ML071430382

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Responses 30 - 33, and 38, to Master List for Audit Needs of NRC Request for Additional Information Re License Renewal Application
ML071430382
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 05/09/2007
From:
Wolf Creek
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 07-0017
Download: ML071430382 (457)


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30. Additional details regarding the detailed assessment of impingement currently being prepared by WCNOC staff (as cited in Enclosure 3 to WM 06-0046, November 17, 2006).

Aquatic Ecology Page 2 of 3* Drawings and a detailed description of the circulating water system/service water system/essential service water system.-Discharge Monitoring Reports for the last 12 month period.-Whole effluent toxicity testing documentation or reports conducted at the facility (and as specified in the facilities National Pollutant Discharge Elimination Systems [NPDES]permit).* Item D.21 of the Facilities NPDES permit states that information required by the 316(b)Phase II regulations shall be submitted to Kansas Department of Heath & Environment (KDHE) in accordance with the dates indicated in the Phase II regulations.

Please describe the steps conducted to date by WCNOC to comply with this permit requirement and provide any data collected to date in support of this submission." Current and historic flow records for the Neosho River." A statement is made in the 5th paragraph of Enclosure 2 to WM 06-0046 (November 17, 2006) that the state of Kansas has not required entrainment monitoring and will not require it for the 316(b) determination.

Please provide documentation from KDHE regarding this issue.-Larval fish monitoring data as described in Paragraph 6 of Enclosure 2 to WM 06-0046 (November 17, 2006).-If available, information on the location of the spawning areas for the various fish species in CCL.* Bathymetric map of CCL." Available information regarding the initial stocking of CCL and subsequent stocking efforts." Available information regarding trends in the Neosho River fish populations." As discussed in Enclosure 1 to WM 06-0046 (November 17, 2006), please provide any information available regarding WCNOC's stakeholder participation in the Watershed Restoration and Protection Strategy.-Additional details regarding the detailed assessment of impingement currently being prepared by WCNOC staff (as cited in Enclosure 3 to WM 06-0046, November 17, 2006).-Possible cold shock impacts to gizzard shad is mentioned in Section 2.2 of the ER (WCGS, 1990). If there have been any incidents of cold shock to gizzard shad or other fish, please provide supporting data.-Within Section 2.2 of the ER, it is noted that WCNOC develops annual fishery monitoring reports and management plans. Please have available the most recent publication of each of these reports.

Draft V WOLF CREEK GENERATING STATION WOLF CREEK COOLING IMPOUNDMENT CLEAN WATER ACT 316(b) -COOLING WATER INTAKE STRUCTURES COMPREHENSIVE DEMONSTRATION STUDY Prepared by: Supervisor Regulatory Support Approval: Manager Regulatory Affairs Approval: ,- I j:j-S=L,-Ralph Logsdon Dan Haines Bob Hammond Date Kevin Moles Date Executive Summary Impingement studies conducted at WCGS over the December 2004 -March 2006 period suggest that impingement rates were very low in both absolute (number of fish) and comparative terms (relative to other nuclear plants of similar design), as was impingement mortality.

Impingement was selective for certain species (freshwater drum, white crappie, gizzard shad) and certain size and age classes (small fish that were not aged but were presumed to be young-of-year).

More than half of fish impinged were "rough fish" that are not avidly sought by recreational fishermen.

The white crappie was the only recreationally important species impinged in significant numbers. Most recreationally important species, including smallmouth bass and walleye, were impinged in very low numbers.Available data suggests that impingement has had little or no effect on fish populations in Coffey County Lake. Coffey County Lake, with its thriving populations of channel catfish, white crappie, smallmouth bass, walleye and wipers, has become a popular destination for Kansas's anglers. Kansas Department of Wildlife and Parks (KDWP) issues annual Fishing Forecasts for public waters in Kansas, which are in effect ratings of public fishing areas,.Coffey County Lake received biologists' rating of Excellent for walleye (the only state reservoir to receive this ranking for walleye) and smallmouth bass (the only state reservoir to receive this ranking for smallmouth bass) (KDWP 2004).Channel catfish, white crappie, white bass, and wiper fishing were all rated Good.

TABLE OF CONTENTS 1.0 PLANT COOLING SYSTEM AND WATER INTAKE STRUCTURE SCREEN A LTER NATIV ES ...........................................................................................

1 1.1 COOLING SYSTEM ALTERNATIVES

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2 1.1.1 C O O LIN G LA K E ......................................................................................

2 1.1.2 NATURAL DRAFT WET COOLING TOWERS .............................................

3 1.1.3 MECHANICAL DRAFT WET COOLING TOWERS ......................

4 1.1.4 EVALUATION OF COOLING SYSTEM ALTERNATIVES

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5 1.2 INTAKE SCREEN ALTERNATIVES

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5 1.2.1 CONVENTIONAL VERTICAL TRAVELING SCREENS ...................................

5 1.2.2 REVOLVING SCREENS ..........................................................................

5 1.2.3 EVALUATION OF INTAKE SCREEN ALTERNATIVES

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5 1.3 NEW TECHNOLOGIES AND OPERATIONAL MEASURES EVALUATION

...... 6 1.3.1 NEW TECHNO LO G IES -, ..... I .........................

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6 1.3.1.1 FINE-MESH TRAVELING SCREENS.................

... ..... ...............

7 1.3.1.2 FISH BARRIER NET ............................

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........7 1.3.1.3 BEHAVIO RAL BARIERS ........................................................................

.7 1.3.2 OPERA TIONAL MESURES ............................

I ..........................................

8 1.3.2.1 CIRCULATING WATER FLOW REDUCTION/CAPS

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8 1.4 RESTORATION EVALUATION

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8 1.5 OTHER COMPLIANCE OPTIONS ........................................................................

9 1.5.1 SITE-SPECIFIC BTA DETERMINATION

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9 1.5.1 1 CO ST/CO ST TEST .........................................................................................

9 1.5.1.2 COST/BENEFIT TEST ........................................

10 1.5.2 EVALUATION OF A SITE-SPECIFIC BTA .......................................................

10 2.0 SOURCE WATER PHYSICAL DESCRIPTION

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11 3.0 CIRCULATING WATER INTAKE STRUCTURE DESCRIPTION

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15 4.0 HISTROY OF AQUATIC BIOTA STUDIES ............................

23 5.0 PROPOSAL FOR INFORMATION COLLECTION

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26 5.1 SAMPLING PLAN AND A STUDENT REASEARCH AND TRAINING GRANT ...... 26 5.2 WOLF CREEK FISH AND SHELLFISH IMPINGEMENT STUDY .......................

27 5.2.1 STUDY O BJECTIVES

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27 5.2.2 STUDY PROCEDURES

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I ...................

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27 6.0 IMPINGEMENT MORTALITY CHARACTERIZATION STUDY ...........................

29 7.0 RESTORATION PLAN ..........................................

29 8.0 VERIFICATION MONITORING PLAN .................................................................

30 9.0 CWIS IMPINGEMENT 316(B) DETERMINATION

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31 9.1 IMPACT OF FISH AND SHELLFISH RESOURCES FROM IMPINGEMENT

....... 31 9.1.1 ASSESSMENT

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..... 33 9 .1.2 R E S U LT S .............................................................................................................

34 9.2 IMPINGEMENT AT WCGS RELATIVE TO CCL FISHERY .. ...............

36 9.2.1 IM PO RTANT SPECIES ...................................................................................

36 9.3 IMPINGEMENT AT WCGS COMPARAED TO SIMILAR PLANTS .....................

40 10.0 C O N C LUS IO N .................................................................................................

41 11.0 LITERATURE CITED ..............................

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.... .... .50 FIGURES Figure 2-1 50-M ILE VIVINITY MAP .............................................................

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12 Figure 2-2 6-M ILE VIVINITY MAP ............................................................................

13 Figure 2-3 SITE-BOUNDARY MAP ..........................................................................

14 DRAWINGS CIRCULATING WATER SCREENHOUSE DRAWING (2) ....................................

17 & 18 CIRCULATING WATER SCREEHOUSE TRAVELING SCREENS DRAWING ......19 CIRCULATING WATER UNDERGROUND PIPING DRAWING (2) .....................

20 & 21 CIRCULATING WATER DISCHARGE PIPING DRAWING .....................................

22 TABLES STOCKING RECORD OF COFFEY COUNTY LAKE ...............................................

25 APPENDICES APPENDIX A RAW IMPINGEMENT DATA APPENDIX B 2006 FISHERY MONITORING REPORT AND 2007 PLAN APPENDIX C BIOLOGICAL CONTROL OF GIZZARD SHAD AT A NUCLEAR POWER PLANT APPENDIX D EPA REGION VII POLICY ON GIZZARD SHAD APPENDIX E CORRESPONDENCE AND TELEPHONE CALL RECORD CONCERNING COFFEY COUNTY LAKE AND FISHERY APPENDIX F MAKEUP WATER SCREENHOUSE EPA PHASE II 316(b)DETERMINATION Comprehensive Demonstration Study 1.0 Plant Cooling System and Water Intake Structure Screen Alternatives In selecting a nuclear power plant site, it is necessary to determine what heat dissipation or cooling system is to be incorporated in the overall design. The cooling system to be used is a primary determinant of the size and character of the site required for the plant.In Kansas, particularly in the southeastern region, the limited availability of cooling water and the requirement to optimize water resource conservation and management are overriding considerations leading to the selection of the plant site. Natural stream flows in the region tend to be low during the summer and fall months and during periods of drought. Normal stream flows are periodically inadequate to supply makeup for a power-plant cooling system and the power plants must be sited on or in proximity to an existing reservoir, or on a reservoir that has been constructed to provide cooling water for the plant.Therefore, long-range water resources planning and wisest possible use and conservation of available water resources are absolutely necessary in. the development of new generating capacity.

Each of the alternative cooling system discussed below offers somewhat different advantages and disadvantages with -the respect to the requirements for effective water resource management.

The second major consideration in. the selection of the alternative cooling systems is the reliability and maintenance problems of the system in questionu,:

No matter how effective a design might be in its net consumptive use of water, the system is not a valid alternative if it is not highly reliable for the operation of a base load nuclear power generating station. Systems that require additional routine maintenance or periodic heavy maintenance may cause disruption of power generation and cutback of power delivery, key factors in the question of system reliability.

The third criterion to be considered in the selection of the cooling system is cost.An economic comparison of the alternative cooling system involves estimation of differences in the construction costs (for example, initial costs of equipment and land acquisition for the cooling facilities), and operating cost (for example, maintenance, fuel costs, net send-out capabilities, makeup and water treatment costs).To enable a direct comparison between the alternative cooling system, the Wolf Creek site has been assumed to be the location for all the systems. In this way, secondary variables such as pipeline and transmission line distances and access routes for road and railroad transportation are kept constant, along with other site-sensitive environmental characteristics not inherently related to the type of cooling system used.1 1.1 Cooling System Alternatives The heat dissipation system is an integral part of the power generating station and is designed to dissipate or transfer wasted thermal energy to the environment.

Even under ideal conditions, no thermodynamic process can convert more than 60 percent of a fuel's thermal energy into mechanical energy used to power the electrical generators.

The total amount of heat or thermal energy that is released and the amount of heat that must be dissipated through the cooling system are functions of the type, size, and efficiency of the plant.The nuclear steam supply system (NSSS) chosen for Wolf Creek has a full load thermal output equivalent to 3,425 Mwt. Approximately 67 percent of the heat generated will be rejected or dissipated to the environment.

To accomplish this heat transfer, the required circulating water flow through the condenser will be 1,225 cubic feet per second (cfs) at a temperature rise of 30.4' F at full load (Sargent & Lundy, 1974). The principal types of cooling systems currently being used or planned for power generating stations include: 1. Cooling lake;2. Mechanical draft wet cooling tower:, 3. Natural draft wet cooling:towers.,..ý 1.1.1 Cooling Lake The' surface of alcooling lake dissipates waste heat to the atmosphere by four heat transfer mechanisms:

Evaporation, ,40 percent; radiation, 30 percent;conduction, 25 percent; and advection, 5 percent; all working as functions of climatic conditions (Koflat, 1971). Thus, the lake depends upon natural conditions and phenomena to remove heat transferred to it by the circulation of cooling lake water through the condensers.

The size of the lake required is determined by such criteria as local climatic conditions, heat load, and effective cooling area of the lake.The cooling lake system alternative is an off-stream cooling water impoundment created by damming Wolf Creek, a minor tributary of the Neosho River. The plant draws circulating water fro the cooling lake, passes it through the condensers, where it picks up heat, and returns it to the lake. The circulating water intake and discharge structure are separated by sufficient distance and baffle dikes to avoid recirculating of the warm water directly back to the condenser.

Most of the water required both for the original filling and the makeup water requirements of the lake arrive by pipeline from John Redmond Reservoir on the Neosho River. The remaining small portion of the water requirements comes from Wolf Creek.A lake surface of about 2,630 acres would be required to meet the temperature limitations of the condenser.

However, during drought conditions equivalent to one occurrence of a 5-year duration in 50 years, the makeup water from John Redmond Reservoir (JRR) would be limited to an average of 40 cfs to meet the water quality flows in the Neosho River. With makeup limited to an average rate of 40 cfs, a lake with a 5,960-acre surface area would be required to provide for the 2,630-acre surface area after maximum drawdown.A significant advantage of the cooling lake system as compared with the alternative is that, except for the circulating water pumps, no additional equipment is necessary for plant operation.

Plant reliability is not jeopardized by the possible mechanical failure of cooling tower fans as in the case with cooling tower systems. In addition, plant maintenance costs and spare parts inventories for cooling lake systems are lower than with other systems. The major cost associated with this system is the construction of the retaining dam, the intake and discharge structures, and the water diversion and return pipelines required to maintain necessary water level and water quality.Note: By definition, Wolf Creek's cooling lake system can be also considered as a "recirculating water" system as water from Coffey County Lake (also known as Wolf Creek Lake) is pumped through the plant condensers for the purpose of removing waste heat, passed ,through a cooling; device (lake) for the purpose of, removing such, heatý from -the water and then passed again the-,;condensers (40 CFR Part 423.11 (h)).1.1.2 Natural Draft Wet Cooling Towers A wet cooling. tower system is a direct contact evaporative cooling device.-Circulating water from the condenser is cascaded down through the tower, passing over baffle plates, which break the flow into drops. Air is drawn across the baffle plates, cooling the water by evaporation.

The cooled water is then pumped back through the condenser.

The required airflow is created by either by fans (mechanical draft) or by a tall shell in which the heated air rises (natural draft) because of the chimney effect (Parker and Krenkel, 1969).The volume of airflow and the cooing efficiency of a natural draft lower depends on the temperature differences betweens the air in the shell and the ambient air.Higher effluent air temperature are normally encountered in natural draft towers than in mechanical draft towers, and natural draft towers are not generally considered suitable for hot climates in which the air density and humidity differences between inside and outside would at times be too small to achieve the minimum required air flow and rate of evaporation of the circulating cooling water (National Academy of Engineering, 1972).Inherently, these conditions tend to reduce the cooling efficiency of a natural draft cooling tower during the hotter, drier months of the year. For example, meteorological data for the southeastern Kansas region indicate that, on the average, a wet-bulb temperature of 750 F would be exceeded at least 10 percent of the time. At such conditions of temperature and humidity, cooling efficiency would drop far below acceptable levels. Because of these atmospheric conditions, the natural draft wet cooling system was not considered practical and was discarded from further consideration.

1.1.3 Mechanical Draft Wet Cooling Towers In considering mechanical draft cooling towers, it was concluded that the induced draft tower would be preferable to the forced draft type, because higher efficiencies are achievable with the former.Of the cooling tower options, the mechanically induced draft wet tower appears most viable for the plant operation.

However, this alternative would have as high a total water consumption as the cooling lake system and, subsequently, would require a storage lake of at least as great an area as the cooling lake system to provide for storage of makeup water during drought conditions equivalent to one occurrence of 5-year duration in 50 years. The lake is required because the maximum water rate demand during summer drought conditions may exceed the average rate of availability (40 cfs) from JRR. Therefore, the wet cooling tower system also requires stored water at. Wolf Creek-for:

use as makeup to the cooling towers to replace water lost by evaporation and blowdown.

The location.of the Wolf Creek storage lake, makeup water source, and the conveyance of blowdown water to the Neosho River for this alternative would be similar to that of the cooling lake system descdbed~above.

Water treatment requirements are also an important consideration in the analysis of cooling tower operation.

Biocide treatment of the circulating water is required in all cooling systems to prevent the growth of biological organisms (slimes) in the cooling system. However, cooling towers with considerable water surface exposed to air and sunlight may require additional biocide treatment to control the growth of algae. For the control of metal corrosion and scaling, cooling towers system may require additional chemical treatment, depending on the quality of the circulating water and the particular materials used in the tower and related construction and equipment.

Because the wet cooling tower requires a storage lake with as much heat dissipating surface as the cooling lake system, there seems no reason to use the wet cooling tower. Particularly, the wet cooling water system is less attractive on the basis of costs and reliability when compared with the cooling lake system because there would be added capital costs, higher operating cost, and other penalties.

There would be power penalties as well, because of additional auxiliary machinery power requirements.

Added maintenance associated with the cooling tower is also a concern. Routine maintenance would be required on the cooling tower fans, gear reducers, drive shafts, motors, water pumps, valves, piping and headers, and other mechanical components.

Maintenance would also be required on such components as louvers and fill material, in addition to the maintenance of a storage lake and pumping facilities similar to the ones required for a cooling lake system.1.1.4 Evaluation of Cooling System Alternatives Through careful consideration of the basic characteristics of each of the cooling system alternatives described above, it was determined that only the cooling lake system would be considered in the design of Wolf Creek Generating Station.The environmental impact, economic and reliability considerations associated with these alternatives indicate that the cooling tower alternatives would cause more depletion of available natural resources by using such resources for the construction of towers, basins, piping, and associated electrical and mechanical equipment.

In addition, the cooling tower options would require the highest manpower expenditure during construction and would result in the poorest utilization of fuel resources.

Also, the cooling lake system would be the most desirable system from an aesthetic standpoint.

Therefore, the cooling lake alternative conclusively offers significant environmental advantages over both of the cooling tower options (WCGS-ER, 1974).1.2 Intake Screen Alternatives 1.2.1 Conventional Vertical Traveling Screens The conventional vertically rotating single entry band type screen is the most-common mechanically operated screen in U.S. power plant intakes. It performs-efficiently over a long service life and requires relatively little operational and maintenance attention.

It is applicable to almost all water screening situations and adapts easily to changing water levels. At present there is no provisions for returning fish greater then 100 mm in size that survive impingement to the cooling lake.1.2.2 Revolving Screens Three major types of revolving screens were considered:

vertical revolving drum screens; horizontal revolving drum screens; and revolving disk screens.Revolving drum screen provide the possibility of returning fish to the body of water. But in the case of CCL, this would not be effective since there is no flow to carry the fish away. Revolving disk screens offer no advantage over other common screens for fish protection, while requiring a very large screen structure to limit approach velocities to species of fish apt to being impinged.1.2.3 Evaluation of Intake Screen Alternatives Regardless of the alternative being selected, the intake velocity will be limited to 1.0 ft/sec at low water level. The sustained swimming speed of the adult species of fish expected to inhabit the lake is sufficient to minimize involuntary impingement at water velocities to or less than 1.0 ft/sec. Phytoplankton, zooplankton, juvenile fish, and fish eggs will undoubtedly be subject to passage through the circulating water intake structure.

The alternative structures are similar in terms of potential effects to biota and thus comparisons are not warranted.

The conventional vertical traveling screen was selected as the type of screening mechanism to be use at the CWIS (WCGS-ER, 1974). Further discussion on the CWIS screening system is described in Section 3.0.Note: The Makeup Water Screenhouse (MUSH) on the Neosho River is used on occasion to add water to Coffey County Lake (CCL). Coffey County Lake was constructed as a cooling lake for the WCGS and is considered a Water of the State. The transfer of water from the Neosho River to CCL is a transfer from a Water of the State to another Water of the State. This is a water transfer and not a direct use of water by WCGS. At this time water transfers are not covered by NPDES permitting, and therefore exempt from 316(b) coverage (USEPA, 2006).See Appendix F for more detailed information.

1.3 New Technologies and Operational Measures Evaluations The Environmental Protection Agency (EPA) 316(b) Phase II regulations, [40 CFR 125.95(b)(l)(i)]

requires that the 316(b) determination include a description of technologies and operational measures, which will be evaluated further to determine feasibility of implementation and" effectiveness in meeting impingement standards.

Several technologies and measures have been developed/conducted and have proven effective, in certain circumstances, in reducing impingement at various CWIS. The feasibility of implementation and the performance of such technologies and operational measures are highly site-specific.

The design and capacity of the existing CWIS, as well as source waterbody physical and biological characteristics, including additional power requirements and loss in generating capacity and unit availability will determine which technologies and/or operational measures are practical for implementation and effective in reducing impingement at WCGS.1.3.1 New Technologies A screening of technologies has been conducted to determine which technologies offer the greatest potential for application at WCGS and therefore would warrant further evaluation.

Technologies have been screened based upon feasibility for implementation, biological effectiveness (i.e., ability to achieve reductions in impingement mortality), and cost of implementation (including capital, installation, and annual operations and maintenance costs).

Based upon the results of the technology screening process discussed above, the following is a list of technologies evaluated to reduce impingement and achieve a performance standard, in whole or in part, for reduction in impingement.

Following is a list of those technologies:

1. Fine-mesh traveling screens 2. Fish barrier net; and 3. Behavioral barriers.1.3.1.1 Fine-Mesh Traveling Screens Fine-mesh traveling screens require an approach velocity no greater than 0.5 ft/s to handle the higher potential clogging rate, which would be inherent with the finer mesh-screening medium. This technology is not viable for WCGS intake system due to high screen flow velocities of the existing system. Further evaluation of this technology is not warranted.

1.3.1.2 Fish Barrier Net A fish net barrier is a mesh curtain installed in the waterbody in front of CWIS.All flow to the intake passes through the net so all-aquatic life forms of a certain size are blocked from entering the intake. The net barrier is sized large enough to have very low approach and through net velocities f 0.1 ft/s of less to preclude impingement of juvenile fish with limited swimming ability. The mesh size must be large enough to preclude fouling during normal station operation while atthe same time small enough to effectively block passage of organisms into the intake.. These conditions typically limit the mesh size such that adult and a percentage of juvenile fish can be blocked.A typical design-loading rate for fish barrier nets is 20-gpm ft 2.Therefore, a barrier net to handle the CWIS flow would require a net area of approximately 7,200 ft 2 for WCGS CWIS (based upon existing facility design capacity).

Maintaining such a fish barrier net in the open lake moored around the existing intake is not practical and would be an operational and mechanical nightmare to upkeep. Further evaluation of this technology is not warranted.

1.3.1.3 Behavioral Barriers A behavioral barrier relies on avoidance or attraction responses of the target aquatic organism to a specific stimulus to reduce the potential of impingement.

Most of the stimuli tested to date are intended to repulse the organism from the vicinity of the intake structure.

Nearly all the behavioral barrier technologies are considered to be experimental or limited in effectiveness to a single target species. Further evaluation of this technology is not warranted.

None of the above listed technologies would further limit the limited amount of impingement seen at WCGS as determined by the impingement monitoring, result analysis and conclusions drawn in Sections 9.0 and 10.0 but these technologies would in turn be impractical as to capital, operational and maintenance cost.1.3.2 Operational Measures Only one operational measure has proven effective in reducing impingement at the CWIS and that is by reducing the flow through the CWIS.1.3.2.1 Circulating Water Flow Reduction/Caps Circulating water flow caps are an operational control measure which would include administratively limiting the total withdrawal of cooling water from CCL to an agreed upon value. The flow reduction may be schedules for periods of the year when impingement are highest to achieve a greater reduction to impingement.

There. are two reasons why this operational measure, will not work. First; the impingement rate for any particular time or month during the year, was not-high;.;

enoughý to warrant this type of. operational control to reduce impingement.;

Secondly, nuclear power plant do not run effectively by having to reduce power generation because of reduce flows through the CWIS. Nuclear power plant,., cannotibe operated as peaking units.:.Note: In Section 1.0 of this position paper the architect/contactor during the construction of WCGS used the best technology and operational measures available at that time. There was no requirement to perform an impingement study at WCGS. KDHE position as indicated in a letter sent by M.W. Gray, Director, Division of Environment, dated February 21, 1975, to M. Miller (KGE)stated "It is in our opinion (KDHE) that Kansas Gas and Electric Company shall not be held responsible for the loss of fish in the lake due to cold shock kill, impingement, or entrainment".

A copy of this letter can be found in Appendix E.1.4 Restoration Evaluation The EPA 316(b) Phase II regulation

[40 CFR 125.95(b)(I)(i)]

allows consideration of restoration measures as one of the options that may be implemented, either alone or in combination with technology and/or operational measures, to achieve performance standards for reduction of impingement.

Facilities may propose restoration measures that will result in an increase in the number of fish and shellfish in the waterbody that would be similar to those achieved with meeting performance standards through the implementation of technologies and/or operational measures.

A further look at restoration as a tool to offset impingement rates can be found in Section 7.0.

1.5 Other Compliance Options One additional compliance alternative that WCGS may pursue includes a site-specific determination of best technology available (BTA). The site-specific determination option would be undertaken only in the event the implementation of some combination of an intake technology, operation change or restoration is significantly greater in cost than anticipated by EPA at this time.1.5.1 Site-Specific BTA Determination The intent of the WCGS approach to compliance is to meet the impingement performance standard established by the EPA when the new rule was promulgated.

However, WCGS also recognizes that if the cost of reaching these goals cannot reasonably be achieved that the EPA 316(b) Phase II regulation allows a somewhat lower impingement standard.

Specifically the new rule would allow WCGS to demonstrate that WCGS is eligible for site-specific determination of BTA to minimize impingement if WCGS has selected, installed, and properly operating and maintaining measures that the director has determined to be the BTA to adverse. environmental

.-impact of. WCGS cooling water-operations.

This compliance alternative allows WCGS to request a site-specific determination of BTA for minimizing impingement if WCGS can demonstrate that the cost for compliance-with, the new rule are significantly greater than those considered by EPA in the development of the new Irule. (cost/cost test) or that the costs::-associated with compliance are.. significantly greater than the benefits (cost/benefit test) that would accrue to the environment.

1.5.1. 1 Cost/Cost Test If WCGS chooses to seek a site-specific determination of BTA, a cost/cost test has to be performed to compare the cost of implementing options to achieve full compliance with the 316(b) Phase II standards to costs estimated by the EPA for the WCGS facility for achieving full compliance.

In the 316(b) Phase II rule, the EPA has assumed that the WCGS facility has already meet the performance standards based on existing technologies and measures already in place.Therefore EPA has projected zero compliance cost for the WCGS facility (Federal Register, Vol. 69 -7/9/2004, page 41678 -see Facility ID# DUT1 105).One thing that has not been fully resolved by EPA is what constitutes "significant" compared to zero dollars that the EPA projected for WCGS. Any cost associated with power reduction or plant shutdown (> $100,00/day) to make changes plus the cost of those changes to the CWIS or traveling screens will fall upward into the significant range even though "significant" has not been defined.

1.5.1.2 Cost/Benefit Test A cost/benefit test may also be performed for WCGS to compare the total costs of achieving compliance with the environmental benefits through implementation of the required technologies, operational, and/or restoration measures.

Costs are the sum of direct costs and indirect costs of any intake, operational, and/or restoration mitigation actions. Direct costs include the costs of implementing compliance alternatives, including capital, O&M, and lost generation revenue due to extended outages. Indirect costs include any costs associated with impairments of higher energy prices, and negative ecological effects of the mitigation actions on the waterbody.

The benefits arise from reducing impingement by the full amount of the 316(b)Phase II rule's performance standard relative to baseline conditions.

The economic benefits of reduction in impingement have been specified by the EPA in its evaluation of the national benefits of the rule. The classes of benefits identified by EPA in its assessments include direct use benefits (e.g., those form commercial and recreational fishing), indirect use benefits (e.g., increased forage organisms), and existence, or passive use benefits (e.g., improved biodiversity).

Restoration is a component of the cost/benefit approach.:.

The: ability of-:a-;:,,.-.-,-

restoration project(s) to generate benefits.

to. offset impingement must, be demonstrated.

This requires a method that can. be used to, quantify restoration benefits in a; manner comparable to impingement effects in the ecosystem.

WCGS..restoration method and measures are described in Appendix B. Kansas., Department of Wildlife and Parks (KDWP), formerly known as Kansas Fish and Game Commission, have accepted this methodology, the use of CCL as a fishery under a re-stocking program, being used by WCGS. KDWP's letters asserting that CCL is a fishery can be found in Appendix E.1.5.2 Evaluation of a Site-Specific BTA None of these methods described in the above paragraphs are viable and a site-specific BTA is not sought along with the use of other technologies and operational measures to meet compliance with the 316(b) Phase II rule. A restoration measure is the only true alternative resource left for WCGS to implement.

WCGS use of a restoration measure is described in Section 7.0, Restoration Plan and will be use to offset impingement losses.

2.0 Source Water Physical Description The Coffey County Lake (CCL sometimes referred to as Wolf Creek Cooling Impoundment) is located on Wolf Creek Generation Station (WCGS) site.WCGS is located in Township 20 and 21 South, Range 16 East of the Sixth Principal Meridian, and Township 20 and 21 South, Range 15 East of the Sixth Principal Meridian.

Of the 11,662 acres possess by our owners, the site occupies 9818 acres, and 1,844 acres lie outside of the site boundary.

The acreage not used for WCGS is managed for wildlife and agricultural purposes.Areas modified by construction of WCGS include 135 acres for the station, 60 acres for the cooling impoundment dams and dikes, and 5090 acres for the cooling impoundment.

A "main" earth dam constructed across Wolf Creek and five saddle dams built along the periphery of the impoundment forms CCL. The main dam is located about seven stream miles from the Wolf Creek and Neosho river confluence.

The tops of the dams are at an elevation of 1,100 feet above mean sea level (MSL) to provide sufficient freeboard.

Service and auxiliary spillways with ogee crests of 1,088 feet MSL and 1,090.5 feet MSL respectively are provided on the east abutment of the main dam to prevent overtopping of the dams by the probable maximum flood and wind and wave action. The ýnormal operating elevation of the cooling impoundment is 1,087 feet MSL. At this elevation the impoundment has a capacity of 111,280 acre-feet and a surface area of 5,090 acres.A major source of makeup water to the cooling impoundment is the conservation storage of the John Redmond Reservoir, providing that the low flow downstream requirements are satisfied.

Additional makeup water is supplied by natural runoff from the Wolf Creek watershed and direct precipitation on the cooling impoundment surface.The topography within Wolf Creek watershed varies from undulating hills upstream of the station site to a floodplain area shared with the Neosho River.The Wolf Creek watershed has a drainage area of 35 square miles. About 27.4 square miles of the 35 square mile Wolf Creek watershed will be upstream of the main dam. The cooling impoundment has altered the draining pattern of the watershed.

Within the impoundment two baffle dikes and two canals having inverts at 1,070 feet MSL are built to prevent short circulating of the water flowing from the circulating water discharge to the Circulating Water Intake Structure.

The impoundment canals are 215 feet wide with slopes of the canal sides at 1 foot vertical per 3 foot horizontal.

The volumetric water rates in these canals are assumed to be 1256 cfs at a water velocity of 0.87 fps when the impoundment water level is at 1087 MSL.

.i~' ,*PC N S 0 0.5 1 2 .3 Moes LEGEND SCounty BoundaryLakes and WaterUrban AreaslWolf Creek Generating Station KANSAS

  • 3.0 Circulating Water Intake Structure (CWIS) Description The CWIS is a shoreline intake structure located at 380 14' 00" latitude and 950 41' 15" longitude.

One hundred percent (100%) of the cooling water flow is used for cooling purposes.

The CWIS is in use providing cooling water flow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven days a week. The only time there is no flow through the CWlS is when both the circulating water and service water system are inoperable.

The CWlS houses three circulating water pumps situated one to each of its three bays. Under normal conditions all three pumps will be operating at a total capacity of 1178 cubic feet per second (cfs). Three service water pumps are also housed in the CWIS. Normally, two service water pumps will be operating at a total capacity of 90 cfs, with one pump serving as a standby. A low-flow and startup pump with a capacity or 14.5 cfs is also provides for the service water system. In addition, the fire protection diesel and electric fire pumps are locates in the CWIS, which will draw water from the CWIS bays. The MWIS contains a bar grill, conventional traveling screens, and strainers.

Also, WCGS employs an ice control system in front of the MWIS using hot water recirculation from the steam condenser and air bubbles.The CWIS sump floor is located at an elevation of 1058 feet MSL. A steel plate is provided at the sump inlet of the MWIS as a weather protection device. This steel plate extends downward from the CWlS operating floor (1092 feet MSL) to 1075 feet MSL. The velocities of the circulating water and service water flow downstream of the steel plate are essentially independent of the cooling impoundment water level.The circulating water and the service water flow from the cooling impoundment through bar grills (trash racks) into bays where the traveling screens are located.The bar grills are used for removing the larger debris. Smaller debris is collected on the traveling screens. The traveling screens, operated intermittently, are backwashed with water drawn from WCCI. This screen wash system is activated normally by a timer or automatically from a high-differential pressure switch.Trash collected on the traveling screens is backwashed to a trash basket. This trash is manually disposed of at Coffey County Landfill.

There are no provisions for returning fish that survive impingement to WCCI unless they are small enough to pass through the trash basket openings.The circulating water is pumped from the intake structure bays through a 12 foot-diameter inlet pipe to the steam condenser, which is designed to increase the circulating water temperature 340 to 420 F at full operating load. The warmed water then will be flow from the condenser through a 12 foot-diameter outlet pipe to the outfall structure.

At the discharge structure the circulating water will be released into a well. The water will then flow over the crest of this well into the cooling impoundment.

Hold up times of the circulating water in the inlet pipe, the condenser, and the outlet pipe are about 3 minutes, 18 seconds, and 2 minutes, respectively.

The discharged water takes approximately 38 days to travel from the discharge outfall to the intake structure.

The service water is pumped from the intake structure bays through a 42 inch-diameter pipe to the station's heat exchangers.

There it will be heated about 100 F and discharged into the 12 foot-diameter pipe containing the circulating water flowing from the steam condenser to the outfall structure.

The service water also supplies cooling water to the essential service water system during normal operations.

Water returning from the essential water system is returned to CCL.Based on the total (circulating water and service water combined) flow rate of 1256 cfs, the average inlet water velocities are calculated to be: Approach velocity to the CWlS: 0.87 feet per second Velocity through the bar grills: 1.06 feet per second Approach velocity to the traveling screens: 1.06 feet per second Velocity through the traveling screens 1.95 feet per second The CWIS bar grill, located at the inlet of the intake bays, is comprised of 1-inch vertical bars spaced at 3-inch intervals.

There are six traveling screens with two traveling screens per bay. The traveling screens are of a vertical single entry/exit type with a standard 0.375-inch mesh made by Envirex in 1982.

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4.0 History of Aquatic Biota Studies WCNOC conducted pre-operational (1973-1984) and operational (1985-1987) monitoring studies of Neosho River and Wolf Creek fish populations.

These studies were intended to establish baseline conditions with regard to Neosho River and Wolf Creek fish populations and, later, to identify possible changes in these populations associated with construction and operation of WCGS.WCNOC surveys of the Neosho River (from John Redmond Reservoir tailwaters to below Wolf Creek) over the 1973-1987 period yielded 52 fish species, with 13 species appearing in samples in every year. Electrofishing and seine data from pre-operational period (1977-1982) and an operational period (1985-1987) were pooled to examine species composition and relative abundance.

In all years, collections were dominated by Cyprinids (minnows and common carp) and Clupeids (gizzard shad). Cyprinids made up 61.2 percent of all fish collected in the 1977-1982 pre-operational period and 73.0 percent of all fish collected in the 1985-1987 operational period. Shad made up 16.4 percent of fish collected in the pre-operational period and 16.8 percent of the fish collected in the operational period. Comparisons of other groups (Ictalurids, Catastomids, .-, and Centrachids) showed relatively small shifts in the abundance between pre-operational and operational phases.Having monitored Neosho River fishes from 1973 to 1987, WNCOC concluded that construction of Coffey County Lake (CCL) and operation of WCGS had little.of no effect on Neosho River fishes. Changes, in relative abundance were seen between the years, but were relatively small and related to factors entirely outside of WCNOC's control. Weather, in particular, appeared to influence fish populations in the Neosho River downstream of John Redmond Reservoir.

Rainfall up-river in the basin determined the volume of water released downstream into the Neosho River. The amount (and timing) of water released downstream affects reproductive success of species that spawn in the river, survival and growth of larval and juvenile fish, age and growth of adult fish, movement of all ages and stages of fish, and predator-prey relationships.

All of these elements shape fish populations in the Neosho River in the vicinity of WCGS.Having established the WCGS was having little of no impact on the Neosho River fish populations, WCNOC shifted its focus in 1988 from the Neosho River to CCL. Just as significantly, WCNOC transitioned from monitoring fish populations for possible station-related changes to monitoring fish populations in order to more effectively manage them. The primary fishery management goal in the years after Coffey County lake filled (reached normal operating level in 1982)was gizzard shad control; specifically limiting numbers of young shad in the lake because they were vulnerable to cold shock. The concern was that cold-killed and cold-stunned gizzard shad could clog WCGS's intake screens. Sudden plant shutdowns and cold shock are more of an issue at single unit nuclear plants, like WCGS, than multiple-unit plants because there are no additional units to moderate the sudden temperature change.Before CCL reached full pool in 1982, WCGS embarked on an "aggressive" stocking program with the goal of establishing a fishery with a diversity of predators.

Species stocked in smaller impoundments within basin to be flooded included largemouth bass, smallmouth bass, channel catfish, blue catfish, bluegill, black crappie, and walleye. Once filled, more of these species and wipers (stripped bass/white bass hybrids) were added. Gizzard shad larvae were unavoidably introduced to the lake from the Neosho River when water was pumped to fill the lake. White bass and white crappie also appeared after the lake filled, and are presumed to have been introduced the same way. No fishing was allowed in the lake in the 1980s, so there was no risk of sport fish populations being overfished.

The ultimate goal was a "cropped" prey (gizzard shad) population with a relatively high proportion of larger, older, individuals and low reproductive potential and a diverse, fast-growing community of predators with the ability to take different ages and sizes of shad occupying different parts of Coffey County Lake.After the lke was opened to fishing (October 1996), gamefish populations

were:.:: managed both to control shad and provide local and regional anglers with high-quality fishing. In June 1998, Coffey County assumed responsibility for managing public use of the Wolf Creek Cooling Impoundment and changed the name of the lake to Coffey County Lake (CCL).Coffey County Lake, with its thriving populations of channel catfish, white crappie, smallmouth bass, walleye and wipers, has become a popular destination for Kansas's anglers. WCNOC closely monitors fish populations in CCL in order to draft annual fisheries management plans that will satisfy the complementary goals of controlling gizzard shad numbers and maintaining healthy population of gamefish.

WCNOC uses a variety of gear types (e.g., electrofishing, fyke netting, gill netting, and seining) and sample CCL in systematic fashion to ensure that species of interest are effectively sampled and sampling results area amenable to statistical analysis.

Fish are collected in spring, summer, or fall, depending on the species and its seasonal habitat preferences.

Sampling is intended to gather information on gizzard shad reproduction, survival, and abundance and predator (largemouth bass, smallmouth bass, white bass, wiper, and walleye) age and growth, condition, and abundance.

Having established population characteristics (size and age distribution, year class strength, actual and relative abundance) and compared population data to previous years, WCNOC submit annual fisheries monitoring reports and management recommendations to WCGS's Manager of Regulatory Affairs.These findings are also discussed with Kansas Department of Wildlife and Parks fishery biologist, who then draft regulations for CCL for WCNOC review. When both organizations are satisfies with the proposed regulations, KDWP biologist submit these regulations to the Kansas Wildlife and Parks Commission, which typically approved them. Regulations approved by the Commission are adopted and made enforceable by order of the Secretary of Wildlife and Parks.Stocking Record of Coffey County Lake Species Date(s) Number Location Flathead Minnow 08/78 56,000 Subimp.Largemouth Bass 08/78 3,500 Subimp.Flathead Minnow 09/79 75,000 Subimp 11/79 52,000 Subimp.Bluegill 09/79 5,000 Subimp.Smallmouth Bass 11/79 40 Subimp.Largemouth Bass 09/79 2,400 Subimp.Flathead Minnow Bluegill Red-ear Sunfish Black Crappie Smallmouth Bass Largemouth Bass Striped Bass Walleye Blue Catfish Channel Catfish Striped X White Bass Hybrid 05/80 06/80 08/80 09/80 05/80 06/80 08/80 09/80 08/80 10/80 08/80 06/80 10/80 06/80 06/80 07/80 10/80 05/80 06/80 08/80 10/80 05/81 90,000 65,000 270,000 57,500.'130 3,150 16,000 12,700 2,000 1,000 500 6,000 1,000 1,200 7,000 5,000 35,000 100 3,100 25,000 25,000 50,000 UHS UHS Subimp.Subimp.Subimp.UHS Subimp.Subimp.Subimp.Subimp.Subimp.UHS Subimp.UHS UHS UHS CCL Subimp.UHS Subimp.CCL CCL Subimp = Sub-impoundment of CCL UHS = Ultimate Heat Sink Basin CCL = Coffey County Lake 5.0 Proposal for Information Collection Development of a restoration plan is proposed by Wolf Creek Nuclear Operating Corporation (WCNOC) to meet applicable Clean Water Act 316(b) requirements.

WCNOC proposes to continue the current fishery management program that monitors and promotes relatively high predator species densities compatible with the ecology of Coffey County Lake (CCL). High predator densities have discouraged large concentration of small forage fish, primarily gizzard shad, which in turn has supported WCGS operation by keeping impingement rates low.The fishery also provides regional recreational benefits.Fishery management has involved periodic stocking to support predator fish populations.

The need for future stockings will be determined based on annual monitoring data. Other restoration measures, such as habitat enhancement or nuisance species removal, will be considered as needed to support the current fishery.5.1 Sampling Plan and a Student Research and Training Grant Wolf Creek Nuclear Operating.

Corporation. (WCNOC) entered into a graduate level research project %with Pittsburgqi State. University to help quantify.environmental interfaces with Wolf Creek Generating Station (WCGS) operation.

This partnership enhanced WCNOC's ability to address these issues in a cost efficient manner. For the university, it helped prepare the students in a field Where such skills will likely- be in demand in the utility industry.

The environmental interfaces that were researched'are industry wide issues, with many utilities likely to contract with consultant firms, which will need biologists to conduct similar research.For WCNOC, primary issues include recently promulgated Clean Water Act 316(b) regulations, and station re-licensing issues with impingement and entrainment aspects of fish and aquatic organisms at the cooling water intake.Information on impingement and entrainment effects will also be useful for fishery management considerations to maintain low gizzard shad -densities.

Impingement refers to impacts to the environment due to larger fish and other organisms being trapped on the traveling screens, which is both a 316(b) and re-licensing issue. Entrainment refers to impacts due to smaller aquatic organisms being pumped through the plant, which is primarily a re-licensing issue. Note: For the purposes of this Comprehensive Demonstration Study (CDS) submittal only impingement will be discussed.

An entrainment study is not required for an intake structure on lake and reservoir.

The product desired from the graduate research will be to collect, analyze, and prepare a manuscript suitable for submittal to a peer-reviewed publication.

All research is to be conducted in an unbiased manner. WCNOC will reserve the right as a coauthor for any publication.

26 As required in 40 CFR 125.95(b)(3), the results of the impingement sampling program will be summarized in this submittal that will answer the following environmental question: What is the fish mortality rate due to impingement at WCGS? This would include; fish density estimates by species in the intake area of CCL, determination of fish numbers at the intake screens that were dead before being impinged on the screens, and annual impingement rates sufficient to confidently extrapolate total plant impacts to the fishery.5.2 Wolf Creek Fish and Shellfish Impingement Study 5.2.1 Study Objectives A. Determine fish community vulnerable to impingement B. Determine impingement C. Evaluate water quality D. Evaluate the factors contributing to impingement 5.2.2 Study Procedures A. In order to determine the fish community vulnerable to impingement:

1. Existing WCNOC fish data will be used to establish historical trends for seasonal changes in: a. species composition
b. relative abundance c. length frequency 2. Ongoing sampling by WCNOC along with some targeted efforts using electro-fishing, trap-nets, gillnets and hydro-acoustics (if practical) will be used to establish current seasonal changes in the intake area.B. In order to determine impingement rates: 1. Screen-wash catch basket surveys will be conducted every eight hours for a 24-hour period on a monthly basis, with more frequent surveys during peak impingement periods. Information collected will include: a. species composition
b. length frequency 27
c. pre-impingement mortality C. In order to evaluate water quality influences, measurements will be taken to determine:
1. DO profiles 2. Temp profiles 3. Turbidity D. In order to evaluate the factors contributing to impingement:
1. Vulnerable species composition, length frequencies, and density estimates will be compared to: a. time of year b. time of day c. dissolved oxygen d. Water temp e. WCGS operating conditions
f. Screen-wash number g. Screen-wash species composition
h. Screen-wash length frequencies
i. Natural mortality, as measured at screen-wash
j. Water clarity k. upstream temperatureh I. upstream dissolved oxygen m. upstream water clarity n. plant operating conditions 28 6.0 Impingement Mortality Characterization Study Wolf Creek's quantitative impingement study is described below, and is designed to review fish impingement over the spring, summer, fall and winter periods.Precision and reliability of reduced sampling designs may be affected by the number of sampling days selected at various times of the year, particularly if the impingement rates of individual fish species are of interest.Intuitively, we suspect that impingement of key species in WCCI tends to be highest in the winter and lowest in the spring. Sampling may therefore be more intense (2-3 days/month) during the key impingement months (December.-

February), and less intensive during other seasons (1 day/month).

This sampling design would allow about 15 days of sampling and ensure reasonable precision and reliability.

Sampling over a 24-hour period will measure any diurnal influence to impingement.

The research is scheduled for two years to account for any weather variations.

7.0 Restoration Plan Wolf Creek can use restoration measures when design and construction and/or" operational measures are. less: feasible, lest cost-effective or -less environmentally desirable.

Wolf Creek's restoration plan is basically a restocking program designed to maintain a desirable fishery in WCCI based on our annual fishery monitoring report (see Appendix A). The WCC1 restocking program was initiated in 1978 and continues today. The Environmental Management group prepares the annual fishery monitoring report.This report targets three issues that need to be addressed prior to restocking WCCI. They are; (1) young-of-year (YOY) gizzard shad changes, (2) adult shad and predator fish population dynamics, and (3) angler harvest impacts to the fishery.First, knowledge of YOY shad production is important because these fish pose the most immediate impingement threat to plant operations.

Identifying increases in YOY numbers before winter temperatures make them vulnerable to impingement will allow operational preparations to compensate for the increased risk of impingement.

Second, the characteristics of the adult fish population provide long-term data to evaluate if YOY shad control benefits will continue.

Higher numbers of shad growing to reproductive size is an indication that less predation is occurring.

Likewise, fewer predator fish growing to reproductive size would indicate declining shad control capabilities.

Increased predator fish health would also indicate this. Stocking recommendations also are derived from the adult fish characteristics Lastly, the adult fishery monitoring will provide information on angler harvest impacts to the fishery. Proper length limit recommendations can be derived from the monitoring data to ensure that public angler harvest and the plant's gizzard shad control efforts remain compatible.

Creel census data collected by Coffey County at the lake access park will be reviewed and compared with the other fishery sampling data.8.0 Verification Monitoring Plan The purpose of the verification-monitoring program is to provide the Environmental Management group with information regarding the WCCI fishery.A variety of sampling gears are used to assess the condition of adult and juvenile classes of both prey and predator species to provide information on potential impingement impacts to station operation.

In addition, the methods employed will assess the effects of station operation and angler harvest on the fish populations in WCCI.An annual report, the Fishery Monitoring Report, detailing the fishery monitoring

.,activities and results are compiled..

Any trend's influence on the ability of the fishery to control fish impingement events, which may affect WCGS operations, willi be identified.

In addition, WCGS Operations will be notified, if necessary; of, the possibility of increased shad impingement that may be expected during the winter. ý:Any adjustments to angling length and creel limits will be proposed.Recommendations that may include: increased monitoring or stocking needs will .be presented.

A summary of the fishery monitoring activities will be completed by April of each year.

9.0 CWIS Impingement 316(b) Determination Kansas Department of Health and Environment (KDHE), Bureau of Water (BOW), has not as of this time, made any Clean Water Act 316(b) determination for cooling water intake structures on either a river, lake or reservoir.

The recently renewed NPDES permit, February 1, 2005, for WCGS takes into account the new EPA 316(b) Phase Ii regulations, 40 CFR Part 125.95 et seq.requirements for once-through cooling systems. The permit requires the applicant to conduct a study of the cooling-water intake for potential adverse environmental impacts in accordance with Section 316(b) of the Clean Water Act and to submit to KDHE the required information by June 2008. Any requirements resulting from the water intake study would be reflected in future NDPES permits.9.1 Impact of Fish and Shellfish Resources from Impingement Cooling Water Source The Circulating Water System (CWS), Service Water System (SWS), and the Essential Service Water System (ESWS) at WCGS all draw from and discharge to Coffey County Lake (CCL), formerly, known as the Wolf Creek Cooling Lake..CCL is located on the WCGS site; A ,main" earth dam constructed across Wolf:Creek and five saddle dams built along the- periphery of the impoundment forms CCL. The main dam is located about seven stream miles from the Wolf Creek and Neosho river confluence, The tops of the dams are at an elevation of 1,100 feet above mean sea level (MSL),to provide sufficient freeboard.

Service and auxiliary spillways with ogee crests of 1,088:feet MSL and 1,090.5 feet MSL respectively are provided on the east abutment of the main dam to prevent overtopping of the dams by the probable maximum flood and wind and wave action. The normal operating elevation of the cooling impoundment is 1,087 feet MSL .At this elevation the impoundment has a capacity of 111,280 acre-feet and a surface area of 5,090 acres.This 5,090-acre reservoir is designed to provide adequate cooling water to the plant during a one-in-fifty-year drought. To maintain the water level in the CCL, it is sometimes necessary to pump makeup water to the CCL from the Neosho River, just below the John Redmond Reservoir dam.Within the impoundment two baffle dikes and two canals having inverts at 1,070 feet MSL were built to prevent short-circuiting of the water flowing from the circulating water discharge to the Circulating Water Intake Structure.

The impoundment canals are 215 feet wide with slopes of the canal sides at 1 foot vertical per 3 foot horizontal.

The volumetric water rates in these canals are assumed to be 1256 cfs at a water velocity of 0.87 fps when the impoundment water level is at 1087 MSL. WCGS cooling water system configuration is considered a once-through cooling water system. Figures 1, provides a simplified drawing of the cooling lake and John Redmond Reservoir System.

Circulating Water System The Circulating Water Screenhouse (CWSH) is located in the southeast comer of the main plant area on the shore of the cooling lake. The screenhouse contains the major equipment associated with the circulating water system (CWS) and the service water system (SWS).The CWS operates continuously during power generation, including startup and shutdown.

Three one-third capacity motor-driven, vertical, wet-pit circulating water pumps pump the circulating water from the cooling lake to the main condenser.

They are designed to operate through the expected range of cooling lake levels. The heated water discharged from the condenser is returned to the cooling lake through a CWS discharge structure.

The main circulating water pipes from the circulating water screenhouse to the power block and from the power block to the discharge structure have an inside diameter of 144 inches.Freeze protection to prevent ice blockage at the circulating water screenhouse is accomplished by a warming line that routes a portion of the circulating water condenser discharge to the inlet of the screenhouse pump bays."The- SWS consists of three one-half capacity service water pumps and one low flow and startup pump, traveling-screens and automatic backwash strainers, all located in the screenhouse.

,.During normal plant operation, the SWS supplies cooling water to the turbine plant auxiliary equipment, steam generator blowdown nonregenerative heat exchanger, and: CVCS chiller, as well as components served by the ESWS. The service Water system is the normal water supply for the Demineralized Water Makeup System.The circulating water and the service water flow from the cooling impoundment through bar grills (trash racks) into bays where the traveling screens are located.The bar grills are used for removing the larger debris. The CWIS bar grill, located at the inlet of the intake bays, is comprised of 1-inch vertical bars spaced at 3-inch intervals.

There are six traveling screens with two traveling screens per bay. The traveling screens are of a vertical single entry/exit type with a standard 0.375-inch mesh made by Envirex in 1982. Smaller debris is collected on the traveling screens.The traveling water screens are operated as per system operating procedures.

The traveling water screens can be rotated and backwashed, manually or automatically, due to differential pressure across the screens. Debris is automatically deposited in a basket for periodic removal by plant personnel.

The plant service water return discharges into the circulating water discharge.

This discharge is directed to the station cooling lake. Each service water pump is sized to deliver 25,000 gpm (-58 cfs) of service water at a discharge pressure of approximately 185 feet. Each circulating water pump has a design capacity of 167,000 gpm (-372 cfs) at a corresponding developed total head of 74 feet of water.The CWIS sump floor is located at an elevation of 1058 feet MSL. A steel plate is provided at the sump inlet of the CWIS as a weather protection device. This steel plate extends downward from the CWlS operating floor (1092 feet MSL) to 1075 feet MSL. The velocities of the circulating water and service water flow downstream of the steel plate are essentially independent of the cooling impoundment water level.Three pumps provide the design flow rate of approximately 500,000 gallons per minute when lake water temperatures are greater than 50 OF. Because condenser cooling is more efficient with colder intake water, only two pumps are operated with a design flow of 365,000 gallons per minute when lake temperatures are below 50 OF. At these pumping rates, design flow across the rotating screens at the point of impingement is less than 1.0 fps.9.1.1 Assessment Data from impingement surveys conducted monthly. at WCGS over the December 2004 through March 2006 period were used for this assessment.

A fine-mesh (0.25 inch bar mesh) collection basket was placed in a catch basin to: collect all fish washed from traveling screens over a given 24-hour period. :The basket-was necessary because small fish are able to move through. the grate at *the base of the catch basin and re-enter the CCL.Fish were removed from the basket every eight hours and identified, measured, and examined in order to ascertain their condition.

Each fish was classified as"live," "recently dead," or "dead" based on its physical condition.

All fish categorized as "dead" based on examination were considered dead before they were impinged on the traveling screens. These fish represented natural mortality in CCL. Fish categorized as "recently dead" were assumed to have been alive when impinged, and died in the collection basket as a result of exposure and oxygen deprivation.

Because the traveling screen wash passes though a trash grating (with 1 inch by 3.75 inch openings or 2.54 centimeters by 9.53 centimeters) at the point at which it leaves the Circulating Water Screenhouse (CWSH) and flows into CCL, the following assumptions were employed in extrapolating monthly and annual rates of impingement mortality from basket surveys: All fish greater than 100 mm total length (TL), no matter their condition in the collection basket, would die under normal circumstances because they would not likely pass through the openings in the trash grating.

All fish in the collection basket less than 100 mm TL categorized as "live" or "recently-dead" would, under normal circumstances, return to the CCL and survive.Table 1 shows how length and condition of fish were used to "bin" fish in order to extrapolate monthly and annual impingement totals based on fish length.Table 1. Basis for adjusting monthly and annual estimates of impingement samples due to fish length and condition.

Fish Length Condition Assumption

> 100 mm TL Dead Natural mortality Recently dead Impingement mortality Live Impingement mortality< 100 mm TL Dead Natural mortality Recently dead Would have survived Live Would have survived Fish size and condition were subsequently used to determine if fish would have-returned to' the reservoir and survived, had the collection basket not been. in, place. After these adjustments, data from 24-ho'u`rbasket surveys served as the basis for estimates of monthly'and annual impingementmortality rates, and their impact to the CCL environment.

`T6-extrapolate monthly and annual impingement rates, the number of fish/shellfish collected over a given 24 -hour period was multiplied by the number of daysin a month. The monthly totals were summed to calculate annual totals. Because no data were available from April 2005, when the plant was down for re-fueling, the impingement rates for March and May 2005 were evaluated for use as surrogates:

the May data was ultimately used because it reflected a much higher rate of impingement, thus was conservative.

Similarly, March 2006 data were used for February 2006 extrapolation.

For annual impingement rates, only 2005. data were used to capture all four seasons and corresponding lake conditions.

9.1.2 Results 9.1.2.1 Data The following overview represents simple gross numbers observed, and is not from data adjusted for non-impingement impact considerations.

Consequently, this general review is a conservative assessment only. A total of 420 fish and 104 shellfish (crayfish and Corbicula, (Asiatic clam)) were collected in impingement samples at WCNOC over the December 2004 -March 2006 period (Table 2). Five fish species represented 93 percent of all impinged fish: freshwater drum (33 percent of fish collected), white crappie (23 percent), gizzard shad (21 percent), bluegill (11 percent), and channel catfish (6 percent).

Smaller numbers of white bass, buffalo, walleye, smallmouth bass, and flathead catfish were also collected, but none of these species comprised more than four percent of the total. Eighty-seven Corbicula and 17 crayfish were also collected over the 16-month period. Both operators of power plants and fish and game agencies regard the non-native Corbicula as a nuisance species across the U.S. This species clogs power plant cooling water systems and out-competes and displaces native freshwater mussels. Any Corbicula losses at WCGS are regarded as beneficial.

The small number of crayfish impinged (approximately one per day) is presumed to be less than the number consumed by a single, actively feeding adult smallmouth bass per day. Because all shellfish were small enough, and were considered hardy, none were considered as impacted by impingement.

Approximately 52 percent of all fish and shellfish impinged were found dead in the collection basket. Gizzard shad, a species known to be fragile and subject to winter kills (Scott and Crossman 1973; Klemesrud 2003; Schoenung 2003), showed the highest mortality rate, 63 percent. Freshwater drum also showed a fairly high rate of mortality, 58 percent. Mortality rates for bluegill, channel catfish, and white crappie were 48 percent, 46 percent, and 31 percent, respectively.

Catfish species are exceedingly hardy and able to tolerate low levels of dissolved oxygen (SRAC 1988; Smitherman and Dunham 1993; .Pennsylvania Angler &Boater 2001) so it is not surprising that they showed lower rates of mortality.-:!

9.11.2.2-Analysis For actual impact, data were adjusted by removingthe fish justified as being non-impingement related, the daily ,(actual) impingement'rates of fish in Table 3 yielded estimated monthly impingement rates ranging from 0 to 1,612.. A annual total of 957 fish and no shellfish were estimated to have died as a result of being impinged (Table 3). This corresponds to impingement mortality rates of 30.8 percent for finfish and zero percent for shellfish.

The highest rates of impingement were observed in late spring-early summer (May and June) and fall-early winter (November and December).

Water temperatures in the 30s and low 40s *F were generally associated with higher rates of impingement and impingement mortality for all fish species, but trends were less than clear-cut.

The lowest temperature observed over the 16-month period (37.5 °F in January 2005) was associated with a fairly low impingement.

Although no statistical tests were performed, there appeared to be no correlation between cooling water withdrawal rates and impingement mortality (Figure 1). Highest impingement rates were often associated with operation of two circulating water pumps; lowest impingement rates were often associated with operation of three circulating water pumps. This suggests that environmental factors influence impingement as much or more than operational factors. These environmental factors include meteorology (frontal movement, specifically air temperature, wind speed, wind direction), water quality (water temperature, dissolved oxygen levels at depth), and biology (distribution and abundance of species that are vulnerable to impingement, such as gizzard shad; overall health of the fish community; size and age composition, as smaller fish are more vulnerable, relatively, than larger fish, which are stronger swimmers).

9.2 Impingement at WCGS Relative to CCL Fishery 9.2.1 Important Species in CCL To determine the fishery's susceptibility to WCGS impingement impacts, a review of species present and those considered important for long term recreational and commercial (industrial) value is necessary.

Fish species present are common to reservoirs in Kansas (Cross and Collins 1995) and are listed in Table 4. The present fishery reflects WCNOC management efforts to biologically control impingement rates by promoting predator species. This continuing effort was undertaken to minimize impingement impact to the lake environment, and to prevent the economic and operational difficulties that could be caused by excessive impingement, particularly gizzard shad. Problem impingement on intake screens can develop because gizzard shad have difficulty avoiding intake flows when they naturally become weakened, and eventually die, as winter water temperatures fall below approximately 40 °F (Bruce NGS 1977, Ontario Hydro*1977,-Olmstead and Clugston 1986,- White et al 1986).. Predator.(game) species that are considered important at WCGS'-to control impingement include-species., that are also important for recreational purposes, These include channel catfish, white bass, wiper hybrids, smallmouth bass, largemouth bass, white crappie, and walleye (Tables 5 and 6). WCNOC's fishery management efforts revolve around eliminating excessive gizzard shad wintertime impingement events that can Greate.operational challenges to the circulating water,, screens. This effort has been successful with shad densities kept low (Table 7). Still, shad are an important forage species in CCL, and critical for the well being of predators in the lake. Reductions caused by natural predation, or other influences, such as winter die-offs or WCGS impingement, cannot be greater than the population can recover from. Extremely low shad densities would cause subsequent reduction in important predator species (Haines 2000). Consequently gizzard shad are considered an important species in CCL, and potential impacts from impingement must be balanced.

There are no listed threatened or endangered fish species known to be present in CCL, nor are any expected.

For the purpose of this evaluation, the commercially important species are considered those important for electricity production at WCGS as explained above. Species used for the commercial food market include buffalo species and common carp.However, there is currently no plans to allow commercial harvest on CCL, thus there should be no impingement impacts expected, and no further assessment will be needed. Additional details on CCL fishery can be found in WCGS's Annual Fishery Monitoring Report and Plans (WCNOC 2006).9.2.1.1 Channel Catfish As previously established, channel catfish are typically hardy, and all but one that were sampled were < 100 mm TL, and thus would have returned to CCL alive (Table 3). For assessment purposes on an annual basis (2005 data), adjusted estimates indicate no mortality attributable to WCGS. Thus, impingement impacts to the channel catfish population in CCL were considered inconsequential.

9.2.1.2 White bass White bass are common to reservoirs in Kansas, and can be highly productive (Colvin 1993). They are a pelagic (open water) species, highly mobile, and are common in the vicinity of the circulating water intake. This may tend to expose them to impingement.

This is reflected by the annual adjusted impingement estimate of 122 (Table 3), and these were all judged to be young-of-year fish.Based on annual catch frequencies, the white bass population in CCL has remained relatively consistent, with normal fluctuation (Table 7). Extrapolating total white bass densities in CCL to estimate impingement percentage was not possible due to the passive sampling gear used (gill nets). Survival rates for CCL white bass were unavailable, but average survival in regional reservoirs ranged from 21 to 52 percent and averaged 35 percent (Colvin 1993). Growth rates in CCL, as well as regionally (Colvin 1993), indicate that it would take approximately three years for white bass,to reach 12 inches (305 mm) TL, which..:.is the current minimum length for recreational harvest. Using average survivalofV:

35 percent, the 122 white bass removed from the CCL population by impingement would be 5.2 fish by the time they are available for harvest. This would be from 0.3 to 1.4 percent of the annual recreational harvest from 1999 through 2005 (Table 5). Because white bass are. highly productive, and the small, percentage of the fish made unavailable, impingement is judged to not pose a.threat to the fishery in CCL.9.2.1.3 Wiper Hybrids, Smallmouth bass, and Largemouth Bass Of the important predator species, there were no wiper hybrids or largemouth bass found in the impingement samples, and only one smallmouth bass observed, which was judged as dead before being impinged (natural mortality).

Fishery sampling by WCNOC indicates catch rates for these species to vary (Table 7). The wiper hybrids were hatchery spawned, and their densities were controlled by WCNOC stocking, which was based on shad control needs. As hybrids, they have not reproduced sufficiently to maintain a population.

Largemouth bass have experienced a long-term decline typical of aging reservoirs (Kimmel and Groeger 1986, Willis 1986). Because these species were not found in the catch basket, they are not considered to be adversely impacted by impingement.

9.2.1.4 White Crappie White crappie is the game fish species with the highest adjusted annual impingement estimate of 185 fish (Table 3). It is an important recreational species, however, because of its current creel limit of only two fish per day, it is not a species sought after for consumption.

It is a species important for WCGS, though, because gizzard shad is major forage item (Cross and Collins 1995, Muoneke et al 1992). Most of the crappies impinged were slightly greater than the 100 mm TL used for data adjustment, and were young-of-year fish. O'Brien et al (1984) determined that crappie 80 to 170 mm TL were wholly pelagic.Smaller crappies have also been more often taken in open water than along the shoreline (Grinstead as cited in Carlander 1977). WCNOC observation also indicates such small crappie distribution in CCL. This would tend to explain the higher impingement for white crappie. The fish would be in the deeper, open water similar to that adjacent to the cooling water intake, and thus more susceptible to impingement.

Annual survival rates ranged from 23 to 29 percent for three Kansas reservoirs after length limits were instituted (Mosher 2000), and 46 percent for Lake Carl Blackwell in north-central Oklahoma (Muoneke 1992).Annual survival rates for CCL have not been calculated, however, it is believed to likely be toward the higher range due to relatively larger, longer-lived crappie present. The current length limit before crappies are available for recreational harvest is 14 inches (356 mm) TL, which is restrictive.

Average growth rates for CCL crappies indicate that they typically reach the length limit at four years ofApplying the higher 46 perCent sUrvival'rate to the adjusted impinged :fish, yields reductions from 185 after year one, to 85-after year two, to 39-after year three, and to 18 after year four. Accordingly,'

impingement would cause 18 crappies to be unavailable for recreational harvest' This represents from 2.5.to 9.8 percent of crappies harvested (Table 5). As stated eadier,:restrictive creel , and.length limits suppress harvest rates for CCL crappies.

A more applicable impact comparison would be for recreational caught-and-released data, for which 18 impinged fish represents from 0.2 to 0.4 percent of the annual recreational catch (Table 6). In summary, white crappie was shown to be relatively vulnerable to impingement, and was the game species most impinged.

The relative percentage of crappie surviving to sizes available for recreational harvest was higher than other CCL species. However, due to restrictive harvest limits, these percentages may be inflated.

Percentages of the recreationally caught-and-released remained low. Consequently, impingement is not expected to adversely impact the CCL fishery, but this species may be more susceptible than other species evaluated.

9.2.1.5 Walleye Walleye is an important species both for WCGS operations and recreation.

During the entire impingement sampling period, only one was considered impinged, and this extrapolates to 30 walleye per year (Table 3). Catch curve regressions for 2003 and 2004 indicate total annual survival estimates for walleye of 41 and 17 percent, respectively.

Averaging these yields a total survival rate of 29 percent. At the current slot limit (18 to 26 inch protected) and at growth rates present in 2003 and 2004, the 30 walleye at 388 mm TL (length of impinged specimen) would remain available for recreational harvest for approximately two years. Applying the 29 percent survival estimate, reductions to the extrapolated 30 impinged walleye would be 21.3 fish the first year, and an additional 6.2 fish the second year. This means that of the 30 impinged walleye, if similar impingement, survival, and growth continued annually, estimated annual loss to the recreational fishery would be 11.2 walleye (8.7 fish remaining after first year, plus 2.5 remaining after second year). This represents

<1.0 percent of the recreationally harvest annually (Table 5), and < 0.2 percent of the walleye caught and released by anglers (Table 6). Because a passive gear type (gill nets) was used to monitor walleye in CCL, total lake population density could not be estimated, only relative catch frequency changes (Table 7). Extrapolating these numbers based on one fish impinged is not statistically defensible, but it will provide in this circumstance a relative measure to assess impacts to walleye in CCL. Because the percent removed from the population was very small, there is no impingement impacts expected to the CCL walleye.9.2.1.6 Gizzard Shad Based on adjusted impingement data, gizzard shad represented the largest number of fish impinged on an annual basis (2005 data, Table 3). An adjusted total of 496 were considered impingement mortality during the sampling period.Using 2005 data as representative of annual mortality., the adjusted impingement:, ,.-mortality was 341 gizzard shad. An estimate of thetotal gizzard shad estimate from CCL could be derived from midsummer seine hauls from 1983 through 1997: (Haines 2000). Average density estimates in CCL of similar sized shad over the 1983 through 1997 period were 3.005 million. Mortality attributable to impingement represents 0.01 percent of this average'young-of-year population estimate.

Observed length of impinged shad would tend to further reduce any potential impingement influences.

Scale aging indicate that the larger adult brood fish achieved first year growth to approximately 200 mm TL, which is above normal growth (Haines2000).

These fish were suspected to have been spawned in the heated discharge from WCGS earlier than normal, and were able to grow sufficiently to not be as susceptible to cold induced mortality (White et al 1986), were too large for predators, and not as susceptible to impingement.

All shad in the impingement samples were smaller young-of-year (approximately 100mm TL), and not as likely to survive in CCL to reach reproductive age. Thus, evidence shows that the sizes impinged would not be as likely to contribute on a long-term basis to the CCL fishery. In summary, gizzard shad is considered one of the most important species in CCL, and had the highest annual (2005)adjusted impingement rates. It was not considered impacted by impingement due to the extremely low percentage removed from the estimated population density. Shad age, growth and size distribution data also imply that the most important shad to the predator fishery were the earlier spawned fish that were able to recruit to reproductive sizes, and were not susceptible to impingement.

Therefore, impingement at CCL does not appreciably impact gizzard shad.

9.2.1.7 Other Species The remaining species were either considered as rough fish, or were infrequently found in the impingement catch basket. Consequently, these were not considered as recreationally of commercially important species as they relate to CCL and impingement.

9.3 Impingement at WCGS Compared to Similar Plants 9.3.1 V.C. Summer Station (South Carolina)VC Summer Nuclear Station (VCSNS), in South Carolina, may be the nuclear plant most similar to WCGS in terms of design and cooling system. Both plants are single-unit Westinghouse PWRs with once-through cooling systems that withdraw and discharge to small cooling reservoirs.

Coffey County Lake, at 5,090 acres, is slightly smaller than Monticello Reservoir (6,500 acres). The 316(b) Demonstration for VCSNS indicated that an estimated 85,000 fish weighing 515 kilograms were impinged annually, which amounted to less than one percent of the reservoirs standing crop (Dames & Moore 1985). Highest rates of impingement were -observed.

in -winter, when- large numbers of:-cold-..

shocked gizzard shad were ýimpinged.

More-than 80-percentof fish impinged.

-,-.:,"over the 12 months of the study (October 1983 through September 1984) were: .gizzard.

shad. Other species commonly impinged were yellow perch, white,.7 catfish, bluegill, and channel catfish. Based on these impingement rates, which.were approximately 20.times those seen at WCGS, the Dames & Moore 316(b).Demonstration concluded that "the number of fishes impinged by VCSNS appear sufficiently low so as to have minimal effect on the fish community." In April 1985, the South Carolina Department of Health and Environmental Control determined that the "location, design, construction, and capacity of the VCSNS cooling water intake structure reflects the best technology available for minimizing adverse environmental impact" (SCE&G 2002). This determination has been made a part of all NPDES permits issued since that time.9.3.2 North Anna Power Station (Virginia)

North Anna Power Station, a two-unit Westinghouse plant near Mineral, Virginia, uses a once-through condenser cooling system that withdraws from and discharges to Lake Anna, a 9,600 acre cooling reservoir.

Virginia Power conducted impingement studies over the 1978-1983 timeframe to characterize impingement and entrainment at the plant. The total number of fish in screen wash samples ranged from 11,063 (1983) to 148,995 (1979) per year, which translated into impingement estimates of 45,591 and 583,530 fish, respectively.

Sixty-one percent of fish impinged were gizzard shad, many of which were cold-stressed.

Yellow perch (15.8 percent) and black crappie (15.7 percent) were the other species impinged in significant numbers. The authors of the NAPS 316(b)demonstration observed that total impingement and entrainment rates tended to track with abundance of gizzard shad, and declined markedly as the gizzard shad became less numerous in collections.

10.0 Conclusion Impingement studies conducted at WCGS over the December 2004 -March 2006 period suggest that impingement rates were very low in both absolute (number of fish) and comparative terms (relative to other nuclear plants of similar design), as was impingement mortality.

Impingement was selective for certain species (freshwater drum, white crappie, gizzard shad) and certain size and age classes (small fish that were not aged but were presumed to be young-of-year).

More than half of fish impinged were "rough fish" that are not avidly sought by recreational fishermen.

The white crappie was the only recreationally important species impinged in significant numbers. Most recreationally important species, including smallmouth bass and walleye, were impinged in very low numbers.Available data suggests that impingement has had little or no effect on fish populations in Coffey County Lake. Coffey County Lake, with its thriving populations of channel catfish, white crappie, smallmouth bass, walleye and.wipers,',.has become a popular:.

destination-for..-Kansas .anglers.

.-Kansas: Department 7of Vildlife:

and Parks, (KDWP) issues annual Fishing Forecasts for public -waters in Kansas, which are in:.effect ratingsof public fishing areas: CoffeyCounty Lake received biologists' -rating of. Excellent for walleye. (the only. [* statereservoir to receive this ranking for walleye) and smallmouth bass (the only:,;.:

-state ý reservoir to receive this ranking for smallmouth bass): (KDWP-i 2004).'..'

Channel-catfish, white crappie, white bass, andwiper fishing wereall rated Good..Therefore, WCNOC concludes that impacts to fish and shellfish in the Coffey County Lake from impingement are SMALL and that mitigative measures are not warranted.

Figure 1 Simplified Drawing of Coffey County Lake and John Redmond Reservoir'RUXOFF & DIRRCT PRECIPITAT1O?

A DMSOAIGE$TRUCTURE.

E.VAPORATION RjWIV011DM?4 ULTIMATE REAT SM(FFFVLX~T-ILBLOWPOIN a 3EEPAGE)4v COOLING LAME -J"Hf REDM4ON RESERVOIR SYSTEM Table 2. Total number of fish in impingement sal -es.Monthly Temp Date (1) GS RCS SBF CC FC WB BG SMB WC WAE FWD C. f. CR sp. Total OF Dec-04 30 0 3 7 0 8 12 0 27 0 98 2 1 188 38.5 Jan-05 20 1 0 2 0 0 0 0 0 0 0 0 2 25 37.5 Feb-05 0 0 0 1 0 0 0 0 0 1 0 1 3 45.2 Mar-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 47.5 Apr-05 0 0 0 0 0 0 0 0 1 0 0 0 0 1 64.9 May-05 0 0 0 0 0 0 1 0 1 0 0 33 1 36 70.2 Jun-05 22 0 0 0 0 0 5 0 0 0 0 20 1 48 81.8 Jul-05 3 0 0 0 0 0 1 0 1 0 2 6 2 15 85.8 Aug-05 2 0 0 0 0 3 0 1 10 0 7 1 2 26 80.7 Sep-05 0 0 0 0 0 0 1 0 1 0 3 15 1 21 79.9 Oct-05 0 0 0 0 0 1 0 0 0 1 1 4 0 7 67.6 Nov-05 1 0 0 1 0 2 26 0 33 1 0 2 0 66 57.8 Dec-05 10 0 3 5 1 2 2 0 19. 0 19 0 4 65 40.5 Jan-06 0 0 0 3 0 0 0 0 1 0 1 3 2 10 45.1 Feb-06 0 0 0 0 0 0 0 0 0 0 0 0 0 0 42.0 Mar-06 0 0 0 5 0 1 0 0 2 .0 4 1 0 13 46.4 2005 88 1 16 24 11 17 48 1 95 2 137 87 17 524 (1) Fish species abbreviations:

Gizzard Shad River carpsucker Smallmouth buffalo Channel catfish Flathead catfish White bass Bluegill GS RCS SBF CC FC WB BG Smallmouth bass White crappie, Walleye Freshwater drum Corbicula fluminea Crayfish sp.SMB WC WAE FWD C.f.CR sp.

Table 3. Estimated monthly impingement mortality for WCGS adjusted for fish considered live and likely returned to the lake unharmed.Date (1) GS RCS SBF CC FC WB BG }SMB WC WAE FWD Cf. sp. Total Dec-04 (21 155 0 93 0 0 186 0 0 62 0 1116 0 0 1612 Jan-05 341 31 0 0 0 0 0 0 0 0 0 0 0 372 Feb-05 0 0 0 *0 0 0 0 0 0 0 0 0 0 0 Mar-05 0 0 0 0 0 0 0 0 0 0 31 0 0 31 Apr-05 0 0 0 0 0 0 0 0 31 0 0 0 0 31 May-05 0 0 0 0 0 0 0 0 31 0 0 0 0 31 Jun-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Jul-05 0 0 0 0 0 0 0. 0 0 0 0 0 0 0 Aug-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Sep-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Oct-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Nov-05 0 0 0 0 0 60 0 Q 30 30 0 0 0 120 Dec-05 0 0 31 0 0 62 31 0- 93 0 155 0 0 372 Jan-06 0 0 0 0 0 0 0 0 31 0 0 0 0 31 Feb-06 0 0 0 31 0 0 0 0 31 0 31 0 0 93 Mar-06 0 0 0 31 0 0 0 0- 31 0 31 0 0 93 L005 341 31 3110 0 3122 31 -0 185 30 16 0 0 29578 ALL 496 31 124 62 0 3081311 013401 30 113641 0 0 2786 (1) Fish species abbreviations:

Gizzard Shad River carpsucker Smallmouth buffalo Channel catfish Flathead catfish GS RCS SBF CC FC Smallmouth bass White crappie Walleye Freshwater drum Corbicula fluminea SMB WC WAE FWD C.f.White bass WB Crayfish sp. CR sp.Bluegill BG (2) All fish in impingement samples (Table 3) that were < 100 mm (TL) and were considered likely to have returned to the lake alive.

Table 4 Fish Species List for Coffey County Lake.Common Name Scientific Name Gizzard shad Dorosoma cepedianum Common carp Cyprinus carpio Golden shiner Notemigonus crysoleucas Ghost shiner Notropis buchanani Red shiner Cyprinella lutrensis Fathead minnow Pimephales promelas River carpsucker Carpiodes carpio Bigmouth buffalo Ictiobus cyprinellus Smallmouth buffalo Ictiobus bubalus Black bullhead Ameiurus melas Yellow bullhead Ameiurus nattalis Channel catfish Ictalurus punctatus Blue catfish Ictalurus furcatus Flathead catfish Pylodictis olivaris Blackstripe topminnow Fundulus notatus Mosquitofish Gambusia affinis White bass Morone chrysops Striped bass Morone saxatilis Wiper hybrid na : Brook silverside Labidesthes sicculus Green sunfish Lepomis cyanellus Longear sunfish Lepomis megalotis Orange-spotted sunfish Lepomis humilis Bluegill Lepomis macrochirus Smallmouth bass Micropterus dolomieu Largemouth bass Micropterus salmoides White crappie Pomoxis annularis Black crappie Pomoxis nigromaculatus Walleye Sander vitreum Logperch Percina caprodes Freshwater drum Aplodinotus grunniens Table 5. Selected fish snecies harvested lyaner~q n't Cnf niitv I Chan. White I Wiper Smallmouth I ] All Anglers catfish I bass hybrid .Bass ass Crappie Walleye fish 1999 9008 No. 1628#Ihour 0.03#/acre 0.32 No. 2258#/hour 0.07#/acre 0.44 2000 6865 2001 7449 No. 2779#Ihour 0.08#Nacre 0.55 4227 No. 1161#/hour 0.08#/acre 0.23>12" 1149 0.02 0.23 859 0.02 0.17 1046 0.03 0.21 378 0.02 0.07 1233 0.05 0.24 1494 0.05>24"1 7<0.01<0.01 3<0.01<0.01 12<0.01.<0.01 7<0.01<0.01.16<0.01<0.01<13" >18" 356 116 0.01 <0.01 0.07 0.02 198 20 0.01 <0.01 0.04 <0.01<13"_ >166" 126 69 0.01 <0.01 0.02 0.01 85 62<0.01 <0.01 0.02 0.01<16" >20" 364 24 0.01 <0.01 0.07 <0.01>21" 14<0.01<0.01 2002 10<0.01<0.01 4<0.01<0.01 7<0.01<0.01 1<0.01<0.01 3<0.01<0.01 6<0.01<0.01>14" 725 0.01 0.14 316 0.01 0.06 415 0.01 0.08 184 0.01 0.04 234 0.01 0.05 386 0.01 0.07 325 0.01 0.06>18" 1669 0.03 0.33 533 0.01 0.10<18" >18" 1609 36 0.05 <0.01 0.32 0.01 862 326 0.04 0.01 0.17 0.06<18"9 >26" 1244 26 0.05 <0.01 0.24 <0.01 2327 7 0.08 <0.01 0.46 <0.01 2441 8 0.08 <0.01 0.48 <0.01 6007 0.13 1.15 4366 1.13 1.35 6291 0.18 1.23 3841 0.18 0.83 5638 0.49 0.93 7662 0.25 1.51 6981 0.24 1.37 2003 4751 No. 2457#1hour 0.10#Nacre 0.48 2004 5674 No. 2989#/hour 0.10#Iacre 0.59 5287 No. 2541#1hour 0.09#Nacre 0.50 18.<0.01 371 0.01 0 0 0 2005 0.29 1281 0.04 0.25<0.01 1 0.07 8<0.01<0.01 303 10 0.01 <1.01 0.06 <0.01 I 0.25 I 1.37 Table 6.Selected fish sDecies cauaht and released by anglers at Coffey County Lake.# Chan. White Wiper -Smallmouth All Anglers catfish bass hybrid Bass LM Bass Crappie Walleye fish 1999 9008 No. 6928 15,171 3503 17,482 3885 7382 31,027 86,464#/hour 0.15 0.32 0.07 0.37 0.08 0.15 0.65 1.82#/acre 1.36 2.98 0.69 3.43 0.76 1.45 6.10 16.99 2000 6865 No. 5191 7838 2267 12,579 4918 5536 21,599 61,102#/hour 0.15 0.23 0.07 0.36 0.14 0.16 0.63 1.77#/acre 1.02 1.54 0.45 2.47 0.97 1.09 4.24 12.00 2001 7449 No. 5623 8777 1810 10,136 4736 7457 20,911 60,417#/hour 0.16 0.25 0.05 0.28 0.13 0.21 0.59 1.70#/acre 1.10 1.72 0.35 1.99 0.93 1.47 4.11 11.87 2002 4227 No. 3949 3623 1649 .8097. 874 4563 11,785 31,807#/hour 0.19 0.17 0.08 0.38 0.04 .0.22 0.56 1.65#/acre 0.77 0.71 0.32 1.59 0.17 0.90 2.31 6.84 2003 4751 No. 6057 8489 6838 8527 3193 5739 6740 45,895#/hour 0.25 0.34 0.27 0.35 0.13 0.23 0.27 1.86#/acre 1.19 1.67 1.34 1.67 0,63 1.13 1.32 *9.02 2004 5674 No. 7175 6748 4553 8989 3096 6386 10,016 47,229#/hour 0.23 0.22 0.15 0.29 0.10 0,21 0.33 1.55#Iacre 1.41 1.33 0.89 1.77 0.61 1.25 1.97 9.28 2005 5287 No. 10,619 8048 2683 7785 1420 4370 9457 44,629#/hour 0.37 0.28 0.09 0.27. 0.05 0.15 0.33 1.54#/acre 2.09 1.58 0.53 1.53 0.28 0.86 1.86 8.77 Table 7. Catch-per-unit-of-effort (CPUE) of selected fish species in Wolf Creek Lake. Fall gill net, Fyke net, and electrofishinci data were not collected in 2001 due to the September 11 events.Gizzard Gizzard Smallmouth Largemouth White Shad Shad (YOY) White bass -Wiper Bass Bass Crappie Walleye 1983 (1) T (1) 23 (1) 15 (2) 24.5 (3) 0 (1) 4 1984 25 18 11 45.0 6 29 1985 3 6 22 45.3 5 26 1986 32 25 14 (2) 1.3 34.5 5 9 1987 10 18 21 8.5 18.8 12 16 1988 12 28 26 10.5 22.0 9 19 1989 18 17 23 14.8 32.3 4 22 1990 10 34 12 12.0 14.0 5 13 1991 14 45 22 20.5 5.5 4 19 1992 19 17 9 10.8 8.3 6 22 1993 11 52 8 15.0 5.0 5 12 1994 9 61 11 12.5 2.0 4 23 1995 25 29 11 .6.3 2.0 5 16 1996 9 (4)22.9 19 3 10.8 0.3 9 20 1997 19 77.0 60 8 5.5 1.3 4 28 1998 18 39.9 45 6 10.5 1.5 3 16 1999 15 9.9 37 4 11 3.3 6 14 2000 18 29.4 36 13 21.5 3.0 (5) 9 28 2001 -----2.0 -2002 11 3.5 32 4 2.0 1.0 6 8 2003 10 1.9 54 9 8.0 2.0 7 14 2004 12 5.5 33 6 34 0.8 -20 2005 11 0.3 37 4 16 0.0 13 9 (1) Data from fall standard gill netting. Units equal number per gill-net-complement-night

> stock size.(2) Data from spring electrofishing.

Units equal number per hour shocked > stock size. Shocking efforts starting in 2004 targeted prime habitats rather than standard locations as completed during prior years.(3) Data from spring Fyke netting. Units equal number per trap-net-night

> stock size.(4) Data from smalimesh gill net. Units equal number per net complement of one 0.5 and one 0.75 mesh net.(5) Data beginning in 2000 were from fall Fyke netting. Netting not Completed during 2004 due to adverse weather. Units equal number per trap-net-night

> stock size.

110. IO0 BG 0-.)70 60..O,. 0'.~CF.D. 'Pr,4 g 'a01 13 W * ,~r br- m- tW F*b Mv ApiMS~ "bu A" AM Aog8 *SIW ~OSN *0.0 DN4 ObWN MOON 11.0 Literature Cited Bruce Nuclear Generating Station. 1977. Fish Impingement at Bruce Nuclear Generating Station. Ontario Hydro Electric Company. 26 pp.Carlander, K. D. 1977. Handbook of Freshwater Fishery Biology Volume Two. The Iowa State University Press, Ames, Iowa.Colvin, M. A. 1993. Ecology and management of white bass: a literature review.Missouri Department of Conservation, Dingell-Johnson project F-1-R-42, Study I-31, Job 1, Final Report.Cross, F. B. and J. T. Collins. 1995. Fishes In Kansas. second edition. University of Kansas Natural History Museum. 315 pp.Dames & Moore. 1985. 316(b) Demonstration for the Virgil C. Summer Nuclear Station.Prepared for South Carolina Electric & Gas Company by Dames & Moore, Atlanta, Georgia. March.Edwards, T. J. , W. H. Hunt, L.E. Miller and J. J. Sevic. 1976. An Evaluation of the Impingement of Fishes at Four Duke Power Company Steam-Generating Facilities.

In Thermal Ecology II. Esch, G. W. and R. W. McFarlane, Editors. Technical Information Center of Energy Research and Development Administration.

Pp 373-380.Federal register.

July 9, 2004. 40 CFR Parts 9, 122et al. National Pollutant Discharge Elimination System -Final Regulations to Establish Requirements for Cooling Water Intake Structures at Phase II Existing Facilities; Final Rule.Haines, D. E. 2000. Biological control of gizzard shad impingement at a nuclear power plant. Environmental Science & Policy 3: S257-S281.

Kansas Department of Health and Environment.

1975 Letter dated February 21, 1975 to M. Miller, Kansas Gas and electric Company.Kansas Gas and Electric Company. 1975. Letter KLKAN-039 form M. E. Miller (KGE) to M. Gray of Kansas Department of Health and Environment.

KDWP (Kansas Dept. of Wildlife and Parks). 2004. Kansas Fishing Forecast.Kimmel, B. L. and A. W. Groeger. 1986. Limnological and Ecological Changes Associated with Reservoir Aging. Pages 103-109 in G. E. Hall and M. J Van Den Avyle, Editors. Reservoir Fisheries Management:

Strategies for the 80's.Reservoir Committee, Southern Division American Fisheries Society.Klemesrud, M. 2003. "Winter stress is causing gizzard shad to die. " From Iowa Outdoors, a publication of Iowa Department of Natural Resources.

http://www.iowadnr.com/news/io/03feb25io.pdf.

Mosher, T. D. 2000. Assessment of a 254-mm Minimum Length Limit for Crappie in Three Northeastern Kansas Reservoirs Final Report. Kansas Department of Wildlife and Parks. Federal Aid Project No. FW-9-12 and F-30-R-1.Muoneke, M. I., C. C. Henry, and 0. E. Maughan. 1992. Population structure and-food habits of white crappie Pomoxis annualris Rafinesque in a turbid Oklahoma reservoir.

Journal of Fish Biology. Volume 1 Page 647 -October.O'Brien W. J., B. Loveless, and D. Wright. 1984. Feeding Ecology of Young White Crappie in a Kansas Reservoir.

North American Journal of Fisheries Management; 4: p 341-349.Olmstead, L.L. and J.P. Clugston.

1986. Fishery Management in Cooling Impoundments in Reservoir Fisheries Management:

Strategies for the 80's. G.Hall and M. Van Den Avyle, Editors. American Fisheries Society. Bethesda, MD.327 pp.Ontario Hydro. 1977. Winter studies of gizzard shad at Lambto GS-1976-77.

Ontario Hydro Research Division Report. No. 77-400-K.

47pp.Pennsylvania Angler & Boater. 2001. "The Basics of Water Pollution in Pennsylvania." http://www.fish.state.pa.us/anglerboater/2001/jf2001

/wpollbas.htm.

Pennsylvania.

Angler & Boater Magazine.. (online), a publication of the Pennsylvania Fish & Boat.Commission.

Schoenung, B. 2003. Fish and Wildlife Research and Management Notes. Indiana Department of Natural Resources, Division of Fish and Wildlife.

Available online at http://www.state.in.us/dnr/fishwild/publications/notes/boggs.htm.

Scott, W.B., and E. J. Crossman.

1973. Freshwater Fishes of Canada. Bulletin 184, Fisheries Research Board of Canada. Ottawa.Smitherman, R.O., and R. A. Dunham. 1993. Relationships Among Cultured and Naturally Occurring Populations of Freshwater Catfish in the United States. In (Collie and McVey, Eds) Proceedings of the Twenty-Second U.S.-Japan Aquaculture Panel Symposium, August 21-22, 1993, Homer, Alaska.South Carolina Electric & Gas Company. 2002. Appendix E -Applicant's Environmental Report, Operating License Renewal Stage, Virgil C. Summer Nuclear Station. August.United States Environmental Protection Agency (EPA). 2006. Letter dated November 22, 2006, from J. Dunn (EPA) to J. Werner (KCPL)United States Environmental Protection Agency (EPA). 2006. Letter dated November 27, 2006, from J. Dunn (EPA) to S. Williams (IDNA)United States Nuclear Regulatory Commission (NRC). 1975. Final Environmental Statement (FES) for Wolf Creek Generating Station. NUREG-75/096 Virginia Power. 1985. Impingement and Entrainment Studies for North Anna Power Station, 1978-1983.

Prepared by Virginia Power Water Quality Department, Richmond.WCNOC. 2006. 2005 Fishery Monitoring Report and 2006 Plan. Internal documents.

Wellborn, T. L. 1988. Channel Catfish: Life History and Biology. Southern Regional Aquaculture Center, Texas A&M University, College. Station, Texas. SRAC Publication No. 180.White, Andrew M., F. D. Moore, N. A. Alidridge, and D. M. Loucks. 1986. The Effects of Natural Winter Stresses on the Mortality of the Eastern Gizzard Shad, Dorosoma cepedianum, in Lake Erie. Environmental Resource Associates, Inc. and John Carrol University, for The Cleveland Electric Illuminating Company and The Ohio Edison Company. 208 pp.Willis, D. W. 1986. Review of Water Level Management on Kansas Reservoirs.

Pages 110-114 in G. E. Hall and M. J Van Den Avyle, Editors. Reservoir Fisheries Management:

Strategies for the 80's. Reservoir Committee, Southern Division American Fisheries Society.

APPENDIX A Raw Impingement Data Raw lImpingement Collection Data Impingement Data L = Live RD = Recently Dead D = Dead Date: 12/19/2004 Wash Time: 1800 Temp: 38.5F White Crappie Length Status 92 RD 62 RD 90 RD 100 RD 91 RD 107 RD Freshwater Drum Length Status 111 RD.89 RD 119 .L 125 RD 124 RD 117 D 136 RD 94 RD 118 RD 114 D 149 RD.75 D 146 RD 142 D 129 RD 92 D 99 RD 119 D 116 RD 129 RD 82 RD 134 L 113 RD 130 RD 109 RD 69 RD 75 RD 57 D Channel Lengtt.83 Cat I Status L Bluegill Length 56 Status RD Crayfish Length 83 Status L Corbicula Quanity Status 2 L Raw Impingement Collection Data Date: 12/20/2004 Wash Time: 445 Temp: 38.5F White Crappie Length Status 80 D 98 RD 76 RD 79 RD 81 RD Freshwater Drum Length Status 147 RD 119 D 89 D 82 D 445 D 90 D 112 RD 101 RD 110 D 109 D 115 D 93 D 115 D 110 D 106 D 114 D 112 D 131 D 132 RD 126 RD 121 D 96 D 102 D 103 D 111 RD 102 D 115 RD 125 RD Channel Cat Length Status 84 RD 79 D Bluegill Length 50 Status 0 Gizzard Shad Length Status.125 D Buffalo Length Status 145 RD 115 RD White Bass Length Status 253 RD 202 RD 195 RD 73 RD Raw Impingement Collection Data Date: 12/20/2004 Wash Time: 1300 Temp: 38.5F White Crappie Length Status 205 RD 99 D.106 D 83 D 90 RD 85 RD.86 RD 93 RD 85 RD 86 RD 101 RD 83 RD 87 RD 81 RD 55 RD 58 RD Freshwater Drum Length Status 123 RD 109 D 99 D 140 L 116 D 132 RD 107 D 123 RD 143 RD 115 D 114 D 141 D 142 D 142 RD 169 D 116 RD 113 D 118 D 115 D 121 D 115 D 103 D 114 D 113 RD 96 RD 107 D 130 RD 109 D 95 D 103 D 110 RD Channel Cat Length Status 95 D 78 RD 86 RD 90 RD Bluegill Length 51 56 59 51 94 60 61 51 56 51 Status RD RD RD D RD RD RD RD D RD White Bass Length Status 223 RD 121 RD 111 D 103 RD Gizzard Shad Length Status 96 D 109 D 91 RD 104 D 100 D 95 D 103 RD 113 D 79 D 96 D 93 D 82 D 95 D 101 D 122 RD 109 D 104 RD 101 D 99 D 104 D 96 RD 93 RD Buffalo Length Status 142 RD 107 94 99 103 112 92 97 RD D RD D RD D RD Raw Impingement Collection Data Date: 12/20/2004 Wash Time: 1300 (Cont.) Temp: 38.5F Freshwater Drum Length Status 91 D 119 D 109 D 115 RD 105 D 119 D 121 RD 109 D 126 D 124 D 123 RD Impingement Data L = Live RD = Recently Dead D = Dead Date: 01/30/2005 Wash Time: 1330 Temp: 37.5F Gizzard Shad Length Status 109 RD 113 D 107 RD 109 RD 104 RD 108 D 108 RD Date: 01/30/2005 Wash Time: 2200 Temp: 37.5F Gizzard Shad Length Status 101 D 107 RD 109 D 102 RD 105 RD 97 D 108 RD Date: 01/31/2005 Wash Time: 600 Temp: 37.5F Gizzard Shad Length Status 95 RD 383 D 91 RD 104 RD 100 D 102 RD River Carp Sucker Length Status 318 RD Channel Cat Length Status 78 RD 81 RD Crayfish Length Status 84 107 L L Impingement Data Date: 02/20/2005 No fish in basket Date: 02/20/2005 No fish in basket.Date: 02/21/2005 Freshwater Drum Length Status 112 D L =Live , RD = Recently Dead D = Dead Wash Time: Wash Time: Wash Time: Channel Cat Length 89 1030-1830 1830-0230 230-1030 Status L Temp: 45.2F Temp: 45.2F Temp: 45.2F Crayfish Length Status 72 L Impingement Data Date: 03/13/2005 No fish in basket Date: 03/13/2005 Freshwater Drum Length Status 122 RD Date: 03/14/2005 No fish in basket L = Live RD = Recently.Dead D = Dead Wash Time: 1050-1850 Wash Time: 1850-0250 Wash Time: 0250-1050 Temp: 47.5F Temp: 47.5F Temp: 47.5F Impingement Data Date: 04/17/2005 Wash Time: Plant Shutdown -Circulating Water System Out of Service L = Live RD = Recently Dead Temp: 64.9F D = Dead Impingement Data Date: 05/12/2005 Bluegill Length Status 59 D L = Live RD = Recently Dead D = Dead Wash Time: 1130-1930 Wash Time: 1930-0730 Temp: 21.2 C Date: Crayfish Length 86 05/12/2005 Temp: 21.4 C Status L Date: 05/13/2005 White Crappie Length Status 110 RD Wash Time: 0730-1000 Corbicula Number Status 10 L 23 D Temp: 20.3 C Impingement Data L = Live RD = Recently Dead D = Dead Date: 06/26/2005 Wash Time: 1100-1900 Temp: 81.8F Gizzard Shad Length Status 70 RD 59 RD 39 D 50 D 55 RD 46 D.44 D 38 D Date: 06126/2005 Gizzard Shad Length Status 50 D 50 D 45 D 40 D 44 RD 40 RD 40 D 40 RD 40 RD 40 RD 47 D 50 D Wash Time: 1900-0300 Temp: 81.8F Crayfish Length 55 Status D Date: 06/27/2005 Gizzard Shad Length Status 46 D 46 D Wash Time: 0300-1100 Temp: 81.8F Bluegill Length 42 50 41 43 41 Status D D RD D RD Corbicula Number.20 Status D Impingement Data Date: 07/24/2005 L = Live RD = Recently Dead D = Dead Wash Time: 1000-1900 Temp: 85.8F No fish in basket Date: 07124/2005 Wash Time: 1900-0300 Temp: 85.8F Gizzard Shad Length Status 69 RD Bluegill Length 68 Status D Crayfish Length 70 Corbicula Number Status Status RD I L Date: 07/25/2005 Wash Time: 0300-1000 Temp: 85.8F Gizzard Shad Length Status 56 D 54 D Crayfish Length 75 Status L Corbicula Number 2 3 Status L D Freshwater Drum Length Status 297 D 46 RD White Crappie Length Status 59 D Impingement Data Date: 08120/2005 Gizzard Shad Length Status 75 D L = Live RD = Recently Dead D = Dead Wash Time: 1030-1830 White Crappie Length Status 71 D Temp: 80.7F Corbicula Number Status 1 L 50 69 68 D D D Date: 08/20/2005 White Crappie Length Status 66 RD Wash Time: 1830-0230 Temp: 80.7F Freshwater Drum Length Status 56 RD 68 RD 60 RD 180 D Small Mouth Bass Length Status 69 D White Bass Length Status 61 D Date: 08/21/2005 Gizzard Shad Length Status 62 D Wash Time: 0230-1030 Temp: 80.7F White Crappie Length Status 65 D 59 D 61 RD 67 RD 65 RD Freshwater Drum Length Status 43 D 85 RD White Bass Length Status 75 D 51 D Crayfish Length Status 89 L 85 D 41 D Impingement Data Date: 09/10/2005 Crayfish Length Status 68 L L = Live RD = Recently Dead D = Dead Wash Time: 0930-1730 Temp: 79.9F Corbicula Number Status 1 1 L D Date: 0911012005 Freshwater Drum Length Status 60 D 301 D Date: 09111/2005 Freshwater Drum Length Status 84 RD Wash Time: 1730-0130 Temp: 79.9F Corbicula Number Status 6 1 L D Wash Time: 0130-0930 Temp: 79.9F White Crappie Length Status 47 D Bluegill Length Status 88 D Corbicula Number Status 3 L 3 D Impingement Data L = Live RD = Recently Dead D = Dead Date: Corbicula Quantity 1 Date: Corbicula Quantity 1 10107/2005 Status D 10/0712005 Wash Time: 1030-1830 Temp: 67.6F Wash Time: 1830-0230 Temp: 67.6F Status D Date: 10108/2005 Corbicula Quantity 2 Wash Time: 0230-1030 Walleye Length(mm)

Status 460 D Status D Freshwater Drum Length(mm)

Status 280 D Temp: 67.6F White Bass Length(mm)

.100 Status D Impingement Data L = Live RD = Recently Dead Temp: 57.8F D = Dead Date: 11112/2005 Wash Time: 1000-1800 Crayfish Length 71 Status L Corbicula Quantity 1.5 Status D White Crappie Length Status 93 D 52 D 53 D Date: 1111312005 Wash Time: 1800-0200 Temp: 57.8F Bluegill Length 29 58 64 51 52 50 44 60 56 55 50 Status RD D D RD D D D RD RD RD RD Channel Cat Length 56 Status D White Crappie Length Status 91 RD 93 RD 95 RD 91 D 91 RD 86 RD 87 RD 87 RD 92 91 94 90 74 RD RD RD RD RD Date: 1111312005 Wash Time: 0200-1000 Temp: 57.81F Bluegill Length 53ý48 48 56 55 54 46 59 58 54 49 46 56 47 Head only Status RD D RD RD D D RD RD RD D D D RD D D Gizzard Shad Length 122 Status RD White Crappie Length Status 101 RD 97 RD 79 RD 92 RD 89 RD 76 RD 95 RD 86 RD 88 RD 93 RD 96 RD 100 RD 94 RD 92 RD 90 RD 87 RD 91 RD White Bass Length 105 209 Corbicula Quantity 1 Status RD RD Status D Walleye Length 388 Status RD Impingement Data L = Live RD = Recently Dead D = Dead Date: 12119/2005 Wash Time: 1000-1800 Temp: 40.5F Freshwater Drum Length Status 172 D 179 D 99 D 104 D 101 RD 85 D 95 RD 90 D Crayfish Length 90 109 99 104 Status L D L D White Crappie Length Status 330 RD 220 L 92 RD 59 D Gizzard Shad Length Status 110 D 108 D 105 D 107 D 104 D 107 D 109 D White Bass Length Status 169 D Buffalo Length Status.125 RD Date: 12/20/2005 Wash Time: 1800-0200 Temp: 40.5F Freshwater Drum Length Status 350 RD 179 RD 158 RD 101 D 111 D 95 D 77 D 96 D 81 D Channel Catfish Length Status 85 D 86 D 110 D Flathead Catfish Length Status 102 D White Crappie Length Status 100 D 90 D.81 RD 98 D 107 RD 61 D 84 RD 90 D 96 D 96 D 96 D 39 D 91 D.98 D Gizzard Shad Length Status 102 D Buffalo Length Status 535 D 173 D White Bass Length Status 168 RD Bluegill Length Status 98 D Date: 12/2012005 Wash Time: 0200-1000 Temp: 40.5F Freshwater Drum Length Status 103 RD 91 D Channel Catfish Length Status 96 D half D White Crappie Length Status 94 RD Gizzard Shad Length Status 116 D 113 D Bluegill Length 162 Status RD Impingement Data L = Live RD = Recently Dead D = Dead Date: 01/1612006 Wash Time: 1020-1820 Temp: 45.1F Channel Catfish Length Status 57 D Corbicula Quantity 1 1 Status L D White Crappie Length 206 Status RD Date: 0111712006 Wash Time: 1820-0220 Temp: 45.1F No fish in basket Date: 01117/2006 Wash Time: 0220-1020 Temp: 45.1F Channel Catfish Length Status 76 D 80 D Corbicula Quantity 1 Status L Freshwater Drum Length Status 90 D Crayfish Length 130 85 Status L L Impingement Data Status L=Live RD=Recently Dead D=Dead Date: 03104/2006 Wash Time: 1030-1830 Temp: 46.4 White Crappie Length(mm) 330 Status L White Bass Length(mm) 188 Status RD Date: 03/0412006 Wash Time: 1830-230 Freshwater Drum Length(mm) 346 72 Status L D Channel Catfish Length(mm) 97 86 Temp: 46.4 Corbicula Quantity I Status L RD Status D Date: 03/05/2006 Wash Time: 230-1030 Freshwater Drum Length(mm) 114 97 Status D RD Channel Catfish Length(mm) 113 94 95 Temp: 46.4 White Crappie Length(mm) 216 Status L L RD Status D Dead, Recently Dead and Living Impingement Sample Data Sample 12-19 to 12-20-2004 Drum Dead Recently Dead Living Total Impinged 55 40 3 98 Channel Cat Dead Recently Dead Living 2 4 1 7 White Crappie Dead Recently Dead Living 4 23 0 27 Bluegill Dead Recently Dead Living Gizzard Shad 3 Dead 9 Recenly Dead 0 Living 20 10 0 30 12 Sample 01-30 to 01-31-2005 Drum Dead Recently Dead Living Total Impinged 0 0 0 0 Channel Cat Dead Recently Dead Living 0 2 0 2 White Crappie Dead Recently Dead Living 0 0 0 Bluegill Dead Recently Dead Living 0 0 0 0 Gizzard Shad Dead Recenly Dead Living 7 13 0 20 0 Sample 02-20 to 02-21-2005 Drum Dead Recently Dead Living Channel Cat 1 Dead 0 Recently Dead 0 Living 0 0 1 White CrappDe Dead Recently Dead Living 0 0 0 Bluegilll Dead Recently Dead Living 0 0 0 Gizzard Shad Dead Recenly Dead Living 0 0 0 Total Impinged I ToalImined I1 000 0 0 Dead, Recently Dead and Living Impingement Sample Data Sample 12-19 to 12-20-2004 Buffalo Dead Recently Dead Living Total Impinged 0 3 0 3 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 0 0 1 Corbicula Dead Recently Dead Living 0 0 2 2 Small Mouth Bass Dead Recently Dead Living 0 0 0 1 0 Sample 1-30 to 1-31-2005 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 1 0 Crayfish Dead Recently Dead Living 0 0 2 2 Corbicula Dead Recently Dead Living 0 0 0 0 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Sample 2-20 to 2-21-2005 I Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 Crayfish Dead Recently Dead Living 0 0 1 Corbicula Dead Recently Dead Living 0 0 0 Small Mouth Bass Dead Recently Dead Living 0 0 0 Total Impinged 0 Total Imige: 1 01 0 0 Dead, Recently Dead and Living Impingement Sample Data Sample 12-19 to 12-20-2004 White Bass Dead Recently Dead Living Total Impinged 1 7 0 8 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 1-30 to 1-31-2005 White Bass Dead Recently Dead Living Total Impinged 0 0 0 0 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 2-20 to 2-21-2005 White Bass Dead.Recently Dead Living 0 0 0 Walleye Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Dead, Recently Dead and Living Impingement Sample Data Sample 03-13 to 03-14-2005 Drum Dead Recently Dead Living Total Impinged 0 1 0 Channel Cat Dead Recently Dead Living 0 0 0 0 White Crapple Dead Recently Dead Living 0 0 0 0 Bluegill Dead Recently Dead Living Gizzard Shad 0 Dead 0 Recenly Dead 0 Living 0 0 0, 0 1 0 Sample 04117 to 04-18-2005 Plant Shutdown -Circ Water Out of Service Sample 05-12 to 05-13-2005 Drum Dead Recently Dead Living Total Impinged 0 0 0 0 Channel Cat Dead Recently Dead Living 0 0 0 0 White Crappie Dead Recently Dead Living 0 1 0* Bluegill Dead Recently Dead Living Gizzard Shad 1 Dead 0 Recenly Dead 0 Living 0 0 0 0 1 I Sample 06-26 to 06-27-2005 Drum Dead Recently Dead Living Channel Cat 0 Dead 0 Recently Dead 0 Living 0 0 0 White Crappie Dead Recently Dead Living 0 0 0 Blueaill Dead Recently Dead Living Gizzard Shad 3 Dead 2 Recenly Dead 0 Living 14 8 0 Total Impinged 0 0 0 5 22 Dead, Recently Dead and Living Impingement Sample Data Sample 3-13 to 3-14-2005 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 0 0 0 0 Corbicula Dead Recently Dead Living 0 0 0 0 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Sample 4117 to 4-18-2005 Plant Shutdown -Circ Water Out of Service Sample 5-12 to 5-13-2005 Buffalo Dead Recently Dead Living Total Impinged 0 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 0 0 1 Corbicula Dead Recently Dead Living 23 0 10 33 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 I Sample 6-26 to 6-27-2005 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 Crayfish Dead Recently Dead Living 1 0 0 Corbicula Dead Recently Dead Living 20 0 0 Small Mouth Bass Dead Recently Dead Living 0 0 0 Total Impinged 0 0 1 20 0 Dead, Recently Dead and Living Impingement Sample Data Sample 3-13 to 3-14-2005 White Bass Dead Recently Dead Living Total Impinged 0 0 0 0 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 4117 to 4-18-2005 Plant Shutdown -Circ Water Out of Service Sample 5-12 to 5-13-2005 White Bass Dead Recently Dead Living Total Impinged 0 0 0 0 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0~0 Sample 6-26 to 6-27-2005 White Bass Dead Recently Dead Living 0 0 0 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Dead, Recently Dead and Living Impingement Sample Data Sample 07-24 to 07-25-2005 Drum Dead Recently Dead.Living Total Impinged Channel Cat I Dead 1 Recently Dead 0 Living 0 0 0 0 White Crapple Dead Recently Dead Living 1 0 0 1 Blusai~l Dead Recently Dead Living 1 0 0 Gizzard Shad Dead Recenly Dead Living 2 1 0 3 2 I Sample 08-20 to 08-21-2005 Drum Dead Recently Dead Living Total Impinged 3 4 0 7 Channel Cat Dead Recently Dead Living 0 0 0 0 White Crapple Dead Recently Dead Living 6 4 0 Bluegill Dead Recently Dead Living 0 0 0 0 Gizzard Shad Dead Recenly Dead Living 2 0 0 2 10 Sample 09-10 to 09-11-2005 Drum Dead Recently Dead Living Total Impinged Channel Cat 2. Dead 1 Recently Dead 0 Living 0 0 0 0 White Crapple Dead Recently Dead Living 1 0 0 I Blueoill Dead Recently Dead Living 1 0 0 Gizzard Shad Dead Recenly Dead Living 0 0 0 0 3 I Dead, Recently Dead and Living Impingement Sample Data Sample 7-24 to 7-25-2005 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living Corbicula Dead Recently Dead Living I 1 3 0 3 6 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Sample 8-20 to 8-21-2005 2 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 1 0 1 2 Corbicula Dead Recently Dead Living 0 0 1 Small Mouth Bass Dead Recently Dead Living I 0 0 1 Total Impinged 0 Sample 9-10 to 9-11-2005 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 Crayfish Dead Recently Dead Living 0 0 1 Corbicula Dead Recently Dead Living 5 0 10 Small Mouth Bass Dead Recently Dead Living 0 0 0 Total Impinged 0 0 1 Totl mpige 0 115 0 Dead, Recently Dead and Living Impingement Sample Data Sample 7-24 to 7-25-2005 White Bass Dead Recently Dead Living Total Impinged 0 0 0 0 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 8-20 to 8-21-2005 White Bass Dead Recently Dead Living Total Impinged 3 0 0 3 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 9-10 to 9-11-2005 White Bass Dead Recently Dead Living 0 0 0 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Dead, Recently Dead and Living Impingement Sample Data Sample 10-07 to 10-08-2005 Drum Dead Recently Dead Living Total Impinged Channel Cat 1 Dead 0 Recently Dead 0 Living 0 0 0 0 White Crapple Dead Recently Dead Living 0 0 0 0 Bluegill Dead Recently Dead Living Gizzard Shad 0 Dead 0 Recenly Dead 0 Living 0 0 0 0 I 0 Sample 11-12 to 11-13-2005 Drum Dead Recently Dead Living Total Impinged 0 0 0 0 Channel Cat Dead Recently Dead Living I 0 0 1 White Crappie Dead Recently Dead Living 4 29 0 33 Bluegill Dead Recently Dead Living Gizzard Shad 13 Dead 13 Recenly Dead 0 Living 0 1 0 0 I Sample 12-19 to 12-20-2005 Drum Dead Recently Dead Living 13 6 0 Channel Cat Dead Recently Dead Living 5 0 0 White Crappie Dead Recently Dead Living 12 6 1 Bluegill Dead Recently Dead Living 0 1 0 Gizzard Shad Dead Recenly Dead Living 10 0 0 Total Impinged 19 ToalImined 195 19 21 2 10 Dead, Recently Dead and Living Impingement Sample Data Sample 10-07 to 10-08-2005 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 0 0 0 0 Corbicula Dead Recently Dead Living 4 0 0 4 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Sample 11-12 to 11-13-2005 Buffalo Dead Recently Dead Living Total Impinged 0 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 0 0 0 Corbicula Dead Recently Dead Living 2 0 0 2 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 0.Sample 12-19 to 12-20-2005 Buffalo Dead Recently Dead Living 2 1 0 River Carpsucker Dead Recently Dead Living 0 0 0 Crayfish Dead Recently Dead Living 2 0 2 Corbicula Dead Recently Dead Living 0 0 0 Small Mouth Bass Dead Recently Dead Living 0 0 0 Total Impinged 3 0 4 Totl mpige 3 40 0 Dead, Recently Dead and Living Impingement Sample Data Sample 10-07 to 10-08-2005 White Bass Dead Recently Dead Living Total Impinged 1 0 0 Walleve Dead Recently Dead Living 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 1 1 Sample 11-12 to 11-13-2005 White Bass Dead Recently Dead Living Total Impinged 0 2 0 2 Walleve Dead Recently Dead Living 0 1 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 I Sample 12-19 to 12-20-2005 White Bass Dead Recently Dead Living Walleve 1 Dead I Recently Dead 0 Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 1 0 0 1 Total Impinged 2 Dead, Recently Dead and Living Impingement Sample Data.Sample 01-16 to 01 2006 Drum Dead Recently Dead Living Total Impinged 1 0 0 Channel Cat Dead Recently Dead Living 3 0 0 3 White Crappie Dead Recently Dead Living 0 1 0 1 Bluenill Dead Recently Dead Living 0 0 0 Gizzard Shad Dead Recenly Dead Living 0 0 0 0 I 0 Sample 02-XX to 02-XX-2006 Unable to Collect Samples Sample 03-04 to 03-05-2006 Drum Dead Recently Dead Living Channel Cat 2, Dead 1 Recently Dead 1 Living 0 2 3 White Crapple Dead Recently Dead Living 1 0 1 B3luegill Dead Recently Dead Living 0 0 0 Gizzard Shad Dead Recenly Dead Living 0 0 0 Total Impinged 4 5 2 0 0 Dead, Recently Dead and Living Impingement Sample Data Sample 01-16 to 01 2006 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 0 0 2 2 Corbicula Dead Recently Dead Living 1 0 2 3 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Sample 02-XX to 02-XX-2006 Unable to Collect Samples Sample 03-04 to 03-05-2006 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 Crayfish Dead Recently Dead Living 0 0 0 Coibicula Dead Recently Dead Living 1 0 0 Small Mouth Bass Dead Recently Dead Living 0 0 0 Total Impinged 0 0 0 Totl mpige 0 01 0 Dead, Recently Dead and Living Impingement Sample Data Sample 01-16 to 01 2006 White Bass Walleve Dead 0 Dead Recently Dead 0 Recently Dead Living 0 Living Total Impinged 0 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 02-XX to 02-XX-2006 Unable to Collect Samples Sample 03-04 to 03-05-2006 White Bass Walleve Dead 0 Dead Recently Dead 1 Recently Dead Living 0 Living Total Impinged I 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 APPENDIX B Coffey County Lake 2005 Fishery Monitoring Report and 2006 Plan AK T WOLF CREEK GENERATING STATION Wolf Creek Lake 2005 FISHERY MONITORING REPORT AND 2006 PLAN Prepared by: Supervisor Regulatory Support Approval: Manager Regulatory Affairs Approval: 2/16/06 Dan Haines Date 02/ 17/ 06 Robert Hammond Date evnMolese02/21/06 Kevin Moles Date EXECUTIVE

SUMMARY

Monitoring during 2005 demonstrated that the fishery in Wolf Creek Lake remained in good condition with no adverse trends identified.

Fish predation pressure on the gizzard shad population continued to prevent excessive shad impingement problems at the circulating water intake. Fishery monitoring activities in 2006 as outlined in this report will continue to measure long-term trends and help Wolf Creek Generating Station prepare for any short term changes, particularly for any changes in the potential for shad impingement events.Public angling on the lake did not impact the fishery's function of supporting plant operations.

The catch and release philosophy promoted when the lake was opened for the public has been compatible with gizzard shad control objectives.

Monitoring data from 2004 warranted management activities to improve the fishery for public use. The following were recommended to the Kansas Department of Wildlife Parks (KDWP): 1. Increase of the creel limit for crappie greater than 14 inches from two to ten fish per day to increase angler use and increase harvest of older crappie.2. Increase the catfish creel limit from five to ten fish per day to be consistent with statewide creel limits. Catfish are not considered a significant predator of gizzard shad.3. Decrease the wiper length limit from 24 to 21 inches to increase harvest of older fish.The KDWP accepted and changed the following beginning for 2006: 1. Crappie creel limits were not changed due to perceptions of angler dissatisfaction.

2. Increased catfish creel limit to ten per day.3. Decreased wiper length limit from 24 to 21 inches.Based on 2005 monitoring, the following are recommended:
1. Maintain current 2006 creel and/or length regulations through 2007.2. Investigate walleye age structure, total annual mortality, and mortality caps to determine if current size and creel regulations are appropriate.
3. Stock a 2006 wiper year-class within budget constraints, and budget for a 2007 stocking at a rate of 10 two-inch fish per acre (50,000).2 2005 FISHERY MONITORING REPORT AND 2006 PLAN INTRODUCTION This report presents the results of fishery monitoring activities on Wolf Creek Lake (WCL). Data are summarized in table form to document long-term trends and demonstrates that the fishery has functioned as desired through 2005. The goal is to increase public safety and plant operating efficiency by reducing the potential for excessive gizzard shad young-of-year (YOY) impingement on the Circulating Water System intake screens. Shad impingement problems to date have not occurred due largely to the characteristics of the current fishery.Public' use of the fishery is also important to maintain community relations and local economic benefits.

Consequently, maintaining and/or enhancing public enjoyment of the fishery that is compatible with the shad impingement control are other important goals of this program. Creel and length limits were determined jointly with the Kansas Department of Wildlife and Parks (KDWP). The catch-and-release strategy employed appears to have succeeded with no detrimental changes to the fishery observed through 2005.Fishery monitoring activities in 2006 will be similar to 2005 to maintain long-term trending.

Short-term changes will also be detected to ensure WCGS can be prepared if impingement potential increases.

METHODS The monitoring methods used during 2005 allowed for continued analyses of important long-term trends. Gill netting was used at long-term sites on WCL (Figure 1). Spring electrofishing effort targeted smallmouth and largemouth bass habitat by shocking in shoreline transects until a minimum number of fish or a designated length of shore was sampled. Small-mesh gill netting replaced shoreline seining in 1998 to better assess young-of-year (YOY) gizzard shad densities and recruitment (Boxrucker et al -1991). Important species to the fishery were targeted when expected to be efficiently sampled.Sampling efforts are listed in Table 1. Fish sampled were weighed to the nearest gram, and measured (total length, TL) to the nearest millimeter.

Proportional stock density (PSD, Anderson 1980), incremental relative stock density (RSD, Gablehouse 1984), and relative weight (Wr, Wege and Anderson 1978) were indices applied. Length-weight equations adopted by KDWP were used.The 2006 efforts will be completed as scheduled in Table 2. These efforts are the same as for 2005. Anglers using the lake park report the number of fish caught and released, the number kept for personal use, and angler satisfaction.

These creel sheets are collected and tabulated by Coffey County. Data from the census sheets will be used to determine if harvest rates change dramatically and to measure angler success.Increasing walleye size variability and maximum size is advantageous to diversified shad control, as well as angler compatibility and success. Consequently, walleye age structure, total annual mortality, and mortality caps will be determined using methods similar to Quist et. al. (2004). The current management objective is to produce larger walleye (>26 inches total length) by encouraging harvest of smaller walleye from a stable population with good recruitment, thus reducing intraspecific competition allowing surviving individuals to grow larger. A slot limit prohibiting harvest of fish between 18 and 26 inches was set to accomplish this. Assessing mortality caps will determine if walleye die of natural mortality before reaching 26 inches, if harvest of smaller individuals is necessary, if decreasing interspecific competition for available prey would 3 be effective, and if regulating length of harvest is applicable given current lake biology and angler impacts. University graduate students will be solicited and supported with research grant funding to complete this task. Available scale and fishery data will be used.RESULTS AND PLANS The fishery in Wolf Creek Lake continued to function as desired. It exhibited signs of low prey densities, which is preferred to minimize fish impingement at the circulating -water intake. The potential for excessive gizzard shad impingement remained small due to relatively low YOY densities going into the winter months. The shad appear to be limited by predation, as indicated by the population indices of the predator species. Gizzard shad typically has been an important forage species in most reservoirs (Carlander 1969, Pflieger 1975, Stein and Johnson 1987, Colvin 1993). For shad to be compatible with WCGS operation, low YOY shad densities must be maintained.

Periodic recruitment of shad young to reproducing adults also must occur to maintain the predators, which in turn control shad numbers. These conditions currently exist in WCL, and benefit WCGS.Catch densities of remained similar to past years for adult gizzard shad, white bass and wiper;, increased for white crappie, and decreased for smallmouth bass and walleye (Table 3). Fall densities of small gizzard shad remained low. Density changes for smallmouth bass is likely due to sampling variation.

Walleye changes may be due to sampling variation because catch densities were within past ranges. Increased angler harvest for two consecutive years may also have contributed (Table 7)Fish length frequencies in 2005, as shown by the PSD/RSD indices (Table 4), showed no major changes to past years, except for gizzard shad. A higher PSD indicates fewer shad recruiting to mid-size due in part to predation, and an older population existing.

Continued recruitment and growth of important species were evident with most showing good percentages of mid-sized individuals (RSDS-Q, RSD Q-P, and RSD M-T size ranges). For wipers, the sizes increased slightly showing continuing maturation of the latest 2001 year-class stocking.

Because of this, budgeting for potential wiper stocking in 2006 is recommended to ensure continued presence.There was a small shift to larger walleye, possibly due to the current regulations, but this shift is not definitive.

Walleye research referenced earlier should determine any relationships.

Body conditions as indicated by Wr indices (Table 5) remained similar to past years for gizzard shad, smallmouth bass, and white crappie; increased for white bass, wiper; and decreased for walleye. All species showed adequate body conditions to maintain their populations.

Large increases or decreases in body condition were not evident for most species. The white bass increase may be attributable to decreasing wiper competition, as the 2001 year-class matures.Overall, this indicates that no large changes in prey availability occurred, primarily gizzard shad densities.

No detrimental impacts due to angler harvest of the predator populations controlling gizzard shad have been observed.

Harvest rates were slightly lower, but still similar for most species, except walleye (Table 6 and 7). Harvest of walleye under 18 inches nearly doubled in 2004, and slightly more in 2005. Because the population indices for catch frequency, length frequency, and body conditions remained similar to past years, influence by angler harvest was not apparent.There are no fish creel and length limit changes recommended for 2007. The current smalimouth bass and walleye slot limits were imposed to increase body condition and growth. These limits should remain in effect until more data is collected to assess their impacts. The current minimum length limit (12 inches) for white bass was set to protect younger wipers. Since a wiper year class stocking is planned for 2006 and 2007, the white bass minimum length should remain in effect.The crappie is an important littoral predator of gizzard shad in the absence of high largemouth 4

densities, so the minimum length limit (14 inches) was set to protect a majority of the larger individuals.

A large proportion of crappie were near the limit (PSD M-T of 28, Table 4), consequently the limit should remain the same.PLAN RESULTS To ensure continued WCGS support and public use, the fishery program will accomplish the following:

1. Continue monitoring as outlined.2. Maintain current 2006 creel and/or length regulations through 2007.3. Investigate walleye age structure, total annual mortality, and mortality caps to determine if current size and creel regulations are appropriate.
4. Stock a 2006 wiper year-class within budget constraints, and budget for a 2007 stocking at a rate of 10 two-inch fish per acre (50,000).5 LITERATURE CITED Anderson, R. 0. 1980. Proportional stock density (PSD) and relative weight (Wr): interpretive indices for fish populations and communities.

Pages 27-33 in S. Gloss and B. Shupp, editors. Practical fisheries management:

More with less in the 1980's. New York Chap., Amer. Fish. Soc., Workshop Proceedings.

Boxrucker, J., D. Degan,.D.

DeVries, P. Michaletz, M. J. Van Den Avyle, B. Vondracek.

~ 1991 (year not specified).

Sampling Shad in Southern Impoundments.

U.S. Fish and Wildlife Service, Reservoir committee of the Southern Division-American Fisheries Society, Coop agreement No. 14-16-0002-91-216.

22 pp.Carlander, K. D. 1969. Handbook of Freshwater Fisheries Biology, Vol. 1. Iowa State University Press, Ames, Iowa. 752 pp.Colvin, Mike. 1993. Ecology and management of white bass: a literature review. Missouri Department of Conservation, Dingell-Johnson Project F-1-R-42, Study 1-31, Job 1, Final Report.Gablehouse, D. W., Jr. 1984. A length-categorization system to assess fish stocks. North American Journal of Fisheries Management.

Vol. 4. P 273-285.Pflieger, W. L. 1975. The Fishes of Missouri.

Missouri Department of Conservation.

343 pp.Quist, M. C., J. L. Stephen, C. S. Guy, and R. D. Schultz. 2004. Age Structure and Mortality of Walleyes in Kansas Reservoirs:

Use of Mortality Caps to Establish Realistic Management Objectives.

North American Journal of Fisheries Management, 24:990-1002.

Stein, R. A. and B. M. Johnson. 1987. Predicting carrying capacities and yields of top predators in Ohio impoundments.

Ohio Department of Natural Resources, Division of Wildlife.Federal Aid in Fish Restoration Project F-57-R-5 through R-9, Study 12. 144 pp.Wege, G. J. And R. 0. Anderson.

1978. Relative weight (Wr): a new index of condition for largemouth bass. Pages 79-91 in G. D. Novinger and J. G. Dillard, editors. New approaches to the management of small impoundments.

North Central Division, American Fisheries Society. Special Publication 5, Bethesda, MD.6 Table 1. Fishery sampling effort by gear type used at Wolf Creek Lake during 2005.Water Gear Date (1) Location Effort Temp IF Electrofishing

'z 5/27 NA (d0.75 72 Standard Gill Netting (4) 10/11 2 (5) 1 66-69 9 1 77-86 10/12 6 1 65-67 8 1 64-65 10/13 2 1 68 9 1 70-85 10/14 6 1 67 8 1 64 Small Mesh Gill Netting (6) 10/26 6 (7) 2 59-62 8 2 59 10/27 6 2 60 8 2 57 Fyke Netting 10/26 2 (8)1 56 6 1 62 8 1 59 10/27 2 1 60 6 1 60 8 1 57 (1) See Figure 1 for locations.

(2) Equipment consisted of a boat-mounted Smith-Root unit operated at 220v, 9-10 amp, DC current pulsed 120 cycles/second (3) Shock effort shown as hours water was energized.

(4) Standard gill nets consisted of a complement of four 8'x100' monofilament nets, one each of 1", 1.5", 2.5", and 4" uniform mesh.(5) Standard gill netting effort listed as number of net-complement-nights set.(6) Small-mesh gill nets consisted of a complement of two 8'xl 00' monofilament nets, one with 0.5", and the second with 0.75" uniform mesh.(7) Small-mesh gill netting effort listed as number of small-mesh-complement-nights set.(8) Fyke netting effort listed as number of trap-net-nights.

7 Table 2. Fish Sampling Schedule at Wolf Creek Lake during 2006.1.2.3.4.5.6.7.8.Minimum Information Needed to Assess Fishery Gizzard shad recruitment through winter White crappie population characteristics and health Largemouth bass population characteristics and health Smallmouth bass population characteristics and health White bass population characteristics and health Wiper survival and health Walleye population characteristics and health Gizzard shad YOY reproduction and densities going into winter Method Preferred Time Frame Electrofishing Fyke netting/Gill netting Electrofishing Electrofishing Gill netting Gill netting Gill netting Small Mesh Gill Netting April/May October/November April/May April/May October October October September/October 8

Table 3. Catch-per-unit-of-effort (CPUE) of selected fish species in Wolf Creek Lake. Fall gill net, data were not collected in 2001 due to the September 11 events.Fyke net, and electrofishing Gizzard Gizzard Smallmouth Largemouth White Shad Shad (YOY) White bass Wiper Bass Bass Crappie Walleye 1983 (1) 7 (1) 23 (1) 15 (2) 24.5 (3) 0 (1) 4 1984 25 18 11 45.0 6 29 1985 3 6 22 45.3 5 26 1986 32 25 14 (2) 1.3 34.5 5 9 1987 10 18 21 8.5 18.8 12 16 1988 12 28 26 10.5 22.0 9 19 1989 18 17 23 14.8 32.3 4 22 1990 10 34 12 12.0 14.0 5 13 1991 14 45 22 20.5 5.5 4 19 1992 19 17 9 10.8 8.3 6 22 1993 11 52 8 15.0: 5.0 5 12 1994 9 61 11 12.5 2.0 4 23 1995 25 29 11 6.3 2.0 5 16 1996 9 (4)22.9 19 3 10.8 0.3 9 20 1997 19 77.0 60 8 5.5 1.3 4 28 1998 18 39.9 45 6 10.5 1.5 3 16 1999 15 9.9 37 4 11 3.3 6 14 2000 18 29.4 36 13 21.5 3.0 (5)9 28 2001 -----2.0 --2002 11 3.5 32 4 2.0 1.0 6 8 2003 10 1.9 54 9 8.0 2.0 7 14 2004 12 5.5 33 6 34 0.8 -20 2005 11 0.3 37 4 16 0.0 13 9 (1) Data from fall standard gill netting. Units equal number per gill-net-complement-night

> stock size.(2) Data from spring electrofishing.

Units equal number per hour shocked > stock size. Shocking efforts starting in 2004 targeted prime habitats rather than standard locations as completed during prior years.(3) Data from spring Fyke netting. Units equal number per trap-net-night

> stock size.(4) Data from smallmesh gill net. Units equal number per net complement of one 0.5 and one 0.75 mesh net.(5) Data beginning in 2000 were from fall Fyke netting. Netting not completed during 2004 due to adverse weather. Units equal number per trap-net-night

> stock size.9 Table 4. Proportional Stock Density (PSD) and Relative Stock Density (RSD) for selected fish species at Wolf Creek Lake.Stock (S), quality (Q), preferred (P), memorable (M), and trophy (T) size ranges are per Gablehouse (1984). Fall gill net, Fyke net, and electrofishing data were not collected in 2001 due tothe September 11 events.Species Index 88 89 90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 Gizzard shad (1)(2)White bass (1)(2)Wiper(1)Smallmouth Bass(4), (5 after 2003)PSD RSD-P PSD RSD S-Q RSD Q-P RSD P-M RSD M-T RSD T+PSD RSD S-Q RSD Q-P RSD P-M RSD M-T RSD T+PSD RSD S-Q 85 90. 100 70 81 93 59 69 84 75 94 81 30 15 10 0 30 19 7 41 31 16 25 6 19 70 77 85 27 59 .80 31 89 63 56 57 59 45 65 23 15 73 41 20 69 11 37 44 43 41 55 35 9 7 2 10 36 5 12 8 51 4 11 3 4 39 62 21 34 35. 24 55 45 0 53 45 40 55 29 15 4 15 9 2 22 11 4 <1 2 2 7<1 1 100 97 96 100 100 100 100 85 30 88 89 100 100 3 4 .15 70 12. 11 1 10 14 3 32 11 42 40 28 47 39 21 6 4 33 73 91 58 58 50 53 53 61 76 92 81 30 23 5 9 42 1 1 2 29 37 40 61 40 44 40 52 58 50 52 77 70 71 63 60 39 60 56 60 48 42 50 48 23 30*8 25 10 22 26 17 20 28 28 23 29 34 28 17 10 27 32 13 20 12 20 26 18 21 36 40 4 5 4 6 1 7 8 4 5 9 2 7 2 1 92 99 97 100 82 85 88 100 100 60 50 100 100 8 1 3 18 15 12. 40 50 50 19 28 19 5 12 10 13 13 20 17 50 72 71 80 95 71 71 75 88 100 40 33 100-87 49 47 83-13 51 53 17-48 33 53 41-52 67 47 59-10 1 5 3-34 29 43 32-.4 3 5 5<1-100 100 100 100-24 3-31 20 65 55-45 80 33 39 2-88 83 66 50-13 17 34 50 38 17 22 17 50 63 36 25 4 8 8 RSD Q-P RSD P-M RSD M-T RSD T+Largemouth PSD Bass (5) RSD S-Q RSD Q-P RSD P-M RSD M-T RSD T+88 50 100 13 25 38 25 17 50 50 83 (7) (7)10 Table 4. (cont.)Species Index 88 89 90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 White PSD crappie (6)l5) RSD S-Q RSD Q-P RSD P-M RSD M-T RSD T+99 100 100 100 100 95 100 100 99 100 100 100 82 1 5 1 18 2 12 9 3 3 2 8 1 9 9 9 43 4 10 13 7 26 14 44 11 12 15 12 13 11 85 60 70 87 63 75 41 87 72 71 74 77 28 10 21 10 3 8 4 7 1 6 5 5 1 1 94 93 96 77 93 90 52 83 73 31 55 74 78 6 7 4 23 7 10 48 17 27 69 45 26 22 81 80 95 59 74 67 41 82 67 28 51 74 75 14 13 1 18 19 22 10 1 6 3 4 3-98 99 97 87-2 1 3 13-34 48 32 53-11 29 15 6-52 21 47 28-1 1 3-47 60 69 62-53 40 31 38-40 57 66 54-8 3 3 7 Walleye (1 PSD RSD S-Q RSD Q-P RSD P-M RSD M-T RSD T+(1) Data from fall gill netting.(2) Corrected for gill net efficiency (Willis et al 1985)(3) Data from spring electrofishing.

(4) Data from fall electrofishing.

(5) Data from spring Fyke netting.(6) Data from spring Fyke netting 1999 and earlier, from fall Fyke netting 2000 and later.(7) Insufficient data to calculate.

(8) 2004 data from fall gill netting.I1 Table 5. Relative weight (Wr) of selected fish species in Wolf Creek Lake. Wr formulas from KDWP were used. Per Wege and Anderson (1978), Wr values of 100 and higher represent fish at or above the 75 percentile, values of 93 to 100 are between the 50 and 75 percentile, values of 86 to 93 are between the 25 and 50 percentile, and values less than 86 are below the 25 percentile.

Fall gill net, Fyke net, and electrofishing data were not collected in 2001 due to the September 11 events.Gizzard ýSmallmouth Largemouth White Shad White bass Wiper Bluegill Bass Bass Crappie Walleye 1983 (1) 85 (1) 78 (1) 90 (2) 107 (2) 974) 107 (1)78 1984 87 94 86 103 98 93 82 1985 88 89 78 102 97 94 83 1986 85 86 84 111 93 93 81 1987 89 93 89 105 (3) 97 88 89 80 1988 90 94 85 108 .92 92 102 81 1989 104 95 80 96 92 87 88 88 1990 100 99 82 121 104 84 98 85 1991 93 93 78 111 91 79 99 86 1992 93 92 88 102 91 84 95 86 1993 93 94 88 92 91 80 85 85 1994 93 90 75 104 86 75 97 85 1995 88 97 88 124 90 89 105 85 1996 89 106 100 121 100 57 104 94 1997 89 97 89 105 81 90 99 88 1998 81 90 83 83 86 91 95 76 1999 82 93 83 105 90 78 97 81 2000 76 86 77 106 85 78 (5)88 80 2001 --102 -84 2002 87 88 75 110 82 89 (5)95 77.2003 85 88 68 116 88 83 96 86 2004 81 87 72 107 84 (5) (1)91 86 2005 83 95 80 84 (5) 89 81 (1)(2)(3)(4)(5)Data from fall gill netting.Data from spring electrofishing.

Data from spring Fyke netting.Data from fall Fyke netting.Insufficient sample size to calculate.

12 Table 6.Selected fish species caught and released by anqlers at Wolf Creek Lake.Chan. White Wiper Smallmouth All Anglers catfish bass-. hybrid Bass J LM Bass Crappie Walleye fish 1999 9008 2000 6865 2001 7449 2002 4227 No.#/hour#/acre No.#/hour#/acre No.#Ihour#/acre No.#/hour#/acre No.#/hour#/acre No.#/hour#/acre No.#/hour#/acre 6928 0.15 1.36 5191 0.15 1.02 5623 0.16 1.10 3949 0.19 0.77 6057 0.25 1.19 7175 0.23 1.41 10,619 0.37 2.09 15,171 0.32 2.98 7838 0.23 1.54 8777 0.25 1.72 3623 0.17 0.71 8489 0.34 1.67 6748 0.22 1.33 8048 0.28 1.58 3503 0.07 0.69 2267 0.07 0.45 1810 0.05 0.35 1649 0.08 0.32 6838 0.27 1.34 4553 0.15 0.89 2683 0.09 0.53 17,482 0.37 3.43 12,579 0.36 2.47 10,136 0.28 1.99 8097 0.38 1.59 8527 0.35 1.67 8989 0.29 1.77 7785 0.27 1.53 3885 0.08 0.76 4918 0.14 0.97 4736 0.13 0.93 874 0.04 0.17 3193 0.13 0.63 3096 0.10 0.61 1420 0.05 0.28 7382 0.15 1.45 5536 0.16 1.09 7457 0.21 1.47 4563 0.22 0.90 5739 0.23 1.13 6386 0.21 1.25 4370 0.15 0.86 31,027 0.65 6.10 21,599 0.63 4.24 20,911 0.59 4.11 11,785 0.56 2.31 6740 0.27 1.32 10,016 0.33 1.97 9457 0.33 1.86 86,464 1.82 16.99 61,102 1.77 12.00 60,417 1.70 11.87 31,807 1.65 6.84 45,895 1.86 9.02 47,229 1.55 9.28 44,629 1.54 8.77 2003 4751 2004 5674 2005 5287 13 Table 7. Selected fish species harvested by anqlers at Wolf Creek Lake.Chan. White Wiper Smallmouth All Anglers catfish bass hybrid Bass I LM Bass Crappie Walleye fish 1999 9008 6865 No. 1628#/hour 0.03#1acre 0.32>12".1149 0.02 0.23 2000 No.2258 I 859 2001#/hour 0.07#/acre 0.44 7449 No. 2779#/hour 0.08#/acre 0.55 4227 No. 1161#/hour 0.08#/acre 0.23 2002 0.02 0.17 1046 0.03 0.21 378 0.02 0.07 1233 0.05 0.24 1494 0.05 0.29 1281 0.04 0.25>24" 7<0.01<0.01 3<0.01<0.01 12<0.01<0.01 7<0.01<0.01 16<0.01<0.01 18<0.01<0.01 8<0.01<0.01<13" 356 0.01 0.07 198 0.01 0.04<13", 126 0.01 0.02 85<0.01 0.02<166" 364 0.01 0.07 371 0.01 0.07 303 0.01 0.06>18" 116<0.01 0.02 20<0.01<0.01>16" 69<0.01 0.01 62<0.01 0.01>20" 24<0.01<0.01 0 0 0 10<1.01<0.01>21" 14<0.01<0.01 10<0.01<0.01 4<0.01<0.01 7<0.01<0.01 1<0.01<0.01 3<0.01<0.01 6<0.01<0.01>14" 725 0.01 0.14 316 0.01 0.06 415 0.01 0.08 184 0.01 0.04 234 0.01 0.05 386 0.01 0.07 325 0.01 0.06>18" 1669 0.03 0.33 533 0.01 0.10<18" >18" 1609 36 0.05 <0.01 0.32 0.01 862 326 0.04 0.01 0.17 0.06<18" >26" 1244 26 0.05 <0.01 0.24 <0.01 2327 7 0.08 <0.01 0.46 <0.01 2441 8 0.08 <0.01 0.48 <0.01 6007 0.13 1.15 4366 1.13 1.35 6291 0.18 1.23 3841 0.18 0.83 5638 0.49 0.93 7662 0.25 1.51 6981 0.24 1.37 2003 4751 No. 2457#/hour 0.10#/acre 0.48 2004 5674 No. 2989#/hour 0.10#/acre 0.59 5287 No. 2541#/hour 0.09#/acre 0.50 2005 14 N III Main Lake Area 6 Figure 1. Fishery sampling location on Wolf Creek Lake.15 APPENDIX C Biological Control Of Gizzard Shad Impingement At A Nuclear Power Environmental Science & Policy www.elsevier.com/locate/envsci ELSEVIER Environmental Science & Policy 3 (2000) S275-S28i Biological control of gizzard shad impingement at a nuclear power plant Dan E. Haines*Wolf Creek Nuclear Operating Corporation, 1550 Oxen Lane, Burlington, KS 66839. USA Abstract Biological control of gizzard shad (Dorosoma cepedianum) using predator fish species was managed to reduce impingement on cooling water intake screens at Coffey County Lake (CCL), Kansas. Long term shad and predator proportional stock densities (PSD) and body conditions (Wr) were used to characterize this fishery. Comparisons were completed between the lake's primary productivity (mg/in 3 chlorophyll-a), catch-per-unit-effort (CPUE) of young-of-year (YOY) and adult gizzard shad, and body conditions of predator species. No relationships were found between the lake's productivity and gizzard shad densities indicating that other mechanisms control shad numbers, likely predation.

Body conditions of the prevalent predator species in CCL were positively compared with the previous year's production during a short-lived increase in shad densities.

It is well documented that shad are an important food source for most predator species present in the lake. It is believed that the predator species present played a significant role in reducing YOY shad densities each year. Body conditions of predators did not indicate a surplus of a primary prey species. High shad growth rates and PSD indices promote survival of sufficient shad to adults, thus making this fishery nearly self-sustaining, and beneficial for plant operation.

© 2000 Elsevier Science Ltd. All rights reserved.Keywords:

Gizzard shad; Cooling lake; Impingement; Fishery; Predation; Biological control 1. Introduction Excessive fish impingement on intake screens can cause costly equipment damage and power production delays. In the mid-west, gizzard shad (Dorosoma cepe-dianum) can produce large numbers of young and typically reach high densities in impoundments (Pflie-ger, 1975; Willis and Jones, 1986; Dettmers and Stein, 1991). Gizzard shad, especially the young-of-year (YOY), are susceptible to winter mortality, usually as water temperatures fall below approximately 4°C (38°F) (Nebraska Public Power District (NPPD), 1985;Willis, 1987; Jester and Jensen, 1972). Impingement problems on power plant intake screens develop because these shad cannot avoid intake flows during Tel.: + 1-316-364-8831, ext. 4672; fax: + 1-316-364-4154.

E-mail address: dahaine@wcnoc.com (D.E. Haines).such natural winter die-offs (Olmstead and Clugston, 1986; White et al., 1986).Gizzard shad is also an important forage species in most reservoirs (Pflieger, 1975; Carlander, 1969; Stein and Johnson, 1987; Colvin, 1993). Some predator in-fluences have been documented (Dettmers and Stein, 1991), but typically shad have not been controlled by predation (Putman and DeVries, 1994). It would be an obvious advantage in a power plant cooling lake, to have predator species reduce gizzard shad YOY.abun-dance to densities low enough to prevent excessive impingement on intake screens, on an annual basis. In addition, adverse environmental, public relation, and regulatory impacts associated with large impingement events could also be avoided.In 1977, early during the construction of CCL, it was expected that gizzard shad could not be excluded from, and would flourish in the lake. Consequently, an aggressive stocking program was completed, with the goal of limiting winter survival of YOY gizzard shad.1462-9011/00/$

-see front matter © 2000 Elsevier Science Ltd. All rights reserved.PII: S1462-9011(00)00067-8 S276 D.E. Haines/ Environmental Science & Policy 3 (2000) S275-S281 Using management techniques not uncommon for lakes managed for sport fishing, a fishery was estab-lished with a diversity of predators.

Angler harvest was not a factor initially as no fishing was allowed.The fishery's ability to eliminate gizzard shad impin-gement events depends to a large degree on the inter-actions between the array of predator and prey species. Typical prey species tend to produce a large number of young each year. Characteristics of an annually cropped prey population, such as in CCL, would be a high relative percentage of larger, older in-dividuals, fast growth of YOY, and good health of in-dividuals.

Recruitment would also be low, which would limit the ability of the population to produce the number of YOY needed to support the predators (Eichner and Ellison, 1983). Characteristics of predator populations in a low-prey fishery would include low recruitment due to predation or cannibalism, large per-centages of older individuals, and poor health of adults.2. Study area Coffey County Lake was constructed to provide once-through cooling water for Wolf Creek Generating Station (WCGS), an 1150 Mw, single unit nuclear power plant in east-central Kansas (Fig. 1). The lake first reached full pool in 1982, is 2060 ha (5090 acres), and has an- average depth of 6.5 m (21.5 ft). It impounds an intermittent stream with a small drainage of 5050 ha (19.5 square miles). The lake was initially filled, and subsequently maintained, via makeup water pumping from the nearby Neosho River. Two rip-rapped dikes totaling 3.6 km (2.25 miles) in length serve to disperse water flows, to maximize cooling effi-ciency. WCGS cooling water is pumped at a rate of approximately 2006 m 3 (530,000 gpm) through self-cleaning rotating screens.2.1. Fishery establishment The fishery was initially established with a stocking program funded and completed by the utility, with technical advice from the Kansas Department of Wild-life and Parks (KDWP). The goal was to establish a predator population with as much species diversity as possible.

Prior to lake filling, basin preparation included comprehensive removal of undesirable fish species from ponds and pool areas of Wolf Creek. Fol-lowing renovation, and prior to inundation, selected ponds within the basin were stocked with fathead min-nows (Pimephales promelas) for initial forage, then with predator species selected for shad control benefits.These primarily included largemouth bass (Micropterus salmoides), smallmouth bass (M. dolomieu), black crappie (Pomoxis nigromaculatus), walleye (Stizoste-.

dion vitreum), striped bass (Morone saxatilis), and hybrid striped bass (wipers, M. saxatilis x M. chry-sops). The objectives of the basin stockings were to provide adults capable of spawning as the lake filled.Presence of adult predators in the young fishery also would reduce the production of initial large year classes of undesirable, rough-fish species. Predator stockings during and shortly after lake fill were com-pleted to bolster year class strength and maintain pre-dator species diversity.

Gizzard shad larvae were unavoidably introduced to the lake from the Neosho River when water was pumped to fill the lake. White bass (M. chrysops) and white crappie (P. annularis) were likely introduced in this way. These two species added to the diversity of the predator populations.

3. Methods The methods employed from 1983 to 1998 allowed for continued analyses of important long term trends.Trap (Fyke) netting, electrofishing, and gill netting were used at long-term sites on CCL (Fig. 1). Four 5'..I.4 I Q Fig. 1. Coffey County Lake, Kansas with fishery sampling areas identified.

S278 D.E. Haines/ Environmental Science & Policy 3 (2000) S275-S281 chi depth measurements taken concurrent with chlorophyll a (mg/rn 3) monitoring were compared.This relationship was significant (r =- 0.71, n = 24, p:50.05).

Therefore, secchi depths were reflective of CCL primary productivity, and could be used in place of chlorophyll a measurements.

A similar relationship was identified for some Missouri reservoirs (Michaletz, 1999).To determine if YOY shad densities were influ-enced by CCL productivity, secchi depths measured concurrent with seine efforts were compared with YOY shad catches per seine haul. These compari-sons were segregated by lake location and month.No significant relationships were found between any of the comparisons.

This indicates that gizzard shad in CCL have not been limited by. lake productivity, and have been limited by other limiting factors, likely by predation.

Predation influences on shad YOY densities were tested by comparing the predator Wr indices (Table 1)with the previous year's YOY CPUE from seine*efforts. Only data from 1993 to 1997 were used to bracket the largest rise and fall of YOY shad densities (Fig. 2). Largemouth bass data were not analyzed because too few specimens were collected to obtain a confident Wr average. Significant relationships (p:50.05) were identified for white bass (r = 0.92), wiper hybrid (r = 0.83), smallmouth bass (r = 0.72), white crappie (r = 0.97), and walleye (r = 0.79). This is evidence demonstrating that predator species respond to larger increases and subsequent decreases in shad YOY densities.

Such relationships were not as evident for the other years sampled. It is possible that other prey species, or cannibalism were relied upon during periods of low shad production, and predator Wr may reflect variations in those prey sources.4.2. Long term maintenance via recruitment The long term maintenance of the predator-prey balance of this fishery depends on the continued recruitment of sufficient gizzard shad, as stated above.In CCL, shad survival to reproducing adults may have depended on how quickly they were able to grow too large to be eaten. Typically, gizzard shad grow quickly to sizes large enough to escape significant predation, and this has been considered a detriment to sport fish management (Putman and DeVries, 1994). However, this was not considered detrimental in CCL, but rather beneficial to maintaining low shad densities vulnerable to impingement.

There were inferences that many of the reproducing sized shad were recruited from the fas-ter growing YOY identified in scale age analyses.Many of the larger fish sampled in 1998 had back-cal-culated first-year growth from 200 to 230 mm (Table 2). Because of the heated water discharge, past monitoring has shown that these larger, first-year shad were likely spawned earlier in the year, and their growth was enhanced by a longer growing season.(Nuclear Regulatory Commission, 1982). The first year-growth shown in Table 2 also implies that few of the smaller (90-150 mm TL) YOY shad survived to recruit to reproducing size, and heavy predation was a likely cause. Once the larger YOY grew large enough to escape the majority of CCL predators, consumption of the smaller shad should have intensified from late summer to early autumn. Apparently, the faster grow-ing shad were the ones that successfully recruited, and comprised the majority of the reproducing sized adults that support the predator populations.

Without the thermal discharge influences, length frequency distri-butions of YOY shad would likely be more com-pressed, similar to other area lakes (Willis 1987).Gizzard Shad Catch-Per-Unit-Effort for Coffey County Lake 2 50 F 45£40.~38 530 25 20 Adult shad YOY shad -/I*I.\ I gO 80 70_60z 50.S 40o, 30 10 0 Fig. 2. Gizzard shad catch7per-unit-effort for adults from standard gill net complements and young-of-year from seine efforts at Coffey County Lake, Kansas.

D.E. Haines / Environmental Science & Policy 3 (2000) S275-S281 S277 primary lake locations were consistent from year to year and chosen to sample the upstream, main-body, plant cooling water intake, and the plant discharge areas. Important species to the fishery were targeted when they were expected to be most efficiently sampled.Two Fyke nets were set at each location during two nights for a total of four net-nights per location per year. Locations included the upper and main body during 1983, with the intake area being added during 1984, and the discharge area in 1986. These nets were set near shore .in 4-6 ft of water as spring-time water temperatures approached 12°C (55°F), usually during early April of each year. Fyke nets targeted primarily crappie and walleye. Important information was also provided about the winter survival and recruitment of the previous year's gizzard shad production.

The CPUE was calculated as the number of fish of a tar-geted species per trap net-night.

A Smith-Root boat mounted shocker with circular electrode arrays, operated at approximately 10 A and 220 V of pulsed DC current, was used for electrofish-ing samples. Four efforts each year, two in the spring (May-June), and two in the autumn (September-Octo-ber) were completed.

Locations included the upper and main body during 1983, with the intake area added during 1984, and the discharge area in 1986. Two 15 min (energized time) subsamples at each location were shocked each time. This gear type targeted large-mouth bass and bluegill (Lepomis macrochirus) in the spring. Fall shocking targeted smallmouth bass, and provided indications on shad YOY production.

Elec-trofishing efforts were also completed during other months at the same locations during some years to provide YOY gizzard shad data. Electrofishing CPUE was calculated as the number of fish per hour shocked.Gill netting was an extensive, two night effort in October of each year. Locations included the upper, main body, and intake areas during 1983, with the dis-charge area being added during 1986. The gill nets were used to sample white bass, wiper, walleye, and gizzard shad. One gill net complement was set at lo-cations consistent over the years during two consecu-tive nights for a total of eight complement net-nights each year. A standard gill-net complement included four nets, one each of 25.4, 38.1, 63.5, and 101.6 mmn mesh (bar measure).

Each was a 30.5 x 2.4 m uniform mesh monofilament net. The CPUE was calculated as the number of a species sampled per standard comp-lement night.Seine hauls were completed monthly (June-August) from 1983 to 1993. From 1994 to 1997, only June and July samples were taken. Effort consisted of two hauls per location per month from 1983 to 1984. Five hauls per location per month were completed from 1985 to 1997 (Fig. 1). The upper and main body locations.were sampled since 1983, while the intake area was included since 1984. The discharge area was sampled beginning in 1985 and ending in 1996. Seine dimen-sions were 15.2 x 1.8 m, with a 1.8 x 1.8 m bag. A seine haul consisted of one 90° arc along the shoreline.

The CPUE was reported as the number of fish per seine haul.Fish sampled were weighed to the nearest gram, and measured (total length (TL)) to the nearest millimeter.

Secchi depth measurements were taken concurrent with most fishery sampling efforts. Proportional stock density (PSD, Anderson, 1976) was calculated for all species. PSD is the proportion of a sample that are lar-ger than a predetermined length. Fish smaller than a minimum size are excluded.

Relative weight (Wr, Anderson, 1980) indices were calculated for each species and used to assess the health of a species rela-tive to its capability in this region. Length-weight equations for Wr adopted by the KDWP were used.Gill net efficiency adjustments to the PSD indices were completed for gizzard shad, white bass, and walleye (Willis et al., 1985).Primary productivity expressed as chlorophyll a con-centrations (mg/n 3) were. determined for upper, main body, and intake areas of CCL roughly corresponding to fishery sampling locations (Fig. 1). Chlorophyll a values were corrected for phaeophytin, and determined using flourometric methods per American Public Health Association et al. (1981). Secchi depth measure-ments were taken concurrent with most chlorophyll a samples. Pearson correlation coefficients were calcu-lated to determine relationships between chlorophyll a, CPUE, and Wr. Paired student's t-tests were, used to test significance at p < 0.05.4. Results and discussion 4.1. Influence on and control of gizzard shad YO Y densities Gizzard shad production of YOY were measured using mid-summer seine efforts throughout 1997 (Fig. 2). Results from these efforts were highly vari-able, which is inherent to this gear type (Ploskey et al., 1990). This variability from CCL in itself indicates low densities because sampling the sparse schools of shad created a 'hit or miss' result. Despite the variability, the results provide an approximation of YOY shad production trends and were of value in some of the comparisons.

To ensure that the survival of YOY shad was not limited by lake productivity, shad densities were compared with secchi depth measurements.

Secchi depths were used as indices of primary productivity of CCL. To confirm this relationship for CCL, sec-Table I Catch-per-unit-effort (CPUE), proportional stock density (PSD), and condition indices (Wr) for gizzard shad and predator fishes sampled from 1983 to 1998 at Coffey County Lake Species 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 Gizzard shad" CPUE PSD Wr White bassa CPUE PSD Wr Wiper hybrid'CPUE PSD Wr Largemouth bassb CPUE PSD Wr Smallmouth basse CPUE PSD Wr White crappie CPUE PSD Wr Walleye 8 CPUE PSD Wr 10.5 24.8. 3.0 32.1 9 24 31 84 85 87 88 85 9.7 12.3 20.5 10.1 16.6 21.3 11.5 92 96 97 100 92 93 _98 89 90 104 100 93 93 93 23 100 78.15 100 90.18 94 94 1i 100 86 6 100 89 22 100 78 25 34 86 18 92 93 28 74 94 17 82 95 23 97 80 34 35 99 45 63 93 17 82 92 52 43 94 5 25.5 10.4 20.1 18.9 75 96 94 99 88 89 89 81 .i 29 19 60 45 S" 76 58 46 61 97 106 97 90 ;;11 3 8 6 85 30 88 89 88 100 89 83 14 21 26 100 100 100 84 89 85 12 22 9 8 11 96 100 100 100 100 82 78 88 88 75 32.0 42.3 45.3 .35.4 18.8 22.0 32.3 14.0 5.5 41 76 92 91 93 92 99 97 100 97 98 97 93 88 92 87 84 79 8.3 5.0 82 85 84 80 2.0 88 75 6.5 5.0 5.3 1.3 8.5 10.5 14.8 12.0 20.5 10.8 15.0 12.5 50 67 33 80 55 29 37 40 61 40 44 40 96 99 95 93 97 92 92 104 91 91 91 86 2.0 0.3 1.3 1.5 " 100 100 60 50 89 57 90 91 6.3 10.8 5.5 10.5 .52 58 50 52 90 100 81 86 5 9 4 3 87 72 71 74 105 104 99 95 16 20 28 16 83 73 31 55 85 94 88 76 0 6-.94-93 5 20 94 26 75 83 5 .12 52 68 93 89 9 85 102 19.95 81 4 60 88 22 94 88 5 70 98 13 96 85.4 87 99 19 77 86 6 63 95 5 75 87 4 41 97 13 52 85 4 29 78 29 75 82 9 74 81 16 100 80 22 12 93 90 86 85 8Data from fall gill netting, CPUE = It/gill net complement net night.b Data from spring electrofishing, CPUE = 0t/h.C'Data from fall electrofishing, CPUE = I/h.d Data from spring Fyke netting, CPUE = #t/trap net night.cjo'q0 S280 D.E. Haines / Environmental Science & Policy 3 (2000) S275-S281 Table 2 Gizzard shad back-calculated lengths from scale samples collected during October, 1998 at Coffey County Lake. Final entries for each year class represents total length at capture. Size at scale formation assumed at 30 mm Year class Total length at annulus formation 1 2 3 4 5 6 1993 (n 5)Average 257 346 378 400 430 450 Range 234-297 317-371 352-398 386-421 414-445 428-463 1994 (n = 10)Average 226 337 385 416 437 Range 151-317 279-374 351-407 394-407 415-455 1995 (n = 14)Average 222 353 390 414 Range 120-329 274-397 302-424 310-448 1996 (n = 16)Average 196 297 327 Range 82-275 246-337 296-358 1997 (n = 2)Average 132 189 Range 115-148 184-194 Consequently, the power plant discharges contribute to both the recruitment of the faster growing YOY, and the annual consumption of YOY shad vulnerable to impingement.

5. Conclusions The dynamics of the CCL fishery demonstrate that impingement can be biologically controlled in certain instances.

Impacts from the intake of cooling water, both to impinged fish and to plant operating efficiency can be reduced. Fishery management techniques can be used to promote predator prey balances that enhance the compatibility of cooling lakes for power plants and a sustainable fishery.References American Public Health Association, American Water Works Association, Water Pollution Control Federation, 1981. Standard Methods for the Examination of Water and Wastewater, 15th ed.APHA, Washington.

Anderson, R.O., 1976. Management of small warm water impound-ments. Fisheries 1(6), 5-7, 26-28.Anderson, R.O., 1980. Proportional Stock Density (PSD) and Relative Weight (Wr): Interpretive Indices for Fish Populations and Communities.

In: Gloss, S., Shupp, B. (Eds.) Practical Fisheries Management:

More With Less in the 1980's. New York Chap., American Fisheries Society, Workshop Proceedings, pp.27-33.Carlander, K.D., 1969. Handbook of Freshwater Fisheries Biology, vol. 1. Ames, Iowa: Iowa State University Press.Colvin, M., 1993. Ecology and Management of White Bass: a Literature Review. Missouri Department of Conservation, Dingell-Johnson Project F-I-R-42, Study 1-31, Job 1, Final Report.Dettmers, J.M., Stein, R.A., 1991. Controlling Gizzard Shad Populations via Introduced Predators.

Ohio Department of Natural Resources, Division of Wildlife.

Federal Aid in Sport Fish Restoration Project F-57 and F-69, Study 19, 185 pp.Eichner, D., Ellison, D.G., 1983. Lake McConaughy Fishery Investigations.

Study VI. Nebraska Game and Parks Commission, Fisheries Division.

Federal Aid in Fish Restoration, Dingell-Johnson Project F-51-R-5, 66 pp.Jester, D.B., Jensen, B.L., 1972. Life History and Ecology of the Gizzard Shad, Dorosoma cepedianum (LeSueur)

With Reference to Elephant Butte Lake. New Mexico Agricultural Experiment Station Research Report 218.Michaletz, P.H., 1999. Influence of reservoir productivity and juven-ile density on first-year growth of gizzard shad, North American Journal of Fisheries Management 19, 842-847.Nebraska Public Power District (NPPD), 1985. Gerald Gentleman Station Impact Assessment of the 1984 Year-class, Sutherland Reservoir.

Prepared by EA Engineering, Science, and Technology, Inc. EA Report NPP52G.Nuclear Regulatory Commission, 1982. Final Environmental Statement Related to the Operation of Wolf Creek Generating Station, Unit No. 1, NUREG-0878.

Washington, DC.Olmstead, L.L., Clugston, J.P., 1986. Fishery management in cooling impoundments.

In: Hall, G., Van Den Avyle, M. (Eds.), Reservoir Fisheries Management, Strategies for the 80's.American Fisheries Society, Bethesda, MD, p. 327.Pflieger, W.L., 1975. The Fishes of Missouri.

Missouri Department of Conservation.

Ploskey, G.R., Stephen, J.L., Gablehouse Jr, D.W., 1990. Evaluation of Summer Seining in Kansas Reservoirs.

Proceedings of the Annual Conference Southeastern Association of Fish and Wildlife Agencies 44, 76-88.Putman, J.H., DeVries, D.R., 1994. The Influences of Gizzard Shad (Dorosoma cepedianum) on Survival and Growth of Largemouth Bass (Micropterus salmoides), Bluegill (Lepomis machrochirus), and White Crappie (Pomoxis annularis).

Alabama Department of Conservation and Natural Resources.

Investigation of Management Techniques for Public Waters, Study XIV. Federal Aid in Fish Restoration Project F-40-R, Study XIV.8 D.E. Haines/ Environmental Science & Policy 3 (2000) S275-S281 S281 Stein, R.A., Johnson, B.M., 1987. Predicting Carrying Capacities and Yields of Top Predators in Ohio Impoundments.

Ohio Department of Natural Resources, Division of Wildlife.

Federal Aid in Fish Restoration Project F-57-R-5 through R-9, Study 12, 144 pp.White, A.M., Moore, F.D., Alldridge, N.A., Loucks, D.M., 1986.The Effects of Natural Winter Stresses on the Mortality of the Eastern Gizzard Shad, Dorosoma cepedianwn, in Lake Erie. The Cleveland Electric Illuminating Company and The Ohio Edison Company, Cleveland, Ohio. Environmental Resource Associates, Inc. and John Carrol University.

Report 78. 208 pp.Willis, D.W., 1987. Reproduction and recruitment of gizzard shad in Kansas reservoirs.

North American Journal of Fisheries Management 7, 71-80.Willis, D.W., Jones, L.D., 1986. Fish standing crops in wooded and nonwooded coves of Kansas reservoirs.

North American Journal of Fisheries Management 6, 393-425.Willis, D.W., McCloskey, K.D., Gablehouse Jr, D.W., 1985.Calculation of stock density indices based on adjustments for gill net mesh size efficiency.

North American Journal of Fisheries Management 5, 126-137.Dan E. Haines received a BSc degree from Emporia State University, Emporia, Kansas and a MSc degree from Emporia State University in Environmental Biology. He has been employed as an Environmen-tal Biologist at Wolf Creek Nuclear Operating Corporation since 1983. Responsibilities include natural resource and fishery manage-ment of the cooling lake to support operation of the electric generat-ing plant.

APPENDIX D EPA Region VII Policy on Gizzard Shad UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION VII 901 NORTH 5TH STREET KANSAS CITY, KANSAS 66101 7 NOV 20 Mr. Steve Williams Bureau of Water, NPDES Permits Iowa Department of Natural Resources Wallace'State Office Building 502 East 9t" Street Des Moines, IA 50319

Dear Mr. Williams:

The Iowa Department of Natural Resources (IDNR) forwarded a report to the Environmental Protection Agency (EPA) which was submitted by Muscatine Power and Water titled Analysis of Gizzard Shad Winter Die-Off and Its iRelevance to 376(b). Muscatine Power and Water has indicated that dead and moribund gizzard shad shbuld not be counted as part of the impingement calculation baseline.

The report proposes a methodology for the accounting for.dead and moribund gizzard shad in the determination of the impingement calculation baseline...

This is a very important question, because impingement offish is dominated by moribund , *gizzard shad at several powerplants in Region 7. Based on our discussions and research, you asked that I send a letter to show EPA's position.We agree that moribund fish should not be counted in the impingement calculation baseline.

Sampling of impingement should count all fish, but moribund fish should not count toward the calculation baseline.As defined in the 316(b) Regulations at 40 CFR § 125.93, the "Calculation Baseline means an estimate of impingement mortality' (emphasis added). The definition goes on to describe that the baseline estimate is based on a certain configuration of a once-through cooling water intake. With this in mind, the primary guide of setting the baseline calculation is the impingement mortality associated with a baseline intake configuration.

The rule does not directly show how moribund fish should be considered in setting the baseline estimate, although it does allow for consideration of moribund fish in the Verification Monitoring Plan. As emphasized above, the baseline calculation is an estimate of impingement mortality; the mortality that would occur due to impingement on the intake screens. Therefore, the calculation baseline should be an estimate of impingement mortality based in the impingement and harm of healthy fish, not the incidental capture of moribund and dying fish.The paper submitted by Muscatine Power and Water provides a good overview of the natural history of the gizzard shad, a description of the biological mechanisms of the winter die-off, and the field conditions that precipitate the die-off.RECYCLED RftWFIBER 2 The Muscatine Power and Water paper lines up several points to make an estimate of moribund vs. healthy gizzard shad on a seasonal basis. Here are the main points: Description of the monthly conditions associated with the. die-off; i.e., the site specific calendar dates where die off conditions are observed.An estimate of the percentage of kill during die-off events. Even in the cold months, there are some healthy individuals and the report uses data to make an estimate of healthy fish.* The report assumes that gizzard shad are healthy during the warm months of the year.The EPA Region 7 supports the Muscatine Power and Water approach and we believe that the logic of this methodology could be used at other sites in Region 7.Thank you for your help in workingthrough this approach.

If you have any questions,call'me at 913-551-7594.

Sincerely, Environmental Engineer Wastewater and Infrastructure Management Branch cc: Daryl Jahn, Muscatine Power and Light t August 9, 2006 Mr. Daryl K. Jahn Environmental Specialist Muscatine Power and Water 3205 Cedar Street Muscatine, Iowa 52761-2204

Dear Mr. Jahn:

HDRILMS is pleased to submit the final version of the report that describes the winter die-off of gizzard shad in the more northerly portions of its geographical range. This is an annual phenomenon.

which often strains the capability of water traveling screens :when large numbers of dead and dying shad are brought in .through the intake structures:

of electric.generating facilities.

The relevance of these dead and dying fish to the determination of the calculation baseline in the Section 316(b) Phase II Rule is not addressed in the Rule which sets forth a Performance Standard for reduction of 'impingement mortality of fish on the traveling screens. The key'term is impingement mortality which should not apply to fish that are dead or irreversibly dying before they reach the traveling screens.We are confidant that the information put forth in this report will be considered by the Iowa DNR as it deliberates this issue.If you have any questions, please do not hesitate to contact me after my return from vacation on August 22, 2006.Very truly yours, Bruce L. Lippincott, Ph.D.Manager Mid West Operations HDR ILMS 10207 Lucas Road Phone. 18151334.9511 HDR Engineerinlg.

IJe. Woostock it I0090-7445 Fax: 18)5 334-,514 I w .hdrirkc.cm Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)Prepared for Muscatine Power and Water 3205 Cedar Street Muscatine, Iowa 52761 August 2006 HDRNLMS 10207 Lucas Road Woodstock, Illinois 60098 I Table of Contents 1 Introduction

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1 1.1 Background

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1 1.2 Question ..........................................................................................................

1 1.3 O bjective ..................................................................................................................

2 2 Gizzard Shad Range Extension and Winter Mortality

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2 3 Synopsis of Physiological and Biochemical Studies on Gizzard Shad Collected During the Winter Season ................................................

3 3.1 Use of Total Lipids as Energy Source .................................................................

4.3.2 Effects of Starvation on Lipid Reserves, Serum Glucose, and Total Serum Protein4 3.3 Cystolic Lactate Dehydrogenase

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5 3.4 Serum and Brain Glucose ....................................................................................

5 3.5 Cholesterol

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6 3.6 Summary ..........................................................................................

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.. 7 3.6.1 Total Lipids ...................................................................................................

7 3.6.2 Cystolic Lactate Dehydrogenase

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7 3.6.3 Serum and Brain Glucose ..................................

8 3.6.4 Cholesterol

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8 4 Quad Cities Nuclear Generating Station Intake Studies .....................

8 5. Impingement Data Collected During Winter 2005/2006

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10 6. Relevance to 316b Phase l ..l..... ................

.. ; ..................................

19 7. Recom edindations.....................................

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19 8. References

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20 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)Analysis of Gizzard Shad Winter Die-Off and Its Relevance To 316(b)1 Introduction

1.1 Background

Following several years of discussion, review, and revision by both regulators and the regulated community, USEPA published the Clean Water Act, Section 316(b) Phase II Rule on July 9, 2004. This rule is directed primarily at existing electric generating facilities with the objective of reducing the numbers of fish and shellfish that are removed from the source water body by the Cooling Water Intake System (CWIS) through impingement on the traveling water screens and/or entrainment of early life stages in the cooling water stream.The Rule defines Performance Standards to be met for both impingement and entrainment, criteria for qualifying for each standard, a roadmap by which to navigate through the process, generic groupings of compliance measures that are to be considered, economic valuations, and a general. instruction directed at monitoring effectiveness of compliance measures selected.

The Rule is. clear that all facilities must comply with the impingement standard but some are exempted from the entrainment standard.Central to the Rule is the determination of the calculation baseline which estimates the numbers' " of organisms that are impinged and/or entrained.

This is the set of numbers against which the Performance Standard is measured and influences compliance measures selected to satisfy the'Performance Standard.

Nearly all affected facilities have needed to conduct impingement studies (and some have needed to conduct entrainment studies) to provide current data for determination of the calculation baseline.The Rule and the text which surrounds it are silent on one aspect of counting impinged fish for computation of the calculation baseline; namely, the treatment of fish that are dead or moribund before they reach the traveling water screens during periods of winter die off. (Moribund fish are mentioned in the verification monitoring section of the Rule but only to the extent that they will need to be addressed at that time.) By its silence, the Rule infers that this decision is to be made by state Directors, who are defined in the Rule. It appears, then, that each state will need to decide how to treat these fish within the context of the Rule. More specifically, decisions need to be made about the treatment of gizzard shad in those states that are located within the northern portion of this species' geographical range and that experience large, natural winter die off of gizzard shad on an annual basis.1.2 Question The salient question is: Should dead and moribund gizzard shad be counted in determination of the impingement calculation baseline?HIDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)The simplest answer is "yes;" but that contradicts the intent of the Rule which is to reduce the numbers of live fish lost to the environment through compliance with the Performance Standard using one or several compliance measures.

That is, mortality caused by impingement is to be reduced by at least 80% and there is no benefit to be gained by including already dead or moribund gizzard shad in the computations.

Assigning some calculated monetary value to fish that have already died or are close to death is a questionable exercise that places an undue burden on the applicant.

A more practical response is "no" in those cases where a large portion of the total annual impingement, either by numbers or by weight, is composed of gizzard shad and most of them are collected in a moribund state during the cold weather period between November 1 and March 31.The latter response needs to be supported by scientific data that documents the percentages of healthy, dead, and moribund gizzard shad that are found in the vicinity of the CWIS traveling screens during the winter months and provision of physiological information that explains cold death in this species and its irreversible path in moribund specimens.

1.3 Objective The objective of this "white paper" is to provide scientific information that can be used in the decision-making process to answer .the question.

This will include a.brief history of the northerly

..range extension of gizzard shad and observations on winter behayior,.-results of a winter study -conducted at an electric generating station located on the Mississippi River which documents

.percentages of healthy, dead, and moribund gizzard shad collected before the trash racks,. and a:'.synopsis of critical physiological and biochemical pathways that. are disrupted by cold ambient'water temperatures leading to death in this more southerly species.2 Gizzard Shad Range Extension and Winter Mortality Gizzard shad, Dorosoma cepedianum, is a southerly species that began to radiate northward sometime after 1820 when it was first reported in the Ohio River near Cincinnati (Kirtland, 1844). The species continued to migrate northward through the remainder of the 1800's; and by 1900 had reached Lake Erie and southern Lake Michigan (Miller, 1960). During the second half of the 20'h Century, gizzard shad were reported from the Upper Great Lakes (Scott and Crossman, 1973; Becker, 1983) and Eddy and Underhill (1974) reported a collection being made during the decade of the 1960's in the Minnesota portion of the Upper Mississippi River.Concurrent with this range extension, gizzard shad populations in established areas began to explode during the 1950's. This trend continued for a period of over 30 years and continues today. A number of authors have suggested possible reasons for this range extension and population explosion including increased phytoplankton availability (Trautman, 1956), increased spawning habitat (Bodola, 1955), a decreased number of predators (White et al., 1975), increased areas of thermal discharge (Becker, 1983), and a documented warming trend between 1950 and 1980 (Assel, 1980). While it is difficult to separate these factors, White et al. (1986) suggest that the warming trend was a central cause. The warming that is attributed to the greenhouse gasses continues to contribute to the success of this species widely in range extension and population numbers. On a more local level, warm water discharges provide winter sanctuaries that shelter gizzard shad during the cold weather period which allows them to survive to the following season.2 FDR/ILMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)Numerous authors have reported periodic die off of this species that occurs always during the winter. Kirtland (1844) reported heavy winter kills in the Ohio River and White et al. (1986)described the winter kills as often being massive and population dependent.

Most authors noted that the die offs occurred in December during periods of rapidly declining temperatures.

This was observed annually in Crab Orchard Lake in southern Illinois (Wehr, 1976).However, rapid temperature declines were not the only phenomenon observed to be associated with the die offs. Heidinger (1983) indicated that winds that cause turnover at 40 C contribute to the die off in lakes suggesting that this may be a tipping point temperature.

Walberg (1964)reported that 100% of the 0+ age class of gizzard shad died after ice covered a South Dakota Lake for more than 103 days. Not all authors agree on specific temperatures at which these fish become disoriented and die and recovery has been observed following exposure to low temperatures for short periods of time (Neumann et al., 1977). All this suggests that several temperature parameters work in concert to cause death. In addition to rapid temperature declines, low temperatures and duration of the low temperature period both play a role in the winter mortality.

The last parameter that appears to play a role in winter mortality is size of the individual fish (Heidinger, 1983; Mayhew, 1983). Most observers have noted that the smaller individuals die first in the earlier part of the winter and.the larger individuals die later in the season. This has'been doc'umnted byý Trauan (1981) w ho -re -nr gizzard shad in Lake Erie ranged in size fromr 64 to'10 mm in length in Novemnbe but ranged from 100 to 230'm mmin length by annulus formation in the Spring. Caroots (1976) showed that Lake Erie gizzard shad&YOY.imeasured from 30 to 160 mm in October but from 95 to 165 mm by about the first of-April.' Wbile acclimation may play some role in these observations, it does not fully explain he : observatiorns., Furthermore, this is essentially a no growth period for these fish. -These data suggest. that high mortality issiize selective and that YOY gizzard shad are especially vulnerable' to winter mortality.

All authors report that, after May 1, mortality rates in the gizzard shad populations return to normal levels.Information presented in this section has been observed over a long period of time and leads to two questions.

First, what causes such large numbers of gizzard shad, particularly YOY shad, to die during the cold weather period? Second, what percentage of gizzard shad coming into CWIS are healthy during the winter months?3 Synopsis of Physiological and Biochemical Studies on Gizzard Shad Collected During the Winter Season White et al. (1986) conducted the seminal study that investigated many physiological and biochemical pathways in YOY gizzard shad during the winter period to determine why and how these fish die. They determined from literature that the YOY size range for Lake Erie gizzard shad was40-160 mm SL which, using information presented in Carlander (1969), converts to a range of approximately 50-210 mm TL.It is not the intent of this synopsis to summarize each pathway investigated; but rather, to present information concerning those that are most critical to death of individual shad. These include: 3 BDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)* Use of Total Lipids as Energy Source* Effects of Starvation on Lipid Reserves, Serum Glucose, and Total Serum Protein* Cystolic Lactate Dehydrogenase

  • Serum and Brain Glucose* Cholesterol 3.1 Use of Total Lipids as Energy Source Cold-blooded organisms survive winter in one of three ways. One is to cease feeding and become totally inactive.

A second is to remain active and feed opportunistically and the third is to cease feeding but remain somewhat active. In all three survival mechanisms, lipids are used as energy sources with some catalysis of other tissues as emergency sources of energy when lipids are depleted.

These other tissues are quickly regenerated when ambient temperatures begin to rise in the spring.Gizzard shad is a species that appears to use the third survival strategy, i.e. it remains active until temperatures approach freezing but discontinues feeding when water temperatures reach approximately 11 C (Bodola, 1966). White et al. (1986) reported that total lipid content in gizzard shad taken from Lake Erie during the October-November period ranged from 23 to 41% 1/of dry weight but that this percentage did'not: decrease over the winter and the total lipid content 'actuallyincreased slightly by March 1 which was contrary to the survival strategy.A time series experiment.

was then designed to sample gizzard shad bi-weekly throughout the following winter season to identify thewater temperature at which lipid utilization ceases and the results indicated that, when water temperatures are below 8° C, lipids are no longer utilized for energy. The result is that gizzard shad, particularly YOY shad, begin to .starve in spite of.relatively high lipid reserves.

Liver and muscle glycogens are quickly exhausted and this is followed by tissue catalysis to provide energy. Liver tissue is broken down first and is accompanied by loss of liver functions including elimination of ammonia, breakdown of bilirubin, and red blood cell lysis. By the end of winter, the liver is not recognizable and the total physiologic failure of individuals causes continuous mortality throughout the winter season. This catalysis is not reversible following long periods of cold weather.Small YOY shad were observed dying in November before water temperatures declined below 80 C and assays of these fish revealed that they had no lipids stored. It was concluded that they were hatched late in the season and food was used entirely for growth with very little being converted to lipids.3.2 Effects of Starvation on Lipid Reserves, Serum Glucose, and Total Serum Protein White et al. (1986) designed a series of laboratory experiments to determine whether gizzard shad utilize lipids at water temperatures greater than 110 C when they are starved. Results of these tests showed that that death occurred daily after about 22 days of starvation at room temperatures (20-220 C). Fish were randomly selected throughout the experiments and assayed. Data from one such experiment showed that serum glucose declined by 29.3%, total serum protein by 21.6%, and lipids by 37.9%, while serum ammonia remained essentially constant.

In a separate 4 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)progressed.

This baseline ranged from 35 to 40 mg/dl and concentrations measured during the winter months continually rose and reached levels that were about 10 times those of the active feeding periods. These high levels were indicative of some physiologic failure and the authors investigated and dismissed several possible causes including adrenal collapse, which controls catabolism of muscle tissue to serve as an energy substrate, and starvation.

As they systematically tested possible failures, it became evident that increased serum glucose levels were indicative of cell membrane transport failures, i.e. substances were not being diffused either in or out of cells and glucose was building up as a result. Cell membranes had become rigid at lower water temperatures.

Of all the body tissues, those of the central nervous system, including the brain, are the most demanding for a steady supply of energy. Due to loss of permeability of the membranes, these cells, particularly brain cells, are deprived of this energy supply. If this occurs rapidly, then the brain loses its ability to function which is manifested in loss of locomotion function and quickly thereafter by loss of equilibrium.

Individuals are observed to be swimming erratically and/or on their sides. This is often followed by a comatose condition.

Is this loss of locomotion and equilibrium attributed to a hyperglycemic or a hypoglycemic condition?

Unfortunately, both conditions manifest in similar observable behavior and the investigators found that both existed during different die-offs.

Therefore, the condition is attributable to a difference in concentrations across the membranes rather than either too much or'too:little glucose in the brain. This suggests membrane failure orutheilSS ofmembrane fluidity..

Thermal .shock that may be experienced by shad swimming init and out of thermally enhanced:`

areas would result in a hyperglycemic condition.

Because the hypoglycemic condition was also, documented, the authors concluded that die-offs are not caused by thermal shock., Combining the observations of substantial increases in serum with a hypoglycemic condition in the brain indicates that shad attempt to compensate the loss of membrane fluidity or transport by increasing concentrations outside the brain cells. This is the physiologic failure that leads to erratic swimming and the comatose condition which is quickly followed by death.3.5 Cholesterol The basic premise of functionality of biological membranes is the ability to maintain a constant fluidity, irrespective of temperature.

This fluidity is a function of the types of lipid molecules in the membrane and can be tested by measuring the cholesterol content of the serum and cell membranes, with higher, relatively constant levels being associated with individuals that are adapted and survive the winter. Conversely, individuals that exhibit low serum cholesterol concentrations at any given time during the winter are at greatest risk of dying. This, coupled with shad having the greatest degree of liver degeneration, provides the best predictor of risk of death.Shad assayed for serum cholesterol throughout the winter including prior to, during, and following die off events indicated that those which died had lower serum cholesterol concentrations than those that survived.

Because serum cholesterol levels are not quickly modified, it is possible to predict which subsets of the population are at risk by knowing the serum cholesterol concentrations.

6 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)progresses.

The biochemical information discussed in the previous chapter supports this observation.

Viewing the totals for the entire study period, 4.1% were deemed healthy while 71.1% were moribund and 22.3% were classified as dead. The remaining small percentage was either decayed or gilled.In summary, this study documents the percentages of healthy, moribund, and dead gizzard shad that were intercepted before reaching the traveling water screens during most of the cold weather period (with the exception of January).

It is reasonable to assume that the percentage of healthy shad in January was very similar to December (3.6%) and February (3.5%) and that the sum of moribund and dead shad in January was also similar to those of December (94.7%) and February (95.0%).5. Impingement Data Collected During Winter 2005/2006 As stipulated ,in the Muscatine Plant's(Navigation Pool 17) PIC, impingement collections were made weekly between June 2005 and May 2006 at all three units. When more than 30 specimens of a species were collected in a sample, a subsampling routine which selected the first 30 specimens was used to satisfy the length and weight requirements of the program. When lesk." than 30 individuals of a species were collected, all were measured and weighed.Impingement species composition and abundance data is presented by month for actual numbers.counted at each intake (Tables 5-1 through 5-3) and extrapolated to estimated total numbers and Table 4-1 Condition of Gizzard Shad Entrapped on the Barrier Net During 2-hr Sets.Quad Cities Nuclear Station -1984 Healthy Moribund No. % No. %Dead No.Decayed% No. %Gilled Total No. % No. Effort Date Fish/hr.Feb 2-hr 34 3.5 619 64.4 March 2-hr 0 o.0 0 0.0 Novei Decen Totals mber 2-hr 8 33.3 11 45.8 nber 2-hr 13 3.6 334 93.6 2-hr 55 4.1 964 71.1 294 30.6 0 0.0 5 20.8 4 1.1 303 22.3 14 1.5 o 0.o 0 0.0 0 0.0 14 1.0 0 0.0 0 0.0 0 0.0 6 1.7 6 0.4 0 12.0 24 4.0 961 12.0 80.1 0.0 6.0 357 6.0 59.5 1356 34.0 39.9 10 MDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-1.SPECIES COMPOSITION AND ABUNDANCE OF IMPINGED FISH SAMPLED FROM THE TRASH BASKET AT MPW UNIT 7 INTAKE, JUNE 2005 -MAY 2006.TAXA JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY TOTAL Gizzard shad Mooneye Cyprind spp.Silvery mimnw Sihvr cihb Emerald shiner Striped shiner River shiner Spotfin shiner Sand shiner Fadicad minnow Bullhead minnow River caxpsucker Channel catfish Stonecat Flathezad catfish White bass Yellow bass..Pumpkinseed Orangespotted sunfish Bluegil *Freshwater.dnrm N o. o f fi "i .No. of axaa Sampe volume (MGF)3 4 1 5 368 9104 10,412 8063 7999 233 1 I 1 I 3 I 4 2 2 i 4 S 1 t I I I I 2 7 36198 1 i 5 4 8 0 1 1 4 1 2 11 63 2 25.13 7 1 15 15 -227 134-' 36583 4: 21 114ý.4 -i885.6!1 16 14 4 1 I I t 1 2 1 4.2 3 6 I/4 8 3 5 I: .-S I 1 3 2 4 5 45 69 1 I 4 3 9 20 23 11 271'- 37 10 ;6 4 S'" 5 98.61 206.1 272.8. 167.8.. .4 1 4 6 13 16 385 :"i28 3 .8 28.109,3.- 136.8 206.1 I 24 ,10441 10 9.9*8082 4 108.8 8071 12 145.8 322 9 109.2 11 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-2. SPECIES COMPOSITION AND ABUNDANCE OF IMPINGED FISH SAMPLED FROM THE TRASH BASKET AT MPW UNIT 8 INTAKE, JUNE 2005 -MAY 2006.TAXA JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY TOTAL Gizzard shad Silvery minnow Silver chub Emerald shiner Striped shiner Btullhead minnow Channe cwAf*sh Flathcad catfish White bass Bluegill Largemouth bass Freshwater drum 2 6 2519 9,852 1252 686 11 1 2 14328 1 t 4 0 I I 1 3 6 3 1 1 1 1 17 2 1 1 I I I 1 2 2 7 i 94 I 3 1 1 1 56 2 10 18 No. of fish No. of taxa Sample voulume (MOW)4 I 8 9 6 3 1 4 3 3 369.8 360.3 518.3 418.5 288.4 9 2523 9911 1254 697 33 2 14457 4 5 4 2 3 5 2 11 288.0 48.0 170.7 219.2 223.8 215.3 174.5 3294.7 12 HIDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-3. SPECIES COMPOSITION AND ABUNDANCE OF IMPINGED FISH SAMPLED FROM THE TRASH BASKET AT MPW UNIT 9 INTAKE, JUNE 2005 -MAY 2006.TAXA JU.N JUlL AUGA S1P IV'T hNr-¶ VN'e I:m A W IZZO Ml F.D iVIJ J~iL% MAl T TOAL Gizzard shad Common carp Silvery minnow Silver chub Emerald shiner Striped shiner River shiner Bullhead minnow River carpsucker Channel catfish Stonecat Tadpole madtorm Fladtead caffish White bau Yellow bass Green sunfish Orangesponed sunfish Bluegill Logperch Freshwater drum No. of fish No. of Sample voulume (MGW)1 I i 1 I 10 33 9573 6.757 2690 181 1 2 1 .I 3 1 12 1 19259 1 2 1 9 2 5 I 1 5 0 I 1 I 1 1 1!!2 1 9 15 11 2 2. 1 2 7 5 17.1 3 13 6 7 9 18 14 107 2 7 1 2 4 9 6 4 6 4 .66 1 2 1 5 1 2 3!1 1 4 1 2 2. 2 1 3 2 11*1 3 '23' 18 4 1 *2 12 11 12 88 9 15 15 4 26 83 71 73 104 17 41 12 7 31 39 83 68 9629 6855 2777 282 156 47 19986 8 5 8 5 11 9 8. 7 7 7 9 12' 19 685.3 556.7 696.0. 557.5 554.6 550.6 210.6' 279.4 359.7 207.1 556.9 556.8 '5771.2 Four sampling events at Unit 9 were missed between 28 February and 19 March due to a scheduled maintenance outage.13 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)weights for the year based on intake flow (Tables 5-4 through 5-6). Lengths are presented as a length frequency table (5-7) that begins with June 2005 and extends through May 2006 and combines all the fish measured at the three units. This is intended to aid the reader in following the 2005 year class through the winter season.Inspection of Tables 5-1 through 5-3 shows the expected pattern of low gizzard shad impingement from June through the October/November period followed by dramatic increases of shad impingement during the December through March period. Based on information gathered from the literature, discussion of the breakdown of biochemical pathways and enzymes, and results of the winter study at the Quad Cities Nuclear Station on Pool 14 of the Mississippi River, it is reasonable to conclude that the preponderance of these shad were either dead or moribund at the time they were impinged during these winter months. Tables 5-4 through 5-6 show that shad impinged during the cold weather months comprised in excess of 95% of the total annual impingement collection of all species by both numbers and weight at each intake.Investigators have determined that most of the winter mortality occurs in YOY gizzard shad.White et al. (1986) defined YOY shad is those between 40 and 160 mm SL which converts to about 52 to 210 mm TL. Table 5-7 presents length frequency data (TL) by size category.

The majority of the fish that were measured were within this YOY range and as the season progressed the mean size of the fish increased.

This is consistent with the observation that smaller individuals have smaller livers and die earlier in the winter as a result of liver failure,.Conversely, larger individuals die later in the winter. because they have larger livers to provide.energy for a longer period of time'.This information supports the observation that gizzard shad in Iowa are living in the northerly portion of their geographical range and die off in great numbers when water temperatures decline first below 80 C.White et al. (1986) concluded that winter mortality is high, natural (particularly YOY), and is caused by the failure of the species to adapt to long-term cold stress in the northerly portions of its geographical range. Impingement during this winter period is composed largely (>95%) of shad that have died from long-term cold stress and other natural causes prior to being impinged.14 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-4. TOTAL ESTIMATED IMPINGEMENT (BASED ON FLOW) OF FISH COLLECTED AT MPW UNIT 7, JUNE 2005 THROUGH MAY 2006 NUMBER WEIGHT TAXA TOTAL PERCENT TOTAL (kg) PERCENT AVERAGE(g)

Gizzard shad Freshwater drum White bass Bluegill Cyprinid spp.Channel catfish Emerald shiner Silvery minnow Mooneye Yellow bass Orangespotted sunfish Pumpkinseed Siver, chub.- Flathead catfish River carpsucker Stonecat Sand shiner River shiner Fathead minnow Spotfin shiner Bullhead minnow Total Total taxa 373,248.1,854 105 122 4 428 45 35 6 8 56 8 27 222.12 i7 4 6 8 18 99.2%0.5%<0.1%<0.1%<0.1%0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.. 1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%22,743.8 48.0 5.2 0.5 0.0 12.0 0.1 0.2 1.1 0.1 0.3 0.0 0.3* .: .,_,1.5 : 0.0' 0:01 ...0.0 0.0 0.0 99.7%0.2%<0.1%<0.1%<0.1%0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1.%<0.1%<0.1%<0.1%<0,1%<0.1%<0.1%<0.1%<0.1%60.9 25.9 49.7 4.0 4.3 27.9 2.1 4.4 197.1 15.3 4.5 2.6 1i.0 6.7 4.3 11.3 2.9'2.1 2.9 1.3 376,237 21 22,813.4 15 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-5. TOTAL ESTIMATED IMPINGEMENT (BASED ON FLOW) OF FISH COLLECTED AT MPW UNIT 8, JUNE 2005 THROUGH MAY 2006 NUMBER WEIGHT TAXA TOTAL PERCENT TOTAL (kg) PERCENT AVERAGE(g)

Gizzard shad Freshwater drum White bass Bluegill.Channel catfish Emerald shiner Largemouth bass Silvery minnow Silver chub Flathead catfish Bullhead minnow Total Total taxa 155,324 836 7 59 126 24 10 10 5 28 6 156,434 11 99.3%0.5%<0.1%<0.1%0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%9,308.7 16.5.0.0 0.4 0.6 0.0 0.1 0.0 0.0 0.2 0.0 9,326.8 99.8%0.2%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%59.9 19.8 2.0 6.7 4.9 2.0 12.0 3.0 6.0 7.5 1.0 16 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-6. TOTAL ESTIMATED IMPINGEMENT (BASED ON FLOW) OF FISH COLLECTED AT MPW UNIT 9, JUNE 2005 THROUGH MAY 2006 NUMBER WEIGHT TAXA TOTAL PERCENT TOTAL (kg) PERCENT AVERAGE(g)

Gizzard shad Freshwater drum White bass Bluegill Common carp Channel catfish Emerald shiner Silvery minnow Yellow bass Orangespotted sunfish Silver chub Flathead catfish..

.Tadpole madtom.Logperch River carpsucker Green sunfish Stonecat River shiner Bullhead minnow Total Total taxa 170,370 2,900 39 598 12 774 33 58 27 71 35.497 13 8 6 14 48 7 6 175,514 19 97.1%1.7%<0.1%0.3%<0.1%0.4%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%9,432.6 62.7 3.9 4.0 0.1 5.2 0.1 0.3 0.5 0.3 0.2 8.1 0.1 0.1 2.5 0.1 0.3 0.0~0.0 99.1%0.7%<0.1%<0.1%<0.1%0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%:<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%55.4 21.6 101.9 6.7 5.3 6.7 2.6 4.6 19.0 4.0.5.1 16.3 7.6 7.0 418.0 7.3... 6.2 5.0 5.0 9,521.1 17 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-7. LENGTH FREQUENCY OF GIZZARD SHAD SUBSAMPLED FROM MPW IMPINGEMENT COLLECTIONS, JUNE 2005 THROUGH MAY 2006 TOTAL MONTH LENGTH (mm) JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY<60 60-69 3 3 4 70-79 1 7 11 1 80-89 .6 8 90-99 5 5 7 100-109 "5 3 1 3.110-119 5 3 2 120-129 1 5 8 11 2 2 1 130-139 1 2 5 9 6 4 1 1 140-149 2 4. 10 13 12 7 6 3 150-159 1 15 37 24 15 12.._ 11 .1 160-169 2 2 22 44 48 50 29 _17., 170-179 4 39 56 47 56 38 28 180-189 7 1 22 45 67 52 70 23 190-199. 10 30 53 37 40 66 15 1 200-209 2 1 10 24 36 29 23 12 1 210-219 1 8 5 22 8 14 2 220-229 2 2 "4 6 8 1 1 230-239 2 1 5 4 1 240-249 250-259 1 1 260-269 1 1 1 1 2 270-279 1 2 1 5 3 2 280-289 1 2 7 5 6 1 290-299 1 2 3 .5 3 4 1 300-309 6 2 5 5 310-319 2 3 3 1 320-329 1 3 2 1 1 330-339 1 .3 1 1 340-349 1 1 1> 350 2 3 5 2 TOTAL 4 4 31 0 17 196 336 359 314 294 126 8 MINIMUM 129 62 143 64 61 75 109 104 88 121 123 MAXIMUM 204 78 295 -203 297 406 397 427 409 322 201 MEAN 167 68 194 -104 166 179 190 191 194 183 154 18 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)6. Relevance to 316b Phase II The impingement performance standard set forth in the Phase H Rule states that impingement mortality must be reduced or offset by a minimum of 80% of the calculation baseline.

A number of operational and technological measures are available to accomplish this reduction, along with possible restoration measures should they survive the court challenge.

One technological measure is a class of technologies that return fish alive to the source water body. Returning fish that were dead or moribund before being impinged returns energy to the waterway system but has no bearing on reducing impingement mortality as stipulated in the Rule, i.e. the intended benefit is not available at the beginning of the process; and, therefore, can not be accomplished.

Similarly, implementing operational measures to reduce impingement based on these numbers of dead/dying fish also will not accomplish the intended goal of the Rule to reduce impingement mortality.

Designing restoration programs to offset losses of fish that are dead or moribund would place an undue financial burden on the applicant by necessarily over-designing the restoration program to account for dead and dying fish that were merely removed from the waterway much the same as a vacuum cleaner does -its job. Besides, restoration should offset mortality losses that result from: impingement.

The question then becomes how to best approach integrating this information into either determining .thei'calculation baseline or satisfying the performance standard, the :objective of which is to reduce impingement mortality.

.7. Recommendations There may be different approaches to answering the question; but the most direct and simplest is to eliminate dead and moribund gizzard shad collected during the winter months from the calculation baseline.

Recognizing that not all gizzard shad die during the winter, it is recommended that 4% of the numbers impinged during the November through March period be considered alive and healthy (the average for this period in the Quad Cities Station study); and therefore, included in the calculation baseline for a.generating facility.Although a late season hatch may die off during late October, it is recommended that all shad impinged from April through October be included in the calculation baseline.This approach includes those portions of the gizzard shad population which are truly at risk to impingement mortality without inflating the calculation baseline with irrelevant dead or moribund shad whose mortality is attributed to natural causes induced by long-term cold stress.The State of Illinois which shares a common border with Iowa along the Mississippi River is taking this approach.19 HDR/LMS August 2006 0 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)8. References Cited Assel, Raymond A. 1980. Maximum freezing degree-days as a winter severity index for the Great Lakes, 1897-1977.

Monthly Weather Review, 108:1440.Becker, G.C. 1983. Fishes, of Wisconsin.

Univ. of Wisc. Press. Madison, Wisc. Pp. 273-277.Bodola, A. 1955. Life history of the gizzard shad, Dorosoma cepedianum (LaSeuer) in Western Lake Erie. PhD Dissertation, Ohio State University.

Columbus, Ohio.Bodola, A. 1966. Life history of the gizzard shad, Dorosoma cepedianurn (LaSeuer) in Western Lake Erie. US Fish Wildl. Serv. Bull. 65(2):391.

Carlander, K.D. 1969. Handbook of freshwater fishery biology. Vol. 1. The Iowa State University Press. Ames, Iowa. pp. 82-89.Caroots, M.S. 1976. A study of the Eastern Gizzard Shad, Dorosoma cepedianum, from Lake Erie. MS Thesis, John Carroll University.

University Heights, Ohio.Eddy, S. and J. Underhill.

1974. Northern Fishes. University of Minnesota Press. Minneapolis, MN. P. 147.Heidinger, Roy C. 1983. Life history of the gizzard shad and threadfin shad as it relates to the ecology of small lakes fisheries.

Proc. Of Small Lakes Management Workshop -Pros and Cons of Shad. Iowa Conservation Commission and Sport Fishery Institue, Des Moines, Iowa.198 pp.Kirtland, J.P. 1844. Descriptions of fishes of Lake Erie, the Ohio River and its tributaries.

Article 7. Boston Journal of Natural History, No. 4. p. 23 1.Lawler, Matusky & Skelly Engineers.

1985. Quad Cities Aquatic Program, 1984 Annual Report.Submitted to Commonwealth Edison Company, Chicago, IL.Mayhew, J. 1983. Proc. Of Small Lakes Management Workshop -Pros and Cons of Shad. Iowa Conservation Commission and Sport Fishery Institue, Des Moines, Iowa. 198 pp.Miller, R.R. 1960. Systematics and biology of the gizzard shad, (Dorosoma cepedianum), and related fishes. Fishery Bull., US Fish Wildi Serv. 60:371.Neumann, David A., W.J. Wachter, E.L. Melisky and D.G. Bardarik.

1977. Filed and laboratory assessment of factors affecting the occurrence and distribution of gizzard shad (Dorosoma cepedianum) at Front Street Steam Electric Generating Station, Erie, Pennsylvania.

Pennsylvania Electric Company.Scott, W.B. and E.J. Crossman.

1973. Freshwater Fishes of Canada. Fish Res. Bd. Canada, Ottawa. Bulletin No. 184. pp. 133-137.20 HDRfLMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)Trautman, M.B. 1956. The Fishes of Ohio. Ohio State University Press. Columbus, Ohio.p. 182.1981. The Fishes of Ohio. Ohio State University Press. Columbus, Ohio. p.201-204.

Walburg, C. 1964. Fish population studies,Lewis and Clark Lake, Missouri River, 1956-1962.

Spec. Sci. Rpt., US Fish WildI. Serv. No. 482: 1-27.Wehr, Larry W. 1976. Osmotic variation of serum of gizzard shad, Dorosoma cepedianum, in relation to seasonal temperature changes. PhD Dissertation, Southern Illinois University.

Carbondale, IL.White, A.M., M.B. Trautman, EJ. Foell, M.P. Kelty and R. Gaby. 1975. Water Quality Baseline Assessment for the Cleveland Area -Lake Erie. Vol. IH. The fishes of the Cleveland metropolitan area including the Lake Erie shoreline.

USEPA Report: EPA-905n5-001.

White, A.M., F.D. Moore, N.A. Alldridge and D.M. Loucks. 1986. The Effects of Natural Winter Stresses on the Mortality of the Eastern Gizzard Shad, Dorosoma cepedianum, in Lake Erie. Submitted to The Cleveland Electric Illuminating Company, Cleveland, Ohio and The Ohio Edison Company, Akron, Ohio. 209 pp.21 HDR/LMS August 2006 APPENDIX E Correspondence and Telephone Call Records Concerning Coffey County Lake and Fisheries W1 LF CREEK NUCLEAR OPERATING CORPORATION Kevin J. Moles Manager Regulatory Affairs JAN 1720 RA 07-0004 Kansas Department of Health and Environment Bureau of Water -Industrial Programs.1000 SW Jackson St., Suite 420 Topeka, Kansas 66612-1367 Attention:

Mr. Eric Staab

Reference:

Letter from E. C. Staab (KDHE) dated 11/22/06 to J. E. Werner (KCPL) confirming makeup to La Cygne Lake from the. Marais des Cygnes River constitutes a water transfer..

Subject:

Request for a letter from KDHE confirming makeup from the......: .Neosho River to Coffey County Lake is a water transfer.

Dear Mr. Staab:

Based on a conversation with Ralph Logsdon on January 9, 2007, Wolf Creek. Nuclear.Operating .C0poration (WCNOC) requests a letter confirming Kansas. Department of Health-t.and Environment's (KDHE)positionon water. transfers.

The Wolf Creek Generating Station (WCGS) Makeup Water Screenhouse (MUSH). on the Neosho River is used on occasion to add water to Coffey County Lake (CCL). Although Coffey County Lake was constructed as a cooling lake for the WCGS it is considered a Water of the State. The pumping of water from the Neosho River to CCL is a transfer from a Water: of the.State to another Water of the State. Therefore, this -is actually a water transfer -and not-considered a direct use of water by WCGS. .WCNOC understands that water. transfers are not governed by. NPDES .permitting, and therefore exempt from the requirements of 316(b). WCNOC is requesting written confirmation

-of this position similar to that sent to Kansas City Power and Light in the reference.

If you have any questions regarding this request, please contact Mr. Ralph Logsdon at. (620):364-8831., extension 4730.Sincerely, Kevin J. Moles KJM/rll cc: Don Carlson/KDHE-BOW P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HC/VET

. ~- 'State of Kansas lV .CIED..; ' DEPARTMENT OF HEALTH& E IRONMENT , V:'.,i IG.To ka. Kansas I,* .-. ' -" I --l " 1 "II/ ;Ki" ., D E ..-* It I .I" 4/;13 December 1974_-V,& /.1 -10 Mr. Glenn Koester :"'L -Kansas Gas & Electric Co. " P. 0. Box 208 -.. .. ".E. " Wichita, Kansas 67201 Re: Wolf Creek Generating'Station i i.

Dear Mr. Koester:

We

-..74 wherein o4-.status inorain-~te~n~ad~i

_W~t .1iW1 Supplemental to the information provided, copies of the actual contractual agreements are desirable for documentation purposes...

This request of course- excludes any confidential informa-tion..* o~ur enar..the

~Wo ire --generating,. .s.t n as .t:u ctiogn as .defi~nefi in .Sec~tio .Xat ) an&4 wls.,,epn a-hn The federal standards bf performance for"new sources" of the Electric Power Plant Generating Guidelines, pub-lished in the Federal Register in October 1974, Volume 3+9.+'No.

196, Section 423.13(1) states that ;

ox f~t~Ct~d Thb~b~ -ef r-c ed regWlatinn' zhall. bre -e~r pt" r:the provx.s.ions o ection 316 (a " -9 , .as .oiitrtuc tion egun.-prir to A ecve e.. .. W.e. are ere.. hrt0A i&o7.u We appreciate very much your cooperation in this matter.Very truly yours, Melville W. Gray, P. E.Director Division of Environment TO WG: ht cc: Ralph.Langemeier South Central District Office Slate of Kansas...

ROBERT F. SENNETT. Governor DEPAITMENT OF HEALTH ArD ENVIRIONfMEIIT DWIGHT F. METZLER. Secretary Topeka. Kansas 66620 ' -""* February 21, 1975.Mr. Mike Miller /Environmental Coordinator

,.Kansas Gas & Electric Company Post Office Box. 208 Wichita, Kansas 67201 Re: Wolf Creek Generating Station

Dear Mr. Miller:

In *response to your request for a formal statement by the Kansas Department of *Health and Environment on the possible recreational uses of the Wolf Creek, facility, the following is offered.It is the Department's hope that the impounded water and the adjacent land to the lake will be utilized to its fullest extent from the standpoint of providing a public recreational area and/or a fish rearing facility for the Kansas Fish and Game Commission.

As stated in the previous meetings concerning the Wolf Creek Generating Station, we are of the opinion that the Kansas Gas and Electric Company controls the impounded water and thus will not be held responsible If its degradation is such that the water becomes unsuitable, as outlined by Regulation 28-16-28 of the Kansas Department of Health and Environ-ment, for body contact sports or fishing. As I have expressed in previous meetings, the water quality of the cooling lake shall be maintained so as to not adversely affect, in the judgement of the Kansas Department of Health and Environment, the ground water. It is also our opinion that the Kansas Gas and Electric Company shall not be held responsible for the loss of fish in the lake due to cold shock kill, impingement, or entrainment.

4 Sincerely your,: " " Melville W. -Gray, P.Director Division of Environment , '; .ij.MWG:jac ';." * *'- I.'o.

rUUM iUS bc- Gerald Charnoff I KANS GAS AND ELECTRIC COMPANY* RFosrer P.o. Box 208 Witcha. Kansas 62201 P.V ohs LY'.larr is.Ella 11 JOArterburn

.Rl-lagan GBoy.erv O April 4, 1975 M r. .Mel.'4E W .Cray , P.E. "'.Director,.

Division of. Environment State Department of Health and Environment 6 Forbes Air Forc.e" Base, Building 740Kansas 66620 Re: Wolf Cre'k Generating Station

Dear Hr. Gray:

We have r-eceived your letter of Decem.ber 13, 1974, and note your--finding that the Wolf Creek Generating Station began. construction,.

8as defined in Section 306(a) of PL. 92.-500 (the Federal Water Pol-lution Control Act, as amended), of its cooling impoundment system prior t~o the effective date of 40 CFR 1423. We further note your concurrence with our conclu'sions set forth in my letter to you of November 14, 1974.Therefore, we"are relying onyour letter *of *ecember 13, 1974, as indicating that, pursuant to Effluent Guidelines and Standards for the Steam Electric Generating Point Source Category promulgated by the'United States Environmental Protection Agency on OctoberS, 1974-(39 F.R. 36186), as corrected (40 F.R. 7095),..the Wolf Creek Generating Station is exe-.pt from any limitation on the discharge of heat.Sec*tion 316(s) of the FWPCA contains no effluent limitations.

Section 316(a) provides procedures pursuant to which a p.ermittee may'obtain the relaxation of a propozed therfmal effluent limitation

  • which is :aore stringent than necessary to insure the protection and propagation Iof abba].anced, indigenous poptilation of shellfish, fish, and wildlife in and on the body of water into which the discharge in to be made. Because the Wolf Creek Generating Station is exempt...from any limitation on thermal discharge, Kansas Gas and Electric Company is not planning to develop the type of demonltratyon required by Section 316(a).~Sincerely yours, 11-.'. L. NGLM~i-L CLK:bb

-Slate of Kanlsa ...1 ROBERT F. BEN~NETT.

Governor)EPAlTM H~T. OF HEALTH A H D U ~V I RONhE "NT DWIGHT F. L#ETZLER.

Secretary Topeka. Kansas 66620 (A1~1!175 April 10, 1975 cc: Gerald Charnoff RFoster 'Mr. Glenn L. Koester RVohs Kansas Gas & Electric Company ilarris Post Office Box 208 .ESl1all .-. _: Wichita, Kansas 6720.1 JOArterburn j -..Rilagan Re: Wolf Creek Generating Station GUoytr : ....-...-_ i_'--.--.. .til 11e

Dear Mr.. Koester:

.... 4/i1/75.bb

..-.We are in receipt of your letter addressed to Mr. Melville W. Gray, da -ed , April 4, 1975. In your letter the following statement appears."Therefore, we are relying on your lette-r of December 13, 1974, --.as indicating that, pursuant to Effluent Guidelines Point Source ,_ -----Category promulgated by the United States Environmental Protectio

-*.---------

Agency on Octob'er 8, 1974, (39 F.R. 36186) as corrected (40 F.R.7095), the Wolf Creek Generating Station is exempt from any limitation on the discharge of heat.".This statement is essentially correct in that Mr. Gray's'letter, tb you dated December 13, 1974, is intended to exempt. the Wolf Creek Generating Station from only the Federal limitations dealing with the discharge of heat from Steam Electric Generating Point Sources. As we have pointed out in previous meetings, between the Kansas Gas and Electric Company and the Kansas Depart-ment of Health and Environment, the exemption from any Federal limitation-on the discharge of heat does not in any way exempt or imply that the Wolf Creek* Generating Station is exempted from the Water Quality Criteria for Interstate and Intrastate Waters of Kansas as outlined in Regulation 28-16-28.

A copy of this regulation is enclosed.If you have any questions, please contact our office. Telephone number (913)296-3825.Sincerely yours, Division of Environment

' .]Donald R. Carlson Saaitary Engineer I.,r..+/-r 'ollution.

Control ".DRC:.jac F1~*t.

'~~C 41Z4.LS l Kansais. .noj3ERT F. BENNETT, Governor DWIGHT F. METZLER. Secretary Topeka. Kansas 66620.cC -G L Koester J 0 Arterburn F.ebruary 3, 1976 G D Boycr R Hagan/A Snyde: R Foster..R Vohs D T McPhee (4)Mr. Michael Miller G.Chanoff Enviro rn.mental Coor di a o u .-- G Charnoff *...Cdinator ".' Important Kansas Gas and Electric Company /.DounC) .t File-Post Office Box 208 / Document File W ichita , Kansas 67201

  • m". .,.e.'

Dear Hr. Miller:

'..In response to your inquiry concerning the clarifcation of the locations at which the Kansas .ater Quality Criteria and the proposed National Pol-lutant Discharge Elimination System (NPDES) permit will be enforced, the following is offered: The Water Quality Criteria of the State of Kansas will be enforced in the Neosho River, below the confluence of the W.olf Creek, except for an appropriate mixing-.zone.

The State Water Quality.Criteria will not apply to the Wolf Creek, which is unclassified under the State Water Quality Criteria.In general, the effluent limitations to be stipxilated in the National Pollutant Discha'rge Elimination System .(NPDES) permit will apply at the point the cooling lake di'scharges into Wolf Creek.If you have any questions, please contact our office. (913) 296-3825.Sincerely yours Division of Environment Donn td R. Carlson Snailary Enginoer Water Pollution Control DRC: nb REGIONAL OFFICES: K a n sas P ISPfNorthwest Regional Southwest Regional Office Ri. 2. 183 Bypass 808 Highway 36 Ga 6Dodge City. Kansas 67801 Northcentral Regional Office Southcentral Regional Office BX GBtO 489. 53J Cedar Box 764. 204 West Sixth BOX 54A. RURAL ROUTE 2. PRATT. KANSAS 67124 Concordia.

Kansas 66901 Newton, Kansas 67114-Northeast Regional Office Southeast RAegional Office (316) 6725911 3300 S W. 29th Street 222 West Mtai Building Topeka. Kansas 66614 Suite C & D__....._C hanute. Kansas 66720 May 24, 1983 Mt. Greg Wedd K G & E Education Center P.O. Box 309 Burlington, KS 66839

Dear Greg:

This letter is to initiate a cooperative agreement or understanding between your agency and the Kansas Fish and Game Cam-ission to allow access for Fish and aGme personnel to the cooling reservoir.

This request is made based on the past demonstrated cooperation between our agencies.

It also has foundation in that the Kansas Fish and Game Ccmission, primarily through the efforts of Leonard Jirak, have played an integral part in the development of the reservoir fishery which in-cluded 1) direct assistance in literature review, rehabilitation, stocking and sanpling, 2) technical assistance in management decisions, I 3) location of private fish stocking sources and assisting in. fish trades, 4). savings in stocking costs of several hundred thousand dollars, 5) assistance in generating a positive image through programs and news media concerning the project, 6) advice in developmlent of a fishery designed to benefit the operation of the plant.We request agency access for and through Leonard Jirak to the reservoir for the following purposes:

1) collecting fish for brooders and other Fish and Game management needs such as special species stockings, 2)access for education p'urposes to allow demonstration of the. effective-ness of the ibplemented fishery management plan of the reservoir to other professionals and administrative personnel that would be beneficial in advancing the knowledge and effectiveness of fish management prac-tices.All visits to the reservoir would be preceded by contact with you at least one week in advance for your concurrence.

Sampling gear utilized would include standard fisheries management gear and would include same angling.Certain areas could be designated as off-limits if necessary.

Hopefully, saoe arrangement for access without going through the actual "plant site" could be considered.

I To: Greg Wedd Fran: Bruce Taggart May 24, 1983 Page 2, continued The entire management concept for the current existing fishery was based on our recaomendations from years of management experience.

We feel the request for. our agency's access will enable us to build on that management experience.

We appreciate your cooperation and consideration on this request.Please advise us as soon as possible of yo-r decision.Sincerel, SNce Tag"r Regional Fisheries Supervisor Southeast Region, BT/kg Kansas tish BO Game BOX 54A, RURAL ROUTE 2, PRATT, KANSAS 67124"(316) 672-5911 REGIONAL OFFICES:@Northwest Regional Office Rt. 2, 183 Bypass Hays, Kansas 17601 Northcentral Regional Office Box 489, 511 Cedar Concordia, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeka, Kansas 66614 September 10, 1984 Southwest Regional Office 808 Highway 56 Dodge City. Kansas 67801 Southcentral Regional Office Box 764, 204 West Sixth Newton, Kansas 67114 Southeast Regional Office 222 West Main Building Suite C & D Chanute, Kansas 66720 Mr. Greg Wedd KG&E Education Center P.O. Box 309 Burlington, KS 66839

Dear Greg:

By way of this letter. w6;-ie reqUsng pe sion to collect 2,000 adult largemouth bass and:.500.:adult-smallmoxuth bass fran. your cooling reservoir.

In order to collect tbd~e fish efficiently, w6ewuldlike to bring in our three electrofishing boatsaInd a

týuck to haul fish. We would also appreciate.your participationo ond your,ýlectrofishing equipment, how-ever, this 'is not- a p'reequisit-for our n We would request to collect these fish during a, two-week period from October 198 i in'O. .oghO 14 Depending upon our success, we may need to return in April of 1985 -to colec additional fish.Please advise.u as soon as possible'on your consideration of this request.Thanks.Sinceey Leonard Jirak District:.Fisheries Biologist.;N Strawn District Office LJ/kg cc:. Bruce Taggart Kansas lish&B Game BOX 54A, RURAL ROUTE 2, PRATT, KANSAS 67124 (316) 672-5911 REGIONAL OFFICES: Northwest Regional office Rt. 2, 183 Bypass Hays, Kansas 67601 Northcentral Regional Office*Box 489, 511 Cedar Concordia, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeka, Kansas 666'14 4;O75-4 Southwest Regional Office 808 Highway 56 Dodge City, Kansas 67801 Southcentral Regional Office Box 764i 204 West Sixth Newton. -Kansas 67114 Southeast Regional Office 222 West Main Building Suite C & D Chanute, Kansas 66720 October 15, 1984 Greg Wedd Environmental Biologist Wolf Creek Power Plant Box 444 Lebo,. KS 66856 -.

Dear Greg:

I want this.lettei to expresso..

r appreciation for Kansas Gas and Electric CarPany, s: coopef'ation:

and, assistance in obtaining the 655 .adult black bass-frd.

your dooling resevoir last Friday.Fish and Game staff inolved were not 0only:,irressed with the lake and its fishp..opulation, ',but- also. the very efficient and hardworking Kansas Gas Caopany staff.This. type of project persoifies the type of cooperation that has existed betwenour agencies on fish management activities on your inpoudent In omy opinion, the sportfish population in the reservoir now.

e in the state. Kansas Gas and Electric Ccmpany has.- indeed :done -an: extremely cammhdable job on the fishery.Once again,. thanks, for thefish and the good help.Sincerely,.

Regional Fisheries Supervisor Southeast Region BT/kg cc: Jim Beam Leonard Jirak Kansas Ash& -Game BOX 54A, RURAL ROUTE 2, PRATT, KANSAS 67124 (316) 672-5911 REGIONAL OFFICES: Northwest Regional Office Rt. 2, 183 Bypass Hays, Kansas 7601 Northcentral Regional Office Box 489, 511 Cedar Concordia, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeka, Kansas 66614 Southwest Regional Office 808 Highway 56 Dodge City, Kansas 67801 Southcentral Regional Office Box 764, 204 West Sixth Newton, Kansas 67114 Southeast.Regional Office 222 West Main Building.Suite C & D Chanute, Kansas 66720 April 29, 1985 Greg Wedd P.O. Box 444 Lebo, KS 66856

Dear Greg:

-This letter is:to acknowledge and. thank you for your assistance in obtaining:

blac, crappe br ish for'our hatchery needs at Farlington.

Once .assistance very much appreciated.

sihncerely,'Bruce Taggart" , .~ýegional Fisheries Supervisor Bouteast Region BT/kgf REGIONAL OFFICES:&a hNorthwest Regional Office Southwest Regional Office K Rt. 2,183 Bypass 808 Highway 56 G aeHays, Kansas1 7601 Dodge City, Kansas 67801 Northcentral Regional Office Southcentral Regional Office e G an e Box 489, 511 Cedar Box 764, 204 West Sixth BOX 54A, RURAL ROUTE 2, PRATT, KANSAS 67124 Concordia, Kansas 66901 Newton, Kansas 67114 Northeast Regional Office Southeast Regional Office (316) 672-5911 3300 S.W. 29th Street 222 West Main Building.Topeka, Kansas 66614 Suite C & D Chanute, Kansas 66720 June 13, 1985 Mr. Greg Wedd Environmental Section Kansas Gas & Electric Corpany Wolf Creek Generating Station.Box 444 Lebo, .KS 66856

Dear Greg:

-The fishery in the Wolf Creek developed as planned and even better thanh'expectedý.'-,.

The Kansas Gas and Electric Company staff is to be coamended -for-their concern and response 'in,.developing the reser-voir resource to its fullest-potenital.'.":

The original plan was to build a high density predator fish poPuiationi to, control rough fish and gizzard shad densitie3s.

recisel.y-.what.

c-i:tan place., The plan also called for us6eof the "sportfish

-,.for rilod stock'in other, state waters and has~he au.",ocrrd.

byth public for this has also o-,ccurred.

The.. lake wads -,also' to -be ue ytepbi o fishing ifI NiRC.and KG&E regulations y 'ould allow it.The survival and the subse quentdensity of prdacious fish has been ex-tremely high and initial groýwh was excelient.

and has remained good.The fishery has-a now reached, apopuaton:.:nsity and biomass where sane type of major harvest would ..be:: beneficial..,The lake has been full for four years and .thebiaas of the sportfish population has reached or is near its peak. At the same time the lake's 'carrying capacity is most likely declining....

It is my concern that these f sh".hav:reached.

a critical bicomass that the aquatic system will now be hard pressed .to maintain.

Growth of inter-mediate size and smaller gamefish has, slowed and will become severely depressed.

I expect that the body condition of all but the very largest predacious fish will decline noticeably by late sumner. Considering the decreased body condition and high density there is a strong potential for winter stress, disease transmission, and significant fish mortality.

This is a problem that is poorly documented in any literature.

This problem is rare because very few fisheries managers have been successful in producing such a high biomass of sportfish.

Most that have, intended the fishery for public use and angler harvest has prevented the fish population from reaching the proportions of the standing crop at Wolf Creek. Those that have not allowed public utilization most likely did not expend the effort to have a quality fishery as you have.

To: Greg Wedd Fran: Leonard Jirak June 13, 1985 Page 2, continued The potential problem that exists needs to be anticipated in time to re-medy the situation.

Once a massive die off is observed, little can be done to change the situation.

As in most animal populations the end result is a lower population than would have occurred if *moderate removal had occurred.The action necessary is much like the initiation of the pre-inpoundment management program where problems were circumvented and management strategies were desighed to take advantage of opportunities as they became available.

I suggest that the fish population be monitored closely over the next several months to observe if this problem continues to develop, and that remedial action be taken before a very valuable resource is lost. If the Kansas Fish and Game Cammrission can be of any assistance, please feel free to request our help.Sincerely, Leonard Jirak District Fisheries Biologist New Strawn District Office LJ/kg cc: Bruce Taggart Kansas Pish&,..Game BOX 54A, RURAL ROUTE 2. PRATT, KANSAS 67124 (316) 672-5911 REGIONAL.

OFFICES: 0 Northwest Regional Office Rt. 2, 183 Bypass Hays, Kansas 67601 Northcentral Regional Office Box 489, 511 Cedar.Concordla, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeka, Kansas 66614 Southwest Regional Office 808 Highway 56 Dodge City, Kansas 67801 Southcentral Regional Office Box 764. 204 West Sixth Newton..Kansas 67114 Southeast Regional Office 222 West Main Building Suite C & D1 Chanute, Kansas 66720 September Us, 1985 Greg Wedd P.O. Box 444 Lebo, KS 66856

Dear Greg:

We would like to electrofish

  • and transport fish fromn your lake on the 19th and 20th -of .ptember, ..1985. We have- aneed for 1,000 largemouth bass adults,'.

200 ;.-,s iuth bass adults, 1,000 wipers, 200* black crappie,, and 200 wte crappie. If we are unsuccessful or incarpleteý-iini.our.results, we" would also: like to try. again in October afteýr it coo-ls off.. T hanks for your consideration of this request./ ,< ...........

.. ..Bruce Taggart Regional, Fisheries Supervisor Southeast Region BT/kg Kansas Ash& Game BOX 54A, RURAL ROUTE 2. PRATT, KANSAS 67124 (316) 672-5911 REGIONAL OFFICES: Northwest Regional Office Rt. 2, 183 Bypass Hays, Kansas 7601 Northcentral Regional Office Box 489, 511 Cedar Concordia, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeka, Kansas 66614 Southwest Regional Office 808 Highway 56 Dodge City, Kansas 67801 Southcentral Regional Office Box 764, 204 West Sixth Newton, Kansas 67114 Southeast Regional Office 222 West Main Building.Suite C & D Chanute, Kansas 66720 February 1:7, 1986.Greg Wedd Wolf Creek Educational Center Box 309 Burlington,.

KS 66839

Dear Greg:

We would like to."obt aintwelve

ý(12) large feemale and.four (4) male striped bass frar your .lake the last week of April....;'These fish will be spawned for striped bass production in Kansas. Please let me know if this can be worked in. T-hanks.--'.-..

Sincerely Bru Supervisor Regiona Fisheries Supervisor Southeast Region BT/kg cc: Leonard Jirak, Kansas Ish B Game BOX54A, RURAL.ROUTE 2, PRATT, KANSAS 67124 (316) 672-5911 REGIONAL OFFICES: 0 Northwest Regional Office Rt. 2, 183 Bypass Hays, Kansas 67601 Northcentral Regional Office Box 489, 511 Cedar, Concordia, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeka, Kansas 66614 Southwest Regional Office* 808 Highway 56 Dodge City. Kansas 67801 Southcentral Regional Office Box 764," 204 West Sixth Newton, Kansas 67114 Southeast Regional Office 222 West Main Building Suite C & D Chanute, Kansas 66720 March 27, 1986 Greg Wedd Wolf Creek Educational Center Box 309 Burlington, KS 66839 Gregg: Thank you for your assistance in obtaining largemouth bass fran Wolf Creek. We stocked 455.largemouth that averaged two pounds-each. The following, is. a, b own 1. of where the fish went: Montg :yStat'e-Fishing LeLa .-150 Neosho State Fi6hingLake

-250-Neosho Rearing Pond ., 55 The fish in: the Neosho Rearing .Pond will be used to evaluate mor-tality and survivors will be stocked at the Mined Land Wildlife Area..-Sincerely, Bruce Taggart* Regional Fisheries Supervisor Southeast Region BT/kg Kansas Fish WSOUTHEAST REGIONAL OFFICE 222 W. MAIN BLDG. SUITE C&D, CHANUTE, KS 66720 (316) 431-0380 W--March 23, 1987 Greg Wedd Wolf Creek Educational Center Box 309 Burlington, KS 66839

Dear Gregg:

Thank you for *your assistance in obtaining fish from The following is a breakdown of where the fish went: Date Location 2-25-87 MLWA MLWA Farlington 3-5-87. NOSL NOSL WOSL Big Hill Ponds Species LM B Wipers Stripers Number 366 33 21 Wolf Creek.Size 2-7 1 bs.3 lb. ave.5 lbs. ave.C CAT LM B LM B LM B 11 59 135 117 2-10 lbs.2 lb. ave.2 lb. ave.2 lb. ave.All of the stripers died at Farlington.

It is believed that hauling stripers and largemouth together from where they were collected to the hatchery truck caused the mortalityy.

In the future, striper brooders will be moved independently.

The 'only other fish loss was about six largemouth bass.Sorry for the delay in getting this information to you.Sincerely, Bru e Regional Fisheries Supervisor Southeast Region BT/kg cc: Steve Mense Leonard Jirak Rob Friggeri EQUAL OPPORTUNITY EMPLOYER Kansas Fish S2SOUTH EAST REGIONAL OFFICE e 222 W. MAIN BLDG. SUITE C&D, CHANUTE, KS 66720 (316) 431-0380 June 24, 1987 Greg Wedd and Staff Wolf Creek Education Center Box 309 Burlington, KS 66839

Dear Gregg and Staff:

We commend your effort in helping supply quality fish for the John Redmond Kid's Fishing Derby. It has become a huge success mainly due to the qualiity of fishing experienced by those young children that participate.

Most of the fish in the pond a big thanks from the Kansas fishing kids.were provided from W.C.G.S. Again, Fish & Game Commission and all the Sinc (pl Leonna Jirak District Fisheries Biologist New Strawn, KS 66839 i/kg cc: Bruce Taggart EQUAL OPPORTUNITY EMPLOYER I!I1E REGION 5 OFFICE P.O. Box 777 Chanute, KS 66720 316-431-0380 Equal Cpportunity Employer WILDLIFE.4:PARKS I qc1 77!April 1, 1997 qr1.7~ 6 Brad Loveless Wn7f rreek Lake% Leonard Jirak 540 16th Road NW Hartford, Ks. 66854 Brad, On behalf of Public Wholesale Water Supply District #11 and the anglers of southeast Kansas, I would like to whole-heartedly thank you for permitting us to collect smallmouth bass adults from Wolf Creek Lake for stocking into the recently constructed Bo~ne eqk Lake (540 acres). Hopefully these fish will soon s provide an exciting sportfishery in two years when the lake opens to fishing.Leonard was able to collect a total of 40 fish ranging in size from 8-15 inches. The fish hauled very well and looked to be in excellent condition when stocked into Bone Creek.Lake.

Again, thanks for providing us with these fish. Anglers should reap the benefits of your generosity for many years to come.Sincerely, Rob Frigg,ý Y Dist. Fisheries Biologist Pittsburg (!KANSAS OUTDOORS "America's Best Kept Secret" Kansas Ash.&,.Game BOX 54A, RURAL ROUTE 2. PRATT, KANSAS 67124 (316) 672-5911 REGIONAL OFFICES: Northwest Regional Office Rt. 2, 183 Bypass Hays, Kansas 67601 Northcentral Regional Office Box 489. 511 Cedar Concordia, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeka, Kansas 66614 Southwest Regional Office 808 Highway 66 Dodge City, Kansas 67801 Southcentral Regional Office Box 764; 204 West Sixth Newton, Kansas 67114 Southeast Regional Office.222 West Main Building Suite C & D Chanute, Kansas 66720 New Strawn February 23,1988 Mr. Greg Wedd Environmental Section Kansas Gas & Electric Company Wolf Creek Generating Station Box 44 Lebo, KS 66856....~ ~ ~~~. ;.>i./::./

....:..............Dear Greg;Following our,. discussion

'on moving fish from Wolf Creek to our public fishing lakes I. have compiled.

the ýfollowing list: Montgomery SFLý 250 La,.Irg'emouth

~bas's Woodson SFL 250 argemou th-bass Strewn CityiLake 50 i-Largemouth bass 50 wipero 25 large channel' cat.Lairds Pond.........

50 wipers 100..channe1-cat The largemouth need-to be a minimum of 12 inches to be in the protected size range..The wipers:. and- channel catfish can be any size with the larger catfish going :toStrawn city lake. We would be ready to move these fish at your convenience.

Thanks in Advance!inc rely Leonard Ji ak District Fisheries Biologist STATE OF KANSAS* 7 -. DEPARTMENTuOF WILDLIFE & PARKS -MoundCity District Office Courthouse.

315 Main Mound City, KS 66056 PH: 913.795.2218 FAX: 913.795.2889 To: Wolf Creek Nuclear Operating Station DanWtlliamson, Environmental Section Burlington, KS From: Don George -, Fisheries Biologist KS. Dept. Of Wildlife & Parks 315 Main.Mound City, KS. 66056 Date: 04-15-1998

Dear Mr. Wiliamson:

I am requesting permission to obtain up to 75 smallmouth bass adults from Wolf Creek Reservoir.

This mission will be conducted by Leonard Jirah and I will assist. It is my goal to obtain this sample before these fish spawn. The smallmouth bass collected will be placed into LaCygne Reservoir to compliment the stocking that occurred in 1997. Thanks for your assistance with this project.

IMA~t; REGION 2 OFFICE 3300 SW 29TH TOPEKA, KS 66614.4 (913) 273-674066614 Equal Opportunity Employer WILDLIFE Richard Sanders 2512 Cimarron Dr.Lawrence, KS. 66046 January 22, 1991 Brad Loveless Wolf Creek Nuclear Operating Corp.P.O. Box 411 Burlington, KS 66839

Dear Brad,

Your cooperation in supplying fishes for the Topeka Boat Show made the display tank a success. Species and numbers of fishes displayed included: I. Morone spp. -8 2. Drum -1 3. Bluegill'-

I 4. Black Crappie -1 5. Walleye -6 6. Flathead Catfish -3 7. Channel Catfish -3 8. Smallmouth Bass -5 9. Largemouth Bass -15 Thanks, for your assistance.

Sincerely, Richard Sanders cc: Steve Hawks KANSAS OUTDOORS "America's Best Kept Secret" K3A REGION 2 OFFICE 'K3300 SW 29TH TOPEKA, KS 66614-2053 (913) 273-6740 " MAR 21993 i Equal Opportunity Employer ..:-' I'ARKS Richard Sanders 2512 Cimarron Drive Lawrence, KS 66046 February 26, 1993 Brad Loveless Wolf Creek Nuclear Operation.

Corporation P.O. 411 Burlington, KS 66839*

Dear Brad,

Thanks, for allowing Kansas Department of Wildlife &.Parks to collect display fish from Wolf Creek for use at the Topeka Boat.and Outdoor Show. Dan put us on the fish right away and we got a good representation of Kansas sportfish.

The display was a hit with the public. If my memory is correct, the following fish were used in the display: Species Number Largemouth Bass 13 Smallmouth Basss 5 Wiper 5 White Bass 2 Blue Catfish 1 Flathead Catfish 1 Common Carp 2 Smallmouth Buffalo 1 Bigmouth Buffalo 1 Again, thanks for your cooperation.

Sincerely, Richard Sanders cc: Leonard Jirak Steve Hawks KANSAS OUTDOORS "America's Best Kept Secret" STATE OF KANSAS 93- o/ 29Y 01 Joan Finney Governor DEPARTMENT OF WILDLIFE & PARKS OPERATIONS OFFICE Rt. 2, Box 54A Pratt, KS 67124 -9599 (316) 672-5911 / FAX (316) 672-6020 Theodore D. Ensley Secretary Brad Loveless Supervisor, Environmental Management Wolf Creek Nuclear Operating Corp.P.O. Box 411 Burlington, KS 66839 August 31, 1993

Dear Mr. Loveless,

The recent flooding appears to have had a detrimental affect on the Department's walleye management programs.

Our biologists have reported that Glen Elder and Lovewell reservoirs, our primary sources for walleye egg collection, have experienced severe losses of adult fish.Complicating the situation is the fact that many other State Fishing Lakes and federal reservoirs also lost walleye. This will result in sharply increased stocking requests to rebuild these populations.

We would like to explore the possibility of collecting walleye eggs from the Wolf Creek Cooling Lake next spring. Our biologists would capture walleye using modified fyke nets, strip the eggs, and then release the fish. The eggs would then be transported to our Milford Hatchery for production of stockable fry.Department policy has been to stock fry back into lakes where egg taking occurred to insure we have no negative impact on donor lakes' recruitment.

We would gladly set aside a portion of the fry produced for returnto Wolf Creek.The Department and the anglers of Kansas would be grateful to Western Resources for considering this request Please contact me if you have any questions.

Sincerely, Douglas D. Nygren Fisheries Management Liaison xc: Joe Kramer Jim Beam Steve Adams Leonard Jirak Larry Tiemann VftI..4LF CREEK NUCLEAR OPERATING COROA(O Warren B. Wood August 10, 1995 Generl CounW wWl Secretary GC 95-0132 File No. 40.004.01 Kansas Department of Wildlife and Parks Route 2, Box 54A Pratt, Kansas 67124-9599 Attention:

Mr. Doug Nygren:

Subject:

Proposed Wolf Creek Lake Angling Regulations

Dear Mr. Nygren:

Wolf Creek Nuclear Operating Corporation (WCNOC) proposes that the angling regulations that appear on Exhibit 1 attached to this letter be adopted by the Kansas Department of Wildlife and Parks (KDWP) beginning in 1996 for Wolf Creek Lake. These regulations were designed by WCNOC and KDWP biological staff with the primary goal of preserving the existing fishery.This fishery supports power plant operation by biologically controlling excessive numbers of.gizzard shad in the cooling lake. The proposed regulations will also allow for a small amount of harvest from a primarily catch-and-release fishery that many anglers can enjoy for a long time.We look forward to working with KDWP to provide this recreational opportunity to the general public. If you have any questions on the proposed regulations, please feel free to contact Brad Loveless (316) 364-8831 extension 4530.Very truly yours, Warren B. Wood WBWrjaf cc: Leonard Jirak (KDWP)James Cambell (Coffey County Attorney)P.O. Box 411 / Burlington.

KS 66839 / Phone: (316) 364-4105 An Equal Opportunity Employer M/FIHCNET EXHIBIT I to GC 95-0132 PROPOSED CREEL AND SIZE REGULATIONS FOR WOLF CREEK LAKE August 8, 1995 Maximum Minimum Total Channel, blue and flathead catfish (any combination) 2 any size White bass 2 14 Wiper hybrid 1 24 Largemouth bass 1 21 Smallmouth bass 1 18 Crappie (black or white) 2 14 Walleye 21 No creel or minimum length limits will be imposed on any other species.

Mound City District Office Courthouse, 315 Main -Mound City. KS 66056 Ph. 913/795-2218 FAX 913/795-2889 To: Wolf Creek Nuclear Generating Plant Brad Loveless, Chief Biologist Burlington, KS.From: Don George, District Fisheries Biologist.

Mound. City, KS.Topic: Smallmouth Bass Request Date: 05-08-97 Mr. Brad Loveless: With this letter I am requesting permission from the Managers of Wolf Creek to obtain 250 adult Smallmouth Bass. These bass will be transported and stocked into La Cygne Reservoir.

As the Department's Liaison to the Wolf Creek Nuclear Generating Plant is Leonard 'irah, I am sending this request through him. With this letter I am asking Leonard to forward this request and obtain permission from the proper authorities in scheduling this project.Thank you for your assistance with this project.

The Worldwide Authority on Bass Fishing P.O. Box 10000 e Lake Buena Vista, Florida 32830. (407) 566 2277

Dear Mrs. Smith:

BASS/ESPN Outdoors, the worldwide authority on bass fishing, has a 35-year history of supporting fisheries and aquatic resource conservation.

We represent over half a million bass anglers across the United States. Through our BASS/ESPN Outdoors Conservation program, we work closely with state and federal agencies to protect and promote sportfishing and to conserve and improve our nation's fisheries resources.

Because of this interest, I am writing to express our concerns and opinion regarding selected provisions of the final Phase II rule under Section 316(b) of the Clean Water Act. We are aware that several concerned stakeholders groups, including Riverkeeper, have filed suit to prevent implementation of the Phase II rule in its current form. BASS is not party to any of these filings. Conversely, there are specific elements of the Phase H1 rule we support.Trillions of aquatic organisms are killed annually by impingement and entrainment (I&E) in power plant cooling-water intake systems. Compliance with Phase H rule provisions could achieve dramatic reductions in aquatic organism mortality.

The intent of the rule is to protect aquatic organisms from the impacts of large power plant coolant-water intake systems (CWIS), approximately 135 of which are located on lakes or reservoirs.

As we understand the rule, Phase II establishes three categories for covered electric power plants, as well as three compliance alternatives.

The second category (lakes and reservoirs other than the Great Lakes), and the compliance alternative allowing for selection and implementation of restoration measures, are the focus of our comments.Despite the contentions of Riverkeeper and others, BASS feels strongly that the restoration option in the Phase II rule will be appropriate in some cases, and can be very beneficial for some lake and reservoir systems. We feel it should remain an option, as currently stated in the regulations.

According to a 2001 U.S. Fish and Wildlife Service survey, 85% of the nation's anglers fish on lakes, reservoirs or ponds, excluding the Great Lakes. It cannot be denied that impingement in power plant cooling-water intake systems on power generation reservoirs can have a substantial effect on fisheries and the overall ecosystem.

However, habitat decline is the real culprit in the decline of sport fisheries on most reservoirs, especially those built prior to the 1960's. Flooded terrestrial vegetation that provided excellent habitat for juvenile and adult fish has long since decayed, leaving many reservoirs without physical Bassmoster Magazine *BASS Times-

  • Fishing Tackle Retailer'
  • Bassmaster's' Techniques
  • The Bassmasters on ESPN2 o bassmaster.com habitat. On these reservoirs, with the exception of high water years that flood terrestrial vegetation, there is little or no cover for young fish to use to escape from predators, resulting in low recruitment.

Other reservoirs have become overrun with aquatic nuisance vegetation, impacting all recreational uses.States lack the money or resources to implement massive habitat restoration efforts on these large waterbodies.

Federal agencies responsible for many of these reservoirs receive little funding to enhance recreational fishing. Hydropower, navigation and flood control receive priority.BASS feels that all alternatives need to be available to mitigate for the impacts of power plants.Restoration should be available as a compliance alternative, especially if there are not readily available technological or operational fixes. Using habitat restoration as a compliance alternative will yield net benefits to the fishery resource, increasing survival of spawned fish, leading to increased recruitment, which essentially contributes to replacing organisms lost by impingement.

Indirect benefits of habitat restoration can include increased fishable areas; improved angling success; added habitat for waterfowl, birds and other animals; and improved water quality and aesthetics.

Habitat restoration can provide benefits in perpetuity, with decreasing cost to the utility over time.In many cases, restoration will be a better option than actually reducing impingement mortality.

Most reservoir fisheries have evolved under the influence of these power generation facilities.

Your own estimates are that 98% of the fish affected by facilities in inland waters are non-game species. Often these are species whose impingement numbers are low in relation to their overall population size. While many are important forage species, they are species having typically high reproductive rates, and their abundance is generally limited by other factors such as habitat availability.

In some cases, natural and other mortality actually exceeds impingement mortality.

In one study of two Texas reservoirs, the number of fish consumed by cormorants exceeded the number of fish impinged by power plants [PBS&J. 2003.Comprehensive Aquatic Surveys ofBraunig and Calaveras Lakes Data Report. Prepared for City Public Service of San Antonio].The need to revitalize habitat on aging reservoirs is an overwhelming problem. If restoration remains a compliance alternative in both Phase II and Phase III rules, the potential outcome could be millions of dollars for aquatic habitat restoration.

This would represent only a fraction of the costs of retrofitting or changing operational practices.

Without the restoration alternative, consumers will likely absorb the expense of modifications that have no measurable benefit to reservoir fisheries.

Loss of fish habitat across the nation is recognized as a critical issue for fish and wildlife managers.

Lost habitat undermines the health and productivity of aquatic systems and dependant fish populations.

Declining fish habitat also diminishes aesthetic and angling opportunities, undermining the ability of states to deliver quality public outdoor recreational opportunities.

In recognition of this, in 2003 the International Association of Fish and Wildlife Agencies committed to taking a leadership role in the development of a National Fish Habitat Initiative (NFHIl), modeled after the highly successful North American Waterfowl Management Plan. BASS is proud to serve as a member of the NFHI Partnership Council, working to develop a comprehensive national strategy to conserve and enhance fish habitat. We feel that all options for enhancing fishery resources need to be available as part of this national strategy, including a restoration alternative for I&E impacts.Thank you for the opportunity to comment. If you would like further discussion, I can be reached at noreen.k.clough@bassmaster.com, or 334-551-2422.

Sincerely,/s/NOREEN K. CLOUGH Conservation Director BASS/ESPN Outdoors Logsdon Ralph L From: Williamson Daniel L Sent: Thursday, July 28, 2005 2:53 PM To: Hammond Robert A Cc: Haines Daniel E; Logsdon Ralph L

Subject:

Support for 316(b) Restoration FYI. Published in the July 25, 2005 EEl EnviroWeek newsletter.

Mary T. Smith EPA 316(b) Letter On July 7, Noreen Clough, Conservation Director for BASS/ESPN Outdoors (The Worldwide Authority on Bass Fishing) sent Mary Smith, Director, Engineering and Analysis Division, EPA Office of Water and lead HQ 316(b) contact a letter (see below) stating that despite the contentions of Riverkeeper and others, BASS feels strongly that the restoration option in the Phase II rule will be appropriate in some cases, and can be very beneficial for some lake and reservoir systems. BASS feels it should remain an option, as currently stated in the regulations.

MaryTSmithEPA31 61tr._BASS.pdf 1

DATE: 8/4/05 TIME: 1330 TE: TE: Telephone Call Record TO: Steve Adams FROM: Dan Haines COMPANY: ADDRESS: TELEPHONE NO:

SUBJECT:

Kansas Dept of Wildlife and Parks Office of the Secretary, Topeka, KS 785-296-0019 Steve Adams was called to confirm KDWP reporting, expectations for fish kills on Coffey County Lake due to cold shock or impingement.

KDWP partners with the Kansas Department of Health and Environment of fish kill investigations.

It was explained that such events are not currently reported based on: 1. KDHE position that lake is private, thus fish are not regulated.

2. KDHE 1975 letter stating that WCGS is not responsible for the loss of fish in the lake due to cold shock kill or impingement.
3. NRC FES evaluation expecting such cold shock events, and subsequent NRC direction to not report unless significantly greater than evaluated.

In addition, procedures direct WCNOC to report such events if significant using these guidelines:

1. event possibly receiving news media attention 2. event offsite 3. event greater than previously evaluated Steve Adams agreed with the current reporting procedures, and stated that there are no KDWP regulations requiring WCNOC to report cold-shock fish kill events. KDWP would like a courtesy call if such events might be observed by the public.ACTION REQUIRED AND DATE: No actions required.DISTRIBUTION:

Bob Hammond (CC EM)Records Management File 21.16 Ralph Logsdon (CC-EM)(Signature)

DATE: 8/4/05 TIME: 1400 TE: TE: Telephone Call Record TO: Steve Haslouer FROM: Dan Haines COMPANY: ADDRESS: Kansas Dept of Health and Environemtn Topeka, KS TELEPHONE NO: 785-296-0079

SUBJECT:

Steve Haslouer was called to confirm KDHE reporting expectations for fish kills on Coffey County Lake due to cold shock or impingement.

Steve Haslouer works with fish kill investigations for the KDHE, which partners with KDWP. It was explained that such events are not currently reported based on: 1. KDHE position that lake is private, thus fish are not regulated.

2. KDHE 1975 letter stating that WCGS is not responsible for the loss of fish in the lake due to cold shock kill or impingement.
3. NRC FES evaluation expecting such cold shock events, and subsequent NRC direction to not report unless significantly greater than evaluated.

In addition, procedures direct WCNOC to report such events if significant using these guidelines:

1.2.3.event possibly receiving news media attention event offsite event greater than previously evaluated Steve Haslouer agreed with the current reporting procedures, and stated that there are no KDHE regulations requiring WCNOC to report cold-shock fish kill events. He agreed with Steve Adams of the KDWP that a courtesy call if such events might be observed by the public would be appropriate.

ACTION REQUIRED AND DATE: No actions required.DISTRIBUTION:

Bob Hammond (CC EM)Records Management File 21.16 Ralph Logsdon (CC-EM)(Signature)

APPENDIX F MAKEUP WATER SCREENHOUSE 316(b) DETERMINATION oK-oooSS KANSAS Kathleen Sebelius, Governor Roderick L. Bremby, Secretary DEPARTMENT OF HEALTH AND ENVIRONMENT www.kdheks.gov January 23, 2007 Mr. Kevin J. Moles Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 RE: Wolf Creek Generating Station (WCGS) 316(b) Water Transfer Information NPDES Permit No. I-NE07-PO02

Dear Mr. Moles:

KDHE has reviewed the letter dated January 17,2007 regarding the referenced facility.

KDHE concurs with WCGS's finding that the intake on John Redmond Reservoir constitutes a water transfer and not a direct use of water by the power plant. As such, the John Redmond Reservoir intakes are not cooling water intakes subject to 316(b).If you have any questions in regard to this issue, please feel free to call me at (785) 296-4347.Sincerely, ECS:es pc: Eric C. Staab, P.E.Industrial Programs.

Section Bureau of Water Northeast District Office Ralph Logsdon, WCGS John Dunn, EPA Region VII KDHE, BOW, IPS CURTIS STATE OFFICE BUILDING, 1000'SW JACKSON ST., STE. 420, TOPEKA, KS 66612-1367 Voice 785-296-5545 Fax 785-296-5509 WES'F:CREEK 1 NUCLEAR OPERATING CORPORATION Kevin J. Moles Manager Regulatory Affairs JAN 17 200 RA 07-0004 Kansas Department of Health and Environment Bureau of Water -Industrial Programs-.

1000 SW Jackson St., Suite 420 Topeka, Kansas 66612-1367 Attention:

Mr. Eric Staab

Reference:

Letter from E. C. Staab (KDHE) dated 11/22/06.

to.J. E. Wemer (KCPL) confirming makeup to La Cygne Lake from the. Marais des Cygnes River constitutes a water transfer.

Subject:

Request fora letter from KDHE confirming makeup from. the Neosho River to Coffey County Lake is a water transfer;

Dear Mr. Staab:

Based: on. a conversation with Ralph 'Logsdon on January 9, 2007, Wolf Creek. Nuclear.Operating.

Corporation (WCNOC) requests a letter confirming.

Kansas. Department of .Health...

and Environment's (KDHE) position on water. transfers.

The Wolf Creek Generating Station (WCGS) Makeup Water Screenhouse (MUSH) on the Neosho River is used on occasion to add water to Coffey County Lake (CCL). Although Coffey County Lake was constructed as a cooling lake for the WCGS it is considered a Water of the State. The pumping of water from the Neosho River to CCL is a transfer from a Water: of the.State to another Water of the State. Therefore, this -is actually a water transfer -and not considered a direct use of water by WCGS.WCNOC understands that water transfers are not govemed -by NPDES -permitting, and therefore exempt from the requirements of 316(b).- WCNOC is requesting written confirmation

  • of this position similar to that sent to Kansas City Power and Light in the reference.

If you-have .any questions regarding this request, please contact Mr. Ralph Logsdon at.. (620) 364-8831., extension 4730.Sincerely, Kevin J. Moles KJM/rll cc: Don Carlson/KDHE-BOW P.O. Box 411 / Burlington, KS 66839 I Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HC/VET KANSAS RODERICK L. BREMBY, SECRETARY KATHLEEN SEBELIUS, GOVERNOR DEPARTMENT OF HEALTH AND ENVIRONMENT November 22, 2006 Mr. Joseph E. Werner KCP&L P.O. Box 418679 Kansas City, MO 64141-9679 RE: LaCygne 316(b) Proposal Information NPDES Permit No. I-MC18-POOI

Dear Mr. Werner:

KDHE has reviewed the Proposal for Information Collection (PIC) dated March 31, 2006 for the referenced facility and the Errata transmitted by letter dated.October 16,2006. Additional clarifications are included KCP & L's letter to EPA dated October 18, 2006 and EPA's response dated November 15,2006...

KDHE concurs with EPA's finding that the intake on the Marais des Cygnes River constitutes a water transfer and not a direct use of water by the power plant.. As such, the Marais des Cygnes River intakes are not cooling water intakes subject to 316(b).KDHE approves the errata modifying the original PIC. KDHE understands that KCP & L has proceeded with implementation of the PIC. However, the issue of how the sampling data will be used to develop the calculation baseline and demonstrate impingement mortality reduction remains somewhat unclear.This issue in part remains unresolved in EPA guidance on the subject. It is anticipated that this issue will be resolved as data is generated, evaluated and presented as part of the Comprehensive Demonstration Study.Once KCP & L resolves the issue of how the sampling data will be calculated to demonstrate compliance, the PIC will be approved.If you have any questions in regard to this issue, please feel free to call me at (785) 296-4347.Sinc erely, " Eric C. Staab, P.E.Industrial Programs Section Bureau of Water ECS:es pc: Northeast District Office John Dunn, EPA Region VII KDHE, BOW, IPS DIVISION OF ENVIRONMENT Bureau of Water -Industrial Programs Section CURTIS STATE OFFICE BUILDING, 1000 SW JACKSON ST., STE 420, TOPEKA, KS 66612-1367 Voice 785-296-5545 Fax 785-296-0086 http://www.kdhe.state.ks.us low UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION VII 901 NORTH 5TH STREET KANSAS CITY, KANSAS 66101 5 NOV 200 Mr. Joseph E. Werner Senior Environmental Biologist Kansas City Power and Light P.O. Box 418679 Kansas City, MO 64141-9679

Dear Mr. Werner:

In your letter, dated October 18, 2006, you requested clarification on the applicability of the Phase 11316(b) regulations to a water intake on the Marais des Cygne River. The Kansas Department of Health and Environment (KDHE) is the permitting authority for the National Pollutant Discharge Elimination (NPDES) permit program in the state of Kansas. I did. some regulatory research and discussed my findings with Eric Staab with K.DHE. The KDHE agrees with the finding that I am sharing in this letter.The intake on the Marais des Cygne River is used on occasion to add water to La Cygne Lake. The La Cygne Lake was constructed as a cooling lake for the La Cygne Generating Station and is a Water of the State. The KCPL provided basic data on the operation of the river intake and asserted that the intake was a water usage commensurate with a closed-cycle system, and therefore, exempt from 316(b) coverage.The transfer of water from the Marais des Cygne River to La Cygne Lake is a transfer from a Water of the State to another Water of the State. This is a water transfer and not a direct use of water by the powerplant.

At this time, water transfers are not covered by NPDES permitting.

Recently, EPA public noticed a rulemaking which confirmed that NPDES regulations would not apply to water transfers.

The public comment period has closed and the rule is expected to be finalized in early 2007.La Cygne Lake is a Water of the State, so the 316(b) rules still apply to the cooling water intake for the La Cygne powerplant.

..... If you have questions, please callne at 913:55-7.594, 9... ...... ........Sinc ely, hnA. Dunn Er Environmental Engineer Wastewater and Infrastructure Management Branch cc; Eric Staab, KDHE" .JECVCLER MB FIBER October 18, 2006 John Dunn U.S. Environmental Protection Agency, Region VII 901 North Fifth Street Kansas City, KS 66101 RE: Clean Water Act 316(b) "Proposal for Information Collection" Kansas City Power & Light La Cygne Generating Station La Cygne, Kansas

Dear Mr. Dunn:

To aid in your evaluation of Kansas City Power and Light's request to have the Marais des Cygne River intake exempt from Section 316(b) requirements, the following additional information including historical data on withdrawals and river flows is provided, as you requested.

The La Cygne Generating.Station uses La Cygne Lake as the source and receiver of once-through condenser cooling water. Sometimes, water outputs from the lake exceed water inputs. To maintain the water level in La Cygne Lake for normal plant operations, recreational use, and fish and wildlife habitat, water is occasionally pumped from the Marais des Cygne River to La Cygne Lake. If flow in the Marais des Cygnes River will not support pumping,, then assurance releases are requested.

This withdrawal is supported by the purchase of assurance storage space in Melvern and Pomona lakes.Withdrawal rates range from approximately 25.8 MGD with one pump to approximately 38.7 MGD for two pumps. Historic water withdrawal rates, as reported to the Kansas Department of Agriculture, Division of Water Resources, from the Marais des Cygnes River were evaluated for the period of 2002 through 2005. Daily river flow data from the U.S. Geological Survey river gaging station 06915800 Marais des Cygnes River at La Cygne, Kansas were obtained for the same period. This gaging station is located where State Highway 152 crosses the Marais des Cygnes River just west of La Cygne and approximately 5.7 river miles upstream of the La Cygne Lake intake (Figure 1).Monthly withdrawals from the Marais des Cygne River ranged from 0 to 1,122.41 million gallons (MG) (Figure 2a) and averaged 207.44 MG. No withdrawals occurred in 31 of the 48 months during this period. Concurrently, monthly flows in the Marais des Cygnes River ranged from 1,162 to 274,014 MG (Figure 2b) and averaged 31,368 MG.Over the period of record, total flow in the river was 1,505,650 MG and total withdrawal was 9,957 MG or 0.66 percent of the river's flow.

A- Withdrfawal from Marais des Cvnne River 5 1,200 c 0 E 1,ooo 0=* 800" 600 W 6 400 o 200 0 0.... .........300,000 0 E 250,000 i_L 200,000 0-.2150,000 0, 5 100,000 0 S50,000 S 0 B. Flow in Marais des Cygnes River"V N " " M M MV MV '0 V~* Vq V~ W to U) to c 75 Figure 2 Monthly withdrawals from and flow in Marais des Cygnes River, 2002 through 2005 The design intake rate for the cooling water intake at the La Cygne Generating Station is 1,186 million gallons per day. This daily cooling water intake rate is slightly greater than the maximum monthly withdrawal rate from the Marais des Cygne River recorded during 2002 through 2005 (1,122.41 MG). The maximum monthly river withdrawal rate is 3.2 percent of the monthly design cooling water intake rate (1,186 X 30 = 35,580 MG).The average Marais des Cygne River monthly withdrawal rate (207.44 MG) is only 0.6 percent of the open-cycle cooling withdrawal rate. The relative amount of water withdrawn for closed-cycle cooling (i.e., cooling towers) is typically about 5 percent of that used for open-cycle (i.e., once-through) cooling. Even at the maximum rate, therefore, the withdrawal rate by Marais des Cygne River intake is commensurate with a typical closed-cycle cooling system. As such, the Marais des Cygne River intake complies with Section 316(b) performance standards at 40 CFR 125.94(a)(1)(i) and should be exempt from the Section 316(b) Comprehensive Demonstration Study.As we have previously discussed, we also wish EPA Region VII to consider the fact that the Marais des Cygne River intake is part of a water transfer system and that the water transfer system was not a point source of pollution.

As such, the water transfer system and the intake are not subject to the National Discharge Pollutant Elimination System (NPDES). Because Section 316(b) regulations are administered under the NPDES, the Marais des Cygne River intake cannot be considered subject to the Section 316(b)regulations.

I hope you will find this information useful in evaluating our request to have the Marias des Cygne River intake exempt from Section 316(b) requirements.

Please call me at 816-654-1741 if you have any additional questions regarding this request. I look forward to your decision.Sincerely, KANSAS CITY POWER & LIGHT Joseph E. Werner Senior Environmental Biologist Cc: Chris Dubinick (KCP&L)Greg Howick (Bums and McDonnell)

31. Possible cold shock impacts to gizzard shad is mentioned in Section 2.2 of the ER (WCGS, 1990). If there have been any incidents of cold shock to gizzard shad or other fish, please provide supporting data.

Aquatic Ecology Page 2 of 3* Drawings and a detailed description of the circulating water system/service water system/essential service water system." Discharge Monitoring Reports for the last 12 month period." Whole effluent toxicity testing documentation or reports conducted at the facility (and as specified in the facilities National Pollutant Discharge Elimination Systems [NPDES]permit).-Item D.21 of the Facilities NPDES permit states that information required by the 316(b)Phase II regulations shall be submitted to Kansas Department of Heath & Environment.(KDHE) in accordance with the dates indicated in the Phase II regulations.

Please describe the steps conducted to date by WCNOC to comply with this permit requirement and provide any data collected to date in support of this submission." Current and historic flow records for the Neosho River.* A statement is made in the 5th paragraph of Enclosure 2 to WM 06-0046 (November 17, 2006) that the state of Kansas has not required entrainment monitoring and will not require it for the 316(b) determination.

Please provide documentation from KDHE regarding this issue.* Larval fish monitoring data as described in Paragraph 6 of Enclosure 2 to WM 06-0046 (November 17, 2006).-If available, information on the location of the spawning areas for the various fish species in CCL.* Bathymetric map of CCL." Available information regarding the initial stocking of CCL and subsequent stocking efforts.* Available information regarding trends in the Neosho River fish populations.

  • As discussed in Enclosure 1 to WM 06-0046 (November 17, 2006); please provide any information available regarding WCNOC's stakeholder participation in the Watershed Restoration and Protection Strategy.-Additional details regarding the detailed assessment of impingement currently being prepared by WCNOC staff (as cited in Enclosure 3 to WM 06-0046, November 17, 2006).-Possible cold shock impacts to gizzard shad is mentioned in Section 2.2 of the ER (WCGS, 1990). If there have been any incidents of cold shock to gizzard shad or other fish, please provide supporting data.-Within Section 2.2 of the ER, it is noted that WCNOC develops annual fishery monitoring reports and management plans. Please have available the most recent publication of each of these reports.

Aquatic Ecology Audit Needs request #63"A mention is made in Section 2.2 of the ER (WCGS, 1990) of possible cold shock impacts to gizzard shad. Have there been any incidents of cold shock to gizzard shad or other fish? If so, please provide supporting data." The reference to possible cold shock impacts to gizzard shad as it relates to Section 2.2 of the ER is unclear. The citation "WCGS 1990" could not be found in Section 2.2 of the ER. There is inference in Section 2.2 of the ER (Operating License Renewal Stage) to gizzard shad's vulnerability to cold shock (second complete paragraph on page 4 of 52).The inference relates to the natural mortality of gizzard shad to wintertime water temperatures, the increased potential for impingement this may cause on the circulating water intake screens, and the associated operational challenges such impingement may cause.In the circulating water discharge area of Coffey County Lake (CCL), which is influenced by thermal discharges, cold shock potential is present. This is most likely during colder winter periods when fish are attracted into that portion of the lake. After plant shutdowns during such times, thermal discharges stopped, which can subject fishes to potential rapid decreases in water temperature, and cause cold shock mortality.

Such plant shutdowns have occurred during cold-water temperatures since Wolf Creek Generating Station (WCGS) operation began. Not all resulted in cold shock mortality to fish. Each incidence of cold shock mortality that has occurred was evaluated to determine if the event was greater than expected in the original licensing evaluation (see Final Environmental Statement related to the Operation of WCGS, NUREG-0878).

Reviews of such evaluations were provided in the Annual Environmental Operating Reports required by Environmental Protection Plan, Appendix B to the Facility Operating License.There have been seven fish kill events attributable to cold shock influences between September 1985 and January 2007. Copies of WCGS internal evaluations of these events are attached as supporting data for cold shock effects to gizzard shad and other fish during each incident.

None were considered to have greater impacts to the CCL fishery than previously evaluated.

0~ /71O)ffV~kV'c~

KSF-LEl REV 1/85 KANSAS GAS AND EEECTRIC COMPANY WOLF QSK ~TDI MD. 86 -08 Peslutian Appfyd by SE24 EN D

  • i N NONOOwMPLI C RmEPOR 1. Sumnary of Initial Norxrmpliance and Ieference Critieria:

Between January 8 and 23, maintenance on all three circulating water pumps caused 3 approximately 10 0 F transients in the discharge cove. As a result, approximately 4,845 qizzard shad were killed. An accurate estimate of total mortality and impact is very difficult, but it is judged to be insiqnificant in this case. Nevertheless, per EPP Section 4.1, this fish kill should be reported via this noncompliance report.Does this event violate Environmental Protection Plan (EPP), criteria?Yes D X_Dom n this fcn uplinwof involve evirnmesntal impat reqiriM rvtfi~icnof NBC (per EPP)? Yes NO) X Does this nrncxmpliance require ruieevent (per EPP)?Initiated by: Greg Wed Date: 2/14/86 supplenental evaluation a a non-Yes ND X Assigned to: Greq w%1d GroI: Env. Mgt.2. Chrm-logical Record of 0orrective Action: 1/16/86 -1/17/86 -2/13/86 -dead shad were observed in the discharge cove talks with WCGS maintenance personnel indicated that additional work would be performed on 1/23/86 and would not be necessary again for several months.Envirormental evaluation campleted (see attached report).3. Comments: esolved D~te7 Report on the Wolf Creek Generating Station Fish Kill of January 1986, Associated Events, and Potential Mitigative Measures Proximal Events On January 16, 1986, Environmental Management personnel were collecting temperature data in the WOCL discharge cove and noticed a number of dead gizzard shad scattered around the cove's northern portions.

It was suspected that the 10 0 F transient experienced on January 10 and 15 due to maintenance on a circulating water pump may have been the cause. During the afternoon of the 16th, personnel walked along the cove's entire north shoreline from a position on Don't Point opposite the end of Baffle Dike B to Laydown Point (See Figure 1), counting dead and dying fishes, noting their sizes, and approximating the time since death. The counts were as follows: Gizzard shad 4213 Channel catfish 12 Striper 6 Walleye 5 Black crappie 4 Largemouth bass 1 Of the gizzard shad, approximately 3,033 (72%) had been dead less than one week. The remaining 1,180 (28%) were judged to have been older and 115 (3%)were not yet completely dead. Approximately 5% of the shad were less than 200mn, with 20% being 200-250mm and the remainder larger. All of the remaining gamefish species were in advanced stages of decomposition, indicating more time since their deaths. The wind, as measured by RRIS, was south-southwest at 21 mph.After the third circ water pump had undergone maintenance on January 23, an additional count was made on a portion of shore 0.28 mile long from the tip of Stringtown Point west on an area cleared of previously killed fishes. A total of 81 new gizzard shad were found which, when compared with the'previous count for this area and this percentage extrapolated relative to the total initial count, equalled 632, bringing the total of both kills to 4,845 gizzard shad.Between January 8 and 23 on consecutive weeks, each of the three WCGS circ-ulating water pumps were taken out of service for preventive maintenance.

Pump B on January 8 was secured at 0446 and put back in service on January 10 at 1932. The initial discharqe temperature increase was 7 0 F, and the temperature decrease was 9 0 F when the pump was put back into service. On January 15, pump A was secured with a resultant temperature rise of 10 0 F and at 1640, it was restarted with a discharge temperature drop of 10 0 F.Lastly, on January 23, pump C was secured at 0553 and restarted at 2110, but no temperature data was collected.

Page 2 Environmental/Chemical Parameters Wintertime attraction of fishes to heated discharges has been often docunented and was predicted to occur in the W1CL discharge cove KG&E 1981, NRC 1975, NRC 1985. Significant mortality was expected due to cold shock in the event of a midwinter plant trip (Appendix B of the Wolf Creek operating License), and is assumed that the potential for mortality due to small transients from operations such as pump maintenance was included in this assessment.

Gizzard shad have been shown to undergo loss of equilibrium or death at drops of 2 0 C (Agersborq 1930) and 11-13 1/2 0 C (Cox and Coutant 1976). Marked temperature rises, although to a lesser degree, have also been shown to cause mortality (review in Prosser and Brown 1961).Interestingly, Aqersborg (1930) noted of heat-shocked fish: "Fish dying in this way remained for many days without decomposing, even when kept in the laboratory with ordinary room temperature, indicating, it seems, that a certain deqree of coagulation of the protoplasm had. taken place just prior to death. Rigor uotis was much more vigorous in such fish than in individuals caught alive and left to die on land. In the latter, decomposition was very evident on the second day." This tends to weaken our field estimates of time-since-death, so we place little confidence in them.The loss of equilibrium stage is particularly important in a discussion about gizzard shad because lab studies indicate that it is very seldcm that shad fully recover once this stage is reached (Cox and Coutant 1975). In a lake situation such as at Wolf Creek, the probability of being washed onshore or to a zone of even colder water is high, further reducing survival chances. Additionally, fish floating aimlessly due to cold shock have been documented to have a higher risk of being preyed upon (Coutant et al. 1974, Coutant et al. 1976, Wolters and Coutant 1976). Warmwater discharges have been often documented as winter predator attractors (Ash et al. 1974, Glass and Maughan 1985) and Wolf Creek's has concentrated larqemouth bass and all Morone species since mid-December (KG&E in prep.). Hence, an abundance of predators, particularly largemouth bass and striped X white bass hybrids, exists in the discharge cove.Another environmental consideration in this assessment must be natural mortality of shad in the discharge cove. Rouqhly 2f% of largemouth bass electroshocked behind the discharge wingwalls had bulging bellies and/or a fish tail prortruding from their mouths (KG&E, in prep.) Almost without exception, those prey checked were gizzard shad. January largemouth bass populati.on estimates for the immediate discharge, using the Petersen method (Everhart and Youngs 1981), were 3968 + 237,134 and 4650 + 267,676. While the value of estimates with such wide Zonfidence intervals is limited, the average of these two numbers was used for our projections.

If 4,300 largemouth bass is assumed to be the population size and 20% of these were typically full, approximately 860 bass were full at any given time. Data fran Molnar and Tolg (1962) indicated that at January discharge temperatures, largemouth bass would digest shad-sized prey at a rate of 1 per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or a total of 860 would have been removed per day.

Page 3 Unusually warm temneratures in January were due to consistently southerly winds. Environmental Management records indicate south-southeast to south-southwest winds throughout the weeks when pump maintenance was being performed.

Consequently, deposition of dead fishes was considered most probable on the north shore of the discharge cove, where counts were made.Environmental Impact The total of 4,845 gizzard shad counted on the discharge cove shoreline during the final two weeks of January pump maintenance is not a large number by fishery management standards (Bruce NGS 1977, Ecological Analysts 1983).Winterkills of much larger maqnitude are commonplace in the midwest (Bodola 1966) and seldom of concern. Based on the projection of gizzard shad predation in the discharqe cove, the magnitude of the documented winterkill would be exceeded in 6 days. Therefore, while the ocmbination of plant-induced, shad mortality and predation may have long-term detrimental effects on the WCCL fishery, the magnitude of the documented winterkill is believed to be the smaller camponent of this impact.Mitigation Measures to mitigate subsequent gizzard shad winterkills could include efforts to reduce both the frequency of maintenance and the magnitude of resultant transients.

The need for frequent maintenance on circulating water pumps will decline drastically in the future due to changes in upkeep and an increase in preventative maintenance (T. Deddens, pers. comm.). Thus maintenance will be more often performed at times of our choosing when impacts are least likely, such as late spring through early fall. Second, varying power level while turning pumps on or off could decrease cold and heat shock mortality by reducing the magnitude of temperature changes, but coordination of plant systems to achieve this would be very difficult and the benefits realized would likely be small. Thus, increasing pump'reliability, a course of action already begun, is viewed as the most promising mitigative measure.Conclusion In Wolf Creek as in many midwestern reservoirs, the gizzard shad is the primary forage species for predatory gamefishes.

But, due to their prolific nature (Cross and Colins 1975), ability to reproduce successfully with relatively few adults (Anderson 1973), common, massive winterkills (Bruce NGS 1978, Ecological Analysts 1983), and their high, natural mortality in WCCL due to discharge cove predation, this thermally-induced fish kill is judged to be insignificant to the WCCL fishery and specifically to its gizzard shad population.

Signature:

A,, pl" _Date:

Agersborg, H. P. K., 1930. Influence of Temperature on Fish. Ecology 1i:136-144.

Anderson, R. 0., 1973. Axplication of theory and research to manaqemdnt of warmwater fish populations.

Trans. Am. Fish. Soc. 101(1):164-171.

Ash, G. R., N. E. Chymko, and D. N. Gallup, 1974. Fish kill due to a "cold-shock" in Lake Wabanun, Alberta. J. Fish. Res. Board Can. 31:1822-1824.

Bodola,,A., 1966. Life history of the gizzard shad, Dorosoma cepedianum (LeSeur), in Western Lake Erie. U.S. Fish and Wildl. Serv. FishBul.65(2) :391-425.Bruce Nuclear Generating Station, 1977. Fish Impingement at Bruce N. G. S.Ontario Hydro, Ontario, Canada.Coutant, C. C., H. M. Ducharme, and J. R. Fisher, JR., 1974. Effects of cold-shock on vulnerability of juvenile channel catfish (Ictalurus punctatus) and largemouth bass (Micropterus salmoides) to predation.

J.tfsh Res. Board Con. 31:351-354.

Coutant, C. C., D. K. Cox, and K. W. Moored, Jr., 1976. Futher studies of cold-shock effects on susceptibility of young channel catfish to predation in Thermal Ecology II, G. W. Esch and R. W. McFarlane, eds.Cox, D. K. and C. C. Coutant, 1976. Acute cold-shock vesistance of gizzard shad in Thermal Ecology II, G. W. Esch and R. W. McFarlane, eds.Cross, F. B. and J. T. Collins, 1975. Fishes of Kansas. Univ. of Kansas, 189 pp.Deddens, T., personal communication.

Maintenance contractor, Wolf Creek Generating Station.Ecological Analysts, 1983. Gerald Gentleman Station Imoact Assessment of the 1982 Fisheries Year-Class, Sutherland Reservoir, Report to Nebraska Public Power District, Columbus.Everhart, W. H. and W. D. Youngs, 1975. Principles of Fishery Science, 2nd ed. Cornell University Press, Ithaca an 9 pp.Glass, R. D. and 0. Eugene Maughan, 1985. Concentrated harvest of striped bass X white bass hybrids near a heated water outlet. N. Am. J. Fish.Man. 5:105-107.

Jester, D. B. and B. L. Jensen, 1972. Life history and ecology of the gizzard shad, Dorosama cepedianum, with reference to Elephant Butle Lake.New Mexico State Univ. Aqric. Exper. Station. Res. Rep. 218. 57 pp.Kansas Gas and Electric, 1981. Wolf Creek Generating Station Environmental Report (Operating License Stage). Wichita, Kansas. 2 vols.Kansas Gas and Electric, in preparation.

Wolf Creek Generating Station Fishery Monitoring Report for 1985. Wichita, Kansas.

Molnar, G. and I. Tolg, 1962. Relation between water temperature and gastric digestion of largemouth bass(Micropterus salmoides).

J. Fish.Res. Board Can. 19:1005-1012.

Nuclear Regulatory Commission, 1975. Wolf Creek Generating Station Final Environmental Statement (construction Phase). Washington, D.C.Nuclear Regulatory Commission, 1985.Operating License NPF-32, Appendix Prosser, C. L. and F. A. Brown, 1961.Saunders Co., Phila. 888 rp.Wolf Creek Generating Station B. Washington, D.C.Ccmparative Animal Physiology, W. B.Wolters, W. R. and C.- C. Coutant, 1976. The effect of cold-shock on the vulnerability of young bluegill to predation in Thermal Ecology ILI, G. W.Esch and R. W. McFarlane, eds.

a Don't Point Dike B Figure 1.Wolf Creek Cooling Lake discharge cove. Scale: 8 inches = I mile.Circ Water Discharge 0 j] M I O CREEK NUCLEAR OPERATING COBPU IOI KLF-LE1 Rev 2/87 No. 88 -6 ENVIRONMENTAL NONCOMPLIANCE EVENT REPORT Identified by Dan Haines, Don Eccles Date: 2 /24/ 88 Date: 3 / 18/ 88 Evaluated by Brad Loveless 1. Summary of Event and Applicable References On February 26, 29 and March 17 shorelines in the vicinity of the WCGS circ water discharge were surveyed to quantify a fish kill which was discovered on February 24. The great majority of those killed were gizzard shad, but channel catfish, striped bass, carp, largemouth bass and smallmouth buffalo were also found. This event is detailed in the attached evaluation and was evaluated relative to expected cold-shock, and chemical release fish kills discussed in the FES(OLS) Section 5.5.2.2, the ER(OLS) Section 5.1.3.4.2, the FES(CP) Section 5.5.2.3, and the EPP.2. Yes X No Does this event potentially deviate from the RETS. If yes, immediately contact Rad Services and coordinate resolution and corrective action with them.3. X Yes No Does this event potentially involve an unusual or important occurrence that could result in significant environmental impact related to plant operation.

If yes, immediately notify the Manager of Licensing or his designee.The Manager of Licensing was contacted and this event was judged to be nonreportable.

See evaluation to Question #4 for a detailed explanation of this judgement.

4.Yes X No Does this EPP. If Licensing event potentially deviate from the yes, immediately notify the Manager of or his designee.Several references in licensing documents are made to predicted cold shock mortality in WCCL. The FES(CP) Section 5.5.2.3 cited a significant cold shock mortality event and predicted five plant shutdowns per winter which would kill "an unknown number of fish"v The ER(OLS) Section 5.1.3.4.2 projected that winter plant trips will "probably" result in mortality but that "the overall impact is expected to be minimal".

Wh.ile the first No. 88 -6 Page 2 citation infers that high mortality is expected and may comprise a significant impact, the second downplays this prospect and anticipates the impact to be very small. Based on these licensing studies, the EPp concluded in Section 2.1(c) that "Cold shock effects on fish due to reactor shutdowns could cause significant mortality to aquatic species in the cooling lake". Later, in Section 4.1, the EPP directs that unusual events caused by the plant which indicate significant environmental impact should be reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed by a written report.The most recent direction that has been received regarding reporting of environmental events came via a phone conversation between 0. Maynard, G.Wedd and the NRC regional office. The question was asked that since cold shock fish mortality was acknowledged by the NRC to have a potentially significant impact, should such a kill be reported per EPP Section 4.1.The NRC responded that only if the impact of a fish kill was significantly worse than what was predicted should it be reported.

It is the interpretation of Environmental Management that the NRC desires notification of cold shock mortality only if it surpasses the significant level and has a profound environmental impact. Although the February 1988 fish kill has been judged significant, such a judgement is biologically complicated and sufficient population data on WCCL gizzard shad do not exist to show that the impact exceeds this level. Therefore, this event is judged to not require reporting to the NRC.Because the EPP, as cited above, provides that cold shock could cause significant mortality in WCCL, this fish kill matches these expectations.

Therefore, it is worthy of evaluation as an important and unusual event.5-. Yes X No Does this event potentially deviate from any other environmental requirements.

If yes, the SEX will be responsible for determining the recommended course of action. If the recommended actions potentially involve notification of organizations outside of VCNOC, the SEN will notify the Manager of Licensing or his designee.See evaluation to Question #4.6. Summary of Actions Taken See attached evaluation.

No. 88 -6 Prepared by Date: / ?i Reviewed by Date: The time 1Ipse etwee is fish kill was quantified and when this evaluation was completed is worthy of explanation.

Several. factors caused the delay, most notably more pressing environmental tasks, difficulty in obtaining the Susquehanna River fish kill reference in the FES(CP), and disagreement over the correct approach to take for this evaluation.

It is important to note that this delay was allowed after it was decided that no corrective action recommendations would be made.7. Close-out complete (Attach copies of all letters, telecons, and notes Date:. ____Supe~isv RnvironCenta Management Attachment to KLF-L1I, #88-6 1 EVALUATION Initial Observations On 2/24/83 Dan Haines and Don Eccles noticed many dead fish along the shores of the Lime Sludge Pond Cove (LSPC) during a collision survey (Figure 1).They estimated that the fish had been dead 1-2 weeks. On 2/26 Brad Loveless inspected a length- of shoreline on the east side of the LSPQ-(Figure 1).Numbers of fish found were as follows: Gizzard shad -4260 Channel catfish -4 Striped bass -4 Common carp -5 Largemouth bass -I Smallmouth buffalo -1 On 2/29 Brad Loveless reinspected this same shoreline finding no appreciable change in numbers and also inspected the opposite (west) shore in this cove during a collision survey. Densities on the western shore were estimated at approximately 1/10 of those on the eastern side. Based on this distribution of fishes, it was assumed that during the die-off period a southwest wind must have been prevalent.

Plant Operations and Meteorological Data A review of plant operation data was done to determine what the cause of fish mortality may have been. Plant data revealed that from January 22 through February 15 the plant was down for maintenance.

Two events occurred during this time which were evaluated for their potential to cause the observed die-off.From February 8 through 10 the plant's steam generators were drained and discharged with the circulating water (Outfall 003). Concentrations of ammonia in circ water prior to mixing in WCCL were calculated to be 0.0024 ppm for the 3 day average with a 0.0042 ppm maximum (see attachments).

Compared to the 0.12 ppm of continuous ammonia exposure required to cause reduced growth and gill damage in channel catfish (Piper et al. 1982), the maximum amount discharged was approximately 30 times weaker. Based on the low concentrations released and that during this period the plant was down so that there was no heated effluent to attract fish to the discharge area, steam generator drainage is ruled out as the probable cause of mortality.

The second possible cause of fish death in the discharge cove was a change in plant power which may have led to cold shock. On the evening of February 16 plant power level increased, ranging from 21% at 2100 to 33% at 0200 on Feb., 17, when it fell to near zero. It remained there until late that evening when power levels began to rise steadily.

The plant reached 100%power on Feb. 19 and remained at or near there until after fish were found.

N 0 R~,f D isS 3 Based on these and past data on wintertime discharge cove temperatures, it is concluded that the rise in plant power during nighttime on Feb. 16 likely attracted fishes to the discharge area. The temperature increase during the 3-hour period between 2100 and 0200 with 2 circ water pumps operating likely ranged between 14 and 170F based on previous winter data. Winter 1985/86 data showed that delta T's in this range attracted many fish to the discharge area (LI 87-0092).

Data presented in the referenced evaluation also showed that higher circ water flows for longer periods combined with southerly winds create the largest warmed areas in the discharge cove.These warmed areas, it was determined, functioned to buffer cold-shock effects and reduce mortality in the event of a plant trip. Given this, the short-term 2-pump operation with the north-northeast wind would have created very little buffer area. The quick drop of 14-17OF could have easily killed gizzard shad (Cox and Coutant 1976) and affected gamefish (LI 87-0092)i Meteorological data in the days following February 16 showed winds out of the northeast to northwest varying from approximately 8-18 mph for 7 of the 8 days following the plant trip. This undermines the initial assumption that, based on fish distribution in the LSPC, the prevailing winds in the days following the fish kill were from the south.Follow-up Observations On March 17 areas of shoreline along the east and west sides of the Cemetery Cove (CC, Figure 1) were surveyed for signs of the fish kill. Because over two weeks had elapsed since they were last observed, the previously counted east shore of the LSPC was first surveyed so estimates elsewhere could be adjusted for depredation and deterioration.

Based on the March 17 survey, few fish were washed ashore on the east side of the CC but portions of the western shore had high densities similar to the eastern shore of the LSPC.Quantifications of Fish toss and Uncertainty As cited earlier, an exact fish count was done on a portion of the eastern LSP cove. From this count and area, shoreline

density was calculated.

Counts on other shorelines were later approximated by comparing densities with those found initially (2/26) and later (3/17) on the eastern shore of the LSP cove.When estimates were totaled for both the east and west shorelines of the LSPC and the CC, the number of gizzard shad was 18,600. Gamefish numbers were far lower, amounting to less than 100.Obviously, much uncertainty remains in this estimate.

The largest source for this is that the prevailing wind following the plant trip was from the north and the area surveyed was to the north of the discharge.

Thus, the largest portion of dead and dying shad would logically have been carried to the, south (Figure 1). Bird survey observations, in contrast, noted high concentrations of gulls on the shorelines to the northeast and not to the south. These birds were later assumed to be eating the dead and dying fish. Because neither gulls nor dead fish were observed on the south side of the cove in the vicinity of Baffle Dike B, it is concluded that the fish which died were washed ashore primarily to the north and east. This conclusion gives more credence to the extrapolated estimate of 18,600 gizzard shad.

4 Impact This fish kill is judged to have a significant impact on the WCCL fishery based on the estimated 18,600 gizzard shad which died. The evaluation of the loss as having significant impact resulted from three considerations.

First, gizzard shad are the keystone prey species in midwestern reservoirs (Cross and Collins 1975) and Wolf Creek is included in this group. As such, both pelagic and littoral predator fishes depend heavily on this species.Second, unlike the young-of-the-year winter shad kills seen commonly in other area reservoirs, the WCCL shad killed were exclusively adults with all being larger than 240mm long. This means that, were it not for the fish kill, the fish lost would have likely survived both predators and cold temperatures to reproduce the following spring. Since gizzard shad are unusually fecund, loss of this production could have a large effect.Lastly, loss of 18,600 gizzard shad is important because shad numbers in WCCL are unusually small to start with. Abundances of both young and adult shad are very low in WCCL compared with other reservoirs (Wolf Creek Nuclear.Operating Corporation 1988). Such low numbers are not accidental; shad densities are purposely kept at low to moderate levels in WCCL by use of natural predation in order to reduce impingement rates and increase plant reliability.

Due to the role of shad as the WCCL keystone prey, however, reductions which are too extreme could starve the predators which depend on Wolf Creek shad and initiate a boom/bust population cycle which. would lead to increased impingement.

Thus, maintenance of consistent, low to moderate gizzard shad levels is highly desirable.

While a much larger monitoring effort would be required to resolve if this mortality comprised a statistically significant portion of the WCCL population, based on the aforementioned information it is the judgement of Environmental Management that it is worthy of the "significant" status.To summarize, gizzard shad are key prey fishes in WCCL which occur at unusually low densities.

Loss of the estimated 18,600 adult shad is also unusual and represents an apparently large percentage of the WCCL population.

As such, this mortality is determined to be significant.

5 Citation Cross, F. B. and J. T. Collins. 1975. Fishes in Kansas. University of Kansas Publications, Lawrence.

189 pp.Piper, R. G., I. B. McElwain, L. E. Orme, J. P. McCraren, L. G. Fowler and J. R. Leonard. 1982. '-'ish Hatchery Management.

United States Fish and Wildlife Service, Washington, D. C. 517 pp.

MMLF CREEK, INTEROFFICE NUCLEAR OPERATING CORPORATION 0 CORRESPONDENCE TO: FROM: DATE: B. S. Loveless (I;C-TR)B. D. Reischrnann (MS6-02)April 14, 1988 NS 88-0436 TE 42607/42654 I A' PR>ncentrations

-i te

SUBJECT:

Steam Generator Drain Chemical Cc in the Circulating W..ater Discharc The attached calculations and data sheets are to aid in your evaluation 5f chemical concentrations in the circulating water discharge that resulted from draining the steam generators in February prior to restart of the plant, From chemistry discharge sheets the average flow rates for the steam generator drain were calculated using times and totalizer flow readings.

As the drain down was done using gravity the initial flow readings were the highest at 41 gallons per minute. As the level of the steam generators was reduced, the flow rates decreased to about 30 gallons per minute. These drain values were used to calculate the dilution factors. The circulating water flow rate was assumed.to be 320,000 gallons per minute, which is for one circulating water.pumnp running. Service 6ater flow rates were assumed to be 30,000 gallons per,.minute. Although two service water pumps should have 48,000 gallons per minute flow, a value of 18,000 gallons per minute was assumed to discharge via the E91 discharge lines.Steam generator chemical concentrations used in these calculations were taken from analysis data of February 3rd. Hydrazine concentrations averaged 190 ppm, with a maximum of 223 ppm.The pH values averaged 10.24 with a maximum, of 10.3. The steam generator

--4ter was not analyzed for ammonia, and the high concentrations of hydrazine would cause interference with the test, so these values were calculated using a !VIS program names PKTOT. Amionia values were calculated by PKTOT to match the, measured steam generator pH, with consideration of the hydrazine contribution to pH, and ranged from 18 to 36 ppm of ammonia.The results of this analysis, with average and maximum values, are su, narized below.CHEMICAL COWErRATIONS IN CIRCULATING WATER DISCHARGE FROM STEAM GENERAOR DRAIN D(WN Chemical Ammon ia Hydrazine Average Concentrations Maximum Concentrations 2 ppb 16 ppb 1 4 ppb 26 ppb K .~:--. r~.-ý X "I Page Two NS88-043(3 April 14, 1983 9 If more. information is required on this project please contact me.BDR,,bjh /)~t Attachments cc: R. L. L~ogsdon (CC-.CH), %</a L. K. Loney (IMS6-02), w/a C. A. Swartzendruber (MS6-02), w/a J. D. Ziesenis (WC-CH), w/a Records Managenent (WC-MS), w/a

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.W6LF CREEK NUCLEAR OPERATING CORPORATION INTEROFFICE CORRESPOND!

TO: G. R. Wedd (WC-TR)LI 88-0399 FROM: 0. L. Maynard (WC-LI)DATE: August 29, 1988

SUBJECT:

Environmental Noncompliance Event Report #88-6 The purpose of this letter is to document the reportability determination associated with the subject report. This letter, along with the attached justification, should be included with the record copy of Environmental Noncompliance Event Report #88-6.My evaluation of the subject report concluded that. the event is not reportable pursuant to the EPP. The attachment provides the justification and rationale for this conclusion.

OLM/jad Attachment cc: B. S. Loveless (WC-TR), w/a Records Management (WC-MS), w/a Attachment to LI 88 9 Page 1 of 3 REPORTABILITY DETERMINATION FOR ENVIRONMENT.NONCOMPLIANCE EVENT REPORT 88-6 As a result of a recent cold shock mortality event at Wolf Creek, an Environmental Noncompliance Event Report was initiated in accordance with KP-LE-2202 to document and control the evaluation of the event. The Environmental Biologist identified that the event could potentially be reportable as an unusual or important occurrence relative to the Environmental Protection Plan. The Manager of Licensing was subsequently contacted in accordance with KP-LE-2202 to determine whether or not the event was reportable to the Nuclear Regulatory Commission.

The Manager of Licensing reviewed the event report, Licensing documents, and regulations in order to determine reportability.

The evaluation concluded that the event did not constitute a noncompliance and the event was not reportable pursuant to NRC requirements.

Evaluation Noncompliance Environmental Management procedure.

KP-LE-2202 defines an Environmental Noncompliance as "an event or occurrence that results in an environmental condition which deviates form the project environmental requirements".

The following documents were reviewed to determine the project environmental requirements relative to cold shock mortality in Wolf Creek Cooling Lake:-WCGS Environmental Report-NUREG-75/096 "Final Environmental -Statement related to the construction of Wolf Creek Generating Station"-WCGS Environmental Report OLS-NUREG 0878 "Final Environmental Statement related to the operation of Wolf Creek Generating Station"-Letter KMLNRC 84-210 dated December 3, 1984 from G. L. Koester to H. R. Denton which transmitted the proposed Environmental Protection Plan-WCGS Operating License NPF-42 All of the above Licensing documents provide a consistent position relative to cold shock mortality.

The Wolf Creek documents and correspondence identify the fact that plant transients during the winter months will likely result in a significant number of fish killed but large mortality will not result in significant impact to the environment.

Attachment to LI 88& 9 Page 2 of 3 The NRC documents and correspondence acknowledge the cold shock mortality and agree that it would not have a significant impact on the environment.

During the review of the above documents,, there were no environmental requirements identified from which this event deviates.

Therefore, this evaluation concluded that the event did not constitute an "Environmental Noncompliance" as defined in KP-LE-2202.

It should be noted that although this event did not appear to be an"Environmental Noncompliance", the Environmental Noncompliance Event Report is an appropriate mechanism for documenting the event and the associated evaluation.

Reportability Although the above evaluation concluded that the event did not constitute a noncompliance, the event was evaluated for reportability relative to Environmental Protection Plan (EPP) section 4.1 Again, the same Licensing documents and correspondence were reviewed to determine the regulatory requirements and overall environmental significance relative to the subject event. For convenience EPP section 4.1 is provided below: 4.1 Unusual or Important Environmental Events Any occurrence of an unusual or important event that indicates or could result in significant environmental impact casually related to plant operation shall be recorded and promptly reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed by a written report per Subsection 5.4.2.The following are examples:

excessive bird impaction events, onsite plant or animal disease out breaks, mortality or unusual occurrence of any species protected by the Endangered Species Act of 1973, fish kills, increase in nuisance organizms or conditions, and unanticipated or emergency discharge of waste water or chemical substances.

No routine monitoring programs are required to implement this condition.

The question of which fish kills are reportable and which ones are not has been raised in the past. Since there were differing interpretations of the reportability requirements relative to fish kills, a telephone conference was held with the NRC Project Manager (Paul O'Connor) and an. NRC Environmental reviewer in 1987 to discuss the reporting requirements.

The NRC's interest in having events reported is to be made aware of any unusual or important environmental occurrence relating to plant operation that could have a significant environmental impact that had not been reviewed or considered as part of the licensing process. Therefore, fish kills resulting from thermal shock would not be reportable as long as the event was limited to the Wolf Creek Cooling Lake and did not involve any endangered species. However, fish kills of even small magnitude on the Neosho River, Wolf Creek, or John Redmond would be reportable.

This differentation is made because the NRC concluded that cold shock mortality was acceptable in part because it would be limited to the cooling lake.

Attachment to LI 880 9 Page 3 of 3 In considering the reportability relative to EPP section 4.1 it iS important to consider several factors. Wolf Creek Cooling Lake was constructed by the project for the sole purpose of providing cooling for the plant. The fishery has been developed to enhance, plant availability by minimizing impingment potential.

While cold shock mortality could potentially alter the fishery in the cooling lake, it will not adversely impact any of the public or other surrounding waters and fisheries.

Therefore, a significant cold shock mortality in Wolf Creek Cooling Lake does not result in a potentially significant environmental impact unless it impacts other bodies of-water or endangered species.In conclusion, this evaluation determined that the subject event was not reportable for the following reasons:.-The event was limited to WCCL, and-The event was within the scope of what had been previously reviewed and found environmentally acceptable in the Licensing process, and-No endangered species were involved.This evaluation is consistent with the guidance obtained from the NRC on previous occurrences.

0 0 WOLF NUCLEAR OPERATING CORPORATION Inl-LuI Rev 2187 No. 8_9_. 2 ENVIRONMENTAL NONCGMPLIANCE EVENT REPORT Identified by Brad Loveless Date: 2 1 2 89 Date: 2 1 7 89 Evaluated by Brad Loveless 1. Summary of Event and Applicable.References On Feb. 2, 1989 at 1321 the plant tripped from 100X power. Before and after the trip, two circ water pumps were running leading to a delta T of aproximately 38 F. Previously and for the next two days, the wind was strong (10-20 mph) and from due north. On the third day, wind began to shift slightly to the west and by the fourth day, it was from 3000.Temperatures during these days ranged from -10OF to 200F. On Feb.3 in the evening WCGS began to ascend in power, returning to 100 power on Feb. 4. On the day after the trip, Feb. 3, morning and afternoon fish counts were done. At these times wind and wave action made observations difficult, but estimates of approximately 500 shad and very few other species were made based on visible fish washed up on Baffle Dike B. On Feb. 6 at 1000 a follow-up survey was done. Estimates of 400 conmmon carp, 100 smallmouth buffalo and 1200-3000 gizzard shad were made. All carp and buffalo were found on the west leg of the dike with all shad found on the eastern leg. Additionally, approximately ten walleye were killed and washed up on the baffle dike during this time. Observations were still difficult due to heavy ice cover. Our observations indicated that very few fish had been scavenged up until our Feb. 6 survey and due to the strong north winds, we believe that nearly all fish killed by the falling temperatures were blown onto the north side of Baffle Dike B.*2.Yes X No Does this event potentially deviate from the RETS. If yes, Immediately contact Rad Services and coordinate resolution and corrective action Vith them.3. Yes X No Does this event potentially involve an unusual or important occurrence that could result in significant enviromoental impact related to plant operation.

If yes, Immediately notify the Manager of Licensing or his designee.Letter LI 88-0399 from 0. Maynard to G. Wedd provides a determination that fish kills in WCCL due to thermal shock are neither reportable nor do they constitute an environmental noncompliance.

4. Yes X No Does this event potentially deviate from the EPP. If yes, immediately notify the Manager of Licensing or his designee.

6 Page 2 No. 89 -2 5.Yes X No Does this event potentially deviate fro any other environmental requirements.

If yes, the SE1 will be responsible for. determining the recomended course of action. If the recommended actions potentially involve notification of organizations outside of VCNOC, the SE1 will notify the Manager of Licensing or his designee.6. Summary of Actions Taken Prepared by 7_ / A P- ..d Date: .2-3.1 .L Reviewed by 49 ; 4/1'44ý" Date: _ _10 _ q 7. Close-out complete (Attach copies of all letters, telecons, and notes Supervi r vironmental Management Date: cltO ic;"

W6 °LF CREEK NUCLEAR OPERATING CORPORATION INTEROFFICE CORRESPONDI TO: G. R. Wedd (WC-TR)LI 88-0399 FROM: 0. L. Maynard (WC-LI)DATE: August 29, 1988

SUBJECT:

Environmental Noncompliance Event Report #88-6.The purpose of this letter is to document the reportability associated with the subject report. This letter, along with justification, should be included with the record copy of Noncompliance Event Report #88-6.determination the attached Environmental My evaluation of the subject report concluded that the event is not reportable pursuant to the EPP. The attachment provides the, justification and rationale .for this conclusion.

OLM/j ad Attachment cc: B. S. Loveless (WC-TR), w/a Records Management (WC-MS) wv/a Attachment to LI 88 9 Page 1 of 3 REPORTAB ILITY DETERMINATION FOR ENVIRONMENT NONCOMPLIANCE EVENT REPORT 88-6 As a result of a recent cold shock mortality event at Wolf Creek, an Environmental Noncompliance Event Report was initiated in accordance with KP-LE-2202 to document and control the evaluation of the event. The Environmental Biologist identified that the event could potentially be reportable as an unusual or important occurrence relative to the Environmental Protection Plan. The Manager of Licensing was subsequently contacted in accordance with KP-LE-2202 to determine whether or not the event was reportable to the Nuclear Regulatory Commission.

The Manager of Licensing reviewed the event report, Licensing documents, and regulations in order to determine reportability.

The evaluation concluded that the event did not constitute a noncompliance and the event was not reportable pursuant to NRC requirements.

Evaluation Nonc omjliance Environmental Management procedure KP-LE-2202 defines an Environmental Noncompliance as "an event or occurrence that results in an environmental condition which deviates form the project environmental requirements".

The following documents were reviewed to determine the project environmental requirements relative to cold shock mortality in Wolf Creek Cooling Lake:-WCGS Environmental Report-NUREG-75/096 "Final Environmental Statement related to the construction of Wolf Creek Generating Station"-WCGS Environmental Report OLS-NUREG 0878 "Final Environmental Statement related to the operation of Wolf Creek Generating Station"-Letter KMLNRC 84-210 dated December 3, 1984 from G. L. Koester to H. R. Denton which transmitted the proposed Environmental Protection Plan-W.CGS Operating License NPF-42 All of the above Licensing documents provide a consistent position relative to cold shock mortality.

The Wolf Creek documents and correspondence identify the fact that plant transients during the winter months will likely result in a significant number of fish killed but large mortality will not result in significant impact to the environment.

  • Attachment to LI 84 99 Page 2 of 3 The NRC documents and correspondence acknowledge the cold shock mortality and agree that it would not have a significant impact on the environment.

During the review of the above documents, there were no environmental requirements identified from which this event deviates.

Therefore, this evaluation concluded that the event did not constitute an "Environmental Noncompliance" as defined in KP-LE-2202.

It should be noted that although this event did not appear to be an"Environmental Noncompliance", the Environmental Noncompliance Event Report is an appropriate mechanism for documenting the event and the associated evaluation.

Reportabilit" Although the above evaluation concluded that the event did not constitute a noncompliance, the event was evaluated for reportability relative, to Environmental Protection Plan (EPP) section 4.1 Again, the same Licensing documents and correspondence were reviewed to determine the regulatory requirements and overall environmental significance relative to the subject event. For convenience EPP section 4.1 is provided below: 4.1 Unusual or Important Environmental Events Any occurrence of an unusual or important event that indicates or could result in significant environmental impact casually related to plant operation shall be recorded and promptly reported to the. NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed by a written report per Subsection 5.4.2..The following are examples:

excessive bird impaction events, onsite plant or animal disease out breaks, mortality or unusual, occurrence of any species protected by the Endangered Species Act of 1973, fish kills, increase in nuisance organizms or conditions, and unanticipated or emergency discharge of waste water :or chemical substances.

No routine monitoring programs are required to implement this condition.

The question of which fish kills are reportable and which ones are not has been raised in the past. Since there were differing interpretations of the reportability requirements relative to fish kills, a telephone conference was held with the NRC Project Manager (Paul O'Connor) and an NRC Environmental reviewer in 1987 to discuss the reporting requirements.

The NRC's interest in having events reported is to be made aware of any unusual or important environmental occurrence relating to plant operation that could have a significant environmental impact that had not been reviewed or considered as part of the licensing process. Therefore, fish kills resulting from thermal shock would not be reportable as long as the event was limited to the Wolf Creek Cooling Lake and did not involve any endangered species. However, fish kills of even small magnitude on the Neosho River, Wolf Creek, or John Redmond would be reportable.

This differentation is made because the NRC concluded that cold shock mortality was acceptable in part because it would be limited to the cooling lake.

Attachment to LI 80 99*

  • Page 3 of 3 In considering the reportability relative to EPP section 4.1 it is important to consider several factors. Wolf Creek Cooling Lake was constructed by the project for the sole purpose of providing cooling for the plant. The fishery has been developed to enhance plant availability by minimizing impingment potential.

While cold shock mortality could potentially alter the fishery in the cooling lake, it will not adversely impact any of the public or other surrounding waters and fisheries.

Therefore, a significant cold shock mortality in Wolf Creek Cooling Lake does not result in a potentially significant environmental impact unless it impacts other bodies of water or endangered species.In conclusion, this evaluation determined that the subject event was not reportable for the following reasons:-The event was limited to WCCL, and-The event was within the scope of what had been previously reviewed and found environmentally acceptable in the Licensing process, and-No endangered species were involved.This evaluation is consistent with the guidance obtained from the NRC on previous occurrences.

FORM KLF-LE3, REM.93 (Sheet 1 of 2)No. 94-02 EPP DESIGN OR OPERATIONAL CHANGE EVALUATION Summary of Design or Operational Change PMR # NA Rev. NA (if applicable)

This evaluation addresses the impact of fish kills due to cold shock effects following two plant shutdowns.

The first was on 01-14-94 when the reactor was shut down for planned repair and returned to service on 01-17-94.

The second was on 01-26-94 when the plant was tripped for a forced outage brought online again on 01-30-94.

Intake temperatures during both trips were approximately 35°F.Discharge temperatures prior to each trip were approximately 720 to 75°F.Station biologists inspected Baffle Dike B on 01-17-94 expecting cold shocked fish to be present. No dead fish were found. Prevailing winds were southerly on 01-15-94, but were northerly on 01-17-94.

On 01-25-94 dead fish were observed and subsequently, a dead fish count was conducted on 01-28-94.Approximately 4200 fish, mostly shad and carp, were estimated to have been killed. Some game fish were also present (see attached data sheet). It was surmised that the time lapse between the plant trip and when the fish were first noted was due to thermal refuges in the cove area, which delayed cold shock mortality.

There were not any dead fish counted on 01-28-94 that were killed from the 01-26-94 trip. Subsequent shoreline searches on 02-04-94 and 02-07-94 found only four additional dead carp. Consequently, no environmental impacts from the 0 1-26-94 plant trip occurred.Documents which define the level of environmental impact previously evaluated by the NRC.* FES-OLS (NUREG -0878)* FES-CP (NUREG -75/096)* EPP, Appendix B to Facility Operating License NPF-42 Does this design or operational change involve measurable nonradiological effects outside the onsite areas disturbed during site preparation and plant construction?

Yes No x Explanation:

The fish kill event was confined to the plant discharge area of the lake.Does this design or operational change constitute an unreviewed environmental question?An enironmental question must meet one or more of the following criteria to be classified as unreviewed.

A. Does this change constitute a matter which results in a significant increase in any adverse environmental impact previously evaluated by NRC?Yes No x Explanation:

Fish kills due to cold shock after sudden plant trips were previously evaluated by the NRC but these incidents were not considered to have significantly impacted the fishery.They were not considered significant or reportable to the NRC based on the following guidance provided in LI 88-0399 (copy attached):

1. The event was limited to WCCL.2. Appreciable mortality was expected to result from cold shock in the licensing documents and such mortality was considered environmentally acceptable.

The numbers involved in these events (-4200) was small compared to the total fishery and well within licensing process expectations.

3. There were no threatened or endangered species killed.

FORM KLF-LE3, RE.*/93 (Sheet 2 of 2)No. 94-02 B. Will this change constitute a significant change in effluents or power level?Yes No x Explanation:

Plant effluents or power levels are not changed.C. Will this change constitute a matter not previously reviewed and evaluated in licensing documents which results in a significant adverse environmental impact?Yes No x Explanation:

Cold shock events were previously evaluated by the NRC.Overall determination of unreviewed environmental question.Yes No x Explanation:

Based on the answers to A, B, and C, an unreviewed enviromnental question does not exist.Does this design or operation change necessitate an EPP change?Yes No x Explanation:

An unreviewed impact did not occur, so no change is necessary.

Does this design or operation change constitute a decrease in the effectiveness of the EPP in meeting its objectives?

Yes No x Explanation:

The effectiveness of the EPP was notjeopardized.

If this design or operation change has been determined to be unreviewed with significant environmental impact or constitute an EPP change, a written evaluation must be submitted to the NRC and approval received PRIOR to initiation of the change.Is transmittal of the evaluation required to the NRC? (If yes, retention required for the life of the plant.)Yes No x If Yes: Transmittal approved:

NA Transmittal d t NA Evaluation prepared by: Jear A lf qIte"/Preparer J\ Dfite'SEM approval:

.-[i4[q SEM Date Attachmnent to EPP Design or Operational Change Evaluation 94-02 Fish Kill Data Sheet for January 28, 1994 Inspected by Dan Haines Wind -Northwest at 15-20 mph Transect #1 -East shoreline of Stringtown Cove from TLD to 345 KV (3600 total feet)Species Shad (all adult)Carp Buffalo sD Channel catfish Morone g2 Smanlmouth bass Largemouth bass Walleye Total Number 31 23 67 3 2 3 1 2 Number/Foot 0.009 0.006 0.019 0.001 0.001 0.001<0.001 0.001<0.039 132 Transect #2 -North shoreline of LSP Cove from TLD to 345 KV (1300 total feet)Species Shad (all adult)Carp Buffalo g2 Channel catfish Smallmouth bass Largemouth bass Walleye Total Number 95 16 36 4 5 10 1 167 Number/Foot 0.073 0.012 0.028 0.003 0.004 0.008 0.001 0.129 Transect #3 -South shore of discharge channel from DC wing-wall to base of BDB OCAB Gate (1000 total feet)Species Shad (all adult)Carp Buffalo s2 Channel catfish Morone sp Smallmouth bass Largemouth bass Walleye Total Number 52 46 45 1 4 10 6 1 113 Number/Foot 0.052 0.046 0.045 0.001 0.004 0.010 0.006 0.001 0.113 2 Transect #4 -Baffle Dike B from TLD bend to OCAB Gate (North side) (2000 total feet)Species Shad (all adult)Carp Buffalo V Smallmouth bass Largemouth bass Morone _M Total Number 266 241 38 20 21 3 589 Number/Foot 0.133 0.121 0.019 0.010 0.011 0.002 0.295 All Transects Combined (7900 total feet)Species Shad (all adult)Carp Buffalo -M Channel catfish Smallmouth bass Largemouth bass Morone _M Walleye Total Number 444 326 216 8 38 38 9 4 1083 Total estimated cold shock fish kill due to 01-14-94 trip* Estimate from aerial picture a total of 27,060 feet of discharge shoreline* Counted 7900 feet or 29% of effected area Assuming even distribution based on average #/ft from 4 transects, the following were killed: Species Shad Carp Buffalo 9 .Channel catfish Morone sR Smallmouth Bass Largemouth Bass Walleye Total x #/ft. X 27060'= Total Est. x N weight 0.067 0.046 0.028 0.001 0.002 0.006 0.007 0.001 1806 1251 751 34 47 162 189 20 4260 (bs.)1 4 8 8 1 1 2 2 X Est. Value/lb. *$ 0.34 0.27 0.59 1.10 1.15 4.48 4.48 6.29 Est. $Value$ 614 1351 3545 299 54 725 1693 252$8,533* Values based on Investigation and Valuation of Fish Kills, AFS, Spec. Publ. 24 WA4LF'CREEK NUCLEAR OPERATING CORPORATION INTEROFFICE COR G. R. Wedd (WC-TR)TO: LI 88-0399 0. L. Maynard (WC-LI)-" DATE: August 29, 1988

SUBJECT:

Environmental Noncompliance Fvent #83-5 The purpose of this letter is to document the reportability associated with the.subject report. This- letter, along with justification, should be included with.the record copy of Noncompliance Event Report #88-6.determination the attached Environmental"y evaluation of. the subject report -.concluded that. the event is.. not reportable pursuant to the EPP. -The attachment provides the..justification and rattionale for this conclusion.

OLM/jad Attachment cc: B.- S. Loveless (WC-TR), w/a..Records Management (WC-MS), w/a V Attachment to LI -0399 Pagel1 of 3 REPORTABILITY DETERMINATION FOR ENVIRONMENT NONCOMPLIANCE EVENT REPORT 88-6 As a result of a. recent cold. shock mortality event at Wolf Creek,. an Environmental Noncompliance Event Report was -initiated in accordance with KP-LE-2202 to document and control the evaluation of the event. The t. Environmental Biologist identified that the event could potentially be reportable as an unusual or important occurrence relative to the Environmental Protection Plan. The Manager of Licensing was subsequently contacted in accordance-with KP-LE-2202 to determine whether or not.the even: vas reportablse to Nhe .uclear egulat~ry Commissi-n.

The Manager of Licensing reviewed the event report, Licensing.

documents, and regulations in order to determine reportability.

The evaluation concluded that the event did not constitute a noncompliance and the event was not reportable pursuant"'

..to NRC..requirements.

.Evaluation Environmental Management

.procedure KP-LE-2202 defines an ..Environmental Noncompliance as "an event or occurrence that results in an environmental condition which deviates form the project environmental requirements".

The following documents were reviewed to determine the project environmental requirements relative to cold shock mortality in Wolf Creek Cooling Lake:-WCGS Environmental Report-NUREG-75/096 "Final Environmental Statement related to the construction of Wolf Creek Generating Station"-WCGS Environmental Report OLS-NUREG 0878 "Final Environmental Statement related to the operation of Wolf Creek Generating Station"-Letter KMLNRC 84-210 dated December 3, 1984 from G. L. Koester to H. R. Denton which transmitted the proposed Environmental Protection Plan.-WCCS Operating License NPF-42 All of the above Licensing documents provide a consistent position relative to cold shock mortality.

The Wolf Creek documents and correspondence ident'ify the' fact that plant transients during the winter months will likely result in a significant number of fish killed but large mortality will not result in significant impact to the environment.

Attachment to LI 0399 Page 2 of .3 The NRC documents and correspondence acknowledge the cold shock mortality and agree that it would not have a significant impac-t on the environment.

During the review of the requirements identified from evaluation concluded that Noncompliance" as defined in above documents, there were no environmental which this event deviates.

Therefore,, this the event did not constitute an "Environmental KP-LE-2202.

It should be .noted that although this event did not appear to be an"Environmental Noncompliance", the Environmental Noncompliance Event Report is an appropriate mechanism for documenting the event and the associated e'ia1.at Re__rtabilit_

Although the above evaluation concluded that the event did not constitute a noncompliance,, the event was evaluated for reportability relative to Environmental Protection Plan (EPP) section 4.1 Again, the same Licensing documents and. correspondence were reviewed .to determine the regulatory

--requirements and overall environmental significance relative to the subject'event. For convenience EPP section 4.1 is provided below: 4.1 Unusual or Important Environmental Events".Any occurrence of an unusual or important event that indicates or could result in significant environmental impact casu.ualyLj.jated to plant operation shall be recorded and promptly reported "to t~e NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed' by a written report per. Subsection 5.4.2.The following are examples:

excessive bird impaction events, onsite plant or animal disease, out breaks, mortality or unusual occurrence of any species protected by the Endangered-Species Act of 1973, fish kills, increase in nuisance organizms or conditions, and unanticipated or emergency discharge of waste water or chemical substances.

No routine monitoring programs are required to implement condition.

this The question of which fish kills are reportable and which ones are not has-been raised in the past. Since there were differing interpretations of the-:'reportability requirements relative to fish kills, a telephone conference was held with the NRC Project Manager (Paul O'Connor) and an NRC Environmental reviewer in 1987 to discuss the reporting requirements.

The NRC's interest in having events reported is to be made aware of any unusual or important environmental occurrence relating.to plant operation that could have a significant environmental impact that had not been reviewed or considered as part of the licensing process. Therefore, fish kills resulting from thermal shock would not be reportable as long as the event was limited to the Wolf Creek Cooling Lake and did not involve any.endangered species. However, fish kills of even small magnitude on the Neosho River, Wolf Creek, or John Redmond would be reportable.

This differentation is made because the NRC concluded that cold shock mortality was acceptable in part because it would be limited to the cooling lake.

  • Attachment to L1 0399 Page 3 of 3 In considering the reportability relative to EPP section 4.1 it is important to consider several factors. Wolf Creek Cooling Lake. was constructed by the project for the sole purpose of providing cooling for the plant. The fishery has been developed to enhance- plant availability by minimizing impingment potential.

While cold shock mortality could potentially alter the fishery in the cooling lake, it will not adversely impact any of the public or other surrounding waters and fisheries.

Therefore, a significant cold shock mortality in Wolf Creek Cooling Lake does not result in a potentially significant environmental impact unless 1itjmpacts other bodies of water or endangered species.In conclusion, this evaluation determined that the subject event was not reportable for the following reasons:-The event was limited to WCCL, and-The event was- within the scope of what had been previously reviewed and found environmentally, acceptable in the Licensing process, and-No endangered.

species were involved.This evaluation is consistent with the guidance obtained fr'om the NRC on previous occurrences.

0 FORM KLF-LE3, REV. 4/93 (Sheet 1 of 2)0 No. 96-05 ft EPP DESIGN OR OPERATIONAL CHANGE EVALUATION Summary of Design or Operational Change EER# NA Rev.(if applicable)

This evaluation addresses the impact of the cold-shock fish kill following the 1/30/96 plant trip due to icing problems on the rotating screens and determines if the impact of this event was greater than expected in licensing documents.

Cold-shock induced fish kills due to reactor shutdowns were expected to occur (FES-CP Section 5.5.2.3 and FES-OLS Section 5.5.2.2) and the effects could cause significant mortality to aquatic species in the cooling lake [EPP Section 2.0 (c)].The conclusion of this evaluation demonstrates that the 1/30/96 plant trip did not impact the cooling lake fishery above those considered acceptable in the licensing documents.

The event does not constitute an unreviewed environmental question as defined in the Section 3.0 of the EPP. This determination is based on actual quantification of the kill and lack of measurable impacts following past fish kills of similar magnitude.

Documents which define the level of environmental impact previously evaluated by the NRC.Environmental Protection Plan, Appendix B to the Facility Operating License NPF-42.Final Environmental Statement

-Construction Phase (FES-CP)Final Environmental Statement

-Operating License Stage (FES-OLS)Does this design or operational change involve measurable nonradiological effects outside the onsite areas disturbed during site preparation and plant construction?

Yes No X Explanations This fish kill event was confined to the cooling lake. No offsite areas were affected.Does this design or operational change constitute an unreviewed environmental question?An environmental question must meet one or more of the following criteria to be classified as unreviewed.

A. Does this change constitute a matter which results in a significant increase in any adverse environmental impact previously evaluated by NRC?Yes.Explnatio No X Cold-shock fish mortality due to winter-time plant trips such as happened during this event was specifically evaluated in the licensing documents.

Appreciable mortality was expected and considered acceptable and this evaluation demonstrates that this event's impact was not greater than forecasted.

This incident was not considered to have significant impact to the fishery or reportable to the NRC based on the following guidance provided in LI 88-0399 (see attached Environmental Noncompliance Report 88-6).1. The event was limited to the cooling lake. Thermal effluents do not greatly impact discharge water from the lake, thus cold-shock impacts are not applicable beyond the lake proper.2. There were no threatened or endangered species killed. No threatened and endangered fish or aquatic species have been found in the lake.3. The event was not greater than licensing document expectations.

The attached evaluation demonstrates this point.

FORM KLF-LE3, REV. 4/93 (Sheet 2 of 2)No. 96-05 B. Will this change constitute a significant change in effluents or power level?Yes No X Explanation:

This event does not involve plant effluent of power level changes.C. Will this change constitute a matter not previously reviewed and evaluated in licensing documents which results in a significant adverse environmental impact?Yes No X Explanation:

Fish kill events were previously evaluated.

See answer to question A.Overall determination of unreviewed environmental question.Yes No X Explanation:

This event does not represent an increase to previously evaluated fish kill impacts, changes to plant effluents or power levels, nor does it constitute a matter not previously reviewed.

An unreviewed environmental question does not exist.Does this design or operation change necessitate an EPP change?Yes No X Expanation No changes are needed.Does this design or operation change constitute a decrease in the effectiveness of the EPP in meeting its objectives?

Yes No X Explanation:

No changes occurred that would decrease the effectiveness of the EPP.If this design or operation change has been determined to be unreviewed with significant environmental impact or constitute an EPP change, a written evaluation must be submitted to the NRC and approval received PRIOR to initiation of the change.Is transmittal of the evaluation required to the NRC? (If yes, retention required for the life of the plant.)Yes No X If Yes: Transmittal approved: N/A I ransmiua, dae:I Evaluation prepare d by: Dan Haines A@A4.I5/10/96 Preparer Date SEM approval:

Dae SEM Date 0 0 EVALUATION OF COLD-SHOCK INDUCED FISH KILL ON WOLF CREEK LAKE FOLLOWING 1/30/96 PLANT TRIP, ATTACHMENT TO EPP DESIGN OR OPERATIONAL CHANGE EVALUATION

  1. 96-05 INITIAL OBSERVATIONS AND QUANTIFICATION The plant tripped due to icing problems on the circulating water screens on 1/30/96. Station biologists inspected Baffle Dike B on 2/1/96 for dead fish. Shoreline water temperature was still 450 F on the dike. No dead fish were observed.

Cold shocked fish typically take several days to appear along the shorelines.

A small number of dead and dying shad were observed on 2/2/96 toward the west end of the dike where water temperatures were -330 F. On the same day, shoreline water temperatures at the northeast base of the dike were approximately 380 F. Due to the extremely cold air temperatures, complete ice cover occurred on 2/3/96 making fish kill observations useless.Prevailing winds were from the north.The ice cover in the discharge cove melted enough to allow for fish kill assessment on 2/9/96. Dead fish. were counted on two segments of shoreline where fish numbers were considered the greatest.

Weakened and dying fish were still evident and were included in the count. These segments totaled approximately 5840 feet. Spot shoreline inspections around the northern portion of the lake were completed to determine the total length of shoreline with dead fish. This total was approximately 50,800 feet. By extrapolating the number of fish on the counted shore segments, an estimated total of 19,763 fish were killed. This total is considered worst case because the calculations assumed equal concentration of fish as the segments where dead fish were counted. Below is a summary of the estimated worst case fish kill.EtiN. % of Tol Gizzard shad 15,884 80 Common carp 2157 11 Buffalo 1331 7 Channel catfish 122 1 Freshwater drum 52 <1 Wiper 35 <1 White bass 35 <1 Smallmouth bass 35 <1 Walleye 35 <1 Bluegill 26 <1 Blue catfish 17 <1 Largemouth bass 17 <1 White crappie 17 <1 IMPACTS Gizzard Shad: No impacts are expected to gizzard shad as a result of this fish kill event. A main environmental concern with this loss of shad was the further reduction of already low shad numbers, however, this is not expected to be detrimental.

This is contradictory to a shad kill of similar magnitude in 1988. Environmental evaluation at that time determined the impact to the shad and subsequently to the predator fishery to be biologically significant (see Environmental Noncompliance Event Report 88-6 attached).

The main difference between the 1988 kill and this one is that nearly all shad were adults in the 1988 kill. Plant caused mortality events could reduce adult shad numbers to a point low enough so that reproduction was too low to feed and maintain the predator species currently controlling the shad.Shad control efforts are to reduce the impingement impact from normal shad winter kill events to plant operations.

Fishery monitoring after the 1988 kill and other smaller events has not measured any changes to the fishery that could be attributed to the kills (Environmental Noncompliance Report 86-08, and 89-2).

0 0 Roughfish:

No impacts to the fishery are expected to result from the number of roughfish killed. Common carp, buffalo (mostly smallmouth), and freshwater drum made up approximately 18% of the fish killed. These species are not preferred sportfish nor do they help appreciably with reducing shad numbers. The combined total of 3540 represents less than I fish per acre (5090 acres of lake).Gamefish: Less than two percent of the fish killed were game fish. This number is small when compared to the entire lake population and is not considered detrimental.

CONCLUSION A large number of shad were killed by the cold shock event, but based on past monitoring after similar cold shock events, detrimental impacts are not expected.

The number of other species killed was small when compare to the entire lake population.

Because measurable impacts to the fishery are not expected, no increase to previously evaluated impacts due to cold-shock mortality occurred.

quLF CREEK NUCLEAR OPERATING CORPb. ATION KLF-LE1 Rev 2/87 No.* 88 -6 ENVIRONMENTAL NONCOMPLIANCE EVENT REPORT Identified by Dan Haines, Don Eccles Date: 2 / 24/ 88 Date: 3 / 18/ 88 Evaluated by Brad Loveless 1. Summary of Event and Applicable References On Februjary

26. 29 and Mprnh 17 shnrelines in the vitcinitv nf lýe WenS circ water discharge were surveyed to quantify a fish kill, which was discovered on February 24. The great majority of those killed were gizzard shad, but channel catfish, striped bass, carp, largemouth bass and smallmouth buffalo were also found. This event is detailed in the attached evaluation and was evaluated relative to expected cold-shock, and chemical release fish kills discussed in the FES(OLS) Section 5.5.2.2, the ER(OLS) Section 5.1.3.4.2, the FES(CP) Section 5.5.2.3, and the EPP.2. Yes X No Does this event potentially deviate from the RETS. If yes, immediately contact Rad Services and coordinate resolution and corrective action vith them.3- X Yes No Does this event potentially involve an unusual or important occurrence that could result in significant environmental impact related to plant operation.

If yes, immediately notify the Manager of Licensing or his designee.The Manager of Licensing was contacted and this event was judged to be nonreportable.

See evaluation to Question #4 for a detailed explanation of this judgement.

.4.Yes X No Does this EPP. If Licensing event potentially deviate, from the yes,- immediately notify the Manager of or his designee.Several references in licensing documents are made to predicted cold shock mortality in WCCL. The FES(CP) Section 5.5.2.3 cited a significant cold shock mortality event and predicted five plant shutdowns per winter which would kill "an unknown number of fish". The ER(OLS) Section 5.1.3.4.2 projected that winter plant trips will "probably" result in mortality but that "the overall impact is expected to be minimal".

While the first

  • _* .No. 88 -6 Page 2 citation infers that high mortality is expected and may comprise a significant impact, the second downplays this prospect and anticipates the impact to be very small. Based. on these licensing studies, the EPP concluded in Section 2.1(c) that "Cold shock effects on fish. due to reactor shutdowns could cause significant mortality to aquatic species in the cooling lake". Later, in Section 4.1, the EPP directs that'unusual events caused by the plant which indicate significant environmental impact should be reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed by a written report.The most recent direction that has been received regarding reporting of environmental events came via a phone conversation between 0. Maynard, G.shock fish mortality was acknowledged by the NRC to have a potentially significant impact, should such a kill be reported per EPP Section 4.1.The NRC responded that only if the impact of a fish kill was significantly worse than what was predicted should it be reported.

It is the interpretation of Environmental Management that the NRC desires notification of cold shock mortality only if it surpasses the significant level and has a profound environmental impact.. Although the February 1988 fish kill has been judged significant, such a judgement is biologically complicated and sufficient population data on WCCL gizzard shad do not exist to show that the impact exceeds this level. Therefore, this event is judged to not require reporting to the NRC.Because the EPP, as cited above, provides that cold shok could caus,:5'significant mortality in WCCL, this fish kill matches these expectations.

Therefore, it is worthy of evaluation as an important and unusual event.. -, 5-. Yes X No Does this event potentially deviate from any other environmental requirements.

If yes, the SE, will-be responsible for determining the recommended course of action. If the recommended actions potentially involve notification of organizations outside of WCNOC, the SEN will notify the Manager of Licensing or his designee.See evaluation to Question #4-6. Summary of Actions Taken See attached evaluation.

No. 88 -6 Page 3 Prepared by ____________Date:

Reviewed by Date: i/r/Zo.'17p/s n wh en -th is"i kil The time pse wee is fish kill was quantified and when this evaluation was completed is worthy of explanation.

Several factors caused the delay, most notably more pressing environmental tasks, difficulty in obtaining the Susquehanna River fish kill reference in the FES(CP), and disagreement over the correct approach to take for this evaluation.

It is important to note that this delay was allowed after it was decided that no corrective action recommendations would be made.7. Close-out complete (Attach copies of all letters, telecons, and notes Date:iro___

Attachment to KLF-LEI , #88-6 1 WvALUATION Initial Observations On 2/24/83 Dan Haines and Don Eccles noticed many dead fish along the shores of the ime Sludge Pond Cove (LSPC).during a collision survey (Figure 1).They estimated that the fish had been dead 1-2 weeks. On 2/26 Brad Loveless inspected a length. of shoreline on the east side of the LSPO.(Figure 1).'lumbers of fish founid were as follows: Gizzard shad -4260 Channel catfish -4 Common carp 5 Largemouth bass -I Smallmouth buffalo -1 On 2/29 Brad Loveless reinspected this same shoreline finding no appreciable change in numbers and also inspected the opposite (west) shore in this cove during a collision survey. Densities on the western shore were estimated at approximately 1/10 of those on the eastern side, Based on this distribution of fishes, it was assumed that during the die-off period a southwest wind must have been prevalent.

Plant Operations and Meteorological Data A review of plant operation data was done to determine what the cause of fish mortality may have been. Plant data revealed that from January 22 through February 15 the plant was down for maintenance.

Two events occurred during this time which were evaluated for their potential to cause the observed die-off.From February 8 through 10 the plant's steam generators were drained and discharged with the circulating water (-utfall0O03).

Concentrations of ammonia in circ water prior to mixing in WCCL were calculated to be 0.0024 ppm for the 3 day average with a 0.0042 ppm maximum (see attachments).

Compared to the 0.12 ppm of continuous ammonia exposure required to cause reduced growth and gill damage in channel catfish (Piper et al. 1982), the maximum amount discharged was approximately 30 times weaker. Based on the low concentrations released and that during this period the plant was down so that there was no heated effluent to attract fish to the discharge area, steam generator drainage is ruled out as the probable cause of mortality.

The second possible cause of fish death in the discharge cove was a change in plant power which may have led to cold shock. On the evening of February 16 plant power level increased, ranging from 21% at 2100 to 3.3% at 0200 on Feb.1 17, when it fell to near zero. It remained there until late that evening when power levels began to rise steadily.

The plant reached 100%power on Feb. 19 and remained at or near there until after fish were found.

Ii N 1'e. .OCA,--

3 Based on thse and past data on wintertime discharge cove temperatures, it is concluded that the rise in plant power during nighttime on Feb. 16 likely attracted fishes to the discharge area. The temperature increase during the 5-hour period between 2100 and 0200 with 2 circ water pumps operating likely ranged between 14 and 17 0 F based on previous winter data. Winter 1985/86 data showed that delta T's in this range attracted many fish to the discharge area (LI 37-0092).

Data presented in the referenced evaluation also showed that higher circ water flows for longer periods combined with southerly winds create the largest warmed areas in the discharge cove.These warmed areas, it was determined, functioned to buffer cold-shock effects and reduce mortality in the event of a plant trip. Given this, the short-term 2-pump operation with the north-northeast wind would have created very little buffer area. The quick drop of 14-17 0 F could have easily killed izzar"! 6C vox ann CoutaxIt i97b) ann affected gamefish kLI 87-0092).Meteorological data in the days following February 16 showed winds out of the northeast to northwest varying from approximately 8-18 mph for 7 of the 8 days following the plant trip. This undermines the initial assumption that, based on fish distribution in the LSPC, the prevailing winds.in the days following the fish kill were from the south.Follow-up Observations On March 17 areas of shoreline along the east and west sides of the Cemetery Cove (CC, Figure 1) were surveyed for signs of the fish kill. Because over tw9 weeks had elapsed since they were last observed, the previously counted east shore of the tSPC was first surveyed so estimates elsewhere could be..adjusted for depredation and deterioration.

Based on the March i7 survey, few fish were washed ashore on the east side of the CC but portions of the western shore had high densities similar to the eastern shore of the LSPC.Quantifications of Fish Loss and. Uncertainty As cited earlier, an exact fish count was done on a portion of the eastern LSP cove. From this count and area, shoreline "density was calculated.

Counts on other shorelines were later approximated by comparing densities with those found initially (2/26) and later (3/17) on the eastern shore of the LSP cove..When estimates were totaled for both the east and west shorelines of the LSPC and the CC, the number of gizzard shad was 18,600. Gamefish.

numbers were far lower, amounting to less than 100.Obviously, much uncertainty remains in this estimate.

The largest source for this is that the prevailing wind following the plant trip was from the north and the area surveyed was to the north of the discharge.

Thus, the largest portion of dead and dying shad would logically have been carried to the , south (Figure I). Bird survey observations, in contrast, noted high concentrations of gulls on the shorelines to the northeast and not to the south. These birds were later assumed to be eating the dead and dying fish. Because neither gulls nor dead fish were observed on the south side of the cove in the vicinity of Baffle Dike B, it is concluded that the fish which died were washed ashore primarily to the north and east. This conclusion gives more credence to the extrapolated estimate of 18,600 gizzard shad.

4 Imtact This fish kill is judged to have a significant impact on the WCCL fishery based on the estimated 18,600 gizzard shad which died. The evaluation of the loss as having significant impact resulted from three considerations.

First, gizzard shad are the keystone prey species in midwestern reservoirs (Cross and Collins 1975) and Wolf Creek is included in this group. As such, both pelagic and littoral predator fishes depend heavily on this species., Second, unlike the young-of-the-year winter shad kills seen commonly in other..area reservoirs, the WCCL shad killed were exclusively adults with all being larger than 240mm long. This means that, were it not for the fish kill, the fish lost would have likely survived both predators qnd cold ceuiperacures W reproauce tne foiLowing spring. Since gizzard shad are unusually fecund, loss of this production could have a large effect.Lastly, loss of 18,600 gizzard shad is important because shad numbers in WCCL are unusually small to start with. Abundances of both young and adult shad are very low in WCCL compared with other reservoirs (Wolf Creek Nuclear Operating Corporation 1988). Such low numbers are not accidental; shad densities are purposely kept at low to moderate levels in WCCL by use of natural predation in order to reduce impingement rates and increase plant reliability.

Due to the role of shad as the WCCL keystone prey, however, reductions which are too extreme could starve the predators which depend on Wolf Creek shad and initiate a boom/bust population cycle which would lead to increased impingement.

Thus, maintenance of consistent, low to moderate gizzard shad levels is highly desirable.

While a much larger monitoring effort would be required to resolve if this mortality comprised a statistically significant portion of the WCCL population, based on the aforementioned information it is the judgement of Environmental Management that it is worthy of the "significant" status.To summarize, gizzard shad are key prey fishes in WCCL which occur at unusually low densities.

Loss of the estimated 18,600 adult Shad is also unusual and represents an apparently large percentage of the WCCL population

... As such, this mortality is determined to be significant.

-.;, * : ',-*

0)5 Citation Cross, F. B. and J. T. Collins. 1975. Fishes in Kansas. University of Kansas Publications, Lawrence.

189 pp.Piper, R. G., I. B. McElwain, L. E. Orme, J. P. McCraren, L. G. Fowler and J. R. Leonard. 1982. 7ish Hatchery Management.

United States Fish and Wildlife Service, Washington, D. C. 517 pp.J:...A -.

INTEROFFICE NUCLEAR OPERATING CORPORATION CORRESPONDENCE TO: FROM: DATE: B. S. Loveless (I;C-TR)B. D. Reischmann (M"S6-02)April 14, 1988 HS 88-0436 TE 42607/42654

  • ,IAPR 1 -:3 ,ncentrations; e

SUBJECT:

Steam Generator Drain Chemical Cc in the Circulating W.ater Discharc The attach-ed calculations and data sheets are to aid in your evaluation cf chemical concentrations in the circulating water discharge that resulted from draining the steam generators in February prior to restart of the plant.From chemistry discharge sheets the average flow rates for the steam generator drain were calculated using times and totalizer flow readings.

As the dr3in down was done using gravity the initial flow readings were the highest at-. 41 gallons per minute. As the level of the steam generators was reduced, the flow rates decreased to about 30 gallons per minute. These drain values used to calculate the dilution factors. The circulating water flow rate assumed to be 320,000 gallons per minute, which is for one circulating water pump running. Service water flow rates were assumed to be 30,000 gallons per minute. Although two service water pumps should have 48,000 gallons per minute flow, a value of 18,000 gallons per minute was assumed to discharge via the ESI discharge lines.Steam generator chemical concentrations used in these calculations were taken from analysis data of February 3rd. Hydrazine concentrations averaged 190 pp., with a maximum of 223 ppm.The pH values averaged 10.24 with a maximum of .10.3. The steam generator WEter was not analyzed for ammonia, and the high concentriations of hydrazine would cause interference with the test, so these values were calculated using a TS program names PKTrOT. Annmonia values were calculated by PKTOT to match the measured steam generator pH, with consideration of the hydrazine contribution to pH, and ranged from 18 to 36 ppm of ammonia.The results of this analysis, with average and maximum values, are stxnnaarized below.CHEMICAL CONCEMRATIONS IN CIRCULATING WATER DISCHARGE FRCM STEAM GENERATOR DRAIN DCWN Chemical Anmonia Hydrazine Average Concentrations Maximum Concentrations 2 ppb 16 ppb 4 ppb 26 ppb-~ ~

Page Two NS 88-0436 April 14, 2988 If -more information is requirej on this project please. contact me.BDR;"bjh Attac1hents cc: R. L. Lrogsdon (WC-CH), w/a C. A. 5wartzendruber (MS6-02), w/a J. D. Ziesenis (WC-CH), w/a Records "4anagement

(,IC-,MS), w/a I Z FORM KSF-C7 REV. --7, ...;CALCULATION WORKSHEET Nuclear Services Division 5 -,,cr-eOY'C;iýý e yoq 4ay, D),tz ih P c2 Allm fn J*Utlu k gjdb1"-21'W at (', Ld. , -e,'C,-C. LV&,A^)At ZOJ~4~---OIjI% -30 ree ooDrp.I -~f -. :1/4ydalrk -Ix ; o ,, ' -.t2 2$4/-* 21A.1r" 0rccA ~fV1~4J' 4'or"' i~~AA~1 1I ...U DsIIIu1tje~a CC-ýic. &./)S~P4%f Coa.(C, C. LA4A~-¶ F10W j- +5 5.uO. Plow.. *Sf6jra. Flew A vvc C "4 C" 'r.0 ( 4 Opp-)(?t 3 )0.01/6 3p~ 4,, I giciru.A t, I 39VIp i3)O~0. o~ooeL.fpi' Sppt, ,,.ni r" oi'Al40'C&~CA~~b r. /f-4S£ C 4 d WA. 8 (.$c- kx e 7 , (2 23~p-~)544~4'ML 0 ~-~"'~0,o a: o.0o 4-" It/lc)r4/1 4 kvlmn¶'.(3'pP&( q 8 1)PREPARED BY K -DATE q- j4-I CALCULATION PACKAGE NO.PAGE _. OP -" .

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  • 0 ..' .W6LF*..CREEK NUCLEAR OPERATING CORPORATION INTEROFFICE CORRESPOND TO: G. R. Wedd (WC-TR)LI 88-0399 FROM: 0. L. Maynard (WC-LI)DATE: August 29, 1988

SUBJECT:

Environmental Noncompliance Event Report #88-6 The purpose of this letter is to document the reportability determination associated with the subject report. This letter, along with the attached justification, should be included with the record copy of Environmental.....

Noncompliance Event Report #88-6.My evaluation of the subject report concluded that, the event is. not reportable pursuant to the EPP. The attachment providesithe justification and rationale for this conclusion.

OLM/j ad Attachment

.cc: B. S. Loveless (WC-.TR), w/a Records Management (WC-MS), w/a Attachment to LI page 1 of 3 REPORTABILITY DETERMINATION FOR ENVIRONMENT NONCOMPLIANCE EVENT REPORT 88-6 As a result of a recent cold shock mortality event at Wolf Creek, an Environmental Noncompliance Event Report was initiated in accordance with KP-LE-2202 to document and control the evaluation of the event. The Environmental Biologist identified that the event could potentially be reportable as an unusual or important occurrence relative to the Environmental Protection Plan. The Manager of Licensing was subsequently

ontacted in accor-an:e "ih --c ..etr-ae what'her )r a.c che event was reportable to the Nuclear Regulatory Commission, The Manager of Licensing reviewed the event report, Licensing documents, and regulations in order to determine reportability.

The evaluation concluded that the event did not constitute a noncompliance and the event was not reportable pursuant to NRC requirements.

Evaluation Nonclompiiance Environmental Management procedure KP-LE-2202 defines an Environmental Noncompliance as "an event or occurrence that results in an environmental conaition which deviates form the project environmental requirements".

The following documents were reviewed to determine the project environmental requirements relative to cold shock mortality in Wolf Creek Cooling Lake:-WCGS Environmental Report-NUREG-75/096 "Final Environmental Statement construction of Wolf Creek Generating Station" related to the" WCGS Environmental Report OLS I'm NUREG 0878 "Final Environmental Statement related to the operation*of Wolf Creek Generating Station"-Letter KMLNRC 84-210 dated December 3, 1984 from G. L. Koester to H. R. Denton which transmitted the proposed Environmental Protection Plan-WCGS Operating License NPF-42 All of the above Licensing documents provide a consistent position relative to cold shock mortality.

The Wolf Creek d6cuments and correspondence identify the fact that plant transients during the winter months will likely result in a significant number of fish killed but large mortality will not result in significant impact to the environment.

Attachment to LI .39 page 3 of3 In considering the reportability relative to EPP section 4.1 it is important to consider several factors. Wolf Creek Cooling Lake was constructed by the project, for the sole purpose of providing cooling for the plant. The fishery has been developed to enhance plant availability by minimizing impingment potential.

While cold shock mortality could potentially' alter the fishery in the cooling lake, it will not adversely impact any of the public or other surrounding waters and fisheries.

Therefore, a significant cold shock mortality in Wolf Creek Cooling Lake does not result in a potentially significant-environmental impact unless it impacts other bodies of water or endangered species.in conclusina, Cnis evaiuacion Jecennined chac the subject event was not reportable for the following reasons:-The event was limited to WCCL, and The event was within the scope of what had been previously reviewed and found environmentally acceptable in the Licensing process, and-No endangered species were involved.This evaluation is consistent with the guidance obtained -from the NRC on previous occurrences.

AIF 07-002-01 Rev. 1 (Page 1 of 2)No._2004-02 EPP PLANT DESIGN OR OPERATIONAL CHANGE EVALUATION

1. GENERAL

SUMMARY

Document Number NA Rev Summary of Design or Operational Change: This evaluation documents the cold-shock fish kill following the plant trip on 2/13/04. An environmental evaluation is completed to determine if the event was greater than expected in the Final Environmental Statement, Operating License Stage (FES-OLS), Section 5.5.2.2.An evaluation of the event was completed immediately after the plant trip and concluded that it was not significant per AP 07-002, Environmental Protection Plan.2. EXCLUSIONS:

IF either questions 2.A OR 2.B listed below are answered yes, THEN an unreviewed environmental question determination is not required.

Section 3 on this form can be skipped. Provide explanations complete with applicable source document references.

A. Are all measurable nonradiological environmental effects confined to the on-site areas previously disturbed during site preparation and plant construction?

Yes X No Explanation:

The event was confined to the cooling lake, thus in an area disturbed by plant contruction.

B. Is this design or operational change required to achieve compliance with other Federal, State, and local environmental regulations (EPP section 3.3)?Yes Explanation:

NA No X 3. UNREVIEWED ENVIRONMENTAL QUESTION DETERMINATION:

An environmental question must meet one or more of the following criteria to be classified as unreviewed.

Provide explanations complete with applicable source document references.

A. Does this change constitute a matter which results in a significant increase in any adverse environmental impact previously evaluated by NRC?Yes No .X Explanation:

The fish kill event was less than a previous evaluation that did not result in measurable adverse impacts to the lake fishery (see EPP Design or Operational Change Evaluation 96-05). The plant shutdown started AIF 07-002-01 Rev. 1 (Page 2 of 2)on 2/13/04. Lake temperatures at the intake ranged from 36 to 38 F from 2/13/04 through 2/17/04. Discharge temperatures were estimated at 78 to 80 F, which was in the preferred temperature range of most fish species.Several surveys were completed following the shutdown and following are the results.Survey Date Species Area Number fish found 2/13/04 None found Discharge, Baffle Dike B 0 2/14/04 None found Discharge, Baffle Dike B, Lime Sludge 0 Pond shore, Stringtown Cemetery shore 2/16/04 Common carp 12 Gizzard shad 2 2/18/04 Common carp 50 Gizzard shad 5 Channel catfish 2 2/20/04 No additional 0 dead fish observed The fish mortality observed was much lower than estimated for EPP evaluation 96-05. Monitoring since the 1996 event did not indicate any adverse impacts attributable to the plant shutdown.

None are likely from this 2004 event.Per AP 07-002 guidance, the event was not considered significant based on: 1. The event was small; no game fish were impacted, and confined to the discharge area of the lake, which was closed to public access. Thus media attention was not likely.2. There were no impacts to offsite areas.3. Mortality observed was well below the numbers where no measurable impacts were observed in the past.Impacts greater than previously evaluated did not occur.B. Will this change constitute a significant change in effluents or power level?Yes No X Explanation:

NA C. Will this change constitute a matter not previously reviewed and evaluated in licensing documents which results.in a significant adverse environmental impact?Yes No X Explanation:

Fish mortality related to winter time plant shutdowns were previously evaluated in the FES-OLS.4. EPP EFFECTIVENESS AIF 07-002-01 Rev. 1 (Page 3 of 2)Does this design or operational change constitute a decrease in the effectiveness of the EPP in meeting its objectives?

Yes No X Explanation:

5. EPP CHANGE Does this design or operational change necessitate an EPP change?Yes No X Explanation:

If this design or operational change has been determined to be unreviewed with significant environmental impact, reducing the effectiveness of the EPP, or constitute an EPP change, a written evaluation must be submitted to the NRC and approval received PRIOR to initiation of the change. Submittals shall be in accordance with AP 26A-004 and AP 26B-001.Evaluation prepared by: 8/9/04 Preparer Date ,--E# IJL-S=L-Supervisory approval: 8/9/04 Supervisor Date Manager approval: Manager Date (Manager approval required only if the design or operational change involves an unreviewed environmental question, reduces the effectiveness of the EPP, or requires an EPP change.)

33. Section 2.5 of the ER (WCGS, 1980) describes the Topeka shiner, Neosho madtom, and Neosho mucket mussel. Please have available any records of these species being collected in impingement and entrainment sampling.

Aquatic EcologyP Page 3 of 3* Section 2.5 of the ER (WCGS, 1980) describes the Topeka shiner, Neosho madtom, and Neosho mucket mussel. Please have available any records of these species being collected in impingement and entrainment sampling.Information on the source of water for the Sharpe Generating Station mentioned in Section 2.12 of the ER (WCGS, 1980).-Information on potential riparian/wetland communities in the project area, including along the transmission line.* Information on any microbiological monitoring program, including any recent data." Section 6.2 of the ER (WCGS, 1980) notes that routine mitigation and monitoring programs are conducted, including effluent chemistry monitoring and water quality and fishery monitoring of CCL. Please provide at a minimum the most recent set of these data.* A description, including volumes, chemical, and radiological characteristics, of all solid, liquid, aqueous, and gaseous waste streams generated by the facility.

Include information on whether waste streams are disposed at off-site locations, or released to land, air, or water bodies on-site.IA Question 64. Section 2.5 of the ER (WCGS, 2006) describes the Topeka shiner, Neosho madtom, and Neosho mucket mussel. Are there any records of these species being collected in the impingement and entrainment sampling?Due to the unique habitat the Neosho madtom inhabits (I.e., riffles), madtoms are not found in lakes or reservoirs.

In addition, there has been no record of any of the above-described species being collected in WCGS impingement and entrainment studies.

KANSAS GAS AND ELECTRIC COMPANY WOLF CREEK GENERATING STATION MAKEUP SCREENHOUSE IMPINGEMENT MONITORING REPORT NOVEMBER, 1980 -OCTOBER, 1981 ACCEPTED:-.

Raymod F. Lewis, Jr.Supervisor Radiological/

Environmental Assessment APPROVED:

1.4F Greg R. Wedd Supervisor nvironmental Assessment A ,~ar AT.ý S chreibe" " Mark A'. Schreibet Environmental Biologist....;. /Stephen M. Williams Environmental Technician ii TABLE OF CONTENTS Page List of Tables ........ ...........

... iii List of Figures ..............

iv INTRODUCTION

...... ........ 1.METHODS ..................3 RESULTS AND DISCUSSION

......... ...9 SUM4MARY ..................43 Literature Cited ..............45 Appendices

....46.. .1 60 iii LIST OF TABLES Table Page 1. Randomized sampling dates ....... 4 2. Randomized sub-sampling periods ...7 3. Actual sampling dates .10 4. List of all taxa collected

......11 5. Estimated annual and percent of total impingement for all taxa .......13 6. Estimated daily minimum/maximum, monthly diurnal/nocturnal, monthly total impingement and monthly variance ....* ...........14 7. Calculated monthly biomass, diversity values, diurnal/nocturnal impingement rate and mean water temperature

....15 B. Monthly length and weight range/mean, impingement rate, and estimated number of. gizzard shad .....o ....0. 16 9. Monthly length and weight range/mean, impingement rate, and estimated number of common carp .. .. ....... 17 10. Monthly length and weight range/mean, impingement rate, and estimated number of goldfish .. .............

18 11. Monthly length and weight range/mean, impingement rate, and estimated number of red shiner ...0 0 0 0 .0 0 19 12. Monthly length and weight range/mean, impingement rate, and estimated number of ghost shiner o .......o ...20 13 Monthly length and weight range/mean, impingement rate, and estimated number of Notropis sp .......... ..21 14. Monthly length and weight range/mean, impingement rate, and estimated number of golden shiner ..o ...o. .o .o 22 iv LIST OF TABLES (cont'd)Table Page 15. Monthly length and weight range/mean, impingement rate, and estimated number of Pimephales sp .... .... ... 23 16. Monthly length and weight range/mean, impingement rate, and estimated number of river carpsucker

..........24 17. Monthly length and weight range/mean, impingement rate, and estimated number of smallmouth buffalo .........25 18. Monthly length and weight range/mean, impingement rate, and estimated number of channel catfish .*. ........26 19. Monthly length and weight range/mean, impingement rate, and estimated number of blue catfish. ... ........27 20. Monthly length and weight range/mean, impingement rate, and estimated number of flathead catfish .*. ........28 21. Monthly length and weight range/mean, impingement rate, and estimated number of white bass. .... ........29 22. Monthly length and weight range/mean, impingement rate, and estimated number of bluegill.

.............30 23. Monthly length and weight range/mean, impingement rate, and estimated number of orangespotted sunfish .......31 24. Monthly length and weight range/mean, impingement rate, and estimated number of longear sunfish 32 25. Monthly length and weight range/mean, impingement rate, and estimated number of green sunfish .......... .33 26. Monthly length and weight range/mean, impingement rate, and estimated number of Lepomis sp .............34 V LIST OF TABLES (cont'd)Table Page 27. Monthly length and weight range/mean, impingement rate, and estimated number of white crappie ..... .. ..... 3S 28. Monthly length and weight range/mean, impingement rate, and estimated number of walleye .........36 29. Monthly length and weight range/mean, impingement rate, and estimated number of freshwater drum .......... 37 vi LIST OF FIGURES Figure 1. Impingement study field data sheet .Page 8 INTRODUCT ION A permit for the construction of Wolf Creek Generating Station, Unit No. 1 (WCGS) was issued to Kansas Gas and Electric Company (KG&E) and Kansas City Power and Light Com-pany (KCPL) in 1977. As a condition to issuance of the per-mit [Item 3.f.(2)], the Nuclear Regulatory Commission (NRC)established a requirement that KG&E/KCPL monitor the impinge-ment of fish during the lake-filling phase of construction.

This report presents the results of a one-year impinge-ment study which fulfills the NRC requirement outlined in Section 6.1.3.2 of the Final Environmental Statement (FES), NUREG-75/096.

The objective of this study was to document species composition and abundance, size distribution and seasonality of fish impinged at the, WCGS Makeup Water Screenhouse (MUSH) located in the tailwaters of John Redmond Reservoir (JRR).The MUSH is situated on the east side of the Neosho River downstream of JRR dam. The MUSH houses three pumps, each with a maximum capacity of approximately 38,000 gallons per minute (gpm). Trash bar grills and 0.375 inch mesh ver-tical traveling screens are placed in front of each pump.The screen wash system is activated manually, by a timer or automatically from a high differential pressure switch. In-take velocities at the MUSH are quite low with calculated 2 velocities at the traveling screens ranging from 0.19 to 0.57 feet per second (fps) at 1007.5 MSL.An intake channel supplies makeup water to the screen house during normal flow conditions.

During low flow con-ditions, the channel deadends at the MUSH. However, when moderate to high flow exists, the channel is contiguous with the river. A more detailed description of the JRR discharge system and the MUSH can be found in the WCGS Environmental Report -Operating License Stage (ER/OLS), Section 3.4.3.1.

METHODS The study was initiated in November 1980 and continued through October 1981. Sampling frequency followed the schedule specified by the NRC in the FES and was as follows: two 12-hour screen counts twice weekly from April to July and twice monthly from August to March; one screen count for the period beginning at 0800 and ending at 2000; the other for the period beginning at 2000 and ending at 0800 the following day. Traveling screens were washed starting about 30 minutes before the beginning and end of a sample period.All debris and fish washed from the screen were collected in an aluminum basket or nylon bag net. The mesh size of both collection devices was 0.375 inch.A program was written to permit the random choice of sampling dates within intervals specified by the NRC. A Hewlett-Packard Model 41-C calculator was programmed and sampling dates recorded as they were produced.

The random-ized schedule of sampling dates is given in Table 1. The schedule of dates produced was utilized as a rigid schedule throughout the study. Impingement was monitored on any scheduled day when makeup pumps were operating.

If MUSH pumps were not in operation on a scheduled sampling date, that sampling effort was dropped from the study. In August, one exception to this system occurred due to erratic' pumping.In this case, a single additional sampling date was incor-porated into the study to replace the missed dates.

4 Table 1. Randomized sampling dates.MONTE DATE November, 1980 18, 25 December 3, 15 January, 1981 7, 19 February 1, 12 March 16, 27 April 2, 4, 6, 7, 13, 15, 21, 22, 27 May 1, 5, 8, 11, 12, 18, 21, 28, 29, 31 June 2, 7, 11, 18, 19, 25, 26, 28 July 1, 7, 8, 12, 13, 24, 25, 27, 28 August 15, 18 September 13, 14 October 7, 20 I 5 Fish collected during a 12-hour period were enumerated by species, making a full count of those species represented by 30 individuals or less. If the total number of a given species (N) was over 30 but less than 100, 50 percent of the group or a minimum of 30 individuals were processed.

If N was greater than 100, 30 fish plus one percent of N-100 were processed.

This system was used during the initial portion of the study, however, an alternative method was utilized when it became apparent that this method required the handling of excessive numbers of fish. Effective February 1, 1981, the system for enumeration of collected fish was changed to require full enumeration of those species represented by 25 individuals or less. If the actual or calculated total number of a given species (N) was greater than 25, an addi-tional one percent of the total (N) were processed, up to a maximum of 40 fish.Throughout the study, when species were present in num-bers greater than 100 individuals, the number and weight of the individuals of that species in the representative sub-sample was recorded.

These values were then compared with the total weight of all the individuals of that species in the sample to permit extrapolation of the total number.Extremely high impingement rates were encountered on February 1, 1981, and forced the reduction of the 12-hour collection period to four 10-minute subsamples within each 12-hour period. Times for these subsamples were selected 6 using the Random Number Generating Program. A separate run of the program was made for each of the sampling periods (Table 2). The 10-minute subsamples were taken at the be-ginning of each scheduled hour. Even with the time reduc-tion, limited resources made it impossible to completely sort each subsample.

Only a representative portion of each 10-minute subsample was sorted. Results of these sortings were then used to estimate the total number for each respec-tive subsample.

All fish enumerated were characterized by length, weight, size and maturity on a field data sheet (Figure 1).In addition, the following physical conditions were also recorded at the end of each sample period: water tempera-ture, air temperature, cloud cover, relative humidity, wind direction, wind speed, sample date, start and finish times.WCGS Operations personnel provided daily flow rate informa-tion for the duration of the study period.Data accumulated during the study were compiled into a program developed on a Sperry Univac Series 1100 Computer System. These results were then extrapolated to estimate various parameters of total impingement using equations modified from appropriate portions of EPRI EA-1402 (1980).Additionally, KG&E Environmental Assessment personnel per-formed calculations-of diversity (Lloyd et al, 1968).

7 Table 2. Randomized sub-sampling periods.SAMPLE DATE TIME PERIOD SUBSAMPLE TIME February 1, 1981 0800-2000 0900 1000 1800 1900 2000-0800 2000 2200 0500 0600

"'3 g.4.'I-4 4.1,~.d.so I Ct ca I-tb p.1.0 01 01 0 0 Ct WOLF GMRATING STATION DIPINGDO SIUDY FISH DATA SHEET No. 8 -Page _ of I i#4 U U Project Name Date-Beqin Sample Period Begin End Water Temperature Date-End Total Stomach Scale Physical Sex Species Length Weight Sampile Sample Cordition M/F Maturity 2.3.4.S.!7.9.10.11.12.13.14.15.16.18.19.20.21.22.23.24.25.Sample Duration Flowmeter No.Measuring Board No.Scale No.Scale No.Scale No.Scale No.Psychrometer No.Thenzmo"ter No.Camments _Collector's Signature Date Witness Signature Date Physical Conditions:

Air Temperature Cloud Cover Ralative.

Hum iity Whind Direction Wiind Speed Water Velocity: Surface m/sec.Mid Deptnh n/ec.Bottcm m/sec.Condition:

A = Alive B = Damaged C a DOaW Reviewed RESULTS AND DISCUSSION Monitoring Schedule Impingement at the MUSH was monitored when makeup pumping to WCCL was occurring according to the schedule in Table 1. However, shut-downs of MUSH pumping occurred perodically and sampling was not performed during these periods. Intermittent pumping resulted in deletion of a single monitoring date in both January and February.

Pump-ing was stopped to permit modification/maintenance of the pump control system for a prolonged period in early spring from April 1 to May 21. This resulted in a total of 15 sampling dates being dropped from the study. Additionally,.Ln August intermittent pumping caused both scheduled dates to be missed. In this case, a single sampling date was added to the study on a non-random basis. This was done to provide data for a month when significant pumping occurred that otherwise would not have been included in the study.Impingement was monitored at the MUSH on a total of 33 dates. A list of actual dates sampled for the study appears in Table 3.General A total of 19 species representing 15 genera and eight families were collected during this study (Table 4). The calculated estimate of the total impingment for the study 10 Table 3. Actual sampling dates.MONTH DATE November, 1980 December January, 1981 February March April May June July August September October 18, 25 3, 15 19 1 16, 27 21, 28, 29, 31 2, 7, 11, 18, 19, 25, 26, 28 1, 7, 8, 12, 13, 24, 25, 27, 28 28 13, 14 20 11 Table 4. List of all taxa collected.

Family Clupeidae Dorosoma cepedianum Gizzard shad Family Cyprinidae Cyprinus carpio Carassius auratus Notropis lutrensis Notropis buchanani Notropis sp.Notemigonus crysoleucas Pimephales sp.Common carp Goldfish Red shiner Ghost shiner Golden shiner Family Catostomidae Carpiodes carpio Ictiobus bubalus River carpsucker Smallmouth buffalo Family Ictaluridae Ictalurus punctatus Ictalurus furcatus Pylodictis olivaris Channel catfish Blue catfish Flathead catfish Family Percichthyidae Morone chrysops White bass Family Centrarchidae Lepomis macrochirus Lepomis humilis Lepomis megalotis Lepomis cyanellus Lepomis sp.Pomoxis annularis Bluegill Orangespotted sunfish Longear sunfish Green sunfish White crappie Family Percidae Stizostedion vitreum vitreum Family Sciaenidae Aplodinotus grunniens Walleye Freshwater drum 12 period was 105,465,103 fish. The weight of these individ-uals was estimated through calculations to be 1,403,086 kilograms.

The estimated annual impingement and percent of total impingement is presented in Table 5 for all taxa. Daily minimum/maximum, monthly diurnal/nocturnal, estimated month-ly total impingement and monthly variance appear in Table 6.Daily minimum/maximum values were derived either from actual 24-hour sample results or from mean daily impingement num-bers calculated from estimated monthly impingement.

Table 7 presents monthly biomass estimates, diversity values, diurnal/nocturnal/total impingement rates by volume and mean water temperature values. The ranges and means of length/weight, as well as impingement rate and estimated number impinged is presented for each taxa on a monthly basis in Tables 8 -29. Length frequency distribution for impinged fish is presented by month in Appendix I for all taxa.Observations on maturity of impinged fish are presented by month, along with estimates of numbers within each maturity classification in Appendix II.Impingement at the MUSH exhibited a high degree of variability seasonally in terms of numbers and species com-position.

Monthly impingement was highest during the winter months with an estimated peak of 80,139,235 fish in February (Table 6). Monthly variance seemed to generally correlate to impingement with the highest values occurring in the winter months and the lowest in the summer. Values for 13 Table 5. Estimated annual and percent of total impingement for all taxa.ESTIMATED ANNUAL % OF TOTAL SPECIES IMPINGEMENT IMPINGEMENT Gizzard shad White bass Freshwater drum White crappie Channel catfish Smallmouth buffalo Orangespotted sunfish Notropis sp.Flathead catfish River carpsucker Longear sunfish Green sunfish Common carp Golden shiner Bluegill Pimephales sp.Ghost shiner Lepomis sp.Goldfish Red shiner Walleye Blue catfish 104,965,263 244,747 239,355 7,318 5,429 2,098 206 103 101 99 85 77 59 39 37 28 25 12 9 7 3 2 99.526061 0.232065 0.226952 0.006939 0.005148 0.001990 0.000196 0.000097 0.0o0096 0.000094 0.000080 0.000073 0.000056 0.000037 0.000035 0.000026 0.000024 0.000011 0.000009 0.000007 0.000003 0.000002 Table 6.Estimated daily minimum/maximum, monthly diurnal/nocturnal, monthly total impingement and monthly variance.24-HOUR 24-HOUR MINIMUM MAXIMUM DIURNAL NOCTURNAL TOTAL ESTIMATE ESTIMATE MONTHLY MONTHLY MONTHLY MONTH OR ACTUAL OR ACTUAL ESTIMATE ESTIMATE ESTIMATE VARIANCE November 3,179 6,773 61,141 59,036 120,177 90,417,852.00 December 17,028 53,236 206,815 393,936 600,751 10,593,760,896.00 January 791,089 1,563,326 1,326,165 23,197,605 24,523,770 February 2,862,116 5,258,352 46,011,859 34,127,376 80,139,235 March 1,061 2,920 44,769 27,665 72,434 4,482,474.50 April -- NO SAMPLING COMPLETED

--May 18 108 198 375 573 5,514.65 June 14 61 518 447 965 765.94 July 17 80 754 685 1,439 999.24 August 19 29 207 394 602 -September 46 55 787 714 1,500 483.31 October 65 175 2,252 1,411 3,663 107,982.67 H~

Table 7. Calculated monthly biomass, diversity values, diurnal/nocturnal impingement rate and mean water temperature.

BIOMASS DIURNAL RAWE NOCTURNAL R§TE TOTAL RATE MEAN WATER MONTH ESTIMATE (Kg) DIVERSITY

(#/gal x 10-} (#/gal x 10 ) (#/gal x 10 ) TEMP (*C)November 2,114.20 0.18 58.03 56.67 57.35 4.7 December 9,717.18 0.06 314.95 640.73 455.61 4.3 January 397,738.44 0.01 2,028.15 36,232.44 19,803.58 3.9 February 990,514.38 0.05 68,430.75 53,990.42 63,617.30 0.6 March 2,690.86 0.54 39.51 23.99 31.76 12.5 April -- NO SAMPLING COMPLETED

--May 9.98 1.94 0.42 0.96 0.71 19.8 June 30.29 2.52 0.37 0.33 0.35 23.9 July 71.13 2.83 0.45 0.42 0.44 27.0 August 50.00 2.42 0.18 0.34 0.26 23.6 September 76.06 1.90 0.48 0.43 0.46 24.4 October 73.16 1.22 1.32 0.83 1.07 15.7 U1 w ---Table 8. Monthly length and weight range/mean, impingement rate and estimated number of gizzard shad.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 ) NUMBER November 49-234 98.1 10-115 11.4 55.982 117,302 December 65-235 91.0 10-122 10.0 452.787 597,151 January 81-236 96.0 10-113 10.1 19,796.330 24,514,431 february 85-233 101.1 10-107 10.9 63,313.879 79,732,164 fjarch 78-242 123.0 10-113 27.4 1.292 .2,954 April -- NO SAMPLING COMPLETED

--May 88-207 147.7 10-66 31.7 0.026 19 June 70-242 139.8 10-126 36.0 0.063 174 July 35-282 155.9 10-126 43.1 0.082 273 August 58-378 190.9 10-315 117.2- 0.063 145 September 100-260 178.1 27-120 54.2 0.041 134 October 42-190 96.2 10-54 38.0 0.152 520 I-a w *~- ---MW -qW -__Table 9. Monthly length and weight range/mean, impingement rate and estimated number of common carp.LENGTH MEAN WEIGHT MEAN RATE ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 106) NUMBER November .... 0.000 0 December .... 0.000 0 January ..... 0.000 0 February ..... 0.000 0 March ..... 0.000 0 April -- NO SAMPLING COMPLETED

--May .-.. 0.000 0 June 109 109.0 22 22.0 0.001 4 July 14-57 41.7 10-34 20.5 0.003 10 August ---. 0.000 0 September , ---0.000 0 October 73-106 90.7 10-20 15.5 0.013 46-4 Table 10. Monthly length and weight range/mean, impingement rate and estimated number of goldfish.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10% NUMBER November .... 0.000 0 December .... 0.000 0 January .... 0.000 0 February ----0.000 0 March .... 0.000 0 April -- NO SAMPLING COMPLETED

--May 157 157.0 46 46.0 0.003 2 June 110 110.0 16 16.0 0.001 4 July 130 130.0 36 36.0 0.001 3 August ----0.000 0 September

--0.000 0 October --0.000 0 Go


Table 11. M4onthly length and weight range/mean, impingement rate and estimated number of red shiner.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 ) NUMBER November .... 0.000 0 December .... 0.000 0 January .... 0.000 0 February .... 0.000 0 March .... 0.000 0 April -- NO SAMPLING COMPLETED

--May ---0.000 0 June 64-65 64.5 10 10.0 0.003 7 July ----0.000 0 August ----0.000 0 September


0.000 0 October ----0.000 0 I-'

-NNO-w-, w "r -w Table 12. Monthly length and weight range/mean, impingement rate and estimated number of ghost shiner.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 ) NUMBER November .... 0.000 0 December .... 0.000 0 January .... 0.000 0 february ..... 0.000 0 March 44 44.0 10 10.0 0.008 18 April -- NO SAMPLING COMPLETED

--May ---0.000 0 June 50 50.0 10 10.0 0.001 4 July 47 47.0 10 10.0 0.001 3 August ---0.000 0 September


0.000 0 October .... 0.000 0 0

!qble 14. Monthly length and weight range/mean, impingement rate and estimated number of Notropis sp.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 106) NUMBER November ----0.000 0 December 37 37.0 10 10.0 0.008 9 January .... 0.000 0 February ..... 0.000 0 March 36-43 39.3 10 10.0 0.024 55 April -- NO SAMPLING COMPLETED

--May ---0.000 0 June 45-55 50.0 10 10.0 0.003 7 July 44-53 49.7 10 10.0 0.003 10 August 63 63.0 10 10.0 0.009 21 September


0.000 0 October .... 0.000 .0 I-a 1010ý ."W- ---w ----w -n ------Table 14. Monthly length and weight range/mean, impingement rate and estimated number of golden shiner.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 NUMBER November .- 0.000 0 December --0.000 0 January .- 0.000 0 February .- -0.000 0 March 68-80 74.0 10 10.0 0.016 36 April -- NO SAMPLING COMPLETED

--May 80 80.0 10 10.0 0.003 2 June .... 0.000 0 July ... 0.000 0 August ... 0.000 0 September

... 0.000 0 October .... 0.000 0 Table 15.Monthly length and weight range/mean, impingement rate and estimated number of Pimephales sp.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 NUMBER November .- 0.000 0 December .- 0.000 0 January .- 0.000 0 february ----0.000 0 March 61 61.0 .10 10.0 0.008 18 April -- NO SAMPLING COMPLETED

-" May 72 72.0 10 10.0 0.003 2 June 39-40 39.5 10 10.0 0.003 7 July ----0.000 0 August --. 0.000 0 September

--0.000 0 October --0.000 0 wU

.ow -W ----Table 16. Monthly length and weight range/mean, impingement rate and estimated number of river carpsucker.

LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10-) NUMBER November 117-250 183.5 26-192 109.0 0.012 24 December ----0.000 0 January 236-371 315.0 172-720 452.3 0.038 48 Yebruary ----0.000 0 March .... 0.000 0 April -- NO SAMPLING COMPLETED

--May .... 0.000 0 June .- -0.000 0 July 172-398 257.9 66-800 269.5 0.008 27 August ----0.000 0 September

.... 0.000 0 October .... 0.000 0 q1NW -Mý- --Table 17. Monthly length and weight range/mean, impingement rate and estimated number of smallmouth buffalo.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 ) NUMBER November 110 110.0 16 16.0 0.006 12 December 105 105.0 13 13.0 0.008 9 qanuary .... 0.000 0 february 117-148 129.7 21-42 30.0 2.033 2,050 March 120 120.0 26 26.0 0.008 18 April -- NO SAMPLING COMPLETED

-May 128-129 128.5 30 30.0 0.006 6 June ---0.000 0 July 59 59.0 10 10.0 0.001 3 August ----0.000 0 September

.... 0.000 0 October .... 0.000 0 U'

". -W W W -Table 18.. Monthly length and weight range/mean, impingement rate and estimated number of channel catfish.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 ) NUMBER November 44-264 136.1 10-100 31.8 0.150 314 December 77-220 161.9 10-75 38.1 0.0.98 124 January 5.8-167 101.0 10-34 12.4 0.127 168 February 86-125 101.3 10-19 11.3 2.033 2,050 March 58-465 91.2 10-710 88.9 0.917 2,092 April -- NO SAMPLING COMPLETED May 77-218 117.9 10-65 15.9 0.247 196 june 80-290 136.9 10-211 37.4 0.024 68 July 35-345 145.2 10-170 41.6 0.011 37 August 53-220 146.2 10-75 38.2 0.054 124 September 64-197 118.0 10-63 28.4 0.032 104 October 53-218 107.9 10-106 39.8 0.045 153 at W- -mw w- ----Table 19. Monthly length and weight range/mean, impingement rate and estimated number of blue catfish.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 106) NUMBER November .... 0.000 0 December .- 0.000 0 January .- 0.000 0 February .- 0.000 0 March .- 0.000 0 April -- NO SAMPLING COMPLETED

--May 135 135.0 20 20.0 0.003 2 June ----0.000 0 July ----0.000 0 August --0.000 0 September

--0.000 0 October --- -0.000 0 Table 20. Monthly length and weight range/mean, impingement rate and estimated number of flathead catfish.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 106) NUMBER povember .... 0.000 0 December .... 0.000 0 January ..... 0.000 0 February .... 0.000 0 March .... 0.000 0 April -- NO SAMPLING COMPLETED

--14ay 68-142 105.0 10-29 18.0 0.006 6 June ---0.000 0 duly 59-220 145.7 10-102 72.5 0.004 13 August 94 94.0 10 10.0 0.009 21 September


0.000 0 October 48-90 64.0 10 10.0 0.018 60 I~J r- --w --Table 21. Monthly length and weight range/mean, impingement rate and estimated number of white bass.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 ) NUMBER November 103-292 161.4 10-340 95.2 0.029 60 December 88-117 101.6 10-20 14.6 0.498 625 January 94-111 102.0 10-20 15.5 1.507 1,951 February 89-111 102.6 10-19 13.9 175.668 241,357 ,4arch 95-108 101.9 10-15 11.5 0.104 238 April -- NO SAMPLING COMPLETED May ----0.000 0 June 32-68 45.7 10 10.0 0.019 53 July 43-196 70.9 10-100 15.5 0.079 262 August 207 207.0 114 114.0 0.009 21 September 92-203 157.8 10-120 53.6 0.041 134 October 108-195 138.3 15-65 33.0 0.013 46 qko Iwo--w --Nwqw -W mupw~w ~ -w --w -------'WW -w ~--M ý W W Table 22. Monthly length and weight range/mean, impingement rate and estimated number of bluegill.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 NUMBER November ---0.000 0 December 38 38.0 10 10.0 0.008 9 January .... 0.000 0 February .... 0.000 0 March .... 0.000 0 April -- NO SAMPLING COMPLETED

--May 62 62.0 10 10.0 0.003 3 June 65-114 97.0 11-36 23.7 0.004 11 July 67-109 83.2 12-30 19.5 0.004 13 August ---0.000 0 September 0.000 0 October 0.000 0 L.J 0 WWFW I-%WqW 1W "WqxMW-a-q "-- WW -W 1W W " --w --W AW --w --ý -M. 4W -ý "r Table 23. Monthly length and weight range/mean, impingement rate and estimated number of orangespotted sunfish.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 ) NUMBER November .... 0.000 0 December ... 0.000 0 January ... 0.000 0 February ... 0.000 0 March 50-57. 53.5 10 10.0 0.016 36 April -- NO SAMPLING COMPLETED

--May 53-83 66.8 10-18 10.0 0.067 61 June 51-83 67.7 10-14 10.0 0.017 46 July 49-102 69.6 10-22 10.7 0.019 63 August ---0.000 0 September 0.000 0 October 0.000 0 I-A 1W- W -W --Table 24. Monthly length and weight range/mean, impingement rate and estimated number of longear sunfish.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 NUMBER November ----0.000 0 December .... 0.000 0 January ---0.000 0 february .... 0.000 0 March ----0.000 0 April --NO SAMPLING COMPLETED

--May ---0.000 0 June 55-97 71.3 10-21 13.0 0.009 25 July 64-135 84.3 10-70 18.1 0.018 60 August ---0.000 0 September

---0.000 0 October ---0.000 0 L.

Table 25. Monthly length and weight range/mean, impingement rate and estimated number of green sunfish.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 ) NUMBER November .... 0.000 0 December ----0.000 0 January 114 114.0 30 30.0 0.013 17 February ----0.000 0 March ..... 0.000 0 April -- NO SAMPLING COMPLETED

--May 74-107 90.5 16-46 31.0 0.006 6 June 60-65 62.0 10 10.0 0.004 11 July 61-173 84.7 10-110 22.6 0.013 43 August --. 0.000 0 September

--0.000 0 October -0.000 0 LAI Table 26. Monthly length and weight range/mean, impingement rate and estimated number of Lepomis sp.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 NUMBER November ----0.000 0 December 56 56.0 10 10.0 0.008 12 January .... 0.000 0 February .... 0.000 0 March -, -0.000 0 April -- NO SAMPLING COMPLETED

--May .... 0.000 0 June .0.000 0 July .- 0.000 0 August .- 0.000 0 September

.- 0.000 0 October 0.000 0'4 m w-------- ----w -qup -Wr qW -Table 27. Monthly length and weight range/mean, impingement rate and estimated number of white crappie.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 ) NUMBER November 114-253 183.5 19-245 132.0 0.012 24 December 103-278 222.2 16-355 210.0 0.049 59 January 105-252 180.4 18-270 86.2 0.127 164 February 89-279 150.7 10-305 88.5 3.775 5,869 March 102-296 195.8 14-435 159.6 0.160 365 April -- NO SAMPLING COMPLETED

--May 162.0 162.0 54.0 54.0 0.003 2 June 108-248 165.8 19-265 73.3 0.033 92 July 36-284 156.1 10-370 78.1 0.039 130 August 77-278 181.0 10-275 99.7 0.072 166 September 77-280 166.9 10-290 79.2 0.122 401 October 97-118 104.3 12-19 14.3 0.013 45 Ln


w '- ------w --w -w w -ý -qw 4W --WýTable 28. Monthly length and weight range/mean, impingement rate and estimated number of walleye.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 ) NUMBER November --, -0.000 0 December .- -0.000 0 January .- -0.000 0 February ---0.000 0 March ---0.000 0 April -- NO SAMPLING COMPLETED

--May ----0.000 0 June .- -0.000 0 July 490 490.0 1360 1360.0 0.001 3 August ----0.000 0 September

.... 0.000 0 October .... 0.000 0 w Table 29. Monthly length and weight range/mean, impingement rate and estimated number of freshwater drum.LENGTH MEAN WEIGHT MEAN RATE 6 ESTIMATED MONTH RANGE (mm) LENGTH (mm) RANGE (g) WEIGHT (g) (#/gal x 10 ) NUMBER November 67-218 116.7 10-106 21.7 1.164 2,440 December 66-238 129.0 10-136 33.0 2.146 2,751 January 7.7-195 103.2 10-74 15.0 5.434 6,990 February 68-202 98.6 10-78 10.4 119.919 155,745 March 77-185 100.6 10-60 10.8 29.203 66,602 April -- NO SAMPLING COMPLETED

--May 72-236 114.1 10-136 18.4 0.327 265 June 27-180 111.4 10-60 23.1. 0.163 453 July 38-387 100.7 10-550 36.4 0.147 485 August 48-78 65.4 10 10.0 0.04.5 104 September 59-182 90.1 10-68 14.7 0.221 728 October 62-237 91.9 10-122 13.5 0.819 2,793-4 38 January, February, and September were not available since sampling occurred on only one date in each of these months.Impingement was not consistently higher during either diur-nal or nocturnal periods throughout the study. Diversity values were highest during the mid-summer months, peaking.in July at 2.83 while the lowest value, 0.01, occurred in January (Table 7). A discussion of various parameters as they relate to the taxa collected plus the mechanisms affecting impingement follows for each family occurring in the study.Clupeidae This family was represented by only the gizzard shad, which comprised over 99.5% of the total impingement during the study. Length-frequency data indicated that over 90% of gizzard shad processed during the study were less than 125 mm total length (TL). The data would therefore indicate that these fish fall within the average first year growth for mid-western gizzard shad (Purkett, 1958). The rate of impingement indicates that the largest numbers of young-of-the-year (YOY) gizzard shad were impinged during the winter (Table 8).Impingement of gizzard shad increased from December through February, peaking at over 63,000 fish per million gallons. On several occasions during this period, substan-tial numbers of YOY gizzard shad were observed being swept through the JRR gates and out of the stilling basin's low 39 flow channel. These fish were unable to maintain their orientation in the current and appeared to be in a stressed condition.

When monitoring resumed in May, the rate of gizzard shad impingement had dropped to its lowest rate observed during the study. Although gizzard shad continued to be impinged throughout the remainder of the study, their rates were similar to other species.Cyprinidae During the study, several members of this family were impinged including common carp, goldfish, red shiner, ghost shiner, golden shiner, Notropis sp. and Pimephales sp. As a family, cyprinid taxa comprised a minor portion of the total impingement.

Only two members of this family, Notropis sp. and golden shiner, were impinged at a rate exceeding 0.015 fish I per million gallons (Tables 9 -15). Notropis sp. and golden shiner impingement both peaked in March at 0.024 and 0.016 fish per million gallons, respectively.

Common carp were never a large component of sampled daily impingement.

They occurred in June, July and October, peaking in October at a rate of 0.013 fish per million gallons.Catostomidae Two species of this family, river carpsucker and small-mouth buffalo, were collected during the study (Tables 16 -I 40 17). River carpsucker were not a major component of total impingement but smallmouth buffalo were the sixth most com-mon taxa impinged during the study (Table 5). Despite the number six ranking, total smallmouth buffalo impingement was calculated to be only slightly over 2,000 fish for the entire study period.Ictaluridae Channel catfish, blue catfish and flathead catfish represented this family during the study. Channel catfish" occurred consistently throughout the study. This species ranked fifth in total impingement with a calculated estimate of 5,429 fish (Table 5). Throughout the study the majority of channel catfish impinged were less than 150 mm TL al-though individuals up to 465 mm were collected in March (Table 18). Monthly mean lengths of impinged channel cat-fish never exceeded 162 mm throughout the study.Only one blue catfish was processed during collections at the MUSH. This individual, was 135 mm in length and was collected in May (Table 19). The collection of this indi-vidual coincided with the harvesting of a Kansas Fish and Game Commission (KF&G) rearing pond which contained blue catfish and drained into the Neosho River. This individual was within the size range of fish harvested from this pond and probably escaped during draining operations.

Flathead catfish occurred during the summer months but were never numerous (Table 20). October was the peak month 41 for impingement of this species with a calculated total of 60 individuals.

Percichthyidae Only one member of this family, white bass, occurred during the study. Although this species was the second most commonly impinged taxa, it comprised less than 0.25% of total impingement (Table 5). Throughout the study white bass impingement was confined to early age groups with the monthly average length never exceeding 210 mm TL (Table 21).Over 98% of total white bass impingement occurred in February and during that month their mean length was approx-imately 102 mm.Centrarchidae The six taxa of this family which occurred during the study were bluegill, orangespotted sunfish, longear sun-fish, green sunfish, Lepomis sp. and white crappie. Of these taxa, only white crappie ranked in the top six in terms of total impingement, ranking number four (Table 5).Mature white crappie in ripe condition were impinged during March but comprised only 5% of all crappie processed for that month (Appendix II). Other members of the sunfish family were observed in spawning condition.

Bluegill, orangespotted sunfish, longear sunfish and green sunfish were impinged in ripe and running ripe condition.

These spawning individuals comprised significant portions of 42 impingement for their respective species. However, none of these species ranked high in terms of total impingement.

Percidae Impingement of this family was limited to one species, the walleye. Only one individual was collected during sampling and the total annual walleye impingement was cal-culated to be three fish (Table 28).Sciaenidae The only member of this family impinged was the fresh-water drum. Although freshwater drum ranked third in impingement, they comprised slightly less than 0.25% of the total catch (Table 5). This species was impinged throughout the study with peak numbers occurring in February.

The monthly mean length ranged from 65 to 129 mm (TL) and monthly mean weights never exceeded 37 grams (Table 29).Additionally, over 98% of all drum which could be sexed were classified as immature (Appendix II).

SUMMARY

Data collected during monitoring at the MUSH reveals a pattern typical of impingement at many other facilities (Edwards et al, 1976: Freeman and Sharma, 1977). This pattern shows impingement dominated by the major clupeid species present, peaking during winter months and composed of young-of-the-year (YOY) fish, with sportfish occurring at low rates.Throughout the study gizzard shad were the dominant component of impinged fish, comprising over 99% of the calculated total. Field observations plus impingement study data supports a hypothesis that during peak impingement, shad were being discharged from JRR in a stressed condition and were unable to avoid the low intake velocities present at the MUSH.Gizzard shad, along with white bass and freshwater drum, comprised more than 99.9% of total impingement.

Peak impingement for all three of these taxa occurred during January and February and was predominantly YOY fish.Neither blue sucker (Cycleptus elongatus) or Neosho madtom (Noturus placidus) individuals were impinged during the study. No impingement of Neosho madtoms was expected since this species has not been collected during prolonged monitoring in the area of the MUSH. Additionally, no other rare, threatened or endangered species were impinged at the MUSH.

44 The data compiled and circumstances observed during the monitoring period indicate that a worst case situation has been monitored.

Low rainfall resulted in discharge rates from JRR which were low enough to consistently isolate the intake channel from the Neosho River throughout late 1980 and early 1981. Additionally, lake filling activities necessitated maximum pumping efforts throughout the study.These factors combined to cause the high impingement ob-served during the winter months.Normal rainfall patterns will typically provide more favorable flow conditions and completion of lakefill will substantially reduce demands for makeup water. The combin-ation of these circumstances will ameliorate the contri-butory factors of the observed impingement thereby moderat-ing long-term impingement at the MUSH.

LITERATURE CITED Edwards, T. J., W. H. Hunt, L. E. Miller and J. J. Sevic.1976. An evaluation of the impingement of fishes at four Duke Power Company steam-generating facilities.

in Thermal Ecology II. Esch, G. W. and R. W. McFarlane, Editors. Technical Information Center of Energy Re-search and Development Administration.

pp. 373-380.Electric Power Research Institute.

1980. Methodology for assessing population and ecosystem level effects re-lated to intake of cooling waters. Electric Power Research Institute Report EA-1402 Volume 1, 370 pp.Freeman, R. F. III and R. K. Sharma. 1977. Survey of fish impingement at power plants in the United States; Vol-ume II. Argonne National Lab. ES-56. 328 pp.Lloyd, M., J. H. Zar and J. R. Karr. 1968. On the calcula-tion of information-theoretical measures of diversity.

Am. Midl. Nat. 79(2):257-272.

Purkett, C. A., Jr. 1958. Growth rates of Missouri stream fishes. Mo. Cons. Comm., D-J Ser. No. 1, 46 pp.United States Nuclear Regulatory Commission, Final Environ-mental Statement for Wolf Creek Generating Station.1975. NUREG-75/096.

APPENDIX I 47 Length Frequency and Individuals Processed by Month for All Taxa SPECIES MONTH SIZE (mm)ACTUAL NUMBER Gizzard shad November December January February March May 26-50 76-100 101-125 126-150 176-200 201-225 226-250 51-7 5 76-100 101-125 176-200 201-225 226-250 76-100 101-125 226-250 76-100 101-125 201-225 226-250 76-100 101-125 126-150 201-225 226-250 76-100 101-125 126-150 201-225 1 237 30 1 1 7 3 30 466 45 1 3 1 237 60 1 157 79 3 1.42 26 1 9 7 2 2 1 3 48 Length Frequency and Individuals Processed by Month for All Taxa (continued)

SPECIES MONTH SIZE (mm)ACTUAL NUMBER Gizzard shad June July August September 51-75 76-100 101-125 126-150 151-175 176-200 201-225 226-250 26-50 51-75 76-100 101-125 126-150 151-175 176-200 201-225 226-250 251-275 27 6-3 00 51-75 126-150 151-175 226-250 251-275 376-400 76-100 151-175 176-200 201-225 226-250 251-275 2 8 13 8 10 1 3 4 3 8 1 6 17 26 34 6 8 3 1 2 1 1 1 1 1 1 4 1 1 1 1 49 Length Frequency and Individuals Processed by Month for All Taxa (continued)

SPECIES MONTH SIZE (mm)ACTUAL NUMBER Gizzard shad October Common carp June July October 26-50 51-75 76-100 101-125 151-175 176-200 101-125 1-25 51-75 51-75 76-100 101-125 151-175 101-125 126-150 51-75 26-50 26-50 26-50 Goldfish 4 7 15 1 4 3 Red shiner Ghost shiner May June July June March June July 1 1 2 1 1 1 1 1 1 2 1 Notropis sp.December March June 26-50 26-50 26-50 51-75 26-50 51-75 51-75 1 3 1 1 1 1 July August 50 Length Frequency and Individuals Processed by Month for All Taxa (continued)

SPECIES MONTH SIZE (mm)ACTUAL NUMBER Golden shiner Pimephales sp.March May March May June River carpsucker November January July Smallmouth buffalo November December February March May July 51-75 76-100 76-100 51-75 51-75 26-50 101-125 226-250 226-250 326-350 351-375 151-175 201-225 226-250 301-325 376-400 101-125 101-125 101-125 126-150 101-125 126-150 51-75 1 1 1 1 1 1 3 1 2 1 1 1 1 1 1 2 1 1 2 1 1~2 1 51 Length Frequency and Individuals Processed by Month for All Taxa (continued)

SPECIES MONTH SIZE (mm)ACTUAL NUMBER Channel catfish November December January February March 26-50 51-75 76-100 101-125 151-175 176-200 201-225 226-250 251-275 76-100 101-125 151-175 176-200 201-225 51-75 76-100 101-125 126-150 151-175 76-100 101-125 51-75 76-100 101-125 126-150 151-175 176-200 201-225 426-450 451-475 1 5 3 5 5 2 3 1 1 2 1 3 4 2 1 5 2 1 1 2 1 46 24 3 1 1 2 1 1 1 52 Length Frequency and Individuals Processed by Month for All Taxa (continued)

SPECIES MONTH SIZE (mm)ACTUAL NUMBER Channel catfish May June I July I 76-100 101-125 126-150 151-175 176-200 201-225 76-100 101-125 126-150 151-175 251-275 276-300 26-50 51-75 101-125 126-150 176-200 326-350 51-75 101-125 151-175 176-200 201-225 51-75 101-125 176-200 51-75 76-100 101-125 151-175 201-225 30 26 2 5 6 3 4 6 5 2 1 1 1 I 3.2 3 1 1 1 2 3 3 2 2 2 3 3 1I 1.August September October Blue catfish May 126-150 1 53 Length Frequency and Individuals Processed by Month for All Taxa (continued)

SPECIES MONTH SIZE (mm)ACTUAL NUMBER Flathead catfish May July August October White bass November December January February March June July August September 51-75 126-150 51-75 151-175 201-225 76-100 26-50 51-75 76-100 101-125 201-225 276-300.76-100 101-125 76-100 101-125 76-100 101-125 76-100 101-125 26-50 51-75 26-50 51-75 76-100 151-175 176-200 201-225,76-100 101-125 176-200 201-225 3 1 1 21.37 27.62 36 96 3 10 12 3 10 47 18 3 1 1 2 1 5 I.1 1 1 1 1 1 1 2 1 54 Length Frequency and Individuals Processed by Month for All Taxa (continued)

SPECIES MONTH SIZE (mm)ACTUAL NUMBER White bass October Bluegill December May June 101-125 176-200 26-50 51-75 51-75 101-125 51-75 76-100 101-125 2 1 1 1 1 2 2 1 1 July Orangespotted sunfish I I I I I I March May June July June 26-50 51-75 51-75 76-100 51-75 76-100 26-50 51-75 76-100 101-125 51-75 76-100 51-75 76-100 126-150 101-125 51-75 101-125 51-75 1 1 17 4 11 2 2 11 5 i 5 2 4 13 1 Longear sunfish July i I I Green sunfish January May 1 1 1 3 June 55 Length Frequency and Individuals Processed by Month for All Taxa (continued)

SPECIES MONTH SIZE (mm)ACTUAL NUMBER Green sunfish July 51-75 76-100 101-125 151-175 7 3 2 1 1 Lepomis sp.White crappie December November December January February March May 51-75 101-125 251-275 101-125 151-175 226-250 251-275 276-300 101-125 126-150 151-175 176-2 00 201-225 226-250 251-275 76-100 101-125 276-300 101-125 126-150 151-175 201-225 226-250 251-275 276-300 151-175 56 Length Frequency and Individuals Processed by Month for All Taxa (continued)

SPECIES MONTH SIZE (mm)ACTUAL NUMBER White crappie June July August September 101-125 126-150 151-175 176-200 201-225 226-250 26-50 51-75 76-100 101-125 126-150 151-175 176-200 201-225 226-250 251-275 276-300 76-100 101-125 126-150 176-200 201-225 226-250 276-300 76-100 101-125 126-150 151-175 176-200 201-225 226-250 251-275 276-300 2 5 9 7 2 1 2 2 4 1 4 11 11 1 1 1 1 1 1 1 1 2 1.1 4 2 3 5 6 3 1 1 1 57 Length Frequency and Individuals Processed by Month for All Taxa (continued)

SPECIES MONTH SIZE (mm)ACTUAL NUMBER White crappie October Wal leye July Freshwater drum November December January February March 76-100 101-125 476-500 51-75 76-100 101-125 151-175 176-200 201-225 51-75 76-100 101-125 151-175 176-200 201-225 226-250 76-100 101-125 126-150 176-200 51-75 76-100 101-125 176-200 201-225 76-100 101-125 126-150 151-175 176-200 8 83 31 2 21 11 2 67 16 4 30 10 2 43 16 1 5 2 73 30 1 1~81 47 2 3 2 1 1.

58 Length Frequency and Individuals Processed by Month for All Taxa (continued)

SPECIES MONTH SIZE (mm)ACTUAL NUMBER Freshwater drum May June July August September 51-75 76-100 101-125 126-150 151-175 176-200 201-225 226-250 26-50 76-100 101-125 126-150 151-175 176-200 26-50 51-75 101-125 126-150 151-175 201-225 226-250 376-400 26-50 51-75 76-100 51-75 76-100 101-125 126-150 176-200 3 26 58 3 1 6 2 1 19 13 39 51 4 1 9 64 12 53 5 1 1 2 2 9 34 3 1 2-59 Length Frequency and Individuals Processed by Month for All Taxa (continued)

SPECIES MONTH SIZE (mm)ACTUAL NUMBER Freshwater drum October 51-75 76-100 101-125 126-150 151-175 226-250 15 50 15 1 1 1 APPENDIX II 61 Maturity Classification Estimates by Taxa SPECIES MONTH MATURITY ESTIMATED NUMBER Gizzard shad November December January February March May June July August September October Immature Mature Immature Mature Immature Mature Immature Mature Unknown Immature Mature Immature Mature Unknown Immature Mature Spent Unknown Immature Mature Unknown Unknown Immature Immature Unknown Unknown Immature Immature Immature Immature Unknown 112,275 5,027 594,964 2,187 24,432,168 82,263 78,403,294 1,328,869 104 2,433 417 17 2 32 124 11 7 140 126 7 145 59 148 520 Common carp June July October May June July 4.3 7 46 Goldf ish 2 4-3 62 Maturity Classification Estimates by Taxa (continued)

SPECIES MONTH MATURITY ESTIMATED NUMBER Red shiner Ghost shiner June March June July Notropis sp.December March June July Golden shiner Pimephales sp.August March May March May June Immature Immature Unknown Unknown Immature Immature Immature Unknown Immature Unknown Immature Immature Immature Mature Immature Immature Mature Mature Unknown Immature Mature Immature Immature Immature Immature Immature Immature 7 18 4 3 9 55 7 3 7 21 36 2 18 2 7 12 12 48 17 7-3 River carpsucker November January July Smallmouth buffalo November December February March May July 12 9 2,050 18 6-3 63 Maturity Classification Estimates by Taxa (continued)

SPECIES MONTH MATURITY ESTIMATED NUMBER Channel catfish November December January February March May June July August September October Immature Mature Immature Immature Immature Immature Mature Unknown Immature Mature Unknown Immature Unknown Immature Unknown Unknown Immature Unknown Immature Immature Immature Unknown Immature Unknown Unknown Immature 230 85 124 168 2,050 2,040 52 3 191 3 11 57 17 20 124 15 89 46 107 Blue catfish Flathead catfish May May July August October 2 6 10 21 15 45 64 Maturity Classification Estimates by Taxa (continued)

SPECIES MONTH MATURITY ESTIMATED NUMBER White bass November December January February March June July August September October Immature Mature Immature Immature Immature Immature Immature Unknown Immature Unknown Unknown Immature Unknown Immature 48 12 625 1,951 241,357 238 53 70 193.21 45 89 15 31 Bluegill December May June Immature Immature Immature Mature Running Ripe Unknown Running Ripe 9 3 4 4 4 10 3 July Orangespotted sunfish March May Immature Unknown Immature Mature Ripe Running Ripe 36 3 12 17 26 3 65 Maturity Classification Estimates by Taxa (continued)

SPECIES MONTH MATURITY ESTIMATED NUMBER Orangespotted sunfish June July Longear sunfish June July Immature Mature Ripe Running Ripe Unknown Immature Mature Ripe Running Ripe Ripe Running Ripe Unknown Mature Running Ripe Spent Unknown Unknown Running Ripe Immature Unknown Immature Ripe Running Ripe Immature 32 4 7 4 20 3 13 20 7 11 14 10 3 40 7 17 3 3 11 3 3 33 3 Green sunfish January May June July Lepomis sp.White crappie December November December Immature Mature Immature Mature 12 12 12 10 49 66 Maturity Classification Estimates by Taxa (continued)

SPECIES MONTH MATURITY ESTIMATED NUMBER White crappie January February March May June July August September October Immature Mature Immature Mature Immature Mature Ripe Mature Unknown Immature Mature Unknown Immature Mature Unknown Unknown Immature Immature Unknown Immature Mature Immature Mature Immature Immature Mature Unknown Immature Mature 148 16 4,402 1,467 183 164 18 2 28 60 4 63 60 7 166 252 149 45 Wal leye July 3 Freshwater drum November December January February March 2,002 438 2,478 273 6,990 154,289 1,456 497 65,608 497 67 Maturity Classification Estimates by Taxa (continued)

SPECIES MONTH MATURITY ESTIMATED NUMBER Freshwater drum May June July August September October Unknown Immature Mature Unknown Immature Unknown Immature Unknown Immature Immature Unknown Immature 3 260 3 32 420 83 402 62 41 728 67 2,726

38. A description, including volumes, chemical, and radiological characteristics, of all solid, liquid, aqueous, and gaseous waste streams generated by the facility.Include information on whether waste streams are disposed at off-site locations, or released to land, air, or water bodies on-site.

Aquatic Ecology Page 3 of 3-Section 2.5 of the ER (WCGS, 1980) describes the Topeka shiner, Neosho madtom, and Neosho mucket mussel. Please have available any records of these species being collected in impingement and entrainment sampling.* Information on the source of water for the Sharpe Generating Station mentioned in.Section 2.12 of the.ER (WCGS, 1980).-Information on potential riparian/wetland communities in the project area, including along the transmission line." Information on any microbiological monitoring program, including any recent data." Section 6.2 of the ER (WCGS, 1980) notes that routine mitigation and monitoring programs are conducted, including effluent chemistry monitoring and water quality and fishery monitoring of CCL. Please provide at a minimum the most recent set of these data.-A description, including volumes, chemical, and radiological characteristics, of all solid, liquid, aqueous, and gaseous waste streams generated by the facility.

Include information on whether waste streams are disposed at off-site locations, or released to land, air, or water bodies on-site..

Aquatic Ecology 104 Provide a description, including volumes and chemical and radiological characteristics, of all solid, liquid, aqueous,.and gaseous waste streams generated by the facility.

Include information on whether waste streams are disposed at offsite locations, or released to land, air, or water bodies onsite.Solid Wastes WCGS has greatly reduced the volume of hazardous waste generated over the years. Until 2004, WCGS was considered to be an EPA (Large Quantity)Generator of hazardous wastes. Since 2004, WCGS has been a Kansas Generator.

In 2006, WCGS generated a total of 1577.6 lbs. of hazardous waste (see attached table). All hazardous wastes generated at WCGS are sent to offsite treatment and disposal facilities.

WCGS has been an interim status permitted storage facility for mixed (hazardous/radioactive) waste, but the storage facility has been empty since 1997. The process of closing this storage facility has been initiated.

WCGS generates two waste streams managed as universal wastes. In 2006, 2400 lbs. of universal waste batteries and 240 lbs. of universal waste lamps were generated.

Several nonhazardous waste streams are generated and shipped offsite for treatment and/or disposal (see attached table). WCGS has implemented recycling programs for a variety of materials.

These programs are listed in the Waste Minimization Plan (attached).

Finally, approximately 32,000 lbs. of regular trash are disposed of in the Coffey County Landfill annually.

Waste Description Characteristics Pounds Disposition Generated Battery Post Cleaning toxic (lead) 2 offsite TSDF Solids Ignitable Liquids ignitable 162.8 offsite TSDF HW EPA 2000 toxic (lead, cadmium) 573.4 offsite TSDF Silver Nitrate Sol. toxic (silver) 3.1 offsite TSDF Photovolt Sol. toxic (pyridine) 0 offsite TSDF Petroleum Ether Waste ignitable 35.3 offsite TSDF Monoethylamine ignitable 77.7 offsite TSDF Gun Cleaning Waste toxic (lead) 62.8 offsite TSDF Film Fixer toxic (silver) 68.7 offsite TSDF Waste Fuel ignitable 77.3 offsite TSDF Parts Washer Sludge toxic (lead, cadmium) 0 offsite TSDF Paint Solids toxic (lead, cadmium, 4.4 offsite TSDF barium, chromium)Paint Related Materials toxic (lead, cadmium, 0 offsite TSDF barium, chromium)Paint Sludge ignitable, toxic (lead, 0 offsite TSDF cadmium, barium, chromium)Paint Thinner ignitable, toxic (lead, 342.1 offsite TSDF cadmium, chromium)HW Sampling Equipment toxic (varies) 4 offsite TSDF Labpacks varies 122 offsite TSDF Lead Insulation toxic (lead) 42 offsite TSDF Mixed Waste

  • varies 0 offsite TSDF 2006 Hazardous Waste Generation at Wolf Creek Generating Station (* Mixed Waste is hazardous and radioactive.

All other hazardous wastes in this table are nonradioactive.)

Waste Description Estimated Annual Disposition Generation Volume Alumina Air Desiccant 2 cubic yards Coffey County Landfill*Empty Drums 20 Coffey County Landfill*Activated Charcoal 20 cubic yards Coffey County Landfill*Oil & Fuel Filters/Oily Rags 4 cubic yards Coffey County Landfill*Resin Beads 30 cubic yards Coffey County Landfill*Oil Sweeps 10 cubicyards Coffey County Landfill*Asbestos Containing Wastes 1 cubic yard Coffey County Landfill*Sandblast Grit 25 cubic yards Coffey County Landfill*Grease < 1 cubic yard Coffey County Landfill*Rags Slightly Contaminated With < 1 cubic yard Coffey County Landfill*Isopropanol Capacitors, Non PCB < 1 cubic yard Coffey County Landfill*Fire Protection Training Area Sludge < 1 cubic yard Coffey County Landfill*Aux Boiler Stack Clean-Out

< 1 cubic yard Coffey County Landfill*Antifreeze 100 gal. offsite recycling Used Oil 3000 gal. offsite (burned as fuel)Nonhazardous Wastes Generated at Wolf Creek Generating Station (* Disposed of under Special Waste Disposal Authorizations from the Kansas Department of Health and Environment)

A G E.D 0'&/0 2/2 0 0 ,5 DOCUMENT CONTROL NUMBER WCEM-04-010 Document Control Revision I WOLF CREEK NUCLEAR OPERATING CORPORATION WASTE MINIMIZATION PLAN Rev. 06/2005 I for K. Moles 6/24/2005 APPROVED: Manager Regulatory Affairs Date RELEASE DATE: T % J -; '-5 E_ WASTE MINIMIZATION PLAN D FOR cWOLF CREEK GENERATING STATION~Purpose/This waste minimization plan has been created to help Wolf Creek Generating Station 2 (WCGS) achieve a reduction in both the volume and toxicity of waste generated.

This will be accomplished using techniques such as product substitution, more efficient use of 2 chemicals, improved chemical control, improved work processes, reuse, and recycling.

0 One of the primary goals of this plan established in 2003 was to allow WCGS to drop 0 from an EPA (Large Quantity)

Generator classification (2200 lbs. or more of hazardous waste / month) to a Kansas Generator classification (55 -2200 lbs. of hazardous waste /month). This goal was achieved with a notification letter to the Kansas Department of Health and Environment in October of 2004. The goal now is to continue to decrease the volume of waste generated and work towards the Small Quantity Generator classification (less than 55 lbs. of hazardous waste I month).ScoDe The successful implementation of this plan requires the support and participation of all employees and contractors working at WCGS. While this plan is driven by requirements to reduce the volume and toxicity of hazardous waste generated, it is not limited to this one waste (hazardous) classification.

It is also the goal of this plan to reduce the amount of nonhazardous solid (industrial) waste and ordinary office trash. The Supervisor Regulatory Support is responsible for the implementation of this program.Previously Implemented Practices There have been a number of programs and practices implemented already which have either reduced the amount and toxicity of waste generated or reduced the volume of waste being disposed of in a landfill.

Some of these programs and practices are: 1. office paper recycling 2. corrugated cardboard recycling 3. laser printer toner cartridge recycling 4. use of low mercury lamps 5. spent lamp recycling 6. lead-acid battery recycling 7. nickel-cadmium battery recycling 8. dry cell alkaline battery recycling 9. recycling of all other batteries 10. scrap metal recycling 11. use of reusable shop towels 12. aluminum can recycling 13. used oil recycling 14. antifreeze recycling 15. use of EPA 2000 as primary cleaning solvent in parts washers 16. use of hot water parts washers 17. paint wastes segregation

1 A E 18. fiberboard drum reuse E 19. recycling of some poly and steel drums 20. "reuse" of diesel fuel from offloading process and sample testing 21. selling or giving away materials obsoleted from the warehouse 22. reusing styrofoam peanuts and other packing materials Plan 2 This plan encourages the continuance of all programs and practices previously 2 implemented.

When this plan was revised in 2003, several additional programs andpractices being implemented were listed as goals of the plan. Following are updates on o these specific goals: 5 1. Paint Wastes -There has been a concerted effort to reduce the volume of hazardous waste paint solids, sludges, and paint-related materials.

The goal of this effort was to eliminate the use of paints that could result in the generation of a hazardous waste when the paint has been used and is dry. This was to be accomplished through discontinued use of certain paints, product substitution, and control of approved paints. Hazardous waste paint solids and paint-related materials had been two of the larger volume hazardous wastes generated at WCGS for many years. The goal of this plan was to generate no hazardous waste paint solids or paint-related materials from painting processes.

Because some hazardous waste paint sludges may be generated from shelf-dated (and no longer usable) paints, leaking containers in storage, or spills, it would be somewhat unrealistic to expect zero generation of hazardous paint wastes. In 2002, seven drums (2095 lbs.) of hazardous waste paint solids and paint related materials were generated.

The goal established In 2003 was to generate no more than one 55 gal. drum (approx. 450 lbs.) of hazardous paint waste per year. In 2003, 1620 lbs. of hazardous paint waste were generated.

In 2004, 394 lbs. of hazardous paint. waste were generated, and the goal was achieved.2. Parts Washer Cleaning Solvent -While the use of EPA 2000 as the primary parts washer solvent has been a positive step as the waste is no longer ignitable hazardous waste and it presents fewer health and safety concerns to workers compared with the previously used petroleum distillate solvents, it has not completely eliminated the generation of hazardous waste from the parts cleaning process. Through use, the solvent can pick up high enough levels of certain.heavy metals (primarily cadmium and lead) to require disposal as hazardous waste. If the solvent in the parts washers is changed out more frequently, the concentration of heavy metals may be below the level that would require it to be disposed of as hazardous waste. The goal established In 2003 was to sample and test the parts washer solvent frequently (at least bi-monthly) to determine if more frequent change-out would reduce or eliminate the volume of this waste which is disposed of as hazardous waste. Sampling and testing began in 2004. It was determined that an increased frequency of changing out the EPA 2000 could result in the waste solvent being characterized as nonhazardous waste. In 2002, two drums (800 lbs.) of hazardous waste EPA 2000 were generated.

In 2003, 1455 lbs. were generated.

In 2004, 737 lbs. of hazardous waste EPA 2000 were generated.

The installation of a filtration unit on a parts washer in 2005 should extend the b life of the EPA 2000 and further reduce the possibility of the waste solvent E being characterized as hazardous waste.DI 0 3. Diesel Fuel -Because of its flashpoint, diesel fuel which was disposed of had been managed as hazardous waste. One source of diesel fuel which was being/ managed that way was the fuel drawn from the storage and day tanks by Operations to inspect for the presence of water. This is clean diesel fuel, and there was no good reason why it should be managed as waste. Operations and 2/ Administrative Services implemented a program for accumulating it as clean 2 diesel and using it as fuel in vehicles or equipment.

In 2002, approximately 1150 2~ lbs. of diesel fuel from this source were disposed of as hazardous waste. The goal established in 2003 was to completely eliminate this as a waste 0 stream. This goal has been achieved, and no waste diesel fuel has been generated from this process since 2003.4. Batteries

-Recycling programs had been in place for lead-acid and nickel-cadmium batteries for many years. Although not requiring management as a hazardous waste, a large number of dry cell alkaline batteries had been disposed of as office trash. A small number of other types of batteries are also likely being disposed of in the trash. The goal established in 2003 was to implement a recycling program for dry cell alkaline batteries and for as many other types of batteries as is possible.

This goal was achieved In October of 2003.Opportunities exist for WCGS to find other businesses that may reuse or recycle materials that would otherwise be disposed of as waste. Several material and waste exchanges can now be accessed via the internet.

Inventory control can also play a significant role in waste reduction.

A significant amount of both hazardous and nonhazardous waste has been generated in the past by the disposal of shelf-dated or obsoleted products.

Supply Chain Services is now pursuing other options before determining that materials should, as a last resort, be disposed of as waste.The use of products that will not produce a hazardous waste can contribute greatly to the reduction in the volume of hazardous waste generated.

There are also more opportunities for recycling additional types of wastes and spent products.In order to heighten employees' awareness of the need for waste minimization and to encourage individuals to actively support the effort, a program has been implemented to solicit minimization ideas and reward employees for those ideas which are implemented.

While all ideas which are implemented will earn the originator a reward, those which result in more significant reductions will earn the originator a more significant reward.Monthly hazardous waste generation volume will continue to be tracked. Performance indicators will be utilized to track both monthly hazardous waste generation and total cumulative quantities of hazardous waste.This waste minimization plan should be revised annually to reflect accomplishments and update goals.

kA 37 631/WrLF CREEK'NUCLEAR OPERATING CORPORATION kOI~OI7 Kevin J. Moles Manager Regulatory Affairs.APR3O02001i RA 04-0036 U: S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-

Subject:

Docket No. 50-482: Wolf Creek Generating Station Annual Radioactive Effluent Release Report -Report 27 Gentlemen:

.This letter transmits the enclosed Wolf Creek Generating Station (WCGS) Annual Radioactive Effluent Relea'e Report. The report covers the period from January 1, 2003, through December 31, 2003. It is being submitted pursuant to Section 5.6.3 of the WCGS Technical Specifications.

Three attachments are included as part of this report. Attachments I, II; and III are revised procedures required to be submitted with this report: AP 07B-003, "Offsite Dose Calculation Manual,' AP 07B-004, "OffsIte Dose Calculation Manual (Radiological Environmental Monitoring Program),*

and AP 31A-100, "Solid Radwaste Process Control Program.'No commitments are identified in this correspondence.

If you have any questions concerning this matter, please contact me at (620) 364-4126, or Mr. William Muilenburg at (620) 364-8831, ext. 4511.KJM/rlg Enclosure cc: J. N. Donohew (NRC), w/e D. N. Graves (NRC), wle B. S. Mallett (NRC), wle Senior Resident Inspector (NRC), wle P.O. Box 411 I Burlington, KS 668391 Phone: (620) 364-8831 An Equal Opporiunity Employer M/F/HC!VET P Wolf Creek Nuclear Operating Corporation

..X Wolf Creek Generating Station Docket No: 50-4,82 Facility Operating License No: .NPF-42 Ahnual Radloactive Effluent Release. Report Report No. 27, Reportirig Period: Janury 1, 2003 Dbcbmbe" 31, 2003 "2 of.40 Table of Contents Executive Summary 4"'P Section I*8 q Report of 2003 Radioactive Effluents:

Liquid 8 2003 Liquid Effluents 10 2003 Liquid Cumulative Dose Summary?-

Table 1 12 2003 Liquid Curriulative Dose Summary -Table 2 13 Report of 2003 Radioactive Effluents:

Airborne 14 2003 Gaseous Effluents 16 p 2003 Gaseous Cumulative Dose Summary -Table I 18 2003 Gaseous Cumulative Dose Summary -Table 2 19 Section I1 20 Offsite Dose Calculation Manual Limits 20 Effluent Concentration Limits (ECLs) 20 Average Energy 21 Measurements and Approximations of Total Radioactivity (Liquid and 21 Gaseous Waste' Effluents)

Batch Releases 23 Continuous Releases 23 Doses to a Member of the Public from Activities Inside the Site S, Boundary 23.Additional.

Information 23 2003.Effluent Concentration Limits 26' 2003 Solid Waste Shipments 27 Irradiated Fuel Shipments

.28 Section 111 29*Meteorological Data -Hours At Each Wind Speed and Direction 29"Section IV 38" Unplanned or Abnormal Releases '38 Offsite Dose Calculation Manual 38 Major Changes to Liquid, Solid, or Gaseous Radioactive Waste Treatment Systems 38 Land Use Census 39 Radwaste Shipments 39 Inoperability of Effluent Monitoring Instrumentation 39 Storage Tanks 39, J 3 of 40' Table of Contents Attachment I -WCGS Procedure AP 07B-003, Revision 4, "Offsite Dose Calculation Manual" Attachment II -WCGS Procedure AP 07B-004, Revision 5, "Offsite Dose Calculation Manual (Radiological Environmental Monitoring Program)" Attachment III -WCGS Procedure AP 31A-100, Revision 4, "Solid Radwaste Process Control Program'.

, 0T* II I. I ..

4 of 40 IT1 *EXECUTIVE

SUMMARY

This Annual Radioactive Effluent Release Report (Report # 27) documents the quantities of liquid* and gaseous effluents and solid waste released by the Wolf Creek Generating Station (WCGS)P from January 1, 2003, through December 31, 2003. The format and content of this report are in accordance with Regulatory Guide 1.21, Revision 1, "Measuring, Evaluation; and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants.".

Sections I; II, I1l, and IV of this report provide information required by NRC Regulatory Guide 1.21 and Section 7.2 of AP 076-003,"Offsite Dose Calculation Manual" (ODCM).Section I --- Section I contains in detail the quantities of radioactive liquid and gaseous effluents and cumulative dose summaries for 2003, tabulated for' each quarter and for yearly totals., Specific ODCM effluent limits and dose limits are also listed in Section I, along with the percentage of the effluent limits actually released, and the percentages of, the dose limit actually received.

No effluent or dose limits were exceeded during 2003.An elevated release pathway does not exist at WCGS. All airborne releases are considered to be ground levelreleases.

The gaseous pathway dose determination is met by the WCGS ODCM methodology of assigning all gaseous pathways to a hypothetical individual residing at the highest annual X/Q and D/Q location, as specified in the ODCM. This results in a conservative estimate of dose to a member of the public, rather than determining each pathway dose for each release condition.

A conservative error of thirty percent has been estimated in the effluent data.As stated above, no ODCM dose limits were exceeded in 2003.Section II Section II includes supplemental information on continuous and batch releases, calculated doses, and solid waste disposal.

There were 87 gaseous batch releases in 2003 versus 77 in 2002. There were 76 liquid batch releases in 2003 versus 71 In 2002. WCGS released 0.020 curies in liquid releases during 2003 versus 0.018 curies in 2002, excluding gas and tritium. Continuous release pathways remained the same as previous years and all continuous releases were monitored.

There was a missed surveillance as a result of a valve misalignment on the sample isolation valve for Gas Decay Tank #3. The event is further discussed in the Performance Improvement Request (PIR) report information.

The report contains information on the following PIRs.PIR 2003-0173

-On 1-29-2003 the Balance of Plant Operator (BOP) in the Control Room taking log readings noted that monitor GHRE-10A was in accident isolation which switches sample suction from room air rather than the Radwaste Vent effluent stream. The sampling as required by ODCM Table 3-2 was not met for 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> since the sample air was coming from room air.PIR 2003-0529

-Support Engineering incorrectly reported a previous flow rate of 4627 cfm for the containment mini-purge unit as the current flow to Operations and Chemistry.

The correct current flow should have been reported as 4260 cfm.PIR 2003-0848

-During the channel calibration portion of STS IC-474B, "Channel Calibration Unit Ventilation System Radiation Monitor GTRE21B," it was discovered that the pump diaphragm had a hole in it. The sample air passing by the detector was diluted due to the pump diaphragm hole being upstream of the pump and the detector being downstream of the pump. It is unknown how long the hole in the pump diaphragm was present before being discovered.

4 5 of40 PIR 2003-1882

-Waste Gas Decay Tank (WGDT) #3 decreased in pressure and WGDT #8 increased in pressure during a Volume Control Tank (VCT) Purge. The purge was secured and all reach rod valves that could cause a decrease in pressure in the gas decay tanks were verified closed. Work Order 03-25.3.665 was generated to replace the relief valve.PIR 2003-2158

-On 7-17-2003 the "A waste gas compre~ssor moisture separator tank relief valve was being replaced.

When the relief valve flange was broken loose water commenced spraying from the flange area. The flange bolts were retightened.

This relief valve discharges S.into WGDT #8 that contained

-5 psig pressure.

WGDT #8 Oressure decreased

-'0.4 psig during , this. evolution.

PIR 2003-2580-Containment Atmosphere Monitors GTRE31 and GTRE32 were 6hanged 8-29-.* ,2003. The particulate filters were discolored.

Gamma scans performed on the filters indicated no gamma activity.

The discoloration of the filters. ist not indicative of Reactor Coplant System (RCS) leakage. The filters. were sent off for boron and iron analysis and the results were inconclusive.

PIR 2003-2805

-The sample isolation valve for WGDT #3 was found in the open position by a Chemistry technician on 9-22-2003.

The. chemistry technicign was performing STS CH-009, Waste Gas Decay Tank Curie Content Surveillance.

The last sample from WGDT #3 taken for STS CH-009 was on 9-5-2003.

After WGDT #3 was sampled, a curie content sample was obtained from WGDT #8 the same day. It is probable that the sample obtained for WGDT #8 on 9-5-2003 was not representative of what was in that tank, buf rather a composite of WGDT #3 and WGDT #8 since the sample isolation valve for WGDT. #3 was still in the open position..

Once the sample isolation, valve for WGDT #3 was closed the total ctrie content surveillance for WGDT#8 was completed.

The cornseqpence of thevalve alignmentis'a missed siurveillance.

PIR 2003-3555

-The low setpoint for WGDT permit 2003165 was incorrect..

The correct setpoint to use was 7.97E+02 p.Ci/sec, but 8.83E+02 pCi/sec. was recorded.

The calculated low setpoint was 7.97E+02 pCi/sec. The low setpoint for the Radwaste Vent was 8.83E+02 pCi/sec. The release was performed using a less conservative setpoint, but the low setpoint was not compromised due to the built-in conservatism of the setpoint calculation.

PIR 2003-3591

-The, high setpoint for containment purge permit 2003178 for GTRE-22 and.GTRE-33.was recorded as 1.02E-02 pCi/cc and the correct setpoint should have been recorded asi. 1.OOE-02 pCi/cc. This incorrect setp6int could have prevented the Control Room from receiving the Hi-Hi Process Radiation Alarm prior, to the ESFAS (Engineering Safety Feature Actuation System) isolating the containment purge. The low setpoint was not jeopardized during the release.Section III -Section III documents WCGS meteorological data for wind speed, wind direction, and atmospheric stability.

WCGS did not meet the Regulatory Guide 1.23, "Meteorological Programs in Support of Nuclear Power Plants' requirement for having at least 90%meteorological data recovery for 2003. PIR 2004-0620 has been written to address this and the resolution will be presented in the 2005 Annual Report.

6 of 40 Section IV -Section IV documents unplanned and abnormal releases, changes to radwaste treatment systems, land use census, monitoring instruments, radwaste shipments,.and storage tank quantities.

PIR 2003-2158 documents the decrease of -0.4 psig in WGDT #8 during an* evolution to replace the "A" waste gas compressor moisture separator tank relief valve. Water sprayed out when the flange was loosened causing the decrease in pressure.

The subsequent increase in the GHRE-IOB monitor reading was determined to. be from Chemistry sampling activities.

There was no uncontrolled or unmonitored release in either circumstance.

No ODCM limits were exceeded.No changes or events occurred on the land use census, monitoring instruments, radwaste shipments, and storage units.Q 7 of 40 ATTACHMENTS Attachment I-AP 07B-003, revision 4, "Offsite Dose Calculition Manual" Attachment 11-AP 078-004, revision 5, 'Offsite 'Dose Calculation Manual (Radiological Environmental Monitoring Program)'Attachment III-AP 31A-1 00, revision 4, "Solid Radwaste Process Control Program'p -I.0W'"* °0°

.4 3 8 of 40 SECTION I REPORT OF 2003 RADIOACTIVE EFFLUENTS:

LIQUID P X Unit A. Fission and Activation Products 1. Total Release (not including tritium, gases, alpha).2. Average Diluted Concentration During Period 3. Percent of Applicable Limit (1)B.' Tritium 1. Total Release 2. Average Diluted Concentration During Period 3. Percent of Applicable Limit (2) (ECL)Ci pCi/mi Ci Ci/ml Quarter 1 1.09E-03 6.69E-1 I 2.17E-02 3.11E+02 1.91 E-05 1.91 E+00 3.30E-03 2.03E-10 1.02E.-04 4.23E-06 4.52E+07 1.62E+10 Quarter 2 1.87E-03 1.17E-10 3.73E-02 3.24E+02 2.03E-05 2.03E+00 C. Dissolved and Entrained Gases 1. Total Release 2. Average Diluted Concentration During.Period 3. Percent of Applicable Limit I Ci pCi/ml'3) %D. 'Gross Alpha Radioactivity

1. Total Release E. Volume of Waste Released (prior to dilution)F. Volume of Dilution Water Used 3.54E-03 2.228-1 0 1.11E-04.0.OOEO00 9.42E+07 1 .59E+10 Cl Liters Liters NOTES: 1) The applicable limit for the WCGS is 5 Curies per year. (Reference 10 CFR 50, Appendix I, "Guides On Design Objectives For Light-Water Cooled Nuclear Power Reactors,*

Paragraph A.2.) The value is derived by dividing the total release Curies by 5 Curies and then multiplying the result by 100.2) This value Is derived by the following formula: (Average Diluted Concentration)

(100)% of Applicable Limit=(MPC or ECL, Appendix B, Table 2 10CFR20)3) This value is derived by the following formula: So'f Applicable Limit= (Average Diluted Concentration)

(100)(2E -04 from ODCM Section 2.1)

P X 9 of 40 REPORT OF 2003 RADIOAC A. Fission and Activation Products 1. Total Release (not including tritium, gases, alpha 2. Average Diluted Concentration During Period , , 3. Percent of'Applicable Limit (1)B. Tritium*1. Total Release 2. Average Diluted Concentration During Period*3. Percent of-Applicable Limit (2) (ECL)C. Dissolved and Entrained Oases 1. Total Release 2. Average Diluted Concentratlon'During Period 3.' Percent of Applicable Limit (3)D. Gross Alpha 'Radioactivity

1. Total Release E. Volume, of Waste Released (prior to dilution)F. Volume of Dilution Water Used.;TIVE EFFLUENTS:

LIQUID Unit *Quarter 3 Ci. 4.75E-03 PjCVmI 1.88E-10% , 9.50E-02 Cl iCVml.Cl PCVml Cl liters liters 7.11 E+02 2.82E-05 2.82E+00 3.89E-02 1.54E-09*7.71 E-04 8.88E-05*3.53E+07 2.52E+1,0 Quarter 4 1.25E-02 5.77E-10 2.50E-01, 1 .52E+02 7.02E-066*7.02E-01*2.32E-02 5.34E-04 I .53E-05-8.78E+07,* 2.16E+10= !NOTE.T: 1). The applicable limit for the WCGS is 5 Curies per year. (Reference 10 CFR 50, Appendix I, "Guides On Design Objectives For Light-Water Cooled Nuclear Power Reactors," Paragraph A.2.) The value Is derived by dividing the total release Curies by 5 Curies and then multiplying the result by 100.2) This value is derived by the following formula:% of Applicable Limit = (Average Diluted Concentration)

(100)(MPC or ECL, Appendix B,Table 2,10CFR20)

3) This value is derived by the following formula:.(Average Diluted Concentration)

(100)(2E -04 from ODCM Section 2.1)

P7 P1 10 of 40 2003 LIQUID EFFLUENTS Continuous Mode N'uclides Released H-3 Mn-54 Fe-55 Fe-59 Co-57 Co-58 Co-60 Zn-65 Sr-89 Sr-90 Mo-99 Sb-126 Sb-125 1-131..1-133 Cs-134 Cs-137 Ce-141 Ce-144 Gross Alpha Ar4l 1 Kr-85M 1 , Kr-85 Kr87"'Kr-88 Xe-131M Xe-133M Xe-133 Xe-135M Xe-135 Unit Quarter I Cl Ci Cl Ci Ci Ci Ci Ci Cl C'Ci Ci Ci Ci Ci Cl Ci Ci Cl Cl Ci* Ci'.Ci C1'Ci Ci Cl Ci Ci Ci 1.111E+00<2.24E-02<4.47E-02<2.24E-02 I n/a<2.24E-02<2.24E-02<2.24E-02<2.24E-03<2.24E-03<2.24E-02 n/a n/a<4.47E-02 n/a<2.24E-02<2.24E-02<2.24E-02<2.24E-02<4.47E-03<4.47E-01<4.7E-01<4.47E-01<4.47E-01<4.47E-01<4.47E-01<4.47E-01,<4.47E-01<4.47E-01<4.47E-01 Quarter 2 7.55E-01<4.68E-02<9.35E-02<4.68E-02 n/a<4 .68E-02<4.68E-02<4.68E-02<4 .68E-03<4 .68E-03<4 .68E-02 n/a n/a<9.35E-02 n/e<4.68E-02<4.68E-02<4.68E-02<4.68E-02<9.35E-03<9.35E-01<9.35E-01<9.35E-O1<9.35E-01<9.35E-01<9.35E-01<9.35E-01<9.35E-01<9.35E-01<9.35E-01 Ba Quarter 1 3.10E+02<2.37E-04<4.74E-04<2.37E-04 n/a 1.82E-04 1.17E-04<2.37E-04<2.37E-05<2.37E-05<2.37E-04 rna 7.54E-04<4.74E-04 1.30E-06 1.48E-06 3.14E-05<2.37E-04<2.37E-04 4.23E-06<4.74E-03<4.74E-03<4.74E-03<4.74E-03<4.74E-03<4.74E-03<4.74 E-03 3.30E-03<4.74E-03<4.74E-03 3.23E402<3.20E-04<6.3 9E-04<3.20E-04.

1 .42E-66 5.88t-05 I :96E-04<3.20E-04<3.20E-05<3.20E-05<3.20E-04 2.53E-06 1.51 E-03<6.39E-04 n/a 2.24E-06 8.97E-05<3.20E-04<3.20E-04<c6.39E-05

<6.39E-.03

  • <6.39E-03' 7.44E-04<6.39E-03* <6.39E-03<6.39E-03<6.39E-03 2.B0E-03<6.39E-03<6.39E-03 itch Mode C)uarter 2 NOTE"Less than' values are calculated using the Lower Limit of Detection (LLD) values listed in Table 2-1 of the ODCM multiplied by the volume of waste discharged during the respective quarter. The "less than" values are not included in the summation for the total release values.

0-1.1 of 40 2003 LIQUID EFFLUENTS X.P Nuclides Released.H-3 Mn-54 Fe-55 Fe-59 Co-57 Co-58 Co-60 Zn-65 Sr-89 Sr-g0 Mo-99 Sb-124 Sb-125 1-131 1-132 1-133 Cs-1 34 Cs-137 Ce-141 Ce-144 Cr-51 Rb-88 Ba-1 39 Mn-56 Nb-97 Sn-1 17m Gross Alpha Ar41 Kr-85M Kr-85 Kr-87 Kr-88 Xe-131M eXi133M Xe- 133 Xe-135M Xe- 135 Unit Cl Ck Ci.Ci Ci Cl'Ci Ci Ci: Ci Ci Ci CI Ci Ci Cl CI Ci Ci Ci Cl.C0 Cl Cl Ci CI cf Ci CI Ci Cl Ci Ci Cl Ci Ci Cl Continuous Mode Quarter 3 5.43E-01<1.70E-02<3.39E-02 , <1.70E-02 n/a<1.70E-02-;1.70E-02

<1 .70E-02,,'<1.70E-03

<1.70E-03<1.70E-02' n/a.n/a-<3.39E-02 n/a n/a<1.70E-02<1.70E-02<1.70E-02<1.70E-02'n/a n/a n/a n/a n/a<3.39E-03<3.39E-01<3.39E-01.<3.39E-01

<3.39E-01.<3.39E-01

<3.39E-01<3.39E-01<3.39E-01<3.39E-01<3.39E-01 Quarter 4 1.41 E+00<4.33E-02<8.66E-02<4.33E-02 n/a<4.33E-02'

<4.33E-02<4.33E-02<4.33E-03<4.33E-03<4.33E-02 n/a n/a<8.66E-02.

Ida n/a<4.3"3E-02

<4.33E-02.

<4.33E-02<4.33E-02 n/a ri/a'n/ia* n/a:*n/a<8.66E <8.66E-O1<8.66E-01<8.66E-O1<8.66E-01<8.66E-01<8.66E-01<8.66E-01<8.66E-01<8.66E-O1<8.66E-01 Quarter 3 3atch Mode Quarter 4* 7.1OE+02 8.68E-06<1.40E-03<7.02E-04 n/a 1.24E-05 4.30E-04<7.02E-04<7.02E-05<7.02E-05 4 .,7.02E-04 n/a 3.65E-03 2.13E-04 n/a ri/a,* .9.90E-06 5.84E-05 , '7.02E-04<7.02E-04 3.65E-05 3.27E-04' "'.* 7.OOE-06 n/a n/a S In/a 8.88E-05<1 .40E-02 3.91 E-05<I.40E-02<I.40E-02 4.48E-05 5.09E-05 5.13E-04 3.62E-02<1.40E-02 2.08E-03 1.51 E+02 7.52E-07<1.19E-03<5.97E-04.1.34E-05 5.01 E-03 5'.imoE4<5.97E-04<5.97E-05<5k9E-05<5.97 E-04* 2.36E-05 6 `A9E-03 1 .77E-04 2.23t-06 2-97E-05 8.46E-0B 4.34E-05<5.97E-04<5'c.97E-04 4.92E-04 n/a I., n/a* 3.66E-06 7.39E-06~6.83E-06 I1.53E-05<1 .19E-02<1.19E-02<1.19E-02<1.19E.02 ci .19E-02<1 .19E-02 3.84E-04 2.1 5E-02<1.19E-02 1 .32E-03 NOTE"Less than" values are calcutated using the Lower Limit of Detection (LLD) values listed In Table 2-1 of the ODCM multiplied by the volume of waste discharged during the respective quarter. The "less than" values are not included in the summation for the total release values.

12 of 40 LIQUID CUMULATIVE DOSE

SUMMARY

(2003) TABLE I QUARTER 1 OF 2003 (mrem)P P TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE FOR BONE FOR LIVER FOR TOTAL BODY FOR THYROID FOR KIDNEY FOR LUNG FOR GI-LLI ODCM CALCULATED DOSE 1.67E-04 4.06E-02 4.05E-02 4.04E-02 4.04E-02 4.04E-02 4.04E-02 2.96E-04 3.06E-02 3.04E-02 3.02E-02 3.03E-02 3.02E-02 3.02E-02 ODCM LIMIT(1)5.OOE+DO 5.06E+DO i .50E+OO 5.00E+61)5.OOE+OO 5.OOE+0O 5.OOE+0O 5.00 E+OO 5.OOE+D0 I .50E+DO 5.OOE+OO 5.OOE+0O*5.001E+00 5.00E+00 QUARTER 2 OF 2003 (mrem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI QUARTER 3 OF 2003 (mrem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG T6TAL DOSE FOR GI-LLI QUARtER.4 OF 2003 (mrem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI TOTALS FOR 2003 (mrem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI 2.18E-04 5.43E-02 5.42E-02 5.44E-02 5.41E-02 5.40E-02.5.41 E-02 2.78E-04 8.67E-02 8.66E-02 8.73E-02 8.64E-02 8.63E-02 8.67E-02 9.59E-04 2.12E-01 2.12E-01 2.12E-01 2.11 E-01 2.11E-01 2.11E-01 5.OOE+OO 1 .50E+00 5.00E4-00 5.001E+00 5 OOE+00 5.00E+06 5.0OE+00 5.OOE+0O 11.50E+00 5.OOE+0O 5.00E+00 5.OOE+0O, 5.00E+00 1 .OOE+0I I .OOE+01 3.OOE+OO 1 .0OE+01 1 .00E+01 1 .O0E+01 I .0OE+01% OF LIMIT 3.34E-03 8.12E-01 2.7OE+00 8.07E-01 8.09E-01 8.08E-01 8.08E-01 5.92E-03 6.12E-01 2.03E-OI-6.04E-01 6.06E-01 6.04E-01 6.04E-01 4.36E-03 1.09E+00 3.62E+00 1.09E+00 1.0BE+00 t1.08E+00 1.08E+00 5.56E-03 1.73E+00 1.75E+00 1.73E+00 1.73E+00 1.73E+00 9.59E-03 2.12E+00 7.06E+00 2.12E+00 2.11 E+00 2.11 E+00 2.11E+00 1. Based on ODCM Section 2.2, which restricts dose to the whole body to :10.5 mRem per quarter and 3.0 mRem per year. Dose restriction of any organ is _<5.0 mRem per quarter and 10.0 mRem per year.

'3)p p'4;.9 13 of 40 LIQUID CUMULATIVE DOSE

SUMMARY

(2003) TABLE 2 A.Fission and Activation Products (not including H-3, gases, alpha)Total Release -(Ci)Maximum, Organ Dose (mRem)Organ Dose Limit (mRemr) *Percent of Limit Quarter 1 Quarter2 Quarter 3 Quarter4 1.2.3.4.B.1.2.3.4.1.09E-03 2.34E-04 5.OOE+00 4.68E-03*1.86E 4 .OBE-04'5.005+00 8.17E-03 4.75E-03 4.1IOE-04 5.OOE+0O 8.20E-03 1.25E-02 1.03E-03 5.OOE+0O 2.07E-02 Total 2.02.-02 1.45E-03 1.00E+01 1.45E-02 Tritium Total Release -(Ci)Maximum Organ Dose (rnRem)Organ Dose Limit (mRem)Percent of Limit.3.11E+02 4.04E-02 5.OOE+00.8.07E-01 3.24E+02-3.02E-02 5.OQE+00 6.04E-01 7.I11E+02 5.40E-02 5.OOE+00 1.08E+O0!1.52E+02 8.62E-02 5.OOE+00 1.72E+00 1 .50E+03.2.11IE-01 I .OOE+0I 2.11 E+i00 This table Is included to show the correlation between Curies released and the .associated calculated maximum organ dose. Wolf Creek 06CM methodology is used to calculate the maximum, organ dose. that assumes that an individual drinks the water and eats the fish from the discharge point. ODCM Section 2.2 organ dose limits are used. The less than values are not included in the summation for the total release values.. ,

14 of 40.REPORT OF 2003 RADIOACTIVE EFFLUENTS:

AIRBORNE Quarter Quarter Unit 1 2 A. Fission and Activation Gases 1. Total Release Ci 3.28E-01 7.72E-01 2. Average Release Rate for Period pCi/sec 4.21 E-02 9.82E-02 3. Percent of ODCM Limit (1) % 4.14E-03.

5.68E-03 ,0 B. Iodine 1. Total Release Cl O.OOE.00 0.OOE+O0 P3 .2: Average Release Rate for Period pCi/sec 0.OOE+00 0.00E+00 3. Percent of Applicable Limit (2) % 0.OOE+00 O.OOE+00 C. Particulates

1. Particulates with Half-lives

> 8 days Ci O.OOE+00 0.OOE+00 2. Average Release Rate for Period pCi/sec 0.OOE+00 0.OOE+00 3. Percent of ODCM Limit (3) % 0.0E+0 0.00E+0O0 4. Gross Alpha Radioactivity Cl O.OOE+00 0.OOE.00 D. Tritium 1. Total Release Cl 9.76E+O0 1.31 E+01 2. Average Release Rate for Period PCi/sec 1.26E+00.

1..66E+0O*3. Percent of ODCM Limit (4) % 9.25E-02 1.23E-01 NOTES: 1) The percent of ODCM limit for fission and activation gases Is calculated using the following methodology:.

% of ODCM Limit (Qtrly Total Beta Airdose)(100) or (Qtrly Total Gamma Airdose)(100) 10 mrad 5mrad The largest value calculated between Gamma and Beta air dose is listed as the % of ODCM Limit.2) The percent of ODCM limit for iodine is calculated using the following methodology:

S % of ODCM Limit -(Total Curies of Iodine -131)(100)I Curie 3) The percent of ODCM limit for particulates is calculated using the following methodology:.

% of ODCM Limit -(Highest Organ Dose Due to Particulates)(100) 7.5 mrem This type of methodology Is used since the Wolf Creek ODCM ties release limits to doses rather than curie release rates.4) The percent of ODCM limit for tritium is calculated using the following methodology.

% of ODCM Limit= (Highest Organ Dose Due to H-3)(100)7.5 mrem P,'P px Q 15 of 40 REPORT OF 2003 RADIOACTIVE EFFLUENTS:

AIRBORNE A. Fission and Activation Gases 1. Total Release 2. Average Release Rate for Period 3. Percent of ODCM Limit '.()B. lodines 1. Total Iodine-131

2. Average Release Rate for;Period

.*3. Percent of Applicable Limit (2)C. Particulates

1. Particulates with Half-lives

> 8 days.2. Average Release Rate for Period 3. Percent of ODCM Limit '(3)4. Gross Alpha Radioactivily D. Tritium 1. Total Release 2. Average Release Rate for. Period 3. Percent of ODCM Limit .. (4)NOTES: Unit Ci pCi/sec Cil pCi/sec Ci.PCI/sec Cl..Quarter 3 1.44E+00 1.81 E-01.1.41E-02 0.OOE+O0 O.OOE+00 SO.OOE+O0 0.OOE+O0 0.00E400 0.OOE+O0 0.OOE+60 Quarter 4+2.13E+00 2.68E-01 4.38E-03 0.001E+00 0.0012÷00 O.OOE+00 3.72E-0.4.68E-07 2.64E-05 0.60E+O0 Cl pCi/seC 1.25E+01 1.58E+00 i 1.20E-01 9.27E-O0 1.17E+00 8.73E-02 1) The percent of ODCM limit forfission and activatioh gases is calculated using th efollowing methodology:.

, O/0 A OrhCM Timit (QtrlyTotal Beta Airdose)(100) nr (QtrlyTotal Gamma Airdose)(100) 10 mrad 5 mrad The largest value calculated between Gamma and Beta air dose is'listed as the % of ODCM LimiL 2) The percent of ODCM limit for Iodine Is calculated using the following methodology:.

%of ODCM .Limit= (Total .Curies of Iodine-131)(100) 1 Curie 3) The percent of ODCM limit for particulates is calculated using the following methodology:.

% of ODCM Limit= (Highest Organ Dose Due to Particulates)(100) 7.5 mrem This type of methodology Is used since the Wolf Creek ODCM ties release limits to doses rather than cude release rates.4) The percent of 00CM limit for tritium is calculated using the following methodology:.

% of ODCM Limit = (Highest Organ Dose Due to H-3)(100)7.5 nuem IID 0 16 of 40 2003 GASEOUS EFFLUENTS.Continuous Mode Batch Mode Quarter I Quarter 2 Nuclides Released 1. Fission and Activation Gases Ar-41 Kr-85 Kr-85M* "Kr-87 Kr-88 Xe-131M, Xe-133 Xe-1 33M Xe-135 Xe-138 Total 2. Halogens (Gaseous)1-131 1-133 Total 3. Particulates and Tritium H-3 Mn-54 Fe-59 , Co-58 CoL-60 Zn-A65 Unit Cl Ci Ci Ci Ci Ci Ci Cl Ci Cl Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Cl Ci Ci Cl Ci Ci Cl Ci Quarter I n/a n/a n/a<2.09E+01<1.77E+01 n/a<1.39E+01<4.46E+01<5.42E+00<4.28E+02 0.00E+00<2.65E-04<2.65E-02 O.00E+00 9.14E+00<2.65E-03<2.65E-03<2.65E-03<2.65E-03<2.65E-03<2.65E-03<2.65E-03<2.65E-03<2.65E-03<2.65E-03<2.65E-03<2.65E-03<2.65E-03 9.14E+00 Quarter 2 n/a n/a n/a<2.08E+01<1.76E+01 n/a ,<1.38E+01<4.44E+01<5.39E+00<4.26E+02 0.OOE+00<2.64E-04<2.64E-02 0.OOE+00 1.08E+01<2.64E-03<2.64E-03<2.64E-03<2.64E-03<2.64E-03<2.64E-03<2.64E-03<2.64E-03<2.64E-03<2.64E-03<2.64E-03<2.64E-03<2.64E-03 1.08E+01 3.1OE-01 n/a n/a 1.35E-03<1.95E-02 n/a 8.07E-03<4.90E-;02

<5.95E-03 8.05E-03 3.27E-01<2.91 E-07<2.91 E-05 0.OOE+00 6.18E-01<2.91E-06<2.'91 E-06<2.91E-06<2.91 E-06<2.9.1 E-08<2.91 E-06<2.91 E-06<2.91 E-06<2.91 E-06<2.91 E-06<2.91 E-06<2.91 E-06<2.91 E-06 6.18E-01 4.37E-01 3.17E-01 n/a<3.25E-02<2.76E-02 n/a 1.81 E-02 6.54E-05 1.21E-05<6.67E-01 7.72E-01* <4.13E-07<4.13E-05* 0.00E+00 2.25E+00<4.13E-06<4.13E-06<4.13E-08<4.13E-06<4.13E-06<4.13E-06<4.13E-06<4.13E-06<4.13E-06<4.13E-06<4.13E-06<4.13E-06<4.13E-06 2.25E+00" Mo-99 Cs-i34 Cs- 137 Ce-141 Ce-144 Sr-89 Sr-90 Gross Alpha Total NOTE"Less than* values for Noble Gases are calculated using the Lower Limit of Detection (LLD) values obtained at Wolf Creek Generating Station multiplied by the volume of air discharged during the respective quarter.For the Halogens and Particulates the ODCM LLD values are used....I i-I ,~'I1.0 p 4: P 17 of 40 2003 GASEOUS EFFLUENTS" Continuous Mode Batch Mode Quarter 3 Quarter 4 Nuclides Released Unit 1. Fission and Activation Gases Ar-41 Ci Kr-85' Ci Kr-85M Ci Kr-87 Ci Kr-88 Ci Xe-131M .." Cl Xe-133 Ci Xe-133M Ci, Xe-135 Ci Xe-138 Ci, Total Ci 2. Halogens (Gaseous)1-131 Ci 1-133. Ci Total Ci 3. Particulates and Triiium: H-3 Ci Mn-54 Ci Fe-59 Cl Co-58. Ci Co-60 " Ci Zn-65 ..Ci Mo-99 Cl Cs-134 Cl Cs-137 Ci Ce-141 Ci Ce-144 Ci Sr-89 Ci Sr-90 Cl Gross Alpha Ci.Total Ci Quarter 3'n/a n/a n/a<2.14E+01<1.82E+01 3.54E-01<4.57E+01<5.55E+00<4.39E+02 3.54E-01<2.27E-04<2.27E-02 0.OOE+00 9.59E+00<2.72E-03<2.72E-03<2.72E-03<2.72E-03<2.72E-03<2.72E-03<2.72E-03<2.72E-03<2.72E-03<2.72E-03<2.72E-03<2.72E-03<2.72E-03 9.59E+00 Quarter 4 n/a n/a rnla<2.19E+01<1.861t+01 n/a 1-.57E.00<4.68E+01 6.OOE-02<4.49E+02 1 ! .63E+00.<2.78E-04

<2.78E-02 0.006+00 7.02E+00<2.78E-03<2.78E-03 3.724-06<2.78E-03<2.78E-03,<2.78E-03 , 2.78E-03<2:78E-03<2.78E-03<2.78E-03<2.78E-03<2.78E-03<2.78E-03 7.02E+00 1.07E+00 1.06t-02 n/a<7.38E-02<6.27E-02 1.56E-05 7.28E-03<1.58E-01<1.92E-02<1.52E+00 1.09E+00<9.38E-07<9.38E-05 0.00E+00 2.95E+00<9.38&-06<9.38E-08<9.38E-06<9.38E-&6<Q.38E-06<9.38E-06<9,38E-06<9.38E-06<9.38E-06<9.38E-06<9.38E-08<9.38E-06<9.38E-06 2.95E+00 2.58E-01.1.71 E-01.n/a 5.82E-03<1.51 E+00 2.91 E-04 6.61E-02 2.49E-04 1.79E-04<3.66E+01 5.02E-01<2.27E-05<2.27E-03 0.00E-+O 2.25E+00-<2.27E-04

<2.27E-04<2.27E-04<2.27E-04<2.27E-04<2.27E-04<2.27E-04<2.27E-04<2.27E-04<2.27E-04<2.27E-04<2.27E-04<2.27E-04 2.25E+00 I NOTE*Less than" values for Noble Gases are calculated using the Lower Limit of Detection (LLD) values obtained at Wolf Creek Generating Station multiplied by the volume of air discharged during the respective quarter.For the Halogens and Particulates.

the ODCM LLD values are used.

'-I 3'7)~1~0 p p 4: p 4: w P 18 of.40 GASEOUS CUMULATIVE DOSE

SUMMARY

(2003) TABLE I QUARTER I OF 2003 (mRem)TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE FOR BONE FOR LIVER FOR TOTAL BODY FOR THYROID FOR KIDNEY FOR LUNG FOR GI-LLI ODCM CALCULATED DOSE O.00E+00 6.91 E-03 6.91 E-03 6.91 E-03 6.91 E-03 6.91 E-03 6.91 E-03 0.OOE+00 9.24E-03 9.24E-03'9.24E-03 9.24E-03 9.24E-03 9.24E-03 QUARTER 2 OF 2003 (mRem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG.TOTAL DOSE FOR GI-LLI.QUARTER 3 OF 2003 (mRem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TDTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI QUARTER4 OF 2003 (mRem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI TOTALS FOR 2003 (mRem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL.DOSE FOR LUNG TOTAL DOSE FOR GI-LLI 0.00E+00 8.87E-03 8.87E-03 8.87E703 8.87E-03 8.87E-03.8.87E-03 8.04E-07 6.55E-03 6.55E-03 6.55E-03 6.55E-03 6.55E-03 6.55E-03 8.04E-07 3.16E-02 3.16E-02 3.16E-02 3.16E-02 3.16E-02 3.16E-02 ODCM LIMIT 75(1)7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7,50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+60 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 1.560E+01 1.50E+01 1.50E+01 1.50E+01 1.50E+01 1.50E+01 1 .50E+01% OF LIMIT O.OOE+00 9.21 E-02 9.21E-02 9.21 E-02 9.21 E-02 9.21 E-02 9.21 E-02 O.OOE+00 1.23E-01 1.23E-01 1.23E-01 1.23E-01 1.23E-01 1.23E-01 0.OOE+00 1.18E-01 1.18E-01 1,18E-01 S1.18E-01 1.18E-01 1.07E-05* 8.73E-02 8.73E-02 8.73E-02 8.73E-02 8.73E-02 8.73E-02 5.36E-06 2.11 E-01 2.11E-01 2411 E-01 2A11E-01 2.11E-01 2.11 E-01 1. Based on Wolf Creek ODCM Section 3.2.2 which restricts dose during any calendar quarter to less than or equal to 7.5 mRem to any organ and during any calendar year to less than or equal to 15 mRem to any organ.

  • 131 p 0 p p 19 of 40 GASEOUS CUMULATIVE DOSE

SUMMARY

(2003) TABLE 2 Nuclides Released Quarter 1 Quarter 2 ' Quarter 3 A. Fission and Activation Gases 1.2.3.4.5.6.7.Total Release -(Ci).Total Gamnia Airdose (mnRad)Gamma Airdose Limit (mRad)Percent of Gamma Airdose Limit Total Beta Airdose (MrRad)Beta Airdose Limit (mlad)Percent of Beta Airdose Limit (mRad)3.27E-01 2.07E-04 5.OOE+00 4.14 E-03 7.51 E-05*1.OOE+01"7.51E-04 7.72E-01 2.84E-.04 5.90E+00 5.68E-03 1.44E-64 1.00E+01 1.44E-03 1.44E+00 7.03E-04 5.OOE+0O 1.41 E-02 2.73E-04 1.OOE+01 2.73E-03 Quarter 4 2.13E+00 2.19E-04 5.OOE+00 4.37E-03 2.17E-04 1.00E+01 2.17E-03 Total 4.67E+00 1.41E-03 1.00E+01 1.41 E-02: 7.09E-04 2.00E+01 3.54E-b03 B. Particulates 1.2.3.4.Total Particulates (Ci)-Maximum Orgah Dose (tmRem)Organ Dose Limit (mRem)Percent of Limit C. Tritium 1.2.3.4.D.1.2.3.4.Total Release (Ci)Maximum Organ Dose (mRem)Organ Dosq Limit (mRem)Percent of Limit -, O.OQE+00 O.OOE+O0 7.50L+00 O.00E+O0 9.76E+00 6.94 E-03.7.50 E+00 9.25E-02 0.0OE+00.0.00E400 7.50E+00 0.OOE+00 O.'OOE+00 O.012+O00 7 .50E+00 0.00E+60 Iodine 0.00E+00 0.00E+00 7.50E+00 O.OOEf+00'1.31 E+01 9.25E-93 7.50E+00.1.23E-01 0.00E+00 0.OOE+0O 7.50E+00 0.00E+00 1.25E+01 8.87E-03 7.50E+00 1.18E101 0.00E+00 o.00E+00 7.50E+00 0.OOE+00 3.72E-06 1.98E-06 7.50E+00.2.64E-05 9.27E.+00 6.55E-03 7.50E+00 8.73E-02 0.00E+00 0.00E+00 7.50E+00 0.00E+00 4.46E+01 3.16E-02 1.50E+01 2.11E-01* 3.72E-08 1.98E-06" 1.50E+01 1.3'2E-05 Total 1-131,'1-133 (CI)Maximum Organ Dose (mRem)Organ Dose Limit (mRem)Percent of Limit 0.00E+00 0.00E+00 1.50E+01 0.00E+00 This table Is included to .show the correlation between Curies released and the associated calculated maximum organ dose. The maximum organ dose is calculated using Wolf Creek ODCM methodology which assumes that an individual actually resides at the release point. ODCM Section 3.2.2 organ dose limits are used.

H 3 20 of 40 SECTION II p SUPPLEMENTAL INFORMATION

1. Offsite Dose Calculation Manual Limits A. For i9ud waste effluents A.1. The concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS shall be limited to the concentrations specified In 10 CFR 20,.Appendix B, Table 11, Column 2, for radionuclides other than dissolved or entrained noble Rases. For dissolved or entrained noble gases, the concentration shall be limited to A.2 2 x 10 microCuries/ml total activity.*A.2 The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive P materials in liquid effluents released, from each unit, to UNRESTRICTED AREAS shall be limited: a. During any calendar quarter to less than or equal to 1.5 mrems 'to the whole body and to less than or equal to 5 mrems to any organ, and b. During any calendar year to less than or equal to 3 mrems, to the whole body and to less than or equal to 10 mrems to any organ.B. For gaseous waste effluents B.1 The dose rate due to radioactive material released in gaseous effluents from the site to area at and beyond the SITE BOUNDARY shall be limited to the followfng: , .For noble gases: Less than or equal to 500 mrems/yr to the whole body and less'than-or equal to 3000 mremslyr to the skin, and*. ,b. For Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-livei greater than 8 days: Less than or equal to 1500 mrems/yr to any organ.B.2 The air dose due to noble gases released in gaseous effluents, from each unit, to areas at and beyond the SITE BOUNDARY shall be limited to the following:
a. During any calendar quarter: Less than or equal to 5 mrads for gamma radiation and less than or equal to 10 mrads for beta radiation, and b. During any calendar year: Less than or equal to 10 mrads for gamma radiation and less than or equal to 20 mrads for beta radiation.

B.3 The dose from Iodine-131, Iodine-133, tritium, and a radionuclide in particulate form with half-lives greater than 8 days in gaseous effluents released to area at and beyond the SITE BOUNDARY shall be limited to the following:

a. During any calendar quarter: Less than or equal to 7.5 mrems to any organ, and b. During any calendar year: Less than or equal to 15 mrems to any organ.2. Effluent Concentration Limits (ECLs)Water -covered in Section I.A.Air -covered in Section I.B.

I~)* ~1i.0 p.0 4:*0 3)1 p 21 of 40 3. Average Energy Average energy of fission and activation gaseous effluents is not applicable.

See ODCM Section 3.1 for the methodology used iri determining the release rate limits from noble gas releases.4. Measurements and Approximations of Total Radioactivity A. Liquid Effluents Liquid Release Sampling Method of Analysis Type of Activity Type Frequency

__Analysis P*1. Batch Waste Each Batch P.HJA Principal Gamma Emitters Release Tank Each Batch P.H.A. 1-131 a. Waste Monitor P Dissolved and Entaln.ed Tank One Batch/M :Gass (Gamma Emitters)b. Secondary Liquid P L.$. H-3 Waste Monitor Each Batch S.A.C. Gross Alpha Tanks .._ _._* , , P O.S.L' Sr-89,.Sr-90 S.i I 2. Continuous Daily -P.H.A. Principal Gamma Emitters Releases Grab Sample P.H.A. 1-13t.a. Steam Generator M Dissolved and entrained Blowdown Grab Sample P.H.A, Gases (Gamma Emitters)b.i Turblne Building Daily .L.S. H-3 SumplWaste Water Grab Sample Treatment S.A.C. Gross Alpha O.S.L Sr-89, Sr-90 c. Lime Sludge Pond Daily Grab Sample O.S.L Fe-55* I P = prior to each batch M = monthly L. S. = Liquid scintillation detector S.A.C. = scintillation alpha counter O.S.L = performed by an offslte laboratory P.H.A. = gamma spectrum pulse height analysis using a High Purity Germanium detector 22 of 40 0 B. Gaseous Waste Effluents Ip P Gaseous, Release Sampling Frequency Method of Analysis Type of Activity Type Analysis.P P.HJ.A Principal Gamma Emitters Waste Gas Decay Tank Each Tank, ,, Grab Sample Containment Purge or' P P.HJA Principal Gamma Emitters Vent Each Purge Grab Sample Gas Bubbler'and L.S. H-3 (oxide)Unit Vent M P.HJ.A Principal Gamma Emitters Grab Sample Gas Bubbler and L.S. H-3 (oxide)Radwaste Building M P.HA Principal Gamma Emitters Vent Grab Sample For Unit Vent and Continuous P.H.A. 1-131 Radwaste Building Vent release types 1-133 listed abvve ,__Continuous P.H.A. Principal Gamma Emitters Particulate Sample-.Continuous S.A.C. Gross Alpha Composite Particulate Sample Continuous O.S.L Sr-89, Sr-90 Composite Particulate Sample P = prior to each batch M monthly L.S. = Liquid scintillation detector SAC. = scintillation alpha counter OS.L. = performed by an offsite laboratory P.HA = gamma spectrum pulse height analysis using a High Purity Germanium detector 23 of 40.AIr 5. Batch Releases.A batch release is the discontinuous release of gaseous or liquid effluents which takes place over a finite period of time, usually hours or days.There were 87 gaseous batch releases during the reporting period. The longest gaseous.o batch release lasted 9,795 minutes, while the shortest lasted 58 minutes. The average release lasted 734 minutes with a total gaseous batch release time of 63,828 minutes., There we're 76'liquid batch .releases.

during the reporting period. The longest liquid batch release lasted 382 minutes, while the shortest lasted 51 minutes. The average release lasted 202 minutes with a total liquid batch release time of 15,350 minutes. , 6. Continuous Releases A contin'uous release is ,a release of gaseous or ..liquid effluent, which is essentially uninterrupted for extended periods during normal operation of the facility.

Four. liquid release pathways Were designated as continuou's releases during this reporting -period: Steam Generator Blowdown, Turbine Building Sump, Waste Water Treatment, and Lime Sludge Pond. Two gas release pathways were designated as continuous releases:

Unit Vent and Radwaste Building Vent.7. Doses to a Member of the Public from Activities Inside the Site Boundary Four activities by members of the public were considered in this evaluation:

personnel making deliveries to the plant, workers at the Williarn Allen White Building located outside of the restricted area, the use of the access road' sbuth 6f the Radwaste Building, and public use of the cooling lake during .times when fishing was allowed. 'The dose calculated for the maximum exposed individual for these four activities was as follows: Plant Deliveries 3.41E-01 mRem William Allen White Building Workers 7.86E-03 mRem Access Road Users 3.49E-03 mRem Lake Use 4.90E-02 mRem The plant delivery calculations were based on'deliveries 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> per week for 50 weeks per year. The William Allen White Building occupancy was based on normal working hours of 2000 per year. The usage factor. for the access road south of the Radwaste Building was 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> per year. The dose to fishermen on the lake was based upon 3528 hours0.0408 days <br />0.98 hours <br />0.00583 weeks <br />0.00134 months <br /> (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a day for 294 days, based on the number of days that the lake was open to fisherman).

Pathways used in the calculation were gaseous inhalation, submersion, and ground plane. All calculations were performed in accordance with the methodology and parameters in the ODCM.8. Additional Information PIR 2003-0173

-On 1-29-03 the BOP Operator was taking log readings on the RM-11 and noticed monitor GHRE-10A was in accident isolation mode so the monitor was pulling sample from room air rather than from the Radwaste Vent effluent stream. The monitor was reset and flow was re-established through GHRE-10A.

A review of the RM-11 showed that GHRE-10A went into the "purging" mode at 1-28-03/2129.

I&C personnel were performing STS SP-010B, Channel Operability Test, on GHRE-10B from 1900 to -2300 on 1-28-03. The technicians were performing a database download on 24 of 40 I;)GHRE-10B at a time when the detector counts were high. As part of the downloading process the GHRE-10B software enables the detection circuitry.

When the detector circuitry was enabled with existing high counts, the GHRE-10B signal was at a sufficient level to actuate the "alert" alarm. When GHRE-10B goes into "alert', GHRE-10A goes* into "purge" mode. We did not have sampling as required by the ODCM Table 3-2 for P -6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> when the sampling air was being pulled from room air.P PIR 2003-0529

-The letter sent as a result of STS PE-003, Emergency Exhaust System Flow Rate and Combined Pressure Drop Test, contained incorrect flow rate data for the P Coritainrrient Purge unit. It had a recorded value of 4627 cfm as opposed to the current value of 4260 cfm. This incorrect flow rate was used in the low setpoint calculation for containment purge permit 2003030. The higher flow rate used In the calculation lent* itself to a more conservative setpoint.

The low setpoint used on the permit was 3.87E-05 0 uCi/cc based on 4627 cfm. The correct low setpoint would have been 4.23E-05 uCi/cc using 4260 cfm.PIR 2003-0848

-On 3-28-2003 during the channel calibration portion of STS IC-474B, Channel Calibration Unit Ventilation System Radiation Monitor GTRE21B, It was dis&vered that the pump diaphragm had a hole in it. The last time a procedure was perfoirmed that would have detected a hole in the pump diaphragm was 2-25-2003.

Chemistry reads the flow from the local rotometer and this flow reading Is used in the calculation that determines the total volume of sample that passed through the applicable filter. The rotometer is on the discharge side of the pump and registers all flow passing through it, including any dilution air. It is unknown when the hole in the diaphragm P developed..

'PIR 2003-1882

-On June 23, 2003 following a VCT purge and hydrogen recombining to GDT #3' it was noted that-the pressure in GDT #8 increased and the pressure in GDT #3 decreased.

The pressure in GDT #3 was 13 psig and the pressure In GDT #8 was 1.8 psig at 0830/6-23-2003.

Once the waste gas system was secured readings were taken on the eight gas decay tanks and monitored during the shift. The readings remained stable and at 0600/6-24-2003 the reading was 11.4 psig on GDT #3 and 3.6 psig on GDT#8. It was determined that the waste gas compressor relief valve could have caused the increase in GDT #8 and the decrease in GDT #3. Work Order 03-253665 was generated to investigate a potential hardware failure of the waste gas compressor relief valve.Troubleshooting determined the moisture separator tank relief valve for "A" compressor was intermittently leaking by based on gas decay tank pressure changes and the relief valve was changed.PIR 2003-2580

-Containment Atmosphere filters were changed on GTRE31 and GTRE32 on 8-29-2003.

The particulate filters were discolored with a "dirty tan' color. A gamma scan was performed on the particulate filter from GTRE-31 and there was no activity detected.

Filters discolored with rust or boric acid may be an indication of RCS leakage. The discoloration on the filters is not indicative of RCS leakage. The unit tripped on 8-18-2003.

On 8-23-2003 the unit reduced power to 80%. These events could have contributed to the color on the filters as well. The filters were sent to Sherry Laboratories for iron and boron analysis so a baseline could be established.

We are to complete 3 months of baseline sampling during routine operation and then perform periodic analysis to ensure the baseline hasn't changed. We didn't use the filters from the outage as a part of our baseline study so this PIR is still open. The conclusion will be included in the 2005 Annual Radioactive Effluent Report.

25 of 40 O PIR 2003-2805 On 9-22-2003 a chemistry technician

'found the sample isolation valve open for Gas Decay Tank #3. This tank was last sampled 9-5-2003.

Gas Decay Tank#8 was sampled following the sample for Gas Decay Tank #3 that was taken earlier in the day. The sample for Gas Decay Tank #8 may not have been a representative

' sample since the isolation valve for Gas Decay Tank #3 was still open. The P consequence of this' valve misalignment is a missed Technical Requirements Manual , surveillance.

Technical Surveillance Requirement 3.10.3.1 is "required once per 7 days during addition of radioactive material to the tank, AID once within 7 days following Qaddition of radioactive material to the tank". Upon 6iscovery both WGDT #3 and #8 were.' sampled, analyzed and the curie content for-each tank was determined.

This missed surveillance is .not :.reportable in the' form of a...Reportability Evaluation' Request 'or Licensee Event Report.P PIR 2003-3555

-Gas Decay Tank Release permit 2603165 was issued with an incorrect low setpoint.

The low setpoint is calculated using AIF 07B-022-07, Skin Dose Rate, and AIF 07B-022-08, Whole Body Dose Rate. The lower of the two values calculated .is the" .setpoint .If the calculated low setpoint is greater than the RWV (Radwaste Vent) low. setpoint, then the low setpoint on the GDT,. permit is set equal to the low setpoint on the RWV permit. If the calculated low setpoint is lower than the RWV low setpoint, than the calculated setpoint is used. The .clculated low setpoint was 7.97E+02 pCi/sec. The low setpoint on the RWV permit was 8.83E+02 pCi/sec. The correct low setpoint to use .on the permit was 7.97E+02 pCi/sec, but 8.83E+02 pCi/sec was recorded on the permit. The'release was performed with a less conservative setpoint, but the low setpoint Was not compromised due to the built-in conSerVatism of the setpoint calculation.

An expected monitor response is calculated which cpnsiders the rale of the release. The calculated monitor response is thendoubled and this'is the value that.is compared to the low setpoint If the expected monitor response indicates the low. setpoint could be exceeded, then the expected monitor response cal.tulation is performed again using a lower release rate to ensure the low setpoint is not breached.

The expected monItor response on the permit was 7.81E+01 pCi/sec, and the monitor reading during the release was 2.98E+01 pCi/sec.PIR 2003-3591

-Containment Purge Permit 2003178 had an incorrect value for the high setpoint for GTRE-22 and GTRE-33, Containment Air monitors.

The setpoint on the permit was recorded as 1.02E-02 pCi/cc and the setpoint should have been recorded as 1.001E-02 pCi/cc. The use of the Incorrect setpoint was discovered after the release occurred by the technician who retrieved the permit from the control room. Monitor setpoints are used to ensure compliance with 10CFR20. The ESFAS actually controls the actuation of a containment purge isolation signal, therefore the radiation monitor, via the ESFAS, would have terminated the purge prior to exceeding any 10 CFR dose limits.

N'7'-4 p~1I p p p 4: 0 26 of 40 2003 EFFLUENT CONCENTRATION LIMITS Nuclides H-3 Cr-51 Mn-54 Mn-56 Co-57 Co-58 Co-60 Sb-125 Sb-126 1-131 1-132 1-133 Cs-134 Cs-137 Nb-97 Ba-139 Rb-88 Sn-117M Sb-124'Kr-85 Kr-85M Kr-88 Xe-131M Xe-133M Xe-1 33 Xe-1 35 Curies 1.50E+03 5.29E-04 9.43E-06 3.66E-06 1.48E-05 5.26E-03 1.25E-03 9.84E-03 2.53E-06 3.90E-04 2.23E-06 3.1OE-05 2.21 E-05 2.23E-04 7.39E-06 7.OOE-06 3.27E-04 6.83E-06 2.36E-05 7.44E-04 3.91 E-05 4.48E-05 5.09E-05 8.97E-04 6.38E-02 3.40E-03 Average Diluted Concentration 1.90E-05 6.68E-112 1.19E-13 4.62E-14 1.87E-13 6.65E-11 1.58E-1 1 1.24E-10 3.20E-14 4.93E-12 2.82E-14 3.92E-1 3 2.79E-13 2.82E-12 9.34E-14 8.84E-14 4.13E-12 8.63E-14 2.98E-1 3 9.40E-12 4.94E-1 3 5.66E-13 6.43E-13 1.13E-11 8.06E-1 0 4.30E-11 10 CFR 20 ECL (Pcilml)1.OOE-03 5.OOE-04 3.00E-05 7.OOE-05 6.00E-05.2.00E-05 3.00E-06 3.OOE-05 7.OOE-06 1.OOE-06 1.00E-04 7.OOE-06 9.OOE-07 1.00E-06 3.OOE-04 2.OOE-04 4.00E-04 1.00E-08 7.00E-06 2.OOE-04 2.00E-04 2.00E-04 2.00E:04 2.00E-04 2.OOE-04 2.O0E-04% of ECL 1.90E+00 1.34E-06 3.97E-07 6.60E-08 3.12E-07 3.33E-04 5.27E-04 4.13E-04 4.57E-07 4.93E-04 2.82E-Q8 5.60E-06 3.10E-05 2.82E-04 3.11E-08 4.42E-08 1.03E-06 8.63E-04 4.26E-06 4.70E-06.2.47E-07 2.83E-07 3.22E-07 5.65E-06 4.03E-04 2.15E-05 i-I 27 of 40 0 p 0 I.;.0 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT 2003 SOLID WASTE SHIPMENTS A. SOLID RADWASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)1., Type of Waste a. Spent resins,.filter sludges evaporator bottoms, etc.b. Dry compressiblewaste,.

contaminated equip. etc.c. Irradiated components,.

control rods, etc.Unit 1-Year Period-m3* 7.52E+01*Ci 4.32E+02 m3* 8.48E+02*Ci 2.12E+00 m3* O.OOE+00 Ci. .O.OOE+00*Est. Total Error %2.50E+01 2.50E+01 2.50E+01 d. Other m3* O.OOE+00 Ci O.OOE+00 , 2.50E+01*m3 = cubic meters ** This is the volume sent'offsite for volume reductio n, prior to disposal. , .2. Estimate of Major Nuciide Composition (by.type of waste).[Nuclides listed with % abundance greater tharn 10 %]a. Spent resin, filter sludges, evaporator bottoms, etc.Nuclide Name Fe-55 Co-58 Ni-63 Percent Abundance 54.398 11.685 15.417.Curies 2.35E+02 5.05E+01 6.66E+01 b. Dry compressible waste, contaminated equipment, etc.Nuclide Name Fe-55 Co-58 Ni-63 Percent Abundance.

36.688 10.216 32.908 Curies 7.79E-01 2.17E-01 6.99E-01 AT 28 of 40 c. Irradiated components, control rods, etc. -None~3.p p p p.d. Other- None* 3. Solid Waste Dis Number of Shipments.2*4 2 2 84 8 position Mode of Transportation Truck (Hittman Transport Services)Truck (Hittman Transport Services)Truck (Hitlman Transport Services)Truck (Hittman Transport Services)Truck (TAG Transport).

Truck (R&R Trucking)Truck (R&R Trucking)Destination Barnwell Waste Management Facility, Barnwell, SC Duratek, Inc., Bear Creek, Oak Ridge, TN Duratek Inc., Gallaher, Oak Ridge, TN Studsvik Processing Facility, LLC;Columbia, SC Studsvik Processing Facility, LLC;Columbia, SC ALARON Corporation (Wampum, PA)RACE, LLC (Memphis, TN)4. Class of Solid Waste a. Class A, Class B, Class C- Corresponding to 2a". Class A, Class B, Corresponding to 2b c. Not applicable, c. Not applicable

5. Type of Container a. LSA (Strong, tight), Type A, Type B -Corresponding to 2a b. LSA (Strong, tight) -Corresponding to 2b c. Not applicable
d. Not applicable
6. Solidification Agent a. Not applicable
b. Not applicable
c. Not applicable
d. Not applicable B. IRRADIATED FUEL SHIPMENTS (Disposition)

No irradiated fuel shipments occurred during the 2003 period.

29 of.40 SECTION III HOURS AT'EACH WIND SPEED AND DIRECTION This section documents VYCGS meteorological data for wind speed, wind direction, and.atmospheric stability.

The meteorological data supplied in the following tables covers the period from January 1, 2003,'through December 31,.2003, and indicates the number of hours at each wind speed and direction for each stability class. All gasedus releases at the WCGS are ground level releases. (Wolf.P Creek Station did not meet Re'gulatory Guide 1.23 requirement for having at least 90%meteorological data recovery for 2003. PIR 2004-0620 has been written and the resolution will be presented in the 2005 Annual Report.)A Meteorological Professor at the University of Kansas established the first set of criteria*

that.is used to determine data 'availability and. verification.

This verification takes a look at all instruments on the tower and compares the instruments.

against one another to verify- a parameter that is outside the normal meteorological parameters for this part of Kansas. The software then flags 'all paramet ers in that 15-minute pe6riod as bad data. Bad data is then.accumulated assuming all parameters were unavailable.

This method also flags data as bad anytime the communication link to the plant computer' is down or the plant computer is down.This method is conservative and may flag data as bad evert though the required Reg. Guide 1.23 instruments are .stillavailable.

Data availabilityusing this r'iethod.is 84.4%., I A review of the data from the instruments reveal that approximately 12% of the missirg/bad data is from data that. was either 0, or the data did not change from one 15 minute average 'to the other. This is due to either instrument malfunction or the computer or computer link/modem being down. The Meteorological Tower Instruments will be replaced in 2004 and the problem of unresponsive instruments and the computer being down will be eliminated, or greatly reduced.Therefore, it is reasonable assurance that when the new instruments get installed that the data availability will be greater than 90%. The data availability for the Meteorological Data for the year 2003 is 84.4%.

30 of 40 HOURS AT EACH WIND SPEED AND DIRECTION ,PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2003 rp STABILITY CLASS: A ELEVATION:

10 METERS WIND SPEED (mph)WIND DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 0 1 12 28 6 1 48 NNE 0 15 36 13 1 1 66 NE .1 26 51 2 0 0, 80 ENE 0 15 32 1 1 0 : 49 E 0 3 14 2 0 0 19 ESE 1 4 12 15 1 1 34 SE 2 5 23 13 4 0 47 SSE 0 20 43 25 10-.. 0 98 S. 2 27 56 98 47 6 236 SSW 0 9 37 84 22 6 158 SW 3 5 20 19 6 0 53 WSW 1 14 19 5 0 0 39' W 0 11 41 7 0 2 61 WNW ' .2 8 6 8 10 2 34" NW 0 4 6 17 17' 0. 44 NNW .0 1 8 33. 14- 0 58 TOTAL 12 166 418 370 139 19 1122 PERIOD OF CALM*. (HOURS): 0

  • N P P P 31 of 40 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1,THROUGH DECEMBER 31,2003 STABILITY CLASS: B ELEVATION:

10 METERS WIND DIRECTION N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW TOTAL WIND 1'3 4-7 8-12 SPEED (mph)13-18 19-24'0 0 1.*I 0 0 I 0 0 2 1 0 0 0..6 11 12 9 2 0:4 5.4"0 S3 7 5'72 ,5.'18 11 8 4* 11.i0 17 22 16*11 8 6 2 4 9 162 14 0 I 2 3 3* 7.7 13 4 0 2 6 15 15.102, 4.0 0 0*"'I 1 1 3 6,.0*3'41>24 0 0 0 0 0 0 0 0 1.I 0 0.0 0 0 0 3 TOTAL 21 43 24 19 8 15 19 33 38 40 17 13 16 11 33 38 386.PERIOD OF CALM (HOURS): 0 32 of 40 0 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF IRECORD: JANUARY 1 THROUGH DECEMBER 31, 2003 STABILITY CLASS: C ELEVATION:

10 METERS WIND SPEED (mph)WIND DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 0 2 12 12 3 1 30.NNE 0 6 25 13 0, 0 44 NE 1 13 10 2 0 0 26 ENE 0 14 6 0 0 0 20 E 1 5 5 1 0 0 12 ESE 1. 5 11 5 0 0 22 SE .1 7 12 3 1 0 24 SSE .0 2 18 8 4. 1 33 S 1 7 12 20 6 2 48 SSW 1 5 11 24 4 2 47 SW 0 7 5 4 1 0 17 WSW 1 1 8 1 0. 0 11 W 0 2 4 3 0 0 9 WNW 0. 1 6 8 5 0 20.' NW. .0 0 12 21 12. 0 45 NNW '.., 0 4 18 22 5. 0 49 TOTAL 7 81 175 147 41 6 457 PERIOD OF CALM (HOURS): 0 A.n M p p.P 33 of 40 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2003 STABILITY CLASS: D ELEVATION:

10 METERS WIND.DIRECTION N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW TOTAL WIND SPEED (mph).1-3 0 3'9 9 8, 7 3 1.1*,0 04.0 47 4-7 , 8-12. .13-18 19-24 >24 15 33 76, 72 62 42 44.52.64.44 46 26 17 i2'31 646.,31 74 40 42.44 37 64 102 132 81 40 29 32 42 74-64 928* 86 71 16 11 13 21.."19.104 135 65 13 14 13 40 79 63'763" 18"" 619 4 0 0 0... 0 1, 0 1 0 1 0 25 .' .0 28 7'14 2 5 ,0 3 0 0. , 0 4 ..,0*55" 1 25. 0'.199 .20 TOTAL 156 204 141 134 128 108 131 287 367 207 105 73 62 98 1219 183 2603 PERIOD OF CALM (HOURS): 0 34 of 40-HOURS AT EACH WIND SPEED AND DIRECTION p, PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2003 STABILITY CLASS: E ELEVATION:

10 METERS WINDWIND SPEED (mph)O WIND DIRECTION 1-3 4-7 8-12 13-18 19-24 >24.TOTAL N 0 7 14 11. 0 1 33*NNE 1 32 27 10 4 1 75 w. NE 10 59 9 2 0 0 80 P ENE 9 38 11 1 0 0 59 E 7 62 33 4 0 0 108 ESE 4 78 23 6 0 0 ,111 SE 6 62 71 5 0 0 144 SSE 3' 55 128 42 8 1 237 S *6 67 87 94 57 1 312 SSW ..4 40 61 21 5. 0 131 SW 4 43 25 .2 0 0 74 WSW 4 31 25 4 0 0 64 W 2 20 10 2 0 0 34 WNW 5 28 19 1 0. 0 53' NW 3 32 47 7 0 0 89 NNW ..13 32 48 6 0 0 89* .-TOTAL 71 686 638 218 74' 4 1691 PERIOD OF CALM (HOURS): I 35 of 40 Ac HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY f'THROUGH DECEMBER 31. 2003 STABILITY CLASS: " F ELEVATION:

10 METERS WIND DIRECTION N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW TOTAL WIND SPEED' (mph), 1-3 4-7 '8-12. 13-18 19-24>24 TOTAL 10 19 0 41 8.' 42 2 39.7 52 4 64 2 79 3 42'3 12 2 15 1 23 5- 9 0 ..-3 3 .7.2- 17 1 .1 29--43 '493 ,12 , 15 2 3 16 11.19 24 13 11 13 4 0 3 9 12 167.0.0 0.I 0 0 0 4'.9 0 0 0 0 0'0.16, 0 60, 0 0"0 0 0 0, 0, 0 0 0" 1., 0 0 0 0 0 0 0 0*0 0 0 0 0 0.0 0 0 32 '56 52 45..75 79 100 73 38 29 37 18 3 13.28 42-720 I .: PERIOD OF CALM.(HOURS): 0 36 of40 a HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2003*11 STABILITY CLASS: G , .ELEVATION:

10 METERS 0 WIND WIND SPEED (mph)\ WIND DIRECTION

.1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 0 8 4. 0 0 0 12 W. NNE 1 41 17 1 0 0 60.NE 7 38 1 0 0 0 46 ENE 3, 39 3 0 0 0 45 E 0 40 5 0 0 0 45 ESE 1 33 0 0 0 0 34 SE 1 44 4 0 0 0 .49 SSE 2 24 4 0 0 0 30 S .3 12 8 0 0* 0 23 SSW 1 3 0 0 0 0 4 SW 0 3 2 0 0 0 5 WSW 1 3 1 .0 0 0 5 W 1 7 0 0 0 0 8 WNW 0 6 0 0 0 0 a NW 1 17 3 "0 0 0 21 NNW- 0 .15 6 0 0 0. 21 TOTAL 22 333 58 1 0, 0 .414 PERIOD OF CALM (HOURS): 0 37 of 40 q7)111 p P 0 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1'THROUGH DECEMBER 31, 2003 STABILITY CLASS: 'ALL.-*ELEVATION:

WIND DIRECTION 10 METERS WIND SPEED (mph)1-3 4-7 8-12. 13-18 N NNE 0 NE ENE E ESE SE SSE* S SSW SW WSW W WNW NW NNW TOTAL 0 .,.54 5 179 37 266 24 226 23 226 18 226 16 .245 12 202 is 194 9. 120 11 127 14 87 3. 67.10. 60.6 85 4 .113 208 2477 90., 212 124 105 121 105 203 336..330 217 116 94 93 78 155 165 2544 148 122 22 15 22 50 43 190 363 S2.08 42 24 27 63 139 139 1617'19-24 31 24 0 1"1 3 7.48'142*51 12.4 1...22.93".9 55 495>24 9 6 0 0 0 1 0 3 17 11 0 0 2 2 50 52 TOTAL 332 548 449 371 393 403.514 791 1062 616 308..223 193 235'479 476 7393 PERIOD OF CALM (HOURS):0 38 of 40 a SECTION IV ADDITIONAL INFORMATION

p. 1. Unplanned or Abnormal Releases P On 7-17-2003 workers were in the process of replacing the "A" waste gas compressor moisture.separator tank relief valve. This work was being performed under work order 03-253665.

When P the relief valve flange was brokern loose water commenced-spraying from the flange area and the flange bolts were This relief valve discharges to Gas Decay Tank #8 that contained approximately 5 psig.pressure.

Gas Decay Tank #8 lost approximately 0.4 psig during.this evolution.

The radwaste vent gaseous effluent monitor channel GHE103 indicated an increase'p from 9.02 to 16.2. uCVsec. The'water released from, the relief valve resulted in the area being contaminated and the area was decontaminated.

Health Physics sampling 'for airborne contaminants did not show any. radioactive particulates or iodine. Mechanical maintenance personnel exited the area and'were not contaminated or gassed up. The increase of channel GHE103 appearedtQ'be.

a result of chemistry sampling of the radwaste vent. A graph over the previous two months was reviewved and channel GHE103 increased each time chemistry sampling or filter changes were performed.

There was' no unplanned, unmonitored

  • or uncontrolled release of radioactive material to areas accessible to the public. This event wasn't due to an equipment problem. The clearance order fo" the job was not adequate and S '. maintenance personnel assumed the system was; vented to atmosphere, but did not validate it.2. Offsite Dose Calculation Manual (ODCM) .*The ODCM is in the form of two separate Wolf Creek Nuclear Operating Corpora.tibn (WCNOC)administrative procedures.

One of these* Iroce'dures, the, WCNOC "Offsite Dose Calculation Manual", AP 07B-003, Revision 4, is included 'this report as Attachment I. The 'other procedure, "Offsite Dose Calculation Manual (Radiological-Environmental Monitoring Program), AP 078-004, Revision 5, was revised in 2003; it is included with this report as Attachment I1.3. Major Changes to Liquid, Solid, or Gaseous Radioactive Waste Treatment Systems Temporary Modificatioin 98-018HB that installed the TUF (tubular ultra filtration) skid is still In.place. This Temporary Modification is being made permanent with the implementation of Design Change Package (DCP) 9337. The estimated implementation date of DCP 9337 is expected to be March of 2004. The DCP makes the DTS (Diversified Technologies)

Zero Filtration System, along with the WPS Demineralizer System, the primary means of liquid waste processing at Wolf Creek. Permanent piping and power supply are being added to mobile liquid radwaste processing skids. The primary liquid radwaste evaporator will be permanently out of service and abandoned in place.

3 39 of 40 4. Land Use Census No new locations for dose calculation were identified during this report period.S5. Radwaste Shipments IX Twenty-three shipments of radioactive waste occurred during this report period. Section Ii, Subsection 3, of this report contains specific details regarding each shipment's mode of p) transportation and destination.

6. Inoperability of Effluent Monitoring Instrumentation , No events occurred that violated ODCM Requirements Tables 2-2 and 3-2, liquid or gaseous effluent monitoring instrumentation.
7. Storage Tanks'At no time during the year 2003 was there an event that led to liquid holdup tanks or gas storage tanks, exceeding the limits of Technical Requirements Manual Sections 3.10.1 or 3.10.3.Technical Specification requirements for the program' are now covered by Technical Requirements Manual Section 3.10, "Explosive Gas and Storage Tank Radioactivity Monitoring.*

h'd /-9/ 7 I M A G E D 0 CI 0 0 W4jLF CREEK'NUCLEAR OPERATING CORPORATION Kevin J. Moles Manager Regulatory Affairs April 29, 2005 RA 05-0039 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482: Wolf Creek Generating Station Annual Radioactive Effluent Release Report -Report 28 Gentlemen:

This letter transmits the enclosed Wolf Creek Generating Station (WCGS) Annual Radioactive Effluent Release Report. The report covers the period from January 1, 2004, through December 31, 2004. It is being submitted pursuant to Section 5.6.3 of the WCGS Technical Specifications.

Included as part of the report are copies of revised procedures required to be submitted with this report. Procedures AP 07B-003, "Offsite Dose Calculation Manual," AP 07B-004, "Offsite Dose Calculation Manual (Radiological Environmental Monitoring Program)," and AP 31A-100, "Solid Radwaste Process Control Program." are included as Attachments I, II, and III to the report.No commitments are identified in this correspondence.

If you have any questions concerning this matter, please contact me at (620) 364-4126, or Ms. Diane Hooper at (620) 364-4041.KJM/rIg Enclosure cc: J. N. Donohew (NRC), wle D. N. Graves (NRC), w/e B. S. Mallett (NRC), w/e Senior Resident Inspector (NRC), w/e P.O. Box 411 / Burlington.

KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer MIF/HCNET A.U E D Ci LWolf Creek Nuclear Operating Corporation CI Wolf Creek Generating Station Docket No: 50-482 Facility Operating License No: NPF-42 Annual Radioactive Effluent Release Report Report No.28 Reporting Period: January 1, 2004 -December 31, 2004 I 2 of 40 E Table of Contents Page E Executive Summary 4 Section I 8 4 Report of 2004 Radioactive Effluents:

Liquid 8 2004 Liquid Effluents 10 2004 Liquid Cumulative Dose Summary -Table 1. 12 2004 Liquid Cumulative Dose Summary -Table 2 13* Report of 2004 Radioactive Effluents:

Airborne 14 2004 Gaseous Effluents 16 2004 Gaseous Cumulative Dose Summary -Table 1 1B 2004 Gaseous Cumulative Dose Summary -Table 2 19 Section II 20 Off site Dose Calculation Manual Limits 20 Effluent Concentration Limits (ECLs) 20 Average Energy 21 Measurements and Approximations of Total Radioactivity (Liquid and 21 Gaseous Effluents)

Batch Releases 23 Continuous Releases 23 Doses to a Member of the Public from Activities Inside the Site Boundary 23 Additional Information 23 2004 Effluent Concentration Limits 27 2004 Solid Waste Shipments 28 Irradiated Fuel Shipments 29 Section III 30 Meteorological Data -Hours At Each Wind Speed and Direction 30 Section IV 39 Unplanned or Abnormal Releases 39 Offsite Dose Calculation Manual 39 Major Changes to Liquid, Solid, or Gaseous Radioactive Waste 39 Treatment Treatment Systems 39 Land Use Census 39 Radwaste Shipments 39 Inoperability of Effluent Monitoring Instrumentation 39 Storage Tanks 39 I A 3 of 40-E Table of Contents-Attachment I -WCGS Procedure AP 07B-003, Revision 5, "Offsite Dose Calculation Manual"* Attachment II -WCGS Procedure AP 07B-004, Revision 8, "Offsite Dose Calculation Manual GR (Radiological Environmental Monitoring Program)" Attachment III -WCGS Procedure AP 31A-100, Revision 5, "Solid Radwaste Process Control 4 Program" 2 0 C I (I!4 of 40 A.E EXECUTIVE

SUMMARY

D[I This Annual Radioactive Effluent Release Report (Report # 28) documents the quantities of liquid V and gaseous effluents and solid waste released by Wolf Creek Generating Station (WCGS) from January 1, 2004 through December 31, 2004. The format and content of this report are in C1 accordance with Regulatory Guide 1.21, Revision 1, "Measuring, Evaluation, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants." Sections I, II, I1l, and IV of this report provide information required by NRC Regulatory Guide 1.21 and Section 7.2 of AP 07B-003,"Offsite Dose Calculation Manual" (ODCM).Section I -Section I contains, in detail, the quantities of radioactive liquid and gaseous effluents and cumulative dose summaries for 2004, tabulated for each quarter and for yearly totals.Specific ODCM effluent limits and dose limits are also listed in Section I, along with the percentage of the effluent limits actually released and the percentages of the dose limit actually received.

No effluent or dose limits were exceeded during 2004.An elevated release pathway does not exist at WCGS. All airborne releases are considered to be ground level releases.

The gaseous pathway dose determination is met by the WCGS ODCM methodology of assigning all gaseous pathways to a hypothetical individual residing at the highest annual X/Q and D/Q location, as specified in the ODCM. This results in a conservative estimate of dose to a member of the public, rather than determining each pathway dose for each release condition.

A conservative error of thirty percent has been estimated in the effluent data.As stated above, no ODCM dose limits were exceeded in 2004.Section II -Section II includes supplemental information on continuous and batch releases, calculated doses, and solid waste disposal.

There were 67 gaseous batch releases in 2004 versus 87 in 2003. There were 58 liquid batch releases in 2004 versus 76 in 2003. WCGS released 0.019 curies in liquid releases during 2004 versus 0.020 curies in 2003, excluding gas and tritium. Continuous release pathways remained the same as previous years and all continuous releases were monitored.

The report contains information on the following Performance Improvement Requests (PIRs): PIR 2003-2580

-This PIR is being included as a follow-up from the 2004 Annual Report.Baseline results were sent to engineering for evaluation.

Engineering made a request for additional blank filters to be sent off for comparison.

The results of those filters showed that the establishment of a baseline was not feasible.PIR 2003-3253

-This PIR is being included due to an omission from the 2004 Annual Report.On 10-29-03, a Turbine Building Sump composite was prepared and analyzed based on calculations performed on the excel spreadsheet, AIF 07B-020-02.

The calculations were performed incorrectly due to a change in daylight savings time not being included.PIR 2004-0037

-Weekly composites for both Waste Water Treatment and Turbine Buildirig Sump were completed without all required samples. Both instances resulted in improperly performed Offsite Dose Calculation Manual surveillances.

PIR 2004-0620

-The MET tower did not meet the 90% data recovery availability for 2003 required by Reg Guide 1.23, "Meteorological Programs in Support of Nuclear Power Plants." Actual availability was 84.4%. Instrumentation has been replaced to improve availability, I ,M. 5 of 40 G E D PIR 2004-1096

-On April 16, 2004, while recircing Waste Gas Decay Tank #6, the tank pressure C! was noticed to be decreasing by Operations.

After investigating, it was determined that the pressure loss was accounted for by an increase in Gas Decay Tank #8.PIR 2004-1235

-During the Quick Hit Assessment (04-153) of high ammonia chemistry, it was discussed that there was no clear determination on the effect of the ZERO system if high concentrations of ETA water are found to be leaking into the Dirty Radwaste System (DRW) from the Blowdown system.! PIR 2004-1287

-While preparing a liquid release permit for Waste Monitor Tank A (THB07A) on CMay 6, 2004, it was discovered that radiation monitor HBRE-18 was inoperable.

Chemistry had not been notified of the monitor inoperability.

The Offsite Dose Calculation Manual requires at least two independent samples be analyzed and at least two qualified individuals verify release rates and valve lineup with an inoperable monitor.PIR 2004-1410

-The ODCM contains a statement that information contained in appendix B of attachment A is "proprietary information provided by SAL." This is a concern because the Nuclear Regulatory Commission (NRC) cannot put information identified as proprietary in the public domain, and they cannot withhold the information without the appropriate documentation describing what is proprietary and why.PIR 2004-2087

-On August 13, 2004, the channel checks for radiation monitors GTRE-31 and GTRE-32 were not performed as required by Surveillance Requirements between 1100 and 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br />. This is considered a missed surveillance in accordance with Surveillance Requirement 3.0.3.PIR 2004-3146

-A Steam Generator Blowdown composite sample was not obtained within the necessary time, including the 25% grace period. The composite sample is required by AP 07B-003, Offsite Dose Calculation Manual. The result was a missed ODCM surveillance.

PIR 2004-3374

-The Effluent Management Software (EMS) used for performing Offsite Dose Calculation Manual required effluent release permit calculations was found to be inoperable on December 12, 2004. The Information Services help desk was contacted to resolve the problem, but due to the software age, lack of IS knowledge and no support system set up for immediate vendor assistance, the problems have yet to be resolved.Section III --- Section III documents WCGS meteorological data for wind speed, wind direction, and atmospheric stability.

At the time of this report, MET data was not made available.

6 of 40 ,'-E Section IV --- Section IV documents unplanned and abnormal releases, changes to radwaste treatment systems, land use census, monitoring instruments, radwaste shipments, and storage tank quantities.

There were no unplanned or abnormal releases that occurred in 2004..No changes to events occurred on the land use census, monito ring instruments, radwaste shipments, and storage units.'I It 7 of 4O A-E D ATTACHMENTS 0 Attachment I -AP 07B-003, revision 5, "Offsite Dose Calculation Manual" Attachment II -AP 07B-004, revision 8, "Offsite Dose Calculation Manual (Radiological I Environmental Monitoring Program)" A Attachment III -AP 31A-1 00, revision 5, "Solid Radwaste Process Control Program" 4 II 0

,iii A. 8 of 40 E E SECTION I REPORT OF 2004 RADIOACTIVE EFFLUENTS:

LIQUID Unit Quarter I Quarter 2 4 A. Fission and Activation Products 1. Total Release (not including tritium, gases, Ci 4.53E-03 1.94E-03 2 alpha)2. Average Diluted Concentration During piCi/ml 3.74E-10 1.53E-10 r. Period 3. Percent of Applicable Limit (1) % 9.06E-02 3.87E-02 B. Tritium 1. Total Release Ci 1.68E+01 7.66E+01 2. Average Diluted Concentration During gICvml 1.39E-06 6.04E-06 Period 3. Percent of Applicable Limit (2) (ECL) % 1.39E-01 6.04E-01 C. Dissolved and Entrained Gases 1. Total Release Ci O.OOE+00 0.00E+00 2. Average Diluted Concentration During ACi/ml 0.OOE+00 0.OOE+00 Period 3. Percent of Applicable Limit (3) % O.OOE+00 0.OOE+O0 D. Gross Alpha Radioactivity

1. Total Release Ci 5.97E-06 2.32E-06 E. Volume of Waste Released (prior to Liters 4.58E+07 7.98E+07 dilution)F. Volume of Dilution Water Used Liters 1.20E+10 1.26E+10 NOTES: 1) The applicable limit for the WCGS is 5 Curies per year. (Reference 10 CFR 50, Appendix I, 'Guides On Design Objectives For Light-Water Cooled Nuclear Power Reactors," Paragraph A.2.) The value is derived by dividing the total release Curies by 5 Curies and then multiplying the result by 100.2) This value is derived by the following formula:% of Applicable Limit = (Average Diluted Concentration)

(100)(MPC or ECL, Appendix B, Table 2 1OCFR20)3) This value is derived by the following formula:% of Applicable Limit = (Average Diluted Concentration)

(100)(2E -04 from ODCM Section 2. 1) ill G E U 0/U/U U 9 of 40 REPORT OF 2004 RADIW A. Fission and Activation Products 1. Total Release (not including tritium, gases, alpha 2. Average Diluted Concentration During Period 3. Percent of Applicable Limit (1)B. Tritium 1. Total Release 2. Average Diluted Concentration During Period 3. Percent of Applicable Limit (2) (ECL)C. Dissolved and Entrained Gases 1. Total Release 2. Average Diluted Concentration During Period 3. Percent of Applicable Limit (3)D. Gross Alpha Radioactivity

1. Total Release E. Volume of Waste Released (prior to dilution)CTIVE EFFLUENTS:

LIQUID Unit Quarter 3 Ci 5.60E-03 ACi/ml 4.09E-1 1% 1.12E-01 Ci laCi/ml Ci uiCi/ml 5.52E+02 4.03E-06 4.03E-01 4-GOE-03 2.93E-1 1 1 .46E-05 0.OOE+00 9.80E+07 Quarter 4 6.55E-03 4.89E-1 1 1.31 E-01 4.18E+02 3.12E-06 3.12E-01 9.05E-03 6.76E-1 1 3.38E-05 0.OOE+00 1.10E+08 Ci liters F. Volume of Dilution Water Used liters 1.37E+1 1 1.34E+1 1 NOTES: 1) The applicable limit for the WCGS is 5 Curies per year. (Reference 10 CFR 50, Appendix I, "Guides On Design Objectives For Light-Water Cooled Nuclear Power Reactors," Paragraph A.2.) The value is derived by dividing the total release Curies by 5 Curies and then multiplying the result by 100.2) This value is derived by the following formula:% of Applicable Limit = (Average Diluted Concentration)

(100)(MPC or ECL, Appendix B, Table 2, 1 OCFR20)3) This value is derived by the following formula:%of Applicable Limit= (Average Diluted Concentration)

(100)(2E -04 from ODCM Section 2. 1)

I..10 of 40 A.G E 2004 LIQUID EFFLUENTS Continuous Mode Batch Mode (3 Nuclides Unit Quarter 1 Quarter 2 Quarter 1 Quarter 2 c Released (3 H-3 Ci 8.31 E-01 7.19E-01 1.60E+01 7.59E+01 4 Cr-51 Ci n/a n/a 8.39E-06 n/a Mn-54 Ci <2.26E-02

<3.96E-02 3.26E-06 6.17E-07 2 Fe-55 Ci <4.53E-02

<7.93E-02

<5.18E-04

<4.48E-04 C1 Fe-59 Ci <2.26E-02

<3.96E-02

<2.59E-04

<2.24E-04 0 Co-57 Ci n/a n/a 1.24E-05 n/a Co-58 Ci <2.26E-02

<3.96E-02 3.45E-03 7.60E-04 Co-60 Ci <2.26E-02

<3.96E-02 1.70E-04 6.30E-05 Zn-65 Ci <2.26E-02

<3.96E-02

<2.59E-04

<2.24E-04 Sr-89 Ci <2.26E-03

<3.96E-03

<2.59E-05

<2.24E-05 Sr-90 Ci <2.26E-03

<3.96E-03

<2.59E-05

<2.24E-05 Mo-99 Ci <2.26E-02

<3.96E-02

<2.59E-04

<2.24E-04 Sb-124 Ci n/a n/a 6.62E-06 2.54E-06 Sb-125 Ci n/a n/a 8.31 E-04 1.07E-03 1-131 Ci <4.53E-02

<7.93E-02

<5.18E-04

<4.48E-04 1-133 Ci n/a n/a n/a Cs-134 Ci <2.26E-02

<3.96E-02 9.1OE-06 6.69E-06 Cs-137 Ci <2.26E-02

<3.96E-02 4.20E-05 3.28E-05 Ce-141

  • Ci <2.26E-02

<3.96E-02

<2.59E-04

<2.24E-04 Ce-144 Ci <2.26E-02

<3.96E-02

<2.59E-04

<2.24E-04 Gross Alpha Ci <4.53E-03

<7.93E-03 5.97E-06 2.32E-06 Ar-41 Ci <4.53E-01

<7.93E-01

<5.18E-03

<4.48E-03 Kr-85M Ci <4.53E-01

<7.93E-01

<5.18E-03

<4.48E-03 Kr-85 Ci <4.53E-01

<7.93E-01

<5.18E-03

<4.48E-03 Kr-87 Ci <4.53E-01

<7.93E-01

<5.18E-03

<4.48E-03 Kr-88 Ci <4.53E-01

<7.93E-01

<5.1 8E-03 <4.48E-03 Xe-131M Ci <4.53E-01

<7.93E-01

<5.18E-03

<4.48E-03 Xe-133M Ci <4.53E-01

<7.93E-01

<5.18E-03

<4.48E-03 Xe-133 Ci <4.53E-01

<7.93E-01

<5.18E-03

<4.48E-03 Xe-1 35M Ci <4.53E-01

<7.93E-01

<5.1 8E-03 <4.48E-03 Xe-135 Ci <4.53E-01

<7.93E-01

<5.18E-03

<4.48E-03 NOTE"Less than" values are calculated using the Lower Limit of Detection (LLD) values listed in Table 2-1 of the ODCM multiplied by the volume o1 waste discharged during the respective quarter. The "less than" values are not included in the summation for the total release values.

I E p 0 U 1I of*40 2004 LIQUID EFFLUENTS ntinuous Mode Quarter 4 Batch Mode Nuclides Released H-3 Cr-51 Mn-54 Fe-55 Fe-59 Co-57 Co-58 Co-60 Zn-65 Sr-89 Sr-90 Mo-99 Sb-124 Sb-125 1-131 1-132 1-133 Cs-134 Cs-137 Ce-141 Ce-144 Rb-88 Ba-139 Mn-56 Nb-97 Sn-1 17m Gross Alpha Ar-41 Kr-85M Kr-85 Kr-87 Kr-88 Xe-131M Xe-133M Xe-133 Xe-135M Xe-135 Unit Quarter 3 1.78E+00 n/a<4.86E-02<9.73E-02<4.86E-02 n/a<4.86E-02<4.86E-02<4.86E-02<4.86E-03<4.86E-03<4.86E-02 n/a n/a<9.73E-02 n/a n/a<4.86E-02<4.86E-02<4.86E-02<4.86E-02 n/a n/a n/a n/a n/a<9.73E-03<9.73E-01<9.73E-01<9.73E-01<9.73E-01<9.73E-01<9.73E-01<9.73E-01<9.73E-01<9.73E-01<9.73E-01 1.64E+00 n/a<5.44E-02<1.09E-01<5.44E-02 n/a<5.44E-02<5.44E-02<5.44E-02<5.44E-03<5.44E-03<5.44E-02 n/a n/a<1.09E-01 n/a n/a<5.44E-02<5.44E-02<5.44E-02<5.44E-02 n/a n/a n/a n/a n/a<1.09E-02<1.09E+00<1.09E+00<1.09E+00<1.09E+00<1.09E+00<1.09E+00<1.09E+00<1.09E+00<1.09E+00<1.09E+00 Quarter 3 5.50E+02 2.53E-05<3.11 E-04<6.22E-04<3.11 E-04 4.63E-06 9.78E-04 2.06E-04<3.11 E-04<3.11 E-05<3.1 1 E-05<3.11 E-04 n/a 4.36E-03<6.22E-04 n/a n/a 4.OOE-07 2.05E-05 2.35E-07<3.11 E-04 n/a n/a n/a n/a n/a<6.22E-05<6.22E-03<6.22E-03<6.22E-03<6.22E-03<6.22E-03<6.22E-03<6.22E-03 4.OOE-03<6.22E-03 3.42E-06 Quarter 4 4.16E+02 n/a<3.58E-04<7.17E-04<3.58E-04 n/a 2.88E-04 1.04E-04<3.58E-04<3.58E-05<3.58E-05<3.58E-04 n/a 6.11 E-03 2.52E-06 n/a n/a 1.52E-06 4.1 OE-05<3.58E-04<3.58E-04 n/a n/a n/a n/a n/a<7.17E-05<7.17E-03<7.17E-03<7.17E-03<7.17E-03<7.17E-03<7.17E-03 4.32E-05 8.98E-03<7.17E-03 3.30E-05 NOTE"Less than" values are calculated using the Lower Limit of Detection (LLD) values listed in Table 2-1 of the ODCM multiplied by the volume of waste discharged during the respective quarter. The "less than" values are not included in the summation for the total release values.

A.G E D CI 01 0 12 of 40 LIQUID CUMULATIVE DOSE

SUMMARY

(2004) TABLE 1 QUARTER 1 OF 2004 (mrem)TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE FOR BONE FOR LIVER FOR TOTAL BODY FOR THYROID FOR KIDNEY FOR LUNG FOR GI-LLI ODCM CALCULATED DOSE 2.06E-04 2.53E-02 2.53E-02 2.50E-02 2.51 E-02 2.51 E-02 2.52E-02 1.23E-04 1.40E-02 1.40E-02 1.38E-02 1.39E-02 1.39E-02 1.39E-02 ODCM LIMIT(l)5.OOE+00 5.00E+00 1.50E+00 5.00E+00 5.OOE+00 5.OOE+00 5.OOE+00 5.OOE+00 5.OOE+00 1.50E+00 5.OOE+00 5.OOE+00 5.OOE+00 5.00E+00 QUARTER 2 OF 2004 (mrem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI QUARTER 3 OF 2004 (mrem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY.TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI QUARTER 4 OF 2004 (mrem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI TOTALS FOR 2004 (mrem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI 7.27E-05 4.13E-02 4.13E-02 4.12E-02 4.13E-02 4.12E-02 4.1 3E-02 2.05E-04 3.68E-02 3.67E-02 3,65E-02 3,66E-02 3.65E-02 3.66E-02 6.07E-04 1.17E-01 1.17E-01 1.1 7E-01 1.17E-01 1.17E-01 1.17E-01 5.OOE+00 5.OOE+00 1.50E+00 5.OOE+00 5.OOE+00 5.00E+00 5.OOE+O0 5.OOE+00 5.OOE+00 1.50E+00 5.OOE+00 5.00E+00 5.00E+00 5.00E+00 1.OOE+01 1.00E+O1 3.00E+00 1.00E+01 1.OOE+01 1.00E+01 1.OOE+01% OF LIMIT 4.12E-03 5.07E-01 1.68E+00 5.01 E-01 5.03E-01 5.01 E-01 5.04E-01 2.46E-03 2.81 E-01 9.32E-01 2.77E-01 2.78E-01 2.77E-01 2.78E-01 1.45E-03 8.26E-01 2.75E+00 8.24E-01: 8.25E-01 8.25E-01 8.27E-01 4.1OE-03 7.36E-01 2.45E+00 7.30E-01 7.32E-01 7.31 E-01 7.33E-01 6.07E-03 1.17E+00 3.91 E+00 1.17E+00 1.17E+00 1.17E+00 1.17E+00 1. Based on ODCM Section 2.2, which restricts dose to the whole body to s 1.5 mRem per quarter and 3.0 mRem per year. Dose restriction of any organ is -- 5.0 mRem per quarter and 10.0 mRem per year.

13 of 40 A.E[) LIQUID CUMULATIVE DOSE

SUMMARY

(2004) TABLE 2 U A. Fission and Activation Quarter I Quarter 2 Quarter 3 Quarter 4 Total Products (not including H-3, gases, alpha)1. Total Release -(Ci) 4.53E-03 1.94E-03 5.60E-03 6.55E-03 1.86E-02/ 2. Maximum Organ Dose (mRem) 3.18E-04 1.84E-04 1.02E-04 2.74E-04 8.71 E-04 L 3. Organ Dose Limit (mRem) 5.00E+00 5.OOE+00 5.OOE+00 5.OOE+00 1.00E+01 4. Percent of Limit 6.36E-03 3.69E-03, 2.04E-03 5.48E-03 8.71 E-03 j B. Tritium 1. Total Release -(Ci) 1.68E+01 7.66E+01 5.52E+02 4.18E+02 1.06E+03 2. Maximum Organ Dose (mRem) 2.50E-02 1.38E-02 4.12E-02 3.65E-02 1.17E-01 3. Organ Dose Limit (mRem) 5.OOE+00 5.OOE+00 5.OOE+00 5.OOE+00 1.OOE+01 4. Percent of Limit 5.01 E-01 2.77E-01 8.24E-01 7.30E-01 1.17E+00 This table is included to show the correlation between ,Curies released and the associated calculated maximum organ dose'. Wolf Creek ODCM methodology is used to calculate the maximum organ dose that assumes that an individual drinks the water and eats the fish from the discharge point. ODCM Section 2.2 organ dose limits are used. The less than values are not included in the summation for the total release values.

I A. 14 of 40 G F REPORT OF 2004 RADIOACTIVE EFFLUENTS:

AIRBORNE Quarter Quarter O Unit 1 2 A. Fission and Activation Gases 0 1. Total Release Ci 3.28E-01 4.07E-01 2. Average Release Rate for Period pCi/sec 4.17E-02 5.18E-02 3. Percent of ODCM Limit (1) % 4.25E-03 3.59E-03 b-? B. Iodine 1 .Total Release Ci O.OOE+00 O.OOE+00 2. Average Release Rate for Period pCilsec O.OOE+00 O.OOE+00 3. Percent of Applicable Limit (2) % O.OOE+00 O.OOE+00 C. Particulates

1. Particulates with Half-lives

> 8 days Ci 2.86E-07 O.OOE+00 2. Average Release Rate for Period pCi/sec 3.64E-08 O.OOE+00 3. Percent of ODCM Limit (3) % 2.03E-06 O.OOE+00 4. Gross Alpha Radioactivity Ci O.OOE+00 O.OOE+00 D. Tritium 1., Total Release Ci 4.63E+00 1.02E+01 2. Average Release Rate for Period p.Ci/sec 5.89E-01 1.29E+00 3. Percent of ODCM Limit (4) % 4.76E-02 1.00E-01 NOTES: 1) The percent of ODCM limit for fission and activation gases is calculated using the following methodology:.

% of ODCM Limit = (Qtrly Total Beta Airdose)(100) or (Qtrly Total Gamma Airdose)(100) 10 mrad 5 mrad The largest value calculated between Gamma and Beta air dose is listed as the % of ODCM Limit.2) The percent of ODCM limit for iodine is calculated using the following methodology:

% of ODCM Limit= (Total Curies of Iodine- 131)(100)] Curie 3) The percent of ODCM limit for particulates is calculated using the following methodology:.

%of ODCM Limit= (Highest Organ Dose Due to Particulates)(100) 7.5 mrem.This type of methodology is used since the Wolf Creek ties release limits to doses rather than curie release rates.4) The percent of ODCM limit for tritium is calculated using the following methodology:.

% of ODCM Limit= (Highest Organ Dose Due to H-3)(100)7.5 mrem I A 15 of 40 G E REPORT OF 2004 RADIOACTIVE EFFLUENTS:

AIRBORNE D Quarter Quarter 0 Unit 3 4 A. Fission and Activation Gases 1. Total Release Ci 3.04E-01 3.86E-01 2. Average Release Rate for Period pCi/sec 3.83E-02 4.86E-02 3. Percent of ODCM Limit (1) % 3.64E-03 4.08E-03 B. lodines-1. Total Iodine-131 Ci 0.OOE+O0 O.OOE+00 2. Average Release Rate for Period piCi/sec O.OOE+00 O.OOE+00 3. Percent of Applicable Limit (2) % O.OOE+00 O.OOE+00 C. Particulates

1. Particulates with Half-lives

> 8 days Ci 0.O0E+00 O.OOE+00 2. Average Release Rate for Period piCi/sec 0.OOE+00 0.OOE+00 3. Percent of ODCM Limit (3) % O.OOE+00 O.OOE+00 4. Gross Alpha Radioactivity Ci 0.OOE+00 O.OOE+00 D. Tritium 1.. Total Release Ci 1.51E+01 4.52E+00 2. Average Release Rate for Period pCi/sec 1.90E+00 5.69E-01 3. Percent of ODCM Limit (4) % 1.38E:01 3.91 E-02 NOTES: 1) The percent of ODCM limit for fission and activation gases is calculated using the following methodology.

%of ODCM Limit= (Qtrly Total Beta Airdose)(100) (Qtrly Total Gamma Airdose)(100) or l0 mrad 5 mrad The largest value calculated between Gamma and Beta air dose is listed as the % of ODCM Limit.2) The percent of ODCM limit for iodine is calculated using the following methodology:

% of ODCM Limit= (Total Curies of Iodine- 131)(100)1 Curie 3) The percent of ODCM limit for particulates is calculated using the following methodology:

% of ODCM Limit = (Highest Organ Dose Due to Particulates)( 100)7.5 mrem This type of methodology is used since the Wolf Creek ODCM ties release limits to doses rather than curie release rates.4) The percent of ODCM limit for tritium is calculated using the following methodology:

%of ODCM Limit= (Highest Organ Dose Due to H-3)(100)7.5 mrem 16 of 40 E 0 2004 GASEOUS EFFLUENTS Continuous Mode Batch Mode Nuclides Released Unit Quarter 1 Quarter 2 Quarter 1 Quarter 2 1. Fission and Activiation (i Gases Ar-41 Ci n/a n/a 3.27E-01 2.77E-01/ Kr-85 Ci n/a n/a n/a 1.25E-01 Kr-85M Ci n/a n/a n/a 1.55E-06 Kr-87 Ci <1.02E+01

<1.01E+01

<1.35E-02

<1.14E-02 Kr-88 Ci <1.14E+01

<1.13E+01

<1.52E-02

<1.28E-02 U Xe-131M Ci n/a n/a n/a n/a Xe-133 Ci <6.38E+00

<6.32E+00 5.56E-04 5.13E-03 Xe-133M Ci <2.63E+01

<2.60E+01

<3.50E-02 7.26E-05 Xe-135 Ci <2.75E+00

<2.72E+00

<3.66E-03 1.96E-04 Xe-138 Ci <2.96E+02

<2.93E+02

<3.93E-01

<3.32E-01 Total Ci O.OOE+00 O.OOE+00 3.28E-01 4.07E-01 2. Halogens (Gaseous)1-131 Ci <2.64E-04

<2.61 E-04 <3.51 E-07 <2.96E-07 1-133 Ci <2.64E-02

<2.61 E-02 <3.51 E-05 <2.96E-05 Total Ci O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 3. Particulates and Tritium H-3 Ci 4.49E+00 9.68E+00 1.43E-01 4.94E-01 Mn-54 Ci <2.64E-03

<2.61 E-03 <3.51 E-06 <2.96E-06 Fe-59 Ci <2.64E-03

<2.61 E-03 <3.51 E-06 <2.96E-06 Co-58 Ci 2.86E-07 <2.61 E-03 <3.51 E-06 <2.96E-06 Co-60 Ci <2.64E-03

<2.61 E-03 <3.51 E-06 <2.96E-06 Zn-65 Ci <2.64E-03

<2.61E-03

<3,51E-06

<2.96E-06 Mo-99 Ci <2.64E-03

<2.61 E-03 <3,51 E-06 <2.96E-06 Cs-134 Ci <2.64E-03

<2.61 E-03 <3.51 E-06 <2.96E-06 Cs-1 37 Ci <2.64E-03

<2.61 E-03 <3.51 E-06 <2.96E-06 Ce-141 Ci <2.64E-03

<2.61 E-03 <3.51 E-06 <2.96E-06 Ce-144 Ci <2.64E-03

<2.61E-03

<3.51 E-06 <2.96E-06 Sr-89 Ci <2.64E-03

<2.61E-03

<3.51E-06

<2.96E-06 Sr-90 Ci <2.64E-03

<2.61E-03

<3.51E-06

<2.96E-06 Gross Alpha Ci <2.64E-03

<2.61 E-03 <3.51 E-06 <2.96E-06 Total Ci 4.49E+00 9.68E+00 1.38E-01 4.94E-01 I NOTE"Less than" values for Noble Gases are calculated using the Lower Limit of Detection (LLD) values obtained at Wolf Creek Generating Station multiplied by the volume of air discharged during the respective quarter.For the Halogens and Particulates the ODCM LLD values are used.

I 17 of 4O A.G E E 2004 GASEOUS EFFLUENTS O Continuous Mode Batch Mode Nuclides Released Unit Quarter 3 Quarter 4 Quarter 3 Quarter 4 1. Fission and Activiation Ci Gases Ar-41 Ci n/a n/a 2.81 E-01 3.12E-01 Kr-85 Ci n/a n/a 1.83E-02 8.71 E-03 Kr-85M Ci n/a n/a n/a n/a 2 Kr'-87 Ci <1.03E+01

<1.01 E+01 <1.20E-02

<1.27E-02 Kr-88 Ci <1.16E+01

<1.14E+01

<1.35E-02

<1.43E-02 0 Xe-131M Ci n/a n/a 2.61E-04 n/a Xe-1 33 Ci <6.48E+00 6.27E-02 5.23E-03 2.36E-03 Xe-133M Ci <2.67E+01

<2.61 E+01 2.75E-05 1.80E-05 Xe-1 35 Ci <2.80E+00

<2.73E+00

<3.24E-03

<3.44E-03 Xe-1 38 Ci <3.OOE+02

<2.93E+02

<3.48E-01

<3.70E-01 Total Ci 0.00E+00 6.27E-02 3.04E-01 3.23E-01 2. Halogens (Gaseous)1-131 Ci <2.68E-04

<2.62E-04

<3.11 E-07 <3.30E-07.1-133 Ci <2.68E-02

<2.62E-02

<3.11E-05

<3.30E-05.Total Ci 0.00E+00 0.00E+00 0.00E+00 0.00E+00 3. Particulates and Tritium H-3 Ci 1.41E+01 4.14E+00 1.00E+00 3.82E-01 Mn-54 Ci <2.6BE-03

<2.62E-03

<3.11 E-06 <3.30E-06 Fe-59 Ci <2.68E-03

<2..62E-03

<3.11E-06

<3.30E-06 Co-58 Ci <2.68E-03

<2.62E-03

<3.11E-06

<3.30E-06 Co-60 Ci <2.68E-03

<2.62E-03

<3.11E-06

<3.30E-06 Zn-65 Ci <2.68E-03

<2.62E-03

<3.11E-06

<3.30E-06 Mo-99 Ci <2.68E-03

<2.62E-03

<3.11E-06

<3.30E-06 Cs-134 Ci <2.68E-03

<2.62E-03

<3.11E-06

<3.30E-06 Cs-137 Ci <2.68E-03

<2.62E-03

<3.11E-06

<3.30E-06 Ce-1 41 Ci <2.68E-03

<2.62E-03

<3.11E-06

<3.30E-06 Ce-144 Ci <2.68E-03

<2.62E-03

<3.11E-06

<3.30E-06 Sr-89 Ci <2.68E-03

<2.62E-03

<3.11E-06

<3.30E-06 Sr-90 Ci <2.68E-03

<2.62E-03

<3.11 E-06 <3.30E-06 Gross Alpha Ci <2.68E-03

<2.62E-03

<3.11 E-06 <3.30E-06 Total Ci 1.41 E+01 4.14E+00 1.00E+00 3.82E-01 NOTE"Less than" values for Noble Gases are calculated using the Lower Limit of Detection (LLD) values obtained at Wolf Creek Generating Station multiplied by the volume of air discharged during the respective quarter.For the Halogens and Particulates, the ODCM LLD values are used.

I Ii A.G E U 0 0.e1/0 18 of 40 GASEOUS CUMULATIVE DOSE

SUMMARY

(2004) TABLE 1 QUARTER 1 OF 2004 (mRem)TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE FOR BONE FOR LIVER FOR TOTAL BODY FOR THYROID FOR KIDNEY FOR LUNG FOR GI-LLI ODCM CALCULATED DOSE 6.19E-08 3.27E-03 3.27E-03 3.27E-03 3.27E-03 3.27E-03 3.27E-03 0.OOE+00 7.19E-03 7.19E-03 7.19E-03 7.19E-03 7.19E-03 7.19E-03 ODCM LIMIT (1)7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 QUARTER 2 OF 2004 (mRem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI QUARTER 3 OF 2004 (mRem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI QUARTER 4 OF 2004 (mRem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI TOTALS FOR 2004 (mRem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI 0.OOE+00 1.07E-02 1.07E-02 1.07E-02 1 .07E-02 1.07E-02 1.07E-02 0.OOE+00 3.20E-03 3.20E-03 3.20E-03 3.20E-03 3.20E-03 3.20E-03 6.19E-08 2.43E-02 2.43E-02 2.43E-02 2.43E-02 2.43E-02 2.43E-02 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 1.50E+01 1.50E+01 1.50E+01 1.50E+01 1.50E+01 1.50E+01 1.50E+01% OF LIMIT 8.25E-07 4.36E-02 4.36E-02 4.36E-02 4.36E-02 4.36E-02 4.36E-02 0.OOE+00 9.59E-02 9.59E-02 9.59E-02 9.59E-02 9.59E-02 9.59E-02 O.OOE+00 1.42E-01 1.42E-01 1.42E-01 1.42E-01 1.42E-01 1.42E-01 0.OOE+00 4.26E-02 4.26E-02 4.26E-02 4.26E-02 4.26E-02 4.26E-02 4.13E-07 1.62E-01 1.62E-01 1.62E-01 1.62E-01 1.62E-01 1.62E-01 1. Based on Wolf Creek ODCM Section 3.2.2 which restricts dose during any calendar quarter to less than or equal to 7.5 mRem to any organ and during any calendar year to less than or equal to 15 mRem to any organ.

I A. 19 of 40 G E[] GASEOUS CUMULATIVE DOSE

SUMMARY

(2004) TABLE 2 U Nuclides Released Quarter 1 Quarter 2 Quarter 3 Quarter 4 Total/ A. Fission and Activation Gases ,4 1. Total Release -(Ci) 3.28E-01 4.07E-01 3.04E-01 3.86E-01 1.43E+00/ 2. Total Gamma Airdose (mRad) 2.12E-04 1.80E-04 1.82E-04 2.04E-04 7.78E-04 3. Gamma Airdose Limit (mRad) 5.OOE+00 5.00E+00 5.00E+00 5.OOE+00 1.OOE+01 o 4. Percent of Gamma Airdose Limit 4.25E-03 3.59E-03 3.64E-03 4.08E-03 7.78E-03 o 5, Total Beta Airdose (mRad) 7.49E-05 8.07E-05 6.70E-05 7.74E-05 3.OOE-04 6. Beta Airdose Limit (mRad) 1.OOE+01 1.OOE+01 1.00E+01 1.OOE+01 2.OOE+01-7. Percent of Beta Airdose 7.49E-04 8.07E-04 6.70E-04 7.74E-04 1.50E-03 Limit (mRad)B. Particulates

1. Total Particulates (Ci) 2.86E-07 0.OOE+00 0.00E+00 0.OOE+00 2.86E.07 2. Maximum Organ Dose (mRem) 1.52E-07 0.OOE+00 O.OOE+00 0.OOE+00 1.52E-07 3. Organ Dose Limit (mRem) 7.50E+00 7.50E+00 7.50E+00 7.50E+00 1.50E+01 4. Percent of Limit 2.03E-06 0.OOE+00 O.OOE+00 0.OOE+00 1.02E-06-C. Tritium 1. Total Release (Ci). 4.63E+00 1.02E+01 1.51 E+01 4.52E+00 3.44E+01 2. MaximumýOrgan Dose (mRem) 3.57E-03 7.50E-03 1.03E-02 2.93E-03 2.43E-02 3. Organ Dose Limit (mRem) 7.50E+00 7.50E+00 7.50E+00 7.50E+00 1.50E+01 4. Percent of Limit 4.76E-02 1.OOE-01 1.38E-01 3.91 E-02 1.62E-01 D. Iodine 1. Total 1-131, 1-133 (Ci) 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 2. Maximum Organ Dose (mRem) 0.00E+00 0.00E+00 0.OOE+00 0.OOE+00 0.OOE+00 3. Organ Dose Limit (mRem) 7.50E+00 7.50E÷00 7.50E+00 7.50E+00 1.50E+01 4. Percent of Limit 0.OOE+00 0.OOE+00 O.OOE+00 0.OOE+00 0.OOE+00 This table is included to show the correlation between Curies released and the associated calculated maximum organ dose. The maximum organ dose is calculated using Wolf Creek ODCM methodology which assumes that an individual actually resides at the release point. ODCM Section 3.2.2 organ dose limits are used.

I" 20 of 40 E SECTION II D SUPPLEMENTAL INFORMATION

1. Offsite Dose Calculation Manual Limits WA. For liqUid waste effluents A.1 The concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS shall be limited to the concentrations specified in 10 CFR 20, Appendix B, Table II, Column 2, for radionuclides other than dissolved or entrained noble rases. For dissolved or entrained noble gases, the concentration shall be limited to 2 x 10Y microCuries/ml total activity.A.2 The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released, from each unit, to UNRESTRICTED AREAS shall be limited: a. During any calendar quarter to less than or equal to 1.5 mrems to the whole body and to less than or equal to 5 mrems to any organ, and b. During any calendar year to less than or equal to 3 mrems, to the whole body and to less than or equal to 10 mrems to any organ.B. For gaseous waste effluents B.1 The dose rate due to radioactive material released in gaseous effluents from the site to area at and beyond the SITE BOUNDARY shall be limited to the following:
a. For noble gases: Less than or equal to 500 mrems/yr to the whole body and less than or equal to 3000 mrems/yr to the skin, and b. For Iodine-i131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days: Less than or equal to 1500 mrems/yr to any organ.B.2 The air dose due to noble gases released in gaseous effluents, from each unit, to areas at and beyond the SITE BOUNDARY shall be limited to the following:
a. During any calendar quarter: Less than or equal to 5 mrads for gamma radiation and less than or equal to 10 mrads for beta radiation, and b. During any calendar year. Less than or equal to 10 mrads for gamma radiation and less than or equal to 20 mrads for beta radiation.

B.3 The dose from Iodine-131, Iodine-133, tritium, and a radionuclide in particulate form with half-lives greater than 8 days in gaseous effluents released to area at and beyond the SITE BOUNDARY shall be limited to the following:

a. During any calendar quarter: Less than or equal to 7.5 mrems to any organ, and b. During any calendar year. Less than or equal to 15 mrems to any organ.2. Effluent Concentration Limits (ECLs)Water -covered in Section I.A.Air -covered in Section I.B.

A.E D C 2i 0: 21 of 40 3. Average Energy Average energy of fission and activation gaseous effluents is not applicable.

See ODCM Section 3.1 for the methodology used in determining the release rate limits from noble gas releases.4. Measurements and Approximations of Total Radioactivity A. Liquid Effluents.

Liquid Release Sampling Method of Analysis Type of Activity Type Frequency Analysis P 1. Batch Waste Each Batch P.H.A. Principal Gamma Emitters Release Tank P Each Batch P.H.A. 1-131 a. Waste Monitor P P.H.A. Dissolved and Entrained Tank One Batch/M Gases (Gamma Emitters)b. Secondary Liquid P L.S. H-3 Waste Monitor Each Batch S.A.C. Gross Alpha Tanks P O.S.L. Sr-89. Sr-90 2. Continuous Daily P.H.A. Principal Gamma Emitters Releases Grab Sample P.H.A. 1-131 a. Steam Generator M Dissolved and entrained Blowdown Grab Sample P.H.A. Gases (Gamma Emitters)b. Turbine Building Daily L.S. H-3 SumplWaste Water Grab Sample Treatment S.A.C. Gross Alpha O.S.L. Sr-89, Sr-90 c. Lime Sludge Pond Daily Grab Sample O.S.L. Fe-55 P = prior to each batch M = monthly L. S. = Liquid scintillation detector S.A.C. = scintillation alpha counter O.S.L. = performed by an offsite laboratory P.H.A. = gamma spectrum pulse height analysis using a High Purity Germanium detector A~.G E 0 0 22 of 40 B. Gaseous Waste Effluents Gaseous, Release Sampling Frequency Method of Analysis Type of Activity Type Analysis P P.H.A. Principal Gamma Emitters Waste Gas Decay Tank Each Tank Grab Sample Containment Purge or P P.H.A. Principal Gamma Emitters Vent Each Purge Grab Sample Gas Bubbler and L.S. H-3 (oxide)Unit Vent M P.H.A. Principal Gamma Emitters Grab Sample Gas Bubbler and L.S. H-3 (oxide)Radwaste Building M P.H.A Principal Gamma Emitters Vent Grab Sample For Unit Vent and Continuous P.H.A. 1-131 Radwaste Building Vent release types 1-133 listed above Continuous P.H.A. Principal Gamma Emitters Particulate Sample Continuous S.A.C. Gross Alpha Composite Particulate Sample Continuous O.S.L. Sr-89, Sr-90 Composite Particulate Sample P = prior to each batch M = monthly L.S. = Liquid scintillation detector S.A.C. = scintillation alpha counter O.S.L. = performed by an offsite laboratory P.H.A. = gamma spectrum pulse height analysis using a High Purity Germanium detector Ii A. 23 of 40 G E 5. Batch Releases D A batch release is the discontinuous release of gaseous or liquid effluents which takes place over a finite period of time; usually hours or days.There were 67 gaseous batch releases during the reporting period. The longest gaseous U batch release lasted 522 minutes, while the shortest lasted 42 minutes. The average release lasted 178 minutes with a total gaseous batch release time of 11,899 minutes./There were 58 liquid batch releases during the reporting period. The longest liquid batch C_1 release lasted 265 minutes, while the shortest lasted 29 minutes. The average release Ulasted 156 minutes with a total liquid batch release time of 8,981 minutes.6. Continuous Releases A continuous release is a release of gaseous or liquid effluent, which is essentially uninterrupted for extended periods during normal operation of the facility.

Four liquid release pathways were designated as continuous releases during this reporting period: Steam Generator Blowdown, Turbine Building Sump, Waste Water Treatment, and Lime Sludge Pond. Two gas release pathways were designated as continuous releases:

Unit Vent and Radwaste Building Vent.7. Doses to a Member of the Public from Activities Inside the Site Boundary Four activities by members of the public were considered in this evaluation:

personnel making deliveries to the plant, workers at the William Allen White Building located outside of the restricted area, the use of the access road south of the Radwaste Building, and public use of the cooling lake during times when fishing was allowed. The dose calculated for the maximum exposed individual for these four activities was as follows: Plant Deliveries 2.63E-01 mRem William Allen White Building Workers 5.91 E-03 mRem Access Road Users 2.69E-03 mRem Lake Use 3.66E-02 mRem The plant delivery calculations were based on deliveries 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> per week for 50 weeks per year. The William Allen White Building occupancy was based on normal working hours of 2000 per year. The usage factor for the access road south of the Radwaste Building was 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> per year. The dose to fishermen on the lake was based upon 3840 hours0.0444 days <br />1.067 hours <br />0.00635 weeks <br />0.00146 months <br /> (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a day for 320 days, based on the number of days that the lake was open to fisherman).

Pathways used in the calculation were gaseous inhalation, submersion, and ground plane. All calculations were performed in accordance with the methodology and parameters in the ODCM.8. Additional Information PIR 2003-2580

-This PIR is being included as a follow-up from the 2004 Annual Report. Several months' filters were sent to Sherry Laboratories for vendor analysis of boron and iron to establish a baseline for results. All results were sent to engineering for evaluation.

At the request of engineering, several new filters, all from different lots, were sent to the vendor for comparison.

Following the return of these results from the vendor, engineering determined that the establishment of a baseline for boron and iron on sample I A. 24 of 4O G E filters was not feasible.

Engineering recommended that the iron and/or boron content of D exposed radiation monitor filters not be used as a first indication for RCS leakage.0! Instead, isotopic analyses should be used, considering both total activity and isotopes present. Changes were made to chemistry procedures AP 02-002, Chemistry Surveillance Program, and AP 02-003, Chemistry Specification Manual, to provide necessary guidance to ensure any potential RCS leakage be quickly assessed./1 PIR 2003-3253

-This PIR is being included due to an omission from the 2004 Annual 2Report. On 10-29-03, a Turbine Building Sump composite was prepared and analyzed 2j based on calculations performed on excel spreadsheet, AIF 07B-020-02.

The 01 spreadsheet did not account for the hour gain due to daylight savings time and incorrectly calculated the discharge volume. The composite volume for the Turbine Building Sump was corrected for the end of daylight savings time, and other composites were reviewed to ensure the program error did not occur with them. Not including the 60-minute difference had virtually no impact, as there was an insignificant difference

(<0.5%) in the volume used for the total composite volume. A change was made to chemistry procedure Al 07B-020, Instructions for Composite Preparation, informing the user that daylight savings corrections need to be performed manually.PIR 2004-0037

-For the week of 11-5 through 11-11-03, the Turbine Building Sump (TBS) weekly composite did not contain a required sample. For the week of 11-12 through 11-18-03, the Waste Water Treatment (WWT) weekly composite did not contain a required sample. Both instances resulted in improperly performed Offsite Dose Calculation Manual (ODCM) surveillances.

Both instances happened during Refueling Outage 13. The TBS miss occurred due to' miscommunication about the ucomposite*

week". Discussions between technicians resulted in the daily composite, pulled 11-5-03, not being added to the weekly composite.

The review of appropriate paperwork was done improperly and that daily composite remained on the shelf. The omission was questioned but not resolved.

The WWT miss also occurred due to miscommunication between Chemistry and Operations, as well as within Chemistry itself. A sample of the B basin was pulled 11-11-03 and saved for composite.

That basin was held for three days prior to release due to a circ water outage. There was confusion between groups as to which basin had actually been sampled, and information about that was apparently recorded incorrectly.

The result was that the composite for B basin, pulled 11-11 and released 11-14-03, was not included in the weekly composite.

The volumes for both weekly composites were corrected and corresponding release permits edited to correct discharge volumes and total curies released.

Several procedure changes were made to address daily compositing, defining the composite week, and changing the composite review and verification process. In addition, the problems and resolutions identified in this PIR were reviewed with all technicians face to face.PIR 2004-0620

-The MET tower did not meet the 90% data recovery availability for 2003 required by Reg Guide 1.23, "Meteorological Programs in Support of Nuclear Power Plants." The actual availability was 84.4 %. The lower availability was due to instrument malfunction or the computer or computer link/modem being unavailable.

A change package (09882) was implemented to replace instrumentation on the MET tower.Meteorological instrumentation was replaced by mid-August 2004 to improve availability.

2004-1096

-On April 16, 2004, while recircing Waste Gas Decay Tank (WGDT) #6, the tank pressure was noticed to be decreasing by Operations.

After investigating, it was determined that the pressure loss was accounted for by an increase in WGDT #8. The II 25 of 40 A.G E result of the pressure transfer did not affect any ongoing operations.

During El troubleshooting, it was determined that HA V-1032F, Compensating Seal Make-up Valve o solenoid, was not operating properly.

That valve was replaced, tested, and found operating properly.

However, a pressure change between #6 and #8 was still observed.It was then determined that the transfer appeared to be a result of the Waste Gas* Compressor B moisture separator relief valve leaking by the valve seat, which may have 0] been a result of the previously bad solenoid valve. A workorder was issued to replace the moisture separator relief.2004-1235

-During the Quick Hit Assessment (04-153) of high ammonia chemistry, it was discussed that there was no clear determination on the effect of the ZERO system if high concentrations of ethanolamine (ETA) water are found to be leaking into the Dirty Radwaste System (DRW) from the Blowdown system. Discussions were held with Diversified Technologies Services (DTS) chemical engineer, who was contacted for advice on processing liquid waste containing ammonia and/or ETA. The DTS position is that the SRO unit will reject the ETA, which will result in this chemical being concentrated in the reject waste stream. It will then be concentrated as a dry solid waste in the Drum Dryer prior to disposal.

ETA concentrations should not impact the existing liquid waste processing systems.2004-1287

-While preparing a liquid release permit for Waste Monitor Tank A (THB07A)on May 6, 2004, it was discovered that radiation monitor HBRE-18 was inoperable.

...Chemistry had not been notified of the monitor inoperability.

The ODCM requires at least two independent samples be analyzed and at least two qualified individuals verify release rates and valve lineup with an inoperable monitor. In addition Chemistry is required to initiate APF 02-007-01, HBRE-18 Operability.

The inoperability was due to a loss of communication between the RM1 1 and HBRE-18. Upon investigation, it was reported that the monitor was functioning properly locally. Due to the fact that it was operating locally and there was no release actually in progress, the Control Room Supervisor did not consider the monitor inoperable and no actions were taken. After further investigation, it was recognized that notification should have been made. The miscommunication resulted in unnecessary delays in permit preparation and additional unscheduled work for Chemistry.

2004-1410

-The ODCM, submitted as an attachment to the 2003 Annual Effluent Report, contains a statement that information contained in appendix B of attachment A is"proprietary information provided by SAL." This is a concern because the Nuclear Regulatory Commission (NRC) cannot put information identified as proprietary in the public domain, and they cannot withhold the information without the appropriate documentation describing what is proprietary and why. This phrase has been included in the ODCM since revision 0 was released because the ODCM receives its own review as part of revision process and is only an attachment to the report. The statement is not appropriate and there is no concern with prior submittals, but the NRC requested that the 2004 report be corrected so it can be handled properly.

Following investigation, it appeared that the statement may have been inappropriately "cut and pasted" along with the data in this appendix but is not proprietary to SAL. The conclusion was that the statement could be removed without violating any agreement or rights of SAL. AP 07B-003, ODCM, was revised to remove the "proprietary information" label from the document.

It was released 9-29-04. In addition, letter RA 04-0119 was submitted to the NRC on 10-13-04 to provide them with the revised version of the Annual Report containing the revised ODCM.

I (I'A, 26 of 40 G E D 2004-2087

-On August 13, 2004, the channel checks for Containment Atmosphere radiation monitors GTRE-31 and GTRE-32 were not performed as required by Surveillance Requirements between 1100 and 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br />. This is considered to be a missed surveillance in accordance with Surveillance Requirement (SR) 3.0.3. The* ~. previous check had been completed satisfactorily at 0449. The subsequent check ,4 completed at 2206. As allowed by SR 3.0.3, the surveillance was performed satisfactorily within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the missed surveillance.

A review of historical data for both monitors indicated that both channels remained operable during the time of the o missed surveillance.

C2004-3146

-On November 23, 2004, a Steam Generator Blowdown composite sample was not obtained within the necessary time, including the 25% grace period. The composite sample is required by AP 07B-003, ODCM. The sample on 11-22 was obtained at 0805. The sample on 11-23 was not obtained until 1455, after prompting from the Control Room. Based on the grace period allowance, the sample was required by 1405. The result was a missed ODCM surveillance.

The consequences of this were minor due to the fact that the daily sample composite represents a larger volume that will be reflected when included in the weekly composite.

2004-3374

-The Effluent Management Software (EMS) used for performing ODCM required effluent release permit. calculations was found to be inoperable on December 12, 2004. The Information Services'help desk was contacted to resolve the problem, but due to the software age, lack. of IS knowledge

and no support system set up for immediate vendor assistance, the problems were slow to be resolved.

Data had not been backed up on EMS since 11-23, so reentering all of the permit data would have been required prior to performing additional release calculations.

The evolution was expected to take between 12 and 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> for entry and verification.

Fortunately, the system recovered long enough to perform a backup. EMS had to be accessed on a backup server, designed for testing/development not production.

The consequences of not having EMS accessible to perform release calculations were missing ODCM required surveillances and potentially causing containment pressure to exceed Technical Specification limits. This malfunction happened previously in 2003. Backups are being performed on a weekly basis. A purchase requisition has been issued to establish an annual maintenance agreement with Computer Associates, the database support vendor.In addition, a request for funding new software has been approved for 2005.

A.C, E D ru 5 uI c-0i 27 of 40 2004 EFFLUENT CONCENTRATION LIMITS Nuclides H-3 Cr-51 Mn-54 Mn-56 Co-57 Co-58 Co-60 Sb-125 Sb-124 1-131 1-132 1-133 Ce-141 Cs-134 Cs-137 Nb-97.ýBa-13.9.Rb-88 Sn-i 17M Sb- 124 Kr-85 Kr-85M Kr-88 Xe-131M Xe- 133M Xe-133 Xe-135 Curies 1.06E+03 3.37E-05 3.87E-06 n/a 1.70E-05 5.47E-03 5.44E-04 1.24E-02 9.16E-06 2.52E-06 n/a n/a 2.35E-07 1.77E-05 1-.36E-04 n/a n/a n/a n/a n/a n/a n/a n/a n/a 4.32E-05 1.30E-02 3.64E-05 Average Diluted Concentration (gCi/ml)3.59E-06 1.14E-13 1.31E-14 n/a 5.76E- 14 1.85E-11 1.84E-12 4.20E-11 3.10E-14 8.53E-1 5 n/a n/a 7.96E-16 5.99E-14 4.60E-13 n/a n/a n/a n/a n/a n/a n/a n/a n/a 1.46E-13 4.40E-11 1.23E-13 10 CFR 20 ECL (klCi/mI)1.OOE-03 5.OOE-04 3.OOE-05 7.OOE-05 6.OOE-05 2.OOE-05 3.OOE-06 3.OOE-05 7.OOE-06 1.OOE-06 1.OOE-04 7.OOE-06 3.OOE-05 9.OOE-07 1.OOE-06 3.00&E04 2.0OE-04 4.00E-04 1.OOE-08 7.OOE-06 2.OOE-04 2.OOE-04 2.OOE-04 2.OOE-04 2.OOE-04 2.00E-04 2.OOE-04% of ECL 3.59E-01 2.28E-08 4.37E-08 n/a 9.60E-08 9.25E-05 6.13E-05 1.40E-04 4.43E-07 8.53E-07 n/a n/a 2.65E-09 6.66E-06 4.60E-05 n/a n/a n/a n/a n/a n/a n/a n/a n/a 7.30E-08 2.20E-05 6.15E-08 I 11 A.G E D j AI 2i G.28 of 40 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT 2004 SOLID WASTE SHIPMENTS A. SOLID RADWASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)1. Type of Waste a. Spent resins, filter sludges evaporator bottoms, etc.b. Dry compressible waste, contaminated equip. etc.c. Irradiated components, control rods, etc.: Unit m3*Ci m3*Ci m3*Ci 1- Year Period 3.37E+01 **9.85E+01 2.76E+02**

4.43E+00 O.OOE+00 0.OOE+00 Est. Total Error %2.50E+01 2.50E+01 2.50E+01 d. Other*m3 = cubic meters disposal.m3* 0.OOE+00 Ci 0.00E+00 2.50E+01 This is the volume sent offsite for volume reduction, prior to 2. Estimate of Major Nuclide Composition (by type of waste).(Nuclides listed with % abundance greater than 10 %0 a. Spent resin, filter sludges, evaporator bottoms, etc.Nuclide Name Fe-55 Co-58 Ni-63 Percent Abundance 25.733 10.083 47.900 Curies 2.68E+01 1.01 E+01 4.56E+01 b. Dry compressible waste, contaminated equipment, etc.Nuclide Name Fe-55 Co-58 Ni-63 Percent Abundance 58.081 12.997 15.644 Curies 2.54E+00 1.75E-01 7.60E-01 A.G E F G]C~29 of 40 c. Irradiated components, control rods, etc. -None d. Other-None

3. Solid Waste Disposition Number of Shipments 3 1 3 4 Mode of Transportation Truck (Hittman Transport Services)Truck (Hittman Transport Services)Truck (Hittman Transport Services)Truck (Interstate Freight)Truck (RACE Logistics, LLC)Truck (R&R Trucking)Destination Barnwell Waste Management Facility, Barnwell, SC Envirocare of Utah, Inc; Clive UT Studsvik Processing Facility, LLC;Columbia, SC RACE, LLC; Memphis, TN RACE, LLC; Memphis, TN RACE, LLC; Memphis, TN* 4. "Class of Solid Waste a. Class A, Class B, Class C- Corresponding to 2a b. Class A -Corresponding to 2b c. Not applicable
d. Not applicable
5. Type of Container a. LSA (Strong, tight), Type A, Type B -corresponding to 2a b. LSA (Strong, tight) -corresponding to 2b c. Not applicable
d. Not applicable
6. Solidification Agent a. Not applicable
b. Not applicable
c. Not applicable
d. Not applicable B. IRRADIATED FUEL SHIPMENTS (Disposition)

No irradiated fuel shipments occurred during the 2004 period.

I 30 of 40 A E O *SECTION III O! HOURS AT EACH WIND SPEED AND DIRECTION J/ , 0 4 This section documents WCGS meteorological data for wind speed, wind direction, and/ atmospheric stability.

2 o The meteorological data supplied in the following tables covers the period from January 1, 2004, 0 through December 31, 2004, and indicates the number of hours at each wind speed and direction for each stability class. All gaseous releases at the WCGS are ground level releases. (Wolf Creek Station did not meet Regulatory Guide 1.23 requirement for having at least 90%meteorological data recovery for 2004. As identified in PIR 2004-0620 problems with instrumentation or computer link were the cause of this problem and resulted in the replacement of the meteorological tower instruments.

A Meteorological Professor at the University of Kansas helped to establish the first set of criteria that is used to determine data availability and verification.

This verification takes a look at the required instruments on the tower and compares the instrument output (meteorological value)against one another and against a set of criteria for the particular parameter being measured.This method also flags data as bad anytime the communication link to the plant computer is down or the plant computer is down. This method is conservative and may flag data as bad even though the required Reg. Guide 1.23 instruments are still available.

Data availability using this method is 85.2%, for the year 2004.The Meteorological Tower Instruments were replaced in 2004 and the problem of unresponsive instruments and the computer being down have been greatly reduced. Since the new instruments were installed data availability has been meeting the 90% availability requirement.

The data availability for the Meteorological Data for the year 2004 as stated above is 85.2%. Part of the unavailability for the year 2004 came from the time that it took to replace the instruments that were causing the system downtime.

Wolf Creek Engineering change package 09882 updated the meteorological instrumentation (over 230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br />). It was recognized that the tower would be out of service while this replacement was ongoing and during this time back-up, hand instruments were available (if needed by the E-Plan) but these instruments are not credited for collection of meteorological data. It is expected that the meteorological tower data will be considerably more reliable from this point forward due to the installation of the replacement instrumentation and the fact that the key parameters have "back-up" instruments installed with the replacements.

I M 31 of 40 A G E D HOURS AT EACH WIND SPEED AND DIRECTION 0 r PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2004/ STABILITY CLASS: A 0 ELEVATION:

10 METERS WIND SPEED (mph)LWIND DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL 0 N 1.75 23.75 25.75 31.00 4.25 0.50 87.00 NNE 5.75 28.00. 25.25 9.00 1.00 0.00 69.00 NE 6.50 24.00 11.75 0.00 0.00 0.00 42.25 ENE 2.50 13.50 17.50 4.25 0.00 0.25 38.00 E 0.75 10.25 7.00 0.50 0.00 0.00 18.50 ESE 1.00 5.00 9.25 1.75 0.00 0.00 17.00 SE 0.75 6.25 14.75 4.50 0.00 0.00 26.25 SSE 2.25 19.25 31.00 23.50 0.25 0.00 76.25 S 3.00 16.25 47.50 57.50 17.75 0.50 142.50 SSW 2.25 13.25 15.50 13.75 3.25 0.00 48.00 SW 3.25 16.50 8.25 4.50 0.00 0.00 32.50 WSW 2.00 11.00 9.25 0.50 0.00 0.25 23.00 W 1.25 8.50 13.00 2.75 0.25 0.25 26.00 WNW 2.75 10.50 9.50 1.75 0.00 0.00 24.50 NW 1.75 7.25 12.25 7.00 0.00 0.50 28.75 NNW 1.50 12.50 22.75 18.50 2.75 0.00 58.00 TOTAL 37.25 225.75 280.25 180.75 29.50 2.25 757.50 PERIOD OF CALM (HOURS): 0.50 I M A G E D r 0 4/2 0 0 5 32 of 40 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2004 STABILITY CLASS: B ELEVATION:

10 METERS WIND WIND SPEED (mph)8-12 13-18 19-24 >24 TOTAL DIRECTION 1-3 N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW TOTAL 0.50 0.75 0.50 1.25 0.50 0.25 0.75 1.50 0.75 0.00 1.00 1.75 0.25 0.75 0.25 0.50 4-7 2.50 6.75 5.50 3.75 5.50 2.50 3.25 6.00 3.50 2.25 2.50 3.50 2.75 3.25 2.75 2.25 7.75 9.00 9.50 3.75 4.00 5.25 6.00 18.50 16.50 11.00 7.50 2.50 7.00 4.50 7.00 9.25 9.00 5.25 0.25 1.00 0.25 0.25 2.00 14.00 20.25 10.50 2.00 1.75 3.75 5.25 8.75 9.00 1.00 1.25 0.00 0.00 0.00 0.00 0.00 0.25 5.50 1.75 1.25 0.25 0.00 0.00 0.00 3.50 0.25 0.25 0.00 0.00 0.25 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 21.00 23.25 15.75 9.75 10.50 8.25 12.00 40.25 46.50 25.50 14.25 9.75 13.75 13.75 18.75 24.50 10.75 58.50 129.00 93.25 14.75 0.75 307.50 PERIOD OF CALM (HOURS): 0.25 M A G E D 0 5/'0 4/2 0 0 5 33 of 40 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2004 STABILITY CLASS: C ELEVATION:

10 METERS WIND DIRECTION 1-3 4-7 WIND SPEED (mph)8-12 13-18 19-24 >24 TOTAL N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW TOTAL 1.00 1.00 2.00 0.00 0.25 1.75 1.25 0.75 0.75 0.75 0.50 1.25 1.50 0.75 0.25 0.50 4.75 6.75 8.75 4.00 8.25 5.75 5.25 11.25 9.00 5.00 5.25 3.00 1.50 5.75 3.25 2.75 6.25 12.00 6.50 5.75 4.75 4.00 10.25 21.75 17.00 13.00 8.25 4.75 3.25 4.00 11.75 10.25 11.25 9.50 0.75 2.50 1.00 0.25 2.00 12.50 19.50 12.50 4.25 1.00 4.75 7.75 9.50 18.00 0.25 1.25 0.00 0.00 0.00 0.00 0.00 0.00 10.75 2.75 1.00 0.25 0.25 1.75 3.25 2.25 0.25 0.75 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.25 0.00 23.75 31.25 18.00 12.25 14.25 11.75 18.75 46.25 57.00 34.00 19.25 10.25 11.25 20.00 28.25 33.75 13.25 90.25 143.50 117.00 23.75 1.25 390.00 PERIOD OF CALM (HOURS): 0.00 34 of 40 0/0/2 0 a C'3 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2004 STABILITY CLASS: D ELEVATION:

10 METERS WIND DIRECTION N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW 1-3 WIND SPEED (mph)8-12 13-18 19-24 4-7 3.50 45.50 86.75 99.50 29.00 5.75 72.25 85.75 80.50 13.00 20.25 79.00 81.00 6.25 0.00 11.75 61.25 49.00 12.75 0.00 11.25 65.00 43.50 16.00 0.75 8.00 41.75 36.75 4.00 0.25 7.50 48.25 48.50 15.25 1.00 8.75 53.00 112.75 101.25 15.00 7.25 51.50 133.25 162.00 55.50 6.75 48.75 106.25 107.75 34.25 7.50 34.25 25.00 15.25 0.75 4.25 19.00 18.50 11.00 2.00 2.75 12.75 19.25 22.25 2.75 3.25 14.75 41.00 55.75 7.25 3.00 27.50 104.00 73.75 27.50 3.50 28.50 66.75 49.00 15.75>24 TOTAL 3.50 267.75 2.00 259.25 0.00 186.50 0.00 134.75 0.00 136.50 0.00 90.75 0.00 120.50 0.50 291.25 4.00 413.50 10.50 314.25 0.00 82.75 3.25 58.00 0.00 59.75 0.50 122.50 2.00 237.75 2.50 166.00 28.75 2941.75 TOTAL 111.50 703.00 1058.00 832.25 204.75 PERIOD OF CALM (HOURS): 0.00 I M A G E D 0/0/2 0 0 J 35 of 40 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2004 STABILITY CLASS: E ELEVATION:

10 METERS WIND SPEED (mph)WIND DIRECTION 1-3 N 5.25 NNE 10.75 NE 27.25 ENE 11.50 E 11.00 ESE 9.25 SE 6.00 SSE 6.75 S 4.00 SSW 8.75 SW 3.75 WSW 3.75 W 1.25 WNW 1.75 NW 3.75 NNW 2.00 4-7 8-12 13-18 19-24 >24 TOTAL 35.75 55.00 18.25 29.50 31.75 9.25.44.00 11.50 0.25 57.50 19.75 2.00 62.50 44.50 6.00 58.00 34.75 2.25 77.25 100.50 21.00 66.50 201.25 115.25 48.25 161.75 257.00 52.75 71.25 42.00 66.75 26.00 4.25 23.00 21.00 5.25 26.25 23.50 2.25 18.50 44.75 3.25 37.50 64.75 11.50 32.25 41.50 19.25 5.50 0.00 0.00 0.00 1.50 1.25 3.25 25.75 79.75 11.75 2.00 1.00 0.00 0.25 0.75 3.25 0.25 120.00 0.00 81.25 0.00 83.00 0.00 90.75.0.25 125.75 0.25 105.75 0.25 208.25 7.75 423.25 24.25 575.00 5.25 191.75 0.75 103.50 1.25 55.25 0.00 53.25 0.00 68.50 0.00 118.25 0.25 98.50 TOTAL 111.50 736.25 953.50 519.00 136.00 40.50 2502.00 PERIOD OF CALM (HOURS): 1.25 I M A G E 0/2 0 C J 36 of 40 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2004 STABILITY CLASS: F ELEVATION:

10 METERS WIND SPEED (mph)WIND DIRECTION N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW 1-3 2.50 6.50 17.00 9.00 5.25 12.50 7.00 1.00 3.25 5.00 7.50 3.50 2.25 3.75 5.00 4.50 4-7 8-12 13-18 19-24>24 TOTAL 25.00 42.25 40.75 45.00 38.25 67.25 88.75 40.50 19.00 17.00 22.25 7.00 5.25 8.25 24.25 26.25 14.00 6.50 1.75 2.50 10.00 7.75 29.25 46.50 15.75 4.50 2.25 3.00 0.75 1.75 6.00 9.75 0.00 1.00 0.00 0.00 0.00 0.25 0.75 6.75 9.25 2.00 0.00 0.25 0.00 0.25 0.50 0.50 0.00 0.00 0.00 0.00 0.00 0.00 0.50 0.50 3.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.50 0.00 0.00 0.00 0.00 0.00 0.00 0.00 41.50 56.25 59.50 56.50 53.50 87.75 126.25 95.25 50.75 28.50 32.00 13.75 8.25 14.00 35.75 41.00 TOTAL 93.00 517.00 162.00 21.50 4.00 0.50 800.50 PERIOD OF CALM (HOURS): 0.50 M A G E D 0 5/0/2 0 5 37 of 40 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2004 STABILITY CLASS: G ELEVATION:

10 METERS WIND DIRECTION 1-3 WIND SPEED (mph)4-7 8-12 13-18 19-24 >24 TOTAL N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW TOTAL 4.00 4.75 22.25 12.75 8.25 10.25 4.75 2.00 1.25 1.50 2.50 0.50 0.50 3.25 5.75 5.50 35.00 87.00 43.50 42.50 34.25 50.00 50.75 21.25 6.50 0.75 3.50 2.75 0.50 1.50 17.25 29.75 12.50 7.75 0.25 0.50 1.25 3.00 2.25 6.75 8.25 0.25 0.00 0.00 0.00 0.00 2.25 2.50 0.50 0.00 0.25 0.25 0.00 0.25 0.00 0.50 0.75 0.25 0.00 0.25 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.25 0.75 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.25 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 52.00 99.50 66.25 56.00 43.75 63.50 59.25 31.25 16.75 2.75 6.00 3.50 1.00 4.75 25.25 37.75 85.75 426.75 47.50 ' 3.00 2.00 0.25 569.25 PERIOD OF CALM (HOURS): 0.00 I 38 of 40 A C E O HOURS AT EACH WIND SPEED AND DIRECTION O PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31,2004 STABILITY CLASS: ALL/ ELEVATION:

10 METERS WIND SPEED (mph)2 WIND o DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 18.50 172.25 208.00 169.50 40.00 4.75 613.00 5 NNE 35.25 272.50 178.00 114.50 16.50 3.00 619.75 NE 95.75 245.50 122.25 7.75 0.00 0.00 471.25 ENE 48.75 227.50 98.75 22.75 0.00 0.25 398.00 E 37.25 224.00 115.00 23.75 2.25 0.50 402.75 ESE 43.00 230.25 100.75 9.00 1.50 0.25 384.75 SE 28.00 279.75 211.50 45.50 6.00 0.50 571.25 SSE 23.00 217.75 438.50 273.75 42.50 8.25 1003.75 S 20.25 154.00 400.00 526.25 172.25 29.25 1302.00 SSW 25.00 139.75 221.75 188.75 53.75 15.75 644.75 SW 26.00 151.00 77.25 30.25 5.00 0.75 290.25 WSW 17.00 69.25 59.00 20.00 3.50 4.75 173.50 W 9.75 57.50 66.75 35.75 3.25 0.25 173.25 WNW 16.25 62.50 105.50 74.00 9.25 0.50 268.00 NW 19.75 119.75 208.00 111.00 31.50 2.75 492.75 NNW 18.00 134.25 162.75 114.25 27.50 2.75 459.50 TOTAL 481.50 2757.50 2773.75 1766.75 414.75 74.25 8268.50 Hours of Calm (<1.0 Hours of Hours of mph):2.50 Missing Bad Data: Data: 513 785 I II 39 of 40 G SECTION IV O ADDITIONAL INFORMATION 5/ 1. Unplanned or Abnormal Releases 0 4 There were no unplanned or abnormal releases that occurred in 2004./2. Offsite Dose Calculation Manual (ODCM)o The ODCM is in the form of two separate Wolf Creek Nuclear Operating Corporation (WCNOC)5 administrative procedures.

One of these procedures, the WCNOC "Offsite Dose Calculation Manual", AP 07B-003, Revision 5, is included with this report as Attachment I. The other procedure, "Offsite Dose Calculation Manual (Radiological Environmental Monitoring Program), AP 07B-004, Revision 8, is included with this report as Attachment I1.3. Major Changes to Liquid, Solid, or Gaseous Radioactive Waste Treatment Systems Temporary Modification 04-002HB is in the design process as a result of CCP 9337 modifications.

Previous changes to the Zero Filtration System in Radwaste resulted in possible line overpressure problems to the Drum Dryer, as well as drain problems from the sample sink.After further testing, it was determined that over pressurization was not a problem; however, changes are being made to allow for the use of a TMP that will throttle flow to the Drum Dryer Holdup Tank to monitor the system pressure.

To address the drain problems from the sample sink, a new vent line will be installed to the SRO (Spiral Reverse Osmosis unit) so that the SRO sample line will no longer be used as a continuous process vent. This should improve the functioning of the sample sink drain by reducing the flow into the sink.4. Land Use Census No new locations for dose calculation were identified during this report period.5. Radwaste Shipments Twelve shipments of radioactive waste occurred during this report period.Section II, Subsection 3, of this report contains specific details regarding each shipment's mode of transportation and destination.

6. Inoperability of Effluent Monitoring Instrumentation No events occurred that violated ODCM Requirements Tables 2-2 and 3-2, liquid or gaseous effluent monitoring instrumentation.
7. Storage Tanks At no time during the year 2004 was there an event that lead to liquid holdup tanks or gas storage tanks exceeding the limits of Technical Requirements Manual Sections 3.10.1 or 3.10.3.Technical Specification requirements for the program are now covered by Technical Requirements Manual Section 3.10, "Explosive Gas and Storage Tank Radioactivity Monitoring." a W(LF CREEK'NUCLEAR OPERATING CORPORATION 0/Kevin J. Moles 8 Manager Regulatory Affairs April 27, 2006/,2 O RA 06-0067 0'6 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482: Wolf Creek Generating Station Annual Radioactive Effluent Release Report -Report 29 Gentlemen:

This letter transmits the enclosed Wolf Creek Generating Station (WCGS) Annual Radioactive Effluent Release Report. The report covers the period from January 1, 2005, through December 31, 2005. It is being submitted pursuant to Section 5.6.3 of the WCGS Technical Specifications.

Included as part of the report are copies of revised procedures required to be submitted with this report. Procedures AP 07B-003, "Offsite Dose Calculation Manual," AP 07B-004, "Offsite Dose Calculation Manual (Radiological Environmental Monitoring Program)," and AP 31A-100, "Solid Radwaste Process Control Program." are included as Attachments 1, 11, and III to the report.No commitments are identified in this correspondence.

If you have any questions concerning this matter, please contact me at (620) 364-4126, or Ms. Diane Hooper at (620) 364-4041.Sincerely, Kevin J. Mol KJM/rlt Enclosure cc: J. N. Donohew (NRC), w/e W. B. Jones (NRC), w/e B. S. Mallett (NRC), w/e Senior Resident Inspector (NRC), w/e P.O. Box 411 'Burlington.

KS 66839 / Phone: (620) 364-8831 An Equal Oppor!unity Employer M,F "CNVET I M A D 0 4/2 Wolf Creek Nuclear Operating Corporation 2 0 0 Wolf Creek Generating Station 6 Docket No: 50-482 Facility Operating License No: NPF-42 Annual Radioactive Effluent Release Report Report No. 29 Reporting Period: January 1,2005 -December 31, 2005 I A 2 of36 V Table of Contents Paaqe 4/ Executive Summary 4 Section 1 ,6 8 Report of 2005 Radioactive Effluents:

Liquid 6 2005 Liquid Effluents 8 2005 Liquid Cumulative Dose Summary -Table 1 10 U 2005 Liquid Cumulative Dose Summary -Table 2 11 , Report of 2005 Radioactive Effluents:

Airborne 12 b 2005 Gaseous Effluents 14 2005 Gaseous Cumulative Dose Summary -.Table 1 16 2005 Gaseous Cumulative Dose Summary -Table 2 17 Section II 18 Offsite Dose Calculation Manual Limits 18 Effluent Concentration Limits (ECLs) 18 Average Energy 19 Measurements and Approximations of Total Radioactivity (Liquid and 19 Gaseous Effluents)

Batch Releases 21 Continuous Releases 21 Doses to a Member of the Public from Activities Inside the Site Boundary 21 Additional Information 22 2005 Effluent Concentration Limits 23 2005 Solid Waste Shipments 24 Irradiated Fuel Shipments 25 Section III 26 Meteorological Data -Hours At Each Wind Speed and Direction 26 Section IV 35 Unplanned or Abnormal Releases 35 Off site Dose Calculation Manual 35 Major Changes to Liquid, Solid, or Gaseous Radioactive Waste Treatment Systems 35 Land Use Census 35 Radwaste Shipments 35 Inoperability of Effluent Monitoring Instrumentation 35 Storage Tanks 35 Attachments 36 I 3 of 36 D Table of Contents A Attachment I -WCGS Procedure AP 07B-003, Revision 5, "Offsite Dose Calculation Manual"/ Attachment II -WCGS Procedure AP 07B-004, Revision 10, "Offsite Dose Calculation Manual (Radiological Environmental Monitoring Program)" 8 Attachment III -WCGS Procedure AP 31A-100, Revision 5, "Solid Radwaste Process Control/ Program" 0 6 I 4 of 36 b E EXECUTIVE

SUMMARY

0 4 This Annual Radioactive Effluent Release Report (Report # 29) documents the quantities of liquid and gaseous effluents and solid waste released by Wolf Creek Generating Station (WCGS) from January 1, 2005 through December 31, 2005. The format and content of this report are in accordance with Regulatory Guide 1.21, Revision 1, "Measuring, Evaluation, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants.! Sections I, II, Ill, and IV of this report 19 provide information required by NRC Regulatory Guide 1.21 and Section 7.2 of AP 07B-003, o "Offsite Dose Calculation Manual" (ODCM).6 Section I --- Section I contains, in detail, the quantities of radioactive liquid and gaseous effluents and cumulative dose summaries for 2005, tabulated for each quarter and for yearly totals.Specific ODCM effluent limits and dose limits are also listed in Section I, along with the percentage of the effluent limits actually released and the percentages of the dose limit actually received.

No effluent or dose limits were exceeded during 2005.An elevated release pathway does not exist at WCGS. All airborne releases are considered to be ground level releases.

The gaseous pathway dose determination is met by the WCGS ODCM methodology of assigning all gaseous pathways to a hypothetical individual residing :at the highest annual X/Q and D/Q location, as specified in the ODCM. This results in a conservative estimate of dose to a member of the public, rather than determining each pathway dose: for each release condition.

A conservative error of thirty percent has been estimated in the effluent data..As stated above, no ODCM dose limits were exceeded in 2005.Section II --- Section II includes supplemental information on continuous and batch releases, calculated doses, and solid waste disposal.

There were 72 gaseous batch releases in 2005 versus 67 in 2004. There were 62 liquid batch releases in 2005 versus 58 in 2004. WCGS released 0.014 curies in liquid releases during 2005 versus 0.019 cures in 2004, excluding gas and tritium. Continuous release pathways remained the same as previous years and all continuous releases were monitored.

The report contains information on the following Performance Improvement Request (PIR): PIR 2005-1836

-While performing a Volume Control Tank (VCT) purge to Gas Decay Tank #3 (GDT), a leak was identified on a moisture separator pressure switch (HAPS1035B).

The leak resulted in an unplanned, monitored release.Section III --- Section III documents WCGS meteorological data for wind speed, wind direction, and atmospheric stability.

Section IV -Section IV documents unplanned and abnormal releases, changes to radwaste treatment systems, land use census, monitoring instruments, radwaste shipments, and storage tank quantities.

There was one unplanned, monitored release in 2005.No changes to events occurred on the land use census, monitoring instruments, radwaste shipments, and storage units.

I A 5 of 36 G E D ATTACHMENTS Attachment I -AP 071-003, revision 5, "Offsite Dose Calculation Manual" Attachment I1 -AP 078-004, revision 10, "Offsite Dose Calculation Manual (Radiological Environmental Monitoring Program)"/ Attachment III -AP 31A-100, revision 5, "Solid Radwaste Process Control Program"/2 0 6 I A 6 of 36.E p SECTION I 0$ REPORT OF 2005 RADIOACTIVE EFFLUENTS:

LIQUID/Unit Quarter 1 Quarter 2 A. Fission and Activation Products 1. Total Release (not including tritium, gases, Ci 2.08E-03 9.92E-03 alpha)2. Average Diluted Concentration During VCi/ml 2.65E-1 1 1.09E-10Period 3. Percent of Applicable Limit (1) % 4.16E-02 1.98E-01 B. Tritium 1. Total Release Ci 3.20E+02 1.26E+02 2. Average Diluted Concentration During gCi/ml 4.07E-06 1.39E-06 Period 3. Percent of Applicable Limit (2) (ECL) % 4.07E-01 1.39E-01 C. Dissolved and Entrained Gases 1. Total Release Ci 2.35E-02 1.OOE-02 2. Average Diluted Concentration During ACi/ml 2.99E-10 1.10E-10 Period 3. Percent of Applicable Limit (3) % 1.49E-04 5.50E-05 D. Gross Alpha Radioactivity

1. Total Release Ci 0.OOE+00 0.00E+00 E. Volume of Waste Released (prior to Liters 1.14E+08 9.52E+07 dilution)F. Volume of Dilution Water Used Liters 7.85E+10 9.08E+10 NOTES: 1) The applicable limit for the WCGS is 5 Curies per year. (Reference 10 CFR 50, Appendix I, "Guides On Design Objectives For Light-Water Cooled Nuclear Power Reactors," Paragraph A.2.) The value is derived by dividing the total release Curies by 5 Curies and then multiplying the result by 100.2) This value is derived by the following formula:% of Applicable Limit = (Average Diluted Concentration)

(100)(MPC or ECL, Appendix B, Table 2 1OCFR20)3) This value is derived by the following formula:% of Applicable Limit = (Average Diluted Concentration)

(100)(2E -04 from ODCM Section 2.1)

I N E D 0 4/2 0.0 b^7 of 36 REPORT OF 2005 RADIO?A. Fission and Activation Products 1. Total Release (not including tritium, gases, alpha 2. Average Diluted Concentration During Period 3. Percent of Applicable Limit (1)B. Tritium 1. Total Release 2. Average Diluted Concentration During Period 3. Percent of Applicable Limit (2) (ECL)C. Dissolved and Entrained Gases 1. Total Release 2. Average Diluted Concentration During Period 3. Percent of Applicable Limit (3)D. Gross Alpha Radioactivity

1. Total Release E. Volume of Waste Released (prior to dilution)CTIVE EFFLUENTS:

LIQUID Unit Quarter 3 Ci 1.64E-03 Rui/ml 1.18E-11.% 3.27E-02 Ci Ci VICi/ml 1.95E+01 1.41 E-07 1.41 E-02 0.OOE+00 0.00E+00 0.OOE+00 0.OOE+00 1.34E+08 Quarter 4 8.1 OE-04 8.23E-12 1.62E-02 3.62E+01 3.68E-07 3.68E-02 0.00E+00 0.OOE+00 0.OOE+00 4.35E-06 8.40E+07 Ci liters F. Volume of Dilution Water Used liters 1.38E+11 9.84E+10 NOTES: 1) The applicable limit for the WCGS is 5 Curies per year. (Reference 10 CFR 50, Appendix I, "Guides On Design Objectives For Light-Water Cooled Nuclear Power Reactors," Paragraph A.2.) The value is derived by dividing the total release Curies by 5 Curies and then multiplying the result by 100.2) This value is derived by the following formula: (Average Diluted Concentration)

(100)(MPC or ECL, Appendix B, Table 2,1 OCFR20)3) This value is derived by the following formula: (Average Diluted Concentration)

(100)% of Applicable Limit =(2E -04 from ODCM Section 2.1)

I A 8 of 36 G E) 2005 LIQUID EFFLUENTS 0 Continuous Mode Batch Mode 4 Nuclides Unit Quarter I Quarter 2 Quarter 1 Quarter 2 Released 1H-3 Ci 1.66E+00 3.71 E+01 3.18E+02 8.90E+01 Cr-51 Ci N/A N/A N/A 9.98E-04 Mn-54 Ci <5.68E-02

<6.69E-02 2.28E-06 <5.30E-04 Fe-55 Ci <1.14E-01

<1.34E-01

<8.81E-04

<1.06E-03 Fe-59 Ci <5.68E-02

<6.69E-02

<4.41 E-04 <5.30E-04 Co-57 Ci N/A N/A N/A 1.04E-05 6 Co-58 Ci <5.68E-02

<6.69E-02 2.73E-05 2.53E-03 Co-60 Ci <5.68E-02

<6.69E-02 4.68E-05 2.35E-04 Zn-65 Ci <5.68E-02

<6.69E-02

<4.41 E-04 <5.30E-04 Sr-89 Ci <5.68E-03 46.69E-03

<4.41 E-05 <5.30E-05 Sr-90 Ci <5.68E-03

<6.69E-03

<4.41E-05

<5.30E-05 Mo-99 Ci <5.68E-02

<6.69E-02

<4.41E-04

<5.30E-04 Sb-124 Ci N/A N/A <4.41 E-04 4.21 E-04 Sb-125 Ci N/A N/A 1.OOE-03 5.46E-03 1-131 Ci <1.14E-01

<1.34E-01 5.24E-04 3.92E-05 I1-133 Ci N/A N/A 2.76E-04 1.47E-05 Cs-134 Ci <5.68E-02

<6.69E-02 2.52E-06 5.69E-06 Cs-137 Ci <5.68E-02

<6.69E-02 8.68E-05 1.25E-04 Ce-141 Ci <5.68E-02

<6.69E-02

<4.41 E-04 <5.30E-04 Ce-144 Ci <5.68E-02

<6.69E-02

<4.41E-04 k5.30E-04 Na-24 Ci N/A N/A N/A 1.16E-06 Rb-88 Ci N/A N/A 2.68E-05 N/A Nb-95 Ci N/A N/A N/A 3.77E-06 Tc-99M Ci N/A N/A 3.64E-05 1.88E-05 Sb-122 Ci N/A N/A N/A 1.04E-05 Sb-126 Ci N/A N/A N/A 3.77E-05 1-135 Ci N/A N/A 5.05E-05 N/A Gross Alpha Ci <1.14E-02

<1.34E-02

<8.81E-05

<1.06E-04 Ar-41 Ci <1.14E+00

<1.34E+00 1.40E-05 <1.06E-02 Kr-85M Ci <1.14E+00

<1.34E+00 3.20E-05 1.11E-05 Kr-85 Ci <1.14E+00

<1.34E+00

<8.81E-03

<1.06E-02 Kr-87 Ci <1.14E+00

<1.34E+00

<8.81E-03

<1.06E-02 Kr-88 Ci <1.14E+00

<1.34E+00 1.99E-05 <1.06E-02 Xe-131M Ci <1.14E+00

<1.34E+00

<8.81E-03

<1.06E-02 Xe-133M Ci < 1.14E+00 <1.34E+00 2.80E-04 1.76E-04 Xe-133 Ci <1.14E+00

<1.34E+00 2.06E-02 8.53E-03 Xe-135M Ci <1.14E+00

<1.34E+00

<8.81E-03

<1.06E-02 Xe-135 Ci <1.14E+00

<1.34EE+00 2.53E-03 1.28E-03 NOTE"Less than" values are calculated using the Lower Limit of Detection (LLD) values listed in Table 2-1 of the ODCM multiplied by the volume of waste discharged during the respective quarter. The "less than" values are not included in the summation for the total release values.

I, 9 9of 36 E 2005 LIQUID EFFLUENTS O Continuous Mode Batch Mode 4 Nuclides Unit Quarter 3 Quarter 4 Quarter 3 Quarter 4/ Released 2 8 H-3 Ci 1.53E+00 1.30E+00 1.79E+01 3.49E+01/ Cr-51 Ci N/A N/A N/A N/A Mn-54 Ci <6.69E-02

<4.19E-02 5.63E-06 <1.46E-04 2 Fe-55 Ci <1.34E-01

<8.37E-02

<3.03E-04

<2.92E-04 Fe-59 Ci <6.69E-02

<4.19E-02 1.56E-04 <1.46E-04 U Co-57 Ci N/A N/A N/A N/A 6 Co-58 Ci <6.69E-02

<4.19E-02 1.79E-04 4.36E-05 Co-60 Ci <6.69E-02

<4.19E-02 3.38E-05 2.91E-05 Zn-65 Ci <6.69E-02

<4.19E-02 2.44E-06 <1.46E-04 Sr-89 Cl <6.69E-03

<4.19E-03

<1.52E-05

<1.46E-05 Sr-90 Ci <6.69E-03

<4.19E-03

<1.52E-05

<1.46E-05 Mo-99 Ci <6.69E-02

<4.19E-02

<1.52E-04

<1.46E-04 Sb-124 Ci N/A N/A 1.17E-05 N/A Sb-125 Cl N/A N/A 1.37E-03 4.85E-04 1-131 Ci <1.34e-01

<8.37E-02

<3.03E-04

<2.92E-04 1-135 Ci N/A N/A N/A 4.41 E-07 Cs-134 Ci <6.69E-02

<4.19E-02 2.20E-06 5.88E-06 Cs-137 Ci <6.69E-02

<4.19E-02 2.50E-05 6.40E-05 Ce-141 Ci <6.69E-02

<4.19E-02

<1.52E-04

<1.46E-04 Ce-144 Ci <6.69E-02

<4.19E-02

<1.52E-04

<1.46E-04 Sr-91 Ci N/A N/A 3.73E-06 2.28E-06 Nb-95 Ci N/A N/A N/A 1.35E-07 W-187 Ci N/A N/A N/A 1.80E-04 Gross Alpha Ci <1.34E-02

<8.37E-03

<3.03E-05 4.35E-06 Ar-41 Ci <1.34E+00

<8.37E-01

<3.03E-03

<2.92E-03 Kr-85M Ci <1.34E+00

<8.37E-01

<3.03E-03

<2.92E-03 Kr-85 Cl <1.34E+00

<8.37E-01

<3.03E-03

<2.92E-03 Kr-87 Ci <1.34E+00

<8.37E-01

<3.03E-03

<2.92E-03 Kr-88 Ci <1.34E+00

<8.37E-01

<3.03E-03

<2.92E-03 Xe-1i31M Ci <1.34E+00

<8.37E-01

<3.03E-03

<2.92E-03 Xe-1i33M Ci <1.34E+00

<8.37E-01

<3.03E-03

<2.92E-03 Xe-133 Ci <1.34E+00

<8.37E-01

<3.03E-03

<2.92E-03 Xe-135M Ci <1.34E+00

<8.37E-01

<3.03E-03

<2.92E-03 Xe-135 Ci <1.34E+00

<8.37E-01

<3.03E-03

<2M92E-03 NOTE" "Less than" values are calculated using the Lower Limit of Detection (LLD) values listed in Table 2-1 of the ODCM multiplied by the volume of waste discharged during the respective quarter. The "less than" values are not included in the summation for the total release values.

I M A G.E D 6 4//2 0 6 10 of 36 LIOUID CUMULATIVE DOSE

SUMMARY

(2005) TABLE 1 QUARTER 1 OF 2005 (mrem)TOTAL DOSE TOTAL DOSE TOTAL. DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE FOR BONE FOR LIVER FOR TOTAL BODY FOR THYROID FOR KIDNEY FOR LUNG FOR GI-LLI ODCM CALCULATED DOSE 4.56E-04 6.04E-02 6.02E-02 6.16E-02 6.OOE-02 5.99E-02 5.98E-02 1.32E-02 2.17E-01 2.11E-01 2.02E-01 2.05E-01 2.01E-01 2.08E-01 ODCM LIMIT(l)5.OOE+00 5.OOE+00 1.50E+00 5.OOE+00 5.OOE+00 5.00E+00 5.OOE+00 5.00E+00 5.OOE+00 1.50E+O0 5.OOE+00 5.OOE+0O 5.OOE+00 5.00E+00 QUARTER 2 OF 2005 (mrem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI QUARTER 3 OF 2005 (mrem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI QUARTER 4 OF 2005 (mreom)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI TOTALS FOR 2005 (mrem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI 8.80E-05 2.24E-02 2.23E-02 2.22E-02 2.23E-02 2.23E-02 2.23E-02 2.22E-04 5.77E-03 5.66E-03 5.45E-03 5.56E-03 5.49E-03 5.59E-03 1.40E-02 3.05E-01 2.99E-01 2.91 E-01 2.93E-01 2.89E-01 2.96E-01 5.00E+00 5.OOE+00 1.50E+00 5.00E+00 5.OOE+00 5.00E+00 5.OOE+O0 5.OOE+00 5.OOE+00 1.50E+00 5.00E+00 5.OOE+00 5.00E+00 5.00E+00 1.00E+01 1 .00E+01 3.OOE+00 1.00E+01 1 .00E+01 1.00E+01 1.OOE+01% OF LIMIT 9.12E-03 1.21 E+00 4.01 E+00 1.23E+00 1.20E+00 1.20E+00 1.20E+00 2.65E-01 4.34E+00 1.41 E+01 4.04E+00 4.1 OE+O0 4.02E+00 4.17E+00 1.76E-03 4.47E-O1 1.49E+00 4.45E-01 4.46E-01 4.45E-01 4.45E-01 4.45E-03 1.15E-01 3.78E-01 1.09E-01 1.11E-01 1.10E-01 1.12E-01 1.40E-01 3.05E+00 9.97E+00 2.91 E+00 2.93E+00 2.89E+00 2.96E+00 1. Based on ODCM Section 2.2, which restricts dose to the whole body to < 1.5 mRem per quarter and 3.0 mRem per year. Dose restriction of any organ is < 5.0 mRem per quarter and 10.0 mRem per year.

I I of 36 G E D LIQUID CUMULATIVE DOSE

SUMMARY

(2005) TABLE 2 4 A. Fission and Activation Quarter 1 Quarter 2 Quarter 3 Quarter 4 Total/1 Products (not including H-3, gases, alpha)0/ 1. Total Release -(Ci) 2.08E-03 9.92E-03 1.63E-03 8.10E-04 1.44E-02 2 2. Maximum Organ Dose (mRem) 1.79E-03 1.79E-02 1.25E-04 3.18E-04 1.90E-02 O 3. Organ Dose Limit (mRem) 5.00E+00 5.OOE+00 5.OOE+00 5.00E+00 1.00E+01 o 4. Percent of Limit 3.59E-02 3.58E-01 2.50E-03 6.36E-03 1.90E-01 6 B. Tritium 1. Total Release -(Ci) 3.20E+02 1.26E+02 1.95E+01 3.62E+01 5.02E+02 2. Maximum Organ Dose (mRem) 5.98E-02 1.99E-01 2.22E-02 5.45E-03 2.86E-01 3. Organ Dose Limit (mRem) 5.OOE+00 5.OOE+00 5.OOE+00 5.OOE+00 1.00E+01*4. Percent of Limit 1.20E+00 3.98E+00 4.45E-01 1.09E-01 2.86E+00 This table is included to show the correlation between Curies released and the associated calculated maximum organ dose. Wolf Creek ODCM methodology is used to calculate the maximum organ dose that assumes that an individual drinks the water and eats the fish from the discharge point. ODCM Section 2.2 organ dose limits are used. The less than values are not included in the summation for the total release values.

I H A 12 of 36 G.E D REPORT OF 2005 RADIOACTIVE EFFLUENTS:

AIRBORNE o Quarter Quarter 4 Unit 1 2/ A. Fission and Activation Gases 2 1. Total Release Ci 3.53E-01 6.02E-01/-2. Average Release Rate for Period pCi/sec 4.54E-02 7.65E-02 2 3. Percent of ODCM Limit (1) % 4.16E-03 3.76E-03 o B. Iodine 1. Total Release Ci 0.OOE+00 O.OOE+00 2. Average Release Rate for Period jpCi/sec 0.OOE+00 O.OOE+00 3. Percent of Applicable Limit (2) % 0.OOE+00 0.OOE+00 C. Particulates

1. Particulates with Half-lives

> 8 days Ci 0.00E+40 0.OOE+00 2. Average Release Rate for Period PCi/sec 0.OOE+00 0.OOE+O0 3. Percent of ODCM Limit (3) % 0.OOE+00 O.OOE+O0 4. Gross Alpha Radioactivity Ci O.OOE+00 O.OOE+00 D. Tritium 1. Total Release Cl 2.76E+00 1.43E+01 2. Average Release Rate for Period pCi/sec 3.55E-01 1.82E+00 3. Percent of ODCM Limit (4) % 2.66E-02 1.41 E-01 NOTES: 1) The percent of ODCM limit for fission and activation gases is calculated using the following methodology:.

% of ODCM Limit (Qtrly Total Beta Airdose)(100) or (Qtrly Total Gamma Airdose)(100) 10 mrad 5 mrad The largest value calculated between Gamma and Beta air dose is listed as the % of ODCM Limit.2) The percent of ODCM limit for iodine is calculated using the following methodology:

% of ODCM Limit = (Total Curies of Iodine -131)(100)

I Curie 3) The percent of ODCM limit for particulates is calculated using the following methodology:.

%of ODCM Limit = (Highest Organ Dose Due to Particulates)(100) 7.5 mrem This type of methodology is used since the Wolf Creek ties release limits to doses rather than curie release rates.4) The percent of ODCM limit for tritium is calculated using the following methodology:

% of ODCM Limit = (Highest Organ. Dose Due to H -3)(100)7.5 mrem I.13 of 36 6 E D REPORT OF 2005 RADIOACTIVE EFFLUENTS:

AIRBORNE O Quarter Quarter 4Unit 3 4/ A. Fission and Activation Gases 2 1. Total Release Ci 1.78E-01 3.98E-01 2. Average Release Rate for Period piCi/sec 2.23E-02 5.00E-02 3. Percent of ODCM Limit (1) % 2.16E-03 3.31E-03 0 B. lodines 0 6 1. Total Iodine-131 Ci 0.OOE+00 0.OOE+00 2. Average Release Rate for Period ipCi/sec 0.OOE+00 O.OOE+00 3. Percent of Applicable Limit (2) % 0.00E+00 0.OOE+00 C. Particulates

1. Particulates with Half-lives

> 8 days Cl O.OOE+00 0.OOE+00 2. Average Release Rate for Period f.Ci/sec 0.OOE+00 O.OOE+00 3. Percent of ODCM Limit (3) % O.OOE+00 0.OOE+00 4. Gross Alpha Radioactivity Ci O.OOE+00 O.OOE+00 D. Tritium 1. Total Release Ci 1.39E+01 1.30E+01 2. Average Release Rate for Period pCi/sec 1.75E+00 1.64E+00 3. Percent of ODCM Limit (4) % 1.37E-01 1.10E-01 NOTES: 1) The percent of ODCM limit for fission and activation gases is calculated using the following methodology:

% of ODCM Limit = (Qtrly Total Beta Airdose)(100)or (Qtrly Total Gamma Airdose)(100) 10 mrad 5 mrad The largest value calculated between Gamma and Beta air dose is listed as the % of ODCM Limit.2) The percent of ODCM limit for iodine is calculated using the following methodology.(Total Curies of Iodine-131)(l00)

% of ODCM Limit =I Curie 3) The percent of ODCM limit for particulates is calculated using the following methodology:

% of ODCM Limit = (Highest Organ Dose Due to Particulates)(100) 7.5 mrem This type of methodology is used since the Wolf Creek ODCM ties release limits to doses rather than curie release rates.4) The percent of ODCM limit for tritium is calculated using the following methodology.

% of ODCM Limit = (Highest Organ Dose Due to H -3)(100)7.5 mrem I 14 of36 G E 2005 GASEOUS EFFLUENTS Continuous Mode Batch Mode Nuclides Released Unit Quarter 1 Quarter 2 Quarter 1 Quarter 2 1. Fission and Activiation Gases Ar-41 Ci N/A N/A 3.21 E-01 2.74E-01 Kr-85 Ci N/A N/A 2.86E-02 4.07E-02 Kr-85M Ci N/A N/A N/A 5.05E-05' Kr-87 Ci <1.35E+01

<1.41E+01

<1.88E-02 1.12E-04 0 Kr-88 Ci <1.09E+01

<1.13E+01

<11.51E-02 1.43E-04 6 Xe-131M Ci N/A N/A 5.98E-05 1.26E-03 Xe-133 Ci <4.34E+00

<4.51E+00 3.73E-03 2.75E-01 Xe-1 33M Ci <1.44E+01

<1.49E+01 2.36E-05 3.91 E-03 Xe-135 Ci <1.54E+00

<1.60E+00

<3.66E-03 1.13E-03 Xe-1 35M Ci N/A N/A N/A 1.62E-04 Xe-138 Ci <1.63E+03

<1.69E+03

<2.25E+00 3.13E-04 Total Ci 0.00E+00 0.OOE+00 3.53E-01 6.01 E-01 2. Halogens (Gaseous)1-131 Ci <2.58E-04

<2.68E-04

<3.58E-07

<1 .70E-05 1-133 Ci <2.58E-02

<2.68E-02

<3.58E-05

<1.70E-03 Total Ci 0.OOE+00 O.OOE+00 0.OOE+00 , .00E+00 3. Particulates and Tritium H-3 Ci 2.59E+00 9.66E+00 1.68E-01 4.65E+00 Mn-54 Ci <2.58E-03

<2.68E-03

<3.58E-06

<1.70E-04 Fe-59 Ci <2.58E-03

<2.68E-03

<3.58E-06

<1.70E-04 Co-58 Ci <2.58E-03

<2.68E-03

<3.58E-06

<1.70E-04 Co-60 Ci <2.58E-03

<2.68E-03.

<3.58E-06

<1 .70E-04 Zn-65 Ci <2.58E-03

<2.68E-03

<3.58E-06

<1 .70E-04 Mo-99 Ci <2.58E&03

<2.68E-03

<3.58E-06

<1.70E-04 Cs-134 Ci <2.58E-03

<2.68E-03

<3.58E-06

<1.70E-04 Cs-137 Ci <2.58E-03

<2.68E-03

<3.58E-06

<1.70E-04 Ce-141 Ci <2.58E-03

<2.68E-03

<3.58E-06

<1.70E-04 Ce-144 Ci <2.58E-03

<2.68E-03

<3.58E-06

<1.70E-04 Sr-89 Ci <2.58E-03

<2.68E-03

<3.58E-06

<1.70E-04 Sr-90 Ci <2.58E-03

<2.68E-03

<3.58E-06

<1.70E-04 Gross Alpha Ci <2.58E-03

<2.68E-03

<3.58E-06

<1.70E-04 Total Ci 2.59E+00 9.66E+00 1.68E-01 4.65E+00 NOTE"Less than" values for Noble Gases are calculated using the Lower Limit of Detection (LLD) values obtained at Wolf Creek Generating Station multiplied by the volume of air discharged during the respective quarter.For the Halogens and Particulates the ODCM LLD values are used.

I H A 15 of 36 2005 GASEOUS EFFLUENTS 4 Continuous Mode Batch Mode Nuclides Released Unit Quarter 3 Quarter 4 Quarter 3 Quarter 4 2 1. Fission and Activiation 8 * .Gases G Ar-41 Ci N/A N/A 1 .66E-01 2.18E-01 Kr-85 Ci N/A N/A 5.90E-03 N/A Kr-85M Ci N/A N/A N/A N/A Kr-87 Ci <1.40E+01

<1.39E+01

<1.01 E-02 <1.16E-02 U Kr-88 Ci <1.13E+01

-1.12E+01

<8.16E-03

<9.37E-03 6 Xe-131M Ci N/A N/A N/A N/A Xe-133 Ci <4.50E+00

<4.45E+00 5.26E-03 <3.72E-03 Xe-133M Ci <1.49E+01

<1.47E+01 6.64E-05 <1.23E-02 Xe-135 Ci <1:59E+00 1.80E-01 2.61E-05 <1.32E-03 Xe-138 Ci <1.68E+03

<1.67E+03

<1.22E+00

<1.40E+00 Total Ci 0.OOE+00 1.80E-01 1.78E-01 2.18E-01 2. Halogens (Gaseous)1-131 Ci <2.67E-04

<2.64E-04

<1.93E-07

<2.21E-07 1-133 Ci <2.67E-02

<2.64E-02

<1.93E-05

<2.21 E-05 Total Ci O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 3. Particulates and Tritium H-3 Ci 1.34E+01 1.27E+01 5.27E-01 3.71E-01 Mn-54 Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21E-06 Fe-59 Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21 E-06 Co-58 Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21E-06 Co-60 Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21 E-06 Zn-65 Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21 E-06 Mo-99 Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21 E-06 Cs-134 Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21E-06 Cs-1 37 Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21 E-06 Ce-141 Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21E-06 Ce-144 Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21E-06 Sr-89 Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21 E-06 Sr-90 Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21 E-06 Gross Alpha Ci <2.67E-03

<2.64E-03

<1.93E-06

<2.21 E-06 Total Ci 1.34E+01 1.27E+01 5.27E-01 3.71 E-01 NOTE"Less than" values for Noble Gases are calculated using the Lower Limit of Detection (LLD) values obtained at Wolf Creek Generating Station multiplied by the volume of air discharged during the respective quarter.For the Halogens and Particulates, the ODCM LLD values are used.

M A G E D 0 4/8/4.0 6 16 of 36 GASEOUS CUMULATIVE DOSE

SUMMARY

(2005) TABLE I QUARTER 1 OF 2005 (mRem)TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE TOTAL DOSE FOR BONE FOR LIVER FOR TOTAL BODY FOR THYROID FOR KIDNEY FOR LUNG FOR GI-LLI ODCM CALCULATED DOSE 0.OOE+00 1.95E-03 1.95E-03 1.95E-03 1.95E-03 1.95E-03 1.95E-03 O.OOE+00 1.01 E-02 1.01 E-02 1.01 E-02 1.01 E-02 1.01 E-02 1.01 E-02 QUARTER 2 OF 2005 (mRem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI QUARTER 3 OF 2005 (mRem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI QUARTER 4 OF 2005 (mRem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI TOTALS FOR 2005 (mRem)TOTAL DOSE FOR BONE TOTAL DOSE FOR LIVER.TOTAL DOSE FOR TOTAL BODY TOTAL DOSE FOR THYROID TOTAL DOSE FOR KIDNEY TOTAL DOSE FOR LUNG TOTAL DOSE FOR GI-LLI 0.OOE+00 9.86E-03 9-86E-03.9.86E-03 9.86E-03 9.86E-03 9.86E-03 0.OOE+00 9.22E-03 9.22E-03 9.22 E-03 9.22E-03 9.22E-03 9.22E-03 0.OOE+00 3.11 E-02 3.11IE-02 3.11 E-02 3.11 E-02 3.11 E-02 3.11 E-02 ODCM LIMIT (1)7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+0O 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 7.50E+00 1.50E+01 1.50E+01 1 ,50E+01 1.50E+01 1.50E+01 1.50E+01 1.50E+01% OF LIMIT O.OOE+00 2.60E-02 2.60E-02 2.60E-02 2.60E-02 2.60E-02 2.60E-02 O.OOE+O0 1.35E-01 1.35E-01 1.35E-01 1.35E-01 1,35E-01 1.35E-01 O.OOE+O0 1.31 E-01 1.31 E-01 1.31E-01 1.31E-01 1.31 E-01 1.31 E-01 O.OOE+0O 1.23E-01 1.23E-01 1.23E-01 1.23E-01 1.23E-01 1.23E-01 O.OOE+00 2.08E-01 2.08E-01 2.08E-01 2.08E-01 2.08E-01 2.08E-01 1. Based on Wolf Creek ODCM Section 3.2.2 which restricts dose during any calendar quarter to less than or equal to 7.5 mRem to any organ and during any calendar year to less than or equal to 15 mRem to any organ.

I A 17of36 G E D GASEOUS CUMULATIVE DOSE

SUMMARY

(2005) TABLE 2 0 4 Nuclides Released Quarter 1 Quarter 2 Quarter 3 Quarter 4 Total A. Fission and Activation Gases 8/ 1. Total Release -(Ci) 3.53E-01 6.02E-01 1.78E-01 3.98E-01 1.53E+00 2. Total Gamma Airdose (mRad) 2.08E-04 1.88E-04 1.08E-04 1.65E-04 6.70E-04 3. Gamma Airdose Limit (mRad) 5.OOE+00 5.00E+00 5.OOE+00 5.OOE+O0 1.00E+01 4. Percent of Gamma Airdose Limit 4.16E-03 3.76E-03 2.16E-03 3.31 E-03 6.70E-03 0 5. Total Beta Airdose (mRad) 7.75E-05 9.03E-05 3.92E-05 8.07E-05 2.88E-04 b 6. Beta Airdose Limit (mRad) 1.OOE+01 1.OOE+01 1.OOE+01 1.OOE+01 2.OOE+01 7. Percent of Beta Airdose 7.75E-04 9.03E-04 3.92E-04 8.07E-04 1.44E-03 Limit (mRad)B. Particulates

1. Total Particulates (Ci) O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 2. Maximum Organ Dose (mRem) O.OOE+00 O.OOE+00 0.00E+00 O.OOE+00 O.OOE+00 3. Organ Dose Limit (mRem) O.OOE+00 7.50E+00 7.50E+00 7.50E+00 1.50E+01 4. Percent of Limit O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 C. Tritium 1. Total Release (Ci) 2.76E+00 1.43E+01 1.39E+01 1.30E+01 4.41 E+01 2. Maximum Organ Dose (mRem) 2.00E-03 1.06E-02 1.03E-02 8.25E-03 3.11 E-02 3. Organ Dose Limit (mRem) 7.50E+00 7.50E+00 7.50E+00 7.50E+00 1.50E+01 4. Percent of Limit 2.66E-02 1.41E-01 1.37E-01 1.10E-01 2.08E-01 D. Iodine 1. Total 1-131,1-133 (Ci) O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+O0 2. Maximum Organ Dose (mRem) O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+O0 3. Organ Dose Limit (mRem) 7.50E+00 7.50E+00 7.50E+00 7.50E+00 1.50E+01 4. Percent of Limit O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 This table is included to show the correlation between Curies released and the associated calculated maximum organ dose. The maximum organ dose is calculated using Wolf Creek ODCM methodology which assumes that an individual actually resides at the release point. ODCM Section 3.2.2 organ dose limits are used.

I A18 of36 G E D. SECTION II CI SUPPLEMENTAL INFORMATION 4/ 1. Offsite Dose Calculation Manual Limits A. For li!qud waste effluents/ A.1 The concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS shall be limited to the concentrations specified in 10 CFR 20, 0 Appendix B, Table II, Column 2, for radionuclides other than dissolved or entrained noble pases. For dissolved or entrained noble gases, the concentration shall be limited to& 2 x 10 microCuries/ml total activity.A.2 The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released, from each unit, to UNRESTRICTED AREAS shall be limited: a. During any calendar quarter to less than or equal to 1.5 mrems to the whole body and to less than or equal to 5 mrems to any organ, and b. During any calendar year to less than or equal to 3 mrems, to the whole body and to less than or equal to 10 mrems to any organ.B. For gaseous waste effluents B.1 The dose rate due to radioactive material released in gaseous effluents from the site to area at and beyond the SITE BOUNDARY shall be limited to the following:" a. For noble gases: Less than or equal to 500 mrems/yr to the whole body and less than or equal to 3000 mrems/yr to the skin, and b. For lodine-131, Iodine-1 33, tritium, and all radionuclides in particulate form with half-lives greater than 8 days: Less than or equal to 1500 mrems/yr to any organ.B.2 The air dose due to noble gases released in gaseous effluents, from each unit, to areas at and beyond the SITE BOUNDARY shall be limited to the following:

a. During any calendar quarter: Less than or equal to 5 mrads for gamma radiation and less than or equal to 10 mrads for beta radiation, and b. During any calendar year: Less than or equal to 10 mrads for gamma radiation and less than or equal to 20 mrads for beta radiation.

B.3 The dose from Iodine-131, Iodine-133, tritium, and a radionuclide in particulate form with half-lives greater than 8 days in gaseous effluents released to area at and beyond the SITE BOUNDARY shall be limited to the following:

a. During any calendar quarter: Less than or equal to 7.5 mrems to any organ, and b. During any calendar year: Less than or equal to 15 mrems to any organ.2. Effluent Concentration Limits (ECLs)Water -covered in Section I.A.Air -covered in Section I.B.

I ii.6 0 4/.9/0 0 6 19 of 36 3. Average Energy Average energy of fission and activation gaseous effluents is not applicable.

See ODCM Section 3.1 for the methodology used in determining the release rate limits from noble gas releases.4. Measurements and Approximations of Total Radioactivity A. Liquid Effluents Liquid Release Sampling Method of Analysis Type of Activity Type Frequency Analysis P 1. Batch Waste Each Batch P.H.A. Principal Gamma Emitters Release Tank P Each Batch P.H.A. 1-131 a. Waste Monitor P P.H.A. Dissolved and Entrained Tank One Batch/M Gases (Gamma Emitters)b. Secondary Liquid P L.S. H-3 Waste Monitor Each Batch S.A.C. Gross Alpha Tanks P O.S.L Sr-89. Sr-90 2. Continuous Daily P.H.A. Principal Gamma Emitters Releases Grab Sample P.H.A. 1-131 a. Steam Generator M Dissolved and entrained Blowdown Grab Sample P.H.A. Gases (Gamma Emitters)b. Turbine Building Daily L.S. H-3 Sump/Waste Water Grab Sample Treatment S.A.C. Gross Alpha O.S.L. Sr-69, Sr-90 c. Lime Sludge Pond Daily Grab Sample O.SL.L Fe-55 P = prior to each batch M monthly L. S. = Liquid scintillation detector S.A.C. = scintillation alpha counter O.S.L. = performed by an offsite laboratory P.H.A. = gamma spectrum pulse height analysis using a High Purity Germanium detector I H A G E DI 0 4!8/2.0 0 6 20 of 36 B. Gaseous Waste Effluents Gaseous, Release Sampling Frequency Method of Analysis Type of Activity Type Analysis P P.H.A. Principal Gamma Emitters Waste Gas Decay Tank Each Tank Grab Sample Containment Purge or P P.H.A. Principal Gamma Emitters Vent Each Purge Grab Sample Gas Bubbler and L.S. H-3 (oxide)Unit Vent M P.H.A. Principal Gamma Emitters Grab Sample Gas Bubbler and L.S. H-3 (oxide)Radwaste Building M P.H.A Principal Gamma Emitters Vent Grab Sample For Unit Vent and Continuous P.H.A. 1i131 Radwaste Building Vent release types 1-133 listed above Continuous P.H.A. Principal Gamma Emitters Particulate Sample Continuous S.A.C. Gross Alpha Composite Particulate Sample Continuous O.S.L. Sr-89, Sr-90 Composite Particulate Sample P = prior to each batch M = monthly L.S. = Liquid scintillation detector S.A.C. = scintillation alpha counter O.S.L. = performed by an offsite laboratory P.H.A. = gamma spectrum pulse height analysis using a High Purity Germanium detector I A 21 of 36 G E D 5. Batch Releases 0 A batch release is the discontinuous release of gaseous or liquid effluents which takes 4 place over a finite period of time; usually hours or days.There were 72 gaseous batch releases during the reporting period. The longest gaseous 8batch release lasted 9777 minutes, while the shortest lasted 75 minutes. The average release lasted 538 minutes with a total gaseous batch release time of 45,683 minutes.2 o There were 62 liquid batch releases during the reporting period. The longest liquid batch 0" release lasted 375 minutes, while the shortest lasted 30 minutes. The average release b lasted 156 minutes with a total liquid batch release time of 10,545 minutes.6. Continuous Releases A continuous release is a release of gaseous or liquid effluent, which is essentially uninterrupted for extended periods during normal operation of the facility.

Four liquid release pathways were designated as continuous releases during this reporting period: Steam Generator Blowdown, Turbine Building Sump, Waste Water Treatment, and Lime Sludge Pond. Two gas release pathways were designated as continuous releases:

Unit Vent and Radwaste Building Vent.7. Doses to a Member of the Public from Activities Inside the Site Boundary Four activities by members of the public were considered in this evaluation:

personnel making deliveries to the plant, workers at the William Allen White Building located outside of the protected area boundary, the use of the access road south of the Radwaste Building, and public use of the cooling lake during times when fishing-was-allowed.

The dose calculated for the maximum exposed individual for these four activities was as follows: Plant Deliveries 3.36E-01 mRem William Allen White Building Workers 7.42E-03 mRem Access Road Users 3.54E-03 mRem Lake Use 4.57E-02 mRem The plant delivery calculations were based on deliveries 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> per week for 50 weeks per year. The William Allen White Building occupancy was based on normal working hours of 2000 per year. The usage factor for the access road south of the Radwaste Building was 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> per year. The dose to fishermen on the lake was based upon 4356 hours0.0504 days <br />1.21 hours <br />0.0072 weeks <br />0.00166 months <br /> (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a day for 363 days, based on the number of days that the lake was open to fisherman).

Pathways used in the calculation were gaseous inhalation, submersion, and ground plane. All calculations were performed in accordance with the methodology and parameters in the ODCM.

I A 22 of 36 G E D 8. Additional Information 0 4 PIR 2005-1836

-While performing a Volume Control Tank (VCT) purge to Gas Decay i/ Tank #3 (GDT), a leak was identified on a Swagelok fitting on a moisture separator 2 pressure switch (HAPS1035B).

During the VCT purge, the Radwaste Treatment Systems Operator noticed a significant drop in pressure.

The purge was secured and the system/ lineup verified, with no deficiencies found. The leak was found to be at a fitting on HAPS1035B, which allowed an unexpected pressure loss from GDT #3, from 21 psig to 0 6.8 psig over a time period of 94 minutes. Work Request 05-050478 was written. The 0 leak resulted in an unplanned, monitored release of noble gases from the Radwaste S Building Vent. No ODCM limits were exceeded.

An estimated 6.22E-03 curies were released.

I M A G E 0/0 63 23 of 36 2005 EFFLUENT CONCENTRATION LIMITS Nuclides H-3 Cr-51 Mn-54 Mn-56 Co-57 Co-58 Co-60 Sb-125 Sb-124 1-131 1-133 1-135 Ce-141 Cs-134 Cs-i 37 Nb-97 Ba-139 Rb-88 Sn-i 17M Sb-122 Sb-126 Na-24 Nb-95 Tc-99M Fe-59 Sr-91 Zn-65 W-187 Ar-41 Kr-85 Kr-85M Kr-88 Xe-1 31M Xe-133M Xe-133 Xe-135 Curies 5.01 E+02 9.98E-04 7.91 E-06 N/A 1.04E-05 2.79E-03 3.44E-04 8.32E-03 4.33E-04 5.63E-04 2.91 E-04 5.09E-05 N/A 1.63E-05 3.01 E-04 N/A N/A 2.68E-05 N/A 1.04E-05 3.78E-05 1.16E-06 3.91 E-06 5.53E-05 1.56E-06 6.01 E-06 2.44E-06 1.80E-04 1.40E-05 N/A 4.30E-05 1.99E-05 N/A 4.55E-04 2.91 E-02 3.81 E-03 Average Diluted Concentration (uCi/ml)1.23E-06 2.46E-12 1.95E-14 N/A 2.56E-14 6.87E-12 8.47E-13 2.05E-1 1 1.07E-12 1.39E-12 7.17E-13 1.25E-1 3 N/A 4.01E-14 7.41E-13 N/A N/A 6.60E-1 4 N/A 2.56E-14 9.31E-14 2.86E-1 5 9.63E-15 1.36E-13 3.84E- 15 1.48E-14 6.01E-15 4.43E-13 3.45E-14 N/A 1.06E-13 4.90E-14 N/A 1.12E-12 7.17E-1 1 9.38E-12 10 CFR 20 ECL (uCi/ml)1.OOE-03 5.OOE-04 3.OOE-05 7.OOE-05 6.OOE-05 2.OOE-05 3.OOE-06 3.OOE-05 7.OOE-06 1.OOE-06 7.OOE-06 3.OOE-05 3.OOE-05 9.OOE-07 1.OOE-06 3.OOE-04 2.OOE-04 1.OOE-08 1.OOE-05 7.OOE-06 5.OOE-05 3.OOE-05 1.OOE-03 1.OOE-05 2.OOE-05 5.OOE-06 3.OOE-05 2.OOE-04 2.OOE-04 2.OOE-04 2.OOE-04 2.00E-04 2.OOE-04 2.OOE-04 2.OOE-04% of ECL 1.23E-01 4.92E-07 6.50E-08 N/A 4.27E-08 3.44E-05 2.82E-05 6.83E-05 1.53E-05 1.39E-04 1.02E-05 4.17E-07 N/A.4.46E-06 7.41 E-05 N/A N/A 1.65E-08 N/A 2.56E-07 1.33E-06 5.72E-09 3.21 E-08 1.36E-08 3.84E-08 7.40E-08 1.20E-07 1.48E-06 1.73E-08 N/A 5.30E-08 2.45E-08 N/A 5.60E-07 3.59E-05 4.69E-06 I M A 24 of 36 E D O EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT 4 2005 SOLID WASTE SHIPMENTS A. SOLID RADWASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)/1. Type of Waste Unit 1- Year Est. Total O Period Error %a. Spent resins, filter sludges m3* 1.07E+01**

evaporator bottoms, etc. Ci 6.48E+02 2.50E+01 b. Dry compressible waste, m3* 3.47E+02**

contaminated equip. etc. Ci 1.56E+00 2.50E+01 c. Irradiated components, m3* O.OOE+00 control rods, etc. Ci O.OOE+00 2.50E+01 d. Other m3* O.OOE+00 Ci O.OOE+00 2.50E+01*m3 = cubic meters This is the volume sent offsite for volume reduction, prior.to disposal.2. Estimate of Major Nuclide Composition (by type of waste).[Nuclides listed with % abundance greater than 10 %]a. Spent resin, filter sludges, evaporator bottoms, etc.Nuclide Percent Name Abundance Curies Fe-55 24 1.57E+02 Ni-63 52 3.34E+02 Co-60 11 7.03e+01 b. Dry compressible waste, contaminated equipment, etc.Nuclide Percent Name Abundance Curies Fe-55 61 9.41E-01 Ni-63 23 3.57E-01 I M A G E[)0 4/2.V/2.0 0 6 25 of 36 c. Irradiated components, control rods, etc. -None d. Other- None 3. Solid Waste Disposition Number of Shipments Mode of Transportation 2 Truck (Hittman Transport Services)3 Truck (Hittman Transport Services)2 Truck (Hittman Transport Services)1 Truck (RACE Logistics, LLC)2 Truck (RSB Logistics)

I Destination Barnwell Waste Management Facility, Barnwell, SC Duratek; Kingston, TN*Studsvik Processing Facility, LLC;Erwin, TN RACE, LLC; Memphis, TN Studsvik Processing Facility, LLC;Erwin, TN 4. Class of Solid Waste a. Class A, Class B, Class C- Corresponding to 2a b. Class A -Corresponding to 2b c. Not applicable

d. Not applicable
5. Type of Container a. LSA (Strong, tight), Type A, Type B -corresponding to 2a b. LSA (Strong, tight) -corresponding to 2b c. Not applicable
d. Not applicable
6. Solidification Agent a. Not applicable
b. Not applicable
c. Not applicable
d. Not applicable B. IRRADIATED FUEL SHIPMENTS (Disposition)

No irradiated fuel shipments occurred during the 2005 period.

I M A 26 of 36.G D SECTION III 0 HOURS AT EACH WIND SPEED AND DIRECTION 4 2 This section documents WCGS meteorological data for wind speed, wind direction, and/ atmospheric stability.

The meteorological data supplied in the following tables covers the period from January 1, 2005, 0 through December 31, 2005, and indicates the number of hours at each wind speed and direction for each stability class. All gaseous releases at the WCGS are ground level releases.Wolf Creek Station did meet Regulatory Guide 1.23 requirement for data recovery and had a 90.58% meteorological data recovery for 2005.

I A b E D 0 4./2 A 0 I 2 0 0 6 27 of 36 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2005 STABILITY CLASS: A ELEVATION:

10 METERS WIND DIRECTION 1-3 N 0.00 NNE 7.50 NE 0.50 ENE 0.25 E 0.00 ESE 0.00 SE 0.00 SSE 0.00 S 0.00 SSW 0.00 SW 0.00 WSW 0.50 W 0.00 WNW 0.50 NW 0.25 NNW 0.25 TOTAL 9.75 PERIOD OF CALM (HOURS): 0 4-7 0.25 1.25 2.50 0.50 3.25 1.75 1.25 1.75 2.25 0.50 0.75 1.50 3.75 2.00 4.50 1.50 29.25 WIND SPEED (mph)8-12 13-18, 19-24 3.50 11.00 3.25 3.00 11.25 0.50 5.75 3.50 0.00 1.75 1.00 0.00 3.00 4.25 0.00 8.00 6.50 0.00 7.75 4.25 0.00 27.50 18.75 4.50 40.75 83.75 18.25 14.25 46.75 11.75 6.00 1.50 0.00 5.00 1.75 0.00 14.00 5.50 1.25 7.50 10.50 3.25 5.50 8.00 3.25 9.25 10.75 8.75 1.62.50 229.00 54.75>24 1.50 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.50 0.50 0.00 0.25 1.00 0.50 0.75 3.75 8.75 TOTAL 19.50 23.50 12.25 3.50 10.50 16.25 13.25 52.50 145.50 73.75 8.25 9.00 25.50 24.25 22.25 34.25 494.00 I A 28 of 36 G E D HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31,2005 4 STABILITY CLASS: B ELEVATION:

10 METERS 2 WIND SPEED (mph)WIND DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 O TOTAL 6 N 1.00 2.75 10.25 10.25 3.75 0.50 28.50 NNE 0.25 2.50 6.75 8.75 0.75 0.00 19.00 NE 0.50 3.00 5.25 1.75 0.25 0.00 10.75 ENE 0.00 3.75 2.50 0.50 0.00 0.00 6.75 E 0.00 21.50 4.75 0.75 0.50 0.50 28.00 ESE 0.00 1.25 3.50 2.50 0.00 0.00 7.25 SE 0.00 2.00 10.25 1.75 0.25 0.00 14.25 SSE 0.25 5.25 12.25 5.50 2.00 0.00 25.25 S 0.00 5.50 24.75 20.50 8.75 0.25 59.75 SSW 0.25 3.00 18.25 23.75 4.00 0.50 49.75 SW 0.00 1.75 8.25 0.25 0.25 0.00 10.50.WSW 1.25 3.50 3.75 0.25 0.00 0.75 9.50 W 0.50 3.75 8.75 3.25 0.25 1.75 18.25 WNW 0.50 3.75 7.50 2.00 0.75 1.25 15.75 NW 0.50 5.00 7.25 9.25 2.25 0.50 24.75 NNW 0.50 3.00 6.50 8.75 6.25 1.25 26.25 TOTAL 4.50 71.25 140.50 99.75 30.00 7.25 354.25 PERIOD OF CALM (HOURS): 0 I M A 29 of 36 G E D HOURS AT EACH WIND SPEED AND DIRECTION 0 4 PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2005/ STABILITY CLASS: C 2 ELEVATION:

10 METERS 8/2 WIND SPEED (mph)o WIND 0 DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 6 TOTAL N 1.25 9.50 14.25 17.50 3.00 0.25 45.75 NNE 0.75 10.50 10.75 5.50 1.00 0.00 28.50 NE 1.50 8.25 6.75 2.25 0.00 0.00 18.75 ENE 1.00 9.75 7.25 2.25 0.00 0.00 20.25 E 1.25 11.25 7.00 1.25 1.00 0.75 22.50 ESE 0.00 6.25 6.00 1.75 0.00 0.00 14.00 SE 0.75 5.75 10.75 2.75 0.00 0.00 20.00 SSE 0.50 11.75 24.25 7.75 1.50 0.00 45.75 S 0.25 14.75 23.75 15.25 9.00 0.25 63.25 SSW 2.00 5.00 23.00 19.75 3.00 0.00 52.75 SW 0.50 5.00 8.00 1.50 0.25 0.00 15.25 WSW 1.00 5.00 6.00 1.25 0.00 1.00 14.25 W 0.75 5.50 10.25 4.25 0.25 0.00 21.00 WNW 0.25 4.75 6.25 2.50 0.50 1.00 15.25 NW 1.00 7.00 5.00 9.75 5.50 2.00 30.25 NNW 0.25 3.75 11.00 10.75 3.25 2.00 31.00 TOTAL 11.75 123.75 180.25 106.00 28.25 7.25 458.50 PERIOD OF CALM (HOURS): 0.25 I Ii A D 4 0 0 6 30 of 36 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2005 STABILITY CLASS: D ELEVATION:

10 METERS WIND SPEED (mph)WIND DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW TOTAL 11.50 62.00 142.25 97.25 13.25 7.75 52.00 121.50 579.75 3.75 27.00 119.50 75.75 18.00 0.25 16.00 69.75 30.75 3.00 0.25 12.00 60.75 61.00 8.25 5.50 13.25 44.00 49.50 7.75 2.50 12.25 37.75 52.25 11.75 1.50 27.25 62.75 77.00 33.00 10.75 9.50 54.25 133.00 137.75 44.50 9.00 48.75 84.25 52.25 10.25 7.00 46.00 17.50 3.00 0.50 12.25 29.50 17.50 3.75 1.50:7.25 24.25 '28.75 10.50 2.25 16.25 29.50 41.75 21.25 9.75 15.75 17.25 40.00 60.50 16.25 16.75 37.50 72.50 51.75 12.25 209.25 795.50 1045.25 1099.50 135.00 1.50 327.75 2.50 767.25 0.25 240.75 0.00 119.75 0.25 147.75 0.00 117.00 0.00 115.50 0.75 211.50 3.50 382.50 1.75 206.25.0.75 74.75 1.75 66.25 0.50 73.50 1.25 119.75 3.00 152.75 5.25 196.00 23.00 .3319.00 PERIOD OF CALM (HOURS): 4 ii A G[)0 4/2 2 0 0 6 31 of 36 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31,2005 STABILITY CLASS: E ELEVATION:

10 METERS WIND DIRECTION 1-3 4-7 WIND SPEED (mph)8-12 13-18 19-24 >24 N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW TOTAL 6.75 35.00 48.25 17.00 19.75 22.50 21.25 33.75 17.50 17.50 32.00 11.25 20.75 51.25 34.25 12.50 55.25 34.75 11.00 56.25 44.00 7.25 91.75 180.25 5.50 67.75 188.00 8.00 36.50 92.75 8.25 50.75 13.75 3.25 18.50 19.75 3.75 15.25 38.75 1.75 13.00 33.00 3.25 24.25 26.50 5.75 36.25 31.00 146.75 637.25 836.25 9.00 4.00 0.75 1.00 10.00 6.75 10.00 77.25 154.25 35.50 3.50 4.00 4.25 3.25 9.75 7.25 340.50 0.75 0.50 0.00 0.00 1.25 0.00 0.50 10.00 39.75 7.00 0.00 0.00 0.25 1.00 1.50 2.00 64.50 0.25 0.50 0.00 0.00 0.00 0.00 0.00 0.00 1.25 0.75 0.00 0.25 0.00 0.00 0.50 1.50 5.00 TOTAL 100.00 64.25 73.25 61.75 117.50 109.25 121.75 366.50 456.50 180.50 76.25 45.75 62.25 52.00 65.75 83.75 2037.00 PERIOD OF CALM (HOURS): 188.25 I A 32 of 36 G E D HOURS AT EACH WIND SPEED AND DIRECTION 0 4 PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2005/ STABILITY CLASS: F ELEVATION:

10 METERS/2 WIND SPEED (mph)O WIND o DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL 6 N 4.50 30.00 9.75 0.25 0.00 0.00 44.50 NNE 7.00 22.50 6.25 0.00 0.00 0.00 35.75 NE 11.25 19.50 0.25 0.00 0.00 0.00 31.00 ENE 9.25 14.50 0.50 0.00 0.00 0.00 24.25 E 7.75 63.75 12.75 0.00 0.00 0.00 84.25 ESE 15.50 67.25 10.50 2.25 0.00 0.00 95.50 SE 11.50 68.25 16.00 175.50 0.00 0.00 271.25 SSE 4.75 75.25 34.50 3.25 0.00 0.00 117.75 S 4.50 35.25 31.75 8.75 0.00 0.00 80.25 SSW 3.25 13.00 9.25 2.00 0.00 0.00 27.50 SW 2.50 24.50 3.50 0.00 0.00 0.00 30.50Q WSW 3.00 8.25 1.00 0.00 0.00 0.00 12.25 W 4.50 7.25 4.75 0.25 0.00 0.00 16.75 WNW 3.25 5.25 3.75 2.00 2.00 0.00 16.25 NW 1.00 17.25 7.00 5.50 1.50 0.00 32.25 NNW 5.50 31.50 8.75 0.25 0.00 0.00 46.00 TOTAL 94.50 503.25 160.25 200.00 3.50 0.00 966.00 PERIOD OF CALM (HOURS): 4 I M A 33 of 36 G E D HOURS AT EACH WIND SPEED AND DIRECTION 0 4 PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2005/ STABILITY CLASS: G 2 ELEVATION:

10 METERS 0/2 WIND SPEED (mph)WIND DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 7.25 35.25 2.25 0.00 0.00 0.00 44.75 NNE 3.50 39.50 3.25 0.00 0.00 0.00 46.25 NE 6.00 36.00 1.00 0.00 0.00 0.00 43.00 ENE 10.25 31.75 0.00 0.00 0.00 0.00 42.00 E 7.75 46.75 1.50 0.00 0.00 0.00 56.00 ESE 9.75 46.00 1.00 0.00 0.00 0.00 56.75 SE 6.50 31.75 2.75 0.25 0.00 0.00 41.25 SSE 3.25 30.75 3.50 0.00 0.00 0.00 37.50 S 1.75 16.75 6.75 0.75 0.00 0.00 26.00 SSW 1.25 3.25 2.25 1.25 0.00 0.00 8.00 SW 0.75 3.25 0.00 0.00 0.00 0.00 4.00 WSW 0.75 0.50 0.00 0.00 0.00 0.00 1.25 W 2.50 0.25 0.00 0.00 0.00 0.00 2.75 WNW 2.00 0.75 0.00 0.00 0.00 0.00 2.75 NW 2.00 9.50 0.25 0.00 0.00 0.00 11.75 NNW 4.75 29.00 4.50 0.00 0.00 0.00 38.25 TOTAL 62.75 361.00 29.00 2.25 0.00 0.00 462.25 PERIOD OF CALM (HOURS): 2 I 11 b E D 0 4///2 U 0 6 34 of 36 HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: JANUARY 1 THROUGH DECEMBER 31, 2005 STABILITY CLASS: ALL ELEVATION:

10 METERS WIND DIRECTION WIND SPEED 8-12 13-18 N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW TOTAL 1-3 32.25 43.75 68.00 54.25 49.50 51.00 42.00 43.25 21.50 23.75 19.00 22.00 19.25:24.50 23.75 33.75 571.50 4-7 174.75 148.00 222.50 162.00 258.50 221.75 203.00 279.25 196.50 110.00 132.00 66.75 60.00 59.00 84.75 142.50 2521.25 230.50 174.00 112.25 54.00 124.25 113.25 143.75 359.25 448.75 244.00 57.00 53.00 105.25 99.75 91.50 143.50 2554.00 145.25 609.25 26.25 7.75 24.50 27.50 206.25 145.50 421.00 181.25 9.75 11.00 28.00 41.50 102.75 89.50 2077.00 (Mph)19-24 24.00 6.50 0.50 0.25 8.25 2.50 2.25 28.75 120.25 36.00 1.00 1.50 4.25 17.25 30.25 32.50 316.00>24 TOTAL 4.00 3.00 0.25 0.00 1.50~0.00 0.00 0.75 5.75 3.50 0.75 4.00 3.25 4.00 6.75 13.75 51.25 610.75 984.50 429.75 278.25 466.50 416.00 597.25 856.75 1213.75 598.50 219.50 158.25 220.00 246.00 339.75 455.50 8091.00 PERIOD OF CALM (HOURS): 198.5 I 35 of 36 E D SECTION IV 4, ADDITIONAL INFORMATION 2 p 1. Unplanned or Abnormal Releases/One unplanned, monitored release occurred in 2005. See Section II, Additional Information.

o 2. Offsite Dose Calculation Manual (ODCM)The ODCM is in the form of two separate Wolf Creek Nuclear Operating Corporation (WCNOC)administrative procedures.

One of these procedures, the WCNOC "Offsite Dose Calculation Manual", AP 07B-003, Revision 5, is included with this report as Attachment

i. The other procedure, "Offsite Dose Calculation Manual (Radiological Environmental Monitoring Program), AP 07B-004, Revision 10, is included with this report as Attachment II.3. Major Changes to Liquid, Solid, or Gaseous Radioactive Waste Treatment Systems There were no major changes to any of the radioactive waste treatment systems in 2005.4. Land Use Census No new locations for dose calculation were identified during this report period.5. Radwaste Shipments Twelve shipments of radioactive waste occurred during this report period.Section II, Subsection 3, of this report contains specific details regarding each shipment's mode of transportation and destination.
6. Inoperability of Effluent Monitoring Instrumentation No events occurred that violated ODCM Requirements Tables 2-2 and 3-2, liquid or gaseous effluent monitoring instrumentation.
7. Storage Tanks At no time during the year 2005 was there an event that led to liquid holdup tanks or gas storage tanks exceeding the limits of Technical Requirements Manual Sections 3.10.1 or 3.10.3.Technical Specification requirements for the program are now covered by Technical Requirements Manual Section 3.10, "Explosive Gas and Storage Tank Radioactivity Monitoring."