ML061210117
| ML061210117 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/20/2006 |
| From: | Snyder-Conn E US Dept of Interior, Fish & Wildlife Service |
| To: | Kuo P Division of Regulatory Improvement Programs |
| References | |
| Download: ML061210117 (5) | |
Text
United States Department of the Interior IN REP FISH AND WILDLIFE SERVICE 1208-B Main Street Daphne, Alabama 36526 LY REFEI. TO:
April 20, 2006 Mr. Pao-Tsin Kuo, Program Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C. 20555-0001
Dear Mr. Kuo:
This responds to your request of October 25, 2004, for our concurrence with your effects determinations for the proposed License Renewal and Extended Power Uprate (EPU) of the Browns Ferry Nuclear Power Plant Units 1, 2, and 3 (BFN). The Fish and Wildlife Service (Service) has reviewed the U.S. Nuclear Regulatory Commission's (NRC) Biological Assessment (BA) for the proposed action and all supplemental biological, physical, and chemical data provided by NRC and the Tennessee Valley Authority (TVA) through meeting minutes, conference calls, electronic mail and letter correspondence.
We are providing the following comments in accordance with the Fish and Wildlife Coo:dination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.), the Migratory Bird Treaty Act (40 Stat. 755, as amended; 16 U.S.C. 703 et seq.), and the Endangered Species Act of 1973 (ESA) (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.).
By letter dated April 7, 2006,we received supplemental data from TVA addressing six requests for additional information (RAI) regarding impacts of the proposed activities to Federally-listed species. The TVA's letter represented the final information or data necessary for us to complete requirements under Section 7 of the ESA.
It is imperative the commitments agreed to by TVA and NRC during our informal consultation process regarding BFN's license renewal and EPU are met. The following is the list cf commitments made.
- 1. The TVA would continue to maintain their Heritage Program and staff biologists through appropriate funding and training so that Federally-listed fish, wildlife, and plant resources are tracked and surveyed on TVA-managed lands and along BFN's transmission line rights-of-way. The TVA would continue to follow and implement the practices outlined in TVA's best management practices document entitled: A Guide for Environmental Protection and Best Management Practices for Tennessee Valley Authority Transmission Construction and Maintenance Activities.
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- 2.
The TVA would implement a trial usage period of the surfactants recommended by the Service to determine efficacy of these recommended (or other) low-toxicity surfactants (with 96-hr LC50 toxicity for larval fish or daphnids >>1 00 mg/L) in combination with herbicides TVA currently uses near water. Beyond this, TVA commits to adjusting their evaluated surfactant use near aquatic sites and substituting new low-toxicity herbicides and surfactants, as efficacious products are identified. The TVA has committed to engage expert assistance to evaluate the effectiveness of different spray mixtures for optimal vegetation control on associated TVA rights-of-way Streamside Management Zones (SMZs). Based on the surfactant evaluation, the TVA would consider utilizing these products on an extended schedule in the BFN's SMZs, as well as on a wider scale across the TVA region. Near surface waters with known listed species, TVA is also encouraged to-avoid use of ammonia-based adjuvants; if sediment-free, low-hardness water is used as a diluent in pesticide tank mixes, such ammonia based adjuvants are usually unnecessary.
- 3.
Prior to initiating the EPU at BFN, TVA would establish an environmental baseline for current BFN operations (Unit 2 and 3) by implementing an ichthyoplankton characterization study similar to the one conducted before BFN's initial startup, from 1974 - 1979. Biological surveys would continue on a regular basis following the initiation of EPU to monitor effects of the EPU and license renewal on the aquatic biota and their habitats. Those data would then be provided to the Service for review. Should data disclose measurable impacts to fish species which are rare in the reservoir and may serve as hosts to listed mussels, the TVA will reinitiate consultation with the Service.
- 4.
The TVA would monitor water temperature, dissolved oxygen, alkalinity, pH, total residual chlorine, copper, ammonia, and hydrazine at the downstream end of the mixing zone on a monthly basis to determine if modeling has accurately predicted concentrations, targeting bottom waters at those times of the year that have historically produced the lowest river flow and warmest river water temperatures.
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Additional bottom water data (bottom meter) are desirablein thefuture during-early-morning, summer hours within the modeled plume area after startup and power output at the predicted 120% EPU. The TVA will conduct a formal risk assessment using Environmental Protection Agency methods to assess whether concentrations are protective of sensitive fish and invertebrates, particularly Federally-listed mussels, with extended low-flow, high-temperature conditions modeled in the risk assessment.
- 5.
The TVA has proposed the construction and operation of a sixth 20-cell cooling tower at BFN and has committed placing the tower in operation prior to the first summer following the return of Unit I to service. We understand the construction and operation of this cooling tower would help TVA in meeting their requirements under the National Pollutant Discharge Elimination System (NPDES) limits for water quality, particularly during the hot summer months.
- 6.
The TVA will promptly report any fish or invertebrate die-offs in the reservoir to the Service and will allocate additional resources to determine sources of the die-off that could be related to BFN and/or TVA reservoir operations related to flow and volume management.
Given these commitments are met, we believe fish, wildlife, and plant resources would be adequately protected; and the proposed action would have minimal detrimental effects to these resources. We, therefore, concur with NRC's effects determinations for the 49 Federally-listed threatened, endangered, or candidate species (11 terrestrial and 38 aquatic species) that occur, at least historically, within the portion of the Tennessee River that encompasses Wheeler Reservoir or within one or more counties of Alabama and Mississippi where BFN transmission lines are located. It should be noted that since initiation of this informal consultation, the Eggert's sunflower Helianthus eggertii has been delisted.from the Federal list 6f Endangered and Threatened species (USFWS 2005). However, when Egge:rt's sunflower is encountered by TVA botanists or TVA-contracted botanists, we recommend that these plant populations be surveyed, monitored, and/or tracked.
Based on the information and data provided, the Service believes all requirements of Section 7 of the Endangered Species Act have been met and has concluded that formal consultation will not be necessary. However, obligations under Section 7 of the Act must be reconsidered if: (:1) new information reveals impacts of this identified action that may affect listed species or critical habitat in a manner not considered, (2) the action is subsequently modified to include activities which were not considered in this consultation, or (3) new species are listed or critical habitat designated that might be affected by the proposed action.
We offer the following recommendations to ensure impacts to fish, wildlife and plant species and their habitats are minimized and adequately addressed following the EPU and during the 20-year license renewal period.
If poor and/or declining water quality conditions persist in the mixing zone and the plume area as modeled or measured, or if poor water quality conditions extend beyond previously modeled areas or depths of high temperature or poor water quality in Wheeler Reservoir or downstream, we recommend TVA and NRC consider modifications to the existing intake and outfall structures. Relocation of these structures further apart from one another may alleviate and/or remediate thermal conditions in Wheeler Reservoir. If ichthyofaunal losses relate to screening at water intakes or pump operations, additional screening or modifications should also be considered.
- 2.
De-rating of BFN's units, during extreme drought conditions, is the option TVA has committed to exercising for the purposes of meeting water quality standards for the protection of fish and wildlife and to meet requirements of the NPDES permit. We concur that this is a critical option to ensure that environmental conditions for aquatic species in Wheeler Reservoir are protected. However, during extended drought conditions in north Alabama, when BFN is operating at full EPU capacity (120% of original operating license) and NPDES limits are continually being exceeded and de-rating does not occur; we recommend TVA and
NRC consider upgrades to cooling tower capacity and/or upgrades to. BFN's capacity for placing BFN on "helper mode" operation to ensure discharged cooling water to Wheeler Reservoir meets NPDES limits.
We recommend TVA consider locating a standard Vital Signs monitoring station near the edge of BFN's mixing zone. Water quality data collected at this station could be used to calibrate modeled water quality conditions on the perimeter of the mixing zone. These data could lead to more accurate predictions of water quality conditions within the mixing zone and/or downstream of BFN. Additionally, a station located on the edge of the mixing area w6uld likely detect anomalies, such as toxic substances unintentionally released through the diffusers during short periods of time. Such short-lived pulses, if they occur, could, nonetheless, exert:
profound effects on aquatic organism health and viability, particularly of non---
mobile species such as mussels and other invertebrate fauna.
We appreciate the opportunity to work with your agency and TVA on the BFN license renewal proposal and proposed EPU for Units 1, 2, and 3 at BFN. If you have any questions or need additional information, please contact Mr. Rob Hurt at (256) 353-7243 ext. 29. In correspondence, please refer to the reference number above.
Sincerely, Elaine Snyder-Conn Assistant Field Supervisor cc:
Mr. Glenn W. Morris, TVA-Nuclear, Chattanooga, TN Mr. Jon M. Loney, TVA-NEPA, Knoxville, TN Ms. Peggy Shute, TVA-Heritage, Knoxville, TN Dr. Michael Masnik, US NRC, Washington, D.C.
Ms. Harriet Nash, US NRC, Washington, D.C.
- Mr. Greg6ryHogue, USDI:O PCitl GA Ms. Sue Cielinski, USFWS, Atlanta, GA Mr. Rob Hurt, USFWS, Decatur, AL Mr. Ray Aycock, USFWS, Jackson, MS Dr. Lee Barclay, USFWS, Cookeville, TN Mr. Brian Cole, USFWS, Asheville, NC
References U.S. Fish and Wildlife Service. 2005. Endangered and Threatened Wildlife and Plants; Removal of Helianthus eggertii (Eggert's sunflower) From the Federal List of Endangered and Threatened Plants. Federal Register 70 (159): 48482 - 48490.
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