ML022680545
| ML022680545 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/13/2002 |
| From: | Chezik M US Dept of Interior (DOI) |
| To: | NRC/ADM/DAS/RDB |
| References | |
| 67FR44245 00011, ER 02/0570, NUREG-1437 | |
| Download: ML022680545 (7) | |
Text
IN REPLY REFER TO United States Department of the Interior
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OFFICE OF THE SECRETARY 0
Office of Environmental Policy and Compliance
,- ý -7 Custom House, Room 244
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Philadelphia, Pennsylvania 19106-2904 C
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ER 02/0570 Chief, Rules Review and Directives Branch U.S. Nuclear Reguli.tory Commission
._Mail Stop_T6-D59 Washington, D.C. 20555-0001
Dear Sir:
The Department of the Interior has reviewed draft Supplement 10 (NUREG-1437) to the Generic Environmental Impact Statement for the Peach Bottom Atomic Power Station (Peach Bottom),
Units 2 and 3, located on the Susquehanna River in Lancaster County, Pennsylvania. Please give these comments careful consideration in preparing final Supplement 10.
General Comments The Departrhenishares a goal with the Nucleir'kegulat6or Commission(NRC) to bring Peach Bottom into comphiance'with current environmental regulationg. -With the advances in our uniderstandimig of e6ological relationships,t it dp`propniat'e' anid uiseffil that federal and state natural resource agencies use the license renewhal procesi to'rey'iew site condtions in 'order to maintain'the highest level of'en`'ironnmienta1 protectionI.' The following comments are intended to assist the NRC with protection of natural resources.
Specific Comments Thermal Releases We recommend the inclusion of "thermal release" in final Supplement 10 as a "source of potential or lknoxxn impact:" One of the'reported negative effects of thermal discharges is increased incidence of disease and Iarasites in fish attracted to tlhe plu'e. 'D'r.'J6hn" Cairns of Virginia Polytechnic Institut6 may have piublished on this and ielated subjects; arid we suggest he be consulted. He can-be reached'at the Center for Enivirornenial and HazardousMAterials Studies, 1020 Derring Hall, -VPI&SU, Blacksburg, VA 24061-0415 (telephone': 703-231-5538).
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As a means to avoid adverse impacts to aquatic life, the Department. recommends that NRC require upgrading of this project to include a closed cooling system instead of the existing open cooling system.
Fish Entrainment and Impingement Peach Bottom is licensed to Excelon (formerly known as Philadelphia Electrical Company, or PECO) and is located in York County on the lower Susquehanna River. Since Peach Bottom came online in 1974, it has withdrawn water for cooling from Conowingo Pond, which is the lower-most pool on the Susquehanna River. The U.S. Fish and Wildlife Service (USFWS) is restoring American shad to the Susquehanna river basin. During the autumn outmigration period,
.juvenile American shad pass downstream through Conowingo Pond.
RMC Environmental Services (RMC) has been contracted by PECO to evaluate entrainment at the Peach Bottom cooling water intake. RMC examined intake-screen-wash samples for juvenile American shad over the last eight autumn outmigration periods. RMC found juvenile shad impinged each year, except 1987-1988 when Peach Bottom was shut down. Samples were taken three times each week and represented the total accumulation of impinged fish. The number of impinged juvenile shad found has ranged from a high of 341 fish in 1986 (October 14 December 10) to a low of 3 fish in 1989 (August 22 through November 22). This level of mortality, by itself, is not considered detrimental to the Service's restoration program, but the loss must be considered within the context of other sources of loss. These numbers are expected to increase as the number of American shad restored to the Susquehanna River also increases.
About two dozen species of fish were found impinged on intake screens (R. St. Pierre, USFWS, personal communication) totaling about 3000 fish within a three-month sampling period for the sampling season of 2001. Species included riverine fish as well as shad species. Of the species found, those making up the bulk of the fish biomass found include channel catfish (1326),
gizzard shad (1281), blueback herring (105), bluegill (71), American shad (65), largemouth bass (17), white crappie (15) and yellow perch (11). At a minimum, the applicant should establish a year-round screen sampling protocol to account for year-round fish losses.
Excelon uses traveling mesh screens and a spray wash system together to reduce or minimize impacts to fish. To further minimize the impacts, in the process of replacing worn or damaged screens, the screens should be replaced with mesh size less than or equal to one millimeter.
Additionally, entrance velocities should be less than or equal to 0.5 feet per second (Gowan and Garman 1999). Impinged biota should be removed from the traveling screens and returned to the river.
Decommissioning Facilities The draft Supplement 10 contains an evaluation of partial or total decommissioning of existing facilities as the alternative to relicensing. Such analysis should answer at least the following
3 additional questions: How wofull contaminated facilities and unised or spent fuel be disposed?
How would the project sites be reclaimed? What would be the consequences for fish and wildlife resources and their habitat at both the former project sites and disposal areas?
Exposure to Radiation A thorough review should be made on the effects of various levels of radiation exposure on fish and wildlife resources and their habitats. Such exposure may result from leakage, accident (e.g.,
Three Mile Island,: Chernobyl) or disposal. [We suspect that the risk of radiation exposure over time may increase, despite planned maintenance as plants age.]
Transmission Lines Contaminant Management on Rights-of-Way: Transmission towers frequently leach zinc, which is toxic to vegetation and creates bare soil areas. PCBs often leak from old transformers.
Remediation is possible and should be a condition of relicensing. Herbicide use should be minimized.
Erosion Control on Rights-of-Way: Transmission lines are frequently kept in early stages of succession, grassed or farmed. Soil erosion from these areas contributes to the degradation of streams, rivers, and bays by adding nutrients, sediment, and pollutants of concern in the Chesapeake and Delaware Bay drainages. We recommend that rights-of-way be maintained to avoid erosion of sediments into surface waters. One measure to control erosion would be to maintain multiple vegetative strata to reduce splash, sheet and gully erosion.
We suspect that many transmission line corridors expand opportunities for various forms of recreation. Some of these (i.e., off-road vehicle use) may result in alteration, degradation or destruction of fish and wildlife habitats, particularly streams and wetlands, as well as the harassment and disturbance of wildlife. We recommend that controlled public use of rights-of way (type and season) to avoid such degradation be a condition of relicensing.
Wild---life Management on Rig-ts-of-Way: Mltiple-strata o-f vegetati-on-
-- *nwould also create feeding and nesting cover for some migratory bird species, while perhaps reducing the effects of forest fragmentation on others. The Department is concerned that fragmentation of large forest blocks is reportedly contributing to the population decline of some area-sensitive migratory birds.
Appropriate management of rights-of-way would make considerable land available for wildlife.
This has been demonstrated in Maryland and discussed in the transmission line document prepared by the USFWS's Power Plant Team (Management of Transmission Line Rights-of-Way for Fish and Wildlife, Vol. I, Background Information. FWS/OBS-79/22).
Transmission lines kept in early successional stages prevent nesting by birds requiring tree cavities. Excellent management opportunities exist to enhance some rights-of-way by providing
4 and maintaining nest boxes for cavity-nesting species like bluebirds, great crested flycatchers, wrens, and chickadees displaced from areas where forest has been cleared.
Right-of-Way Routing: Some migratory birds, particularly waterfowl and herons, will not fly within one-quarter mile of powerlines, depending on lighting (time of day) and the reflectivity of the line. This effectively takes valuable migratory bird habitat when transmission lines cross wetlands. We recommend that plans for routing existing lines to avoid wetlands be developed in consultation with the USFWS as part of the relicensing process.
Maintenance of Rights-of-Way: To avoid and minimize taking migratory birds, active nests, and their eggs, we recommend that time-of-year restrictions on vegetation clearing and maintenance-on rights-:of-waybe pato__ license or amendment. In the Northeast, such restrictions would include the primary migratory bird nesting season from April 1 to July 15 (for raptors, it is February 1 to July 15). Buffers around active raptor nests of at least 100 meters may be sufficient. In addition, activity within a 100-meter radius of raptor nests should be avoided from February 1 through July 13.
Cumulative Impact Evaluations We recommend that secondary and cumulative evaluations of this project be primarily quantitative, that nuclear plants be considered along with the "other sources" of cumulative impacts, and that cumulative impacts to avian and terrestrial resources be included along with aquatic resources. We also recommend that ichthyoplankton be considered with aquatic resources.
One question that should be evaluated is the cumulative impact of impingement and entrainment on finfish or other aquatic life in the Conowingo Pool area. To answer this question, NRC or Excelon would first need to know the losses from all water intakes in the water body; the finfish population size, dynamics, exploitation, structure, etc; and how the impingement/entrainment losses are partitioned among the various intakes. This information is useful for determining where, when, and under what conditions entrainment and/or impingement losses cause an observable effect on fish populations or other aquatic life. This quesonwill be difficult to answer without sufficient advance preparation, however.
We also recommend that the cumulative effects of transmission line operation and maintenance be part of the evaluation. Topics such as forest fragmentation, electromagnetic field effects, bird collisions, and contaminants should be explored.
As implied elsewhere, Excelon should identify state-of-the-art technology, design, operation and maintenance for cooling water systems, tiansmission lines and other operating features of nuclear plants. These features should be incorporated into the cumulative impact analyses and the existing projects when appropriate during the relicensing process.
5 Mitigation Currently, there are no provisions for mitigating impacts to Susquehanna River fish caused by impingement by the intakes at the Peach Bottom facility. The current fish collection practices conducted by the licensee's consultant, Normandeau, while useful for monitoring shad mortality, cannot be considered an acceptable form of mitigation. As a long-term (for the life of the license) mitigation practice we find this practice inappropriate. Although the current level of mortality of American shad, by itself, is not considered detrimental to the Shad Restoration Program, the loss must be considered within the context that fish mortality numbers are expected to increase as the number of American shad restored to the river also increases. Additionally, the losses of resident fishes are not accounted for. In this context, we strongly recommend that NRC and Excelon determine the impact on all finfish, not only American shad, and other aquatic life due to impingement in the Peach Bottom water intake in the Conowingo Pool, and that appropriate long-term mitigation measures be developed and implemented by the licensee to mitigate for riverine and anadromous fish losses.
Fish and Wildlife Coordination Act Relicensing has the same consultation requirements as original licensing under the Fish and Wildlife Coordination Act (FWCA). Consultation under NEPA does not supplant the need for consultation under FWCA; although these laws are similar, they do not have the same requirements with respect to fish and wildlife, and reporting by the USFWS. As Excelon develops an application for relicense, the USFWS should be consulted during scoping of issues, study needs, and interpretation of results. Draft applications should be made available by the applicant for review and comment. The USFWS comments (i.e., FWCA report) will be provided to the applicant and should be part of their application submitted to the NRC. That report should be considered by NRC when preparing the EIS for the plant. There may be a need for further consultation under the FWCA on NRC's preferred alternative if the "Federal Action" will be significantly different than that proposed by the applicant.
The Department appreciates NRC's request for comments on the draft Supplement 10 and is we-ca--timeilling-t6 cooeraTefu-rth"er-6tih'*dxtefhtfth e can. A Ie-,the UISFWS requests that the NRC initidte consultation under the FWCA for relicensing nuclear power plants. The Service does not believe that either the equal consideration or mitigation planning provisions of the FWCA are satisfied by the NEPA process alone. To fully consider the protection of fish and wildlife resources and their habitats affected by each plant, NRC should request that the Service provide NRC with reports in accordance with the FWCA which should be part of NRC's decision document.
Summary of Recommendations The Department recommends that the NRC adopt the following recommendations in order to maintain optimum protection of natural resources at the Peach Bottom Atomic Power Station:
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Require system upgrading at this project to include a closed cooling system instead of the existing open cooling system.
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Evaluate the potential consequences of decommissioning (contaminated facilities and unused or spent fuel disposal, reclaiming project site, consequences for fish and wildlife resources and their habitats at former project sites and disposal areas) in the alternatives analysis for relicensing.
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Require the intake screen replacements to have a mesh size of one millimeter or less intake water velocities less than 0.5 feet per second, and return biota collected by the traveling screens returhed to the river.
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Require maintenance of transmission line right-of-ways for wildlife feeding cover and nesting activities, while minimizing habitat degradation and encouraging habitat enhancements.
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Require applicant to maintain multiple layers of vegetative cover in transmission line rights-of-way to reduce or control splash, sheet and gully erosion.
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Require controlled public use of transmission line rights-of-way (type and season) to avoid erosion and sedimentation.
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Require an assessment of cumulative impacts of all projects from all water intakes in the Conowingo Pool area, including finfish population size, dynamics, exploitation, and structure, and, the partitioning of impingement! entrainment losses among the various intakes.
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Require an ass'essment of cumulative effects from transmission line operation and maintenance, including forest fragmentation, electromagnetic field effects, bird collisions, and contaminant issues.
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Rquire-devel6pment and iffiPlemeiitatiofi-of ai p-ra--Hiea-aroii'n-d asse-ssmet method for:evaluating Susquehanna River fish losses and a mitigation plan for losses of Susquehanna River fish (resident and anadromous) caused by intake impingement.
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Initiate and continue consultation with the USFWS under the FWCA for the relicensing of the Peach Bottom Nuclear Power Plant.
We appreciate the opportunity to review the draft environmental document and provide comments on natural resource protection. If you have any questions regarding the these comments, please contact Jennifer Kagel of the USFWS's Pennsylvania Field Office at (814) 234-4090.
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7 Sincerely, Michael T. Chezik Regional Environmental Officer cc:
A. Hoar, FWS, Haa1ley, MA J. KagIl, EWS, State College, PA_.._._
Reference Gowan, C. and G. Garman. 1999. Design criteria for fish screens in Virginia: Recommendations based on a review of the literature. Prepared for: Virginia Department of Game and Inland Fisheries, Richmond, VA.