ML050660098
| ML050660098 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/25/2005 |
| From: | Grecheck E Dominion Nuclear Connecticut |
| To: | NRC/ADM/DAS/RDB |
| References | |
| 04-745, 69FR71437 00022 | |
| Download: ML050660098 (32) | |
Text
Dominion Nuclear Connecticut, Inc.
Millstone Power Station Rope Ferry Road Dominion DPt Waterford, CT 06385 February 25, 2005 , 7-,Z 7 Chief, Rules Review and Directives Branch /
United States Nuclear Regulatory Commission Serial No.: 04-745 Mail Stop T6-D59 LR/RJG RO Washington, DC 20555-0001 Docket Nos.: 50-336 50-423 License Nos.: DPR-65 NPF-49 DOMINION NUCLEAR CONNECTICUT, INC. (DNC)
MILLSTONE POWER STATION UNITS 2 AND 3 LICENSE RENEWAL APPLICATIONS COMMENTS ON DRAFT SUPPLEMENT 22 TO THE GENERIC ENVIRONMENTAL IMPACT STATEMENT On December A, 2004, the Nuclear Regulatory Commission (NRC) issued Draft Supplement 22 to the Generic Environmental Impact Statement (GEIS) regarding the license renewal applications (LRAs) for Millstone Power Station Units 2 and 3.
Comments on the draft were solicited.
DNC has reviewed the draft and presents the following observations. Draft Supplement 22 fairly represents the environmental conditions associated with plant operation.
Furthermore, we concur with the overall conclusions concerning the impacts associated with the station's operation, and offer the attached comments and clarifications concerning the content of the draft.
Should you have any questions regarding this letter, please contact Mr. William D.
Corbin, Director, Nuclear Engineering Department, Dominion Resources Services, Inc.,
at (804) 273-2365.
Very truly yours, E. S. Grecheck Vice President - Nuclear Support Services
Attachment:
Comments on Draft Supplement 22 to the GEIS for License Renewal Commitments made in this letter: None.
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Serial No.04-745 Docket Nos.: 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Page 2 of 4 cc: U.S. Nuclear Regulatory Honorable Christopher Dodd Commission US Senate Region I 100 Great Meadow Road 475 Allendale Road Wethersfield, CT 06109 King of Prussia, PA 19406-1415 Ms. Catherine Marx Mr. V. Nerses Governor's Eastern Office Senior Project Manager P.O. Box 1007 U.S. Nuclear Regulatory 171 Salem Turnpike Commission Norwich, CT 06360-1007 One White Flint North 11555 Rockville Pike Mr. William Meinert Mail Stop 8C2 MMWEC Rockville, MD 20852-2738 P.O. Box 426 Ludlow, MA 01056-0426 Mr. S. M. Schneider NRC Senior Resident Inspector Honorable Andrea Stillman Millstone Power Station CT State Senate 5 Coolidge Court Honorable Wayne L. Fraser Waterford, CT 06385 First Selectman P.O. Box 519 Honorable Ed Jutila Niantic, CT 06357-0519 CT House of Representatives 23 Brainard Road Mr. Stephen Page Niantic, CT 06357 Central VT PSC 77 Grove Street Honorable Robert Simmons Rutland, VT 06701 US Congress 2 Courthouse Square Honorable Elizabeth Ritter Norwich, CT 06360 CT House of Representatives 24 Old Mill Road Mr. Thomas Wagner Quaker Hill, CT 06375 Town of Waterford Town Planner Mr. Denny Galloway 15 Rope Ferry Road Supervising Radiation Control Waterford, CT 06385 Physicist State of Connecticut - DEP Dr. Edward L. Wilds Division of Radiation Director, Division of Radiation 79 Elm Street State of Connecticut - DEP Hartford, CT 06106-5127 79 Elm Street Hartford, CT 06106-5127
Serial No.04-745 Docket Nos.: 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Page 3 of 4 Chairman Donald Downes Mr. Jim Butler DPUC Executive Director - Council of 10 Franklin Square Governments New Britain, CT 06051 8 Connecticut Avenue Norwich, CT 06360 Honorable Dennis L. Popp Chairman - Council of Mr. Bill Palomba Governments Executive Director, DPUC Municipal Building 10 Franklin Square 295 Meridian Street New Britain, CT 06051 Groton, CT 06340 Honorable Ernest Hewett Chief Murray J. Pendleton State House of Representatives Director of Emergency 29 Colman Street Management New London, CT 06320 41 Avery Lane Waterford, CT 06385-2806 Honorable Terry Backer CT House of Representatives Honorable Richard Blumenthal Legislative Office Building Attorney General Room 2102 55 Elm Street Hartford, CT 06106 Hartford, CT 06106-1774 Honorable Kevin DelGobbo Mr. John Markowicz CT House of Representatives Co-Chairman - NEAC 83 Meadow Street 9 Susan Terrace Naudautuck, CT 06770 Waterford, CT 06385 Honorable Thomas Herlihy Mr. Evan Woolacott CT Senate Co-Chairman - NEAC 12 RiveRvalk 128 Terry's Plain Road Simsbury, CT 06089 Simsbury, CT 06070 Honorable Cathy Cook Honorable M. Jodi Rell CT Senate, 18th District Governor 43 Pequot Avenue State Capitol Mystic, CT 06355 Hartford, CT 06106 Mr. Edward Mann Mr Mark Powers Office of Senator Dodd 4 Round Rock Road Putnam Park Niantic, CT 06357 100 Great Meadow Road Wethersfield, CT 06109 Mr. Jay Levin 23 Worthington Road New London, CT 06320
Serial No.04-745 Docket Nos.: 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Page 4 of 4 Chairperson Pam Katz CT Siting Council 10 Franklin Square New Britain, CT 06051 Mr. Ken Decko CBIA 350 Church Street Hartford, CT 06103 Honorable Paul Eccard First Selectman Town of Waterford 15 Rope Ferry Road Waterford, CT 06385 Mr. Richard Brown City Manager New London City Hall 181 State Street New London, CT 06320 Honorable Jane G. Glover Mayor, New London New London City Hall 181 State Street New London, CT 06320
SN: 04-745 Docket Nos.: 50-336/423
Subject:
Comments on Draft Supplement 22 to the Generic Environmental Impact Statement COMMONWEALTH OF VIRGINIA )
)
COUNTY OF HENRICO )
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck, who is Vice President -
Nuclear Support Services, of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.
Acknowledged before me this f6jn day of4 6lwe 2005.
My Commission Expires: J44 4 1t 3/, door
/ Publ Nota:
Notary Public (SEAL)
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 1 of 27 Attachment Millstone Power Station Units 2 and 3 License Renewal Applications Comments on Draft Supplement 22 to the Generic Environmental Impact Statement for License Renewal Dominion Nuclear Connecticut
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 2 of 27 Section 2.1.1 External Appearance and Setting Page 2-2, Line 18 Draft GEIS Supplement 22 Statement All development at Millstone is situated south of this mostly below-grade rail line.
Dominion Comment After the word "Millstone," insert "except the training facility," such that the sentence reads:
'All development at Millstone, except the training facility, is situated south of this mostly below-grade rail line."
Section 2.1.3 Cooling and Auxiliary Water Systems Page 2-7, Line 9 Draft GEIS Supplement 22 Statement
...cuts excavated from the bedrock at the eastern end of the quarry into Long Island Sound.
Dominion Comment "eastern" should be changed to "southem," such that the line reads:
"...cuts excavated from the bedrock at the southern end of the quarry into Long Island Sound."
Section 2.1.3 Coolina and Auxiliary Water Systems Page 2-7, Lines 29-32 Draft GEIS Supplement 22 Statement Service water is withdrawn and diverted from the system before the water enters the condensers. This water is used in a variety of applications, including component cooling (e.g., pump bearings and spent fuel pool water) and fire protection. A maximum of 2.3 m3/s (36,000 gpm) of service water is withdrawn.
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 3 of 27 Dominion Comment The configuration of the service water system is somewhat different than that stated, and the stated pump capacity is that only for the three pumps at Unit 2. During normal operation, two pumps at each unit are operating, for a total of 3.4 m3 /s (54,000 gpm). Also, service water is used as backup for several other systems, but not for fire protection. This paragraph should be changed to read:
"Service water is also withdrawn inside the intake structures. This water is used in a variety of applications, including component cooling (e.g., pump bearings and spent fuel pool water) and as an emergency backup supply for some systems. During normal operation, approximately 3.4 m3/s (54,000 gpm) of service water is withdrawn for both units."
Section 2.1.4 Radioactive Waste Management Systems and Effluent Control Systems Page 2-8, lines 27-29 Draft GEIS Supplement 22 Statement Millstone is in the process of obtaining a permit to construct a dry fuel storage area for additional spent fuel assemblies.
Dominion Comment Millstone has obtained the permit described above. It is suggested that "is in the process of obtaining a permit to construct" be changed to "has constructed" so the sentence reads:
"Millstone has constructed a dry fuel storage area for additional spent fuel assemblies."
Section 2.1.4.3 Solid Waste Processinq Page 2-12, line 3 Draft GEIS Supplement 22 Statement
...volume was 24.3 m3 (858 ft3)...
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 4 of 27 Dominion Comment Change to:
"...volume was 243 m3 (8580 ft3 )...
Section 2.1.5 Nonradioactive Waste Systems Page 2-12, Lines 11-12 Draft GEIS Supplement 22 Statement Dominion has petitioned the CTDEP to be classified as a small-quantity generator because of a reduction in the amount of waste generated at Millstone.
Dominion Comment Although Millstone generates hazardous waste at the rate of a small-quantity generator, the decision was made not to pursue classification as a small-quantity generator, in order to maintain flexibility in storage and shipping. It is suggested that this sentence be deleted.
Section 2.1.5 Nonradioactive Waste Systems Page 2-12, Lines 17-19 Draft GEIS Supplement 22 Statement Common types of hazardous waste generated at Millstone are lead acid sludges and batteries, solvent rags, and sawdust contaminated with chemicals regulated under RCRA.
Dominion Comment Lead acid batteries and sawdust contaminated with chemicals are classified as Connecticut-regulated wastes. This sentence should be changed to the following:
"Common types of hazardous waste generated at Millstone are aerosol cans, paint-related waste materials, and solvent rags."
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 5 of 27 Section 2.1.6 Plant Operation and Maintenance Page 2-12, line 37 Draft GEIS Supplement 22 Statement Dominion assumes that an additional 60 employees will be needed...
Dominion Comment Sentence should be changed to:
"Dominion assumes that no more than 5 additional employees will be needed..."
Section 2.1.7 Power Transmission System Page 2-15, Line 2 Draft GEIS Supplement 22 Statement All personnel applying herbicides are required to process a valid applicator's license.
Dominion Comment It is suggested that the word "process" be changed to "possess," so that the sentence reads:
"All personnel applying herbicides are required to possess a valid applicators license."
Section 2.2.2 Water Use Page 2-17, Line 2 Draft GEIS Supplement 22 Statement Additional minor amounts of ocean water are used for fire protection and other systems.
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 6 of 27 Dominion Comment Although ocean water can be used as backup for some systems, it is not used in the fire protection system. The sentence should be modified as follows:
"Additional minor amounts of ocean water may be used as emergency backup for other systems."
Section 2.2.2 Water Use Page 2-17, Lines 6-7 Draft GEIS Supplement 22 Statement Dye tracer and modeling studies estimate that 20 percent of the Niantic River discharge goes through the plant.
Dominion Comment These studies determined flow characteristics during three-unit operation. It is estimated that current two-unit operation results in approximately 15 percent of the Niantic River discharge going through the plant. The sentence should be changed to:
"Dye tracer studies estimated that 20 percent of the Niantic River discharge went through the plants during three-unit operation. It is estimated that current two-unit operation results in approximately 15 percent of Niantic River discharge going through the plants."
Section 2.2.3 Water Quality Page 2-17, Line 36 Draft GEIS Supplement 22 Statement The NPDES permit, which is renewed every five years, expired in 1997.
Dominion Comment Change 'expired in 1997" to "was set to expire in 1997 but remains in effect because a timely renewal application was filed with the CTDEP" so sentence reads:
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 7 of 27 "The NPDES permit, which is renewed every five years, was set to expire in 1997 but remains in effect because a timely renewal application was filed with the CTDEP."
Section 2.2.3 Water Quality Page 2-18, Lines 7-8 Draft GEIS Supplement 22 Statement Recent monitoring results show that the discharge quality occasionally exceeds permit limits.
Dominion Comment It is suggested that the sentence be changed by adding "There have been occasional instances when" before "monitoring results," substituting "have been above" for "show that the discharge quality occasionally exceeds" and adding "These instances have been properly reported in Millstone's monthly discharge monitoring reports to the CTDEP" so the sentence reads:
"There have been occasional instances when monitoring.results have been above permit limits (e.g., total suspended solids). These instances have been properly reported in Millstone's monthly discharge monitoring reports to the CTDEP.'
Section 2.2.3 Water Quality Page 2-18, Line 24 Draft GEIS Supplement 22 Statement
...may be present for no more than two hours in any one day.
Dominion Comment After "two hours," insert "per unit," so the sentence reads:
"...may be present for no more than two hours per unit in any one day."
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 8 of 27 Section 2.2.4 Air Quality Page 2-20, Lines 20-22 Draft GEIS Supplement 22 Statement Air emissions from these sources are subject to Connecticut General Statutes section 22a-174-33 of the Regulations of Connecticut State Agencies (Connecticut Legislature 2003).
Dominion Comment In addition to section 22a-174-33 (which regulates Title V air permits), air emissions from site sources are subject to other regulations. It is suggested that this sentence read:
"Air emissions from these sources are subject to Connecticut General Statutes, various sections of the Regulations of Connecticut State Agencies, Title 22a-174, 'Abatement of Air Pollution,' and various federal regulations."
Section 2.2.5 Aquatic Resources Page 2-20, Lines 28-29 Draft GEIS Supplement 22 Statement Millstone is located at Millstone Point, a small peninsula of land situated on the west shore of Long Island Sound near Waterford, Connecticut.
Dominion Comment Change "west" to "north," and change "near" to "in," so the sentence reads:
"Millstone is located at Millstone Point, a small peninsula of land situated on the north shore of Long Island Sound in Waterford, Connecticut."
Section 2.2.5 Aauatic Resources Page 2-20, Lines 38-39, and Page 2-21, Line 4.
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 9 of 27 Draft GEIS Supplement 22 Statement
...about 20 percent of the water discharged from the station from the Niantic River could be passed through the Millstone cooling water system under three-unit operation...
Dominion Comment Delete "from the station," and add "and about 15 percent under two-unit operation" to the end of the sentence, so the sentence reads:
"...about 20 percent of the water discharged from the Niantic River could be passed through the Millstone cooling water system under three-unit operation, and about 15 percent under two-unit operation..."
Section 2.2.5.1 General Water Body Characteristics Page 2-22, Lines 12-15 Draft GEIS Supplement 22 Statement Millstone Point lies on the western shore of Long Island Sound, near the mouth of the sound.
This area of Long Island Sound experiences a salinity of approximately 23 parts per thousand. Salinity is influenced by the presence of three major rivers: the Thames, the Housatonic, and the Connecticut. These rivers flow into the Sound in the vicinity of the site.
Dominion Comment It is suggested that "westem shore" be changed to "eastem end," that "23" be changed to "26-30," and that "These" be changed to "The Thames and Connecticut," so the sentence reads:
"Millstone Point lies on the eastern end of Long Island Sound, near the mouth of the sound.
This area of Long Island Sound experiences a salinity of approximately 26-30 parts per thousand. Salinity is influenced by the presence of three major rivers: the Thames, the Housatonic, and the Connecticut. The Thames and Connecticut rivers flow into the Sound in the vicinity of the site."
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 10 of 27 Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish Species Page 2-24, Line 41 Draft GEIS Supplement 22 Statement
...and the northern Atlantic cost of the U.S.
Dominion Comment Change "cost" to "coast."
Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish Species Page 2-25, Line 28 Draft GEIS Supplement 22 Statement Individual females can produce up to 500,000 eggs.
Dominion Comment It is suggested that the sentence be changed to read:
"Individual females can produce up to 2,500,000 eggs, but 500,000 eggs is an approximate average."
Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish Species Page 2-25, Line 36 and Page 2-26, Figure 2-6.
Draft GEIS Supplement 22 Statement
...reporting years (Figure 2-6) (NOAA 1998; MacLeod 2003; National Marine Fisheries Service...
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 11 of 27 Dominion Comment It is suggested that "Gottschall et al. 2003" be added to the reference list for Figure 2-6 on line 36, and in the figure itself. Gotschall et al. is the citation for the CTDEP Long Island Sound Trawl Survey.
Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish Species Page 2-26, Lines 4-8 Draft GEIS Supplement 22 Statement According to NOAA, "The continuing low levels of landings, catch per unit effort indices, and survey indices suggest that winter flounder abundance in the Gulf of Maine has been reduced substantially. Future improvements in the condition of the stock will depend on decreases in exploitation in both the recreational and commercial fisheries, and on improved recruitment.
The stock is at a low biomass level and is considered to be exploited) (NOAA 1998).
Dominion Comment It is suggested that the following information regarding the Southern New England stock be added to this paragraph, or as an additional paragraph:
"With regard to current winter flounder stock abundance, NEFSC (2003) stated that the Southern New England/Mid-Atlantic winter flounder stock complex has been overfished and overfishing is continuing to occur. The current assessment provided a much more pessimistic evaluation of stock status than the previous assessment made in 1998.
Recruitment to the winter flounder stock has been below average since 1989, and indications are that the 2001 year-class is the smallest in 22 years."
The reference for this statement is:
NEFSC (Northeast Fisheries Science Center). 2003. B1. Southern New England/Mid-Atlantic (SNE/MA) winter flounder. Pages 139-220 in Report of the 36th northeast regional stock assessment workshop (SAW): stock assessment review committee (SARC) consensus summary of assessments. NOAA/National Marine Fisheries Service, Woods Hole, MA.
Accessed via:
http:x/www.nefsc.noaa.-ov/nefsc/Dublications/crd/crdO3O6
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 12 of 27 Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish Species Page 2-28, Lines 15-16 Draft GEIS Supplement 22 Statement
...with commercial harvests over the past seven years for the Atlantis seaboard ranging from approximately 259 to over 300 MT (286 to 331 tons)...
Dominion Comment Change "Atlantis" to "Atlantic." Also, all of the numbers in this sentence should be followed by ux 103 ."
Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish Species Page 2-28, Line 25 Draft GEIS Supplement 22 Statement The silverside (Menidia menidia, family Atherinidae) is a small...
Dominion Comment Two different species of silverside are found in the area. It is suggested that the sentence be changed to:
'The silversides (Menidia menidia/Menidia beryllina, family Atherinidae) are small..."
Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish Species Page 2-28, Line 32
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 13 of 27 Draft GEIS Supplement 22 Statement Regional abundance data are not available.
Dominion Comment Dominion notes that Gotschall et al (2003) observed similar fluctuations without trend throughout Long Island Sound.
Section 2.2.5.6 Other Important Aquatic Resources Page 2-31, Line 8 Draft GEIS Supplement 22 Statement
...bamacles, the algae Fucus spp., the red alga Chondrus spp., and...
Dominion Comment It is suggested that this sentence include Ascophyllum nodosum, and that it read:
...barnacles, the brown algae Fucus spp. and Ascophyllum nodosum, the red alga Chondrus crispus, and...
Section 2.2.5.6 Other Important Aquatic Resources Page 2-31, Line 22 Draft GEIS Supplement 22 Statement
- .and the bivalve mollusc Nuculana annulata...
Dominion Comment Change "Nuculana" to uNucula."
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 14 of 27 Section 2.2.5.7 Threatened or Endangered Aquatic Species Page 2-33, Line 9 Draft GEIS Supplement 22 Statement Adult-sized (10 cm [6 or more Jj.D sturgeon are occasionally seen...
Dominion Comment Dominion believes that the intent was to characterize adult-sized sturgeon as 6 feet long, rather than 6 inches.
Section 2.2.6.1 Site Terrestrial Resources Page 2-36, line 10 Draft GEIS Supplement 22 Statement
...173 fledglings have been produced over this period.
Dominion Comment As of the present time, the number of fledglings produced at Millstone stands at 186.
Section 2.2.6.1 Site Terrestrial Resources Page 2-36, line 14 Draft GEIS Supplement 22 Statement There are 18 species listed by FWS or the state of Connecticut as being known to occur on the site.
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 15 of 27 Dominion Comment Dominion believes this sentence refers to the 18 species listed in Table 2-3. Some of those species have been observed on the site or along the transmission lines, and some have not been observed, but may occur. It is suggested that the sentence be changed to:
"There are 18 species listed by FWS or the State of Connecticut that have either been observed on the site or have the potential to occur in the area or along transmission lines."
Section 2.2.6.1 Site Terrestrial Resources Table 2-3 Draft GEIS Supplement 22 Statement This table lists terrestrial species known to occur or that potentially occur at Millstone or along the transmission lines.
Dominion Comment Dominion notes the following:
- As of June 2004, the Cooper's hawk is no longer listed by the State of Connecticut.
- The piping plover is listed as "threatened" by the State of Connecticut.
- Dominion is unable to find any citation by the State of Connecticut that lists the New England cottontail as either threatened or endangered.
- The seabeach sandwort is listed by the State of Connecticut as a "special concern" species.
Section 2.2.8.1 Housinci Page 2-44, line 1 Draft GEIS Supplement 22 Statement
...while another 200 live in Niantic and East Lime.
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 16 of 27 Dominion Comment Change "Lime" to "Lyme."
Section 2.2.8.2 Public Services Page 2-47, Lines 10-12 Draft GEIS Supplement 22 Statement A new water supply line was constructed in 2000 to supply Millstone, and this line replaced the use of two shallow low-yield wells that had been used to irrigate ball fields and supply concession stands on the Millstone site licensed to Waterford.
Dominion Comment It is suggested that this paragraph be replaced with the following clarification:
"A new water supply line was constructed in 2000 to supply a concession stand at the ball fields licensed by Millstone to Waterford. The stand had been supplied by a shallow low-yield well, which continues to be used to irrigate the ball fields on a seasonal basis."
Section 2.2.8.5 Demography Page 2-55, Line 30 Draft GEIS Supplement 22 Statement Source: Dominion 20004a Dominion Comment Delete a zero in the date of the citation.
Section 2.2.8.5 Demography Page 2-56, Line 35
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 17 of 27 Draft GEIS Supplement 22 Statement
... eafter September 11, 2000...
Dominion Comment Change "2000" to "2001."
Section 2.2.9.1 Cultural Background Page 2-60, Line 25 Draft GEIS Supplement 22 Statement
....Park overlooking the Thames River about 8km (5 mi) northwest of Millstone.
Dominion Comment Change unorthwest" to unortheast."
Section 2.2.9.1 Cultural Back-round Page 2-63, Line 16 Draft GEIS Supplement 22 Statement Actual power generation began in 1975.
Dominion Comment Unit 1, which is not the subject of this report, began generating power in 1970. It is suggested that "at Unit 2" be inserted so sentence reads as follows:
"Actual power generation at Unit 2 began in 1975."
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 18 of 27 Section 2.3 References Dominion Comment It is suggested that the following new references be added to this list, as discussed in comments above:
uGottschall, K.F., D.J. Pacileo, and D.R. Molnar. 2003. Job 2: Marine finfish survey. Part l:
Long Island Sound trawl survey and Part II: estuarine seine survey. Pages41-149 in: A study of marine recreational fisheries in Connecticut. CT Dept. of Envir. Prot., Bureau of Natural Resources, Fisheries Division."
and MNEFSC (Northeast Fisheries Science Center). 2003. B1. Southern New England/Mid-Atlantic (SNE/MA) winter flounder. Pages 139-220 in Report of the 36th northeast regional stock assessment workshop (SAW): stock assessment review committee (SARC) consensus summary of assessments. NOAA/National Marine Fisheries Service, Woods Hole, MA.
Accessed via:
http://www.nefsc.noaa.pov/nefsc/tublications/crd/crdO306" Section 4.1 Cooling System Page 4-7, lines 38-39 Draft GEIS Supplement 22 Statement The barrier prevents fish from entering the quarry. Since installation of the fish barriers, the licensee has not observed any fish kills related to the station discharge.
Dominion Comment As discussed in section 4.1.3, page 4-28, lines 26-27, temperatures within the quarry occasionally exceed lethal temperature thresholds for some species. Some periodic, smaller-scale fish kills have occurred due to thermal stress for fish that entered the quarry as eggsAarvae, as juveniles, or during barrier maintenance activities. None of these occurrences have been of a magnitude that resulted in an impact to source populations, and they have been confined to the quarry. The sentences should be modified as follows:
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 19 of 27 "The barrier is designed to prevent fish from swimming into the quarry. Since installation of the fish barriers, the licensee has not observed any gas bubble disease-related fish kills related to the station discharge."
Section 4.1.1 Entrainment of Fish and Shellfish in Early Life Stages Page 4-10, lines 17-19 Draft GEIS Supplement 22 Statement Licensees are required to demonstrate compliance with the Phase /I performance standards at the time of renewal of their NPDES permit.
Dominion Comment "are" should be changed to "will be," and "at the time of renewal of their NPDES permit" should be changed to "in accordance with the provisions of the new rule" so the sentence reads as follows:
"Licensees will be required to demonstrate compliance with the Phase II performance standards in accordance with the provisions of the new rule."
Section 4.1.1 Entrainment of Fish and Shellfish in Early Life Stages Page 4-10, Lines 19-21 Draft GEIS Supplement 22 Statement Licensees may be required as part of the NPDES renewal to alter the intake structure, redesign the cooling system, modify station operation, or take other mitigative measures as a result of this regulation.
Dominion Comment Delete the words "as part of the NPDES renewal" so the sentence reads as follows:
"Licensees may be required to alter the intake structure, redesign the cooling system, modify station operation or take other mitigative measures as a result of this regulation."
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 20 of 27 Section 4.1.1 Entrainment of Fish and Shellfish in Early Life Stages Page 4-13, Table 4-4 Dominion Comment The 2003 Annual Report (Dominion 2004b) contained minor changes to the data in this table.
Also, the data columns are each x106 . It is suggested that the table be replaced with the following:
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 21 of 27 Table 4-4 Estimated Number of Anchovies, Winter Flounder, American Sand Lance, Grubby, and Atlantic Menhaden Larvae Entrained Each Year from 1976 Through 2003 at Millstone and the Volume of Cooling Water on Which the Entrainment Estimates Were Based (From Dominion [2004b]).
Anchovies Winter Flounder American Sand Grubby Atlantic Menhaden Lance' Year No. Volume No. Volume No. Volume No. Volume No. Volume entrained (m3)b entrained (M3) b entrained (M3) b entrained (m3) b entrained (m3 ) b
((X106) 106) (X10 6 ) (X10 6) (X10 6 ) (X10j) (X106 ) (X100) (X106 )
1976 381 738 121 629 - - - - 3 796 1977 418 821 29 444 81 954 30 489 2 773 1978 165 912 80 390 176 709 11 554 3 621 1979 805 786 44 343 110 919 20 546 '1 716 1980 877 633 168 562 111 960 32 699 2 643 1981 1,452 860 45 373 74 620 42 408 2 711 1982 451 635 164 638 27 932 48 648 14 743 1983 623 691 211 541 30 902 54 628 19 564 1984 169 801 84 508 18 835 38 524 4 557 1985 693 697 80 469 8 712 35 527 44 521 1986 1,096 1,208 123 1,064 4 1,577 53 844 5 1,217 1987 119 1,332 165 1,193 30 1,712 51 1,144 2 893 1988 386 1,790 184 1,173 74 1,291 112 1,132 6 791 1989 518 1,445 167 889 42 1,511 67 857 208 1,420 1990 981 1,483 133 1,174 39 1,607 47 998 33 1,367 1991 451 899 116 750 7 1,278 31 760 56 802 1992 157 1,091 492 1,076 19 1,302 76 1,293 51 1,220 1993 214 1,221 42 1,387 46 1,801 51 1,157 21 1,126 1994 507 1,033 173 920 58 899 58 843 66 868 1995 171 896 214 1,006 90 1,532 57 996 86 997 1996 24 138 51 472 18 729 41 467 23 92 1997 17 145 76 173 3 212 28 154 5 135 1998 64 480 84 358 11 440 22 300 33 615 1999 157 1,119 146 748 14 860 49 620 124 1,377 2000 75 875 333 1,003 88 1,459 47 754 466 1,571 2001 26 1,031 377 963 13 1,008 178 721 143 908 2002 28 881 119 880 6 760 33 875 1,454 1,088 2003 - - 434 1,096 19 725 153 890 - -
(a) Includes data from December of the previous calendar year.
(b) Volume was determined from the condenser and service cooling water flow at Millstone during the season of occurrence for each taxon.
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 22 of 27 Section 4.1.1 Entrainment of Fish and Shellfish in Early Life Stages Page 4-14, Table 4-5 Dominion Comment The 2003 Annual Report (Dominion 2004b) contained minor changes to the data in this table.
It is suggested that the table be replaced with the following:
Table 4-5. Estimated Number of Cunner, Tautog, and Anchovy Eggs Entrained Each Year from 1979 through 2002 at Millstone and the Volume of Cooling Water on Which the Entrainment Estimates Were Based (From Dominion [2004b]).
Cunner Tautog Anchovies Year No. Volume No. Volume No. Volume Entrained (m3) entrained (mi3 ) a Entrained (m3) a 6 6 6 6 6 6 (X10 ) (X10 ) (X10 ) (X10 ) (X10 ) (x10 )
1979 1,055 423 445 680 323 383 1980 1,640 677 962 773 87 359 1981 1,535 620 1,353 620 285 583 1982 2,074 755 1,248 719 210 501 1983 1,888 462 1,019 627 411 377 1984 2,089 532 1,302 569 883 453 1985 2,809 737 1,717 774 26 441 1986 2,855 1,795 3,747 1,795 523 772 1987 4,082 1,713 3,575 1,713 31 740 1988 4,294 1,800 2,693 1,800 15 905 1989 4,306 1,436 3,001 1,510 5 632 1990 3,634 1,689 2,100 1,641 27 724 1991 4,116 1,223 1,513 1,214 105 538 1992 2,648 1,509 1,341 1,509 18 648 1993 5,379 1,492 2,048 1,492 228 626 1994 6,099 1,381 1,989 1,381 175 867 1995 5,524 1,198 2,481 1,198 29 737 1996 871 256 312 256 4 114 1997 569 185 105 134 <1 92 1998 577 718 494 709 47 376 1999 1,963 1,222 1,173 1,222 1 339 2000 4,800 1,254 2,149 1,369 <1 849 2001 4,339 1,416 3,015 1,416 8 635 2002 3,340 1,188 2,040 1,188 <1 750 (a) Volume was determined from the condenser cooling-water flow at Millstone during the season of occurrence for each taxon.
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 23 of 27 Section 4.1.1 Entrainment of Fish and Shellfish in Early Life Stages Page 4-16, Line 1 Draft GEIS Supplement 22 Statement
...nonentrained, late stage larvae from reaching reproductive maturity.
Dominion Comment It is suggested that "and subsequent juveniles" be inserted after larvae, so the sentence reads:
"...nonentrained, late stage larvae and subsequent juveniles from reaching reproductive maturity."
Section 4.1.1 Entrainment of Fish and Shellfish in Early Life Stages Page 4-18, line 17 Draft GEIS Supplement 22 Statement
.. cooling water entrained through the cooling system, the number of eggs entrained,...
Dominion Comment It is suggested that "eggs" be changed to "larvae."
Section 4.1.2 Impingement of Fish and Shellfish Page 4-22, lines 8-10 Draft GEIS Supplement 22 Statement Licensees are required to demonstrate compliance with the Phase 11 performance standards at the time of renewal of their NPDES permit.
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 24 of 27 Dominion Comment "are" should be changed to "will be," and "at the time of renewal of their NPDES permit" should be changed to "in accordance with the provisions of the new rule" so the sentence reads as follows:
"Licensees will be required to demonstrate compliance with the Phase II performance standards in accordance with the provisions of the new rule."
Section 4.1.2 Impingement of Fish and Shellfish Page 4-22, lines 10-12 Draft GEIS Supplement 22 Statement Licensees may be required as part of the NPDES renewal to alter the intake structure, redesign the cooling system, modify station operation, or take other mitigative measures as a result of this regulation.
Dominion Comment Delete the words "as part of the NPDES renewal" so the sentence reads as follows:
"Licensees may be required to alter the intake structure, redesign the cooling system, modify station operation or make other mitigative measures as a result of this regulation."
Section 4.1.2.1 Impingement Monitoring Page 4-24, Table 4-6 Dominion Comment Dominion believes that the correct reference for this table is Jacobson et al (1998). See the comment below for Section 4.10 for the complete reference.
Also, on line 18, the species name for the rock crab is irroratus.
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 25 of 27 Section 4.1.3 Heat Shock Page 4-29, Lines 9-15 Dominion Comment Dominion offers the following minor edits:
Line 9, change "concorta"to "contorta."
Line 10, change "gragile" to 'fragile," and change "Saragassum gilipendula" to "Sargassum filipendula."
Line 13, change "abundance" to "nodal growth."
Line 15, change "abundance" to "growth."
Section 4.4.2 Public Services: Public Utility Impacts During Operations Page 4-40, Lines 17-18 Draft GEIS Supplement 22 Statement Millstone's 2000 to 2001 potable water usage averaged 1.257 X 106 L per day (3.320 X 106 gpd).
Dominion Comment Change "3.320 X 106 gpd" to "3.320 X 105 gpd."
Section 4.6.2 Terrestrial Species Page 4-52, Lines 33-34 Draft GEIS Supplement 22 Statement Both the bald eagle (Haliaeetus leucocephalus) and the piping plover (Charadrius melodus) are known to occasionally use the Millstone site.
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 26 of 27 Dominion Comment To Dominion's knowledge, the piping plover has not been observed on the Millstone site.
Dominion believes the intent may have been to name the roseate tern, which has been observed on the site. It is suggested that the sentence be changed to:
"Both the bald eagle (Haliaeetus leucocephalus) and the roseate tern (Sterna dougallii) are known to occasionally use the Millstone site."
Section 4.10 References Page 4-62 Dominion Comment Add the following reference, as discussed above:
"Jacobson, P.M., E. Lorda, D.J. Danila, J.D. Miller, C.A. Tomichek, and R.A. Sher. 1998.
Studies of cooling water intake effects at two large coastal nuclear power stations in New England. In Proceedings of a workshop on Clean Water Act Section 316(b) Technical Issues held at the Coolfont Conference Center, Berkeley Springs, WV, September 22-23, 1998.
Electric Power Research Institute, Palo Alto, CA EPRI Technical Report."
Section 8.1 No-Action Alternative Page 8-4, Lines 26-27 Draft GEIS Supplement 22 Statement When the plant stops operating, there will be a reduction in use of groundwater.
Dominion Comment The station itself does not use groundwater. The only use of groundwater is that used by the town of Waterford for seasonal irrigation of the ball fields. Therefore, closure of the plants would not necessarily result in a reduction in the use of groundwater.
Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 27 of 27 Section 8.2.5.10 Utilitv-Sponsored Conservation Page 8-50, Line 18 Draft GEIS Supplement 22 Statement Dominion participates in State-wide residential, commercial, and industrial programs to reduce...
Dominion Comment Dominion is not the local distributor of electricity. It is suggested that "Dominion participates in" be replaced with "Connecticut has" so the sentence reads:
"Connecticut has State-wide residential, commercial, and industrial programs to reduce..."
Appendix H Page H-1, Lines 17-18 Draft GEIS Supplement 22 Statement
...or were related to a reactor coolant pump (RCP) seal loss of coolant accident (LOCA).
Dominion Comment uloss of coolant accident (LOCA)" should be replaced with "dependency on charging pumps" so the sentence reads:
"....or were related to a reactor coolant pump (RCP) seal dependency on charging pumps."