*U.S.NRC

United States Nuclear Regulatory Commission

Protecting People and the Environment

NUREG-1437

Supplement 31

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 31

Regarding

James A. FitzPatrick

Nuclear Power Plant

Final Report

Office of Nuclear Reactor Regulation
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*U.S.NRC

United States Nuclear Regulatory Commission

Protecting People and the Environment

NUREG-1437

Supplement 31

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 31

Regarding

James A. FitzPatrick

Nuclear Power Plant

Final Report

Manuscript Completed: December 2007

Date Published: January 2008

Office of Nuclear Reactor Regulation
NUREG-1437, Supplement 31, has been

reproduced from the best available copy.
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 (GELS), NUREG-1 437,

Volumes 1 and 2, and codified the results in Part 51 of Title 10 of the Code of Federal

Regulations (10 CFR Part 51). In the GElS (and its Addendum 1), the NRC staff identifies

92 environmental issues and reaches 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 GElS.

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

application submitted to the NRC by Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear

Operations, Inc. (Entergy) to renew the OL for James A. FitzPatrick Nuclear Power Plant

(JAFNPP) 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 NRC staff's recommendation

regarding the proposed action.

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

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

applies to JAFNPP. In addition, the NRC staff determined that information provided during the

scoping process did not call into question the conclusions in the GELS. Therefore, the NRC staff

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

identified for these issues in the GElS. For each of these issues, the NRC staff's conclusion in

the GElS is that the impact is of SMALL(1) significance (except for collective offsite 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 JAFNPP are addressed in this SEIS.

For each applicable issue, the NRC staff concludes that the significance of the potential

environmental impacts of renewal of the OL would be SMALL. The NRC staff also concludes

that additional mitigation measures are not likely to be sufficiently beneficial as to be warranted.

The NRC staff determined that information provided during the scoping process did not identify

any new issue with a significant environmental impact.

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

noticeably alter any important attribute of the resource.

January 2008 iii NUREG-1437, Supplement 31 1
Abstract

The NRC staffs recommendation is that the Commission determine that the adverse

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

option of license renewal for energy-planning decision makers would be unreasonable. This

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

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

NRC staffs own independent review; and (5) the NRC staffs consideration of public comments

received during the scoping process and on the draft SEIS.

Paperwork Reduction Act Statement

This NUREG contains information collection requirements that are subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information

collections were approved by the Office of Management and Budget, approval numbers

3150-0004; 3150-0155; 3150-0014; 3150-0011; 3150-0021; 3150-0132; 3150-0151,

3150-0199, and 3150-0093.

Public Protection Notification

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NUREG-1437, Supplement 31 iv January 2008
Contents

A b s tra c t ...................................................................................................................................... iii

Executive Sum mary ................................................................................................................ xiv

Abbreviations/Acronyms ........................................................................................ , ................ xix

1 .0 In tro d u c tio n ...................................................................................................................... 1 -1

1.1 Report Contents ..................................................................................................... 1-2

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

1.2.1 Generic Environmental Im pact Statement ................................................... 1-3

1.2.2 License Renewal Evaluation Process ......................................................... 1-4

1.3 The Proposed Federal Action ................................................................................. 1-7

1.4 The Purpose and Need for the Proposed Action ..................................................... 1-7

1.5 Compliance and Consultations ............................................................................... 1-8

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

2.0 Description of Nuclear Power Plant and Site and Interaction

with the Environm ent ........................................................................................................ 2-1

2.1 Facility and Site Description and Proposed Facility Operation During

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

2.1.1 External Appearance and Setting ................................................................. 2-1

2.1.2 Reactor Systems ........................................................................................ 2-5

2.1.3 Cooling and Auxiliary W ater Systems ......................................................... 2-5

2.1.4 Radioactive Waste Management Systems and Effluent

Control Systems ......................................................................................... 2-7

2.1.4.1 Liquid Waste Processing Systems and Effluent Controls .............. 2-8

2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls ......... 2-9

2.1.4.3 Solid W aste Processing ............................................................. 2-10

2.1.5 Nonradioactive W aste Systems ................................................................ 2-10

2.1.5.1 Nonradioactive W aste Streams .................................................... 2-10

2.1.5.2 Pollution Prevention and W aste Minim ization .............................. 2-13

2.1.6 Facility Operation and Maintenance .......................................................... 2-13

2.1.7 Power Transmission System .................................................................... 2-14

2.2 Facility Interaction with the Environment ............................................................... 2-16

2.2.1 Land Use ................................................................................................. 2-16

2.2.2 W ater Use ................................................................................................. 2-17

2.2.3 W ater Quality ............................................................................................ 2-17

January 2008 v .. NUREG-1 437, Supplement 31 I
Contents

2.2.4 Clim ate, M eteorology, and Air Q uality ....................................................... 2-21

2.2.4.1 Clim ate ........................................................................................ 2-21

2.2.4.2 M eteorology ................................................................................ 2-22

2.2.4.3 Air Q uality ..................................................................................... 2-22

2.2.5 Aquatic Resources ................................................................................... 2-23

2.2.6 Terrestrial Resources ............................................................................... 2-30

2.2.6.1 Terrestrial Resources at the JAFNPP Site ................................... 2-30

2.2.6.2 Terrestrial Resources in Transm ission Corridors ......................... 2-32

2.2.6.3 Terrestrial Species of Concern .................................................... 2-34

2.2.7 Radiological Im pacts ................................................................................ 2-38

2.2.8 Socioeconom ic Factors ............................................................................ 2-39

2.2.8.1 Housing ....................................................................................... 2-39

2.2.8.2 Public Services ........................................................................... 2-41

2.2.8.3 Offsite Land Use ........................................................................ 2-42

2.2.8.4 Visual Aesthetics and Noise ........................................................ 2-43

2.2.8.5 Dem ography ................................................................................ 2-44

2.2.8.6 Econom y .................................................................................... 2-46

2.2.9 Historic and Archaeological Resources ..................................................... 2-49

2.2.9.1 Cultural Background ............................... 2-49

2.2.9.2 Historic and Archaeological Resources at JAFNPP ..................... 2-51

2.2.10 Related Federal Project Activities and Consultations ................................. 2-53

2.2.10.1 Coastal Zone M anagem ent Act .................................................... 2-53

2.2.10.2 Clean Water Act Section 401 Water Quality Certification ............ 2-54

2.3 References .............................................................................................................. 2-55

3.0 Environm ental Im pacts of Refurbishm ent ......................................................................... 3-1

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

4.0 Environm ental Im pacts of O peration ................................................................................ 4-1

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

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

4.1.2 Im pingem ent of Fish and Shellfish ............................................................. 4-15

4.1.3 Heat Shock ............................................................................................... 4-21

4.2 Transm ission Lines ............................................................................................... 4-24

4.2.1 Electrom agnetic Fields- Acute Effects ...................................................... 4-28

4.2.2 Electrom agnetic Fields- Chronic Effects .................................................. 4-29

4.3 Radiological Im pacts of Norm al O perations ......................................................... 4-30

4.4 Socioeconomic Impacts of Plant Operations During the License

Renewal Term ..................................................................................................... 4-32

I NUREG-1437, Supplement 31 vi January 2008
Contents

4.4.1 Housing Impacts ....................................................................................... 4-34

4.4.2 Public Services: Public Utility Impacts ....................................................... 4-35

4.4.3 Offsite Land Use ....................................................................................... 4-36

4.4.3.1 Population-Related Impacts ......................................................... 4-36

4.4.3.2 Tax-Revenue-Related Impacts .................................................... 4-37

4.4.4 Public Services: Transportation Impacts .................................................... 4-37

4.4.5 Historic and Archaeological Resources ..................................................... 4-37

4.4.6 Environmental Justice .............................................................................. 4-39

4.4.6.1 Minority Population in 2000 .......................................................... 4-40

4.4.6.2 Low-Income Population in 2000 ...................... 4-40

4.4.6.3 Analysis of Im pacts ..................................................................... 4-42

4.5 Groundwater Use and Quality .............................................................................. 4-44

4.6 Threatened or Endangered Species ..................................................................... 4-44

4.6.1 Aquatic Species ........................................................................................ 4-46

4.6.2 Terrestrial Species .................................................................................... 4-46

4.7 Evaluation of New and Potentially Significant Information on

Impacts of Operations During the Renewal Term .................................................. 4-47

4.8 Cumulative Impacts .............................................................................................. 4-47

4.8.1 Cumulative Impacts on Aquatic Resources ............................................... 4-48

4.8.2 Cumulative Im pacts on Terrestrial Resources ........................................... 4-51

4.8.3 Cum ulative Impacts on Human Health ...................................................... 4-53

4.8.3.1 Cumulative Impacts Resulting from Continued Operation

of the Transmission Lines ........................................................... 4-53

4.8.3.2 Cumulative Radiological Im pacts ................................................. 4-54

4.8.4 Cumulative Socioeconom ic Impacts .......................................................... 4-54

4.8.5 Conclusions Regarding Cum ulative Im pacts ............................................. 4-54

4.9 Summary of Impacts of Operations During the Renewal Term ............................. 4-54

4.10 References ........................................................................................................... 4-55

5.0 Environmental Im pacts 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 ................................................................. 5-4

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

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

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

5.2.4 Evaluation of Risk Reduction and Costs of Improvements .......................... 5-7

January 2008 Vii NUREG-1437, Supplement 31 I
Contents

5.2.5 Cost-Benefit Comparison ............................................................................ 5-8

5.2.6 Conclusions ............................................................................................... 5-9

5.3 References ............................................................................................................. 5-9

6.0 Environmental Impacts of the Uranium Fuel Cycle and Solid

W aste Management ........................................................................................................ 6-1

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

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

7.0 Environm ental Impacts of Decom missioning .................................................................... 7-1

7.1 Decom missioning ................................................................................................... 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

8.2 Alternative Energy Sources .................................................................................... 8-6

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

8.2.1.1 Once-Through Cooling System ...................................................... 8-9

8.2.1.2 Closed-Cycle Cooling System ...................................................... 8-18

8.2.2 Natural Gas-Fired Generation .................................................................. 8-19

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

8.2.2.2 Closed-Cycle Cooling System ...................................................... 8-29

8.2.3 Nuclear Power Generation ....................................................................... 8-29

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

8.2.3.2 Closed-Cycle Cooling System ...................................................... 8-38

8.2.4 Purchased Electrical Power .......................... ............................................ 8-38

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

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

8.2.5.2 W ind Power ................................................................................. 8-39

8.2.5.3 Solar Power ................................................................................. 8-40

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

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

8.2.5.6 W ood W aste ................................................................................ 8-42

8.2.5.7 Municipal Solid W aste * ................................................................ 8-42

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

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

8.2.5.10 Delayed Retirement .................................................................... 8-44

8.2.5.11 Utility-Sponsored Conservation .................................................. 8-45

8.2.6 Com bination of Alternatives ....................................................................... 8-46

8.3 Sum mary of Alternatives Considered ................................................................... 8-46

I NUREG-1437, Supplement 31 viii January 2008
Contents

8 .4 R e fe re nce s .......................................................................................................... 8-5 1

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 ..................................................................... 9-5

9.1.2 Irreversible or Irretrievable Resource Commitments .................................... 9-5

9.1.3 Short-Term Use Versus Long-Term Productivity .................................... 9-6

9.2 Relative Significance of the Environmental Impacts of License

R enew al and A lternatives ....................................................................................... 9-6

9.3 NRC Staff Recommendation ................................................................................... 9-8

9 .4 R efe re nce s ........................................................................................................... 9 -8

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 ............. C-1

Appendix D Organizations Contacted ............................................................................ D-1

Appendix E Compliance Status and Consultation Correspondence .............................. E-1

Appendix F GElS Environmental Issues Not Applicable to James A. FitzPatrick

Nuclear Power Plant .................................................................................. F-1

Appendix G Severe Accident Mitigation Alternatives ..................................................... G-1

January 2008 ix NUREG-1437, Supplement 31 1
Figures

Figure 2-1. Location of JAFNPP, 50-mi Region ..................................................................... 2-2

Figure 2-2. Location of JAFNPP, 6-mi Region ........................................................................ 2-3

Figure 2-3. JAFNPP Approximate Site Boundary .................................................................... 2-4

Figure 2-4. JAFNPP Transmission Lines ............................................................................. 2-15

Figure 4-1. Minority Block Groups in 2000 within a 50-mi Radius of JAFNPP ....................... 4-41

Figure 4-2. Low-Income Block Groups within a 50-mi Radius of JAFNPP ............................ 4-43

I January 2008 X NUREG-1437, Supplement 31
Tables

Table 2-1. JAFNPP Transmission Lines, Substations, and Corridors ................................... 2-15

Table 2-2. Selected Water Quality Parameters of Lake Ontario ........................................... 2-19

Table 2-3. Aquatic Species Listed as Endangered, Threatened, or a Species of

Special Concern by New York State, Potentially Occurring in Oswego

and O nondaga C ounties ..................................................................................... 2-28

Table 2-4. Federally Listed and New York State-Listed Terrestrial Species

Potentially Occurring in the Vicinity of JAFNPP and in Associated

Transm ission Line C orridors ............................................................................... 2-34

Table 2-5. JAFNPP Permanent Employee Residence by County in 2006 ............. 2-40

Table 2-6. Number of Occupied, Vacant, and Total Housing Units in Oswego

and Onondaga Counties, New York, in 2000 and 2005 ....... I ............................... 2-40

Table 2-7. Major Public Water Supply Systems in Oswego County, Average

Daily Use, and M axim um Daily Capacity ............................... * ........................... 2-41

Table 2-8. Land Use in Oswego and Onondaga Counties ................................................... 2-44

Table 2-9. Population Growth in Oswego and Onondaga Counties, New York,

from 1970 to 2000 and Projected for 2010 and 2020 .......................................... 2-45

Table 2-10. Major Employers in Oswego County in 2006 ..................................................... 2-47

Table 2-11. Oswego County, Town of Scriba, and Mexico Central Schools Tax

Revenues, 2002 to 2005; JAFNPP Property Tax, 2002 to 2005; and

JAFNPP Property Tax as a Percentage of Tax Revenues .................................. 2-48

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

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

Table 4-1. Category 1 Issues Applicable to the Operation of the JAFNPP

Cooling System During the Renewal Term ........................................................... 4-3

Table 4-2. Category 2 Issues Applicable to the Operation of the JAFNPP

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

Table 4-3. Results of Impingement Monitoring of Selected Species at JAFNPP

fro m 1976 throug h 1997 ...................................................................................... 4 -17

Table 4-4. Results of Impingement Monitoring of Selected Species at JAFNPP,

2 0 0 4 ................................................................................................................... 4 -1 9

Table 4-5. Category 1 Issues Applicable to the JAFNPP Transmission Lines

D uring the R enew al T erm ................................................................................. 4-25

Table 4-6. Category 2 and Uncategorized Issues Applicable to the JAFNPP

Transmission Lines During the Renewal Term .................................................... 4-28

Table 4-7. Category 1 Issues Applicable to Radiological Impacts of Normal

O perations During the Renewal Term ............................................................... 4-31

January 2008 Xi NUREG-1437, Supplement 31 I
Tables

Table 4-8. Category 1 Issues Applicable to Socioeconomics During the

R enew al T erm .................................................................................................... 4-32

Table 4-9. Category 2 Issues Applicable to Socioeconomics and Environmental

Justice During the Renew al Term ..................................................................... 4-34

Table 4-10. Category 2 Issue Applicable to Threatened or Endangered Species

D uring the R enew al Term .................................................................................. 4-45

Table 5-1. Category 1 Issues Applicable to Postulated Accidents During the

R e n e w a l T e rm ..................................................................................................... 5 -3

Table 5-2. Category 2 Issues Applicable to Postulated Accidents During the

R e ne w al T e rm ......... ............................... ............................................... 5-4

Table 5-3. JAFNPP Core Damage Frequency ....................................................................... 5-6

Table 5-4. Breakdown of Population Dose by Containment Release Mode ........................... 5-7

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

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

Table 7-1. Category 1 Issues Applicable to the Decommissioning of JAFNPP

Follow ing the R enew al Term ................................................................................. 7-2

Table 8-1. Summary of Environmental Impacts of the No-Action Alternative .......................... 8-3

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

Alternate Site Using Once-Through Cooling ....................................................... 8-10

Table 8-3. Summary of Environmental Impacts of Coal-Fired Generation at an

Alternate Site with Closed-Cycle Cooling ........................................................... 8-19

Table 8-4. Summary of Environmental Impacts'of Natural Gas-Fired Generation

at the JAFNPP Site and an Alternate Site Using Once-Through

C o o lin g . ............................................................................................................... 8 -2 1

Table 8-5. Summary of Environmental Impacts of Natural Gas-Fired Generation

at Either the JAFNPP Site or an Alternate Site with Closed-Cycle

C o o lin g ............................................................................................................... 8 -3 0

Table 8-6. Summary of Environmental Impacts of New Nuclear Power

Generation at the JAFNPP Site and an Alternate Site Using OnceT h ro ug h C o o ling ................................................................................................. 8-32

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

Sited at an Alternate Site with Closed-Cycle Cooling ......................................... 8-38

Table 8-8. Summary of Environmental Impacts of an Assumed Combination of

Generation-Does Not Include Impacts from Purchased Generation

Once-Through Cooling Alternative ...................................................................... 8-47

Table 9-1. Summary of Environmental Significance of License Renewal, the NoAction Alternative, and Alternative Methods of Power Generation ......................... 9-7

Table A-I. Individuals Providing Comments During Scoping Comment Period ..................... A-3

Table A-2. Individuals Providing Comments on the Draft SEIS ; ............................................ A-7

I NUREG-1437, Supplement 31 xii January 2008
Tables

Table E-1.

Table E-2.

Table F-1.

Table G-1.

Table G-2.

Table G-3.

Table G-4.

Table G-5.

C onsultation C orrespondence ............................................................................. E-1

Federal, State, Local, and Regional Licenses, Permits, and Other

Approvals for the James A. FitzPatrick Nuclear Power Plant (JAFNPP) ............... E-2

GElS Environmental Issues Not Applicable to James A. FitzPatrick

N uclear P ow er P lant ....................................................................................... . . F-1

JAFNPP Core Damage Frequency for Internal Events ......................................... G-3

Breakdown of Population Dose by Containment Release Mode .......................... G-4

JAFNPP PSA Historical Summary ....................................................................... G-6

Fire Areas and Their Contribution to the Fire CDF ............................................... G-9

SAMA Cost/Benefit Screening Analysis for JAFNPP ......................................... G-20

January 2008 xiii NUREG-1437, Supplement 31 I
EXECUTIVE SUMMARY

By letter dated July 31, 2006, Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations,

Inc. (Entergy) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to

renew the operating license (OL) for the James A. FitzPatrick Nuclear Power Plant (JAFNPP)

for an additional 20-year period. If the OL is renewed, State regulatory agencies and Entergy

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 October 17, 2014.

The NRC has implemented Section 102 of the National Environmental Policy Act (NEPA),

Title 42, Section 4321, of the United States Code (42 USC 4321) in Part 51 of Title 10 of the

Code of Federal Regulations (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 (GELS), NUREG-1 437, Volumes 1 and 2.(1)

Upon acceptance of the Entergy 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 NRC staff held public scoping meetings on October 12, 2006, in Oswego, New

York, and conducted a site audit at JAFNPP on December 5 and 6, 2006. In the preparation of

this supplemental environmental impact statement (SEIS) for JAFNPP, the NRC staff reviewed

the Entergy Environmental Report (ER) and compared it to the GELS, consulted with other

agencies, conducted an independent review of the issues following the guidance set forth in

NUREG-1 555, Supplement 1, 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.

The draft SEIS was published in June 2007. The NRC staff held two public meetings in

Oswego, New York, in August 2007, to describe the results of the NRC environmental review

and to answer questions. When the comment period ended, the NRC staff considered and

addressed all of the comments received. These comments are addressed in Appendix A.

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

references to the "GELS" include the GElS and its Addendum 1.

I January 2008 xiv NUREG-1 437, Supplement 31
Executive Summary

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 mitigation measures for reducing or avoiding adverse effects. It also includes the NRC

staff's recommendation regarding the proposed action.

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

from the GELS:

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 evaluation criterion for the NRC staff's environmental review, as defined in 10 CFR

51.95(c)(4) and the GELS, 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 decision

makers 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 GElS 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 LARGEJanuary 2008 XV NUREG-1437, Supplement 31 I
Executive Summary

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 GELS, the analysis in the GElS 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 offsite 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 not likely

to be sufficiently beneficial to warrant implementation.

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

significant information, the NRC staff relied on conclusions in the GElS 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 GELS. 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 GELS. Information on the chronic effects of electromagnetic fields

was not conclusive at the time the GElS was prepared.

This SEIS documents the NRC staff's consideration of all 92 environmental issues identified in

the GELS. The NRC 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 JAFNPP) and alternative methods of power generation.

I NUREG-1437, Supplement 31 xvi January 2008
Executive Summary

Based on projections made by the U.S. Department of Energy's Energy Information

Administration (DOE/EIA), gas- and coal-fired generation appear to be the most likely powergeneration alternatives if the power from JAFNPP is replaced. These alternatives are evaluated

assuming that the replacement power generation plant is located at either the JAFNPP site or

some other unspecified alternate location.

Entergy and the NRC 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 NRC staff has identified information that is both new and

significant related to Category 1 issues that would call into question the conclusions in the

GElS. Similarly, neither the scoping process nor the NRC staff has identified any new issue

applicable to JAFNPP that has a significant environmental impact. Therefore, the NRC staff

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

JAFNPP.

Entergy's license renewal application presents an analysis of the Category 2 issues plus

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

reviewed the Entergy analysis for each issue and has conducted an independent review of each

issue. 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 JAFNPP 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 1973 Final

Environmental Statement Related to Operation of James A. FitzPatrick Nuclear Power Plant.

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. Some 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 all 11 Category 2 issues and

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

SMALL significance in the context of the standards set forth in the GELS. In addition, the NRC

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 severe accident mitigation alternatives (SAMAs), the

NRC staff concludes that several candidate SAMAs are potentially cost-beneficial. However,

none of these SAMAs 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.

January 2008 xvii NUREG-1437, Supplement 31
Executive Summary

Mitigation measures were considered for each Category 2 issue. Current measures to mitigate

the environmental impacts of plant operation were found to be adequate, and no additional

mitigation measures were deemed sufficiently beneficial to be warranted.

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, where the JAFNPP license renewal impacts are

deemed to be SMALL, the NRC staff concluded that these impacts would not result in significant

cumulative impacts on potentially affected resources.

If the JAFNPP OL is not renewed and the plant ceases operation on or before the expiration of

its current OL, then the adverse impacts of likely alternatives would not necessarily be smaller

than those associated with continued operation of JAFNPP. The impacts may be greater in

some areas, depending on the alternatives selected.

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

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

option of license renewal for energy planning decision makers would be unreasonable. This

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

Entergy; (3) consultation with other Federal, State, and local agencies; (4) the NRC staff's own

independent review; and (5) the NRC staff's consideration of public comments received during

the scoping process and on the draft SEIS.

I NUREG-1437, Supplement 31 xviii January 2008
ABBREVIATIONS/ACRONYMS

AT temperature difference

ac acre(s)

AC alternating current

ACC averted cleanup and decontamination costs

AEC Atomic Energy Commission

ALARA as low as reasonably achievable

AOC averted offsite property damage costs

AOE averted occupational exposure costs

AOSC averted onsite costs

APE averted public exposure

ATWS anticipated transient without scram

BACT best available control technology

BTU British thermal unit(s)

BWR boiling-water reactor

BWROG boiling-water reactor owner group

°C degree Celsius

CANDU Canadian Deuterium Uranium

CDF core damage frequency

CEQ Council on Environmental Quality

CET containment event tree

CFR Code of Federal Regulations

Ci curie(s)

CMP coastal management program

COE cost of enhancement

CRD control rod drive

CST condensate storage tank

CWA Clean Water Act

CWD chronic wasting disease

CZMA Coastal Zone Management Act

DC direct current

DCH direct containment heating

DBA design-basis accident

DSM demand-side management

March 2007 xix Draft NUREG-1437, Supplement 31
I Abbreviations/Acronyms

DOC U.S. Department of Commerce

DOE U.S. Department of Energy

ECCS emergency core cooling system

EDG emergency diesel generator

EIA Energy Information Administration

EIS environmental impact statement

Entergy Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc.

EPA U.S. Environmental Protection Agency

EPRI Electric Power Research Institute

EPZ emergency planning zone

ER environmental report

ESA Endangered Species Act

ESW emergency service water

ETE evacuation time study

TF degree Fahrenheit

FDS fish deterrence system

FES Final Environmental Statement

FIVE fire-induced vulnerability evaluation

FSAR Final Safety Analysis Report

ft fobt (feet) ' ft3 cubic foot (feet)

ft/m foot (feet) per minute

ft/s feet (feet) per second

FWS U.S. Fish and Wildlife Service

gal gallon(s)

GE General Electric

GElS generic environmental impact statement

GLFC- Great Lakes Fishery Commission

GLWQA Great Lakes Water Quality Agreement

gpd gallon(s) per day

gpm gallons per minute

ha hectare(s)

HCLPF high confidence low probability of failure

HLW high-level waste

HPCI high pressure coolant injection

NUREG-1437, Supplement 31 xx January 2008
Abbreviations/Acronyms I

I&C instrumentation and control

IJC International Joint Commission

IGLD International Great Lakes Datum

in. inch(es)

IPE individual plant examination

IPEEE individual plant examination of external events

ISFSI independent spent fuel storage installation

ISLOCA interfacing system loss of coolant accident

ISLRBC International St. Lawrence River Board of Control

J joule

JAFNPP James A. FitzPatrick Nuclear Power Plant

km kilometer(s)

Kr krypton

kt(s) knot(s)

kV kilovolt

kWh kilowatt-hour

L liter

LAER lowest achievable emissions rate

lb pound(s)

LERF large early release frequency

LLMW low-level mixed waste

LOCA loss of coolant accident

LOSP loss of offsite power

LPCI low pressure coolant injection

m meter(s)

mA milli-ampere(s)

MAAP Modular Accident Analysis Program

MACCS2 MELCOR Accident Consequence Code System 2

m/s meter(s) per second

m 3 cubic meter(s)

MCC Motor Control Center

mg/L milligram(s) per liter

mi mile(s)

min minute(s)

January 2008 xxi NUREG-1437, Supplement 31 1
I Abbreviations/Acronyms

ml

mph

mrem

m/s

MSA

MSIV

mSv

MT

MTHM

MWB

MWd/MTU

MWe

MWh

MWt

NAS

NEPA

NESC

I ng/J

NHPA

NIEHS

NMPNS

NOx

NOAA

NPDES

I NPSH

NRC

NWS

NYCRR

NYISO

NYNHP

NYPA

NYPSC

NYSDEC

NYSDOS

NYSERDA

NYSHPO

OCWA

milliliter

mile(s) per hour

millirem

meter per second

metropolitan statistical area

main steam isolation valvue

millisievert(s)

metric ton(s)

metric ton of heavy metal

Metropolitan Water Board

megawatt days per metric ton of uranium

megawatts-electric

megawatt hour

megawatts-thermal

National Academy of Sciences

National Environmental Policy Act of 1969

National Electrical Safety Code

nanogram(s) per joule

National Historic Preservation Act of 1966

National Institute of Environmental Health Sciences

Nine Mile Point Nuclear Station

nitrogen oxides

National Oceanic and Atmospheric Administration

National Pollutant Discharge Elimination System

net positive suction head

U.S. Nuclear Regulatory Commission

National Weather Service

New York State Codes Rules and Regulations

New York Independent System Operator

New York Natural Heritage Program

New York Power Authority

New York Public Service Commission

New York State Department of Environmental Conservation

New York State Department of State

New York State Energy Research and Development Authority

New York State Office of Parks, Recreation, and Historic Preservation

Onondaga County Water Authority

I NUREG-1437, Supplement 31 xxii January 2008
Abbreviations/Acronyms I

ODCM

OL

OMNR

OPG

OWS

PBT

PCB

PCS

PDS

PGA

PM10

ppm

PSA

PSD

Offsite Dose Calculation Manual

operating license

Ontario Ministry of Natural Resources

Ontario Power Generation

Oswego Water System

persistent, bioaccumulative, and toxic

polychlorinated biphenyls

power conversion system

plant damage status

peak ground acceleration

particulate matter with an aerodynamic diameter less than or equal to 10 microns

parts per million

probabilistic safety assessment

prevention of significant deterioration

radwaste

RAI

rem

RCIC

RCRA

REMP

RHR

RHRSW

ROW

RPC

RRW

SAMA

SAR

SBO

SCR

SEIS

SER

SHPO

SLCS

SMA

SOx

SPDES

January 2008

radioactive waste

request for additional information

roentgen equivalent man

reactor core isolation cooling

Resource Conservation and Recovery Act

Radiological Environmental Monitoring Program

residual heat removal

residual heat removal service water

right-of-way

replacement cost

risk reduction worth

severe accident mitigation alternative

Safety Analysis Report

station blackout

selective catalytic reduction

supplemental environmental impact statement

Safety Evaluation Report

State Historic Preservation Office

standby liquid control system

seismic margin assessment

sulfur oxides

State Pollutant Discharge Elimination System

xxiii NUREG-1437, Supplement 31 1
I Abbreviations/Acronyms

SQUG Seismic Qualification User Group

SRV safety relief valves

SUNY State University of New York

Sv sievert

TMDL total maximum daily load

TRC total residual chlorine

TSCA Toxic Substance Control Act

TSDF Treatment, Storage, or Disposal Facility

USACE U.S. Army Corps of Engineers

USC United States Code

USCB U.S. Census Bureau

USGS U.S. Geological Survey

USI unresolved safety issue

VOC volatile organic compound

Xe xenon

I NUREG-1437, Supplement 31 xxiv January 2008
1.0 INTRODUCTION

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

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

National Environmental Policy Act of 1969 (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 NRC staff has prepared a Generic Environmental Impact Statement

for License Renewal of Nuclear Plants (GELS), NUREG-1437, Volumes 1 and 2 (NRC 1996;

1999).(1) The GElS 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 license renewal proceedings. Use of

the GElS guides the preparation of complete plant-specific information related to the OL

renewal process.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy) operate the

James A. FitzPatrick Nuclear Power Plant (JAFNPP) in northern New York under OL DPR-59,

which was issued by the NRC. This OL will expire in October 2014. By letter dated July 31,

2006, Entergy submitted an application to the NRC to renew the JAFNPP OL for an additional

20 years under 10 CFR Part 54. 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 plant-specific supplement to the GElS (the supplemental EIS [SEIS]) for the

Entergy license renewal application. This SEIS is a supplement to the GElS because it relies, in

part, on the findings of the GELS. The NRC staff will also prepare a separate safety evaluation

report in accordance with 10 CFR Part 54.

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

references to the "GELS" include the GElS and its Addendum 1.

January 2008 1-1 NUREG-1437, Supplement 31 1
Introduction

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 GElS and the process used by the NRC staff to assess

the environmental impacts associated with plant operations during license renewal; (2) describe

the proposed Federal action to renew the JAFNPP 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 GELS.

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

short-term 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 NRC staff's recommendation with respect to the proposed license renewal action.

Additional information is included in appendixes. Appendix A contains public comments related

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

Appendixes B through G, respectively, list the following:

" The preparers of the supplement,

" The chronology of NRC staff's environmental review correspondence related to this

SEIS,

" The organizations contacted during the development of this SEIS,

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

consultation correspondence prepared and sent during the evaluation process),

* GElS environmental issues that are not applicable to JAFNPP, and

" Severe accident mitigation alternatives (SAMAs).

I NUREG-1437, Supplement 31 1-2 January 2008
Introduction

1.2 Background

Use of the GELS, which examines the possible environmental impacts that could occur as a

result of renewing individual nuclear power plant OLs under 10 CFR Part 54, and the

established license renewal evaluation process support the thorough evaluation of the impacts

of renewal of OLs.

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 GELS, which serves as the principal reference for all nuclear

power plant license renewal EISs.

The GElS 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 GElS

(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.

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

mitigation measures would continue.

January 2008 1-3 NUREG-1 437, Supplement 31 1
Introduction

The GElS 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 GELS, 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 offsite 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 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, and

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

In the GELS, the NRC 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 uncategorized issues are environmental justice and chronic effects of electromagnetic

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

addressed in the SEIS. Information on the chronic effects of electromagnetic fields was not

conclusive at the time the GElS 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 GElS is

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

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, reviewed, and assessed to verify the environmental impacts of

the proposed license renewal.

I NUREG-1437, Supplement 31 1-4 January 2008
Introduction

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

* 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

* 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

" 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

" Consider the need for power and other issues not related to the environmental effects of

the proposed action and the alternatives

* 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)

" 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 GElS and codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, or

(2) information that was not considered in the analyses summarized in the GElS and that leads

to an impact finding that is different from the finding presented in the GElS and codified in

10 CFR Part 51.

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

ensure that information not addressed in or available during the GElS evaluation regarding the

environmental impacts of license renewal for JAFNPP would be properly reviewed before

submitting the ER, and to ensure that such new and potentially significant information related to

renewal of the license would be identified, reviewed, and assessed during the period of NRC

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 GElS remained valid with respect to

JAFNPP. This review was performed by personnel from Entergy and its support organizations

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).

January 2008 1-5 NUREG-1 437, Supplement 31 I
Introduction

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 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 NRC staff is evaluated for significance using the

criteria set forth in the GElS. 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 GElS that are

applicable to JAFNPP. At the beginning of the discussion of each set of issues, a table

identifies the issues to be addressed and lists the sections in the GElS 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 GElS conclusion codified in Table B-1 of 10 CFR Part 51,

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

issues, in addition to the list of GElS 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.

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 publication of a Notice of Acceptance for

docketing and opportunity for a hearing in the Federal Register (FR; 71 FR 55032 [NRC 2006])

on September 20, 2006, which also included a Notice of Intent to prepare an EIS and conduct

scoping. Two public scoping meetings were held on October 12, 2006, in Oswego, New York.

Comments received during the scoping period were summarized in the Environmental Scoping

Summary Report Associated with the Staff's Review of the Application by Entergy for Renewal

of the Operating License for James A. FitzPatrick Nuclear Power (NRC 2007a). Comments

within the scope of the environmental review are presented in Appendix A.

The NRC staff followed the review guidance contained in NUREG-1 555, Supplement 1 (NRC

2000). The NRC staff and contractors retained to assist the staff conducted a site audit at the

JAFNPP site on December 5 and 6, 2006, to gather information and to become familiar with the

site and its environs. The NRC 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 JAFNPP were reviewed and are

referenced in this SEIS.

This SEIS presents the NRC staff's analysis that considers and weighs the environmental

effects of the proposed renewal of the OL for JAFNPP, the environmental impacts of

I NUREG-1437, Supplement 31 1-6 January 2008
Introduction

alternatives to license renewal, and mitigation measures available for avoiding adverse

environmental effects. Chapter 9, "Summary and Conclusions," provides the NRC staff's

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

decision makers would be unreasonable.

On June 15, 2007, the NRC published the Notice of Availability of the draft SEIS in 72 FR 33222

(NRC 2007b). A 75-day comment period began on the date of publication of the U.S.

Environmental Protection Agency Notice of Availability of the draft SEIS to allow members of the

public to comment on the results of the NRC staff's review. In August 2007, during this

comment period, two public meetings were held in Oswego, New York. During these meetings,

the NRC staff described the preliminary results of the NRC environmental review and answered

questions. The comment period for the James A. FitzPatrick draft SEIS ended on September 5,

2007. Comments made during the 75-day comment period, including those made at the two

public meetings, are presented in Part 2 of Appendix A. The NRC responses to those

comments are also provided.

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

the proposed renewal of the OL for JAFNPP, the environmental impacts of alternatives to

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

Chapter 9 provides the NRC staffs 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 decision makers would be unreasonable.

1.3 The Proposed Federal Action

The proposed Federal action is renewal of the OL for JAFNPP. JAFNPP is located in northern

New York on the south shore of Lake Ontario, approximately 7 miles (mi) northeast of Oswego,

New York, 36 mi north-northeast of Syracuse, New York, and 65 mi east of Rochester, New

York. The plant has a single boiling water reactor (BWR) designed by the General Electric

Company with a rated power level of 2536 megawatts thermal (MWt) and a gross power output

of 881 megawatts electric (MWe). Plant cooling is provided by a once-through cooling system

that discharges heated water back to Lake Ontario through a discharge structure. The current

OL for JAFNPP expires on October 17, 2014. By letter dated July 31, 2006, Entergy submitted

an application to the NRC (Entergy 2006a) to renew this OL for an additional 20 years of

operation (i.e., until October 17, 2034).

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

January 2008 1-7 NUREG-1 437, Supplement 31 I
Introduction

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 (GElS 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.

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 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. 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 JAFNPP license renewal.

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

Appendix E.

The NRC 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. The ER states that Entergy is in compliance with applicable

environmental standards and requirements for JAFNPP. The NRC staff has not identified any

environmental issues that are both new and significant.

I NUREG-1437, Supplement 31 1-8 January 2008
Introduction

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 (AEA). 42 USC 2011, et seq.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006a.

James A. FitzPatrick Nuclear Power Plant - License Renewal Application. Lycoming,

New York. Accessible at ML062160494.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006b.

James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E:

Applicant's Environmental Report, Operating License Renewal Stage. Lycoming, New York.

Accessible at ML062160557.

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

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

for License Renewal of Nuclear Plants. NUREG-1 437, Volumes 1 and 2. Office of Nuclear

Regulatory Research, Washington, D.C.

U.S. 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. Office of Nuclear Regulatory Research. Washington,

D.C.

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

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

Supplement 1. Office of Nuclear Reactor Regulation. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2006. "Notice of Acceptance for Docketing of the

Application, Notice of Opportunity for a Hearing and Notice of Intent to Prepare an

Environmental Impact Statement and Conduct Scoping Process for Facility Operating License

No. DPR-59 for an Additional 20-Year Period, Entergy Nuclear Operations, Inc., James A.

January 2008 1-9 NUREG-1 437, Supplement 31 1
Introduction

Fitzpatrick Nuclear Power Plant." Federal Register Vol. 71, No. 182, pp. 55032-55035.

September 20, 2006. Accessible at ML071000085.

U.S. Nuclear Regulatory Commission (NRC). 2007a. Environmental Scoping Summary Report

Associated with the Staff's Review of the Application by Entergy for Renewal of the Operating

License for JAFNPP. Washington, D.C. March 2, 2007. Accessible at ML070440393.

U.S. Nuclear Regulatory Commission (NRC). 2007b. "Environmental Impacts Statements;

Notice of Availability: James A. Fitzpatrick Nuclear Power Plant, License Renewal of Nuclear

Plant, Site Specific Supplement 31 to NUREG 1437, Town of Sriba, NY." Federal Register, Vol.

72, No. 115, pp. 33221-33222. Washington, D.C. June 15, 2007. Accessible at ML071780243.

I -NUREG-1437, Supplement 31 1-10 January 2008
2.0 DESCRIPTION OF NUCLEAR POWER PLANT AND SITE AND

INTERACTION WITH THE ENVIRONMENT

James A. FitzPatrick Nuclear Power Plant (JAFNPP) is located in the town of Scriba, New York.

The plant consists of one unit, a boiling water reactor (BWR), which employs a once-through

cooling system. JAFNPP is owned and operated by Entergy Nuclear FitzPatrick, LLC, and

Entergy Nuclear Operations, Inc. (Entergy). The plant and its environs are described in

Section 2.1, and the environment in which the plant is located is presented in Section 2.2.

2.1 Facility and Site Description and Proposed Facility Operation During the

Renewal Term

JAFNPP is located on approximately 702 acres (ac) of land on the south shore of Lake Ontario,

at a location known as Nine Mile Point. The plant is in a rural area, approximately seven miles

(mi) northeast of Oswego, 36 mi north-northwest of Syracuse, and 65 mi east of Rochester,

New York. The largest town within a 50-mi radius is Syracuse. Nine Mile Point Nuclear Station,

Units 1 and 2, operated by Nine Mile Point Nuclear Station, LLC, is immediately west of

JAFNPP. Figures 2-1 and 2-2 show the site location and features within 50 mi and 6 mi,

respectively (Entergy 2006d).

2.1.1. External Appearance and Setting

The area surrounding JAFNPP is generally flat, rising gently from Lake Ontario to the

Appalachian Uplands on the south, and bounded on the east by the Tug Hill Upland. The plant

is at an elevation of 270 feet (ft) above mean sea level. Elevation rises to 310 ft at the

property's southern edge 1 mi away. The JAFNPP site is partially wooded and surrounded

primarily by residential and recreational areas except for the Nine Mile Point Nuclear Station.

There is no residential, agricultural, or industrial development (other than JAFNPP) on the

JAFNPP site. The nearest residence is outside the site boundary approximately 0.7 mi to the

east-southeast.

The buildings associated with JAFNPP lie on the northwest part of the site (See Figure 2-3).

The plant consists of a reactor building, turbine building with electrical and heater bays,

administration building and control room, radioactive waste building, screenwell-pumphouse

building with intake and discharge tunnels and structures, diesel generator building, auxiliary

boiler building, main stack, independent spent fuel storage installation (ISFSI), sewage

treatment plant, interim radioactive waste storage building, switchyard, shooting ranges, and

associated transmission lines. The facility is enclosed by a security fence and access to the site

is controlled. Although the plant structures can be seen by recreational users on Lake Ontario,

JAFNPP is not visible to local communities due to the surrounding forest cover.

January 2008 2-1 NUREG-1437, Supplement 31 I
Plant and the Environment

Key to features

Major cities and towns

*. 2505-4593 - Major highways

* 4594- 7053 " Z] County Boundaries

* 7054-17954 Canada

* 17955 - 28574

o 28575- 147306

0 5 10 20 30 40 50

Miles

Figure 2-1.

I NUREG-1437, Supplement 31

Location of JAFNPP, 50-mi Region (Entergy 2006d)

2-2. January 2008
Plant and the Environment

Fitzpatrick

Key to features

Major cities and towns

* 2505.- 4593

* 4594-7053

0 7054-.17954

* 17955 - 28574

* 28575- 147306

0 1 2 4 6

Miles

Figure 2-2. Location of JAFNPP, 6-mi Region (Enteergy 2006d)

January 2008 2-3 NUREG-1 437, Supplement 31
Plant and the Environment

o 0.1 0.2 0.4 0.6 0.8 1

Miles

Figure 2-3. JAFNPP Approximate Site Boundary:

The plant is accessed by Lake Road, which connects to Oswego County Route 29. A spur of

Conrail Railroad is currently blocked for security purposes. but could be re-opened to provide rail

service to the plant. JAFNPP can also be reached by barge on Lake Ontario.

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Within a 50-mi radius of JAFNPP there are 17 state parks, 20 state wildlife management areas,

and one national wildlife refuge. The closest public park, Sunset Bay Park, is approximately

1 mi east of JAFNPP on the shore of Lake Ontario. This park has 48 ac of mostly woods and

brush land, a boat launch, nature trail, and picnic area. The next closest public park,

Independence Park, is approximately 2 mi southwest and also on Lake Ontario. This park has

50 ac of wooded land, walking trails, and an observation deck. Scriba Town Park is 5 mi south

of Scriba and includes a picnic area, playground, and swimming facilities.

2.1.2 Reactor Systems

JAFNPP is a single-cycle, forced-circulation BWR that produces steam for direct use in the

steam turbine. The rated thermal output of the unit is 2536 megawatts-thermal (MWt),

corresponding to an electrical output of approximately 881 megawatts-electric (MWe). JAFNPP

achieved commercial operation in 1975 (Entergy 2006d).

The JAFNPP facility boundary is depicted in Figure 2-3. The reactor building is designed as a

low in-leakage, elevated release secondary containment system that houses the primary

containment system, refueling facilities, and most of the components of the nuclear steam

supply system. The secondary containment system provides secondary containment when the

primary containment system is closed and in service, and provides primary containment when

the primary containment system is open, as in refueling. The secondary containment system

consists of the reactor building, standby gas treatment system, reactor building isolation control

system, and main stack.

In the event of a postulated pipe break inside the drywell or a fuel handling accident, the reactor

building is isolated by the reactor building isolation control system to provide a low leakage

barrier. The standby gas treatment system, which is initiated by the same conditions that isolate

the reactor building, exhausts air from the reactor building to maintain a reduced pressure within

the reactor building relative to the outside atmosphere, treats the air to remove particulates and

iodines, and releases the air through the elevated release point, the main stack. These safety

features function to localize, control, mitigate, and terminate such events to limit the public's

exposure levels to below applicable dose guidelines.

The fuel for the reactor core consists of slightly enriched uranium dioxide pellets contained in

sealed Zircaloy-2 tubes that were evacuated, backfilled with helium, and sealed with Zircaloy

end plugs welded in each end. The core is designed to permit the energy extraction of

19,000 megawatt-days per metric ton of uranium averaged over the initial core load (Entergy

2006d).

2.1.3 Cooling and Auxiliary Water Systems

JAFNPP uses water from Lake Ontario for station cooling. Approximately 91 percent of the

water withdrawn from the lake is used for the circulating water system to cool the station's main

condenser. Approximately 9 percent of the water withdrawn from the lake is used for the station

January 2008 2-5 NUREG-1437, Supplement 31 I
Plant and the Environment

service water system and other plant systems including the emergency service water system,

the residual heat removal system, and the fire protection system.

Water is withdrawn from the lake from an offshore submerged intake structure and through the

intake tunnel to the screenwell-pumphouse building. Water is eventually returned to the lake by

way of a discharge tunnel and an in-lake diffuser system. The cooling and auxiliary water

systems for JAFNPP include the intake structure, intake tunnel, screenwell and pumphouse

building, discharge tunnel, and diffuser. Neither the intake or discharge diffuser structures are

in the shipping lanes of the lake and therefore do not constitute a hazard to commercial

shipping.

The offshore intake structure is a reinforced concrete structure located approximately 900 ft

from the shoreline in approximately 25 ft of water. Water is drawn from lower levels of the lake

to prevent the formation of vortices at the surface and minimize the possibility of interactions

with floating ice and the lake fishery. The structure is approximately 14 ft high and the top of the

intake structure is approximately 10 ft below the lake surface. The fan-shaped intake is located

on the shoreward side of the structure. Water is drawn through four openings with a total intake

area of approximately 8 ft by 70 ft. The intake velocity at the intake structure is approximately

1.6 feet per second (ft/s).

The intake opening also includes a bar rack, with bars placed 1 ft apart, to prevent large debris

from entering the intake. The bars are heated by induction coils to minimize the probability of

frazil ice adhering to the bars and blocking the intake. The heaters are normally kept energized

except during maintenance. During maintenance, any frazil ice that is drawn past the intake

racks is tempered in the screenwell structure with water from the circulating water discharge

chamber. In the unlikely event that the intake is blocked and the volume of water needed for

normal shutdown cannot be drawn, the flow in the discharge structure can be reversed using a

series of gates, and cooling water can be drawn through the discharge tunnel to the screenwellpumphouse building.

JAFNPP has installed a high-frequency/high-amplitude acoustic fish deterrence system (FDS)

on the intake structure. The JAFNPP FDS consists of nine overlapping, wide-beam, highfrequency transducers mounted on the top of the intake structure. The transducers produce a

sound field designed to deter alewifes from entering the intake structure and eventually

becoming impinged on the intake screens.

From the intake structure, the lake water drops 60 ft below lake level to a tunnel connecting the

intake structure to the onshore screenwell-pumphouse building. The D-shaped tunnel has a flat

bottom, vertical sides, and round top; average water velocity in the tunnel is 4.7 ft/s. From the

intake tunnel, the water rises into the forebay of the screenwell-pumphouse building.

The screenwell-pumphouse building, which is the structure immediately north of the turbine

building, houses the trash racks, traveling screens, pumps for the circulating water, service

I NUREG-1437, Supplement 31 2-6 January 2008
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water, emergency service water, residual heat removal, and fire protection systems. The

screenwell-pumphouse also houses the water treatment tanks and associated biofouling control

equipment.

From the intake tunnel, water enters the screenwell-pumphouse forebay, travels through vertical

trash bars that excludes debris greater than 3 1/8-inches, then through the vertical traveling

screens with a 3/8-inch mesh. The screenwell behind the vertical traveling screens houses

three circulating water pumps each with a rated flow of 120,000 gpm. The design circulating

water flow is 352,600 gpm through the main condenser.

Discharge from the main condenser and service water system is returned to Lake Ontario

through the discharge tunnel and diffuser system in the lake. The design effluent flow rate to

the discharge tunnel is 388,600 gpm, including the design service water pumps discharge of

36,000 gpm. The discharge tunnel starts from the screenwell-pumphouse building and extends

approximately 1400 ft northward into the lake to a junction with the diffuser branch tunnels,

which are generally parallel to the shoreline. The discharge diffuser consists of six diffuser

heads, three on each diffuser branch and spaced approximately 150 ft apart. On top of each

riser is a diffuser head consisting of two horizontal discharge nozzles separated by an included

angle of 42 degrees. Each nozzle is 2.5 ft in diameter and discharges water at an exit velocity

of 14 ft/s in the offshore direction. The centerline of the nozzles is five to six ft above the lake

bottom.

Discharges from the cooling water and service water systems are regulated by the New York

State Department of Environmental Conservation (NYSDEC) under State Pollutant Discharge

Elimination System (SPDES) Discharge Permit NY-0020109 (Entergy 2006d).

2.1.4 Radioactive Waste Management Systems and Effluent Control Systems

JAFNPP radioactive waste (radwaste) systems are designed to collect, treat, and dispose of the

radioactive and potentially radioactive wastes that are byproducts of plant operations. The

byproducts are activation products resulting from the irradiation of reactor water and impurities

therein (principally metallic corrosion products) and fission products resulting from defective fuel

cladding or uranium contamination within the reactor coolant system. Operating procedures for

radwaste systems ensure that radioactive wastes are safely processed and discharged from the

plant within the limits set forth in Part 20 of Title 10 of the Code of Federal Regulations (10 CFR

Part 20), 10 CFR Part 50, the plant's technical specifications, and JAFNPP's Offsite Dose

Calculation Manual or ODCM (Entergy 2004c, 2006d).

Radioactive wastes resulting from plant operations are classified as liquid, gaseous, or solid.

Liquid radioactive wastes are generated from liquids received directly from portions of the

reactor coolant system or were contaminated by contact with liquids from the reactor coolant

system. Gaseous radioactive wastes are generated from gases or airborne particulates vented

from reactor and turbine equipment containing radioactive material. Solid radioactive wastes

January 2008 2-7 NUREG-1437, Supplement 31
Plant and the Environment

are solids from the reactor coolant system, solids that came into contact with reactor coolant

system liquids or gases, or solids used in the reactor coolant system or steam and power

conversion system operation or maintenance (Entergy 2006d).

Reactor fuel that has exhausted a certain percentage of its fissile uranium content is referred to

as spent fuel. Spent fuel assemblies are removed from the reactor core and replaced with fresh

fuel assemblies during routine refueling outages, typically every 24 months. 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 at the onsite ISFSI. JAFNPP also provides for onsite

storage of mixed wastes, which contain both radioactive and chemically hazardous materials

(Entergy 2006d).

JAFNPP's ODCM contains the methodology and parameters used to calculate offsite doses

resulting from radioactive gaseous and liquid effluents, and the gaseous and liquid effluent

monitoring alarm and trip set points used to verify that the radioactive material being discharged

meets regulatory limits (Entergy 2004c). The ODCM also contains the radioactive effluent

controls and radiological environmental monitoring activities and descriptions of the information

that should be included in the annual Radiological Environmental Operating Report and annual

Radioactive Effluent Release Report required by 10 CFR Part 50, Appendix I, and 10 CFR

50.36a, respectively.

2.1.4.1 Liquid Waste Processing Systems and Effluent Controls

The liquid waste processing system collects, holds, treats, processes, and monitors all liquid

radioactive wastes for reuse or disposal. The system is divided into several subsystems so that

liquid wastes from various sources can be segregated and processed separately. Cross

connections between the subsystems provide additional flexibility for processing the wastes by

alternate methods. The wastes are collected, treated, and disposed of according to their

conductivity and/or radioactivity (Entergy 2006d).

Liquid waste is collected in sumps and drain tanks and transferred to the appropriate subsystem

collection tanks for subsequent treatment, disposal, or recycle. The subsystems provide for

filtration, demineralizing, dewatering, and resin filtration; and include a modular fluidized transfer

demineralization and sluice system. Following treatment and batch sampling, the liquid waste is

normally returned to condensate storage tanks for reuse in the plant. Liquid releases to the lake

are infrequent, and limited to the maximum extent possible to satisfy the design objectives of

Appendix I to 10 CFR Part 50. Liquid discharge concentrations are further reduced by dilution

water before any release to the lake. Chemical waste is dewatered and sent offsite to an

approved disposal site. Controls for limiting the release of radiological liquid effluents are

described in the ODCM (Entergy 2004c).

The NRC staff reviewed the JAFNPP radioactive effluent release reports for 2001 through 2005

for liquid effluents (Entergy 2006a, 2005a, 2004a, 2003, 2002a, 2002b). In 2005, 3 million liters

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Plant and the Environment

(L) of radiological liquid effluents diluted with 921 million L of water and a total of 1.01 x 10-2 Ci

of tritium diluted to concentrations below 2 x 10-6 pCi/mI were released (Entergy 2006a). The

releases contained no other fission or activation products, gross alpha radioactivity, or dissolved

and entrained gases.

Based on the liquid waste processing systems and effluent controls and performance from 2001

through 2005, similar small quantities of radioactive liquid effluents are expected from JAFNPP

and are not expected to increase during the renewal period. These releases would result in

doses to members of the public that are well below the as low as reasonably achievable

(ALARA) dose design objectives of Appendix I to 10 CFR Part 50, as discussed in Section

2.2.7.

2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls

The gaseous radwaste processing system processes and disposes of condenser off-gases via

the main stack. Non-radioactive gland seal gas and gases from the start-up mechanical pump

are also discharged via the stack. During routine reactor operation, condenser off-gas is the

major contributor to the activity in the off-gas release. Condenser off-gas entering this system

consists of non-condensables from the main condenser, which consist of hydrogen and oxygen

formed in the reactor by the radiolytic decomposition of water, air in-leakage to the turbinecondenser, water vapor, and a negligible volume of fission gases. The most important sources

of radioactive gases are activation gases in the reactor coolant and fission gases that leak

through the fuel cladding (Entergy 2006d).

The gaseous radwaste processing system controls, filters, and removes radioactive particulates

and iodine from off-gas steam, recombines radiolytic hydrogen and oxygen, provides adequate

holdup time for decay of short-lived radionuclides, and uses charcoal beds for the hold-up and

partial decay of xenon (Xe) and krypton (Kr) gases. The stack design ensures prompt mixing of

gas inlet streams at its base, thereby providing prompt dilution of hydrogen and allowing the

location of sample points as near the base as possible.

JAFNPP maintains gaseous effluents in accordance with the procedures and methodology

described in the ODCM. The gaseous radwaste system is used to reduce radioactive materials

in gaseous effluents before discharge to meet the ALARA dose design objectives in 10 CFR

Part 50, Appendix I. Radioactive effluent gases are released at a typical rate of 24 to 28 cubic

feet per minute (ft3/min). Two air dilution fans are in the base of the stack, both rated at

3000 ft3/min. One dilution fan operates continuously while the other fan is on standby. The flow

from the operating stack dilution fan also ensures that hydrogen is diluted to less than 4 percent

by volume. In addition, the limits in the ODCM are designed to prevent members of the public in

unrestricted areas from being exposed to radioactive materials in excess of the limits specified

in 10 CFR Part 20, Appendix B (Entergy 2004c).

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The NRC staff reviewed the JAFNPP radioactive effluent release reports for 2001 through 2005

for gaseous effluents (Entergy 2006a, 2005a, 2004a, 2003, 2002a, 2002b). In 2005, the total

fission and activation products released was 4370 Ci; iodine-131 was 9.35 x 10-3 Ci; particulates

were 3.52 x 10-3 Ci; and tritium was 17.1 Ci. These activities are typical of past years and are

not expected to increase during the renewal period. See Section 2.2.7 for a discussion of the

theoretical doses to the maximally exposed individual as a result of these releases.

2.1.4.3 Solid Waste Processing

The solid radwaste processing equipment is located in the radioactive waste building with the

exception of the cleanup phase separator tanks, which are located in the reactor building. Both

wet and dry radioactive solid wastes are processed. Wet solid wastes include backwash sludge

wastes from the reactor water cleanup system, waste from floor drain filters, the fuel pool filterdemineralizers, spent resins from the waste and condensate demineralizers, and spent media

from modular fluidized transfer demineralization and sluice system. Dry solid wastes include

rags, contaminated clothing, paper, small equipment parts, and solid laboratory wastes (Entergy

2006d).

Contaminated waste such as demolished piping, equipment, and components from facility

radiological-controlled areas are first processed at an onsite decontamination unit. If the

material is below the acceptable release limits and after additional cleaning shows no further

reduction of contamination levels, the material may be returned to use or released from the

radiological-controlled area. If the material is not below the release limits and after additional

cleaning shows no further reduction of contamination levels, it will be disposed of as radioactive

waste. In some instances, the solid material is sent to a vendor for decontamination. This

material may be returned for reuse or disposed of as radioactive waste per the vendor's process

(Entergy 2006d).

In 2005, JAFNPP made a total of 35 shipments of solid waste to offsite vendors. The solid

waste volumes were 623 cubic meters (mi3) of dry compressible waste, contaminated

equipment, and spent resins, with an activity of 131 Ci (Entergy 2006a). No irradiated

components or control rods were shipped. The solid waste volumes and radioactive material

activity levels are typical of annual waste shipments for JAFNPP and are not expected to

increase during the renewal period.

2.1.5 Nonradioactive Waste Systems

JAFNPP generates nonhazardous waste, hazardous and universal waste, mixed waste, and

wastewaters from routine facility operations and maintenance activities.

2.1.5.1 Nonradioactive Waste Streams

JAFNPP generates solid waste, as defined by the Resource Conservation and Recovery Act

(RCRA), as part of routine plant maintenance, cleaning activities, and plant operations. A

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contract service collects this waste, which is neither radioactive or hazardous, and disposes of

the waste offsite. JAFNPP has an active recycling program for nonhazardous waste such as

office paper, aluminum cans, and plastic.

Hazardous waste is nonradioactive waste that is listed by the U.S. Environmental Protection

Agency (EPA) as hazardous waste or that exhibits characteristics of ignitability, corrosivity,

reactivity, or toxicity (40 CFR Part 261). RCRA regulates the treatment, storage, and/or

disposal of hazardous waste and requires a hazardous waste permit for facilities that treat or

store large quantities of hazardous waste for more than 90 days and for entities that dispose of

hazardous waste at the facility. RCRA regulations are administered in New York State by

NYSDEC.

JAFNPP generates a variety of hazardous waste streams including broken fluorescent lamps,

mercury, off-specification or expired chemicals, oil lab wastes, oils and solvents, paint waste,

photographic waste, and polychlorinated biphenyls (PCBs). JAFNPP is a small-quantity

generator of hazardous waste, meaning the plant generates less than 1000 kilograms (kg) of

non-acute hazardous waste in a month and stores less than 6000 kg of this waste at any one

time. A small-quantity generator can also be classified as generating less than 1 kg of acute

hazardous waste in a month and storing less than 1 kg of this waste at one time. In 2004,

JAFNPP generated 5266 kg of hazardous waste. Most of the waste was associated with the

demolition of buildings. Approximately 318 kg of hazardous waste was generated in 2005 and

626 kg in 2006. During 2004 to 2006, NYSDEC conducted two regulatory compliance

inspections of JAFNPP's RCRA program. No hazardous waste permit violations were noted.

Universal waste is hazardous waste that has been specified as universal waste by the EPA.

Universal waste, including mercury-containing equipment, batteries, lamps, and pesticides, has

specific regulations (40 CFR Part 273) to ensure proper collection and recycling or treatment.

States may modify the universal waste rule and add additional wastes to their list of universal

wastes. New York State classifies batteries, pesticides, mercury-containing thermostats, and

lamps as universal wastes, which are therefore subject to specific universal waste regulations

(6 NYCRR Subpart 374).

JAFNPP generates pesticides, batteries, and fluorescent lamps as universal wastes from

normal facility operations. The batteries and lamps are accumulated in satellite areas and then

moved to a locked storage building, in accordance with State universal waste regulations. The

wastes are then shipped off-site by a contract service for recycling. In 2005, JAFNPP

generated approximately 7193 kg of spent batteries and 843 kg of spent fluorescent bulbs. In

2006, 2749 kg of spent batteries and 843 kg of spent bulbs were generated. During the 2004

RCRA inspection, one universal waste program violation related to the management of spent

fluorescent bulbs was noted but fixed immediately by site personnel (Entergy 2006h).

The Toxic Substance Control Act (TSCA) of 1976 (15 USC s/s 2601 et seq.) implemented

regulations for EPA to track specific toxic chemicals used in the U.S. PCBs, a TSCA chemical

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are found at JAFNPP in limited quantities in lighting ballasts and capacitors. Although the waste

was properly disposed, JAFNPP received a fine from EPA in 2005 for shipping used oil

containing PCBs on a manifest not specified under TSCA. As a result, Entergy created a fleetwide TSCA management plan that has been implemented at JAFNPP.

Low-level mixed waste (LLMW) is waste that exhibits hazardous characteristics and contains

low levels of radioactivity. LLMW has been regulated under multiple authorities. EPA or state

agencies regulate the hazardous component of LLMW through RCRA, and either the U.S.

Department of Energy (DOE) or NRC regulates the radioactive component. New York State

has adopted the EPA rule (6 NYCRR Part 374), which provides for a conditional exemption of

LLMW storage, to eliminate dual regulation of LLMW. Storage of LLMW at JAFNPP is

I permitted under its NYSDEC Treatment, Storage, or Disposal Facility (TSDF) permit

(No. NYD000765073). The permit was issued in November 1995 and expired in January 2000.

New York Power Authority (NYPA), the owner of JAFNPP at the time, submitted a letter to

NYSDEC (NYPA 2000) with its intention to operate under the conditional exemption.

Subsequently, NYSDEC allowed the existing permit to continue under the State Administrative

Procedures Act (Section 401) until the EPA rule was finalized (NYSDEC 2000a). JAFNPP

submitted a letter to NYSDEC in November 2005 stating that JAFNPP qualified for the LLMW

exemption and would, therefore, like to terminate its Part 373 Permit (Entergy 2005d). The

permit is still pending termination by NYSDEC.

JAFNPP generates oil and solvent wastes, off-specification chemicals, and paint wastes (solids

and liquids) from normal facility operation and maintenance. These wastes, when generated,

are stored in locked, marked containment buildings specifically for LLMW. JAFNPP last

shipped LLMW offsite for disposal in 2005. JAFNPP generates small amounts of LLMW but

does not currently have any stored in the mixed waste storage building (Entergy 2006h).

JAFNPP generates two types of wastewater: sanitary liquid wastes and industrial effluents.

Radioactive liquid waste is addressed in Section 2.1.4. Section 2.2.3 provides more information

on JAFNPP's SPDES permit.

JAFNPP operates a sewage treatment plant to treat sanitary wastewater generated by the plant.

The treated water is discharged into a drainage ditch that flows into Lake Ontario and is

regulated as Outfall 012 in the SPDES permit (No. NY-0020109) issued by NYSDEC. Sanitary

sludge from the sewage treatment plant is placed in covered sludge drying beds. The sludge is

removed by a contractor as needed and disposed of at an offsite treatment facility.

Industrial effluents are typically combined with cooling water discharges in accordance with

SPDES permit requirements. There are five SPDES-permitted outfalls (Outfalls 001 through

005). Circulating cooling water, service water, intake screen backwash, clarifier blowdown, filter

backwash, clearwell overflow, waste tank discharges, borated water, and emergency diesel

generator cooling water are discharged at Outfall 001. Combined storm water and oil-water

separator wastewater are discharged at Outfall 002. Storm water runoff is discharged at

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Outfalls 003, 004, and 005. Overflow from the sedimentation containment pond is also

discharged from Outfall 005. JAFNPP's SPDES permit requires specific monitoring and/or

sampling at each of the outfalls.

The Emergency Planning and Community Right-to-Know Act (EPCRA) requires applicable

facilities to provide information on hazardous and toxic chemicals to emergency planning

authorities and the EPA. JAFNPP is subject to EPCRA Section 312 reporting and therefore

submits annual reports to local emergency agencies on the following chemicals: carbon dioxide,

diesel fuel, electrohydraulic fluid, fuel oil, gasoline, hydrogen, lube oils, nitrogen, oxygen, resins,

and sodium hypochlorite (Entergy 2006h).

2.1.5.2 Pollution Prevention and Waste Minimization

Currently, JAFNPP has several waste minimization measures in place. JAFNPP recycles

grease from the onsite cafeteria, as well as aluminum, office paper, and used oil. Another

waste minimization measure is the use of shock absorbing concrete (SACON) blocks as

backstops for firing activities at the firing ranges. The SACON blocks capture expended rounds,

preventing potential groundwater or soil lead contamination. The block supplier removes the

spent SACON blocks and recycles them into other concrete products (Entergy 2007a).

Entergy has a corporate policy and plan for waste minimization at its nuclear power plants,

including JAFNPP (Entergy 2006c). The plan provides a hierarchy of waste minimization

options that emphasize source reduction, reuse/recycling, treatment to reduce volume and/or

toxicity, and disposal, in that order. A fleet-wide focus group meets to discuss opportunities for

waste minimization and information sharing among the Entergy nuclear facilities. There are

also fleet-wide programs for Waste Management and Chemical Control. It is expected that

Entergy would continue to implement its waste minimization policy and programs during the

license renewal period for JAFNPP. The EPA's Office of Pollution Prevention and Toxics has

established a clearinghouse that provides information regarding management, technical, and

operational approaches to pollution prevention. The EPA's clearinghouse can provide

additional opportunities for waste minimization and pollution prevention at JAFNPP.

2.1.6 Facility Operation and Maintenance

Maintenance activities conducted at JAFNPP include inspection, testing, and surveillance to

maintain the current licensing basis of the facility and to ensure compliance with environmental

and safety requirements. Various programs and activities currently exist at JAFNPP to

maintain, inspect, test, and monitor the performance of facility equipment. These maintenance

activities include inspection requirements for reactor vessel materials, boiler and pressure

vessel in-service inspection and testing, maintenance structures monitoring program, and

maintenance of water chemistry.

Additional programs include those implemented to meet technical specification surveillance

requirements, those implemented in response to the U.S. Nuclear Regulatory Commission

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(NRC) generic communications, and various periodic maintenance, testing, and inspection

procedures. Certain program activities are performed during the operation of the unit, while

others are performed during scheduled refueling outages. Entergy refuels JAFNPP on a

nominal 24-month interval.

2.1.7 Power Transmission System

Two single-circuit, 345-kilovolt (kV) transmission lines, the Edic and Scriba lines, were

constructed to connect JAFNPP to the grid. Both of these lines are owned by NYPA. The Edic

line (Table 2-1) is approximately 70 mi long and was constructed to connect the JAFNPP to the

New York Power Pool transmission grid. This line runs southeasterly from the plant 345-kV

switchyard to the Edic Substation located near Utica, New York (Figure 2-4). NYPA has owned

and operated the transmission line since it was constructed in the early 1970s. A 400-ft wide

right-of-way (ROW) was acquired by NYPA for the Edic 345-kV transmission line although a

width of only 150 ft, totaling 1273 ac, was actually cleared for the line. The remaining ROW was

acquired for the possible construction of future transmission lines. The Edic transmission line

was constructed with steel self-supporting towers spaced about 1200 ft apart. When the ROW

was acquired, about 65 percent of the ROW passed through forests, 29 percent through

agricultural lands, and 6 percent through wetlands. Most of ROW land remains in private

ownership and is used for a variety of compatible purposes.

A second single circuit, 345-kV transmission line was also constructed to connect JAFNPP to

the grid. The Scriba line (Table 2-1) is approximately 4900 ft (0.9 mi) in length and runs

southward from the plant's 345-kV switchyard to the National Grid Scriba Substation where it

connects to the 345-kV transmission system.

The two 345-kV lines for JAFNPP have transmission capacity in excess of the JAFNPP

generating unit, so either line can be out of service without curtailing the output from the plant.

Both lines exceed the requirements of the National Electric Safety Code for heavy loading

districts, Grade B (Entergy 2006d).

In addition to the two 345-kV transmission lines for power distribution, offsite power is provided

to JAFNPP by two single-circuit 11 5-kV transmission lines connected to the plant's 115-kV bus.

One 115-kV line (Table 2-1) runs southward from the site and connects to the National Grid

115-kV transmission line that extends to the Lighthouse Hill Hydroelectric Station located about

26 mi east of JAFNPP. In addition to being a hydroelectric generating station and an integral

part of the National Grid 115-kV system, the Lighthouse Hill facility also serves as the

switchyard for several other hydroelectric facilities in the area. The other JAFNPP 115-kV line

I (Table 2-1) is approximately 3700 ft (0.7 mi) in length and is connected to the 115-kV bus at

Constellation Nuclear Nine Mile Point Nuclear Station. The 11 5-kV bus at Constellation Nuclear

Nine Mile Point Nuclear Station Unit 1 is also connected via a 11 5-kV transmission line to the

South Oswego Substation (Entergy 2006d).

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Table 2-1. JAFNPP Transmission Lines, Substations, and Corridors.

Within

Approximate Scope of

Number Distance License

Substation Owner of Lines kV in miles Renewal

Edic NYPA 1 345 70 Yes

Scriba NYPA 1 345 0.9 Yes

Lighthouse Hill National 1 115 26 No

Grid

Nine Mile Point Constellation 1 115 0.7 No

Nuclear Station

Source: Entergy 2006d

Figure 2-4. JAFNPP Transmission Lines

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Ownership of the four JAFNPP transmission lines is as follows: (1) Edic Substation 345-kV

transmission line: from 345-kV switchyard to approximately the site property line, JAFNPP owns

the line; from the JAFNPP property line to the Edic Substation, NYPA owns the line; (2) Scriba

Substation 345-kV transmission line: from 345-kV switchyard to approximately the site property

line, JAFNPP owns the line; from the JAFNPP property line to the Scriba Substation, NYPA

owns the line; (3) Lighthouse Hill Hydroelectric Station 115-kV transmission line: from 115-kV

Switchyard to approximately the site property line, JAFNPP owns the line; from the JAFNPP

property line to the Lighthouse Hill Hydroelectric Station, National Grid owns the line; and

(4) Constellation Nuclear Nine Mile Point Nuclear Station 115-kV transmission line: from 115-kV

switchyard to approximately the site property line, JAFNPP owns the line; from the JAFNPP

property line to the Constellation Nuclear Nine Mile Point Nuclear Station 115-kV bus,

Constellation Nuclear Nine Mile Point Nuclear Station owns the line.

For the two 345-kV transmission line ROWs, NYPA uses a vegetation management plan

approved by the New York State Public Service Commission. NYPA uses an integrated

vegetation management computer application, which employs geographic information system

technology. The vegetation management program is designed to control tall-growing tree

species and to enhance the abundance of lower-growing desirable vegetation. Field inventories

are conducted annually for the ROW scheduled for clearing the following year. Inventories and

treatment recommendations are reviewed and approved by the NYPA forestry staff. The

majority of clearing is performed using mechanical methods. Herbicide applications are applied

to selected plant species by licensed contractors, and a safe buffer is maintained around

wetlands, and stream and river crossings. A safe buffer is also used around wells and springs

that are used for residential water supplies. Areas where herbicides are used are posted with

information regarding the chemicals that were used and when they were applied. Herbicides

are not applied on NYPA ROWs using aerial application methods (Entergy 2006d).

2.2 Facility Interaction with the Environment

Sections 2.2.1 through 2.2.8 provide general descriptions of the environment near JAFNPP as

background information. They also provide detailed descriptions where needed to support the

analysis of potential environmental impacts of refurbishment and operation during the renewal

term, as discussed in Chapters 3 and 4. Section 2.2.9 describes the historic and archaeological

resources in the area, and Section 2.2.10 describes possible impacts associated with other

Federal project activities.

2.2.1 Land Use

JAFNPP is located in an unincorporated and primarily rural area approximately seven mi

northeast of Oswego, New York. Syracuse is the largest city within 50 mi of JAFNPP. Lake

Road (County Road 1A) provides road access to the site and transverses JAFNPP property in

an east-west direction just south of the plant. Exclusion distances for the JAFNPP site are

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approximately 3000 ft to the east, over 1 mi to the west, and about 1.5 mi to the southern site

boundary. The nearest location with public access to the reactor building and any points of

potential gaseous effluents, with the exception of the lake shoreline, are at the northeast corner

of the property. The nearest residence lies outside the site boundary to the east-southeast at

0.7 miles (Entergy 2006d). See Figure 2-2.

JAFNPP features include the reactor building, turbine building, administration building and

control room, ISFSI, and several support facilities. The most prominent feature on the site is the

off-gas stack, which is 385 ft high. Only 3 percent of the site is occupied by JAFNPP structures,

with the remainder consisting of forest shrub, grasslands, and wetlands or ponds (Entergy

2006d). See Figure 2-3.

The site lies mainly within the Erie-Ontario Lowlands physiographic province. This province

consists of a relatively flat plain that rises gently from Lake Ontario to the Appalachian Uplands,

which form the province's southern border. Erie-Ontario Lowlands are bounded on the east by

Tug Hill Upland, through which small portions of the transmission line pass. The site is a

generally flat and featureless plain. It has an elevation of 270 ft rising to 310 ft 1 mi away at the

southern extremity. The surface soils are derived from bouldery-ablation tills that immediately

overlay a compact basal till lying on bedrock (AEC 1973).

2.2.2 Water Use

Water use associated with the operation of JAFNPP consists of fresh water drawn from Lake

Ontario used primarily for cooling. Water from Lake Ontario is used for the cooling and auxiliary

systems. JAFNPP receives its potable water from the City of Oswego. JAFNPP is not a direct

user of groundwater, and there are no plans for direct groundwater use in the future. There are

no production wells onsite (Entergy 2006d).

2.2.3 Water Quality

JAFNPP is located on the southeastern shore of Lake Ontario, which is the furthest downstream

and smallest of all the Great Lakes, having a surface area of 7340 square miles. It is an

international body of water with the border of the United States and Canada being

approximately midway across the width of the lake. It has an average depth of 283 ft with a

maximum depth of 802 ft (EPA 2006d).

The combination of prevailing west-northwest winds over the lake area and the eastern flow of

water from Lake Erie results in the lake being dominated by a counterclockwise horizontal

circulation pattern. Although winds can play a major role in affecting localized lake water flow

patterns, currents on the southern shore of the lake often move in an easterly direction in a

relatively narrow band. Because Lake Ontario is the furthest downstream of all the Great

Lakes, its water quality is influenced not only by human activities on its own shores, but by

impacts on all the other Great Lakes as well. Approximately 80 percent of the influx of water to

Lake Ontario comes directly from Lake Erie via the Niagara River. The remaining 20 percent of

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the influx comes from basin tributaries, groundwater and precipitation. Approximately

93 percent of Lake Ontario's water flows out through the St. Lawrence River with the remaining

7 percent being lost to evaporative processes. The estimated water retention time is 6 years

(EPA 2006d).

Changes in wind speed and direction on Lake Ontario can also contribute to vertical mixing of

lake water. Strong winds can cause upwelling and sudden oscillations of thermocline depth.

Strong easterly winds along the east-west axis of Lake Ontario will cause a surface drift to the

right, which can result in tilting of the thermocline. When the tilted thermocline is pushed along

the nearshore zone it can become so intense that an outbreak of cold hypolimnion water will

upwell to the surface in the nearshore environment and create a steep temperature gradient in

the lake center. An increase in longshore current velocity can be associated with these events

as well, increasing the dispersion of both pollutants and nutrients from the lake bottom along the

shore (EC 2000).

Both meteorological and hydrological processes are responsible for a seasonal thermal

response on the lake. Incoming solar radiation heats the surface waters of the lake, more so in

the summer, while changes in wind speed and direction aid in the mixing of these heated waters

to lower depths in the lake. The mean summer ambient temperature of Lake Ontario in the Nine

Mile Point area is approximately 670 Fahrenheit (F). Most of the lake is vertically stratified

during the summer (June through September) with warm surface waters (epilimnion) averaging

nearly 70°F and cool deeper waters (hypolimnion) ranging between 38.8 and 39.20 F. Mixing of

these strata begins as the thermocline breaks down during September as a result of surface

water cooling and continues until water temperatures are the same throughout the water column

(EC 2000). The date of this overturn varies annually due to short term weather patterns and

storms. The isotherms following the overturn tend to be parallel to the shore resulting in a

freezing of nearshore waters with the deeper offshore waters remaining open.

Lake Ontario outflows, and thus lake water levels, are controlled by a series of dams on the

St. Lawrence River under the authority of the International St. Lawrence River Board of Control

(ISLRBC). The ISLRBC requires that Lake Ontario water levels be maintained within a target

range of 243 to 247 ft International Great Lakes Datum to support lake navigation and to provide

water for power production facilities on the lake. The target level of 243 ft is maintained from

April through November when lake water evaporation rates would be highest and the

St. Lawrence River is likely close to low-flow conditions (ISLRBC 2004).

Once an oligotrophic system, by 1970 Lake Ontario was almost entirely eutrophic, caused by

high levels of anthropogenic nutrients (primarily phosphorous) and uncontrolled pollutant

discharge to the lake. The eutrophication of Lake Ontario was recognized as a serious water

quality problem by the U.S. and Canada and led to the creation of the bi-national Great Lakes

Water Quality Agreement (GLWQA) in 1972. Since then the lake has seen dramatic

improvement in water quality. Much of this improvement can be attributed to stricter controls on

land use in the Lake Ontario basin and lake-wide management plans sponsored by the GLWQA

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that reduced levels of non-point source pollution entering the lake. However, changes in lake

water quality since the 1970s have altered the biological landscape within Lake Ontario.

Nutrient supplies and other environmental pressures have had direct effects on all trophic levels

within the lake ecosystem (Stewart et al. 1999).

The New York State Department of Environmental Conservation (NYSDEC) conducted a study

of water quality throughout New York State over the past 30 years, including selected basic

water quality parameters of Lake Ontario; this information is summarized in Table 2-2. Data

was collected in the Nine Mile Point area in 1972 and 1978, the City of Oswego water intake

(approximately 8 mi southwest of JAFNPP) in 1998 and 1999, and at the Monroe County water

intake (approximately 50 mi west of JAFNPP) in 2000 (NYSDEC 2000b).

Table 2-2. Selected Water Quality Parameters of Lake Ontario

Year

Parameter 1972(a) 1 9 7 8 (b) 1998-99(c) 2000(e)

pH 8.0 8.4 7.96 7.6

Total alkalinity (mg/L) 72-90 94.2 92 83

Total phosphorus (mg/L) 0.01-0.28 0.027 0 .0 0 6 (d) 0.005(d)

Total dissolved solids (mg/L) 107-186 202 NA 160

Total nitrates (mg/L) 0.04-0.40 < 0.18 NA 0.34

Turbidity 2-6 JTU 3.0 NTU 0.5 NTU 0.09 NTU

mg/L = milligram(s) per liter

JTU = Jackson Turbidity Unit(s)

NTU = Nephelometric Turbidity Unit(s)

(a) Source: AEC 1974

(b) Source: NMPC 1985

(c) Source (except total phosphorus): NRC 2006

(d) Source: EPA 2005

(e) Source (except total phosphorus): NRC 2006; pH and

alkalinity data are from water distribution system and not from

ambient lake water

Today, the largest source of pollutants and nutrients (including phosphorous and nitrogen)

entering Lake Ontario is through the Niagara River, which drains Lake Erie. As in the past,

additional nutrients also still enter the lake through runoff from agricultural lands, urban areas,

sewage outflows, and erosional processes. The NYSDEC water quality study indicated that

although over the past 30 years there have been general reductions in some pollutants, such as

phosphorous and dissolved solids, nitrogen inputs to Lake Ontario have increased. Runoff from

agricultural lands and atmospheric deposition are likely significant contributors to lake nitrogen

levels.

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In another bi-national effort, in 1989 the U.S. and Canada developed the Lake Ontario Toxics

Management Plan. The plan addressed persistent bioaccumulative and toxic chemicals (PBTs),

which include mirex, polychlorinated biphenyls (PCBs) and dioxins (NYSDEC 2000b). PBTs

enter Lake Ontario through various tributaries and have historically accumulated in sediments at

the bottom of the lake. Several portions of Lake Ontario's New York shoreline are classified by

the NYSDEC as "impaired," requiring total maximum daily load (TMDL) development in order to

reduce the input of the specific pollutants (Entergy 2006h). Some Lake Ontario biota saw

reductions in toxic chemical concentrations from the 1960s through the 1980s that were

generally attributed to restrictions placed on the manufacture and use of PBTs, but those

declines have since leveled off. This may be due in part to the sequestration of chemicals in the

benthic lake sediments. Consumption advisories for certain lake fish species continue to be

issued by NYSDEC based on PBT levels found in some fish samples (NYSDEC 2000b).

If needed, JAFNPP is approved to use a Betz Clam-Trol CT-1 (a chlorine-based molluscicide)

program within their service and cooling water systems to control zebra mussels (Dreissena

polymorpha) and quagga mussels (D. bugensis). The site-specific SPDES permit limits the

administration of the molluscicide program to a maximum of four times per year and includes

special conditions for outfall monitoring during applications and strict discharge limitations

(Entergy 2006c); however, Betz Clam-Trol CT-1 has not been used at JAFNPP in more than ten

years. Biofouling control at JAFNPP is achieved through the application of sodium hypochlorite

in the service water system and the condenser waterboxes. Sodium hypochlorite injection

occurs continuously, but at a concentration and volume that does not result in the exceedance

of the SPDES limit of 0.2 parts per million (ppm) total residual chlorine (TRC), as measured in

the discharge canal. Waterbox chlorination is limited to two hours per day, not to exceed a total

of nine hours per week, and during daytime hours only when ichthyoplankton entrainment levels

are historically low. The JAFNPP SPDES permit also prescribes a waterbox chlorination

limitation of 0.2 ppm TRC (Entergy 2006d).

Treated effluent from the sanitary waste water treatment system is regulated as Outfall 012

before discharging into a drainage ditch that flows into Lake Ontario. The effluent is monitored

for flow, biochemical oxygen demand, suspended solids, settable solids, fecal coliform, pH, and

total residual chlorine. Maximum permitted flow is 60,000 gpd as a 30-day average. During

2006, daily flow ranged from 400 to 25,000 gpd (Entergy 2006g).

JAFNPP operates in accordance with applicable local, State, and Federal discharge limitations.

The NRC staff review of the past five years of JAFNPP SPDES reports found no notices of

violation (Entergy 2006d).

Groundwater is available in the Nine Mile Point area from both confined and unconfined

aquifers. There are four hydrostratigraphic units in existence within the JAFNPP site area: nonlithified sediments and soils, the Oswego Sandstone, the Pulaski Formation and the Whetstone

Gulf Formation, in descending order. The unconfined aquifer is composed of clay-rich soils

derived from glacial till and the uppermost portion of the Oswego Sandstone. Due to the

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increase of interbedded silts and clays within the Oswego Sandstone at depth, the sandstone

becomes relatively impermeable at 20 ft. The first confined aquifer lies in both the lower portion

of the Oswego sandstone and uppermost portion of the Pulaski Formation, which is composed

of sandstone, siltstone and shale. An additional confined aquifer lies within the Pulaski

Formation at depth within a sandstone unit bounded by siltstone and shale. The underlying

Whetstone Gulf Formation has a low permeability as it is dominated by black shales with

interbedded sandstone and siltstones. All three aquifers are confined under pressure and would

result in artesian wells if utilized at the surface.

Within a two mile radius of JAFNPP, the local water table elevation varies from 300 to 246 ft

National Geodetic Vertical Datum with an average gradient of 0.7 percent to the north-northwest

(toward Lake Ontario). The normal groundwater level within the site boundary is approximately

255 ft and can have annual variations of up to 2 ft.

Groundwater recharge in this area occurs as a result of precipitation and localized seepage

from ponds and swamps through the surface soils into the unconfined aquifer. Due to the low

permeability of the clay-rich soils in the immediate vicinity of the site, most of the precipitation

runs off toward surface culverts or directly toward Lake Ontario. Groundwater recharge to the

Oswego Sandstone most commonly occurs through filtration of water through the unsaturated

zone of the unconfined aquifer and can also occur directly through local outcrops located to the

south and southeast of JAFNPP. Recharge to the lower confined aquifers occurs through

fractures in the Oswego Sandstone or directly through surface outcrops upgradient of the site.

Due to a permeability of 1 x 10s cm/s and an average gradient of 0.7 percent, groundwater

velocity within the unconfined aquifer is estimated at a few yards per year.

2.2.4 Climate, Meteorology, and Air Quality

2.2.4.1 Climate

The climate of western New York State is representative of the humid continental type, warm

summer subtype. The climate is designated Dfb in the Koeppen system and is sometimes

referred to as hemiboreal. Typical of the Dfb climate zone, weather changes between summer

and winter are very large around the JAFNPP site with cold, snowy winters and long, warm (not

hot) summers. Latitude, topography, and proximity to large bodies of water such as Lake

Ontario have a profound effect on the climate and short-term weather.

JAFNPP's proximity to Lake Ontario makes it subject to locally extreme amounts of precipitation

in the winter. This phenomenon, called "lake effect snow," is produced when cold arctic air

crosses the warmer lake, absorbing water vapor, which then falls as precipitation on the

adjacent shore, The elevated areas south and east of JAFNPP frequently set daily records for

snowfall in the Untied States because the lake effect snow is enhanced by orographic uplift.

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The following climatological data is based on 30 years of observations (from 1971 to 2000) from

the nearest National Oceanic and Atmospheric Administration (NOAA) station in Oswego, New

York (NOAA 2004a). Average minimum temperature in January was 16.7°F, and average

maximum temperature in July was 80.0°F. Month-long average temperatures ranged from

23.6°F in January to 70.8 0 F in July. Average monthly precipitation ranged from 2.83 in. in

February to 4.47 in. in November. Average annual precipitation was 42.9 in. Precipitation

occurred almost uniformly throughout the year, caused by advancing polar fronts in the winter

and advection of tropical moisture in the summer.

2.2.4.2 Meteorology

Meteorological measurements for JAFNPP are collected nearby at the Nine Mile Point Nuclear

Station through an agreement between the two managing companies (Entergy and

Constellation Nuclear, respectively). Measurements are made from a 200-ft main tower and

also at a nearby shorter tower (approximately 100 ft). At the main tower, winds and temperature

are measured at three levels-at 30, 100, and 200 ft. The Nine Mile Point meteorological

system determines atmospheric stability by using the EPA-approved Delta-T method. More

information on the main tower and the data collected there is in the Nine Mile Point

Environmental Impact Statement (NRC 2006, Section 2.2.4).

Severe thunderstorms with winds exceeding 58 mph and/or property damage occur an average

of five days per year in Oswego County (2001 through 2006) (NOAA 2004b). Since 1950, eight

tornadoes have been reported in Oswego County (NOAA 2004b). The strongest tornado

reached F3(1) strength near the town of Phoenix on May 2, 1983, and resulted in no injuries.

The other seven tornadoes were categorized as F1 or lower. One of these struck a mobile

home, resulting in minor injuries to three people. The probability of a tornado striking JAFNPP

is estimated to be 3 x 10-3 in a reactor's licensing period of 40 years (Entergy 2001).

Wind resources are expressed in terms of wind power classes ranging from Class 1 to Class 7.

Each class represents a range of mean wind power density or approximate mean wind speed at

specified heights above the ground. The wind energy resource for most of the Lake Ontario

shoreline of Oswego County is rated between Class 3 and 4 (Renewable Resource Data Center

2004, Figure 3-25). Areas designated as Class 3 or greater are suitable for most wind energy

applications.

2.2.4.3 Air Quality

JAFNPP is located in Oswego County which is part of the Central Air Quality Control Region 7

of the New York State Department of Environmental Conservation. With the exception of

(1) The Fujita six-point scale (FO to F5) is used to rate the intensity of a tornado based on the damage it

inflicts to structures and vegetation. Lowest intensity is FO; highest is F5.

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ozone, Region 7 is designated as being in attainment of or as unclassifiable for all criteria

pollutants, as defined in 40 CFR 81.333. Jefferson County, northeast of Oswego County, is

designated as a nonattainment area for ozone and classified as moderate for the 8-hour ozone

National Ambient Air Quality Standards and marginal for the 1-hour. The Clean Air Act

established Class 1 Federal Areas where visibility is important. No areas designated as

Prevention of Significant Deterioration Class I are within 62 mi of JAFNPP.

There are four emergency diesel generators, two diesel fire pumps, and two auxiliary boilers on

the JAFNPP site. The emissions from the emergency diesel generators, fire pumps, and boilers

are regulated under a Certificate to operate an Air Contamination Source (7-3556-00020/00012)

issued by NYSDEC. This certificate limits fuel usage, fuel type, and hours of operation for these

emission sources.

2.2.5 Aquatic Resources

Lake Ontario is the source of water for the circulating and service water systems at JAFNPP.

Station discharge from both the main condenser and service water system is returned to the

lake. Site drainage includes two offsite ditches on either side of the plant and two onsite storm

sewer outfalls; all ditches and outfalls discharge to Lake Ontario and are regulated under the

plant's SPDES permit (Entergy 2006d). There are no natural watercourses onsite. Associated

transmission corridors cross 60 watercourses of which seven are classified by the New York

State Water Resources Commission as suitable for water supplies and 27 for agriculture and

industry (AEC 1973).

Lake Ontario, the source and the receiving water body for JAFNPP, is last in the chain of Great

Lakes. It is the smallest of the five Great Lakes and with a watershed of 24,720 mi2, Lake

Ontario has the highest ratio of watershed land area to lake surface area of all the Great Lakes

(EPA 2006a). The lake's drainage basin is almost evenly split between the province of Ontario

and the state of New York. Approximately 7 percent of the drainage basin is urbanized: major

industrial centers on the lake shore include Hamilton and Toronto in Ontario and Rochester in

New York. Although not categorized as urban, the Syracuse-Oswego area in New York is

relatively densely populated. Forests cover about 49 percent of the basin, with agriculture

practiced over approximately 39 percent. In general, the New York shoreline is less urbanized

than the Canadian shoreline and is not intensively farmed (Stewart et al. 1999).

Shipping is a major activity on Lake Ontario and has encouraged the development of

manufacturing industry and port cities. The Port of Oswego, approximately 6 mi west of

JAFNPP, had an overall annual tonnage of 457,770 in 2002. The port has a main channel

depth of 27 ft, and its primary cargoes include aluminum, potash, urea, limestone, salt, cement,

and petroleum products (GLSLSS 2006). Lake Ontario also supports a minor commercial

fishing industry, grossing just $46,000 in 2004. Recreational fishing is much more important to

the Lake Ontario area, with the total economic value to coastal communities estimated to range

from $100 million to more than $200 million per year (EPA 2006c).

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Lake Ontario has two major basins: Kingston Basin, which is shallow and in the northeastern

corner of the lake, and a deeper main basin that covers the majority of the lake. The bottom of

Lake Ontario is relatively smooth with the exception of the sill that separates the Kingston and

main basins. The main basin is further split into three sub-basins: Rochester, Mississauga, and

Niagara (from east to west). With the majority of the lake's water coming in from the Niagara

River and the prevailing west-southwest winds, circulation in Lake. Ontario flows in an easterly

direction along the southern and eastern shores and within sub-basins of the lake (EPA 2006b).

Being a relatively deep lake, Lake Ontario experiences seasonally dependent horizontal and

vertical thermal stratification. Stratification occurs when different water temperatures create

different water densities, which prevents mixing. Horizontal stratification occurs in the main

basin between near-shore and offshore zones and lasts from mid-autumn until approximately

mid-June when offshore waters finally warm and mixing can occur. For the remainder of the

summer, main basin waters are vertically stratified, meaning that warm surface waters do not

mix with cool, deeper waters. The vertical stratification begins to break down during September

when surface waters begin to cool and slowly sink and mix with deeper waters. Mixing

continues until an isothermal condition prevails throughout the winter (EPA 2006b). During the

winter months, inshore areas of Lake Ontario freeze, but of all the Great Lakes, Lake Ontario

has the least amount of ice cover, with typically 85 percent of the lake ice-free throughout the

winter. In general, waters are warmer in the southeastern portion of the lake and cooler in the

northwestern portion. Lake water temperatures typically range from 32 to 39.2°F in January and

from 53.6 to 680F in July (PC 2006).

Lake Ontario is oligotrophic with low primary productivity-roughly half that of Lake Erie. Lake

water clarity ranges from 16.4 to 32.8 ft. Over the years, the trophic status of Lake Ontario has

continually been influenced by human activities, including point-source pollution from industry

and waste disposal and non-point source pollution from agriculture and urban development.

The lake is affected not only by its drainage basin but also by being the most downstream Great

Lake. Thus, pollution sources in the upper Great Lakes impact Lake Ontario as well (EPA

2006b).

Since the first Euro-Americans arrived in the Great Lakes area, Lake Ontario has experienced

ecological stress that included overfishing, anthropogenic eutrophication, land-use changes,

contaminant discharge, loss and degradation of critical habitat, colonization of invasive species,

and substantial declines and profound changes in fish communities (NYSDEC 2004).

Lake Ontario was an oligotrophic system prior to European colonization of the Great Lakes

area. However, with increasing industrial development on the northern shore of the lake and

the subsequent increase in nutrient inputs (anthropogenic sources of phosphorous and

nitrogen), the lake experienced excess algal growth and became mesotrophic with inshore

areas becoming eutrophic. Phosphorous levels peaked in the 1960s and 1970s until water

pollution controls were implemented throughout the Great Lakes. Since then, nutrient levels in

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the lake have declined, and the lake has returned to a more balanced oligotrophic state (Mills et

al. 2005; EPA 2006b).

Although water quality has improved over the last 20 years in response to lake-wide

management plans, the Lake Ontario ecosystem is still very much in transition. NYSDEC and

the Ontario Ministry of Natural Resources (OMNR) annually stock the lake with salmonids to

support a lucrative sport fishery. Non-native fish populations such as the alewife (Alosa .

pseudoharengus) are highly dynamic with large fluctuations in population from year to year, and

pelagic zooplankton production is continually declining. Oligotrophic fish populations are slowly

recovering, and invasive species such as quagga mussels (Dreissena bugensis) and the

cladoceran waterflea (Cercopagis pengol) are thriving (NYSDEC 2004; OMNR 2006).

There have been a series of milestones in the management of Lake Ontario. In 1955, the

Canadian/U.S Convention on Great Lakes Fisheries created the Great Lakes Fishery

Commission (GLFC). The GLFC is a bi-national cooperative agency that coordinates fisheries

research and facilitates cooperative fishery management among the state, provincial, tribal, and

federal agencies. The GLFC is responsible for implementing the Joint Strategic Plan for

Management of Great Lakes Fisheries (GLFC 1997). Eight states bordering the Great Lakes,

the Province of Ontario, two intertribal agencies, and several federal agencies are signatory to

this management plan, working together and leveraging each others' resources to rehabilitate

native lake species, control exotic species, prevent and manage fishery diseases, coordinate

law enforcement, produce new research, publish state-of-the-lake reports, and determine total

allowable catch and allocation agreements and fish stocking levels (GLFC 2006).

The GLFC also funded the 1971 Salmonid Communities in Oligotrophic Lakes symposium,

which examined the effects of cultural eutrophication, exploitation, and exotic species

introduction on salmonid communities in the five Great Lakes. In 2004, these issues were

revisited in a second symposium with an emphasis on linkages between trophic levels (GLFC

2007).

In 1972, the first Great Lakes Water Quality Agreement (GLWQA) was signed between the

International Joint Commission (IJC) of Canada and the United States. Both countries pledged

to address the deterioration of Great Lakes water quality from point source and non-point

source pollution. A new GLWQA was signed in 1978 that outlined a commitment to restoring

and maintaining the "chemical, physical, and biological integrity" of the Great Lakes. In 1987,

the IJC drafted a protocol that focused on the overall human and aquatic ecosystem health of

the Great Lakes. Remedial action plans and lake-wide management plans were developed that

implemented an ecosystem approach to improving the Great Lakes waters. The plans are

designed to work in concert with local resource management plans, such as those that address

a specific fishery (IJC 2004).

Close to JAFNPP, the Little Salmon and Oswego rivers are two of the ten major tributaries that

feed Lake Ontario. Both rivers have been designated by the NYSDOS Division of Coastal

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Resources as "Significant Coastal Fish and Wildlife Habitats." Little Salmon River empties into

Lake Ontario at Mexico Point near the town of Mexico, approximately 10 mi east of JAFNPP.

The river provides an important fish spawning and nursery area and supports large

concentrations of warmwater species including northern pike (Esox lucius), largemouth bass

(Micropterus salmoides), rock bass (Ambloplites rupestris), white sucker (Catostomus

commersoni), and brown bullhead (Ameiurus nebulosus). Little Salmon River is one of the

primary salmonid habitats in eastern Lake Ontario. As a result of NYSDEC's ongoing sport

fishery stocking program, Chinook salmon (Oncorhynchus tshawytscha), coho salmon

(Onchorhynchus kisutch), brown trout (Salmo trutta), and steelhead trout (Oncorhynchus

mykiss) can also be found in Little Salmon River during spawning periods (NYSDOS 2006).

The Oswego River is located in the city of Oswego, approximately 6 mi west of JAFNPP. Land

along this river has been impacted by extensive human disturbance, including a number of locks

and dams that impede or act as barriers to fish migrating upriver to spawn. However, the river

is still an important habitat for warmwater fish species including alewife, gizzard shad (Dorsoma

cepedianum), brown bullhead, white perch (Morone americana), yellow perch (Perca

flavescens), smallmouth bass (Micropterus dolomieu), largemouth bass, walleye (Sander

vitreus), pumpkinseed (Lepomis gibbosus), and black crappie (Pomoxis nigromaculatus). The

river is the primary spawning and nursery area for walleye in the Oswego County area, and in

1982, lake sturgeon (Acipenser fulvescens) were also spotted in the river, making it the only

Lake Ontario tributary that historically supported this species. Stocked salmonids also attempt

to use this river for spawning (NYSDOS 2006).

Lake Ontario offshore waters have been dominated historically by lake trout (Salvelinus

namaycush), Atlantic salmon (Salmo salar), deepwater sculpin (Myoxocephalus thompsoni),

coregonids (Coregonus spp.), and burbot (Lota Iota). By the 1970s, Lake Ontario's major native

fish stocks were near extinction as a result of cumulative ecological stressors including

overfishing, anthropogenic eutrophication, industrial pollution, degradation and loss of habitat,

and colonization of invasive species.

The external parasite, sea lamprey (Petromyzon marinus), was also seriously impacting fish

populations. Populations of the sea lamprey, an invasive species, sharply increased in the early

1900s, coincident with high numbers of lake trout. It is believed that commercial fishing and sea

lampreys acted together to drive large piscivores in Lake Ontario to near extinction (Mills et al.

2005). Atlantic salmon, deepwater sculpin, lake trout, burbot, and coregonids all but

disappeared, while non-native fish such as alewife, rainbow smelt (Osmerus mordax), and white

perch proliferated. Alewife, a planktivore fish that is prey for large piscivores, first appeared in

Lake Ontario by the late 1800s, and in the absence of abundant piscivores, the alewife

population exploded. Rainbow smelt experienced significant increases around the same time

and were implicated in the decline of native cisco (Coregonus artedit) populations (Jackson

1997).

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In 1968, the first year of what were to become annual releases, brown trout, Chinook salmon,

coho salmon, and steelhead trout were stocked to reduce alewife populations and create a sport

fishery. Between 1968 and the late 1980s, salmonid stocking rates rose steadily to more than

8 million individuals per year. Concurrently, water conditions were improving and Lake Ontario

returned to an oligotrophic system, but by 1990, the high rates of salmonid stocking and the low

lake nutrient levels were affecting the Lake Ontario food web-including decreases in the size of

salmon returning to spawn and reduced angler harvest rates, likely due to a reduction in prey.

Current combined NYSDEC and OMNR salmonid stocking rates have been maintained

between 4.0 and 5.5 million individuals per year. Improvements in habitat and water quality

have resulted in the decline of Lake Ontario's carrying capacity at all levels. Food web studies

of the lower trophic levels conducted in the 1980s and 1990s indicated declines in algal

abundance (phytoplankton) and zooplankton biomass and production. Because phytoplankton

and zooplankton rely on the very nutrients that impact water quality, the effect of nutrient

reductions extends into the food web (Jackson 1997; Mills et al. 2003).

Currently, growth of stocked salmonids is sustained primarily by alewife populations and to a

lesser degree by rainbow smelt and slimy sculpin (Cottus cognatus). Salmonid predation has

been so excessive that the present alewife population has been reduced almost entirely to prereproductive individuals: from the early 1980s to the 1990s, the alewife population declined

42 percent (Jackson 1997). Alewives are the primary planktivores in Lake Ontario, and

historically, intense feeding pressure on large plankton species by the alewife population has

selected for smaller species. The precipitous alewife population decline has subsequently

changed the Lake Ontario plankton community-there has been a shift from smaller to larger

zooplankton species. Zooplankton have an intermediate position in the Lake Ontario food web

and are an important link between phytoplankton and fish. Larger zooplanktons also feed on

smaller zooplankton species, and the presence of large zooplankton therefore competes with

other invertebrates and fish for smaller zooplankton prey (NYSDEC 2004).

The lower food web declines in Lake Ontario were likely exacerbated by the new presence of

exotic (invasive) species. By the 1990s, exotic species, including the zebra mussel; the quagga

mussel; the amphipod Echinogammarus ischmus, a non-native cladoceran; the round goby

(Neogobius melanostomus); and the bloody red shrimp (Hemimysis anomala) had been

introduced to the Great Lakes via transoceanic shipping. Through their efficient phytoplankton

grazing and ability to cover any available substrate quickly and entirely, zebra and quagga

mussels significantly increased water clarity throughout the 1990s, causing profound impacts

throughout the food web. Historically, the native amphipod Diporeia spp. accounted for 60 to

80 percent of Lake Ontario's benthic community. However, the spread of dreissenid mussels

altered Lake Ontario's benthic habitat. Diporeia spp. declined after dreissenid introduction,

impacting bottom fish species including native lake whitefish (Coregonus clupeaformis) (Mills et

al. 2003). More recent benthic studies indicate that quagga mussels have largely replaced

zebra mussels in all benthic habitats of Lake Ontario; this transition may have occurred due to

round goby predation on zebra mussels. Since first appearing in Lake Ontario in 1998, the

round goby, an aggressive, bottom-dwelling fish, has established itself in Lake Ontario and is

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expected to trigger further changes in the benthic community. Additionally, where round gobies

have become abundant, numbers of native bottom-dwelling fish have declined, such as

tessellated darters (Etheostoma olmstedi) and sculpins (Cottidae spp.) (Stewart et al. 1999).

Despite other improvements in the Lake Ontario ecosystem, the unintentional introduction of

non-native species to the benthic, planktonic and fish communities will likely prevent Lake

Ontario from ever returning to its original state.

The reduction in available nutrients combined with the increased penetration of light and

extended, seasonal, warm water periods, has also resulted in the return and increased growth

of submerged aquatic vegetation, primarily filamentous Cladophora spp (NRC 2006). The

proliferation of Cladophora resulted in two unplanned shutdowns at JAFNPP in September and

October 2007. Storm events caused an influx of the green filamentous algae to accumulate on

the intake traveling screens, eventually failing the shear pins and stopping the screens. Lake

Ontario will likely continue to experience ecological and meteorological conditions favorable for

Cladophora growth, thus making this an ongoing issue for JAFNPP operation (NRC 2007a,

2007b), The increased algal vegetation coverage provides protection and nursery areas for a

number of invertebrate and fish species (NRC 2006); however, the increasing clarity of Lake

Ontario water may cause a shift of some light-sensitive fish species, such as the walleye, to

relocate into deeper waters (Stewart et al. 1999).

There are no aquatic species Federally listed as threatened or endangered under the

Endangered Species Act (ESA) in the vicinity of JAFNPP (NYSDEC 2007). Through

consultation with the U.S. Fish and Wildlife Service (FWS), no aquatic species (fish, molluscs,

or aquatic plants) were identified as potentially occurring at the site or in watercourses along or

across the associated transmission corridors.

Five aquatic species that have been designated by New York State as threatened, endangered,

or a species of special concern and that may occur in the vicinity of JAFNPP are listed in

Table 2-3. There were no reported takings of these fish at JAFNPP in 2004 (EA 2005).

Table 2-3. Aquatic Species Listed as Endangered, Threatened, or a Species of Special

Concern by New York State, Potentially Occurring in Oswego and Onondaga Counties

Scientific Name Common Name Federal Status State Status

Acipenser fulvescens lake sturgeon - T

Erimyzon sucetta lake chubsucker - T

Lythrurus umbratilis redfin shiner - S

Myoxocephalus thompsoni deepwater sculpin - E

Prosopium cylindraceum round whitefish - E

- = No listing S = Species of Special Concern Source: NYSDEC 2007

E = Endangered T = Threatened

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State-threatened lake sturgeon (Acipenser fulvescens) are found primarily in freshwater lakes

and large rivers in northeastern North America. In New York, lake sturgeon have been found in

the St. Lawrence River, Lake Ontario, Lake Erie, the Niagara River, Lake Champlain, Cayuga

Lake, the Seneca Canals, and in the Grasse, Oswego, and Oswegatchie rivers. The Oswego

River is a historic spawning ground for lake sturgeon and is the only Lake Ontario tributary

where lake sturgeon have been found in recent years. One of New York's largest freshwater

fish, mature adults are between 3 and 5 ft long and weigh between 10 and 80 pounds (Ib). Lake

sturgeon subsist primarily on small organisms: leeches, snails, clams and other invertebrates,

small fish, and algae. They spawn from May to June in areas with clean, large rubble such as

along windswept rocky shores and in the rapids of streams. Young fish grow rapidly but have a

slow reproductive cycle: females do not reach sexual maturity until they are 14 to 23 years old,

and they spawn only every four to six years during their 80-year lifespan. Lake sturgeon were

historically abundant, but as their value increased, population levels decreased significantly due

to overfishing. Other threats to lake sturgeon include the construction of dams that cut off

upstream spawning grounds, channelization, and pollution (WSG 2006; NYSDEC 1999e).

Lake chubsuckers (Erimyzon sucetta), a State-threatened species, are medium-sized with an

average length of 8 to 10 in. They are found only in quiet, clear, well-vegetated waters because

they are intolerant of turbid or silty conditions. Lake chubsuckers feed along the water bottom

on copepods, cladocerans, and aquatic insect larvae. In New York, lake chubsuckers were

historically found in embayments along the south shore of Lake Ontario and the eastern shore

of Lake Erie. No lake chubsuckers have been caught in New York for more than 60 years.

Siltation, wetland drainage, increased water turbidity, and pollution have likely caused the

decline or extirpation of this species (ROM 2006; NYSDEC 1999b;).

The redfin shiner (Lythrurus umbratilis), a State species of special concern, occurs in the Great

Lakes and Mississippi River Basin, western New York to Minnesota, south to Louisiana, and

Gulf drainages west to Texas. The redfin shiner is essentially a pool dweller but can also be

found in moderate- to low-gradient streams with some vegetation and sand or gravel bottoms.

Within New York, the redfin shiner has been found only at a few sites in Tonawando Creek, the

Niagara River, and Johnson Creek. Redfin shiners are found in schools feeding on filamentous

algae, bits of higher plants, and aquatic and terrestrial insects. They become sexually mature in

their second or third summer and spawn from early June to mid-August in nests within sunfish

nesting territories. One reason for their low occurrence may be that they require clear water

during spawning, but the rest of the year they can tolerate siltation (NYSDEC 1999d; WSG

2006).

The State-endangered deepwater sculpin (Myoxocehalus thompson) is the largest of New

York's freshwater sculpins; they can be up to 9 in. long but average length is 2 to 5 in.

Deepwater sculpin are found in deep, cool lake waters at depths ranging from 240 to 300 ft.

Found in all the Great Lakes except for Erie, the deepwater sculpin was once prolific in Lake

Ontario. Competition with alewife and rainbow smelt, as well as alewife and rainbow smelt

predation on sculpin eggs and larvae, may have caused a decline in the deepwater sculpin

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population-the species was thought to be extirpated until catches were reported from 1996 to

1999. The deepwater sculpin is a bottom feeder, so continual exposure to contaminated

sediments may be another possible cause for their decline. NYSDEC identified the non-native

round goby as another potential source of competition for this species (NYSDEC 1999a; OME

1999).

The State-endangered round whitefish (Psosopium cyclindraceum) has an average length of

8 to 12 in., occasionally reaching 22 in. This species feeds primarily at or near the bottom on

small aquatic organisms, including eggs of lake trout and other fish. Round whitefish were

historically found in all the Great Lakes except Lake Erie; only seven New York State waters are

known to contain round whitefish populations. Lake Ontario once supported a small round

whitefish commercial fishery, but the last commercial catch was in 1942. Round whitefish are

now protected from harvest or possession by the State of New York Endangered Species Law.

Reasons for the species' decline may include predation by yellow perch on round whitefish eggs

and fry, loss or degradation of spawning sites, siltation, and lake acidification (WSG 2006;

NYSDEC 1999c).

2.2.6 Terrestrial Resources

2.2.6.1 Terrestrial Resources at the JAFNPP Site

JAFNPP is on a flat plain 20 ft above the shore of Lake Ontario, with hills to the immediate

south of the property (USGS 1982). As part of the Erie and Ontario Lake Plain ecoregion, this

area was shaped by glacial erosion and deposition processes (NYSDEC 2006d). After the last

glacial period, which ended between 19,000 and 11,000 years ago, the region was colonized by

vegetation that probably consisted of upland forest and wetland communities (NRC 2006; PRI

2006).

Typical-natural communities in this area vary, depending on the underlying geology and soils,

but include beech-maple, maple-basswood, and hemlock-northern hardwood forests;

grasslands; shrub lands; and wetland communities (SUNY Oswego 2006a). When the property

was purchased by Entergy, it was partially forested and being used for recreation and

residential purposes (Entergy 2006d). The area was once used as an artillery range (AEC

1973). Currently, the area immediately around the plant is maintained in a landscaped

condition. The majority of the property (600 ac) is not landscaped and is expected to develop to

climax communities unless further disturbed.

Dominant communities on the site include 66 percent forest, 21 percent open grasslands, and

10 percent wetlands and ponds (Entergy 2006d). These areas are in various states of

succession, ranging from early grassland/meadow communities in recently disturbed areas to

I secondary growth hardwood forests (Entergy 2006d). Common tree species include sugar

maple (Acer saccharum), American beech (Fagus grandifolia), Canadian hemlock (Tsuga

canadensis), white ash (Fraxinus amerincana), basswood/American linden (Tilia americana),

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black birch/sweet birch (Betula lenta), yellow poplar/tulip poplar (Liriodendron tulipifera), and

oaks (Quercus spp.), including chestnut (Q. prinus), red (Q. rubra), black (Q. velutina), white

(Q. alba), and bur oaks (Q. macrocarpa) (AEC 1973). Surveys for rare plants have not been

performed at the site.

The FWS National Wetlands Inventory database indicates that there are wetland areas on site

(FWS 2006c). While no formal wetland delineation activities have been performed, Entergy

estimates that there are approximately 70 ac of wetlands and ponds on the property (Entergy

2006d). Swamps and arborvitae and cattail marshes are scattered throughout the area near the

site (AEC 1973).

A variety of mammals, birds, reptiles, amphibians, and insects are commonly seen at the

JAFNPP site and in the surrounding area. Reptiles including snakes, turtles, and tortoises may

be found in the area, as well as amphibians including frogs, toads, salamanders, and newts

(SUNY Oswego 2006c).

Migratory waterfowl frequent the site and congregate near the discharge area offshore. These

include greater scaup (Aythya marila), golden eye (Bucephala clangula), merganser (Mergus

merganser), canvasback (A. valisineria), and oldsquaw (Clangula hyemalis) (Entergy 2006d).

The discharge area has been designated by the New York State Natural Heritage Program as

part of a waterfowl winter concentration area. Although Nine Mile Point Nuclear Station

(NMPNS), which is located just west of JAFNPP, had an incident in 2000 in which diving ducks

were impinged in the screenwell building, this was an isolated event, and thought to be the

result of both the presence of zebra mussels (Dreissena polymorpha) located on or near the

intake structures and plant reverse flow conditions (NRC 2006). JAFNPP has not observed

diving ducks near any intake structures which is likely due to the absence of their preferred food

source, zebra mussels, at JAFNPP.

Other birds that may breed in the area include the red-shouldered hawk (Buteo lineatus), sharpshinned hawk (Accipiter striatus), Cooper's hawk (A. cooperi,), common nighthawk (Chordeiles

minor), red-headed woodpecker (Melanerpes erthrocephalus), horned lark (Eremophila

alpestris), golden-winged warbler ( Vermivora chrysoptera), cerulean warbler (Dendroica

cerulean), vesper sparrow (Pooecetes gramineus), and grasshopper sparrow (Ammodramus

savannarum) (NRC 2006).

Common small mammal species in the area include the white-footed mouse (Peromyscus

leucopus), deer mouse (P. maniculatus), woodchuck (Marmota monax), meadow jumping

mouse (Zapus hudsonius), meadow vole (Microtus pennsylvanicus), red squirrel (Tamiasciurus

hudsonicus), raccoon (Procyon lotor), and cottontail rabbit (Sylvilagus floridanus) (NMPC 1985).

Larger mammals include red and gray foxes (Vulpes vulpes, Urocyon cinereoargenteus),

coyotes (Canis latrans), and white-tailed deer (Odocoileus virginianus) (SUNY Oswego 2006b).

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No wildlife management plans currently exist for the JAFNPP property. The site likely provides

productive habitat for wildlife, and hunting is not allowed on the property. Some animal mortality

may occur from vehicle collisions. Migratory bird collisions with buildings have been rare and

are not anticipated to be a significant source of injury during the renewal term. Surveys for rare

animals have not been performed at the site.

The area around the plant is maintained through a combination of mowing and herbicide

application. Lawns are mowed as needed. Two drainage swales are vegetated with lowgrowing herbaceous cover, which should help to reduce and absorb runoff and protect water

quality while providing some habitat for small animals (EPA 2006c). No maintenance activities

occur around wetlands or Lake Ontario. Roundup M T herbicide is used for weed control in

isolated locations by licensed applicators using hand sprayers. Entergy is required to submit

annual pesticide use reports to NYSDEC, listing qualified applicators. These reports estimate

herbicide use at 33 gallons (gal) in 2003, 30 gal in 2004, and 17 gal in 2005 (Entergy 2004b,

2005b, 2006e). When used according to label directions, such herbicide applications are not

expected to have significant environmental impacts.

Important terrestrial habitats near JAFNPP include Teal Marsh 4 mi west of the site, a rare

shrub fen 4 mi south of the site, and Butterfly Creek Wetlands 6 mi east of the site (NRC 2006).

Local parks where wildlife may comprise important recreational attractions include Selkirk

Shores State Park 5 mi east of the site, Fairhaven Beach State Park 20 mi southwest of the site,

and Beaver Lake Nature Center 25 mi south of the site (NYSHPO 2006a, 2006c; Onondaga

County Parks 2006). Little environmental interaction occurs between these areas and the

JAFNPP site, with the exception of bird travel between the site and these locations.

Ecological issues of statewide concern include chronic wasting disease (CWD) in white-tailed

deer (NYSDEC 2006a), botulism in shore birds (NYSDEC 2006e), and vegetation damage

resulting from caterpillars (NYSDEC 2006b) and wood wasps (NYSDEC 2006f). The NRC staff

is not aware of any linkage between continued operation of JAFNPP and these issues.

2.2.6.2 Terrestrial Resources in Transmission Corridors

There are four transmission lines that connect JAFNPP to other facilities and substations

(Entergy 2006d). See Table 2-1. Two of the transmission lines, the Edic and Scriba 345-kV

lines, are within the scope of license renewal. The Edic transmission line runs approximately

70 mi southeast to the Edic Substation near Utica, New York. The corridor associated with this

line is 150-ft wide and crosses Erie-Ontario Lake plain and fringe areas of Tug Hill plateau and

the Mohawk Valley (AEC 1973). These areas are predominantly forested, with some

agricultural, low-density residential, and wetland areas (AEC 1973). Important resource areas

crossed by this line include Catfish Creek, Butterfly Creek, the Little Salmon River, Mohawk

River, Nine Mile Creek, numerous wetlands, and various state wildlife management areas

(Microsoft 2005).

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The Edic line is owned and maintained by NYPA (Entergy 2006d). The NRC staff met with

NYPA personnel on December 4, 2006, to discuss their transmission line maintenance program.

NYPA maps land use and vegetative cover within the transmission corridor using a geographic

information system. This information is used to develop a maintenance plan for each mapped

parcel to remove only tall-growing species that may interfere with line operations, while allowing

other species to grow. Dead trees that may fall into the lines are removed from the edges of the

ROW by corridor maintenance personnel (NYPA 1998). Herbicides are applied to individual

plants by licensed applicators only as needed to ensure that that tall-growing vegetation does

not interfere with line operations. Maintenance personnel follow the NYPA Systemwide Rightof-Way Management Plan (NYPA 1998).

The transmission line towers are constructed of weathering steel, which requires little

maintenance and is less reflective than galvanized steel (AEC 1973). There is evidence that

some portions of the transmission line corridor are used by off-road vehicles and hunters, but

these activities appear to be limited in area and intensity.

Two invasive exotic plant species, common reed (Phragmites australis) and Japanese

knotweed (Polygonum cuspidatum), have been noted by NYPA personnel as occurring within

the Edic transmission corridor. Common reed is a threat to wetland areas because it crowds

out native vegetation and may negatively alter wildlife habitat. It is commonly controlled to

protect native species of plants and animals and promote a balanced, productive native

ecosystem. This is typically performed using herbicides, but mowing and controlled burns may

be effective in removing it (PCA 2006a). Japanese knotweed is an introduced species that can

rapidly crowd out native plant species and alter native ecosystems. It is commonly controlled

with diluted pesticides applied to a cut stem or to the leaves (PCA 2006b).

The eastern portion of the Edic transmission line passes near the towns of Annesville, Lee,

Western, Floyd, Trenton, and Marcy, where chronic wasting disease (CWD) in white-tailed deer

is an issue of concern (NYSDEC 2006c). This disease is contagious between deer and leads to

severe weight loss and death, but there is no evidence that it is transmissible to humans or

livestock (NYSDEC 2006a). NYSDEC is working to control the spread of CWD in this area.

Continued operation and maintenance of the lines is not anticipated to contribute appreciably to

the spread of this disease among the white-tailed deer population.

The second transmission line within the scope of this license renewal review is the 345-kV

Scriba line. The Scriba line is approximately 4900 feet in length and runs southward from the

JAFNPP 345-kV switchyard over Entergy property, then turns westward, crossing a portion of

the Nine Mile Point Nuclear Station site and enters the Scriba substation. The portion of the

transmission corridor that is not on the JAFNPP site is maintained by NYPA, the owner of the

line. The Scriba line crosses forested and landscaped areas maintained by JAFNPP and NYPA

using periodic mowing and vegetation control procedures.

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2.2.6.3 Terrestrial Species of Concern

Terrestrial species that are listed by the FWS or the State of New York and have the potential to

occur on or in the vicinity of the JAFNPP site or along the Edic and Scriba transmission

corridors are presented in Table 2-4.

The NRC staff met with NYPA on December 4, 2006. At this meeting, the NRC staff was

informed that no threatened or endangered species have been reported by maintenance

personnel as occurring in or near the transmission corridor. Corridor maintenance personnel

are trained in identifying endangered species and are expected to take measures to avoid

damage to these species if they are identified within the transmission line corridor during the

renewal period.

Consultation with New York Natural Heritage Program (NYNHP) revealed the existence of two

important natural heritage areas near the Edic transmission line corridor. The areas consist of

State-listed upland sandpiper (Bartramia Iongicauda) habitat and a rare fen. In addition, the

NYNHP staff identified the area immediately offshore from the JAFNPP site as an important

State-recognized waterfowl winter concentration area. The pied-billed grebe (Podilymbus

podiceps) and least bittern (Ixobrychus exilis) are known to forage nearby. Both species are

listed as threatened by the State of New York.

Table 2-4. Federally Listed and New York State-Listed Terrestrial Species Potentially

Occurring in the Vicinity of JAFNPP and in Associated Transmission Line Corridors

Federal State

Scientific Name Common Name Status Status

Reptiles and Amphibians

Ambystoma jeffersonianum Jefferson salamander - S

Ambystoma laterale blue-spotted salamander - S

Clemmys guttata spotted turtle - S

Clemmys insculpta wood turtle - S

Clemmys muhlenbergii bog turtle T E

Crotalus horridus timber rattlesnake - T

Birds

Accipiter cooperli

Accipiter striatus

Ammodramus henslowli

Ammodramus savannarum

Aquila chrysaetos

Cooper's hawk

sharp-shinned hawk

Henslow's sparrow

grasshopper sparrow

golden eagle

S

S

T

S

E

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Table 2-4 (cont.)

Federal State

Scientific Name Common Name Status Status

Birds (cont.)

Asio flammeus short-eared owl - E

Bartramia longicauda upland sandpiper - T

Buteo lineatus red-shouldered hawk - S

Charadrius melodius piping plover E E

Chlidonias niger black tern - E

Chordeiles minor common nighthawk - S

Circus cyaneus northern harrier - T

Cistothorus platensis sedge wren - T

Dendroica cerulean cerulean warbler - S

Eremophila alpestris horned lark - S

Falco peregrinus peregrine falcon - E

Gavia immer common loon - S

Ixobrychus exilis least bittern - T

Lanius ludovicianus loggerhead shrike - E

Melanerpes erythrocephalus red-headed woodpecker - S

Pandion haliaetus osprey - S

Podilymbus podiceps pied-billed grebe - T

Sterna hirundo common tern - T

Vermivora chrysoptera golden-winged warbler - S

Mammals

Myotis leibii small-footed bat - S

Myotis sodalis Indiana bat E E

Plants

Carex chordorrhiza

Eleocharis quadrangulata

Eleocharis obtuse var. ovata

Lycopodium complanaturn

Polygonum setaceum var.

interjecturn

Polystichum archostichoides

Thelypteris noveboracensis

creeping sedge

angled spikerush

blunt spikerush

northern running pine

swamp smartweed

Christmas fern

New York fern

T

E

E

E

E

S

S

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Table 2-4 (cont.)

Federal State

Scientific Name Common Name Status Status

Plants (cont.)

Trillium flexipes nodding trillium - E

Trillium sessile toad-shade - E

Trillium spp. trillium - S

- = No listing Source:

C = Candidate for federal listing Entergy 2006d

E = Endangered NYSDEC 2006g

S = Species of Special Concern (New York State) NYSDEC 2007

T = Threatened

Federally Protected Species

The endangered Indiana bat (Myotis sodalis) is a chestnut-brown, medium-sized bat that

forages for insects near streamside and upland forests (FWS 2006b). These bats roost and

hibernate in caves or mines, known as hibernacula, or under the loose bark of recently dead

trees. Reasons for the decline of this species include natural mortality, human disturbance of

hibernating bats, and deforestation, especially the removal of dead standing trees and trees

near streams (FWS 1983). Indiana bats may be utilizing large dead trees with loose bark either

onsite or along the margins of the Edic or Scribal transmission corridors. There have been no

reports of Indiana bats using dead trees along the transmission corridors; however, there has

been no systematic survey of this potential habitat.

The threatened bog turtle (Clemmys muhlenbergii) is a very small black turtle that lives in open

sedge meadows and fens bordered by wooded areas (FWS 2001). The bog turtle's diet

consists primarily of insects but also includes plants, frogs, and carrion (Bury 1979). The

greatest threats to the bog turtle include the degradation and destruction of open wetland

habitat and illegal collection (Groombridge 1982). Two potential sources of habitat loss within

the transmission corridor, if such habitat is present, are the colonization by common reed and

the natural progression by trees. The common reed establishes a dense monoculture that is

unsuitable for many wetland species, including bog turtles (FWS 2001). Because the bog turtle

depends on open wetlands without any tree cover, the current transmission corridor

maintenance program may preserve potential bog turtle habitat. The NRC staff is unaware of

any reported occurrences of bog turtles inhabiting wetlands along the Edic or Scriba

transmission corridors; however, there has not been a systematic survey of these lines for this

species.

For completeness, Federally protected species that were identified by the NRC staff during the

NEPA review for the NMPNS license renewal were included below. NMPNS lies immediately

west of JAFNPP. The species identified in the NMPNS review are the massausauga

rattlesnake (Sisturus catenatus catenatus), bald eagle (Haliaeetus leucocephalus), and piping

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plover (Charadrius melodius). The massasauga rattlesnake is a candidate species for Federal

protection. It lives in wet prairies, sedge meadows, and early successional fields, and natural

succession of woody vegetation may cause habitat deterioration (NRC 2006). It is not known to

occur near the JAFNPP site.

The bald eagle was removed from the Federal List of Threatened and Endangered Species in

July 2007 (FWS 2007), but the species continues to be protected under the Bald and Golden

Eagles Act of 1962, as amended, and the Migratory Bird Treaty Act of 1918. The bald eagle is

a transient species and is not found in the vicinity of JAFNPP or associated transmission line

ROWs.

The endangered piping plover is a small, stocky sandy-colored bird resembling a sandpiper.

Like the bald eagle, it may migrate through the area, but is not found in the vicinity of the

JAFNPP site or associated transmission line ROW (Entergy 2006d).

State-Protected Species

The NRC staff consulted with NYNHP on December 7, 2006 to determine which State-listed

species were known to occur near JAFNPP and the Edic and Scriba transmission lines. The

NYNHP identified three State-threatened bird species and one State-threatened plant species.

No other State-listed species were identified as occurring near the site or along the Edic and

Scriba transmission corridors.

The State-threatened upland sandpiper (Bartramia Iongicauda) is a small brown-and-white

mottled bird that inhabits open, grassy areas, including pastures, upland meadows, and fallow

fields. This species feeds on invertebrates and grains. It has declined due to excessive hunting

in the past and has not recovered from this historical stress (CDEP 2004b). One area of known

upland sandpiper habitat was identified by the NYNHP as occurring near the JAFNPP site.

The State-threatened pied-billed grebe (Podilymbus podiceps) is a diving duck that forages in

an area near the JAFNPP site. It lives in marshes and ponds and feeds mostly on aquatic

invertebrates, occasionally eating fish, reptiles and amphibians. Although this species is found

throughout North America, it is rare in New York (Cornell Laboratory of Ornithology 2003).

The State-threatened least bittern (Ixobrychus exilis) is found in emergent vegetation in

freshwater marshes not far from the JAFNPP site. It feeds on small fish, amphibians, insects,

invertebrates, and occasionally shrews and mice. Its decline is attributed to the destruction of

wetland habitat (CDEP 2004a).

The State-threatened creeping sedge (Carex chordorrhiza) is a wetland plant known to occur

near the JAFNPP site.

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2.2.7 Radiological Impacts

JAFNPP conducts a Radiological Environmental Monitoring Program (REMP) in which

radiological impacts to employees, the public, and the environment in and around the JAFNPP

site are monitored, documented, and compared to the appropriate standards. The objectives of

the REMP are to:

" Measure and evaluate the effects of facility operation on the environs and verify the

effectiveness of the controls on radioactive material sources

" Monitor natural radiation levels in the environs of the JAFNPP site

" Demonstrate compliance with the requirements of applicable Federal regulatory

agencies, including technical specifications and the ODCM

Information on radioactive releases and radiological environmental monitoring is summarized in

two JAFNPP reports: the Annual Radiological Environmental Operating Report (Entergy 2006b)

and Annual Radioactive Effluent Release Report (Entergy 2006a; 2005a; 2004a; 2003; 2002a;

2002b). Limits for all radiological releases are specified in the JAFNPP ODCM (Entergy 2004c)

and are used to meet Federal standards and requirements. The REMP includes monitoring of

the waterborne environment (surface water, Oswego City water, shoreline sediment); airborne

environment (radioiodine, particulates, direct radiation); and ingestion pathways (milk, fish,

vegetation). During 2005, 2318 analyses were performed on collected samples of

environmental media and showed no significant or measurable radiological impact from the

operations at JAFNPP (Entergy 2006b).

The NRC staff's review of the 2005 radiological environmental monitoring data verified that

there were no unusual or adverse trends in the environs around the JAFNPP site.

The New York State Department of Health also measures the levels of radiation exposure and

concentration of radioactive material at locations surrounding Nine Mile Point and JAFNPP.

The State measures direct radiation and radioactivity in air, milk, water, sediment, vegetation,

and fish. The State's 10-year monitoring data from 1995 through 2004 show radiation levels

typical for background levels for air, water, milk, fish, sediment samples, vegetation, and direct

radiation (New York State Department of Health 2007).

In addition to the REMP, Entergy has a groundwater protection program to monitor for potential

leaks from the plant. The monitoring program includes periodic surveillance and monitoring of

selected plant buildings, systems, and components containing liquids with radioactive material

for indication of leaks. The program also includes reporting criteria and provision for

remediation of contaminated groundwater (Entergy 2006i). Although there are currently no

groundwater monitoring wells at JAFNPP, there has been no indication of radioactive leaks into

the groundwater. The applicant will evaluate the effectiveness of the groundwater protection

program and make appropriate changes based on the results of its surveillance and monitoring.

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During the baseline NRC inspection of the REMP, the monitoring program will also be reviewed

for information on indications of leaks into the groundwater and the actions taken by the

applicant.

The NRC staff reviewed five years of radiological effluent release data (2001 through 2005)

from JAFNPP and the resultant calculated doses to members of the public. The data

demonstrate that the calculated doses to maximally exposed individuals in the vicinity of

JAFNPP were within the limits specified in the JAFNPP ODCM (Entergy 2004c) to meet the

ALARA dose criteria in Appendix I to 10 CFR Part 20; 10 CFR Part 50 and were a small fraction

of the limits specified in Federal radiation protection standards; 10 CFR Part 20 and 40 CFR

Part 190. For 2005, the most recent data reviewed, dose estimates were calculated based on

actual liquid and gaseous effluent release data and conservative models to simulate the

transport mechanisms. The results are described in the 2005 Annual Radioactive Effluent

Release Report (Entergy 2006a). A summary of the calculated maximum dose to an individual

located at the JAFNPP boundary from liquid and gaseous effluents released during 2005 is as

follows:

* The maximum whole-body dose to an offsite member of the general public from liquid

effluents was 1.68 105 millirem (mrem), well below the 3-mrem-dose criteria in Appendix

I to 10 CFR Part 50,.

* The maximum whole-body dose to the likely most-exposed member of the general public

from gaseous effluents was 4.39 mrem, below the 5-mrem-dose criteria in Appendix I to

10 CFR Part 50,.

The NRC staff found that the 2005 radiological data are consistent with the five year historical

radioactive effluent releases. Therefore, the NRC staff does not anticipate any significant

changes to the radioactive effluent releases or exposures from JAFNPP operations during the

period of extended operation and, the impacts to the environment are therefore not expected to

change.

2.2.8 Socioeconomic Factors

The NRC staff reviewed the JAFNPP Environmental Report (ER) (Entergy 2006d) and

information obtained from County, City, school district, and local economic development staff.

The following sections describe the housing market, community infrastructure, population, and

economy in the region surrounding the JAFNPP site.

2.2.8.1 Housing

JAFNPP employs a permanent workforce of 716 employees (Entergy 2006d). Approximately

78 percent live in Oswego County, New York, and 18 percent in Onondaga County, New York

(Table 2-5). Both counties are in the Syracuse metropolitan statistical area (MSA), which also

includes Cayuga and Madison counties. Given the residential locations of JAFNPP employees,

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the most significant impacts of plant operations are likely to occur in Oswego and Onondaga

counties. The focus of the analysis in this environmental impact statement (SEIS) is therefore

on the impacts of JAFNPP in these two counties.

Table 2-5. JAFNPP Permanent Employee

Residence by County in 2006

Number of JAFNPP Percentage

County Personnel of Total

Oswego 556 77.7%

Onondaga 127 17.7%

Other 33 4.6%

Total 716 100.0%

Source: Entergy 2006d

JAFNPP schedules refueling outages at 24-month intervals. During refueling outages, site

employment increases by 700 to 900 workers for approximately 30 days. These workers are

assumed to be from the same geographic areas as the permanent JAFNPP staff.

The number of housing units and housing vacancies in Oswego and Onondaga counties in

2000 and 2005 are shown in Table 2-6. In Oswego County, the total number of housing units

and occupied units grew at a rate of 1.7 and 3.2 percent, respectively, from 2000 to 2005.

Table 2-6. Number of Occupied, Vacant, and Total Housing Units

in Oswego and Onondaga Counties, New York, in 2000 and 2005

Housing Year Approximate

County Units 2000 2005 Change

Oswego Occupied 45,522 46,964 +3.2%

Vacant 7,309 6,766 -7.4%

Total 52,831 53,730 +1.7%

Onondaga Occupied 181,153 183,032 +1.0%

Vacant 15,480 17,704 +14.4%

Total 196,633 200,736 +2.1%

Source: USCB 2006a

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In Onondaga County, the total number of housing units grew at a rate of 2.1 percent from 2000

to 2005, while average annual growth of occupied units was slightly less at 1.0 percent (USCB

2006a).

2.2.8.2 Public Services

This section contains a discussion of public services including water supply, education, and

transportation.

Water Supply

Slightly more than half of Oswego County's population receives potable water from one of the

county's 29 public water districts, with the remaining population receiving water from private

groundwater wells (NRC 2006). Public water districts in the county obtain water from Lake

Ontario or a variety of groundwater aquifers and springs and the Onondaga County Water

Authority (OCWA) (OCDPCD 1997). Public water suppliers draw water from three principal

groundwater aquifers (Sand Ridge, Fulton, and Tug Hill) with substantial groundwater resources

available from other local or regional aquifers that have been largely unused (OCDPCD 1997).

The three major public water supply systems in Oswego County are the Oswego Water System,

the City of Fulton, and the Metropolitan Water Board.

Table 2-7 lists the daily water consumption and maximum daily capacity for the three major

public water supply systems in Oswego County.

Table 2-7. Major Public Water Supply Systems in Oswego County,

Average Daily Use, and Maximum Daily Capacity

Average Daily Use Maximum Daily Capacity

Water Supplier in million gpd in million gpd

Oswego Water System 8.0 20.1

City of Fulton 2.4 2.4

Metropolitan Water Board 25.0 62.5

Source: NRC 2006

The Oswego Water System (OWS) provides water service to approximately 23,950 customers

in the communities of Oswego, Minetto, Scriba, and Volney, and potable water to JAFNPP

(OCDPCD 1997). Current JAFNPP usage is approximately 137,500 gpd with no restrictions on

supply (Entergy 2006h). While the OWS could potentially withdraw up to approximately 62.5

million gpd from Lake Ontario, the design capacity of the water plant is only 20.1 million gpd

(OCDPCD 1997). County planning officials estimate that the capacity of the OWS is adequate

to meet the demands of an additional 4000 to 8000 residential customers (OCDPCD 1997).

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The City of Fulton water supplier serves approximately 12,900 customers. The City has

10 groundwater wells extracting up to 2.4 million gpd. As average daily demand exceeds

supply in the city, the City of Fulton has an agreement with the OCWA to obtain up to 3 million

gpd to cover the extra demand (OCDPCD 1997).

The Metropolitan Water Board (MWB) functions as a potable water wholesaler to public water

districts and water authorities in both Oswego and Onondaga counties. Most of the MWB's

water is sold to the OCWA, with 25 percent of its pipeline capacity available to Oswego County.

While the capacity of MWB is 60 million gpd, the MWB withdrew an average of only 25 million

gpd in 1998, of which 200,000 gpd was provided to communities in Oswego County. The MWB

therefore has large excess capacity to support future growth in the county (OCDPCD 1997).

Education

JANFPP is located in the Mexico Central School District, which had an enrollment of

2682 students in 2005. Including the Mexico Central School District, Oswego County contains

9 school districts. In 2000, there were 35,240 students enrolled in schools in the county with an

average class size of 21 students. The average expenditure per student in low-need districts in

New York is approximately $15,000. Onondaga County has a total of 18 school districts. Total

enrollment in the district is approximately 132,240 students based on data from the 2000

Census Bureau (Entergy 2006h).

Transportation

The road structure in the immediate vicinity of JAFNPP consists primarily of smaller county

roads rather than state or interstate highways. JAFNPP is accessed from the east by Lake

Road, a two-lane paved road east of the intersection of County Route 1A and Lakeview Road

(see Figure 2-2). According to the Oswego County Planning and Community Development

Department, the average daily traffic count for County Route 1A from County Route 1 to Lakeview

Road was 4900 vehicles in 1995 (NRC 2006).

Due to the rural nature of JAFNPP's location, there is no state level of service determination for

the county roads that service JAFNPP and the immediate area. The Oswego County

Department of Public Works reviewed traffic patterns for the major roads around the JAFNPP as

part of a reconstruction project for County Route 1A. The County determined that traffic counts

were within acceptable levels (NRC 2006).

2.2.8.3 Offsite Land Use

In order to accommodate and regulate growth and development, Oswego and Onondaga

counties have developed county-specific comprehensive growth management plans

characterizing current conditions and setting standards, regulations, and goals for land use and

development. Land-use planning and zoning regulations have been developed by towns,

villages, and municipalities within Oswego and Onondaga counties. Therefore, land use

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standards may vary greatly in different regions within the counties. Neither county has

implemented growth control measures that would limit residential housing development.

Agriculture remains the predominant land use in the county, but rural residential development

has increased. In all or parts of many towns, residential development surrounding major

employment centers has reached or is approaching suburban density. Most towns in Oswego

County have developed some type of land-use regulation, either zoning or subdivision

regulations. Although elements of the rural landscape remain, the community character is

clearly residential (OCDPCD 1997). Residential growth has been strongest in towns in southern

Oswego County and the town of Scriba in northern Oswego County. Commercial and industrial

land uses, particularly energy production, such as the Nine Mile Point Nuclear Station and Sithe

Industries, which operates a natural gas fueled power plant, have centered near the cities of

Oswego and Fulton and their surrounding areas. State-regulated wetlands account for

13 percent of the total land area in Oswego County, and development is restricted in these

areas (OCDPCD 1999).

Onondaga County is somewhat more developed, with an increase of both residential and

commercial land uses in towns and villages near Syracuse. Growth has been steady

throughout northern and central Onondaga County. County planning officials expect residential

growth to continue in northern and central Onondaga County following the Onondaga County

Settlement Plan (Syracuse-Onondaga County Planning Agency 2001). This plan proposes to

control growth within the county by guiding county infrastructure investments only to developed

areas.

Seventeen state parks, 20 state wildlife management areas, and one national wildlife refuge are

located within a 50-mi radius of JAFNPP. The Montezuma National Wildlife Refuge is north of

Cayuga Lake in Seneca County, approximately 44 mi southwest of the site.

Land use in Oswego and Onondaga counties is listed in Table 2-8.

2.2.8.4 Visual Aesthetics and Noise

The area around JAFNPP is generally flat, forested, and rural. The most prominent features on

the site are the reactor building and the off-gas stack, which is 385 ft high. Due to the forest

cover in the area, the physical plant is not visible from local communities. However, plant

structures can be seen by recreational boaters and fishermen on Lake Ontario.

January 2008 2-43 NUREG-1437, Supplement 31 1
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Table 2-8. Land Use in Oswego and Onondaga Counties

Percentage of Total

Oswego County Onondaga County Land Use (1995) (2006)

Agriculture, forested, vacant 55% 51%

Residential 36% 29%

Public 6% 10%

Commercial 3% 10%

Total 100% 100%

Sources: Oswego County: OCPCD 1997; Onondaga County: SyracuseOnondaga County Planning Agency 2006

Currently, there are no reports of noise complaints from the areas surrounding JAFNPP or from

recreational users of Lake Ontario. Additionally, noise concerns have not been considered a

problem at the site due to the plant's distance from local communities (Entergy 2006d). EPA

recommends that noise levels for residential areas near the boundary of an industrial facility not

exceed an annual equivalent sound level of 55 decibels. There is no expected increase in noise

levels associated with the proposed license renewal activities.

2.2.8.5 Demography

In 2000, approximately 109,440 persons lived within a 20-mi radius of JAFNPP, which equates

to a population density of 87 persons per mi 2. This density translates to a Category 3 (60 to

120 persons per mi 2 or fewer than 60 persons per mi 2 with at least one community of 25,000

or more persons within 20 mi) using the Generic Environmental Impact Statement (GELS)

(NRC 1996, 1999) measure of sparseness (Entergy 2006d). At the same time, there were

approximately 914,668 persons living within a 50-mi radius of the plant, for a density of

117 persons per mi2 . The Syracuse MSA, located within 50 mi of the site, had a total population

in 2000 of 732,117. Therefore, JAFNPP falls into Category 3 (one or more cities with 100,000

or more persons and fewer than 190 persons per mi 2 within 50 mi) of the NRC sparseness and

proximity matrix. A Category 3 value indicates that JAFNPP is in a medium density population

area (Entergy 2006d).

Table 2-9 shows population growth rates and projections from 1970 to 2020 in Oswego and

Onondaga counties. Oswego County grew at a relatively slow annual rate of less than

0.1 percent for the period of 1990 to 2000. The average annual growth rate for New York for

this period was 0.5 percent. Only slight increases in population are expected for the period

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2000 through 2020. The population declined in Onondaga County during the 1990s and this

trend is expected to continue during the period 2000 to 2020.

In 2000, Oswego, the largest city in Oswego County, located approximately 5 mi southwest of

JAFNPP had a population of 17,954 persons (USCB 2006a). The second largest city, Fulton,

located approximately 12 mi south of JAFNPP had a population of 11,855 persons. The town of

Scriba had an estimated population of 7331 persons. The U.S. Census Bureau lists 21 other

towns in Oswego County, all of which have populations between 500 and 9000 persons (USCB

2006a). Most of the remaining population lives in unincorporated rural areas (OCDPCD 1997).

Although some towns and municipalities surrounding Syracuse have experienced modest

growth, Onondaga County and Syracuse declined in population from 1990 to 2000. In 2000 the

Onondaga Reservation in southern Onondaga County had an estimated population of

1473 persons (Answers.com 2006).

Table 2-9. Population Growth in Oswego and Onondaga Counties,

New York, from 1970 to 2000 and Projected for 2010 and 2020

Oswego County Onondaga County

Annual Growth Annual Growth

Year Population Percent(a) Population Percent(a)

1970- 100,897 - 472,835

1980 113,931 +1.2 463,920 -0.2

1990 121,771 +0.7 468,973 +0.01

2000 122,377 +0.05 458,336 -0.02

2010 123,400 +0.08 442,531 -0.4

2020 123,591 +0.02 423,235 -0.4

- = No data available.

(a) Annual percent growth rate is calculated over the previous decade.

Sources: Population data for 1970 through 2000 (USCB 2006a); projected

population data for 2010 and 2020 (NRC 2006)

Transient Population

Within 50 mi of JAFNPP, colleges and recreational opportunities attract daily and seasonal

visitors who create demand for temporary housing and services. In Oswego County,

6.6 percent of all housing units are considered temporary housing for seasonal, recreational, or

occasional use. By comparison, temporary housing accounts for only 1.0 percent and

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3.1 percent of total housing units in Onondaga County and the State of New York, respectively

(USCB 2005).

Migrant Farm Workers .

Migrant farm workers are individuals whose employment requires travel to harvest agricultural

crops. These workers may or may not have a permanent residence. Some migrant workers

may follow the harvesting of crops, particularly fruit, throughout the northeastern U.S. rural

areas. Others may be permanent residents near JAFNPP who travel from farm to farm

harvesting crops.

Migrant workers may be members of minority or low-income populations. Because they travel

and can spend a significant amount of time in an area without being actual residents, migrant

workers may be unavailable for counting by census takers. If uncounted, these workers would

be "underrepresented" in USCB minority and low-income population counts.

Onondaga and Oswego counties host relatively small numbers of migrant workers. According

to 2002 Census of Agriculture estimates, 1745 temporary farm laborers (those working fewer

than 150 days per year) were employed on 170 farms in Onondaga County, and 718 were

employed on 93 farms in Oswego County (Entergy 2006h).

2.2.8.6 Economy

This section contains a discussion of the economy, including employment and income,

unemployment, and taxes.

Employment and Income

Between 1990 and 2004, total employment in Oswego County increased 2.5 percent (24,396 to

25,011 persons) and decreased in Onondaga County by 3.6 percent (232,120 to 223,649

persons) (USCB 2006b). Government and health care sectors employed the largest number of

people in both counties followed closely by retail, manufacturing, and the service industry. The

largest employer in Oswego County in 2006 was the State University of New York at Oswego

(SUNY Oswego) with 3934 employees (Table 2-10). The majority of jobs in Oswego County are

located in the cities of Oswego and Fulton (Oswego County 2006).

Personal income in Oswego County totaled $2.9 million in 2004, with a per capita personal

income of $23,481. In Onondaga County, personal income totaled $14.7 million, with a per

capita income of $32,122. Both are lower than the state's per capita personal income in 2004,

which was $38,364 (FedStats 2006).

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Table 2-10. Major Employers in Oswego County in 2006

Number of

Firm Employees

SUNY Oswego 3934

County of Oswego 1048

Constellation Energy Group 900

Central Square School District 841

Oswego Health 730

Oswego City School District 723

Novelis Corporation 714

Fulton School District 647

Huhtamaki Packaging 630

Wal-Mart 620

Oswego Opportunities (non-profit) 604

Oswego County Bringing Our Community 569

Education Solutions (BOCES)

Entergy Nuclear Northeast 560

Source: Oswego County 2006

Unemployment

The unemployment rate in Oswego and Onondaga counties in October 2006 was 4.3 and

3.7 percent, respectively. Although there have been fluctuations, the overall rates in both

counties have remained about the same over the past decade. The current rate for the state

(November 2006) is 4.0 percent (NYSDOL 2006).

Taxes

JAFNPP is assessed annual property taxes by Oswego County, the Town of Scriba, and Mexico

Central Schools. Property taxes paid to Oswego County and the Town of Scriba fund services

such as transportation, education, public health, and public safety. See Table 2-11.

The continued availability of JAFNPP and the associated tax base is an important feature in the

ability of the Town of Scriba and Oswego County communities to continue to invest in

infrastructure and to draw industry and new residents.

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In 2005, Entergy paid approximately $7.2 million in taxes for JAFNPP. It is estimated that a

minimum of $38.1 million in taxes will be paid by Entergy for JAFNPP through the original

license period (Entergy 2006d). These property taxes, and other local taxes, along with

JAFNPP operating payroll and locally purchased goods and services, aid the local economy.

The energy market in the state of New York has been deregulated to encourage the

development of competition in the production and sale of electricity. A study performed by the

New York State Board of Real Property Services concluded that the value of many powergenerating plants is likely to decline in a deregulated market. Therefore, future property taxes

assessed through the license renewal term should be similar to or may be less than the

estimated in lieu payments.

Table 2-11. Oswego County, Town of Scriba, and Mexico Central Schools Tax Revenues,

2002 to 2005; JAFNPP Property Tax, 2002 to 2005; and JAFNPP Property Tax

as a Percentage of Tax Revenues

Property Tax

Tax Revenues Paid by JAFNPP JAFNPP Property

(in millions of (in millions of Tax as Percentage

Entity Year dollars) dollars) of Tax Revenues

Oswego County 2002 $152.9 $2.9 1.9%

2003 $156.1 $2.9 1.9%

2004 $172.5 $2.9 1.7%

2005 $162.4 $2.9 1.8%

2006 $161.0 $2.9 1.8%

Town of Scriba 2002 $4.0 $0.4 10.9%

2003 $4.9 $0.4 9.0%

2004 $4.3 $0.4 10.3%

2005 $5.1 $0.4 8.6%

2006 $4.6 $0.4 9.4%

Mexico Central 2002 $32.4 $3.9 12.1% Schools 2003 $32.7 $3.9 12.0%

2004 $34.1 $3.9 11.5%

2005 $34.0 $3.9 11.4%

2006 $34.0 $3.9 11.6%

Source: Entergy 2006d (years 2002-2005)

Entergy 2006h (year 2006)

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2.2.9 Historic and Archaeological Resources

This section discusses the cultural background and the known historic and archaeological

resources at the JAFNPP site and in the surrounding area.

2.2.9.1 Cultural Background

The region around JAFNPP contains prehistoric and historic Native American and EuroAmerican cultural resources. There are 43 properties listed in the National Register of Historic

Places within approximately 10 mi of JAFNPP (Entergy 2006d). The nearest National Register

site is the Riverside Cemetery in Scriba; none are located in areas affected by operation of

JAFNPP.

Paleo Indians occupied North America from 12,000 to 10,000 years ago, subsisting on hunting

game and gathering plant material. In the New York area, Paleo Indians migrated into an

environment changed by retreating glacial ice. Evidence from archaeological work in the state

suggests that small game and plants played a significant role in the lives of the people. Stone

tools show little variability over wide areas of North and South America, but raw material for

these tools often have sources far from where archaeologists find the tools. Known PaleoIndian sites near JAFNPP include the Potts Site southeast of Scriba (Ritchie 1994).

During the Archaic Period, from approximately 10,000 years ago to about 3500 years ago,

people underwent local changes to adapt to resources. In the New York area, as forests

evolved from spruce and pine to mixed deciduous communities, populations near present day

JAFNPP probably were low in density to begin with but steadily increased in density as both

resource quality and the cultural means to access resources improved. Archaeologists find

evidence of more occupation by the end of the Archaic Period when climate reached its modern

condition. They interpret the settlement patterns they find as suggestive of an increase in

breadth of resources sought by prehistoric people as they lived in smaller territories. Archaic

people collected, hunted, and gathered most of what they needed for survival in their home

territory. Large base camps found near major water sources provided a focal point for groups

during the hard months. During other seasons, camps divided and people engaged in more

mobile foraging activities. Primary areas of occupation were along the Oswego River about

7 mi to the west of JAFNPP. Small hunting parties may have crossed the JAFNPP site and

hunting encampments could be present. One late Archaic archaeological deposit near the

JAFNPP area is the Oberlander 1 site in Oswego County on the Oneida River (Ritchie 1994).

The Transitional Period, from approximately 3500 years ago to about 1000 years ago, is viewed

by New York archaeologists as representing a continuum of change in adaptation by prehistoric

peoples. The central defining characteristic of the period is the introduction of stone (steatite)

vessels at the beginning and the first production of pottery at the end (Ritchie and Funk 1973).

Over the same period, burial treatment became more elaborate, and people once again got

some materials for making stone tools from distant sources (Ritchie and Funk 1973).

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The "Woodland" culture occupied the region between 3000 years ago until the time of European

contact. In the Woodland culture, Native Americans became regionally distinct cultural entities.

Woodland people ultimately became dependent on maize agriculture, lived in villages, used the

bow and arrow in hunting, and began to regularly make and use pottery. Known examples of

prehistoric sites are rare on the shore of Lake Ontario. Known archaeological resources found

in Oswego County are concentrated along the Oswego River, Oneida Lake, along the Salmon

River, and at the mouth of the Salmon River.

JAFNPP is situated within a region bordered by Lake Ontario to the north. No major drainage

occurs within 5 mi. Any large prehistoric sites would most likely be found along major

waterways away from JAFNPP. Since JAFNPP is not within the daily foraging radius of any

major river valley, prehistoric people visiting the area could have made overnight camps along

minor streams as they hunted and collected local resources. The terrain to the south and east

of JAFNPP consists of glacial kettle ponds and wetlands surrounded by small knolls and hills.

Paleo-lndian and Archaic Period peoples could have foraged for resources in and around these

kettle ponds. Later prehistoric groups could have used this area for hunting and foraging on a

reduced scale. JAFNPP is also situated on a rocky coastal bluff. This, along with the lack of a

beach, would not have been attractive for fishing. Any archaeological sites found in the vicinity

of the JAFNPP would consist of small scatters of stone tools and debris from making stone

tools, associated with cooking hearths.

The Native American societies in the region shared several important characteristics at the time

they were first contacted by Europeans. These included an economic base that combined

hunting and gathering with growing domesticated plants; and an annual settlement that varied in

population size between semi-permanent river-side villages in summer, large camps in winter,

and population dispersal among scattered camps in the spring and fall.

The JAFNPP site is located on Onondaga Indian Nation's eighteenth century lands, although

the territorial boundaries between Native American groups were in flux throughout the historic

period and until the mid-nineteenth century. Treaties between New York Indians and the United

States government in 1794 and 1838 eroded tribal territorial holdings in the state of New York.

European settlement and exploration of the region occurred slowly with most of the settlement

activity concentrated away from JAFNPP near the mouth of the Oswego River near Forts

Ontario and Oswego.

In 1788, the state purchased large tracts of land from the Onondaga, Oneida, and Cayuga

nations; the lands, which were divided into parcels, included Scriba's Patent, and that included

the JAFNPP. George Scriba, a resident of Holland, New York, took possession of nearly

0.5 million ac of land in the patent. The patent was divided into 16 townships in Oswego

County, and George Scriba began to sell portions to speculators and settlers (Kozub and Carter

2003).

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The town of Scriba was created in 1811, although settlers in the area arrived as early as 1798.

The scene for the first non-Indian settlement was at "Scriba Corners." The township of Scriba

flourished throughout the nineteenth century with small farms, apple orchards, and a booming

cider industry. Seven homesteads, a railroad line, and a stave factory (for cider barrels) existed

on the JAFNPP tract in 1867 (Stone 1867).

The early economy was based on timber harvesting and lumber production. As forests were

cut, residents moved to farming, especially dairy and fruit production (Churchill 1895). The

Oswego Canal opened in 1828 and the Syracuse & Oswego Railroad opened in 1848. The

canal and railroad precipitated surges in the lumber industry and in agriculture (Churchill 1895).

By 1855 more than half of the county's workers were farmers (Wellman 1987). However, by the

late 1800s, the shipping industry in Oswego collapsed, as did agriculture, and farmers began to

leave. It took Oswego County 90 years to return to the population level of 1870. By 1900, at

least 12 residences had located in the JAFNPP area (USGS 1900). The number of farms and

homes remained relatively stable until 1955, when there were 14 residences (USGS 1955).

Camp Oswego, also known as the Camp Drum Anti-Aircraft Artillery Firing Range, was located

immediately to the west of JAFNPP on property now occupied by Nine Mile Point Nuclear

Station (USGS 1955). The camp was established during World War II and continued to operate

well into the 1950s as a summer training base. Sometime after 1956, the camp was closed and

the land was later purchased by Niagara-Mohawk Electric Company for construction of the Nine

Mile Point Nuclear Station.

2.2.9.2 Historic and Archaeological Resources at JAFNPP

During preparation and review of the Final Environmental Statement Related to Operation of

James A. Fitzpatrick Nuclear Power Plant (AEC 1973), it was determined that no known historic

places and archaeological sites existed within the plant site or in the ROW for the transmission

line. The New York State Historic Preservation Office (SHPO) was contacted during the early

stages of site construction for information about archaeological resources in the vicinity of

JAFNPP and received certification that the plant would not have a harmful effect on any sites of

historic and archaeological importance (AEC 1973). Subsequently, Entergy contacted the New

York State Office of Parks, Recreation, and Historic Preservation (NYSHPO) regarding license

renewal for JAFNPP in February 2006 (Entergy 2006d). In April 2006, NYSHPO responded to

Entergy stating that they consider the project area to be "sensitive for archaeological resources"

(NYSHPO 2006b).

The JAFNPP site is generally flat, with the area surrounding the plant largely forested and rural

(Entergy 2006d). Aerial photographs show that a considerable portion (approximately one-third)

of the site has been disturbed due to the construction of JAFNPP. After a review of NYSHPO

site files, NRC staff confirmed that no known archaeological and historic architectural sites have

been recorded at JAFNPP. In addition, according to NYSHPO records, there have been several

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archaeological studies and surveys conducted in the vicinity of JAFNPP and one actual study of

the site. The results of these studies are summarized chronologically below.

The first known archaeological survey in the vicinity of JAFNPP was conducted in 1977 by Pratt

and Pratt Archaeological Associates, Inc., for Niagara Mohawk Power Corporation. This report

consisted of a literature search and survey for siting a power line and substation (Nine Mile

Point Nuclear Station Unit 2-Volney 765-kV line) that crossed JAFNPP property. The literature

review found no recorded prehistoric archaeological sites or National Register properties within

the proposed substation site and corridor area. However, the report indicated there was a high

potential for finding historic sites within the project corridor but only a moderate potential that

these sites would be impacted by the proposed project. In 1983, Pratt and Pratt Archaeological

Associates, Inc., published an addendum to the 1977 report, which did not change the

conclusions of the earlier report.

In 1987, a comprehensive literature review and cultural resource inventory was conducted at the

JAFNPP site by Hartgen Archeological Associates, Inc. Again, the literature review found no

recorded prehistoric or historic archaeological sites on file at the New York State Museum or

SHPO. However, Hartgen noted that due to environmental conditions, the JAFNPP site and

surrounding area could have been used for foraging and hunting by limited numbers of

prehistoric peoples for short durations, and concluded that there was a low to moderate

probability of prehistoric sites being found on the plant site. The survey also reported that

historic development within the JAFNPP site consisted primarily of scattered homes along North

Lake Road and Oswego County Route 29. As late as 1955, the number of structures identified

on maps within the JAFNPP property was only 16. Given that these historic structures once

stood on the JAFNPP site, the potential for finding historic resources on the site is high.

Most of the other archaeological studies and surveys conducted between 1987 and 2004

consisted of literature searches for water and electric transmission line and roadway projects.

These studies and surveys found no significant prehistoric or historic sites within their project

areas.

In October 2006, Entergy contracted Enercon Services, Inc., to perform a Phase 1A literature

review and archaeological sensitivity assessment for the JAFNPP site. The assessment

included a walk-over of selected undeveloped portions of the JAFNPP site that were identified

as being potentially sensitive for cultural resources. As stated in previous archaeological

reviews, Enercon also concluded that there is a potential for finding prehistoric sites on the

small knolls and hills next to kettle ponds across the eastern and southern portions of the

JAFNPP property. The assessment also concluded that since the site was mostly orchard

farmland prior to the construction of JAFNPP, it is very likely that historic resources associated

with those farms exist on the site.

A walk-over of selected undeveloped portions of the JAFNPP site by NRC staff confirmed the

existence of historic resources on the plant site. Early maps of the JAFNPP area indicate that a

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number of structures, mostly of nineteenth-century origin, existed on the JAFNPP site prior to

construction. Most of these sites today consist of foundations and probable associated historic

artifact scatters. Prehistoric cultural resources could also be present in the relatively

undisturbed southern and eastern portions of the JAFNPP site in areas next to kettle ponds.

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 operating license for JAFNPP. Any such activity could result in cumulative

environmental impacts and the possible need for a Federal agency to become a cooperating

agency in the preparation of the JAFNPP SEIS.

The 7068-ac Montezuma National Wildlife Refuge, located approximately 44 mi southwest of

JAFNPP serves as a major resting area for waterfowl and other waterbirds on their journeys to

and from nesting areas in northeastern and east-central Canada. This refuge is also in the

middle of one of the most active flight lanes in the Atlantic Flyway (FWS 2006a).

The Onondaga Reservation, a 5953-ac Indian reservation, is located in Onondaga County. As

of the 2000 census, the Indian reservation had a population of 1473 (Answers.com 2006).

JAFNPP shares an eastern boundary with the NMPNS, a two-unit electricity-generating nuclear

power plant operated by Nine Mile Point Nuclear Station, LLC. There are also approximately 25

hydropower electricity-generating facilities within 50 mi of the JAFNPP site.

NRC is required under Section 102 of the National Environmental Policy Act of 1969 (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. Federal agency comment

correspondence is included in Appendix E.

2.2.10.1 Coastal Zone Management Act

The Coastal Zone Management Act of 1972 (CZMA) grants the National Oceanic and

Atmospheric Administration (NOAA) the authority to encourage and assist states and territories

with developing management programs that preserve, protect, develop, and, when possible,

restore coastal zone resources. A "coastal zone" is generally described as the coastal waters

and the adjacent shore lands strongly influenced by each other and includes islands, transitional

and intertidal areas, salt marshes, wetlands, beaches, and Great Lakes waters (NOAA 2007).

Federal activities that are reasonably likely to affect coastal use or resources, such as license

renewal of nuclear power plants, must be consistent with the approved State coastal

management program (CMP). The federal consistency provision is promulgated in Section

307(c)(3)(a) of the CZMA and requires applicants for Federal licenses or permits to certify that

any proposed activity in the coastal zone is consistent with the enforceable policies of the State

CMP (NOAA 2007). A copy of the applicant's consistency certification, as submitted to the

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Federal agency, is provided to the State agency responsible for conducting consistency

reviews. Upon receipt of all necessary information, the State has six months to notify the

applicant and Federal agency of whether it concurs with or objects to the applicant's

certification. The Federal license or permit being sought by the applicant cannot be granted

without State approval of the consistency certification (DOC 2003).

In 1982, NOAA certified New York State's CMP, as codified in 19 NYCRR Parts 600-601.

Implementation of the CMP and a consistency review are performed by the New York State

Department of State Division of Coastal Resources (NYSDOS 2007). JAFNPP is located on a

Great Lakes coastline that falls under the jurisdiction of the CZMA, and license renewal is a

Federal activity that requires a consistency determination. As such, Entergy submitted a copy

of its New York State CMP certification, as contained within Attachment D of the ER (Entergy

2006d), to the State on July 31, 2006. New York State requires review of the final SEIS prior to

making a consistency determination. To ensure the six-month review time frame is maintained,

upon request of the State, Entergy withdrew its consistency certification and will resubmit the

certification closer to the date of the final SEIS issuance (Entergy 2006f).

2.2.10.2 Clean Water Act Section 401 Water Quality Certification

Under Section 401 of the Clean Water Act of 1977 (CWA), an applicant for a Federal license or

permit to conduct any activity that may result in discharge into navigable waters must obtain

certification from the appropriate state pollution control agency verifying compliance with the

CWA. A license or permit cannot be granted by the Federal agency until this certification has

been obtained or waived by the State. Furthermore, a license or permit cannot be granted if

certification has been denied by the State, interstate agency, or the EPA Administrator. The

401 Water Quality Certification sets forth applicable effluent limitations and prescribes

monitoring requirements to ensure that the applicant remains in compliance with those

limitations. Any Federal license or permit for a 401 Water Quality Certification that has been

obtained may be suspended or revoked by the issuing Federal agency upon judgment that the

facility or licensed activity has violated its certification or any applicable provisions of the CWA.

In New York, the NYSDEC Department of Water reviews and issues Section 401 Water Quality

Certifications. JAFNPP's original 401 Certification and Initial Reporting Requirements is dated

June 1, 1973, and accompanied the original licensing action by the NRC. In accordance with

Section 401 regulations, Entergy submited a Section 401 Water Quality Certification application

to NYSDEC in April 2007 (Entergy 2007b) to accompany the request for license renewal. Upon

receipt of the application, NYSDEC will have 12 months to review the application and grant or

deny a certification. NYSDEC anticipates issuing a decision for JAFNPP in March 2008,

approximately three months prior to the NRC's expected license renewal decision in May 2008

(assuming the standard 22-month NRC license renewal review timeline).

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2.3 References

6 NYCRR Part 374. Title 6 of the Codes, Rules, and Regulations of the State of New York,

Part 374.3. "Management of Specific Hazardous Wastes - Standards for Universal Waste."

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, "Domestic Licensing of

Production and Utilization Facilities."

19 NYCRR Parts 600-601. Title 19 of the Codes, Rules, and Regulations of the State of New

York Chapter XIII: Waterfront Revitalization of Coastal Areas and Inland Waterways, Parts 600 -

603: Local Government Waterfront Revitalization Programs.

40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81,

"Designation of Areas for Air Quality Planning Purposes."

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."

Answers.com. 2006. Onondaga Reservation, New York. Available URL:

http://www.answers.com/topic/onondaga-reservation-new-york (accessed September 5, 2006).

Accessible at ML073241533.

Bald and Golden Eagles Act of 1962, as amended. 16 USC 668-668d.

Bury, R.B. 1979. "Review of the ecology and conservation of the bog turtle, Clemmys

muhlenbergii." U.S. Department of the Interior, Fish and Wildlife Service, Special Scientific

Report - Wildlife 2 19: 1-9.

Churchill, J.C. (ed). 1895. Landmarks of Oswego County New York. C.D. Mason and

Company: Syracuse, New York.

Clean Water Act of 1977. Federal Water Pollution Control Act of 1977, 33 USC 1251, et seq.

January 2008 2-55 NUREG-1437, Supplement 31 I
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Coastal Zone Management Act of 1972. 16 USC 1456(c)(3)(A).

Connecticut Department of Environmental Protection (CDEP). 2004a. "Least Bittern Fact

Sheet." Available URL: http://dep.state.ct.uslburnatr/wildlife/factshts/lebitt.htm (accessed

December 28, 2006). Accessible at ML070120341.

Connecticut Department of Environmental Protection (CDEP). 2004b. "Upland Sandpiper Fact

Sheet." Available URL: http://dep.state.ct.us/burnatr/wildlife/factshts/upsand.htm (accessed

December 28, 2006). Accessible at ML070120339.

Cornell Laboratory of Ornithology. 2003. "All About Birds: Pied-billed Grebe." Available URL:

http://www.birds.cornell.edu/AllAboutBirds/ BirdGuide/Pied-billedGrebe_dtl.html (accessed

December 28, 2006). Accessible at ML070120343.

EA Science and Technology (EA). 2005. 2004 SPDES Biological Monitoring Report James A.

FitzPatrick Nuclear Power Plant (Permit No. NY 0020109, Section 10, CP-04.03). Newburgh,

New York. Accessible at ML062970416.

Endangered Species Act of 1973 (ESA). 16 USC 1531 et seq.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2001.

Nuclear James A. Fitzpatrick, James A. Fitzpatrick Nuclear Power Plant Final Safety Analysis

Report. This document is not publicly available.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2002a.

Effluent and Waste Disposal, Semi-Annual Report, January 1, 2001 - June 30, 2001. James A.

FitzPatrick Nuclear Power Plant, Docket No. 50-333, License No. DPR-59. Accessible at

ML053420220.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2002b.

Effluent and Waste Disposal, Semi-Annual Report, July 1, 2001 - December 31, 2001.

James A. FitzPatrick Nuclear Power Plant, Docket No. 50-333, License No. DPR-59.

Accessible at ML053420221.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2003.

Annual Radioactive Effluent Release Report, January 1, 2002 - December 31, 2002. James A

FitzPatrick Nuclear Power Plant, Docket No. 50-333, License No. DPR-59. Accessible at

ML053420227.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2004a.

Annual Radioactive Effluent Release Report, January 1, 2003 - December 31, 2003. James A.

FitzPatrick Nuclear Power Plant, Docket No. 50-333, License No. DPR-59. Accessible at

ML041260153.

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Plant and the Environment

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2004b.

Letter to New York State Department of Environmental Conservation transmitting Pesticide Use

Annual Report - 2003. Accessible at ML063620528.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2004c.

Offsite Dose Calculation Manual [ODCM], James A. FitzPatrick Nuclear Power Plant, DVP01.02, Revision 9. Accessible at ML063630360.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2005a.

Annual Radioactive Effluent Release Report, January 1, 2004 - December 31, 2004. James A.

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January 2008 2-67 NUREG-1437, Supplement 31 I

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 (GELS), NUREG-1437,

Volumes 1 and 2 (NRC 1996; 1999).(1) The GElS 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 GElS, 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 offsite 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 (SEIS) 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.

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

determined to be Category 1 issues are listed in Table 3-1.

Environmental issues related to refurbishment considered in the GElS 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.

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

references to the "GELS" include the GElS and its Addendum 1.

January 2008 3-1 NUREG-1437, Supplement 31 I
Environmental Impacts of Refurbishment

Table 3-1. Category 1 Issues for Refurbishment Evaluation

ISSUES-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS 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

Onsite land use 3.2

HUMAN HEALTH

Radiation exposures to the public during refurbishment 3.8.1

Occupational radiation exposures during refurbishment 3.8.2

SOClOECONOMICS

Public services: public safety, social services, and tourism and 3.7.4; 3.7.4.3;

recreation 3.7.4.4; 3.7.4.6

Aesthetic impacts (refurbishment) 3.7.8

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 FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy) indicated that it has

performed an evaluation of structures and components pursuant to Section 54.21 of Title 10 of

the Code of Federal Regulations (10 CFR 54.21) to identify activities that are necessary to

continue operation of JAFNPP 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).

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

I NUREG-1437, Supplement 31 3-2 January 2008
Environmental Impacts of Refurbishment

Table 3-2. Category 2 Issues for Refurbishment Evaluation

10 CFR 51.53

GElS (c)(3)(ii)

ISSUES-l0 CFR Part 51, Subpart A, Appendix B, Table B-1 Sections 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 3.3 F

maintenance areas)

SOCIOECONOMICS

Housing impacts 3.7.2

Public services: public utilities 3.7.4.5

Public services: education (refurbishment) 3.7.4.1

Offsite land use (refurbishment) 3.7.5

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 GElS 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

NRC staff's environmental impact statement.

plant operations as evaluated in the Final Environmental Statement Related to Operation of

James A. FitzPatrick Nuclear Power Plant (AEC 1973). 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

JAFNPP beyond the end of the existing operating license. Therefore, refurbishment is not

considered in this SEIS.

January 2008 3-3 NUREG-1437, Supplement 31
Environmental Impacts of Refurbishment

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."

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006.

James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E: -

Applicant's Environmental Report, Operating License Renewal Stage. Lycoming, New York.

Accessible at ML062160557.

U.S. Atomic Energy Commission (AEC). 1973. Final Environmental Statement Related to

Operation of James A. FitzPatrick Nuclear Power Plant. Power Authority of the State of New

York. Docket No. 50-333. Washington, D.C. Accessible at ML062360088.

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

for License Renewal of Nuclear Plants. NUREG-1 437, Volumes 1 and 2. Office of Nuclear

Regulatory Research, Washington, D.C.

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

for License Renewal of Nuclear Plant. NUREG-1437, Volume 1, Addendum 1. Office of

Nuclear Regulatory Research, Washington, D.C.

I NUREG-1437, Supplement 31 3-4 January 2008
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 (GELS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999).(1) The GElS

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 GELS, 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 offsite 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 period of extended operation

that are listed in Table B-1 of Part 51 of Title 10 of the Code of Federal Regulations (10 CFR Part

51), Subpart A, Appendix B and are applicable to the James A. FitzPatrick Nuclear Power Plant

(JAFNPP). Section 4.1 addresses issues applicable to the JAFNPP cooling system. Section 4.2

addresses issues related to transmission lines and onsite 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

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

references to the "GElS" include the GElS and its Addendum 1.

January 2008 4-1 NUREG-1437, Supplement 31 I
Environmental Impacts of Operation

impacts. The results of the evaluation of environmental issues related to operation during the

renewal term are summarized 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 JAFNPP because they

are related to plant-design features or site characteristics not found at JAFNPP 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

the JAFNPP cooling system operation during the renewal term are listed in Table 4-1. Entergy

Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy) stated in its

Environmental Report, James A. FitzPatrick Nuclear Power Plant - License Renewal

Application, Appendix E: Applicant's Environmental Report, Operating License Renewal Stage

(JAFNPP ER) (Entergy 2006a), that it is not aware of any new and significant information

associated with the renewal of the JAFNPP operating license (OL). The NRC staff has not

identified any new and significant information during its independent review of the JAFNPP ER

(Entergy 2006a), the site audit, the scoping process, and its evaluation of other available

information and public comments on the draft SEIS. Therefore, the NRC staff concludes that

there are no impacts related to these issues beyond those discussed in the GELS. For all of the

issues, the NRC staff concluded in the GElS that the impacts are SMALL, and additional plantspecific mitigation measures are not likely to be sufficiently beneficial to be warranted.

A brief description of the NRC staffs review and the GElS conclusions, as codified in Table B-I,

for each of these issues follows:

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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC 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 GELS.

I NUREG-1437, Supplement 31 4-2 January 2008
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Table 4-1. Category 1 Issues Applicable to the Operation of the JAFNPP

Cooling System During the Renewal Term

ISSUES-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Section

SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Altered current patterns at intake and discharge structures 4.2.1.2.1

Altered thermal stratification of lakes 4.2.1.2.3

Temperature effects on sediment transport capacity 4.2.1.2.3

Scouring caused by discharged cooling water 4.2.1.2.3

Eutrophication 4.2.1.2.3

Discharge of chlorine or other biocides 4.2.1.2.4

Discharge of sanitary wastes and minor chemical spills 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

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

Premature emergence of aquatic insects 4.2.2.1.7

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 4.2.2.1.10

exposed to sublethal stresses

Stimulation of nuisance organisms 4.2.2.1.11

HUMAN HEALTH

Microbiological organisms (occupational health) 4.3.6

Noise 4.3.7

January 2008 4-3 NUREG-1437, Supplement 31 1
Environmental Impacts of Operation

* Altered thermal stratification of lakes. Based on information in the GElS, the Commission

found that

Generally, lake stratification 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of altered thermal stratification of

lakes during the renewal term beyond those discussed in the GELS.

" Temperature effects on sediment transport capacity. Based on information in the GElS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of temperature effects on sediment

transport capacity during the renewal term beyond those discussed in the GElS.

" Scouring caused by discharged cooling water. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of scouring caused by discharged

cooling water during the renewal term beyond those discussed in the GELS.

" Eutrophication. Based on information in the GELS, the Commission found that

Eutrophication 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.

I NUREG-1437, Supplement 31 4-4 January 2008
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The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information including plant monitoring data and technical

reports and public comments on the draft SEIS. Therefore, the NRC staff concludes that

there would be no impacts of eutrophication during the renewal term beyond those

discussed in the GELS.

" Discharge of chlorine or other biocides. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information including the State Pollutant Discharge Elimination

System (SPDES) permit for JAFNPP and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of discharge of chlorine or other

biocides during the renewal term beyond those discussed in the GElS.

* Discharge of sanitary wastes and minor chemical spills. Based on information in the GELS,

the Commission found that

Effects are readily controlled through [National Pollutant Discharge Elimination

System] NPDES permit and periodic modifications, if needed, and are not

expected to be a problem during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information including the SPDES permit for JAFNPP and public

comments on the draft SEIS. Therefore, the NRC staff concludes that there would be no

impacts of discharges of sanitary wastes and minor chemical spills during the renewal term

beyond those discussed in the GELS.

* Discharge of other metals in wastewater. Based on information in the GElS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

January 2008 4-5 NUREG-1437, Supplement 31 I
Environmental Impacts of Operation

evaluation of other available information including the SPDES permit for JAFNPP and public

comments on the draft SEIS. Therefore, the NRC staff concludes that there would be no

impacts of discharges of other metals in wastewater during the renewal term beyond those

discussed in the GELS.

" 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC 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 GElS.

" Accumulation of contaminants in sediments or biota. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of available information and public comments on the draft SEIS. Therefore, the

NRC 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 GElS.

" Entrainment of phytoplankton and zooplankton. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of entrainment of phytoplankton

and zooplankton during the renewal term beyond those discussed in the GELS.

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" Cold shock. Based on information in the GEIS, the Commission found that

Cold shock has been satisfactorily mitigated at operating nuclear plants with

once-through 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information including JAFNPP's original CWA Section 316(a)

demonstration report (NYPA 1976) and public comments on the draft SEIS. Therefore, the

NRC staff concludes that there would be no impacts of cold shock during the renewal term

beyond those discussed in the GELS.

" Thermal plume barrier to migrating fish. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information including JAFNPP's original CWA Section 316(a)

demonstration report (NYPA 1976) and public comments on the draft SEIS. Therefore, the

NRC staff concludes that there would be no impacts of thermal plume barriers to migrating

fish during the renewal term beyond those discussed in the GELS.

* Distribution of aquatic organisms. Based on information in the GELS, the Commission found

that

Thermal discharge may have localized effects but is not expected to affect the

larger geographical distribution of aquatic organisms.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information including JAFNPP's original CWA Section 316(a)

demonstration report (NYPA 1976) and public comments on the draft SEIS. Therefore, the

NRC staff concludes that there would be no impacts on distribution of aquatic organisms

during the renewal term beyond those discussed in the GElS.

January 2008 4-7 NUREG-1437, Supplement 31 1
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" Premature emergence of aquatic insects. Based on information in the GELS, the

Commission found that

Premature emergence has been found to be a localized effect at some operating

nuclear power plants but has not been a problem and is not expected to be a

problem during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of premature emergence of aquatic

insects during the renewal term beyond those discussed in the GELS.

" Gas supersaturation (gas bubble disease). Based on information in the GELS, 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.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no impacts of gas supersaturation during the renewal

term beyond those discussed in the GELS.

" Low dissolved oxygen in the discharge. Based on information in the GELS, the Commission

found that

Low dissolved oxygen has been a concern at one nuclear power plant with a

once-through 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of low dissolved oxygen during the

renewal term beyond those discussed in the GELS.

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" Losses from predation, parasitism, and disease among organisms exposed to sublethal

stresses. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of losses from predation,

parasitism, and disease among organisms exposed to sublethal stresses during the renewal

term beyond those discussed in the GELS.

" Stimulation of nuisance organisms. Based on information in the GElS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of stimulation of nuisance

organisms during the renewal term beyond those discussed in the GElS.

" Microbiological or-ganisms (occupational health). Based on information in the GELS, the

Commission found that

Occupational health impacts are expected to be controlled by continued

application of accepted industrial hygiene practices to minimize worker

exposures.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of microbiological organisms during

the renewal term beyond those discussed in the GElS.

January 2008 4-9 NUREG-1437, Supplement 31 1
Environmental Impacts of Operation

* Noise. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of noise during the renewal term

beyond those discussed in the GELS.

The Category 2 issues related to cooling system operation during the renewal term that are

applicable to JAFNPP are listed in Table 4-2 and discussed in the sections that follow.

Table 4-2. Category 2 Issues Applicable to the Operation of the JAFNPP

Cooling System During the Renewal Term

ISSUES-10 CFR Part 51, Subpart A, GElS 10 CFR 51.53(c)(3)(ii) SEIS

Appendix B, Table B-1 Section Subparagraph 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 power plants with once-through cooling systems, the entrainment of fish and shellfish in

early life stages into cooling water systems associated with nuclear power plants is considered

a Category 2 issue that requires site-specific assessment before license renewal. Applicable

Category 2 issues are listed in Table 4-2. The NRC staff reviewed the JAFNPP ER (Entergy

2006a) and related documents, including Entergy's Proposal for Information Collection dated

January 31, 2006 (Entergy 2006b), and the 2004 SPDES Biological Monitoring Report for the

James A. FitzPatrick Nuclear Power Plant, dated May 2005 (EA 2005), and visited the JAFNPP

site several times. The NRC staff also reviewed the applicant's most current SPDES permit

(NY-0020109) and the accompanying fact sheet, the State of New York Best Technology

Available (BTA) determination letter dated March 1, 1996, and the State of New York 401

Certification letter dated November 5, 1975 (Entergy 2006a).

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

I NUREG-1437, Supplement 31 4-10 January 2008
Environmental Impacts of Operation

water intake structures reflect the best available technology 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

available technology. Licensees may be required as part of the NPDES 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 Phase II

Rule has been suspended and compliance with the rule is based on EPA's best professional

judgment.

JAFNPP has a once-through heat dissipation system that uses water from Lake Ontario for

condenser cooling and service water. Under normal operating conditions at JAFNPP, all three

circulating water pumps are operating to produce a combined intake flow of 352,600 gallons per

minute (gpm) (518 million gallons per day [gpd]), as measured through the condensers. Three

50 percent-capacity service water pumps also draw water from the intake bay, downstream of

the traveling screens, at a rate of 36,000 gpm (52 million gpd). At the submerged offshore

intake structure, water velocity at the outer face of the bar racks is 1.2 feet per second (ft/s) and

1.6 ft/s through the bar racks. Once in the D-shaped intake tunnel, average water velocity is

4.7 ft/s. Reinforced invert paving and wire mesh-reinforced gunite lining provides for hydraulic

smoothness throughout the tunnel (Entergy 2006a). Once in the screenwell-pumphouse intake

bay, the water flows through the trash bars and traveling screens. Each traveling screen has a

design capacity flow rate of 125,000 gpm and design approach velocity of 1.2 ft/s; the screens

rotate from 10 to 20 feet per minute (ft/m). Screen wash pumps operate periodically and in

response to pressure differentials to remove debris from the traveling screens. Screen wash

pumps take water from the service water system and spray the traveling screens at a rate of

720 gpm/screen, at a minimum of 80 pounds per square inch (lb/in 2) gauge pressure (Entergy

2006b).

The maximum allowable temperature rise of the cooling system water through the main

condenser is 32.4 degrees Fahrenheit (OF) above ambient water temperature (Entergy 2006a).

Organisms entrained in the intake flow that are small enough to pass through the vertical

traveling screens enter the station cooling system where they are subjected to thermal stress

and mechanical and hydraulic forces. In a study of the Haddam Neck Plant, a nuclear power

plant with a once-through cooling system that formerly operated on the Connecticut River, it was

found that mechanical damage is the main cause of entrainment mortality, while thermal shock

was responsible for only about 20 percent of mortality (Marcy 2004). While some entrainment

survival may occur, for this review NRC staff conservatively assumed that 100 percent of

entrained organisms die.

During periods of cold weather, when inlet water temperature is below 450F, warm discharge

water is recirculated from the discharge tunnel into the intake bay by a tempering gate-the

amount of raw intake water is reduced approximately 16 to 18 percent during this mode of

operation. Total entrainment loss is directly proportional to both the density of ichthyoplankton

in the nearfield source of water and to the raw water intake flow during the period of

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consideration. JAFNPP has compiled monthly actual intake flow data from January 1998

through July 2005, and actual pumping rates have historically been lower than plant-design

flows. This is because the circulating water pumps operate at various head differentials and the

plant's cooling water needs vary in response to reduced generation, environmental conditions,

and periodic maintenance outages. This historical operation is considered representative of the

current and expected future cooling water intake flow operations at JAFNPP (Entergy 2006b).

In the late 1960s, the New York Power Authority (NYPA) and the Niagara Mohawk Power

Corporation conducted ecological studies in the nearshore vicinity of the Nine Mile Point

promontory to determine the potential impact of power plants on the Lake Ontario aquatic

ecosystem. Part of this program included weekly monitoring of the distribution of fish eggs and

larvae at contour depths from 20 to 100 ft, from April through December of 1973 through 1979.

Egg collections consisted primarily of alewife (Alosa pseudoharengus) and rainbow smelt

(Osmerus mordax); larval samples were also dominated by alewife. Alewife were the primary

component of the ichthyoplankton community, followed by rainbow smelt, white perch (Morone

americana), sculpin (Cottidae spp.), and tessellated darter (Etheostoma olmstedi). Low

numbers of other species were collected, including yellow perch (Perca flaverscens), rainbow

smelt, and Morone spp., but overall, the data indicated that the Nine Mile Point vicinity was a

significant spawning habitat for only alewife and rainbow smelt. A study of species composition

and distribution of fish larvae collected in the Nine Mile Point area published in 1975 concluded

the area is not a desirable spawning or nursery habitat because of extensive nearshore wave

action and unsuitable bedrock and rubble substrate (TI 1979).

The ecological studies revealed that the temporal distribution of eggs and larvae in the Nine

Mile Point vicinity is generally characterized by two spawning groups: those that spawn from

winter to early spring (burbot [Lota Iota], Coregonus spp., rainbow smelt, and yellow perch), and

those that spawn from late spring through summer (alewife, white perch, and carp [Cyprinus

carpio]). Subsequently, eggs and larvae from these groups are most abundant from April to

June and from July to August, respectively. Eggs and larvae were most abundant at the 20-ft

contour depth; their numbers were lower at deeper contours (TI 1979).

Because Nine Mile Point Nuclear Station (NMPNS) Unit 1 is so close to JAFNPP and NMPNS's

intake and cooling systems are similar to JAFNPP's, entrainment data from NMPNS were

reviewed for this analysis. NMPNS sampled water directly from the Unit 1 intake forebay once

or twice a month from 1973 through 1978. The species composition of the intake water was

generally very similar to the species composition of Lake Ontario, except that intake water

ichthyoplankton densities were lower than lake water ichthyoplankton densities and species that

occurred at low frequencies in the lake samples were not detected at all in the intake water

samples. Temporal abundance was also similar (Entergy 2006b).

The first year NMPNS Unit 1 entrainment data were collected when both NMPNS Unit 1 and

JAFNPP were operating was 1976. Burbot and Coregonus spp. were most frequently entrained

at NMPNS Unit 1 in the early spring, rainbow smelt in mid-spring, and alewife in late spring and

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summer. Abundance of entrained fish was highest in the summer due to the large alewife

population: weekly average alewife densities were 0 to 34.4 eggs per cubic meter (M3 ) and 0 to

0.5 larvae per M3 . Weekly average rainbow smelt densities were 0 to 0.15 eggs per M3 and 0 to

0.02 larvae per M3 . Conservatively assuming the maximum weekly density and that NMPNS

Unit 1 was running at full capacity, weekly entrainment totals were estimated at 350 million

alewife eggs and 4.9 million alewife larvae; and 1.5 million rainbow smelt eggs and 205,000

rainbow smelt larvae. For perspective, these numbers were extrapolated using alewife

fecundity data and compared to the estimated standing stock number of alewife in the U.S.

waters of Lake Ontario (12.56 billion in 1976), resulting in an estimated loss of approximately

0.0002 percent of alewife population females and 0.014 percent alewife larvae. An estimated

0.00001 percent female rainbow smelt population loss was calculated for egg entrainment and

0.025 percent for larval entrainment (Entergy 2006b).

A 1997 NMPNS entrainment study showed much lower total entrainment numbers than the

1977 data: corrected for flow into the plant, an estimated 86.6 million ichthyoplankton were

entrained from April through August at NMPNS Unit 1. Alewife represented 90.7 percent of the

ichthyoplankton entrainment, followed by the tessellated darter at 4.2 percent (3.6 million) and

the threespine stickleback (Gasterosteus aculeatus) at 2.8 percent (2.4 million). Rainbow smelt

accounted for only 0.1 percent. The difference in the 1977 and 1997 entrainment numbers is

likely due primarily to the difference in abundance of alewife and rainbow smelt lake-wide

(Entergy 2006b). Both alewife and rainbow smelt populations throughout Lake Ontario have

likely declined due to excessive salmonid predation and lake-wide food web changes that

occurred primarily in response to Dreissenid spp. invasion and lake water quality improvements

(Mills et al. 2003).

The status of Lake Ontario's alewife population is of particular concern. As prey fish for stocked

salmonids, alewife support the lake's major sport fisheries, which are strong contributors to local

economies. To put the 1997 alewife entrainment data into perspective, NRC staff calculated

alewife fecundity loss in a similar manner to the 1976 calculations above. In performing these

calculations, NRC used a 1997 Lake Ontario (U.S. waters) alewife standing stock population of

941,300,000 (Entergy 2006a); assumed a 1:1 sex ratio; assumed an alewife average lifetime

fecundity of 26,272 eggs (Entergy 2006b); and conservatively assumed the entire percentage of

entrained alewife ichthyoplankton was composed of eggs. In estimating total entrainment for all

of 1997, NRC staff also conservatively assumed that the April to August rate of entrainment was

maintained throughout the entire year, which due to the spawning habits of alewife and lower

intake flows during winter months, is highly unlikely. By multiplying the number of female

alewife by fecundity and dividing this number by entrainment, the estimated loss of population

fecundity in the U.S. waters of Lake Ontario caused by NMPNS Unit 1 was 0.0015 percent for

1997. This minor percentage of ichthyoplankton loss would not result in a detectable impact on

the lake's alewife population.

On January 24, 2006, JAFNPP applied for a renewal of its New York SPDES permit, which was

scheduled to expire on August 1, 2006. Until this renewal permit is finalized, the existing permit

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Environmental Impacts of Operation

(NY-0020109) remains in effect. As stated earlier, no entrainment studies have been completed

by JAFNPP since the original Nine Mile Point promontory baseline ecology studies done in the

1970s. On July 9, 2004, the EPA published a final rule that addressed cooling water intake

structures at existing facilities with flow levels that exceed a minimum threshold value of 50

million gpd (316(b) Phase II regulations). Owners of such facilities that did not utilize closed

cycle cooling were provided a number of compliance alternatives to demonstrate compliance

with the new regulations. The demonstration is implemented through the NPDES permitting

program. To demonstrate compliance, JAFNPP is currently conducting a one-year entrainment

sampling program that was approved by the New York State Department of Environmental

Conservation (NYSDEC). The program began in April 2006 and will conclude in March 2007. A

second year of entrainment sampling may occur to verify the 2006 results. An entrainment

survival study may also be undertaken if it appears there is a high survival rate for

ichthyoplankton. The goal of the entrainment program is to estimate the seasonal and annual

total abundance of fish eggs and larvae that flow into the cooling water intake system. The goal

of the survival study, if undertaken, would be to determine the effects the cooling water intake

system has on entrained organisms (Entergy 2006b). The majority of fish, fish larvae, and eggs

are not expected to survive passage through the JAFNPP cooling system, as cooling water

temperature rises up to 32.40 F above ambient intake water temperature and organisms would

experience significant hydrodynamic changes and mechanic forces (AEC 1973).

In the 2006 JAFNPP entrainment sampling program, intake water was sampled weekly from

April to November of 2006 and every two weeks from November 2006 through March 2007.

One daytime and one nighttime sample were taken on the same day each week from the

forebay at two sample depths, 14 ft and 20 ft below the water surface, for a total of 160

entrainment samples. The sampling was conducted using a pump with 3-inch (in.) intake and

discharge hoses and a plankton net suspended in a tank. Each sample was at least 100 m3

(26,417 gallons) as calibrated by an in-line flow meter (Entergy 2006b). As of the date of

publication of this SEIS, the results of the one year study are not available. Nevertheless, the

NRC staff did review preliminary (unpublished) study data to support this analysis.

In reviewing the historical entrainment data at NMPNS Unit 1, it appears that the primary factor

influencing entrainment rates is the abundance of eggs and larvae in the water near the plant

intake. Potential entrainment losses at JAFNPP, when compared to the standing stock of the

lake's fish species, are not likely to adversely affect the Lake Ontario fish community. A study

on entrainment and impingement rates at a nuclear power plant located on the Upper

Mississippi River (LaJeone and Monzingo 2000) concluded that naturally occurring

environmental conditions have a greater effect on fish populations than plant operations, and

fluctuations in the annual impingement and entrainment numbers reflect primarily river

conditions and fish populations' responses to them. The estimated 0.0015 percent fecundity

loss of the female alewife in Lake Ontario (U.S. waters) standing stock from NMPNS Unit 1 in

1997 was a conservative estimate of the potential entrainment impact that is possible at

JAFNPP and would not result in a detectable impact on the alewife fishery. Until the results of

the 2006 entrainment study are finalized, there can be no definitive quantification of the current

entrainment impacts on Lake Ontario at JAFNPP. However, based on the results of historical

I NUREG-1437, Supplement 31 4-14 January 2008
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entrainment studies, similar operations at NMPNS Unit 1, and no change in operations at

JAFNPP during the license renewal term, there is no evidence to suggest that past, current, or

future entrainment of eggs, larvae, or juvenile forms of these species would destabilize or

noticeably alter any important attribute of Lake Ontario. The preliminary data from the recent

entrainment study at JAFNPP supports this conclusion. Therefore, the NRC staff has

determined that the potential impacts of entrainment of fish and shellfish by JAFNPP during the

20-year renewal period would be SMALL. The NRC staff identified potential mitigation

measures, including closed cycle cooling, and derating the facility and scheduling outages

during historic periods of high ichthyoplankton density. However, the NRC staff concluded that

none of the mitigation measures considered would eliminate adverse entrainment impacts and

would not reduce the significance level below SMALL. Under the provisions of the state NPDES

permitting program, however, NYSDEC may impose further restrictions or require modifications

to the cooling system to reduce the impact of entrainment.

4.1.2 Impingement of Fish and Shellfish

For plants with once-through cooling systems, the impingement of fish and shellfish on debris

screens associated with plant cooling systems is considered a Category 2 issue, which requires

a site-specific assessment before license renewal. The NRC staff reviewed the JAFNPP ER

(Entergy 2006a) and related documents, including Entergy's Proposal for Information Collection

dated January 31, 2006 (Entergy 2006b), and the 2004 SPDES Biological Monitoring Report for

the James A. FitzPatrick Nuclear Power Plant, dated May 2005 (EA 2005), and visited the

JAFNPP site several times. The NRC staff also reviewed the applicant's most current SPDES

permit (NY-0020109) and the accompanying fact sheet, the State of New York Best Technology

Available (BTA) determination letter dated March 1, 1996, and the 401 Certification letter dated

November 5, 1975 (Entergy 2006a).

Section 316(b) of the CWA, requires that the location, design, construction, and capacity of

cooling water intake structures reflect the best available technology for minimizing adverse

environmental impacts (33 U.S.C. 1326). Impingement 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 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

Phase II Rule has been suspended and compliance with the rule is based on EPA's best

professional judgment.

JAFNPP does not have a fish retum system for fish impinged on the traveling screens.

Therefore, impinged fish are not returned to the lake and do not survive (Entergy 2006a).

JAFNPP operates a high-frequency/high-amplitude acoustic fish deterrence system (FDS)

annually from April through October that is specifically designed to deter alewife. Historical

studies have shown that 97 percent of alewife impingement occurs during these months (Ross

and Dunning 1996). The JAFNPP FDS consists of nine overlapping, wide-beam, highfrequency transducers mounted on top of the submerged intake structure. The transducers

January 2008 4-15 NUREG-1437, Supplement 31 I
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produce an array sound field, ensuring 3600 coverage from the water surface to the lake bottom

and extending at least 33 ft from the perimeter of the intake structure. Per the JAFNPP SPDES

permit, the FDS is dewinterized and operational by the first week of April each year and is

removed from service (winterized) each October. The FDS was put into long-term operation in

1998 (EA 2005).

Impingement of fish was monitored at JAFNPP annually from 1976 to 1997 and again in 2004.

In issuing the most recent SPDES permit, NYSDEC determined that JAFNPP's impingement

database was adequate to support a transition to a long-term, less intensive monitoring

program, requiring the plant to conduct only one, one-year impingement program during the

five-year permit period from 2001 to 2006 (Entergy 2006a). The results of JAFNPP

impingement monitoring from 1976 to 1997 are summarized in Table 4-3. Generally, alewife

and rainbow smelt account for the majority of individuals impinged from 1976 through 1994.

The threespine stickleback is the third-most frequently impinged species, but larger

impingement numbers did not occur until 1995 to 1997 and 2004 with one anomaly year in 1978

(EA 2005). These impingement trends reflect lake-wide conditions. The abundance of alewife

and rainbow smelt has declined over the past decade due to ecological stressors, invasive

species, and increasing predatory pressure; concurrently the threespine stickleback population

has greatly increased. Fish population studies of Lake Ontario suggest that the lake pelagic fish

community may be undergoing a change (Schaner and Prindle 2004).

The 2004 SPDES Biological Monitoring Report for JAFNPP also suggests that weather

conditions can dramatically affect impingement rates, with other studies supporting this

observation. An exceptionally high number of alewife were impinged in 1976 (almost 4 million

fish) as compared to the rest of the data from 1977 to 1997 and 2004; the latter data is more

representative than the 1976 data of impingement abundance observed during the past two

decades. Although annual die-offs of alewife occur every year, a catastrophic die-off of alewife

occurred in the winter and early spring of 1977, resulting in an estimated 60 to 75 percent loss

of the adult alewife population, explaining the high 1976 impingement numbers (EA 2005).

The alewife was the most common species taken during the entire 22-year impingement study.

Rainbow smelt were most abundant in 1978, 1979, 1987, 1990, and 1992, and typically the

second-most abundant species impinged each year. Comparing impingement rates to lakewide population estimates for U.S. waters, in 1997 alewife and rainbow smelt impingement at

JAFNPP represented only 0.0015 percent and 0.0012 percent of the populations, respectively

(EA 2005).

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Table 4-3. Results of Impingement Monitoring of Selected Species at JAFNPP from 1976

through 1997

Fish Impingement, Percentage of 1976-1997(a)Pecnaeo Fish Impinged,

Total Range of Annual Average Over

Number Fish Number of Fish 22-Year Period

Scientific Name Common Name Impinged Impinged(b) (1976-1997)

Alosa alewife 7,546,639 1,312-3,916,717 58.73%

pseudoharengus

Cottus spp. sculpins 35,232 747-4,916 0.27%

Dorosoma cepedianum gizzard shad 116,239 26-26,173 0.90%

Etheostoma olmstedi tessellated darter 34,423 68-6,708 0.27%

Gasterosteus threespine 3,114,822 78-1,392,763 24.24%

aculeatus stickleback

Morone americana white perch 69,669 53-13,353 0.54%

Notropis atherinoides spottail shiner 82,245 282-11,683 0.64%

Osmerus mordax rainbow smelt 1,780,388 1,527-282,373 13.86%

Percopsis trout perch 70,120 180-12,183 0.55%

omiscomaycus

Source: EA 2005

(a) Number of fish taken on the intake screens, corrected for flow.

(b) Lowest and highest annual impingement rates.

The alewife is of special concern because Lake Ontario's valuable salmonid sport fishery is

primarily dependent on this single-forage species. Alewife populations show high mortality rates

after especially cold winters and have historically experienced mass die-offs. Alewife are easily

stressed and during peak population levels, stress can result in large spring die-offs.

Susceptibility to cold is related to inadequate lipid reserves, and in spring, alewife are in a

weakened condition due to lack of forage in the winter and by the stress related to spawning

(Eshenroder at al. 1995). They are affected by both osmotic stress associated with life in fresh

water and exposure to fluctuating water temperatures when they move to inshore waters (e.g.,

exposure to colder waters during an upwelling event can cause the fish to die). Stressed fish

are more susceptible to impingement because they exhibit little or no motility and are passively

drawn into the intake (UWSGI 2002).

This alewife population instability has been compounded by excessive salmonid predation-in

1991 the predator demand was estimated to be equal to the total prey production, and modeling

I

January 2008 4-17 NUREG-1437, Supplement 31 I
Environmental Impacts of Operation

suggested that a die-off of more than 25 percent above average would cause the alewife

population to crash (Stewart and Schaner 2002). U.S. Geological Survey (USGS) data indicate

that Lake Ontario alewife numbers are moderate and have remained stable since the mid1990s. Abundance is considerably less than it was in the 1980s, but as discussed in Section

2.2.5 of this SEIS, the alewife population decrease was likely caused by excessive salmonid

predation and changes in the Lake Ontario food web (O'Gorman et al. 2005). In response to

the decreasing alewife population, New York State and Ontario, Canada, both reduced their

salmonid stocking programs in 1993. However, in 1997 the stocking rates were increased

slightly again. Additionally, since 1997, increasing natural reproduction of Chinook salmon

(Oncorhynchus tshawytscha) has been observed, so predation pressure continues on the

alewife (Schaner and Prindle 2004). O'Gorman et al. (2005) report that although the 2004

alewife population in the U.S. waters of Lake Ontario is well below the long-term (19-year)

average, the wet weight condition of adult alewife in the fall of 2004 was higher than in any year

since 1980, indicating the population was more in balance with the productivity of Lake Ontario.

This recent population stabilization may be occurring because of fewer individuals to compete

for food, a switch in alewife diet from the zebra muscle-decimated amphipod Diporeia sp. to the

possum shrimp (Mysis sp.), and the population's subsequent movement toward deeper lake

waters, where they avoid the intake structure altogether (EA 2005).

Rainbow smelt impingement rates appear to be influenced by meteorological conditions (strong

winds and increased wave action) and lake-wide population changes due to cannibalism of

young smelt by adult smelt and salmonid predation on adult smelt (EA 2005). Similar to the

alewife population, changes in the Lake Ontario ecosystem brought on by improvements in

water quality and invasive species have altered the distribution of the rainbow smelt population

away from the area of the intake structure and to deeper portions of the Lake where food is

more plentiful (Mills et al. 2005).

Impingement abundance of other fish, including white perch, yellow perch, smallmouth bass

(Micropterus dolomieu), and salmonids also appears to fluctuate with regard to population

dynamics and short-term meteorological events that influence the impingement process.

Results from the JAFNPP impingement monitoring program in 1976 to 1997 and 2004 indicate

that late fall and winter storms tend to increase impingement of the young-of-year fish for these

species. During the 2004 impingement monitoring, no rare, threatened, or endangered species

were collected at JAFNPP (EA 2005). Data from the 2004 impingement monitoring are

summarized in Table 4-4. Data presented in Table 4-4 are actual numbers of fish (including

damaged individuals) collected during 2004 sampling events, corrected for collection

efficiencies. Adjusting these numbers for flow into the plant, the total impingement at JAFNPP

in 2004 was 230,534 organisms, of which threespine stickleback comprised 87.44 percent of

total impingement, alewife 7.29 percent, rainbow smelt 0.66 percent, smallmouth bass 0.48

percent, white perch 0.21 percent, yellow perch 0.17 percent, salmonids 0.06 percent, and all

others species 3.69 percent (EA 2005).

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Table 4-4. Results of Impingement Monitoring of Selected Species at JAFNPP, 2004

Fish Impingement, 2004(a)

Total Number Average Monthly Percentage of All

of Fish Number of Fish Fish Impinged,

Scientific Name Common Name Impinged Impinged 2004(b)

Alosa pseudoharengus alewife 9,203 767 20.64%

Cottus spp. sculpins 432 36 0.97%

Dorosoma cepedianum gizzard shad 35 3 0.08%

Etheostoma olmstedi tessellated darter 18 2 0.04%

Gasterosteus aculeatus threespine 32,543 2,712 72.98%

stickleback

Morone americana white perch 71 6 0.16%

Notropis atherinoides spottail shiner 118 10 0.26%

Osmerus mordax rainbow smelt 315 26 0.71%

Percopsis trout perch 275 23 0.62%

omiscomaycus

Source: EA 2005

(a) Total number of fish taken on the intake screens during 2004, corrected for collection efficiencies.

(b) 44,593 organisms (including damaged individuals) collected during 2004.

The 2004 alewife and rainbow smelt impingement rates comprise just 0.0074 percent and

0.0001 percent of estimated lake-wide populations, respectively, when compared to 2005 lakewide standing stock estimates of alewife and rainbow smelt. These represent very minor losses

to the populations. The 2005 standing stock numbers were estimated by a joint pelagic

planktivore monitoring program conducted by the NYSDEC and the Ontario Ministry of Natural

Resources (OMNR). The NYSDEC/OMNR report indicated that the 2005 alewife population

was the lowest since the bi-national pelagic planktivore monitoring program began in 1997,

making 0.0074 percent a conservative estimate; however, the rainbow smelt population had

increased in 2005 from two previous low years (Schaner and LaPan 2005). Threespine

stickleback is an invasive species that has been prominent in the Lake Ontario ecosystem since

the early 1990s. There is no formal monitoring program conducted for this species, but

monitoring programs for pelagic fish of interest (alewife and rainbow smelt) have noted that

threespine stickleback have been the dominant catch in most lake tows (Schaner and Prindle

2004).

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Since the inception of the JAFNPP impingement monitoring program, a total of 2966 salmonids

(corrected for intake flow and traveling screen efficiencies) have been impinged from 1976

through 1997, and in 2004. In 2005 alone, the NYSDEC salmonid stocking program stocked

3,554,745 salmonids in Lake Ontario and its tributaries (Eckert 2005). OMNR also conducts its

own stocking program. Concentrated stocking efforts began in 1980, with Ontario and New

York limiting stocking to a total of 8 million salmonids per year. In response to the prey fish

population concerns, current combined stocking levels have been maintained between 4 and

5.5 million salmonids per year since 1993 (Mills et al. 2003).

A number of biological, environmental, and meteorological factors may work in concert to

influence yearly variations in impingement species abundance. The recent increase in

threespine stickleback impingements may be partly caused by the lake-wide decrease in alewife

and the dominating presence of zebra mussels. Impingement rates are highest in the spring

and peak in May when approximately 35 percent of all impingement occurs. This corresponds

with fish migrating toward warmer inshore waters to spawn. The timing of the migration may

vary according to meteorological conditions. Impingement rates then begin to fall again in June

as fish migrate back to deeper waters after spawning. Impingement rates once again increase

from October through December, when 21 percent of all impingement occurs. This is thought to

occur because at this time, young-of-year fish, especially alewife and rainbow smelt, grow to a

size that is particularly susceptible to impingement. Certain meteorological conditions, such as

strong westerly and northwesterly winds, wave height, and water temperature, also appear to

influence young-of-year impingement at this time of year (EA 2005).

Other factors impacting impingement include the timing and duration of station outages for

refueling and maintenance. During maintenance or refueling outages, typically only one or two

of the three main circulating water pumps are operational, significantly reducing the flow of lake

water into the plant. The reduced flow through the intake generally results in reduced

impingement. In recent years, plants outages have become less frequent and shorter in

duration due to improvements in plant operational efficiency, so outage reduction effects on

impingement are less than those that occurred in the 1980s and 1990s (EA 2005). Warm

discharge water is also recirculated during periods of cold weather, reducing lake water flow into

the plant. JAFNPP has compiled monthly actual intake flow data from January 1998 through

July 2005, and actual pumping rates have historically been lower than plant-design flows. This

is because the circulating water pumps operate at various head differentials and the plant's

cooling water needs vary in response to reduced generation, environmental conditions, and

periodic maintenance outages. These historical data are considered representative of the

current and expected future cooling water intake flow operations at JAFNPP (Entergy 2006b).

Generally, meteorological conditions that change fish populations appear to have the most

profound effect on impingement rates at JAFNPP. Periodic die-offs of populations occur due to

a combination of climatic conditions and the physical condition of population individuals. As

mentioned above, this was most prominently seen in the winter/spring 1977 alewife die-off: the

alewife impingement rate dropped from 3,916,717 fish in 1976 to 187,305 in 1977 (EA 2005).

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Historically, changes in fish populations around JAFNPP have likely been the result of naturally

occurring fluctuations. When the changes are profound (such as a mass winter die-off of

alewife), they are easily observed in the annual estimates of fish impinged at JAFNPP.

However, when the changes are subtle and over a longer period of time, it is difficult to

differentiate between meteorological conditions and daily plant operations, the two main factors

in fish impingement.

Due to the susceptibility of alewife to be impinged in the intake area, the delicate nature of

alewife, and the strong fright response to high frequency sound that alewife demonstrate, at the

time of JAFNPP's last SPDES permit issuance, NYSDEC determined the FDS installed at

JAFNPP was the best technology available for reducing impingement impacts (Entergy 2006a).

This determination is documented in a letter from the NYSDEC dated March 1, 1996. Testing of

the FDS occurred in spring of 1991 and 1993, and it was shown to reduce alewife impingement

by over 87 percent. Another deterrence system test was conducted in 1997, and preliminary

results confirmed the FDS reduced alewife impingement by 87 percent (EA 2005). The FDS

has only been proven to deter alewife; no studies have been done to document its effectiveness

on other pelagic species. Since the FDS was installed, there have been no significant alewife

impingement events at JAFNPP.

In the JAFNPP Proposal for Information Collection dated January 31, 2006 (Entergy 2006b),

submitted to the NYSDEC to satisfy 316(b) Phase II regulations, JAFNPP proposed to obtain no

new impingement data because a recent annual impingement study had been completed in

2004. Since plant operations will not change significantly, these 2004 impingement rates are

indicative of future impingement rates, and are considered by the NRC staff to be too small to

have any observable impact on the lake-wide populations and biomass. Based on the results of

past impingement studies and the operating history of the JAFNPP intake structure and FDS,

the NRC staff concludes that the potential impacts of impingement for fish and shellfish at

JAFNPP are SMALL. The NRC staff identified potential mitigation measures, including installing

a fish return system, closed cycle cooling, and derating the facility and scheduling plant outages

during historic peak impingement periods. However, the NRC staff concluded that none of the

mitigation measures considered would eliminate adverse impingement impacts and would not

reduce the significance level below SMALL. Under the provisions of the state NPDES

permitting program, however, NYSDEC may impose further restrictions or require modifications

to the cooling system to reduce the impact of impingement.

4.1.3 Heat Shock

Heat shock can be defined as acute thermal stress caused by exposure to a sudden elevation

of water temperature that adversely affects the metabolism and behavior of fish and can lead to

death. Heat shock is most likely to occur when an offline unit returns to service or when a

station has a discharge canal, effectively trapping fish in the flow of the heated discharge from

the plant. For plants with once-through cooling systems, the effects of heat shock are listed as

a Category 2 issue, requiring a plant-specific assessment before license renewal. In the GELS,

January 2008 4-21 NUREG-1437, Supplement 31 I
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the NRC made impacts on fish and shellfish resources resulting from heat shock a Category 2

issue for once-through plants 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. Information to be considered includes (1) the type of cooling system

(whether once-through or cooling pond) and (2) evidence of a CWA Section 316(a) variance or

equivalent State documentation. To perform this evaluation, the NRC staff visited the JAFNPP

site several times, reviewed the JAFNPP ER (Entergy 2006a), reviewed JAFNPP's original

CWA Section 316(a) demonstration report (NYPA 1976), and reviewed JAFNPP's most current

SPDES permit (NY-0020109), which was issued on August 1, 2001, and is in force until a new

permit is issued by NYSDEC (Entergy 2006a).

Section 316(a) of the CWA establishes a process whereby the applicant 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 U.S.C. 1326). The JAFNPP CWA Section 316(a) demonstration was

submitted to the NYSDEC in 1976 by NYPA, the former owner of JAFNPP. The demonstration

was based on pre-operational and post-operational engineering, hydrological, and ecological

data, and concluded that thermal discharge from the plant would not result in any long-term

adverse impacts to the Lake Ontario ecosystem. The JAFNPP CWA Section 316(a)

demonstration followed procedures prescribed by the EPA during meetings between NYPA and

EPA, and as outlined in the draft EPA document, 316(a) Technical Guidance Manual and Guide

for Thermal Effects Sections of Nuclear Facilities Environmental Impact Statements, dated

May 1, 1977 (EPA 1977). The 316(a) demonstration included a description of the plant,

baseline hydrographic characteristics of Lake Ontario and the site, plant thermal discharge

characteristics, a description of the biological community in the Nine Mile Point vicinity and a

selection of representative fish species, and an evaluation of potential impacts of the plant's

thermal discharge. The potential thermal discharge effects were based on thermal tolerance

and behavior data for the representative fish species, field data collected in the vicinity of

JAFNPP, and a review of literature on the effect of thermal discharges. It was concluded that

the multi-port diffuser design of the JAFNPP discharge structure would prevent the thermal

discharge from harming the biological community in the Nine Mile Point vicinity (NYPA 1976).

NYSDEC accepted the conclusions of the 316(a) demonstration in their first issuance of the

JAFNPP SPDES permit containing the CWA Section 316(a) variance specifying alternative

thermal effluent limitations for the plant, and subsequently in renewed permits issued thereafter.

JAFNPP's SPDES permit states that thermal discharge from the plant ensures the "protection

and propagation of a balanced indigenous population of shellfish, fish, and wildlife in Lake

Ontario" and as such, the plant is allowed alternative effluent limitations. These limitations are

included in Part 1, Condition 8 of the plant's SPDES permit and state that the water temperature

at the surface of the lake shall not be raised more than 3°F over the. ambient temperature of the

water, with the exception of a 35-acre (ac) (1.524.6 x 106 ft2) mixing zone from the point of

discharge. To ensure this condition is met, the permit allows a maximum discharge temperature

of 112°F as measured at the discharge outlet in the screenwell-pumphouse, with a maximum

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allowable intake-discharge temperature difference (AT) of 32.40 F. The net addition of heat

rejected to Lake Ontario is limited to 6.00 x 109 British thermal units per hour (BTU/hr) (Entergy

2006a). Total heat rejected to the lake is a function of electrical load-heat rejection increases

with an increase in electrical load. When JAFNPP is operating at full power, the heat rejection

rate is calculated to be 5.714 x 109 BTU/hr (NYPA 1976).

Because of the proximity of NMPNS (3200 ft west of JAFNPP), the U.S. Atomic Energy

Commission (AEC) in its 1973 Final Environmental Statement Related to the Operation of

James A. FitzPatrick Nuclear Power Plant determined that under certain conditions JAFNPP

discharge could exceed New York State thermal criteria (AEC 1973). The JAFNPP SPDES

permit specifies thermal limitations on Outfall 1 discharges to Lake Ontario, which include

circulating cooling water, service water, and intake screen backwash. As such, JAFNPP

conducts a thermal monitoring program consisting of continual discharge temperature and AT

recording, and has proposed mitigation measures, such as flow reductions, should corrective

action be needed to maintain compliance with the New York State thermal criteria. To date, no

additional mitigation measures have been necessary. JAFNPP submits quarterly reports to

NYSDEC that contain information on daily electrical output, water use, and intake and discharge

water temperatures (Entergy 2006a; AEC 1973).

Heat shock to fish is a function of the temperature increase that the fish are subjected to in the

discharge flow area and the residence time of the fish in the heated discharge flow (Fry 1971;

Dean 1973). Cold shock can occur when fish acclimated to warm effluents are abruptly

exposed to very low ambient temperatures. This may occur during plant outages when

discharge flow is lower than during normal operation (NYPA 1976). According to JAFNPP

personnel, to date, there have been no heat or cold shock events during station operation that

have resulted in the immediate distress or acute mortality of fish. If such an event were

observed by JAFNPP personnel, the incident would have to be reported to NYSDEC as a

condition of the SPDES permit (Section 5b[1][iv]) (Entergy 2006a).

The multi-port diffuser design and offshore location of JAFNPP's discharge structure have likely

prevented heat and cold shock events. Analysis of the JAFNPP diffuser design in the 1976

NYPA 316(a) demonstration indicated that the discharge plume (before surfacing) decreases in

AT from 31.5°F to 13.5°F in one second and further decreases to 90F four seconds after

discharge. Additionally, hydrothermal field surveys confirmed the rapid dilution of the thermal

effluent: the 30F isotherm would cover a maximum surface area of 27.5 ac (1196 x 103 ft2), well

within the maximum 35-ac mixing zone allowed in the JAFNPP SPDES permit Section 316(a)

variance (NYPA 1976).

The 316(a) demonstration study reported that voluntary exposure to the heated effluent by

representative fish species would not likely cause mortalities because the velocity of the

discharge stream would not allow fish to maintain themselves long enough in an area where the

discharge water temperature would be lethal. Fish behavior studies have indicated that when

given a range of temperatures, fish demonstrate avoidance responses to unsuitable

temperatures; the offshore, open area location of the JAFNPP discharge structure allows fish to

January 2008 4-23 NUREG-1437, Supplement 31 1
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avoid the heated discharge stream. The design of the multi-port diffuser discharge structure

could entrain fish into the high-velocity discharge jet stream, but it was demonstrated that fish

entrained at the point of discharge would be in safe water temperatures in less than one

second, making plume entrainment mortality unlikely. Regarding cold shock, acclimation to

elevated temperatures is a precondition for cold shock mortality. The diffuser jets at JAFNPP

preclude this acclimation as fish are not able to maintain themselves in the area of heated

discharge. Additionally, during plant outages, because of JAFNPP's proximity to NMPNS

(providing another source of heated discharge) and the location of the discharge structure, cold

shock would not be expected to impact fish in the JAFNPP vicinity (NYPA 1976).

The NRC staff has reviewed the available information, including that provided by the applicant,

visited the site, and reviewed other public sources of information on heat shock. Plant operating

conditions have not changed significantly since the original 316(a) demonstration, and it can

therefore be reasonably concluded that the extent and distribution of JAFNPP's thermal plume

has remained relatively unchanged. The NRC staff evaluated the potential impacts to aquatic

resources due to heat shock during continued operation and determined that thermal impacts

were unlikely because of the design and location of the JAFNPP discharge structure.

Furthermore, there have been no observable impacts related to plant thermal discharges.

Therefore, it is the NRC staffs conclusion that the potential impacts to fish and shellfish due to

heat shock during the renewal term are SMALL. The NRC staff identified potential mitigation

measures, including closed cycle cooling, helper cooling towers, derating the plant, and certain

operational procedures. 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 Lake Ontario.

4.2 Transmission Lines

The JAFNPP ER (Entergy 2006a) describes two 345-kilovolt (kV) and two 115-kV transmission

lines that connect JAFNPP with the transmission system (see Section 2.1.7 of this SEIS for a

description of the transmission lines). Two of the lines, the Edic and the Scriba 345-kV lines,

are within the scope of the license renewal review. Offsite line maintenance for both lines is

accomplished by the lines' owner, NYPA. For the two 345-kV transmission line right-of-ways

(ROWs), NYPA uses a vegetation management plan approved by the New York State Public

Service Commission. NYPA uses an integrated vegetation management computer application,

which employs geographic information system technology. The vegetation management program

is designed to control tall-growing tree species and to enhance the abundance of lower growing

desirable vegetation. Field inventories are conducted annually for the ROW scheduled for

clearing the following year. The inventories and treatment recommendations are reviewed and

approved by the NYPA forestry staff. The majority of clearing is performed using mechanical

methods. Herbicide applications are individually applied to selected plant species by licensed

contractors, and a safe buffer is maintained around wetlands, and stream and river crossings.

A safe buffer is also used around wells and springs that are used for residential water supplies.

Areas where herbicides are used are posted with information regarding the

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chemicals used and when they were applied. Herbicides are not applied on NYPA ROWs using

aerial application methods.

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-I, that are applicable to

transmission lines from JAFNPP are listed in Table 4-5. Entergy stated in the JAFNPP ER that

it was not aware of any new and significant information associated with the renewal of the

JAFNPP OL. The NRC staff has not identified any new and significant information during its

independent review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process,

and its evaluation of other available information and public comments on the draft SEIS.

Therefore, the NRC staff concludes that there are no impacts related to these issues beyond

those discussed in the GELS. For all of those issues, the NRC staff concluded in the GElS that

the impacts would be SMALL, and additional plant-specific mitigation measures are not likely to

be sufficiently beneficial to be warranted.

Table 4-5. Category 1 Issues Applicable to the JAFNPP Transmission

Lines During the Renewal Term

ISSUES-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Section

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 4.5.6.3

crops, honeybees, wildlife, livestock)

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

Onsite land use 4.5.3

Power line right of way 4.5.3

A brief description of the NRC staff's review and GElS conclusions, as codified in 10 CFR

Part 51, Subpart A, Appendix B, Table B-i, for each of these issues follows:

* Power line ROW management (cuttingj and herbicide application). Based on information in

the GELS, the Commission found that

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The impacts of right-of-way maintenance on wildlife are expected to be of small

significance at all sites.

The NRC staff has not identified any new and significant information during: its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other information and public comments on the draft SEIS. Therefore, the NRC

staff concludes that there would be no impacts of power line ROW maintenance during the

renewal term beyond those discussed in the GElS.

Bird collisions with power lines. Based on information in the GELS, the Commission found

that

Impacts are expected to be of small significance at all sites.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other information and public comments on the draft SEIS. Therefore, the NRC

staff concludes that there would be no impacts of bird collisions with power lines during the

renewal term beyond those discussed in the GELS.

" Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, honeybees,

wildlife, livestock). Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other information and public comments on the draft SEIS. Therefore, the NRC

staff concludes that there would be no impacts of electromagnetic fields on flora and fauna

during the renewal term beyond those discussed in the GELS.

" Floodplains and wetland on power line ROW. Based on information in the GELS, the

Commission found that

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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other information and public comments on the draft SEIS. Therefore, the NRC

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staff concludes that there would be no impacts of power line ROWs on floodplains and

wetlands during the renewal term beyond those discussed in the GELS.

" Air quality effects of transmission lines. Based on the information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other information and public comments on the draft SEIS. Therefore, the NRC

staff concludes that there would be no air quality impacts of transmission lines during the

renewal term beyond those discussed in the GELS.

Onsite land use. Based on the information in the GELS, the Commission found that

Projected onsite 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other information and public comments on the draft SEIS. Therefore, the NRC

staff concludes that there would be no onsite land-use impacts during the renewal term

beyond those discussed in the GELS.

" Power line ROW. Based on information in the GELS, the Commission found that

Ongoing use of power line right of ways would continue with no change in

restrictions. The effects of these restrictions are of small significance.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other information and public comments on the draft SEIS. Therefore, the NRC

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.

One issue related to transmission lines is a Category 2 issue, and another issue related to

transmission lines is being treated as a Category 2 issue. These issues are listed in Table 4-6

and are discussed in Sections 4.2.1 and 4.2.2.

January 2008 4-27 NUREG-1437, Supplement 31 1
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Table 4-6. Category 2 and Uncategorized Issues Applicable to the

JAFNPP Transmission Lines During the Renewal Term

ISSUES-10 CFR Part 51, Subpart A, GElS 10 CFR 51.53(c)(3)(ii) SEIS

Appendix B, Table B-1 Section Subparagraph Section

HUMAN HEALTH

Electromagnetic fields-acute effects 4.5.4.1 H 4.2.1

(electric shock)

Electromagnetic fields-chronic effects 4.5.4.2 NA 4.2.2

4.2.1 Electromagnetic Fields-Acute Effects

Based on the GELS, 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 GELS, the NRC staff found that without a review of the conformance of each nuclear plant

transmission line with National Electrical Safety Code (NESC®) 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.

As described in Section 2.1.7 of this SEIS, two single-circuit 345-kV lines exiting the switchyard

connect JAFNPP to the transmission grid. One line, approximately 70 miles (mi) long, connects

to the transmission system at NYPA's Edic Substation. The other line, approximately 4900 ft

(0.9 mi) long, connects to the transmission system at the National Grid Scriba Substation

located on the NMPNS site. Although JAFNPP owns the lines within the site property boundary,

lines exiting the property boundary are owned and maintained by NYPA. These two lines were

evaluated concerning adherence to the NESC® steady-state limit (Entergy 2006a).

As stated above, the NESC® specifies minimum vertical clearances to the ground for electric

lines. For electric lines operating at voltages exceeding 98-kV alternating current (AC) to

ground, the clearance provided must limit the steady-state current due to electrostatic effects to

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5 milliamperes (mA) if the largest anticipated vehicle were short-circuited to ground. The largest

vehicle anticipated under JAFNPP's 345-kV lines is a tractor-trailer that is 65 ft long and13.5 ft

tall, parked along a roadway. The 5-mA design standard limits electric fields within the ROW to

7 to 8 kV/meter (Entergy 2006a).

According to the NYPA Transmission Engineering Department, the two 345-kV transmission

lines at JAFNPP are operated and maintained in a manner consistent with the design criteria

listed in the GELS, Section 4.5.4.1. Specifically, these lines meet a more stringent induced

shock standard than the 5-mA design criterion of NESC® (1981). The State of New York Public

Service Commission (NYPSC) requires that transmission lines in New York be designed so that

the short-circuit current to ground, produced from the largest anticipated vehicle or object, is

limited to less than 4.5 mA. This allows no more than 7.0 kV/meter electric field levels on the

ROWs. In 1991, NYPA demonstrated to the NYPSC that its transmission lines, including the

two 345-kV lines associated with JAFNPP, do not exceed safety levels of 6.5 kV/meter for

electric fields or 4.5 mA for induced shocks (Entergy 2006a).

Nuisance shocks are further controlled through NYPA's annual routine inspection of ROWs for

land intrusion, along with its program of informing landowners about induced shock hazards and

assisting them with grounding any metallic structures in or near a ROW.

Entergy's assessment concluded that electric shock is of SMALL significance for the JAFNPP

345-kV transmission lines (Entergy 2006a). The lines are operated within their original design

specifications, the ROWs are routinely monitored for any land-use changes, and NYPA has

demonstrated that the 345-kV transmission lines meet the NESC® (1981) requirements for

preventing induced shock hazards. Due to the small significance of the issue, mitigation

measures such as installing warning signs at road crossings or increasing clearances are not

warranted.

Based on a review of the available information, including that provided by the applicant (Entergy

2006a), the NRC staffs site audit, the scoping process, and an evaluation of other information,

the staff concludes that the potential impacts for electric shock during the renewal term are

SMALL. The NRC staff identified potential mitigation measures, including installing road signs

at road crossings and increased clearances. However, the NRC staff concluded that none of

the mitigation measures considered would be beneficial enough to reduce the significance of

the adverse impacts to people.

4.2.2 Electromagnetic Fields-Chronic Effects

In the GELS, the chronic effects of 60-Hz electromagnetic fields from power lines are 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

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research through the U.S. Department of Energy (DOE). The report by NIEHS (1999) contains

the following conclusion which is supported by recently published Environmental Health Criteria

Monograph No. 238 (WHO 2007):

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 NRC staff to change its position with respect to the

chronic effects of electromagnetic fields. Footnote 4 to Table B-1 of 10 CFR Part 51, Subpart A,

Appendix B, states

If in the future, the Commission finds that, contrary to current indications, a consensus has

been reached by appropriate Federal health agencies that there are adverse health effects

from electromagnetic fields, the Commission will require applicants to submit plant-specific

reviews of those health effects as part of their license renewal applications. Until such time,

applicants for license renewal are not required to submit information on this issue.

The NRC staff considers the GElS finding of "Uncertain" still appropriate and will continue 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

JAFNPP in regard to radiological impacts are listed in Table 4-7. Entergy stated in its ER

(Entergy 2006a) that it is not aware of any new and significant information associated with the

renewal of the JAFNPP OL. The NRC staff has not identified any new and significant

information during its independent review of the JAFNPP ER, the site audit, the scoping

process, and its evaluation of other available information and public comments on the draft

SEIS. Therefore, the NRC staff concludes that there are no impacts related to these issues

beyond those discussed in the GELS. For these issues, the NRC staff concluded in the GElS

that the impacts are SMALL, and additional plant-specific mitigation measures are not likely to

be sufficiently beneficial to be warranted.

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Table 4-7. Category 1 Issues Applicable to Radiological Impacts

of Normal Operations During the Renewal Term

ISSUES-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Section

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 NRC staff's review and the GElS conclusions, as codified in 10 CFR

Part 51, Subpart A, Appendix B, Table B-1, for each of these issues follows:

" Radiation exposures to public (license renewal term). Based on information in the GElS, the

Commission found that

Radiation doses to the public will continue at current levels associated with

normal operations.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of radiation exposures to the public

during the renewal term beyond those discussed in the GELS.

" Occupational radiation exposures (license renewal term). Based on information in the

GELS, 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 well below regulatory limits.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts of occupational radiation exposures

during the renewal term beyond those discussed in the GELS.

There are no Category 2 issues related to radiological impacts of routine operations.

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4.4 Socioeconomic Impacts of Plant Operations During the License Renewal Term

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 4-8. JAFNPP stated in its

ER (Entergy 2006a) that it is not aware of any new and significant information associated with

the renewal of the JAFNPP OL. The NRC staff has not identified any new and significant

information during its independent review of the JAFNPP ER, the site audit, the scoping

process, and its evaluation of other available information and public comments on the draft

SEIS. Therefore, the NRC staff concludes that there are no impacts related to these issues

beyond those discussed in the GELS. For these issues, the NRC staff concluded in the GElS

that the impacts are SMALL, and additional plant-specific mitigation measures are not likely to

be sufficiently beneficial to be warranted.

Table 4-8. Category 1 Issues Applicable to Socioeconomics During the Renewal Term

ISSUES-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections

SOCIOECONOMICS

Public services: public safety, social services, and tourism and 4.7.3; 4.7.3.3;

recreation 4.7.3.4; 47.3.6

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 NRC staffs review and the GElS conclusions, as codified in Table B-1

of 10 CFR Part 51, Subpart A, Appendix B, for each of these issues follows:

* Public services: public safety, social services, and tourism and recreation. Based on

information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts on public safety, social services,

and tourism and recreation during the renewal term beyond those discussed in the GELS.

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" Public services: education (license renewal term). Based on information in the GELS, the

Commission found that

Only impacts of small significance are expected.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no impacts on education during the renewal

term beyond those discussed in the GElS.

" Aesthetic impacts (license renewal term). Based on information in the GELS, the

Commission found that

No significant impacts are expected during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no aesthetic impacts during the renewal term

beyond those discussed in the GELS.

" 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there would be no aesthetic impacts of transmission lines

during the renewal term beyond those discussed in the GELS.

Table 4-9 lists the Category 2 socioeconomic issues, which require plant-specific analysis, and

environmental justice, which was not addressed in the GEIS.

January 2008 4-33 NUREG-1437, Supplement 31 1
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Table 4-9. Category 2 Issues Applicable to Socioeconomics

and Environmental Justice During the Renewal Term

10 CFR

ISSUES-10 CFR Part 51, Subpart A, 51.53(c)(3)(ii) SEIS

Appendix B, Table B-1 GEIS Section Subparagraph Section

SOCIOECONOMICS

Housing impacts 4.7.1 I 4.4.1

Public services: public utilities 4.7.3.5 I 4.4.2

Offsite 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 GElS and the

associated revision to 10 CFR Part 51 were prepared. Therefore, environmental justice must be

addressed in the NRC staffs environmental impact statement.

4.4.1 Housing Impacts

In determining housing impacts, the applicant chose to follow Appendix C of the GElS, which

presents a population characterization method that is based on two factors, sparseness and

proximity (GELS, Section C.1.4). Sparseness measures population density within 20 mi of the

site, and proximity measures population density and city size within 50 mi. Each factor has

categories of density and size (GElS, Table C.1). A matrix is used to rank the population

category as low, medium, or high (GELS, Figure C.1).

In 2000, approximately 109,440 persons lived within a 20-mi radius of JAFNPP (Entergy

2006a), which equates to a population density of 87 persons per square mile (mi2). This density

translates to Category 3 (60 to 120 persons per mi2 or fewer than 60 persons per mi2 with at

least one community of 25,000 or more persons within 20 mi) using the GElS sparseness factor.

At the same time, there were approximately 914,668 persons living within a 50-mi radius of the

2 plant, for a density of 117 persons per mi . The Syracuse MSA, located within 50 mi of the site,

had a total population in 2000 of 732,117. Therefore, JAFNPP falls into Category 3 (one or

more cities with 100,000 or more persons and fewer than 190 persons per mi within 50 mi)

using the GElS proximity factor. A Category 3 value indicates that JAFNPP is in a mediumdensity population area (NRC 1996).

NUREG-1437, Supplement 31 4-34 January 2008
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Refurbishment activities and continued operations could result in housing impacts due to

increased staffing. However, there are no major refurbishment activities required for JAFNPP

license renewal. Therefore, there would be no refurbishment-related impacts to area housing.

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability

are expected to be of small significance at plants located in a medium-density population area

where growth-control measures are not in effect. Oswego County is not subject to growthcontrol measures that would limit housing development, and Entergy does not anticipate a need

for additional full-time workers during the license renewal period.

Since Entergy has no plans to add employees to support plant operations during the license

renewal period, there would be no increase in demand for housing in the vicinity of the JAFNPP

site. Therefore, there would be no housing impacts during the license renewal period and no

mitigation would be required.

4.4.2 Public Services: Public Utility Impacts

Impacts on public utility services are considered SMALL if there is little or no change in the

ability of the system to respond to demand and thus there is no need to add capital facilities.

Impacts are considered MODERATE if service capabilities are overtaxed during periods of peak

demand. Impacts are considered LARGE if services (e.g., water, sewer) are substantially

degraded and additional capacity is needed to meet ongoing demand. The GElS 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.

Analysis of impacts on the public water supply system considered both plant demand and plantrelated population growth. Section 2.1.8.1 of this SEIS describes the JAFNPP permitted

withdrawal rate and actual use of water. The Oswego Water System (OWS) provides potable

water to JAFNPP (OCDPCD 1997). Current plant usage averages 137,500 gpd with no

restrictions on supply. The OWS serves approximately 23,950 customers in the City of Oswego

and towns of Minetto, Scriba, and Volney. The water plant obtains its water from Lake Ontario

and has an allowable withdrawal allocation of approximately 62.5 million gpd. The full design

capacity of the water plant is 20.1 million gpd, although 8 million gpd is reserved for Sithe

Energies, Inc., with the remaining 12 million gpd available for other industrial, residential, and

commercial customers.

Since Entergy has no plans to add employees to support plant operations during the license

renewal period, there would be no increase in demand for public water. Therefore, there would

be no impacts to public water supply during the license renewal period and no mitigation would

be required.

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4.4.3 Offsite Land Use

Offsite land use during the license renewal term is a Category 2 issue (10 CFR 51, Subpart A,

Appendix B, Table B-i). 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 GElS 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.

Tax revenue can affect land use because it enables local jurisdictions to provide the public

services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of

the GElS 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, taxdriven 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 GElS states that if tax

payments by the plant owner are less than 10 percent of the taxing jurisdiction's 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 land-use 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.

4.4.3.1 Population-Related Impacts

Since Entergy has no plans to add employees to support plant operations during the license

renewal period; there would be no change in land use conditions in the vicinity of the JAFNPP

site. Therefore, there would be no population-related land use impacts during the license

renewal period and no mitigation would be required.

I NUREG-1437, Supplement 31 4-36 January 2008
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4.4.3.2 Tax-Revenue-Related Impacts

JAFNPP is assessed annual property taxes by Oswego County, the Town of Scriba, and Mexico

Central Schools. Property taxes paid to Oswego County and the Town of Scriba fund such

services as transportation, education, public health, and public safety.

Entergy has entered into an agreement with Oswego County, the Town of Scriba, and the

Mexico Central Schools regarding property taxes paid to those entities for JAFNPP. The

agreement stipulates that Entergy, instead of paying property taxes for JAFNPP based on the

assessed value of the plant, will make standardized annual payments in lieu of taxes to the

taxing entities.

Since Entergy has indicated that there would be no major plant refurbishment or license

renewal-related construction activities necessary to support the continued operation of the

JAFNPP beyond the end of the existing operating license term during the license renewal

period, there would be no increase in the assessed value of JAFNPP and annual payments to

the Town of Scriba, the Mexico Central Schools, and Oswego County would remain constant

throughout the license renewal period. Based on this information, there would be no tax

revenue-related land-use impacts during the license-renewal period and no mitigation would be

required.

4.4.4 Public Services: Transportation Impacts

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

Since Entergy has no plans to add employees to support plant operations during the license

renewal period, there would be no change in traffic volume and levels of service on roadways in

the vicinity of the JAFNPP site. Therefore, there would be no transportation impacts during the

license renewal period and no mitigation would be required.

4.4.5 Historic and Archaeological Resources

The National Historic Preservation Act of 1966 (NHPA), as amended, requires Federal agencies

to take into account the potential effects of their undertakings on historic properties. The

historic-review process mandated by Section 106 of the NHPA is outlined in regulations issued

January 2008 4-37 NUREG-1437, Supplement 31 1
Environmental Impacts of Operation

by the Advisory Council on Historic Preservation in 36 CFR Part 800. The renewal of an OL for

a nuclear power plant is an undertaking that could possibly affect either known or potential

historic properties that may be located on or near the plant site. In accordance with the

provisions of the NHPA, the NRC is required to make a reasonable effort to identify historic

properties in the areas of potential effect. If no historic properties are present or affected, the

NRC is required to notify the State Historic Preservation Office (SHPO) 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.

As discussed in Section 2.2.9.2 of this SEIS, Entergy contacted the New York State Office of

Parks, Recreation, and Historic Preservation (NYSHPO) on February 9, 2006, regarding

preparation of its application for the license renewal of JAFNPP (Entergy 2006a). In

accordance with 36 CFR 800.8(c), the NRC contacted the NYSHPO (NRC 2006b), the Advisory

Council on Historic Preservation (NRC 2006c), and the appropriate Federally recognized Native

American Tribes with current and historical ties to the region on September 15, 2006.

On December 4, 2006, NRC staff conducted a search of the NYSHPO files for the region

around JAFNPP. Although no prehistoric or historic archaeological sites have been recorded on

the JAFNPP property or along the associated transmission line corridors, literature reviews,

surveys, and sensitivity assessments of the JAFNPP site demonstrate there is a potential for

historic and archaeological resources on undisturbed portions of the site. The potential exists

for prehistoric sites to be found in and around the kettle ponds and associated wetland areas.

Early maps of the JAFNPP site indicate that a number of structures, most from the nineteenth

century, existed on the JAFNPP site prior to construction. Most of these structures today

consist of foundations and have probable associated historic artifact scatters. Prehistoric

cultural resources could also be present in the relatively undisturbed southern and eastern

portions of the JAFNPP site next to kettle ponds. A walk-over of selected undeveloped portions

of the JAFNPP site by NRC staff confirmed the existence of historic resources on the plant site.

Camp Oswego (also known as Camp Drum Anti-Aircraft Artillery Firing Range) was established

during World War II immediately west of JAFNPP on property that is now occupied by Nine Mile

Point Nuclear Station (USGS 1955). The camp operated well into the 1950s as a summer

training base and closed sometime after 1956. The Niagara-Mohawk Electric Company later

purchased the land for construction of the Nine Mile Point Nuclear Station.

Continued operations at JAFNPP during the renewal term would likely protect any

archaeological sites present within the JAFNPP site boundary by protecting the site from

development and providing secured access. However, because there is the potential for

cultural resources to be present at the site, the applicant should take care during normal

operations and maintenance activities related to operations not to inadvertently affect cultural

resources. To avoid such adverse impacts, environmental review procedures have been put in

place at JAFNPP regarding undertakings that involve land-disturbing construction or operational

activities in undisturbed areas. Entergy has no plans to alter current operations during the

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license renewal period. Additionally, Entergy states that any maintenance activities necessary

to support license renewal would be limited to previously disturbed areas onsite. There is no

planned expansion of the existing facilities and there are no planned refurbishment activities to

support license renewal (Entergy 2006a).

Based on the NRC staffs review of NYSHPO files, archaeological reviews, surveys,

assessments, and other information, the NRC staff concludes that the potential impacts on

historic and archaeological resources during the license renewal term would be SMALL. This

conclusion is based on the following: (1) no new ground disturbance or refurbishment activities

would occur during the renewal period, (2) the applicant understands that archaeological and

historic resources could be present at the JAFNPP site, and (3) the applicant has administrative

controls in place to ensure that if cultural resources are found at JAFNPP, they will be protected.

The NRC staff has determined that the impact of license renewal on historic and archaeological

resources would be SMALL, and additional mitigation is not warranted.

4.4.6 Environmental Justice

Under Executive Order 12898 (59 FR 7629), Federal agencies are responsible for identifying

and addressing potential disproportionately high and adverse human health and environmental

impacts on minority and low-income populations. Although the Executive Order is not

mandatory for independent agencies such as the NRC, the NRC has voluntarily committed to

undertake environmental justice reviews. In 2004, the Commission issued a Policy Statement

on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions

(NRC 2004a).

The Council of Environmental Quality (CEQ) provides the following information in Environmental

Justice: Guidance Under the National Environmental Policy Act (1997):

Disproportionately High and Adverse Human Health Effects. Adverse health effects are

measured in risks and rates that could result in latent cancer fatalities, as well as other fatal

or nonfatal adverse impacts on human health. Adverse health effects may include bodily

impairment, infirmity, illness, or death. Disproportionately high and adverse human health

effects occur when the risk or rate of exposure to an environmental hazard for a minority or

low-income population is significant (as defined by NEPA [National Environmental Policy

Act]) and appreciably exceeds the risk or exposure rate for the general population or for

another appropriate comparison group (CEQ 1997).

Disproportionately High and Adverse Environmental Effects. A disproportionately high

environmental impact that is significant (as defined by NEPA) refers to an impact or risk of

an impact on the natural or physical environment in a low-income or minority community that

appreciably exceeds the environmental impact on the larger community. Such effects may

include ecological, cultural, human health, economic, or social impacts. An adverse

environmental impact is an impact that is determined to be both harmful and significant (as

January 2008 4-39 NUREG-1437, Supplement 31 I
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defined by NEPA). In assessing cultural and aesthetic environmental impacts, impacts that

uniquely affect geographically dislocated or dispersed minority or low-income populations or

American Indian tribes are considered (CEQ 1997).

The environmental justice analysis assesses the potential for disproportionately high and

adverse human health or environmental effects on minority and low-income populations that

could result from the operation of JAFNPP during the renewal term. In assessing the impacts,

the following CEQ (1997) definitions of minority individuals and populations and low-income

population were used:

* Minority individuals. Individuals who identify themselves as members of the following

population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black or

African American, Native Hawaiian or Other Pacific Islander, or two or more races meaning

individuals who identified themselves on a Census form as being a member of two or more

races, for example, Hispanic and Asian.

* Minority populations. Minority populations are identified when (1) the minority population of

an affected area exceeds 50 percent or (2) the minority population percentage of the

affected area is meaningfully greater than the minority population percentage in the general

population or other appropriate unit of geographic analysis.

" Low-income population. Low-income populations in an affected area are identified with the

annual statistical poverty thresholds from the Census Bureau's Current Population Reports,

Series PB60, on Income and Poverty.

4.4.6.1 Minority Population in 2000

According to 2000 census data, 11.5 percent of the population (approximately 109,350

individuals) residing with a 50-mi radius of JAFNPP were minority individuals. The largest

minority group was Black or African American (57,308 or 6 percent), followed by Hispanic or

Latino (10,034 or about 1 percent). About 3.5 percent of Oswego County were minorities, with

Hispanics the largest minority group (1.3 percent). Hispanics resided throughout the 50-mi

radius, but most were in Jefferson County (USCB 2006).

Census block groups with minority populations exceeding 20 percent were considered minority

block groups. Based on 2000 census data, Figure 4-1 shows minority block groups within a

50-mi radius of JAFNPP in which more than 20 percent of the block group population is minority

(USCB 2006).

4.4.6.2 Low-Income Population in 2000

According to 2000 census data, approximately 45,007 individuals (approximately 4.7 percent)

residing within a 50-mi radius of JAFNPP were identified as living below the Federal poverty

threshold. The 1999 Federal poverty threshold was $17,029 for a family of four. The median

I NUREG-1437, Supplement 31 4-40 January 2008
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Key to features

Major cities and towns Major 'hlghways 0 5 10

. 2505-4593, NativeAmerican Land

* 4594-7053 Canada

* 7054- 17954 = Block groups meeting NRC minority critena

@ 17955 - 28574: =.County Boundades

* 28575 - 147306

20 30 40 50

Miles

Figure 4-1. Minority Block Groups in 2000 within a 50-mi Radius of JAFNPP*(USCB 2006).

January 2008 4-41 NUREG-1437, Supplement 31 I
Environmental Impacts of Operation

household income for New York in 1999 was $43,393, while 14.6 percent of the state population

was determined to be living below the 1999 Federal poverty threshold.

Oswego County had one of the lowest median incomes ($36,598) and the highest percentage

(14 percent) of individuals living below the poverty level when compared to the other counties in

the area. Conversely, Onondaga County had one of the highest median incomes ($40,847) and

the lowest percentage (7.3 percent) of individuals living below the poverty level when compared

to other counties in the area.

Census block groups were considered low-income block groups if the percentage of the

population living below the Federal poverty threshold exceeded 14 percent. Based on 2000

Census data, Figure 4-2 shows low-income block groups within a 50-mi radius of JAFNPP

(USCB 2006).

4.4.6.3 Analysis of Impacts

Consistent with the impact analysis for the public and occupational health and safety, the

affected populations are defined as minority and low-income populations who reside within a

50-mi radius of JAFNPP. Based on the analysis of impacts for other resource areas, NRC

expects no high and adverse impacts from the operation of JAFNPP during the renewal term.

However, if impacts occur, NRC expects the impacts to affect all populations in the area equally.

NRC also analyzed the risk of radiological exposure through the consumption patterns of

special pathway receptors, including subsistence consumption of fish, native vegetation, surface

waters, sediments, and local produce; absorption of contaminants in sediments through the

skin; and inhalation of plant materials. The special pathway receptors analysis is important to

the environmental justice analysis because consumption patterns may reflect the traditional or

cultural practices of minority and low-income populations in the area.

Subsistence Consumption of Fish and Wildlife

Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and

appropriate, to collect and analyze information on the consumption patterns of populations who

rely principally on fish and/or wildlife for subsistence and to communicate the risks of these

consumption patterns to the public. In Section 2.2.8.5 of this SEIS, NRC considered whether

there were any means for minority or low-income populations to be disproportionately affected

by examining impacts to American Indian, Hispanic, and other traditional lifestyle special

pathway receptors. Special pathways that took into account the levels of contaminants in native

vegetation, crops, soils and sediments, surface water, fish, and game animals on or near the

JAFNPP site were considered.

Entergy has a comprehensive Radiological Environmental Monitoring Program (REMP) at

JAFNPP to assess the impact of site operations on the environment. Samples are collected

from the aquatic and terrestrial pathways applicable to the site. The aquatic pathways include

I NUREG-1437, Supplement 31 4-42 January 2008
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'' 4 A

Key to Features

Major cities and towns Major highways

* 2505 *4593 Natiye American Land

* 4594 - 7053 M .Canada

* 7054 . 17954 Block groups meeting NRC poverny.cnte

* 17955- 28574 • County Boundaries

* 28575- 147306

0 5 10 20 30 40 50

Miles

na N

Figure 4-2. Low-Income Block Groups within a 50-mi Radius of JAFNPP (USCB 2006).

January 2008 4-43 NUREG-1437, Supplement 31 1
Environmental Impacts of Operation

Lake Ontario fish, surface waters and lakeshore sediment. The terrestrial pathways include

airborne particulates and radioiodine, milk, food products and direct radiation. During 2005,

2318 analyses were performed on collected samples of environmental media as part of the

required REMP and showed no significant or measurable radiological impact from JAFNPP

operations. Cesium-137 was detected in one aquatic sample (shoreline sediment) at very low

levels and was attributed to fallout from past weapons testing. The 2005 results for all samples

are consistent with the previous five-year historical results and exhibit no adverse trends

(Entergy 2006c).

The results of the 2005 REMP demonstrate that the routine operation at the JAFNPP site had

no significant or measurable radiological impact on the environment. No elevated radiation

levels were detected in the offsite environment as a result of the hydrogen injection program,

storage of radioactive waste, or implementation of the Independent Spent Fuel Storage

Installation. The results of the REMP continue to demonstrate that the operation of the plant did

not result in a significant measurable dose to a member of the general population or adversely

impact the environment as a result of radiological effluents (Entergy 2006c). REMP continues

to demonstrate that the dose to a member of the public from the operation of JANFPP remains

significantly below the federally required dose limits specified in 10 CFR Part 20, 40 CFR Part 190,

and 10 CFR Part 72.

Based on recent monitoring results, concentrations of contaminants in native vegetation, crops,

soils and sediments, surface water, fish, and game animals in areas surrounding JAFNPP have

been quite low (at or near the threshold of detection) and seldom above background levels

(Entergy 2006c). Consequently, no disproportionately high and adverse human health impacts

would be expected in special pathway receptor populations in the region as a result of

subsistence consumption of fish and wildlife.

4.5 Groundwater Use and Quality

No Category 1 or Category 2 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, are

potentially applicable to JAFNPP groundwater use and quality during the renewal term. The

NRC staff has not identified any new and significant information during its independent review of

:the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its evaluation of other

available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there are no impacts related to these issues beyond those discussed in the

GELS.

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 4-10.

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*Table 4-10. Category 2 Issue Applicable to Threatened

or Endangered Species During the Renewal Term

ISSUE-10 CFR Part 51, Subpart A, GElS 10 CFR 51.53(c)(3)(ii) SEIS

Appendix B, Table B-1 Section Subparagraph Section

THREATENED OR ENDANGERED SPECIES (FOR ALL PLANTS)

Threatened or endangered species 4.1 E 4.6

Entergy contacted the U.S. Fish and Wildlife Service (FWS) on February 9, 2006, regarding

threatened and endangered species at the JAFNPP site (Entergy 2006a). No information

regarding the transmission lines was provided in this letter. In its response letter to Entergy,

dated May 19, 2006, the FWS identified the Federally and State-listed Indiana bat (Myotis

sodalis) and the Federally and State-listed bog turtle (Clemmys muhlenbergii) as potentially

occurring within the transmission corridor (Entergy 2006a). The Indiana bat is known to roost

within 11 mi of the site, and the bog turtle is known to occur within 12 mi of the site. The bog

turtle was also identified in the JAFNPP Final Environmental Statement (FES) for operation as

probably occurring within the marshes that are crossed by JAFNPP to the Edic transmission line

(AEC 1973).

On December 7, 2006, NRC staff met with New York Natural Heritage Program (NYNHP) to

discuss potential impacts of continued operation on State-listed species. The NYNHP found

that upland sandpiper (Bartramia Iongicauda) habitat has been identified near the JAFNPP-toEdic transmission line corridor. No other State-listed species are known to occur near the

JAFNPP facility or transmission corridors. The NYNHP staff have not identified any significant

foreseeable impacts on State-protected species or areas that would result from continued

operation or maintenance activities during the renewal term.

The NRC staff met with the New York Power Authority (NYPA) on December 4, 2006. At this

meeting, the NRC staff was informed that no threatened or endangered species have been

reported by maintenance personnel as occurring in or near the transmission corridor. Corridor

maintenance personnel are trained in identifying endangered species and are expected to take

measures to avoid damage to these species if they are identified within the transmission line

corridor during the renewal period.

This Category 2 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 JAFNPP during the license renewal term. The characteristics and

habitat of threatened or endangered species in the vicinity of the JAFNPP site are discussed in

Sections 2.2.5 and 2.2.6 of this SEIS. The NRC initiated informal consultation with the FWS on

September 19, 2006, to determine which species may be affected by continued operations and

maintenance procedures at the JAFNPP site and the associated transmission lines (NRC

January 2008 4-45 NUREG-1437, Supplement 31 I
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2006d). NRC submitted a Biological Assessment, dated May 21, 2007, to the FWS regarding

the Indiana bat, bog turtle, Eastern massasauga (Sistrurus catenatus catenatus), bald eagle (Haliaeetus leucocephalus), and piping plover (Charadrius melodus). The FWS responded by

letter dated November 15, 2007, with a determination that no further coordination pursuant to

the ESA is required for the bald eagle, Eastern massasauga, or piping plover (FWS 2007a).

The FWS concurred with the NRC's determination that activities associated with plant operation

and transmission line ROW maintenance are not likely to adversely affect the Indiana bat (FWS

2007a). The FWS concurred with the NRC's determination that activities associated with plant

operation are not likely to adversely affect the bog turtle; however, the FWS requested

additional information related to the presence of suitable habitat for the bog turtle along the

transmission ROWs in order to determine if transmission line maintenance activities are likely to

adversely affect the bog turtle (FWS 2007a). Thus, consultation with the FWS is ongoing.

Correspondences related to the Biological Assessment for JAFNPP can be found in Appendix

E.

4.6.1 Aquatic Species

No Federally listed or proposed threatened or endangered aquatic species, with the exception

of transient individuals, are known to exist in the vicinity of JAFNPP or the aquatic habitats

crossed by the transmission lines associated with JAFNPP (FWS 2007b). There are no plans to

conduct refurbishment or construction activities at JAFNPP during the license renewal term

(Entergy 2006a). The NRC staffs conclusion is that there would be no impacts on threatened

and endangered aquatic species from operation of JAFNPP during the renewal term, and

mitigation is therefore not warranted.

4.6.2 Terrestrial Species

Currently, no threatened or endangered species are known as occurring at the JAFNPP site or

within the Edic or Scriba transmission corridors. The State-protected upland sandpiper is

known to occur near the transmission corridor, but no impacts to this species are expected as a

result of continued use or maintenance of the lines. The Federally protected bog turtle and

Indiana bat have the potential to occur at the JAFNPP site.

The NRC staff encourages NYPA to report the existence of any Federally or State-listed

endangered species within or near the transmission corridors to NYSDEC and/or FWS if any

such species are identified during the renewal term. If any evidence of injury or mortality of

migratory birds or threatened or endangered species is seen within the corridor during the

renewal period, NYPA is encouraged to promptly report this to the appropriate wildlife

management agencies. Care should also be taken to ensure that the corridor does not provide

a path for invasive plant species to colonize wetland areas that would not otherwise be

colonized without the corridor. In particular, common reed (Phragmites australis) may colonize

and degrade undocumented bog turtle habitat (FWS 2001). Likewise, transmission corridor

maintenance activities should be conducted in a manner that avoids damage to wetlands within

I NUREG-1437, Supplement 31 4-46 January 2008
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and near the corridor. Maintenance personnel should be aware of the foraging and roosting

needs of Indiana bats, and the removal of standing dead trees and trees harboring Indiana bats

should be avoided during times of the year when bats may be present.

The NRC staff, after discussions with the FWS, found that the Indiana bat and the bog turtle had

the potential to be present on the JAFNPP site or along the Edic and Scriba transmission

corridors. As a result, the NRC staff initiated informal Section 7 consultation under the

Endangered Species Act of 1973 with the FWS for both the Indiana bat and the bog turtle. The

NRC staff has determined that the continued operation of the JAFNPP may affect, but is not

likely to adversely affect, either species. Therefore, the NRC staffs conclusion is that the

potential impacts on Federally protected species of an additional 20 year of JAFNPP operation

would be SMALL. The FWS concurred with the NRC's determination that the operation of the

JAFNPP for an additional 20 years may affect, but is not likely to adversely affect, the Indiana

bat or bog turtle. Although the FWS found that plant operation is unlikely to affect the bog turtle,

the FWS has requested additional information on the presence of suitable habitat for the

species along the transmission line ROWs in order to determine if transmission line

maintenance activities are likely to affect the bog turtle. The NRC staff, in its ongoing

consultation with the FWS, has discussed the FWS's information needs with Entergy and

NYPA.

4.7 Evaluation of New and Potentially Significant Information on Impacts of

Operations During the Renewal Term

The NRC staff has not identified new and significant information on environmental issues listed

in 10 CFR Part 51, Subpart A, Appendix B, Table B-I, related to plant operation during the

renewal term. The NRC staff also determined that information provided during the public

comment period did not identify any new issue that requires site-specific assessment. The NRC

staff reviewed the discussion of environmental impacts associated with operation during the

renewal term in the GElS and has conducted its own independent review, including public

scoping meetings, to identify issues with new and significant information. Processes for

identification and evaluation of new information are described in Section 1.2.2.

4.8 Cumulative Impacts

The NRC staff considered potential cumulative impacts on the environment resulting from the

incremental impact of license renewal when added to other past, present, and reasonably

foreseeable future actions. For the purposes of this analysis, past actions are related to the

resources when JAFNPP was licensed and constructed, present actions are related to the

resources during current operations, and future actions are those that are reasonably

foreseeable through the end of plant operations including the license renewal term. The

January 2008 4-47 NUREG-1437, Supplement 31 I
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geographic area over which past, present, and future actions are assessed is dependent on the

affected resource.

The impacts of the proposed action, license renewal, as described in this chapter of the SEIS,

are combined with other past, present, and reasonably foreseeable future actions regardless of

which agency (Federal or non-Federal) or entity is undertaking the actions. The 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. 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 Aquatic Resources

This section assesses the impacts of the proposed action that relate to the withdrawal and

discharge of lake water by the JAFNPP once-through cooling system, combined with other past,

present, and reasonably foreseeable future actions that occur within the defined geographic

area of Lake Ontario. The geographic area considered for the analysis of cumulative impacts

on aquatic resources focuses on the Nine Mile Point promontory and all of Lake Ontario.

Like the other Great Lakes, Lake Ontario has experienced significant changes in the structure

and functioning of its aquatic ecosystem since the beginning of the Euro-American historical

period, and the cumulative impacts of past actions have resulted in the existing water quality

and aquatic resource conditions near JAFNPP. Lake Ontario is a dynamic aquatic ecosystem

and over the years has evolved in response to ecological stressors such as overfishing,

contaminant releases from industry, cultural eutrophication, land-use changes, and the

introduction of non-native species. These stressors have profoundly changed the species

composition and abundance of organisms from almost all trophic levels lake-wide. It is likely

these changes to Lake Ontario's aquatic resources have not stabilized, and continuing changes

in this complex ecosystem can be expected in the future. Furthermore, potential impacts of

climate change on Lake Ontario cannot be quantified at this time but could include changes in

water temperature, summer stratification, water quality, water level, productivity, and

subsequently, aquatic species composition and abundance (UCS 2003).

Since the 1970s, there have been a number of bi-national management efforts between the

U.S. and Canada to restore the ecological integrity of Lake Ontario, including the creation of the

Great Lakes Fishery Commission (GLFC) and the International Joint Commission, and the

signing of three Great Lakes Water Quality Agreements (Mills et al. 2005). Coordinated

research, monitoring, and assessment efforts at both regional and lake-wide scales by these binational parties are the backbone of management decisions and actions taken by New York

State and Ontario. The most recent agreement took place in 1987 and committed Canada and

the U.S. to developing lake-wide management plans for each of the Great Lakes. Part of this

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effort includes the creation of remedial action plans that address areas of concern and sources

of 11 lake-wide critical pollutants. The plans coordinate localized efforts throughout Lake

Ontario by other groups such as the GLFC and State and Province fishery management

programs (EPA 1998).

While Lake Ontario water quality has vastly improved since the implementation of these binational efforts, the status of its fisheries is still considered to be the most damaged of the five

Great Lakes (USGS 2002). Lake researchers believe there is an incongruity between the goals

of the fishery stakeholders and what Lake Ontario ecosystem can actually support (Stewart et

al. 1999). Furthermore, the colonization of non-native species has so fundamentally changed

the lake's ecosystem that it is unlikely to ever return to its original state. Management of

invasive species at the local level, where resource uses are affected by their presence, is a

major activity by Lake Ontario management groups and a foreseeable continuing focus of these

groups. Contributions to cumulative impacts on Lake Ontario aquatic resources during the

license renewal period can be reasonably expected to be similar to those currently impacting

the lake. However, given the emphasis on lake-wide management plans and remedial action

plans to collaboratively protect and restore the lake and its resources, potential cumulative

effects will likely be carefully assessed and managed over time.

Future use of Lake Ontario likely includes its continued use for water supply, waste water

disposal, cooling water for power plants, shipping, and recreational fishing and boating.

However, with coordinated efforts between State, Federal, and Provincial agencies, and the

above-mentioned bi-national groups, such activities would be monitored and regulated to avoid

adverse impacts to the lake. Additionally, future continued development of the Lake Ontario

watershed may impact the lake's water quality. To counter this stressor, the State of New York

and the Province of Ontario each have comprehensive water resources management and land

development programs. In 2005 Ontario passed the Greenbelt Act, which allowed the creation

of a Greenbelt Plan, protecting approximately 1.8 million acres of environmentally-sensitive and

agricultural land in the Golden Horseshoe region of Ontario from urban development and sprawl

(EPA 2007).

Port Oswego, approximately 6 mi west of JAFNPP, will likely continue to receive cargo ships.

The discharge of ballast water from foreign ships, the primary vector for invasive species, has

become an issue of special importance for lake managers. According to the National Oceanic

and Atmospheric Administration (NOAA), approximately 183 aquatic non-indigenous species

have populated the five Great Lakes and shipping activities are responsible for more than onethird of the aquatic non-indigenous species introductions to the Great Lakes (NOAA 2006, EPA

2007). In response, when ships enter the St. Lawrence Seaway, ballast water is now carefully

monitored by the U.S. Coast Guard, the St. Lawrence Seaway Development Corporation, and

Transport Canada Marine Safety (GLSLSS 2007).

In addition to JAFNPP, four power-generating facilities in the near vicinity of JAFNPP withdraw

water from and discharge water to Lake Ontario-Constellation Energy Group's two-unit Nine

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Mile Point Nuclear Station, immediately west of and adjacent to JAFNPP; Dynegy

Independence Station, a 1064-MW natural gas-fired combined-cycle cogeneration plant

approximately 7 mi southwest of JAFNPP; NRG Energy, Inc., Oswego Steam Station, an oil and

natural gas-fired 1700-MW peaking plant approximately 7.5 mi southwest of JAFNPP; and

Indeck-Oswego Energy Center, a 50-MW gas-turbine combined-cycle cogeneration facility

approximately 6.5 mi southwest of JAFNPP (Dynegy 2007; NRG 2007; Indeck 2007).

Additionally, the R.E. Ginna Nuclear Power Plant (Ginna) is located approximately 40 miles

west-southwest of Oswego, four miles north of Ontario, New York. In May of 2004, Ginna

received a renewed license from the NRC to operate through September 18, 2029 (NRC

2004b). It can be reasonably assumed that these facilities will remain in operation throughout

the JAFNPP license renewal period, and water withdrawals and discharges from these facilities

will be regulated by the NYSDEC under the SPDES permitting and 401 Certification process.

Ontario Power Generation (OPG) also owns and operates a number of power-generating

facilities located on the Canadian shores of Lake Ontario. Pickering A and Pickering B are

nuclear stations just east of Toronto, which have a total output of 3100 MW. Pickering A

consists of four Canadian Deuterium Uranium (CANDU) reactors that were brought online in

1971, of which only Units 1 and 4 are in commercial operation after undergoing a refurbishment

program; Units 2 and 3 are in a safe shutdown state. Pickering B consists of four CANDU

reactors brought online in 1983. OPG is currently conducting a refurbishment study to

determine the feasibility of refurbishing the units at Pickering B in order to extend their operating

lives until 2050-2060. Darling Nuclear Generating Station is a four-unit station located

approximately 44 miles east of Toronto in Clarington, Ontario, with a total output of 3524 MW.

Lennox Generating Station is a 2140-MW duel-fueled oil and natural gas plant located on the

eastern shore of Lake Ontario near Bath, Ontario (OPG 2007). To meet greenhouse gas

emission goals, Ontario government recently announced a plan to close all of its coal-fired

plants by 2014 (CTV 2007).

Additional impacts to the Lake Ontario fishery could occur due to the number of dams on Lake

Ontario tributaries. Brookfield Power operates eight hydroelectric facilities along the Oswego

and Salmon rivers (Brookfield 2006). OPG operates two hydroelectric facilities along the

Niagara River: Adam Beck I (498 MW) and Adam Beck 11 (1488 MW) (OPG 2007). It is

expected that these dams will remain in operation for the duration of the JAFNPP license

renewal period (Brookfield 2006). Dams generally impact fish populations: migration and other

fish movements can be impeded or blocked entirely; quantity, quality, and access to essential

habitat can be affected; and fish may suffer mortality or morbidity while passing through the

turbines or over spillways. Additionally, changes in river discharge regime, water quality, and

primary and secondary productivity caused by the dams may indirectly impact fish populations

(Larinier 2000).

A study of species composition and distribution of fish larvae collected in the Nine Mile Point

nearshore waters published in 1975 concluded the coastline area of Lake Ontario was not a

desirable fish spawning or nursery habitat because of extensive nearshore wave action and

I NUREG-1437, Supplement 31 4-50 January 2008
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unsuitable bedrock and rubble substrate (TI 1979). However, Lake Ontario offshore waters are

important forage areas for the lake's valuable salmonid populations and their prey species, the

alewife and rainbow smelt. Recent studies have suggested that prey fish populations are

moving offshore in response to changes in Lake Ontario's food web, which have occurred

mostly from the introduction of invasive species to the lake in the early 1990s. Alewife in

particular may be moving to deeper waters to escape forage competition from round goby, a

thriving and aggressive Lake Ontario invasive species (USGS 2002).

As discussed in Section 4.1 of this SEIS, the NRC staff found no new and significant information

to indicate that the conclusions regarding any of the Category 1 issues related to the cooling

system at JAFNPP are inconsistent with the GElS (NRC 1996). Assuming no future changes in

station cooling system design or operation, the NRC staff determined that potential losses of

aquatic resources resulting from Category 2 issues during the license renewal term would not

alter any important attribute of Lake Ontario. Furthermore, the NYSDEC may impose additional

restrictions or require modifications to the JAFNPP cooling system to reduce impacts of

entrainment and impingement. The temperature and volume of heated effluent discharged by

JAFNPP to Lake Ontario will continue to be monitored daily by plant personnel and regulated by

the NYSDEC. Additionally, the transmission line ROW maintenance activities in the vicinity of

stream and river crossings employ procedures to minimize erosion and shoreline disturbance

while encouraging vegetative cover. Therefore, impacts from maintenance of transmission lines

associated with JAFNPP would have negligible impact on aquatic resources.

Because Lake Ontario and the Nine Mile Point promontory area are influenced by many

controlling factors, the impact of JAFNPP operations during the license renewal term can only

be qualitatively described with some degree of certainty. The NRC staff concludes, however,

that the SMALL impacts of the JAFNPP cooling system, including entrainment and impingement

of fish and shellfish, heat shock, or any of the cooling system-related Category 1 issues are not

contributing to an overall decline in Lake Ontario water quality or its aquatic resources.

Therefore, the NRC staff concludes that the contribution of impacts associated with the

continued operation of JAFNPP during the renewal period to the cumulative impacts likely to be

experienced in Lake Ontario would be SMALL.

4.8.2 Cumulative Impacts on Terrestrial Resources

This section analyzes past, present, and future actions that could result in adverse cumulative

impacts on terrestrial resources, including wildlife population, upland habitat, wetlands,

floodplains, invasive species, land use, and protected species. For the purposes of this

analysis, the geographic area that encompasses the past, present, and foreseeable future

actions that could contribute to adverse cumulative impacts on terrestrial resources includes

Oswego and Oneida counties, which contain JAFNPP and its associated transmission corridors

that are within the scope of the license renewal review.

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Since the initial construction of JAFNPP and the associated transmission line, there have been

changes in land use and land cover with resulting changes on terrestrial ecosystems both at the

JAFNPP site and along the transmission corridor.

Initial construction of JAFNPP resulted in a change in land use for part of the property from

residential to industrial. Most of the property was left undeveloped and allowed to mature from

secondary growth forests toward old-growth forests, with some areas continuing as wetlands

and ponds (Entergy 2006a). Construction of the transmission lines to the Edic Substation and

the Lighthouse Hill Hydroelectric Station converted a portion of forested land to low shrubby and

herbaceous cover, with resulting changes in the wildlife and plant species present. In some

locations, this caused a forested area to be fragmented. This effect increases habitat for

species that live on forest edges and reduces habitat for species that live in the interior of forest

parcels. Some species, particularly insects and small mammals, have difficulty crossing

transmission corridors (Forman 2001). Other contributors to forest fragmentation in this region

include construction of the transmission lines associated with Nine Mile Point Nuclear Station,

clearing and continued use of land for farming, road construction and maintenance, and

commercial and residential development. In some areas, abandoned farms adjacent to forests

are developing into forests, reducing the impacts of fragmentation. The NRC staff has not

identified any interior species populations that have significantly decreased in the region as a

result of the cumulative impacts of forest fragmentation. The NRC staff has not found any

information to conclude that continued operation or maintenance activities of JAFNPP or the

associated transmission lines would have significant negative impacts on any non-protected

plant or animal species, including interior species populations. Therefore, the NRC staff

believes that the incremental impact of license renewal on terrestrial species and habitat, would

be minor.

NRC staff identified two invasive species in the area that may degrade terrestrial habitat. Their

spread could be accelerated by present and future actions. Common reed is thought to have

been introduced by accident in the late 1700s or early 1800s and has spread across North

America (PCA 2006a). Japanese knotweed (Polygonum cuspidatum) was introduced

intentionally in the U.S. in the late 1800s, probably as an ornamental plant, and has spread

throughout the eastern U.S. (PCA 2006b). These two species are spreading throughout New

York at various rates due to natural and human processes, resulting in habitat loss for native

species (PCA 2006a; 2006b). Both species are spread by the wind; Japanese knotweed

usually grows in streamside areas, while common reed colonizes wetlands (PCA 2006a;

2006b). Open areas like transmission corridors have lower wind resistance than forests

(Forman 2001), potentially allowing wind-borne seeds to spread farther through transmission

corridors than adjacent forests. Construction and maintenance of the transmission line corridor

has created a potential pathway for the spread of these species. Potential preventative and

mitigative measures include surveys and programs for monitoring and removing these species

within the corridor and at the JAFNPP site. Given the ability of these species to drastically alter

local ecosystems, the impacts of the introduction and spread of these species could over time

I NUREG-1437, Supplement 31 4-52 January 2008
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significantly alter the habitat. NRC staff does not believe, however, that the continued operation

and maintenance of the JAFNPP transmission lines contribute significantly to this impact.

The FWS has identified the Federally protected Indiana bat and the bog turtle as potentially

occurring near or within the project area, which includes the Edic and Scriba transmission

corridors. The NRC staff has initiated informal consultation under Section 7 of the Endangered

Species Act of 1972 with the FWS. As part of that consultation the FWS will assess the

cumulative impacts to both species. The NRC staff has determined that continued operation of

the JAFNPP for an additional 20 years may affect but is not likely to adversely affect the Indiana

bat and the bog turtle. By letter dated November 15, 2007, the FWS determined that the Indiana

bat is not likely to be adversely affected by plant operation or transmission line ROW

maintenance (FWS 2007a). The FWS determined that the bog turtle is not likely to be

adversely affected by plant operation; however the FWS has requested additional information to

assess the impacts of transmission line ROW maintenance on the species (FWS 2007a). The

consultation with the FWS is ongoing and may result in additional requirements to ensure

protection of this species.

The NRC staff examined the cumulative effects of forest fragmentation, the spread of invasive

species, and impacts to Federally protected species as they relate to terrestrial resources within

the project area. The NRC staff finds that the impacts could be MODERATE, depending on the

extent of alteration of habitat within the project area due to the spread of invasive Japanese

knotweed and the common reed. However, the NRC staff finds that the direct impacts of

continued operation of JAFNPP and the maintenance of the transmission corridors on terrestrial

resources to be SMALL.

4.8.3 Cumulative Impacts on Human Health

4.8.3. 1 Cumulative Impacts Resulting from Continued Operation of the Transmission Lines

Cumulative impacts resulting from continued operation of the electrical transmission lines

associated with JAFNPP were evaluated to determine whether there was the potential for

adverse cumulative impacts to terrestrial resources, wetlands, floodplains, or aquatic resources.

Other than the existing power transmission lines from JAFNPP and the Nine Mile Point Nuclear

Station, the NRC staff is unaware of any planned activities within the area that could have

additional cumulative impacts. Furthermore, the NRC staff concluded in Section 4.2.1 of this

SEIS that the potential impacts for electric shock from existing transmission lines during the

renewal period are SMALL and that no additional mitigation measures are warranted.

Therefore, the NRC staff has determined that the cumulative impacts of the continued operation

of the JAFNPP transmission lines are also SMALL and that no additional mitigation is

warranted.

January 2008 4-53 NUREG-1437, Supplement 31 I
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4.8.3.2 Cumulative Radiological Impacts

The radiological dose limits for protection of the public and workers were developed by the EPA

and NRC to address the cumulative impact of acute and long-term exposure to radiation and

radioactive material. The dose limits are codified in 40 CFR Part 190 and 10 CFR Part 20. For

the purpose of this analysis, the area within an 80-km (50-mi) radius of the JAFNPP site was

included. The Radiological Environmental Monitoring Program (REMP) conducted by Entergy

in the vicinity of the JAFNPP site measures radiation and radioactive materials from all sources,

including JAFNPP and the adjacent Nine Mile Point Nuclear Station (owned by Constellation

Nuclear). Results for 2001 through 2005 were reviewed as part of the cumulative impacts

assessment. Additionally, in Sections 2.2.7 and 4.3 of this SEIS, the NRC staff concluded that

impacts of radiation exposure to the public and workers (occupational) from operation of

JAFNPP during the renewal term would be SMALL. Therefore, both REMP and the NRC staffs

conclusion considered cumulative impacts. The NRC and the State of New York would regulate

any future actions in the vicinity of the JAFNPP site that could contribute to cumulative

radiological impacts.

4.8.4 Cumulative Socioeconomic Impacts

The continued operation of JAFNPP during the license renewal term would not add to any

socioeconomic impacts beyond those already being experienced in the region. The NRC staff

determined that there would be no impacts on housing, public utilities, public services, and

environmental justice. There would also be no impact on offsite land use because no

refurbishment actions are planned at JAFNPP and no incremental sources of plant-related tax

payments are expected. There are no reasonably foreseeable scenarios that would alter these

conclusions in regard to cumulative impacts. Therefore, the NRC staff concludes that there

would be no cumulative socioeconomic impacts from continued operations at JAFNPP and

mitigation would not be required.

4.8.5 Conclusions Regarding Cumulative Impacts

The NRC staff considered the potential impacts resulting from the operation of JAFNPP during the

license renewal term and other past, present, and future actions in the vicinity of JAFNPP. The

NRC staff's determination is that the potential cumulative impacts resulting from JAFNPP operation

during the license renewal term would generally be SMALL. The NRC will work with the FWS to

determine whether the impacts of license renewal on protected terrestrial species would

significantly add to these impacts.

4.9 Summary of Impacts of Operations During the Renewal Term

Neither JAFNPP 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 JAFNPP operation during

the renewal term. Consequently, the NRC staff concludes that environmental impacts

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associated with these issues are bounded by the impacts described in the GELS. For each of

these issues, the GElS concluded that the impacts would be SMALL and that additional plantspecific 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

JAFNPP operation during the renewal term and for environmental justice and chronic effects of

electromagnetic fields. For these 11 issues and environmental justice, the NRC staff concluded

that the potential environmental impact of renewal term operations of JAFNPP would be of

SMALL significance in the context of the standards set forth in the GElS and that additional

mitigation would not be warranted. In addition, the NRC staff determined that a consensus has

not been reached by appropriate Federal health agencies regarding chronic adverse effects

from electromagnetic fields. Therefore, the NRC staff did not conduct an evaluation of this

issue.

4.10 References

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10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, "Licensing

Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive

Waste, and Reactor-Related Greater Than Class C Waste."

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 Requirements for Normal Operations of Activities in the

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Stewart, T.J., R.E. Lange, S.D. Orsatti, C.P. Schneider, A. Mathers, and M.E. Daniels. 1999.

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ML073241536.

January 2008 4-61 NUREG-1437, Supplement 31 1

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 (GELS), NUREG-1437,

Volumes 1 and 2 (NRC 1996; 1999).(1) The GElS 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 GELS, 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 offsite 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 describes the environmental impacts from postulated accidents that might occur

during the period of extended operation.

5.1 Postulated Plant Accidents

Two classes of accidents are evaluated in the GElS. These are design-basis accidents (DBAs)

and severe accidents, as discussed below.

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

references to the "GELS" include the GElS and Addendum 1.

January 2008 5-1 NUREG-1437, Supplement 31
Postulated Accidents

5.1.1 Design-Basis Accidents

In order to receive 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.

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 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 maximum

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 GElS.

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 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 the James A. FitzPatrick Nuclear Power Plant (JAFNPP), is listed in Table 5-1.

I NUREG-1437, Supplement 31 5-2 January 2008
Postulated Accidents

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 GElS Sections

POSTULATED ACCIDENTS

Design basis accidents 5.3.2; 5.5.1

Based on information in the GELS, 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 FitzPatrick, LLC, and 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 JAFNPP OL. The NRC staff has not identified

any new and significant information during its independent review of the JAFNPP ER (Entergy

2006a), the site audit, the scoping process, and its evaluation of other available information and

public comments on the draft SEIS. Therefore, the NRC staff concludes that there are no

impacts related to design basis accidents beyond those discussed in the GELS.

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, whether or not there are serious offsite

consequences. In the GELS, the NRC staff assessed the impacts of severe accidents during the

license renewal period, 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 have not traditionally been discussed in quantitative terms in FESs and

were not specifically considered for JAFNPP in the GELS. However, in the GElS the NRC staff

did evaluate existing impact assessments performed by 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 GElS contains an 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 to be expected from internally

initiated events. (Amergen Energy, Co. LLC. License Renewal for Oyster Creek Nuclear

station), CLI-07-08, 65 NRC --. (slip op.) (Feb. 26, 2007). Based on the above, the Commission

concludes that the risk from sabotage and beyond design basis earthquakes at 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 severe accidents.

January 2008 5-3 NUREG-1437, Supplement 31 I
Postulated Accidents

Based on information in the GELS, the Commission found that

The probability weighted consequences of atmospheric releases, fallout onto

open bodies of water, releases to ground water, 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 JAFNPP, is

listed in Table 5-2.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006a), the site audit, the scoping process, and its

evaluation of other available information and public comments on the SEIS. Therefore, the

NRC staff concludes that there are no impacts of severe accidents beyond those discussed in

the GELS. However, in accordance with 10 CFR 51.53(c)(3)(ii)(L), the NRC staff has reviewed

severe accident mitigation alternatives (SAMAs) for JAFNPP. The results of its review are

discussed in Section 5.2.

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

ISSUE-10 CFR Part 51, Subpart A, GElS 10 CFR 51.53(c)(3)(ii) SEIS

Appendix B, Table B-1 Sections Subparagraph Section

POSTULATED ACCIDENTS

Severe Accidents 5.3.3; 5.3.3.2; L 5.2

5.3.3.3; 5.3.3.4;

5.3.3.5; 5.4; 5.5.2

5.2 Severe Accident Mitigation Alternatives

Section 51.53(c)(3)(ii)(L) requires that license renewal applicants consider alternatives to

mitigate severe accidents if the NRC 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

JAFNPP; therefore, the remainder of Chapter 5 addresses those alternatives.

I NUREG-1437, Supplement 31 5-4 January 2008
Postulated Accidents

5.2.1 Introduction

This section presents a summary of the SAMA evaluation for JAFNPP conducted by Entergy as

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 Pacific

Northwest National Laboratory. The entire evaluation for JAFNPP is presented in Appendix G.

The SAMA evaluation for JAFNPP was conducted with a four-step approach. In the first step

Entergy quantified the level of risk associated with potential reactor accidents using the plantspecific probabilistic safety assessment (PSA) and other risk models.

In the second step Entergy examined the major risk contributors and identified possible ways

(SAMAs) of reducing that risk. Common ways of reducing risk are changes to components,

systems, procedures, and training. Entergy initially identified 293 potential SAMAs for JAFNPP.

Entergy screened out 230 SAMAs from further consideration because they are not applicable at

JAFNPP due to design differences, have already been implemented at JAFNPP, or are

addressed by a similar SAMA. The remaining 63 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, based on further consideration of

potentially cost-beneficial SAMAs at other plants, Entergy identified one additional potentially

cost-beneficial SAMA (Entergy 2006b).

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.

5.2.2 Estimate of Risk

Entergy submitted an assessment of SAMAs for JAFNPP as part of the ER (Entergy 2006a).

This assessment was based on the most recent JAFNPP PSA available at that time, a plantspecific offsite consequence analysis performed using the MELCOR Accident Consequence

Code System 2 (MACCS2) computer program, and insights from the JAFNPP Individual Plant

Examination (IPE) (NYPA 1991) and Individual Plant Examination of External Events (IPEEE)

(NYPA 1996).

January 2008 5-5 NUREG-1437, Supplement 31 1
Postulated Accidents

The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is

approximately 2.74 x 10-6 per year. This CDF is based on the risk assessment for internallyinitiated events. Entergy did not include the contribution to risk from external events within the

JAFNPP 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 4. The breakdown of CDF by initiating event is provided in Table 5-3.

As shown in Table 5-3, events initiated by station blackout (SBO) and transients are the

dominant contributors to the CDF. Anticipated transient without scram (ATWS) sequences are

not significant contributors to the CDF.

Table 5-3. JAFNPP Core Damage Frequency

Percent

CDF Contribution to

Initiating Event (per year) CDF

Station Blackout 1.27 x 10- 6 46

Transients with loss of containment heat removal 7.78 x 10-7 28

Transients with loss of all emergency core cooling 2.66 x 10-7 10

system (ECCS) injection

Anticipated transient without scram 1.38 x 10-7 5

Loss of a 4.16kv alternate current (AC) safeguard bus 1.18 x 10-7 5

Loss of both direct current (DC) divisions 9.55 x 10-8 3

Loss of coolant accident (LOCAs) 2.83 x 10-8 1

Loss of a division of DC power 2.60 x 10-8 1

Relay room flooding 2.53 x 10-8 1

Total CDF (from internal events) 2.74 x 10-6 100

Entergy estimated the dose to the population within 50 mi of the JAFNPP site to be

approximately 0.0163 person-Sv (1.63 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 24 hours following event initiation) and the early

time frame (0 to 24 hours following event initiation) dominate the population dose risk at

JAFNPP, contributing about equally to the population dose risk.

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

I

I NUREG-1437, Supplement 31 5-6 January 2008
Postulated Accidents

for candidate SAMAs. Accordingly, the NRC staff based its assessment of offsite risk on the

CDFs and offsite doses reported by Entergy.

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

Population Dose

(Person-Rem(a) Percent

Containment Release Mode Per Year) Contribution

Late Containment Failure 0.87 53

Early Containment Failure 0.76 47

Intact Containment negligible negligible

Total 1.63 100

(a) One person-rem = 0.01 person-Sv

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 293 potential risk-reducing

improvements (SAMAs) to plant components, systems, procedures and training.

Entergy removed 230 SAMAs from further consideration because they are not applicable at

JAFNPP due to design differences, have already been implemented at JAFNPP, or are

addressed by a similar SAMA. A detailed cost-benefit analysis was performed for each of the

63 remaining SAMAs.

The NRC staff concludes that Entergy used a systematic and comprehensive process for

identifying potential plant improvements for JAFNPP, and that the set of potential plant

improvements identified by Entergy is reasonably comprehensive and, therefore, acceptable.

5.2.4 Evaluation of Risk Reduction and Costs of Improvements

Entergy evaluated the risk-reduction potential of the remaining 63 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 63 candidate SAMAs through the application of

engineering judgment, 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.

January 2008 5-7 NUREG-1437, Supplement 31 I
Postulated Accidents

The NRC 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 generally conservative (i.e., the estimated risk reduction is similar to or

somewhat higher than what would actually be realized). Accordingly, the NRC staff based its

estimates of averted risk for the various SAMAs on Entergy's risk reduction estimates.

The NRC staff reviewed the basis for the applicant's cost estimates. For certain improvements,

the NRC 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

I operating reactors and advanced light-water reactors. The NRC staff found the cost estimates

to be consistent with estimates provided in support of other plants' analyses.

I The NRC staff concludes that the risk reduction and the cost estimates provided by Entergy are

sufficient and appropriate for use in the SAMA evaluation.

5.2.5 Cost-Benefit Comparison

The cost-benefit analysis performed by Entergy was based primarily on NUREG/BR-01 84 (NRC

1997) and was conducted 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, 2006b).

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:

* SAMA 26 - provide additional DC battery capacity to ensure longer battery capability

during the SBO event, which would extend high pressure coolant injection (HPCI)/

reactor core isolation cooling (RCIC) operability and allow more time for AC power

recovery.

" SAMA 30 - modify plant equipment to provide 16-hour SBO injection to improve

capability to cope with longer SBO scenarios.

" SAMA 36 - modify plant equipment to extend DC power availability in an SBO event,

which would extend HPCI/RCIC operability and allow more time for AC power recovery.

* SAMA 61 - modify plant procedures to allow use of a portable power supply for battery

chargers, which would improve the availability of the DC power system.

* SAMA 62 - modify plant procedures to open the doors of the emergency diesel

generator (EDG) buildings upon receipt of a high temperature alarm, which improves the

reliability of the EDGs following high temperatures in the EDG buildings.

I NUREG-1437, Supplement 31 5-8 January 2008
Postulated Accidents

In supplemental information to the ER, Entergy provided a revised assessment based on a

separate accounting of uncertainties (Entergy 2006b). The revised assessment resulted in

identification of the same potentially cost-beneficial SAMAs. However, based on further

consideration of potentially cost-beneficial SAMAs at other plants, Entergy identified one

additional potentially cost-beneficial SAMA (Entergy 2006b). This alternative involves use of a

portable generator (to power battery chargers) to extend the coping time in loss of AC power

events.

The NRC 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 NRC 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 multiplier to account for potential benefits in external events.

Based on its review of the SAMA analysis, the NRC 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 NRC 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, "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."

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

Renewal of Operating Licenses for Nuclear Power Plants."

January 2008 5-9 NUREG-1437, Supplement 31 I
Postulated Accidents

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, "Reactor Site

Criteria."

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006a.

James A. FitzPatrick Nuclear Power Plant --- License Renewal Application, Appendix E:

Applicant's Environmental Report, Operating License Renewal Stage. Lycoming, New York.

Accessible at ML062160557.

Entergy Nuclear Operations, Inc. (Entergy). 2006b. Letter from P. Dietrich, Entergy, to NRC

Document Control Desk. Subject: "Entergy Nuclear Operations, Inc., James A. FitzPatrick

Nuclear Power Plant, Docket No. 50-333, License No. DPR-59, License Renewal Application,

Amendment 1," JAFP-06-0167, Lycoming, New York, dated December 6, 2006. Accessible at

ML063480624.

New York Power Authority (NYPA). 1991. "James A. FitzPatrick Nuclear Power Plant Docket

No. 50-333, Individual Plant Examination,"(JPN-91-048), September 1991.

New. York Power Authority (NYPA). 1996. "James A. FitzPatrick Nuclear Power Plant Individual

Plant Examination for External Events," (JAF-RPT-MISC-0221 1), June 1996, Revision 0.

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

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation

Handbook. NUREG/BR-01 84, Washington, D.C.

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

for License Renewal of Nuclear Plants. NUREG-1437, Volume 1, Addendum 1, Washington,

D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S.

Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C.

I NUREG-1437, Supplement 31 5-10 January 2008
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 (GELS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999).(1) The GElS 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 GElS, 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 offsite radiological impacts from the fuel cycle and from

high-level 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, and

therefore, additional plant-specific review of these issues is required. There are no Category 2

issues related to the uranium fuel cycle and solid waste management.

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 10 CFR Part 51,

Subpart A, Appendix B, and are applicable to James A. FitzPatrick Nuclear Power Plant

(JAFNPP). The generic potential impacts of the radiological and non-radiological environmental

impacts of the uranium fuel cycle and transportation of nuclear fuel and wastes are described in

detail in the GElS 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 to and from One Light-

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

references to the "GELS" include the GElS and its Addendum 1.

January 2008 6-1 NUREG-1437, Supplement 31 I
Fuel Cycle

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 GELS.

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

JAFNPP 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

ISSUES - 10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections

URANIUM FUEL CYCLE AND WASTE MANAGEMENT

Offsite radiological impacts (individual effects from other than 6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3;

the disposal of spent fuel and high level waste) 6.2.4; 6.6

Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6

Offsite radiological impacts (spent fuel and high level waste 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6

disposal)

Nonradiological impacts of the uranium fuel cycle 6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 6.2.2.9;

6.2.3; 6.2.4; 6.6

Low-level waste storage and disposal 6.1; 6.2.2.2; 6.4.2; 6.4.3; 6.4.3.1;

6.4.3.2; 6.4.3.3; 6.4.4; 6.4.4.1;

6.4.4.2; 6.4.4.3; 6.4.4.4; 6.4.4.5;

6.4.4.5.1; 6.4.4.5.2; 6.4.4.5.3;

6.4.4.5.4; 6.4.4.6;6.6

Mixed waste storage and disposal 6.4.5.1; 6.4.5.2; 6.4.5.3; 6.4.5.4;

6.4.5.5; 6.4.5.6; 6.4.5.6.1; 6.4.5.6.2;

6.4.5.6.3; 6.4.5.6.4; 6.6

Onsite spent fuel 6.1; 6.4.6; 6.4.6.1; 6.4.6.2; 6.4.6.3;

6.4.6.4; 6.4.6.5; 6.4.6.6; 6.4.6.7; 6.6

Nonradiological waste 6.1; 6.5; 6.5.1; 6.5.2; 6.5.3; 6.6

Transportation 6.1; 6.3.1; 6.3.2.3; 6.3.3; 6.3.4; 6.6,

Addendum 1

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy), which

operate JAFNPP, stated in its Environmental Report (ER) for JAFNPP (Entergy 2006) that it is

not aware of any new and significant information associated with the renewal of the JAFNPP

operating license. The NRC staff has not identified any new and significant information during

I NUREG-1437, Supplement 31 6-2 January 2008
Fuel Cycle

its independent review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process,

and its evaluation of other available information and public comments on the draft SEIS.

Therefore, the NRC staff concludes that there are no impacts related to these issues beyond

those discussed in the GElS. For these issues, the NRC staff concluded in the GElS that the

impacts are SMALL except for the collective offsite 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.

A brief description of the NRC staff's review and the GElS conclusions, as codified in Table B-i,

10 CFR Part 51, for each of these issues follows:

" Offsite radiological impacts (individual effects from other than the disposal of spent fuel and

high level waste). Based on information in the GELS, the Commission found that

Offsite 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 GELS, impacts on individuals from radioactive gaseous and liquid releases

including radon-222 and technetium-99 are small.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no offsite radiological impacts of the uranium fuel

cycle during the renewal term beyond those discussed in the GELS.

" Offsite radiological impacts (collective effects). Based on information in the GELS, 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 [Roentgen Equivalent Man], 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 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

January 2008 6-3 NUREG-1 437, Supplement 31
Fuel Cycle

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 the uncertainty, some judgment as to the regulatory

NEPA [National Environmental Policy Act of 1969] implications of these matters

should be made and it makes no sense to repeat the same judgment 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 collective

effects of the fuel cycle, this issue is considered Category 1.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no offsite radiological impacts (collective effects)

from the uranium fuel cycle during the renewal term beyond those discussed in the GELS.

Offsite radiological impacts (spent fuel and high level waste disposal). Based on information

in the GELS, the NRC found that

For the high level waste and spent fuel disposal component of the fuel cycle,

there are no current regulatory limits for offsite 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," 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 [1 mSv] 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

[1 mSv] 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 [1 mSv]

per year. The lifetime individual risk from 100 millirem [1 mSv] annual dose limit

is about 3 x 10-3.

Estimating cumulative doses to populations over thousands of years is more

problematic. The likelihood and consequences of events that could seriously

I NUREG-1437, Supplement 31 6-4 January 2008
Fuel Cycle

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,

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 [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 [of heavy

metal] (MTHM) repository.

Nevertheless, despite all the uncertainty, some judgment as to the regulatory

NEPA implications of these matters should be made and it makes no sense to

repeat the same judgment 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

January 2008 6-5 NUREG-1437, Supplement 31 I
Fuel Cycle

repository for the geologic disposal of spent nuclear fuel and high-level nuclear waste. The

,U.S. Congress approved this recommendation on July 9, 2002, in House Joint Resolution

87, which designated Yucca Mountain as the repository for spent nuclear waste. On

July 23, 2002, the President signed House 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 represent new and significant information with respect to the

offsite radiological impacts from license renewal related to disposal of spent nuclear fuel and

high-level nuclear waste.

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. In response to the

Court's decision, EPA issued its proposed revised standards on August 22, 2005

(70 Federal Register [FR] 49014). In order to be consistent with EPA's revised standards,

NRC proposed revisions to 10 CFR Part 63 on September 8, 2005 (70 FR 53313).

Therefore, for the high-level waste and spent fuel disposal component of the fuel cycle,

there is some uncertainty with respect to regulatory limits for offsite releases of radioactive

nuclides for the current candidate repository site. However, prior to promulgation of the

affected provisions of the Commission's regulations, we assumed that limits would be

developed along the lines of 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.

Despite the current uncertainty with respect to these rules, some judgment as to the

regulatory NEPA implications of offsite radiological impacts of spent fuel and high-level

waste disposal should be made. The NRC 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no offsite radiological impacts related to spent fuel

and HLW disposal during the renewal term beyond those discussed in the GELS.

I NUREG-1437, Supplement 31 6-6 January 2008
Fuel Cycle

" Nonradioloqical impacts of the uranium fuel cycle. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no nonradiological impacts of the uranium fuel cycle

during the renewal term beyond those discussed in the GELS.

Low-level waste storaqe and disposal. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no impacts of low-level waste storage and disposal

associated with the renewal term beyond those discussed in the GElS.

" Mixed waste storacqe and disposal. Based on information in the GELS, 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

January 2008 6-7 NUREG-1 437, Supplement 31 I
Fuel Cycle

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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no impacts of mixed waste storage and disposal

associated with the renewal term beyond those discussed in the GELS.

" Onsite 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no impacts of onsite spent fuel associated with

license renewal beyond those discussed in the GELS.

" Nonradioloqical waste. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no nonradiological waste impacts during the renewal

term beyond those discussed in the GELS.

" Transportation. Based on information contained in the GELS, 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

I NUREG-1437, Supplement 31 6-8 January 2008
Fuel Cycle

of Fuel and Waste to and from One Light-Water-Cooled 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.

JAFNPP meets the fuel-enrichment and burnup conditions set forth in Addendum 1 to the

GElS (NRC 1999). The NRC staff has not identified any new and significant information

during its independent review of the JAFNPP ER (Entergy 2006), the site audit, the scoping

process, and its evaluation of other available information and public comments on the draft

SEIS. Therefore, the NRC staff concludes that there are no impacts of transportation

associated with license renewal beyond those discussed in the GELS.

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."

70 FR 49014. 70 Federal Register 49014. "Public Health and Environmental Radiation

Protection Standards for Yucca Mountain, Nevada; Proposed Rule." August 22, 2005.

70 FR 53313. 70 Federal Register 53313. "Implementation of a Dose Standard After

10,000 Years; Proposed Rule." September 8, 2005.

D. C. Circ. 2004. Nuclear Energy Inst., Inc. v. Environmental Protection Agency,

373 F.3d 1251.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006.

James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E:

Applicant's Environmental Report, Operating License Renewal Stage. Lycoming, New York.

Accessible at ML062160557.

National Academy of Sciences (NAS). 1995. Technical Bases for Yucca Mountain Standards.

National Academy Press, Washington, D.C.

January 2008 6-9 NUREG-1 437, Supplement 31 I
Fuel Cycle

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

Public Law 107-200, 116 Stat. 735. 2002. "Approving the site at Yucca Mountain, Nevada, for

the development of a repository for the disposal of high-level radioactive waste and spent

nuclear fuel, pursuant to the Nuclear Waste Policy Act of 1982."

U.S. Department of Energy (DOE). 1980. Final Environmental Impact Statement: Management

of Commercially Generated Radioactive Waste. DOE/EIS-0046F, Washington, D.C.

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

for License Renewal of Nuclear Plants. NUREG-1 437, Volumes 1 and 2. Office of Nuclear

Regulatory Research, Washington, D.C.

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

for License Renewal of Nuclear Plants NUREG-1437, Volume 1, Addendum 1. Office of

Nuclear Regulatory Research, Washington, D.C.

I NUREG-1437, Supplement 31 6-10 January 2008
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 I (NRC 2002). The

NRC staff's evaluation of the environmental impacts of decommissioning presented in NUREG0586, 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 (GELS), NUREG-1 437,

Volumes I and 2 (NRC 1996; 1999).(1) The GElS 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 GELS, 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. There are no Category 2

issues related to decommissioning.

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

references to the "GEIS" include the GElS and its Addendum 1.

January 2008 7-1 NUREG-1 437, Supplement 31 I
Environmental Impacts of Decommissioning

7.1 Decommissioning

Category 1 issues in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B that are applicable to

James A. FitzPatrick Nuclear Power Plant (JAFNPP) decommissioning following the renewal

term are listed in Table 7-1. Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operation,

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 JAFNPP license renewal.

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its evaluation

of other available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there are no impacts related to these issues beyond those discussed in the

GELS. For all of these issues, the NRC staff concluded in the GElS 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 JAFNPP

Following the Renewal Term

ISSUES-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections

DECOMMISSIONING

Radiation Doses 7.3.1; 7.4

Waste Management 7.3.2; 7.4

Air Quality 7.3.3; 7.4

Water Quality 7.3.4; 7.4

Ecological Resources 7.3.5; 7.4

Socioeconomic Impacts 7.3.7; 7.4

A brief description of the NRC staff's review and the GElS conclusions, as codified in Table B-i,

for each of the issues follows:

Radiation doses. Based on information in the GElS, 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.

I NUREG-1437, Supplement 31 7-2 January 2008
Environmental Impacts of Decommissioning

The NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no radiation dose impacts associated with

decommissioning following the license renewal term beyond those discussed in the GELS.

Waste management. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no impacts from solid waste associated with

decommissioning following the license renewal term beyond those discussed in the GELS.

" Air quality. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no impacts on air quality associated with

decommissioning following the license renewal term beyond those discussed in the GELS.

" Water quality. Based on information in the GElS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no impacts on water quality associated with

decommissioning following the license renewal term beyond those discussed in the GElS.

January 2008 7-3 NUREG-1 437, Supplement 31 I
Environmental Impacts of Decommissioning

" Ecological resources. Based on information in the GElS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no impacts on ecological resources associated with

decommissioning following the license renewal term beyond those discussed in the GELS.

* Socioeconomic Impacts. Based on information in the GELS, 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 NRC staff has not identified any new and significant information during its independent

review of the JAFNPP ER (Entergy 2006), the site audit, the scoping process, and its

evaluation of other available information and public comments on the draft SEIS. Therefore,

the NRC staff concludes that there are no socioeconomic impacts associated with

decommissioning following the license renewal term beyond those discussed in the GELS.

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 FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006.

James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E: -

Applicant's Environmental Report, Operating License Renewal Stage. Lycoming, New York.

Accessible at ML062160557.

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

for License Rehewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Office of Nuclear

Regulatory Research. Washington, D.C.

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

for License Renewal of Nuclear Plants, Main Report. NUREG-1437, Volume 1, Addendum 1.

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

I NUREG-1437, Supplement 31 7-4 January 2008
Environmental Impacts of Decommissioning

U.S. 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, D.C.

January 2008 7-5 NUREG-1437, Supplement 31 I

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) and the potential environmental

impacts from electric power generating sources other than the James A. FitzPatrick Nuclear

Power Plant (JAFNPP); the possibility of purchasing electric power from other sources to

replace power generated by JAFNPP and the associated environmental impacts; the potential

environmental impacts from a combination of generation and conservation measures; and other

generation alternatives that were deemed unsuitable for complete replacement of power

generated by JAFNPP. 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 Part 51 of Title 10 of the Code of Federal Regulations (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.

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 (GELS) NUREG-1437,

Volumes 1 and 2 (NRC 1996; 1999)(1) with the additional impact category of environmental

justice.

8.1 No-Action Alternative

The NRC's regulations implementing the National Environmental Policy Act (NEPA) of 1969

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 JAFNPP OL and JAFNPP

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

references to the "GELS" include the GEIS and its Addendum 1.

January 2008 8-1 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

would then cease facility operations by the end of the current license and initiate the

decommissioning of the power plant.

JAFNPP will eventually be required to shut down and to comply with NRC decommissioning

requirements in 10 CFR 50.82 whether or not the OL is renewed. If the JAFNPP OL is

renewed, shutdown of the unit 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 GElS; Chapter 7 of this supplemental environmental impact

statement (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 (NRC 2002).(2) Therefore, immediate impacts that occur between power plant

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. These impacts

are discussed below, with the results presented in Table 8-1. Power plant shutdown will result

in a net reduction in power production capacity. The power not generated by JAFNPP during

the license renewal term would likely be replaced by (1) power purchased from other electricity

providers, (2) generating alternatives other than JAFNPP, (3) demand-side management and

energy conservation, or (4) some combination of these options. The environmental impacts of

these options are discussed in Section 8.2.

Land Use

In Chapter 4 of this SEIS, the NRC staff concluded that there would be no impacts of

continued power plant operation on land use. Onsite land use would not be affected

immediately by the cessation of operations. Power plant structures and other facilities are

likely to remain in place until decommissioning. The transmission lines associated with the

project are expected to remain in service after the power plant stop operating. As a result,

maintenance of the rights-of-way (ROWs) would continue as before. Therefore, there would

be no impacts on land use from power plant shutdown.

(2) 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.

I NUREG-1437, Supplement 31 8-2 January 2008
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Table 8-1. Summary of Environmental Impacts of the No-Action Alternative

Impact Category Impact Comment

Land Use NO IMPACT No impacts because power plant shutdown is not expected

to result in changes to onsite or offsite land use.

Ecology

Water Use and Quality -

Surface Water

Water Use and Quality -

Groundwater

SMALL

SMALL

Impacts are expected to be SMALL because there would

be a reduction in cooling water flow and the thermal plume

from the power plant, and terrestrial impacts are not

expected because there would not be any land-use

changes.

Impacts are expected to be SMALL because surface water

intake and discharges would decrease.

NO IMPACT There is no groundwater use at the site.

Air Quality SMALL

Waste SMALL

Human Health SMALL

Impacts are expected to be SMALL because emissions

related to power plant operation and worker transportation

would decrease.

Impacts are expected to be SMALL because the

generation of high-level waste would stop, and the

generation of low-level and mixed waste would decrease.

Impacts are expected to be SMALL because radiological

doses to workers and members of the public, which are

within regulatory limits, would be reduced.

Impacts are expected to be MODERATE to LARGE

because of a decrease in employment and tax revenues to

local jurisdictions.

Transportation impacts would be SMALL because the

decrease in employment would reduce traffic.

Socioeconomics MODERATE

to LARGE

Transportation

Aesthetics

Historic and

Archaeological Resources

Environmental Justice

SMALL

NO IMPACT No impacts are expected because power plant structures

would remain in place.

SMALL Impacts are expected to be SMALL because shutdown of

the power plant would not change land use.

Economic impacts are expected to be SMALL to LARGE

because loss of employment opportunities is expected.

SMALL to

LARGE

January 2008 8-3 NUREG-1 437, Supplement 31 I
Environmental Impacts of Alternatives

* Ecology

In Chapter 4 of this SEIS, the NRC staff concluded that the ecological impacts of power

plant operation were SMALL. Cessation of operations would be accompanied by a

reduction in cooling water flow and the thermal plume from the power plant.

The impact of power plant closure on the terrestrial ecosystem would be negligible because

the transmission lines to the power plant would remain energized. Therefore, the NRC staff

concludes that ecological impacts from shutdown of the power plant would be SMALL.

" Water Use and Quality-Surface Water

In Chapter 4 of this SEIS, the NRC staff concluded that impacts of power plant operation on

surface water use and quality were SMALL. When the power plant stops operating, there

would be an immediate reduction in the consumptive use of water because of reduction in

cooling water flow and in the amount of heat transferred to Lake Ontario. Therefore, the

NRC staff concludes that the impacts on surface water use and quality from power plant

shutdown would be SMALL.

* Water Use and Quality-Groundwater

In Chapter 4 of this SEIS, the NRC staff concluded that there would be no impacts on

groundwater use, availability, and quality. Therefore, the NRC staff concludes that there

would be no impact on groundwater use and quality from shutdown of the power plant.

" Air Quality

In Chapter 4 of this SEIS, the NRC staff found the impacts of power plant operation on air

quality were SMALL. When the power plant stops operating, there would be a reduction in

emissions from activities related to power plant operation such as use of diesel generators

and worker transportation. Therefore, the NRC staff concludes that the impact on air quality

from shutdown of the power plant would be SMALL.

" Waste

The impacts of waste generated by power plant operation are discussed in Chapter 6 of this

SEIS. The impacts of low-level and mixed waste from power plant operation would be

SMALL. When the power plant stops operating, the power plant would stop generating

high-level waste, and the generation of low-level and mixed waste associated with power

plant operation and maintenance would be reduced. Therefore, the NRC staff concludes

that the impact of waste generated after shutdown of the power plant would be SMALL.

I NUREG-1437, Supplement 31 8-4 January 2008
Environmental Impacts of Alternatives

" Human Health

In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of power 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 would be reduced.

Therefore, the NRC staff concludes that the impact of shutdown of the power plant on

human health would be SMALL. In addition, the variety of potential accidents at the power

plant would be reduced to a limited set associated with shutdown events and spent fuel

handling. In Chapter 5 of this SEIS, the NRC staff concluded that the impacts of accidents

during operation were SMALL. Therefore, the NRC staff concludes that the impacts of

potential accidents following shutdown of the power plant would be SMALL.

" Socioeconomics

In Chapter 4 of this SEIS, the NRC staff concluded that there would be no socioeconomic

impacts of continued power plant operation. Conversely, there would be immediate

socioeconomic impacts associated with the shutdown of the power plant because of the

reduction in JAFNPP staff. There would also be an immediate reduction in property tax

revenues for Oswego County. The NRC staff concludes that the socioeconomic impacts of

power plant shutdown would range from MODERATE to LARGE. Some of these impacts

would be offset if new power-generating facilities were built at or near the current site. See

Appendix J of NUREG-0586, Supplement 1 (NRC 2002), for additional discussion of the

potential impacts of power plant shutdown.

" Transportation

In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of continued power

plant operation on transportation would be SMALL. Cessation of operations would be

accompanied by a reduction in traffic in the vicinity of the power plant. Most of the reduction

in traffic would be associated with a decrease in the power plant workforce but there would

also be a decrease in shipments of material to and from JAFNPP. Therefore, the NRC staff

concludes that the impacts of power plant closure on transportation would be SMALL.

* Aesthetics

In Chapter 4 of this SEIS, the NRC staff concluded that there would be no aesthetic impacts

of continued power plant operation. Power plant structures and other facilities would remain

in place until decommissioning. Therefore, there would be no aesthetic impacts from power

plant closure.

* Historic and Archaeological Resources

In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of continued power

plant operation on historic and archaeological resources would be SMALL. Onsite land use

January 2008 8-5 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

would not be affected immediately by the cessation of operations. Power plant structures

and other facilities are likely to remain in place until decommissioning. The transmission

lines associated with the project are expected to remain in service after the power plant

stops operating. As a result, maintenance of transmission line ROWs would continue as

before. Therefore, the NRC staff concludes that the impacts on historic and archaeological

resources from JAFNPP plant shutdown would be SMALL.

Environmental Justice

In Chapter 4 of this SEIS, the NRC staff concluded that there would be no disproportionately

high and adverse impacts on minority and low-income populations from the continued

operation of the JAFNPP plant. Shutdown of JAFNPP could have disproportionately high

and adverse economic impacts on minority and low-income populations because of the loss

of employment opportunities at the site. The NRC staff concludes that the impacts of power

plant shutdown on minority and low-income populations could range from SMALL to

LARGE. Some of these impacts would be offset if new power-generating facilities are built

at or near the current JAFNPP site. See Appendix J of NUREG-0586, Supplement 1 (NRC

2002), for additional discussion of these impacts.

8.2 Alternative Energy Sources

This section discusses the environmental impacts associated with alternative sources of electric

power to replace the power generated by JAFNPP, assuming that the OL is not renewed. The

order of presentation of alternative energy sources in this section does not imply which

alternative would be most likely to occur or would have the least environmental impact.

The following power generation alternatives are considered in detail:

" Coal-fired generation at an alternate site (Section 8.2.1)

" Natural gas-fired generation at the JAFNPP site and an alternate site (Section 8.2.2)

" New nuclear generation at the JAFNPP site and an alternate site (Section 8.2.3)

The alternative of purchasing power from other sources to replace power generated at JAFNPP

is discussed in Section 8.2.4. Other power-generation alternatives and conservation

alternatives considered by the NRC staff and found not to be reasonable replacements for

JAFNPP baseload power is 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. The Annual Energy Outlook 2007 with

Projections to 2030 was issued in February 2007 (DOE/EIA 2007). EIA projects that natural

I NUREG-1437, Supplement 31 8-6 January 2008
Environmental Impacts of Alternatives

gas-fired and coal-fired electricity generation will constitute approximately 90 percent of

electrical capacity additions between 2006 and 2030. Natural gas-fired generation is typically

based on combined-cycle(3) or combustion turbine technology, which can supply peak and

intermediate capacity and can also be used to meet baseload(4) requirements. Coal-fired power

plants are generally used to meet baseload requirements. Renewable energy sources,

including conventional hydroelectric, geothermal, wood, wood waste, municipal solid waste,

landfill gas, other biomass, solar and wind power are projected by EIA to account for 6 percent

of capacity additions (DOE/EIA 2007).

EIA projects that oil-fired generation will continue to decrease in the U.S. through 2030 because

high world oil prices encourage switching from oil-fired generation to natural gas and nuclear

power and reinforce coal's important role in world electric power generation. Similarly, the

relatively high fossil fuel prices of recent years are raising renewed interest in nuclear power

and making renewable energy sources more competitive economically. EIA's projections are

based on the assumption that providers of new generating capacity will seek to minimize cost

while meeting applicable environmental requirements. The cost of new oil-fired generation is

not expected to be competitive with that of coal, natural gas, or renewable energy sources

(DOE/EIA 2007).

EIA also projects a small increase in nuclear power generation through 2030, accounting for

0.6 percent of the generation growth (DOE/EIA 2007). The projected growth in nuclear power

generation is not higher because natural gas and coal-fired power plants are projected to be

more economical. In spite of this projection, since 1997, the NRC has certified four new

standard designs for nuclear power plants under procedures in 10 CFR Part 52, Subpart B.

Therefore, a new nuclear power plant alternative for replacing power generated by JAFNPP is

considered in Section 8.2.3. The submission to the NRC of these four applications for

certification indicates continuing interest in the possibility of licensing new nuclear power plants.

The NRC has established a new office to prepare for and manage future new reactor and site

licensing applications.

JAFNPP has a gross rating of 881 megawatts-electric (MWe). For the coal alternative, the NRC

staff assumed construction of an 816-MWe power plant. For the natural gas alternative, the

NRC staff assumed construction of an 816-MWe power plant, which is consistent with the

James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E:

Applicant's Environmental Report, Operating License Renewal Stage (JAFNPP ER) (Entergy

(3) In a combined-cycle unit, hot combustion gas in a combustion turbine rotates the turbine to generate

electricity. The hot exhaust from the combustion turbine is routed through a heat-recovery boiler to

make steam to generate additional electricity.

(4) 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, i.e., these units generally run near full load.

January 2008 8-7 NUREG-1 437, Supplement 31 I
Environmental Impacts of Alternatives

2006). For the new nuclear alternative, the NRC staff assumed construction of a 1 000-MWe

power plant. This assumption will overstate the environmental impacts of replacing the

881 MWe from JAFNPP by roughly 13.5 percent.

8.2.1 Coal-Fired Power Generation

The NRC staff believes that the JAFNPP site would not be a viable location for a representative

coal-fired power plant. The primary consideration pertinent to this determination is the size of

the JAFNPP site. Use of the site would necessitate offsite disposal of waste. Therefore, the

NRC staff assumes that the representative coal-fired power plant would be located at an

alternate site.

Consistent with the JAFNPP ER, the NRC staff assumed construction of two 408-MWe units for

a combined capacity of 816 MWe as a potential replacement for JAFNPP. The assumption of

816 MWe is slightly less generating capacity than JAFNPP's capacity of 881 MWe, but the NRC

staff concluded that the differences are not significant and would not change the standard of

significance (SMALL, MODERATE, or LARGE) of any impacts.

Unless otherwise indicated, the assumptions and numerical values used in Section 8.2.1 are

from the JAFNPP ER (Entergy 2006). The NRC staff reviewed this information and compared it

to environmental impact information in the GELS. Although the OL renewal period is only

20 years, the impact of operating the coal-fired alternative for 40 years was assumed.

The coal-fired power plant would consume approximately 2.36 million tons per year (tons/yr) of

pulverized bituminous coal with an ash content of approximately 7.11 percent (Entergy 2006).

JAFNPP assumes a heat rate(5) of 10,200 BTU/kWh and a capacity factor(6) of 0.85 in its ER

(Entergy 2006). After combustion, 99.9 percent of the ash would be collected and disposed at

either an onsite or offsite landfill. In addition, approximately 136,995 tons of scrubber sludge

would be disposed of at the power plant site based on annual limestone usage of approximately

46,241 tons. Limestone is used in the scrubbing process for control of sulfur dioxide (SO 2 )

emissions.

(5) Heat rate is measure of generating station thermal efficiency. In English units, it is generally

expressed in British thermal units (BTUs) per net kilowatt-hour (kWh). It is computed by dividing the

total BTU content of the fuel burned for electric generation by the resulting kWh generation. The

corresponding metric unit for energy is the Joule (J).

(6) The capacity factor is the ratio of electricity generated, for the period of time considered, to the energy

that would have been generated at continuous full-power operation during the same period.

I NUREG-1437, Supplement 31 8-8 January 2008
Environmental Impacts of Alternatives

8.2.1.1 Once-Through Cooling System

For purposes of this section, the NRC staff assumed that a coal-fired power plant located at an

alternate site would use a once-through cooling system. The overall impacts of the coal-fired

generating system using once-through cooling are discussed in this section and summarized in

Table 8-2. The extent of impacts at an alternate site would depend on the location of the site.

In Section 8.2.1.2, the NRC staff evaluates the impacts of using a closed-cycle cooling system

at an alternate site.

Land Use

Development of the coal-fired power plant would require approximately 1387 acres (ac) of

land for the power plant site. Additional land would be necessary to allow for an onsite and

peripheral buffer. The NRC estimates that 1700 ac would be required for a 1000-MWe

power plant. Depending on the location of the power plant, additional land would be

required for offsite infrastructure, particularly transmission lines to connect the power plant

to the grid and facilities for coal and limestone delivery, most likely including a rail spur and

possibly some upgrades to existing or recently abandoned rail lines. Construction of a

barge terminal would also be a reasonable option for a power plant located on Lake Ontario.

Land-use changes would also occur offsite in an undetermined coal-mining area to supply

coal for the power plant. In the GELS, the NRC staff estimated that approximately 22 ac of

land per MWe would be affected for mining the coal and disposing of the waste to support a

coal-fired power plant during its operational life. Therefore, the 816-MWe power plant

proposed in this analysis would require approximately 17,592 ac of land to support the entire

fuel cycle.

The location and design of coal-fired power plant facilities at an alternate site would be

subject to substantial regulatory scrutiny and that a reasonable potential exists for the

eventual restoration of disposal areas and the development of compatible uses that would

not affect landfill integrity (e.g., recreation). Under these assumptions, the NRC staff

expects that land-use impacts would be noticeable but would not affect land-use

characteristics at an existing industrial site. Depending particularly on transmission line and

rail line routing, this alternative would result in MODERATE to LARGE land-use impacts.

Ecoloqy

Impacts on ecological resources from construction and from operation of the representative

coal-fired power plant would be highly site-specific. However, as much as 1387 ac of

terrestrial habitat would be displaced by the power plant and onsite landfill, and additional

terrestrial habitat would be adversely affected from development of offsite infrastructure

(e.g., transmission line connection, rail spur construction). Impacts would depend on

January 2008 8-9 NUREG-1 437, Supplement 31 I
Environmental Impacts of Alternatives

Table 8-2. Summary of Environmental Impacts of Coal-Fired Generation

at an Alternate Site Using Once-Through Cooling

Impact Category Impact Comments

Land Use MODERATE

to LARGE

MODERATE

to LARGE

Ecology

Water Use And Quality

-Surface Water

Water Use and Quality

-Groundwater

SMALL to

MODERATE

SMALL to

MODERATE

MODERATE

Would use approximately 1387 ac for the power plant roads,

parking areas, office buildings, and transmission line. There

would be additional land impacts for coal and limestone mining.

The total impact would depend on whether the alternate site had

been previously disturbed or had existing infrastructure.

Impacts would depend on whether the site had been previously

developed. Factors to consider include location and ecology of

the site, transmission line route, and rail spur route. In total,

impacts would include habitat degradation, fragmentation, or

loss as a result of construction activities and conversion of land

to industrial use. Ecological communities might experience

reduced productivity and biological diversity from disturbing

previously intact land.

Impacts would depend on the volume of water withdrawn and

discharged and the characteristics of the surface water body.

Impacts would depend on the volume of water withdrawn and

discharged and the characteristics of the aquifer.

" Sulfur oxides: 2514 tons/yr

" Nitrogen oxides: 591 tons/yr

o Particulates: 19 tons/yr of PM10

" Carbon monoxide: 591 tons/yr

" Small amounts of mercury and other hazardous air pollutants

and naturally occurring radioactive materials- mainly

uranium and thorium.

" Total suspended particulates: 84 tons/yr

Total waste volume would be approximately 136,995 tons/yr of

ash and scrubber sludge requiring approximately 161 ac for

disposal during the 40-year life of the power plant.

Impacts are uncertain but considered SMALL in the absence of

more quantitative data.

Impacts are expected to be SMALL to LARGE and site

dependent because of changes in employment and tax

revenues.

Air Quality

Waste MODERATE

Human Health

Socioeconomics

SMALL

SMALL to

LARGE

I NUREG-1437, Supplement 31 8-10 January 2008
Environmental Impacts of Alternatives

Table 8-2 (cont.)

Impact Category Impact Comments

Transportation SMALL Transportation impacts associated with construction could be

to LARGE MODERATE to LARGE. Transportation impacts associated

with power plant operations would also be site-dependent and

would be SMALL to MODERATE. For rail transportation of coal

and lime, the impact would be MODERATE to LARGE. For

barge transportation, the transportation impact would be

SMALL.

Aesthetics SMALL Impacts would include visual impairment, construction of new

to LARGE transmission lines, and infrastructure for the delivery of coal and

limestone. The impact severity would be dependent on location.

Historic and SMALL to Building a coal-fired power plant and other support facilities

Archaeological MODERATE would require cultural resource studies. Impacts would vary

Resources depending on location and presence of historic and

archaeological resources.

Environmental SMALL Impacts to minority and low-income populations would vary

Justice to LARGE depending on the site location of the power plant and other

support facilities.

whether the site had been previously developed. Factors to consider include location and

ecology of the site, transmission line route, and rail spur route. In total, impacts would

include habitat degradation, fragmentation, or loss as a result of construction activities and

conversion of land to industrial use. Ecological communities might experience reduced

productivity and biological diversity from disturbing previously intact land.

Impact to aquatic communities as a result of construction would include some permanent

alteration of habitat, particularly if a barge terminal were developed for delivery of coal and

limestone. Fish and benthic communities would be initially disrupted but would be expected

to reestablish with accompanying localized changes in species composition and distribution

in response to changes in bottom substrate availability, water depth, and other factors.

Potential for some adverse impact on aquatic communities would persist through the

operational period as a result of large boat traffic, periodic maintenance dredging, and

potential for spills of coal, petroleum products, or other materials. However, construction

and maintenance dredging would be conducted in accordance with the provisions of

applicable permits from the U.S. Army Corps of Engineers (USACE) and the New York State

Department of Environmental Conservation (NYSDEC). Similarly, spill prevention measures

would be effective during the operational period. Once-through cooling water withdrawal

and discharge would have adverse aquatic resource impacts.

I

January 2008 8-11 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

Given this information, the NRC staff concludes that development of the representative coalfired power plant at an alternate site in upstate New York would have a MODERATE to

LARGE impact on ecological communities.

Water Use and Quality-Surface Water

Construction phase impacts on water quality of greatest potential concern at an alternate

site would include (1) erosion and sedimentation associated with land-clearing operations,

and (2) suspension of bottom sediments during construction of cooling water intake and

discharge structures and, if the option were chosen, from construction of barge delivery

facilities. However, land-clearing activities are subject to storm-water protections in

accordance with the State Pollutant Discharge Elimination System (SPDES) program. Work

in waterways would be regulated by the USACE under the Clean Water Act of 1977,

Section 404, and the Rivers and Harbors Appropriation Act of 1899, Section 10, by the

NYSDEC via permits and by the New York Department of State (NYSDOS) under the

State's Coastal Zone Management program (if located within the coastal zone). In addition,

these adverse effects would be localized and temporary. The NRC staff concludes that

impacts on surface water quality associated with construction of the representative power

plant would be SMALL.

Potential impacts on water quality and use associated with operation of the representative

power plant would be to some extent site-specific. Cooling water and other wastewater

discharges would be regulated by a SPDES permit regardless of location. The impact on

surface water would depend on the volume of water withdrawn and discharged and the

characteristics of the surface water body. The NRC staff concludes that the impacts of

surface water use and quality from the operation of a representative power plant located at

an alternate site would be SMALL to MODERATE.

* Water Use and Quality-Groundwater

Use of groundwater for a coal-fired power plant at an alternate site is possible.

Groundwater withdrawal would require a permit. Overall, the impact to groundwater at an

alternate site is considered SMALL to MODERATE and would depend on the volume of

water that is withdrawn and discharged and the characteristics of the aquifers.

" Air Quality

The air-quality impacts of coal-fired generation vary considerably from those of nuclear

generation due to emissions of sulfur oxides (SOx), nitrogen oxides (NOx), particulates,

carbon monoxide, hazardous air pollutants such as mercury, and naturally occurring

radioactive materials.

Oswego County is designated as unclassifiable or in attainment with all criteria pollutants.

The nearest area of non-attainment is Jefferson County, which is classified as marginal for

I NUREG-1437, Supplement 31 8-12 January 2008
Environmental Impacts of Alternatives

ozone. Onondaga County, where Syracuse is located, is a maintenance area for carbon

monoxide and classified as moderate, i.e., less than or equal to 12.7 parts per million (ppm).

A new coal-fired generating power plant in upstate New York would likely need a prevention

of significant deterioration (PSD) permit and an operating permit under the Clean Air Act of

1970. The power plant would need to comply with the new source performance standards

for such power plants set forth in 40 CFR 60, Subpart D(a). The standards establish limits

for particulate matter and opacity (40 CFR 60.42[a]), S0 2 (40 CFR 60.43[a]), and NOx (40

CFR 60.44[a]). The facility would be designed to meet best available control technology

(BACT) or lowest achievable emissions rate (LAER) standards, as applicable, for control of

criteria air emissions.

The U.S. Environmental Protection Agency (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 as attainment or unclassified under

the Clean Air Act.

Section 169A of the Clean Air Act 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. The EPA issued a new regional haze rule

in 1999 (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 power plant were located close to a

mandatory Class I Federal area, additional air pollution control requirements would be

imposed. It is assumed that an alternate site would not be chosen near a mandatory Class I

Federal area.

In 1998, the EPA issued a rule requiring 22 Eastern states, including New York, to revise their

state implementation plans to reduce NOx emissions, which contribute to violations of the

national ambient air quality standard for ozone (EPA 1998). The total amount of NOx that can

be emitted by each of the 22 Eastern states in the year 2007 ozone season (May 1 to

September 30) is set out at 40 CFR 51.121(e). For New York, the amount is 190,360 tons.

Impacts for particular pollutants are as follows:

Sulfur oxides emissions. A new coal-fired power plant would be subject to the

requirements in Title IV of the Clean Air Act. Title IV was enacted to reduce emissions of

SO2 and NOx, the two principal precursors of acid rain, by restricting emissions of these

pollutants from power plants. Title IV caps aggregate annual power plant SO 2 emissions

and imposes controls on S02 emissions through a system of marketable allowances. EPA

January 2008 8-13 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

issues one allowance for each ton of SO2 a unit is allowed to emit. New units do not receive

allowances but are required to have allowances to cover their SO2 emissions. Owners of

new units must therefore acquire allowances from owners of other power plants by

purchasing them or reducing SO2 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 regional SO2 emissions, although it might do so locally. Regardless, SO2 emissions

would be greater for the coal alternative than the OL renewal alternative because a nuclear

power plant releases negligible amounts of SO 2 during normal operations.

Entergy estimates that by using the BACT to minimize SOx emissions, the total annual stack

emissions would be approximately 2514 tons of SOx (Entergy 2006).

Nitrogen oxides emissions. Section 407 of the Clean Air Act establishes technologybased emission limitations for NOx emissions. The market-based allowance system used

for SO2 emissions is not used for NOx emissions. A new coal-fired power plant would be

subject to the new source performance standards for such power plants in 40 CFR

60.44a(d)(1). This regulation, issued on September 16, 1998 (EPA 1998), limits the

discharge of any gases that contain nitrogen oxides (expressed as NO2 ) in excess of 200

nanograms per Joule (ng/J) of gross energy output (1.6 pounds per megawatt hour

[Ib/MWh]), based on a 30-day rolling average.

Entergy estimates that by using NOx burners with overfire air and selective catalytic

reduction (SCR), the total annual NOx emissions for a new coal-fired power plant would be

approximately 591 tons. Regardless of the control technology, this level of NOx emissions

would be greater than the OL renewal alternative because a nuclear power plant releases

negligible amounts of NOx during normal operations.

Particulate emissions. Entergy estimated that for coal-fired generation, the total annual

stack emissions would include 84 tons of total suspended particulates and 19 tons of

particulate matter with an aerodynamic diameter of less than or equal to 10 microns (PM1o).

Fabric filters or electrostatic precipitators would be used for control. In addition, coalhandling equipment would introduce fugitive particulate emissions. Particulate emissions

would be greater under the coal alternative than the OL renewal alternative because nuclear

power plants release few particles during normal operation.

During the construction of a coal-fired power plant, fugitive dust would be generated. In

addition, exhaust emissions would come from vehicles and motorized equipment used

during the construction process.

Carbon monoxide emissions. Entergy estimated that for a coal-fired power plant, the total

carbon monoxide emissions would be approximately 591 tons/yr. This level of emissions is

greater than the OL renewal alternative.

I NUREG-1437, Supplement 31 8-14 January 2008
Environmental Impacts of Alternatives

Hazardous air pollutants including mercury. In December 2000, the EPA issued

regulatory findings on emissions of hazardous air pollutants from electric utility steamgenerating units (EPA 2000). The 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 the EPA to emit arsenic, beryllium, cadmium, chromium, dioxins,

hydrogen chloride, hydrogen fluoride, lead, manganese, and mercury (EPA 2000). The EPA

concluded that mercury is the hazardous air pollutant of greatest concern. The 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, subsistence fisheating populations) are believed to be at potential risk of adverse health effects due to

mercury exposures resulting from consumption of contaminated fish (EPA 2000).

Accordingly, the EPA added coal- and oil-fired electric utility steam-generating units to the

list of source categories under Section 112(c) of the Clean Air Act for which emission

standards for hazardous air pollutants will be issued (EPA 2000).

Uranium and thorium. Coal contains uranium and thorium. Uranium concentrations are

generally in the range of 1 to 10 ppm. Thorium concentrations are generally about 2.5 times

greater than uranium concentrations (Gabbard 1993). One estimate is that a typical coalfired power 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 dioxide. A coal-fired power plant would have unregulated carbon dioxide

emissions that would contribute to global warming. The level of emissions from a coal-fired

power plant would be greater than the OL renewal alternative.

Summary. The GElS analysis did not quantify emissions from coal-fired power plants but

implies that air impacts would be substantial. The GElS also mentions global warming from

unregulated carbon dioxide emissions and acid rain from SOx and NOx emissions as

potential impacts. Adverse human health effects such as cancer and emphysema have

been associated with the products of coal combustion.

The NRC staff concludes that the overall impact on air quality from a coal-fired power plant,

located at an alternate site in upstate New York, would be MODERATE. The impacts would

be clearly noticeable but because of air quality control regulations would not destabilize air

quality.

Waste

Coal combustion generates waste in the form of ash, and equipment for controlling air

pollution generates additional ash and scrubber sludge. The representative coal-fired power

January 2008 8-15 NUREG-1437, Supplement 31 1
Environmental Impacts of Alternatives

plant would generate approximately 136,995 tons of this waste annually for 40 years. The

waste would be disposed of onsite, accounting for approximately 161 ac of land area over

the 40-year power plant life. Waste impacts to groundwater and surface water would extend

beyond the operating life of the power plant if leachate and runoff from the waste storage

area occurred. Disposal of the waste would noticeably affect land use and groundwater

quality, but with appropriate management and monitoring, it would not destabilize any

resources. After closure of the waste site and revegetation, the land would be available for

other uses. Debris would be generated during construction activities.

In 2000, the EPA issued a "Notice of Regulatory Determination on Wastes From the

Combustion of Fossil Fuels" (EPA 2000). The EPA concluded that some form of national

regulation is warranted to address coal combustion waste products because (1) the

composition of these wastes could present danger to human health and the environment

under certain conditions, (2) the 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, (3) present disposal practices are such that, in 1995,

these wastes were being managed in 40 to 70 percent of landfills and surface

impoundments without reasonable controls in place, particularly in the area of groundwater

monitoring, and (4) the EPA identified gaps in state oversight of coal combustion wastes.

Accordingly, the EPA announced its intention to issue regulations for disposal of coal

combustion waste under Subtitle D of the Resource Conservation and Recovery Act of

1976.

For all of the preceding reasons, the appropriate characterization of impacts from waste

generated from burning coal is MODERATE. The impacts would be clearly noticeable but

would not destabilize any important resource.

Human Health

Coal-fired power generation introduces worker risks from fuel and limestone mining, fuel and

lime/limestone transportation, and disposal of coal combustion waste. In addition, there are

public risks from inhalation of stack emissions. Emission impacts can be widespread, and

health risks can be difficult to quantify. The coal alternative also introduces the risk of coalpile fires and attendant inhalation risks.

In the GELS, the NRC staff stated that there would be human health impacts (cancer and

emphysema) from inhalation of toxins and particulates, but the NRC staff did not identify the

significance of these impacts. In addition, uranium and thorium discharges from coal-fired

power plants can potentially produce radiological doses in excess of those arising from

nuclear power plant operations (Gabbard 1993).

Regulatory agencies, including the EPA and state agencies, set air emission standards and

requirements based on human health impacts. These agencies also impose site-specific

I NUREG-1437, Supplement 31 8-16 January 2008
Environmental Impacts of Alternatives

emission limits as needed to protect human health. As discussed previously, the EPA has

recently concluded that certain segments of the U.S. population (e.g., the developing fetus,

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.

Socioeconomics

It is estimated that the 816-MWe coal-fired power plant would take approximately four years

to construct with a workforce ranging from 979 to 2040 workers (Entergy 2006). The extent

of socioeconomic impacts from the construction of the coal-fired power plant would depend

on its location. As stated in the GELS, socioeconomic impacts are expected to be larger at a

rural site than at an urban site because more of the peak construction workforce would need

to move to the area to work. Socioeconomic impacts at a rural site would be LARGE, while

impacts at a site in the vicinity of a more populated metropolitan area (e.g., Syracuse) would

be SMALL to MODERATE. Impacts during construction would consist of short-term

increased demand for rental housing and public services that could temporarily offset the

loss of jobs and tax revenue from the closure of JAFNPP. Communities in Oswego County

in particular would experience MODERATE to LARGE impacts due to losses in employment

and tax revenues from the closure of JAFNPP, especially if the coal-fired power plant is

constructed outside the area.

Overall, the socioeconomic impacts of a coal-fired power plant at an alternate site would be

SMALL to LARGE depending on the location of the plant.

Transportation

Transportation-related impacts associated with construction at an alternate site are sitedependent but would be MODERATE to LARGE. Transportation impacts related to power

plant operations would also be site-dependent and would be SMALL to MODERATE.

Coal and lime/limestone would likely be delivered to the site by rail or barge.

Socioeconomic impacts associated with rail transportation would likely be MODERATE to

LARGE. For example, there would be highway traffic delays as trains pass road crossings.

Barge delivery of coal and lime/limestone would likely have SMALL socioeconomic impacts.

Aesthetics

Potential aesthetic impacts of construction and operation of the coal-fired power plant at an

alternate site would include visual impairment from a large industrial facility. There would

also be an aesthetic impact associated with construction of a new transmission line. Noise

and light from the power plant would be detectable offsite. Aesthetic impacts at the power

plant site would be mitigated if the coal-fired power plant were located in an industrial area

January 2008 8-17 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

or adjacent to other power plants. Noise impacts from a rail spur, if required, would be most

significant for residents living in the immediate vicinity of the power plant and along the rail

route.

These impacts are highly site-specific. Therefore, the NRC staff concluded that depending

on location aesthetic and noise impacts associated with the development and opQration of a

coal-fired power plant at an alternate site would range from SMALL to LARGE.

Historic and Archaeological Resources

Before construction at an alternate site, historic and archaeological studies would be needed

to identify, evaluate, and address the potential impacts of new power plant construction on

cultural resources. These studies would be needed for all areas of potential disturbance at

the proposed power plant site and other support facilities, and along associated corridors

where new construction would occur (e.g., roads, transmission corridors, rail lines, other

ROWs). Historic and archaeological resource impacts can generally be effectively managed

and as such are considered SMALL to MODERATE depending on location and presence of

cultural resources.

Environmental Justice

Impacts on minority and low-income populations associated with a replacement coal-fired power

plant built at an altemate site in New York State would depend on the location of the site and

population distribution. Impacts on housing availability and prices during power plant

construction could disproportionately affect minority and low-income populations. Closure of

JAFNPP would result in the loss of approximately 716 jobs causing economic conditions that

could affect employment prospects for minority or low-income populations. Depending on plant

location, overall impacts would vary between SMALL and LARGE.

8.2.1.2 Closed-Cycle Cooling System

The environmental impacts of constructing a coal-fired generation system at an alternate site

using closed-cycle cooling with cooling towers would be essentially the same as for a coal-fired

power plant using a once-through cooling system. However, there are some environmental

differences between the closed-cycle and once-through cooling systems. Table 8-3

summarizes the incremental differences.

I NUREG-1437, Supplement 31 8-18 January 2008
Environmental Impacts of Alternatives

Table 8-3. Summary of Environmental Impacts of Coal-Fired Generation

at an Alternate Site with Closed-Cycle Cooling

Impact Category Change in Impacts from Once-Through Cooling System

25 to 30 additional ac would be required for cooling towers and associated support

Land Use

Ecology

Water Use and

QualitySurface Water

Water Use and

QualityGroundwater

Air Quality

Waste

Human Health

Socioeconomics

Transportation

Aesthetics

Historic and

Archaeological

Resources

25 to 30 additional ac would be required for cooling towers and associated support

infrastructure.

Impact would depend on ecology at the site. Reduced impact to aquatic ecology.

Discharge of cooling tower blowdown containing dissolved solids. Discharge would be

regulated by the State. Decreased water withdrawal and less thermal load on the receiving

body of water. Consumptive use of water due to evaporation from cooling towers.

No change

No change

No change

No change

No change

No change

Introduction of cooling towers and associated plume. Natural draft towers would be up to

520 ft tall. Mechanical draft towers would be up to 100 ft tall and would have an associated

noise impact.

No change

Environmental Justice No change

8.2.2 Natural Gas-Fired Generation

The environmental impacts of a natural gas-fired alternative are examined in this section. The

NRC staff reviewed Entergy's ER and compared it to environmental impact information in the

GELS. Although the OL renewal period is only 20 years, the impact of operating the natural gasfired alternative for 40 years was assumed.

Entergy assumed that a replacement natural gas-fired power plant would use combined-cycle

technology. In a combined-cycle unit, hot combustion gases in a combustion turbine rotate the

January 2008 8-19 NUREG-1437, Supplement 31 1
Environmental Impacts of Alternatives

turbine to generate electricity. Waste combustion heat from the combustion turbine is routed

through a heat-recovery boiler to make steam to generate additional electricity.

For operation of a gas-fired facility at the existing JAFNPP site, an additional 25 miles (mi) of

pipeline for gas supply would need to be constructed. Offsite infrastructure needed to locate the

power plant at an alternate site is conjectural but would reasonably include a natural gas supply

pipeline, transmission line, and makeup water and discharge pipelines. The extent to which

such infrastructure would be required is location-specific, but such needs would be considered

in siting the facility and would be subject to regulatory scrutiny under New York's Public Service

Law, Articles VII and X, or comparable process (Entergy 2006).

The natural gas-fired alternative is analyzed for both the existing JAFNPP site and for an

unnamed alternate site. Siting a new natural gas-fired power plant at the site of an existing

nuclear power plant would reduce environmental impacts by allowing the new facility to take

advantage of existing infrastructure, including transmission facilities, roads, parking areas, office

buildings, and the existing cooling system (to the extent needed). Approximately 90 ac would

be required to locate the gas-fired power plant at an alternative site.

The NRC staff assumed that construction of the gas-fired units would be scheduled to coincide

with the expiration date of the JAFNPP OL. Consistent with the JAFNPP ER (Entergy 2006),

the NRC staff assumed a combined-cycle natural gas facility based on two 408-MWe combinedcycle units for a total facility size of 816 MWe. This assumption slightly understates the

environmental impacts of replacing the 881 MWe from JAFNPP. As a rough estimate, if a

natural gas-fired power plant of exactly 881 MWe were built, any numerical impacts in this

section, e.g., quantities of air pollutants, might simply be adjusted upward accordingly.

However, given these adjustments, the NRC staff has determined that the differences in

impacts between 816 MWe and 881 MWe of natural gas-fired generation would not be

significant and would not change the standard of significance (SMALL, MODERATE, or LARGE)

of any impacts.

The NRC staff assumed that the power plant would use a once-through cooling system. The

impacts of using a closed-cycle cooling system are evaluated in Section 8.2.2.2.

8.2.2.1 Once-Through Cooling System

The overall impacts of the natural gas-generating system using a once-through cooling system

are discussed in this section and summarized in Table 8-4. The extent of impacts at an

alternate site would depend on the location of the site.

I NUREG-1437, Supplement 31 8-20 January 2008
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Table 8-4. Summary of Environmental Impacts of Natural Gas-Fired Generation at the

JAFNPP Site and an Alternate Site Using Once-Through Cooling

JAFNPP Site Alternate Site

Impact

Category Impact Comments Impact Comments

Land Use

Ecology

SMALL to

MODERATE

MODERATE

The natural gas-fired power

plant would be constructed on

undeveloped portions of the

JAFNPP site. It would

require upwards of 90 ac for

power block, roads, parking

areas, and a gas pipeline

ROW. It would use existing

infrastructure, minimizing new

land requirements.

The natural gas-fired

alternative at the JAFNPP

site would be constructed

partly on previously disturbed

areas and would disturb

relatively little acreage at the

site. However, a 25-mi gas

supply line would need to be

constructed, which, assuming

a construction ROW of 75 ft,

would disrupt up to 230 ac of

terrestrial habitat. Ecological

impacts would include

impacts on threatened or

endangered species, wildlife

habitat loss and reduced

productivity, habitat

fragmentation, and a local

reduction in biological

diversity.

SMALL to

MODERATE

SMALL to

MODERATE

Land-use requirements

would be larger at the

alternate site because of the

need for additional

infrastructure such as

transmission facilities, roads,

parking areas, office

buildings, and cooling

system. The total impact

would depend on whether

the alternate site had been

previously disturbed.

Impacts would depend on

whether the alternate site is

previously developed.

Factors to consider include

location and ecology of site

and transmission line route.

Ecological impacts would

include impacts on

threatened or endangered

species, wildlife habitat loss

and reduced productivity,

habitat fragmentation, and a

local reduction in biological

diversity.

January 2008 8-21 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

Table 8-4 (cont.)

JAFNPP Site Alternate Site

Impact

Category Impact Comments Impact Comments

Water Use and SMALL

Quality-Surface

Water

Water Use and NO IMPACT

QualityGroundwater

Air Quality MODERATE

Combined-cycle units have

lower water requirements

than nuclear and coal-fired

power plants. The natural

gas-fired alternative would

use the existing once through

cooling system.

JAFNPP does not have

onsite pumpable groundwater

wells. Potable water is

supplied by the Town of

Scriba.

" SOx: 85 tons/yr

" NOx:272 tons/yr

" Carbon monoxide:

57 tons/yr

" PM10 particulates:

47 tons/yr

" Other: (1) hazardous air

pollutants, including

arsenic, formaldehyde,

and nickel and (2) carbon

dioxide emissions, which

contribute to global

warming

Minimal waste product from

fuel combination

Impacts would be minor.

SMALL to Combined-cycle units have

MODERATE lower water requirements

than nuclear and coal-fired

power plants. Total impacts

would depend on the volume

and other characteristics of

the receiving body of water.

SMALL to The impact to groundwater

MODERATE would depend on the site

characteristics, including the

amount of groundwater

available.

MODERATE The impacts at an unnamed

alternate site would be the

same as those for the

JAFNPP site.

Waste

Human Health

SMALL

SMALL

SMALL

SMALL

The impacts at an unnamed

alternate site would be the

same as those for the

JAFNPP site.

The impacts at an unnamed

alternate site would be the

same as those for the

JAFNPP site.

I NUREG-1437, Supplement 31 8-22 January 2008
Environmental Impacts of Alternatives

Table 8-4 (cont.)

JAFNPP Site Alternate Site

Impact

Category Impact Comments Impact Comments

Socioeconomics SMALL to

LARGE

Transportation MODERATE

Aesthetics SMALL

Historic and

Archaeological

Resources

Environmental

Justice

SMALL to

MODERATE

SMALL to

MODERATE

Impacts are expected to be

SMALL to LARGE and site

dependent because of

changes in employment and

tax revenue.

Transportation impacts

associated with construction

would be MODERATE.

Construction and operation of

a natural gas-fired power

plant at JAFNPP would not

alter the overall aesthetic

characteristics of the site.

Constructing a natural gasfired power plant would

require cultural resource

studies. Impacts would vary

depending on the location of

the plant on the undeveloped

portions of the JAFNPP site

and the presence of historic

and archaeological

resources.

Impacts to minority and lowincome populations would

vary depending on the

location of the power plant

site and other support

facilities

MODERATE

SMALL to Construction and operation

LARGE of a natural gas-fired power

plant at an alternate site

would change the aesthetic

characteristics of the site.

Transportation impacts

associated with construction

would be MODERATE.

SMALL to The impacts at an alternate

LARGE site would be the same as

those for the JAFNPP site.

SMALL to

MODERATE

SMALL to

MODERATE

The impacts at an alternate

site would be the same as

those for the JAFNPP site.

The impacts at an alternate

site would be the same as

those for the JAFNPP site.

Land Use

For siting at JAFNPP, existing facilities and infrastructure would be used to the extent

possible, limiting the amount of new construction that would be required. Specifically, the

NRC staff assumed that the natural gas-fired replacement power plant alternative would

require approximately 90 ac of land and would make use of existing transmission facilities,

roads, and parking areas. Operation of a new combined-cycle facility at the JAFNPP site

January 2008 8-23 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

would require the construction of approximately 25 mi of natural gas pipeline. It is estimated

that the pipeline would require approximately 230 ac for an easement. The onsite facilities

would represent expansion of an existing industrial land use.

For construction at an alternate site, the full land-area requirement for a natural gas-fired

facility would be necessary because no existing infrastructure would be available. Additional

land would be impacted by construction of a transmission line and natural gas pipelines to

serve the power plant. The gas line requirements at an alternate site would depend on the

characteristics and location of the alternate site.

Regardless of where the gas-fired power plant was built, additional land would be required

for natural gas wells and collection stations. Partially offsetting these offsite land

requirements would be the elimination of the need for uranium mining to supply fuel for

JAFNPP. In the GELS, the NRC staff estimated that approximately 1000 ac would be

affected for mining the uranium and processing it during the operating life of a nuclear power

plant.

Overall, the land-use impacts of constructing the natural gas-fired power plant at the

JAFNPP site would be SMALL to MODERATE. Overall, the land-use impacts of siting the

natural gas-fired power plant at an alternate site would depend on the chosen site and are

characterized as SMALL to MODERATE.

Ecology

Entergy expects that development of the gas-fired alternative power plant at the JAFNPP

site would be constructed partly on previously disturbed areas and would disturb relatively

little acreage at the site. However, to accommodate a gas-fired power plant at the JAFNPP

site, a 25-mi gas supply line would need to be constructed, which, assuming a construction

ROW of 75 ft, would disrupt up to 230 ac of terrestrial habitat. Ecological impacts to the

power plant site and utility easements would include impacts on threatened or endangered

species, wildlife habitat loss and reduced productivity, habitat fragmentation, and a local

reduction in biological diversity.

The GElS noted that land-dependent ecological impacts from construction would be SMALL

unless site-specific factors indicated a particular sensitivity and that operational impact

would be smaller than for other fossil fuel technologies of equal capacity. The connection to

a gas pipeline approximately 25 mi from the JAFNPP site is a site-specific factor that would

make the gas-fired alternative's ecological impacts larger than those of license renewal.

Therefore, in this case, ecological impacts of siting a natural gas-fired power plant at the

JAFNPP site would be MODERATE.

Impact on ecological resources from construction and operation of the representative natural

gas-fired power plant and associated offsite infrastructure at an alternate site is conjectural.

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However, ecological resources throughout much of the area would be similar to those for the

JAFNPP site alternative. The NRC staff concludes that the associated impact on ecological

resources would be SMALL to MODERATE.

Water Use and Quality-Surface Water

Overall, water requirements for combined-cycle generation are much less than for

conventional generators such as nuclear generators and coal-fired generators. A natural

gas-fired power plant sited at JAFNPP is assumed to use the existing once-through cooling

system. Surface water impacts would be expected to remain SMALL.

A natural gas-fired power plant at an alternate site is assumed to use a once-through

cooling system. The impact on surface water would depend on the volume and other

characteristics of the receiving body of water. The impacts would be SMALL to

MODERATE.

The NRC staff noted in the GElS that at either the JAFNPP site or an alternate site, some

erosion and sedimentation probably would occur during construction. Water-quality impacts

from sedimentation during construction are characterized in the GElS as SMALL. The NRC

staff also noted in the GElS that operational water quality impacts would be similar to, or

less than, those from other generating technologies.

" Water Use and Quality-Groundwater

JAFNPP does not have onsite pumpable groundwater wells. Potable water is supplied by

the Town of Scriba and cooling water is taken from Lake Ontario. Therefore, there would be

no groundwater impacts at the JAFNPP site.

For a natural gas-fired power plant at an alternate site, any groundwater withdrawal would

require a permit from the local permitting authority. The impact to groundwater would

depend on the site characteristics, including the amount of groundwater available. The

impacts would range between SMALL and MODERATE.

" Air Quality

Natural gas is a relatively clean-burning fuel. The gas-fired alternative would release similar

types of emissions but in lesser quantities than the coal-fired alternative. Hence, the gasfired alternative would be subject to the same type of air-quality regulations as a coal-fired

power plant, discussed in Section 8.2.1. The greatest concerns from combined-cycle

facilities are the emissions of ozone precursors, NOx, and volatile organic compounds

(VOCs).

January 2008 8-25 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

JAFNPP projects the following emissions for the natural gas-fired alterative (Entergy 2006):

o Sulfur oxides: 85 tons/yr

o Nitrogen oxides: 272 tons/yr

o Carbon monoxide: 57 tons/yr

o PM1o particulates: 47 tons/yr

A natural gas-fired power plant would also have unregulated carbon dioxide emissions that

would contribute to global warming. While these emissions have not traditionally been an

important environmental concern, they are becoming increasingly relevant at both the

national and international levels.

In December 2000, the EPA issued regulatory findings on emissions of hazardous air

pollutants from electric utility steam-generating units. Natural gas-fired power plants were

found by the EPA to emit arsenic, formaldehyde, and nickel (EPA 2000). Unlike coal and

oil-fired power plants, the EPA did not determine that emissions of hazardous air pollutants

from natural gas-fired power plants should be regulated under Section 112 of the Clean Air

Act.

Construction activities would result in temporary fugitive dust. Exhaust emissions would

also come from vehicles and motorized equipment used during the construction process and

by employee and delivery vehicles during operations.

The preceding emissions would likely be the same at JAFNPP or at an alternate site.

Impacts from the above emissions would be clearly noticeable but would not be sufficient to

destabilize air resources as a whole. The overall air-quality impact for a new natural gasfired power plant sited at JAFNPP or at an alternate site is considered MODERATE.

Waste

There would be spent catalyst from NOx emissions control and small amounts of solid-waste

products (i.e., ash) from burning natural gas fuel. In the GElS, the NRC staff concluded that

waste generation from gas-fired technology would be minimal. Gas firing results in very few

combustion by-products because of the clean nature of the fuel. Waste-generation 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 might become necessary for a replacement baseload natural gas-fired power

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. Number 2 fuel oil does not produce any appreciable ash.

I NUREG-1437, Supplement 31 8-26 January 2008
Environmental Impacts of Alternatives

Overall, the waste impacts would be SMALL for a natural gas-fired power plant sited at

JAFNPP or at an alternate site.

Human Health

In Table 8-2 of the GELS, the NRC staff identifies cancer and emphysema as potential

health risks from gas-fired power plants. The risk may be attributable to NOx emissions that

contribute to ozone formation, which in turn contribute to health risks. Emissions of NOx

from any gas-fired power plant would be regulated. For a power plant sited in New York,

NOx emissions would be regulated by the NYSDEC. Human health effects would not be

detectable or would be sufficiently minor that they would neither destabilize nor noticeably

alter any important attribute of the resource. Overall, the impacts on human health of the

natural gas-fired alternative sited at JAFNPP or at an alternate site would be SMALL.

Socioeconomics

Construction of a natural gas-fired power plant would take approximately two years. In the

GELS, peak employment is determined to be approximately 1200 workers, The NRC staff

assumed that construction would take place while JAFNPP continued operation and would

be completed by the time it permanently ceased operations. During construction, the

communities surrounding the JAFNPP site would experience demands on housing and

public services that would have SMALL impacts. These impacts would be tempered by

construction workers commuting from other parts of Oswego and Onondaga counties. After

construction, the communities would be impacted by the loss of jobs. The current JAFNPP

workforce (716 workers) would decline through a decommissioning period to a minimal

maintenance size. The gas-fired power plant would introduce a replacement tax base at

JAFNPP or an alternate site and approximately 50 new permanent jobs. Impacts in Oswego

and Onondaga counties resulting from decommissioning of JAFNPP might be offset to some

degree by potential job opportunities in the Syracuse area.

In the GELS, the NRC staff concluded that socioeconomic impacts from constructing a

natural gas-fired power plant would not be very noticeable and that the small operational

workforce would have the lowest socioeconomic impacts of any nonrenewable technology.

Compared to the coal-fired and nuclear alternatives, the smaller size of the construction

workforce, the shorter construction time frame, and the smaller size of the operations

workforce would minimize socioeconomic impacts. For these reasons, socioeconomic

impacts associated with the construction and operation of a natural gas-fired power plant

would be MODERATE for siting at JAFNPP.

The extent of socioeconomic impacts from constructing and operating a natural gas-fired

power plant at an alternate site in upstate New York would depend on its location. Impacts

near large population centers (i.e., Syracuse) would likely be small, with moderate impacts

possible in more rural areas. Communities in Oswego County in particular would

January 2008 8-27 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

experience MODERATE to LARGE impacts due to losses in employment and tax revenues

from the closure of JAFNPP, especially if the natural gas-fired power plant is constructed

outside the area. Overall, the socioeconomic impacts of a natural gas-fired power plant at an

alternate site would be SMALL to LARGE depending on the location of the plant.

" Transportation

Transportation-related impacts associated with construction and operations would depend

on the population density and transportation infrastructure in the vicinity of the site. The

impacts can be classified as MODERATE for siting at the JAFNPP site or an alternate site.

" Aesthetics

The turbine buildings (106-ft tall) and exhaust stacks (approximately 225-ft tall) would be

visible during daylight hours from offsite. The gas pipeline compressors would also be

visible. However, development of the natural gas-fired power plant at the JAFNPP site

would represent an incremental addition to an existing power plant with similar

characteristics. A forest buffer provides a visual screen to residential developments

bordering the site. Overall, the NRC staff concludes that aesthetic impacts from

development of a natural gas-fired power plant at the JAFNPP site would be SMALL.

At an alternate site, the buildings and associated transmission line and gas pipeline

compressors would be visible offsite. The visual impact of a new transmission line would be

especially significant. Aesthetic impacts would be mitigated if the power plant were located

in an industrial area adjacent to other power plants. Overall, the aesthetic impacts

associated with an alternate site are categorized as MODERATE to LARGE. The greatest

contributor to this categorization is the aesthetic impact of the new transmission line.

Natural gas generation would introduce mechanical sources of noise that would be audible

offsite. Sources contributing to total noise produced by power plant operation are classified

as continuous or intermittent. Continuous sources include the mechanical equipment

associated with normal power plant operations. Intermittent sources include the use of an

outside loudspeaker and the commuting of power plant employees. However, it is expected

that the power plant would comply with all applicable noise ordinances and standards.

Therefore, the noise impacts of a natural gas-fired power plant at the JAFNPP site would be

SMALL. At an alternate site, these noise impacts would be SMALL to LARGE depending on

the location of the site.

Historic and Archaeoloqical Resources

At both JAFNPP and an alternate site, a cultural resource inventory would be needed for

any undeveloped portions of the site that had not been previously surveyed. Other

properties, if any, which would be acquired to support the power plant, would also need to

I NUREG-1437, Supplement 31 8-28 January 2008
Environmental Impacts of Alternatives

be surveyed for cultural resources prior to ground-disturbing activities at the power plant

site.

Before construction at JAFNPP or an alternate site, historic and archaeological studies

would be needed to identify, evaluate, and address the potential impacts of new power plant

construction on cultural resources. These studies would likely be needed for all areas of

potential disturbance at the proposed power plant site, other support facilities, and along

associated corridors where new construction would occur (e.g., roads, transmission and

pipeline corridors, other ROWs). Historic and archaeological resource impacts can

generally be effectively managed and as such are considered SMALL to MODERATE

depending on the location and presence of cultural resources.

Environmental Justice

Impacts on minority and low-income populations associated with a replacement natural gasfired power plant built at JAFNPP or an alternate site in New York State would depend on

the location of the site and population distribution. Impacts on housing availability and prices

during power plant construction could disproportionately affect minority and low-income

populations. Closure of JAFNPP would result in the loss of approximately 716 jobs causing

economic conditions that could affect employment prospects for minority or low-income

populations. Depending on plant location, overall impacts could vary between SMALL and

MODERATE.

8.2.2.2 Closed-Cycle Cooling System

This section discusses the environmental impacts of constructing a natural gas-fired generation

system at either the JAFNPP site or an alternate site using closed-cycle cooling. The impacts

(SMALL, MODERATE, or LARGE) of this option are the same as for a natural gas-fired power

plant using the once-through cooling system. However, there are minor environmental

differences between the closed-cycle and once-through cooling systems. Table 8-5

summarizes the incremental differences.

8.2.3 Nuclear Power Generation

Since 1997, the NRC has certified four new standard designs for nuclear power plants under

10 CFR 52, Subpart B. These designs are the 1300 MWe U.S. Advanced Boiling Water

Reactor (10 CFR 52, Appendix A), the 1300 MWe System 80+ Design (10 CFR 52,

Appendix B), the 600 MWe AP600 Design (10 CFR 52, Appendix C), and AP 1000 (10 CFR 52,

Appendix D). All of these power plants are light-water reactors. Recently, several Combined

License (COL) applications have been submitted to the NRC. A COL is an authorization from

the NRC to construct and operate a nuclear power plant at a specific site in accordance with

laws and regulations. These recent developments indicate continuing interest in the possibility

of licensing new nuclear power plants. Consequently, construction of a new nuclear power

January 2008 8-29 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

plant at both the JAFNPP site and an alternate site is considered in this section. The NRC staff

assumed that the new nuclear power plant would have a 40-year lifetime.

Table 8-5. Summary of Environmental Impacts of Natural Gas-Fired Generation at Either

the JAFNPP Site or an Alternate Site with Closed-Cycle Cooling

Impact Category Change in Impacts from Once-Through Cooling System

Land Use 25 to 30 additional ac required for cooling towers and associated support

infrastructure.

Ecology Impact would depend on ecology at the site. Additional impact to

terrestrial biota from cooling tower drift. Reduced impact to aquatic

ecology.

Water Use and Quality- Discharge of cooling tower blowdown containing dissolved solids.

Surface Water Discharge would be regulated. Decrease water withdrawal and less

thermal load on receiving body of water. Increase in consumptive use of

water due to evaporation.

Water Use and Quality- No change

Groundwater

Air Quality No change

Waste No change

Human Health No change

Socioeconomics No change

Transportation No change

Aesthetics Introduction of cooling towers and associated plume with noise impacts

from operation of cooling towers.

Historic and Archaeological No change

Resources

Environmental Justice No change

NRC has summarized environmental data associated with the uranium fuel cycle in Table S-3 of

10 CFR 51.51. The impacts listed 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 and sited

at JAFNPP or an alternate site. The impacts shown in Table S-3 are for a 1000-MWe reactor.

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

I NUREG-1437, Supplement 31 8-30 January 2008
Environmental Impacts of Alternatives

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 once-through cooling is presented in Section 8.2.3.1 and closed-cycle cooling in

Section 8.2.3.2.

8.2.3.1 Once-Through Cooling System

The overall impacts of a nuclear generating system using a once-through cooling system are

discussed in this section. The impacts are summarized in Table 8-6. The extent of impacts at

an alternate site would depend on the location of the site.

Land Use

The existing facilities and infrastructure at the JAFNPP site would likely be used, limiting the

amount of new construction that would be required. Existing transmission facilities, roads,

parking areas, and cooling system would be used. According to the GELS, light-water

reactors require approximately 500 to 1000 ac excluding transmission lines (these estimates

are not scaled to any particular facility size). Much of the land that would be used has been

previously disturbed. The JAFNPP site consists of approximately 700 ac and would be

adequate to support a new nuclear facility. There would be no net change in land needed

for uranium mining because land needed to supply the new nuclear power plant would

replace the land no longer needed to supply uranium for fueling the existing reactors at

JAFNPP. Overall, the land use impact of a replacement nuclear power plant at the existing

JAFNPP site would be SMALL. However, the impact would be greater than the OL renewal

alternative.

Land-use requirements at an alternate site would be similar to siting at JAFNPP except for

the possible need for additional land for a new transmission line. In addition, it might be

necessary to construct a rail spur to bring in equipment during construction. Depending on

transmission line routing, siting a new nuclear power plant at an alternate site would result in

MODERATE to LARGE land-use impacts.

Ecology

Locating a replacement nuclear power plant at the JAFNPP site would alter ecological

resources because of construction and the need to convert unused land to active industrial

use. In total, impacts would include habitat degradation, fragmentation, or loss as a result of

construction activities. Ecological communities would experience reduced productivity and

biological diversity from disturbing previously intact land. Overall, the ecological impacts of

the nuclear alternative at the JAFNPP site would be SMALL. However, the impact would be

greater than the OL renewal alternative.

January 2008 8-31 NUREG-1437, Supplement 31 1
Environmental Impacts of Alternatives

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

JAFNPP Site and an Alternate Site Using Once-Through Cooling

JAFNPP Site Alternate Site

Impact

Category Impact Comments Impact Comments

Land Use

Ecology

Water Use

and QualitySurface Water

Water Use

and QualityGroundwater

SMALL

SMALL

SMALL

Would require approximately

500 to 1000 ac for the power

plant. The new nuclear

power plant would require the

use of previously disturbed

undeveloped portions of the

JAFNPP site. Would use the

existing infrastructure to the

extent possible.

Would use undeveloped

areas at current Nine Mile

Point site.

The nuclear alternative would

use the existing once-through

cooling system.

MODERATE

to LARGE

MODERATE

to LARGE

SMALL to

MODERATE

SMALL to

MODERATE

Land use requirements would

be larger at the alternate site

than at the JAFNPP site

because of the potential need

for land for a transmission line.

Overall, impacts would depend

on whether the alternate site

had been previously disturbed.

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; and

reduced productivity and

biological diversity.

Impacts would depend on the

volume of water withdrawn

and the characteristics of the

surface body of water.

Impacts would depend on the

volume of water withdrawn

and the characteristics of the

groundwater source.

Same impacts as JAFNPP

site.

NO IMPACT Groundwater is not used at

the JAFNPP site.

Air Quality SMALL Fugitive emissions and

emissions from vehicles and

equipment during

construction. Small amount

of emissions from diesel

generators and possibly other

sources during operation.

SMALL

I NUREG-1437, Supplement 31 &.32 January 2008
Table 8-6 (cont.)

JAFNPP Site Alternate Site

Impact

Category Impact Comments Impact Comments

Waste SMALL

Human Health SMALL

Socioeconomics SMALL to

MODERATE

Transportation SMALL to

LARGE

Waste impacts for an

operating a nuclear power

plant are set out in

10 CFR 51, Appendix B,

Table B-1. Debris would be

generated and removed

during construction.

Human health impacts for an

operating nuclear power plant

are set out in 10 CFR 51,

Appendix B, Table B-I.

During the construction,

impacts would be

MODERATE. Up to 2500

workers during the peak of

the five-year construction

period. During operation,

employment levels would be

similar to those for JAFNPP.

Overall, socioeconomic

impacts from operation would

be SMALL.

Transportation impacts

associated with construction

would be MODERATE to

LARGE. Transportation

impacts associated with

operations would be SMALL.

There would be visual

aesthetic impacts associated

with power plant buildings

and structures. There would

be both intermittent and

continuous noise impacts

from the power plant during

construction and operations.

SMALL

SMALL

Same impacts as JAFNPP

site.

Same impacts as JAFNPP

site.

SMALL to The characteristics of the

LARGE construction period and

operation at an alternate site

would be similar to those at

JAFNPP.. Socioeconomic,

impacts to the local community

would depend on the location

of the alternate site and would

vary from SMALL to LARGE.

SMALL to Transportation impacts

LARGE associated with construction

would be MODERATE to

LARGE. Transportation

impacts associated with

operations would be SMALL to

MODERATE.

SMALL to The significance of the

LARGE impacts would depend on the

location of the alternate site.

An alternate site could require

transmission lines, with

aesthetic impacts.

Aesthetics SMALL to

MODERATE

January 2008 8-33 NUREG-1 437, Supplement 31 1
Environmental Impacts of Alternatives

Table 8-6 (cont.)

JAFNPP Site Alternate Site

Impact

Category Impact Comments Impact Comments

Historic and SMALL to Construction of a new nuclear SMALL to The impacts at an alternate

Archaeological MODERATE power plant would require MODERATE site would be the same as

Resources cultural resource studies. those for the JAFNPP site.

Impacts could varydepending

on the location of the plant on

undeveloped portions of the

JAFNPP site and presence of

historic and archaeological

resources.

Environmental SMALL to Impacts to minority and low- SMALL to The impacts at an alternate

Justice MODERATE income populations would MODERATE site would be the same as

vary depending on the those for the JAFNPP site..

location of the power plant

site and other support

facilities.

At an alternate site, there would be construction impacts and new incremental operational

impacts. Even assuming siting at a previously disturbed area, the impacts might alter the

ecology. Impacts would include habitat degradation, fragmentation or loss, reduced

ecosystem productivity (i.e., including wildlife species), and a reduction in biological

diversity. Construction and maintenance of transmission lines, a rail spur, or a barge

offloading facility would result in the same types of ecological impacts. Overall, the impacts

of the nuclear alternative at an alternate site would be MODERATE to LARGE.

Water Use and Quality-Surface Water

It is assumed that the replacement nuclear power plant alternative at the JAFNPP site would

use the existing once-through cooling system, which would minimize incremental water-use

and quality impacts. Surface-water impacts would be expected to remain SMALL. The

impacts would be sufficiently minor that they would not noticeably alter any important

attribute of the resource.

For an alternate site, the cooling water would likely be drawn from a surface body of water.

The impact on the surface water would depend on the volume of water needed and the

characteristics of the body of water. The impacts would be SMALL to MODERATE.

I NUREG-1437, Supplement 31 8-34 January 2008
Environmental Impacts of Alternatives

" Water Use and Quality-Groundwater

Groundwater is not currently used for operation of JAFNPP, and it is unlikely that

groundwater would be used for an alternative nuclear power plant sited at JAFNPP.

Therefore, there would be no groundwater impacts at the JAFNPP site. Use of groundwater

for a nuclear power plant sited at an alternate site would be a possibility. Any groundwater

withdrawal would require a permit from the local permitting authority. The impacts of the

nuclear alternative at an alternate site would be SMALL to MODERATE.

* Air Quality

Construction of a new nuclear power plant sited at JAFNPP or 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 power plant would have minor air emissions associated with diesel generators and

other minor intermittent sources. These emissions would be regulated by NYSDEC.

Overall, emissions and associated impacts to air quality of a nuclear power plant at either

the JAFNPP site or an alternate site would be SMALL.

" Waste

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. Construction-related debris would be

generated during construction activities and removed to an appropriate disposal site.

Overall, waste impacts of a new nuclear power plant at either the JAFNPP site or an

alternate site would be SMALL.

" Human Health

Human health impacts for an operating nuclear power plant are set out in 10 CFR 51

Subpart A, Appendix B, Table B-I. Overall, human health impacts of a new nuclear power

plant at either the JAFNPP site or an alternate site would be SMALL.

" Socioeconomics

Construction of the new nuclear power plant would be conducted over a period of five years

with a peak workforce of 2500. Construction would take place while the existing nuclear unit

would continue operation and would be completed by the time JAFNPP permanently ceased

operation.

If the new nuclear power plant were constructed at the JAFNPP site, the construction

workers would be in addition to the employees who currently work at the site. Surrounding

communities would experience significant demands on rental housing and public services.

The construction workforce would also add to the local tax base. After construction, the local

January 2008 8-35 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

communities would be impacted by the loss of the construction jobs. In total, the

socioeconomic impacts during the construction period for the nuclear alternative at the

JAFNPP site would be MODERATE.

At an alternate site, the construction impacts would be similar to those at the JAFNPP site.

Impacts would be SMALL to LARGE, depending on the location of the alternate site to a

large population center.

It is assumed that the replacement nuclear unit would have an operating workforce

comparable to the 716 workers currently working at JAFNPP. The replacement nuclear unit

would provide a new tax base to offset the loss of tax base associated with

decommissioning JAFNPP. For all of these reasons, the socioeconomic impacts for

operating a new nuclear power plant at JAFNPP would be SMALL.

The impacts of operating a new nuclear power plant at an alternate site would be generally

larger than those at the JAFNPP site, depending on the proximity of the alternate site to a

large population center. Impacts would be SMALL to LARGE, depending on the location of

the alternate site.

Transportation

During the five-year construction period, up to 2500 construction workers would be working

at the JAFNPP site in addition to the 716 workers who operate JAFNPP. In addition, the

large construction workforce and delivery of construction materials would put significant

pressure on existing highways near the JAFNPP site. Impacts would be MODERATE to

LARGE. Transportation impacts associated with the operation of JAFNPP would be

SMALL.

Transportation-related impacts associated with commuting construction workers and the

delivery of construction materials and equipment at an alternate site would be sitedependent and would be MODERATE to LARGE. Transportation impacts associated with

operations would also be site-dependent and would be SMALL to MODERATE.

Aesthetics

The nuclear alternative would result in both visual and noise aesthetic impacts. Visual

impacts would result from the construction of several new structures, including, most

prominently, the containment building. The replacement nuclear units would also likely be

visible at night because of outside lighting. Visual impacts at night would be mitigated by

reduced lighting and appropriate shielding. Overall, the visual aesthetic impacts of the

nuclear alternative at the JAFNPP site would be MODERATE.

At an alternate site, the aesthetic impacts would be larger. There would also be aesthetic

impacts associated with the need for new transmission lines. Light from the new nuclear

I NUREG-1437, Supplement 31 8-36 January 2008
Environmental Impacts of Alternatives

power plant would-be detectable offsite. The impact of light could be mitigated if the power

plant were located in an industrial area adjacent to other power plants. Overall, the

aesthetic impacts associated with an alternate site would be MODERATE to LARGE

including the aesthetic impact of a new transmission line.

Nuclear generation would introduce continuous and intermittent noise from power plant

operations. Sources of noise include the mechanical equipment associated with normal

power plant operations, outside loudspeakers, and the workforce. At the JAFNPP site,

power plant-operation noises would be similar to existing noise levels from current power

plant operations. Noise impacts of the nuclear alternative at JAFNPP would be SMALL. At

an alternate site, noise impacts would be SMALL to LARGE, depending on the location of

the site.

Historic and Archaeological Resources

At both JAFNPP and an alternate site, a cultural resource inventory would be needed for

any undeveloped portions of the site that had not been previously surveyed. Other

properties, if any, that were acquired to support the power plant would also need to be

surveyed for cultural resources, prior to ground-disturbing activities at the power plant site.

Before construction at JAFNPP or an alternate site, studies would be needed to identify,

evaluate, and address the potential impacts of new power plant construction on cultural

resources. These studies would be needed for all areas of potential disturbance at the

proposed power plant site, other support facilities, and along associated corridors where

new construction would occur (e.g., roads, transmission corridors, rail lines, other ROWs).

Historic and archaeological resource impacts would generally be effectively managed and

as such would be SMALL to MODERATE depending on location and presence of cultural

resources.

" Environmental Justice

Impacts on minority and low-income populations associated with a replacement nuclear

power plant at JAFNPP or an alternate site in New York State would depend on the location

of the site and population distribution. Impacts on housing availability and prices during

power plant construction could disproportionately affect minority and low-income

populations. Closure of JAFNPP and construction of a replacement nuclear power plant at

an alternate site would result in the loss of approximately 716 jobs causing economic

conditions that could affect employment prospects for minority or low-income populations in

the vicinity of JAFNPP. Depending on the plant location, overall impacts could vary

between SMALL and MODERATE.

January 2008 8-37 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

8.2.3.2 Closed-Cycle Cooling System

This section discusses the environmental impacts of constructing at an alternate site a nuclear

power plant that uses a closed-cycle cooling system with a cooling tower. The impacts (SMALL,

MODERATE, or LARGE) of this option would be similar to the impacts for a nuclear power plant

using a once-through cooling system. However, there would be minor environmental

differences between the closed-cycle and once-through cooling systems. Table 8-7

summarizes the incremental differences.

Table 8-7. Summary of Environmental Impacts of a New Nuclear Power Plant Sited at an

Alternate Site with Closed-Cycle Cooling

Impact Category Change in Impacts from Once-Through Cooling System

Land Use 20 to 30 ac of land would be required on previously disturbed undeveloped

land for cooling towers and associated infrastructure.

Ecology Impacts would depend on ecology at the site. Additional impact to terrestrial

ecology from cooling tower drift. Reduced impact to aquatic ecology.

Water Use and Quality- Discharge of cooling tower blowdown containing dissolved solids. Discharge

Surface Water would be regulated by the State of New York. Decreased water withdrawal

and less thermal load on receiving body of water. Consumptive use of water

due to evaporation from cooling towers.

Water Use and Quality- No change

Groundwater

Air Quality No change

Waste No change

Human Health No change

Socioeconomics No change

Transportation No change

Aesthetics Introduction of cooling towers and associated plume. Natural draft towers

would be up to 520 ft tall. Mechanical draft towers would be up to 100 ft tall

and would have an associated noise impact.

Historic and Archaeological No change

Resources

Environmental Justice No change

8.2.4 Purchased Electrical Power

If available, purchased power from other sources would potentially obviate the need to renew

the JAFNPP OL. The New York State energy plan (NYSERDA 2002) is designed to promote

competition in energy supply markets by facilitating participation by non-utility suppliers. A

I NUREG-1 437, Supplement 31 8-38 January 2008
Environmental Impacts of Alternatives

regulatory structure is in place to appropriately anticipate and meet electricity demands. The

New York Independent System Operator (NYISO) anticipates that adequate supplies of

electricity will be available to meet anticipated future demands through at least 2021. In theory,

purchased power is a feasible alternative to JAFNPP license renewal. There is no assurance,

however, that sufficient capacity or energy would be available during the entire time frame of

2014 to 2034 to replace the approximately 881 MWe of baseload generation from JAFNPP. For

example, EIA projects that total gross U.S. imports of electricity from Canada and Mexico will

gradually increase from 38.4 billion kWh in year 2001 to 48.9 billion kWh in year 2005 and then

gradually decrease to 24.4 billion kWh in year 2020 (DOE/EIA 2004). On balance, it appears

unlikely that electricity imported from Canada or Mexico would be able to replace JAFNPP's

generating capacity.

If power to replace JAFNPP capacity were purchased from sources in the U.S. or from a foreign

country, the generating technology would likely be one of those described in this SEIS and in

the GElS (i.e., coal, natural gas, or nuclear). The description of the environmental impacts of

other technologies in Chapter 8 of the GElS is representative of the purchased electrical power

alternative to renewal of the JAFNPP OL. Thus, the environmental impacts of imported power

would still occur but would be located elsewhere within the region, nation, or in another country.

For these reasons, the NRC staff does not believe that purchasing power to make up for the

generation at JAFNPP is a meaningful alternative that requires independent analysis.

8.2.5 Other Alternatives

Other power generation technologies considered by NRC are discussed in Sections 8.2.5.1

through 8.2.5.11.

8.2.5.1 Oil-Fired Generation

EIA projects that oil-fired power plants will account for very little of the new power generation

capacity in the U.S. through the year 2030 because of higher fuel costs and lower efficiencies

(DOE/EIA 2007). Oil-fired operation is more expensive than nuclear or coal-fired operation.

Future increases in oil prices are expected to make oil-fired generation increasingly more

expensive than coal-fired generation. The high cost of oil has prompted a steady decline in its

use for electricity generation. Increasing domestic concerns over oil security will only

exacerbate the move away from oil-fired electricity generation. Therefore, the NRC staff does

not consider oil-fired generation by itself a feasible alternative to the baseload generation of

JAFNPP.

8.2.5.2 Wind Power

Wind power, by itself, is not suitable for large baseload capacity. As discussed in Section 8.3.1

of the GElS, wind has a high degree of intermittency, and average annual capacity factors for

wind power plants are relatively low (less than 30 percent). Wind power, in conjunction with

January 2008 8-39 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

energy storage mechanisms, might serve as a means of providing baseload power. However,

current energy storage technologies are too expensive for wind power to serve as a large

baseload generator.

Most of western New York is in wind-power Class 2 or 3, in which the average wind speed is

4.4 to 5.6 meters per second (m/s) (Elliott et al. 1986). There is a narrow band of Class 3 and 4

areas along Lake Ontario. Wind turbines are economical in Class 3 through 7 areas, in which

the average wind speeds are 7.0 to >8.8 m/s (DOE 2005). Wind turbines typically operate at

25 to 35 percent capacity factor compared to 80 to 95 percent for a baseload power plant

(NWPPC 2000). Because the largest commercially available wind turbines produce in the range

of 1 MW to 3 MW, 294 to 881 units would be required to replace the JAFNPP generating

capacity.

As of September 2006, there were approximately 280 MW of grid-connected wind-power

facilities in New York State, with an additional 255 MW of additional capacity in various stages

of planning (AWEA 2006). The New York State Energy Research and Development Authority

(NYSERDA) estimates there is a statewide potential for approximately 17,000 MW of installed

capacity, of which approximately 3200 MW would be available for the peak summer load

(NYSERDA 2002). Access to many of the best wind-power sites would require extensive road

building, clearing (for towers and blades), and leveling (for the tower bases and associated

facilities) in steep terrain. Also, many of the best quality wind sites are on ridges and hilltops

that would have greater archeological sensitivity than surrounding areas. For these reasons,

development of large-scale, land-based wind-power facilities are likely to be costly and would

have MODERATE to LARGE impacts on aesthetics, archaeological resources, land use, and

terrestrial ecology.

The offshore wind speeds on Lake Ontario are higher than those onshore and would thus

support greater energy production than onshore facilities. Development of an offshore windpower facility could impact shipping lanes, disrupt the aquatic ecology, and would be visible for

many miles, resulting in considerable aesthetic impacts. These impacts would be MODERATE

to LARGE.

For these reasons, the NRC staff concludes that wind power alone is not a feasible substitute at

this time for the baseload generation from JAFNPP. However, the NRC staff recognizes that

wind power projects are being developed in areas with significant wind potential. Therefore, it is

reasonable to include wind power in a combination of alternatives that would replace the

generation from JAFNPP. Combined alternatives are discussed in Section 8.2.6.

8.2.5.3 Solar Power

Solar technologies use the sun's energy and light to provide heat, cooling, light, hot water, and

electricity for homes, businesses, and industry. Solar-power technologies, both photovoltaic

and thermal, cannot currently compete with conventional fossil-fuel technologies in gridI NUREG-1437, Supplement 31 8-40 January 2008
Environmental Impacts of Alternatives

connected applications due to higher capital costs per kilowatt of capacity. The average

capacity factor for photovoltaic cells is approximately 25 percent and for solar thermal systems,

25 to 40 percent. These capacity factors are low because solar power is an intermittent

resource, providing power when the sun is strong, whereas JAFNPP provides constant

baseload power. Solar technologies simply cannot make up for the capacity from JAFNPP

when the sun is not shining.

There could be substantial impacts to natural resources (e.g., wildlife habitat, land use,

aesthetics) from the construction of solar power-generating facilities. As stated in the GELS,

land requirements are high. Based on the land requirement of 14 ac for every 1 MWe

generated, over 12,000 ac would be required to replace the approximately 881 MWe produced

by JAFNPP. There is not enough land for either type of solar electric system at the existing

JAFNPP site, and both would have large environmental impacts at an alternate site.

Construction impacts would be similar to those associated with a large wind farm, as discussed

in Section 8.2.5.2. The operating facility would also have considerable aesthetic impact.

Because of natural resource impacts (land, ecological, and aesthetic), and high technology

costs, solar power is not deemed a feasible baseload alternative to license renewal of JAFNPP.

However, the NRC staff recognizes that distributed solar power does provide generation and

that during the license renewal period, generation from solar power could continue to grow.

Therefore, it is reasonable to include solar power in combinations of alternatives to replace the

generation from JAFNPP. Combined alternatives are discussed in Section 8.2.6.

8.2.5.4 Hydropower

New York State has a technical potential for 2527 MW of additional installed hydroelectric

capacity by the year 2022, only 909 MW of which represents summer peak capacity. If all this

capacity were developed, it would be enough to replace the 881-MW generating capacity of

JAFNPP. However, as stated in Section 8.3.4 of the GElS, 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. DOE/EIA states that potential sites for hydroelectric dams have already

been largely established in the U.S., and environmental concerns are expected to prevent the

development of any new sites (DOE/EIA 2002).

The NRC staff estimates in the GElS that land requirements for hydroelectric power are

approximately 1 million ac per 1000 MWe. Replacement of JAFNPP generating capacity would

require flooding slightly less than this amount of land. Due to the large land-use and related

environmental and ecological resource impacts associated with siting hydroelectric facilities

large enough to replace JAFNPP, the NRC staff concludes that local hydropower is not a

feasible alternative to JAFNPP OL renewal on its own. Any attempts to site hydroelectric

facilities large enough to replace JAFNPP would result in LARGE environmental impacts.

January 2008 8-41 NUREG-1437, Supplement 31 1
Environmental Impacts of Alternatives

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, the NRC staff stated in the GElS that geothermal technology

is not widely used as baseload generation because of the limited geographical availability of the

resource and immature status of the technology. As illustrated by Figure 8.4 in the GELS,

geothermal power plants are most likely to be sited in the western continental U.S., Alaska, and

Hawaii where geothermal reservoirs are prevalent. A study commissioned by NYSERDA and

the DOE, completed in 1996, found that there is some potential for geothermal electric power

production in western upstate New York but high cost inhibits its development (NRC 2006).

Therefore, the NIRC staff concludes that geothermal energy is not a feasible alternative to

renewal of the JAFNPP OL.

8.2.5.6 Wood Waste

The use of wood waste to generate electricity is limited largely to states with significant wood

resources, such as California, Georgia, Maine, Michigan, Minnesota, Oregon, and Washington.

Electric power is generated in these states by pulp, paper, and paperboard industries, which

consume wood and wood waste for energy, benefiting from the use of waste materials that

would otherwise represent a disposal problem.

The NRC staff stated in the GElS that 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. The required fuels are variable and site-specific. A significant barrier to

using wood waste to generate electricity is the high delivered-fuel cost and high construction

cost per MW of generating capacity. Larger wood-waste power plants generate only 40 to 50

MWe. The overall construction impact per MW of installed capacity is estimated in the GElS to

be approximately the same as that for a coal-fired power plant, although facilities using wood

waste for fuel would be built on smaller scales. Like coal-fired power plants, wood-waste power

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

baseload generating facility, ecological impacts of large-scale timber cutting (e.g., soil erosion,

loss of wildlife habitat), and high inefficiency, the NRC staff determined that wood waste is not a

feasible alternative to renewing the JAFNPP OL.

8.2.5.7 Municipal Solid Waste

Municipal waste combustors incinerate 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 (EPA 2006). Municipal waste

combustors use three basic types of technologies: mass burn, modular, and refuse-derived fuel

(DOE/EIA 2001). Mass burning technologies are most commonly used in the U.S. This group

I NUREG-1437, Supplement 31 8-42 January 2008
Environmental Impacts of Alternatives

of 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. 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, New

York, 511 U.S. 383, 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 2001).

The decision to burn municipal waste to generate energy is usually driven by the need for an

alternative to landfills. The use of landfills as a waste disposal option is likely to increase in the

near term, but it is unlikely that many landfills will begin converting waste to energy because of

unfavorable economics, particularly with electricity prices declining in real terms.

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 is the portion of unburned waste

that falls to the bottom of the grate or furnace. Fly ash is the small particles that rise from the

furnace during combustion. Fly ash is generally removed from flue-gases using fabric filters

and/or scrubbers (DOE/EIA 2001).

Currently there are approximately 89 waste-to-energy power plants operating in the U.S. These

power plants generate approximately 2800 MWe or an average of 31.5 MWe per power plant

(IWSA 2006), which is much smaller than what is needed to replace the 881 MWe of JAFNPP.

The NRC staff stated in the GElS that the initial capital costs for municipal solid-waste power

plants are greater than for comparable steam-turbine technology at wood-waste facilities, due to

the need for specialized waste-separation and -handling equipment for municipal solid waste.

Furthermore, the overall construction impact from a waste-fired power plant is estimated in the

GElS to be approximately the same as that for a coal-fired power plant. Additionally, wastefired power plants have the same or greater operational impacts (including impacts on the

aquatic environment, air, and waste disposal). Some of these impacts would be MODERATE

but still larger than the environmental effects of license renewal of JAFNPP. Therefore,

municipal solid waste would not be a feasible alternative to renewal of the JAFNPP OL,

particularly at the scale required.

January 2008 8-43 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

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 GELS, the NRC staff pointed 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 power plant such as JAFNPP. For these reasons, such

fuels do not offer a feasible alternative to renewal of the JAFNPP OL.

8.2.5.9 Fuel Cells

Fuel cells work without combustion and therefore do not have the environmental impacts of

combustion. Power is produced electrochemically by passing a hydrogen-rich fuel over an

anode and air over a cathode and separating the two by an electrolyte. The only by-products

are heat, water, and carbon dioxide. 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 approximately $4500 per kW of installed capacity (DOE 2006).

Higher-temperature second-generation fuel cells achieve higher fuel-to-electricity and thermal

efficiencies. The higher temperatures contribute to improved efficiencies and give the secondgeneration fuel cells the capability to generate steam for cogeneration and combined-cycle

operations.

DOE launched a major initiative, the Solid State Energy Conversion Alliance, to bring about

dramatic reductions in fuel cell costs. The goal is to cut the cost to as low as $400 per kW by

2010, which would make fuel cells competitive for virtually every type of power application (DOE

I 2006). By comparison, the installed capacity cost for a natural gas-fired, combined-cycle power

plant is about $400 per kW (DOE 2006). At present, fuel cells are not economically or technologically competitive with other alternatives for baseload electricity generation and are

consequently not a feasible alternative to renewal of the JAFNPP OL.

8.2.5. 10 Delayed Retirement

As noted in the GELS, extending the lives of existing non-nuclear generating power plants

beyond the time they were originally scheduled to be retired represents another potential

alternative to license renewal. Even without retiring any electrical power generating units,

Entergy expects to require additional capacity in the near future. Thus, even if substantial

capacity were scheduled for retirement and would be delayed, some of the delayed retirement

would be needed just to meet load growth.

Older power plants that may be candidates for retirement tend to use less efficient generation

and pollution control technologies than modern power plants. Therefore, substantial upgrades

I NUREG-1437, Supplement 31 8-44 January 2008
Environmental Impacts of Alternatives

are typically required to achieve efficiencies necessary to cost effectively extend operations and

meet applicable environmental standards.

It was stated in the GElS that NYISO load and capacity projections assume that nuclear

generating units in the State will cease operation upon expiration of their current OLs but do not

acknowledge retirement of any non-nuclear generating units in the State from 2005 through

2021. Therefore, any such retirements that do occur in this period would merely act to further

increase projected demand.

Based on this information, the NRC staff concluded that delayed retirement of other Entergy

generating units would not be a feasible alternative to renewal of the JAFNPP OL.

8.2.5. 11 Utility-Sponsored Conservation

The utility-sponsored conservation alternative refers to a situation in which JAFNPP ceases to

operate, no new generation is brought online to meet the lost generation, and the lost

generation is replaced by more efficient use of electricity. More efficient use would arise from

utility-sponsored conservation programs, potentially including energy audits, incentives to install

energy-efficient equipment, and informational programs to inform electricity consumers of the

benefits of, and possibilities for, electricity conservation.

Demand-side management resource strategies aimed at increasing energy efficiency on the

customer side of the electric meter generally fall under the following categories:

" Energy efficiency-selecting equipment that performs the same work with less energy input

" Load response-customers who agree to respond to utility requests to reduce use during

times of utility peak demand

" Load management, which encourages customers to reduce their usage during peak times

of day and peak season through the use of time-of-use rates, seasonal rates, and

interruptible contracts

* Direct load control, in which a utility interrupts power supply to customer equipment

Typically, demand-side management induced load reductions are acknowledged in load

forecasts and cannot therefore be used as credits to offset the power generated by JAFNPP.

As a practical matter, it would be impossible to increase the energy savings by an additional

881 MWe to replace the JAFNPP generating capability, particularly in upstate New York, which

represents a relatively small fraction of electrical load in the State.

Therefore, the NRC staff does not consider energy efficiency, by itself, a feasible alternative to

license renewal. However, the NRC staff recognizes that energy conservation is promoted and

that increases in energy efficiency occur as a normal result of replacing older equipment with

January 2008 8-45 NUREG-1437, Supplement 31 1
Environmental Impacts of Alternatives

modern equipment. It is reasonable to include conservation in a combination of generation

sources that would replace JAFNPP. Combined alternatives are discussed in Section 8.2.6.

8.2.6 Combination of Alternatives

Even though individual alternatives to JAFNPP might not be sufficient on their own to replace

JAFNPP capacity due to the small size of the resource or lack of cost-effective opportunities, it

is conceivable that a combination of alternatives might be cost-effective.

There are many possible combinations of alternatives. As discussed previously, these

combinations would include baseload gas-fired or coal-fired power plants, purchased power,

alternative and renewable technologies, and conservation. For the purpose of this discussion,

one combination of alternatives has been assumed: 600 MWe of generation from a combinedcycle facility at the JAFNPP site, 81 MWe of energy conservation, and 200 MWe purchased

from other generators. The impacts of other combinations, such as those from combinations

that include wind or solar power, would be different and possibly less than the assumed

combination. In some areas, such as the aesthetic impact of solar panel or wind turbines, the

impacts would be at least as large as the impact of the assumed combination of alternatives. In

other areas, such as waste, impacts would be smaller for these alternative technologies.

Table 8-8 contains a summary of the environmental impacts of an assumed combination. The

impacts associated with the combined-cycle natural gas-fired units are based on the gas-fired

generation impact assumptions discussed in Section 8.2.2, adjusted for the reduced generation

capacity. While the demand-side management measures would have few environmental

impacts, operation of the new natural gas-fired power plant would result in increased emissions

and environmental impacts. The environmental impacts associated with power purchased from

other generators would still occur but would be located elsewhere within the region or nation, as

discussed in Section 8.2.4. The impacts of purchased power are not shown in Table 8-8. The

NRC staff concluded that it is very unlikely that the environmental impacts of any reasonable

combination of generating and conservation options would be reduced to the level of impacts

associated with renewal of the JAFNPP OL.

8.3 Summary of Alternatives Considered

As indicated in Chapter 4 of this SEIS, the environmental impacts of the proposed action,

license renewal of JAFNPP, are SMALL for all impact categories (except collective offsite

radiological impacts from the fuel cycle and from high-level waste and spent fuel disposal, for

which a single significance level was not assigned). 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.

I NUREG-1437, Supplement 31 8-46 January 2008
Environmental Impacts of Alternatives

Table 8-8. Summary of Environmental Impacts of an Assumed Combination of GenerationDoes Not Include Impacts from Purchased Generation Once-Through Cooling Alternative

JAFNPP Site Alternate Site

Impact

Category Impact Comments Impact Comments

Land Use

Ecology

SMALL to

MODERATE

SMALL to

MODERATE

The natural gas-fired power

plant would be constructed

on undeveloped portions of

the JAFNPP site. It would

require upwards of 110 ac for

power block, offices, roads,

parking areas, and a gas

pipeline ROW. It would use

existing infrastructure,

minimizing new land

requirements. There would

be additional land impacts for

construction of an

underground gas pipeline.

The natural gas-fired

alternative would use

undeveloped areas at the

JAFNPP site. There would

be potential for significant

habitat loss and

fragmentation and reduced

productivity and biological

diversity.

SMALL to Land-use requirements would

LARGE be larger at an alternate site

because of the need for

additional infrastructure such as

transmission facilities, roads,

parking areas, office buildings,

and cooling system. The total

impact would depend on

whether the alternate site had

been previously disturbed.

I

SMALL to Impacts would depend on

LARGE whether the alternate site had

been previously developed.

Factors to consider include

location and ecology of the site

and transmission line route. In

total, impacts would include

habitat degradation,

fragmentation or loss as a result

of construction activities and

conversion of land to industrial

use. Ecological communities

might experience reduced

productivity and biological

diversity from disturbing

previously intact land.

January 2008 8-47 NUREG-1 437, Supplement 31 I
Environmental Impacts of Alternatives

Table 8-8 (cont.)

JAFNPP Site Alternate Site

Impact

Category Impact Comments Impact Comments

Water Use and

QualitySurface Water

SMALL Combined-cycle units have

lower water requirements

than nuclear and coal-fired

power plants. The natural

gas-fired alternative would

use existing once-through

cooling system to the degree

necessary.

SMALL to Combined-cycle units have

MODERATE lower water requirements than

* nuclear and coal-fired power

plants. The natural gas-fired

alternative would use closedcycle cooling to the degree

necessary. Total impacts

would depend on the volume

of water withdrawal, the

constituents of the discharge

water, the characteristics of

the surface water or

groundwater source, and the

required new intake

structures.

Water Use and

QualityGroundwater

SMALL

Air Quality MODERATE

Use of groundwater is very

unlikely.

" Sulfur oxides: 34 tons/yr

" Nitrogen oxides:

109 tons/yr

( Carbon monoxide:

7 tons/yr

SMALL to

MODERATE

MODERATE

Impact depends on volume of

water withdrawal and

discharge.

The impacts at an unnamed

alternate site would be the

same as those for the

JAFNPP site.

" P~IVo particulates: 126 tons/yr

" Other: (1) hazardous air

pollutants, including arsenic,

formaldehyde, and nickel and

(2) carbon dioxide emissions,

which contribute to global

warming.

I NUREG-1437, Supplement 31 8-48 January 2008
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Table 8-8 (cont.)

JAFNPP Site Alternate Site

Impact

Category Impact Comments Impact Comments

Waste SMALL Minimal waste product from SMALL The impacts at an alternate site

fuel combination, would be the same as those for

the JAFNPP site.

Human Health SMALL Impacts would be minor. SMALL The impacts at an alternate site

would be the same as those for

the JAFNPP site.

Socioeconomics SMALL to During power plant SMALL to Construction and operation

MODERATE construction, impacts would LARGE impacts at an alternate site

beMODERATE. would be similar to those at the

Construction activities would JAFNPP site. Socioeconomic

place noticeable burdens on impacts to the local community

existing infrastructure, would depend on the location of

including housing. the alternate site and would vary

During plant operations, from SMALL to LARGE.

employment would decrease

from 716 permanent workers

to approximately 50. Impacts

on housing and vitality of the

local economy would occur.

Overall, socioeconomic

impacts from operation would

be SMALL.

Transportation MODERATE Construction-related MODERATE Transportation impacts of the

transportation impacts would natural gas-fired alternative at

be MODERATE. an alternate site would be

similar to those at the JAFNPP

site.

I

January 2008 8-49 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

Table 8-8 (cont.)

JAFNPP Site Alternate Site

Impact

Category Impact Comments Impact Comments

Aesthetics SMALL There would be visual MODERATE to Visual aesthetic impacts would be

aesthetic impacts associated LARGE similar to the JAFNPP site, but

with the construction of new would depend on the location of

power plant buildings and the alternate site. The natural gasstructures. There would be fired power plant at an alternate

both continuous and site could require transmission

intermittent noise impacts lines, with aesthetic impacts.

from power plant operation.

Historic and SMALL to Cultural resource studies SMALL to The historic and archaeological

Archeological MODERATE would be needed to identify, MODERATE resource impacts of the natural

Resources evaluate, and address the gas-fired power plant at an

mitigation of potential cultural alternate site would be similar to

resource impacts from the those at the JAFNPP site.

construction of a new power

plant.

Environmental SMALL to Impacts to minority and low- SMALL to The impacts at an alternate site

Justice MODERATE income populations would MODERATE would be the same as those for

vary depending on the the JAFNPP site.

location of the power plant

site and other support

facilities.

The no-action alternative would require the replacement of electrical generating capacity by

(1) demand-side management and energy conservation, (2) power purchased from other

electricity providers, (3) generating alternatives other than JAFNPP, 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. For example, the

land-disturbance impacts resulting from construction of any new facility would be greater than

the impacts of continued operation of JAFNPP. The impacts of purchased electrical power

(imported power) would still occur but would occur elsewhere. Alternative technologies are not

considered feasible at this time for complete power replacement, and it is very unlikely that the

environmental impacts of any reasonable combination of generation and conservation options

would be reduced to the level of impacts associated with renewal of the JAFNPP OL.

I NUREG-1437, Supplement 31 8-50 January 2008
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The NRC staff concluded that the alternative actions, including the no-action alternative, may

have environmental effects in at least some of the impact categories that would reach

MODERATE or LARGE significance.

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 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. New York State Wind Energy

Development. Available URL: http://www.awea.org/projects/newyork.html. (Accessed

December 28, 2006.)

C&A Carbone, Inc. v. Town of Clarkstown, New York. 511 U.S. 383. 1994. U.S. Supreme

Court Reports.

Clean Air Act of 1970. 42 USC 7401, et seq.

Clean Water Act of 1977. Federal Water Pollution Control Act of 1977. 33 USC 1251, et seq.

Elliott, D.L., C.G. Holladay, W.R. Barchet, H.P. Foote, and W.F. Sandusky. 1986. Wind Energy

Resource Atlas of the United States. DOE/CH 10093-4, U.S. Department of Energy,

Washington, D.C. Available URL: http://rredc.nrel.gov/wind/pubs/atlas (accessed December 28,

2006).

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006.

James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E:

Applicant's Environmental Report, Operating License Renewal Stage. Lycoming, New York.

Accessible at ML062160557.

January 2008 8-51 NUREG-1437, Supplement 31 I
Environmental Impacts of Alternatives

Gabbard, A. 1993. "Coal Combustion: Nuclear Resource or Danger." Oak Ridge National

Laboratory Review. Oak Ridge National Laboratory: Oak Ridge, Tennessee. Available URL:

http://www.ornl.gov/info/ornlreview/rev26-34/text/colmain.html (accessed October 18, 2004.)

Integrated Waste Services Association-(IWSA). 2006. "America's Own Energy Source."

Available URL: http://www.wte.org/aoes.shtml (accessed December 28, 2006.) Accessible at

ML071130360.

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

New York State Energy Research and Development Authority (NYSERDA). 2002. 2002 State

Energy Plan and Final Environmental Impact Statement. Available URL: http://www.nyserda

.org/sep.html (accessed October 18, 2004.)

Northwest Power Planning Council (NWPPC). 2000. "Northwest Power Supply

Adequacy/Reliability Study Phase I Report." Available URL: http://www.nwcouncil.org/library/

2000/2000-4.pdf (accessed December 28, 2006.)

Resource Conservation and Recovery Act of 1976. 42 USC 6901, et seq.

Rivers and Harbors Appropriation Act of 1899. 33 USC 403, et seq.

U.S. Department of Energy (DOE). 2005. "U.S. Wind Energy Resource Potential Map."

Available URL: http://wwwl.eere.energy.gov/windandhydro/wind_potential.html (accessed

December 28, 2006.) Accessible at ML071130366.

U.S. Department of Energy (DOE). 2006. "Future Fuel Cells R&D." Available URL:

http://www.fossil.energy.gov/programs/powersystems/fuelcells (accessed December 28, 2006.)

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2001. Renewable

Energy 2000: Issues and Trends. DOE/EIA-0628 (2000). Washington, D.C. Available URL:

http://tonto.eia.doe.gov/ftproot/renewables/06282000.pdf (accessed December 28, 2006.)

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2002. International

Energy Outlook 2002. DOE/EIA-0484 (2002). Washington, D.C. Available URL:

http://www.eia.doe.gov/pub/pdf/international/0484(2002).pdf (accessed December 28, 2006.)

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2004. Annual

Energy Outlook 2004 with Projections to 2025. Washington, D.C.

U.S. Department of Energy/Energy Information Administration (DOE/EIA). 2007. Annual

Energy Outlook 2007 with Projections to 2030. Washington, D.C., February, 2007. Available

URL: http://www.eia.doe.gov/oiaf/aeo/index.html (accessed April 12, 2007).

I NUREG-1437, Supplement 31 8-52 January 2008
Environmental Impacts of Alternatives

U.S. 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 Vol. 63, No. 179, pp. 49442-49455.

Washington, D.C. (September 16, 1998.)

U.S. Environmental Protection Agency (EPA). 1999. "Regional Haze Regulations, Final Rule."

Federal Register Vol. 64, No. 126, pp. 35714-3577. Washington, D.C. (July 1, 1999.)

U.S. Environmental Protection Agency (EPA). 2000. "Regulatory Finding on the Emissions of

Hazardous Air Pollutants from Electric Utility Steam Generating Units." Federal Register.

Vol. 65, No. 245, pp. 79825-79831. Washington, D.C. (December 20, 2000.)

U.S. Environmental Protection Agency (EPA). 2006. "Municipal Solid Waste Disposal."

Available URL: http://www.epa.gov/epaoswer/non-hw/muncpl/disposal.htm (accessed

December 28, 2006).

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

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Final Generic Environmental Impact

Statement for License Renewal of Nuclear Plants: Main Report. NUREG-1437, Volume 1,

Addendum 1. Washington, D.C.

U.S. 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, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2006. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants: Regarding Nine Mile Point Nuclear Stations, Units 1 and

2, Final Report. NUREG-1427, Supplement 24. Office of Nuclear Reactor Regulation.

Washington, D.C.

January 2008 8-53 NUREG-1437, Supplement 31 I

9.0 SUMMARY AND CONCLUSIONS

By letter dated July 31, 2006, Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations,

Inc. (Entergy) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to

renew the operating license (OL) for James A. FitzPatrick Nuclear Power Plant (JAFNPP) for an

additional 20-year period (Entergy 2006a). If the OL is renewed, State regulatory agencies and

Entergy 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

of the current OL, which expires on October 17, 2014.

Section 102 of the National Environmental Policy Act (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 Part 51 of Title 10 of the Code of Federal Regulations (10 CFR Part 51). Part 51 identifies

licensing and regulatory actions that require an EIS. In 10 CFR 51.20(b)(2), the Commission

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 (GELS),

NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999).(1)

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

described in 10 CFR Part 51 by publishing on September 20, 2006, a Notice of Intent to prepare

an EIS and conduct scoping (NRC 2006a). The NRC staff held public scoping meetings on

October 12, 2006, in Oswego, New York (NRC 2006b), and conducted a site audit in

December 2006 (NRC 2007b). The NRC staff reviewed Entergy's environmental report (ER) for

JAFNPP (Entergy 2006b) and compared it to the GELS, consulted with other agencies, and

conducted an independent review of the issues following the guidance set forth in NUREG1555, Supplement 1, Standard Review Plans for Environmental Reviews for Nuclear Power

Plants, Supplement 1: Operating License Renewal (NRC 2000). The NRC staff also

considered the public comments received during the scoping process for preparation of this

supplemental environmental impact statement (SEIS) for JAFNPP (NRC 2007a). 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 of this SEIS.

The draft SEIS was published in June 2007. The NRC staff held two public meetings in Oswego,

New York, in August 2007, to describe the preliminary results of the NRC environmental review,

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

information to assist them in formulating their comments on this SEIS. When the comment

(1) The GElS was issued in 1996, and Addendum 1 to the GElS was issued in 1999. Hereafter, all

references to GElS include Addendum 1.

January 2008 9-1 NUREG-1437, Supplement 31 1
Summary and Conclusions

period ended on September 5, 2007, the NRC staff considered and addressed all of the

comments received. These comments were addressed in Part 2 of Appendix A.

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 NRC staff's recommendation regarding the

proposed action.

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

GELS:

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 evaluation criterion for the NRC staff's environmental review, as defined in 10 CFR

51.95(c)(4) and the GELS, 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 decision makers 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) and in accordance with § 51.23(b).

The GElS 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

I NUREG-1437, Supplement 31 9-2 JJanuary 2008
Summary and Conclusions

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 GELS, the NRC staff analysis in the GElS 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 high-level 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.

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

significant information, the NRC staff relied on conclusions in the GElS for issues designated

Category 1 in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B. The NRC staff also

determined that information provided during the public comment period did not identify any new

issue that requires site-specific assessment.

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 GELS. The remaining two issues,

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

Environmental justice was not evaluated on a generic basis in the GElS and must be addressed

in the SEIS. Information on the chronic effects of electromagnetic fields was not conclusive at

the time the GElS was prepared.

This SEIS documents the NRC staff's consideration of all 92 environmental issues identified in

the GELS. The NRC staff considered the environmental impacts associated with alternatives to

January 2008 9-3 NUREG-1437, Supplement 31 1
Summary and Conclusions

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 JAFNPP) and alternative methods of power generation.

These alternatives were evaluated assuming that the replacement power generation plant is

located at either the JAFNPP site or some other unspecified location.

9.1 Environmental Impacts of the Proposed Action-License Renewal

Entergy and the NRC 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 NRC staff has identified information that is both new and

significant related to Category 1 issues that would call into question the conclusions in the

GELS. Similarly, neither the scoping process, Entergy, nor the NRC staff has identified any new

issue applicable to JAFNPP that has a significant environmental impact. Therefore, the NRC

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

JAFNPP.

Entergy's license renewal application presents an analysis of the Category 2 issues that are

applicable to JAFNPP, plus environmental justice (Entergy 2006b). The NRC staff has

reviewed the Entergy analysis for each issue and has conducted an independent review of each

issue plus environmental justice. Six Category 2 issues are not applicable because they are

related to plant design features or site characteristics not found at JAFNPP. 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 JAFNPP, 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 James A. FitzPatrick Nuclear Power Plant (AEC 1973).

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. Four 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 all 11 Category 2 issues and

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

SMALL significance in the context of the standards set forth in the GELS. For severe accident

mitigation alternatives (SAMAs), the NRC staff concludes that a reasonable, comprehensive

effort was made to identify and evaluate SAMAs. Based on its review of the SAMAs for

JAFNPP, and the plant improvements already made, the NRC staff concludes that several

candidate SAMAs are potentially cost-beneficial. However, none of these SAMAs relate to

I NUREG-1437, Supplement 31 9-4 January 2008
Summary and Conclusions

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.

Mitigation measures were considered for each Category 2 issue. Current measures to mitigate

the environmental impacts of plant operation were found to be adequate, and no additional

mitigation measures were deemed sufficiently beneficial to be warranted.

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, where JAFNPP license renewal impacts are

deemed to be SMALL, the NRC staff concluded that these impacts would not result in significant

cumulative impacts on potentially affected resources.

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.

The adverse impacts of continued operation identified are considered to be of SMALL

significance, and none warrants implementation of additional mitigation measures. The adverse

impacts of likely alternatives if JAFNPP ceases operation at or before the expiration of the

current OL will 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 the JAFNPP 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 offsite 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. JAFNPP replaces approximately one third of its fuel

assemblies during routine refueling outages, typically every 24 months (Entergy 2006b).

January 2008 9-5 NUREG-1437, Supplement 31 I
Summary and Conclusions

The likely power-generation alternatives if JAFNPP ceases operation on or before the expiration

of the current OL will 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 the

JAFNPP site was set when the plant was approved and construction began. That balance is

now well established. Renewal of the OL for JAFNPP and continued operation of the plant will

not alter the existing balance but may postpone the availability of the site for other uses. Denial

of the application to renew the OL will lead to shutdown of the plant and will alter the balance in

a manner that depends on subsequent uses of the site. For example, the environmental

consequences of turning the JAFNPP site into a park or an industrial facility are quite different.

9.2 Relative Significance of the Environmental Impacts of License Renewal

and Alternatives

The proposed action is renewal of the OL for JAFNPP. 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 JAFNPP. 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 nuclear or gas- or coal-fired generation of power at the JAFNPP site and

an unspecified "alternate site," and a combination of alternatives are compared in Table 9-1.

Continued use of a once-through cooling system for JAFNPP is assumed for Table 9-1.

Substitution of once-through cooling for the recirculating cooling system in the evaluation of the

nuclear and gas- and coal-fired generation alternatives would result in somewhat greater

environmental impacts in some impact categories.

Table 9-1 shows that the significance of the environmental effects of the proposed action is

SMALL for all impact categories (except for collective offsite radiological impacts from the fuel

cycle and from HLW and spent fuel disposal, for which a single significance level was not

assigned [see Chapter 6]). The alternative actions, including the no-action alternative, may

have environmental effects in at least some impact categories that reach MODERATE or

LARGE significance.

I NUREG-1437, Supplement 31 9-6 January 2008
C_

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Table 9-1. Summary of Environmental Significance of License Renewal

the No-Action Alternative, and Alternative Methods of Power Generation

Proposed No-Action Coal-Fired

Action Alternative Generation Natzal-Gas-Fired Generation Now Nuclea Generation Combination of Altematives

Ucense Denial of

Impact Category Reewal Renewal Alternate Site JA=NPP site Alternate Site JAFNPP Site Alternate Site JAFNPP Site Alternate Site

ýLand as SMALL NQIMPAOT MoPeRAE ML~' MDEAEo S~~~SkUC SMLLt toL~o' 

LAGE Mbbi@RAT MOERT LARQ _ MODERATE 1ARGE'"

Ecology SMALL SMALL MODERATE to MODERATE SMALL to SMALL MODERATE to SMALL to SMALL to

LARGE MODERATE LARGE MODERATE LARGE

Sit~Ueat MALL SALL2 SM~ALL to ' SMALL, SA& MI SMALL-to,,, SL ALt

MODERAT MODERATE.. - MODERATE' NWOE'T

Water Use and SMALL NO IMPACT SMALL to NO IMPACT, SMALL to SMALL SMALL to SMALL SMALL to

Quality- MODERATE MODERATE MODERATE MODERATE

Groundwater

AMODERATE, SMA. SMALL MODERAT ý,MODERATE'

Waste SMALL SMALL MODERATE SMALL SMALL SMALL SMALL SMALL SMALL

,l.Htman',Hea~lh SMAULta0 SMALL GMAU ALLI,__, SMALL SMALL . SMALL~ SMALL SM4LMALL . . . . . • .

Scioecononýics SMALL MODERATE SMALL to SMALL to SMALL to SMALL to SMALL to SMALL to SMALL to

to LARGE LARGE,. LARGE.. LARGE MODERATE LARGE . MODERATE LARGE

SMAL~' MMALL-~ t no ui#u ArjtyTE SL~ ML o~ MODERATE MODSR&,TE.

Aesthetics SMALL NO IMPACT SMALL to SMALL SMALL to SMALL to SMALL to SMALL MODERATE to

LARGE LARGE MODERATE LARGE LARGE

Hlst~cm an d SMALL SMALL SMALL to MALLt to SMALL1~KK8~ to SMALL to SMALL to

ArhelgclMODERATE &MODERATE MODERATE M~ODERATE ~MODERATE' M~ODERATE Moeke

Rerces -V

Enwonmental ) SMALL SMALL to SMALL to SMALL to SMALL to SMALL to SMALL to -SMALL to SMALL to

Justice . LARGE LARGE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE

(a) Except for colective offsile radiological impacts from the fuel dcye and frtm HLW and sent-fuil disposal, for which a signircance level was not assigned..

See Chapter 6 tor details.

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Summary and Conclusions

9.3 NRC Staff Recommendation

Based on (1) the analysis and findings in the GELS, (2) the ER submitted by Entergy (Entergy

2006b), (3) consultation with Federal, State, and local agencies, (4) the NRC staff's own

independent review, and (5) the NRC staff's consideration of public comments received, the

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

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

option of license renewal for energy planning decision makers 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."

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006a.

James A. FitzPatrick Nuclear Power Plant License Renewal Application. Lycoming, New York.

Accessible at ML062160494.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006b.

James A. FitzPatrick Nuclear Power Plant - License Renewal Application, Appendix E:

Applicant's Environmental Report, Operating License Renewal Stage. Lycoming, New York.

Accessible at ML062160557.

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

U.S. Atomic Energy Commission (AEC). 1973. Final Environmental Statement Related to

Operation of James A. FitzPatrick Nuclear Power Plant Power Authority of the State of New

York. Docket No. 50-333. Washington, D.C. Accessible at ML062360088.

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

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2. Washington, D.C.

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

for License Renewal of Nuclear Plants, "Section 6.3 - Transportation, Table 9.1, Summary of

findings on NEPA issues for license renewal of nuclear power plants, Final Report." NUREG1437, Volume 1, Addendum 1. Office of Nuclear Regulatory Research, Washington, D.C.

U.S. 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, D.C.

I NUREG-1437, Supplement 31 9-8 January 2008
Summary and Conclusions

U.S. Nuclear Regulatory Commission (NRC). 2006a. "Notice of Acceptance for Docketing of

the Application, Notice of Opportunity for Hearing and Notice of Intent to prepare an

Environmental Impact Statement and Conduct Scoping Process of Facility Operating License

No. DPR-59 for an Additional 20-Year Period, Entergy Nuclear Operations, Inc., James A.

FitzPatrick Nuclear Power Plant." Federal Register: Vol. 71, No. 182, pp. 55032-55035.

Washington, D.C. Accessible at ML071000085.

U.S. Nuclear Regulatory Commission (NRC). 2006b. NRC press release announcing Public

License Renewal Process and Environmental Scoping Meeting Associated with the Application

to Renew the Operating License for JAFNPP. Accessible at ML062760465.

U.S. Nuclear Regulatory Commission (NRC). 2007a. Letter to M. Kansler, Entergy. Subject:

Environmental Scoping Summary Report. March 2, 2007. Accessible at ML070440393.

U.S. Nuclear Regulatory Commission (NRC). 2007b. Environmental Scoping Summary Report

Associated with the Staff's Review of the Application by Entergy for Renewal of the Operating

License for JAFNPP. Washington, D.C. Accessible at ML070440393.

January 2008 9-9 NUREG-1437, Supplement 31 1

Appendix A

Comments Received on the Environmental Review

1

Appendix A:

Comments Received on the Environmental Review

On September 20, 2006, the U.S. Nuclear Regulatory Commission (NRC) published a Notice of

Intent in the Federal Register (71 FR 55032) to notify the public of the NRC staffs intent to

prepare a plant-specific supplement to the Generic Environmental Impact Statement for License

Renewal of NuclearPlants (GElS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999),(a)

related to the renewal application for the James A. FitzPatrick Nuclear Power Plant (JAFNPP)

operating license and to conduct scoping. The plant-specific supplement to the GElS has been

prepared in accordance with the National Environmental Policy Act (NEPA), Council on

Environmental Quality (CEQ) guidance, and Title 10 of the Code of Federal Regulations, Part

51 (10 CFR Part 51). As outlined by NEPA, the NRC initiated the scoping process with the

issuance of the Federal Register Notice. The NRC invited the applicant; Federal, State, and

local government agencies; Native American tribal organizations; local organizations; and

individuals to participate in the scoping process by providing oral comments at the scheduled

public meetings and/or submitting comments by November 14, 2006.

The scoping process included two public scoping meetings, which were held at the Town of

Scriba Municipal Building in Oswego, New York, on October 12, 2006. The NRC issued press

releases and distributed flyers locally. Approximately 14 members of the public attended the

meetings. Both sessions began with NRC staff members providing a brief overview of the

license renewal process. Following the NRC's prepared statements, the meetings were open

for public comments. Three attendees provided either oral comments or written statements that

were recorded and transcribed by a certified court reporter, and written comments were

appended to the transcript. The transcripts of the meetings are an attachment to the meeting

summary, which was issued on October 30, 2006 (meeting transcripts, ML063030195 and

ML063030209; meeting summary, ML062980148). The documents are publicly available and

can be found at the Agencywide Documents Access and Management System (ADAMS) at

http://adamswebsearch.nrc.gov/dologin.html or through the NRC's Electronic Reading Room

link at http://www.nrc.gov. Persons who do not have access to ADAMS or who encounter

problems in accessing the documents located in ADAMS should contact the NRC's Public

Document Room staff at 1-800-397-4209 or 301-415-4737, or by email at pdr@nrc.gov.

At the conclusion of the scoping period, the NRC staff reviewed the transcripts and all written

material received and identified individual comments. Each set of comments from a given

commenter was given a unique alpha identifier (Commenter ID letter), allowing each set of

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

references to the "GELS" include the GElS and its Addendum 1.

January 2008 A-1 NUREG-1437, Supplement 31 1
Appendix A

comments from a commenter to be traced back to the transcript, letter, or email in which the

comments were submitted. Specific comments were numbered sequentially within each

comment set. All of the comments received and the NRC staff responses are included in the

JAFNPP Scoping Summary Report dated March 2, 2007 (ML070440393).

Comments were consolidated and categorized according to the topic within the proposed

supplement to the GElS or according to the general topic if outside the scope of the GELS.

Comments with similar specific objectives were combined to capture the common essential

issues that had been raised in the source comments. Once comments were grouped according

to subject area, the NRC staff determined the appropriate action for the comment.

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. The

individuals are listed in the order in which they spoke at the public meeting, and in the

alphabetical order for the comments received by letter. To maintain consistency with the

Scoping Summary Report, the unique identifier used in that report for each set of comments is

retained in this appendix. The Commenter ID is preceded by FNP, which stands for James A.

FitzPatrick Nuclear Power Plant. Accession numbers indicate the location of the written

comments in ADAMS.

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:

0 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 GELS. They

also address alternatives and related Federal actions.

* 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 JAFNPP license renewal

application.

a Questions that do not provide new information.

0 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 staffs responses are

summarized in this appendix. The parenthetical alpha-numeric identifier after each comment

I NUREG-1437, Supplement 31 A-2 January 2008
Appendix A

refers to the comment set (Commenter ID) and the comment number. This information, which

was extracted from the JAFNPP 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 JAFNPP are

not included here. More detail regarding the disposition of general or inapplicable comments

can be found in the summary report. The ADAMS accession numberfor the Scoping Summary

Report is ML070440393. This accession number is provided to facilitate access to the document

through the Public Electronic Reading Room (ADAMS) at http://www.nrc.gov/reading-rm.html.

Comments in this section are grouped into the following categories:

A.1.1 Aquatic Ecology

A.1.2 Socioeconomics

A.1.3 Postulated Accidents

A.1.4 Uranium Fuel Cycle and Waste Management

Table A-I. Individuals Providing Comments During Scoping Comment Period

Comment Source,

Commenters' ID Commenter Affiliation (If stated) ADAMS Accession Number(a)

FNP-A Ed Putnam Candidate, New York State Assembly Afternoon Scoping Meeting

FNP-B Tim Judson Citizens Awareness Network (CAN) Evening Scoping Meeting

FNP-C Tom Dellwo CAN Evening Scoping Meeting

FNP-D Joseph J. Heath General Counsel, Onondaga Nation Letter (ML063240283)

FNP-E Christopher M. Project Manager, New York State Letter (ML063240331)

Hogan Department of Environmental

Conservation

(a) The afternoon and evening transcripts can be found under accession numbers ML063030195 and ML063030209, respectively.

Part I - Comments Received During Scoping

A.1.1 Aquatic Ecology Issues

Comment: [Environmental Report] Appendix E; Section 4.2: Entrainment of Fish and Shellfish

in Early Life Stages, and Section 4.3: Impingement of Fish and Shellfish Statements regarding

previous Departmental Best Technology Available (BTA) decisions for FitzPatrick are

overstated. While in 1996 and 2001 the Department determined that the high frequency/high

amplitude acoustic fish deterrent system (FDS) was BTA for reducing impingement, the

January 2008 A-3 NUREG-1437, Supplement 31 1
Appendix A

Department did not state that the FDS was BTA for reducing entrainment. In fact, the letter

Entergy used as a reference specifically states, "Moreover, the fish deterrent system has not

been evaluated as an entrainment mitigative device..." In addition, while the State Pollution

Discharge Elimination System (SPDES) Permit Fact Sheet that accompanied the 1996 and

2001 SPDES permits discussed the potential benefit of the FDS for reducing alewife

entrainment, it referenced the need for studies to determine the effectiveness of the FDS

system on larval life stages of alewives. Requirements for these studies were made part of the

SPDES permit, but Department records indicate that the study was never conducted.

Even if the study had been completed and the Department had made a BTA determination

regarding entrainment, documented changes in the fish community in Lake Ontario (as

described in Appendix E, Section 2.2.4 of the license renewal application) compel a review of

previous determinations to determine if changes are warranted. To that end, Entergy is

currently conducting biological sampling at FitzPatrick to determine the extent of current

impacts. Data from this sampling will be included in a Comprehensive Demonstration Study

that Entergy must submit to the Department in early 2008. A new BTA decision will be based, in

part, on the Comprehensive Demonstration Study. Thus, conclusory statements that

entrainment impacts do not warrant mitigation are premature. Decisions regarding the need for

mitigation will be addressed via the SPDES permit process. (FNP-E-1)

Comment: [Environmental Report] Section 6.2 Mitigation. Entergy's contention that "the current

permits, practices, and programs that mitigate the environmental impacts of plant operations are

adequate (page 6-1)" are not necessarily accurate. For example, the decision regarding

adequacy of mitigative measures for addressing impacts from impingement and entrainment will

be addressed via the SPDES permit process. That permit process will address the adequacy of

current practices and, if necessary, will result in requirements for additional measures to reduce

impacts. In addition and as explained above, statements in Table 6-1 regarding past BTA

determinations are overstated. (FNP-E-2)

Comment: Counter to statements contained in Section 4.2.6, Section 4.3.6, and Table 6-

1 federal regulations do not require limiting the focus of mitigation requirements to impacts on

fish populations (see 10 CFR 51.53(c) and 10 CFR 51.45(c)). In fact, the federal regulations

dealing with impingement and entrainment at power plants focus on the reduction in the

numbers of individual organisms (see 40 CFR 125-Subparts I and J). (FNP-E-3)

Response: These comments are related to information regarding entrainment and impingement

of fish and shellfish, as provided in the applicant's Environmental Report. Aquatic ecology will

be discussed in Chapters 2 and 4 of the SEIS.

A.1.2 Socioeconomic Issues

Comment: One of the economic factors which affects the retention of current industry in central

New York and which also affects the attraction of new industry to this region is the provision of

I NUREG-1437, Supplement 31 A-4 January 2008
Appendix A

inexpensive, trustworthy, and accessible power. We need this company to be a player in this

attempt to bolster the economy of central New York. The Oswego County Public Utility Service

offers "low cost electrical energy" to new and expanding business in Oswego County, in the

hope that it will inspire new jobs and retain existing jobs through the low-cost electricity provided

by Entergy at the FitzPatrick plant. This is a positive initiative, which has begun to be shared

with the local economic community.

A similar form of utility incentive for domestic usage would be a welcome message to the

residents of this region. It seems inconsistent that this community, which houses nuclear power

plants, does not experience significant benefit from the presence. The economic downturn in

this region is desperately in need of signs of recovery, and thus nuclear power industry has the

capability of leading the way. (FNP-A-10)

Response: The comments are related to the socioeconomic impacts specific to JAFNPP.

Socioeconomic impacts such as taxes are Category 2 issues and will be addressed in Chapters

2 and 4 of the SEIS.

A.1.3 Postulated Accidents

Comment: The operation of nuclear power plants is not without the potential for accidents, with

serious consequences for both short and long term health in surrounding communities.

(FNP-D-3)

Response: The GElS evaluated severe accidents and design basis accidents, and concluded

the impact was small. During the environmental review of JAFNPP, the NRC will determine

whether there is any new and significant information bearing on the previous analyses in the

GELS. Section 5.1.2 of the plant-specific SEIS for JAFNPP will address this issue. In addition,

alternatives to mitigate severe accidents must be considered on a plant-specific basis for all

plants that have not previously considered such alternatives. The applicant provided a severe

accident mitigation alternatives (SAMA) analysis as part of the license renewal application for

JAFNPP. The NRC staff's review of the SAMA analysis will discussed in Section 5.2 and

Appendix G of the SEIS for JAFNPP.

A.1.4 Uranium Fuel Cycle and Waste Management Issues

Comment: From start to finish, the production of nuclear energy is fraught with hazards. The

mining and enrichment of uranium produces radioactive isotopes that contaminate and degrade

the surrounding environment. (FNP-D-2)

Comment: Finally, creation of nuclear energy leads to the accumulation of extremely

hazardous, radioactive material that persists in the environment for tens of thousands of years.

January 2008 A-5 NUREG-1437, Supplement 31 I
Appendix A

Additionally, this process creates byproducts, which, in a worst-case scenario, could be

obtained and used to create dangerous weapons. (FNP-D-4)

Response: Environmental impacts associated with the uranium fuel cycle were addressed in

the GELS. The GElS concluded those impacts including the off-site radiological impact of

storage, transportation, and disposal of spent fuel and other radioactive waste are Category 1

issues. The impact of these Category 1 issues was judged to be small in the GEIS. During the

environmental review of JAFNPP, the NRC determine whether there is any new and significant

information bearing on the previous analysis.

Part 2 - Comments Received on Draft SEIS

The NRC staff transmitted the Generic Environmental Impact Statement for License Renewal of

Nuclear Plants Regarding James A. FitzPatrick Nuclear Power Plant, Draft Report for Comment

(NUREG-1437, Supplement 31, referred to as the draft Supplemental Environmental Impact

Statement [SEIS]) to Federal, State, and local government agencies; certain Indian tribes; and

interested members of the public. As part of the process to solicit public comments on the draft

SEIS, the NRC staff:

G placed a copy of the draft SEIS into the NRC's Public Electronic Reading Room, on its

license renewal website, at the Penfield Library SUNY in Oswego, New York, and at the

Oswego Public Library in Oswego, New York;

* published a notice of availability of the draft SEIS in the Federal Register on June 15,

2007 (72 FR 32924);

* issued public service announcements and press releases announcing the issuance of

the draft SEIS, the public meetings, and instructions on how to comment on the draft

SEIS; and

* announced and held two public meetings in Oswego, New York, on August 1, 2007, to

describe the results of the environmental review and answer related questions.

During the comment period, the NRC staff received four comment letters, in addition to

comments submitted during the public meetings. The public meeting transcripts and comment

letters have been incorporated by reference and are available online in ADAMS. Appendix A,

Part II, Section A.2 contains a summary of the comments and the NRC staff's responses.

Related comments are grouped together for ease of reference, followed by the NRC staffs

response. Where the comment resulted in a change in the text of the draft report, the

corresponding response refers the reader to the appropriate section of this report where the

change was made. Revisions to the text in the draft report are designated by vertical lines

beside the text.

I NUREG-1437, Supplement 31 A-6 January 2008
Appendix A

Each comment was assigned a specific alphanumeric identifier (marker). Table A-2 provides a

cross-reference of the alphanumeric identifiers, the speaker or author of the comment, the page

where the comment can be found, and the subsection(s) of this appendix. Oral and written

comments are identified by a specific letter representing the commenter, followed by a number

that identifies each comment in approximate chronological order in which the comments were

made.

There was no significant new information provided on generic (Category 1) issues or information

that caused the NRC staff to change their conclusions regarding site-specific (Category 2)

issues. Therefore, the conclusions in the GElS and draft SEIS remained valid and bounding,

and no further evaluation was performed.

Table A-2. Individuals Providing Comments on the Draft SEIS

Section

Commenter and Affiliation Comment Source and Where

Commenters' ID (if stated) ADAMS Accession Number Addressed

A-1 Mike Stevens Afternoon Transcript, ML072260051 A.2.1

B-1 Gary Toth Afternoon Transcript, ML072260051 A.2.1

C-1 Andrew Raddant, Letter, ML072530436 A.2.5

NYSDOI

C-2 Andrew Raddant Letter, ML072530436 A.2.5

C-3 Andrew Raddant Letter, ML072530436 A.2.4

C-4 Andrew Raddant Letter, ML072530436 A.2.4

C-5 Andrew Raddant Letter, ML072530436 A.2.4

C-6 Andrew Raddant Letter, ML072530436 A.2.5

D-1 Jim Costedio, Entergy Letter, ML072530437 A.2.2

D-2 Jim Costedio Letter, ML072530437 A.2.2

D-3 Jim Costedio Letter, ML072530437 A.2.2

D-4 Jim Costedio Letter, ML072530437 A.2.2

D-5 Jim Costedio Letter, ML072530437 A.2.2

D-6 Jim Costedio Letter, ML072530437 A.2.2

D-7 Jim Costedio Letter, ML072530437 A.2.11

D-8 Jim Costedio Letter, ML072530437 A.2.11

D-9 Jim Costedio Letter, ML072530437 A.2.11

D-10 Jim Costedio Letter, ML072530437 A.2.11

D-11 Jim Costedio Letter, ML072530437 A.2.9

January 2008 A-7 NUREG-1437, Supplement 31 I
Appendix A

Table A-2. (cont.)

Commenters' ID

D-12

D-13

D-14

D-15

D-16

D-17

D-18

D-19

D-20

D-21

D-22

D-23

D-24

D-25

D-26

D-27

D-28

D-29

D-30

D-31

D-32

D-33

D-34

D-35

D-36

D-37

D-38

D-39

D-40

D-41

Commenter and Affiliation

(if stated)

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Table 

A-2. 

Comment (cont.) Source and

ADAMS Accession Number

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Section

Where

Addressed

A.2.9

A.2.9

A.2.9

A.2.9

A.2.11

A.2.9

A.2.9

A.2.9

A.2.9

A.2.9

A.2.11

A.2.11

A.2.2

A.2.11

A.2.11

A.2.11

A.2.3

A.2.11

A.2.4

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.7

A.2.11

I NUREG-1437, Supplement 31 A-8 January 2008
Appendix A

Table A-2. (cont.)

Commenters' ID

D-42

D-43

D-44

D-45

D-46

D-47

D-48

D-49

D-50

D-51

D-52

D-53

D-54

D-55

D-56

D-57

D-58

D-59

D-60

D-61

D-62

D-63

D-64

D-65

D-66

D-67

D-68

D-69

D-70

D-71

Commenter and Affiliation

(if stated)

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Table 

A-2. 

Comment (cont.) Source and

ADAMS Accession Number

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Section

Where

Addressed

A.2.7

A.2.2

A.2.2

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.2

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

January 2008 A-9 NUREG-1437, Supplement 31 1
Appendix A

Table A-2. (cont.)

Commenters' ID

D-72

D-73

D-74

D-75

D-76

D-77

D-78

D-79

D-80

D-81

D-82

D-83

D-84

D-85

D-86

D-87

D-88

D-89

D-90

D-91

D-92

D-93

D-94

D-95

D-96

D-97

D-98

D-99

D-100

D-101

Commenter and Affiliation

(if stated)

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Comment Source and

ADAMS Accession Number

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Section

Where

Addressed

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.10

A.2.10

A.2.11

A.2.11

A.2.10

A.2.11

A.2.11

A.2.11

A.2.10

A.2.10

A.2.10

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

I NUREG-1437, Supplement 31 A-10 January 2008
Appendix A

Table A-2. (cont.)

Commenters' ID

D-102

D-103

D-104

D-105

D-106

D-107

D-108

D-109

D-110

D-111

D-112

D-113

D-114

D-115

D-116

D-117

D-118

E-1

E-2

E-3

E-4

E-5

E-6

E-7

E-8

F-1

F-2

F-3

Commenter and Affiliation

(if stated)

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

Jim Costedio

John Filippelli,

EPA Region 2

John Filippelli

John Filippelli

John Filippelli

John Filippelli

John Filippelli

John Filippelli

John Filippelli

Christopher Hogan,

NYSDEC

Christopher Hogan

Christopher Hogan

• ,Table 

A-2. 

Comment (cont.) Source and

ADAMS Accession Number

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530437

Letter, ML072530439

Letter, ML072530439

Letter, ML072530439

Letter, ML072530439

Letter, ML072530439

Letter, ML072530439

Letter, ML072530439

Letter, ML072530439

Letter, ML063240331

Letter, ML063240331

Letter, ML063240331

Section

Where

Addressed

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.11

A.2.4

A.2.9

A.2.4

A.2.6

A.2.2

A.2.8

A.2.4

A.2.9

A.2.4

A.2.4

A.2.4

January 2008 A-1 1 NUREG-1437, Supplement 31 I
Appendix A

Table A-2. (cont.)

Section

Commenter and Affiliation Comment Source and Where

Commenters' ID (if stated) ADAMS Accession Number Addressed

G-1 David Stilwell, FWS Letter, ML032000110 A.2.5

G-2 David Stilwell Letter, ML032000110 A.2.5

G-3 David Stilwell Letter, ML032000110 A.2.5

G-4 David Stilwell Letter, ML032000110 A.2.5

G-5 David Stilwell Letter, ML0320001 10 A.2.5

No comments were submitted at the evening meeting. However, the transcripts can be found under accession number

ML072260053.

NYSDOI - New York State Department of Interior

EPA - Environmental Protection Agency

NYSDEC - New York State Department of Environmental Conservation

FWS - U.S. Fish and Wildlife Service

A.2 Comments and Responses

Comments in this section are grouped in the following categories:

A.2.1 General Comments in Support of License Renewal at JAFNPP

A.2.2 Comments Concerning Water Use and Quality

A.2.3 Comments Concerning Air Quality

A.2.4 Comments Concerning Aquatic Resources

A.2.5 Comments Concerning Terrestrial Resources

A.2.6 Comments Concerning Radiological Impacts

A.2.7 Comments Concerning Socioeconomic Factors

A.2.8 Comments Concerning Postulated Accidents

A.2.9 Comments Concerning Uranium Fuel Cycle and Waste Management

A.2.10 Comments Concerning Alternatives

A.2.1 1 Editorial Comments

A.2.1 General Comments in Support of License Renewal at JAFNPP

Comment: I was born and raised just within a few miles of Nine Mile Point. My family and I live

less than a mile from the plant, on the lake, in our home, where we will expect to be retiring in. I

came in today just to state that I'm in favor of the license extension. My feelings are based on

several facts. The plant operation, as most of you know, is closely monitored, as you can see

I NUREG-1437, Supplement 31 A-12 January 2008
Appendix A

here today, and regulated. There's FEMA, the NRC, the EPA, etcetera. Redundant safety

systems at the plant protect the public and all of our vital equipment. The equipment receives

preventative maintenance to ensure reliability in case of any need for it. Even the most simplistic

tasks are completed using written procedure to ensure success and accuracy. Drills and the use

of equipment simulators ensure training is effective for all workers, and that the workers are

prepared for anything. Safe operation and a strong safety culture is always number one at the

station. Spent nuclear fuel is stored safely in heavy sealed containers, protecting it from all

natural or manmade disasters, unlike most other stations in the U.S. The lack of emissions

make operation environmentally friendly, and a positive impact to the local economy and tax

base, as we all know. Power consumption is increased to date, and no new plants have been

started, and nuclear power reduces our demand on foreign oil. As you might think, my

knowledge of these facts is because I work at J.A.F. I'm not here as an employee today. I'm

here as a concerned resident. I'll retire long before the license extension is needed, and will

continue to draw my pension, with or without the continued operation of FitzPatrick. I'm making

my feelings known for the good of the community and not the interests of the company that I

happen to work for. The general public would feel the same way that I do, if they knew what the

workers already know, 'that the plant is safe, the redundant systems protect the health and

safety of the public. We, as in residents, should be more concerned of potential emissions such

as coal dust, arsenic, methane, carbon dioxide from the proposed coal gassification plant which

will be processing 20,000 tons of coal a day, or the damage to our fish population by the latest

invader called the round goby, which I've caught a million of in the lake recently. Or the newest

virus infection that the fish are infested with, which is called VHS. (A-1)

Comment: I'm a life-long resident of Oswego County, and I'm also the business manager of

Carpenters Local 747, and I came today in support of the license renewal for the FitzPatrick

nuclear plant. I have about 425--I checked my registration. I have about 425 members who. live

right in Oswego County. A lot of them live in the Oswego school district and in Scriba, and I tell

you, we have a lotta guys that work at the plant. They're in there, and out, quite a bit. To a man,

everyone has gone in that plant, done their job, and come out safely. That plant is operated very

safely, very well. I worked at that plant. I worked with divers. I worked in some of the more

restricted areas. I didn't help build the plant cause it was a little before my time. But I can attest

through our membership, and the people that work there, that's a very well-run plant, a very

well-maintained plant, a very safe plant. I live about ten miles east of here, towards Mexico,

actually west of here, towards Mexico, and I'm the third generation here. I'm very comfortable

with this plant operating for another 20 years beyond its license renewal--or beyond its license

date. So again, I stand here on behalf of about 420 members and their families, and myself, as

a resident, in support of the license renewal. (B-I)

Response: The comments, general in nature, are supportive of license renewal at James A.

FitzPatrick Nuclear Power Plant. However, the comments provide no new additional information

on the environmental analysis; therefore, there were no changes made to the Supplemental

EIS.

January 2008 A-13 NUREG-1437, Supplement 31 I
Appendix A

A.2.2 Comments Concerning Water Use and Quality

Comment: Page 2-20, Lines 8-12: While the use of Betz Clam-Trol CT-1 is still allowed by the

JAF SPDES Permit, it has not been used in at least 10 years. Correspondingly, remove

references to it from line 8 through line 12. (D-24)

Response: Lines 8-12 have been amended to note that although JAFNPP is permitted by the

state to use Betz Clam-Trol CT-1, it has not been used in over 10 years.

Comment: Page 4-23, Lines 8-12: Remove from "As such..." on line 8 to "...thermal criteria." on

line 12 as this is not a requirement of the current SPDES permit. (D-61)

Response: Lines 8-12 have been corrected to reflect that thermal monitoring is not a condition

of the current SPDES permit, however, Ouffall Number 001 - Circulating Cooling Water, Service

Water & Intake Screen Backwash, is subject to thermal limitations specified in the SPDES

permit.

Comment: The final SEIS should discuss any actions the licensee may have taken to follow-up

on the NRC information notices informing operators of nuclear power and research and test

reactors of the potential for onsite groundwater contamination due to undetected leakage of

radioactive water. (E-5)

Response: A description of Entergy's leakage monitoring program has been added to Section

2.2.7 in response to this comment.

Comment: In Section 2.2.10.2 of the Generic Environmental Impact Statement for License

Renewal of Nuclear Plants, NUREG-1437, Supplement 31 Draft Report for Comment (SEIS) for

Entergy Nuclear FitzPatrick's, LLC (Entergy), James A. FitzPatrick Nuclear Power Plant

(JAFNPP), the U.S. Nuclear Regulatory Commission (NRC) states that "[u]ntil NYSDEC has

issued a Section 401 Water Quality Certification*for JAFNPP, the NRC will not be able to grant

the license renewal." Entergy respectfully submits that § 401 of the Clean Water Act, 33 U.S.C.

§ 1341 does not apply in the license renewal context and, even if it does apply, Entergy has

satisfied its § 401 obligations by submitting to the Commission copies of its currently effective

State Pollutant Discharge Elimination Permit ("SPDES") permit issued by the New York

Department of Environmental Conservation ("DEC"). (DEC is authorized to implement the

NPDES permitting program. See 6 NYCRR § 750-01.1.) Accordingly, the Commission need not

await any further DEC action in order to grant the license renewal. (Entergy voluntarily

submitted an application to DEC for a certification under § 401 and is proceeding with the

collection and submittal of information solicited by DEC for that purpose. However, Entergy has

reserved its rights to raise any legal arguments in that proceeding, including whether a § 401

WQC is required to renew its NRC license. See JAFNPP's Applicant Environmental Report, at

9-2 ("consistent with the FEIS, JAFNPP is providing the copy of its SPDES permit as evidence

of state water quality (401) certification"). (D-1)

I NUREG-1437, Supplement 31 A-14 January 2008
Appendix A

Comment: 1. The renewal of JAFNPP's license will not result in any new, currently

unauthorized discharge to waters of the United States.

Section 401 of the CWA provides, in relevant part, that:

[a]ny applicant for a Federal license or permit to conduct any activities including, but not limited

to, the construction or operation of facilities, which may result in any discharge into navigable

waters, shall provide the licensing or permitting agency a certificate from the State in which the

discharge originates or will originate, ... that any such discharge will comply with the applicable

provisions of sections 1311, 1312, 1313, 1316, and 1317 of this title.

33 U.S.C. § 1341(a) (emphasis supplied). The renewal of the NRC license for JAFNPP will not,

in and of itself, result in a discharge to navigable waters. While license renewal is a necessary

condition to the continued operation of JAFNPP beyond the current !icense period, the

Commission's inquiry is focused on the effect on nuclear safety of the aging of certain

components over the extended license period, 10 CFR § 54.29. The Commission's

determination to renew the license, therefore, does not address nor contemplate any new and

currently unregulated discharge into waters of the United States. Moreover, any new or modified

discharge by JAFNPP could only occur through re-issuance or modification by DEC of its

SPDES permit which, as discussed below, assures compliance with all applicable Clean Water

Act requirements. Therefore, certification under § 401 is not required for the Commission's

license renewal decisions. (D-2)

Comment: 2. Even if § 401 applies to the Commission's license renewal decision, Entergy has

satisfied any such requirements by submitting to the Commission a copy of its currently effective

SPDES permit.

To the extent applicable, Section 401 requires only that the applicant for a federal license

submit a certification from the State that future discharges will comply with the identified

provisions of the Clean Water Act. The submission to the Commission of a currently effective

SPDES permit is sufficient for this purpose.

Both New York and federal law expressly require that SPDES permits be issued only where the

subject discharge will comply with the very same provisions identified in § 401, i.e., §§ 301, 302,

303, 306 and 307 of the' Clean Water Act. See 33 U.S.C. §§ 1342(b)(1)(A) (requiring SPDES

permits to ensure compliance with, among others, §§ 301, 302, 306, and 307 of the Clean

Water Act); 131 1(b)(1)(C) (requiring compliance with state WQS); see also 40 C.F.R. §§

122.44(d)(1) (NPDES permits must achieve WQS established under.§ 303 of the CWA,

including State narrative criteria for water quality); 123.25(a)(15) (requiring same for SPDES

permits); see also 6 NYCRR § 750-1.11 (imposing same requirements for SPDES permits). In

fact, the currently effective JAFNPP SPDES permit expressly states that DEC has determined

that operation in compliance with that permit assures compliance with applicable water quality

standards. See JAFNPP SPDES Permit No. NY-0020109, General Provision 1(b) ("a

January 2008 A-1 5 NUREG-1437, Supplement 31 I
Appendix A

determination has been made on the basis of a submitted application, plans, or other available

information, that compliance with the specified permit provisions will reasonably protect

classified water use and assure compliance with applicable water quality standards."); see also

6 NYCRR § 750-2.1 (b). Accordingly, every element of a § 401 certification is satisfied by the

submission of JAFNPP's effective SPDES permit. Any further certification under § 401 would be

entirely redundant.

JAFNPP currently discharges, and intends to continue to discharge if re-licensed, in compliance

with its SPDES permit or subsequent renewals thereof. (As the SEIS notes, on January 24,

2006, JAFNPP applied for a renewal of its New York SPDES permit, which was scheduled to

expire on August 1, 2006. Until the JAFNPP renewal permit is finalized, the existing SPDES

permit remains in effect. See SEIS at 4-14.) As noted above, the license renewal for JAFNPP

does not involve any new discharge and, therefore, operations during the extended license

period already has been determined by DEC to be in compliance with the provisions cited in §

401. Moreover, under the New York SPDES program, water quality determinations will be

routinely revisited, both during the current license period and any extended license period,

affording the State multiple opportunities to reassess water quality issues. See 6 NYCRR § 750-

1 .15 (SPDES permits for surface water discharges have a fixed term of five years); see also 6

NYCRR § 750-2. 1(b) (authorizing modifications to SPDES permits where even compliant

operations contribute to contravention of State water quality standards). (D-3)

Comment: 3. Based upon our review of NRC practice in the license renewal context, the

Commission has relied on the submission of NYSPDES permits as satisfying the licensee's

obligations (if any) under § 401.

NRC guidance confirms that a § 401 certification is not required for re-licensing where the

facility discharges under an effective SPDES permit. See NRC's Generic Environmental Impact

Statement for License Renewal of Nuclear Plants, NUREG 1437, Volume 1 ("GELS"), at 4-4 ("Of

course, issuance of an NPDES permit by a state water quality agency implies certification under

Section 401.") [See also GELS, §§ 2.3.3 ("effluent discharges are regulated under the provisions

of the Clean Water Act and the implementing effluent guidelines, limitations, and standards

established by EPA and the states."), 4.2.1.1 ("Once a plant is operating, however, the

continuing regulation of nonradiological impacts on water quality and aquatic ecology is

primarily the responsibility of [EPA] or the applicable state permitting agency.")]; see also 56

Fed. Reg. 47,016, 47,019 (September 17, 1991) (with respect to the aquatic impacts of

entrainment, impingement, and heat shock stating that "[t]he permit process authorized by the

[CWA] is an adequate mechanism for control and mitigation of these potential impacts. If an

applicant to renew a license has appropriate EPA or State permits, further NRC review of these

potential impacts is not warranted. Therefore, the proposed rule requires an applicant to provide

the NRC with certification that it holds [CWA] permits, or if State regulation applies, current

State permits."); 61 Fed. Reg. 28467, 28474 (June 5, 1996) ("As a result of this analysis, the

Commission has concluded that the environmental impacts on surface water quality are small

for those effluents subject to existing permit or certification requirements.").

I NUREG-1437, Supplement 31 A-16 January 2008
Appendix A

NRC appears to have invariably followed this practice in the license renewal context, because

our review indicates that none of the other SEISs issued for license renewals expressly requires

the issuance of a § 401 certification by the state prior to license renewal. (Although the state of

New York issued contingent § 401 WQCs for the Ginna and Nine Mile Point nuclear stations,

these documents were WQCs in name only because they expressly deferred to the New York

SPDES program for demonstrating compliance with the Best Technology Available standard

under 6 NYCRR § 704.5. See e.g., October 7, 2003, 2006 § 401 WQC for Ginna, Natural

Resource Permit Condition #4 ("Best Technology Available (BTA) Determination. A BTA

determination will be conducted, pursuant to the SPDES permit, by the Department to

determine if the facility meets the regulatory criteria to minimize adverse environmental impacts

to aquatic species and whether any mitigation is required. Upon evaluation by the Department

of the submitted studies, the Department will determine whether additional BTA measures will

be needed, for which Mitigation Plans will need to be developed, submitted, and completed in

consultation with Department staff."); see also June 21, 2006 § 401 WQC for Nine Mile Point,

Natural Resource Permit Condition #2 ("Best Technology Available (BTA) Determination.

Pursuant to 6 NYCRR Part 704 and Section 316(b) of the Clean Water Act a Best Technology

Available (BTA) determination will be conducted for the facility as part of the renewal of the

State Pollutant Discharge Elimination (SPDES) permit. The BTA determination is based on

whether the facility meets the regulatory criteria to minimize adverse environmental impacts to

aquatic species. Biological studies will be required by the SPDES permit, and will be used by

the Department to determine whether additional measures are needed to achieve BTA. As

necessary, Mitigation Plans will need to be developed, submitted, and completed in consultation

with Department staff."). Therefore, the Commissions' change of course in the SEIS constitutes

a change in NRC procedures without any change in the underlying law. Entergy respectfully

submits that such a deviation is improper. (D-4)

Comment: 4. If the Commission persists in requiring a separate certification from DEC, Entergy

reserves its rights to demonstrate to the Commission that it falls within the statutory exceptions

to certification provided under § 401.

Section 401 contains several statutory exemptions from the requirement to obtain a State

certification, including those set forth in §§ 401(a)(3) and (a)(6). Federal case law confirms that

the NRC is the proper entity to determine whether either of the § 401 WQC exceptions apply

here. See Keating v. FERC, 927 F.2d 616, 625 (D.C. Cir. 1991) ("the application of section 401

(a)(3) involves a federal question that, absent satisfactory explanation, presumably must be

resolved by the applicable federal licensing authority and the federal courts"). Thus, here again,

a § 401 certification by the state prior to license renewal is not required.

Further, if the Commission concludes that a separate § 401 certification is required (i.e.,

something other than the submission of the currently effective SPDES permit), Entergy reserves

its right to submit documentation to the Commission supporting the application of these

exemptions to JAFNPP. (D-5)

January 2008 A-1 7 NUREG-1437, Supplement 31 I
Appendix A

Comment: Conclusion: In short, although JAFNPP is working with the State on a voluntary and

collaborative basis, as a matter of federal and state law, the JAFNPP license renewal does not

require a § 401 WQC. As detailed above, this is because § 401 does not apply in the license

renewal context and, even if it does apply, Entergy has satisfied its § 401 obligations by

submitting to the Commission copies of its currently effective SPDES permit issued by the DEC.

To the extent the Commission requires any further certification under § 401, Entergy reserves

its right to request from the Commission an exemption from such requirements. (D-6)

Response: Section 54.23 ("Contents of application -- environmental information") of the NRC's

nuclear power plant operating license renewal regulations states that each license renewal

application must include a supplement to the environmental report that complies with the"

requirements of subpart A of 10 CFR Part 51. Section 51.45(d) ("Environmental report"), in turn,

requires the applicant to list in the environmental report "all federal permits, licenses, approvals

and entitlements which must be obtained in connection with the proposed action," and to

"describe the status of compliance with these requirements." This section further states that the

environmental report shall discuss "the status of compliance with applicable environmental

quality standards and requirements, including, but not limited to ... thermal and other water

pollution limitations or requirements which have been imposed by Federal, State, regional, and

local agencies having responsibility for environmental protection." 10 CFR 51.45(d); see also

10 CFR 51.53 (stating that the environmental report "must describe in detail the modifications

directly affecting the environment and plant effluents that affect the environment"). The

necessary implication of these provisions is that license renewal applicants must discuss and

document continued Section 401(a) (1) certification into the renewal period.

Although evidence of continued certification into the renewal period is required, we do not

believe that an entirely new Section 401(a)(1) certification must always be tendered as part of

the renewal application. If the original Section 401(a)(1) certification did not include an

expiration date, or if the expiration occurs in the renewal period, then a new certification is not

necessary (although once the certification expires the licensee must provide a new certification).

Alternatively, certification may be evidenced by a valid state water quality permit which is

effective into the renewal period (again, if the state water permit expires in the renewal period, a

new certification would then be necessary). However, if a state has a bifurcated process then

evidence of a Section 401(a) (1) certification will be required before issuance of a renewed

license. Furthermore, the NRC will consider if Entergy falls within any of the statutory

exemptions to 401 certifications.

All applicants for license renewal, in accordance with Section 51.45, should state in their

renewal application whether their facility will possess continuing Section 401(a) (1) certification

into the renewal period, and the basis for their conclusion on this matter.

Comment: Page 2-54, Line 9: Replace "draft" with "final". (D-43)

Comment: Page 2-54, Line 12: Replace "draft" with "final". (D-44)

I NUREG-1437, Supplement 31 A-1 8 January 2008
Appendix A

Response: The text in Section 2.2.10 has been changed in response to the comments.

A.2.3 Comments Concerning Air Quality

Comment: Page 2-23, Lines 21-24: Should read as follows: "The emergency diesel generators,

fire pumps and boilers are regulated under a Certificate to operate an Air Contamination Source

(7-3556-00020/00012) issued by NYSDEC. This certificate limits fuel usage, fuel type, and

hours of operation for the three sets of equipment." (D-28)

Response: The text has been changed as follows: "The emissions from the emergency diesel

generators, fire pumps and boilers are regulated under a Certificate to operate an Air

Contamination Source (7-3556-00020/00012) issued by NYSDEC. This certificate limits fuel

usage, fuel type, and hours of operation for these emission sources."

A.2.4 Comments Concerning Aquatic Resources

Comment: The Service considers the entrainment of fish to be one of the most significant

adverse environmental effects of this facility. The DGEIS utilizes entrainment data from the

adjacent Nine Mile 1 Nuclear Power Plant (Nine Mile 1) as an estimate of entrainment at this

facility since the intake and cooling systems are similar (and no entrainment data exists for

FitzPatrick). According to the DGEIS, the number of entrained fish eggs and larvae entrained at

Nine Mile 1 have varied throughout its operation. The DGEIS cites that in 1976, approximately

350 million alewife (Alosa pseudoharengus) eggs, 4.9 million alewife larvae, 1.5 million rainbow

smelt (Osmerus mordax) eggs, and 205,000 rainbow smelt larvae were entrained per week. A

1997 entrainment study showed lower numbers of entrained fish - approximately 4 to 5 million

ichthyoplankton per week over the period of April through August.

The DGEIS characterizes these entrainment losses as "small", defined as "environmental

effects are not detectable or are so minor that they will neither destabilize nor noticeably alter

any important attribute of the resource." We disagree that entrainment losses of at least 4 to 5

million fish larvae and eggs per week are "small" and believe it is inappropriate to draw

conclusions about the significance of this mortality by comparing entrained numbers against an

estimated standing stock. The DGEIS does not provide information to support its estimate of

alewife or rainbow smelt standing stocks in the U.S. waters of Lake Ontario, nor does it explain

why the only "important resource attributes" evaluated in making a determination of "small

impacts" are fish standing stock numbers within Lake Ontario. It may be equally appropriate to

evaluate the impact of FitzPatrick entrainment on other important resource attributes, such as

age structure within a given fish species or a specified sub-basin within Lake Ontario or impacts

of entrainment on fish community structure. (C-3)

Response: The NRC must evaluate impingement and entrainment in terms of impact to the

environment, thus requiring the staff to develop methods to quantitatively evaluate the impact of

January 2008 A-1 9 NUREG-1437, Supplement 31 I
Appendix A

impingement and entrainment on the affected fishery. To determine these quantitative impacts,

NRC staff must use available population data, which for the JAFNPP review was population

estimates of alewife and rainbow smelt in U.S. waters from 1982 through 2001. These U.S.

waters estimates came from unpublished data compiled by Rochester Gas & Electric

Corporation*.

While the NRC agrees there is no indication that all fish species being impinged and entrained

at JAFNPP function as a single lake-wide population, there is also no evidence that there are

distinct populations specific to U.S. waters or to the Rochester sub-basin of Lake Ontario. The

fish species of interest and most affected by the JAFNPP cooling water system include alewife

(Alosa pseduoharengus) and rainbow smelt (Osmerus mordax), both of which are pelagic

species and likely do not remain in one area of the lake. Even if the U.S. waters population

estimates were roughly divided to reflect local (Nine Mile Point promontory) population

estimates, the effects of impingement and entrainment on either of these two species at

JAFNPP would still be categorized by the NRC as SMALL.

The assessment presented in the SEIS will be based on the best available information, drawing

from a variety of sources, including data collected at JAFNPP by Entergy, data collected at Nine

Mile Point Nuclear Station Unit 1, the New York State Department of Environmental

Conservation (NYSDEC), other governmental agencies, and independent researchers. The

NRC staff recognizes that the amount and quality of data available for NEPA evaluations is

sometimes less than desired; however, the staff believes that there was sufficient information

available to perform the assessment of the impacts of license renewal at JAFNPP. If new and

significant information becomes available in the future that demonstrates a significant impact on

the aquatic environment as a result of continued station operation, the NRC staff expects the

NYSDEC to require modifications to the cooling system necessary to protect the resource

through the New York State Pollutant Discharge Elimination System (SPDES) and 401

Certification permitting program. The comment provides no new and significant information;

therefore, no changes were made to the text in response to the comment.

*Rochester Gas & Electric Corporation. Population Estimates for Alewife and Rainbow Smelt in

Lake Ontario, 1982-2001. Unpublished Data. 2003

Comment: The DGEIS should quantitatively evaluate FitzPatrick entrainment losses within the

context of other fishery impacts, particularly since the DGEIS indicates that both alewife and

rainbow smelt have declined lake-wide and the status of Lake Ontario's alewife population is of

concern. The cumulative impacts assessment presented in the DGEIS mentions entrainment at

adjacent nuclear power plants, nearby oil and gas-fired power plants, and hydroelectric facilities

along the Oswego River. We recommend that a more thorough cumulative impact analysis be

performed that quantitatively evaluates all significant sources of entrainment within the Lake

Ontario basin. This would include addressing entrainment at all Lake Ontario power plants, as

well as at hydroelectric facilities on all Lake Ontario tributaries. In that FitzPatrick entrainment

I NUREG-1437, Supplement 31 A-20 January 2008
Appendix A

losses are expressed in terms of a percentage of the Lake Ontario fish standing stocks,

cumulative impacts should be evaluated for all of Lake Ontario. (C-4)

Response: Section 4.8.1 Cumulative Impacts on Aquatic Resources in the JAFNPP SEIS will

be revised to evaluate cumulative impacts on a lake-wide basis, to be consistent with the

entrainment and impingement reviews which reference U.S. waters population estimates for

alewife and rainbow smelt.

The NRC staff recognizes that further studies may be required for JAFNPP under the New York

SPDES and 401 Certification permitting process. The studies may result in additional mitigation

measures for this facility. However, based on a comprehensive review of the information

currently available, the NRC staff concluded that losses of fish and shellfish from impingement

and entrainment at JAFNPP are SMALL and additional mitigation is not warranted at this time.

A reduction in entrainment losses due to further mitigation would not be expected to have a

detectable effect at the population level. The conclusion of SMALL impact for entrainment and

impingement is based on an assessment of losses of individuals due to plant operation to the

population estimates of alewife and rainbow smelt in U.S. waters of Lake Ontario. Furthermore,

the NRC's regulatory jurisdiction is limited to the characterization and quantification of impacts

in accordance with NEPA. The US, EPA and the NYSDEC have the regulatory authority to

require JAFNPP compliance with the requirements of the Clean Water Act (CWA). The need to

operate JAFNPP using closed cycle cooling or restore spawning habitat to mitigate impacts on

aquatic resources is subject to a determination by New York State under the CWA and could

become a condition of future SPDES and 401 Certification permitting. The comment provides

no new and significant information; therefore, no changes were made to the SEIS in response to

this comment.

Comment: We note that Nine Mile 1 has an intake flow of 418 million gallons per day, less than

the 518 million gallons per day of intake flow at FitzPatrick. We also understand that on-site

entrainment data are being collected at FitzPatrick. These data should be used in lieu of the

Nine Mile 1 data to better estimate fish entrainment losses and should be provided to the

Service for their review.

The Department recommends that the NRC evaluate alternatives to mitigate the entrainment

losses at FitzPatrick, including modifying the cooling system from a once through system to a

closed cooling system and other potential fish entrainment mitigation methods, including

enhancing/restoring spawning habitat for the species most affected by the facility. (C-5)

Response: As noted in the SEIS, Entergy is proceeding with further entrainment studies.

Preliminary, unpublished results from these studies support the assertion that JAFNPP's offshore intake structure reduces the amount of fish eggs and larvae entrained into the cooling

system, and both the off-shore location of the intake and the fish deterrence system reduce the

amount of fish impinged. At the time of publication of the final SEIS, the results of the studies

will not be available for inclusion in the entrainment and impingement evaluations. If new and

January 2008 A-21 NUREG-1437, Supplement 31 I
Appendix A

significant information becomes available in the future that demonstrates an impact greater than

SMALL on the aquatic environment as a result of continued station operation, the NRC staff

expects the NYSDEC to require modifications to the cooling system necessary to protect the

resource through the SPDES and 401 Certification permitting program. The comments

provided no new and significant information; therefore, there were no revisions to Sections 4. 1.1

and 4.1.2 of the SEIS.

Comment: Page 4-19, Table 4-4: Numbers in Table 4-4 do not match numbers in the text on pg

4-18, lines 31-35. Numbers in text are correct. (D-60)

Response: Table 4.4 has been corrected to reflect the percentages of actual number of fish

taken from the intake screens (corrected for collection efficiencies) during the 2004

impingement monitoring program. The percentages in the text refer to the 2004 impingement

rates that were calculated using plant flow: the text has also been amended to make this clear.

Comment: Page 2-26, Line 28: Pg 2-24, line 12 says the Port of Oswego is "approximately 6

miles west of JAFNPP". This distance should be consistent, either 4 or 6 miles in both places?

(D-30)

Response: The distance given on page 2-26 has been changed to 6 miles to be consistent with

the distance given on page 2-24.

Comment: We have concerns with the impacts due to entrainment and impingement of fish and

shellfish, and an inadequate cumulative impacts analysis. (E-1)

Response: Section 4.8.1, Cumulative Impacts on Aquatic Resources, in the JAFNPP SEIS will

be revised to evaluate cumulative impacts on a lake-wide basis, to be consistent with the

entrainment and impingement reviews which reference U.S. waters population estimates for

alewife and rainbow smelt.

Comment: EPA is concerned that the information being used to determine the potential impact

of the use of cooling water on the entrainment of organisms is dated and that the determination

does not take into account the changes in fisheries stocks that have been seen in Lake Ontario.

The ichthyoplankton entrainment estimates are made by extrapolating data from a 1997 Study

performed near the Nine Mile Point Nuclear Station. Not only is that data ten years old, but, as

stated in the draft SEIS, the fisheries species in Lake Ontario have changed rapidly over the

past 10 years with decreasing numbers of alewife and increasing numbers of invasive aquatics,

such as quagga mussels (Dreissena buggensis). Also, the draft SEIS points out that studies

done in the 1980s and 1990s have shown a decline in zooplankton and algal abundance, and

implies an increased competition between smaller fish and other invertebrates for zooplankton

prey. Clearly, the existing condition of the Lake is different from what it was in the 1990s.

The NRC concludes that the potential impacts of the use of once-through cooling water to fish

and shellfish are small. This conclusion may be premature, particularly when there is a current

I NUREG-1437, Supplement 31 A-22 January 2008
Appendix A

study that will provide new information concerning the significance of the impact. The draft SEIS

states that on January 24, 2006, JAFNPP applied for a renewal of its New York SPDES permit,

and as part of that program, JAFNPP recently conducted a one-year entrainment sampling

program, which concluded in March 2007. While NRC states that it reviewed preliminary data

from this study, the entire dataset should be analyzed and presented within the final SEIS. The

Council on Environmental Quality's NEPA regulations state that relevant environmental

documents should be made part of the record. A small delay in releasing the final SEIS should

not interfere with the relicensing date of 2014, and will allow the public and interested parties to

examine the new data. (E-3)

Response: Based on the information currently available, the NRC staff concluded that losses of

fish and shellfish from impingement and entrainment are SMALL when compared to alewife and

rainbow smelt fishery in U.S. waters. These U.S. waters estimates came from unpublished data

compiled by Rochester Gas & Electric Corporation*. Due to the lack of entrainment data for

JAFNPP, the NRC used the best available data, which was an entrainment study conducted at

Nine Mile Point Nuclear Stations Unit 1 in 1997. The NRC staff recognizes that the amount and

quality of data available for NEPA evaluations sometimes fall short of ideal, but believes that

there was sufficient information available to perform an assessment of the impacts of license

renewal at JAFNPP.

As noted in the SEIS, Entergy is proceeding with further entrainment studies. Preliminary,

unpublished results from these studies support the assertion that JAFNPP's off-shore intake

structure reduces the amount of fish eggs and larvae entrained into the cooling system, and

both the off-shore location of the intake and the fish deterrence system reduce the amount of

fish impinged. At the time of publication of the final SEIS, the results of the studies will not be

available for inclusion in the entrainment and impingement evaluations. If new and significant

information becomes available in the future that demonstrates a significant impact on the

aquatic environment as a result of continued station operation, the NRC staff expects the

NYSDEC to require modifications to the cooling system necessary to protect the resource

through the SPDES and 401 Certification permitting program. The comment provides no new

and significant information; therefore, no changes were made to the SEIS in response to this

comment.

*Rochester Gas & Electric Corporation. Population Estimates for Alewife and Rainbow Smelt in

Lake Ontario, 1982-2001. Unpublished Data. 2003

Comment: Page 4-13,14 - Draft NUREG-1437, Supplement 31.- The NRC should not use fish

populations in the entire water body (Lake Ontario) to determine the significance of impacts

regarding impingement and entrainment. NRC uses the following standards to categorize

environmental impacts (10 CFR Part 51 (Footnote 3, Table B-I)):

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

destabilize nor noticeably alter any important attribute of the resource.

January 2008 A-23 NUREG-1437, Supplement 31
Appendix A

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

important attributes of the resource.

LARGE - Environmental effects;areclearly noticeable and are sufficient to destabilize important

attributes of the resource.

While it is logical to look at fish when analyzing potential impingement and entrainment impacts

from the continued operation of FitzPatrick, NRC standards do not require a broad scale

evaluation limited to consideration of lake-wide fish populations. There is no indication that all

fish species being impinged and entrained at FitzPatrick function as a single lake-wide

population. Moreover, New York State is entrusted with the conservation of fisheries resources

at a finer scale (i.e., New York State). Thus, a conservative approach focusing on local

abundance of fish seems more appropriate. In fact, NRC used just such of an approach when

considering cumulative impacts. In that case, NRC considered cumulative impacts within a 50-

mile radius of FitzPatrick (Page 4-47 - Draft NUREG-1437, Supplement 31). (F-I)

Response: The NRC recognizes the difference in perspective between the goals of the

NYSDEC and the NRC's license renewal NEPA review. When evaluating impingement and

entrainment at a plant, one could argue that even the loss of a few fish is unacceptable and

mitigation is warranted. The NRC must evaluate impingement and entrainment in terms of

impact to the environment, thus requiring the staff to develop methods to quantitatively evaluate

the impact of impingement and entrainment on the affected fishery. To determine these

quantitative impacts, NRC staff must use the best available population data, which for the

JAFNPP review was population estimates of alewife and rainbow smelt for U.S. waters from

1982 through 2001. These U.S. waters estimates came from unpublished data compiled by

Rochester Gas & Electric Corporation*.

While the NRC agrees there is no indication that all fish species being impinged and entrained

at JAFNPP function as a single lake-wide population, there is also no evidence that there are

distinct populations specific to New York/U. S. waters or the three Lake Ontario sub-basins

(Niagara, Mississauga, and Rochester). The fish species of interest and most affected by the

JAFNPP cooling water system include alewife and rainbow smelt, both of which are pelagic

species which likely do not remain in one area of the lake. Even if the U.S. waters population

estimates were roughly divided to reflect local New York waters or Rochester sub-basin

population estimates, the effects of impingement and entrainment on either of these two species

at JAFNPP would still be categorized by the NRC as small. The comment provides no new and

significant information; therefore, no changes were made to the SEIS in response to this

comment.

*Rochester Gas & Electric Corporation. Population Estimates for Alewife and Rainbow Smelt in

Lake Ontario, 1982-2001. Unpublished Data. 2003

I NUREG-1437, Supplement 31 A-24 January 2008
Appendix A

Comment: Page 4-14 - Draft NUREG-1437, Supplement 31.- References to factors

contributing to fish populations in the Mississippi River (LaJeone and Monzingo 2000) lend little

support for factors contributing to fish mortality in Lake Ontario. The ecological systems are

completely different and have different fish species, water quality parameters, and flow

dynamics. (F-2)

Response: The comment refers to a scientific paper prepared by Larry J. LaJeone of

Commonwealth Edison Company and Richard G. Monzingo of EA Engineering, Science and

Technology, entitled "316(b) and Quad Cities Station, Commonwealth Edison" published in

Environmental Science & Policy in 2000. The paper summarizes the findings and conclusions

of 14 years of entrainment and impingement monitoring at Quad Cities Station, an open-cycle

plant located on the Upper Mississippi River. The paper concluded that naturally occurring

environmental conditions have a greater effect on fish populations than actual plant operations,

and fluctuations in annual impingement and entrainment numbers primarily reflect waterbody

conditions and fish populations' responses to them. NRC staff does not assert there is similarity

between the Upper Mississippi River and Lake Ontario, instead it references the paper to

support the same conclusion with regard to natural fluctuations in Lake Ontario fish populations

and subsequent impingement and entrainment rates at JAFNPP. As part of the environmental

review for the JAFNPP license renewal application, the LaJeone and Mozingo reference will

remain in Section 4.1.1 Entrainment of Fish and Shellfish in Early Life Stages. The comment

provides no new and significant information; therefore, no changes were made to the SEIS in

response to this comment.

Comment: Page 4-15,21 - Draft NUREG-1437, Supplement 31.- The following changes would

improve New York's position for requiring mitigation (if appropriate) while still reflecting NRC

staff conclusions:

Original Wording: However, the NRC staff concluded that none of the mitigation measures

considered would be beneficial enough to reduce the significance of adverse entrainment

{impingement} impacts to the Lake Ontario fishery.

Proposed Wording: However, the NRC staff concluded that none of the mitigation measures

considered would eliminate adverse entrainment {impingement} impacts and would not reduce

the significance level below SMALL. (F-3)

Response: The text in Sections 4.1.1 and 4.1.2 has been changed in response to this

comment.

Comment: While NRC staff has determined that the potential impacts of entrainment and

impingement by JAFNPP are small as those numbers comprise a small percent of the lakewide

population, it did not evaluate the cumulative impact to those resources on the entire lake. The

cumulative impacts analysis does not evaluate the use of Lake Ontario water as cooling for

other nuclear or coal electric generating facilities in Canada, such as the Pickering Nuclear

January 2008 A-25 NUREG-1437, Supplement 31 I
Appendix A

Generating Station or Darlington Nuclear Generating Station, and the cumulative impacts to

aquatic species. (E-7)

Response: Section 4.8.1 Cumulative Impacts on Aquatic Resources in the JAFNPP SEIS has

been revised to evaluate cumulative impacts on a lake-wide basis, to be consistent with the

entrainment and impingement reviews which reference U.S. waters population estimates for

alewife and rainbow smelt.

A.2.5 Comments Concerning Terrestrial Resources

Comment: The U.S. Fish and Wildlife Service (Service) has reviewed the NRC's May 2007

Biological Assessment (BA) for the proposed project. Pursuant to Section 7(a)(2) of the ESA,

the NRC has determined that the proposed project will have no effect on the Federally-listed

endangered Great Lakes breeding population of the piping plover (Charadrius melodus), and

that the proposed project may affect, but is not likely to adversely affect the Federally-listed

threatened bog turtle (Clemmys muhlenbergii) or bald eagle (Haliaeetus leucocephalus), the

Federally-listed endangered Indiana bat (Myotis sodalis), or the eastern massasauga (Sistrurus

catenatus catenatus), a candidate for listing.

The eastern massasauga is not known to occur in the Vicinity of the proposed project. The bald

eagle was officially delisted on August 8, 2007, removing all ESA requirements for this species.

However, the bald eagle continues to receive protection under the Bald and Golden Eagle

Protection Act (BGEPA) (54 Stat. 250, as amended; 16 U.S.C. 668 et seq.) and the NRC should

follow the Service's May 2007 Bald Eagle Management Guidelines* to avoid impacts to this

species. The Service agrees that the project is unlikely to affect the piping plover or its

designated critical habitat. However, the Service cannot concur with NRC's determinations for

the bog turtle or Indiana bat at this time due to lack of sufficient information provided in the BA

to fully understand the potential impacts. Pursuant to conversations between Ms. Robyn Niver,

of this office, and Ms. Jessie Muir, of the NRC, we understand that additional information is

forthcoming. (C-1)

Comment: In your May 21, 2007, letter and BA, the NRC determined the proposed project may

affect but is not likely to adversely affect the bald eagle, bog turtle, Indiana bat, and Eastern

massasauga. The Department of the Interior' s August 28, 2007, letter to Ms. Jessie Muir, of

the NRC, concluded that no further coordination or consultation pursuant to the ESA was

required for the bald eagle, Eastern massasauga, or the piping plover. However, the NRC,

Entergy, NMPNS, and NYPA should follow the Bald Eagle Management Guidelines found on

our website to avoid any impacts to the bald eagle which continues to receive protection under

the Bald and Golden Eagle Protection Act (54 Stat. 250, as amended; 16 U.S.C. 668 et seq.).

(G-1)

Response: We have removed the eastern massasauga rattlesnake from Table 2-4 and clarified

the wording in Section 2.2.6.3 to better convey that the species is included in the discussion

I NUREG-1437, Supplement 31 A-26 January 2008
Appendix A

because it was identified in the NRC's previous review of Nine Mile Point Nuclear Station, which

lies directly west of JAFNPP. We have removed the bald eagle from Table 2-4 and reworded

Section 2.2.6.3 to reflect the recent delisting of the species, while adding information about its

continued protection under the Bald and Golden Eagle Protection Act and Migratory Bird Treaty

Act. We have reviewed the Fish & Wildlife Service's (FWS) May 2007 Bald Eagle Management

Guidelines to ensure the continued avoidance of impact to the species that might result from

continued operation of JAFNPP. Text has been added to Sections 4.6 and 4.6.2 to reflect the

FWS's determination that no further consultation is required for the bald eagle, Eastern

massasauga rattlesnake, or piping plover.

Comment: As a reminder, until the proposed relicensing is complete, the NRC should check

our website every 90 days from the date of this letter to ensure that listed species

presence/absence information is current. Please remember that a Federal agency shall make

no irreversible or irretrievable commitment of resources that would prevent formulating or

implementing any reasonable or prudent alternatives for the action as described in 50 CFR Part

402.14. This prohibition remains until the requirements of Section 7(a)(2) are satisfied. (C-2)

Comment: Should project plans change, or if additional information on listed or proposed

species or critical habitat become s available, these determinations may be reconsidered. The

most recent compilation of Federally-listed and proposed endangered and threatened species in

New York is available for your information.- Until the proposed project is complete, we

recommend that you check our website every 90 days from the date of this letter to ensure that

listed species presence/absence information for the proposed project is current.*

The above comments pertaining to endangered species under our jurisdiction are provided

pursuant to the ESA. This response does not preclude additional Service comments under any

other legislation. (G-4)

Comment: As a reminder, all Federally-listed species, as well as the Eastern massasauaga and

bald eagle, are also listed by the State of New York. Any additional information regarding the

proposed project and its potential to impact listed species should be coordinated with both this

office and with the NYSDEC. The NYSDEC contact for the Endangered Species Program is Mr.

Peter Nye, Endangered Species Unit, 625 Broadway, Albany, NY 12233 (telephone: [518] 402-

8859). (G-5)

Response: NRC staff has checked the FWS's and the NYSDEC's websites to ensure that we

have included an accurate and up-to-date description of all listed species and updated our

references accordingly. NRC staff will continue to check these sites until the Final SEIS is

issued for JAFNPP and make the appropriate changes to the document, as needed. If project

plans change, the NRC will notify the FWS and NYSDEC, as any changes may alter the FWS's

previous determinations regarding potential adverse impacts to listed threatened or endangered

species. Additionally, the NRC will be sure to coordinate any additional information regarding

the JAFNPP license renewal review with both the FWS and NYSDEC.

January 2008 A-27 NUREG-1437, Supplement 31 I
Appendix A

Comment: The DGEIS indicates that impingement of diving ducks has not been observed at

FitzPatrick but has been an issue at Nine Mile Point Nuclear Station. The NRC should clarify the

measures, such as monitoring, that are being taken to monitor waterfowl impingement at the

intake. (C-6)

Response: Although Nine Mile Point I had an incident in 2000 in which diving ducks were

impinged in the screenwall building, this was an isolated event, and thought to be the result of

both the presence of zebra mussels located on or near the intake structures and plant reverse

flow conditions. Nine Mile Point now annually cleans all intake structures to remove zebra

mussels and schedules reverse flow conditions during periods when diving duck feeding is

limited. JAFNPP uses a molluscicide within its service and cooling water systems to control for

zebra mussels, which is regulated by JAFNPP's SPDES permit. Because of the use of

molluscicide, established populations of zebra mussels do not exist on JAFNPP's intake

structures. JAFNPP has not observed the presence of diving ducks in the vicinity of its intake

structures, which is likely due to the absence of their food source, zebra mussels; therefore, no

monitoring is conducted at JAFNPP for diving ducks. Text has been added to Section 2.2.6 to

clarify there is no concern of waterfowl impingement at JAFNPP's intake.

Comment: Based on the additional information provided in an August 20, 2007, letter from Ms.

Jessie Muir, of the NRC, we concur that the activities associated with operating and maintaining

the Plant and associated transmission lines are not likely to adversely affect the Indiana bat as

any adverse effects will be either insignificant (effects which are unable to be meaningfully

measured, detected, or evaluated) or discountable (effects extremely unlikely to occur). (G-2)

Comment: We also concur that activities conducted at the Plant are not likely to adversely

affect the bog turtle. However, we are unable to concur that transmission line maintenance

activities are not likely to adversely affect the bog turtle given our understanding of the project

location and activities. We understand that the following activities are likely to occur within

rights-of-way: mowing, herbicide application, use of motorized vehicles, and tree-trimming or

removal. These activities have the potential to impact bog turtles and/or their habitat. Therefore,

we recommend that a qualified surveyor conduct Phase I surveys (potential habitat surveys) for

any wetlands that may be disturbed during the operating and maintenance of the lines. Some

surveys have already been completed in Oswego County that may reduce the ultimate scope of

necessary survey work. We understand that NRC does not maintain GIS data for the proposed

project and have requested this directly from the NYPA to determine whether any known or

previously identified potential habitat for bog turtles occurs within the associated ROWs. You

can find Phase I guidelines and template reporting forms on our website.* If known sites or

potential habitat is present within the ROWs, further coordination/consultation with the Service

is required. NYPA can also assume that all wetlands provide habitat for the bog turtle and

employ standard avoidance and minimization measures (e.g., timing of activities). Please

contact Ms. Niver for further information regarding options for addressing this species. In

addition, we request a copy of the NYPA System Right-of-Way Management Plan for further

description of maintenance activities. (G-3)

I NUREG-1437, Supplement 31 A-28 January 2008
Appendix A

Response: Text has been added to Section 4.6 and 4.6.2.to reflect the FWS's determination

that operation of JAFNPP and maintenance of the associated transmission line ROWs is not

likely to adversely affect the Indiana bat and the FWS's determination that operation of JAFNPP

is not likely to adversely affect the bog turtle. Text has been added to update the status of the

ongoing consultation with FWS in regards to FWS's concerns over the possible effects of

transmission line maintenance activities on the bog turtle. The NRC will continue to consult with

the FWS to assure protection of the bog turtle.

A.2.6 Comments Concerning Radiological Impacts

Comment: In Section 2.2.7 of the draft SEIS, NRC states that for 2005, whole-body dose

estimates were calculated based on actual liquid and aqueous effluent release data and

conservative models to simulate the transport mechanisms. This text should be expanded to

provide perspective on whether the maximum whole-body doses calculated for 20G5 are typical

of what would be expected considering the last 5-10 years of liquid and gaseous effluent data

available for JAFNPP. (E-4)

Response: The discussion of the radiological impacts in Section 2.2.7 has been expanded in

response to this comment to state that the radiological data from previous years is consistent

with the data reported for calendar year 2005.

A.2.7 Comments Concerning Socioeconomic Factors

Comment: Page 2-40, Line 7-15: The percentages in the text do not match the percentages in

Table 2-6. (D-40)

Response: The numbers in the text are not supposed to match the numbers in the table. The

text is showing an average annual rate while the table is showing the total growth over the

5-year period. Changes have been made to the text to clarify the difference in numbers in the

text and the table.

Comment: Page 2-47, Line 1: In Table 2-10, change the number of Entergy Nuclear Northeast

employees from "560" to "716" to accurately reflect the employment and to be consistent with

what is known on Page 2-39 (Line 16) of the draft SEIS. (D-42)

Response: The numbers in Tables 2-5 and 2-10 are correct. The total number of permanent

JAFNPP employees (716), in Table 2-5, represents all employees while the numbers shown in

Table 2-10, represents data from only Oswego County. No changes were made to the text as a

result of this comment.

January 2008 A-29 NUREG-1437, Supplement 31 I
Appendix A

A.2.8 Comments Concerning Postulated Accidents

Comment: Section 5 of the draft SEIS should include a discussion on how the impacts of

intentional destructive acts (e.g., terrorism) aimed at the plant, as well as the dry cask storage

facilities, were addressed in the assessment of the impacts from postulated accidents. The

requirement to consider such acts as part of the NEPA analysis is based on the Ninth District

Court's decision in San Luis Obispo Mothers for Peace v. Nuclear Regqulatory Commission

(June 2006). (E-6)

Response: Comment noted; however, Fitzpatrick is not in the 9th Circuit. The Commission

noted that in San Luis Obispo Mothers for Peace v. NRC, 449 F.3d 1016 (9th Cir. 2006), cert.

denied sub nom. Pacific Gas & Elec. Co. v. San Luis Obispo Mothers for Peace, No. 06-466

(Jan. 16, 2007), the Ninth Circuit held that the NRC could not, under NEPA, categorically refuse

to consider the consequences of a terrorist attack against a spent fuel storage facility. The

Commission respectfully disagreed with the Ninth Circuit's view, but stated -that it will follow that

ruling in the Ninth Circuit-indicating its belief that a different outcome might be reached by other

Courts of Appeals. Oyster Creek, CLI-07-8, 65 NRC at 128. Therefore, no changes were made

to Section 5.1.2.

A.2.9 Comments Concerning Uranium Fuel Cycle and Waste Management

Comment: Page 2-10, Line 32: Change "solid" to "nonhazardous" since hazardous and mixed

wastes are considered solid waste under 40CFR261. (D-1 1)

Response: The text has been changed in response to this comment.

Comment: Page 2-10, Lines 35-36: Delete the sentence "Solid waste is waste that is neither

radioactive nor hazardous as defined by the Resource Conservation and Recovery Act (RCRA)

(40 CFR Part 260)" and replace with "A solid waste can be nonhazardous, hazardous or

radioactive." (D-12)

Response: The sentence in question has been deleted.

Comment: Page 2-10, Line 36: Change "solid" to "nonhazardous" since hazardous and mixed

wastes are considered solid waste also under 40CFR261. (D-1 3)

Comment: Page 2-11, Line 3: Insert "other nonhazardous waste such as" between "for" and

"office". (D-14)

Comment: Page 2-11, Line 32: Delete "disposed of offsite by a contract service" and replace

with "then shipped off-site by a contract service for recycling" since these type materials are

recycled and not disposed. (D-15)

I NUREG-1437, Supplement 31 A-30 January 2008
Appendix A

Comment: Page 2-12, Line 1 - Delete "transformer oil" since oils in onsite transformers do not

contain PCBs based on analytical testing. (D-17)

Comment: Page 2-12, Lines 2-3: Replace the sentence "In 2005, JAFNPP received a fine from

EPA for improperly identifying a drum of used oil as nonhazardous instead of PCB-waste and

not disposing of the drum at a TSCA disposal facility" with "Although the wastes was properly

disposed, JAFNPP received a fine from the EPA in 2005 for shipping used oil containing PCBs

on a Straight Bill of Lading instead of the required hazardous waste shipping manifest specified

under TSCA" since the waste was ultimately disposed of properly and the issue was associated

with not using the EPA hazardous waste manifest. (D-18)

Comment: Page 2-12, Line 12: Change "Discharge" to "Disposal" to reflect the correct title in

the regulations. (D-19)

Comment: Page 2-12, Line 25: Delete "several accumulation areas in" since mixed waste is

only accumulated in one area. (D-20)

Comment: Page 2-12, Line 25: Insert "currently" between "not" and "have". (D-21)

Response: The text in Section 2.1.5 has been changed in response to the comments.

Comment: Also, we recommend that the final SEIS address opportunities for pollution

prevention and waste recycling. (E-2)

Comment: The draft SEIS was also silent on the issue and options for pollution prevention (P2).

The final SEIS should discuss the internal and external processes and the waste streams that

would be candidates for pollution prevention technologies. Some P2 opportunities can be as

simple as specific landscaping and reduction of herbicides within the facility grounds, to

reduction of sanitary or hazardous (non-radioactive) wastes. We encourage consultation with

the U.S. Department of Energy's P2 office to obtain recommendations that would fit with the

processes at JAFNPP. (E-8)

Response: Implementation of pollution prevention measures at JAFNPP is not within the NRC's

regulatory purview, but is implemented under state and local regulations and requirements.

Therefore, the NRC does not identify candidate waste streams for pollution prevention

technologies in the SEIS but instead highlights resources Entergy can use to identify waste

minimization opportunities, such as the Environmental Protection Agency's Office of Pollution

Prevention and Toxics. No change was made to Section 2.1.5 as a result of this comment.

January 2008 A-31 NUREG-1437, Supplement 31 I
Appendix A

A.2.10 Comments Concerning Alternatives

Comment: Page 8-32: Under the "Impact" column for "Water Use and Quality-Groundwater"

at the "JAFNPP Site", change "SMALL" to "NO IMPACT" to be consistent with the impact

conclusion reached for the natural gas alternative at the JAFNPP site (Page 8-25). (D-84)

Response: The text in Table 8-6 has been changed in response to the comment.

Comment: Page 8-35, Line 6: Change "Overall, the impacts of the nuclear alternative at the

JAFNPP site would be SMALL" to "Overall, there would be no impacts of the nuclear alternative

at the JAFNPP site" to be consistent with the impact conclusion reached for the natural gas

alternative at the JAFNPP site (Page 8-25). (D-85)

Response: The text in Section 8.2.3.1 has been changed in response to the comment.

Comment: Page 8-49: Under the "Socioeconomics Impact" column at an "Alternate Site",

should the impacts be "SMALL to MODERATE" instead of "SMALL to LARGE" based on the

summary in the "Comments" column since it states "SMALL to MODERATE"? (D-88)

Response: The "Comments" column in Table 8-8 has been changed to "SMALL to LARGE".

This is consistent with the impacts for the natural gas-fired plant, which is the primary driver of

the impacts for the combined alternative section.

Comment: Page 9-7: Under the "No-Action Alternative" column for "Water Use and QualityGroundwater', change "SMALL" to "NO IMPACT" to be consistent with what is shown in Table

8-1 of the Draft SEIS (Page 8-3). (D-92)

Comment: Page 9-7: Under the "New Nuclear Generation" column at an "Alternate Site" for

"Transportation", change "SMALL to MODERATE" to "SMALL to LARGE" to be consistent with

what is shown in Table 8-6 of the Draft SEIS (Page 8-33). (D-93)

Response: The text in Table 9-1 has been changed in response to the comments.

Comment: Page 9-7: Under the "Combination of Alternatives" column at an "Alternate Site" for

"Socioeconomics", should the impacts be "SMALL to MODERATE" instead of "SMALL to

LARGE" since the summary in the "Comments" column of Table 8-8 (Page 8-49) states "SMALL

to MODERATE"? (D-94)

Response: The "Comments" column of Table 8-8 was changed to "SMALL to LARGE",

therefore, no change was made to Table 9-1.

A.2.11 Editorial Comments

Comment: Page xxi, Line 20: Change "Lowest" to "lowest". (D-7)

I NUREG-1437, Supplement 31 A-32 January 2008
Appendix A

Comment: Page 1-5, Line 33: Insert a space between "Renewal" and NUREG-1555". (D-8)

Comment: Page 2-6, Line 37: Change "services" to "service".. (D-9)

Comment: Page 2-9, Line 29: Add "releases" or "effluents" between "gaseous" and "in". (D-10)

Comment: Page 2-12, Line 1: Replace "is" with "are". (D-16)

Comment: Page 2-16, Line 9: Insert "(0.7 mi)" after "3700 ft" to be consistent with previous

write-up on Page 2-14. (D-22)

Comment: Page 2-17, Line 17: Change "0.71" to "0.7" to be consistent with how this number is

listed on Page 2-1 (Line 24) of the Draft SEIS. (D-23)

Comment: Page 2-20, Line 20: Change "(Entergy 2006a)" to "(Entergy 2006c)" to accurately

reflect the reference source in the Section 2.3 references of the Draft SEIS. (D-25)

Comment: Page 2-21, Line 5: Change "(Entergy 2006c)" to "(Entergy 2006f)" to accurately

reflect the reference source in the Section 2.3 references of the Draft SEIS. (D-26)

Comment: Page 2-22, Line 30: Insert a space between "Statement" and "(NRC 2006,

Section 2.2.4)". (D-27)

Comment: Page 2-23, Line 26: Change "system" to "systems". (D-29)

Comment: Page 2-28, Line 29: There is no "(NYSDEC 2003)" listing in the Section 2.3

references of the Draft SEIS. (D-31)

Comment: Page 2-28, Line 33: Add "Endangered Species Act of 1972" to the references listed

in Section 2.3 of the Draft SEIS to be consistent with other Federal Acts listed. (D-32)

Comment: Page 2-28, Line 33: Change "(Entergy 2006b)" to "(Entergy 2006c)" to accurately

reflect the reference source in the Section 2.3 references of the Draft SEIS. (D-33)

Comment: Page 2-31, Line 5: Change "(Entergy 2006)" to "(Entergy 2006c)" to accurately

reflect the reference source in the Section 2.3 references of the Draft SEIS. (D-34)

Comment: Page 2-31, Line 15: Delete spaces between "birch" and "/" and "/" and "sweet".

(D-35)

Comment: Page 2-31, Line 30: Change "(Entergy 2006b)" to "(Entergy 2006c)" to accurately

reflect the reference source in the Section 2.3 references of the Draft SEIS. (D-36)

Comment: Page 2-35: Need to delete "Table 2-4 (cont'd)" and subheading under it. Should be

a continuation of the bird listing. (D-37)

January 2008 A-33 NUREG-1437, Supplement 31
Appendix A

Comment: Page 2-37, Line 19: Change "on" to "or'. (D-38)

Comment: Page 2-38, Line 14: Insert "are" between "and" and "used". (D-39)

Comment: Page 2-46, Lines 1-2: For the list of Sources, change "(USCB 2006)" and "(NRC

2006a)" to "(USCB 2006a)" and "(NRC 2006)" respectively, to accurately relect the reference

source in the Section 2.3 references of the Draft SEIS. (D-41)

Comment: Page 2-55, Lines 23-26: There is no "Boyd and Biberhofer' reference listing in the

Section 2.0 write-up (Pages 2-1 through 2-54). (D-45)

Comment: Page 2-56, Line 12: Insert "(EA)" after "Technology" to be consistent with how the

reference is shown in the Section 2.0 write-up (Page 2-28). (D-46)

Comment: Page 2-59, Lines 1-3: There is no "(ISLFBC 2002a)" reference listing in the Section

2.0 write-up (Pages 2-1 through 2-54). (D-47)

Comment: Page 2-59, Lines 4-6: There is no "(ISLFBC 2002b)" reference listing in the Section

2.0 write-up (Pages 2-1 through 2-54). (D-48)

Comment: Page 2-61, Lines 3-5: There is no "(NYSDEC 2001)" reference listing in the Section

2.0 write-up (Pages 2-1 through 2-54). (D-49)

Comment: Page 2-62, Lines 26-27: There is no "(NMPC 1975)" reference listing in the Section

2.0 write-up (Pages 2-1 through 2-54). (D-50)

Comment: Page 2-62, Lines 30-32: There is no "(NMPNS 2002a)" reference listing in the

Section 2.0 write-up (Pages 2-1 through 2-54). (D-51)

Comment: Page 2-64 through 65, Lines 33 and 1-2: There is no "(USACE 2002)" reference

listing in the Section 2.0 write-up (Pages 2-1 through 2-54). (D-52)

Comment: Page 2-65, Lines 14-17: There is no "U.S. Department of Agriculture 2002"

reference listing in the Section 2.0 write-up (Pages 2-1 through 2-54). (D-53)

Comment: Page 2-65, Lines 18-22: There is no "(EPA et al 1998)" reference listing in the

Section 2.0 write-up (Pages 2-1 through 2-54). (D-54)

Comment: Page 2-66, Lines 24-28: There is no "(NRC 1985)" reference listing in the Section

2.0 write-up (Pages 2-1 through 2-54). (D-55)

Comment: Page 2-66, Lines 29-30: There is no "(NRC 1996)" reference listing in the Section

2.0 write-up (Pages 2-1 through 2-54). (D-56)

I NUREG-1437, Supplement 31 A-34 January 2008
Appendix A

Comment: Page 2-66, Lines 31-34: There is no "(NRC 1999)" reference listing in the Section

2.0 write-up (Pages 2-1 through 2-54). (D-57)

Comment: Page 2-67, Lines 10-11: There is no "(Zilkoski et al. 1992)" reference listing in the

Section 2.0 write-up (Pages 2-1 through 2-54). (D-58)

Comment: Page 4-4, Lines 1-10: Delete these sentences since they are a repeat of the

sentences on Page 4-2 (Lines 21-30). (D-59)

Comment: Page 4-24, Line 25: Replace "limes" with "lines". (D-62)

Comment: Page 4-34, Line 20: Change "(NRC 2006a)" to "(NRC 1996a)" to accurately reflect

the reference source in the Section 2.3 references in the Draft SEIS. (D-63)

Comment: Page 4-35, Line 26: Replace "Minetta" with "Minetto". (D-64)

Comment: Page 4-46, Line 36: Add "Endangered Species Act of 1972" to the references listed

in Section 4.10 of the Draft SEIS to be consistent with other listed federal Acts shown in

previous sections. (D-65)

Comment: Page 4-50, Line 7: Change "(NRC 1996)" to "(NRC 1996a)" to accurately reflect the

reference source in the Section 4.10 references of the Draft SEIS. (D-66)

Comment: Page 4-51, Line 4: The "(Entergy 2006b)" reference appears to be incorrect for this

statement. However, the "(Entergy 2006a)" reference would appear to be more appropriate for

this statement. (D-67)

Comment: Page 4-52, Line 4: Add "20" between "additional" and "year" and add an "s" to

"year". (D-68)

Comment: Page 4-55, Lines 26-28: There is no "(Fox 2006)" reference listing in the Section 4.0

write-up (Pages 4-1 through 4-54). (D-69)

Comment: Page 4-57, Lines 11-13: There is no "(Oswego County 2006)" reference listing in the

Section 4.0 write-up (Pages 4-1 through 4-54). (D-70)

Comment: Page 4-58, Lines 30-32: There is no "(EPA 2004)" reference listing in the Section

4.0 write-up (Pages 4-1 through 4-54). (D-71)

Comment: Page 4-59, Lines 15-17: There is no "(NRC 1996b)" reference listing in the Section

4.0 write-up (Pages 4-1 through 4-54). (D-72)

Comment: Page 4-60, Lines 15-17: There is no "(Wilke 2006)" reference listing in the Section

4.0 write-up (Pages 4-1 through 4-54). (D-73)

January 2008 A-35 NUREG-1437, Supplement 31 I
Appendix A

Comment: Page 5-1, Line 5: There is no "(NRC 1996)" listing in the Section 5.3 references of

the Draft SEIS. (D-74)

Comment: Page 5-1, Line 5: There is no "(NRC 1999)" listing in the Section 5.3 references of

the Draft SEIS. (D-75)

Comment: Page 5-2, Line 16: Add "10 CFR Part 50" and "10 CFR Part 100" to the references

listed in Section 5.3 of the Draft SEIS to be consistent with other listed federal regulations

shown in previous sections. (D-76)

Comment: Page 5-2, Line 37: Add "10 CFR Part 51" to the references listed in Section 5.3 of

the Draft SEIS to be consistent with other listed federal regulations shown in previous sections.

(D-77)

Comment: Page 5-3, Line 28: There is no "(NRC 1996)" listing in the Section 5.3 references of

the Draft SEIS. Delete "(NRC 1996)" {Footnote on page 5-1 states that all GEIS references are

to the GEIS and Addendum 1}. (D-78)

Comment: Pages 5-3 through 5-4, Lines 31-33 and 1: Recommend deleting this sentence since

it is captured in the sentence shown on Page 5-4 (Lines 1-5). (D-79)

Comment: Page 5-6, Line 21: Change "(NPA 1991)" to "(NYPA 1991)" to accurately reflect the

reference source in the Section 5.3 references of the Draft SEIS. (D-80)

Comment: Page 5-6, Line 22: Change "(NPA 1996)" to "(NYPA 1996)" to accurately reflect the

reference source in the Section 5.3 references of the Draft SEIS. (D-81)

Comment: Page 5-7: In Table 5-3 line item for station blackout, change the exponent for "1.27 x

10-6" to superscript "1.27 x 10-6''. (D-82)

Comment: Page 8-32, Line 1: Insert "However," prior to "the impact". (D-83)

Comment: Page 8-42, Line 9: There is no "(NRC 2006)" listing in the Section 8.4 references of

the Draft SEIS. (D-86)

Comment: Page 8-43, Line 25: Insert "what is" between "than" and "needed". (D-87)

Comment: Page 8-53, Lines 8-10: There is no "(EPA 2000a)" reference listing in the Section

8.0 write up (Pages 8-1 through 8-51). (D-89)

Comment: Page 8-53, Lines 17-18: There is no "(NRC 1988)" reference listing in the Section

8.0 write up (Pages 8-1 through 8-51). (D-90)

I NUREG-1437, Supplement 31 A-36 January 2008
Appendix A

Comment: Page 9-6, Line 24' Change "closed-cycle" to "on(ce-through" since JAFNPP is

equipped with a once-through cooling system. (D-91)

Comment: Page E-3: For Table E-2, change footnote (a) to read "Permit has been

administratively continued under the New York State Administrative Procedures Act; therefore,

JAFNPP continues to operate under the existing permit while NYSDEC completes the SPDES

permit renewal." (D-95)

Comment: Page G-1, Line 14: Change "(NPA 1991)" to "(NYPA 1991)" to accurately reflect the

reference source in the Section G.8 references of the Draft SEIS. (D-96)

Comment: Page G-1, Line 14: Change "(NPA 1996)" to "(NYPA 1996)" to accurately reflect the

reference source in the Section G.8 references of the Draft SEIS. (D-97)

Comment: Page G-2, Line 7: Change "(NPA 1991)" to "(NYPA 1991)". (D-98)

Comment: Page G-2, Line 18: Change the reference for the breakdown of CDF by initiating

event provided in Table G-1 to Entergy 2007, rather than Entergy 2006a. The information

presented in Entergy 2006a contained values prior to combining and subsuming cutsets. In

response to RAI 5.1, values after combining and subsuming cutsets were presented in Entergy

2007. (D-99)

Comment: Page G-3, Line 1: Change "(MAAP 4.04)" to "(MAAP 4.0.4)": (D-100)

Comment: Page G-3: In Table G-1 line item for station blackout, change the exponent for

"1.27 x 10-6" to superscript "1.27 x 106",. (D-101)

Comment: Page G-4, Lines 11-12: Change "(NPA 1991)" to "(NYPA 1991)" to accurately reflect

the reference source in the Section G.8 references of the Draft SEIS. (D-102)

Comment: Page G-4, Line 12: Change "(NPA 1996)" to "(NYPA 1996)" to accurately reflect the

reference source in the Section G.8 references of the Draft SEIS. (D-103)

Comment: Page G-7, Line 7: Change "(NPA 1991)" to "(NYPA 1991)" to accurately reflect the

reference source in the Section G.8 references of the Draft SEIS. (D-104)

Comment: Page G-7, Line 7: Change "(NPA 1996)" to "(NYPA 1996)". (D-105)

Comment: Page G-7, Line 8: Change "(NRC 19961b)" to "(NRC 1991 b)" to correct a

typographical error. (D-106)

Comment: Page G-7: In last item in Table G-3, delete "for instrument, master and slave trip

units" leaving only "Updated initiating event frequencies and component failure data." (D-107)

January 2008 A-37 NUREG-1437, Supplement 31 I
Appendix A

Comment: Page G-8, Line 1: Change "(NPA 1996)" to "(NYPA 1996)" to accurately reflect the

reference source in the Section G.8 references of the Draft SEIS. (D-108)

Comment: Page G-8, Line 2: Change "(NPA 1991)" to "(NYPA 1991)" to accurately reflect the

reference source in the Section G.8 references of the Draft SEIS. (D-109)

Comment: Page G-1 0, Line 15: Change "(NPA 1996)" to "(NYPA 1996)" to accurately reflect

the reference source in the Section G.8 references of the Draft SEIS. (D-110)

Comment: Page G-1 1, Lines 30-31: Change "(MAAP 4.04)" to "(MAAP 4.0.4)". (D-111)

Comment: Page G-12, Line 17: Draft SEIS states 4.66 percent enrichment, but reference

document (Entergy 2007) states that 4.65 percent enrichment was assumed. (D-112)

Comment: Page G-1 5, Line 37: Change "(NRC 2006a)" to "(NRC 2006)" only to accurately

reflect the reference source in the Section G.8 references of the Draft SEIS. (D-113)

Comment: Page G-1 8, Line 27: Change "Table G-4" to "Table G-5". (D-114)

Comment: Page G-27: Population dose reduction for SAMA 29 has a stray mark prior to the

value. (D-115)

Comment: Page G-42, Lines 29-30: Add "10 CFR Part 54" to the references listed in'Section

G.8 of the Draft SEIS to be consistent with other listed federal regulations shown in previous

sections. (D-116)

Comment: Page G-43, Lines 19-20: There is no "(NYPA 2004)" reference listing in the

Appendix G write-up (Pages G-1 through G-42). (D-117)

Comment: Page G-43, Line 30: Change "1991" to "1991a" to be consistent with how the

reference is listed in the Section G.2.2 write-up (Page G-10) of the Draft SEIS. (D-118)

Response: The comments are noted, and wording in the identified sections of the SEIS has

been changed in response to these comments.

I NUREG-1437, Supplement 31 A-38 January 2008
Appendix B

Contributors to the Supplement

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 supplement

was prepared by members of the Office of Nuclear Reactor Regulation with assistance from

other NRC organizations, Lawrence Livermore National Laboratory, and Pacific Northwest

National Laboratory.

Name Affiliation Function or Expertise

NUCLEAR REGULATORY COMMISSION

Rani L. Franovich Nuclear Reactor Regulation Branch Chief

Jessie M. Muir Nuclear Reactor Regulation Project Manager, Nonradiological Waste

Samuel Hernandez Nuclear Reactor Regulation Backup Project Manager, Alternatives

Jeffrey Rikhoff Nuclear Reactor Regulation Socioeconomics, Cultural Resources, Environmental

Justice

Richard Emch New Reactors Radiation Protection

Stephen Klementowicz Nuclear Reactor Regulation Radiation Protection

Jennifer A. Davis Nuclear Reactor Regulation Cultural Resources

Scott Werts(a) Nuclear Reactor Regulation Hydrology, Air, Alternatives

Michael Masnik New Reactors Aquatic and Terrestrial Ecology

Sarah Lopas Nuclear Reactor Regulation Aquatic Ecology, Hydrology, Water Use and Quality

Evan Keto(a) Nuclear Reactor Regulation Terrestrial Ecology, Threatened and Endangered Species

Briana Balsam Nuclear Reactor Regulation Terrestrial Ecology, Threatened and Endangered Species

Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation Alternatives

LAWRENCE LIVERMORE NATIONAL LABORATORY(b) I

Drucu McLouwe.

Lily Baldwin(a)

Hank Khan

Crystal Quinly

Diana Burke

Nancy Woods

Lisa Crawford

January 2008

I edarn LeadUe

Deputy Team Leader, Hydrology, Water Use and Quality

Health Physics

Land Use

Lead Editor

Editor

Socioeconomics, Alternatives

B-1 NUREG-1437, Supplement 31
Appendix B

Name

Frank Gouveia

Affiliation Function or Expertise

Meteorology, Air Quality

PACIFIC NORTHWEST NATIONAL LABORATORY (c)

Steve Short Severe Accident Mitigation Alternatives

Bruce Schmitt Severe Accident Mitigation Alternatives

Fred Leverenz Severe Accident Mitigation Alternatives

(a) Employee is no longer employed with the NRC or LLNL.

(b) Lawrence Livermore National Laboratory is operated for the U.S. Department of Energy by Lawrence Livermore

National Security, LLC.

(c) Pacific Northwest National Laboratory is operated for the U.S. Department of Energy by Battelle.

I NUREG-1437, Supplement 31 B-2 January 2008
Appendix C

Chronology of NRC Staff Environmental Review Correspondence

Appendix C:

Chronology of NRC Staff Environmental Review Correspondence

This appendix contains a chronological listing of correspondence between the U.S. Nuclear

Regulatory Commission (NRC) and Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear

Operations, Inc. (Entergy) and other correspondence related to the NRC staff's environmental

review, under Title 10 of the Code of Federal Regulations, Part 51 (10 CFR Part 51), of the

Entergy application for renewal of the James A. FitzPatrick Nuclear Power Plant (JAFNPP)

operating license. All documents, with the exception of those containing proprietary information,

are publicly available at 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://adamswebsearch.nrc.gov/dologin.htm. The ADAMS

accession numbers for each document are included below. Persons who do not have access to

ADAMS, or who encounter problems in accessing the documents located in ADAMS, should

contact the NRC's PDR reference staff by telephone at 1-800-397-4209 or 301-415-4737, or by

e-mail at pdr@nrc.gov.

July 27, 2006

July 31, 2006

July 31, 2006

August 4, 2006

August 7, 2006

August 11, 2006

Summary of meeting held on June 26, 2006, between NRC and

Entergy to discuss submittal of JAFNPP license renewal application.

(Accession No. ML062090176)

Letter from P. Dietrich, Entergy, submitting the application for renewal of

the operating license for the JAFNPP. (Accession No. ML062160491)

James A. FitzPatrick Nuclear Power Plant - License Renewal

Application, Appendix E: Applicant's Environmental Report, Operating

License Renewal Stage. (Accession No. ML0621 60557)

NRC press release announcing the availability of the license renewal

application for JAFNPP. (Accession No. ML062160240)

Letter to P. Dietrich, Entergy, Receipt and Availability of the License

Renewal Application for JAFNPP. (Accession No. ML062190106)

Federal Register Notice of Receipt and Availability of Application for

Renewal of JAFNPP (Operating License No. DPR-59) for an Additional

20-Year Period (71 FR 55032). (Accession No. ML071000081)

January 2008 C-1 NUREG-1437, Supplement 31
Appendix C

September 7, 2006

September 7, 2006

September 14, 2006

September 15, 2006

September 15, 2006

September 15, 2006

September 15, 2006

September 15, 2006

September 15, 2006

NUREG-1437, Supplement

Letter to M. Bennett, Penfield Library, regarding the maintenance of

reference material at the SUNY Oswego-Penfield Library, related to

the JAFNPP license renewal application. (Accession No.

ML062500286)

Letter to C. Ferlito, Oswego Public Library, regarding the maintenance

of reference material at the Oswego Public Library, related to the

JAFNPP license renewal application. (Accession No. ML062500247)

Determination of Acceptability and Sufficiency for Docketing, Proposed

Review Schedule, and Opportunity for a Hearing Regarding the

Application from Entergy Nuclear Operations, Inc., for the renewal of

the operating license for JAFNPP. (Accession No. ML062570127)

Letter to D. L. Kilma, Advisory Council on Historic Preservation

(ACHP), the JAFNPP License Renewal Application Review.

(Accession No. ML062480229)

Letter to B. Castro, New York State Historic Preservation Office,

Request for Comments Concerning the JAFNPP License Renewal

Application Review. (Accession No. ML062480220)

Letter to L. Henry, Tuscarora Nation, Request for Comments

Concerning the JAFNPP License Renewal Application Review.

(Accession No. ML062480205)

Letter to W. Jacobs, Cayuga Nation, Request for Comments

Concerning the JAFNPP License Renewal Application Review.

(Accession No. ML062480069)

Letter to R. Halbritter, Oneida Indian Nation, Request for Comments

Concerning the JAFNPP License Renewal Application Review.

(Accession No. ML062480063)

Letter to I. Powless, Jr., Onondaga Indian Nation, Request for

Comments Concerning the JAFNPP License Renewal Application

Review. (Accession No. ML062480057)

31 C-2 January 2008
Appendix C

September 15, 2006

September 15, 2006

September 15, 2006

September 19, 2006

September 20, 2006

September 20, 2006

September 25, 2006

September 26, 2006

October 3, 2006

Letter to B. Snyder, Seneca Nation of Indians, Request for Comments

Concerning the JAFNPP License Renewal Application Review.

(Accession No. ML062480035)

Letter to J. Ransom, St. Regis Mohawk Tribe, Request for Comments

Concerning the JAFNPP License Renewal Application Review.

(Accession No. ML062480053)

Letter to R. Hill, Tonawanda Band of Senecans, Request for

Comments Concerning the JAFNPP License Renewal Application

Review. (Accession No. ML062480044)

Letter to M. Moriarty, U.S. Fish and Wildlife Service Northeast

Regional Office, Request for List of Protected Species Within the Area

Under.Evaluation for the JAFNPP License Renewal Application

Review. (Accession No. ML062630292)

Notice of Acceptance for Docketing of the Application, Notice of

Opportunity for Hearing and Notice of Intent To Prepare an

Environmental Impact Statement and Conduct Scoping Process for

Facility Operating License No. DPR-59 for an Additional 20-Year

Period, Entergy Nuclear Operations, Inc., James A. FitzPatrick Nuclear

Power Plant (71 FR 55032). (Accession No. ML071000085)

NRC press release announcing the opportunity to request a hearing on

application to renew operating license for JAFNPP. (Accession No.

ML062630056)

Meeting Notice, Forthcoming Meeting to Discuss the License Renewal

Process and Environmental Scoping for JAFNPP License Renewal

Application Review. (Accession No. ML062680355)

Notice of Intent to Prepare an Environmental Impact Statement and

Conduct Scoping Process for License Renewal for JAFNPP.

(Accession No. ML062480235)

NRC press release announcing Public License Renewal Process and

Environmental Scoping Meeting Associated with the Application to

Renew the Operating License for JAFNPP. (Accession No.

ML062760465)

January 2008 C-3 NUREG-1437, Supplement 31 1
Appendix C

October 3, 2006

October 30, 2006

November 7, 2006

November 7, 2006

November 13, 2006

November 14, 2006

November 27, 2006

November 29, 2006

November 30, 2006

December 6, 2006

Transcripts of the Proceedings of the JAFNPP Public Scoping

Meetings. (Accession Nos. ML063030195 [afternoon], ML063030209

[evening])

Summary of Public Environmental Scoping Meetings Related to the

Review of the JAFNPP License Renewal Application. (Accession No.

ML062980148)

Letter to K. Lynch, New York State Department of Environmental

Conservation (NYSDEC) Region 7, Request for List of State Protected

Species Within the Area Under Evaluation for the JAFNPP License

Renewal Application Review. (Accession, No. ML062960276)

Letter to P. Dietrich, Entergy, Request for Additional Information

Regarding the Review of the License Renewal Application for

JAFNPP. (Accession No. ML062850382)

Letter from J. Heath, General Council for the Onondaga Nation,

concerning the JAFNPP license renewal application. (Accession No.

ML063240283)

Letter from C. Hogan, NYSDEC, in response to request for comments

on the JANFPP License Renewal Environmental Report. (Accession

No. ML 063240331)

Letter to M. Kansler, Entergy, Environmental Site Audit Regarding the

JAFNPP License Renewal Application. (Accession No.

ML063250406)

Letter to M. Kansler, Entergy, Request for Additional Information

Regarding Severe Accident Mitigation Alternatives for JAFNPP.

(Accession No. ML063060257)

Letter from T. Seoane, NYDEC Natural Heritage Program, Report on

Rare or State-Listed Animals, Significant Natural Communities, and

Other Habitats in Regards to the JAFNPP License Renewal

Application Review. (Not publicly available)

Letter from P. Dietrich, Entergy, JAFNPP License Renewal

Application, Amendment 1. (Accession No. ML063480585)

NUREG-1437, Supplement 31 C-4 January 2008
Appendix C

December 6, 2006

December 7, 2006

January 8, 2007

January 26, 2007

January 29, 2007

March 2, 2007

March 7, 2007

May 21, 2007

May 21, 2007

June 8, 2007

June 8, 2007

JAFNPP License Renewal Application Amendment 1 Attachments.

(Accession No. ML063480596)

Letter from A. Wonderley, Oneida Indian Nation, in response to

JAFNPP Environmental Review of License Renewal Application.

(Accession No. ML063480314)

Letter to M. Kansler, Entergy, Environmental Project Manager and

Schedule Change for the License Renewal Environmental Review of

JAFNPP. (Accession No. ML063550121)

Summary of Site Audit Related to the Review of the License Renewal

Application for JAFNPP. (Accession No. ML070220055)

Letter from P. Dietrich, Entergy, License Renewal Application

Amendment 4 Concerning SAMA Request of Additional Information.

(Accession No. ML070370170)

Letter to M. Kansler, Entergy, Environmental Scoping Summary Report

(Accession No. ML070440393)

Letter to E. Alkiewicz, NYPA, Information Regarding Transmission Line

Corridor Inspection for the JAFNPP License Renewal Application

Review. (Accession No. ML070400200)

Letter to M. Moriarty, USFWS, regarding the Biological Assessment for

Proposed License Renewal of James A. FitzPatrick Nuclear Power

Plant. (Accession No. ML071160167)

Letter from E. Alkiewicz, NYPA, to R. Franovich, NRC, regarding

NYPA FitzPatrick-Edic Transmission Line. (Accession No.

ML071520215)

Letter to C. Ash, NYSHPO, from R. Franovich, NRC, regarding James

A. FitzPatrick Nuclear Power Plant License Renewal Application

Review (SHPO No. 06PR0982). (Accession No. ML071240271)

Letter to U.S. EPA, Notice of Availability of the Draft Site-Specific

Supplement 31 to the Generic Environmental Impact Statement for

January 2008 C-5 NUREG-1437, Supplement 31
Appendix C

June 8, 2007

June 15, 2007

June 15, 2007

June 21, 2007

July 10, 2007

July 12, 2007

July 23, 2007

August 1, 2007

License Renewal of Nuclear Plants Regarding the James A.

FitzPatrick Nuclear Power Plant. (Accession No. ML071240405)

Letter to M. Kansler, Entergy, from R. Franovich, NRC, Notice of

Availability of the Draft Plant-Specific Supplement 31 to the Generic

Environmental Impact Statemtn for License Renewal of Nuclear Plants

(GELS) regarding James A. FitzPatrick Nuclear Power Plant (TAC No.

MD2667). (Accession No. ML071240156)

Federal Register Entergy Nuclear FitzPatrick, LLC. And Entergy

Nuclear Operations, Inc.; James A FitzPatrick; Notice of Availability of

the Draft Supplement 31 to the Generic Environmental Impact

Statement for License Renewal of Nuclear Plants, and Public Meeting

for the License Renewal of James A. FitzPatrick (72 FR 32924).

(Accession No. ML073050300)

Federal Register Environmental Impact Statement Notice of Availability

(72 FR 33221). (Accession No. ML071780243)

Email Correspondence between R. Niver, USFWS, and J. Muir, NRC,

regarding the FitzPatrick Biological Assessment. (Accession No.

ML071780266)

NRC Press Release: NRC Issues Draft Environmental Report for

James A. FitzPatrick License Renewal Application, Announces August

01, 2007 Public Meetings. (Accession No. ML071910381)

Meeting Notice to Discuss the Draft Supplemental Environmental

Impact Statement for License Renewal of James A. FitzPatrick Nuclear

Power Plant. (Accession No. ML 071780266)

Email communication between E. Alkiewicz, NYPA, and J. Muir, NRC,

Responses to NYPA Vegetation Management Questions. (Accession

ML072120589)

Transcripts of the Proceedings of the JAFNPP Public Meetings

Regarding the Draft Supplemental EIS for FitzPatrick. (Accession No.

ML072260051 [afternoon], ML072260053 [evening])

NUREG-1437, Supplement 31 C-6 January 2008
Appendix C

August 1, 2007

August 20, 2007

August 20, 2007

September 10, 2007

November 15, 2007

Slides for JAFNPP Public Meetings Regarding the Draft Supplemental

EIS. (Accession No. ML072260023)

Summary of Public Meetings on the Draft Supplemental Environmental

Impact Statement Regarding the James A. FitzPatrick Nuclear Power

Plant License Renewal Review (TAC MD2667). (Accession No.

ML072270042)

Letter from J. Muir, NRC, to R. Niver, USFWS, Response to Request

for Additional Information Concerning the Biological Assessment for

James A. FitzPatrick Nuclear Power Plant License Renewal

Application Review. (Accession No. ML072110510).

Note to File: Summary of Teleconference with the New York State

Department of Environmental Conservation in Support of the NRC

Staff's Review of the James A. FitzPatrick Nuclear Power Plant

License Renewal. (Accession No. ML072480636)

Letter from D. Stilwell, USFWS, to R. Franovich, NRC, Response to

NRC's Biological Assessment for JAFNPP. (Accession No.

ML07320001 1).

January 2008 C-7 NUREG-1437, Supplement 31 I

Appendix D

Organizations Contacted

Appendix D:

Organizations Contacted

During the course of the U.S. Nuclear Regulatory Commission 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, Washington, DC

Cayuga Nation, Akron, New York

City of Oswego, Oswego, New York

County of Oswego, Oswego, New York

New York Department of State, Albany, New York

New York Power Authority, White Plains, New York

New York State Department of Environmental Conservation, Albany, New York

New York State Department of Health, Albany New York

New York State Energy Research and Development Authority, Albany, New York

New York State Historic Preservation Office, Waterford, New York

Onondaga Indian Nation, Nedrow, New York

Oneida Indian Nation, Verona, New York

Seneca Nation of Indians, Irving, New York

St. Regis Mohawk Tribe, Akwesasne, New York

Tonawanda Band of Senecans, Basom, New York

Town of Scriba, Scriba, New York

Tuscarora Indian Nation, Lewiston, New York

US Fish and Wildlife Service, Northeast Regional Office, Hadley, New York

January 2008 D-1 NUREG-1437, Supplement 31 I

Appendix E

Compliance Status and Consultation Correspondence

Appendix E:

Compliance Status and Consultation Correspondence

Consultation correspondence related to the evaluation of the application for renewal of the

operating license for James A. FitzPatrick Nuclear Power Plant (JAFNPP) is identified in

Table E-1. Copies of the consultation correspondence are included at the end of this appendix.

The licenses, permits, and other approvals obtained from Federal, State, regional, and local

authorities for JAFNPP, are listed in Table E-2.

Table E-1. Consultation Correspondence

Source Recipient Date of Letter

U.S. Nuclear Regulatory New York State Historic September 15, 2006

Commission (R. Franovich) Preservation Office (B. Castro)

U.S. Nuclear Regulatory Onondaga Indian Nation September 15, 2006

Commission (R. Franovich)(a) (I. Powless, Jr.)

U.S. Nuclear Regulatory U.S. Fish and Wildlife Service September 19, 2006

Commission (R. Franovich) Northeast Regional Office

(M. Moriarty)

U.S. Nuclear Regulatory New York State Department of November 7, 2006

Commission (R. Franovich) Environmental Conservation

(K. Lynch)

New York State Department of U.S. Nuclear Regulatory November 30, 2006

Environmental Conservation Commission (S. Hernandez)

Natural Heritage Program

(T. Seoane)(b)

U.S. Nuclear Regulatory U.S. Fish and Wildlife Service May 21, 2007

Commission (R. Franovich) Northeast Regional Office

(M. Moriarty)

U.S. Nuclear Regulatory U.S. Environmental Protection June 8, 2007

Commission (R. Franovich) Agency

U.S. Nuclear Regulatory New York State Historic June 8, 2007

Commission (R. Franovich) Preservation Office (C. Ash)

U.S. Fish and Wildlife Service U.S. Nuclear Regulatory November 15, 2007

Northeast Regional Office Commission (R. Franovich)

(D. Stilwell)

(a) Similar letters were sent to other Native American Tribes listed in Appendix C.

(b) Not publicly available.

January 2008 E-1 NUREG-1 437, Supplement 31 1
z

m

G,)

Cn

CD

CD

m

Table &.2. Federal, State, Local, and Regional Licenses, Pernits, and

Other Approvals for the James A. FitzPatnck Nuclear Power Plant (JAFNPP)

Agency

RIC

Auttwcvityý Requirement

A~,ink Energy Adct Lt.eiso to->044

IOCFR 50

.49 C FR 107; SUDpa IG Hazdýxs. Mdle~a

C erd Cai# o4 Reg,~1aL

Numbor

DOT 06 1 307550662p

m

K)

N.YSODEC 6 NYCIRR Part 201

NYSDEC f, NYCR R Part 3 72

N.VStEC 6 NYCHRRPae1675

N Y SMC 6 NYCRR Pw596.

NYSOEC 6 NVfR Pati 760

NYSOEC 6 NYCRR Pat 612

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Table E-2.. (cont.)

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llPru~ta;bi aat r~i~ i.t~~ 11,01t~N" Yuwk Sliste AJtirpn isive Pmtedu,-s Act fliettlate JA.FNPP ~c:raimsei uC porate &.~now th- o*asfýn) pcarri9 wmimt

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5.x

in
Appendix E

September 15. 2006

Ms, BemadetteCastro. SHPO

Parks. Recreation & Historc Preservation

Agency Building ,1

Empire State. Plaza

Albany. NY 12238

SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT LICENSE RENEWAL

APPLICATION REVIEW .SHPO NO. 06PR0982'i

Dear Ms Castro

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing an applticaon to renew the

operating license for James A. FitzPatnck Nuclear Power.Plani (JAFNPP'i. which is located on

Lake Ontano in Osweqo County. approximately seven miles northeast of the City of.Oswego,

New York JAFNPP ;soperated by. Entergy Nucjear Operations. Inc. (Ente-gyi. The application

for renewal was.subritted by Entergy ma letter dated July 31. 2006. pursuant to Title 10 of the

Code of Federal Regtaiticrs Part 54 (10 CFR Part 54).

The NRC has established tmat, as part of the staff's teview of.ary.nucear power plant license

renewal action. a sne.•pocific Supplemental Environrmental Impact Statement iSEIS;.to its

,'Generic Environmental Impact Statemient for License Renewal of Nuclear Plants.'

NUREG-1437. witl be prepared under te provisions of 10 CFR Parl 51 me NRC regulation

that implements the National Environmental Policy Act of 1969 iNEPA). .In accordance with

36 CFR 800-8E(c) the-SEIS will include analysesof potentialhimpacts to nistonc: and.cultural

resources,

In the context. of the National Historic Proservatron Act of 196,. as amended, the NRC staff 'has

detarmined that the area of potential effect (APE) for a license renewal action is the area at the

power plant site and its immediate environs that may be impacted by post-license renewal

landdisturting oWerations or projected refurbishment aclivitks associated with the proposed

action. The APE may extend, beyond the immediate environs in those instances where postlicense renewal land-disturbiag opterations or pro cled refurbishmentact"vities specifically.

related to license. renewal may potentially have an effect on known or proposed historic sites.

This determination is made irrespective of ownership or control of the lands.of interest,

On October 12. 2006. the NRC will conduct two public NEPA scoping meetings at me Town

Municipal Building. 42Cireamery ROad..Oswego. New Yor_ 13126. You and your staff are

invited to attend. Your office will receve a; copy of tme draft SEIS along wth a request for

comments: The staff expectsto publish the draft SEISin August 2007.

I NUREG-1437, Supplement 31 E74 January.2008
Appendix E

B: Castro 2-

If you have any, questions or require addftional information, please contact Mr. Samuelý

Herandez. Environmental Project Manager! by phono: at 30 1--4 154049 or by e-rmail at

Sincerely

IRA/

Rani.Franovichi Branch Chief

Environmental Branch B

ý,Diwshon of Licenso Renewal

Officu of Nuclear Ruactoi Regulation

Docket No. 50-333

cc. See next page

.January2008 :E-5 NUREG-1437, Supplement 31 I
Appendix E

September 15. 2006

The Honorable Irving Powless. Jr. Chief

Onondaga Indian Naton

Box 319B

Nedrow, NY13120

-SUBJECT: REQUEST FOR COMMENTS CONCERNING THE JAMES Ak FITZPATRICK

NUCLEAR POWER-PLANT LICENSE RENEWAL APPLICATION REVIEW

DearChief Powtess:

The U.S Nuclear :Regulatory. Commission t'NRCt is seeking input for its environmental review

of an application from Entergy Nuclear Operations. Inc.. (Entergy.) for thererfwal of the

operating license for the James A.. FitzPatrick Nuclear Power Plant jJAFNPP:), located on Lake

Ontano in Oswego.Counly. aeproximately seven miles northeast of the city ofOswego. New.

York.. JAFNPP is in close prrxnmiTy to lands that may be of intetest'to the Onondaga Indian

Nation. As descrnbed Delow, th.e NRC's process incdudes an opportunity for public and intergovernmental participation in the environmental review. We want to ensure that you are aware

of our efforts and, pursuant, to Tifle 10 of the Code.ofFederaf Roguaon'orls Pail 51.28(bi

110 CFR 51-281b)). the NRC nvites the-Onondaga.lndroan Nation to provide input to the scoping

process relatingto the NRC's ,•nvironmerntat review-of the application In additions as:o'uthned

in 36 CFR 8,008fc),.the- NRC plans to courd~nate:cunotiance with Section 106 of theNational

Histo-rc Preservation Act o 1966 through the requirements of the National Environmental Policy

Act of 1969

Under NRC regulations the original oerating licensefor a nuclear power plant is issued for up

to 40 years. The license may be renewed forup to an addilionaf 20.years if NRC requirements

are met. The current operating lcense for JAFNPP willoxpire in October 17, 2014. Entergy

submitted its application for renewal of the JAFNPP operating license in a letter dated

July 31. 2006:

The NRC is gathering information for a JAFNPP site-s"ecific supplement to its "Generic;

Environmental Impact Statement for License Renewal of. Nuclear Plants' (GEIS).

NUREG-1437 The suppiement Will contain the results of theareview of the environmental

impacts on the area surrounding the JAFNPP site that are related to terrestrial ecology. aquatic

ecology, hydrology, cultural resources, andsocioeconomic issues.lamong others) and will

contain a recommendation regarding the environmental acceptabiliry of the license renewal

acton. Enclosed foryour information is a map showing the location of Ihe JAFNPP site

NUREG-1437, Supplement 31J .E-6 January 2008
Appendix E

I. Powless -2-

The NRC w*l1 hold two public scoping meetings for the JAFNPP license renewal supplement to

the GElS on October '2. 2006. at the Town .Municipal Building. 42 Creamery Road. Oswego.

New York 13126. There wifl be two sessions to accommodate irnterested parbes. Thefirst

session will convene. 5t, 1 30 p.m, and will-continue until 4.30 p. .m.,as necessary. The second.

session will convene:at 7.00 p.m . with a repeat of. the overview portions of the meeting, and-will

'continue until 10_00 om.. as nucessary, Additionally thu NRC stafftwill host.informal

discussions one hour before the stan of each-session. To be-considered, comments must be

provided. either at the transcp-ed Public-.me•qetings or.4n writing. No for rmal comments on the

-pro-posed scope of the supplement to the GElS wifi be accepted during rifirmnal discussions

The liconso•enewal application ILRA) is publicly available at the NRC Public-Document Room

.(PDR). located at One While Flint North:. 11555 Rockville Pike. Rockvinle. Maryand. 20852..or

from the NRC's Agencywido Documents Access and-Management System IADAMS)- The.

ADAMS-Public Electronic Reading Room is accessibeat , ..

dolootn.htm- The:accession number for the LRA is ML062160557. Persons who do not have.

access to ADAMS. orwho encounter problems in accessing the docum ents. located in ADAMS,

should contact the NRC:s PDR reference staff by telephone at 1-800-397-4209, or

301 -415-4737-or by e-mail at.adrdmriý_o.

TheJAFNPP LRA is also available on the internel -at 1.i,.

"l,., -, in addition, the followingpublic libranes have

agreed to make the LRA available for public inspoction Penfield Library SUNY. 7060 State

Route 104. Osweoo. New York 1.3126ý and Owego Pubfl L& , 140-142 EnoSecmn

beet. Cewego. Now Yo* 13128.

The GElS which documents the NRC's'assessment of .Me scope and impact of environmental

effects that would be associated with license renewal at any nuclear power plant site, can also

be found on the NRC's website or at the NRC'sPDR.

Please submiJt any comments that the Onondaga Indian.Nation may have to offer on the scope

of tie environmental review by November 14. 2006. Written comments should be submitted by

mail to the Chief, Rules and Directives Branch. Division of Administrativa Services. Mail Stop

T-6D59.:US Nuclear Regulatory Commission, Washington D.C. 20555-0001 Electronic

comments maybe submitted to'the NRC by. e-mail atzFiLP71rcqEiri•_"E I At the

conclusion of the- scuping process tho NRC staff wfli prepare a summary of the significant

issues den•ified and the conclusions freached. and na-ld.copy :,oyou.

The staff expects to publisn the draft supplerme.nt to ;he GElS-in August.2007. Thu NRC will

-hold anotler sfet of public netinosin site Si v;icinity to sohct.commentswon the draft. A copy

of the draft supplemental environmental -impact statemen i:(SEIS) will be senz-to you for your

January 2008 E-7 NUREG-1437, Supplement 31 1
Appendix E

1. Powless .3.

review and comment. After consideration of public comments, received.on the draft, the NRC wtil

pfelpare a. final SEIS, The issuance-of a final SEIS for JAFNPP is planned for April 2008. If you need

additional information regarding the environmenial:review procoss. please contact: Mf,: Samuel

Hemandez. Environmwe.ntal Project Manager; at 3014 15-4049 or by-e-mail at -nkwl'onrc: t}ov.

Sincerely.

IRA/

Ram L Fiano0itch. Brancvi Chief

Environmental BrancI. B

Division of License>Rfnevnwai

Office of Nuclear Reactor Regulation

Docket No 50.333

Enclosure

JAFNPP Location Map

cc wencl Seenext page

I NUREG-1437, Supplement 31 E-8 .January 2008
Appendix E

I

'N

L~ke Joffe

FJJAFNPPI IWD rson

Lew1S

\. Wayno Onondaga

S. ca ayugs Ontario

Or eida

all

Enclosure

.January 2008 E-9 JNUREG-1437, Supplement 31 I
Appendix E

September 19, 2006

Marvin Moriarty

Nornheast Regional Office

U.S. Fish and Widlife Service.

300 Westgate Center Drivei.

Hadley. MA 01035-9589

SUBJECT: REOUEST FOR LIST OF PROTECTED SPECIES WITHIN THE AREA UNDER

EVALUATION FOR THE JAMES A. FITZPATRICK NUCLEAR POWER PLANT

LICENSE RENEWAL APPLICATION REVIEW

Dear Mr. Moriarty.

The U S Nuclear ReOuiatory Commission iNRC, is reviewing an a opkation Submitted by

Entergy Nuclear Opefathons. Inc. ,Entergy) for the renew,^alof Ithe ooerating license for James A.

Fitzpatrick Nuciear Power Plant (JAFNPP, JAFNPP is locatel on Lake Ontario in Oswego

County. approximatvjy s5,,erl miles northeasi of trie City of Oswego: New Yonk (Latitude 43.52 N.

Longitude 76 39 WIN. As part of !,ht ru-,iew of the license renewa' application iLRAY thie NRC is.

preparing a.SUpplemental Environmental Imoact.ScateruniSEiS)under the provisions of Title

10 of the C4,de cýf'feacra' Re'gutatio,'s Part S1 110 CFR Part 51,1 the NRC regulations that

implements the Natona; Environm.enail Policy Act (NEPAi of 1969 The SEIS includes an

analysis of pemtnent enVironmentaý issues, .including endangered or threatenea species and

impacts to fish and wildlife This.leter ts being submitted undre the p rovisions of the

Endangered Species Act of 19g73, as amended. and the Frsh and Wildlife ,Coortlination Act of

1934. as amended.

Entergy has stated that if a renewed license is granted. it has no plans to alter current

operations over the license renewal period', and that JAFNPP would use existing plant facilities

and transmission lines and would not require additional construction or disturbance .of new

areas. The JAFNPP site covers approximately 702 acres, of which approximately 21 acres is

industrial. The area surrounding JAFNPP is largely forested andrural charactenzed by rolling

terrain nsing gently up from the take.

JAFNPP uses a once throfoug open-cycle cooling.system w.th an intake and discharge on Lake

Ontario The shoe..faciný intake is located approximatciy.90.0 feet offshore. Waler coming

into the intake passes through trash racks and traveling .water screens JAFNPP operates a

fish'deterrence system installed at he off shore intake. structure from April to Octoberiof each

year as relutred by their New York SPDES Permit..

The discharge water ýs returned to the lake through a dscsharge tunnel and diffuser system

The discharge strucutue .is iuatod approximately 1.4,01 feet off shore. The transmission lines in

the scope of NRCs envronrimcntal rcview for liconse reinewal are thIose that were originally

constructee for the specific purposeiof connecting the plant to 1me transmission system..

I NUREG-1437, Supplement 31 E-10 January 2008
Appendix E

M onarty -2-

A-singeg 345,kitovo.t ikV. transmission line was buit to connect JAFNPP to Mhe New York Power

Pool transmission grid, Thotine runs from the plant switchyard to the Edic Substation; located

in.Utica. New York. The transmission line nght-of-way is 400 feet wide although only 150 feet

were cleared for a total of ',273 acres The corridor passes through land that is primarily pine

forest and swamp forest. There is also a short 345-kV transmission line from JAFNPP, and the

Nine Mge Point Nuclear Station It runs 4.900 feet :from the plants switchyard to the National

Grid Scriba Substation. In addition to he 345-kV lines. offsite power is provided to JAFNPP by

two singte circuit I15-kVtransmission !ines connected to the plants 1 15-kV bus.

To support the SEIS preparation process and to ensure compliance with Secton 7 of the

Endangered Species Act.thu NRC requests informaucon on Federally listed, proposed. and

candidate species, and cribcal habitat that may be in the vicinity of JAFNPP and its associated

tiansmission line rignt-of-way. In addition. please provide any information you consider

appropriate under the provisions of the Fish and Wildlife Coordination Act.

We plan to hold two public NEPA scoping meetings at 1.30 p.m.,and.7:00p.m. on October 12.

2006. at the Scnba Town Municipal Building, 42 Creamery Road; Oswego, Now. York, 1,3126.

On December 04. 2006, we plan to conduct a site audit at the JAFNPP facility., You and your

staff are invited toattend both. public meetings and the site audit. Your office will receive a copy

of the drafl'SEIS along w.tdh a request for comments. The anticipated publication date for the

draft SEIS is August 2007

If you have any questions concerning the NRC staff review of the ficense renewal application.

please contact M,• 'Samuel Hemnandez. Environmenta, Project Manager at 301-415-4049 or by

.-Mail at

Sincerely.

IRA/

Rani Franovich. Branch Chief

Environmental Branch 8

Drviisyon of.License Renewal

OffIce of Nuclear Reactor Regulaeon

Docket No. 50-333

Enclosures:

1- JAFNPP LocationMap

2. Transmission Lines Map

cc wienclsi See next page

January 2008 E-1 1 NUREG-1437, Supplement 31 I
Appendix E

Enclosure 1

NUREG-1437, Supplement 31 E--12 January'2008
Appendix E

January 2008 E-1 3 NUREG-1437, Supplement 31 I
Appendix E

November 7. 2006

Kenneth P.Lynch

Region 7 Office:

New York State Department of Environmental Conservaio.n

615 Erie Boulevard West

Syracuse, NY 13204-2400

SUBJECT: REQUEST FOR LIST OF STATE PROTECTED SPECIES WITHIN THE AREA,

UNDER EVALUATION FOR THE JAMES AX FITZPATRICK NUCLEAR POWER,

PLANT LICENSE RENEWAL APPLICATION REVIEW::

Dear Mr. Lynch:

The U.S- Nuclear Regulatory Commission (NRC) is reviewing an application submitted by

Entergy Nuclear Operations. Inc. (Entergy). for the renewal ofthe operating license for James

A. FitzoatrJck Nuclear Power:Plant (JAFNPP). JAFNPP is located on Lake Ontario in: Oswego

County.::approximately seven miles northeast of the City of Oswego. New York (Latitude 43.52 N.

Longitude 76.39 W). As part of, te review of the license renewat application (LRA). the NRC is

pIeparing a Supplemental Environmental Impact Statement ISEIS) under the provisions of

Title .10 of the: Code Of FodoraiRegulations Part 51, (10 CFR Part 51).,the NRC regulation that

implements the National:Environmental Policy Act (NEPA) of 1969.. The SEIS includes an

analysis of pertinentenvironmental issues, including endangered or threatened species and

impacts to fish and wildlife.

Entergy has slated that if a renewed license is granted. it has no plansto alter current

operations over the license renewal period; and that JAFNPP would use'existing plant facilities.

and transmission lines and would not require additional construction or disturbance of new

areas. The JAFNPP site covers approximately 702 acres, of which approximatety21acresis

industrial The area surrounding JAFNPP is largely forested and rurali, characterized by. rolling

terrain rising gently up from the lake..

JAFNPP uses a once-through open-cycte cooling system with intake and discharge structures

,on:Lake Ontario. The shore-facing intake is located approximately 900 feet offshore. Water,

coming into the intake passes through trash racks and-traveling water screens. JAFNPP

operates a fish deterrence system installed at the offshore intake structure from April to

October of each year as required by their New York SPDES permit.

The discharge water is returnedlto the lake through a discharge tunnel and diffuser system. .

The discharge structure is located approxi-mately 1:.400 feet offshore. The transmission lines in

the scope of NRC's environmental review for license renewal are those that were originally

constructed for the-specific purpose ofconnecting the plant to the transmission system.

I . NUREG-1437, Supplement.31 E-1 4 January 2008
Appendix E

S -2-

A single 345-kilovolt (kV) transmission line was bult to connect JAFNPP to the New.YoVk Power

Pool transmission grid.. The line runs from the plant switchyard to the Edic Substation located

in. utLca. New York. The transmission line'right-of-way is 400 feet wide. although onty.150feet were cleared for a total of 1.273 acres, The corridor passes through land that is primarily pine.

forest and swamp forest in Oswego and Oneida Counties. There is also a short 345-kV

transmission line from JAFNPP and the Nine Mite Point Nuclear Station., It runs 4:900 feelt'from

the plant~s switchyard to the National Grid Scriba Substation in Oswego County. In addition to

the 345-kV lines, offsite power is provided toJAFNPP by two single circuit 11 5-kV transmission.

lines connected to the plant's 1.15-kV bus.

To support the SEIS preparation process, the NRC requests information on state listed.

proposed, and candidate species and critical habitat that may be in the vicnity of JAFNPP and

its associated .transmission line right-of-ways. In addition. please provide any.information you

consider appropriate that might help. the NRC to evaluate impacts that extended operation of

JAFNPP for up toan additional 20 years under the-terms of a license renewal might impose on stae, listed species.

On December 04.-2006. we-plan to conduct a site audit at the, JAFNPP facility:,. You and your

staff are invited to at tend the site audit , Your office will receive a copy of the draft SEOS along

with.a request forucomments. The anticipated publication date forWthe draft SEIS is.August

2007.

If you have any questions :concerning the NRC staff review of the LRA., please contact

Mr. Samuel Hernandez. Environmental Project Manager at 301-415-4049 or via e-mail at

Sincerely.

IRNJ

Rani Franovich. Branch Chief

Environmental Branchý B

Division of License Renewal:

Office of Nuclear Reactor, Regulation

Docket No. 50-333

Enclosures:

1. JAFNPP Location Map

2. Transmission Lines Map

cc wencds : See next page

January 2008 IE-15 Janury 208 E1 5NUREG-1437, Supplement 31 I
Appendix E.

CANADA-J

Oneida

\ Wayne Onorndaga *,

Madison~

.:Seneca Cvg

Ontario

Endogure 1

NUREG-1437, Supplement 316 E-16 January.2008
Appendix E

POW we*

Enclosure 2

January 2008 E-17 7 NUREG-1437, Supplement:31
Appendix E

May 21. 2007

Marvin Moriarty

Northeast Regional Office

U.S., Fish and Wildlife Service

300 Westgate Center Drive

Hadley, MA 01035-9589

SUBJECT: BIOLOGICAL ASSESSMENT FOR-PROPOSED LICENSE RENEWAL OF

JAMES A- FITZPATRICK NUCLEAR POWER PLANT

Dear. Mi Moriarty.

The U.S. Nuclear Regulatory Commission (NRC) staff has prepared the enclosed biological

assessment (BA) (Enclosure 1) to evaluate whether the proposed renewal of the James A.

FilzPatrick Nuclear, Power Plant (JAFNPP) operating license for a period of an additional 20

years would have any adverse affect on listed species. The proposed action. license renewal.

is not a major construction activity. JAFNPP is located in Oswego County in northern New

York. on the southern shore of Lake Ontaro.

By letter dated September 19. 2006, the NRC requested that the U.S. Fish and'Wildlife (FWS)

provide a list of Federally endangered or threatened'species that may be in the vicinity of

JAFNPP and its associated transmission lines. The FWS faxed to the NRC a copy of the ltner

sent to Entergy dated May 19, 2006, which identified the Indiana bat (Myotis sodaJis, and bog

turtle (Cemmys mulVenb•rgi*) as the only Federally listed or proposed~threatened or

endangered species t.at are known to occur in the project area. It also directd Entefgy.t the

following website at thttaww tws gonorheisVlvfotassec hion7tn for'the most recent list

of Fedeoraly listed endangered or threatenedI species. The FWS web site listed three Federally

endangered, threatened.,.o candidate species aspotentially occurring, inOswego and Oneida

counties, which contain the JAFNPP site and transmission line rights-of-way: The species are

the bog turtle. Indiana bat, and the massasauga rattlesnake t Sistrurus cazIenaftus catenatus);

For completeness. the NRC has included those three terrestrial species reportee to occur in

Oswego and'Oneida counties as well as two additional Federally protected species that were

identified by the applicant as potentially 'occurring in the same area: the bald eagle *iwa/etus

leucocephakis) and piping plover ( Chafadrius melodus).

This:BA provides an evaluation of the-potential impact of renewing the JAFNPP operating

license for an additional:20 years ofoperation on the.five species., The.NRC has determined

that the proposed action would have no offect on the threatened piping plover. In addition.. the

NRC staff has determined the proposed action may affect. but is not likely to adversely affect.

the threatened bog turtte. the candidate species massasauga rattlesnake. 'the endangered

Indiana bat, or the threatened bald eagle,

NUREG-1437, Supplement 31 E-18 January 2008
Appendix E

M. Moriarty -2-

We are requesting your concurronce with our determination. In reaching our conclusion, the

NRC staff relied on information provided~by the applicant. literature research and interviews with

experts performed by NRC staff, and information from the FWS (iae.. including current listings

of speOies provided by the FWS New York Field Office).'

If you have any questions regarding this BA. please contact Jesse Muir. Environmental Project

Manager. at 301.415-0491 or by e-mail at nmmU t .nrcgo

Sincerely.

/RA/

Rani Franovich. Branch Chief

Environmental Branch B

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket No. 50-333

Enclosure:

As staled

cc w/encl. See next page

January2008 E-19. NUREG-1437, Supplement 31
Appendix E

June 8, 2007

US Environmental Protection Agency

Office of Federal ActMties

EIS Filing Section

Ariel Rios Buidding (South Oval Lobby), Room 7220

1200 Pennsylvania Avenue. NW

Washington. DC 20004

SUBJECT: NOTICE OF AVAILABILITY OF THE DRAFT SITE.SPECIFIC SUPPLEMENT 31

TO THE GENERIC ENVIRONMENTAL IMPACT STATEMENT FOR LICENSE

RENEWAL OF NUCLEAR PLANTS REGARDING.THEJAMES A.

FITZPATRICK NUCLEAR POWER PLANT

Dear, Sir or Madam:

The.following documents are enclosed for official filing with the U.S- Environmental Protection

Agency:.

1.. Five copies of the draflt Supplement 31 to NUREG-1437. 'Generc Environmental

Impact Statement for License Renewal of Nuclear Plants.' regarding te license

renewal of James A. FitzPatrick Nuclear Power Plant

2 Five copies:of the U:S. Nuclear Regulatory Commission'sdistribubon list for the

draft Supplement 31 to NUREG-1437.

Simultaneously with this.filing. a copyof the draft Supplement 31 is being maled to interested

Federal and State agencies, industry organizations, interest groups, and members of the public.

A copy. of this: document has alsobeen placed in the NRC's Agoncywide Documents Access

and Management System (ADAMS);. ADAMS is located on theNRC's Web site at

httn :hidamswebsearch nrc aovidolo•in-htm. The Accession Number for the draft Supplement

31 to the GElS is ML071420019. Please note that the public comment period for the draft

Supplement 31 toIne GElS ends on September 05.2007,

NUREG-1437, Supplement 31 E-20 January 2008
Appendix E

Environmental Protection Agency w2-

If further information is required, please contact the NRC Environmantal Project*Manager.

Ms. Jessie M. Muir at 301.415-0491 or by e-mail at jLnr7a.Arc..

Sincerely,

IRAI

Rani L. Franovich. Branch Chief

Environmental Branch 8

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket No., 50-333

Enclosures:

As stated

cc wfencW)s: See next page

January 2008 ' E-21 NUREG-1437, Supplement 31
Appendix E

June 8. 2007

Ms. Carol Ash, SHPO

Parks. Recreation & Historic Preservation

Agency Building #1

Empite State Plaza

Aloany, NY 12238

SUBJECT: JAMES A. FITZPATRICK NUCLEAR:POWER PLANT LICENSE RENEWAL

APPUCATION REVIEW ýSHPO NO. 06PR0982)

Deaf Ms. Ash:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing an application to renew the

operating license fof. James A. FitzPatnck Nuclear Power Plant (JAFNPP). whic• is located on

Lake Ontario in Oswego County. approximately seven miles northeast ofýthe City of Oswego.

New York. JAFNPP is operated byr Eritergy Nuclear Operations, Inc.. and owned by Enlergy

Nucer FitzPatrick, LLC. As part of its review of.the-proposed action, the NRC staff has

prepared a site-specific Supplemental.Erviromental Impact Statement(SEIS) toWits Generic

Environmental Impact Statement for License Renewal of Nuclear Plants' (GElS). NUREG.

1437. The SEIS includes analyses of relevant environmental issues.: including potential impacts

,to historic. archaeological and cultural propertles from extended operation and refurbishment

activities associated with license renewal. In. accordance with our letter to, you dated

September .'15. 2006 (Enclosure 1). a copy of the draft SESS is enrclosed. ,Pursuant to 36 CFR

800:8(c). we are requesting your comments on the draft supplement and on our preliminary

conclusions regarding historic properties.

As stated in our Septembier.15.2006letterc. the NRC staff has determined that the area of.

potential effect (APE) for a license renewal: action is the area at thepower: plant site and its

immediate environs that maybe :impactes by post-licenso renewal lan-•.disturDtng operations or

proected refurbishment activities associated wvlh the proposed action. The staff views the APE

for the JAFNPP license renewal as including the JAFNPP site and the immediate environs.

The NRC.staff has cor.ducted an environmental audit at the site and has reviewed historic and

archaeol•;ical records. 'The NRC staff also contacted seven Native American Tribes (Enclosue

2) identified as having potential Interest in the proposed undeftaklng. TheNRC received one

letaer in respnse. dated November, 13. 2006, from the General Coursel for the Onandaga.

Nation stating their opposition to the potential JAFNPP license renewal (Enclosure13).

In the ,ontext of the :National Environmental Policy, Act of 1969. under which the draft

environmental: impact statement was prepared, the NRC staffspreliminary determination, is that

the impact of license renewal on historic and archaeological re-sources is small, and additional

mitigation is not warranted. Under the provisions of the National Historic Preservation Act of

1966, the NRC staffs preliminaryd•etermination is that no historic properties will be affected by

the proposed action,

NUREG-1437, Supplement 31

E-22

January 2008
Appendix E

n2- -

Please note that the period for public comment expires.on September 5. 2007. If your office

requires.additional time, orlfthere are any other questions regarding this correspondence,

please have your representative contact the Enwoiunental Project Manager.

Ms. Jessie M. Muir. at301-41 50491 or j. c g" ."- 

Sincerely.

Ranm Franovich. Branch Chief

Environmental Branch B

Division of Ucense Renewal

Office of Nuclear Reactor Regulation

Docket No 50-333

Enclosuresi

As stated

cc: See next page

January.2008 E-23 NUREG-1437, Supplement 31
Appendix E

Un it c d States Depariment uof the Int..,rior

\Its. Ri~rnid 14raw 1sv4-h rar$bCni,

bivisiol of L icensc lzr:'ewW

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a~s .±ppIcar in &i re IN RC 31' t:, ahaiýIw''. vy2; Niticla 1 Hf z'ati,"r kI un

I~tsi ~II* ~L~ i ) -d~r 144 IL 1 icetsi 'a"1- Lc h. cio iWtil wat ý thi ). Cu 

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NUREG-1437, Supplement 31 E-24 January 2008
Appendix E

Wo ihc baid caglr' w.hich cojit'irct 6I rueex "-i'oti.'ijA~) 'Lmt'f the Bali' ýtril (wCi'c1 i v'lg Proirci.n.tunAc (54 "'d ' C 668 Vca 1.cied 

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January 2008. E-25 NUREG-1 437, Supplement 31
Appendix E

ForI~i ad itiona\ nfIL ')h :~l -j id w n .1 

Tivi' l~ L it kill ildul I-Lj~ Ro Ný k:, V. 1,j (jjv 7' .1934, 1

c.;,: NYPA. Whim ia N r 1 tA'n L. X i~ z/hwI~

NYSDEC.ý Syr~uac-x N\ VHi'nv Vnit.

COLubraNY

NUREG-1437, Supplement 31 E-26 January2008
Appendix F

GElS Environmental Issues Not Applicable

to James A. FitzPatrick Nuclear Power Plant

Appendix F:

GElS Environmental Issues Not Applicable

to James A. FitzPatrick Nuclear Power Plant

Table F-1 lists those environmental issues identified in the Generic Environmental Impact

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

(NRC 1996; 1999) and Title 10 of the Code of Federal Regulations, Part 51 (10 CFR Part 51),

Subpart A, Appendix B, Table B-i, that are not applicable to James A. FitzPatrick Nuclear

Power Plant (JAFNPP) because of plant or site characteristics.

Table F-I. GElS Environmental Issues Not Applicable

to James A. FitzPatrick Nuclear Power Plant

ISSUES-10 CFR Part 51, Subpart A, GElS

Appendix B, Table B-1 Category Sections Comment

SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Altered salinity gradients 1 4.2.1.2.2 The JAFNPP cooling system does

not discharge to an estuary.

Water-use conflicts (plants with cooling 2 4.3.2.1; The JAFNPP cooling system does

ponds or cooling towers using makeup 4.4.2.1 not use makeup water from a small

water from a small river with low flow) river with low flow.

AQUATIC ECOLOGY (FOR PLANTS WITH COOLING TOWER BASED HEAT DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in 1 4.3.3 This issue is related to heatearly life stages dissipation systems that are not

installed at JAFN PP.

Impingement of fish and shellfish 1 4.3.3 This issue is related to heatdissipation systems that are not

installed at JAFNPP.

Heat shock 1 4.3.3 This issue is related to heatdissipation systems that are not

installed at JAFNPP.

NUREG-1437, Supplement 31 F-1 January 2008
Appendix F

Table F-1. (continued)

ISSUES-10 CFR Part 51, Subpart A, GElS

Appendix B, Table B-1 Category Sections Comment

GROUNDWATER USE AND QUALITY

Impacts of refurbishment on 1 3.4.2 JAFNPP does not use groundwater.

groundwater use and quality

Groundwater use conflicts (potable and 1 4.8.1.1; JAFNPP does not use groundwater.

service water, and dewatering; plants 4.8.1.2

that use <100 gallons per minutes

[gpm])

Groundwater use conflicts (potable and 2 4.8.1.1; JAFNPP does not use groundwater.

service water, and dewatering; plants 4.8.2.1

that use >100 gpm)

Groundwater-use conflicts (plants 2 4.8.1.3; This issue is related to heatusing cooling towers withdrawing 4.4.2.1 dissipation systems that are not

makeup water from a small river) installed at JAFNPP.

Groundwater-use conflicts (Ranney 2 4.8.1.4 JAFNPP do not have or use Ranney

wells) wells.

Groundwater quality degradation 1 4.8.2.2 JAFNPP do not have or use Ranney

(Ranney wells) wells.

Groundwater quality degradation 1 4.8.2.1 JAFNPP does not use groundwater.

(saltwater intrusion)

Groundwater quality degradation 1 4.8.3 JAFNPP does not use groundwater.

(cooling ponds in salt marshes)

Groundwater quality degradation 2 4.8.3 JAFNPP does not use groundwater.

(cooling ponds at inland sites)

TERRESTRIAL RESOURCES

Cooling tower impacts on crops and 1 4.3.4 This issue is related to heatornamental vegetation dissipation systems that are not

installed at JAFNPP.

Cooling tower impacts on native plants 1 4.3.5.1 This issue is related to heatdissipation systems that are not

installed at JAFNPP.

Bird collisions with cooling towers 1 4.3.5.2 This issue is related to heatdissipation systems that are not

installed at JAFNPP.

Cooling pond impacts on terrestrial 1 4.4.4 This issue is related to heatresources dissipation systems that are not

installed at JAFNPP.

I NUREG-1437, Supplement 31 F-2 January 2008
Appendix F

Table F-I. (continued)

ISSUES-10 CFR Part 51, Subpart A, GElS

Appendix B, Table B-1 Category Sections Comment

HUMAN HEALTH

Microbial organisms (public health) 2 4.3.6 The JAFNPP cooling system does

(plants using lakes or canals, or not discharge to a small river.

cooling towers or cooling ponds that

discharge to a small river).

F.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."

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

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

U.S. 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, D.C.

January 2008 F-3 NUREG-1 437, Supplement 31 1

Appendix G

Severe Accident Mitigation Alternatives

Appendix G I

Appendix G:

Severe Accident Mitigation Alternatives

GA Introduction

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy) submitted an

assessment of severe accident mitigation alternatives (SAMAs) for the James A. FitzPatrick

Nuclear Power Plant (JAFNPP) as part of the environmental report (ER) (Entergy 2006a).

Supplemental information on the SAMA assessment was provided in Amendment 1 to the

license renewal application (Entergy 2006b). This assessment was based on the most recent

JAFNPP probabilistic safety assessment (PSA) available at that time, a plant-specific offsite

consequence analysis performed using the MELCOR Accident Consequence Code System 2

(MACCS2) computer code, and insights from the JAFNPP individual plant examination (IPE)

(NYPA 1991) and individual plant examination of external events (IPEEE) (NYPA 1996). In

identifying and evaluating potential SAMAs, Entergy considered SAMA that addressed the

major contributors to core damage frequency (CDF) and population dose at JAFNPP, as well as

SAMA candidates for other operating plants which have submitted license renewal applications.

Entergy identified 293 potential SAMA candidates. This list was reduced to 63 unique SAMA

candidates by eliminating SAMAs that: are not applicable to JAFNPP due to design differences,

have already been implemented at JAFNPP, or are similar in nature and could be combined

with another SAMA candidate. Entergy assessed the costs and benefits associated with each

of the potential SAMAs, and concluded in the ER that several of the candidate SAMAs

evaluated are potentially cost-beneficial.

Based on a review of the SAMA assessment, the U.S. Nuclear Regulatory Commission (NRC)

issued a request for additional information (RAI) to Entergy, by letter dated November 29, 2006

(NRC 2006). Key questions concerned: major plant and modeling changes incorporated within

each evolution of the PSA model; source term and release time category assumptions used in

the Level 2 analysis; justification for the multiplier used for external events; identification of

SAMAs to reduce the fire CDF; and further information on several specific candidate SAMAs

and low cost alternatives. Entergy submitted additional information by letters dated

December 6, 2006 (Entergy 2006b) and January 29, 2007 (Entergy 2007). In the responses,

Entergy provided: a summary of the major changes made to each PSA model version and

resultant changes to dominant risk contributors to CDF; a discussion of the Level 2 analysis and

the process for assigning severe accident source terms and binning release categories; a

revised assessment of the baseline SAMA benefits considering a multiplier to account for

external events exclusive of uncertainties; a discussion of measures that have been taken to

reduce risk in dominant fire zones and why the fire CDF for those zones cannot be further

reduced in a cost effective manner; and additional information regarding several specific

SAMAs. Entergy's responses addressed the NRC staff's concerns.

January 2008 G-1 NUREG-1 437, Supplement 31 I
Appendix G

G.2 Estimate of Risk for JAFNPP

Entergy's estimates of offsite risk at JAFNPP are summarized in Section G.2.1. The summary

is followed by the NRC staff's review of Entergy's risk estimates in Section G.2.2.

G.2.1 Entergy's Risk Estimates

Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA

analysis: (1) the JAFNPP Level 1 and 2 PSA model, which is an updated version of the IPE

(NYPA 1991), and (2) a supplemental analysis of offsite consequences and economic impacts

(essentially a Level 3 PSA model) developed specifically for the SAMA analysis. The SAMA

analysis is based on the most recent JAFNPP Level 1 and Level 2 PSA model available at the

time of the ER, referred to as the JAFNPP PSA (Revision 2, October 2004 model). The scope

of the JAFNPP PSA does not include external events.

The baseline CDF for the purpose of the SAMA evaluation is approximately 2.74 x 10-6 per

year. The CDF is based on the risk assessment for internally initiated events. Entergy did not

include the contribution from external events within the JAFNPP risk estimates; however, it did

account for the potential risk reduction benefits associated with external events by multiplying

the estimated benefits for internal events by a factor of 4.(1) This is discussed further in Sections

G.2.2 and G.6.2.

The breakdown of CDF by initiating event is provided in Table G-1 (Entergy 2007). As shown in

this table, events initiated by station blackout and transients are the dominant contributors to the

CDF. Anticipated transient without scram (ATWS) sequences are insignificant contributors to

the CDF.

The Level 2 JAFNPP PSA model that forms the basis for the SAMA evaluation represents an

updated version of the original IPE Level 2 model. The current Level 2 model utilizes a single

containment event tree (CET) containing both phenomenological and systemic events. The

Level 1 core damage sequences are binned into one of 48 Plant Damage State (PDS) bins

which provide the interface between the Level 1 and Level 2 CET analysis. CET nodes are

evaluated using supporting fault trees and logic rules.

The result of the Level 2 PSA is a set of 7 release categories with their respective frequency

and release characteristics. The results of this analysis for JAFNPP are provided in

(1) In the ER, Entergy bounded the combined impact of external events and uncertainties by applying a

multiplier of 16 to the estimated SAMA benefits for internal events. In supplemental information to the

ER, Entergy revised the analysis to include a multiplier of 4 to account for potential SAMA benefits in

both internal and external events, and provided a separate accounting of uncertainties.

I NUREG-1437, Supplement 31 G-2 January 2008
Appendix G I

Table E.1-10 of the ER (Entergy 2006a). The frequency of each release category was obtained

by summing the frequency of the individual accident progression CET endpoints binned into the

release category. Source terms were developed for each of the 7 release categories using the

results of Modular Accident Analysis Program (MAAP 4.0.4) computer code calculations. These

release categories and source terms were further collapsed into three distinct source term bins

to represent no containment failure, early releases, and late releases.

Table G-1. JAFNPP Core Damage Frequency for Internal Events

Percent

CDF Contribution to

Initiating Event (per year) CDF

Station Blackout 1.27 x 10- 6 46

Transients with loss of containment heat removal 7.78 x 10- 7 28

Transients with loss of all emergency core cooling 2.66 x 10-7 10

system (ECCS) injection

ATWS 1.38 x 10-7 5

Loss of a 4.16kv alternating current (AC) safeguard 1.18 x 10-7 5

bus

Loss of both direct current (DC) divisions 9.55 x 10-8 3

Loss of coolant accidents (LOCAs) 2.83 x 10-8 1

Loss of a division of DC power 2.60 x 10-8 1

Relay room flooding 2.53 x 10-8 1

Total CDF (internal events) 2.74 x 10-6 100

The offsite consequences and economic impact analyses use the MACCS2 code to determine

the offsite risk impacts on the surrounding environment and public. Inputs for these analyses

include plant-specific and site-specific input values for core radionuclide inventory, source term

and release characteristics, site meteorological data, projected population distribution (within a

50-mile radius) for the year 2034, emergency response evacuation modeling, and economic

data. The core radionuclide inventory is derived from a reference core inventory for a boiling

water reactor (BWR) in MACCS2. Core inventory was scaled to account for the JAFNPPspecific power level, and long-lived radionuclide inventory was increased by 25 percent to

reflect the expected core exposure and fuel management practices at JAFNPP (Entergy 2007).

The magnitude of the onsite impacts (in terms of clean-up and decontamination costs and

occupational dose) is based on information provided in NUREG/BR-0184 (NRC 1997a).

January 2008 G-3 NUREG-1437, Supplement 31 I
Appendix G

In the ER, Entergy estimated the dose to the population within 50 miles of the JAFNPP site to

be approximately 1.63 person-rem per year. The breakdown of the total population dose by

containment release mode is summarized in Table G-2. Containment failures within the late

time frame (greater than 24 hours following event initiation) and the early time frame (0 to 24

hours following event initiation) dominate the population dose risk at JAFNPP, contributing

about equally to the population dose risk.

Table G-2. Breakdown of Population Dose by Containment Release Mode

Population Dose

(Person-Rem(a) Percent

Containment Release Mode Per Year) Contribution

Late Containment Failure 0.87 53

Early Containment Failure 0.76 47

Intact Containment negligible negligible

Total 1.63 100

(a) One person-rem = 0.01 person-Sv

G.2.2 Review of Entergy's Risk Estimates

Entergy's determination of offsite risk at JAFNPP is based on the following three major elements

of analysis:

" The Level 1 and 2 risk models that form the bases for the 1991 IPE submittal (NYPA

1991), and the external event analyses of the 1996 IPEEE submittal (NYPA 1996),

* The major modifications to the IPE model that have been incorporated in the JAFNPP

PSA, and

" The MACCS2 analyses performed to translate fission product source terms and release

frequencies from the Level 2 PSA model into offsite consequence measures.

Each of these analyses was reviewed to determine the acceptability of Entergy's risk estimates

for the SAMA analysis, as summarized below.

The NRC staffs review of the JAFNPP IPE is described in an NRC report dated May 9, 1994

(NRC 1994). Based on a review of the IPE submittal and responses to RAIs, the NRC staff

concluded that the IPE submittal met the intent of GL 88-20 (NRC 1988); that is, the licensee's

IPE process is capable of identifying severe accident risk contributors or vulnerabilities.

I NUREG-1437, Supplement 31 G-4 January 2008
Appendix G I

No vulnerabilities were identified in the IPE. However, the licensee noted that a number of

actions were under evaluation as a result of the IPE process that would reduce the risk of core

damage and loss of containment function. Specific improvements identified for implementation

included: increasing the reactor core isolation cooling (RCIC) turbine exhaust set points,

repowering the RCIC enclosure exhaust fans from AC to DC, and fire protection system

modifications to provide emergency diesel generator (EDG) jacket water cooling directly or

through the emergency service water (ESW) system. Over 10 additional items were identified

for follow-on evaluation by the licensee (NRC 1994).

There have been two revisions to the IPE model since the 1991 IPE submittal, specifically, a

complete revision of the model in 1998 (Revision 1) in partial response to the boiling-water

reactor owner group (BWROG) peer review, and a revision in October 2004 (Revision 2)

completing the response to the BWROG peer review. The Revision 2 model reflects the

JAFNPP configuration and design as of December 2003 and uses component failure and

unavailability data as of December 2002. A comparison of internal events CDF between the

1991 IPE and the current PSA model indicates an increase of about 40 percent in the total CDF

(from 1.9 x 10-6 per year to 2.7 x 10-6 per year). A listing of those changes that resulted in the

greatest impact on the internal events CDF was provided by Entergy in supplemental

information to the ER (Entergy 2006b) and in response to an RAI (Entergy 2007) and is

summarized in Table G-3.

The CDF value from the 1991 IPE (1.92 x 10-6 per year) is near the lower end of the range of

the CDF values reported in the IPEs for other BWR 3/4 plants. Figure 11.2 of NUREG-1560

shows that the IPE-based total internal events CDF for BWR 3/4 plants ranges from 9 x 10-8 per

year to 8 x 10-5 per year, with an average CDF for the group of 2 x 10-5 per year (NRC 1997b).

It is recognized that other plants have updated the values for CDF subsequent to the IPE

submittals to reflect modeling and hardware changes. The current internal events CDF results

for JAFNPP are comparable to that for other plants of similar vintage and characteristics.

The NRC staff considered the peer reviews performed for the JAFNPP PSA, and the potential

impact of the review findings on the SAMA evaluation. In the ER (Entergy 2006a) and in

response to an NRC staff RAI (Entergy 2007), Entergy described the previous peer reviews,

including independent consultant team reviews of draft versions of the IPE and Revision 1, as

well as the BWROG Peer Review of a draft of Revision 1 conducted in December 1997. The

BWROG review concluded that the JAFNPP PSA can be effectively used to support risk ranking

of systems, structures, and components, and to support applications involving risk significance

determinations when supported by deterministic analyses and when noted items are addressed.

Entergy stated that all major issues and observations from the BWROG Peer Review have been

addressed and incorporated into the current PSA (Revision 2).

January 2008 G-5 NUREG-1437, Supplement 31 I
Appendix G

Table G-3. JAFNPP PSA Historical Summary

CDF

PSA Version Summary of Changes from Prior Model (per year)

1991 IPE Submittal 1.92 x 10-6

1998 * Incorporated impact of design changes (supply EDG jacket 2.44 x 10-6

(Revision 1) cooling water through the ESW system cross-tie, bonnet vents on

the low-pressure coolant injection (LPCI) and core spray injection

valves, keylock bypass switches, normal position of residual heat

removal (RHR) minimum flow bypass valve, and RCIC enclosure

fan power supply changed to an AC inverter feed from a DC

power source)

" Revised model to include catastrophic common cause failure of

both 125V DC battery control boards, and other common cause

equipment failures

* Revised model to assume loss of all AC power in the same

division in which there is a loss of DC power

" Revised internal flooding analysis to include a relay room flooding

scenario

* Revised transient sequences to directly result in core damage if

manual depressurization of the reactor vessel fails

" Revised model to assume core damage occurs given failure to

initiate Standby Liquid Control System (SLCS)

" Updated initiating event frequencies and component failure and

unavailability database

2004 * Reduced station battery depletion time from 8 to 4 hours, and 2.74 x 10-6

(Revision 2) updated non-recovery probabilities for loss of offsite power

" Revised model to include additional accident initiators: loss of

non-safeguard 4.16kV AC Buses, loss of condensate system, loss

of instrument air system, loss of ultimate heat sink, and loss of

reactor water level instrumentation

" Revised model to assume loss of both high-pressure coolant

injection (HPCI) and RCIC during accidents involving a loss of

containment heat removal

" Revised system fault tree models to include additional electrical

and instrumentation and control (I&C) component common cause

failures

" Reevaluated dependencies between post-initiator human actions

and recovery actions

" Updated initiating event frequencies and component failure data

I NUREG-1437, Supplement 31 G-6 January 2008
Appendix G

Given that the JAFNPP internal events PSA model has been peer-reviewed and the peer review

findings were all addressed, and that Entergy has satisfactorily addressed NRC staff questions

regarding the PSA, the NRC staff concludes that the internal events Level 1 PSA model is of

sufficient quality to support the SAMA evaluation.

As indicated above, the current JAFNPP PSA does not include external events. In the absence

of such an analysis, Entergy'used the JAFNPP IPEEE to identify the highest risk accident

sequences and the potential means of reducing the risk posed by those sequences, as

discussed below.

The JAFNPP IPEEE was submitted in June 1996 (NYPA 1996), in response to Supplement 4 of

Generic Letter 88-20 (NRC 1991 b). While no fundamental weaknesses or vulnerabilities to

severe accident risk in regard to the external events were identified, a listing of improvement

opportunities was developed as discussed below. In a letter dated September 21, 2000, the

NRC staff concluded that the submittal met the intent of Supplement 4 to Generic Letter 88-20,

and that the licensee's IPEEE process is capable of identifying the most likely severe accidents

and severe accident vulnerabilities (NRC 2000a).

The JAFNPP IPEEE seismic analysis (NYPA 1996) utilized a seismic margin assessment

(SMA) approach following NRC guidance (NRC 1991 a) and Electric Power Research Institute

(EPRI) guidance (EPRI 1991). This method is qualitative and does not provide numerical

estimates of the CDF contributions from seismic initiators. The seismic analysis was completed

in conjunction with the Seismic Qualification User Group (SQUG) program (SQUG 1992). The

overall seismic approach employed plant walkdowns to identify vulnerabilities, development of

seismic fragility values for components and structures, and quantification of high confidence low

probability of failure (HCLPF) for initiating events. A relay chatter evaluation was performed

using the standard approach for an Unresolved Safety Issue (USI) A-46 (NRC 2000b) program

plant. The conclusions of the JAFNPP IPEEE seismic margin analysis are:

" The overall plant HCLPF capacity at JAFNPP is 0.22g peak ground acceleration (PGA).

This value reflects implemented improvements to strengthen block walls in the

Emergency Diesel Generator Building, which increased the plant HCLPF value from

0.17g to 0.22g. Several buildings and structures have HCLPF values at the 0.22g level.

Thus, further increases in seismic capacity would require multiple plant modifications.

" A vulnerability to fire or explosion as a result of the seismic-induced failure of the

hydrogen line in the turbine building was identified. A note was added to procedure

AOP-14, "Earthquake," stating that the piping can be isolated by closing the hydrogen

supply valve 89A-H2HAS-1. Based on this procedure change, the applicant concludes

that seismic-induced flooding and fires do not pose major risks.

• No unique decay heat removal vulnerabilities to seismic events were found.

• No unique seismic-induced containment failure mechanisms were identified.

January 2008 G-7 NUREG-1437, Supplement 31
Appendix G

The NRC review and closeout of USI A-46 for JAFNPP is documented in a letter dated April 12,

2000 (NRC 2000b). Based on the information provided by the applicant, the NRC staff finds that

seismic risks are not dominant contributors to external event risk and that the treatment of

seismic events is reasonable for the purposes of the SAMA analysis.

The JAFNPP IPEEE fire analysis employed EPRI's fire-induced vulnerability evaluation (FIVE)

methodology to perform a qualitative and quantitative screening review and then a probabilistic

risk analysis to estimate the CDF contribution for the areas that did not screen out. After

qualitative screening, fire event initiation frequencies were determined for the unscreened areas

for use in quantitative screening along with the assumption that all equipment in a compartment

was damaged by the fire. Using results from the IPE, a conservative CDF for the compartment

was determined and areas with a CDF of less than 1 x 10-6 per year (or 1 x 10-7 per year if

containment bypass may result) were screened out. Fire propagation and suppression analysis

was then conducted on the unscreened compartments. Fire-induced CDFs were determined by

propagating the fire initiating events and associated equipment failures determined by the fire

propagation and suppression analysis through event trees similar to those in the IPE. The

potential impact on containment performance and isolation was evaluated following the core

damage evaluation. The JAFNPP fire CDF results are presented in Table E. 1-12 of the ER for

the ten fire areas considered in the analysis, and the fire zones/compartments within each fire

area. The total fire CDF, found by summing the values for all compartments, is 2.56 x 10-5 per

year. The ten fire areas and their contributions to the fire CDF are listed in Table G-4.

In the IPEEE, three opportunities for improvements with respect to fire events were identified.

These improvements involve: (1) addition of a bypass switch to allow opening of the LPCI and

core spray injection valves and an associated procedure for use of these switches during plant

fires, (2) changes to administrative procedures to impose strict limitations on unattended

combustible materials in the cable spreading room, and (3) relocation of heat detectors in the

cable spreading room to limit contribution from transient fires. In supplemental information to

the ER, Entergy indicated that the first two of these improvements have been implemented as

recommended in the IPEEE. The third improvement is considered to be addressed by the

changes to administrative procedures to limit unattended combustible material loading in the

room. Entergy stated that none of these improvements are credited in the IPEEE fire CDF

(Entergy 2006b).

In the ER, Entergy states that the IPEEE CDF values are screening values and that a more

realistic fire CDF may be about a factor of three lower (or 8.53 x 10-6 per year) based on

conservatisms in several areas as qualitatively assessed in the ER. In supplemental

information, Entergy presented the results of a sensitivity analysis to quantitatively justify the

factor of three reduction (Entergy 2006b). The sensitivity analysis included the following:

(1) lower probability of occurrence of spurious actuation or failure due to hot shorts and open

circuits within cable jackets in the Cable Spreading Room, Reactor Building East Crescent, and

Relay Room and (2) lower ignition frequency for a fire in the Main Control Room. The results of

this sensitivity analysis are shown for the four impacted areas in the last two columns of the

I NUREG-1437, Supplement 31 G-8 January 2008
Appendix G I

table below. These reductions would quantitatively justify a reduction in the fire CDF by a factor

of 2.3.

Table G-4. Fire Areas and Their Contribution to the Fire CDF

CDF (per year)

Fire Area Description IPEEE Sensitivity Analysis(a)

Cable Spreading Room 6.71 x 10-6 4.66 x 10-7

Relay Room 5.81 x 10-6 6.8 x 10-7

Reactor Building 3.43 x 10-6 2.46 x 10-6

Control Room 3.00 x 10-6 7.17 x 10-7

Cable Tunnels 1.96 x 10-6 no change

Diesel Generator Building 1.93 x 10-6 no change

Battery Room 1.45 x 10-6 no change

Turbine Building 1.29 x 10-6 no change

Standby Gas Treatment 3.72 x 10-8 no change

Building

Electric Bays 8.98 x 10-6 no change

TOTAL 2.56 x 10- 5 1.10 x 10-5

(a) Source: Entergy 2006b

Entergy noted that this fire CDF would be further reduced by IPEEE improvements not included

in the CDF estimate, including monitoring and controlling the quantity of combustible materials

in critical process areas. These measures would reduce the fire CDF in all dominant fire zones.

Based on the results of the sensitivity analysis and the existence of remaining conservatisms,

the NRC staff finds the use of a fire CDF of 8.53 x 10-6 per year to be reasonable for the

purposes of the SAMA analysis.

The NRC staff inquired about additional steps taken to reduce fire risk and the possibility of

additional SAMAs that might be feasible to reduce the fire risk. Entergy provided a listing of firerelated SAMAs that have been implemented. Most of these SAMAs are improvements in the

fire protection program, which would decrease the fire risk, but are not explicitly credited in the

fire risk analysis. In addition, all but one of the six dominant fire zones (i.e., zones within the

above-mentioned fire areas with a compartment frequency greater than 1.0 x 10-6 per year) are

equipped with fire detection systems, three of the six dominant fire zones have fire suppression

systems, and the Main Control Room, which has neither fire detection or fire suppression

systems, is always occupied ensuring prompt fire detection and manual suppression. Entergy

January 2008 G-9 NUREG-1437, Supplement 31 I
Appendix G

stated that no further cost-effective changes were identified to reduce CDF in the dominant fire

zones (Entergy 2006b). The NRC staff concludes that the opportunity for fire-related SAMAs

has been adequately explored and that it is unlikely that there are any potentially cost-beneficial,

fire-related SAMA candidates.

The IPEEE analysis of high winds, floods and other external events followed the screening and

evaluation approaches specified in Supplement 4 to GL 88-20 (NRC 1991b) and did not identify

any sequences or vulnerabilities that exceeded the 1.0 x 10-6 per year criterion (NYPA 1996).

However, the licensee identified a condition where low pressures associated with hurricanes,

tornadoes, and high winds could threaten the integrity of the air intake duct work supplying the

EDG room. Operating procedures were developed to open switchgear room doors or to open

damaged duct work if necessary to ensure adequate ventilation of the switchgear room and

adequate supply of combustion air to the EDGs. Based on this result, Entergy concluded that

these other external hazards would not be expected to impact the conclusions of the SAMA

analysis and did not consider them further.

Based on the aforementioned results, the external events CDF is approximately 3.1 times the

internal events CDF (based on a fire CDF of 8.53 x 10-6 per year and an internal events CDF of

2.74 x 10-6 per year). Accordingly, the total CDF (from internal and external events) would be

approximately 4.1 times the internal events CDF. In revised SAMA analyses submitted in

response to an RAI, Entergy multiplied the benefit that was derived from the internal events

model by a factor of 4 to account for the combined contribution from internal and external

events. The NRC staff agrees with the applicant's overall conclusion concerning the impact of

external events and concludes that the applicant's use of a multiplier of 4 to account for external

events is reasonable for the purposes of the SAMA evaluation.

The NRC staff reviewed the general process used by Entergy to translate the results of the

Level 1 PSA into containment releases, as well as the results of the Level 2 analysis, as

described in the ER and in response to NRC staff requests for additional information (Entergy

2006a, 2007). The current Level 2 model utilizes a single CET containing both

phenomenological and systemic events. The Level 1 core damage sequences are binned into

one of 48 PDS bins based on binning criteria reflecting the state of the reactor, containment and

cooling systems as the accident progresses. The PDSs provide the interface between the

Level 1 and Level 2 analysis. CET nodes are evaluated using supporting fault trees and logic

rules.

Entergy characterized the releases for the spectrum of possible radionuclide release scenarios

using a set of 7 release categories based on the timing and magnitude of the release and

whether or not the containment remains intact. The frequency of each release category was

obtained by summing the frequency of the individual accident progression CET endpoints

binned into the release category. The release characteristics for each release category were

developed by grouping the hundreds of source terms generated for internal initiators into the

7 categories based on similar properties. Source term release fractions were developed for

I NUREG-1437, Supplement 31 G-1 0 January 2008
Appendix G I

each of the 7 release categories using the results of Modular Accident Analysis Program

(MAAP 4.0.4) computer code calculations. The release categories, their frequencies, and

release characteristics are presented in Tables E.1-8, E.1-10, and E.1-11 of the ER,

respectively (Entergy 2006a). These release categories and source terms were further

collapsed into three distinct source term bins to represent no containment failure, early releases,

and late releases.

The NRC staff noted that in collapsing the 7 release categories into three source term bins,

releases occurring between 0 to 8 hours and between 8 to 24 hours were grouped into one bin.

In response to an RAI, Entergy performed a sensitivity study that showed that this simplification

results in less than a 2 percent change on population dose (Entergy 2007). Based on these

results the NRC staff concludes that the applicant's characterization of releases is adequate for

the purposes of the SAMA evaluation.

The NRC staff's review of the Level 2 IPE concluded that it addressed the most important

severe accident phenomena normally associated with the Mark I containment type, and

identified no significant problems or errors (NRC 1994). It should be noted, however, that the

current Level 2 model is a revision to that of the IPE. The Level 2 PSA model was included in

the independent consultant and BWROG peer reviews mentioned previously. The changes to

the Level 2 model to update the methodology and to address peer review recommendations are

described in Section E.1.4.2.2 of the ER. Based on the NRC staff's review of the Level 2

methodology, and the fact that the Level 2 model was reviewed in more detail as part of the

BWROG peer review, and updated to address the review findings, the NRC staff concludes that

the Level 2 PSA provides an acceptable basis for evaluating the benefits associated with

various SAMAs.

Entergy used the MACCS2 code and scaled the reference BWR core inventory for the JAFNPP

plant-specific power level. Entergy also increased the long-lived radionuclide core inventory by

25 percent to address JAFNPP specific fuel enrichment and burnup. In response to an NRC

staff RAI, Entergy identified that the 25-percent increase was based on a best estimate

inventory of long-lived isotopes (such as Sr-90, Cs-134 and Cs-137) from an ORIGEN computer

code calculation assuming 4.65 percent enrichment and average burnup based on expected

fuel management practices (Entergy 2007). The best-estimate evaluation resulted in an

increase of approximately 25 percent in the inventories of the aforementioned radionuclides.

The NRC staff considers the methods and assumptions for power scaling and 25 percent

increase in long-lived inventory reasonable and acceptable for purposes of the SAMA

evaluation.

The NRC staff reviewed the process used by Entergy to extend the containment performance

(Level 2) portion of the PSA to an assessment of offsite consequences (essentially a Level 3

PSA). This included consideration of the source terms used to characterize fission product

releases for the applicable containment release categories and the major input assumptions

used in the offsite consequence analyses. The MACCS2 code was utilized to estimate offsite

January 2008 G-1 1 NUREG-1437, Supplement 31 I
Appendix G

consequences. Plant-specific input to the code includes the source terms for each release

category and the reactor core radionuclide inventory (both discussed above), site-specific

meteorological data, projected population distribution within a 50-mile radius for the year 2034,

emergency evacuation modeling, and economic data. This information is provided in

Attachment E to the ER (Entergy 2006a).

Entergy used site-specific meteorological data for the 1994 calendar year as input to the

MACCS2 code. The data were collected from the onsite meteorological monitoring system and

regional National Weather System (NWS) stations. In response to an NRC staff RAI, Entergy

identified the location of the National Weather System stations as being at Fulton-Oswego

County Airport and NWS Station No. 14733 in Buffalo, NY (Entergy 2007). Based on a review

of meteorological data between 1985 and 2001, Entergy stated that it considered the year 1994

data to be the most representative set of data because it contained no significant extremes and

reflected average meteorological conditions at the site (Entergy 2006a). Missing data was

obtained from either the upper elevation on the met tower or from estimates based on adjacent

valid measurements of the missing hour. The NRC staff notes that previous SAMA analyses

results have shown little sensitivity to year-to-year differences in meteorological data and

concludes that the use of the 1994 meteorological data in the SAMA analysis is reasonable.

The population distribution the applicant used as input to the MACCS2 analysis was estimated

for the year 2034, based on the New York Statistical Information System projections from year

2000 to 2030 (Brown 2005). The 2000 population was adjusted to account for transient

population. These data were used to project county-level resident populations to the year 2034

using a least squares fit method. The NRC staff considers the methods and assumptions for

estimating population reasonable and acceptable for purposes of the SAMA evaluation.

The emergency evacuation model was modeled as a single evacuation zone extending out 16

kilometers (10 miles) from the plant. Entergy assumed that 100 percent of the population would

move at an average speed of approximately 2.0 meters per second (4.4 miles per hour) with a

delayed start time of 2.25 hours (Entergy 2006a). This assumption is similar to the model used

in NUREG-1 150 study (NRC 1990), which assumed evacuation of 99.5 percent of the

population within the emergency planning zone (EPZ). Sensitivity analyses were performed in

which the evacuation delay time was increased to 4.5 hours, and the evacuation speed was

decreased to 1.0 meters per second. The results were less than a one percent increase in the

total population dose. The NRC staff questioned why the evacuation speed of 2.0 meters per

second (4.4 miles per hour) was different than that used for the Nine Mile Point SAMA analysis

(NRC 2006). In response, Entergy stated that the JAFNPP evacuation speed was based on

evacuation times provided in the 2003 version of the evacuation time study (ETE) (KLD

Associates 2003), whereas the Nine Mile Point evacuation time estimate was based on an ETE

study performed in 1993 (Entergy 2007). The NRC staff also asked Entergy to address the

potential impact on the population dose if 5 percent of the population fails to evacuate the EPZ

(NRC 2006). In response, Entergy performed a sensitivity analysis that showed only a slight

increase in population dose (less than 1 percent for the late release) would result (Entergy

I NUREG-1437, Supplement 31 G-12 January 2008
Appendix G I

2007). The NRC staff concludes that the evacuation assumptions and analysis are reasonable

and acceptable for the purposes of the SAMA evaluation.

Much of the site-specific economic data was provided from the 2002 Census of Agriculture

(USDA 2002). These included the value of farm and non-farm wealth. Other data such as daily

cost for an evacuated person, population relocation cost, daily cost for a person who is

relocated, cost of farm and non-farm decontamination, and property depreciation were provided

from the Code Manual for MACCS2 (NRC 1997c). The data from the default values given in the

MACCS2 code manual were adjusted using the consumer price index of 179.9, the average

value for 2002. Information on regional crops were obtained from the 2002 Census of

Agriculture. Crops for each county were mapped into the seven MACCS2 crop categories.

The NRC staff concludes that the methodology used by Entergy to estimate the offsite

consequences for JAFNPP provides an acceptable basis from which to proceed with an

assessment of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based

its assessment of offsite risk on the CDF and offsite doses reported by Entergy.

G.3 Potential Plant Improvements

The process for identifying potential plant improvements, an evaluation of that process, and the

improvements evaluated in detail by Entergy are discussed in this section.

G.3.1 Process for Identifying Potential Plant Improvements

Entergy's process for identifying potential plant improvements (SAMAs) consisted of the

following elements:

" Review of the most significant basic events from the current, plant-specific PSA,

" Review of potential plant improvements identified in the JAFNPP IPE and IPEEE,

" Review of SAMA candidates identified for license renewal applications for six other U.S.

General Electric (GE) plants, and

" Review of other NRC and industry documentation discussing potential plant

improvements.

Based on this process, an initial set of 293 candidate SAMAs, referred to as Phase I SAMAs,

was identified. In Phase I of the evaluation, Entergy performed a qualitative screening of the

initial list of SAMAs and eliminated SAMAs from further consideration using the following

criteria:

January 2008 G-1 3 NUREG-1 437, Supplement 31 I
Appendix G

" The SAMA is not applicable at JAFNPP due to design differences,

" The SAMA has already been implemented at JAFNPP, or

* The SAMA is similar in nature and could be combined with another SAMA candidate.

Based on this screening, 230 SAMAs were eliminated leaving 63 for further evaluation. The

remaining SAMAs, referred to as Phase II SAMAs, are listed in Table E.2-1 of the ER (Entergy

2006a). In Phase II, a detailed evaluation was performed for each of the 63 remaining SAMA

candidates, as discussed in Sections G.4 and G.6 below. To account for the potential impact of

external events, the estimated benefits based on internal events were multiplied by a factor of 4,

as previously discussed.

G.3.2 Review of Entergy's Process

Entergy's efforts to identify potential SAMAs focused primarily on areas associated with internal

initiating events. The initial list of SAMAs generally addressed the accident sequences

considered to be important to CDF from functional, initiating event, and risk reduction worth

(RRW) perspectives at JAFNPP, and included selected SAMAs from prior SAMA analyses for

other plants.

Entergy provided a tabular listing of the PSA basic events sorted according to their RRW

(Entergy 2006a). SAMAs impacting these basic events would have the greatest potential for

reducing risk. Entergy used a RRW cutoff'of 1.005, which corresponds to about a one-half

percent change in CDF given 100-percent reliability of the SAMA. This equates to a benefit of

approximately $2,500 (after the benefits have been multiplied to account for external events).

Entergy also provided and reviewed the large early release frequency (LERF)-based RRW

events down to a RRW of 1.005. Entergy correlated the top Level 1 and Level 2 events with the

SAMAs evaluated in the ER, and showed that all of the significant basic events are addressed

by one or more SAMAs (Entergy 2006a).

NRC staff noted that no Phase 11 SAMAs were recommended for event NR-LOSP-7HR, nonrecovery of offsite power in seven hours, which is the highest risk reduction worth non-initiator

event. The NRC staff asked the applicant to identify and evaluate SAMAs for this event (NRC

2006). In response to the RAI, Entergy stated that procedure and training improvements for

restoring power to vital equipment following a recovery of the offsite power supply have been

implemented, but that hardware improvements that could facilitate recovery of offsite power

would merely shift NR-LOSP-7HR to a slightly later time on the power recovery curve and

therefore would have little impact on the RRW of the event (Entergy 2007). Entergy further

noted that other Phase II SAMAs (26 through 36 and 62), if implemented, would reduce the

CDF contribution from this basic event. These SAMAs would enhance AC or DC system

reliability or otherwise cope with loss of offsite power and SBO events. These Phase II SAMAs

were evaluated in the ER.

I NUREG-1437, Supplement 31 G-14 January 2008
Appendix G I

NRC staff also noted that no Phase I or Phase II SAMAs were recommended for event IERRFLOOD, transient caused by internal flooding in the relay room, although a procedure

change has been implemented to address the event. In an NRC staff RAI, the applicant was

asked to provide justification for why no SAMAs were identified to address internal flooding

events (NRC 2006). Entergy responded that additional methods of mitigating this flood event

would entail either moving the fire protection line or installing a guard pipe to channel floodwater

out of the relay room, both of which were judged to be costly relative to the risk significance of

the related flood scenarios (Entergy 2007). The remaining flood scenarios are not risksignificant (i.e., above the 1.005 RRW threshold for SAMA identification).

For a number of the Phase II SAMAs listed in the ER, the information provided did not

sufficiently describe the proposed modification. Therefore, the NRC staff asked the applicant to

provide more detailed descriptions of the modifications for several of the Phase II SAMAs

candidates (NRC 2006). In response to the RAI, Entergy provided the requested information

(Entergy 2007).

The NRC staff questioned the ability of some of the candidate SAMAs to accomplish their

intended objectives (NRC 2006). In response to the RAIs, Entergy addressed the NRC staff's

concerns by either re-evaluating the existing SAMA using revised modeling assumptions, or by

evaluating an alternative (additional) SAMA (Entergy 2007). This is discussed further in

Section G.6.2.

The NRC staff also questioned Entergy about lower cost alternatives to some of the SAMAs

evaluated, including: the use of a redundant diesel fire pump to address event FXT-ENG-FR76PI (failure of diesel driven fire pump 76P-1), the use of a local hand wheel or gas bottle

supplies for manual venting of containment, and the use of a portable generator to provide

alternate DC power feeds (NRC 2006). In supplemental information and in response to the

RAIs, Entergy addressed the suggested lower cost alternatives, some of which are covered by

an existing procedure, or are addressed by a new SAMA (Entergy 2006b, 2007). This is

discussed further in Section G.6.2.

In the ER, Entergy states that in both the IPE and IPEEE, several enhancements related to

severe accident insights were recommended and implemented, and that these enhancements

were included in the comprehensive list of Phase I SAMA candidates. However, the list of

Phase I SAMA candidates was not provided in the ER. Therefore, the NRC staff requested that

the applicant indicate whether the enhancement has been implemented, and whether credit for

the enhancement is taken in the current PSA model (used for the SAMA analysis) (NRC 2006).

In supplemental information to the ER, Entergy indicated that Phase I SAMAs 253, 256, 262,

and 280 through 293 include enhancements recommended in the IPE and IPEEE (Entergy

2006b). Entergy further indicated that most of these SAMAs have been implemented and that

SAMA 280 was determined to be unnecessary. Those enhancements that have not been

implemented or determined to not be necessary (SAMAs 281 through 284) were retained for

consideration during Phase I1. In response to the RAI, Entergy noted that except for Phase I

January 2008 G-15 NUREG-1 437, Supplement 31 I
Appendix G

SAMAs 94, 101, 120, and 267, the implemented Phase I SAMAs mentioned in the ER have

been credited in the current PSA model (Entergy 2007). The absence of these four

implemented modifications from the PSA model adds conservatism to the benefit estimates for

Phase II SAMAs.

Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER,

together with those identified in supplemental information to the ER and in response to NRC

staff RAIs, addresses the major contributors to internal event CDF.

Entergy did not identify JAFNPP-specific candidate SAMAs for seismic events. In the JAFNPP

IPEEE seismic analysis, the overall plant HCLPF value was determined to be 0.22g. This value

reflects implemented improvements to strengthen block walls EGB-272-6, 7, 9, and 10 in the

Emergency Diesel Generator Building, which increased the plant HCLPF value from 0.17g to

0.22g. Several buildings and structures have HCLPF values at the 0.22g level. Thus, further

increases in seismic capacity would require multiple plant modifications. The JAFNPP IPEEE

also identified that there is a fire-induced seismic vulnerability due to failure of the hydrogen line

in the turbine building. The NRC staff requested that the applicant provide details on actions

taken to reduce this risk and whether a SAMA to further reduce this risk is cost-beneficial (NRC

2006). In their response, Entergy stated the hydrogen supply is protected by excess flow valves

outside the turbine building that are intended to limit hydrogen release in the event of a line

break (Entergy 2007). Entergy also indicated that this event has already been further mitigated

by making a modification to plant abnormal procedure AOP-14, "Earthquake," to require that

plant operators close hydrogen supply valve 89A-H2HAS-1 following a seismic event (Phase I

SAMA 286). Finally, Entergy notes that the turbine building fire risk provided in the ER (which

does not reflect the implemented plant procedure) is less than 1 x 10-6 per year, and cannot be

further reduced in a cost-effective manner. Based on the licensee's IPEEE, the A-46 efforts to

identify and address seismic outliers, the modifications that have already been implemented,

and the expected cost associated with further seismic risk analysis and potential plant

modifications, the NRC staff concludes that the opportunity for seismic-related SAMAs has been

adequately explored and that it is unlikely that there are any cost-beneficial, seismic-related

SAMA candidates.

Entergy also did not identify any JAFNPP-specific candidate SAMAs for fire events. The fire

risk at JAFNPP is dominated by ten fire areas, eight of which have fire CDF contributions in

excess of 1 x 10-6 per year, with the largest contributor being the Cable Spreading Room. The

NRC staff asked the applicant to explain what measures were taken to further reduce risk and

why the fire risk cannot be further reduced in a cost-effective manner (NRC 2006). In

supplemental information to the ER, Entergy stated that the fire area CDFs are conservative

and presented the results of a sensitivity analysis that reduced modeling conservatisms

(Entergy 2006b). This analysis, as discussed previously in Section G.2.2, reduced the

individual CDF contributions for three of the top four dominant fire areas to below the

1 x 10-6 per year threshold. Entergy also noted that the fire CDF is further reduced by IPEEE

improvements not included in the CDF estimate, such as restraining or relocating flammables

I NUREG-1437, Supplement 31 G-1 6 January 2008
Appendix G I

cabinets, monitoring and controlling the quantity of combustible materials in critical process

areas, and monitoring and control of pre-staging of outage materials (Phase I SAMAs 287

through 289). These measures would reduce the fire CDF in all dominant fire zones.

Therefore, modifications to further reduce the fire CDF are unlikely to be cost-beneficial

(Entergy 2006b). Entergy also stated that all but one of the six dominant fire zones are

equipped with fire detection systems, three of the six dominant fire zones have fire suppression

systems, and the Main Control Room, which has neither fire detection or fire suppression

systems, is always occupied ensuring prompt fire detection and manual suppression (Entergy

2006b). Therefore, no cost-effective hardware changes or other modifications were identified.

As stated earlier, other external hazards (high winds, external floods, and transportation and

nearby facility accidents) are below the threshold screening frequency and are not expected to

impact the conclusions of the SAMA analysis. However, the licensee identified a condition

where low pressures associated with hurricanes, tornadoes, and high winds could threaten the

integrity of the air intake duct work supplying the EDG room. Operating procedures were

developed to open switchgear room doors or to open damaged duct work if necessary to ensure

adequate ventilation of the switchgear room and adequate supply of combustion air to the

EDGs. No plant modifications were identified for these external hazards. The NRC staff

concludes that the applicant's rationale for eliminating fire and other external hazards

enhancements from further consideration is reasonable.

The NRC staff notes that the set of SAMAs submitted is not all-inclusive, since additional,

possibly even less expensive, design alternatives can always be postulated. However, the NRC

staff concludes that the benefits of any additional modifications are unlikely to exceed the

benefits of the modifications evaluated and that the alternative improvements would not likely

cost less than the least expensive alternatives evaluated, when the subsidiary costs associated

with maintenance, procedures, and training are considered.

The NRC staff concludes that Entergy used a systematic and comprehensive process for

identifying potential plant improvements for JAFNPP, and that the set of potential plant

improvements identified by Entergy is reasonably comprehensive and, therefore, acceptable.

This search included reviewing insights from the plant-specific risk studies, and reviewing plant

improvements considered in previous SAMA analyses. While explicit treatment of external

events in the SAMA identification process was limited, it is recognized that the prior

implementation of plant modifications for fire risks and the absence of external event

vulnerabilities reasonably justifies examining primarily the internal events risk results for this

purpose.

January 2008 G-1 7 NUREG-1437, Supplement 31 I
Appendix G

G.4 Risk Reduction Potential of Plant Improvements

Entergy evaluated the risk-reduction potential of the 63 remaining SAMAs that were applicable

to JAFNPP. 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. Such bounding calculations overestimate the benefit and are conservative.

Entergy used model re-quantification to determine the potential benefits. The CDF and

population dose reductions were estimated using the JAFNPP PSA model. The changes made

to the model to quantify the impact of SAMAs are detailed in Section E.2.3 of Attachment E to

the ER (Entergy 2006a). Table G-5 lists the assumptions considered to estimate the risk

reduction for each of the evaluated SAMAs, the estimated risk reduction in terms of percent

reduction in CDF and population dose, and the estimated total benefit (present value) of the

averted risk. The estimated benefits reported in Table G-5 reflect the combined benefit in both

internal and external events, as well as a number of changes to the analysis methodology

subsequent to the ER. The determination of the benefits for the various SAMAs is further

discussed in Section G.6.

The NRC staff questioned the assumptions used in evaluating the benefits or risk reduction

estimates of certain SAMAs provided in the ER (NRC 2006). SAMAs 8, 14, and 22 were each

modeled by assuming that reactor building failures were completely eliminated, yet the results

presented in the ER indicated no reduction in offsite dose. In response to the RAI, Entergy

revised the estimated benefit values submitted in the ER for these SAMAs and all other SAMAs

which directly impact the CET model and alter the distribution of releases within a release bin

(Entergy 2007). In response to this RAI, Entergy also changed the CDF reductions for Phase II

SAMAs 11, 16, 17, and 39 to 0 percent to correct erroneous entries in the ER. The CDF

reduction values for these SAMAs are now consistent with that for SAMA 25, which resolves

another NRC staff RAI questioning that the benefit estimates for these SAMAs should not have

been different (NRC 2006). Table G-5 reflects all of these revisions. Revision of these benefit

estimates had no impact on the original conclusions.

For SAMA 57, control containment venting within a narrow band of pressure, the staff noted that

the analysis assumptions were not directly related to the impact of the SAMA on CDF. In

supplemental information to the ER, Entergy described a sensitivity analysis to assure that the

benefit values reported for this SAMA are conservative. The sensitivity analysis resulted in a

decrease in the assessed benefit; Entergy thus concluded that the benefit values reported in

Table S-1 of the supplemental submittal (and in Table G-5) are conservative (Entergy 2006b).

For SAMA 61, develop a procedure to use a portable power supply for battery chargers, the

staff noted that the events -eliminated in the analysis were not included in the list of risk

significant events in ER Table E.1-2. In response to an NRC staff RAI, Entergy reevaluated the

benefit by eliminating the failures of both DC battery chargers and both 125-V DC battery

control boards, which resulted in an increase in the assessed benefit (Entergy 2007).

I NUREG-1437, Supplement 31 G-1 8 January 2008
Appendix G I

The NRC staff has 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 generally conservative (i.e., the estimated risk reduction is higher

than what would actually be realized). Accordingly, the NRC staff based its estimates of averted

risk for the various SAMAs on Entergy's risk reduction estimates.

G.5 Cost Impacts of Candidate Plant Improvements

Entergy estimated the costs of implementing the 63 candidate SAMAs through the application of

engineering judgment, 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 cost estimates provided in the ER

did not account for inflation. For those SAMAs whose implementation costs were originally

developed for severe accident mitigation design alternative analyses (i.e., during the design

phase of the plant), additional costs associated with performing design modifications to the

existing plant were not included.

The NRC staff reviewed the bases for the applicant's cost estimates (presented in Section E.2.3

of Attachment E to the ER), in supplemental information to the ER (Entergy 2006b), and in

response to NRC staff RAIs (Entergy 2007). For certain improvements, the NRC staff also

compared the cost estimates to estimates developed elsewhere for similar improvements,

including estimates developed as part of other applicant's analyses of SAMAs for operating

reactors and advanced light-water reactors. The NRC staff noted that several of the cost

estimates provided by the applicant were drawn from previous SAMA analyses for a dual-unit

site. For those cost estimates that were taken from a dual-unit SAMA analysis, Entergy reduced

the estimated costs by half. The staff reviewed the costs and found them to be reasonable, and

generally consistent with estimates provided in support of other plants' analyses.

The NRC staff questioned the estimated cost of $400,000 for implementation of SAMA 57,

control containment venting within a narrow band of pressure, for what appears to be a

procedure and training issue (NRC 2006). In supplemental information to the ER, Entergy

further described this modification as requiring detailed engineering studies, potential hardware

modifications, procedure changes, simulator changes, and training (Entergy 2006b). Based on

this additional information, the NRC staff considers the estimated cost to be reasonable and

acceptable for purposes of the SAMA evaluation.

The NRC staff concludes that the cost estimates provided by Entergy are sufficient and

appropriate for use in the SAMA evaluation.

January 2008 G-19 NUREG-1437, Supplement 31 1
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% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Discount Discount

Population Ratelb) Ratelb) Cost

SAMAMa) Assumptions CDF Dose ($) ($) ($)

Common cause failures of the SW system CDF contribution due to 1 1 5.000 6.000

common cause failure of ESW

pumps was eliminated

1 - Add a service water pump 5.900.000

Decay Heat Removal Capability - Torus Completely eliminate loss of 8 9 40.000 52,000

Cooling torus cooling mode of RHR

system events

2 - Install an independent method of 5800.000

suppression pool cooling

15- Dedicated suppression pool cooling 5.800,000

Decay Heat Removal Capability - Drywell Completely eliminate loss of 8 9 40000 51,000 5,800,000

Spray drywell spray mode of RHR

system events

10 - Install a passive containment spray

system

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Table G-5. (cont.)

% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Discount Discount

Population Rate(b) Ratelbi Cost

SAMA Assumptions CDF Dose ($) ($) ($)

Filtered Vent Reduce successful torus 0 4 16,000 23.000

venting accident progression

source terms by a factor of two

3 - Install a filtered containment vent to 1.500000

provide fission product scrubbing.

Option 1 : Gravel bed filter

Option 2 Multiple venturi scrubber

20- Install a filtered vent 1.500000

Containment Vent for AlVV/S Decay Heat Completely eliminate AT'WS 3 8 28,000 38,000

Removal sequences associated with

containment bypass

4 - Install a containment vent large enough >1,000,000

to remove anticipated transient without

scram (ATIWS) decay heat

52- Install an ATWS sized vent >1.000,000

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% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Discount Discount

Population Rate(b) Rate(b) Cost

SAMA Assumptions CDF Dose ($) ($) ($)

Molten Core Debris Removalic) Completely eliminate 0 64 34.000 48.000

containment failures due to

core-conctete interaction (not

including liner failure)

5 - Create a large concrete crucible with >100,000,000

heat removal potential under the base mat

to contain molten core debris

6 - Create a water cooled rubble bed on 19,000,000

the pedestal,

9 - Create a core melt source reduction >5.000,000

system

24 - Install a reactor cavity flooding system 8.750,000

Flooding the Rubble BedIc;l Completely eliminate dry core- 0 22 12000 16,000 2,500,000

concrete interactions

23 - Provide a means of flooding the rubble

bed

Base Mat Melt-Through(C' Completely eliminate 0 -0 -0 -0 >5,000,000

containment failures due to

base mat melt-through

12 -Increase the-depth of the concrete base

mat or use an alternative concrete material

to ensure melt-through does not occur

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Table G-5. (cont.)

% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Discount Discount

Population Rate(bl Ratelbi Cost

SAMA Assumptions COF Dose ($) ($) ($)

Reactor Vessel Exterior Cooling(c) Reduce probability of vessel 0 3 2.000 2,000 2,500,000

failure by a factor of two

13 - Provide a reactor vessel exterior

cooling system

Dryvell Head Flooding Completely eliminate drywell 0 0 0 0

head failures due to high

temperature

7 - Provide modification for flooding the >1.000.000

drywell head

19 - Increase the temperature margin for 12,000.000

seals

21 - Provide a method of drywell head > 1 000.000

flooding

Reactor Building Effectiveness(c) Completely eliminate reactor 0 31 17,000 24,000

building failures

8 - Enhance fire protection system and >2.500.000

SGTS hardware and procedures

14 - Construct a building connected to >1.000.000

primary containment that is maintained at a

vacuum

22 - Use alternate method of reactor >2.500.000

building spray

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% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Discount Discount

Population Rate(b) Rate(b) Cost

SAMA Assumptions CDF Dose (M) ($) (5)

Strengthen Containmentic) Completely eliminate all 0 28 13,000 19.000

energetic containment failure

modes (Direct containment

heating [DCH]. steam

explosions, late overpressurization)

11 - Strengthen primary and secondary 12,000,000

containment

16- Create a larger volume in containment 8.000,000

17- Increase containment pressure 12,000,000

capability (sufficient pressure to withstand

severe accidents)

25- Add ribbing to the containment shell 12,000.000

Vacuum Breakers Completely eliminate vacuum -0 7 22.000 31,000 >500,000

breaker failures

18 - Install improved vacuum breakers

(redundant valves in each line)

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Table G-5. (cont)

% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Discount Discount

Population Rate(b) Rate(b) Cost

SAMA Assumptions CDF Dose (M) ($) ($)

DC Power Increase time available to 39 44 209,000 270,000

recover offsite power (before

HPCI and RCIC are lost) from

14 to 24 hours during SBO

scenarios

26-Provide additional DC battery 500,000

capacity

27- Use fuel cells instead of lead-acid >1,000,000

batteries

30- Provide 16-hour SBO injection 500,000

34- Install fuel cells >1,000.000

36- Extended SBO provisions 500,000

Improved DC System

28-Incorporate an alternate battery Completely eliminate loss of DC 3 -0 8.000 10.000 90,000

charging capability battery chargers

29- Modification for improving DC bus Completely eliminate loss of 1 1 5.000 6000 500000

reliability 125 VDC bus B initiator

61 - power supply for battery Completely elim inate loss of 2 2 10,000 13,000 10,000

chargers(di DC battery chargers and

battery control boards

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% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Discount Discount

Population Rate(b) Rate(b) Cost

SAMA Assumptions CDF Dose ($) ($) ($)

Dedicated DC Power and Additional Completely eliminate loss of DC 1 1 5.000 6,000

Batteries and Divisions battery control board BCB-2A

32 - Add a dedicated DC power supply 3,000,000

33 - Install additional batteries or divisions 3,000,000

35-Install DC Buss cross-ties. 300,000

Alternate Pump Power Source Completely eliminate SBO 1 1 3.000 4,000 >1,000,000

diesel generator failures

31 - Provide an alternate pump power

source

Locate RHR Inside Containment Completely eliminate all RHR 1 1 3,000 4,000 >500,000

ISLOCA sequences

37 - Locate RHR inside containment

Interfacing System Loss of Coolant Completely eliminate all 1 2 7,000 10,000 100,000

Accident (ISLOCA) ISLOCA events

38 - Increase frequency of valve leak

testing

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Table G-5. (cont)

% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Discount Discount

Population Rate(b) Ratelb) Cost

SAMA Assumptions CDF Dose () ($) ($)

Main Steam Isolation Valve (MSIV) Design Completely elirminate 0 20 9,000 13.000 1, 000,000

containment bypass due to

MSIV leakage failures

39 - Improve MSIV design(c)

Main Feedwater Completely eliminate loss of 1 1 3,000 4.000

feedwater initiator

40-install a digital feedwater upgrade 1.500,000

Backup Water for feedwater/condensate

injection

41-Create ability to connect to existing or Completely eliminate 1 1 3,000 4000 170,000

alternate water sources to contribution due to failure of

feedwater/condensate alternate injection from

feedwaterlcondensate

43-Install motor driven feedwater pump Completely eliminate the failure -0 0 0 0 1,650.000

of feedwater turbine driven

pumps

Diesel to condensate storage tank (CST) Completely eliminate switchover 2 -0 2.000 3.000 135,000

Makeup Pumps from CST to torus failures

42 - Install an independent diesel for the

CST makeup pumps

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Table G-5. (cont.) 0

% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Discount Discount

Population Rate(b) Ratelbi Cost

SAMA Assumptions CDF Dose ($) ($) 0)

High Pressure Injection System HPCI system is always 3 1 8.000 10,000

available

44 - Provide an additional high pressure >1.000.000

injection pump with independent diesel

45- Install independent AC high pressure > 1,000,000

injection system

46- Install a passive high pressure system >1.000.000

48- Install an additional active high -1 000000

pressure system

49- Add a diverse injection system >1,000,000

Improve the Reliability of High Pressure Reduce HPCI system failure 2 -0 6.000 7.000

Injection System probability by a factor of 3

47- Improved high pressure systems

>1,000,000

Increase reliability of instrument air after Reduce probability of failure of -0 0 0 0

loss of offsite power (LOSP) normal electric power supply to

air compressors by a factor of

10

50-Modify EOPs for ability to align diesel 1.200.000

power to more air compressors

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Table G-5. (cont.)

% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Discount Discount

Population Rate(b) RatelbI Cost

SAMA Assumptions CDF Dose ($) ($) ($)

Safey relief valve (SRVs) Reseat Completely eliminate stuck 4 4 18.000 23,000

open SRV events

51 - Increase SRV reseat reliability 2,200.000

Diversity of Explosive Valves Completely eliminate common -0 0 0 0

cause failures of SLC explosive

valves

53- Diversify explosive valve operation >200.000

Prevent catastrophic containment failure Reduce CDF contribution in 2 2 10.000_ 14,000

scenarios where containment

venting is successful by a factor

ol 2

54-Implement passive overpressure relief >500,000

Improve control rod drive (CRD) reactor Eliminate failure of CRD reactor -0 0 0 0

vessel injection reliability vessel injection

55-Change CDR flow control valve failure >140.000

position to the 'fail-safest" position

Large Break LOCA Completely eliminate large -0 0 0 0 >100,000

break LOCAs

56 - Provide digital large break LOCA

protection

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% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Discount Discount

Population Rate(b) Rate(b) Cost

SAMA Assumptions CDF Dose ($) ($) ($)

Controlled Containment Venting Reduce probability of operator 14 16 74,000 95,000 400,000

to recognize the need to vent

the torus by a factor of 3

57 - Control containment venting within a

narrow band of pressure

RHR heat removal Completely eliminate CDF -0 1 2,000 3,000

contribution from failure of

cross-be from fie protection to

RHR heat exchanger "A"

58-Provide tap from fire protection to RHR 150.000

heat exchanger "B" via RHRSW header B

Injection and containment heat removal Complete eliminate failure from 11 12 56,000 73,000

residual heat removal service

water (RHRSW)Ioop B

59- Provide a cross-tie between RHRSW

trains downstream of the RHRSW pump

discharge valves 400,000

Turbine Bypass Eliminate CDF contribution due 10 7 42.000 52000

to loss of power conversion

system (PCS) initiator

60-Improve turbine bypass valve capability 745,000

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0

Table G-5. (cont)

% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Discount Discount

Population Rate(b) Rate(b) Cost

SAMA Assumptions CDF Dose ($) ($) ($)

Emergency Diesel Generators 21 24 116,000 149,000

62-Develop a procedure to open the Reduce probability of EDG to 10,000

doors of the EDG buildings upon receipt run failures by a factor of

of a high temperature alarm three.

Reactor Vessel Instrumentation Completely eliminate CDF 2 2 7,000 9,000

contribution due to loss of

reactor vessel water level

reference leg

63-Provide additional reactor vessel 1,200.000

monitoring and actuation system

(a) SAMAs in bold are potentially cost-beneficial

(b) Unless noted otherwise by Footnote (c) or (d). estimated benefits taken from Table S-1 in the supplemental information to the ER (Entergy 2006b)

(c) Estimated benefits taken from a revised assessment provided in response to RAI 5 7 (Entergy 2007)

(d) Estimated benefits taken from a revised assessment provided in response to RAI 5 1 (Entergy 2007)

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Appendix G

G.6 Cost-Benefit Comparison

Entergy's cost-benefit analysis and the NRC staff's review are described in the following

sections.

G.6.1 Entergy's Evaluation

The methodology used by Entergy was based primarily on NRC's guidance for performing costbenefit analysis, i.e., NUREG/BR-01 84, Regulatory Analysis Technical Evaluation Handbook

(NRC 1997a). The guidance involves determining the net value for each SAMA according to

the following formula:

Net Value = (APE + AOC + AOE + AOSC) - COE

where

APE = present value of averted public exposure ($)

AOC = present value of averted offsite property damage costs ($)

AOE = present value of averted occupational exposure costs ($)

AOSC = present value of averted onsite costs ($)

COE = cost of enhancement ($)

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the

benefit associated with the SAMA and it is not considered cost-beneficial. Entergy's derivation

of each of the associated costs is summarized below.

NUREG/BR-0058 has recently been revised to reflect the agency's policy on discount rates.

Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed, one at

3 percent and one at 7 percent (NRC 2004).

I NUREG-1437, Supplement 31 G-32 January 2008
Appendix G I

Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure (Aperson-rem/year)

x monetary equivalent of unit dose ($2000 per person-rem)

x present value conversion factor (10.76 based on a 20-year period with a

7-percent discount rate)

As stated in NUREG/BR-0184 (NRC 1997a), it is important to note that the monetary value of

the public health risk after discounting does not represent the expected reduction in public

health risk due to a single accident. Rather, it is the present value of a stream of potential

losses extending over the remaining lifetime (in this case, the renewal period) of the facility.

Thus, it reflects the expected annual loss due to a single accident, the possibility that such an

accident could occur at any time over the renewal period, and the effect of discounting these

potential future losses to present value. For the purposes of initial screening, which assumes

elimination of all severe accidents due to internal events, Entergy calculated an APE of

approximately $35,000 for the 20-year license renewal period.

Averted Offsite Property Damage Costs (A OC)

The AOCs were calculated using the following formula:

AOC = Annual CDF reduction

x offsite economic costs associated with a severe accident (on a per-event basis)

x present value conversion factor

For the purposes of initial screening, which assumes all severe accidents due to internal events

are eliminated, Entergy calculated an annual offsite economic risk of about $3,300 based on

the Level 3 risk analysis. This results in a discounted value of approximately $36,000 for the

20-year license renewal period.

January 2008 G-33 NUREG-1437, Supplement 31 I
Appendix G

Averted Occupational Exposure (AOE) Costs

The AOE costs were calculated using the following formula:

AOE = Annual CDF reduction

x occupational exposure per core damage event

x monetary equivalent of unit dose

x present value conversion factor

Entergy derived the values for averted occupational exposure from information provided in

Section 5.7.3 of the regulatory analysis handbook (NRC 1997a). Best estimate values

provided for immediate occupational dose (3300 person-rem) and long-term occupational dose

(20,000 person-rem over a 10-year cleanup period) were used. The present value of these

doses was calculated using the equations provided in the handbook in conjunction with a

monetary equivalent of unit dose of $2000 per person-rem, a real discount rate of 7 percent,

and a time period of 20 years to represent the license renewal period. For the purposes of initial

screening, which assumes all severe accidents due to internal events are eliminated, Entergy

calculated an AOE of approximately $1,000 for the 20-year license renewal period.

Averted Onsite Costs

Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted

power replacement costs. Repair and refurbishment costs are considered for recoverable

accidents only and not for severe accidents. Entergy derived the values for AOSC based on

information provided in Section 5.7.6 of NUREG/BR-0184, the regulatory analysis handbook

(NRC 1997a).

Entergy divided this cost element into two parts - the onsite cleanup and decontamination cost,

also commonly referred to as averted cleanup and decontamination costs, and the replacement

power cost.

Averted cleanup and decontamination costs (ACC) were calculated using the following formula:

ACC = Annual CDF reduction

x present value of cleanup costs per core damage event

x present value conversion factor

The total cost of cleanup and decontamination subsequent to a severe accident is estimated in

the regulatory analysis handbook to be $1.5 x 109 (undiscounted). This value was converted to

I NUREG-1437, Supplement 31 G-34 January 2008
Appendix G I

present costs over a 10-year cleanup period and integrated over the term of the proposed

license extension. For the purposes of initial screening, which assumes all severe accidents

due to internal events are eliminated, Entergy calculated an ACC of approximately $32,000 for

the 20-year license renewal period.

Long-term replacement power costs (RPC) were calculated using the following formula:

RPC = Annual CDF reduction

x present value of replacement power for a single event

x factor to account for remaining service years for which replacement power is

required

x reactor power scaling factor

For the purposes of initial screening, which assumes all severe accidents due to internal events

are eliminated, Entergy calculated an RPC of approximately $22,000 for the 20-year license

renewal period.

Using the above equations, Entergy estimated the total present dollar value equivalent

associated with completely eliminating severe accidents from internal events at JAFNPP to be

about $125,000. Use of a multiplier of 4 to account for external events increases the value to

$500,000 and represents the dollar value associated with completely eliminating all internal and

external event severe accident risk at JAFNPP.

Entergy's Results

If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA

was considered not to be cost-beneficial. In the baseline analysis contained in the ER (using a

7 percent discount rate, and considering the combined impact of both external events and

uncertainties), Entergy identified five potentially cost-beneficial SAMAs. The potentially costbeneficial SAMAs are:

* SAMA 26 - provide additional DC battery capacity to ensure longer battery capability

during the station blackout event, which would extend HPCI/RCIC operability and allow

more time for AC power recovery.

* SAMA 30 - modify plant equipment to provide 16-hour SBO injection to improve

capability to cope with longer SBO scenarios.

* SAMA 36 - modify plant equipment to extend DC power availability in an SBO event,

which would extend HPCI/RCIC operability and allow more time for AC power recovery.

January 2008 G-35 NUREG-1437, Supplement 31 I
Appendix G

" SAMA 61 - modify plant procedures to allow use of a portable power supply for battery

chargers, which would improve the availability of the DC power system.

" SAMA 62 - modify plant procedures to open the doors of the EDG buildings upon

receipt of a high temperature alarm, which improves the reliability of the EDGs following

high temperatures in the EDG buildings.

Entergy performed additional analyses to evaluate the impact of alternative discount rates and

remaining plant life on the results of the SAMA assessment. No additional SAMA candidates

were determined to be potentially cost-beneficial (Entergy 2006a). In'supplemental information

to the ER, Entergy provided a revised assessment based on a separate accounting of

uncertainties. The revised assessment resulted in identification of the same potentially costbeneficial SAMAs. However, based on further consideration of potentially cost-beneficial

SAMAs at other plants, Entergy identified one additional potentially cost-beneficial SAMA for

JAFNPP (Entergy 2006b). The potentially cost-beneficial SAMAs, and Entergy's plans for

further evaluation of these SAMAs are discussed in more detail in Section G.6.2.

G.6.2 Review of Entergy's Cost-Benefit Evaluation

The cost-benefit analysis performed by Entergy was based primarily on NUREG/BR-0184

(NRC 1997a) and was conducted consistent with this guidance.

In the ER, Entergy evaluated the reduction in risk for each SAMA in the context of an upper

bound analysis which combined the impact of external events with the impact of uncertainty.

The impact of external events was considered by applying a multiplier of 4.1 to the estimated

SAMA benefits in internal events (1 + [fire CDF of 8.53 x 10-6 per year] / [internal events CDF of

2.74 x 10-6 per year]). The impact of uncertainties was considered by applying an additional

multiplier of 3.83, which represents the ratio of the 95th percentile CDF to the mean CDF for

internal events. Entergy bounded the combined impact of external events and uncertainties by

applying a multiplier of 16 to the estimated SAMA benefits in internal events.

In an RAI, the NRC staff requested that the baseline evaluation be revised to include only the

impact of internal and external events (without uncertainties), and that the impact of analysis

uncertainties on the SAMA evaluation results be considered separately (NRC 2006). In

supplemental information to the ER, Entergy revised the baseline benefit values by applying a

multiplier of 4 to the estimated SAMA benefits in internal events to account for potential SAMA

benefits in both internal and external events (Entergy 2006b).

As a result of the revised baseline analysis (using a multiplier of 4 and a 7 percent real discount

rate), Entergy found that the same five SAMA candidates (mentioned above) remained

potentially cost-beneficial. No additional SAMA candidates were found to be potentially costbeneficial. When benefits were evaluated using a 3 percent discount rate, as recommended in

I NUREG-1437, Supplement 31 G-36 January 2008
Appendix G

NUREG/BR-0058, Revision 4 (NRC 2004), no additional SAMAs were determined to be

potentially cost-beneficial.

Entergy considered the impact that possible increases in benefits from analysis uncertainties

would have on the results of the SAMA assessment. In the ER, Entergy presents the results of

an uncertainty analysis of the internal events CDF which indicates that the 95 percentile value is

a factor of 3.83 times the mean CDF. Entergy re-examined the Phase II SAMAs to determine if

any would be potentially cost-beneficial if the revised baseline benefits were increased by an

additional factor of 4. No additional SAMAs were identified.

The NRC staff questioned the ability of several of the candidate SAMAs identified in the ER to

accomplish their intended objectives or provide the estimated risk reductions (NRC 2006). In

response to the RAI, Entergy provided revised or new evaluations as discussed below.

Phase II SAMA 57, control containment venting within a narrow pressure band, was

identified as a potential SAMA to further reduce the risk contribution from basic event

NVP-XHE-FO-LVENT, operator fails to vent containment using the direct torus vent.

This SAMA would be subject to the same failure-to-vent human error as in the basic

event. The NRC staff questioned both the risk reduction estimate provided by Entergy

for this SAMA, as well as whether an alternative SAMA to create a passive vent system

might be more effective in reducing the risk from this event and be cost-beneficial

(NRC 2006).

In the ER, Entergy estimated the benefit of controlling containment venting within a

narrow pressure band by reducing the probability of operator failure to vent by a factor

of 3. In supplemental information to the ER, Entergy included a sensitivity analysis in

which continued vessel injection from LPCI or Core Spray was credited for those

sequences in which torus venting is successful and alternative injection systems fail after

torus venting (Entergy 2006b). Since the available net positive suction head (NPSH) is

likely to be less than the required NPSH with the vent open, a failure probability of 0.9

was assigned for this new success path. The PSA model change resulted in about a

0.5-percent reduction in CDF, a 0.6-percent reduction in population dose, and a benefit

(including the impact of uncertainties) of approximately $10,000. Entergy concluded that

the original benefit values reported for SAMA 57 (and reported in Table G-5) are more

conservative (Entergy 2006b). Therefore, this SAMA continues to not be cost-beneficial

at JAFNPP.

The NRC staff also asked the applicant to provide an evaluation of the costs and

benefits of converting the vent system to a passive design. In response, Entergy

evaluated a new SAMA that would convert the existing torus vent to a passive torus vent

(Entergy 2007). The benefit of this SAMA was conservatively estimated by removing

operator failure to implement torus venting (NVP-XHE-FO-LVENT was set to zero).

Entergy estimated that this modification would result in a CDF reduction of about

January 2008 G-37 NUREG-1 437, Supplement 31 1
Appendix G

18 percent, a population dose reduction of about 20 percent, and a benefit (7 percent

baseline with uncertainty) of approximately $377,000. However, Entergy estimated the

cost of implementing this SAMA to be greater than $1 M. Therefore, this SAMA

alternative would not be cost-beneficial at JAFNPP.

Phase II SAMA 61, develop a procedure to use a portable power supply for battery

chargers, was identified as a potential SAMA to improve DC system reliability. The staff

questioned the risk reduction estimate provided by Entergy for this SAMA since the

events identified as being eliminated for the analysis were not included in the list of risk

significant events in ER Table E.1-2. In response to an NRC staff RAI, Entergy

performed a revised evaluation by eliminating failures of both DC battery chargers and

both 125-V DC battery boards. The PSA model change resulted in about a 2-percent

reduction in CDF, a 2-percent reduction in population dose, and a benefit (including the

impact of uncertainties) of approximately $40,000. Entergy concluded that this SAMA

remains potentially cost-beneficial (Entergy 2007).

The NRC staff noted that for certain SAMAs considered in the ER, there may be alternatives

that could achieve much of the risk reduction at a lower cost. Several of these alternatives were

evaluated by Entergy subsequent to the ER, and described in the supplemental information to

the ER (Entergy 2006b). One such alternative involves use of a portable generator to extend

the coping time in loss of AC power events (to power battery chargers). Based on a bounding

analysis in which the probability of non-recovery of offsite power for 7 hours was changed to

24 hours for SBO scenarios, this alternative was estimated to result in a CDF reduction of about

39 percent, a population reduction of 44 percent, and a benefit (including impact of

uncertainties) of $838,000. Since the estimated cost of implementing and using the portable

generator is $712,000, Entergy concluded that this SAMA is potentially cost-beneficial to

JAFNPP.

The NRC staff asked the applicant to evaluate several additional lower cost alternatives to the

SAMAs considered in the ER. These alternatives included: (1) use a portable generator to

provide alternate DC feed to panels supplied only by the DC bus, (2) addition of a redundant

diesel fire pump to address event FXT-ENG-FR-76P1, diesel driven fire water pump 76P-1 fails

to continue to run (an alternative to SAMA 49, which involves addition of an entire new injection

system), and (3) several additional alternatives (NRC 2006). Entergy provided a further

evaluation of these alternatives, as summarized below.

Use of a portable generator to provide power to an individual 125 VDC Motor Control

Center (MCC), which would support returning HPCI to service in the event its bus was to

fail -- Based on a bounding analysis in which failure of the HPCI system was eliminated,

this alternative was estimated to result in a CDF reduction of about 3 percent, a

population dose reduction of 1 percent, and a benefit (including impact of uncertainties)

of $34,000 (Entergy 2006b). However, Entergy estimated the cost of implementing this

I NUREG-1437, Supplement 31 G-38 January 2008
Appendix G I

alternative to be approximately $700K. Therefore, this alternative would not be costbeneficial at JAFNPP.

Use of a third redundant diesel fire pump to address event FXT-ENG-FR-76PI -- Based

on a bounding analysis in which events FXT-EG-FR-76PI and FPS-MAI-MA-P4 are set

to zero in the PSA model, this alternative was estimated to result in a CDF reduction of

about 1 percent, a population dose reduction of 1 percent, and a benefit (including the

impact of uncertainties) of $20,000. However, Entergy estimated the cost of

implementing this alternative to be approximately $2M (Entergy 2007). Therefore, this

alternative would not be cost-beneficial at JAFNPP.

* Entergy indicated that the remaining low cost alternatives identified in the RAI are

already implemented or already addressed by existing plant procedures.

In response to an NRC staff RAI, Entergy indicated that the five potentially cost-beneficial

SAMAs identified in the ER plus the one additional potentially cost-beneficial SAMA identified in

the supplemental information to the ER have all been entered into the licensee's engineering

request process to be evaluated for implementation (Entergy 2007). SAMAs 26, 30, 36 and the

one additional SAMA were combined into a single engineering request to determine and

implement the best approach to extend station battery capacity. SAMA 61 has been approved

as a minor modification and is scheduled for installation for late 2007. SAMA 62 was

implemented in November 2006 by revising applicable annunciator response procedures.

The NRC staff notes that all of the potentially cost-beneficial SAMAs identified in either

Entergy's baseline analysis or uncertainty analysis are included within the set of SAMAs that

Entergy plans to further evaluate. The NRC staff concludes that, with the exception of the

potentially cost-beneficial SAMAs discussed above, the costs of the other SAMAs evaluated

would be higher than the associated benefits.

G.7 Conclusions

Entergy compiled a list of 293 SAMAs based on a review of: the most significant basic events

from the plant-specific PSA, insights from the plant-specific IPE and IPEEE, Phase II SAMAs

from license renewal applications for other plants, and review of other NRC and industry

documentation. A qualitative screening removed SAMA candidates that (1) were not applicable

at JAFNPP due to design differences, (2) had already been implemented at JAFNPP, or (3)

were similar and could be combined with another SAMA. Based on this screening, 230 SAMAs

were eliminated leaving 63 candidate SAMAs for evaluation.

For the remaining SAMA candidates, a more detailed design and cost estimate were developed

as shown in Table G-5. The cost-benefit analyses showed that five of the SAMA candidates

January 2008 G-39 NUREG-1 437, Supplement 31 I
Appendix G

were potentially cost-beneficial in the baseline analysis (Phase II SAMAs 26, 30, 36, 61, and

62). Entergy performed additional analyses to evaluate the impact of parameter choices and

uncertainties on the results of the SAMA assessment. No additional SAMAs were identified as

potentially cost-beneficial in the ER. However, as a result of additional analysis, Entergy

concluded that one additional SAMA is potentially cost-beneficial, i.e., use of a portable

generator to extend the coping time in loss of AC power events. Entergy has indicated that the

potentially cost-beneficial SAMAs have been entered into the engineering request process to be

evaluated for implementation. The NRC staff concluded that all of these SAMAs are potentially

cost-beneficial.

The NRC staff reviewed the Entergy analysis and concludes that the methods used and the

implementation of those methods was 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, 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 inclusion of a multiplier to account for external events.

The NRC staff concurs with Entergy's identification of areas in which risk can be further reduced

in a cost-beneficial manner through the implementation of the identified, potentially costbeneficial SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff agrees

that further evaluation of these SAMAs by Entergy is warranted. 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 Title 10 of the

Code of Federal Regulations, Part 54.

G.8 References

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

Renewal of Operating Licenses for Nuclear Power Plants."

Brown, W. 2005. "Baseline Population Projections Nysis Projects SEP02," New York Statistical

Information System, Ithaca, New York, available URL: http://www.nysis.cornell.edu/data.html/

(accessed May 12, 2005).

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006a.

James A. FitzPatrick Nuclear Power Plant --- License Renewal Application, Appendix E:

Applicant's Environmental Report, Operating License Renewal Stage. Lycoming, New York.

Accessible at ML062160557.

I NUREG-1437, Supplement 31 G-40 January 2008
Appendix G

U.S. Nuclear Regulatory Commission (NRC). 1994. "Staff Evaluation of the FitzPatrick

Individual Plant Examination (IPE) (Internal Events Only), (TAC No. M7441 1)." Washington,

D.C. May 9,1994.

U.S. Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation

Handbook. NUREG/BR-0184. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997b. Individual Plant Examination Program:

Perspectives on Reactor Safety and Plant Performance. NUREG-1 560. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997c. Code Manual for MACCS2: Volume 1,

User's Guide. NUREG/CR-6613. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2000a. "James A. FitzPatrick Nuclear Power

Plant - Review of Individual Plant Examination of External Events (IPEEE) Submittal (TAC

No. M83622)." Washington, D.C. September 21, 2000. Not publicly available.

U.S. Nuclear Regulatory Commission (NRC). 2000b. Letter from Guy S. Vissing, U.S. NRC, to

James Knubel, JAFNPP. Subject: James A. FitzPatrick Nuclear Power Plant - Plant-Specific

Safety Evaluation Report for Unresolved Safety Issue (USI) A-46 Program Implementation at

FitzPatrick Nuclear Power Plant (TAC No. M69446). April 12, 2000. Accessible at

ML003702154.

U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S.

Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4. Washington, D.C.

U.S. Nuclear Regulatory Commission. 2006. Letter from Samuel Hernandez, U.S. NRC, to

Michael Kansler, Entergy. Subject: Request for Additional Information Regarding Severe

Accident Mitigation Alternatives for James A. FitzPatrick Nuclear Power Station (TAC No.

MD2667). November 29, 2006. Accessible at ML063060257.

I NUREG-1437, Supplement 31 G -42 January 2008
Appendix G I

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2006b.

Letter from Pete Dietrich, Entergy, to NRC Document Control Desk. Subject: "Entergy Nuclear

Operations, Inc., James A. FitzPatrick Nuclear Power Plant, Docket No. 50-333, License No.

DPR-59, License Renewal Application, Amendment 1," JAFP-06-0167, Lycoming, New York,

dated December 6, 2006. Accessible at ML063480624.

Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy). 2007. Letter

from Pete Dietrich, Entergy, to NRC Document Control Desk. Subject: "Entergy Nuclear

Operations, Inc., James A. FitzPatrick Nuclear Power Plant, Docket No. 50-333, License No.

DPR-59, License Renewal Application, Amendment 4," JAFP-07-0013, Lycoming, New York,

dated January 29, 2007. Accessible at ML070370170.

Electric Power Research Institute (EPRI). 1991. "A Methodology for Assessment of Nuclear

Power Plant Seismic Margin," EPRI NP-6041-SL, Revision 1, Palo Alto, CA. August 1991.

KLD Associates, Inc. 2003. "Nine Mile Point/JA Fitzpatrick Nuclear Facility Development of

Evacuation Time Estimates," Report KLD TR 370.359. Commack, New York, August 2003.

New York Power Authority (NYPA). 1991. "James A. FitzPatrick Nuclear Power Plant Docket

No. 50-333, Individual Plant Examination,"(JPN-91-048). September 1991.

New York Power Authority (NYPA). 1996. "James A. FitzPatrick Nuclear Power Plant Individual

Plant Examination for External Events," (JAF-RPT-MISC-0221 1), Revision 0. June 1996.

Seismic Qualification Users Group (SQUG). 1992. "Generic Implementation Procedure (GIP) for

Seismic Verification of Nuclear Plant Equipment," Revision 2, Corrected. February 14, 1992.

U.S. Department of Agriculture (USDA). 2002. "2002 Census of Agriculture." Available URL:

http://www.nass.usda.gov/Census-of Agriculture/index.asp. (Accessed April 26, 2005).

Accessible at ML071200083.

U.S. Nuclear Regulatory Commission (NRC). 1988. Generic Letter 88-20, "Individual Plant

Examination for Severe Accident Vulnerabilities." November 23, 1988.

U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment

for Five U.S. Nuclear Power Plants. NUREG-1 150. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1991a. "Procedural and Submittal Guidance for

the Individual Plant Examination of External Events (IPEEE) for Severe Accident

Vulnerabilities," NUREG-1407. Washington, D.C. June 1991.

U.S. Nuclear Regulatory Commission (NRC). 1991b. Generic Letter No. 88-20, Supplement 4,

"Individual Plant Examination of External Events for Severe Accident Vulnerabilities," NUREG1407. Washington, D.C. June 28,1991.

January 2008 G-41 NUREG-1437, Supplement 31
NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(9-2004) (Assigned by NRC, Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numbers, if any.)

BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse) NUREG-1437, Supplement 31

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

Generic Environmental Impact Statement for License Renewal of Nuclear Plants MONTH YEAR

Supplement 31

Regarding James A. FitzPatrick Nuclear Power Plant January 2008

Final Report 4, FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

See Appendix B (NRC staff and Contract Support from Lawrence Livermore & Pacific Northwest

National Labs) Technical, Final

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.

provide name and mailing address.)

Division of License Renewal

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

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,

and mailing address.)

Same as Block 8.

10. SUPPLEMENTARY NOTES

50-333

11. ABSTRACT (200 words or less)

This final supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted to

the NRC by Entergy Nuclear FitzPatrick, LLC, and Entergy Nuclear Operations, Inc. (Entergy) to renew the operating license for

James A. FitzPatrick Nuclear Power Plant for an additional 20 years under 10 CFR Part 54. This final SEIS includes the NRC

staffs 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 NRC staffs recommendation regarding the proposed action.

The NRC staff's recommendation is that the Commission determine that the adverse environmental impacts of license renewal

for JAFNPP are not so great that preserving the option of license renewal for energy-planning decision makers would be

unreasonable. This recommendation is based on (1) the analysis and findings in the GELS; (2) the Environmental Report

submitted by Entergy; (3) consultation with Federal, State, and local agencies; (4) the staffs own independent review; and (5)

the staffs consideration of public comments received during the scoping process and on the draft SEIS.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT

Environmental Impact Statement, EIS unlimited

Supplemental EIS, SEIS 14. SECURITY CLASSIFICATION

JAFNPP, FitzPatrick, James A. FitzPatrick Nuclear Power Plant (This Page)

Final SEIS, FSEIS unclassified

Supplement to the Generic Environmental Impact Statement (This Report)

GElS unclassified

NEPA

Environmental 15. NUMBER OF PAGES

License Renewal

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER
Fedaral Recycling Program

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

OFFICIAL BUSINESS