### ENGINEERING FEASIBILITY A ND COSTS OF CONVERSION OF INDIAN POINT UNITS 2 AND 3 TO A CLOSED-LOOP CONDENSER COOLING WATER CONFIGURATION



## Prepared for Entergy Nuclear Indian Point 2, LLC, and Entergy Nuclear Indian Point 3, LLC

Prepared by:

Enercon Services, Inc. 500 TownPark Lane, Suite 275 Kennesaw, GA 30144

February 12, 2010CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

i 

### TABLE OF CONTENTS

Attachments ................................................................................................................... ............ iii Executive Summary ............................................................................................................. ...... iv 1 Background and Introductions ................................................................................................ 1 1.1 History ....................................................................................................................... ....... 1 1.2 Purpose and Scope of this Report .................................................................................... 6 2 Conceptual Design ............................................................................................................. ..... 7 2.1 Conversion of Unit 2 and Unit 3 ...................................................................................... 7 2.2 Conversion of Only Unit 2 ............................................................................................. 14 2.3 Conversion of Only Unit 3 ............................................................................................. 14 3 Station Operational Parameters ............................................................................................. 15 3.1 Administrative/Operating Limits ................................................................................... 15 3.2 Closed-Loop Operational Efficiency (PEPSE Analysis) ............................................... 16 4 Algonquin Pipeline Relocation ............................................................................................. 21 4.1 Pipeline Configuration ................................................................................................... 21 4.2 Feasibility of Relocation ................................................................................................ 22 4.3 Spectra Schedule and Cost Impacts ............................................................................... 23 5 Blasting ...................................................................................................................... ........... 25 5.1 Restrictions to Blasting at IPEC ..................................................................................... 25 5.2 Cost and Schedule Impacts ............................................................................................ 27 5.3 Blasting Outage Timing ................................................................................................. 28 6 Spoils Removal ................................................................................................................ ..... 29 6.1 Blasting Spoils................................................................................................................ 29 6.2 Contamination of Spoils ................................................................................................. 30 6.3 On-Site Relocation of Spoils .......................................................................................... 30 6.4 Off-Site Relocation of Spoils ......................................................................................... 30 6.5 Cost and Schedule Impacts ............................................................................................ 32 7 Cooling Tower Operation / Plume Emissions ...................................................................... 33 7.1 Water Consumption........................................................................................................ 33 7.2 Cooling Tower Plume Emissions ................................................................................... 38 7.3 Plume Abatement ........................................................................................................... 38 8 General Site Considerations .................................................................................................. 40 8.1 Aesthetic Impacts ........................................................................................................... 4 0 8.2 Archaeological Considerations ...................................................................................... 40 8.3 Local Zoning Restrictions .............................................................................................. 41 8.4 Sound Restrictions .......................................................................................................... 4 3 9 Construction and Outage Duration ....................................................................................... 45 9.1 Conversion of Unit 2 and Unit 3 .................................................................................... 46 9.2 Conversion of Only Unit 2 ............................................................................................. 47 9.3 Conversion of Only Unit 3 ............................................................................................. 48 10 Economic and Power Loss Estimates ................................................................................... 49 10.1 Initial Capital Costs .................................................................................................... 49 10.2 Lost Electrical Generation Du e to Construction Outage ............................................ 51CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

ii 10.3 Lost Electrical Generation Due to Ne w Condenser Operating Parameters and Parasitic Losses .............................................................................................................. ........... 51 10.4 Operations and Maintenance Costs ............................................................................ 52 11 Conclusions ................................................................................................................... ........ 54 11.1 Challenges to the NYSDEC Proposed Project ........................................................... 54 11.2 Duration of the NYSDEC Proposed Project............................................................... 55 11.3 Cost and Power Loss of the NYSDEC Proposed Project ........................................... 56 12 References .................................................................................................................... ......... 57CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

iii Attachments

Attachment 1 – 2003 Economic and Envir onmental Impacts Associated with Conversion of Indian Point Units 2 and 3 to a Closed-Loop Condenser Cooling Water Configuration

Attachment 2 – Post Modification Site Rendering and Conceptual Drawings Attachment 3 – Subsurface Radiological Cons iderations Related to Construction of Closed-Loop Cooling at Indian Po int Energy Center Units 2 and 3 (GZA GeoEnvironmental, Inc.) Attachment 4 – Closed-Loop Performance

Attachment 5 – Electrical Dist ribution Model Output Results Attachment 6 – Feasibility Evaluation of Relocating the Algonquin Gas Transmission Pipelines (Spectra Energy Transmission, LLC) Attachment 7 – Blasting Feasibility Study fo r Conversion of Indian Point Units 2 and 3 to a Closed-Loop Cooling Water C onfiguration (Precision Blasting Services)

Attachment 8 – Cultural / Historic Consid erations for Cooling Tower Feasibility

Attachment 9 – Construction Schedule Attachment 10 – Capital Cost EvaluationCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

iv Executive Summary Entergy Nuclear Indian Point 2, LLC, and Ente rgy Nuclear Indian Point 3, LLC (collectively, Entergy), have submitted a timely and complete renewal application for a State Pollutant Discharge Elimination System (SPDES) perm it (SPDES Permit NY0004472) for Indian Point Energy Center (IPEC) nuclear pow ered electric generating stati ons 2 and 3 (collectively, the Stations, individually Unit 2 and Unit 3). The New York State Departme nt of Environmental Conservation (NYSDEC) staff has proposed modifications in IPEC’s draft SPDES permit, including possible construction and operation of cooling towers in a closed-loop cooling configuration (NYSDEC Proposed Pr oject). Consideration of th e NYSDEC Proposed Project is subject to certain feas ibility and alternative technologies assessments, as directed by the NYSDEC Assistant Commissioner’s August 13, 2008 Interim Decision. Accordingly, NYSDEC may revisit its proposed modifications to the draft SPDES permit for IPEC and change them pursuant to Entergy’s closed-loop cooling feas ibility and alternative technologies reports. The Interim Decision provides th at Entergy must submit an engi neering report that addresses significant construction and opera tional considerations, associat ed with conversion of the Stations’ existing cooling water systems to cl osed-loop cooling, ta king into account site constraints, including, but not limited to, exis ting physical features an d the relocation of the Algonquin Gas Transmission pipeline s. As part of this feasib ility analysis of the NYSDEC Proposed Project, this Report supplements an d amends the preliminary 2003 Economic and Environmental Impacts Associated with Conversion of IPEC Un its 2 and 3 to a Closed-Loop Condenser Cooling Water Configuration Report (2003 Report), prepared by Enercon Services, Inc. (ENERCON).

ENERCON was retained to further evaluate the potential c onversion to closed-loop cooling. While different types of cooling towers exist, with varying levels of cost, performance, and impacts, the cooling tower configurations that could reasonably be considered for Unit 2 and Unit 3 are limited to a single 100% capacity round hybrid cooling tower for each Unit. Even with this configuration, several site-specifi c conditions have been identified at IPEC that would challenge the feasibility of the NYSDEC Proposed Project. Such challenges include, but are not limited to, the following:

 As TRC Environmental Corporat ion concluded, air emissions resulting from operation of the cooling towers would exceed the Natio nal Ambient Air Quality Standards for PM 10 and PM 2.5 . Saltwater cooling towers of the scale proposed at IPEC would typically be expected to produce plume emissions exceedi ng National Ambient Air Quality Standards in non-attainment areas (see discussion of San Onofre Nuclear Generating Station in Section 7.2).

 As Saratoga Associates, Landscape Architects, Architects, Engineers and Planners, P.C. concluded, construction of coo ling towers at IPEC may be incompatible with New York law and policy relating to scenic resources and aesthetic impacts.

 Archeological concerns have been identifie d that could affect the excavation schedule and, potentially, tower placement.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

v  The required tower configurations do not c onform to municipal la w, and Village of Buchanan officials are on reco rd in opposition to the constr uction of cooling towers at IPEC. As such, required local zoning a pprovals may be difficult to obtain.

 The topography of the IPEC site and general space constraints, in conjunction with the fact that the elevation of the tower basins mu st be sufficiently low to prevent damage to the condenser tubes, limit th e potential locations for coo ling towers. Where located, approximately 2 million cubic yards of soil a nd inwood marble bedroc k would need to be excavated in conjunction with tower constructio n. This exceeds 50% of the total crushed marble sold or used in the U.S. in 2007. Blast removal would be required to excavate large quantities of bedrock at the cooling tower locations and in the piping trenches outside of the Riverfront area. To avoid prolonged forced outag es, blasting operations are proposed to occur while both Units are online. For reference, blasting operations would produce quantities of broken rock equivalent to between 364 and 518 truck loads (20-cubic yard capacity) each day.

 Excavation in the Riverfront area would intersect ground water contamination plumes containing tritium and strontium, with potential for soil contamination, requiring sampling, analysis, handling, and disposal pr otocols. Additional construction delays beyond those identified in this Report may result from these conditions.

 Algonquin Gas Transmission pipeli nes currently exist where the Unit 3 tower would be constructed, requiring relocation of those facilities within the IPEC site. The Algonquin Gas Transmission pipelines supply approximate ly 50% of the natural gas demand in New England, and the pipelines’ owner has emphasize d that this supply cannot be interrupted, requiring accommodations that may cause furt her construction delay. This relocation also would require Federal Energy Re gulatory Commission (FERC) approval.

 Conversion of the Stations to closed-l oop cooling would be an unprecedented undertaking that would likely encounter unforeseen challenges during design and implementation that are not an ticipated or addressed here. The total duration of the NYSDEC Proposed Project is expected to extend almost 13 years. This schedule includes an 18-month design period be fore NYSDEC approval, a 36-month permitting and licensing period between NYSDEC approval of the project and the start of construction, and the expected construction duration of more than eight years, which includes an estimated 42 weeks of continuous forced outage, conducted s imultaneously, at both units. Of the eight-year construction schedule, approximately four year s would be required for drilling, blasting, and spoils removal. This constructi on timeframe reflects conditions that have arisen since the initial 2003 conceptual construction schedule, as well as additional analysis of the conditions described at that time, including the following:

 Excavation for the conversion to closed-loop cooling would overlap with areas of known radiological groundwater contamination, the reme diation of which is currently subject to NRC oversight. Development and employme nt of protocols fo r sampling, analysis, handling and disposal of contaminated soil and water may result in substantial construction delays.

 The relocation of the on-site Algonquin pipe lines must be undertaken and completed prior to any blasting work performed at the Unit 3 cooling tower location.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

vi Considering the conceptual nature of the curre nt design parameters, the lack of comparable retrofits, and typical unknown conditions that arise in major construction projects, this schedule represents a reasonably aggressive scenario. Significantl y longer durations than currently estimated could result.

The anticipated direct overnight capital cost for the conversion for both Unit 2 and Unit 3 is collectively estimated at a minimum of $1.19 billi on. The estimated cost includes relocation of the Algonquin Gas Transmission pipelines. As Unit 2 and Unit 3 have net capacities of 1078 MWe and 1080 MWe, respectively, a 42 week fo rced outage at both Units 2 and 3, accounting for a coincident maintenance outage at one Unit, would result in approximately 14,502,000 MWhr of lost electrical gene ration, significantly incr easing the overall costs of conversion and adverse environmental impacts. A subsequent report will address forced outage costs specifically, as well as related impacts. 1

As a result of conversion, the Stations would also incur ongoi ng operational and parasitic electrical generation losses. Averaged across the entire year, the combined operational and parasitic losses would be approximately 88.2 MWe; however, operational power losses would increase to approximately 157.8 MWe during the peak summer pow er generation season. Again, this report does not di rectly calculate the impacts of lost electrical generation. In addition to ongoing operational and parasitic losses, the Stat ions would also incur annual operations and maintenance costs due to the NYSDEC Proposed Project. Annual operations and maintenance costs associated with closed-loop cooling at the Stations would be more than $4 million for the first five years, with increasing costs in the subsequent years due to the need for increased equipment replacement and repair. No nuclear stations designed solely for once-th rough cooling have been c onverted to closed-loop cooling. Conversion of the condenser cooling syst em of an existing plant presents fundamental design problems that result in plant performance impacts or require rede sign of the condenser. At the Stations, the expected performance impacts could not be mitigated by condenser modifications without the complete reconstruction of the turbine building. Moreover, absent any practical history of closed-loop co oling retrofits at nu clear facilities, engineering observations and conclusions regarding any such conversion mu st be made on a purely speculative basis and are inherently subject to unforeseen challe nges during the detailed design phase and the subsequent implementation. As such, the cost an d schedule estimates presented herein are likely understated, representing a lowe r bound for the cost and durations for the actual project. In addition, due to the untried nature of this type of conversion and the intrusive plant modifications that would be required, the feasibility of a closed -loop cooling retrofit at a nuclear facility cannot be guaranteed at any point in the design stage. Only upon successful operation of a completed closed-loop cooling retrofit could th is type of conversion be conc lusively considered feasible.

1 Entergy’s legal counsel has directed that forced outage costs be considered, consistent with the Interim Decision, under New York’s State Environmental Quality Review Act (“SEQRA”) and/or an economic test not currently defined by NYSDEC in a separate assessment, and accordingly need not be addressed now.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

1 

## 1 Background and Introductions

1.1 History
Unit 2 and Unit 3 were each approved for se rvice by the New York Public Service Commission in the mid-1970s to meet a demonstrated need for electric po wer. Both Units are pressurized water reactors (PWRs) with net capacities of 1078 MWe and 1080 MWe for Unit 2 and Unit 3, respectively. Loca ted on the east side of the H udson River in the Village of Buchanan, each Unit utilizes a once-through t ype condenser cooling water system (i.e., circulating water (CW) system), with the inta kes from and a shared discharge canal to the Hudson River. The design flow rate of the CW system (i.e., CW system capacity) for each unit is 840,000 gpm.



### 1.1.1 PWR System Operation
Unit 2 and Unit 3 are Westinghouse four-loop PWRs. PWRs consist of two separate systems: a closed, pressurized reactor cool ant system (primary system), and a power conversion system (secondary system) for th e generation of elec tricity. The basic configuration of a typical PWR is shown in Figure 1.1. In the primary system, reactor coolant is heated by nuclear fission in the re actor. The primary sy stem operates at high pressure to prevent the production of steam in the reactor. The heated reactor coolant is used in the steam generators to produce steam in the secondary system. The steam formed in the steam generator is transferred by the s econdary system to the main turbine generator, where it is converted into el ectricity. After passing through the low pressure turbine, the steam is routed to the main condenser, whic h is operated at a vacuum to allow for the greatest removal of energy by the low pressure turbines. The steam is condensed into water in the condenser by the flow of circula ting water through the c ondenser tubes. The water is then pumped back to the steam gene rator for reuse. The primary and secondary systems are physically separated in the steam generator, minimizing radioisotope transfer to the secondary system. The power output of the reacto r, and the outlet temperature of the reactor coolant, are controlled by adjusting severa l factors which affect the co re’s reactivity. The reactor control system is designed to avoid nuclear pl ant transients for prescribed design load perturbations. Long-term regulation of the co re reactivity is accomplished by adjusting the concentration of boric acid in the reactor c oolant, while short term reactivity control for power changes or reactor trip is accomplishe d by the movement of control rod clusters [Ref. 12.7].CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

2 Figure 1.1 Basic Arrangement of a PWR



### 1.1.2 Circulating Water System Background
The circulating water systems for Unit 2 and Unit 3 each consist of six circulating water pumps that draw water from the Hudson River and discharge into the inlet water boxes of their respective condensers. E ach circulating water pump has a design intake flow capacity of 140,000 gpm and is housed in an individual we ll within each unit’s consolidated cooling water intake structure (CWIS). Unit 2 and Unit 3 have separate CWISs, each configured with central service water intake channels lo cated between three circ ulating water channels on each side. The CWISs contain bar racks that filter debris, and coarse mesh traveling water screens that filter fish and residual debris from the intake water prior to the circulating water pumps suction. Unit 2 contains six Allis Chalmers dual speed circulating water pumps rated at 140,000 gpm at 21 feet total dynamic h ead (TDH) when running at 254 rpm, and 84,000 gpm and 15 feet of total dynamic head when running at 187 rpm. Unit 3 contains six Allis Chalmers variable speed pumps that are rated for 140,000 gpm at 29 ft TDH when running at 360 rpm and 84,000 gpm at 19.5 ft TDH when running at 250 rpm. The circulating water pumps discharg e through 84 inch header s to the inlet water boxes and the circulating water subseque ntly passes through th e condenser tubes condensing steam admitted from the turbines. Flow from the condenser outlet waterboxes of Unit 2 and Unit 3 is discha rged through 96 inch piping, and combines in the discharge tunnel prior to being returned to th e Hudson River via the discharge canal.



### 1.1.3 Novelty of Closed-Loop Cooling Retrofits
No nuclear power plant designed for once-thro ugh cooling has ever been retrofitted to closed-loop condenser cooling. One nuclear power plant, Pa lisades Nuclear Generating Station (PNGS), although initia lly designed for once-through cooling, was redesigned for closed-loop cooling during construction; co nsequently, the circulating water system MSR

Hudson RiverCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

3 components, particularly the condensers, were sized to accommodate the expected heat rejection capability prov ided by cooling towers. Absent any practical history of closed-loop cooling retrofits at nuclear facilities, engineering observations and co nclusions regarding any such conversion must be made on a purely speculative basis and ar e inherently subject to unforeseen challenges, with a corresponding, potentially large, degree of uncertainty. Thus, conclusions about feasibility, while based on best professional judgment, do not have the benefit of either available technology or past efforts at comparable facilities. Due to the untried nature of this type of conversion and th e intrusive plant modifications that would be required, the feasibility of a closed-loop coo ling retrofit at a nuclear facili ty cannot be guaranteed at any point in the design stage. Only upon su ccessful operation of a completed closed-loop cooling retrofit could this t ype of conversion be conclusi vely considered feasible. Likewise, only direct comparison to a successf ul closed-loop cooling retrofit could provide reliable basis for cost estimates. For this assessment, cost estimates were done in such a way as to minimize the necessary assumptions, and relied instead on well-developed, detailed conceptual designs. However, give n the absence of any practical applications, costs are likely to be understated.



### 1.1.4 Conclusions from the 2003 Report
In 2003, ENERCON performed a preliminary eval uation of the feasib ility of converting IPEC Units 2 and 3 to closed-loop cooling, an d an assessment of the associated economic and environmental impacts (see Attachment 1). The 2003 Report concluded that conversion of IPEC to closed -loop cooling would be theoretic ally feasible; however, with appreciable elevation changes, a general lack of available space, a subsurface primarily composed of solid rock, the location of a major interstate gas pipeline, local air quality, archeological and aesthetic considerations, etc., significant site-specific challenges existed. This Report further investigates these and ot her challenges to a cl osed-loop conversion of IPEC. There are various methods for heat rejecti on from a closed-loop cooling system, including cooling ponds, canals, and towers. Howeve r, the 2003 Report concluded that cooling towers would be the only heat rejecti on method not rendered infeasible by space constraints at IPEC. Several cooling tower types were evaluated: natural-draft towers, mechanical-draft towers, and hybrid towers.

Conversion of the condenser co oling system of an existing plant presents fundamental design problems. The design of the condenser and turbine is based on the anticipated temperature of the condenser cooling water. If the condenser cooli ng water were not as cold as the original once-th rough design requires for optimal performance, then the condenser heat rejection would be reduced a nd the backpressure on the turbine increased. With an increase of backpressure on the turbine, performance is significantly affected, and ultimately generator output is reduced. The 2003 Report determined that cooling towers, through evaporative cooling, could not match the low temperature of th e River intake. In the winter months the impact would be le ssened, but during the summer performance would suffer appreciably.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

4 Due to IPEC-specific zoning and permitting c onstraints, a tower with visible plume abatement and noise abatement was deemed necessary. Additionally, due to the rocky terrain and rapid elevation changes, a tower with a minimum footprint was selected to reduce overall excavation and clearing. A si ngle round hybrid cooling tower for each Unit was found to most closely meet each Unit’s performance needs. A hybrid, also referred to as a “wet/dry” or “plume abated” cooling tower, addresses many of the shortcomings of other t ypes of cooling tower, particul arly as applies to the IPEC site. Basically, a hybrid tower is the combin ation of the wet tower, with its inherent cooling efficiency, and a dry heat exchanger section used to reduce or eliminate visible plumes in the majority of atmospheric conditi ons. After the plume l eaves the lower “wet” section of the tower, it travels upward through a “dry” section where heated, relatively dry air is mixed with the plume in the proportions required to achieve a non-visible plume in most circumstances. Figure 1.2 illustrates the air flow path through a cell of a parallel path hybrid tower, and the applicable simplified psychrometric chart.

Figure 1.2 Partial Desaturation of Air in a Parallel Path Hybrid Tower A hybrid cooling tower is designed to signifi cantly reduce both the apparent density and the persistency of the plume. Incoming hot water flows first through the dry heat exchanger (finned coil) sections, then through the wet (evaporative cooling) fill section. Parallel streams of air flow across the coil s ections and through the fill sections, leaving the coil sections at dry condi tion 3, and leaving the fill se ctions at saturated condition 2. These two separate streams of air then mix together going through the fans, along the lines 3-4 and 2-4 respectively, exiting the fan cylinde r at sub-saturated condition 4. This exit air then returns to ambient conditions along line 4-1, avoiding the region of super-saturation (visible plume) in most cases.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

5 Figure 1.3 Round Hybrid Tower versus Lin ear Cell-Type Hybrid Tower As detailed in the 2003 Report, the round hybr id tower has the following attributes and features (see Figure 1.3):

 The concentrated center plume is not susceptib le to recirculation to the tower inlets, improving tower performance. Additionall y, the center plume is discharged at a higher elevation, approximately 165 feet, a nd reaches significantly greater heights due to the flow velocity and thermal con centration created by the central discharge shroud. This feature promotes distribution of entrained salts over a much larger area, thus lowering local concentr ations, and reducing ground level plumes that could compromise Station systems, including plant security.

 The round tower has an appreciably smalle r size footprint than an equal capacity linear tower. With the high excavation co sts at IPEC, the smaller footprint would facilitate construction. Th e round design, at approximately 500 feet in diameter for the required capacity for each Unit, compares favorably to a linear tower that could approach 1500 feet in length, running parallel to the River shore.

 Less piping, in a simpler configuration, is required for a round tower. Supply and return piping is required for each cooling to wer. To provide cooling for either Unit 2 or 3, a single round tower or a pair of linear towers would be requi red. In addition to the requirement for more towers, linear towe rs are also subject to more restrictive siting requirements. Siting re strictions can sign ificantly increase piping requirements due to the need for adequate spacing betw een towers and also between towers and other buildings.

 Dedicated fans for the dry and wet sections of the round hybrid allows efficient tower usage, with the dry section fans opera ting at reduced capacity when ambientCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

6 conditions don’t dictate their usage for plume control. Linear, cell-type hybrid towers have a single fan per cell, inducing flow through both sections, hence operate at full fan power at all times. The conceptual design provided in the 2003 Report balanced the siting of each cooling tower against the site terrain and proximity to each Turbine Building to minimize the excavation required. Siting was also constr ained by the maximum cooling tower basin elevation, which was fixed by the maximum pre ssure allowable throu gh the condenser. The cooling tower supply and return piping wa s also concentrated into two 122-inch and two 144-inch concrete lined steel pipes for each cooling tower to minimize the excavation required and reduce capital costs. Because any changes to the condenser cooling systems would involve the very heart of the plant, construction in the Rive rfront area and tie-in with the condenser cooling systems would have to be completed with both Units in a forced outage. Although much of the excavation work and cooling tower erection could be done pre-outag e, new circulating water pumping stations and changes to the co mmon discharge canal force a major outage.



### 1.2 Purpose and Scope of this Report
Although the existing once-through circulating water scheme provides both the lowest cost method of condenser cooling and supports the highest level of Station capacity, IPEC has been required by the NYSDEC to further evaluate possible conversion of the existing system to a closed-loop circulating water system configur ation. The overall purpose and scope of this Report is to determine feasibility of the NYS DEC Proposed Project and, also, update the 2003 Report in order to achieve a higher measure of certainty, with appropriate defined ranges, for the costs of retrofitting with cl osed-loop cooling and the schedule for doing so. This includes further development of the initial conceptual design to a level of detail commensurate with more accurate subsequent cost estimates, upda ting the previously estimated construction and procurement costs to the current dollar value, addressing additional impacts and new site conditions identified since the 2003 Report, and updating construc tion costs and outage schedules to account for additional analysis pe rformed since the orig inal report submittal.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

7 

## 2 Conceptual Design

As discussed in Section 1.1.3, there have been no conversions of exis ting operating nuclear stations from once-through to cl osed-loop cooling. Due to this uncertainty, an investigative analysis on the impact of closed-loop cooling on plant systems, operation, and electrical output must be considered. Conversion to closed-loop cooling would represent a massive and difficult engineering and cons truction undertaking. Three design alternatives are considered for cl osed-loop cooling at IPEC : (1) retrofit both Units to closed-loop cooling, (2) retrof it only Unit 2 to closed-loop coo ling, or (3) retrofit only Unit 3 to closed-loop cooling. Con ceptual designs, including major plant modifications, have been developed for all three alternat ives consistent with the conc lusions of the 2003 Report (Section 1.1.4). The conceptual designs ar e based on summary level scope intended to identify challenges and predict budgetary costs.



### 2.1 Conversion of Unit 2 and Unit 3

The conversion of both Units 2 and 3 to closed -loop cooling would require the installation of two 100% capacity round hybrid cooling towers and the associated piping and equipment (Attachment 1). The cooling towers would need to be placed to the northeast and southwest of the Stations, as shown in Attachment 2, Sketch ENTGNU011-SK-001. Construction of the Unit 3 cooling tower would require relocation of the Algonquin Gas Transmission pipelines, as discussed in Section 4. Each cooling towe r would be approximately 165 feet tall and 525 feet in diameter (Attachment 1).



### 2.1.1 Circulating Water System Piping
The new circulating water piping would need to be routed from new circulating water pumps to the cooling towers and back to th e condenser. The coo ling tower supply piping would need to be two 120-inch (10 feet) diameter concre te-lined steel pipes (AWWA Specification C200 and C205) per Unit. Gravity- driven flow from the cooling tower basin to the condenser would need to be via two 144- inch (12 feet) diameter concrete-lined steel pipes (AWWA Specification C200 and C205) per Unit. Retrofitting a nuclear power plant from a once-through cooling design to closed-loop cooling has not occurred; therefore, there is a large degree of uncertainty in the operation of any closed-loop cooling retrofit. The star tup, steady-state opera tion, and shutdown of the closed-loop cooling system would require balancing the ci rculating water flow between the cooling tower basin and the discharge ca nal reservoir. The control scheme would require a programmable logic control system and redundant instrumentation, and be capable of balancing the clos ed-loop cooling equipment to meet ambient environmental conditions, plant operational requirements, and maintain adequate inventory each basin.



### 2.1.1.1 Pipe Routing / Interferences
The new Unit 2 circulating water pump house would need to be lo cated on the existing discharge canal between the Unit 1 and Unit 3 turbine-generator buildings, as shown in Attachment 2, Sketch ENTGNU011-SK-001. Also shown in Attachment 2, SketchCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

8 ENTGNU011-SK-001, the cooling tower supply pipi ng would need to be routed from the new pump house to the Unit 2 cooling tower through the “Riverfront”, the space between the intake structures and turbine-generator buildings of each Unit. There are several underground utilities present in the Riverfront area, the most significant of which is the Unit 2 service water and existing circulati ng water supply piping and electrical duct banks. Furthermore, this area is commonly us ed for vehicular traffic and is part of the heavy load path (i.e., the road must withstand loads up to 300 tons). Therefore, the supply and return piping would need to be buried to sufficient de pth beneath the road elevation and backfilled to support the current traffic patterns and the resultant structural loads. Outside the protected ar ea (i.e., outside the graded a nd paved Riverfront area), the piping would need to be routed to the coo ling towers following approximately the same gradient as the surface elevation, providing a minimum of 10 feet depth of cover (see Attachment 2, Sketch ENTGNU011-SK-002). Routing the piping from the Riverfront area to the Unit 2 cooling tower basin presents significant challenges. The piping elevation would rise approximately 15 feet between the Riverfront area and the Unit 2 cooling tower basin, following the gradient of the surface elevation, and excavation of the bedroc k would be required. The drainage areas created by the construction of the Independe nt Spent Fuel Storage Installation (ISFSI) would also create challenges for the Unit 2 pi pe routing. These areas would either need to be avoided or moved to appropriate locations consistent with the drainage requirements of the ISFSI. The new Unit 3 circulating water pump house would need to be lo cated on the existing discharge canal near the end, as shown in Attachment 2, Sketch ENTGNU011-SK-001. The cooling tower supply piping would need to be routed almost directly southeast to the Unit 3 cooling tower. Both the cooling towe r supply and return pipes would need to be routed to the cooling towers following approx imately the same gradient as the surface elevation, providing a minimum of 10 feet de pth of cover (see Attachment 2, Sketch ENTGNU011-SK-003). Inside the protected ar ea, the cooling tower return piping would need to be routed to the Unit 3 condenser th rough the Riverfront area between the Unit 3 turbine-generator building and in take structure. Similar to the Unit 2 routing, the Unit 3 pipes would need to be buried to accommodate current traffi c and access patterns and to avoid many underground utilitie s, including the existing Un it 3 service water piping.

Installation of the new circulat ing water piping in the Riverf ront area would require an outage of both Units. Several safety-related systems would still require offline cooling (e.g., Spent Fuel Pool, Emergency Diesel Ge nerators); however, the existing service water supply would be interrupted by ex cavation under and around the service water piping. Each safety-related sy stem requiring offline cooling would need to be reviewed and provided with secondary cooling. Additiona l security would also be required during construction within the protected area.



### 2.1.1.2 Tie-In Locations
The Unit 2 cooling tower return piping would tie-in to the existing Unit 2 CW piping in the Riverfront area prior to flowing through the condensers, as shown in Attachment 2, Sketch ENTGNU011-SK-004. Each cooling tower return pipe would supply threeCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

9 existing CW pipes. One cooling tower retu rn pipe would be routed at centerline elevation 1’-0” above MSL through the Riverfr ont to tie-in to the three northernmost existing CW pipes. The 1’-0” centerline elev ation would allow a 7.5’ depth of cover. The other cooling tower return pipe would be routed at centerline elevation (-) 11’-0” below MSL through the Riverfront to pass unde rneath the exiting service water piping at centerline elevation 1’-0 ” above MSL, with 5’ of clearanc e between pipes. After clearing the existing service water piping, the cool ing tower return line rises to centerline elevation 1’-0” above MSL to connect to the three southernmost existing CW pipes. A header would be required at the end of each cooling tower return line to connect to the existing CW pipes at centerlin e elevation 6’-6” above MSL. A throttling valve would be required after the tie-in on each existing CW pipe to regulate flow to each condenser waterbox and allow for condenser maintenance. The Unit 3 cooling tower return pipes would tie-in to the existing Unit 3 CW pipes in the Riverfront area prior to flow ing through the condens ers, as shown in Attachment 2, Sketch ENTGNU011-SK-007. Each cooling tower return pipe would supply three existing CW pipes. One cooling tower return pipe would be routed at elevation 1’-0” above MSL through the Riverfront to tie-in to the three southernmost existing CW pipes. The 1’-0” elevation would allow a 7.5’ depth of cover. The other cooling tower return pipe would be routed at cen terline elevation (-) 11’-0” be low MSL through the Riverfront to pass underneath the exiting service water piping at cente rline elevation 1’-0” above MSL, with 5’ of clearance be tween pipes. After clearing the existing service water piping, the cooling tower return line would ri se to centerline elevation 1’-0” above MSL to connect to the three northernmost existing CW pipes. A header would be required at the end of each cooling tower return line to connect to the existing CW pipes at centerline elevation 6’-6” above MSL. A throttling valve would be required after the tie-in on each existing CW pipe to regulate flow to each condenser waterbox and allow for condenser maintenance. The new circulating water pumps for each Unit would draw suction from the modified discharge canal to supply water to the cooling tower supply pipelines. In its modified configuration, the discharge canal woul d no longer serve its once-through cooling function to return circulation water to the Hudson River and would become the new circulating water pump pit. The new Un it 2 pump house would be located on the discharge canal between the Un it 1 and Unit 3 turbine genera tor buildings. The new Unit 3 pump house would be locate d on the discharge canal alon g the Hudson River bank. Additional details on how closed-loop cooli ng would require reco nfiguration of the discharge canal are provided in Section 2.1.3.



### 2.1.2 Intake Structure
Although the existing circulating water pumps a nd screens would no longer be required for closed-loop operation, service water flow woul d still be maintained through the existing intake structures. The discharge from the service water systems would be used after a conversion to closed-loop cooling for makeup water to the cooling towers.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

10 

### 2.1.2.1 Closed-Loop Operation
The makeup water flow rate required to s upport closed-loop cooling would vary based on Hudson River water quality and meteorological conditions as further discussed in Section 7.1. In addition, the closed-loop cooling star t-up sequence would require a large amount of makeup water to charge the system. A ll makeup and start-up flow would be supplied to the discharge canal to provide adequate flow to the new circulating water pumps. Under typical operation, the makeup water flow would be provided to the Unit 2 and Unit 3 reservoirs by the service water discharge. An ancillary makeup pump (shown in Attachment 2, Sketch ENTGNU011-SK-007) would provide additi onal makeup flow directly to the Unit 2 reser voir under conditions when the total required makeup flow exceeds the service flow discha rged by both Units. The additional flow from the makeup pump would flow over the weir between the Unit 2 and 3 pump reservoirs to provide flow to the Unit 3 pump reservoi r. The ancillary pump would also likely be used during the closed-loop start-up sequence. The bl owdown flow plus any excess service water flow would be discharged through th e Unit 2 and Unit 3 reservoir weirs. Additional operational procedures would be re quired to ensure flow balance throughout the closed-loop cooling system. As a result , conversion of IPEC to closed-loop cooling would increase the complexity of plant operations and require additional operations personnel.



### 2.1.2.2 Current Equipment to Remain Under Closed-Loop Operation

The current intake structures are divided in to separate channels for each of the six circulating water pumps with a center channel shared by the six service water pumps as shown in Figure 2.1. Each of the circula ting water pump channels is served by a Ristroph-type traveling water screen and the service water pump channels have two Ristroph-type trave ling water screens. 2

2 A full description of the Ristroph-type traveling water screens is included in Section 2.3.1.1 of the Evaluation of Alternative Intake Technologies at Indian Point Un its 2 & 3 [Ref. 12.8], s ubmitted with this Report.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

11 Figure 2.1 Plan View of the Unit 2 (Left) and the Unit 3 (Right) CWISs Due to the need to maintain the existing sa fety-related service water systems, four traveling water screens, two at each Unit, would need to be retained.



### 2.1.3 Discharge Canal

In order to convert Units 2 and 3 to closed -loop cooling, multiple modifications to the discharge canal would be required, as di scussed in Sections 2.1.3.2 through 2.1.3.6. The existing discharge canal would need to be modi fied to serve as a reservoir/pump pit for the twelve new circulating water pumps that woul d supply the cooling towers. A weir would be installed to separate the Unit 2 and Unit 3 pump reservoirs, as shown in Attachment 2, Sketch ENTGNU011-SK-007. The new reser voirs would provide some operational flexibility, whereby the reserve volume in each reservoir acts as a buffer against flow disruptions and equipment failure . The technical and logistical challenges associated with this design are discussed in the following sections.



### 2.1.3.1 New York State Energy Research and Development Authority Discharge Canal Ownership
Entergy’s counsel has advised that convers ion of IPEC to closed-loop cooling may increase the appraised value of the area of the discharge canal leased from the New York State Energy Research and Development Au thority (NYSERDA) and thus increase theCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

12 discharge canal rent obligations upon rene wal of the lease in March 2017 above the current annual cost of approximately $1.0 million.



### 2.1.3.2 Pump Submergence Modification
New Unit 2 and Unit 3 pump houses would need to be constructed on the existing discharge canal, near the Unit 3 turbine-generator build ing and along the Hudson River bank, respectively. The conceptual pum p house locations ar e shown on Sketch ENTGNU011-SK-001 in Attachment 2. In order to provide the necessa ry flow to the cooling towe rs, the new circulating pumps would need to be approximately 45 ft long. Providing the correct submergence of the pump is necessary for continuous cl osed-loop operation, wh ereby inadequate submergence would cause damage to the pu mps, render the circulating water system inoperable, and cause the plant to trip offline. The require d submergence value of these pumps would necessitate excavation to increas e the depth of the existing discharge canal in the locations of the new pump houses. Th e new depth at eleva tion (-) 32’-5” under the Unit 2 pump house would slope up gradually to m eet the existing canal depth at elevation (-) 17’-0” below mean sea level (MSL). The existing canal depth in the Unit 3 pump house location at elevation (-) 20’-0” would require less excavation. This design maximizes the water inventory margin available above the minimum required submergence level of the pumps (Attachment 1). The minimum required submergence would be reached when the wa ter level dropped from the nominal elevation of (+) 1’-0” above MSL to (-) 14’-0” below MSL. This le vel would need to be reached in the Unit 2 and Unit 3 reservoirs after approximately 4 to 6 minutes if supply to the reservoirs was suddenly cut off. Once the water leve l has dropped below the minimum required submergence, the circulating water pumps w ould no longer be capable of pumping water from the reservoirs to the cooling towers. A weir would need to be installed in the existing discharge canal prior to converging with the Unit 3 discha rge tunnel outlet, as shown in Attachment 2 Sketch ENTGNU011-SK -007, to separate the reservoirs for each Unit and prevent an inventory drop in one reservoir from affecting the other.



### 2.1.3.3 Reservoir Capacity
Modifications would be require d to convert the existing discharge canal to serve as the Unit 2 and Unit 3 pump reservoirs. These mo difications would include increasing the depth of the canal beneath the new pump hous es to accommodate new circulating water pumps, adding a weir prior to converging wi th the Unit 3 discharge tunnel outlet, as shown in Attachment 2 Sketch ENTGNU011- SK-007, to separate the Unit 2 and Unit 3 pump reservoirs. After modifi cations, the Unit 2 and Unit 3 reservoirs would hold over 4.2 million and 6.5 million gallons, respectively.



### 2.1.3.4 Offline Effluent Flow
Flow from each Unit’s discharge tunnel would n eed to be rerouted directly to the Hudson River, using temporary piping, to maintain dry construction conditions in the existing discharge canal for modification to new pump reservoirs. Routing of temporary pipingCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

13 would be difficult due to the fact that the disc harge tunnel is rectangular in shape, with the outlet piping into the disc harge tunnel prior to flowing into the discharge canal. Even though construction in the Riverfront ar ea would require an outage of both Units, several safety-related systems would still re quire offline cooling (e.g., Spent Fuel Pool, Emergency Diesel Generators). Each of th ese systems would need to be reviewed and secondary cooling provided. Discharge from these secondary cooling systems would need to be returned directly to the Hudson River via temporary piping.



### 2.1.3.5 Groundwater Contamination
As discussed in Attachment 3, groundwater , currently subject to NRC regulatory oversight because of the presence of radiological contamination (primarily tritium (H-3) and strontium (Sr-90)), migrates through a portion of the expe cted cooling tower excavation area. GZA GeoEnvironmental, Inc. (GZA), an environmental and geotechnical consulting firm, developed gr oundwater contamination plume models for tritium and strontium based on quarter ly groundwater sampling and elevation measurements taken at various monitoring poin ts, as well as the analyses summarized in previous Quarterly Reports and the Concep tual Site Model presented in the final Hydrogeologic Site Report [Ref. 12.14]. Ac cording to GZA, sampling and analysis protocols for groundwater and excavated materi al would be develope d and employed to manage site work and determine appropria te handling and dispos al requirements (see Attachment 3). Further, during the excavation process disc ussed in Section 6, excavation would be required at depths well belo w the groundwater table in th e contaminated areas. To maintain dry conditions required for pipe construction and backfilling, contaminated groundwater would need to be continually pumped from the excavation area below the groundwater table (i.e., dewatering). As described in Attachme nt 3, absent careful management, dewatering could cause the gr oundwater to migrate from contaminated areas to clean areas, altering the existing radionuclide plume. To control spreading, dewatering from within contaminated groundwat er areas would have to begin prior to excavation in the contaminated area, but co incident with excavation and dewatering in the adjacent clean areas. This dewatering would also have to be continued until completion of the excavation. As discussed in Attachment 3, groundwater may contain tritium, strontium, and potentially smaller concentrations of othe r radionuclides, including cesium, that would have to be disposed of. GZ A analyzed several disposal op tions and concluded that the only feasible method of dis posal would be discharge di rectly to the Hudson River (Attachment 3). GZA has been advised by Entergy’s legal counsel that NYSDEC appears to believe they have jurisdiction of discharge to the Hudson River. GZA concluded, therefore, that di sposal options are limited.



### 2.1.3.6 Low Volume Waste Effluents
Conversion to closed-loop cooling would ha ve engineering and operational impacts on the liquid waste disposal system regulated by NRC. With respect to radiological materials, discharge streams are managed cons istent with 10 CFR 20 dose limits and toCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

14 ensure consistency with 10 CFR 50 design ob jectives for keeping potential exposure levels as low as is reas onably achievable (ALARA). Likewise, discharge of nonradioactive material (i.e., boron, chlorine, etc.) is authorized and governed by the SPDES permit [Ref. 12.20]. Both are managed in th e existing liquid waste disposal system. Conversion to closed-loop c ooling would require signific ant changes to the existing liquid waste disposal system, any of which w ould require reconsider ation and/or revision of plant operating procedures and the operating margins to current regulatory limits. Therefore, a thorough review of the fina l design under 10 CFR 50.59 would be required to ensure compliance with 10 CFR 50 ALAR A practices and 10 CFR 20 dose and release rate limits, as well as environmental re views of SPDES permit limitations for nonradioactive releases.



### 2.2 Conversion of Only Unit 2
Conversion of Unit 2 to closed-loop cooling would require the installation of one 100% capacity round hybrid coo ling tower and the associated pipi ng and equipment as described in the 2003 Report (Attachment 1). Th e cooling tower would need to be placed to the northeast of the Unit Containment Build ing, as shown in Attachment 2, Sketch ENTGNU011-SK-002. The closed-loop cooling design of only Unit 2 woul d be identical to that discussed in Section 2.1 without the modifications to Unit 3.



### 2.3 Conversion of Only Unit 3
Conversion of Unit 3 to closed-loop cooling would require the inst allation of one round hybrid cooling tower and the associated piping and equipment as described in the 2003 Report (Attachment 1). The cooling tower would need to be placed to the southwest of the Unit 3 Containment Building, as shown in A ttachment 2, Sketch ENTGNU011-SK-003. Construction of the Unit 3 cooling tower would require relocation of the Algonquin Gas Transmission pipelines, as di scussed in Section 4. The cl osed-loop cooling design of only Unit 3 would be identical to th at discussed in Section 2.1, wh ereby the only modification to Unit 2 would be additional piping to transp ort Unit 2 low level effluents to the Unit 3 discharge point.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

15 

## 3 Station Operational Parameters
Unit 2 and Unit 3 are water-dependent – meaning both that they require a specific quantity and temperature of water. The Stations were designed for and currently utilize the consistently cold brackish water from the Hudson River for operati on. Specifically, the main steam condensers at both Units were designed to operate over the fixe d range of circulating water inlet temperatures provided by the Hudson River. Deviation be yond this range impacts plant performance. Conversion of IPEC to closed-l oop cooling would reduce access to the relatively cold Hudson River water and increase the ci rculating water inlet temperat ure to the main condensers. Therefore, the impact of this increase to ci rculating water temperature on plant systems, operation, and output must be evaluated. Conversion of a nuclear power plant designed for once-through c ooling to closed-loop cooling has never occurred (Section 1.1.3). As such, the following analysis is theoretical, and while benchmarked against actual plant data, is not reflectiv e of any history of operation of a nuclear power plant converted to closed -loop cooling. Subject to th ese limitations, the theoretical impacts on Units 2 and 3 due to conversion from once-through to closed-loop cooling are evaluated herein. This evaluation of closed-loop cooling is perfor med using a state-of-the -art site performance evaluation of power system efficiency (PEPSE) m odel that accurately pred icts and provides plant operational parameters and power reductions associ ated with conversion of IPEC to closed-loop cooling. PEPSE is used across the nuclear powe r industry, as well as the power industry as a whole, and is the standard analytical tool to model “what if” scenario s to determine system impacts of altering power plant operation. The PEPSE model is designed for each Unit’s actual configuration and performance, and used to be nchmark theoretical plant performance against measured data to provide an accurate summary ofthe expected results of conversion to closedloop cooling. Similar to the methodology employe d in the 2003 Report, an analysis was done over the range of expected circulating water inle t temperatures to determ ine plant performance; however, the current analysis utilizes an update d PEPSE model to account for modifications to each Unit and was performed using a much larger set of discrete input pa rameters to increase precision.



### 3.1 Administrative/Operating Limits
The Stations’ equipment operation is gove rned by a set of administrative limits 3 used to ensure safe and reliable operation of each Unit. Specifically, PWRs are subject to nuclear safety constraints on operati ons of various Station equipm ent, including pump net positive suction head requirements, overall plant contro l characteristics, core thermal power limits, and core thermal-hydraulic stab ility. The Stations’ equipment operation must be thoroughly analyzed in regard to the m odifications likely required to convert Unit 2 and 3 from oncethrough to closed-loop cooling, in order to ensure these administrative limits are not exceeded.

3 Administrative limits are limits used to prevent encroachment of NRC licensed limitations (e.g., technical specification limitations, FSAR limitations, etc.) and equipment operational limits . They represent practical limits for safe and reliable plant operation.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

16 Changes to the Stations’ cooling water equipm ent to offset the losses associated with conversion to closed-loop coo ling are restricted by the size and configuration of the equipment within the Turbine Building, par ticularly the condenser and the surrounding components. The main condensers were sized to reflect the use of a stable and cold inlet water source (i.e., water drawn from the Huds on River). In order to maintain current operational efficiencies, a dras tic modification of the condens er (through a size increase) would be required; however, due to the physical constraints of the Turbine Building, a significant size increase of the condensers is no t possible without the co mplete reconstruction of the turbine building. A conde nser / turbine building modificat ion of this magnitude would be unprecedented (i.e., implement ation of a condenser redesign of this magnitude has never occurred at an operational nuclear power plant) . Due to the magnitude of this redesign, the lack of any history of a nuclear plant unde rtaking such a modification, and the physical constraints of the Unit 2 and Unit 3 Turbine Build ings, it is concluded th at modification of the current cooling water equipment to compensate for the expected power generation would not be able to offset the losses associated with conversion to closed-loop cooling. The administrative limits given in the Alar m Response Procedures [Ref. 12.15; Ref. 12.16] require that the main condenser vacuum be above approximately 3.92 and 4.92 in-Hg for Units 2 and 3, respectively. 4 These administrative limits, while considered in the PEPSE analysis, were not projected to be exceeded based on historical meteorological conditions.



### 3.2 Closed-Loop Operational Efficiency (PEPSE Analysis)
As discussed in the 2003 Report (Attachment 1) , closed-loop cooling performance is based on the ambient meteorological conditions, with the result that operational losses at the Stations would vary based on seasonal wet-bulb temperatur e at IPEC. The wet bulb temperature is a meteorological measurement which incorporates both moisture content and temperature of the ambient air. Local meteorological data was ob tained, reviewed, and analyzed for use as an input to the PEPSE models for each Unit. The PEPSE model uses, among other things, cooling water intake temperature and flow ra tes to accurately calculate plant operational parameters and the resulting ne t power generated. The PEPSE model provides the expected plant operational parameters and power reducti ons necessary to theoretically operate IPEC Units 2 and 3 without exceeding equipment limitations and/or resulting in nuclear safety considerations. It should be noted that conve rsion of a nuclear power plant designed for oncethrough cooling to closed-loop cooling has never occurred and as such, the following analysis is theoretical. Although benchmar ked against actual plant data, the analysis is not reflective of any closed loop conversion of a nuclear power plant.

4 The pressure setpoints listed in the Alarm Response Procedures [Ref. 12.15; Ref. 12.16] are 25 and 26 in-Hg absolute for Units 2 and 3, respectively. Subtracting each of these setpoints fr om a standard atmospheric pressure of 29.92 in-Hg results in the main condenser vacuum setpoints of 3.92 and 4.92 in-Hg for Units 2 and 3, respectively.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

17 

### 3.2.1 Cooling Tower Efficiency / PEPSE Analysis

The IPEC PEPSE models were reviewed and run to produce the results discussed herein. 5 A diagram of the IPEC PEPSE model has be en included in Attachment 4, Figures 4-1 through 4-12.



### 3.2.1.1 Meteorological Data Analysis
The performance of any closed-loop cooling water system is primarily driven by the ambient weather conditions at the site and th e baseline inlet water temperature values. Cooling towers define their performance via an approach to wet bulb temperature. The wet bulb temperature is necessary for closed -loop cooling analysis, as cooling towers utilize an evaporative process to remove heat from the con tinuously recirculated cooling water. The approach to wet bulb describes the number of degrees above the ambient wet bulb temperature by which the cooling tower can be expected to reduce the cooling water temperature, whereby a lower approach e quates to lower cooling water temperature exiting the cooling tower. The approach to wet bulb is a value that is based on the size and efficiency of the cooling tower, and essentially represents the cooling ability of the equipment. Although wet bulb temperature is not measured di rectly by site meteorological instruments, wet bulb te mperature was calcula ted using dry bulb temperature and dew point temperature, both of which are measured onsite. Any data set used to predic t the performance of the Stations relies heavily on the presence of either wet bulb temperature meas urements or a combination of values that can be used to calculate the wet bulb temper ature (e.g., dry bulb temperature and relative humidity, dry bulb temperature and dew point, etc.). Ente rgy provided eight years of meteorological data (2001-2008) and a thorough review was conducted to normalize the data, ensuring that a uniform data set with no erroneous data is used as the basis for analysis. Particular focus was paid to the review and acceptance of the meteorological data, as even minor errors pr esent in the meteorological da ta would propagate throughout the analysis. Furthermore, there is almost always some degree of data loss associated with meteorological monitoring. This data loss may be due to a number of causes (equipment failure, biological/human error, etc. ). A general guideline for meteorological data acceptance is that the da ta maintain an average 90% da ta recovery rate [Ref. 12.35]. The average recovery rate fo r the eight year period anal yzed (2001-2008) was 97.2% as shown in Attachment 4, Table 4-1; therefore, the data provided by IPEC greatly exceeds the threshold for validity and represen ts an extremely robust data set.



### 3.2.1.2 Inlet Water Data Analysis
Entergy supplied eight years (2001-2008) of aver age daily inlet water temperatures. This data was reviewed to ensure that a uniform da ta set with no erroneous data is used as the basis for analysis. The average recovery ra te for the eight year period analyzed was

5 While finalizing the Report analysis, updated versions of the IPEC PEPSE models were again developed by Entergy. The new models were reviewed and compared to the PEPSE models originally used for this Report. It was determined that while previous updates were substantia l, the most recent updates to the PEPSE model were less substantial and would not result in any significant differences in the analysis.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

18 99.8%, representing an extremely robust data set. The monthly recovery rate per year is shown in Attachment 4, Table 4-2.



### 3.2.2 Closed-Loop Losses

Conversion of the Stations to closed -loop cooling would in troduce both ongoing operational efficiency losses associated w ith operating beyond the original condenser design conditions and parasitic losses associated with th e operation of the pumps and cooling tower fans. If the effect of clos ed-loop conversion on plant operation is averaged across the entire year, operational power losses would account for a loss in power generation of approximately 11.1 MWe and 4.7 MWe at Units 2 and 3, respectively; however, operational power losses would peak during the warmest temperature and highest dewpoint conditions, when electricity demand is at its highest. Over the historical data analyzed (2001-2008), the peak combined operational powe r loss occurred on June 7 th

, 2008 at 2PM, and accounted for a combined operational power loss of 85.4 MWe. Additional parasitic losses from the circula ting water pumps and the cooling tower fans and booster pumps would add an additional 36.1 MWe per Unit in power generation losses. Summing the operationa l and parasitic losses, Units 2 and 3 combined would experience an average power generation loss of 88.0 MWe and peak summer power generation loss of 157.6 MWe.



### 3.2.2.1 Operational Losses
After review and benchmarking, the IPEC PEPSE model was run over a theoretical bounding range of CW inlet temperatures to calculate the baseline closed-loop operation of the Stations (i.e., the performance of the Stations if converted to closed-loop operation). The PEPSE model allows fo r the calculation of system outputs and operational conditions as a dir ect function of various system inputs. Because these system outputs are fixed, the PEPSE model is limited to the unidirectional calculation of operational conditions via system input. To evaluate performance in the full range of operating conditions, the net thermal input (MWt) for the system was iterated over a series of CW inlet temperatures to find the closest parameters and linearly interpolate between them to calculate the system output and operational conditions (i.e., net power generated (MWe), hotwell temperatures (°F) /condenser backpressures (in-Hg) for each main condenser shell, and the c ondenser output temperatures (° F)). Overall, the CW inlet temperature for each hour is input across a set of data spreadsheets, which in turn allows for the calculation of the lim iting operational parameters. As the operation of cooling towers is dr iven primarily by ambient environmental temperatures, seasonal and daylight conditions have a significant impact on IPEC closedloop operation (see Attachment 4, Sections 4 and 5). The average closed-loop cooling operational losses on a yearly ba sis, including the monthly ope rational power losses that would be incurred at each Unit, are provide d in Attachment 4, Section 3. Table 3.1 presents the average continuous power genera tion losses that would be incurred at each Unit if the Stations were to be converted to closed-loop cool ing. Since closed loop power loss is the difference in power generation fr om once-through to cl osed-loop cooling, theCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

19 months with the highest average power loss, May and June, are those with the largest River water to ambient wet-bulb temperature differential.

Table 3.1 Unit 2 and Unit 3 Av erage Continuous Closed-Loop Cooling Power Generation Losses

Month Power Loss (MWe)

Unit 2 Unit 3
January 5.7 0.1
February 5.3 0.1

March 8.2 0.2
April 15.8 3.2
May 20.8 9.4

June 19.3 13.6
July 9.8 8.5
August 6.2 5.6
September 7.6 6.0

October 12.2 6.1

November 14.1 3.4

December 7.9 0.4
Average Annual 11.1 4.7
As shown in Table 3.1, the overall effect of a closed-loop conversion on plant operation, examined using the IPEC PEPSE models would be an average continuous loss in power generation of approximately 11.1 MWe and 4.7 MW e at Units 2 and 3, respectively (15.8 MWe, total); however, power loss would vary both seasonally and intraday, dependent on the difference between River water and ambient wet-bulb temperature. Over the historical data analyzed (2001-2008), the peak co mbined operational power loss of 85.4 MWe occurred on June 7 th , 2008 at 2PM, when electric ity demand was at its highest.



### 3.2.2.2 Parasitic Losses
In addition to the operational losses, the new cooling towers and equipment would require an appreciable amount of power to operate (i.e., parasitic losses) which would effectively reduce each Unit’s output power. The cooling to wers selected for closed-loop operation of the Stations are round hybrid cooling towers, designed with noise and plume abatement features. In particular, round hybrid cooling towers require significant additional electrical loads since they utilize two fans per cell to draw air in through both the wet and dry sections of the cooling tower. Also, the new circulating wa ter pumps for closed-cycle cooling would require more power than the existing circulating water pumps. The additional power required over theCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

20 existing circulating water pump requirements w ould be another parasitic loss associated with conversion to closed-loop cooling. The parasitic losses associated with each co mponent of closed-loop cooling would be as follows:

 Cooling Towers (26.5 MWe per Unit)

o 44 wet fans (300 HP)

o 44 dry fans (350 HP)

o 4 booster pumps (61,250 gpm at 26 ft)

 Additional Circulating Water Pu mp Load (9.6 MWe per Unit)

o 6 circulating water pumps (117,000 gpm at 72 ft) Summing the additional parasitic losses from the circulating water pumps and the cooling tower fans and booster pumps would be approximately 36.1 MWe per Unit, or a combined parasitic loss of 72.2 MWe. Whenever a Unit woul d be online, th ese parasitic losses would continually draw from the net generating electricity.



### 3.2.2.3 Electrical Distribution Effects
Using the Electrical Transient Analyzer Program (ETAP) software, Attachment 5 provides a model of the anticip ated electrical distribution sy stem required to support the conversion of Units 2 and 3 to closed-loop operation. This analysis accounts for the expected electrical parasiti c losses due to the new compone nts required for closed loop operation at both Unit 2 and Unit 3 to determine if extensive improvement to the electrical distribution sy stem would be required. Reviewing the one line diagrams of this study, the available fault current at the Buchanan 138kV switchyard bus by the IPEC grid contri bution is 16.73 kA . The additional loads added by conversion to closed-l oop cooling would increase this available fault current by 1.75kA, or approximately 10%. Per discussi ons with site personnel, the Buchanan 138kV switchyard bus has a cap acity rating in the order of 60kA, supplying significant margin against a short-circuit event. Due to the magnitude of this margin, and due to the relatively small increase of load, no modificat ions to the switchyard would be expected by conversion of IPEC to closed-loop cooli ng; however, additional electrical distribution analysis and consideration of the available pr otective devices ratings would be required in the detailed design phase to competely ensure ad equate margin is present. Conversion of Unit 2 or Unit 3 individually to closed-loo p cooling would impact the electrical distribution system to a lesser degree then conversion of both Units, and as such this analysis is bounding for each individual conversion scenario. Additional details on the electrical analysis conducted are included in Attachment 5.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

21 

## 4 Algonquin Pipeline Relocation
Due to physical site constraints and water flow requirements, th e Unit 3 cooling tower must be located on the southwest portion of the IPEC site, as discusse d in Section 2.1 and shown in Attachment 2 Sketch ENTGNU011-SK-001. Howeve r, a portion of this location overlaps the existing right-of-way (ROW) for the Algonquin Gas Transmission (Algonquin) pipelines. In order to accommodate excavation and constructi on of a cooling tower for Unit 3, the existing pipelines would have to be reloca ted within the IPEC site, pursuant to the terms of the pipeline easement. Spectra Energy Transmission, LLC (Spectra), owner and operator of the Algonquin pipelines, has preliminarily evaluated the feasib ility of the required relo cation (Attachment 6). The preliminary timeline for relocating the pipelines is approximately 24 months and the estimated cost is approximately $13.8 million, with an accuracy level of (-)25% to (+)40%. The feasibility evaluation considers design, permitting, material, labor, and construction, but does not include the cost and schedule of spoils removal, which would significantly increase the estimated cost provided by Spectra.



### 4.1 Pipeline Configuration
The regional interstate Algonquin pipeline system transports natural gas from New Jersey and southeastern New England to major markets in New England, including Boston, Hartford, and Providence [Ref. 12.27]. The Al gonquin pipelines transport 2.5 bil lion cubic feet of gas per day to serve approximately fifty percent of the natural gas demand in New England (Attachment 6). Algonquin serv es as a major artery thro ugh the northeast portion of the United States, connecting to Spectra’s Te xas Eastern Transmission and Maritimes & Northeast Pipeline. Currently, the Algonquin Pipeline system crosses th e Hudson River next to IPEC. Due to the significant level of service pr ovided by Algonquin to the region, Sp ectra has advised that the Hudson River crossing is considered a critical site and the throughput of the pipeline facilities at this location cannot be interrupted. The Algonquin facilities crossing the IPEC site are comprised of two gas pipelines running east to west through the IPEC site on a 65 foot wide ROW. At the southwest prope rty boundary, a third pipeline is tied into the two other pipelines along with valving and internal inspection facilities fo r all three pipelines. The valve site area is near the Hudson River bank, wi thin the excavation area of the Unit 3 cooling tower. The connection piping is visible above ground, as shown in Figure 4.1. The ROW expands significantly at the valve site to acco mmodate the additional piping and equipment. The existing Algonquin pipeline ROW is show n by solid white lines in Figure 4.1. The proposed location for the Unit 3 cooling towe r is shown by a dotted white oval. The excavation required for construction of the coo ling towers would extend approximately 150 ft beyond the dotted oval, to create the 700 ft di ameter clearing around th e tower and gradual slope from the clearing to the existing grade.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

22 Figure 4.1 Existing Algonquin Gas Tran smission Pipeline Right-Of-Way, With Proposed Unit 3 Cooling Tower Location Shown by Dotted Line



### 4.2 Feasibility of Relocation

In order to construct the Un it 3 cooling tower configuration shown in Attachment 2, the Algonquin pipeline would have to be relocated. Spectra has pr ovided an evaluation of the required pipeline relocation and proposed that pi peline be rerouted around the Unit 3 cooling tower excavation area, as shown in Attachme nt 2 ENTGNU011-SK-001 (Attachment 6). The lack of available space between the cooling tower excavation area and the Hudson River bank would require relocation of the valve site and an extension of the third pipeline. The valve site would be relocated along the existing pipeline to the ar ea adjacent to the Broadway roadway. An extension of the third pipeline w ould be installed running pa rallel to the existing pipelines across the IPEC site. At the Unit 3 cooling tower excavation location, all three pipelines would be rerouted ar ound the cooling tower to tie into the existing Hudson River crossing. The existing 65 ft wide ROW would n eed to expand to 100 ft wide to accommodate the extension of the third pipeline. During blast excavation at the Unit 3 cooling tower location, the required blasting offset (50 ft) from the nearest relocated pipeline would prohibit blasting within 15 ft of the expanded 100 ft ROW. The Unit 3 cool ing tower location has moved in a northerly direction from the original location considered in the 2003 Report (Attachment 1) to accommodate the expanded ROW and blasting offset proposed by Spectra. The revised Unit 3 cooling tower location is shown in this Report (Attachment 2) and is the basis for all excavation discussions in this Report (e.g., Sections 5 and 6).CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

23 The Algonquin Pipeline System is one of the larges t interstate pipelines in the United States [Ref. 12.23]. As such, it is regulated by th e Federal Energy Regulator y Commission (FERC). Any relocation of the Algonquin pipeline would require the pr ior approval of the FERC, a process which could take a year or more [Ref. 12.19]. If FERC approval could not be obtained, the feasibility of closed-loop cooling fo r Unit 3 would be in jeopardy, as site real estate constraints pr eclude alternate c ooling tower sites.



### 4.3 Spectra Schedule and Cost Impacts
Siting of the Unit 3 cooling tower requires re location of the Algonquin pipeline facilities, which must be approved by FERC. A preliminar y timeline and feasibility cost estimate for the relocation is provided by Spectra in Attachment 6. Spectra’s preliminary timeline, shown in Tabl e 4.1, was developed abse nt any detailed field work, facility design, or agency consultatio n and without any detailed construction coordination concerns. This ti meline should therefore be consid ered a high level overview of the time required to relocate the pipeline faci lities and may be understated. The relocated pipeline facilities would need to be constructed in a staged manner to allow tied-in to existing facilities during the months of June through September, when the typical system demands may allow for an approximate 7 day outage for each relocated pipeline to be tied-in and connected. By scheduling the tie-in during th e summer months and in conjunction with any other planned system outages, there may be littl e to no impact to the services of Algonquin’s customers (Attachment 6). Table 4.1 Spectra’s Preliminary Ti meline for Algonquin Pipeline Relocation

Activity Duration Notes Preliminary field work 2 months Facility design 4 months

Permitting 14 months Includes preparations of applications to FERC and New York State

Construction 4 months

In-Service 21 days 7 day outage to tie-in each pipeline (in sequence) must occur between June and September

Total 24 months Assumes 3 week tie-in occurs during planned system outages
The feasibility cost estimate provided by Spectra fo r the relocation of the pipeline facilities is approximately $13.8 million, with an accuracy leve l of (-) 25% to (+) 40% (Attachment 6). The feasibility estimate considers design, permit ting, material, labor, an d construction costs. Of note, the cost of spoils disposal is not included; therefore, the spoils generated by the pipeline relocation are included in considerations of the total s poils that would be generated by the conversion of IPEC to closed-loop cooling (Section 6). The pipeline would have additional schedule and cost impacts on the conversion project as a whole. FERC approval for the pi peline relocation must be obtained before substantial designCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

24 work for conversion of Unit 3 to closed-l oop cooling would be undertaken, and the installation of the relocated pipe line would have to be complete before blast excavation could begin at the Unit 3 tower location. Each cons ideration would delay the overall schedule for both Units due to the combined outage at the en d of the conversion. In addition, due to the significant amount and duration of blast removal, Spectra woul d require field personnel and experts to monitor the relocated pipeline facilities throughout th e construction period (Attachment 6). The cost of pipeline moni toring would be estimated by Spectra after evaluation of the blasting plan and construc tion schedule, and is not currently included.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

25 

## 5 Blasting
Conversion of the Stations to closed-loop cond enser cooling would require the excavation of approximately 2 million cubic yards of soil and in wood marble bedrock. Blast removal would be required to excavate large quantitie s of bedrock at the cooling to wer locations and in the piping trenches outside of the Riverfront area. The f easibility, cost, and schedule of blast removal have been evaluated by Dr. Calvin J. Konya, a nationa lly recognized blasting c onsultant. Dr. Konya’s report is included as Attachment 7, which update s the original analys is for the 2003 Report (Attachment 1). Dr. Konya’s repor t describes the costs and durati on associated with significant aspects of blast removal at IPEC, emphasizing th e impact of site-specific vibration limits on blasting operations. Dr. Konya’s cost estimate for drilling and blasting, excluding removal and disposal of spoils, is over $40 million. The drilli ng and blast removal would be expected to take approximately 4 years.



### 5.1 Restrictions to Blasting at IPEC
Blast removal at IPEC would be limited by proximity to Units 2 and 3, the Algonquin pipeline, and the Village of Buchanan. The respective vibration limitations imposed by these site-specific considerations were reviewed and incorporated into the blasting plan described in Attachment 7.



### 5.1.1 Onsite Blasting Restrictions
As discussed in Section 5.2, blasting excavation would be required for a period of 4 years, and blasting operations are proposed to occur while both Units are online. In addition, the continued operation of the relocated Algonquin pipeline, discussed in Section 4, would be required. Therefore, blasting limitations were determined that would allow and ensure the continued operation of Unit 2, Unit 3, and the relocated Algonquin pipeline. Each Unit is designed to withstand an earthqu ake of Modified Mercalli Intensity VII, which corresponds to a maximum horizontal acceleration of appr oximately 0.15 g [Ref. 12.17; Ref. 12.18]. The seismic monitoring equipment, located in the Unit 3 containment building, is designed to detect ground motion a pproaching or exceeding this facility design basis. The equipment is trigge red by a horizontal acceleration of ≥ 0.01g to record the magnitude, duration, frequency a nd direction of seismic events . Initiation of the seismic monitoring equipment is one of the entry conditions for the seismic event procedure, which requires the immediate inspection of various systems, structures, and components at both units. In addition, an engineering evaluation of the impact of the seismic event on the plant must be completed and the seismic inst rumentation must be recalibrated. When a horizontal acceleration of ≥ 0.1 g is detected, an alarm in the Control Room initiates an abnormal operating procedure which could lead to shutdown of the reactors. The maximum horizontal acceleration of ground mo tion due to blasting is therefore limited to 0.1 g, as measured at the containment stru cture. The 0.1 g acceler ation limit translates to a vibration limit of 0.104 inch /sec due to the high frequencies of blasting compared to the frequencies of earthquakes. Small diamet er blastholes and a tightly-spaced blasthole pattern would be used to meet this limit, as discussed in Attachment 7. At the edges of excavation closest to the containment buildi ngs, additional vibration control would beCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

26 implemented by deck loading the blastholes. Deck loading allows several charges in one blasthole to be fired independently on millisecond delays, thereby reducing the ground vibrations resulting from the blast. As discussed in Section 4, the Algonquin pipelines cross the IPEC site to the south of Unit 3. Spectra, owner and operator of the Algonqu in pipelines, has prop osed an allowable blasting offset of 50 ft as pa rt of a preliminary relocation plan (Attachment 6). Spectra Guideline TG-111 specifies a calculation to determine a maximum allowable charge weight based on distance from the pipelines. At the edge of the proposed blasting offset, 50 feet from the relocated pipeline, the ma ximum allowable charge weight would be greater than the charge weight specified in the blasting pl an to meet the 0.1g horizontal acceleration limit at the containment building. Therefore, the blasting techniques that would be used to protect the Unit 3 facilities would satisfy Spectra’s criteria as well, after relocation of the pipeline. Spectra would al so require field personnel and experts to monitor the relocated pipeline facilities thr oughout the construction period (Attachment 6). A thorough analysis of the impact of blasti ng vibration on specific Unit components and the relocated pipelines would be required to finalize blasting procedures. This analysis would require testing of individual components to determine appropriate vibration limits. Additionally, impact of vibration on construction activitie s would need to be determined, as cooling tower construction for Unit 2 w ould likely begin before blasting excavation ended at the Unit 3 cooling tower site. Each of these blasting considerations would be affected by the site-specific ground conditions, which would need to be determined by onsite ground calibration (Attachment 7). IPEC personnel may experience noticeable vi bration from blasting, e.g., loose objects around the site may rattle. There is a slight potential that these e ffects could also be experienced off-site near the Unit 3 tower ex cavation. The distance from the excavation to the nearest residential areas would be appr oximately 1000 ft; therefore, no noticeable blasting effects would be e xpected in these locations.



### 5.1.2 Code of the Village of Buchanan - Quarrying and Blasting
IPEC is located in the Village of Buchanan, New York. The Village of Buchanan designates acceptable hours for blasting operations , and controls the degree of velocity and displacement of vibrations during those hours when blasting is authorized [Ref. 12.5]. Blasting is not permitted in the incorporated portion of the Village of Buchanan except between the hours of 8:00 a.m. and 7:00 p.m., excluding Saturdays, Sundays, and public holidays when blasting is not permitted at any time. In compliance with regulated blasting industry standards, blasting operations would also only be conducted in daylight; thus, blasting operations would end at dusk or 7:00 p.m., whichever is earlier. During the hours when blasting is permitted, p eak particle velocity and overpressure produced by any blast measured at the closest structure or building not owned or used by the entity conducting th e blast may not exceed 0.75 inch/s ec for frequencies less than 40 Hz or 2.0 inch/sec for freque ncies of 40 Hz or more. In addition, air pressure levels emanating from such blasts may not exceed 131 dB for a high pass filter of 0.1 Hz, 128 dB for a high pass filter of 2 Hz, or 125 dB for a high pass filter of 6 Hz. The blasting planCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

27 formulated by Dr. Konya was designed to co mply with these Village of Buchanan restrictions.



### 5.1.3 Code of the Village of Buchanan - Soil Disturbances and Excavations
Entergy’s counsel has advised that construc tion of the NYSDEC Pr oposed Project will require a soil and excavation permit from the Village of Buchanan. Section 159 of the Code states that an application must be submitted and a permit must be obtained from the Village Building Inspector prior to any excav ation. The Inspector may issue the permit only after review and approval by the Vill age Planning Board. The application must demonstrate that the work will not cause, among other things, substantial traffic hazards. Also, the application must show that the pe riod of time and the methods for the completion of the work are reasonable. Section 159 provides for 2 year excavation permits. Permits may also contain restrictions on the excavation, such as a limitation on the hours of authorized operations. With respect to traffic hazards, and as noted in the discussion of blas ting spoils removal in Section 6, blasting operations alone would produce between 364 and 518 truck loads per day (using 20-cy trucks). As discussed in Section 5.2, blasting and excavation could take as long as 4 years. These factors will be considered un der Section 159 of the Code. Section 159 also requires a certificate of insura nce, establishing the extent of liability of the applicant or contractor. Inquiries re garding insurance for the NYSDEC Proposed Project have received limited response and it may be diffic ult to obtain coverage for all associated risks, especially nuclear incide nt risks (Attachment 7, Section 3). Thus, permitting is not assured.



### 5.2 Cost and Schedule Impacts
The cost and duration of signifi cant aspects of blast removal at IPEC are estimated in Dr. Konya’s report (Attachment 7).

Blast removal duration would be primarily limited by the time necessary to drill the blastholes. All blastholes dr illed in one day could be pr epared, loaded, and fired in approximately 15 minutes at the end of the shif t. Therefore, the maximum number of drills that could be efficiently used would control the project durati on. Using typical drilling rates for the type of bedrock at IPEC, Dr. Konya estimates that 2078 10-hour days of drilling would be required to complete the project. The blastin g plan calls for 10 drills to be used, reducing the overall project dur ation to 208 days of drilling. Assuming a typical 85% equipment availability, the drill days re quired would increase to 245 da ys. Based on actual blasting experience in the New York area, Dr. Konya es timates that drilling could only be conducted the equivalent of 150 10-hour days per year due to weather shutdowns, equipment delays, blasting delays, and shorter drilling and blas ting hours in spring and fall due to reduced daylight hours. Under typi cal commercial operating conditi ons, the blasting would take approximately 1.6 years (see At tachment 7). However, at an operating nuclear site, the duration would necessarily increase to accommoda te the various policies, procedures, and work practices dictated by industrial safety, nucl ear safety, security, an d other relevant site programs. Due to these additional considerati ons particular to the nuclear industry, theCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

28 duration would be expected to be approximately 2.5 time s longer than a comparable commercial operation, resulting in an expect ed duration of approximately 4 years. Cost estimates for the significant aspects of bl ast removal at IPEC are based on the typical rates for similarly complex jobs and industry q uotations. The overall cost estimate for blast excavation for conversion of both Unit 2 and Un it 3 to closed-loop cooling is detailed in Table 5.1. Blasting costs are estimated to be over $40 million, not including removal and disposal of the spoils (contaminated or cl ean) generated by blasting. The removal and disposal of all spoils genera ted by the conversion of IPEC to closed-loop cooling are discussed in Section 6.

Table 5.1 Blast Removal Cost Estim ate for Conversion of Both Units

Total Units Rate [/Unit] Cost Cooling Towers 1,796,000 yd 3 $15 $26,940,000 Trenches 94,600 yd 3 $58 $5,487,000 Presplitting 61,080 yd 2 $85 $5,192,000 Blasting Consultant 800 days $2000 $1,600,000 Seismic Monitoring 34 months $26140 $889,000
Total $40,108,000



### 5.3 Blasting Outage Timing
In order to avoid a prolonged forced construc tion outage at each Unit, blasting operations would occur with both Units online, as discussed in Section 5.1.1. Moreover, if blasting operations are able to be coordinated to overlap with scheduled outages, the cost of blasting could be marginally reduced . Per Attachment 7, a potential cost savings of approximately 5% could be realized duri ng the outage duration by avoiding the need for deck loading in the blastholes near Unit 3. Ho wever, deck loading woul d still be required in blastholes near the Algonquin pipeline. Blas ting during scheduled outages would not impact the total number of blastholes required or the presplitting cost s. The blasting project duration would not be impacted by overlap with sche duled outages; only the cost of blasting in proximity of Unit 3 during an outage would be impacted.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

29 

## 6 Spoils Removal

Conversion of Unit 2 and Unit 3 to closed-l oop cooling would require the excavation of approximately 2 million cubic yards of soil and bedrock, nearly all of which is expected to be crushed inwood marble. As detailed in Table 6 .1, the total estimated di sposal volume includes excavation for the cooling tower basins and clea rings, the circulating water piping trenches, the Algonquin pipeline relocation, and miscellaneous requirements of the conversion to closed-loop cooling (e.g., parking lot relocat ion, pump skids, electrical duc t banks). The total disposal volume is greater than 50% of th e total crushed marble sold or used in the U.S. in 2007 [Ref. 12.34]. Some portion of the excavated material is likely to be radiological ly contaminated. As such, a sampling program would be developed and implemented prior to excavation, so that radiologically contaminated material may be prop erly managed. The cost and rate of removal and disposal of the excavated material would be significant factors in the overall cost and duration of the conversion. Radi ological contamination concerns may cause delay or increase the cost of removal. Table 6.1 Estimated Excavation Volumes by Area

Excavation Area Excavation Volume Cooling Tower Basins and Clearings 1,794,300 yd 3 Piping Trenches 129,600 yd 3 Algonguin Pipeline Relocation 44,600 yd 3 Miscellaneous (Parking Relocation, Electrical Equipment, Etc.) 17,900 yd 3
Total 1,986,400 yd 3



### 6.1 Blasting Spoils
Most of the expected 2 million cubic yards of spoils would be produced by blast removal. Blast removal would produce rocks of varying size. Approximately 65-77% of the rocks produced in the cooling tower site excavati on would be larger th an 1.5 inch pieces (Attachment 7). The blasting in the piping tr enches would produce smaller pieces of broken rock, with approximately 43-61% of the rocks larger than 1.5 inch pieces. These larger rocks would need to be crushed to facilitate transp ortation offsite. A pro cession of dump trucks would carry the blasted rock from loaders at th e blasting site to mobile crushing plants setup near the River. One mobile crushing plant w ould be used at each cooling tower excavation. The crushed rock would be dropped directly fr om the crusher onto a conveyor belt for barge loading. Each step of the excavation process must be carefully planned and executed to efficiently remove the blasted rock. The numbers and capaci ties of loaders, trucks, screens, crushers, conveyers, barges, etc. must be carefully balanced to preven t any individual step in the process from becoming a bottleneck. In theory, it may be feasible to re move the blasted rock at the maximum rate possible as limited by dr illing. If limited only by the drill rate, the excavation would produce between 7,265 and 10,350 cubic yards of broken rock per day (equivalent to between 364 and 518 truck loads, with 20-cubic ya rd capacity). In practice,CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

30 well coordinated efforts would be required to remove, process, and dispose of this expected quantity of material. Significant schedule delays could be introduced by any inefficiency in the rock removal operation. Due to the large scale of the excavation, counsel for Entergy advises th at crushing operations may be viewed by the Village of Buchanan as a primary use of the IPEC property that is prohibited by the Zoning Code, as discussed in Section 8.3.1.



### 6.2 Contamination of Spoils

Historical site assessments a nd groundwater sampling at IPEC , including that performed by GZA, have indicated that groundw ater is radiologically contamin ated in some areas of the site, primarily with strontium-90 and tritium [Ref. 12.14] (Attachment 3). A Long Term Groundwater Monitoring Program (LTMP) has been implemented at IPEC to characterize and monitor the extent of subsurf ace contamination. The results of the program have indicated relatively stable groundwater contamination plum es and a decreasing trend in radionuclide levels [Ref. 12.13]. GZA’s groundwater contam ination plume models indicate localized contamination near Units 1 and 2 that ultimately discharges to the Hudson River, as shown in Figures 1 and 2 of Attachment 3. GZA has advised that all spoils excavated from within the plume boundaries would likely be contaminate d. Therefore, the volume of contaminated spoils that would be generated is expected to be at least 6350 cubic yards. As shown in Section 6.5, contamination would increas e the cost of spoils disposal. Additional sampling and radiological testing w ould be required to determine the quantities and locations of contaminated soil. The sa mpling program would cover areas that could potentially be contaminated, consiste nt with GZA’s recommendations. The blasting/excavation schedule woul d allow workers sufficient tim e to monitor blasted rock.



### 6.3 On-Site Relocation of Spoils
A limited portion of the excavation spoils may th eoretically be reused or stored onsite. However, the expected 2 million cubic yards of excavated spoils would greatly exceed IPEC’s storage capacity. As such, most of the material would need to be remo ved. In addition, the only available area onsite for spoils storage wo uld be the eastern hard wood forest habitat to the northeast of the Unit 2 cooling tower location. The potential impact on the local terrestrial ecology (which includes potential endange red species habit [Ref. 12.11]) would likely preclude spoils storage in that area. Due to th ese considerations and co nstraints, it has been assumed that spoils would not be relocated onsite.



### 6.4 Off-Site Relocation of Spoils
The entire 2 million cubic yards of excavated spo ils are assumed to require off-site relocation, due to the constraints discussed in Section 6.3. Two separate methods of disposal would be required, respectively, for contaminated and clean spoils.



### 6.4.1 Radiologically Contaminated Spoils
Any detection of radiologica l contamination above a defined minimum detectable concentration would require the excavated spoils to be properly disposed of as radioactiveCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

31 waste. Contaminated spoils would be cl assified as directed by 10 CFR 61.55, based the types and quantities of radionuclides presen t. Class A wastes may have a maximum tritium concentration of 40 curies/m 3 , or a maximum strontium concentration of 0.04 curies/m 3 [Ref. 12.3]. If both trit ium and strontium contamination are present, the maximum concentration of both radionuclides is determined by the sum of fractions rule, as described in 10 CFR 61.55. The sum of fractions rule significantly reduces the maximum concentration allowed of both (or either) radionuclide. NRC regulations stipulate that nuclear faci lities may only dispose of licensed nuclear materials offsite by transfer to an authorized recipient, in this case a licensed disposal facility [Ref. 12.1]. Currentl y, there are three commercial lo w-level waste (LLW) disposal sites in the United States. Only one of thes e sites would accept waste from Indian Point: EnergySolutions Clive Operations (Clive), located in Clive, Ut ah. Clive is licensed by the State of Utah to accept Class A waste, and accepts waste from all regions of the United States [Ref. 12.22]. In addition to meeting the concentration li mits listed in 10 CFR 61.55, Class A waste must be packaged according to 10 CFR 61.56. The pr ocessing, packaging, and final disposal of contaminated spoils would be conducted by specia lists in radioactiv e waste handling and processing. In processing, contaminated mate rials would be identif ied and separated to minimize disposal volumes and reduce the co st of regulated and licensed disposal. Contaminated materials would likely be tran sported by truck to the processing facility.



### 6.4.2 Clean Spoils
Potential options for the off-site disposal of clean spoils include sale as a commodity, use as fill material, or artificial reef building proj ects. Site geologic studi es indicate that most of the spoils would be inwood marble, a crystalline metamorphic rock “made from” limestone with considerable heat and pressure [Ref. 12.14]. Crushed stone is a major basic raw material for the construction industry. If clean inwood marble generated by excavation could be crushed onsite and sold as a crushed stone comm odity, a portion of the cost of disposal co uld be recovered. If the clean spoils are not suitable for sale as a crushed stone comm odity, another potential option for disposal is use as backfill for mine reclamation. In 1975, New York State enacted the Mined Land Reclamation law to ensure the environmentally sound, economic development of New York's mineral resources an d the return of affect ed land to productive use for current and future generations. The law requires each regulated mining operation to develop an approved reclam ation plan that provides fo r return to productive use.

Donation of the crushed rock to artificial reef projects off the coasts of New Jersey and New York was considered as another potential method of disposal. The permitting process for this method of disposal would likely repres ent significant additiona l cost of disposal and may introduce schedule delays. Therefore, other options of disposal for the clean spoils would likely be preferred. For each of the clean spoils disposal options considered, spoils would likely be removed from IPEC by barge. Transportation of the s poils by barge would be approximately half asCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

32 expensive as transportation by trucks. 6 In addition, transportation by barge would reduce the impact of construction on the surrounding community, including traffic impacts. The shoreline locations of several aggregates te rminals and existing mines in the region would enable direct barge transpor tation from IPEC. If the fina l disposal location was inland, spoils would likely be removed from IPEC by barge and transferred to trucks at another location due to roadway capacity constraints in the vicinity of IPEC. Transportation by rail has not been considered due to th e lack of a rail spur at IPEC.



### 6.5 Cost and Schedule Impacts
The expected duration of removal and disposal of excavated spoils would be enveloped by the schedule for blast removal presented in Section 5.2. The estimated cost of spoils disposal is approximately $55,620,000, including radiological contamination testing, limited radiologically contaminated spoils removal and di sposal, and clean spoils removal. The costs of clean spoils disposal woul d vary greatly depending on the fi nal disposal method. The cost of radiological testing and dispos al of limited contaminated spoils has been estimated to be approximately $9.2 million. 7
The removal and transportation of clean spoils from the excavation would cost approximately $46,436,000, including labor and equipment (loade rs, dump trucks, crushers, conveyers, barges, etc.). The final disposal location coul d significantly affect this estimate. Revenue from selling the spoils as a commodity or as backfill would offset a portion of the cost of removal, while permitting costs for artificial reef building would increase the total disposal
cost. The estimated cost/revenue of disposal would vary greatly, depending on the chosen clean spoils disposal option. Production of crushed marble in 2007 was 7.6 million metric tons valued at $71.1 million ($9.36 per metric ton) [Ref. 12.34]. Therefore, the potential revenue from selling the excavated spoils as crushed stone could theoretically be over $37 million. However, it is likely that the stone would be transported to and sold by a third party, which would likely significantly decrease the actual revenues that could be collected. Less revenue would be expected if the spoils were used as mine backfill. The costs of permitting would include preparation of the a pplication, applicatio n fees, and any associated legal fees.

6 The costs of transportation by barge and by truck were compared using 2009 cost data in MeansCostWorks.com. Estimated barge transport cost is based on the expected construction schedule while truck transport cost is based on total excavation spoils. Due to this discrepancy in cost rate basis, any change to the planned excavation methods that would lengthen construction schedule would also decrease the cost savings of barge transport.

7 Cost of radiologically contaminated spoils testing and disposal is based on prior decommissioning work and disposal quotes from Toxco Materials Management Center, a radiological disposal company.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

33 

## 7 Cooling Tower Operation / Plume Emissions
The operation of the two hybrid cooling towers sele cted is described in de tail in the 2003 Report (Attachment 1); however, several specific conc erns are discussed in further detail below.



### 7.1 Water Consumption

Conversion of Unit 2 and Unit 3 to closed-loop cooling would significantly reduce the water intake currently required by each Unit. However, a continuous supply of water would still be withdrawn from the Hudson River for evaporat ive cooling tower operation, and 75% of the water withdrawn would be consumed. In term s of water consumption, closed-loop cooling systems have substantially more potential e nvironmental impacts th an once-through systems [Ref. 12.21]. Evaporation and drift from the cooling towers w ould represent a significa nt loss of circulating water that would have to be replenished. Unlike with the current once-through cooling, the water lost through evaporation and drift would not be returned directly to the Hudson River and would represent a true loss of River water. Typically, evaporating water leaves a cooling tower as a pure vapor, increasing the concentra tion of total dissolved solids (TDS) in the circulating water. Local air quality also cont ributes to circulating water quality degradation, as the air is effectively washed by the water in the tower (i.e., the cascading water in the cooling tower acts as a scrubber that rem oves particulates from the atmosphere and concentrates them in the circulating water). To maintain the required water quality for the cooling towers sited at IPEC, a portion of the concentrated circul ating water, referred to as blowdown, would be released to and replaced wi th water from the Hudson River. Therefore, a continuous circulating water supply of 27,440 gpm (Equation 5) would be required to make up the total losses from evaporation, drift, and blowdown. Evaporatio n and drift from the towers would amount to 20,594 gpm (Equation 6), or nearly 30 million gallons per day, of lost Hudson River water.



### 7.1.1 Hudson River Water Consumption

The brackish water from the Hudson River curren tly used in the Stations’ circulating water systems would also be used for the circul ating water in a closed-loop system. Hudson River water analysis and flow rate data show that the plant intake is largely fresh water during times of relatively high River flow ra te, and very brackish when River flows are low. As discussed above, evaporation in the cooling tower would increase the concentration of dissolved solids in the circulating water, as compared to the River water. The number of times the dissolved minerals in the circulating water are concentrated, versus the level in the River water, i.e., th e cycles of concentra tion, is an important parameter for cooling tower operation. Since the intake water qual ity at IPEC varies dramatically based on Hudson River flow ra te, an acceptable number of cycles of concentration would be dependent on the curr ent intake water quality. The cooling tower circulating water salinity would be maintain ed at approximately 7200 ppm, or between three and five cycles, depending upon the makeup water salinity 8 . The higher the salt

8 Chloride concentration (salinity) data was obtained by the U.S. Geological Service for the Verplanck Station, immediately adjacent to IPEC, for the period 1969 to 1975 (Attachment 1).CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

34 content of the makeup water, the fewer cycles of concentration are necessary to maintain 7200 ppm dissolved solids in the circulating water. Estimated blowdown and makeup flow rates would be based on an annual average Hudson River makeup water salinity of 1800 ppm and four cycles of concentration, meani ng that the concentrati on of total dissolved solids in the circulating wate r would be four times that of the incoming Hudson River water [Ref. 12.29]. To achieve an average of four cycl es of concentration in implementation, an automated control system would be required to reduce makeup flow during periods of good water quality (relativel y fresh water) and in crease makeup flow during periods of poor water quality (brackish water). The evaporation and drift flow rates can be calculated using the tower specifications provided by the cooling tower vendor, SPX Cooling Technologie s (SPX). Evaporation can be approximated by multiplying the maximum evaporation percentage, 1.47% for summer conditions with the dry section of the cooli ng towers in operation (Attachment 1), by the total water flow rate (gpm). Per the cooli ng tower vendor, SPX, the total circulating water flow rate required by each Unit at IPEC would be 700,000 gpm. Therefore, the maximum evaporation flow rate from the cooling towe rs for each Unit at IPEC is estimated as follows:

gpm 290 10 gpm 700,000 % 1.47 % Unit n Evaporatio Unit , Q E      (1)
The drift rate is calculated by multiplying the drift percentage, 0.001% in this case (Attachment 1), by the total water flow rate (gpm):

gpm 0

. 7 gpm 000
, 700 % 001

. 0 % Unit Drift Unit      Q D (2)
The required blowdown to maintain 4 cycles of concentration, C 4 , is estimated using the expected evaporation and drift rates [Ref. 12.28]: 

###   

###     gpm 423
, 3 3 gpm 0

. 7 3 gpm 290
, 10
1 1

4 Unit 4 Unit Unit  





 

 

 C D C E B (3)

The makeup flow required by each Unit for coo ling tower operation at IPEC is the sum of tower water losses due to evapor ation, drift, and blowdown:

gpm 720
, 13 gpm 423
, 3 gpm 0

. 7 gpm 290
, 10 Unit Unit Unit Unit        B D E M (4)
Figure 7.1 provides a per Unit closed-loop flow cycle, including makeup, evaporation, drift, and blowdown flowrates.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

35 Figure 7.1 IPEC per Unit Closed-Loop Flow Cycle The total estimated makeup flow required by IPEC is double the makeup flow required by each Unit:

MGD 5

. 39 gpm 440
, 27 gpm 720
, 13 2 2 Unit Total       M M (5)

The total estimated water flow lost from the Hudson River is double the evaporation and drift flow from each Unit: 

###   MGD 7

. 29 gpm 594
, 20 gpm 0

. 7 gpm 290
, 10 2 2 Unit Total        L L (6)
As described in Section 2.1.2.1, the closed-loop configuration considered in this Report would use service water discharge to pr ovide makeup flow. The maximum required makeup flow, based on histor ical meteorological data an d River conditions, would not exceed the design capacity of the Stations’ serv ice water systems, i.e., 46,000 gpm at Unit 2 (including Unit 1 River water flow of 16,000 gpm) and 36,000 gpm at Unit 3 [Ref. 12.17, 12.18]. IPEC has a maximum design fl ow capacity of 886,000 gpm for Unit 2 and 876,000 for Unit 3 [Ref. 12.8]. Therefore, the cl osed-loop cooling re ductions in intake flow from total design flow would exceed 94.8% and 95.9% for Units 2 and 3, respectively. Based on historic flow data from 2001 to 2008, flow reductions would be approximately 98.0% at Un it 2 and 97.8% at Unit 3.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

36 

### 7.1.2 Recycled Wastewater Consumption
Consideration has been given to the use of recycled wastewater as an alternative to using Hudson River water as makeup water for a clos ed-loop cooling system at Units 2 and 3. The use of recycled wastewater as makeup for cooling towers has been studied at coastal power plants in California (Attachment 1). R ecycled wastewater can be treated to enable cooling tower operation at six cycles of con centration, meaning that the concentration of TDS in the circulating water would be six time s that of the incoming recycled wastewater The estimated evaporation and drift rates woul d be unaffected by the allowable cycles of concentration; therefore, the values would be identical to those calculated in Section 7.1.1:

gpm 290 10 Unit , E  gpm 0

. 7 Unit  D
The required blowdown to maintain 6 cycles of concentration, C 6 , is estimated using the expected evaporation and drift rates [Ref. 12.28]: 

##   

##     gpm 051
, 2 5 gpm 0

. 7 5 gpm 290
, 10
1 1

6 Unit 6 Unit Unit   



   

 C D C E B (7)

The makeup flow required per Unit for cool ing tower operation at IPEC using recycled wastewater would be the sum of tower wa ter losses through evapor ation, drift, and blowdown:

gpm 348
, 12 gpm 051
, 2 gpm 0

. 7 gpm 290
, 10 Unit Unit Unit Unit        B D E M (8)
The total makeup flow required by IPEC would double the makeup flow required by each Unit:

MGD 6

. 35 gpm 696
, 24 gpm 348
, 12 2 2 Unit Total       M M (9)
The feasibility of the recycl ed wastewater option depends on the distance between IPEC and the nearest wastewater trea tment facilities able to provide adequate makeup flow, as well as the quality of the recycled wast ewater and available treatment options. The SPDES permits, discharge flow rates, and distances from IPEC for all SPDESpermitted wastewater treatment plants (WWTPs ) located in Westchester County are shown in Table 7.1. The distances from IPEC ar e based on either the facility address or the outfall GPS coordinates liste d in the SPDES permits.

Table 7.1 SPDES Water Di scharge Permit Flows

Facility (SPDES Permit) Flow % Req’d Makeup

Flow Driving Distance to IPEC (approx.) Direct Distance (approx.)

Buchanan WWTP

(NY0029971) 0.5 MGD (347.2 gpm) 1.4% <1 mi. <1 mi.

Peekskill WWTP

(NY100803) 10 MGD (6,944.4 gpm) 28.1% 4 mi. 3 mi.

Ossining WWTP

(NY108324) 7 MGD (4,861.1 gpm) 19.7% 10 mi. 9 mi.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

37 Facility (SPDES Permit) Flow % Req’d Makeup

Flow Driving Distance to IPEC (approx.) Direct Distance (approx.)
Yorktown Heights WWTP (NY0026743) 1.5 MGD (1,041.7 gpm) 4.2% 13 mi. 9 mi.

North Castle WWTP (NY109584) 0.38 MGD (263.9 gpm) 1.1% 25 mi. 16 mi.

Wild Oaks WWTP (NY0065706) 0.06 MGD (41.7 gpm) 0.2% 29 mi. 16 mi.

Port Chester WWTP (NY0026786) 6 MGD (4,166.7 gpm) 16.9% 30 mi. 25 mi.

Oakridge WPCF

(NY0030767) 0.08 MGD (55.6 gpm) 0.2% 31 mi. 23 mi.

Yonkers Joint WWTP (NY0026689) 92 MGD (63,888.9 gpm) 100% + 31 mi. 25 mi.

Blind Brook County WWTP (NY0026719) 5 MGD (3,472.2 gpm) 14.0% 32 mi. 26 mi.

Mamaroneck WWTP (NY0026701) 18 MGD (12,500.0 gpm) 50.6% 34 mi. 26 mi.

New Rochelle WWTP (NY0026697) 13.6 MGD (9,444.4 gpm) 38.2% 38 mi. 27 mi.

As shown in Table 7.1, the SPDES perm its for the twelve SPDES-permitted WWTPs located in Westchester Count y indicate that only Yonkers Joint WWTP could provide sufficient makeup flow for closed-loop cooling towers. The Yonkers Joint WWTP is located approximately 25 miles south-southeas t of IPEC along the eastern shore of the Hudson River. Pipelines di rectly connecting IPEC and the Yonkers Joint WWTP would have to be routed and installed thr ough or around numerous waterfront commercial, residential, and industria l districts, an Amtrak commuter tr ain rail line, and the Briarcliff Peekskill Parkway (New York State Route 9A ). The considerable costs and numerous permits required for such an installation would represent considerable feasibility, cost and schedule impacts to the conversion project. To avoid long stretches of pipe installation, co mbining the flow rate of multiple facilities closer to IPEC was considered. However, th e combined discharge fl ow rates of all eight other WWTFs located less than 25 miles (direct distance) from IPEC would not provide sufficient makeup flow for cl osed-loop cooling towers. Assuming recycled wastewater could be transported through 25 miles of heavilydeveloped New York shoreline, recycled wastewater from Yonkers Joint WWTP would need to undergo a series of further treatmen ts to enable cooling tower operation at six cycles of concentration. This treatment would be similar to that of the 90 MGD recycled wastewater treatment plant located at the Palo Verde Nuclear Generating Station [Ref. 12.26], albeit utilizing approximately 40 percent of the flow rate (35.6 MGD). Using Palo Verde’s recycled wastewater treatment plan t (including the storage reservoir) forCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

38 comparison, if recycled wastewater from Yonkers Joint WWTP was utilized, the water treatment system required by the Stations would occupy approximately 16 acres. Construction of a recycled wastewater treatment plant of this size would further increase the costs associated with transporting and pr ocessing recycled wate r for use as makeup flow for closed-loop cooling towers. As a resu lt of the considerable unknowns, costs, and the numerous permits required, using recycled wastewater from Yonkers Joint WWTP is considered infeasible.



### 7.2 Cooling Tower Plume Emissions

Pursuant to the Interim Deci sion governing this SPDES permit proceeding, air permitting expert TRC Environmental Corporation (TRC) ev aluated the potential air quality impacts of cooling tower plume emissions on the surroundi ng community, consistent with applicable federal, state and local law [R ef. 12.29]. TRC concluded that drift from the cooling towers would contain an appreciable concentration of dissolved minerals and additives that form particulate matter (PM10 and PM2.5). As such, the cooling towers, individually and collectively, would result in particulate matte r emissions. TRC determined that these emissions would exceed the National Ambient Ai r Quality Standards for PM10 and PM2.5. TRC also examined mitigation measures to redu ce particulate emissions, but concluded that available mitigation measures would not sufficien tly redress air quality concerns in a manner consistent with applicable re gulatory requirements. TRC c oncluded that the particulate emissions from the cooling towers will cause an adverse air quality im pact to the surrounding community such that obtaining the required co nstruction and operating air emissions permits would not be possible. The conclusion reached by TRC for the Stations’ cooling tower particulate emissions mirrors the conclusion reached for San Onofre Generati ng Station (SONGS) [Ref. 12.9]. SONGS is located in San Diego County, which like the ar ea surrounding IPEC, is currently designated as non-attainment for PM10 and PM2.5. At S ONGS, drift impacts due to the operation of closed-loop salt water cooling towers would be significant and require a major-source Title V air permit from the San Diego County Air Pollution Control District. It was determined that it would be unlikely that SONGS could locat e and purchase a sufficient number of PM10 emission credits to cover the emissions from closed-loop salt water cooling towers. If the required drift offsets were unavailable, conve rsion of SONGS to closed-loop cooling would be infeasible.



### 7.3 Plume Abatement
As discussed in Section 2, the cooling towers that would be installed at Units 2 and 3 would be round hybrid towers designed w ith noise and plume abatement f eatures, that come at a cost to electric output. When cooling towers are operated without abatement, visible water vapor plumes can form under certain meteorological conditions. According to TRC [Ref. 12.29], these visible plumes normally would be confin ed to the area immedi ately over the cooling tower and over the IPEC property, although under cool temperatures (typ ically during the late fall, winter, and early spring se asons) with high ambient humidity, elevated visible plumes could extend for several hundred to thousands of meters. TRC’s results indicate that, without plume abatement (i.e., operation of the cooling to wers without using the dry section), a visibleCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

39 plume would occur immediately south and northw est of each cooling tower for 610 daylight hours per year on average. Plumes could not only result in complaints by local residents and busin esses, but also may contribute to corrosion and ice formation on nearby components and plume shadowing (which could affect the local agriculture by decreasing the amount of am bient sunlight). Therefore, in order to avoid visible pl umes, the cooling towers at IPEC would be operated with continuous plume abatement, with a corresponding lo ss in electricity output . As discussed in Section 3.2.2.2, utilizing the 44 dry section fans (350 HP) at maximum capacity to achieve continuous plume abatement would result in a loss of more than 13.5 MWe per Unit (over 100,000 MW-hrs annually per Unit).CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

40 

## 8 General Site Considerations

8.1 Aesthetic Impacts
The conversion of the Stations to closed-loop co oling would require seve ral new structures to be constructed on the site (Secti on 2), the largest being the hybr id cooling towers. A Visual Assessment (VA) was prepared by visual anal ysis expert Saratoga Associates, Landscape Architects, Architects, Engineer s and Planners, P.C. (Saratoga ). Saratoga evaluated the potential visual impact of these structures on th e scenic resources of the region consistent with applicable state and local law and policy [Ref. 12.25]. Saratoga concluded that, given their unprecedented scale and visual impact, constructi on and operation of cooling towers at IPEC, singularly or collectively, cannot be reconciled with applicable aesthetic standards, practice, or precedent. Specifically, Saratoga determin ed that the NYSDEC Proposed Project may be incompatible with the NYSDEC Visual Policy in that it impairs scenic resources of statewide significance. Furthermore, it is concluded that mitigation techni ques would have little effect.

Figure 8.1 Visual Representati on of Cooling Towers at IPEC 9



### 8.2 Archaeological Considerations

Phase I-A and Phase I-B archeo logical studies were conducted by ENERCON to assess the presence of historic properties in the Area of Potential Effect (APE) from cooling tower installation at IPEC [Ref. 12.10]. The Phase I studies identified evidence of both historic and pre-historic components in the APE. Reports documenting these findings were submitted to

9 The visual representation of cooling towers at IPEC provided is for wet-mode operation of the cooling towers. This has been provided to illustrate the magnitude of the plume that is created, either visible (wet-mode) or invisible (plume abated). It should be noted that even with pl ume abatement, a visible plum e would occur under certain meteorological conditions.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

41 the New York State Historic Preservation Office (NYSHPO). NYSHPO indicated that if a decision is made to install cooling towers, the APE should be reassessed, a geomorphological assessment should be conducted (if warranted), a nd a Phase II archaeologi cal site examination should be conducted for the historic and prehis toric components identified in the Phase I studies. Additional information on the corr espondence between ENERCON and NYSHPO is documented in Attachment 8.

In the event of a decision to proceed with the NYSDEC Pr oposed Project, a Phase II investigation would be undertak en to determine if significan t archeological deposits are present. The duration and cost of a Phase II investigation is unknown at this time. Since no additional archaeological cost or schedule delay ha s been incorporated in this report, both cost and schedule are understated.



### 8.3 Local Zoning Restrictions
Entergy’s counsel has advised that the NYSDEC Proposed Projec t will be subject to certain local zoning restrictions. IPEC is located wi thin the M-2 Planned Indus trial Zoning District of the Village of Buchanan a nd the Village Zoning Code establ ishes restrictions on both the use of, and dimensions of, struct ures located on property within this District [Ref. 12.2; Ref. 12.6].



### 8.3.1 Use Regulations
Section 211-10 of the Zoning Code authorizes “the peaceful use of atomic energy” as a principal use of the IPEC property [Ref. 12.6] . Entergy’s counsel has advised that the Village may view the NYSDEC Proposed Project as a separate use, given the blasting, crushing, transport and potentia l sale of clean excavated spoi ls involved. Section 211 does not allow mining, and the Village may prohibi t blasting and/or crushing operations. The Village does permit certain accessory uses, but these appear to be limited to residential uses (i.e., swimming pools, etc) and certain re tail sales. Thus, obtaining the requisite zoning approvals for the NYSDEC Pr oposed Project is not assured.



### 8.3.2 Performance Standards Related to Non-Residential Uses
Section 211 of the Village Zoning Code also es tablishes standards for non-residential uses, including noise and air polluti on standards [Ref. 12.6]. As discussed below, due to these standards, obtaining the requisite zoning a pprovals for the NYSDEC Proposed Project is not assured.



### 8.3.2.1 Noise

Section 211-23 establishes enforceable sta ndards for noise generating activities [Ref. 12.6]. The table on the following page pr ovides the allowable decibel levels (as measured at the property lin e), for each frequency range.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

42 Frequency Ranges Containing Standard Octave Bands (cycles per second) Octave Band Sound-Pressure Level (decibels)

20 to 75 65 75 to 150 55 150 to 300 50 300 to 600 45 600 to 1200 40 1200 to 2400 40 Above 2400 35

Adjustments to the above standards are av ailable if the noise is “not smooth and continuous and is not radiated between the hours of 10:00 pm and 7:00 am.” Because the cooling towers would be ope rated continuously and, ther efore, would radiate noise between 10:00 pm and 7:00 am, these adjustments would not apply.



### 8.3.2.2 Other Forms of Air Pollution
Section 211-23 governs “other forms of air pollu tion” like fly ash, dust, fumes, vapors, and gases which can cause damage to health, animals, vegetation or property [Ref. 12.6]. As noted in Section 7, TRC determined th at operation of the NYSDEC Proposed Project will result in emissions of greater than 100 tons per year of PM-10 and PM-2.5 [Ref. 12.29]. Thus, obtaining the requisite z oning approvals for the NYSDEC Proposed Project is not assured.



### 8.3.3 Dimensional Regulations
Sections 211-15 and 211-19 provide dimens ional regulations for maximum building heights in the M-2 Zoning District : (a) 2.5 stories or 35 feet for principal buildings or (b) 2.0 stories or 25 feet for unattached structures accessory to a nonresid ential building. The NYSDEC Proposed Project cooling towers are 165 feet tall (Section 2.1). Counsel has advised that the NYSDEC Proposed Project, therefore, will require a variance from the height limitation. Counsel has further advise d that variances must be obtained from the Village Board of Appeal, and may take appr oximately 6 months from application to decision. This Village denied a prior attempt to obtain a variance for the construction of cooling towers at IPEC; this became the subject of extensive litigation. 10 Resolution of this litigation took 30 m onths from the date of the Board’s variance denial to the final decision of the Court of Appeal overturning the Board’s decision.



### 8.3.4 Site Development Plan Approval
Section 211-25 requires Pl anning Board approval of a fina l site development plan before the Village Building Inspector can issue a bu ilding permit [Ref. 12.6]. Section 211-26 indicates that this ap proval is discretionary and involves consideration of environmental, engineering, and aesthetic impacts [Ref. 12.6].

10 Matter of Consolidated Edison Co. of New York, Inc. v. Hoffman , 43 N.Y.2d 598 (1978).CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

43 

### 8.3.5 Conclusions
Entergy’s counsel has advised that construction of the NYSDEC Proposed Project cannot proceed as of right. The project is dependent on approval from the Village of Buchanan, which is likely to be difficult to obtain based on past preceden t. Based on precedent, it is assumed that zoning approvals and associated litigation would take approximately 36 months to resolve.



### 8.4 Sound Restrictions
Entergy’s counsel has advised that the NYSDEC Proposed Projec t will be subject to certain local noise restrictions.



### 8.4.1 Code of the Village of Buchanan, Chapter 119
Chapter 119, Section 5 of the Vi llage of Buchanan Code prohi bits noise associated with construction or demolition between the hours of 7:00 p.m. and 8:00 a.m., if the noise can be heard by an individual with normal hearing on public prop erty or beyond the boundaries of the property in question [Ref . 12.4]. All other loud or rauc ous noises likely to annoy or disturb people are also prohibited between 11:00 p.m. and 8:00 a.m. As shown in Attachment 2, the proposed locations for both NYSDEC Proposed Proj ect cooling towers are within approximately 50 to 100 feet of the Huds on River (i.e., public property) and the Unit 3 proposed cooling tower is within approximately 50 to 100 feet of the property boundary with the Lafarge Corporat ion. It is, therefore, re asonable to conclude that a person of normal hearing located on the Hu dson River or near the boundary with the Lafarge Corporation could he ar noises associated with construction of the NYSDEC Proposed Project. As a result, it is likely th at construction would be prohibited under Chapter 119 of the Buchanan Code betw een the hours of 7:00 p.m. and 8:00 a.m. 11



### 8.4.2 Noise Impact Evaluation
The NYSDEC procedure for assessing noise effect s is a tiered process that begins with a First Level Noise Impact Evaluation. The Fi rst Level Noise Impact Evaluation determines the maximum amount of sound created at a single point in time by multip le activities of the proposed project. Factors evaluated include sound characteristics (f requency and tone), receptor locations, and the resulting increase in noise from ambient levels. The Second Level Noise Impact Evaluation is subsequently performed and refines the evaluation of the noise impact potential by factoring in any a dditional noise attenuation that will be provided by the existing topography and fabricated st ructures including walls, berms, dense vegetation, or buildings. Wh en the First and Second Level Noise Impact Evaluations indicate that significant noise effects may occur from a pr oposed project, a Third Level Noise Impact Evaluation is performed that evaluates the options for implementation of mitigation measures that avoid or diminish si gnificant noise effects to acceptable levels.

11 An ambient sound monitoring program was conducted in the vicinity of Units 2 and 3 between September 2001 and January 2002 [Ref. 12.30]. The program concluded that both cooling towers operating continuously will cause in increase in noise levels at sensitive receptors of 1 dB(A) or less. Thus, operation of the NYSDEC Proposed Project cooling towers – as distinct from construction activ ities –is not likely to have a recognizable noise impact.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

44 Mitigation measures may include reducing no ise frequency or impulse noise by changing equipment, modifying equipment, or usi ng the appropriate muff lers; reducing noise duration by limiting the days of operation or hours where construction is allowed; and, reducing noise levels by increasing setbacks, erecting sound barriers, or preserving natural barriers as possible. As stated above, construction activities to convert Units 2 and 3 to closed-loop cooling would likely be restricted to between 8:00 a.m. and 7:00 p. m. and would require a noise impact evaluation.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

45 

## 9 Construction and Outage Duration
As discussed in Section 2, three design alternat ives are considered for closed-loop cooling at IPEC: (1) retrofit both Units to closed-loop coo ling, (2) retrofit only Unit 2 to closed-loop cooling, or (3) retrofit only Unit 3 to closed-l oop cooling. Conceptual construction and outage schedules have been developed fo r all three alternativ es and are provided in Attachment 9. Considering the conceptual na ture of the current design pa rameters and the unknown forces outside of the project’s direct co ntrol, many of the tasks are aggr essively optimistic and could be severely impacted as work progresses. Th e initial design and all permitting and licensing requirements are assumed to be completed prior to the start of constructi on. Construction work and field engineering would continue in ta ndem up to and through the recommended outage period. Several factors could present signi ficant scheduling challenges but were not considered for the conceptual construction and outag e schedule. These issues, along with the scheduling issues addressed in this report, in clude but are not limited to:

 Duration of regulatory agency interacti ons (e.g., federal, state and local zoning/permitting/licen sing restrictions).

 Prior relocation of th e Algonquin gas pipeline.

 Uncertainty surrounding the large volume of uncontaminated and radiologically contaminated spoils and cons truction debris disposal.

 Construction delays due to the possible di sturbance of tritiated groundwater pathway.

 Riverside activities and potenti al maritime implications.

 Archaeological concerns delaying constructio n or requiring resiting of the cooling
towers.

 Resource availability (material, equipmen t, and most specifically craft labor).

 Impacts of increased plant security and th e necessary construction equipment access.

 Unpredictable weather phenomena (e.g ., blasting weather restrictions).

The above concerns are not all inclusive but represen t some of the majo r challenges to the NYSDEC Proposed Project. It would be difficult to determine the exact impacts at this point based on probability or severity of the issue involved, but each would tend to increase overall cost and schedule, some substantially. Subject to the uncertainty deta iled above, Attachment 9 provides a schedule of the significant construction activities for each of the three desi gn alternatives. It should be noted that to accurately reflect the timeframe during which cons truction activities would begin, the estimated local zoning/permitting duration of 36 months, pr ovided by Entergy’s counsel, is included within each schedule.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

46 

### 9.1 Conversion of Unit 2 and Unit 3
As discussed in Section 2.1, the conversion of both Units 2 and 3 to closed-loop cooling would require the installation of two round hybrid cooling towe rs and the associated piping and equipment. As shown in Attachment 9, the total length of construction would extend approximately 97 months including approximate ly 42 weeks of continuous forced outage. Considering the conceptual nature of the cu rrent design parameters and the unknown effects of outside forces, the scheduling of many task s are understated and could be significantly impacted, as discussed above.



### 9.1.1 Online Construction Schedule
As discussed in Section 2.1, the cooling towers would be placed to the northeast and southwest of the Station’s Containment Buil dings, as shown in Attachment 2, Sketch ENTGNU011-SK-001. To this ex tent, construction activities that would not be impactive to operation, including excavat ion of the cooling tower ba sins and relocation of the Algonquin Pipelines, could be conducted with each Unit online. Prior to construction of the cooling towers, seve ral general site activities would have to be completed at both Units, including access road construction, fence relocation and additions, environmental protection measures , barge access construction and security modifications. Approximately 13 weeks of general construction ac tivities would be required at Unit 2 prior to cooling tower construction.

Several additional activities would have to be undertaken at Unit 3, in cluding relo cation of the Algonquin pipelines, an existi ng parking lot, and the current sewage lift station and the demolition of the existing sewage treatment fac ilities that would resu lt in approximately 118 weeks of general construction activities prior to the construction of the cooling tower. Therefore, construction of the Un it 2 cooling tower would be able to begin first, and, after the additional activities were finished at Unit 3, construction of the Unit 3 cooling tower could begin. Subject to schedule uncertain ty, cooling tower constructi on would be limited by the drilling rate of blast operations, as discusse d in Section 5, and is estimated to take approximately 271 weeks at Unit 2 and 284 weeks at Unit 3 (see Attachment 9). Construction of the Unit 3 cooling tower w ould begin approximately 3 months after the start of construction on the Unit 2 cooling tower. As discussed in Section 5, construction of hybrid cooling towers woul d entail significant excavatio n at IPEC and would require approximately 4 years for blas ting and rock removal alone.



### 9.1.2 Outage Construction Schedule

In contrast to those activities outlined in Section 9.1.1, due to the proximity of several construction activities to nuclear safety-relate d equipment and the impact on or removal of equipment necessary for power generation (e.g., circulating water pumps), certain activities would require consecutive extended constructi on outages. Due to the joint nature of several of the construction activ ities (i.e., demolition of the Ri verfront area, construction of the pump houses in the existing discharge cana l, etc.) the construc tion outages would be conducted concurrently. Approximately 42 weeks of continuous outage for theCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

47 construction and implementation of closed-loop cooling would be required for each Unit. At IPEC, maintenance and refueling outages are scheduled to occur approximately every 24 months for each Unit and typically last a pproximately 25 days. The scheduled outages are staggered so that both Units are not offline at the same time; therefore it is likely that the extended construction outages could be scheduled to coincide with one Unit’s scheduled maintenance outage.



### 9.2 Conversion of Only Unit 2
As discussed in Section 2.2, the conversion of Unit 2 to closed-loop cooling would require the installation of one round hybrid cooling tower and the associated piping and equipment. As shown in Attachment 9, the total length of construction would extend more than 73 months including approximately 42 week s of continuous outage, schedul ed to coincide with Unit 2 maintenance and refueling outage (i.e., a 38 week continuous for ced outage). Considering the conceptual nature of the current design parame ters and the unknown effe cts of outside forces, the scheduling of many tasks represents a be st-case scenario and could be significantly impacted, as discussed above.



### 9.2.1 Online Construction Schedule
As discussed in Section 2.2, the Unit 2 cooli ng tower would be placed to the northeast of Unit 2, as shown in Attachment 2, Sket ch ENTGNU011-SK-002. To this extent, construction activities that would not be imp active to operation, including excavation of the cooling tower basin, could be conducted with the Unit online. Prior to construction of the cooling towers, seve ral general site activities would have to be completed including access road construction, fence relocation and additions, and security modifications environmental protection. In addition to these ac tivities, barge access construction would be required resulting in approximately 13 weeks of general construction activities prior to cooling tower construction. Subject to schedule uncertain ty, cooling tower constructi on is estimated to take approximately 270 weeks (see Attachment 9). As discussed in Attachment 7, construction of a hybrid cooling tower at Un it 2 would entail significant excavation and would require approximately 4 years for blas ting and rock removal alone.



### 9.2.2 Outage Construction Schedule

In contrast to those activities outlined in S ection 9.2.1, due to the proximity of several construction activities to nuclear safety-relate d equipment and the impact on or removal of equipment necessary for power generation (e.g., circulating water pumps), certain activities would require consecutive extended construc tion outages. Approximately 42 weeks of continuous outage for the construction and im plementation of closed -loop cooling would be required. At IPEC, maintenance and refueling outages are scheduled to occur approximately every 24 months a nd typically last approximately 25 days. It is likely that the extended construction outages could be sche duled to coincide with Unit 2’s scheduled maintenance outage, resulting in a non-pl anned forced construction outage of approximately 38 weeks.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

48 

### 9.3 Conversion of Only Unit 3
As discussed in Section 2.3, the conversion of Unit 3 to closed-loop cooling would require the installation of one round hybrid cooling tower and the associated piping and equipment. As shown in Attachment 9, the total length of construction would ex tend approximately 98 months including approximately 42 weeks of c ontinuous outage, scheduled to coincide with Unit 3 maintenance and refueling outage (i.e ., a 38 week continuous forced outage). Considering the conceptual nature of the cu rrent design parameters and the unknown effects of outside forces, the scheduling of many tasks represents a best-case scenario and could be significantly impacted, as discussed above.



### 9.3.1 Online Construction Schedule
As discussed in Section 2.3, the cooling to wer would be placed to the southwest of the Unit 3, as shown in Attachment 2, Sket ch ENTGNU011-SK-003. To this extent, construction activities that would not be imp active to operation, including excavation of the cooling tower basin and relocation of the Algonquin Pipelines, could be conducted with the Unit online. Prior to construction of the cooling towers, seve ral general site activities would have to be completed including access road construction, fence relocation and additions, and security modifications environmental protection. In addition to these ac tivities, barge access construction, relocation of the Algonquin pipelines, an existing parking lot, and the current sewage lift station and the demolition of the existing sewage treatment facilities would result in approximately 118 weeks of gene ral construction activities prior to the construction of the cooling tower. Subject to schedule uncertain ty, cooling tower constructi on is estimated to take approximately 288 weeks (see Attachment 9). As discussed in Attachment 7, construction of a hybrid cooling tower at Un it 3 would entail significant excavation and would require approximately 4.2 years for bl asting and rock removal alone.



### 9.3.2 Outage Construction Schedule

In contrast to those activities outlined in S ection 9.3.1, due to the proximity of several construction activities to nuclear safety-relate d equipment and the impact on or removal of equipment necessary for power generation (e.g., circulating water pumps), certain activities would require consecutive extended construc tion outages. Approximately 42 weeks of continuous outage for the construction and im plementation of closed -loop cooling would be required. At IPEC, maintenance and refueling outages are scheduled to occur approximately every 24 months and typically last approximat ely 25 days. Subtracting the planned maintenance outage from the constr uction outage duration, implementation of closed-loop cooling at Unit 3 would require a non-planned forced construction outage of approximately 38 weeks.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

49 

## 10 Economic and Power Loss Estimates

This section estimates the costs or lost electr ical generation for the five major aspects of converting IPEC Units 2 and 3 to closed-loop cooling:

 initial capital costs

 construction outage lost electrical generation

 lost electrical generation due to new condenser operating parameters

 lost electrical generati on due to parasitic losses

 operation and maintenance costs, including water treatment costs The capital costs of the closed -loop conversion include design, procurement, implementation, and startup activities, as detailed in Attachme nt 10. The duration of the required Unit outages described in Section 9 is used to dete rmine the lost electrical generation.



### 10.1 Initial Capital Costs
The initial capital costs to convert the Stati ons to closed-loop cooling include the cost of engineering design; the selecti on, procurement, and installa tion of major equipment (i.e., cooling towers, pumps, valves, etc.); and the co sts of closed-loop constr uction, including the blasting required to excavate the cooling towe r areas. Capital cost estimation was done in such a way as to minimize the necessary assu mptions, and relied inst ead on well-developed, detailed conceptual designs to increase th e accuracy of the estimates. The 2003 Report (Attachment 1) lists the components and constr uction activities necessary for closed-loop operation, providing a high level of detail to the conceptual design estimation. Three estimation techniques were used to determine the initial capital costs: (1) Vendor provided budgetary estimates Leading industry vendors were contact ed for updated quotations on the major equipment and material components to al low for as accurate an estimation as possible, with the correspondence, referenc e material, and quotations provided in Attachment 9. (2) Third-party detailed construction estimates Since blasting at each of the cooli ng tower sites would require a unique engineering solution, a nationally recognized consultant was used to determine a conceptual design, cost, and sche dule for blasting (Attachment 7). (3) Computational estimation utilizing na tional production rates and cost factoring Remaining cooling equipment and constr uction activities were estimated using 2009 RSMeans cost data software at MeansCostWorks.com. RSMeans is a construction cost estimating tool that pr ovides detailed cost estimates for the construction industry including labor, pipi ng, concrete, industrial equipment, electrical systems, and other heavy construction components.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

50 The capital cost estimate contained in Attach ment 9 combines these resources to produce a conceptual cost analysis. The major cost cente rs were defined and pr esented in line item format in order to provide flexibility in the ap plication of cost. Some of these line items would be equally shared by both Units 2 and 3 as several of the required construction activities would be common between both Units. These common costs would not simply be cut in half and are conservatively assumed to remain if only one Unit were converted to closed-loop cooling since there would be additi onal costs associated w ith ensuring that the operating Unit not being converted would not be adversely impacted by construction at the other Unit. The engineering, design, and inspection cost was estimated at 15% of estimates which were not quoted for turn-k ey construction [Ref. 12.31]. The anticipated direct capital co st (presented in 2009 US dolla rs) for the conversion for both IPEC Unit 2 and Unit 3 is collectively estimated at a minimum of $1.19 billion without any escalation over time. The anticipated direct ca pital cost for the convers ion of only Unit 2 is estimated at a minimum of $629 million, and th e anticipated direct capital cost for the conversion of only Unit 3 is estimated at a mi nimum of $649 million, without any escalation over time. The one-time costs of conversion of both IPEC Units 2 and 3 to closed-loop cooling are summarized in Table 11.1.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

51 Table 10.1 One-Time Costs of Conversion of both Units 2 and 3 to Closed-Loop Cooling
Capital Costs - Design Estimated Cost Design Engineering and Modification Packages $ 25,526,000 Project Management and Support Labor $ 44,598,000 Capital Costs - Turn-Key Estimates Estimated Cost Blasting $ 40,108,000 Round Hybrid Cooling Tower (2) $ 410,000,000 Relocation of Algonquin Pipeline $ 13,800,000
Subtotal $ 463,908,000 Capital Costs - Construction Estimated Cost Phase I - Online (Pre-Outage) $ 89,495,000 Phase II - Offline (Outage Required) $ 80,672,000
Subtotal $ 170,167,000 Capital Costs - Total Work Scope Estimated Cost
Subtotal $ 704,199,000 Corporate Overheads and Work In Progress Cost (30%) $ 211,260,000 Recommended Minimum Contingency (30%) $ 274,638,000
Total One-Time Costs $ 1,190,097,000



### 10.2 Lost Electrical Generation Due to Construction Outage

From the construction schedules discussed in S ection 9 and detailed in Attachment 9, IPEC Units 2 and 3 would require approximately 42 weeks of continuous outage for the construction and implementation of closed-loop cooling. Maintenance and refueling outages are scheduled to occur approximately every 24 months for each Unit and typically last approximately 25 days. The scheduled outages ar e staggered so that both Units are not offline at the same time; therefore it is likely th at the extended construc tion outages could be scheduled to coincide with one Unit’s sche duled maintenance outage. Subtracting the planned maintenance outage from the construc tion outage duration, one Unit would require a non-planned construction outage of approximate ly 38 weeks. As Unit 2 and Unit have respective net capacities of 1078 MWe and 1080 MW e, a 42 week outage at Unit 2 and a 38 week outage at Unit 3 would result in appr oximately 14,502,000 MWhr of lost electrical generation. A subsequent report will a ddress forced outage costs specifically. As noted in Section 9, the es timated schedule is understated.



### 10.3 Lost Electrical Generation Due to New Condenser Operating Parameters and Parasitic Losses
As discussed in Section 3, Unit 2 and Unit 3 are water-dependent , requiring a specific quantity of cooling water at a specific design temperature, here cons istently cold Hudson River water. Below this design temperature, th e Stations have the capability of marginally increasing electrical production; however, above this design te mperature the Stations produceCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

52 significantly less electricity and could ultimately impact the low pressure turbine procedural limits. To analyze the effect closed-loop co oling would have on th e Stations’ electrical generation, a state-of-the-art PEPSE model for each Unit was used. As discussed in Section 3, the annual average continuous operational losses for Units 2 and 3 were determined to be 11.1 MWe and 4.7 MWe, respectively; however , operational power losses would peak during warmest conditions when electricity demand is at its highest. Over the historical data analyzed (2001-2008), the peak combined operational power loss occurred on June 7 th , 2008 at 2PM, and accounted for a combined operational power loss of 85.4 MWe. As discussed in Section 3.2.2.2, the equipmen t necessary to operate closed-loop cooling at Unit 2 and Unit 3 would require significant input el ectricity, referred to as parasitic losses. Closed-loop conversion of the Stations util izing hybrid cooling towers would require a continuous 36.1 MWe per Unit aggregate parasitic loss (72.2 MWe, total). The lost electrical generation from both the ongoing operational efficiency losses associated operating beyond the original condenser design c onditions and the paras itic losses associated with the pumps and cooling towe r fans is summarized in Table 10.2. These losses require replacement sources, as will be addressed in a separate report.

Table 10.2 Lost Electrical Generation from Co nversion of both Units 2 and 3 to Closed-Loop Cooling

Lost Electrical Generation Annual Average Peak * Operational Efficiency Losses 15.8 MWe 85.4 MWe
Parasitic Losses ** 72.2 MWe 72.2 MWe
Total Lost Electrical Generation 88.0 MWe 157.6 MWe

* Over the historical data analyzed (2001-2008), the peak combined operational power loss occurred on June 7 th , 2008 at 2PM.

** Parasitic losses are continuous, and thus the annual average and peak electrical losses are the same.



### 10.4 Operations and Maintenance Costs
As discussed in Section 3.3 of the 2003 Repor t (Attachment 1), significant operations and maintenance (O&M) support for the closed-l oop cooling systems would be required. Additional O&M costs for the co mponents added due to the conve rsion to closed-loop cooling were estimated by identifying the general tasks for each component, and then based on operational experience and input from vendors, quantifying th e estimated required man-hours and associated costs. Although the conversion to closed -loop cooling is complex, signi ficant new/modified plant components would be limited to the cooling towers with their fans and booster pumps, and the appreciably larger circulating water pumps located in new pu mp houses. Based on the tasks identified in the 2003 Report, annual additio nal operations support for the closed-loop configuration is estimated to be approxima tely $336,000 for each Unit. Based on vendor estimates and historical data, the maintenan ce costs per Unit were estimated as follows:CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

53 Annual maintenance cost estimate per Unit (years 1-5) $670,000

Annual maintenance cost estimate per Unit (years 6-15) $1,340,000

Annual maintenance cost estimate per Unit (years 16-20) $2,680,000
As discussed in Section 3.6 of the 2003 Report (Attachment 1), additional chemicals would be injected into the makeup circulating water to prevent micro and macro fouling of the main condenser and cooling towers. Appreciably in creased costs would be associated with the increased level of water treatment required fo r closed-loop cooling. Local conditions could greatly affect annual costs, but an annual co st per Unit of approximately $1,005,000 would be extremely conservative (i.e., understated). To support the equipment necessary for continuous closed-loop operation, significant operation and maintenance would be incurred. Below is a summation of these annual costs per Unit including labor and mate rial for the hybrid cooling to wers and water treatment.

Years 1 - 5 $2,011,000/year

Years 6 - 15 $2,681,000/year

Years 16 - 30 $4,021,000/yearCONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

54 

## 11 Conclusions
Several site-specific conditions exist at IPEC that would challenge the feasibility of the NYSDEC Proposed Project. These challenges signi ficantly impact the expected duration and cost of the project, which are based on conceptual design absent any practical history of closedloop cooling retrofits at nuclear facilities.



### 11.1 Challenges to the NYSDEC Proposed Project
Challenges to the NYSDEC Proposed Project incl ude, but are not limited to, the following:

 Air emissions resulting from operation of the cooling towers would exceed the National Ambient Air Quality Standards for PM 10 and PM 2.5 . Available mitigation measures would not sufficiently redress ai r quality concerns in a manner consistent with applicable regulatory requirements.

 Due to the size of the structures, constructi on and operation of cooling towers at IPEC may be incompatible with the NYSDEC Visual Policy in that they would impair scenic resources of statewide significance. The a ddition of the cooling towers would have a significant negative aesthetic im pact on the surrounding area.

 Documented prehistoric artif acts found in the Unit 3 cooling tower location indicate that a site of archeological significance may exist.

 The construction of cooling to wers cannot proceed prior to obtaining a varian ce from the Village of Buchanan Board of Appeal (to allow construction in excess of the maximum height allowed) and a site development pl an approval from the Village Planning Board for the construction of the cooling towers. Vi llage officials are on record in opposition of the construction of cooling towers at IPEC a nd local zoning approvals may be difficult to obtain.

 Algonquin Gas Transmission pipeli nes currently exist where the Unit 3 tower would be constructed and would require relocation. The Algonquin Ga s Transmission pipelines supply approximately 50% of the natural gas demand in New England and this supply cannot be interrupted. A prelim inary evaluation suggests that relocation of the pipelines may be feasible; however, further evaluation of the pipeline relocation may impact the location and/or feasibility of the Unit 3 co oling tower. Any relocation of the Algonquin pipeline would require the prior approval of the FERC.

 Excavation in the Riverfront area would intersect ground water contamination plumes containing tritium and strontiu m. Construction delays may be introduced due to the disturbance of these plumes and the mitiga tion measures required to properly manage radiologically contaminated materials.

 Conversion of the Stations to closed-l oop condenser cooling would require the excavation of approximately 2 million cubic ya rds of soil and inwood marble bedrock. Blast removal would be required to excavate large quantities of inwood marble bedrock at the cooling tower locations and in the piping trenches outside of the Riverfront area. Because a forced outage at both Units woul d represent a considerable loss in power generation, blasting operations are proposed to occur while both Units are online. ACONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

55 preliminary blasting plan is based on IPEC seismic design bases; however, site-specific testing and evaluation of blast vibrati on on individual plant components would be required to finalize blasting limitations and methods.

 A continuous supply of approximately 27,400 gpm of makeup water would be required for evaporative cooling tower operation. Un like the current once-through cooling, the water lost through evaporation a nd drift from the towers would not be returned directly to the Hudson River, but instead would represent a true loss of cooling water. This would result in a loss of Hudson River water averaging nearly 30 million gallons per day.

 The topography of the IPEC site and gene ral space constraint s limit the potential locations for cooling towers. The elevation of the tower basin must be sufficiently low to prevent damage to condenser tubes. In ad dition, the towers requi re a 700 ft diameter excavation for clearance to ensure adequate ai r flow. The tower locations considered in this Report address these c oncerns, but any required relo cation may have significant feasibility impacts on the project.

 Conversion of IPEC to closed-loop cooling would be an unprecedented undertaking that would likely encounter unforeseen challenges during design and impl ementation. Thus, assumptions about engineering feasibility, wh ile based on best profes sional judgment, do not have the benefit of either available technology or past e fforts at comparable facilities.



### 11.2 Duration of the NYSDEC Proposed Project
The total duration of the NYSDEC Proposed Project is expected to extend almost 13 years. An eighteen month design period would preced e NYSDEC approval of th e project. A delay of 36 months is anticipated between NYSDEC approval and th e start of construction for litigation on project permitting. The estimated le ngth of construction for retrofit of both Units 2 and 3 would extend 97 months, and include an estimated 42 weeks of continuous forced outage and the permitting and construction peri od for relocation of the Algonquin pipeline. The drilling, blasting, and spoils removal would be expected to take approximately 4 years. Considering the conceptual nature of the curre nt design parameters, the lack of comparable retrofits, and typical unknown conditions that arise in major construction projects, this schedule represents a best-cas e scenario; significantly longe r durations th an currently estimated could result. If only Unit 2 were converted to closed-loop c ooling, the total length of construction would extend more than 73 months including appr oximately 42 weeks of continuous outage, scheduled to coincide with Unit 2 mainte nance and refueling outage (i.e., a 38 week continuous forced outage). If only Unit 3 were converted to cl osed-loop cooling, the total length of construction would extend more than 98 months including approximately 42 weeks of continuous outage, scheduled to coincide with Unit 2 ma intenance and refueling outage (i.e., a 38 week continuous forced outage). The design and permitting periods would be similar to those for conversion of both Units.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

56 

### 11.3 Cost and Power Loss of the NYSDEC Proposed Project
The anticipated direct overnigh t capital cost for th e conversion for both IPEC Unit 2 and Unit 3 is collectively estimated at a minimum of $1.19 billion without any escalation over time. If individually converted to closed loop cooli ng, IPEC Unit 2 and Unit 3 would have estimated capital costs of $629 million a nd $649 million, respectively. As Unit 2 and Unit 3 have net capacities of 1078 MWe and 1080 MWe, respectively, a 42- week outage at both Units 2 and 3, accounting for a coincident maintenance outage at one Unit, would result in approximately 14, 502,000 MWhr of lost el ectrical generation.

In addition to one-time costs and power loss, IPEC would al so incur annual costs due to conversion to closed-loop cooli ng. Annual operations and mainte nance costs associated with closed-loop cooling at IPEC would be more than $4 million for the first five years, with increasing costs in the subsequent years due to the need for increased equipment replacement and repair. IPEC would also incur ongoing operational and pa rasitic electrical generation losses. If the effect of closed-loop conversion on plant operation is averaged across the entire year, the combined operational losses due to decreased condenser efficiency would be approximately 15.8 MWe; however, operationa l power losses would peak during warmest conditions when electricity demand is at its high est. Over the historical data analyzed, the peak combined operational pow er loss occurred on June 7 th , 2008 at 2PM, and accounted for a combined operational power loss of 85.4 MWe. Additional parasitic losses from the circulating water pumps and the cooling to wer fans and booster pumps would add an additional 36.1 MWe per Unit in power gene ration losses. Summi ng the operational and parasitic losses, Units 2 and 3 combined woul d experience an average power generation loss of 88.0 MWe and peak summer power generation loss of 157.6 MWe. For reference, 157.6 MWe is enough electricity to sa tisfy the average power consumption of more than 1.38 million U.S. households. 12

12 Calculation based on the 2007 average U.S residential electricity consumption of 936 kWh and the 2007 nationallevel transmission and distribution loss of 6.5% [Ref. 12.32].CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

57 

## 12 References

12.1 Barlow, G. Precision Blasting in Shadow of On-Line Plant. Electrical World. February 1, 1979. pp. 43-45.

12.2 Buchanan Village Board. Comprehensive Master Plan: Village of Buchanan, NY. March 2005. Available at URL: http://www.fpclark.com/buchanan/masterplan.html Accessed February 3, 2010.

12.3 10 CFR Part 61.55. Code of Federal Regulatio ns, Title 10, Energy, Part 61, Licensing Requirements for Land Dispos al of Radioactive Waste

12.4 Code of the Village of Buchanan. Chapter 119, Noise.

12.5 Code of the Village of Buchanan. Chapter 143, Quarrying and Blasting.

12.6 Code of the Village of Buchanan. Chapter 211, Zoning.

12.7 Consolidated Edison Company of New York, Inc. Economic and Environmental Impacts of Alternative Closed -Cycle Cooling Systems for Indian Point Unit 2. Volume No. 1. December 1, 1974.

12.8 Enercon Services, Inc. Evaluation of Alternat ive Intake Technologies at Indian Point Units 2 & 3. 2010.

12.9 Enercon Services, Inc. Feasibility Study fo r Installation of Cooling Towers at San Onofre Nuclear Generating Station. 2009.

12.10 Enercon Services, Inc. Phase IB Archeol ogical Investigation of Potential Cooling Tower Construction Sites at Indian Poin t Energy Center, Westchester County, New York. July 2009.

12.11 Entergy Nuclear Operations, Inc. Applican t’s Environment Report, Operating License Renewal Stage. Appendix E to Indian Point, Units 2 and 3, License Renewal Application. April 23, 2007.

12.12 Entergy Nuclear Operations, Inc. Proce dure EN-DC-114. Project Management. Rev. 10. June 12, 2009.

12.13 GZA GeoEnvironmental, Inc. Final IP EC Quarterly Long-Term Groundwater Monitoring Report: Quarter Four 2008. New York, New York. September 1, 2009.

12.14 GZA GeoEnvironmental, Inc. Hydrogeologic Site Investigation Report, Indian Point Energy Center, Buchanan, New York. No rwood, Massachusetts. January 7, 2008.

12.15 Indian Point Energy Center. Procedure 2-AR P-SDF. Turbine Recorder. Rev. 24. 2007.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

58 12.16 Indian Point Energy Center. Procedure 3- ARP-007. Panel SDF – Turbine Recorder. Rev. 27. 2009.

12.17 Indian Point Energy Center. Indian Point 2 UFSAR. Rev. 21. 2008.

12.18 Indian Point Energy Center. Indian Point 3 UFSAR. Rev. 3. 2009.

12.19 New York State Department of Environmen tal Conservation. Fact Sheet. New York State Pollutant Discharge Elimination System (SPDES) Draft Permit Renewal with Modification, IP2 and IP3 Electric Genera ting Station, Buchanan, NY. November 2003.

12.20 New York State Department of Environmenta l Conservation. New Yo rk State Pollutant Discharge Elimination System (SPDES) Discharge Permit. SPDES Permit Number: NY-0004472.

12.21 Nuclear Energy Institute. Water Use, Electr ic Power, and Nuclear Energy: A Holistic Approach to Environmental Stewards hip. Washington, D.C. July 2009.

12.22 Nuclear Regulatory Commission. Website . NRC: Locations of Low-Level Waste Disposal Facilities. Available at URL: http://www.nrc.gov/waste/llwdisposal/locations.html Accessed February 3, 2010.

12.23 Rextag Strategies. Interstate Natu ral Gas Infrastructure Map Book. 3 rd Edition. San Diego, CA. 2009.

12.24 RS Means Company, Inc. RS Means Buildi ng Construction Cost Data 2008, 66th ed. Construction Publishers & Consulta nts, Kingston, Massachusetts. 2008.

12.25 Saratoga Associates, Landscape Architects, Architects, Engineers and Planners, P.C. Indian Point Energy Center Closed Cycle Cooling Conversion Feasibility Study Visual Assessment. June 1, 2009.

12.26 Schumerth, Dennis. Gray & Impaired Wate r Cooling in Surface Condensers and Heat Exchangers. Proceedings of PWR2006 ASME Power. Atlanta, GA. May 2-4, 2006.

12.27 Spectra Energy. Algonquin Gas Transmission. Available at: http://www.spectraenergy.com/what_ we_do/businesses/us/assets/algonquin/ . Accessed February 3, 2010.

12.28 SPX Cooling Technologies. Cooling Tower Fundamentals. 2nd Edition. Overland Park, Kansas. 2006.

12.29 TRC Environmental Corporation. Cooling Tower Impact Analysis for the Entergy Indian Point Energy Center Westchester County, New York. Lyndhurst, NJ. September 2009.

12.30 TRC Environmental Corporation. Indian Po int Peaking Facility, Sound. Draft Report 2003.CONVERSION OF INDIAN POINT UNITS 2 & 3 TO A CLOSED-LOOP COOLING WATER CONFIGURATION

59 12.31 United States Department of Energy. Cost Estimating Guide. Publication No. DOE G 430.1-1. March 28, 1997.

12.32 United States Department of Energy – Ener gy Information Administration, Frequently Asked Questions – Electricity. Available at: http://tonto.eia.doe.gov/a sk/electricity_faqs.asp . Accessed February 3, 2010.

12.33 United States Environmental Protection Ag ency. Hudson River PCBs. Available at: http://www.epa.gov/hudson/actions.htm . Accessed February 3, 2010.

12.34 United States Geological Survey. 2007 Minera ls Yearbook, Stone (Crushed). Willet, Jason. January 2009.

12.35 United States Nuclear Regulat ory Commission. Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants.