouling. Because the plant electrical

generation must be reduced during backwashing, the procedure usually is conducted during

off-peak hours. The method involves reversing the flow of heated water so that organisms

fouling the condenser tubes and intake structure are killed by the elevated temperatures. The

process results in the flow of heated water out of the intake structure and into the intake

embayment. The thermal backwashing process generally occurs for approximately 45 to 60

minutes and produces elevated water temperatures averaging approximately 37.8EC. A thermal

survey to determine the effects of backwashing operations at PNPS found that the procedure

caused a relatively thin thermal plume, averaging 3 to 5 ft (0.5 to 1.5 m) in depth, that spread

rapidly from the intake structure across the western end of the intake embayment and along the
Appendix E

July 2007 E-99 NUREG-1437, Supplement 29

outer breakwater. The plume completely dissipated within a few hours (Normandeau

Associates 1977). 

6.0 Potential Effects of the Proposed Action on Designated EFH and Federally

Managed Species in the Vicinity of PNPS

PNPS is located in an area that provides EFH for species managed by the New England

Fishery Management Council. Also, highly migratory species managed by NMFS and their

EFHs occur in the vicinity of PNPS. The NRC staff has conducted an evaluation by considering

all designated EFH that could occur in the vicinity of PNPS, and used a screening process to

eliminate species and their EFHs that would not be in the scope of this assessment. Because

EFH is designated geographically with respect to latitude and longitude, the staff first identified

the geographic boundaries of Cape Cod Bay. Table 6-1 lists the 10 minute latitude by 10

minute longitude geographic areas that were used to identify species to be included in the EFH

assessment.

Table 6-2 lists the resulting species and life stages for which designated EFH potentially occurs

in the vicinity of PNPS. These potentially occurring species were complied based on the species

lists for the locations noted in Table 6-1. Habitat areas of particular concern (HAPCs) have not

been designated for any of these species in the area surrounding PNPS.

The species on this list were further evaluated to determine if EFH was designated for the

geographic area in which PNPS is located (i.e., Cape Cod Bay, Gulf of Maine), and also

whether Cape Cod Bay in the vicinity of PNPS has the salinity, depth, temperature, and

substrate requirements for specific life stages of an individual species. This evaluation was

conducted by determining whether the EFH and general habitat parameters correlate with the

physical and chemical environment surrounding PNPS. As described in Section 3, salinities in

the vicinity of PNPS range from 28 to 33 ppt, while the depths in the immediate area of PNPS

range from 3 to 6 m (10 to 20 ft), with a maximum depth of approximately 55 m (180 ft) at the

mouth of the bay. Water temperatures in this area typically range from 2°C to 22EC at the

surface and from 3°C to 12EC on the bottom, while the substrate in this area is generally sandy

with the exception of two offshore rocky ledges just to the north and south of PNPS. 
Appendix E

NUREG-1437, Supplement 29 E-100 July 2007

Table 6-1. Essential Fish Habitat Areas Associated with Cape Cod Bay

10 Minute x 10 Minute Square Coordinates Description of Geographic Area Source

North East South West

42o

 10.0’N 70o 30.0’W 42o 00.0’N 70o 40.0’W Atlantic Ocean waters within Cape Cod

Bay within the square east of Duxbury,

MA., Kingston, MA., and Marshfield MA.,

from Saquish Neck in Duxbury, MA., to

Rexhame Beach in Marshfield, MA.,

including waters affecting most of

Duxbury Bay and Powder Point in

Duxbury, MA.

http://www.nero.noaa.gov/hc

d/ma3.html and

http://www.nero.noaa.gov/hc

d/STATES4/CapecodtoNH/4

2007030.html://www.nero.no

aa.gov/hcd/ma4.html

42o

 10.0’N 70o 40.0’W 42o 00.0’N 70o 50.0’W Atlantic Ocean waters within the square

within Massachusetts Bay east of

Kingston, MA., and Marshfield, MA. From

Kingston Bay and Kingston to Powder

Point in Duxbury, MA, along with

Rexhame Beach in Marshfield, MA., to

the North River Inlet in Marshfield, MA.

Includes a disposal site just east of

Plymouth Horn on the end of Gurnet Pt.

at the tip of Duxbury Beach.

http://www.nero.noaa.gov/hc

d/ma4.html and

http://www.nero.noaa.gov/hc

d/STATES4/CapecodtoNH/4

2007040.html

42o

 00.0’N 70o 20.0’W 41o 50.0’N 70o 30.0’W Atlantic Ocean waters within Cape Cod

Bay within the square one square

southwest of the square affecting

Provincetown, MA./ tip of Cape Cod. 

http://www.nero.noaa.gov/hc

d/ma3.html and http://

www.nero.noaa.gov/hcd/ST

ATES4/CapecodtoNH/

41507020.html

42o

 00.0’N 70o 30.0’W 41o 50.0’N 70o 40.0’W Waters within Cape Cod Bay within the

square affecting the following: east of

Plymouth, MA., and Kingston, MA., from

Plymouth Harbor south to Lookout Point

in Plymouth, MA., along with the

southern tip of Saquish Neck in Duxbury.

Also affected by these waters are

Browns Bank, Duxbury Pier, Plymouth

Beach, Warren Cove, Rocky Pt., White

Horse Beach and Rocks, Manomet Pt.,

Mary Ann Rocks, Stone Horse, Rocks,

Stone Hill, Stellwagen Rocks, Center Hill

Pt., and Ellisville Harbor.

http://www.nero.noaa.gov/

hcd/ma3.html and

http://www.nero.noaa.gov/

hcd/STATES4/CapecodtoN

H/ 41507030.html

42o

 00.0’N 70o 40.0’W 41o 50.0’N 70o 50.0’W Cape Cod Bay waters within the square

affecting the following: east of Plymouth,

MA., and Kingston, MA., from the Jones

River past High Cliff to Plymouth Harbor

Breakwall.

http://www.nero.noaa.gov/

hcd/ma4.html and 

http://www.nero.noaa.gov/hc

d/STATES4/CapecodtoNH/4

1507040.html
Appendix E

July 2007 E-101 NUREG-1437, Supplement 29

Table 6-1. (contd)

10 Minute x 10 Minute Square Coordinates Description of Geographic Area Source

North East South West

41o

 50.0’N 70o 20.0’N 41o 40.0’N 70o 30.0’W Atlantic Ocean waters within the square

within Cape Cod Bay affecting the

following: north of Sandwich, MA., and

Barnstable, MA. Also, these waters

affect from the Cape Code Canal on the

west, east to the western part of Sandy

Neck, along with the Great Marshes and

the western part of Barnstable Harbor. 

Also affected are: Town Beach, Old

Harbor Creek, and Springhill Beach

northeast of Sandwich, MA., Scorton

Neck and Beach, Scorton Ledge, a dump

site on the northwest corner, and Plowed

Neck.

http://www.nero.noaa.gov/hc

d/states4/capecodtoNH/414

07020.html

41o

 50.0’N 70o 30.0’W 41o 40.0’N 70o 40.0’W Atlantic Ocean waters within the square

within Cape Cod Bay affecting the

following: the Cape Cod Canal and

surrounding from Lookout Point in

Plymouth, MA., southeast to the north

half of Scraggy Neck, and to Great Neck

and Onset, MA., except for the far end of

Stony Point Dike. This square also

includes waters within Buzzards Bay

affecting around Bourne, MA., and the

northeast part of Wareham, MA. Also

affected are: Scusset Beach and

Sagamore Beach. 

http://www.nero. noaa.gov/

hcd/ma3.html and

http://www.nero.noaa.gov/

hcd/STATES4/CapecodtoN

H/41407030.html

Southeast Corner Boundaries

42o

 00 70o 00 41o 40 70o 10

42o

 00 70o 10 41o 40 70o 20

42o

 00 70o 20 41o 40 70o 30

42o

 00 70o 30

41o

 50 70o 00

41o

 50 70o 10

41o

 50 70o 20

41o

 50 70o 30

41o

 40 70o 00

Cape Cod Bay, MA http://www.nero.noaa.gov/hc

d/ma3.html
Appendix E

NUREG-1437, Supplement 29 E-102 July 2007

Table 6-2. EFH Species Potentially Occurring in the Vicinity of PNPS

Species Eggs Larvae Juveniles Adults

Spawning

Adults

American plaice (Hippoglossoides

platessoides) M M M M M 

Atlantic butterfish (Peprilus triacanthus) M M M/E M/E 

Atlantic cod (Gadus morhua) MM M MM

Atlantic halibut (Hippoglossus

hippoglossus) MM M MM

Atlantic mackerel (Scomber scombrus) M/E M/E M/E M/E 

Atlantic sea scallop (Placopecten

magellanicus) MM M MM

Atlantic sea herring (Clupea harengus) M M M/E M/E 

Black sea bass (Centropristus striata) N/A M M 

Bluefin tuna (Thunnus thynnus) MM 

Bluefish (Pomatomus saltatrix) M/E 

Haddock (Melanogrammus aeglefinus) MM 

Little skate (Leucoraja erinacea) M M

Longfin squid (Loligo pealei) N/A N/A M M 

Monkfish (Lophius americanus) MM M 

Ocean pout (Macrozoarces americanus)MM M MM

Ocean quahog (Artica islandica) N/A N/A M M 

Pollock (Pollachius virens) M M/E M

Red hake (Urophycis chuss) M M M/E M M

Scup (Stenotomus chrysops) M M M/E M 

Shortfin squid (Illex illecebrosus) N/A N/A M M 

Smooth skate (Malacoraja senta) M

Spiny dogfish (Squalus acanthias) N/A N/A M M 

Summer flounder (Paralicthys dentatus) M 

Surf clam (Spisula solidissima) N/A N/A M M 

Thorny skate (Amblyraja radiata) M M

White hake (Urophycis tenuis) M M M/E M/E 

Whiting/Silver hake (Merluccius bilinearis) M M M/E M/E M

Windowpane flounder (Scopthalmus

aquosus) M/E M/E M/E M/E M/E

Winter flounder (Pseudopleuronectes

americanus) M/E M/E M/E M/E M/E

Winter skate (Leucoraja ocellata) M E

Witch flounder (Glyptocephalus

cynoglossus) MM 

Yellowtail flounder (Pleuronectes

ferruginea) MM M MM

* M = EFH in marine ecosystem; E = EFH in estuarine ecosystem.

N/A = Species either have no data available on the designated life stages, or those life stages are not present in the

species reproductive cycle.
Appendix E

July 2007 E-103 NUREG-1437, Supplement 29

The following discussions of life stages and habitat preferences for the species listed in Table 2

include evaluations of the potential effects of continued PNPS operations on EFH. This

assessment also evaluates the potential effects of continued PNPS operations on prey items of

the EFH species. For the purposes of this assessment, NRC staff has classified impacts as

having a minimal adverse effect, less than substantial adverse effect, or substantial adverse

effect based on evaluation of entrainment, impingement, thermal effects, and effects on prey

species.

American plaice (Hippoglossoides platessoides)

EFH for American plaice eggs, larvae, juveniles, adults, and spawning adults exists in the

vicinity of PNPS. For eggs and larvae, EFH includes surface waters of the Gulf of Maine and

Georges Bank. This includes areas where water temperatures are below 12 to 14°C, and water

depths are between 30 and 130 m (98 and 426 ft), with a wide range of salinities. EFH for

juveniles, adults, and spawning adults includes bottom habitats with fine-grained, sandy, or

gravel substrates in the Gulf of Maine (NMFS 2006). Water conditions in EFH for the juveniles,

adults, and spawning adults includes water temperatures below 17°C, and depths between 45

and 175 m (148 and 574 ft). Spawning adults are typically found in water with temperatures

below 14°C, and depths less than 90 m (295 ft) (NMFS 2005a). 

Both the eggs and larvae of the American plaice are pelagic and are found in shallow surface

waters, including southern New England and Cape Cod Bay (ENSR 2000). Adults are primarily

benthic, but are known to migrate off of the bottom at night to prey on non-benthic species (DFO

1989 in Johnson 2004). Larvae prey on plankton, diatoms, and copepods found in surface water

layers. As larvae turn into juveniles, they feed on small crustaceans, polychaetes, and

cumaceans (Bigelow and Schroeder 1953 in Johnson 2004). Benthic crustaceans, mollusks,

and small forage fish species make up the diet of the American plaice adults. The American

plaice does not migrate substantially. Results from tagging studies have found that most

recaptured individuals were found within 30 mi from the tagging site, even as long as seven

years later (DFO 1989 in Johnson 2004). In 2005, an analysis of juvenile populations resulted

in a proposal for the designation of HAPCs for the American plaice, including areas within Cape

Cod Bay (Crawford et al. 2005). American plaice populations in the western North Atlantic have

declined dramatically since the early 1980s (Johnson 2004). 

The intake and discharge at PNPS have the potential to adversely affect a small portion of EFH,

including prey for all life stages of the American plaice. American plaice have been impinged at

PNPS, but they are not a common species in the impingement sampling program (Normandeau

2006b). Eggs and larvae of the American plaice dominated entrainment studies at PNPS

(ENSR 2000, Normandeau 2006a). Due to the small area affected by the thermal plume and

because the American plaice would exhibit behavioral avoidance if water temperatures are not

within their preference range, it is unlikely that the PNPS discharge would affect juvenile and

adult American plaice EFH. Continued operation of PNPS may also have the potential to affect
Appendix E

NUREG-1437, Supplement 29 E-104 July 2007

prey items of various life stages of the American plaice either through entrainment of

phytoplankton, zooplankton, or icthyoplankton, or via impingement of small forage fish species. 

Continued operations of PNPS may have a substantial adverse effect on EFH for American

plaice.

Atlantic butterfish (Peprilus triacanthus)

EFH for American butterfish eggs, larvae, juveniles, and adults exists in the vicinity of PNPS. 

EFH for offshore areas includes pelagic waters over the continental shelf from the Gulf of Maine

to Cape Hatteras. Inshore EFH for the butterfish includes the mixing or saline zones of

estuaries where butterfish eggs, larvae, juveniles, and adults are common or abundant on the

Atlantic coast, from Passamaquoddy Bay, Maine to James River, Virginia (NMFS 2006). 

Butterfish eggs and larvae are found in water with depths ranging from the shore to 6000 ft, and

temperatures between 48o

F and 66oF. Juvenile and adult butterfish are found in waters from 33

to 1,200 ft deep, and with temperatures ranging from 37o

F to 82oF (NMFS 2006). Spawning

occurs offshore, at temperatures above 59o

F (Colton 1972 in Cross et al. 1999).

All life stages, including eggs, larvae, juveniles, and adults are pelagic (Cross et al. 1999). 

Adult butterfish prey on small fish, squid, and crustaceans, and in turn are preyed upon by many

species, including silver hake (Merluccius bilinearis), bluefish, swordfish (Xiphias gladuis), and

longfinned squid (Loligo pealei) (ENSR 2000). In summer, the butterfish can be found over the

entire continental shelf from sheltered bays and estuaries, over substrates of sand, rock, or

mud, to a depth of 200 m (Cross et al. 1999). The butterfish migrates annually in response to

seasonal changes in water temperature. During the summer, they migrate inshore into southern

New England and Gulf of Maine waters, and in winter they migrate to the edge of the continental

shelf in the Mid-Atlantic Bight (Cross et al. 1999). 

The PNPS intake and discharge have the potential to adversely affect egg, larvae, juvenile, and

adult Atlantic butterfish EFH. Atlantic butterfish eggs and larvae have been consistently

collected in the PNPS entrainment sampling (Normandeau 2006a). They have also been

collected periodically in the impingement sampling (Normandeau 2006b). However, it is unlikely

that PNPS intake operations are adversely affecting butterfish as the species has not been

reported to be entrained or impinged in high numbers (ENSR 2000). Due to the small area

affected by the thermal plume and because the Atlantic butterfish would exhibit behavioral

avoidance if water temperatures are not within their preference range, it is unlikely that the

PNPS discharge would affect juvenile and adult Atlantic butterfish EFH. Continued operation of

PNPS may also have the potential to affect prey items of various life stages of the Atlantic

butterfish, either through entrainment of icthyoplankton or via impingement of squid or small

forage fish species. Continued PNPS operations are likely to have a less than substantial

adverse effect on EFH for butterfish.
Appendix E

July 2007 E-105 NUREG-1437, Supplement 29

Atlantic cod (Gadus morhua)

EFH for Atlantic cod eggs, larvae, juveniles, adults, and spawning adults exists in the vicinity of

PNPS. EFH for eggs of the species exists in surface waters around the perimeter of the Gulf of

Maine, Georges Bank, and the eastern portion of the continental shelf off southern New

England in water depths less than 100 m (328 ft), and in temperatures below 12o

C. Larval EFH

for cod exists in pelagic waters of the Gulf of Maine, Georges Bank, and the eastern portion of

the continental shelf off southern New England in depths of 30 to 70 m (98 to 230 ft), and

temperatures below 10o

C. EFH for juvenile, adult, and spawning adult cod includes bottom

habitats with substrates of rocks, cobble, or gravel in the Gulf of Maine, Georges Bank, and the

eastern portion of the continental shelf off southern New England. Juvenile cod EFH includes

depths ranging from 25 to 75 m (82 to 246 ft), and water temperatures below 20o

C. Adult and

spawning adult EFH requirements includes water depths from 10 to 150 m (33 to 492 ft) and

temperatures below 10o

C (NMFS 2006). Peak spawning within Massachusetts Bay occurs in

January and February (Lough 2004). 

As the cod become juveniles and adults, they are able to withstand deeper, colder, and more

saline water, and become more widely distributed (Fahay et al. 1999a). Some studies have

shown that juveniles tend to prefer shallow areas with cobble substrates, in order to avoid

predation (Gotceitas and Brown 1993 in Fahay et al. 1999a). Juveniles and younger adults

tend to consume pelagic and benthic invertebrates, while adult cod also feed on both

crustaceans and other fish, including sand lance, cancer crabs, and herring (Clupea harengus)

(Lough 2004). Within the temperate part of their range, including offshore New England, cod are

non-migratory and only make minor seasonal movements in response to temperature changes. 

At the extremes of their range, including Labrador and south of the Chesapeake, the cod

migrate annually (Fahay et al. 1999a). In 2005, an analysis of juvenile populations resulted in a

proposal for the designation of HAPCs for the Atlantic cod, including areas within Cape Cod Bay

(Crawford et al. 2005).

The intake and discharge at PNPS have the potential to adversely affect a small portion of EFH

for all life stages of the Atlantic cod. Eggs and larvae of the Atlantic cod dominated entrainment

studies at PNPS (ENSR 2000, Normandeau 2006a). Atlantic cod life stages have also been

observed in the PNPS impingement sampling program (Normandeau 2006b). Due to the small

area affected by the thermal plume and because the Atlantic cod would exhibit behavioral

avoidance if water temperatures are not within their preference range, it is unlikely that the

PNPS discharge would affect juvenile and adult Atlantic cod EFH. Continued operation of

PNPS may also have the potential to affect prey items of juvenile and adult life stages of the

Atlantic cod as several prey items of the Atlantic cod (sand lance and herring) have been

commonly reported in the impingement and entrainment sampling program at PNPS. 

Continued operations of PNPS may have a substantial adverse effect on EFH for Atlantic cod.
Appendix E

NUREG-1437, Supplement 29 E-106 July 2007

Atlantic halibut (Hippoglossus hippoglossus)

EFH for Atlantic halibut eggs, larvae, juveniles, adults, and spawning adults exists in the vicinity

of PNPS. EFH for eggs includes the pelagic waters and sea floor of the Gulf of Maine and

Georges Bank, with water depths less than 700 m (2296 ft) and temperatures between 4 to 7o

C. 

For larvae, the EFH consists of surface waters of the Gulf of Maine and Georges Bank. 

Juvenile and adult EFH for the halibut includes bottom habitats with sand, gravel, or clay

substrates in the Gulf of Maine and Georges Bank. Juvenile cod are found at water depths from

20 to 60 m (66 to 197 ft) and temperatures above 2o

C. Adults are found in water depths from

100 to 700 m (328 to 2296 ft) and at temperatures below 13.6o

C. Spawning adult EFH consists

of bottom habitats with substrates of soft mud, clay, sand, or gravel in the Gulf of Maine and

Georges Bank. Spawning adults are typically found in water depths less than 700 meters, and

at temperatures below 7o

C (NMFS 2006). Spawning is reported to occur in late fall or spring,

with peak spawning between November and December (NEFMC 1998a in ENSR 2000). 

However, spawning is thought to no longer occur in the Gulf of Maine (Cargnelli et al. 1999b). 

The eggs of the halibut are bathypelagic, suspended within the water column at a depth of 54 to

200 m (177 to 656 ft) (Scott and Scott 1988, Blaxter et al. 1983 in Cargnelli et al. 1999b). Both

the eggs and larvae are pelagic. The larvae live within surface waters until they reach juvenile

stage, at which time they transform into flatfish and move to the bottom (BMLSS 1997/8 in

ENSR 2000). The diet of the Atlantic halibut changes through its lifespan. Juveniles and

smaller adults prey mostly on invertebrates, including annelids and crustaceans. As they grow

larger, the adults prey primarily on other fish (Kohler 1967 in Cargnelli et al. 1999b). In the Gulf

of Maine, the primary prey is squid, crabs, silver hake, northern sand lance (Ammodytes

dubius), ocean pout (Macrozoarces americanus), and alewife (Alosa pseudoharengus)

(Cargnelli et al. 1999b). Juveniles live within their nursery areas until the age of 3 to 4 years,

and after that time perform annual migrations (Stobo et al. 1988 in Cargnelli et al. 1999b).

The PNPS intake and discharge have the potential to adversely affect egg, larvae, juvenile,

adult, and spawning adult Atlantic halibut EFH. However, it is unlikely that PNPS intake

operations are adversely affecting juvenile and adult halibut as the species has not been

reported to be entrained or impinged (Normandeau 2006a, Normandeau 2006b). Due to the

small area affected by the thermal plume and because the Atlantic halibut would exhibit

behavioral avoidance if water temperatures are not within their preference range, it is unlikely

that the PNPS discharge would affect juvenile and adult Atlantic halibut EFH. Continued

operation of PNPS may also have the potential to affect prey items of juvenile and adult life

stages of the Atlantic halibut as several prey items of the Atlantic halibut (squid, northern sand

lance, and alewife) have been commonly reported in the impingement and entrainment

sampling program at PNPS. Continued PNPS operations are likely to have a minimal adverse

effect on EFH for halibut.
Appendix E

July 2007 E-107 NUREG-1437, Supplement 29

Atlantic mackerel (Scomber scombrus)

EFH for Atlantic mackerel eggs, larvae, juveniles, and adults exists in the vicinity of PNPS. EFH

for offshore areas includes pelagic waters over the continental shelf from the Gulf of Maine to

Cape Hatteras. Inshore EFH for the mackerel includes the mixing or saline zones of estuaries 

on the Atlantic coast, from Passamaquoddy Bay, Maine to James River, Virginia (NMFS 2006). 

Mackerel eggs are found in water with depths ranging from the shore to 50 ft, and temperatures

between 41o

F and 73oF. Larvae of the species are found at water depths ranging from 33 to

425 ft, between temperatures of 43o

F and 72oF. Juvenile and adult mackerel are found in

waters from shore to 1250 ft deep, and with temperatures ranging from 37o

F to 72oF (NMFS

2006). Cape Cod Bay is reported to be an important spawning area in the months from May to

August (Studholme et al. 1999).

Both the eggs and larvae of the species are pelagic and transition from drifting pelagic to active

swimming when they reach a size of 30 to 50 mm (1.2 to 2 in.) (Sette 1943 in Studholme et al.

1999). The adult mackerel can feed both by filter feeding and by preying on individuals. The

prey consists of plankton such as amphipods, euphausiids, shrimp, crab larvae, small squid,

and fish eggs (Scott and Scott 1988 in ENSR 2000). The mackerel perform annual migrations,

with movement generally northeast and inshore in the spring, and offshore to deeper water in

the winter (ENSR 2000). Migration is closely related to seasonal temperature changes, as the

mackerel prefers to live in waters between temperatures of 6o

C and 15oC (Overholtz and

Anderson 1976 in Studholme et al. 1999). 

The intake and discharge at PNPS have the potential to adversely affect a small portion of EFH

for eggs, larvae, juvenile, and adult Atlantic mackerel. Eggs and larvae of the Atlantic mackerel

dominated entrainment samples at PNPS (ENSR 2000; Normandeau 2006a). Atlantic mackerel

have also been observed occasionally in the PNPS impingement sampling program

(Normandeau 2006b). Due to the small area affected by the thermal plume and because the

Atlantic mackerel would exhibit behavioral avoidance if water temperatures are not within their

preference range, it is unlikely that the PNPS discharge would affect juvenile and adult Atlantic

mackerel EFH. Continued operation of PNPS may also have the potential to affect prey items of

adult mackerel as several of its prey items (small squid and fish eggs) are commonly reported in

the impingement and entrainment sampling program at PNPS. Continued operations of PNPS

may have a substantial adverse effect on EFH for Atlantic mackerel.

Atlantic sea herring (Clupea harengus)

EFH for Atlantic sea herring eggs, larvae, juveniles, and adults exists in the vicinity of PNPS. 

EFH for eggs is found in bottom habitats with substrates of gravel, sand, cobbles, or shell

fragments in the Gulf of Maine and Georges Bank. Eggs are typically found adhering to the

bottom at water depths of 20 to 80 m (66 to 262 ft), at temperatures below 15o

C, and where tidal

currents result in well-mixed water. Larvae EFH includes pelagic waters of the Gulf of Maine,
Appendix E

NUREG-1437, Supplement 29 E-108 July 2007

Georges Bank, and southern New England that comprise 90 percent of the observed range of

the species. These areas typically have water depths ranging from 50 to 90 m (164 to 295 ft),

and water temperatures below 16o

C. Juvenile and adult EFH exists for herring in pelagic water

and bottom habitats in the Gulf of Maine, Georges Bank, southern New England and the midAtlantic region south to Cape Hatteras. These areas include water depths from 15 to 135 m 

(49 to 443 ft), and water temperatures below 10o

C. EFH for spawning adults exists in bottom

habitats with substrates of gravel, sand, cobble, and shell fragments in the Gulf of Maine,

Georges Bank, southern New England and the mid-Atlantic region south to Delaware Bay. 

Spawning occurs in water depths of 20 to 80 m (66 to 262 ft), at temperatures below 15o

C

(NMFS 2006). Spawning occurs in high energy environments with strong tidal action (Iles and

Sinclair 1982 in Stevenson and Scott 2005). In the Gulf of Maine and Georges Bank, spawning

occurs from July to December (Stevenson and Scott 2005). 

The Atlantic sea herring lays eggs on the bottom, in gravel, rock, or shell substrates. The eggs

adhere to the bottom in layers and form beds (Bigelow and Schroeder 1953, Mansueti and

Hardy 1967 in ENSR 2000). As juveniles, Atlantic herring form large aggregations in coastal

areas. Both the larvae and juveniles feed on zooplankton, including copepods (ENSR 2000). 

The Atlantic herring of all life stages is preyed upon by other fishes, including cod, pollock 

(Pollachuis virens), haddock (Melanogrammus aeglefinus), silver hake, mackerel, dogfish, fin

whales (Balaenoptera physalus), and squid (Hildenbrand 1963, Bigelow and Schroeder 1953 in

ENSR 2000), as well as other marine mammals and birds. Adult Atlantic herring feed on

zooplankton and capture prey by direct, predatory snapping action (Blaxter and Holliday 1963 in

ENSR 2000). There is an annual migration of adult Atlantic herring from summer feeding areas

along the Maine coast to southern New England (Stevenson and Scott 2005).

The intake and discharge at PNPS have the potential to adversely affect a small portion of EFH

for eggs, larvae, juvenile, and adult Atlantic sea herring. Larvae of the Atlantic sea herring

dominated entrainment samples at PNPS (ENSR 2000, Normandeau 2006a). Atlantic sea

herring have not been observed in the impingement sampling program at PNPS (Normandeau

2006b). Due to the small area affected by the thermal plume and because the Atlantic sea

herring would exhibit behavioral avoidance if water temperatures are not within their preference

range, it is unlikely that the PNPS discharge would affect juvenile and adult Atlantic sea herring

EFH. Continued operation of PNPS may also have the potential to affect prey items of larval,

juvenile, and adult stages of the Atlantic sea herring as it is a filter feeder on plankton and

entrainment by the plant removes plankton from the local environment. Continued operations of

PNPS are likely to have a less than substantial adverse effect on EFH for the Atlantic sea

herring.

Atlantic sea scallop (Placopecten magellanicus)

EFH for Atlantic sea scallop eggs, larvae, juveniles, adults, and spawning adults exists in the

vicinity of PNPS. EFH for eggs includes bottom habitats in the Gulf of Maine, Georges Bank,
Appendix E

July 2007 E-109 NUREG-1437, Supplement 29

and southern New England, with water temperatures below 17oC. Larvae EFH includes pelagic

waters and bottom habitats, in areas with substrates of gravelly sand, shell fragments, and

pebbles in the Gulf of Maine, Georges Bank, and south to North Carolina. EFH for juveniles,

adults, and spawning adults includes bottom habitats with cobble, shell, or sand in the Gulf of

Maine, Georges Bank, and south to North Carolina. Juveniles, adults, and spawning adults are

found at water depths from 18 to 110 m (59 to 361 ft), with temperatures generally below 21o

C

(NMFS 2006). Spawning peaks between May and June in the mid Atlantic and in September

and October in Georges Bank, usually in water with temperatures below 16o

C (NEFMC 1998a). 

Eggs are not buoyant and remain on the substrate until hatching into free-swimming larvae

(NEFMC 1998a). Larvae occupy pelagic waters and bottom habitats of gravel, shell litter,

algae, or sedentary benthic infauna (NEFMC 1998a). North of Cape Cod, the sea scallop is

generally found at depths of less than 20 m (65 ft) on hard substrates of cobble, shell litter, or

coarse gravel/sand (NEFMC 1998a, Lai and Rago 1998 in ENSR 2000). Sea scallops are

suspension filter feeders and their diet typically consists of phytoplankton and microzooplankton

(Hart and Chute 2004). 

The PNPS intake and discharge have the potential to adversely affect egg, larvae, juvenile,

adult, and spawning adult Atlantic sea scallop EFH. It is unlikely that PNPS intake operations

are adversely affecting eggs or larval sea scallops as the species has not been reported to be

entrained or impinged (ENSR 2000, Normandeau 2006a, Normandeau 2006b). The thermal

discharge is unlikely to affect sea scallop juveniles and adults because the affected area makes

up a tiny portion of their EFH. Continued operation of PNPS may also have the potential to

affect prey items of the Atlantic sea scallop as it is a filter feeder on plankton and entrainment by

the plant removes plankton from the local environment. Continued PNPS operations are likely

to have a minimal adverse effect on EFH for sea scallop.

Black sea bass (Centropristus striata)

EFH for juvenile and adult black sea bass exists in the vicinity of PNPS. Offshore EFH for both

juveniles and adults includes demersal waters over the continental shelf from the Gulf of Maine

to Cape Hatteras. For inshore areas, EFH is found in estuaries where black sea bass are found

to be common or abundant in the Estuarine Living Marine Resource (ELMR) database for the

mixing and seawater salinity zones. Both juveniles and adults prefer warm water (greater than

43o

F), in areas where the bottom substrate includes rough bottom, shellfish, eelgrass beds, or

man-made or natural structured habitats (NMFS 2006, Jury et al. 1994). Spawning occurs on

the inner continental shelf, at water depths of 20 to 50 m (66 to 164 ft), between the

Chesapeake Bay and Long Island (Steimle et al. 1999d). Larvae have been reported in Cape

Cod Bay, but these are interpreted to have been spawned in Buzzards Bay and moved through

the Cape Cod Canal (MAFMC 1996b in Steimle et al. 1999d). Spawning in Massachusetts

coastal waters occurs on sandy bottoms broken by rocky ledges (Kolek 1990, MAFMC 1996b in

Steimle et al. 1999d). 
Appendix E

NUREG-1437, Supplement 29 E-110 July 2007

Eggs and larvae of the black sea bass are pelagic and are found in spawning areas on the

continental shelf (Steimle 1999d). As juveniles, the species moves inshore, where they form

nurseries in estuaries (et al. Able and Fahay 1998 in Steimle et al. 1999d). Juveniles mature as

females, and then change to males as they grow larger (Lavenda 1949 in Steimle et al. 1999d).

Larval black sea bass probably prey on zooplankton (Steimle et al. 1999d). The juveniles are

visual predators that feed on benthic crustaceans and small fish (Richards 1963, Allen et al.

1978, Werme 1981 in Steimle et al. 1999d). The species is primarily a warm-water fish and

begins to migrate offshore to depths of 30 to 240 m (98 to 787 ft) as bottom-water temperatures

reach 7o

C (Steimle et al. 1999d).

The PNPS intake and discharge have the potential to adversely affect juvenile and adult black

sea bass EFH. However, it is unlikely that PNPS intake operations are adversely affecting

juvenile and adult black sea bass as the species has not been reported to be commonly

entrained or impinged (ENSR 2000, Normandeau 2006a, Normandeau 2006b). Due to the

small area affected by the thermal plume and because the black sea bass would exhibit

behavioral avoidance if water temperatures are not within their preference range, it is unlikely

that the PNPS discharge would affect juvenile and adult black sea bass EFH. Continued

operation of PNPS may also have the potential to affect prey items of various life stages of the

black sea bass, either through entrainment of zooplankton or icthyoplankton, or via

impingement of small forage fish species. Continued PNPS operations are likely to have a

minimal adverse effect on EFH for black sea bass.

Bluefin tuna (Thunnus thynnus)

EFH for juvenile and adult bluefin tuna exists in the vicinity of PNPS. For juveniles, EFH

includes the inshore and pelagic waters warmer than 12o

C in the Gulf of Maine and Cape Cod

Bay, and south to Florida. Adult EFH includes pelagic waters from the Gulf of Maine south to

Texas, at water depths greater than 50 m (164 ft) (NMFS 2006). Spawning for the bluefin tuna

occurs from mid-April to June in the Gulf of Mexico and Florida Straits (NMFS 2005c).

The prey of the bluefin tuna includes mackerel, herring, whiting (Merlussius bilinearis), and

squid (Buck 1995). The species is endothermic, meaning it generates heat internally, which

allows it to dive to deeper and colder waters in search of prey (NMFS 1999). The tuna can live

in water ranging from 7o

C to 30oC (NMFS 1999). The bluefin tuna migrates extensively. 

Following spawning in the Gulf of Mexico area in spring and early summer, the species migrates

north along the U.S. coast to waters off of Canada (Buck 1995).

The PNPS intake and discharge have the potential to adversely affect juvenile and adult bluefin

tuna EFH. However, it is unlikely that PNPS intake operations are adversely affecting juvenile

and adult bluefin tuna as the species has not been reported to be entrained or impinged (ENSR

2000, Normandeau 2006a, Normandeau 2006b). Due to the small area affected by the thermal

plume and because the bluefin tuna would exhibit behavioral avoidance if water temperatures
Appendix E

July 2007 E-111 NUREG-1437, Supplement 29

are not within their preference range, it is unlikely that the PNPS discharge would affect juvenile

and adult bluefin tuna EFH. Continued operation of PNPS may also have the potential to affect

prey items of juvenile or adult life stages of the bluefin tuna as several prey items of the bluefin

tuna (mackerel, herring, whiting, and squid) have been commonly reported in the impingement

and entrainment sampling program at PNPS. Continued PNPS operations are likely to have a

minimal adverse effect on EFH for bluefin tuna.

Bluefish (Pomatomus saltatrix)

EFH for adult bluefish exists in the vicinity of PNPS (EFH for eggs, larvae, and juveniles does

not occur as far north as Cape Cod Bay) (NMFS 2006). EFH for adults includes all major

estuaries from Penobscot Bay, Maine to St. Johns River, Florida; also, north of Cape Hatteras

EFH for adults includes continental shelf waters north to Cape Cod Bay. Adult bluefish are

typically in North Atlantic estuaries from June to October. EFH requirements for adult bluefish

include saline, pelagic waters with temperatures between 14 °C and 16 °C.

Bluefish is a migratory, pelagic species found in temperate coastal zones throughout the world

and are very common along along the east coast of the U.S. (Shepherd 2000b). Within the

western Atlantic, bluefish are found from Maine to Florida, migrating northward in the spring and

southward in the fall (ENSR 2000). Bluefish migrate in response to temperature changes in

order to remain in water with temperatures above 14 to 16 °C (Bigelow and Schroeder 1953 in

Shepherd and Packer 2006). They live in southern New England waters in spring and summer,

and migrate to waters off the southeastern U.S. in autumn (Shepherd and Packer 2006). 

Bluefish reach sexual maturity at the age of two years (Deuel 1964, in Shepherd and Packer

2006; ENSR 2000). Spawning occurs in the area from New York south to Florida (Shepherd

and Packer 2006). Bluefish eggs and larvae are buoyant and live within surface waters, only

within open oceanic waters (Able and Fahay 1998 in Shepherd and Packer 2006). The larvae

feed on surface plankton until they reach juvenile stage, and then migrate to coastal nursery

areas to feed on other fish species (Kendall and Watford 1979, in ENSR 2000; Sheperd and

Packer 2006). Adult bluefish are voracious predators, and prey on squid, shrimp, crabs,

alewives, menhaden, silver hake, butterfish and smaller bluefish (ENSR 2000).

The intake and discharge at PNPS have the potential to adversely affect EFH for adult bluefish. 

Bluefish juveniles and adults are reported to have been observed in the vicinity of PNPS (ENSR

2000). No life stages of the bluefish have ever been observed in the PNPS entrainment

sampling. Juveniles and/or adults have been observed in the PNPS impingement sampling

program. Due to the small area affected by the thermal plume and because the bluefish would

exhibit behavioral avoidance if water temperatures are not within their preference range, it is

unlikely that the PNPS discharge would affect adult bluefish EFH. Some prey species are

entrained and impinged at PNPS; however, because adult bluefish opportunistically feed on

many invertebrate and vertebrate species, the effect of reduced prey availability is expected to
Appendix E

NUREG-1437, Supplement 29 E-112 July 2007

be negligible. Continued PNPS operations are likely to have a minimal adverse effect on EFH

for bluefish.

Haddock (Melanogrammus aeglefinus)

EFH for haddock eggs and larvae exists in the vicinity of PNPS. EFH for eggs of the species is

found in coastal areas of the Gulf of Maine in water with temperatures below 10o

C and depths

from 50 to 90 m (164 to 295 ft). Larval EFH includes surface waters from Georges Bank south

to Delaware Bay, in water with temperatures below 14o

C and depths ranging from 35 to 100 m

(115 to 328 ft) (NMFS 2006). Spawning varies by location and time of year, with spawning

generally occurring from February to May in the Gulf of Maine. The largest spawning area in

U.S waters is Georges Bank, and for the Gulf of Maine stock, spawning occurs at the Jeffrey’s

Ledge and Stellwagen Bank areas (Brodziak 2005 in Cargnelli et al. 1999e). 

Eggs, larvae, and juveniles all live within the upper part of the water column until the juveniles

reach a size of 3 to 10 cm (1.2 to 3.9 in.) (Brodziak 2005 in Cargnelli et al. 1999e). At that time,

juveniles travel to the bottom, identify suitable habitat, and become demersal (Klein-MacPhee

2002 in Cargnelli et al. 1999e). The diet of haddock changes through their life cycle. Larvae

and small juveniles feed on phytoplankton, copepods, and invertebrate eggs suspended in the

water column. Once juveniles move to the bottom, they primarily eat small crustaceans,

polychaetes, and small fish. As adults, haddock feed primarily on benthic organisms such as

echinoderms, crustaceans, polychaetes, and mollusks (Brodziak 2005 in Cargnelli et al. 1999e). 

There are data that suggest larvae drift with currents from Canadian waters as far south as

Cape Cod, and then live a portion of their lives in this area (Colton and Temple 1961 in

Cargnelli et al. 1999e). Haddock are not migratory, with only minor movements shoreward in

summer and to deeper water in winter (Brodziak 2005 in Cargnelli et al. 1999e). 

The PNPS intake and discharge have the potential to adversely affect egg and larval haddock

EFH. However, it is unlikely that PNPS intake operations are adversely affecting haddock as

eggs and larvae are not common in entrainment sampling program (Normandeau 2006a). None

of the haddock life stages have been observed in the PNPS impingement monitoring program

(Normandeau 2006b). Continued operation of PNPS may also have the potential to affect prey

items of various life stages of the haddock, either through entrainment of plankton, or via

impingement of small forage fish species. Continued PNPS operations are likely to have a

minimal adverse effect on EFH for haddock.

Little skate (Leucoraja erinacea)

EFH for little skate juveniles and adults exists in the vicinity of PNPS. In the 2003 FMP for the

Northeast Skate Complex (NEFMC 2003), EFH was designated for the little skate. This

designation included bottom habitats with substrates of sand, gravel, and mud in Cape Cod Bay

for both juveniles and adults (NEFMC 2003). Little skate have a reported depth range of 0 to
Appendix E

July 2007 E-113 NUREG-1437, Supplement 29

137 m (449 ft), with most being found less than about 100 m (328 ft) deep (Bigelow and

Schroeder 1953,; McEachran and Musick 1975 in Packer et al. 2003b). The corresponding

water temperature ranges from 1 to 21o

C (Bigelow and Schroeder 1953; Tyler 1971; McEachran

and Musick 1975 in Packer et al. 2003b). Little skates typically prefer sandy or gravelly

substrates (Bigelow and Schroeder 1953 in Packer et al. 2003b) and are known to bury

themselves in depressions during the day (Michalopoulos 1990 in Packer et al. 2003b). 

Eggs of all skates are encapsulated in a leathery capsule that rests on the bottom (Sosebee

2000; Packer et al. 2003b). The eggs hatch fully developed, so there is no larval stage

(Sosebee 2000; McEachran 2002 in Packer et al. 2003b). Adults are estimated to reach sexual

maturity at the age of 4 years (Packer et al. 2003b). Spawning may occur at any time during the

year, with a peak in southern New England from July to September (Bigelow and Schroeder

1953 in Packer et al. 2003b). The major prey reported for the little skate in the Gulf of Maine

area includes decapod crustaceans, amphipods, and polychaetes (McEachran 1973;

McEachran et al. 1976 in Packer et al. 2003b). Skates do not migrate substantially but do

generally move offshore in summer and early autumn and onshore during winter and spring

(Sosebee 2000). Bottom trawl surveys found juvenile little skates in heavy concentrations

nearshore in Cape Cod Bay in the spring (Packer et al. 2003b). Adults were also found in Cape

Cod Bay during the spring, summer, and fall (Packer et al. 2003b).

The PNPS intake and discharge have the potential to adversely affect EFH for the little skate. 

However, it is unlikely that PNPS intake operations are adversely affecting juvenile and adult

little skate as the species has not been reported to be entrained (Normandeau 2006a). The

little skate has been observed in the impingement sampling program at PNPS; however, it is not

common (Normandeau 2006b). Due to the small area affected by the thermal plume and

because the little skate would exhibit behavioral avoidance if water temperatures are not within

their preference range, it is unlikely that the PNPS discharge would affect juvenile and adult little

skate EFH. It is unlikely that continued operation of PNPS would have an impact on prey items

of the little skate, as its diet consists primarily of benthic invertebrates. Continued PNPS

operations are likely to have a minimal adverse effect on EFH for the little skate.

Longfin squid (Loligo pealei)

EFH for longfin squid juveniles and adults exists in the vicinity of PNPS. EFH for both juveniles

and adults includes pelagic waters over the continental shelf from the Gulf of Maine to Cape

Hatteras. Both juveniles and adults are typically found in water with temperatures ranging from

39o

F to 81oF, and in water depths ranging from the shore to 700 ft (for juveniles) and shore to

1000 ft (for adults) (NMFS 2006). The species is known to spawn year-round, which can vary

geographically (Brodziak et al. 1996, and Hatfield et al. 2002 in Jacobson 2005).

Food habits of longfin squid depend on size: small individuals consume planktonic organisms

(Vovk 1972, Tibbetts 1977 in Cargnelli et al. 1999a), whereas larger individuals consume
Appendix E

NUREG-1437, Supplement 29 E-114 July 2007

crustaceans and small fish (Vinogradov and Noskov 1979 in Cargnelli et al. 1999a). Seasonal

and inshore/offshore variances in the diets of longfin squid were demonstrated by Maurer and

Bowman (1985 in Cargnelli et al. 1999a). Longfin squid are typically observed in waters with

temperatures of at least 9°C (Lange and Sissenwine 1980 in Cargnelli et al. 1999a). During late

autumn to winter, longfin squid migrate to warmer waters along the edge of the continental shelf

(Cadrin 2000 in ENSR 2000). During the spring and early summer, the species moves inshore

to spawn (Cadrin 2000 in ENSR 2000). 

The intake and discharge at PNPS have the potential to adversely affect a small portion of EFH

for juvenile and adult longfin squid. The longfin squid is reported to be one of the most

commonly impinged species identified in impingement studies at PNPS (ENSR 2000). It has

not been observed in the entrainment sampling at PNPS (Normandeau 2006a). Due to the

small area affected by the thermal plume and because the longfin squid would exhibit

behavioral avoidance if water temperatures are not within their preference range, it is unlikely

that the PNPS discharge would affect juvenile and adult longfin squid EFH. Continued

operation of PNPS may also have the potential to affect prey items of juvenile or adult longfin

squid, either through entrainment of plankton, or via impingement of small forage fish species. 

Continued operations of PNPS are likely to have a less than substantial adverse effect on EFH

for the longfin squid.

Monkfish (Lophius americanus)

EFH for eggs, larval, and adult monkfish exists in the vicinity of PNPS. EFH for monkfish eggs

includes surface waters of the Gulf of Maine, Georges Bank, and southern New England to

North Carolina. The eggs are mostly found in water depths ranging from 15 to 1000 m (49 to

3281 ft), and at temperatures below 18o

C. Larval EFH exists in pelagic waters of the Gulf of

Maine, Georges Bank, and southern New England to North Carolina. This includes areas

where water temperatures are below 18o

C and water depth ranges from 25 to 1000 m (82 to

3281 ft). Adult monkfish EFH is found in bottom habitats with substrates of sand-shell mix,

algae covered rocks, hard sand, pebbly gravel, or mud in the Gulf of Maine, Georges Bank, and

southern New England to the mid-Atlantic. Adult monkfish typically live in water depths from 25

to 200 m (82 to 656 ft), and at temperatures below 15o

C (NMFS 2006). 

Spawning occurs in locations including inshore shoals and offshore surface water, in

temperatures below 18o

C, in the months from May to June within the Gulf of Maine (Scott and

Scott 1988, Hartley 1995 in Steimle et al. 1999b). Eggs are buoyant and are laid in rafts that

may be up to 6 to 12 m (20 to 39 ft) long (Steimle et al. 1999b). Larvae and juveniles are also

pelagic and eventually descend to the bottom to live their adult lifespan as benthic fish (NOAA

1998a in ENSR 2000). Once they have settled to the bottom, juveniles prefer a substrate of

sand-shell mix, algae covered rocks, hard sand, pebbly gravel, or mud, with water temperatures

below 15o

C (NEFMC 1998a in ENSR 2000). Adults spend most of their lives resting on the

bottom in depressions within sandy sediment (Steimle et al. 1999b). The larvae feed on
Appendix E

July 2007 E-115 NUREG-1437, Supplement 29

zooplankton, including copepods and crustacean larvae, while juveniles eat smaller fish,

including sand lance, and shrimp and squid (Bigelow and Schroeder 1953 in Steimle et al.

1999b). Adults eat a variety of benthic and pelagic species, sea birds, and even younger

monkfish, and they capture prey with an ambush or sudden rush (Steimle et al. 1999b). The

monkfish has annual migrations in response to spawning preference and food availability.

The PNPS intake and discharge have the potential to adversely affect egg, larvae, and adult

monkfish EFH. Monkfish eggs and larvae have been consistently collected in the PNPS

entrainment sampling program (Normandeau 2006a). They are only infrequently collected as

part of the PNPS impingement sampling program (Normandeau 2006b). Due to the small area

affected by the thermal plume and because the monkfish would exhibit behavioral avoidance if

water temperatures are not within their preference range, it is unlikely that the PNPS discharge

would affect adult monkfish EFH. Continued operation of PNPS may also have the potential to

affect prey items of various life stages of the monkfish, as several prey items of the monkfish

(zooplankton, sand lance, and squid) have been commonly reported in the impingement and

entrainment sampling program at PNPS. Continued PNPS operations are likely to have a less

than substantial adverse effect on EFH for the monkfish.

Ocean pout (Macrozoarces americanus)

EFH for ocean pout eggs, larvae, juveniles, adults, and spawning adults exists in the vicinity of

PNPS. EFH for eggs, larvae, juveniles, and adults includes bottom habitats in the Gulf of

Maine, Georges Bank, southern New England and the mid-Atlantic region south to Delaware

Bay. Eggs and larvae are typically found at water depths less than 50 m (164 ft), and at

temperatures below 10o

C. EFH for juveniles and adults includes water depths up to 110 m (361

ft) and temperatures below 15o

C (NMFS 2006). Spawning adult EFH consists of areas with

hard bottom substrates, including artificial reefs or shipwrecks, in the Gulf of Maine, Georges

Bank, southern New England, and the mid-Atlantic region south to Delaware Bay. Spawning

usually occurs in water less than 50 m (164 ft) deep and at temperatures below 10o

C.

The species lays eggs in nests, which it then guards until they hatch (Steimle et al. 1999c). 

Both the larvae and adults are demersal and are not known to form schools (Steimle et al.

1999c). There are differing reports on how the ocean pout feeds. According to a report by

MacDonald (1983 in Steimle et al. 1999c), ocean pout feed by sorting through mouthfuls of

sediment for fauna contained within the sediment and do not appear to visually follow prey or

leave the bottom to feed. However, Auster (1985 in Steimle et al. 1999c) reported that ocean

pout hide within sediment depressions to wait for prey to swim or drift by. The prey is reported

to consist of echinoderms, crustaceans, and other benthic invertebrates (Anderson 1994 in

ENSR 2000). The ocean pout does not migrate, although it moves seasonally within a limited

region (Bigelow and Schroeder 1953 in Steimle et al. 1999c). Juvenile ocean pout were

reported to be commonly found in saline water (greater than 25 ppt) in many estuaries and

coastal areas, including Cape Cod Bay, throughout the year (Jury et al. 1994 in Steimle et al.

1999c).
Appendix E

NUREG-1437, Supplement 29 E-116 July 2007

The PNPS intake and discharge have the potential to adversely affect egg, larvae, juvenile,

adult, and spawning adult ocean pout EFH. It is unlikely that PNPS intake operations are

adversely affecting ocean pout as the species has not been reported to be entrained

(Normandeau 2006a). It has only been infrequently observed in the impingement sampling

program (Normandeau 2006b). Due to the small area affected by the thermal plume and

because the ocean pout would exhibit behavioral avoidance if water temperatures are not within

their preference range, it is unlikely that the PNPS discharge would affect juvenile and adult

ocean pout EFH. It is unlikely that continued operation of PNPS would have a impact on prey

items of the ocean pout, as its diet consists primarily of benthic invertebrates. Continued PNPS

operations are likely to have a minimal adverse effect on EFH for the ocean pout.

Ocean quahog (Artica islandica)

EFH for ocean quahog juveniles and adults exists in the vicinity of PNPS. EFH for both

juveniles and adults includes the substrate to a depth of 3 ft below the sediment/water interface

from the eastern edge of the Georges Bank and Gulf of Maine throughout the Atlantic exclusive

economic zone (EEZ). Both juveniles and adults are typically found in water with temperatures

below 60o

F, and in water depths ranging from 30 to 800 feet (NMFS 2006). In the Gulf of Maine

region, they are found in relatively nearshore waters (Weinberg 2001).

Similar to surf clams, ocean quahogs are planktivorous siphon feeders and are preyed upon by

moon snails, boring snails, and predatory fish such as haddock and cod (Cargnelli et al. 1999d). 

Estimates for attaining sexual maturity have ranged from 9 to 13 years (Cargnelli et al. 1999d).

The PNPS intake and discharge have the potential to adversely affect juvenile and adult ocean

quahog EFH. However, it is unlikely that PNPS intake operations are adversely affecting eggs

or larval ocean quahog as the species has not been reported to be entrained or impinged

(ENSR 2000, Normandeau 2006a, Normandeau 2006b). The thermal discharge is unlikely to

affect ocean quahog juveniles and adults because the affected area makes up a tiny portion of

their EFH. Due to the small area affected by the thermal plume and because the ocean quahog

would exhibit behavioral avoidance if water temperatures are not within their preference range,

it is unlikely that the PNPS discharge would affect juvenile and adult ocean quahog EFH. 

Continued operation of PNPS may also have the potential to affect prey items of the ocean

quahog as it is a filter feeder on plankton and entrainment by the plant removes plankton from

the local environment. 

Continued PNPS operations are likely to have a minimal adverse effect on EFH for the ocean

quahog.
Appendix E

July 2007 E-117 NUREG-1437, Supplement 29

Pollock (Pollachius virens)

EFH for pollock larvae, juveniles, and adults exists in the vicinity of PNPS. EFH for eggs and

larval pollock includes pelagic waters of the Gulf of Maine and Georges Bank in water depths

from 10 to 270 m (33 to 886 ft) and at water temperatures below 17o

C. Juvenile, adult, and

spawning adult EFH consists of bottom habitats with hard substrates, including artificial reefs,

sand, mud, or rocks in the Gulf of Maine and Georges Bank. Juvenile pollock are found at

water depths from 0 to 250 m (820 ft) and at temperatures below 18o

C. Adult and spawning

adult pollock are found at water depths ranging from 15 to 365 m (49 to 1197 ft), and

temperatures below 14o

C (adults) and 8oC (spawning adults) (NMFS 2006). The western Gulf

of Maine, including Massachusetts Bay, is one of the principal spawning sites for pollock

(Cargnelli et al. 1999g). Spawning in the Gulf of Maine occurs from November to February

(Steele 1963, Colton and Marak 1969 in Cargnelli et al. 1999e), at water temperatures from

4.5°C to 6o

C (Cargnelli et al. 1999g). Eggs are spawned on hard substrates in water depths

between 10 and 365 m (33 to 1197 ft) (NEFMC 1998a in ENSR 2000).

Pollock eggs and larvae are pelagic until the larvae reach an age of about 3 to 4 months. At

that time, the small juveniles migrate inshore and inhabit rocky subtidal and intertidal zones. At

the end of their second year, the juveniles move offshore, where they remain through their adult

life (Cargnelli et al. 1999g). Larvae living in near-surface waters feed on larval copepods

(Steele 1963 in Cargnelli et al. 1999g), while juvenile pollock feed on crustaceans (Cargnelli et

al. 1999g) and fish, including young Atlantic herring (Ojeda and Dearborn 1991 in Cargnelli et

al. 1999g). The primary food source for adults is euphausiids (Meganyctiphanes norvegica) and

Atlantic herring (Cargnelli et al. 1999g). Pollock is a schooling species, but do not have

substantial migration, expect for small movements related to temperature change (Hardy 1978

in Cargnelli et al. 1999g).

The PNPS intake and discharge have the potential to adversely affect juvenile and adult pollock

EFH. However, it is unlikely that PNPS intake operations are adversely affecting pollock as

eggs and larvae are only periodically entrained (Normandeau 2006a) and other life stages have

also not been commonly reported in the impingement sampling program (Normandeau 2006b). 

Due to the small area affected by the thermal plume and because the pollock would exhibit

behavioral avoidance if water temperatures are not within their preference range, it is unlikely

that the PNPS discharge would affect juvenile and adult pollock EFH. Continued operation of

PNPS may also have the potential to affect prey items of various life stages of the pollock, as

several prey items of the pollock (zooplankton and herring) have been commonly reported in the

impingement and entrainment sampling program at PNPS. Continued PNPS operations are

likely to have a minimal adverse effect on EFH for the pollock.
Appendix E

NUREG-1437, Supplement 29 E-118 July 2007

Red hake (Urophycis chuss)

EFH for red hake eggs, larvae, juveniles, and adults exists in the vicinity of PNPS. EFH for

eggs and larval red hake includes surface waters of the Gulf of Maine, Georges Bank, the

continental shelf off southern New England, and the mid-Atlantic region south to Cape Hatteras. 

Red hake eggs are found in water at temperatures below 10o

C. Larvae are found at water

depths less than 200 m (656 ft) and at temperatures below 19o

C. Juveniles, adults, and

spawning adults are all found in bottom habitats, with juveniles preferring substrates of shell

fragments and live scallops, and adults and spawning adults being found near substrates of

sand and mud. The juveniles, adults, and spawning adults are all typically found in waters less

than 100 m (328 ft) deep and in water temperatures below about 16o

C (NMFS 2006). Spawning

occurs in water at temperatures of 5o

C to 10oC (Steimle et al. 1999a), within depressions in

muddy or sandy substrates (NEFMC 1998a in ENSR 2000). The primary spawning grounds

include the southern edge of Georges Bank and shallow areas off of the southern New England

coast (Sosebee 1998 in ENSR 2000). 

Both the eggs and larvae of the red hake are pelagic, occurring in surface waters less than 10o

C

(eggs) and 19o

C (larvae) (NEFMC 1998a in ENSR 2000). Shelter is an important habitat

requirement for red hake (Steiner et al. 1982 in Steimle et al. 1999a). When the fish become

juveniles, they migrate to shallower waters along the coast and live among shell litter or live

scallop beds (Cohen et al. 1990, NEFMC 1998a in ENSR 2000). Adult red hake typically live in

areas with soft sediment bottoms and, less commonly, near gravel or rock bottoms (Steimle et

al. 1999a). Larvae feed mainly on copepods and other micro-crustaceans (Steimle et al.

1999a). Juvenile red hake feed primarily on crustaceans such as amphipods and shrimp. The

adults feed on amphipods and shrimp, as well as squid, herring, various flatfish species, and

mackerel (Cohen et al. 1990 in ENSR 2000). Red hake migrate extensively due to seasonal

and temperature variations. During winter, they live offshore in water greater than 100 m (328

ft) deep, but in summer, red hake migrate into shallow coastal water and estuaries of the Gulf of

Maine, and live in water less than 10 m (33 ft) deep (Steimle et al. 1999a).

The PNPS intake and discharge have the potential to adversely affect egg, larvae, juvenile,

adult, and spawning adult red hake EFH. Eggs and larvae have been consistently observed in

the PNPS entrainment sampling program (Normandeau 2006a). Red hake have also been

commonly observed in the PNPS impingement sampling program (Normandeau 206b). 

However the area affected by the intake system is small and, thus, impacts to red hake EFH are

not expected. Due to the small area affected by the thermal plume and because the red hake

would exhibit behavioral avoidance if water temperatures are not within their preference range,

it is unlikely that the PNPS discharge would affect juvenile and adult red hake EFH. Continued

operation of PNPS may also have the potential to affect prey items of various life stages of the

red hake, as several prey items of the red hake (zooplankton, squid, herring, flatfish species,

and mackerel) have been commonly reported in the impingement and entrainment sampling
Appendix E

July 2007 E-119 NUREG-1437, Supplement 29

program at PNPS. Continued PNPS operations may have a substantial adverse effect on EFH

for the red hake.

Scup (Stenotomus chrysops)

EFH for scup eggs, larvae, juvenile, and adults exists in the vicinity of PNPS. For eggs and

larvae, EFH includes estuaries where scup were identified as common or abundant in the ELMR

database for the mixing and seawater salinity zones (NMFS 2006, Jury et al. 1994). EFH for

juveniles and adults in offshore areas includes demersal waters over the Continental Shelf from

the Gulf of Maine to Cape Hatteras. EFH for juveniles and adults in inshore areas includes

estuaries where scup are identified as being common or abundant in the ELMR database for the

mixing and seawater salinity zones (NMFS 2006, Jury et al. 1994). Both juvenile and adult scup

EFH occurs in waters where temperatures are greater than 45o

F (NMFS 2006). Southern New

England, including Massachusetts Bay, is considered to be a primary spawning area for scup

(Steimle et al. 1999f). Scup spawn in shallow shoal waters less than 10 m (33 ft) deep until late

June, and then move to deeper water (MAFMC 1996a in Steimle et al. 1999f). 

Both eggs and larvae are pelagic, and the larvae become demersal in shoal areas in early July

(Able and Fahay 1998 in Steimle et al. 1999f). The adults can occupy a variety of benthic

habitats, from open water to structured areas (Steimle et al. 1999f). Both juvenile and adult

scup are benthic feeders. Adults eat small crustaceans, polychaetes, mollusks, small squid,

vegetable detritus, insect larvae, sand dollars, and small fish (Bigelow and Schroeder 1953,

Morse 1978, Sedberry 1983 in Steimle et al. 1999f). Smaller scup are frequently found in bays

and estuaries, but larger adult scup usually live in deeper water ranging from 70 to 180 m (230

to 590 ft) (Steimle et al. 1999f). Larval scup were reported in Cape Cod Bay in May through

September, in water with temperatures of 14o

C to 22oC (MAFMC 1996a in Steimle et al. 1999f). 

The PNPS intake and discharge have potential to adversely affect egg, larvae, juvenile, and

adult scup EFH. However, it is unlikely that PNPS intake operations are adversely affecting

scup as eggs and larvae have only been infrequently observed in the entrainment sampling

program (Normandeau 2006a) and are not common in the impingement sampling program

(Normandeau 2006b). Due to the small area affected by the thermal plume and because the

scup would exhibit behavioral avoidance if water temperatures are not within their preference

range, it is unlikely that the PNPS discharge would affect juvenile and adult scup EFH. 

Continued operation of PNPS may also have the potential to affect prey items of various life

stages of the scup, as several prey items of the scup (squid and small fish species) have been

commonly reported in the impingement and entrainment sampling program at PNPS. 

Continued PNPS operations are likely to have a minimal adverse effect on EFH for the scup.
Appendix E

NUREG-1437, Supplement 29 E-120 July 2007

Shortfin squid (Illex illecebrosus)

EFH for shortfin squid juveniles and adults exists in the vicinity of PNPS. EFH for both juveniles

and adults includes pelagic waters over the continental shelf from the Gulf of Maine to Cape

Hatteras. Both juveniles and adults are typically found in water with temperatures ranging from

39o

F to 73oF, and at water depths ranging from the shore to 600 ft (NMFS 2006).

The shortfin squid is highly migratory and is found primarily in the offshore waters of the

continental shelf and slope from Florida to Labrador (Hendrickson 2000 in ENSR 2000).

Individuals experience an extensive spawning migration to warmer waters south of Cape

Hatteras during the autumn (Hendrickson 2000 in ENSR 2000). Peak spawning occurs during

the winter, and larvae and juveniles are conveyed northward in the warm waters of the Gulf

Stream (Hendrickson 2000 in ENSR 2000). The squid that spawned throughout the winter will

migrate during late spring onto the continental shelf (Hendrickson 2000 in ENSR 2000). The diet

of the shortfin squid typically consists of fish and crustaceans (Squires 1957; Froerman 1984,

Mauer and Bowman 1985; Dawe 1988 in Cargnelli et al. 1999a).

The PNPS intake and discharge have the potential to adversely affect juvenile and adult shortfin

squid EFH. It is unlikely that PNPS intake operations are adversely affecting juvenile and adult

shortfin squid as the species has not been entrained or impinged at PNPS (Normandeau 2006a;

Normandeau 2006b). Due to the small area affected by the thermal plume and because the

shortfin squid would exhibit behavioral avoidance if water temperatures are not within their

preference range, it is unlikely that the PNPS discharge would affect juvenile and adult shortfin

squid EFH. Continued operation of PNPS may also have the potential to affect prey items of

various life stages of the shortfin squid, as one of their prey items (small fish species) have

been commonly reported in the impingement and entrainment sampling program at PNPS. 

Continued PNPS operations are likely to have a minimal adverse effect on EFH for the shortfin

squid.

Smooth skate (Malacoraja senta)

EFH for smooth skate juveniles exists in the vicinity of PNPS. In the 2003 FMP for the

Northeast Skate Complex (NEFMC 2003), EFH was designated for the smooth skate. This

designation included bottom habitats with substrates of sand, gravel, broken shell, pebbles, and

soft mud in the Gulf of Maine, including portions of Cape Cod Bay, for juveniles (NEFMC 2003). 

The water depth range for the smooth skate is from 31 to 874 m (102 to 2867 ft), with most

being found from 110 to 457 m (361 to 1499 ft) (McEachran and Musick 1975, McEachran 2002

in Packer et al. 2003d). The temperature range of the species is from 2o

C to 13oC for juveniles

and adults, with most found between temperatures of 4o

C to 8oC (Packer et al. 2003d). The

smooth skate is found mostly on bottom substrates of soft mud and fine sediments (Bigelow and

Schroeder 1953, McEachran and Musick 1975, Scott 1982 in Packer et al. 2003d). 
Appendix E

July 2007 E-121 NUREG-1437, Supplement 29

Little information is known of the life history of the smooth skate (Packer et al. 2003d). Eggs of

all skates are known to be encapsulated in a leathery capsule that rests on the bottom

(Sosebee 2000, Packer et al. 2003d). The eggs hatch fully developed, so there is no larval

stage (Sosebee 2000, McEachran 2002 in Packer et al. 2003d). Females with fully formed egg

capsules are found in both summer and winter (McEachran 2002 in Packer et al. 2003d), but no

other information on spawning times or locations is available. The primary food source for the

smooth skate is epifaunal crustaceans, with decapod shrimps and mysids also being important

(McEachran 1973, McEachran et al. 1976, Bowman et al. 2000, McEachran 2002 in Packer et

al. 2003d). Skates do not migrate substantially, but do generally move offshore in summer and

early autumn, and onshore during winter and spring (Sosebee 2000). No seasonal trends in

abundance were identified by McEachran and Musick (1975 in Packer et al. 2003d). Inshore

trawl surveys in Massachusetts identified juveniles in both the spring and fall near Cape Cod

Bay (Packer et al. 2003d). 

The PNPS intake and discharge have the potential to adversely affect EFH for the smooth

skate. However, it is unlikely that PNPS intake operations are adversely affecting juvenile

smooth skate as the species has not been entrained or impinged at PNPS (Normandeau 2006a,

Normandeau 2006b). Due to the small area affected by the thermal plume and because the

smooth skate would exhibit behavioral avoidance if water temperatures are not within their

preference range, it is unlikely that the PNPS discharge would affect juvenile smooth skate

EFH. It is unlikely that continued operation of PNPS would have a impact on prey items of the

smooth skate, as its diet consists primarily of benthic invertebrates. Continued PNPS

operations are likely to have a minimal adverse effect, if any, on EFH for the smooth skate.

Spiny dogfish (Squalus acanthias)

EFH for spiny dogfish juveniles and adults exists in the vicinity of PNPS. EFH for both juveniles

and adults includes both offshore and inshore habitats. The offshore EFH includes waters of

the continental shelf in areas that encompass the highest 90 percent of all ranked 10-minute

squares for the area where juvenile dogfish were collected in the NEFSC trawl surveys. Inshore

EFH encompasses the saline portions of the estuaries where dogfish are common or abundant

on the Atlantic coast, from Passamaquoddy Bay, Maine to Cape Cod Bay, Massachusetts. 

Both juveniles are typically found in water with temperatures ranging from 37o

F to 82oF, and at

water depths ranging from 33 to 1476 ft (NMFS 2006).

The adult spiny dogfish is a voracious and opportunistic predator and is reported to prey on a

variety of fish, mollusks, and crustaceans. The species travels in large packs and attacks

schools of fish, including cod, haddock, capelin (Mallotus villasus), mackerel, herring, and sand

lance (McMillan and Morse 1999). Spiny dogfish migrate annually in schools from winter habitat

on the edge of the continental shelf to summer habitat in the Gulf of Maine and Georges Bank. 

Trawl surveys conducted in Massachusetts identified an abundance of adult spiny dogfish within
Appendix E

NUREG-1437, Supplement 29 E-122 July 2007

Cape Cod Bay in the spring. Both juveniles and adults were abundant within Cape Cod Bay in

the fall (McMillan and Morse 1999).

The PNPS intake and discharge have the potential to adversely affect juvenile and adult spiny

dogfish EFH. However, it is unlikely that PNPS intake operations are adversely affecting

juvenile and adult spiny dogfish as the species has not been reported to be entrained at PNPS

(Normandeau 2006a). The spiny dogfish has also only been periodically observed in the PNPS

impingement sampling program (Normandeau 2006b). Due to the small area affected by the

thermal plume and because the spiny dogfish would exhibit behavioral avoidance if water

temperatures are not within their preference range, it is unlikely that the PNPS discharge would

affect juvenile and adult spiny dogfish EFH. Continued operation of PNPS may also have the

potential to affect prey items of juvenile and adult spiny dogfish, as several prey items of the

spiny dogfish (cod, haddock, mackerel, herring, and sand lance) have been commonly reported

in the impingement and entrainment sampling program at PNPS. Continued PNPS operations

are likely to have a minimal adverse effect on EFH for the spiny dogfish.

Summer flounder (Paralicthys dentatus)

EFH for summer flounder adults exists in the vicinity of PNPS. Offshore EFH includes demersal

waters of the continental shelf from the Gulf of Maine to Cape Hatteras, and inshore EFH

includes estuaries where summer flounder are identified as being common or abundant. 

Summer flounder adults typically live in water depths shallower than 500 ft (NMFS 2006). In

southern New England and the mid Atlantic, spawning occurs primarily in September (Berrien

and Sibunka 1999 in Packer et al. 1999). Spawning occurs in open ocean areas of the shelf

(Packer et al. 1999), in waters ranging from 30 to 200 m (98 to 656 ft) deep (ENSR 2000). The

timing of spawning coincides with maximum production of autumn plankton, which is the primary

food source for larvae (Morse 1981 in Packer et al. 1999).

Both eggs and larvae of the species are buoyant and pelagic. Eggs are most abundant in the

northwest Atlantic in October and November, and larvae are most abundant from October to

December (Able et al. 1990 in Packer et al. 1999). The larvae are transported toward coastal

areas by the prevailing water currents, and development of post-larvae and juveniles occurs

primarily within bays and estuarine areas (ENSR 2000). Juvenile summer flounder feed upon

crustaceans and polychaetes, and as they grow larger they begin to feed more on fish (Packer et

al. 1999). Adults are opportunistic feeders, preying mostly on fish and crustaceans (Packer et al.

1999). Species preyed upon include windowpane flounder, winter flounder, Atlantic menhaden,

red hake, silver hake, scup, Atlantic silverside, and bluefish, among others (Packer et al. 1999). 

Adult summer flounder in Massachusetts migrate inshore in May and migrate to offshore waters in

late fall (Packer et al. 1999). The shoal waters of Cape Cod Bay, including estuaries and harbors,

are considered to be critically important habitat for the species (Packer et al. 1999). 
Appendix E

July 2007 E-123 NUREG-1437, Supplement 29

The PNPS intake and discharge have the potential to adversely affect adult summer flounder

EFH. However, it is unlikely that PNPS intake operations are adversely affecting adult summer

flounder as eggs and larvae of the species have not been commonly entrained at PNPS

(Normandeau 2006a), and summer flounder have only been infrequently observed in the

impingement sampling program (Normandeau 2006b). Due to the small area affected by the

thermal plume and because the summer flounder would exhibit behavioral avoidance if water

temperatures are not within their preference range, it is unlikely that the PNPS discharge would

affect juvenile and adult summer flounder EFH. Continued operation of PNPS may also have the

potential to affect prey items of adult summer flounder, as several prey items of the summer

flounder (windowpane flounder, winter flounder, Atlantic menhaden, red hake, silver hake, scup,

and Atlantic silverside) have been commonly reported in the impingement and entrainment

sampling program at PNPS. Continued PNPS operations are likely to have a less than

substantial adverse effect on EFH for the summer flounder.

Surf clam (Spisula solidissima)

EFH for surf clam juveniles and adults exists in the vicinity of PNPS. EFH for both juveniles and

adults includes the substrate to a depth of 3 ft below the sediment/water interface from the

eastern edge of Georges Bank and the Gulf of Maine throughout the Atlantic EEZ. Both juveniles

and adults are typically found in water depths ranging from the beach zone to 200 ft (NMFS

2006).

Surf clams are planktivorous siphon feeders whose diet includes diatoms and ciliates (Cargnelli et

al. 1999c). They are preyed upon by moon snails, boring snails, and predatory fish such as

haddock and cod. Surf clams are capable of reproduction in their first year of life, although they

may not reach full maturity until the second year (Weinberg 2000). Water currents in areas where

planktonic surf clam larvae live are important in determining eventual patterns of distribution and

settlement for developing juveniles (ENSR 2000).

The PNPS intake and discharge have the potential to adversely affect juvenile and adult surf clam

EFH. However, it is unlikely that PNPS intake operations are adversely affecting eggs or larval

surf clams as the species has not been reported to be entrained or impinged at PNPS

(Normandeau 2006a, Normandeau 2006b). The thermal discharge is unlikely to affect surf clam

juveniles and adults because the affected area makes up a tiny portion of their EFH. Continued

operation of PNPS may also have the potential to affect prey items of the surf clam as it is a filter

feeder on plankton and entrainment by the plant removes plankton from the local environment. 

Continued PNPS operations are likely to have a minimal adverse effect on EFH for the surf clam.

Thorny skate (Amblyraja radiata)

EFH for thorny skate juveniles and adults exists in the vicinity of PNPS. In the 2003 FMP for the

Northeast Skate Complex (NEFMC 2003), EFH was designated for the thorny skate. This
Appendix E

NUREG-1437, Supplement 29 E-124 July 2007

designation included bottom habitats with substrates of sand, gravel, broken shell, pebbles, and

soft mud in the Gulf of Maine, including portions of Cape Cod Bay, for both juveniles and adults

(NEFMC 2003). The water depth of the thorny skate habitat can range from 18 to 1200 m (59 to

3937 ft) (McEachran 2002 in Packer et al. 2003c). Trawl surveys in the Gulf of Maine found most

adults in the range from 71 to 300 m (233 to 984 ft), and at temperatures between 4o

C and 9oC

(Packer et al. 2003c). The species can be found over a variety of substrates, including sand,

gravel, broken shell, pebbles, and soft mud (Bigelow and Schroeder 1953 in Packer et al. 2003c).

Eggs of all skates are known to be encapsulated in a leathery capsule that rests on the bottom

(Sosebee 2000, Packer et al. 2003c). The eggs hatch fully developed, so there is no larval stage

(Sosebee 2000, McEachran 2002 in Packer et al. 2003c). Based on the capture of females with

fully formed egg capsules, spawning is thought to occur throughout the year, but with a peak

during the summer (Templeman 1982a, McEachran 2002 in Packer et al. 2003c). The primary

prey for the thorny skate is fish, including haddock, sand lance, and redfish (Sebastes Spp.)

(Templeman 1982b in Packer et al. 2003c). Skates do not migrate substantially, but do generally

move offshore in summer and early autumn, and onshore during winter and spring (Sosebee

2000).

The PNPS intake and discharge have the potential to adversely affect EFH for the thorny skate. 

However, it is unlikely that PNPS intake operations are adversely affecting juvenile and adult

thorny skate as the species has not been reported to be entrained or impinged at PNPS

(Normandeau 2006a, Normandeau 2006b). Due to the small area affected by the thermal plume

and because the thorny skate would exhibit behavioral avoidance if water temperatures are not

within their preference range, it is unlikely that the PNPS discharge would affect juvenile and adult

thorny skate EFH. Continued operation of PNPS may also have the potential to affect prey items

of juvenile and adult thorny skate, as one of the prey items of the thorny skate (sand lance) has

been commonly reported in the impingement and entrainment sampling program at PNPS. 

Continued PNPS operations are likely to have a minimal adverse effect on EFH for thorny skate.

White hake (Urophycis tenuis)

EFH for white hake eggs, larvae, juveniles, and adults exists in the vicinity of PNPS. EFH for

eggs is found in surface waters of the Gulf of Maine, Georges Bank, and southern New England. 

EFH for both larvae and pelagic juveniles is identified as pelagic waters of the Gulf of Maine, the

southern edge of Georges Bank, and southern New England to the mid Atlantic. Demersal

juvenile and adult EFH includes bottom habitats with substrates of seagrass, mud, or fine-grained

sand in the Gulf of Maine, the southern edge of Georges Bank, and southern New England to the

mid Atlantic. Demersal juveniles and adults live in water from 5 to 325 m (16 to 1066 ft) deep,

and with a temperature below 19o

C (for juveniles) and 14oC (for adults) (NMFS 2006). The white

hake spawning grounds are centered on the Gulf of St. Lawrence, the southern Georges Bank,

and Mid Atlantic Bight. The contribution of the Gulf of Maine as a spawning ground is reported to

be negligible (Fahay and Able 1989 in Chang et al. 1999a). The eggs, larvae, and early juvenile
Appendix E

July 2007 E-125 NUREG-1437, Supplement 29

stages of the white hake are pelagic (Chang et al. 1999a), and are found in surface waters of the

Gulf of Maine, Georges Bank and southern New England (NEFMC 1998a in ENSR 2000). 

Juvenile white hake feed mainly on polychaetes, shrimp, and other crustaceans, and adults feed

primarily on crustaceans and other fish, including juvenile white hakes (Langston et al. 1994 in

Chang et al. 1999a). Migration of adults occurs annually, with adults moving to shallower waters

in the spring to spawn, and then moving offshore in the autumn. A summary of annual NMFS

Bottom Trawl Survey data identified no white hake in Cape Cod Bay during the fall between 1979

and 2003, and only a few limited occurrences in the bay during the spring in those years

(GOMCML 2006).

The PNPS intake and discharge have the potential to adversely affect egg, larvae, juvenile, and

adult white hake EFH. White hake eggs and larvae are frequently observed in the PNPS

entrainment sampling program (Normandeau 2006a). Life stages of the white hake have also

been observed in the PNPS impingement sampling program continually over its operating history

(Normandeau 2006b). However, it is unlikely that PNPS intake operations are adversely affecting

juvenile and adult white hake as the area affected by the intake system is small. Due to the small

area affected by the thermal plume and because the white hake would exhibit behavioral

avoidance if water temperatures are not within their preference range, it is unlikely that the PNPS

discharge would affect juvenile and adult white hake EFH. Continued operation of PNPS may

also have the potential to affect prey items of adult white hake, as the adults are known to prey on

juveniles, which have been have been commonly reported in the impingement sampling program

at PNPS. Continued PNPS operations are likely to have a less than substantial adverse effect on

EFH for the white hake.

Whiting/Silver hake (Merluccius bilinearis)

EFH for eggs, larvae, juveniles, adults, and spawning adults of the whiting (also known as silver

hake) exists in the vicinity of PNPS. EFH for eggs includes surface waters of the Gulf of Maine,

Georges Bank, the continental shelf off southern New England, and the mid-Atlantic region south

to Cape Hatteras, with water depths between 50 to 150 m (164 to 492 ft) and temperatures below

20o

C. For larvae, the EFH consists of surface waters of the Gulf of Maine, Georges Bank, the

continental shelf off southern New England, and the mid-Atlantic region south to Cape Hatteras. 

Larvae also are found at water depths between 50 to 150 m (164 to 492 ft) and temperatures

below 20o

C. Juvenile, adult, and spawning adult EFH for the whiting includes bottom habitats of

all substrate types in the Gulf of Maine, on Georges Bank, the continental shelf off southern New

England, and the mid-Atlantic region south to Cape Hatteras. Juveniles and adults typically live in

water between 20 and 325 m (66 to 1066 ft) deep and temperatures below 22o

C. Spawning

typically occurs in water depths between 30 and 325 m (98 to 1066 ft) and at temperatures below

13o

C (NMFS 2006). The adults spawn over a variety of substrates in the Gulf of Maine, Georges

Bank, and the southern New England area south of Martha’s Vineyard (Lock and Packer 2004). 

Spawning within the Gulf of Maine generally begins in June, with a peak in July to August (Lock

and Packer 2004).
Appendix E

NUREG-1437, Supplement 29 E-126 July 2007

Whiting eggs and larvae are pelagic, existing in the water column at depths between 50 and 150

m (164 and 492 ft) (NEFMC 1998a in ENSR 2000). As larvae mature into juveniles, they settle to

the bottom (Lock and Packer 2004). As adults, whiting are found in water at depths ranging from

shallow to greater than 400 m (1312 ft) (Dery 1988, Bolles and Begg 2000 in Lock and Packer

2004). Juvenile whiting feed mainly on crustaceans (Cohen et al. 1990 in ENSR 2000), and the

adults feed on both fish and pelagic invertebrates, such as shrimp and squid (Mayo 1998 in

ENSR 2000). Whiting are a dominant predator species on the continental shelf in the northwest

Atlantic, and their dominant biomass and high prey consumption help to regulate the ecosystem

(Bowman 1984, Garrison and Link 2000 in Lock and Packer 2004). The migration of whiting is

seasonal. The northern stock moves to the deep basins of the Gulf of Maine during the winter,

and migrates into nearshore waters in the Gulf of Maine in the spring and summer (Lock and

Packer 2004). Trawl surveys conducted for whiting in 1999 identified concentrations of whiting in

Cape Cod Bay in spring and autumn (Reid et al. 1999 in Lock and Packer 2004). A summary of

annual NMFS Bottom Trawl Survey data identified substantial numbers of whiting in Cape Cod

Bay during the fall every year between 1979 and 2003, but found a more limited number in the

bay during the spring in those years (GOMCML 2006).

The PNPS intake and discharge have the potential to adversely affect egg, larvae, juvenile,

adults, and spawning adult EFH for whiting. Whiting eggs and larvae are frequently observed in

the PNPS entrainment sampling program (Normandeau 2006a). Life stages of the whiting have

also been observed in the PNPS impingement sampling program continually over the operating

history of the facility (Normandeau 2006b). However, it is unlikely that PNPS intake operations

are adversely affecting whiting as the area affected by the intake system is small. Due to the

small area affected by the thermal plume and because the whiting would exhibit behavioral

avoidance if water temperatures are not within their preference range, it is unlikely that the PNPS

discharge would affect juvenile and adult whiting EFH. Continued operation of PNPS may also

have the potential to affect prey items of adult whiting, as several prey items of the whiting (small

fish and squid) have been commonly reported in the impingement and entrainment sampling

program at PNPS. Continued PNPS operations may have a substantial adverse effect on EFH for

the whiting.

Windowpane flounder (Scopthalmus aquosus)

EFH for windowpane flounder eggs, larvae, juveniles, adults, and spawning adults exists in the

vicinity of PNPS. EFH for eggs includes surface waters on the perimeter of the Gulf of Maine,

Georges Bank, southern New England, and the mid-Atlantic region south to Cape Hatteras. EFH

for larvae includes pelagic waters, with water depths between 50 to 150 m (164 to 492 ft) and

temperatures below 20o

C. For larvae, the EFH consists of surface waters on the perimeter of the

Gulf of Maine, Georges Bank, southern New England, and the mid-Atlantic region south to Cape

Hatteras. Both eggs and larvae are found in water depths less than 70 m (230 ft), and in water

temperatures below 20o

C. Juvenile, adult, and spawning adult EFH includes bottom habitats with

substrates of mud or fine-grained sand on the perimeter of the Gulf of Maine, Georges Bank,
Appendix E

July 2007 E-127 NUREG-1437, Supplement 29

southern New England, and the mid-Atlantic region south to Cape Hatteras. These areas are

generally 1 to 100 m (3 to 328 ft) deep and have water temperatures below 26o

C (NMFS 2006).

The windowpane flounder prefers a soft bottom substrate for spawning, and generally spawns

between April and December, with peak spawning activity in July and August on Georges Bank

and in May in the mid-Atlantic region (NEFMC 1998a, Hendrickson 1998 in ENSR 2000). 

Both the eggs and larvae are pelagic, and exist in surface waters cooler than 20o

C (NEFMC

1998a in ENSR 2000). The prey for the windowpane flounder is small benthic invertebrates,

including polychaete worms and amphipods. The species may also prey on small forage bony

fish species (Langston and Bowman 1981 in ENSR 2000). Juveniles living in shallow waters tend

to move to deeper waters as they mature (Chang et al. 1999b). In studies in Massachusetts,

juveniles were most abundant in inshore waters at depths of less than 20 m (66 ft) and at water

temperatures between 5°C to 12o

C in the spring and between 12°C to 19oC in the fall (Chang et

al. 1999b).

The intake and discharge at PNPS have the potential to adversely affect a small portion of EFH

for eggs, larvae, juvenile, adults, and spawning adult windowpane flounder. Eggs of the

windowpane flounder dominated entrainment samples at PNPS (ENSR 2000, Normandeau

2006a). Larvae have also been consistently collected in the plant’s entrainment sampling

program throughout the history of the facility (Normandeau 2006a). In addition, windowpane

flounder have been continually observed in the PNPS impingement sampling program throughout

the history of the facility (Normandeau 2006b). Due to the small area affected by the thermal

plume and because the windowpane flounder would exhibit behavioral avoidance if water

temperatures are not within their preference range, it is unlikely that the PNPS discharge would

affect juvenile and adult windowpane flounder EFH. Continued operation of PNPS may also have

the potential to affect prey items of the windowpane flounder, as one of its prey items (small fish)

has been commonly reported in the impingement and entrainment sampling program at PNPS. 

Continued operations of PNPS may have a adverse effect substantial effect on EFH for the

windowpane flounder.

Winter flounder (Pseudopleuronectes americanus)

EFH for winter flounder eggs, larvae, juveniles, adults, and spawning adults exists in the vicinity of

PNPS. EFH for eggs includes bottom habitats with substrates of sand, muddy sand, and gravel

on the Georges Bank, the inshore areas of the Gulf of Maine, southern New England, and the

mid-Atlantic region south to Delaware Bay. Eggs are typically found in water at depths less than

5 m (16 ft), and in water with temperatures less than 10o

C. Larval EFH occurs in pelagic and

bottom waters of Georges Bank, inshore areas of the Gulf of Maine, southern New England, and

the mid-Atlantic region south to Delaware Bay. Larval EFH includes water less than 6 m (20 ft)

deep and with temperatures below 15o

C. EFH for juvenile winter flounder includes bottom

habitats with substrates of mud or fine-grained sand on Georges Bank, inshore areas of the Gulf

of Maine, southern New England, and the mid-Atlantic region south to Delaware Bay. Young of

year juveniles are found at water depths from 0.1 to 10 m (0.3 to 33 ft) and temperatures below
Appendix E

NUREG-1437, Supplement 29 E-128 July 2007

28oC. Age 1+ juveniles are found at water depths ranging from 1 to 50 m (3 to 164 ft) and at

temperatures below 25o

C. EFH for both adults and spawning adults includes bottom habitats,

including estuaries, with substrates of mud, muddy sand, sand, and gravel on Georges Bank,

inshore areas of the Gulf of Maine, southern New England, and the mid-Atlantic region south to

the Delaware Bay. Adult winter flounder live in water at depths ranging from 1 to 100 m (3 to 328

ft) with temperatures below 25o

C. Spawning adults are found at water depths less than 6 m (262

ft), except for on Georges Bank, where they spawn as deep as 80 m. Water temperatures for

spawning adults are typically below 15o

C (NMFS 2006). Spawning takes place at night over

sandy bottoms in shallow estuaries starting in mid December and ending in May, with a peak in

the February to March time frame.

The various life stages of winter flounder can generally be found in areas where the bottom

habitat has a substrate of mud, sand, or gravel (NEFMC 1998b). Winter flounder eggs are

demersal, adhesive, and stick together in clusters, and hatching may occur in 2 to 3 weeks,

depending upon the water temperature (Bulloch 1986; Pereira et al.1999). Larvae are initially

planktonic, but, as metamorphosis continues, they settle to the bottom. Newly metamorphosed

young of year fish take up residence in shallow water. Pereira et al. (1999) describes winter

flounder as omnivorous or opportunistic feeders, consuming a wide variety of prey, with

polychaetes and amphipods making up the majority of their diet. Typically adult winter flounder

migrate inshore in the fall and early winter and spawn in later winter and early spring. Then they

may leave inshore areas if the water temperature exceeds 15°C, although there may be

exceptions to this due to water temperature and food availability (Pereira 1999). Winter flounder

may move significant distances (Pereira et al. 1999); however, they also can exhibit a high degree

of fidelity and, in general, their movement patterns are localized (Nitschke et al. 2000). Studies

done by PNPS have shown that winter flounder in the area immediately surrounding PNPS (i.e.,

in Plymouth Outer Harbor) have relatively localized movements and are basically confined to

inshore waters (Lawton et al. 1999), resulting in highly localized populations (Lawton et al. 2000). 

The intake and discharge at PNPS have the potential to adversely affect a small portion of EFH

for eggs, larvae, juvenile, adults, and spawning adult winter flounder. The winter flounder eggs

and larvae dominated entrainment samples at PNPS (Normandeau 2006a). Impingement of

winter flounder has consistently occurred throughout the operating history of the facility; however,

the impingement rates are considered to be low. Due to the small area affected by the thermal

plume and because the winter flounder would exhibit behavioral avoidance if water temperatures

are not within their preference range, it is unlikely that the PNPS discharge would affect juvenile

and adult winter flounder EFH. Continued operation of PNPS may also have the potential to

affect prey items of the winter flounder, as they have been described as omnivores preying on a

variety of fish and invertebrates species, many of which have been commonly reported in the

impingement and entrainment sampling program at PNPS. However, there is a potential that

continued operations of the PNPS intake system may have a substantial, adverse effect on EFH

for winter flounder.
Appendix E

July 2007 E-129 NUREG-1437, Supplement 29

Winter skate (Leucoraja ocellata)

EFH for winter skate juveniles and adults exists in the vicinity of PNPS. In the 2003 FMP for the

Northeast Skate Complex (NEFMC 2003), EFH was designated for the winter skate. This

designation included bottom habitats with substrates of sand, gravel, and mud in Cape Cod Bay

for both juveniles and adults (NEFMC 2003). Winter skates in the Gulf of Maine primarily live at

depths of 46 to 64 m (151 to 210 ft) (Bigelow and Schroeder 1953; McEachran 2002 in Packer et

al. 2003a). The species can live in a variety of water temperatures and are reported near the

Massachusetts coast in water from 1o

C to 20oC (Bigelow and Schroeder 1953 in Packer et al.

2003a). The species prefers sandy and gravel bottom substrates (Scott 1982a in Packer et al.

2003a).

Little information on the life history of the winter skate exists. Eggs of all skates are known to be

encapsulated in a leathery capsule that rests on the bottom (Sosebee 2000, Packer et al. 2003a).

The eggs hatch fully developed, so there is no larval stage (Sosebee 2000, McEachran 2002 in

Packer et al. 2003a). Off of Nova Scotia and in the Gulf of Maine, spawning occurs during

summer and fall (Bigelow and Schroeder 1953 in Packer et al. 2003a). The predominant food

source for winter skates is polychaetes and amphipods, with additional feeding upon decapods,

isopods, bivalves, and fish (McEachran 1973 in Packer et al. 2003a). Fish species that are prey

for the winter skate include smaller skates, eels (Anguilla rostrata), alewives, blueback herring

(Alosa aestivalis), menhaden, smelt, sand lance, chub mackerel (Scomber colias), butterfish,

cunners, and silver hake (Bigelow and Schroeder 1953 in Packer et al. 2003a). Skates do not

migrate substantially, but do generally move offshore in summer and early autumn and onshore

during winter and spring (Sosebee 2000).

The PNPS intake and discharge have the potential to adversely affect EFH for the winter skate. 

However, it is unlikely that PNPS intake operations are adversely affecting juvenile and adult

winter skate as the species has not been reported to be entrained at PNPS (Normandeau 2006a)

and it has only been periodically observed in the PNPS impingement sampling program

(Normandeau 2006b). Due to the small area affected by the thermal plume and because the

winter skate would exhibit behavioral avoidance if water temperatures are not within their

preference range, it is unlikely that the PNPS discharge would affect juvenile and adult winter

skate EFH. Continued operation of PNPS may also have the potential to affect prey items of the

winter skate, as several of its prey items (small skates, alewife, menhaden, smelt, sand lance,

butterfish, cunner, and silver hake) have been commonly reported in the impingement and

entrainment sampling program at PNPS. Continued PNPS operations are likely to have a less

than substantial adverse effect on EFH for winter skate.

Witch flounder (Glyptocephalus cynoglossus)

EFH for witch flounder eggs and larvae exists in the vicinity of PNPS. EFH for eggs of the

species includes surface waters of the Gulf of Maine, Georges Bank, the continental shelf off
Appendix E

NUREG-1437, Supplement 29 E-130 July 2007

southern New England, and the mid-Atlantic region south to Cape Hatteras. EFH for larvae is

found in surface waters to a depth of 250 m (820 ft) in the Gulf of Maine, Georges Bank, the

continental shelf off southern New England, and the mid-Atlantic region south to Cape Hatteras. 

Both eggs and larvae are found in water with temperatures below 13o

C (NMFS 2006). Spawning

occurs from March to November, with peak spawning during the summer, at temperatures from 0

to 10o

C (Bigelow and Schroeder 1953 in Cargnelli et al. 1999h). The western and northern areas

of the Gulf of Maine are reported to be the most active spawning areas for the species (Burnett et

al. 1992 in Cargnelli et al. 1999h). 

Eggs are released on the bottom, but are pelagic and rise to the surface. Larvae are also pelagic,

and juveniles descend to the bottom at the age of 4 to 12 months (Bigelow and Schroeder 1953,;

Evseenko and Nevinsky 1975 in Cargnelli et al. 1999h). The primary prey for the witch flounder is

polychaetes and crustaceans, with additional contribution from mollusks and echinoderms

(Cargnelli et al. 1999h). All life stages of witch flounder are common in Massachusetts Bay. 

Eggs were found to be abundant in Massachusetts Bay in the months of May and June, and the

highest larval densities found were observed in Massachusetts Bay (Cargnelli et al. 1999h). 

Bottom trawl surveys and inshore surveys found the greatest concentrations of juveniles on

Stellwagen Bank in Massachusetts Bay. Adults were found in the highest concentrations in

Massachusetts Bay in the autumn, including some catches in Cape Cod Bay (Cargnelli et al.

1999h).

The PNPS intake and discharge have the potential to adversely affect egg and larvae witch

flounder EFH. Witch flounder eggs and larvae have been observed in the PNPS entrainment

sampling program throughout the operating history of the facility (Normandeau 2006a), while the

witch flounder has not been observed in the PNPS impingement sampling program (Normandeau

2006b). However, it is unlikely that PNPS intake operations are adversely affecting witch flounder

as the area makes up a tiny portion of their EFH. The thermal plume is unlikely to affect EFH for

witch flounder eggs and larvae. It is unlikely that continued operation of PNPS would have a

impact on prey items of the witch flounder, as its diet consists primarily of benthic invertebrates. 

Continued PNPS operations are likely to have a minimal adverse effect on EFH for the witch

flounder.

Yellowtail flounder (Pleuronectes ferruginea)

EFH for yellowtail flounder eggs, larvae, juveniles, adults, and spawning adults exists in the

vicinity of PNPS. EFH for eggs and larval yellowtail flounder includes surface waters of Georges

Bank, Massachusetts Bay, Cape Cod Bay, and the southern New England continental shelf south

to Delaware Bay. Eggs and larvae are found in water at depths between 10 to 90 m (33 to 295

ft), and temperatures below 17o

C. Juvenile, adult, and spawning adult EFH occurs in bottom

habitats with substrates of sand or mud on Georges Bank, the Gulf of Maine, and the southern

New England shelf south to Delaware Bay. Juveniles and adults live in water at depths ranging

from 20 to 50 m (66 to 164 ft) and temperatures below 15o

C. Spawning occurs in water at depths
Appendix E

July 2007 E-131 NUREG-1437, Supplement 29

from 10 to 125 m (33 to 410 ft) and temperatures below 17oC (NMFS 2006). Spawning occurs in

the Gulf of Maine, Georges Bank, and the southern New England shelf during the spring and

summer months (Overholtz and Cadrin 1998; NEFMC 1998a in ENSR 2000). 

Both the eggs and larvae of the yellowtail flounder reside in the water column and are found in

surface waters between mid March and July, peaking between April and June. Larvae may drift in

surface waters before developing into juveniles and dropping to the bottom (Overholtz and Cadrin

1998 in ENSR 2000). Adult yellowtail flounder feed on small benthic invertebrates such as

polychaete worms, isopods, shrimp, and amphipods, and also can feed on small forage fish

(Cooper et al. 1998 in ENSR 2000). Mark and recapture studies have shown that the yellowtail

flounder do not migrate, other than minor movements between shallow and deeper water in

response to seasonal temperature variation (Royce et al. 1959; Lux 1964 in Johnson et al. 1999). 

The PNPS intake and discharge have the potential to adversely affect egg, larvae, juvenile,

adults, and spawning adult yellowtail flounder EFH. Yellowtail flounder eggs and larvae have

been consistently collected in the PNPS entrainment sampling program throughout the operating

history of the plant (Normandeau 2006a). The yellowtail flounder has also been periodically

collected in the PNPS impingement sampling program (Normandeau 2006b). However, it is

unlikely that PNPS intake operations are adversely affecting yellowtail flounder as the area

affected by the intake system is small. Due to the small area affected by the thermal plume and

because the yellowtail flounder would exhibit behavioral avoidance if water temperatures are not

within their preference range, it is unlikely that the PNPS discharge would affect juvenile and adult

yellowtail flounder EFH. Continued operation of PNPS may also have the potential to affect prey

items of the yellowtail flounder, as one of its prey items (small fish) has been commonly reported

in the impingement and entrainment sampling program at PNPS. Continued PNPS operations

are likely to have a less than substantial adverse effect on EFH for the yellowtail flounder.

7.0 Impact Avoidance, Minimization, and Mitigation Measures

Operation of the PNPS once-through cooling system may adversely affect EFH in Cape Cod Bay. 

The NPDES permit allows the PNPS cooling system to operate if it does not exceed specified

entrainment, impingement, and discharge limits. The NPDES permit also requires mitigation

measures, which are in place at PNPS.
Appendix E

(a) It should be noted that the NRC cannot impose mitigation requirements on the applicant. The Atomic

Safety and Licensing Appeal Board, in the “Yellow Creek” case determined that EPA has sole

jurisdiction over the regulation of water quality with respect to the withdrawal and discharge of waters

for nuclear power stations, and that the NRC is prohibited from placing any restrictions or

requirements upon the licensees of these facilities with regards to water quality [Tennessee Valley

Authority (Yellow Creek Nuclear Plant, Units 1 and 2), ALAB-515, 8 NRC 702, 712-13 (1978)]. 

NUREG-1437, Supplement 29 E-132 July 2007

The staff has identified a variety of measures that could mitigate potential impacts resulting from

continued operation of the PNPS cooling water system.(a) These could include:

• Behavioral barriers

• Diversion devices

• Alternative intake systems 

• Alternative intake screen systems 

• Closed cycle systems 

• Variable speed pumps

• Cooling water flow adjustments

• Scheduled outages 

• Movement of fish return

• Habitat restoration

• Fish stocking

The NRC staff has not conducted an analysis of each of these measures relative to their

applicability to PNPS. This discussion is only meant to provide a brief overview of these

technologies. ENSR (2000) conducted an analysis of several of these technologies in the 316(b)

demonstration report as required by Section 316 of the Clean Water Act. It is expected that a

more thorough analysis of the costs and benefits of these technologies would be conducted as

part of the 316(b) comprehensive demonstration study currently being conducted by PNPS in

support of the NPDES permit renewal. 

Behavioral barriers are designed to cause fish to actively avoid entry into an area. These may

include sound, light, or air bubbles (Clay 1995). Sound barriers, which would be located at an

intake structure, would include low-frequency, infra-wave sound; pneumatic or mechanically

generated low-frequency sounds; or transducer-generated sound. Light barriers may emit a

constant or strobe-type beam of light, while air bubble curtains produce a continuous, dense chain

of bubbles. Both barrier types may deter some species of fish from entering the intake structure. 

ENSR (2000) determined that, of the behavioral barriers evaluated, light barriers would be the

most effective as several studies have shown that some fish species are attracted to light. 

However, this technology is still considered to be experimental in nature and will only be effective

on species/life stages that can actively respond to a stimulus (i.e., not fish eggs, early larval life

stages, or other planktonic organisms). 
Appendix E

(b) EPA has suggested the Gunderboom fabric barrier as a potential mitigation measure. However, NRC

staff does not consider it as an option because it could present safety issues at intakes of nuclear

power plants.

July 2007 E-133 NUREG-1437, Supplement 29

Diversion devices are the most commonly used barriers and are physical structures such as

louvers, barrier nets, or chains and cables that are designed to guide fish away from a certain

area, such as the intake (Clay 1995). Louvers consist of a series of evenly spaced vertical slats

which create localized turbulence that fish can detect and actively avoid. Louvers typically have a

smaller spacing between the slats or bars than a standard trash rack. Barrier nets are simply nets

placed across an intake channel to prevent fish from access to an intake structure. The design of

a barrier net system has to finely balance the mesh size with the intake requirements.(b) Chains or

cables may be vertically hung in an intake structure to form a physical and visible barrier to fish. 

However, similar to barrier nets, they may alter hydraulic flow patterns in an intake (ENSR 2000). 

These types of structures also only affect those organisms that can actively respond and would

not impact entrainment or impingement of fish eggs, larvae, or other planktonic organisms. 

Another type of mitigation measure may be an alternative intake system. An alternate surface

water intake system could include an offshore intake structure with a velocity cap. Vertical

placement of the offshore intake within the water column would be a major factor in impingement

and entrainment reduction. For example, ENSR (2000) conducted an evaluation of this type of

structure and determined that it would result in lower fish impingement but an increased

entrainment rate, especially for winter flounder as later stages of winter flounder larvae (stages 3

and 4) tend to settle on the bottom substrate. The Seabrook Station Nuclear Power Plant utilizes

a similar structure, however, the intake structure opening is at mid-depth. Based on an analysis

by Saila et al., (1997), the losses due to entrainment at this facility are less than the losses

observed at other facilities. Groundwater could also be potentially used as a cooling water

source. According to EPA Region 1, the Keyspan North Point Station is currently conducting a

pilot study to evaluate the feasibility of using offshore groundwater extraction as a cooling water

source (Earth Tech 2006a). 

Alternative intake screen systems may include Ristroph traveling screens, wedgewire screens,

and/or fine-mesh screens. Ristroph screens are traveling screens fitted with fish buckets that

collect fish and lift them out of the water where they are gently sluiced away prior to debris

removal with a high pressure spray. They have been approved as the best available technology

in several states (Siemens 2006). Recent studies have shown survival of species exceeding 95

percent when using the Ristroph screen (EPRI 2006). Wedgewire screens are constructed of

wire of triangular cross sections so that the surface of the screen is smooth while the screen

openings widen inwards (ENSR 2000). This type of screen has been widely used for hydropower

diversion structures and has been shown to essentially eliminate impingement and reduce larval

entrainment (ENSR 2000). Fine mesh screens are simply wire screens with the mesh sized to

minimize ichthyoplankton entrainment. As reported in ENSR (2000), fine mesh screens have not

proven effective at reducing winter flounder larvae entrainment losses. However, as with any
Appendix E

NUREG-1437, Supplement 29 E-134 July 2007

screen, the smaller the mesh the more clogging and fouling problems. Another potential

mitigation strategy related to the cooling system would be to rotate the existing screens more

often or on a continual basis. This would increase the survival of impinged organisms, but it

would have no impact on the impingement rate or entrainment. 

Closed-cycle systems recycle cooling water in a closed piping system and utilize evaporative

cooling (such as is in a cooling tower or pond) as a means of dissipating the heat from the

condensers. Wet and hybrid cooling towers would still require withdrawal of water from the bay to

make up for water losses due to blowdown and evaporation. However, the water withdrawal rate

would be significantly lower than the current once-through cooling system. A dry cooling tower

utilizes ambient air to dissipate heat, essentially acting as an automobile radiator (ENSR 2000). 

No make-up water is required for this type of system as the steam is condensed in a closed cycle.

However, this results in lower plant efficiency, thus requiring more fuel to produce the same

amount of electricity (ENSR 2000). 

Adjustments to the flow of cooling water through the plant is another type of mitigation strategy

that may be applicable to PNPS. This could include the use of variable speed pumps, cooling

water bypass flow, or rotating the existing screens more often or continuously. Variable-speed

pumps would reduce the intake flow during periods of peak entrainment or impingement. These

have been shown to be effective at reducing impingement and entrainment, but by reducing the

amount of cooling water moving through the system, power generating efficiency may decrease

and the thermal plume may increase in size (ENSR 2000). Cooling water bypass flow would

reduce the cooling water flow rate through the condensers and add a corresponding amount of

bypass flow into the discharge canal (ENSR 2000). This alternative assumes that mortality in the

discharge canal would be less than the condensers. It would most likely reduce entrainment but

not impingement (ENSR 2000).

Another potential mitigation strategy may be to schedule outages for performing regular

inspection, maintenance, and refueling during the peak spawning season of specific fish species

such as the winter flounder, Atlantic menhaden, or rainbow smelt. 

Movement of the fish return sluiceway discharge point may also provide some mitigation benefits

as impinged fish are currently returned to the intake canal where potentially stunned, disoriented,

or injured fish may not be able to actively avoid reentering the intake structure. 

Habitat restoration and fish stocking are also potential mitigation strategies. However, these are

compensatory measures as opposed to preventative measures, which are the preferred mitigation

strategies of Federal and State resource agencies. Several studies have been funded by Entergy

over the last few years to evaluate these options. A monitoring pilot program has been conducted

by Entergy to assess the feasibility of improving the local winter flounder stock by releasing

flounder into the Plymouth area. Up to 25,000 young of year winter flounder, ranging from 26 to

34 mm (1 to 1.3 in.) in length, have been released into Plymouth Harbor on an annual basis since
Appendix E

July 2007 E-135 NUREG-1437, Supplement 29

2001. Post-release sampling has indicated that the released fish do survive and grow well when

released earlier in the season (Marine Research, Inc. 2006). No genetic studies have been

conducted to determine if released hatchery fish breed with the wild stock. Stocking of young of

year fish or eggs may be a proven mitigation strategy; however, both the EPA and MDMF have

stated that re-stocking is not a preferred mitigation alternative (Earth Tech 2006a). 

8.0 Conclusions

The potential impacts of PNPS on Federally managed species and their EFH in the vicinity of

PNPS have been evaluated. Known distributions and records of those species, the ecological

impacts of the operations and maintenance activities of PNPS, and the mitigation measures that

Entergy has implemented to avoid, minimize, and mitigate impacts to the various life history

stages of these species have been considered in this EFH assessment.

Continued operation of the PNPS cooling water system was determined to have a minimal

adverse effect on EFH for 17 species, a less than substantial adverse effect on EFH for 8

species, and a substantial adverse effect on EFH for 7 species. However, within the overall Cape

Cod Bay ecosystem, the staff has determined that continued operation of the PNPS cooling water

system would have a minimal adverse effect on EFH.

9.0 References

Able, K.W., and M.P. Fahay. 1998. The first year in the life of estuarine fishes in the Mid-Atlantic

Bight. Rutgers Univ. Press, New Brunswick, New Jersey, 342 p.

Able, K.W., C.B. Grimes, R.A. Copper, and J.R. Uzmann. 1982. Burrow construction and

behavior of tilefish, Lopholatilus chamaeleonticeps, in the Hudson Submarine Canyon. Environ.

Biol. Fishes 7: 199-205.

Able, K.W., R.E. Matheson, W.W. Morse, M.P. Fahay, and G. Shepherd. 1990. Patterns of

summer flounder Paralichthys dentatus early life history in the Mid-Atlantic Bight and New Jersey

estuaries. Fish. Bull. (U.S.) 88: 1-12.

Allen, D.M., J.P. Clymer, III, and S.S. Herman. 1978. Fishes of Hereford Inlet estuary, southern

New Jersey. Lehigh Univ. Dept. Biol. and Cent. Mar. Environ. Stud. and the Wetlands Institute,

138 p.

Anderson, M.E. 1994. Summary report: Fish Spotting Overflights in western Cape Cod Bay in

1993. In Marine ecology studies related to operation of Pilgrim Station, Semi-annual report No.

43, January 1993-December 1993, 4p.
Appendix E

NUREG-1437, Supplement 29 E-136 July 2007

Auster, P.J. 1985. Some observations of fish orientiation to current direction and effects on

predator-prey interactions. Northwest Atl. Fish. Organ. (NAFO) Sci. Counc. Stud. 8: 53-55.

Berrien, P., and J. Sibunka. 1999. Distribution patterns of fish eggs in the United States

northeast continental shelf ecosystem, 1977-1987. NOAA Tech. Rep. NMFS 145, 310p.

Bigelow, H.B., and W.C. Schroeder. 1953. Fishes of the Gulf of Maine. U.S. Fish. Wildl. Serv.,

Fish. Bull. 53, 577 p.

Blaxter, J.H.S., D. Danielssen, E. Mokness, and V. Oiestad. 1983. Description of the early

development of the halibut, Hippoglossus hippoglossus and attempts to rear the larvae past first

feeding. Mar. Biol. 73: 99-107.

Blaxter, J.S., and F.T. Holliday. 1963. The behavior and physiology of herring and other

clupeids. Adv. Mar. Biol. 1: 261-393.

BMLSS. 1997 and 1998. Accessed at

http://ourworld.compuserve.com/homepages/BLMSS/halibut2.htm, on August 28, 2006.

Bolles, K.L., and G.A. Begg. 2000. Distinction between silver hake (Merluccius bilinearis) stocks

in U.S. waters based on whole otolith morphometrics. Fish. Bull. (U.S.) 98: 451-462.

Bowman, R.E. 1984. Food of silver hake (Merluccius bilinearis). Fish. Bull. (U.S.) 82, 21-35.

Bridges, W.L. and R.D. Anderson. 1984. A brief survey of Pilgrim Nuclear Power Plant effects

upon the marine aquatic environment. In Observations on the Ecology and Biology of Western

Cape Cod Bay, Massachusetts. Lecture Notes on Coastal and Estuarine Studies, vol. 11, Eds.

J.D. Davis and D. Merriman, pp. 263-277. Springer-Verlag. 

Brodziak, J.K.T. 2005. Essential Fish Habitat Source Document: Haddock, Melanogrammus

aeglefinus, Life History and Habitat Characteristics. NOAA Technical Memorandum NMFS-NE196. December 2005.

Brodziak, J.K.T. and W.K. Macy, III. 1996. Growth of long-finned squid, Loligo pealei, in the

northwest Atlantic, Fish. Bull. (U.S.) 94: 9-24.

Buck, E.H. 1995. Atlantic Bluefin Tuna: International Management of a Shared Resource. CRS

Report for Congress, 95-367 ENR. Accessed at

http://www.ncseonline.org/NLE/CRSreports/Marine/mar-5.cfm. on August 28, 2006.

Bulloch, D. K. 1986. Marine Gamefish of the Mid-Atlantic. Special Publication # 13 of the

American Littoral Society.
Appendix E

July 2007 E-137 NUREG-1437, Supplement 29

Burnett, J., M.R. Ross, and S.H. Clark. 1983. Status of witch flounder in the Gulf of Maine –

1983, U.S. Natl. Mar. Fish. Serv., Northeast Fish. Center, Woods Hole Lab, Ref. Doc. No. 83-36,

31p.

Cadrin, S.X. 2000a. Longfin Inshore Squid. Accessed at

http://www.nefsc.noaa.gov/sos/spsyn/iv/lfsquid/. on August 8, 2006.

Cargnelli, L.M., S.J. Griesbach, and C.A. Zetlin. 1999a. Essential Fish Habitat Source

Document: Northern Shortfin Squid, Illex illecebrosus, Life History and Habitat Characteristics. U.

S. Department of Commerce, National Oceanic and Atmospheric Administration, National Marine

Fisheries Service, Northeast Region, Northeast Fisheries Science Center, Woods Hole,

Massachusetts. NOAA Technical Memorandum NMFS-NE-147. September 1999.

Cargnelli, L.M., S.J. Griesbach, and W.W. Morse. 1999b. Essential Fish Habitat Source

Document: Atlantic Halibut, Hippoglossus hippoglosus, Life History and Habitat Characteristics.

NOAA Technical Memorandum NMFS-NE-125. September 1999.

Cargnelli, L.M., S.J. Griesbach, D.B. Packer, and E. Weissberger. 1999c. Essential Fish Habitat

Source Document: Atlantic Surfclam, Spisula solidissima, Life History and Habitat Characteristics.

U. S. Department of Commerce, National Oceanic and Atmospheric Administration, National

Marine Fisheries Service, Northeast Region, Northeast Fisheries Science Center, Woods Hole,

Massachusetts. NOAA Technical Memorandum NMFS-NE-142. September 1999.

Cargnelli, L.M., S.J. Griesbach, D.B. Packer, and E. Weissberger. 1999d. Essential Fish Habitat

Source Document: Ocean quahog, Artica islandica, Life History and Habitat Characteristics. U. S.

Department of Commerce, National Oceanic and Atmospheric Administration, National Marine

Fisheries Service, Northeast Region, Northeast Fisheries Science Center, Woods Hole,

Massachusetts. NOAA Technical Memorandum NMFS-NE-148. September 1999.

Cargnelli, L.M., S.J. Griesbach, P.L. Berrien, W.W. Morse, and D.L. Johnson. 1999e. Essential

Fish Habitat Source Document: Haddock, Melanogrammus aeglefinus, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-128. September 1999.

Cargnelli, L.M., S.J. Griesbach, C. McBride, C.A. Zetlin, and W.W. Morse. 1999f. Essential Fish

Habitat Source Document: Longfin Inshore Squid, Loligo pealeii, Life History and Habitat

Characteristics. U. S. Department of Commerce, National Oceanic and Atmospheric

Administration, National Marine Fisheries Service, Northeast Region, Northeast Fisheries Science

Center, Woods Hole, Massachusetts. NOAA Technical Memorandum NMFS-NE-146. 

September 1999.
Appendix E

NUREG-1437, Supplement 29 E-138 July 2007

Cargnelli, L.M., S.J., Griesbach, D.B. Packer, P.L. Berrien, D.L. Johnson, and W.W. Morse.

1999g. Essential Fish Habitat Source Document: Pollock, Pollachius virens, Life History and

Habitat Characteristics. NOAA Technical Memorandum NMFS-NE-131, September 1999.

Cargnelli, L.M., S.J., Griesbach, D.B. Packer, P.L. Berrien, W.W. Morse, and D.L. Johnson.

1999h. Essential Fish Habitat Source Document: Witch Flounder, Glyptocephalus cynoglossus,

Life History and Habitat Characteristics. NOAA Technical Memorandum NMFS-NE-139.

September 1999.

Chang, S., W.W. Morse, and P.L. Berrien. 1999a. Essential Fish Habitat Source Document:

White Hake, Urophycis tenuis, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-136. September 1999.

Chang, S., P.L. Berrien, D.L. Johnson, and W.W. Morse. 1999b. Essential Fish Habitat Source

Document: Windowpane, Scophthalmus aquosus, Life History and Habitat Characteristics. 

NOAA Technical Memorandum NMFS-NE-137. September 1999.

Chang, S., P.L. Berrien, D.L. Johnson, and C.A. Zetlin. 1999c. Essential Fish Habitat Source

Document: Offshore Hake, Merluccius albidus, Life History and Habitat Characteristics. NOAA

Technical Memorandum NMFS-NE-130. September,1999.

Clay, C.H. 1995. Design of Fishways and Other Fish Facilities. 2nd Edition. CRC Press, Inc. 

Cohen, D.M., T. Inada, T. Iwamoto, and N. Scialabba. 1990. FAO species catalogue, Vol. 10,

Gadiform fishes of the world (Order Gadiformes), An annotated and illustrated catalogue of cods,

hakes, grenadiers and other gadiform fishes known to date: FAO Fish. Synop. 125, 442p.

Colton, J.B., Jr. 1972. Temperature trends and the distribution of groundfish in continental shelf

waters, Nova Scotia to Long Island. Fish. Bull. 70, 637-658.

Colton, J.B., Jr., and R.F. Temple. 1961. The enigma of Georges Bank spawning. Limnol.

Oceanogr. 6: 280-291.

Colton, J.B., Jr., and R.R. Marak. 1969. Guide for identifying the common planktonic fish eggs

and larvae of continental shelf waters, Cape Sable to Block Island. U.S. Bur. Comm. Fish. Biol.

Lab. Woods Hole Lab. Ref. No. 69-9, 43 p.

Cooper, J.A., and F. Chapleau. 1998. Monophyly and intrarelationships of the family

Pleuronectidae (Pleuronectiformes), with a revised classification. Fish. Bull. 96(4): 686-726.
Appendix E

July 2007 E-139 NUREG-1437, Supplement 29

Crawford, J., R. Fleming, J. Smith, and K. Larade. 2005. Candidate HAPC Proposal to the New

England Fishery Management Council (NEFMC), Habitat Areas of Particular Concern: A MultiSpecies Approach for Juveniles of Eight Overfished Species. May 12, 2005. Accessed at:

http://www.nefmc.org/habitat/habitat.html on August 28, 2006.

Cross, J.N., C.A. Zetlin, P.L. Berrien, D.L. Johnson, and C. McBride. 1999. Essential Fish

Habitat Source Document: Butterfish, Peprilus triacanthus, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-145. September 1999.

Davis, J.D. and R.A. McGrath. 1984. Some Aspects of Nearshore Benthic Macrofauna in

Western Cape Cod Bay. In: Lecture Notes on Coastal and Estuarine Studies. Observations on

the Ecology and Biology of Western Cape Cod Bay, Massachusetts. J.D. Davis and D. Merriman

(eds).

Dawe, E.G. 1988. Length-weight relationships for short-finned squid in Newfoundland and the

effect of diet on condition and growth. Trans. Am. Fish. Soc. 177: 591-599.

Department of Fisheries and Oceans (DFO). 1989. Communications Directorate, Ottawa,

Ontario. Accessed at: http://www.mi.mun.ca/mi%2Dnet/fishdeve/plaice.htm. on August 28, 2006.

Dery, L.M. 1988a. Silver hake (Merluccius bilinearis). In Age determination methods for

Northwest Atlantic species, p. 41-44. NOAA Technical Mem. NMFS-72.

Dooley, J.K. 1978. Systematics and biology of the tilefishes (Perciformes: Brackiostegidae and

Malacanthidae), with descriptions of two new species. NOAA Tech. Rep. NMFS Circ. 411, 78 p.

EG&G Global Environmental and Ocean Services (EG&G). 1995. Pilgrim Nuclear Power Station

Cooling Water Discharge Bottom Temperature Study, August, 1994. Final report to Boston

Edison Company, Plymouth, MA. June 1995.

ENSR. March 2000. Redacted Version 316 Demonstration Report – Pilgrim Nuclear Power

Station.

Entergy Nuclear Generation Company. 2006a. Applicant’s Environmental Report, Operating

License Renewal Stage, Pilgrim Nuclear Power Station, Appendix E to License Renewal

Application, Docket No. 50-293, License No. DPR-35. January 2006.

Entergy Nuclear Generation Company. 2006b. Marine Ecology Studies, Pilgrim Nuclear Power

Station, Report No. 67, January-December, 2005. Environmental Protection Group, Entergy

Nuclear-Pilgrim Station. April 30, 2006.
Appendix E

NUREG-1437, Supplement 29 E-140 July 2007

Evseenko, S.A., and M.M. Nevinsky. 1975. Spawning and development of the witch flounder,

Glyptocephalus cynoglossus. In the northwest Atlantic, Int. Comm. Northwest Atl. Fish (ICNAF)

Res. Bull. No. 11, 111-123.

Fahay, M.P., and K.W. Able. 1989. White hake, Urophycis tenuis. In the Gulf of Maine:

spawning seasonality, habitat use, and growth in young of the year and relationships of the

Scotian Shelf population. Can. J. Zool. 67: 1715-1724.

Fahay, M.P., P.L. Berrien, D.L. Johnson, and W.W. Morse. 1999a. Essential Fish Habitat Source

Document: Atlantic Cod, Gadus morhua, Life History and Habitat Characteristics. NOAA

Technical Memorandum NMFS-NE-124. September 1999a.

Fahay, M.P., P.L. Berrien, D.L. Johnson, and W.W. Morse. 1999b. Essential Fish Habitat Source

Document: Bluefish, Pomatomus saltatrix, Life History and Habitat Characteristics. NOAA

Technical Memorandum NMFS-NE-14. September 1999.

Freeman, B.L., and S.C. Turner. 1977. Biological and fisheries data on tilefish, Lopholatilus

chamaeleonticeps Goode and Beane, from the South Atlantic Bight. U.S. Natl. Mar. Fish. Serv.,

Northweast Fish. Cent. Sandy Hook Lab. Tech. Ser. Rep. No. 5, 41 p.

Froerman, Y.M. 1984. Feeding spectrum and trophic relationships of short-finned squid (Illex

illecebrosus) in the Northwest Atlantic. Northwest Atl. Fish. Organ. NAFO Sci. Council.

Galya et al. 1997. Massachusetts Water Resources Authority Outfall Monitoring Overview

Report: 1996. MWRA Environmental Quality Department Technical Report Series 97-8. 57 p.

Garrison, L.P., and J.S. Link. 2000. Diets of five hake species in the northeast United States

continental shelf system. Mar. Ecol. Prog. Ser. 204: 243-255.

Gotceitas, V., and J.A. Brown. 1993. Substrate selection by juvenile cod (Gadus morhua):

effects of predation risk. Oecologia 93: 31-37.

Grimes, G.B., K.W. Able, and R.S. Jones. 1986. Tilefish, Lopholatilus chamaeleonticeps, habitat,

behavior, and community structure in Mid-Atlantic and southern New England waters. Environ.

Biol. Fishes 15: 273-292.

Gulf of Maine Census of Marine Life (GOMCML). 2006. Dynamac Atlas of the Gulf of Maine.

Accessed at: http://gmbis.iris.usm.maine.edu/products.asp. on August 28, 2006.

Hardy, J.D. Jr., 1978. Development of fishes of the Mid-Atlantic Bight: An atlas of egg, larval,

and juvenile stages, Vol. 2 Anguillidae through Syngnathidae. U.S. Fish Wildl. Serv. Biol. Serv.

Prog. FWS/OBS-78/12, 458 p.
Appendix E

July 2007 E-141 NUREG-1437, Supplement 29

Hart, D.R. and A.S. Chute. 2004. Essential Fish Habitat Source Document: Sea Scallop,

Placopecten magellanicus, Life History and Habitat Characteristics. U. S. Department of

Commerce, National Oceanic and Atmospheric Administration, National Marine Fisheries Service,

Northeast Region, Northeast Fisheries Science Center, Woods Hole, Massachusetts. NOAA

Technical Memorandum NMFS-NE-189. September 2004.

Hartley, D.L. 1995. The population biology of the goosefish, Lophius americanus, in the Gulf of

Maine. M.S. Thesis, Univ. of Mass., Amherst, MA, 142 p.

Hatfield, E.M.C., and S.X. Cadrin. 2002. Geographic and temporal patterns in size and maturity

of the longfin inshore squid (Loligo pealeii) off the northeastern United States. Fish. Bull. (U.S.)

100:200-213.

Hendrickson, L. 1998. Windowpane. In S.H. Clark, ed., Status of the fishery resources off the

northeastern United States for 1998, p. 85-87, NOAA Tech. Mem. NMFS-NE-115.

Hendrickson, L. 2000. Northern Shortfin Squid. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/iv/sfsquid/ on August 17, 2006.

Hendrickson, L.C., and E.M. Holmes. 2004. Essential Fish Habitat Source Document: Northern

Shortfin Squid, Illex illecebrosus, Life History and Habitat Characteristics. U. S. Department of

Commerce, National Oceanic and Atmospheric Administration, National Marine Fisheries Service,

Northeast Region, Northeast Fisheries Science Center, Woods Hole, Massachusetts. NOAA

Technical Memorandum NMFS-NE-191. November 2004

Hildenbrand, S.F. 1963. Family Clupeidae. In Fishes of the Western North Atlantic, Sears

Found. Mar. Res. Mem. 1(3). Pp 257-385, 397-442, 452-454.

Iles, T.D., and M. Sinclair. 1982. Atlantic herring stock discreteness and abundance. Science

215: 627-633.

Jacobson, L.D. 2005. Essential Fish Habitat Source Document: Longfin Inshore Squid, Loligo

Pealeii, Life History and Habitat Characteristics. NOAA Technical Memorandum NMFS-NE-193.

August 2005.

Johnson, D.L. 2004. Essential Fish Habitat Source Document: American Plaice,

Hippoglossoides platessoides, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-187. August 2004.

Johnson, D.L., W.W. Morse, P.L. Berrien, and J.J. Vitaliano. 1999a. Essential Fish Habitat

Source Document: Yellowtail Flounder, Limanda ferruginea, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-140. September 1999.
Appendix E

NUREG-1437, Supplement 29 E-142 July 2007

Jury, S.H., J.D. Field, S.L. Stone, D.M. Nelson, and M.E. Monaco. 1994. Distribution and

abundance of fishes and inverterbrates in North Atlantic estuaries. ELMR Rep. No. 13,

NOAA/NOS Strategic Environmental Assessments Division, Silver Spring, Maryland, 221 p.

Kelly, G.F. and A.M. Barker. 1961a. Observations on the behavior, growth, and migration of

redfish at Eastport, Maine. Int. Comm. Northwest Atl. Fish. (ICNAF) Spec. Pub. 3, 263-275.

Kelly, G.F. and A.M. Barker. 1961b. Vertical distribution of young redfish in the Gulf of Maine.

Int. Comm. Northwest Atl. Fish. (ICNAF) Spec. Pub. 3: 220-233.

Kendall, A.W. Jr., and L.A. Walford. 1979. Sources and distribution of bluefish, Pomatus

saltatrix, larvae and juveniles off the east coast of the United States. U.S. Natl. Mar. Fish. Serv.

Fish. Bull. 77(1): 213-227.

Klein-MacPhee, G. 2002. Haddock/Melanogrammus aeglefinus Linnaeus 1758. In Collette,

B.B., and G. Klein-MacPhee, eds., Bigelow and Schroeder’s fishes of the Gulf of Maine, 3rd

Edition. Washington, D.C., Smithsonian Institution Press, p. 235-242.

Kohler, A.C. 1967. Size at maturity, spawning season, and food of Atlantic halibut. J. Fish. Res.

Board Can. 24: 53-66.

Kolek, D. 1990. Homing of black sea bass, Centropristis striata, in Nantucket Sound with

comments on seasonal distribution, growth rates, and fisheries of the species. Massachusetts

Div. Mar. Fish. Pocassett, Massachusetts, 12 p.

Lai, H. and P. Rago. 1998. Sea scallops: Status of Fisheries Resources off Northeastern United

States for 1998. Accessed at: http://www.whoi.edu/sos/spsyn/iv/scallop.html on August 28,

2006.

Lange, A.M.T. and M.P. Sissenwine. 1980. Biological considerations relevant to the

management of squid (Loligo pealei and Illex illecebrosus) of the northwest Atlantic. Mar. Fish.

Rev. 42(7-8): 23-38.

Langston, R.W., and R.E. Bowman. 1981. Food of eight Northwest Atlantic Pleuronectiform

Fishes. NOAA Technical Report NMFS SSRF-749, U.S. Department of Commerce.

Langston, R.W., J.B. Pearce, and J.A. Gibson, eds. 1994. Selected living resources, habitat

conditions, and human perturbations of the Gulf of Maine: Environmental and Ecological

considerations for fishery management. NOAA Technical Memorandum NMFS-NE-106, 70 p.

Lavenda, N. 1949. Sexual differences and normal protogynous hermaphroditism in the Atlantic

sea bass, Centropristes striatus. Copeia 1949 (3): 185-194.
Appendix E

July 2007 E-143 NUREG-1437, Supplement 29

Lawton, R.P., P. Brady, C. Sheehan, W. Sides, E. Kouloheras, M. Borgatti, and V. Malkoski.

1984. The recreational fishery at Pilgrim shorefront. In: Observations on the Ecology and Biology

of Western Cape Cod Bay, Massachusetts. Lecture Notes on Coastal and Estuarine Studies, vol.

11, Eds. J.D. Davis and D. Merriman, pp. 231-240. 

Lawton, R., B. Kelly, J. Boardman, and V. Malkoski. 1999. Annual Report on Assessment and

Mitigation of Impact of the Pilgrim Nuclear Power Station on Finfish Populations in Western Cape

Cod Bay. Project Report No. 66 (January to December 1998). Massachusetts Department of

Fisheries, Wildlife, and Environmental Law Enforcement, Division of Marine Fisheries. Boston,

Massachusetts. April 1999. Marine Ecology Studies Related to Operation of Pilgrim Station. 

Semi-annual Report No. 53, Report Period: January 1998 through December 1998. Regulatory

Affairs Department, Boston Edison Company, Plymouth, Massachusetts. April 30, 1999. 

Lawton, R., V. Malkoski, B. Kelly, J. Boardman, M. Camisa. 2000. Final Report: Winter Flounder

(Pseudopleuronectes americanus) Studies (1993-1999) in Relation to Impact Assessment of

Pilgrim Station on the Local Population. Department of Fisheries, Wildlife, and Environmental

Law Enforcement, Massachusetts Division of Marine Fisheries. Pocasset, Massachusetts. 

March 2000. Pilgrim Nuclear Power Station Marine Environmental Monitoring Program Report

Series No. 10. Entergy. March 2000. 

Libby P.S., W.R. Geyer, A.A. Keller, A.D. Mansfield, J.T. Turner, D. Borkman, and C.A. Oviatt. 

2006. 2004 Annual Water Column Monitoring Report. Boston: Massachusetts Water Resources

Authority. Report ENQUAD 2006-15. 177 p.

Lock, M.C., and D.B. Packer. 2004. Essential Fish Habitat Source Document: Silver Hake,

Merluccius bilinearis, Life History and Habitat Characteristics. NOAA Technical Memorandum

NMFS-NE-186. August 2004.

Lough, R.G. 2004. Essential Fish Habitat Source Document: Atlantic Cod, Gadus morhua, Life

History and Habitat Characteristics. NOAA Technical Memorandum NMFS-NE-190. November

2004.

Lux, F.E. 1964. Landings, fishing effort, and apparent abundance in the yellowtail flounder

fishery. Int. Comm. Northwest Atl. Fish. (ICNAF) Res. Bull. 1: 5-21.

MacDonald, J.S. 1983. Laboratory observations of feeding behavior of the ocean pout

(Macrozoarces americanus) and winter flounder (Pseudopleuronectes americanus) with reference

to niche overlap of natural populations. Can. J. Zool. 61: 539-546.

Magnuson-Stevens Fishery Conservation and Management Act 16 USC 1801 et seq.
Appendix E

NUREG-1437, Supplement 29 E-144 July 2007

Mansueti, A.J., and J.D. Hardy. 1967. Development of fishes of the Chesapeake Bay region: an

atlas of egg, larval, and juvenile stages, Part I. Natural Resources Institute, University of Maryland

Press, College Park, 202 p.

Marak, R.R. 1967. Eggs and early larval stages of the offshore hake, Merluccius albidus. Trans.

Am. Fish. Soc. 96: 227-228.

Marak, R.R. 1973. Food and feeding of larval redfish in the Gulf of Maine. In J.H.S. Baxter, ed.

The early life history of fish, p. 267-275.

Marine Research, Inc. (MRI) 2005a. Winter Flounder Area-Swept Estimate, Western Cape Cod

Bay 2005. Marine Ecology Studies, Pilgrim Nuclear Power Station, Report No. 67, JanuaryDecember, 2005. Environmental Protection Group, Entergy Nuclear-Pilgrim Station. April 30,

2006.

Marine Research, Inc. 2005b. Ichthyoplankton Entrainment Monitoring at Pilgrim Nuclear Power

Station, January-December 2004. Marine Ecology Studies, Pilgrim Nuclear Power Station,

Report No. 65, January-December, 2004. Environmental Protection Group, Entergy NuclearPilgrim Station. April 30, 2005.

Marine Research Inc. (MRI). 2006. Winter Flounder Area-Swept Estimate Western Cape Cod

Bay 2005. Marine Ecology Studies Pilgrim Nuclear Power Station Report No. 67. JanuaryDecember 2005. Environmental Protection Group, Entergy Nuclear-Pilgrim Station, Plymouth

Massachusetts. April 30, 2006.

Maurer, R.O. and R.E. Bowman. 1985. Food consumption of squids (Illex illecebrosus and

Loligo pealei) off the northeastern United States. Northwest Atl. Fish. Organ. (NAFO) Sci. Counc.

Stud. 9: 117-124.

Mayo, R.K. 1998. Silver Hake: Status of Fisheries Resources off Northeastern United States for

1998. Accessed at: http://www.whoi.edu/sos/spsyn/pg/silver.html on August 28, 2006.

McEachran, J.D. 1973. Biology of seven species of skates (Pisces: Rajidae) Ph.D. dissertation,

Coll. William and Mary, Williamsburg, VA, 127 p.

McEachran, J.D. 2002. Skates, Family Rajidae. In B.B. Collette and G. Klein-MacPhee, eds.,

Bigelow and Schroeder’s fishes of the Gulf of Maine, 3rd edition, p. 60-75. Smithsonian Institution

press, Washington, D.C., 748 p.

McEachran, J.D., D.F. Boesch, and J.A. Musick. 1976. Food division within two sympatric

species-pairs of skates (Pisces: Rajidae). Mar. Biol. 35: 301-317.
Appendix E

July 2007 E-145 NUREG-1437, Supplement 29

McEachran, J.D., and J.A. Musick. 1975. Distribution and relative abundance of seven species

of skates (Pisces: Rajidae) which occur between Nova Scotia and Cape Hatteras. Fish. Bull.

(U.S.) 73: 110-136.

McMillan, D.G., and W.W. Morse. 1999. Essential Fish Habitat Source Document: Spiny

Dogfish, Squalus acanthias, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-150. September 1999.

Michalopoulos, C. 1990. A field study on the ecology and behavior of the winter skate (Leucoraja

ocellata) and little skate (Leucoraja erinacea) off outer Cape Cod, Massachusetts. M.S. Thesis,

Southeastern Mass. Univ., North Dartmouth, Massachusetts, 71 p.

Mid-Atlantic Fishery Management Council (MAFMC). 1996a. Amendment 8 to the summer

flounder Fishery Management Plan: Fishery Management Plan and final environmental impact

statement for the scup fishery. January 1996, 162p.

Mid-Atlantic Fishery Management Council (MAFMC). 1996b. Amendment 9 to the summer

flounder Fishery Management Plan: Fishery Management Plan and draft environmental impact

statement for the black sea bass fishery. June 1996. 152 p.

Morse, W. 1978. Biological and fisheries data on scup, Stenotomus chrysops (Linnaeus). U.S.

Natl. Mar. Fish. Serv. Northeast Fish. Cent. Sandy Hook Lab. Tech. Rep. No. 12, 41 p.

Morse, W.W. 1981. Reproduction of the summer flounder (Paralichthys dentatus (L)). J. Fish.

Biol. 19: 189-203.

National Marine Fisheries Service (NMFS). 1999. Highly Migratory Species Management

Division 1999, Final Fishery Management Plan for Atlantic Tuna, Swordfish, and Sharks,

Including the Revised Final Environmental Impact Statement, the Final Regulatory Impact

Review, the Final Regulatory Flexibility Analysis, and the Final Social Impact Assessment. April

1999.

National Marine Fisheries Service (NMFS). 2006. Guide to Essential Fish Habitat Descriptions. 

NOAA Fisheries Service, Habitat Conservation Division. Accessed at:

http://www.nero.noaa.gov/hcd/list.htm on January 19, 2006. 

New England Fishery Management Council (NEFMC). 1998a. Essential Fish Habitat, Volume 1.

New England Fishery Management Council (NEFMC). 1998b. Essential fish habitat description

for Winter flounder (Pleuronectes americanus) contained in NEFMC EFH Amendment, October 7,

1998.
Appendix E

NUREG-1437, Supplement 29 E-146 July 2007

New England Fishery Management Council (NEFMC). 1999. Essential Fish Habitat Overview. 

Accessed at: http://www.nefmc.org/ on August 8, 2006.

New England Fishery Management Council (NEFMC). 2003. Final Fishery Management Plan for

the Northeast Skate Complex, including a Final Environmental Impact Statement, and an Initial

Regulatory Flexibility Act Analysis.

Nitschke P., R. Brown, and L. Hendrickson. 2000. Status of Fisheries Resources off

Northeastern United States – Winter Flounder. Updated January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/fldrs/winter/ on August 8 2006. 

NOAA. 1998. Status of the Fishery Resources off the Northeastern United States. Stephen

Clark, Editor. NOAA Technical Memorandum NMFS-NE-115. Resource Evaluation and

Assessment Division. Northeast Fisheries Science Center.

Normandeau Associates, Inc. 1977. Thermal Surveys of Backwashing Operations at Pilgrim

Station during July 1977. Conducted for Boston Edison Company, Boston, MA. August. 

Normandeau Associates, Inc. 2006a. Icthyoplankton Entrainment Monitoring at Pilgrim Nuclear

Power Station, January-December 2005. Marine Ecology Studies, Pilgrim Nuclear Power Station,

Report No. 67, January-December 2005. Environmental Protection Group, Entergy NuclearPilgrim Station. April 30, 2006.

Normandeau Associates, Inc. 2006b. Impingement of Organisms on the Intake Screens at

Pilgrim Nuclear Power Station, January-December 2005. Marine Ecology Studies, Pilgrim

Nuclear Power Station, Report No. 67, January-December 2005. Environmental Protection

Group, Entergy Nuclear-Pilgrim Station. April 30, 2006.

Ojeda, F.P., and J.H. Dearborn. 1991. Feeding ecology of benthic mobile predators:

experimental analyses of their influence in rocky intertidal communities of the Gulf of Maine, J.

Exp. Mar. Biol. Ecol. 149:13-44.

Overholtz, W.J., and E.D. Anderson. 1976. Relationship between mackerel catches, water

temperatures, and vessel velocity during USA spring bottom trawl surveys in SA 5-6. Int. Comm.

Northwest Atl. Fish. (ICNAF) Res. Doc. 76/XIII/170, 7 p.

Overholtz, W., and S.X. Cadrin. 1998. Yellowtail flounder: Status of Fisheries Resources off

Northeastern United States for 1998. Accessed at:

http://www.whoi.edu/sos/spsyn/pg/yellotail.html. on August 8, 2006.
Appendix E

July 2007 E-147 NUREG-1437, Supplement 29

Packer, D.B., S.J. Griesbach, P.L. Berrien, C.A. Zetlin, D.L. Johnson, and W.W. Morse. 1999.

Essential Fish Habitat Source Document: Summer Flounder, Paralichthys dentatus, Life History

and Habitat Characteristics. NOAA Technical Memorandum NMFS-NE-151. September 1999.

Packer, D.B., C.A. Zetlin, and J.J. Vitaliano. 2003a. Essential Fish Habitat Source Document:

Winter Skate, Leucoraja ocellata, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-179. March 2003.

Packer, D.B., C.A. Zetlin, and J.J. Vitaliano. 2003b. Essential Fish Habitat Source Document:

Little Skate, Leucoraja erinacea, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-175. March 2003.

Packer, D.B., C.A. Zetlin, and J.J. Vitaliano. 2003c. Essential Fish Habitat Source Document:

Thorny Skate, Amblyraja radiata, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-178. March 2003.

Packer, D.B., C.A. Zetlin, and J.J. Vitaliano. 2003d. Essential Fish Habitat Source Document:

Smooth Skate, Malacoraja senta, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-177. March 2003.

Pereira, J. J, R. Goldberg, J.J. Ziskowski, P.L. Berrien, W.W. Morse, and D.L. Johnson. 1999. 

Essential Fish Habitat Source Document: Winter Flounder, Psedopleuronectes americanus, Life

History and Habitat Characteristics. U. S. Department of Commerce, National Oceanic and

Atmospheric Administration, National Marine Fisheries Service, Northeast Region, Northeast

Fisheries Science Center, Woods Hole, Massachusetts. September 1999.

Pikanowski, R.A., W.W. Morse, P.L. Berrien, D.L., Johnson, and D.G. McMillan. 1999. Essential

Fish Habitat Source Document: Redfish, Sebastes spp. , Life History and Habitat Characteristics.

NOAA Technical Memorandum NMFS-NE-132. September 1999.

Reid, R., F. Almeida, and C. Zetlin. 1999a. Essential fish habitat source document: Fishery

independent surveys, data sources, and methods. NOAA Technical Memorandum NMFS-NE122, 39 p.

Richards, S.W. 1963. The demersal fish population of Long Island Sound II, Food of the

juveniles from a sand-shell locality (Station 1). Bull. Bingham Oceanogr. Collect. 18: 32-72.

Royce, W.F., R.J. Buller, and E.D. Premetz. 1959. Decline of the yellowtail flounder (Limanda

ferruginea) off New England. Fish. Bull. (U.S.) 59: 169-267.
Appendix E

NUREG-1437, Supplement 29 E-148 July 2007

Saila, S.B., E. Lorda, J.D. Miller, R.A. Sher, and W.H. Howell. 1997. Equivalent Adult Estimates

for Losses of Fish Eggs, Larvae, and Juveniles at Seabrook Station with Use of Fuzzy Logic to

Represent Parametric Uncertainty. North American Journal of Fisheries Management, Volume

17, pgs 811-825.

Scott, J.S. 1982. Selection of bottom type by groundfishes of the Scotian Shelf. Can. J. Fish.

Aquat. Sci. 39: 943-947.

Scott, W.B. and M.G. Scott. 1988. Atlantic Fishes of Canada. Can. Bull. Fish. Aquat. Sci. 219,

731 p. 

Sedberry, G.R. 1983. Food habits and trophic relationships of a community of fishes on the outer

continental shelf. NOAA Tech. Rep. NMFS SSRF-773, 56p.

Sette, O.E. 1943. Biology of the Atlantic mackerel (Scomber scombrus), of North America, Part I:

Early life history including growth, drift, and mortality of the egg and larval populations. U.S. Fish

Wildl. Serv. Bull. 50: 149-237.

Shepherd, G.R., and D.B. Packer. 2006. Essential Fish Habitat Source Document: Bluefish,

Pomatomus saltatrix, Life History and Habitat Characteristics. NOAA Technical Memorandum

NMFS-NE-198. June 2006.

Sosebee, K.A. 1998. Red Hake. In S.H. Clark, ed., Status of fishery resources off the

northeastern United States for 1998, p. 64-66. NOAA Technical Memorandum NMFS-NE-115.

Sosebee, K.A. 2000. Skates. January 2000. Accessed at:

http://www.nefsc.noaa.gov/sos/spsyn/op/skate/ on August 8, 2006.

Squires, H.J. 1957. Squid, Illex illecebrosus, in the Newfoundland fishing area. J. Fish. Res.

Board Can. 14: 693-728.

Steele, D.H. 1963. Pollock (Pollachius virens (L.)) in the Bay of Fundy. J. Fish. Res. Board Can.

20: 1267-1314.

Steimle, F.W., W.W. Morse, P.L. Berrien, and D.L. Johnson. 1999a. Essential Fish Habitat

Source Document: Red Hake, Urophycis chuss, Life History and Habitat Characteristics. NOAA

Technical Memorandum NMFS-NE-133. September 1999.

Steimle, F.W., W.W. Morse, and D.L. Johnson. 1999b. Essential Fish Habitat Source Document:

Goosefish, Lophius americanus, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-127. September 1999.
Appendix E

July 2007 E-149 NUREG-1437, Supplement 29

Steimle, F.W., W.W. Morse, P.L. Berrien, D.L. Johnson, and C.A. Zetlin. 1999c. Essential Fish

Habitat Source Document: Ocean Pout, Macrozoarces americanus, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-129. September 1999.

Steimle, F.W., C.A. Zetlin, P.L. Berrien, and S. Chang. 1999d. Essential Fish Habitat Source

Document: Black Sea Bass, Centropristis striata, Life History and Habitat Characteristics. NOAA

Technical Memorandum NMFS-NE-143. September 1999.

Steimle, F.W., C.A. Zetlin, P.L. Berrien, D.L. Johnson, and S. Chang. 1999e. Essential Fish

Habitat Source Document: Tilefish, Lopholatilus chamaeleonticeps, Life History and Habitat

Characteristics. NOAA Technical Memorandum NMFS-NE-152. September 1999.

Steimle, F.W., C.A. Zetlin, P.L. Berrien, D.L. Johnson, and S. Chang. 1999f. Essential Fish

Habitat Source Document: Scup, Stenotomus chrysops, Life History and Habitat Characteristics.

NOAA Technical Memorandum NMFS-NE-149. September 1999.

Steiner, W.W., J.J Luczkovich, and B.L. Olla. 1982. Activity, shelter usage, growth and

recruitment of juvenile red hake, Urophycis chuss. Mar. Ecol. Prog. Ser. 7: 125-135.

Stevenson, D.K., and M.L. Scott. 2005. Essential Fish Habitat Source Document: Atlantic

Herring, Clupea harengus, Life History and Habitat Characteristics. NOAA Technical

Memorandum NMFS-NE-192. July 2005.

Stobo, W.T., J.D. Neilson, and P.G. Simpson. 1988. Movements of Atlantic halibut

(Hippoglossus hippoglossus) in the Canadian North Atlantic. Can. J. Fish. Aquat. Sci. 45: 484-

491.

Stone and Webster Engineering Corporation (Stone & Webster). 1975. 316 Demonstration,

Pilgrim Nuclear Power Station – Units 1 and 2. Prepared for Boston Edison Company, Boston,

MA.

Stone and Webster Engineering Corporation (Stone & Webster). 1977. Supplemental

Assessment in Support of the 316 Demonstration, Pilgrim Nuclear Power Station – Units 1 and 2. 

Prepared for Boston Edison Company, Boston, MA.

Studholme, A.L., D.B. Packer, P.L. Berrien, D.L. Johnson, C.A. Zetlin, and W.W. Morse. 1999.

Essential Fish Habitat Source Document: Atlantic Mackerel, Scomber scombrus, Life History and

Habitat Characteristics. NOAA Technical Memorandum NSMFS-NE-141. September 1999.

Templeman, W. 1982a. Development, occurrence, and characteristics of egg capsules of the

thorny skate, (Raja radiata), in the Northwest Atlantic. J. Northwest Atl. Fish. Sci. 3: 47-56.
Appendix E

NUREG-1437, Supplement 29 E-150 July 2007

Templeman, W. 1982b. Stomach contents of the thorny skate, (Raja radiata), from the Northwest

Atlantic. J. Northwest Atl. Fish. Sci. 3: 123-126.

Tennessee Valley Authority (Yellow Creek Nuclear Plant, Units 1 and 2), ALAB-515, 8 NRC 702,

712-13 (1978).

Tibbetts, A.M. 1977. Squid fisheries (Loligo pealei and Illex illecebrosus) off the northeastern

coast of the United States of America 1963-1974. Int. Comm. Northwest Atl. Fish. (ICNAF), Sel.

Pap. 2: 85-109.

Tyler, A.V. 1971. Periodic and resident components in communities of Atlantic fishes, J. Fish.

Res. Board. Can. 28: 935-946.

Vinogradov, V.I. and A.S. Noskov. 1979. Feeding of short-finned squid, Illex illecebrosus, and

longfinned squid, Loligo pealei, off Nova Scotia and New England 1974-75. Int. Comm. 

Vovk, A.N. 1972. Method of determining maturing stages in gonads of the squid Loligo pealeii,

Zool. ZH 51: 127-132, Can. Fish. Res. Transl. Ser. 2337.

Weinberg, J. 2000. Status of Fisheries Resources off Northeastern United States-Atlantic

Surfclam. Revised: January 2000. Accessed at: 

http://www.nefsc.noaa.gov/sos/spsyn/iv/surfclam on August 8, 2006.

Weinberg, J. 2001. Status of Fisheries Resources off Northeastern United States-Ocean

Quahog. Revised: June 2001. Accessed at : http://www.nefsc.noaa.gov/sos/spsyn/iv/quahog,

on August 8, 2006.

Werme, C.E. 1981. Resource partitioning in a salt marsh fish community. Ph.D. dissertation,

Boston Univ., Boston, MA, 132 p.
Appendix F

GEIS Environmental Issues Not Applicable

to Pilgrim Nuclear Power Station 

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

July 2007 F-1 NUREG-1437, Supplement 29

Appendix F

GEIS Environmental Issues Not Applicable

to Pilgrim Nuclear Power Station

Table F-1 lists those environmental issues listed in the Generic Environmental Impact

Statement for License Renewal of Nuclear Plants (GEIS) (NRC 1996; 1999)(a) and 10 CFR

Part 51, Subpart A, Appendix B, Table B-1, that are not applicable to Pilgrim Nuclear Power

Station (PNPS) because of plant or site characteristics.

Table F-1. GEIS Environmental Issues Not Applicable to Pilgrim Nuclear Power Station (PNPS)

ISSUE—10 CFR Part 51, Subpart A,

Appendix B, Table B-1

Category GEIS

Sections Comment

SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Altered thermal stratification of lakes 1 4.2.1.2.2

4.4.2.2

PNPS does not discharge

into a lake. 

Eutrophication 1 4.2.1.2.3

4.4.2.2

PNPS does not discharge

into a lake. 

Discharge of sanitary wastes and minor

chemical spill

1 4.2.1.2.4

4.4.2.2

PNPS does not discharge

sanitary waste to surface

waters. 

Water-use conflicts (plants with cooling

ponds or cooling towers using makeup

water from a small river with low flow)

2 4.3.2.1

4.4.2.1

PNPS does not have a

cooling tower or a cooling

pond and does not use makeup water from a small river

with low flow. 
Appendix F

Table F-1. (contd)

ISSUE—10 CFR Part 51, Subpart A,

Appendix B, Table B-1

Category GEIS

Sections Comment

 NUREG-1437, Supplement 29 F-2 July 2007

AQUATIC ECOLOGY (FOR ALL PLANTS)

Premature emergence of aquatic insects 1 4.2.2.1.7

4.4.3

Aquatic insects are primarily

of concern in freshwater

environments. 

AQUATIC ECOLOGY (FOR PLANTS WITH COOLING TOWER BASED HEAT DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in early

life stages

1 4.3.3 This issue is related to heatdissipation systems that are

not installed at PNPS.

Impingement of fish and shellfish 1 4.3.3 This issue is related to heatdissipation systems that are

not installed at PNPS.

Heat shock 1 4.3.3 This issue is related to heatdissipation systems that are

not installed at PNPS.

GROUNDWATER USE AND QUALITY

Groundwater use conflicts (potable and

service water, and dewatering; plants that

use >100 gpm and plants that use < 100

gpm)

2 4.8.1.1

4.8.2.1

PNPS does not use

groundwater for cooling water

purposes. 

Groundwater-use conflicts (plants using

cooling towers withdrawing makeup water

from a small river)

2 4.8.1.3

4.4.2.1

This issue is related to heatdissipation systems that are

not installed at PNPS.

Groundwater-use conflicts (Ranney wells) 2 4.8.1.4 PNPS does not have or use

Ranney wells.

Groundwater quality degradation (Ranney

wells)

1 4.8.2.2 PNPS does not have or use

Ranney wells.

Groundwater quality degradation (cooling

ponds in salt marshes)

1 4.8.3 PNPS does not use cooling

ponds. 

Groundwater quality degradation (cooling

ponds at inland sites)

2 4.8.3 PNPS is not located at an

inland site.
Appendix F

Table F-1. (contd)

ISSUE—10 CFR Part 51, Subpart A,

Appendix B, Table B-1

Category GEIS

Sections Comment

July 2007 F-3 NUREG-1437, Supplement 29

TERRESTRIAL RESOURCES

Cooling tower impacts on crops and

ornamental vegetation

1 4.3.4 This issue is related to a

heat-dissipation system that

is not installed at PNPS. |

Cooling tower impacts on native plants 1 4.3.5.1 This issue is related to a

heat-dissipation system that

is not installed at PNPS. |

Bird collisions with cooling towers 1 4.3.5.2 This issue is related to a

heat-dissipation system that

is not installed at PNPS. |

Cooling pond impacts on terrestrial

resources

1 4.4.4 This issue is related to a

heat-dissipation system that

is not installed at PNPS. |

HUMAN HEALTH

Microbial organisms (occupational health) 1 4.3.6 This issue is related to a

heat-dissipation system that

is not installed at PNPS. |

Microbial organisms (public health)

(plants using lakes or canals, or cooling

towers or cooling ponds that discharge to

a small river).

2 4.3.6 This issue is related to a

heat-dissipation system that

is not installed at PNPS. |

F.1 References

10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental Protection

Regulations for Domestic Licensing and Related Regulatory Functions.”

Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, DC |

Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for

License Renewal of Nuclear Plants: Main Report, Section 6.3, Transportation, Table 9.1,

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report. 

NUREG-1437, Volume 1, Addendum 1, Washington, DC |



















































BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(9-2004)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

 (Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

NUREG-1437, Supplement 29,

Vol.2 

3. DATE REPORT PUBLISHED

MONTH

July

YEAR

2007

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

Generic Environmental Impact Statement for License Renewal of Nuclear Plants,

Supplement 29

Regarding Pilgrim Nuclear Power Station

Final Report - Appendices

5. AUTHOR(S)

See Appendix B of report.

6. TYPE OF REPORT

Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

Division of License Renewal

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, 

Same as 8. above

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

 Docket No. 50-293

11. ABSTRACT (200 words or less)

This supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted by

Entergy Nuclear Operations, Inc. (Entergy), a subsidiary of Entergy Corporation, to the NRC to renew the OL for Pilgrim Nuclear

Power Station (PNPS) for an additional 20 years under 10CFR Part54. This SEIS includes the NRC staff's analysis that

considers and weighs the environmental impacts of the proposed action, the environmental impacts of alternatives to the

proposed action, and mitigation measures available for reducing or avoiding adverse impacts. It also includes the staff's

recommendation regarding the proposed action.

The NRC staff's recommendation is that the Commission determine that the adverse environmental impacts of license renewal

for PNPS are not so great that preserving the option of license renewal for energy-planning decisionmakers would be

unreasonable. This recommendation is based on (1) the analysis and findings in the GEIS; (2)the Environmental Report

submitted by Entergy; (3) consultations with Federal, State, and local agencies; (4) the staff's own independent review; and (5)

the staff's consideration of public comments.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

Pilgrim Nuclear Power Station

Supplement to the Generic Environmental Impact Statement 

GEIS

29

NUREG 1437, Supplement 29

National Environmental Policy Act 

NEPA 

License Renewal

PNPS

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

(This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commision

Washington, D.C. 20555-0001
Printed

on recycled

paper

Federal Recycling Program