ML071430547

Responses 58 - 62, 67, 69, and 70, to Master List for Audit Needs of NRC Request for Additional Information Re License Renewal Application

ML071430547
Person / Time
Site:	Wolf Creek
Issue date:	05/09/2007
From:	Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 07-0017
Download: ML071430547 (321)

Text

58. The groundwater flow direction was noted to be generally SW from WCGS to the Neosho River. Are there any localized groundwater flow directions to Wolf Creek (below CCL)?

Water Use/Water Quality Page 2 of 2-Historical information on how the water withdrawal controls have been implemented in the past. If there have never been any incidents where low water levels in the reservoir or low flow in the river have resulted in water withdrawal restrictions, then state this. If there have been incidents where the rights of any user (WCGS or any other user) have been restricted, provide information on the cause of the incident, length of duration, restrictions placed on which users, and any other relevant information.

-Please provide actual historical data on water withdrawal volumes from the Neosho River.* Groundwater levels were predicted to rise 45.8 feet within 100 feet of the site 50 years after the filling of CCL. The height of the ground water table was predicted to rise 0.4 feet, 2 miles from the site after the lake was filled. Please provide the elevation of the water table before the lake was filled and the current water table elevation.

-The groundwater flow direction was noted to be generally SW from WCGS to the Neosho River. Are there any localized groundwater flow directions to Wolf Creek (below CCL)?-Regarding water use conflicts at Wolf Creek, although the ER Section 4.1 indicates no surface water use conflicts, our Generic Environmental Impact Statement (GELS) for license renewal says (section 4.4.2.1, p. 4-52): "Two nuclear power plants, the Braidwood Station and Wolf Creek Generating Station, have already experienced wateruse conflicts." Furthermore, the GElS on p. 4-53 (left column, first full para) uses WCGS as an example of potential water use conflicts.

Water use conflicts at Wolf Creek are also cited in section 4.4.3, p. 4-57, left column. Although there seems to be a discrepancy, perhaps all water use conflicts have been solved. If so, Wolf Creek should provide this information.

-An assessment of the impact of population increases attributable to the proposed project on the public water supply, as per 10 CFR 51.53(c)(3)(ii)(I).

Section 2.3 Groundwater Resources 2.3 GROUNDWATER RESOURCES WCGS is located in the Central Lowland physiographic province.

The land surface is gently rolling in the Central Lowland province except where major rivers and their tributaries are deeply incised. Kansas, Missouri, and Nebraska are in part of the North American craton, an area that has been tectonically stable throughout most of geologic time. The area has undergone some deformation, as demonstrated by the Nemaha Uplift, located approximately 50 miles west of WCGS. Pennsylvanian strata are present in the area of WCGS, consisting of shale, sandstone, limestone, and some coal beds. Quarternary and tertiary deposits, consisting primarily of unconsolidated sand and gravel, exist along the Neosho River (USGS 1997).WCGS makes no groundwater withdrawals for plant consumptive use. Only small quantities of groundwater are available within a 50-mile radius of WCGS. The groundwater is produced from three types of aquifers:

the alluvial deposits in the river valleys, the weathered bedrock including the shallow soil, and the unweathered bedrock (WCNOC 2004).The regional alluvial aquifer along the Neosho River is composed of sands, silts, and gravel.The width of the alluvium in the valley ranges from 1 to 10 miles, but is less than 20 feet thick in Coffey, Woodson, and Allen counties.

Yields from wells in the alluvial aquifer are less than 100 gallons per minute (WCGS 1980). Recharge occurs from precipitation and from the Neosho River during periods of high flow (WCNOC 2004). The level in the aquifer is, therefore, closely related to the river level. The chemical quality of the water in regional alluvial aquifers generally is suitable for most uses. Typically, the water is hard and a calcium biocarbonate type.Dissolved solids concentrations are generally less than 500 milligrams per liter and high iron concentrations are common (USGS 1997).The weathered bedrock aquifer consists of weathered shales, siltstones, sandstones, and limestones (WCNOC 2004). The weathered zone may be up to 40 feet thick (NRC 1975).Pressure tests indicate that this aquifer is sufficiently permeable to yield up to 10 gallons per minute. Recharge occurs from precipitation and locally from downward percolation through the overlying alluvium.

Discharge occurs into both alluvium and streams (WCNOC 2004).The consolidated bedrock aquifers are composed of sandstones and limestones which are limited to yields ranging from about 1 to 10 gallons per minute. Recharge occurs by precipitation and infiltration of surface water at the outcrops.

Where overlain by shales and siltstones, which act as aquitards and aquicludes, vertical recharge to the limestones and sandstones is minimal (WCNOC 2004). Test holes installed at WCGS suggest the presence of an aquiclude at a depth of about 40 feet (NRC 1975).Groundwater movement is in a southwesterly direction from the plant site towards the Neosho River. The water table contour is a muted image of the surface topography.

The piezometric surface of the deeper aquifers reflects the gradient of the parent formation.

In all cases, the gradient is generally from the site toward the Neosho River (NRC 1975).Wolf Creek Generating Station Environmental Report for License Renewal Page 6 of 52Z Section 4.6 Groundwater Use Conflicts (Plants Using Cooling Towers or Cooling Ponds and Withdrawing Makeup Water from a Small River)4.6 GROUNDWATER USE CONFLICTS (PLANTS USING COOLING TOWERS OR COOLING PONDS AND WITHDRAWING MAKEUP WATER FROM A SMALL RIVER)NRC"If the applicant's plant utilizes cooling towers or cooling ponds and withdraws make-up water from a river whose annual flow rate is less than 3.15x10 1 2 ft 3/year ... [t]he applicant shall also provide an assessment of the impacts of the withdrawal of water from the river on alluvial aquifers during low flow." 10 CFR 51.53(3)(ii)(A)

"...Water use conflicts may result from surface water withdrawals from small water bodies during low flow conditions which may affect aquifer recharge, especially if other groundwater or upstream surface water users come on line before the time of license renewal..." 10 CFR 51, Subpart A, Appendix B, Table B-I, Issue 34 NRC made groundwater use conflicts a Category 2 issue because consumptive use of withdrawals from small rivers could adversely impact aquatic life, downstream users, and aquifer recharge.

This is a particular concern during low flow conditions and could create a cumulative impact due to upstream consumptive use. From 1962 through 2004, the average annual flow of the Neosho River at Burlington, Kansas (U.S. Geological Survey Station 07182510) was 5.06 x 1010 cubic feet per year (1,603 cfs) (Putnam and Schneider 2005).Therefore, the Neosho River meets the NRC definition of a small river. WCGS withdraws its condenser cooling water from a cooling pond (Coffey County Lake) that receives its makeup water from the Neosho River directly below John Redmond Reservoir Dam. Coffey County Lake provides continuous recharge to the rock and soil underneath the site. Groundwater levels were predicted to rise 45.8 feet within 100 feet of the cooling lake 50 years after filling (NRC 1975). Two miles from WCGS, the rise in groundwater was predicted to be less than 0.4 feet (NRC 1975).As discussed in Section 2.3, a regional alluvial aquifer occurs along the Neosho River (WCGS 1980). The amount of groundwater used within a 20-mile radius of WCGS is small. No groundwater is used for the operation of WCGS (NRC 1982). There are no municipalities in the vicinity of WCGS that use groundwater (EPA 2005). The only known groundwater supply being used for industrial purposes within a 20-mile radius of the site is from one well owned by the Atchison Topeka and Santa Fe Railway located 15 miles west-northwest of WCGS (WCNOC 2004), and therefore upstream of WCGS's withdrawal point from the Neosho River.A well inventory conducted in 1973 identified 198 wells within five miles of the plant site. These local wells are used for domestic and livestock purposes.

They supply small quantities of water from the weathered bedrock and larger quantities from the alluvium.

Most wells in the area intercept groundwater in the weathered bedrock zone where the permeability has been increased by weathering.

Information obtained during the well inventory indicated a trend away from domestic groundwater usage and toward the use of treated surface water (WCNOC 2004).In the final environmental statement (FES) for construction, NRC conducted an analysis of Neosho River flow rates immediately downstream of the John Redmond dam with and without Wolf Creek Generating Station Environmental Report for License Renewal Page 12 of 38 Section 4.6 Groundwater Use Conflicts (Plants Using Cooling Towers or Cooling Ponds and Withdrawing Makeup Water from a Small River)the water being diverted to Coffey County Lake. The results showed that there would be a reduction of flow during some portions of the period-of-record drought. However, there would be no change in the downriver flow during the worst part of the drought because the water surface in John Redmond Reservoir would be below the conservation level. In this case, water would be released downstream only for the previous water rights and for water quality purposes, which are the same with or without the presence of WCGS (NRC 1975).In addition, a water purchase contract between the State of Kansas, Kansas Water Resources Board, Kansas Gas and Electric (KG&E), and Kansas City Power and Light Company (KCP&L)limits the amount of water that WCGS can withdraw from John Redmond Reservoir to 9,672 million gallons of water per year. KG&E and KCP&L own WCGS. The contract states that "If the total amount of waters contracted for withdrawal from the John Redmond Reservoir in the next 12-month period is greater than the supply available from that reservoir which is deemed to be 9,672 million gallons per year due to a prolonged drought, the Board will apportion the available waters among the purchasers having contracts therefore as may best provide for the health, safety, and general welfare of the people of this state as determined by the Board" (State of Kansas 1976). Should the State of Kansas determine that an insufficient amount of water is available to maintain flows in the Neosho River, the state will apportion available waters to best benefit the people of Kansas.WCGS does not use groundwater for operation of the plant but does withdraw water from the Neosho River, which could affect recharge of the alluvial aquifer during low flows. However, during the worst drought conditions and lowest flows in the Neosho River, WCGS would not withdraw water from the Neosho River because the water level in John Redmond Reservoir would be below the conservation stage. The State of Kansas may also limit the amount of water that WCGS can withdraw from John Redmond Reservoir if a prolonged drought is experienced.

Although recharge to the alluvial aquifer could, in theory, be affected by low flows in the Neosho River, impacts caused by WCGS would be minimal because lower water levels in John Redmond Reservoir would ultimately preclude or reduce releases at the dam and thus withdrawal of makeup water for Coffey County Lake. Therefore, continued operation of WCGS would have SMALL impacts on groundwater use conflicts and no mitigation is warranted.

Wolf Creek Generating Station Environmental Report for License Renewal Page 13 of 38 2-11 Table 2.3. Selected gage records of the Neosho River and tributaries Drainage LocaionRecord dischrg Gage area Lriver miles) Period of record Maximum Minimum (square mile e) Flow (lts) Time Flow (c04 Time Neosho River a: Council Grove. Ka.at Americus, Ca.at Strewn, Ka.at Bur!ýntm.on.

Ka.near Iola. Ka.Cottonwood River near Ka.near C"crwnce, Ka..t ,otionwood Falls. Ka.near P!ymouth.

Ka.Cedar Crtcek near Ceg.jr Point, ae.Four Mi:e Creek'car Counci' Grove, Ka.250 622 2933 3042 3818 448.0 Oct. 1938-Sept.

1965 June 1963-Sept.

1965 356.5 June 1948-June 1963 338.4 June 1961-Sept.

1965 284.4 Aug. 1895.-Sept.

196lS 121,000 6,380 400,000 26,800 436.000 66,000 46,000 196.000 57.000 July 11. 1951 Sept. 21, 1955 July 11, 1951 Sept. 13. 1961 July 13, 1951 July 11 '951 June 10, 1965 July 11, 1951 June 5, 1965 0 o 0 5.5 oC 8.7 a Each year 1954-1957 19Wt 1936.nd 1956 Oct. 11. 1964 1955--1957 Oct 21. 1964 329 123.9 Oct. 1938-Sept.

1965 754 102.4 June 1961-Sept.

1965 1327 66.7 Apr. 1932-Sept.

1965 1740 39.2 Mar. 1963-Sept.

1965 110 9.4 Oct. 1938-Sept.

1965 55 4.4 Mar. 1963-Sept.

1965 52,400 June 29. 1951 0 d 5.480 Sept. 27, 1965 C0 1963-1964'Several years.1Occas;ona."y, in veer(s) shown.CNo recoWr !rom December 1903 to October 1917.dt CC;,ts:ZOj tb,t .SouTce: United States Geological Survey. "Surface Water Supply of the United States." Part 7. Lower Missisaippi River Basin, Annual Pub'-ca -i, "26-5.The soil and weathered bedrock aquifer is reported to comprise weathered shale, siltstone, sand-stone and limestone, and the soils derived from them. The weathered zone may be up to 40 ft_thick. The overly-ing alluvial aquifer is hydraulically-connected to-the lower weathered bedrock aquifer. Recharge to both is from local precipitation percolating through- the soil. Thus, the water table elevation is responsive to local precipitation-drought conditions.

Within a five-mile radius of the site, well surveys identified 142 dug wells in the two water-table aquifers (ER, Figs. 2.2-10 and 2.2-12).The bedrock aquifers are composed of sandstones and limestones.

Recharge to the aquifers Is principally from precipitation at the outcrop of the formations, east of the proposed site.Some downward movement from the overlying aquifers may result in recharge of the bedrock aqui-fers. However, the rise of the water level in the applicant's test holes above the upper boundary of the formation strongly suggests the presence of an aquiclude at a depth of about 40 ft. The aquiclude is composed of shale beds that limit vertical permeability.

Groundwater movement is in a southwesterly direction from the plant site towards the Neosho River. The water table contour is a muted image of the surface topography.

The piezometric surface of the deeper aquifers reflects the gradient of the parent formation.

In all cases the gradient is generally from the site toward the Neosho River.Use of groundwater in the site area is discussed in Sects. 4.2.2 and 5.5.2 of this statement.

2.5.3 Water quality 2.5.3.1 Surface water The applicant sponsored surface water studies to establish baseline water quality information.

The locations of the sampling stations including John Redmond Reservoir are shown In Fig. 2.7.Chemical and biological analyses were performed to identify the baseline.

Algal bioassays were performed to identify the growth-support potential of the local surface water. The analyses are based on sampling accomplished in March, June, September, and December 1973.The concentration of selected chemical parameters identified by the applicant is compared with earlier (water year October 1965 to September 1966) analyses by othersW in Table 2.4 and Fig. 2.7.

WCGS. -ER 2.5 HYDROLOGY The Wolf Creek nuclear generating station will be located east of the proposed cooling lake in the Wolf Creek watershed.

Figure 2.5-1 shows the site location with respect to the Neosho River basin in Kansas. Primary makeup water supply to the cooling lake will be derived from the conservation pool of the John Redmond Reservoir.

The Wolf Creek dam will be constructed about 51/2 stream miles north of the creek's confluence with the Neosho River to form the cooling lake with normal pool elevation of 1087 feet above 12 mean sea level (MSL). Natural topographical, hydrological and krl other physical features of the watershed are showqn on Figure 2.5-2.The following subsections describe the site and its regional set-ting for both surface and ground-water regimes. Water usage has been discussed in Section 2.2.2.5.1 Surface Water 2.5.1.1 Surface Hydrosphere 2.5.1.1.1 Wolf Creek Watershed Wolf Creek originates about three-quarters of a mile southwest of Halls Summit and flows southward to the Neosho River. It is 26.6 stream miles long and drains about 35 square miles. The natural stream gradient is about 7.4 feet per mile. The lower reaches share a common floodplain with the Neosho River where Wolf Creek's gradient approximates 3.7 feet per mile. The stream channel is well defined and meanders considerably within rather stable banks.The Wolf Creek watershed is characterized by undulating to level topography with moderate drainage gradients (approximately 38 feet per mile) near its headwater region. Differential erosion of westward-dipping limestone and intervening shales and sand-stones created the hilly terrain.There are several farm ponds located in the watershed, both natural and mnan-miade.

These are used particularly during dry periods when stored water is all that is available; they also serve as floodwater impoundments.

The ponds are otherwise too small to affect the hydrologic characteristics of the watershed.

Precipitation near the site has varied considerably from year to year. The nearest precipitation measurement station to the site is at Burlington.

Data on average and maximum precipitation at this station are presented in Table 2.5-1. The recorded precip-itation averages about 38.0 inches annually with snowfall averaging about 15.2 inches.2.5-1 9/13/74 Revision 2 WCGS -ER 2.5.1.1.2 Neosho River Basin The Neosho River originates in Morris County, Kansas, and flows south-southeastward through the state and eventually joins the Arkansas River near Muskogee, Oklahoma.

The major tributary to the Neosho River above the site is the Cottonwood River, which rises near the McPherson-Marion County line and joins the parent stream about 6 miles east of Emporia, Kansas. Three major tribu-taries to the Neosho River immediately downstream of the site are Long Creek, Big Creek, and Turkey Creek (Figure 2.5-1).. They each drain areas greater than 70 square miles and join the main river in the vicinity of Le Roy, Kansas.The Neosho River drains 5,793 square miles and flows more than 300 river miles in Kansas alone. The headwater reach of the basin is approximately 30 miles wide, then increases to about 80 miles to include the drainage system of the Cottonwood River, and then decreases to about an average of 25 miles in width at the state line. The floodplain of the Neosho River has attained a maximum width of about 5 miles in the vicinities of Neosho Rapids and Le Roy, immediately upstream and downstream of the site area, respectively.

However, a natural constriction is located in the valley area near Burlington, where the floodplain narrows appre-ciably to approximately three-quarters of a mile (Kansas Water Resources Board, 1961; and U.S. Army Corps of Engineers, 1965).In the upper reaches of both the Neosho and Cottonwood Riversl stream gradients exceed 8 and 6 feet per mile, respectively, but then decrease to less than 2 feet per mile near Emporia, Kansas.Near the site area, the channel gradient remains at about 1.5 feet per mile, being largely controlled by outcropping limestone and shale (Kansas Water Resources Board, 1961; and U.S. Army Corps of Engineers, 1965). Some parts of the headwater area are at elevations over 1500'feet above mean sea level (MSL), while the river channel at the state line is 757 feet above MSL. The river-channel elevation near the mouth of Wolf Creek is about 978 feet above MSL. The river banks are rather stable and usually covered with brush and trees (U.S. Army Corps of Engineers, 1965).Mean annual precipitation over the Neosho River basin area in Kansas varies from about 28 inches near the headwater region of the Cottonwood River to about 42 inches near the state line (U.S. Army Corps of Engineers, 1965). The average annual snow-fall in the upper Neosho River Basin is about 18 inches (U.S.Army Corps of Engineers, 1958).Council Grove, Marion Lakes, and John Redmond Reservoir are three major surface water impoundments within the Upper Neosho River Basin which exist for flood control and low-flow augmenta-tion. A fourth reservoir, Cedar Point Lake, is now in the final stages of design and will be constructed sometime in the future.There are numerous farm ponds in the site region, but they do not affect the hydrologic regime of the Neosho River.2.5-2 2.5.1.2 Flow Characteristics S 2.5.1.2.1 Wolf Creek Wolf Creek is ungaged, and no records of streamflow are available.

Streamflow in Wolf Creek was extrapolated from U.S. Geological Survey gaging records obtained at Council Grove, Strawn and Iola on the Neosho River, and at Madison on the Verdigris River, taking into consideration the proper adjustments for the respective drainage areas. The gaging stations are in the adjacent general area of the Wolf Creek drainage; streamflow data for a sufficient period were available for allowing the extrapolation to be made.The intensities of streamflow at the above gaging stations were computed, and an average intensity was applied to the drainage area of Wolf Creek. Estimated monthly streamflows for Wolf Creek 2 at its confluence with the Neosho River are listed below: January -400 acre-feet July -2,800 acre-feet February -510 acre-feet August -560 acre-feet March -940 acre-feet September

-980 acre-feet April -1,050 acre-feet October -805 acre-feet May -1,575 acre-feet November -420 acre-feet June -1,710 acre-feet December -280 acre-feet The estimated average monthly flow is about 1020 acre-feet (17.0 cubic feet per second).Though the flow for a part of September may be very low, as noted in Section 2.5.3i..1.2, Wolf Creek hash-aihghe~raverage streamf low during September than in December, as indicated in the above table.This estimated higher September flow is due to the higher precipi-tation and greater thunderstorm activity in September than in December in the drainage area of Wolf Creek. These relationships are indicated by the monthly average and maximum precipitation at Burlington, Kansas (Table 2.5-1), and the monthly and annual thunderstorms at Wichita, Kansas (Table 2.6-13).Magnitudes and probabilities of natural daily flows for Wolf Creek were also estimated from calculated daily-flow duration curves developed for Salt Creek (Kansas Water Resources Board, 1959) using the appropriate drainage-area ratio as discussed above. Figure 2.5-3 represents an estimated duration curve for natural daily flows of Wolf Creek at its mouth.Rather severe droughts of various durations have occurred in the site region. The most severe drought of record lasted from November, 1951 through March, 1957 (Kansas Water Resources Board, 1967a). Wolf Creek ceased to flow altogether during much of this period. Ground water contributes little to sustain streamflow in this region during periods of little or no surface runoff (Kansas Water Resources Board, 1960). The estimated 7-day, 10-year, low flow of Wolf Creek would be 0 cubic feet per second (cfs) (Kansas Water Resources Board, 1960).7/22/74 Revision 1 2.5-3 9/13/74 Revision 2 WCGS -ER Wolf Creek is characterized as an effluent stream (i.e., gaining water from the ground water system). The ground water and piezo-metric levels in the geologic units having hydraulic continuity with Wolf Creek, and underlying and adjacent to Wolf Creek, are higher than Wolf Creek. Figure 2.5-7 shows a generalized east-west cross section through the plant site. In this illustration, the water table in the alluvium and the weathered bedrock slopes toward Wolf Creek as does the piezometric surface in the Platts-mouth Limestone Member and in the Toronto Limestone Member. The weathered bedrock and the alluvium are the only two water table units, and the Plattsmouth Limestone and the Toronto Limestone Members are the only two artesian strata outcropping along Wolf Creek that are potential domestic or stock water sources of supply.The water table and the potentiometric gradients slope toward Wolf Creek, thus indicating discharge to Wolf Creek. Because of the low permeability of the weathered and unweathered bedrock strata, there are only small quantities of ground water leakage to Wolf Creek.2.5.1.2.2 Neosho River Streamflows of the Neosho River near WCGS-l have been completely regulated since the operation of John Redmond Reservoir began in 1963. Flows at gaging stations near Iola, Chanute, and Parsons, about 55, 69, and 138 river miles, respectively, downstream of Wolf Creek's mouth, reflect this regulation.

Natural and regulated 1 streamflow data for the Neosho River are shown in Tables 2.5-la and 2.5-ib, respectively.

Discharge-frequency curves for the gaging stations at Iola and Parsons, based on upstream reservoir regulation, have been developed by the U.S. Army Corps of Engineers and are reproduced on Figure 2.5-4. Curves for the John Redmond damsite and for the stage gage at Le Roy are also included.

The channel capacity of the Neosho River near the site is approximately 16,000 cfs; it can be expected that with floods of recurrence intervals of about 16 years or greater, bankfull discharges would be exceeded, but due to the topography and expected level of the floods, the plant or related facilities should not be endangered.

There are no records of severe flooding due to stream or river ice formation in the site region, or of ice-jams affecting reser-voir operation.

On a historical basis, any severe ice-jam flood potential can be considered minimal.The Kansas Water Resources Board calculated hydraulic geometry parameters for the Neosho River at two gaging stations downstream of the site for streamflows of 50 and 80 percent duration, and also for average discharges (Kansas Water Resources Board, 1971b).These stream parameters are reproduced in Table 2.5-2 and reflect 2.5-4 7/22/74 Revision 1 5-3 the period-of-record drought, there would have been no change in the down-river flow during the worst part of the drought because the water surface in the John Redmond Reservoir.

naturally.

would have been below the conservation level. In this case, water is released downstream only for the previous water rights and for water quality purposes which are the same with or without the presence of the Wolf Creek Generating Station.ES-2359 0.0 20.0 40.0 80.0 80 100.0 120O TIME IN MONTHS FOR THE PERIOD 1951-1960 Fig. 5.1. Predicted John Redmond Reservoir water surface elevations with Wolf Creek Generating Station in operation(for the years 1951 through 1960). Source: ER, Fig. 2.5-5a.Water will be evaporated from Wolf Creek cooling lake at a rate of 35,760 acre-ft/year.

The staff estimates that evapotranspiration losses from the area that will be covered by the cooling lake are about 13,390 acre-ft/year.

Thus the water losses due to Wolf Creek Generating Station will be 22,370 acre-ft/year.

Makeup withdrawal may cause adverse impacts on the biota and water quality of the Neosho River during drought conditions and on the biota of John Redmond Reservoir through entrainment and impingement.

Section 5.5.2 addresses these impacts in detail.Other than the possibility of small reductions in the sport fishery in John Redmond Reservoir, the staff foresees no significant adverse impacts on recreation in the site area. A small area of the east bank of the Neosho River below John Redmond Dam will no longer be available to fishermen and campers because of the location of the makeup facilities.

5.2.2 Groundwater No groundwater will be used for operation of the WCGS. However, the cooling lake will provide continuous recharge to the rock and soil under and near the site. Groundwater levels will rise.In the case of the Plattsmouth Limestone Member, the applicant calculated a 45.8-ft rise 100 ft from the cooling lake 50 years after filling. Two miles from the site the rise in groundwater would be less than 0.4 ft (ER, Sect.. 5.1.7). The calculated times for cooling lake water to move through one mile of Plattsmouth Limestone Member and Jackson Park Shale Member are 6000 years and 1020 years, respectively (ER, Sect. 5.1.7.3).

Seepage from the cooling lake may affect ground-water quality. However, due to the slow groundwater movement and water table gradients, the staff concludes that groundwater users outside the site boundary would not be affected.

5-4 Table 5.1. Flow rates in the Neosho River immediately downstream of the John Redmond Dam without and with the Wolf Creek generating station Flow rates 1951 1952 1953 1954 1955 1956 1957 1958 1959 January Without WCGS (cfs) 210.1 514.0 With WCGS Icfs) 90.1 394.0 Percentage" 57 23 February Without WCGS (cfs) 351.1 347.4 With WCGS (cfs) 231.1 227.4 Percentage' 34 35 March Without WCGS (cfs) 571.8 2698 With WCGS (cfs) 451.9 2578 Percentage" 21 4 April Without WCGS (cfs) 1030 3457 With WCGS (cfsI 910.6 3337 Percentage' 12 3 May Without WCGS Mcfs) 6738 1487 With WCGS (cfs) 6620 1367 Percentage' 2 8 June Without WCGS (cfs) 5867 337.7 With WCGS (cfs) 5757 217.8 Percentage" 2 36 July Without WCGS (cfs) 28.270 112.8 With WCGS (cfs) 281.150 48.2 Percentage" 0.4 57 August Without WCGS (cis) 2104 153.5 With WCGS (cfs; 1984 79.7 Percentage' 6 48 September Without WCGS (cfs) 6465 24.0 With WCGS {cfs} 6345 24.0 Percentage" 2 0 October Without WCGS (cfs) 1282 24.0 With WCGS (cfs) 1162 24.0 PercentageO 9 0 November Without WCGS {cfs) 913.1 15.0 With WCGS (cfs) 793.1 15.0 Percentagea 13 0 December Without WCGS (cfs) 513.0 56.9 With WCGS (cfs) 393.0 15.0 Percentage?

23 74 68.4" 28.0 24.0 15.0 28.0 24.0 78 0 0 55.0 26.0 15.0 15.0 26.0 15.0 73 0 27 163.8 23.0 27.0 15.0 23.0 27.0 91 0 0 100.3 28.0 15.0 15.0 28.0 15.0 85 0 0 392.0 15.0 15.0 333.5 15.0 15.0 15 0 0 60.0 311.7 175.1 44.0 44.0 44.0 27 86 75 25.7 21.0 344.0 310.2 25.7 21.0 222.3 190.2 0 0 35 39 28.0 21.0 519.0 449.7 28.0 21.0 399.0 312.9 0 0 23 30 25.8 27.4 3773 418.9 25.8 27.4 3653 298.9 0 0 3 29 15.0 535.1 1545 1025 15.0 138.1 1427 905.1 0 74 8 12 391.0 5343 1273 4027 15.0 4964 1153 3908 96 7 2 3 46.4 2613 1674.6 742.5 46.4 2493 1555 622.5 0 5 7 16 41.1 609.8 4117 3452 41.1 489.8 3998 3332 0 20 3 3 55.0 178.3 715.9 473.3 55.0 65.0 596.6 353.4 0 64 17 25 36.0 274.8 1301 392.7 36.0 154.B 1192 272.7 0 44 8 31 24.0 572.1 525.0 2689 24.0 452.1 405.0 2569 0 21 23 4 21 0 730.4 563.0 425.8 21.0 620A 443.0 305.8 0 16 21 28 21.0 278.6 172.5 472.4 21.0 158.6 86.1 352.4 0 43 50 25 56.0 56.0 0 60.0 60.0 0 62.8 267.7 62.8 44.0 0 84 65.1 67.7 65.1 55.0 0 19 40.1 36.3 313.5 40.1 36.3 15.0 0 0 95 26.5 30.2 279.8 26.5 30.2 193.4 0 0 31 25.3 21.7 24.5 25.3 21.7 24.5 0 0 0 27.0 21.5 23.7 27.0 21.5 23.7 0 0 0"Percentage figures are reductions in flow due to plant operation.

Ground-Water Levels in Kansas A Briefing to the Kansas Legislature House Agriculture and Natural Resources Committee January 17,2007 Presented By Brownie Wilson The Kansas Geological Survey The University of Kansas~J KANSAS GEOILOGICALI SUtRVEY The Unlve&slty of Kansas KGS OFR 2007-1 Figure 1 -Annual Normal Precipitation in Kansas (Source: KSU Weather Library).

Normal precipitation is defined as the average total precipitation over the last 30 year decal period, in this case, 1971 to 2000. Precipitation patterns in Kansas have major influences on the landscape, water resources, and uses made of water in the state.

Irrigation Municipal Recreation Industrial SOther Finney 576,522 AF Cheyenne 112,757 AF Douglas 1,206,862 AF-- Seward 287,884 AF Stockwater Figure 2 -Total Authorized Water Right Allocations, by County. Water right allocations represent how much water and for what purpose can be diverted each year. In general, municipal and industrial uses are more prevalent in eastern and south-central Kansas while irrigation dominates in western Kansas. Much as this is influenced by the precipitation patterns and available water sources.

-Ground Water-Surface Water Figure 3 -Proportion of Allocations by Water Source and County. In general, surface water is the primary source in eastern Kansas (red) and with ground water in western Kansas (blue). The gray shaded area in western and south-central Kansas is the primary saturated extent of the High Plains (HP) aquifer. The HP aquifer is the primary water source for virtually all uses in this area.

59. Regarding water use conflicts at Wolf Creek, although the ER Section 4.1 indicates no surface water use conflicts, our Generic Environmental Impact Statement (GElS) for license renewal says (section 4.4.2.1, p. 4-52): "Two nuclear power plants, the Braidwood Station and Wolf Creek Generating Station, have already experienced wateruse conflicts." Furthermore, the GElS on p. 4-53 (left column, first full para) uses WCGS as an example of potential water use conflicts.

Water use conflicts at Wolf Creek are also cited in section 4.4.3, p. 4-57, left column. Although there seems to be a discrepancy, perhaps all water use conflicts have been solved. If so, Wolf Creek should provide this information.

Water Use/Water Quality Page 2 of 2-Historical information on how the water withdrawal controls have been implemented in the past. If there have never been any incidents where low water levels in the reservoir or low flow in the river have resulted in water withdrawal restrictions, then state this. If there have been incidents where the rights of any user (WCGS or any other user) have been restricted, provide information on the cause of the incident, length of duration, restrictions placed on which users, and any other relevant information.

• Please provide actual historical data on water withdrawal volumes from the Neosho* River..* Groundwater levels were predicted to rise 45.8 feet within 100 feet of the site 50 years after the filling of CCL. The height of the ground water table was predicted to rise 0.4 feet, 2 miles from the site after the lake was filled. Please provide the elevation of the water table before the lake was filled and the current water table elevation.

-The groundwater flow direction was noted to be generally SW from WCGS to the Neosho River. Are there any localized groundwater flow directions to Wolf Creek (below CCL)?-Regarding water use conflicts at Wolf Creek, although the ER Section 4.1 indicates no surface water use conflicts, our Generic Environmental Impact Statement (GELS) for license renewal says (section 4.4.2.1, p. 4-52): "Two nuclear power plants, the Braidwood Station and Wolf Creek Generating Station, have already experienced wateruse conflicts." Furthermore, the GElS on p. 4-53 (left column, first full para) uses WCGS as an example of potential water use conflicts.

Water use conflicts at Wolf Creek are also cited in section 4.4.3, p. 4-57, left column. Although there seems to be a discrepancy, perhaps all water use conflicts have been solved. If so, Wolf Creek should provide this information.

• An assessment of the impact of population increases attributable to the proposed project on the public water supply, as per 10 CFR 51.53(c)(3)(ii)(I).

Aquatic Ecology Audit Needs request #114"Regarding water use conflicts at Wolf Creek, although the ER Section 4.1 indicates no surface water use conflicts, our GElS for license renewal says (section 4.4.2.1, page 4-52): "Two nuclear power plants, the Braidwood Station and Wolf Creek Generating Station, have already experienced water-use conflicts." Furthermore, the GElS on p. 4-53) left column, first full para) uses Wolf Creek Generating Station as an example of water use conflicts.

Water use conflicts at Wolf Creek are also cited in section 4.4.3, p. 4-57, left column.Although there seems to be a discrepancy, perhaps all water use conflicts have been solved. If so, Wolf Creek should provide this information." The "water-use conflict" referenced from the Generic Environmental Impact Statement (GELS, NUREG-1437) for WCGS is in regard to potential impacts to the Neosho River that may be caused by makeup water withdrawals during a severe and prolonged drought. Effect of reduced flows on the river's fishery, including the threatened Neosho madtom, was a concern. As identified in the attached correspondence (WCNOC 1990), the Final Environmental Statement-Operating License Stage (FES-OLS, NUREG 0878)expected that water withdrawal by WCGS during severe drought condition would reduce reservoir storage and downstream river flows, potentially prolonging or exacerbating a drought's impact on the river's fisheries.

Such river water use conflicts have not occurred to date (6eoAudit R- ,equ 11)-.As stated in the ER (Operating License Renewal Stage) section 4.1, the State of Kansas can limit withdrawal rates and volumes to ensure water flows in the Neosho River, thus providing local regulatory oversight during drought conditions.

In addition, the withdrawal rates modeled and used for the FES-OLS evaluations were greater than actual make-up pumping capabilities experienced.

These operational and procedural limitations on makeup water are detailed in "An Assessment of the Potential Impacts on the Flow of the Neosho River Related to the Operating License Renewal for Wolf Creek Generating Station, Unit No. 1", which is attached.In summary, the water use conflicts identified in the GElS have not occurred, but are considered as potential impacts. State of Kansas water use contract and appropriation criteria are in place to minimize impacts to the river. And finally, actual makeup water diversion procedures reduce diversion rates to less than used for initial environmental impact assessment.

Literature Cited: WCNOC. 1990. Response to Oak Ridge National Laboratory Relicensing Survey, ET 90-0106. Letter from F. T. Rhodes, WCNOC, to H. L. Spiker KDHE. Dated 6/25/1990.

W*LFCREEK NUCLEAR OPERATING CORPORATION Forres! T. Rhadn June 25, 1990 ET 90-0106 Harold L. Spiker Bureau of Environmental Health Services Kansas Department of Health and Environment Forbes Field Topeka, KS 66620 R- eference:

Letter dated June 4, 1990 from H. L. Spiker (KDHE) to B. S. Loveless (WCNOC)

Subject:

Wolf Creek Nuclear Operating Corporation's Response to the Oak Ridge National Laboratory RelicensLng Survey Dear Hr. Spikers Attached are the responses you requested (see reference) from Hr. Brad Loveless (WCNOC) to aid you in completing the Oak Ridge National Laboratory relicensing survey. Each item on the list of potential or known impacts to fish and wildlife resources was addressed as it pertains to the.N operation of Wolf, Creek Generating Station. All pertinent items on the list were reviewed during licensing of this plant and we have no operational data to indicate significant impacts beyond those considered in the Operating License Stage Final Environmental Statement for our period of operation thus far, nor for beyond the currently licensed time Zrame.If you have any question onthese responses, please contact Brad Loveless at (316)364-4168.

Very truly yours.Forrest T. Rhodes Vice President Engineering

& Technical Services FTR/Jra P.O. BSM411 /9*Qlington, KS666!P1 one:(316)36441031 I An E.U Oppo, "y Empiw KAUCNET Attachment to ET 90-0106 Page 1 of 4 LIST OF IMPORTANT FISH AND WILDLIFE RESOURCES AND POTENTIAL OR KNOWN IMPACTS IN THE VICINITY OF WOLF CREEK GENERATING STATION 1) Important sport and commercial fisheries and level of harvest At this time, the cooling lake at Wolf Creek Generating Station (WCGS)is not open for sport or commercial fishing. The Neosho River. from which WCGS pumps cooling lake makeup water, is considered an important sport fishery. During normal hydrologic conditions, WCGS is not expected to impact the river's fishery. During a severe and prolonged drought WCGS water withdrawal could result in reduced flows in the Neosho River. Water storage in John Redmond Reservoir, which regulates flow in the river, could also be reduced from UCS makeup pumping. Thus, the Final Environmental Statement-Operating License Stage (FES-OLS) expected that water withdrawal by WCGS during severe drought conditions will reduce reservoir storage and downstream river flows, potentially prolonging or exacerbating a drought's impact on the river's fisheries.

However, long term impacts on the sport fish populations in the river are not probable as popular species (i.e.channel catfish and flathead catfish) are expected to repopulate relatively quickly after normal flows return.2) important spawning, nursery, or other habitats for aquatic fauna The spawning, nursery, or other habitats for aquatic fauna in the cooling lake are not expected to be significantly impacted by WCGS operations.

As pointed out above and in the FES-OLS, little or no Neosho River flows during severe drought will stress riffle obligate species. Cooling lake makeup water pumping could prolong this effect.3) Impacts of entraiiunent, impingement, or thermal and chemical releases on aquatic biota Potential entrainment and impingement impacts of the WCGS' cooling system were evaluated as acceptable in plant licensing documents.

As a result, no specific monitoring in these areas has taken place.As expected, thermal discharge has greatly influenced the immediate cooling water discharge area of the cooling lake. Mobile species, primarily fish, avoid this area during summer lake conditions.

During winter conditions, these species are attracted to the area and could experience thermal shock in the event of a rapid plant shutdown.

Fish kills from such occurrences were expected and have occurred infrequently since plant operations began. These fish kills were evaluated and were within the limits reviewed in the licensing documents and none significantly impacted the cooling lake fishery.Impact potential from chemical discharges to the lake is primarily from the use of chlorine.

It is used to prevent biofouling in the plant's cooling system. The FES-OLS concluded that appreciable mortality among chlorine-sensitive species of aquatic biota could occur in the immediate vicinity of the discharge outlet to the lake.

F-Attachment to ET 90-0106 Page 2 of 4 However, it was also determined that these potential impacts would not meaningfully affect the overall biological productivity of the cooling lake. No adverse chlorine impacts have been observed to date. This and other chemical releases are regulated by the plant's NPDES permit and no environmental impacts are expected.Entrainment and impingement impact potential to the aquatic biota of the Heosho River exists during makeup water pumping activities.

Entrainment loss was evaluated in the FES-OLS and was not considered a significant impact. Impingement rates were monitored during the lake filling stage and impacts to the Neosho River fishery as a whole were not significant.

-Thermal and chemical releases from WCGS to the Neosho liver would be from discharges from the cooling lake. Cooling lake releases are subject to specifications of the plant's NPDES permit which is designed to protect the biota of the river.74) Adverce effecta of water withdrawals or discharges on water quality and water use No potential adverse effects due to water withdrawals from or discharges to the Neosho River are known other than those discussed CD above. For the cooling lake, intake and discharge for cooling purposes will add corrosion products and water treatment chemicals.

4Water treatment additions are regulated within the scope of the station's NPDES permit. Corrosion products may tend to be concentrated in the lake due to forced evaporation.

In the FES-OLS it was concluded that corrosion products attributable to WCGS operation, however, are not expected to adversely affect aquatic biota, even during periods of prolonged drought which would tend to concentrate these parameters to higher than normal levels.5) Other sources of impacts (e.g. other power plants, industrial discharges, agricultural runoff) that could contribute to cumulative impacts to aquatic resources There are no other sources of impacts to the fish and wildlife resources of the cooling lake known at this time. Municipal and industrial water withdrawal, discharge, stormvater runoff, and mainstem dams likely contribute to cumulative impacts to the aquatic resources of the Neosho River.6) Construction impacts No specific construction activities at WCGS are expected to occur as a result of relicensing that would potentially affect the environment.

7) Aquatic or terrestrial flora and fauna that are listed as threatened or endangered yr~c$ ~< --* Attachment to ET 90-0106 Page 3 of 4 There are no threatened or endangered populations of aquatic flora or fauna known to exist in the cooling lake. No threatened or endangered terrestrial plants are known occur in VCGS controlled property.Terrestrial threatened or endangered species on the federal list that have been observed around WCGS include the bald eagle, peregrine falcon, and the interior least tern. An additional species on the Kansas list that has been observed in the vicinity is the white-faced ibis. Bald eagles use the cooling lake as a winter feeding and roosting site. The greatest potential for impact to these eagles is from transmission line collision mortality.

The frequency of these events were expected to be low and monitoring has detected no collisions thus far. The remaining threatened or endangered species are occasional or rare migrants through the area and continued station operation is not expected to impact them.Along the Neosho River, there are no threatened or endangered plant or terrestrial animal species which WCGS operations may impact. However,-- the Neosho madtom is a threatened fish species which WCGS may potentially impact. As discussed above, pumping activities for cooling lake makeup could prolong severe drought conditions in the riffle habitats of the river downstream of John Redmond Reservoir.

The Neosho madtom depends on riffles and the lose of these habitats for a period of time would likely impact this species.8) Salt drift and icing impacts on vegetation as a result of cooling towers or cooling ponds There are no cooling towers at WCGS. Limited icing does occur in the immediate vicinity of the cooling system discharge to the cooling lake, however, it is infrequent and short-lived.

No impact to the vegetation occurs.9) Bird mortality due to collision with power lines and natural draft cooling towers Transmission line collision mortality was discussed in the FES-OLS and the need to determine the significance of this to bird populations using the cooling lake was identified in the Environmental Protection Plan (Appendix B to the Facility Operating License).

Monitoring of collision events revealed that these do occur, but at a low frequency.

No difference was detected between collision rates before and after WCGS began operations.

No specimen found was a threatened or endangered species. Given similar usage of the cooling lake by migrating or wintering waterfowl in the future, transmission line collision mortality is not expected to be significant.

10) Impacts on fauna as a result of vegetation cutting and herbicides in power-line corridors Transmission line corridors associated with WCGS are easements purchased from affected landowners.

Except where the towers or poles are located, land use in the easements is not altered by the power-Attachment to ET 90-0106 Page 4 of 4 lines. Little or no vegetation is cut or sprayed in these areas beyond that normally associated with rangeland and cropland practices common to the region. Where the lines cross wooded streams, the right-of-ways are sprayed where cutting is impractical.

Because of the small acreage of these required clearing., no significant impacts from transmission line maintenance are expected.11) Rare plant communities There are no rare plant communities in the vicinity of WCGS that are threatened by continued plant operations.

"0 12) Bird colonies-There are no breeding colonies of birds in the vicinity of WCGS that emay be impacted by continued plant operations.

13) Bird roosts (e.g. raptors)There are no bird roosts in the vicinity of WCGS vital to the survival of bird species in the region. Raptors, bald eagles, and waterbirds such as double-crested cormorants do take advantage of flooded trees 7. in the cooling lake as roost sites, however these are not considered critical.

Continued plant operations is not expected to alter this.14) Waterfowl staging area The WCGS cooling lake provides late winter habitat for migrating or wintering waterfowl.

The lake server as a refuge site and enhances other waterfowl habitats available at John Redmond and other local federal reservoirs.

The cooling lake is not, however, considered a major waterfowl staging area and station operation is not expected to impact this.15) Wetlands There are no potential wetland areas other than the cooling lake that continued WCGS operation has the potential to impact.16) Breeding/strutting/wintering grounds for big game or certain gallinaceous birds There are no major big game breeding or wintering grounds in the vicinity of WCGS. Booming grounds or leks of the greater prairie chicken are present on lands controlled by WCGS. These lek sites are not scarce in this region of Kansas and continued operation of WCGS is not expected to impact local sites.

k y o/State of Kansas Mike Hayden, Go... w "0 r Department of Health and Environment Division of Health (13) 296-1343 Stanley C. Grant, Ph.D., Secretary Landon State Office Bldg., Topeka, KS 86612.1129 FAX (13)12231 June 4. 1990 BRAD LOVELESS SUPERVISOR ENVIRONMENTAL MANAGEMENT WOLF CREEK NUCLEAR OPERATING CORPORATION PO BOX 411 BURLINGTON KS 66839

Dear Brad:

As per our recent telephone conversation, please find enclosed a copy of a request from Oak Ridge National Laboratory (ORNL) for information regarding environmental impacts resulting from the continued operation of the Wolf Creek Generating Station.For the most part, our radiological environmental monitoring program at Wolf Creek Generating Station does not assess the kinds of impacts that ORNL is requesting information on. I am therefore asking for your assistance in addressing those impacts listed for which you have information.

Some of them are obviously not applicable.

Any information you have on these impacts as they relate to Wolf Creek Generating Station would be greatly appreciated.

It appears that references to the pre-licensing EIS would be appropriate for a number of the impacts listed.ORAU is requesting that the information be provided to them by June 30, 1ggO.I will need any information that you may have by June 25, 1990 in order to prepare an appropriate reply.If you have any questions or need additional clarification, please do not hesitate to contact me at 913/296-1561.

Sincerely, Harold L. Spiker Public Health Physicist Bureau of Environmental Health Services Radiation Control Program HLS/psw Enclosure~~~. ..........

.... ..Chw:es K .J_. M V_ M P H Ja'zes Power. P.E.. Lorne Phittips.

Ph D. Rogvl Catlisn Ph.D..D o HE-all- Hei. ectcr of Environment Director of InW rmathon Diect,,i 01 the Kinsa!. Heilth (913, 219b1342 113) 296.153, Sysems and Er,,rrnsrettal Laboraicl, (913) 296.1415 (9131 ,(K, 1r19 77 I OAK RDGE NATIONAl OPERATED &V MARTIN4 MARIMTA L LABORATORY ENERGY SYSTEMS. INC.POST OFFICE BOx 20061 OAK a RIDGE. Tipi;6 139* ~' ~ May 7. 1990 Stanley C. Grant, Secretary State Department of Health and Environment Land and State Office Building 900 SW Jackson, Rm 901 I AI~~LJr...e1 V Topeka, KS 66612-1290

Dear Mr. Grant:

.-Oak Ridge National Laboratory is developing a report fo-f e S.. Nuclear Regulatory Commission that will evaluate environmental impacts of relicensing of nuclear power plants.Information on 118 reactors at 74 sites in the U.S. is being gathered to evaluate potential impacts from relicensing and an additiorial 20 or more year relicen:s period (beginning.40 years after original license).-.The results of this study will be used to modify 10 CFR 51 "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." These modifications may result in-some issues no longer being considered for nuclear plants in NEPA evaluations at their time of relicensing.

Therefore, it is important that we obtain infonnation from your office to help in evaluating any impacts of nuclear plants in your state with regard to fish and wildlife resources.

We would appreciate any information you may have on existing impact and on the. presence of important fish and wildlife resources that may be affected by continued operation of the Wolf-Creek GeneratingStation and its power lines. For your convenience, a list of such resources and potential impacts is attached.We would like to have your response by June 30" so that we can use the information in preparing the draft report. Thank you for your assistani--

Sincerely, RECEIVED (F** EjlF0o -r-Glenn F. Cada Aquatic Ecologist Bldg. 1505, MS-6036 Phone: 615/574-7320

-:"Roger L. Kroodsma Terrestrial Ecologist Bldg. 1505, M.S. 6038 Phone: 615/574-7310 cc: 1. A. Power LIST OF IMPORTANT FISH AND WILDLIFE RESOURCES AND POTENhWAL OR KNOWN IMPACTS important sport and commercial fisheries and level of harvest important spawning, nursery, or other habitats for aquatic fauna-impacts of entrainment, impingement, or thermal and chemical releases on aquatic biota adverse effects of water withdrawals or discharges on water quality and water use other sources of impacts (e.g., other power plants, industrial discharges, agricultural runoff) that could contribute to cumulative impacts to aquatic resources construction impacts (construction for relicensing is expected to be relatively minor and entirely contained within existing site boundaries)

.-- aquatic or terrestrial flora and fauna that are listed as threatened or endangered salt drift and icing impacts on vegetation as a result of cooling towers or cooling ponds-. bird mortality due to collision with power lines and natural draft cooling towersimpacts on fauna as a result of vegetation cutting and herbicides in power-line corridors rare plant communities bird colonies bird roosts (e.g., raptors)waterfowl staging areas wetlands breeding/strutting&/intering grounds for big game or certain gallinaceous birds a An Assessment of the Potential Impacts on the Flow of the Neosho River Related to the Operating License Renewal for Wolf Creek Generating Station, Unit No. 1 INTRODUCTION This is an assessment demonstrating that potential water use impacts to the Neosho River during the license renewal period of Wolf Creek Generating Station (WCGS) operation will be no greater than or less than identified during original licensing evaluations.

This assessment is in support of discussion presented in the Environmental Report -Operating License Renewal Stage (ER-OLRS, Section 4.1).Considered during this assessment are conclusions presented during original licensing, available literature and research since original licensing, water withdrawal permits from the State of Kansas, and operational experience since WCGS operation began.Description of the Neosho River Basin The instream biota within the Neosho River has been described and is characterized in the ER-OLRS, Section 2.2. Most of the riparian habitat along the Neosho River and its tributaries can be described as riparian woodland.

Detailed descriptions of the upstream and downstream riparian habitat, and the wildlife present in the area are available in United States Army Corp of Engineers (USACE 2002), Section 3.4. These habitats represent long-term climax vegetation types, and are not expected to change appreciably during the license renewal period.CONSUMPTIVE WATER USE IMPACTS Consumptive water use resulting from license renewal is not expected to change appreciably from that evaluated in Final Environmental Statement related to the operation of WCGS (Nuclear Regulatory Commission, NRC 1982). Basically, water stored in the Coffey County Lake (CCL, sometimes referred to as Wolf Creek Cooling Lake) will be subject to evaporation losses, both natural and forced (NRC 1982, Section 5.3). This water will be a loss from the Neosho River system. Total volume of makeup diversion to CCL will be somewhat less, based on the assessment below. As stated in the ER-OLRS (Section 3.4), license renewal at WCGS will not necessitate a large increase in work force, thus indirect demands on the Neosho River system from increased domestic water needs, and any resulting adverse impacts to aquatic and riparian organisms, will not occur.MAKEUP DIVERSION IMPACTS The NRC concluded that withdrawal of water for makeup of Coffey County Lake (would not cause unacceptable effects on Neosho River biota under normal hydrological conditions (NRC 1982).However, under severe drought conditions, river flow reductions were predicted in effect to extend the duration and severity of low flow conditions, and thus stress aquatic communities of the Neosho River.To understand makeup withdrawal during normal hydrological conditions, a review of surface water use at WCGS in necessary.

The CCL is a 5090-acre lake formed by a dam across Wolf Creek, an intermittent stream. Natural runoff from the Wolf Creek watershed, and direct precipitation on the CCL is not typically sufficient to maintain the lake at its normal operating level of 1087 feet mean sea level (msl, NRC 1982). Consequently, rights to makeup water have been obtained from the natural flows of the Neosho River, and water stored in the conservation pool of nearby John Redmond Reservoir (JRR). This makeup water is transferred via a pumping station (Makeup Water Screen House, MUSH) located on the east bank of the Neosho River immediately downstream of the JRR dam. This water is pumped through underground piping and discharged to CCL approximately 2.5 miles east of the MUSH. Water to be pumped from the conservation storage in JRR is released to the Neosho River through the JRR dam as detailed in the ER-OLRS, Section 4.1.The State of Kansas regulates the surface water use at WCGS. To summarize, WCGS has been authorized by the State to obtain makeup water via two primary methods. These include water appropriations and a contract for stored water in JRR.Appropriation Water Appropriation refers to the use of natural water flows for beneficial use permitted by the Kansas Department of Agriculture, Division of Water Resources (DWR), as provided for in Kansas Statutes Annotated (KSA) 82a-703. At WCGS, three such appropriations apply to CCL water. These are: 1. Water appropriation (file number 20,275) for all natural flows of Wolf Creek upstream of the CCL dam, (State of Kansas 1977a)2. Water appropriation (file number 14,626) for withdrawal via MUSH of natural flows in the Neosho River at a diversion rate of < 55 cubic feet per second (cfs) and a quantity < 25,000 acre-feet per calendar year (State of Kansas 1977b).3. Water appropriation (file number 19,882) for withdrawal via MUSH of natural flows in the Neosho River at a diversion rate of < 170 cubic feet per second (cfs) and a quantity < 57,300 acre-feet per calendar year (State of Kansas 1977c).Wolf Creek Flow Appropriation Impoundment of the natural flows of Wolf Creek, which is a tributary of the Neosho River, is not expected to have measurable impacts to the stream related habitat and riparian ecological communities of Neosho River. This is due to the creek's small flow contribution to the river. Using the estimated average monthly stream flow (NRC 1982, Table 4.3). The total annual flow for Wolf Creek is approximately 12,985 acre-feet, or 18 cfs. The average annual flow of the Neosho River at Burlington (USGS Station 07182510, 1963 -2004 annual mean), upstream of Wolf Creek, was 1603 cfs, and at Iola (USGS Station 0718300, 1899-2004 annual mean) was 1865 cfs (Putnam and Schneider 2005). Using these estimates, annual flows of Wolf Creek represents 1.1 and 1.0 percent of the Neosho River flows at Burlington and Iola, respectively.

Actual percentage of flows would be less than these estimates because only the flows upstream of the CCL dam are impounded, and all flows above elevation 1088 feet msl will pass over the CCL spillway and flow to the Neosho River.Precipitation inputs to Wolf Creek below the CCL dam will not be impacted.Neosho River Appropriations The remaining two appropriations for water are for natural flows in the Neosho River, diverted via MUSH. Makeup water diverted under the conditions in these appropriations are not expected to cause adverse impacts the instream and riparian ecological communities because of the flow requirements stated within them (State of Kansas 1977b and 1977c). As stated previously, both have maximum diversion rates and annual quantity limits. However, the primary reason that will ensure that makeup withdrawals under these appropriations will not cause adverse impacts are the minimum flows required before diversion is allowed. Both require that withdrawals of natural flows shall be made only at such times and under such conditions that a minimum flow of at least 250 cfs remains in the Neosho River immediately downstream from the intake structure.

In practice, makeup withdrawals using these appropriation are only used when greater than 250 cfs, plus the withdrawal volume, as metered at the MUSH, is being discharged from the JRR dam. Due to physical operational limitations, minimum flow typically needs to be 320 cfs or 370 cfs, depending on MUSH pumping status. These conditions are typically during normal or above normal hydrological conditions in the river. The NRC concluded that withdrawal of water for makeup would not cause unacceptable effects on the Neosho River biota under such conditions (NRC 1982).Minimum desirable stream flows are maintained by the State of Kansas "for instream uses relative to fish, wildlife, water quality, general aesthetics and downstream domestic and senior water rights" (State of Kansas 2006). The minimum desirable steam flow for the Neosho River, as measured at Iola, downstream of the makeup diversion, has been specified by Kansas legislative action as 40 cfs during all months, with 60 cfs in April, and 200 cfs in May and June maintained as spawning flows to be managed if reservoirs (ie JRR) are in flood pool (KSA 82a-703c).

Thus, the minimum of 250 cfs immediately downstream of the MUSH required before use of the allocated river water will ensure that flows will support the instream and riparian habitats along the Neosho River.There are provisions in Neosho River water appropriations where WCGS can request of the Chief Engineer of the DWR to allow withdrawal during times when flows at the makeup diversion point are less than 250 cfs. Only flows not needed to satisfy vested rights, prior appropriations, and prior applications for permits to appropriate water for beneficial use may be requested.

The Chief Engineer may permit such withdrawal to the extent that is found to be in the public interest.

However, the Chief Engineer shall withhold from appropriation that amount of water deemed necessary to establish and maintain the desired minimum stream flow (KSA 82a-703a).

Thus, such requests for makeup withdrawal will not include flows necessary to maintain a minimum of 40 cfs (greater during fish spawning season if available) at Iola. With these considerations, makeup withdrawals using appropriated water will not cause adverse impacts to the Neosho River instream and riparian habitats.Contract for Stored Water In addition to the appropriated natural flows of the Neosho River, a portion of the water stored in the conservation pool of JRR has been contracted for with the Kansas Water Resources Board (State of Kansas 1976), now called the Kansas Water Authority.

Basically, this stored contract water can only be accessed for CCL makeup purposes when JRR is at or below its conservation pool level of 1039 feet msl. At this level, downstream flows are less than 250 cfs criteria used to divert appropriated water, indicating that the Neosho River system would either be in a low flow period, or drought condition.

A greater detailed review of this contract is provided in the ER-OLRS, Section 4.1, and in the Final Environmental Statement related to the Operation of WCGS, Section 4.3.1.1 (NRC 1982).Impact Baseline The NRC determined that during a severe and prolonged drought, the withdrawal of the stored contract water at 41 cfs, will cause a marked drawdown of water levels within the reservoir and reduced flows in the river would occur. Such conditions would stress aquatic communities, including fish populations (NRC 1982, Section 5.5.2.1).

These conclusions were based on hydrologic modeling and makeup diversion during CCL lake operations that were expected during the initial operating license process for WCGS (Sargent and Lundy Engineers 1974; NRC 1975, 1976, and 1982).

Unavailable during environmental impact assessment was actual operational conditions of CCL, and makeup diversion procedural limitations.

These considerations will demonstrate that impacts will be less than those forecasted.

Consequently, WCGS makeup withdrawal impacts to the Neosho River, and by extension, to the riparian areas of its watershed during the license renewal period will not be likely.The predicted impacts involve comparing Neosho River stream flows with and without expected makeup withdrawals (NRC 1975, Section 5.2.1, and NRC 1976). The analysis used meteorological conditions present for the period from January 1951 through December 1959. During this period occurred a record drought having a two percent chance of occurrence in any given year, or a one in 50 year drought. Among other factors, the projections accounted for CCL blowdown for water quality management, and sufficient makeup to replace this blowdown.The results of the NRC (1975) analysis were summarized in Table 5.1, and as amended slightly in NRC (1976) Attachment M. These tables clearly indicate decreased Neosho River flows and modeled JRR capacity from July 1952 through April 1957, the analyzed drought period. Attachment M (NRC 1976) indicated this analysis was for makeup for two reactor units at WCGS. Only one unit is present at WCGS, and only impacts from this unit, which will be correspondingly less, are being addressed in this assessment.

The NRC analysis (NRC 1975, 1976) states that there would be no change in the down-river flow during the worst part of the drought because the JRR water surface would have been below the conservation level. The JRR conservation pool is stored between elevation 1020 and 1039 feet msl (U. S. Army Corp of Engineers, USACE, 2002), so presumably this would mean that JRR would be below 1020 feet msl. The conservation pool is where the water contracted from the KWRB is stored.During such conditions, water is released downstream only for the previous water rights and for water quality purposes, which are the same with or without WCGS. This circumstance would have occurred during 42 of the 58 months included in the drought analysis, and are identified in Table 1 attached.The NRC (1976) analysis concluded that 15 of the 58 drought months in which downstream river flow would be reduced because of WCGS. As shown in Table 1, percent flow diverted was large during some months, with the highest being 95 percent during September 1955. It was also shown that downstream flows would be maintained throughout such drought conditions, thus long term instream and riparian habitats should not be adversely impacted.

However, during drought-induced low flows, makeup withdrawal could in effect extend the duration and severity of low flow conditions, and thus may stress aquatic communities.

The NRC (1976) concluded that such impacts would be acceptable.

License Renewal Period Impacts Using the baseline conditions for considering impacts, makeup diversion during the license renewal period is expected to have less potential for harmful impacts to occur to the instream and riparian habitats of the Neosho River. This is based on the following:

(1) State of Kansas administration of water purchase contract (State of Kansas 1976)effectively limits diversion of stored water to a maximum of 70 cfs.(2) Operations controls limits the maximum MUSH diversion rate to 120 cfs.(3) The reduction in need for CCL blowdown, and subsequent makeup diversion to maintain water chemistry.

Purchase Contract Limiting Factors The water purchase contract for water stored in JRR allows a maximum flow rate of 120 cfs, which in reality is two operating MUSH pumps. The maximum design flow of the bypass pipe through which the contract storage water is obtained is approximately 130 cfs (USACE 1996). However, the actural metered flow capacity through the bypass pipe has been approximately 95 cfs. When JRR is not discharging through its spillway, the only method for obtaining the stored water is through the bypass pipe supplying water to the MUSH. In practice, administration of the purchase contract prevents diverting stored makeup via the MUSH at rates greater than can be obtained through the bypass pipe (approximately 95 cfs). By default, this limits MUSH diversion pumping to one pump only, or 70 cfs.Some of the largest portions of Neosho River flows predicted to be diverted by makeup pumping included times when only stored contract water could have been accessed (Table 1). Considering 40 cfs minimum desirable streamflow at Iola downstream of the diversion point required 40 cfs from JRR, and 70 cfs minimum capability for makeup diversion, 110 cfs would be needed to provide for makeup diversion using the contract conditions.

Eleven of 58 evaluated drought months had such flows.Applying 70 cfs as a monthly diversion average to the predicted flows in Table 1 would change the range of percent diverted from 110 to 95 (predicted) to a range of percent diverted from 14 to 62 percent. In addition, essentially those months when the average Neosho River flow was predicted to be less than 110 cfs (Table 1), contract and allocation permitting likely would not have allowed makeup water to be pumped.Consequently, during low flow or drought conditions, actual access to the stored water would be lower than originally predicted.

This would tend to decrease the drawdown rate of JRR during such conditions.

In addition, partial recharge of the JRR conservation pool during the assessed drought could not be diverted as quickly as originally modeled, further decreasing the duration and severity of makeup diversion impacts to JRR and the Neosho River.Design Limiting Factors At the MUSH, there are three makeup pumps rated at approximately 60 cfs individually, but due to friction losses, design net total flow ranges from approximately 60 cfs with one pump operating to 120 cfs with three pumps operating (WCGS 2002, Section 3.1.1). In addition, the design flow for the makeup water piping is 120 cfs (Sargent & Lundy Engineers, 1979, Section 3.4.1). By design, the maximum diversion rate is limited to 120 cfs.Actual operating experience using flow data metered during makeup diversion indicates that one pump will divert up to approximately 70 cfs, and two pumps up to approximately 120 cfs. With the design makeup piping rated at 120 cfs, operating three pumps simultaneously is not likely due to economic and efficiency considerations.

This effectively limits the maximum diversion rate to 120 cfs.Since, as has been established, the maximum rate of diversion of contracted storage water is 70 cfs, two pump operation (120 cfs) will only be possible using water allowed for in the appropriations (State of Kansas 1977b and 1977c). Consequently, a minimum of 370 cfs discharging from the JRR dam would be necessary to provide for the required 250 cfs downstream plus the 120 cfs diversion rate.During the evaluated 50-year drought, such flows existed only two of 58 months (Table 1). Using the 120 cfs maximum as a monthly average, this would have increased the portion of flow diverted for May 1953 from 11 to 68 percent, but decreased percentage for April from 86 to 24 percent.It must be clarified that the predicted flow rates in Attachment M (NRC 1976), and by extension in Table 1, were monthly averages, which should be interpreted with caution. Such data summary may tend to mask extremes in high and low flows. They do, however, provide a means to assess general magnitude of effects, which are valuable in evaluating potential impacts that may be expected during the license renewal period.CCL Blowdown Reductions Less makeup diversion will be required due to the reduction or absence of the need to replace blowdown water from CCL. During normal operations, increases to total dissolved solids (TDS) due to CCL evaporation was expected, especially during drought conditins (NRC 1982). Expected to be contributing to this was sulfates, a by-product of using sulfuric acid for scale control on condenser tubes. Water treatment processes were also considered as a source of artificial inputs to TDS in CCL. To control TDS buildup, periodic blowdown and subsequent makeup was expected to maintain water chemistry to support operations, and to ensure discharges from CCL would meet water quality standards.

During actual WCGS operations, sulfuric acid addition for condenser scale control was not instituted.

Scaling is currently being controlled using agents that contribute considerably less to the TDS constituents to CCL. Physical scale removal with condenser cleaning balls is also being used, which is a method that will not artificially add TDS in CCL. In addition, recent changes in water treatment and condensate polisher regenerations have further reduced, or eliminated WCGS artificial inputs of TDS. Consequently, blowdown for water chemistry control has not been necessary, and the need for such is expected to be even less during the license renewal period. This will reduce makeup diversion accordingly, and further decrease the potential for increasing the duration and severity of drought conditions, and ensure the lack of adverse impacts to the instream and riparian communities of the Neosho River.BENEFICIAL REGIONAL EFFORTS There are two important efforts that are currently in process that will beneficially impact long-term water availability and quality in JRR and the Neosho River watershed.

These include reallocating water storage space in JRR, and targeted conservation programs in the Neosho River watershed upstream of JRR.Reallocation of water storage in JRR will in effect raise the conservation pool elevation from 1039 feet msl to 1041 feet msl. This will provide for an equitable redistribution of the storage remaining between the flood control and conservation pools due to uneven distribution of sediment.

Congress has directed the USACE to conduct the study on this reallocation, and a Supplemental Final Environmental Impact Statement has been completed (USACE 2002). This document is in draft form, and is expected to be completed and implemented in the near future.Throughout Kansas there are conservation efforts underway to address a variety of water and natural resource concerns on a watershed basis. Examples include water quality, public water supply reservoir protection, flooding issues, and wetland and riparian habitat restoration and protection.

A Watershed Restoration and Protection Strategy (WRAPS) is a process engaging watershed stakeholders to identify needs and goals, then create and implement the strategy.

Common and innovative watershed conservation practices are a result (Kansas Natural Resources Sub-Cabinet 2006). Currently, there are five such WRAPS at varying degrees of completion upstream of JRR.Three are in the implementation phase, and these are above Marion Reservoir, Council Grove Lake, and in the Eagle Creek watershed, which empties into the Neosho River immediately upstream of JRR (Coffey County Regional WRAPS, Marion Reservoir Water Quality Project, and the Twin Lakes Don Snethen, Chief, Watershed Management Section, Kansas Department of health and Environment, 2006, personal communication).

Two WRAPS efforts are in the initial investigation and stakeholder engagement stages. One will include the Neosho River watershed above JRR, and the other the Cottonwood River watershed, the largest tributary to the Neosho River upstream of JRR.WCNOC has participated as an interested stakeholder in these efforts. An important aspect of these WRAPS will be to reduce sediment contribution from land use practices in the watershed, thus reduce sedmintation in JRR, and increase its usable water storage into the future.These regional efforts will serve to increase the availability in the JRR -Neosho River system, thus ensure the water quantity and quality necessary to support the instream and riparian habitats during periods of severe drought, and during the license renewal period.CONCLUSION Because instream flows are not affected, license renewal for WCGS will not cause water use impacts to the Neosho River instream biota and riparian habitats.

This is due to the permit and contract criteria governing WCGS use of the makeup water diversion, which effectively limit removals during normal and low flow conditions in the river. Other factors limiting potential water diversion impacts are design limits on makeup pumps, and a reduced need for blowdown from CCL, which necessitates subsequent makeup. In addition, local and regional conservation efforts exist that will improve water and quantity through the license renewal period. Consequenlty, WCGS operations to the Neosho River over the license renewal term will be small, and not warrant mitigation.

Table 1. Predicted flows used to assess the impacts to the Neosho River from makeup water withdrawal during the initial licensing for Wolf Creek Generating Station. Flow impacts were modeled for a once in 50-year period of record drought determined to be actually experienced from July, 1952 through April, 1957.Month Flow (cfs) 1952 1953 1954 1955 1956 1957 January River flow: 64.7 28.0 24.0 25.7 21.0 Makeup flow: 49.7 0 0 0 0 Percent flow: diverted 77 0 0 0 0 February River flow 51.0 26.0 15.0 28.0 21.0 Makeup flow 36.0 0 0 0 0 Percent flow diverted 70 0 0 0 0 March River flow 168.6 23.0 27.0 25.8 27.4 Makeup flow 153.6 0 0 0 0 Percent flow diverted 91 0 0 0 0 April River flow 96.2 28.0 15.0 15.0 494.7 Makeup flow 61.5 0 0 0 423.7 Percent flow diverted 64 0 0 0 86 May River flow 381.0 15.0 15.0 239.4 End of Makeup flow 41.0 0 0 224.4 drought Percent flow diverted 11 0 0 94 June River flow 44.0 286.2 180.2 46.4 Makeup flow Start of 0 242.2 136.2 .0 Percent flow diverted drought 0 85 76 0 July River flow k') 112.8 56.0 54.4 267.7 41.1 Makeup flow (2) 64.6 0 0 223.7 0 Percent flow diverted (1)57 0 0 .84 0 August River flow 135 60.0 65.1 67.7 55.0 Makeup flow 73.8. 0 0 12.7 0 Percent flow diverted 48 0 0 19 0 September River flow 24.0 40.1 36.3 313.5 36.0 Makeup flow 0 0 0 298.5 0 Percent flow diverted 0 0 0 95 0 October River flow 24.0 26.5 30.2 279.8 24.0 Makeup flow. 0 0 0 86.4 0 Percent flow diverted 0 0 0 31 0 November River flow 15.0 25.3 21.7 24.5 21.0 Makeup flow 0 0 0 0 0 Percent flow diverted 0 0 0 0 0 December River flow 56.9 27.0 21.5 23.7 21.0 Makeup flow 41.9 0 0 0 0 Percent flow diverted 74 0 0 0 0 (1) Neosho River flow values and percent that makeup diversion flow comprises of the total river flow below John Redmond Dam were reproduced from modeled forecasts by the NRC (1976) presented in Attachment M.(2) Makeup flows were derived from the difference between Attachment M river flows without makeup diversion and with makeup diversion.

LITERATURE CITED Kansas Natural Resources Sub-Cabinet.

2006. Watershed Restoration and Protection Strategy -WRAPS. Brochure accessed on Kansas Department of Health and Environment web site.http://www.kdheks.gov/nps/wraps.

Accessed November 8, 2006.NRC. 1975. Final Environmental Statement related to construction of Wolf Cree Generating Station Unit 1, NUREG-75/096, Docket No. STN 50-482. Office of Nuclear Reactor Regulation, Washington, D.C., October.NRC. 1976. Supplemental Testimony before the Atomic Safety and Licensing Board. Docket No.STN 50-482, January 6, 1976.NRC. 1982. Final Environmental Statement related to the operation of Wolf Cree Generating Station, Unit 1, NUREG-0878.

Office of Nuclear Reactor Regulation, Washington, D.C., June.Putnam, J. E., and D. R. Schneider.

2005. Water Resources Data, Kansas, Water Year 2004, Water-Data Report KS-04-1. U. S. Department of the Interior, U. S. Geological Survey.Sargent and Lundy Engineers.

1974. Cooling Systems Evaluation Wolf Creek Generating Station Units 1 and 2. Report prepared for Kansas Gas and Electric Company, Kansas City Power &Light Company. Report SL-3060.Sargent and Lundy Engineers.

1979. Design Criteria for Cooling Lake Makeup Water and Blowdon System, DC-WL-01-WC, Rev. 3. Wolf Creek Generating Station, Kansas Gas and Electric Company, Kansas City Power & Light Company.State of Kansas. 1976. Kansas Water Resources Board, Water Purchase Contract No. 76-2.State of Kansas. 1977a. Approval of Application and Permit to Proceed, Appropriation of water for Beneficial Use File Number 20,275. Kansas Department of Agriculture, Division of Water Resources.

Topeka, Kansas. August.State of Kansas. 1977b. Approval of Application and Permit to Proceed, Appropriation of water for Beneficial Use File Number 14,626. Kansas Department of Agriculture, Division of Water Resources.

Topeka, Kansas. August.State of Kansas. 1977c. Approval of Application and Permit to Proceed, Appropriation of water for Beneficial Use File Number 19,882. Kansas Department of Agriculture, Division of Water Resources.

Topeka, Kansas. August.State of Kansas. 2006. Kansas Water Office, Kansas Water Plan. Available online at http://www.kwo.orq.

Accessed November 5, 2006.USACE, 1996. John Redmond Dam and Reservoir, Neosho River, Kansas, Water Control Manual, Appendix 0 Part III to Water Control Master. Manual Arkansas River Basin. Department of the Army Tulsa District, Corp of Engineers.

Oklahoma.

April.

USACE, 2002. Draft Supplement to the Final Environmental Impact Statement Prepared for the: Reallocation of Water Supply Storage Project: John Redmond Lake, Kansas. Volume 1, U. S.Army Corp of Engineers.

June.Wolf Creek Generating Station. 2002. Wolf Creek System Description, Cooling Lake makeup Water and Blowdown System Makeup Water System, FD-WL-02-WC.

Rev 6. Internal Document.

60. An assessment of the impact of population increases attributable to the proposed project on the public water supply, as per 10 CFR 51.53(c)(3)(ii)(I).

/i. : I Water Use/Water Quality Page 2 of 2-Historical information on how the water withdrawal controls have been implemented in the past. If there have never been any incidents where low water levels in the reservoir or low flow in the river have resulted in water withdrawal restrictions, then state this. If there have been incidents where the rights of any user (WCGS or any other user) have been restricted, provide information on the cause of the incident, length of duration, restrictions placed on which users, and any other relevant information.

• Please provide actual historical data on water withdrawal volumes from the Neosho River.-Groundwater levels were predicted to rise 45.8 feet within 100 feet of the site 50 years after the filling of CCL. The height of the ground water table was predicted to rise 0.4 feet, 2 miles from the site after the lake was filled. Please provide the elevation of the water table before the lake was filled and the current water table elevation.

• The groundwater flow direction was noted to be generally SW from WCGS to the Neosho River. Are there any localized groundwater flow directions to Wolf Creek (below CCL)?-Regarding water use conflicts at Wolf Creek, although the ER Section 4.1 indicates no surface water use conflicts, our Generic Environmental Impact Statement (GELS) for license renewal says (section 4.4.2.1, p. 4-52): "Two nuclear power plants, the Braidwood Station and Wolf Creek Generating Station, have already experienced wateruse conflicts." Furthermore, the GElS on p. 4-53 (left column, first full para) uses WCGS as an example of potential water use conflicts.

Water use conflicts at Wolf Creek are also cited in section 4.4.3, p. 4-57, left column. Although there seems to be a discrepancy, perhaps all water use conflicts have been solved. If so, Wolf Creek should provide this information.

-An assessment of the impact of population increases attributable to the proposed project on the public water supply, as per 10 CFR 51.53(c)(3)(ii)(I).

1. 115 Please provide an assessment of the impact of population increases attributable to the proposed project on the public water supply, as per 10 CFR 51.53(c)(3)(ii)(I).

RESPONSE:

NRC Regulation 10 CFR 51.53(c)(3)(ii)(I) requires the environmental report to contain "...an assessment of the impact of population increases attributable to the proposed project on the public water supply." As described in Section 3.4 of the ER, WCNOC does not plan to increase staff size, either permanently or for outages. Section 4.15 of the ER states,"Because WCN OC has no plans to increase plant municipal water usage or increase employment for license renewal purposes, WCNOC concludes that im pacts on public water supply would be SMALL and not require mitigation.".

61. Clarify discussions regarding site boundaries, land ownership, and land use within Section 2.4 and Figure 2-3 of the ER (WCGS, 1980).Clarify the difference between "Site Boundary" and the "Plant Site" on the map, with respect to whether these are a land ownership distinction, a physical fencing distinction, or some other regulatory or access distinction.

Please claarify whether or not the referenced agricultural production areas are within the "Site Boundary" as shown on Figure 2-3. Identify any areas fenced to restrict human access and any areas fenced that may restrict wildlife access.

Terrestrial Ecology Page 1 of I-Clarify discussions regarding site boundaries, land ownership, and land use within Section 2.4 and Figure 2-3 of the ER (WCGS, 1980). Clarify the difference between"Site Boundary" and the "Plant Site" on the map, with respect to whether these are a land ownership distinction, a physical fencing distinction, or some other regulatory or access distinction.

Please claarify whether or not the referenced agricultural production areas are within the "Site Boundary" as shown on Figure 2-3. Identify any areas fenced to restrict human access and any areas fenced that may restrict wildlife access.-Additional data on the avian collision studies that were ceased in 1986. Section 2.4 of the ER (WCGS, 1980) states that sufficient data had been collected by 1986. Provide any documentation of regulatory involvement and concurrence in this determination of sufficiency., Details on the power transmission system, including information on the design of the towers, the number and configuration of the lines on the towers within each right-of-way (ROW).* Details regarding the maintenance procedures used in the transmission line ROWs, including mechanical, chemical, and biological control methods for vegetation management.

-More detailed maps/aerial photos of the transmission line ROWs showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains, and the location of the Sharpe Generating Station.* Please provide information on the locations of transmission line ROWs crossings with parks, wildlife refuges, or wildlife management areas, or any major lakes (in addition to CCL), ponds, or streams? If so, please provide information on these crossings and their locations.

• Any available studies or other information about the issues raised in the letter from the U.S. Fish and Wildlife Service (November 14, 2005) regarding terrestrial threatened and endangered species.For example:-Any assessments of the transmission lines for conformity with "Suggested Practices for Raptor Protection on Power Lines" (Raptor Research Foundation 1996)? Please provide any such assessments and details of transmission line construction relevant to raptor protection.

Also provide a copy of "Suggested Practices," if available.

-- Any special ROW maintenance procedures used to reduce the potential for impacts to Mead's milkweed or animals with federal or state listing status..* Any available maps and aerial photographs of the WCGS plant site and the area within and adjoining the larger site boundary (which encompasses CCL) showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains.

-Any available information identifying natural communities and dominant species of plants and animals that utilize terrestrial habitats of the site and the transmission line ROWs, as well as semiaquatic species subCh as waterfowl that use Lime Sludge Pond and CCL.

Terrestrial Ecology Audit Needs request#"Please clarify discussions regarding site boundaries, land ownership, and land use within Section 2.4 and Figure 2-3 of the ER (WCGS, 1980). Clarify the difference between "Site Boundary" and the "Plant Site" on the map, with respect to whether these are a land ownership distinction, a physical fencing distinction, or some other regulatory or access distinction.

Are the referenced agricultural production areas within the "Site Boundary" as shown on Figure 2-3? Which areas are fenced to restrict human access, and are any areas fenced that may restrict wildlife access?Reference to ,(WCGS, 1980)" is unclear. The boundaries at Wolf Creek Generating Station (WCGS) are as follows: 1. The "Site Boundary" encompasses 9818 acres necessary for WCGS, per Section 2.1.1.2 Site Area, of the Updated Safety Analysis Report (USAR) for WCGS.The Site Boundary is within the boundary illustrated in Figure 2-3 of the ER-OLRS. See Audit Needs Request*#-S for maps showing this boundary.

All land is owned or controlled by the owners of WCGS. There are no specific fences required or existing that are designed to restrict human or wildlife access on this boundary.

Agricultural production and wildlife management occurs within the 9818 acres encompassed by the Site Boundary.2. As indicated in Section 2.1.1.1 of the USAR, the "Plant Site" includes WCGS, and is that which is within the "Site Boundary".

3. The "Owner Controlled Area" (OCA), per procedure Al 07D-001 Resource Management and Ecological Monitoring Programs, includes all properties contiguous to the reactor site and acquired by fee title or easement for WCGS for which public access is limited. The OCA includes the Site Boundary and other lands owned by the owners of WCGS, and shares common borders in many areas (see #"8e-fer maps). The OCA encompasses approximately 11,300 acres.Agricultural production and wildlife management occurs within this area similar to that within the Site Boundary.4. The Exclusion Area Boundary (EAB), sometimes referenced as the restricted area boundary, encompasses an area within a 1200-meter radius of the reactor, and includes approximately 1,118 acres maps). This area is entirely owned in fee title by the owners of WCGS. Agricultural production does not occur within the EAB, however wildlife management activities do occur.There are no fences on this boundary.5. The Protected Area Boundary includes the area in the immediate vicinity of the reactor, and associated buildings.

It is fenced to restrict human, and thus some wildlife, access.

62, Additional data on the avian collision studies that were ceased in 1986. Section 2.4 of the ER (WCGS, 1980) states that sufficient data had been collected by 1986.Provide any documentation of regulatory involvement and concurrence in this determination of sufficiency.

Terrestrial Ecology Page 1 of 1-Clarify discussions regarding site boundaries, land ownership, and land use within Section 2.4 and Figure 2-3 of the ER (WCGS, 1980). Clarify the difference between"Site Boundary" and the "Plant Site" on the map, with respect to whether these are a land ownership distinction, a physical fencing distinction, or some other regulatory or access distinction.

Please claarify whether or not the referenced agricultural production areas are within the "Site Boundary" as shown on Figure 2-3. Identify any areas fenced to restrict human access and any areas fenced that may restrict wildlife access.* Additional data on the avian collision studies that were ceased in 1986. Section 2.4 of the ER (WCGS, 1980) states that sufficient data had been collected by 1986. Provide any documentation of regulatory involvement and concurrence in this determination of sufficiency.

• Details on the power transmission system, including information on the design of the towers, the number and configuration of the lines on the towers within each right-of-way (ROW).-Details regarding the maintenance procedures used in the transmission line ROWs, including mechanical, chemical, and biological control methods for vegetation management.

-More detailed maps/aerial photos of the transmission line ROWs showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains, and the location of the Sharpe Generating Station.-Please provide information on the locations of transmission line ROWs crossings with parks, wildlife refuges, or wildlife management areas, or any major lakes (in addition to CCL), ponds, or streams? If so, please provide information on these crossings and their locations.

• Any available studies or other information about the issues raised in the letter from the U.S. Fish and Wildlife Service (November 14, 2005) regarding terrestrial threatened and endangered species.For example:-Any assessments of the transmission lines for conformity with "Suggested Practices for Raptor Protection on Power Lines" (Raptor Research Foundation 1996)? Please provide any such assessments and details of transmission line construction relevant to raptor protection.

Also provide a copy of "Suggested Practices," if available.

-Any special ROW maintenance procedures used to reduce the potential for impacts to Mead's milkweed or animals with federal or state listing status.-Any available maps and aerial photographs of the WCGS plant site and the area within and adjoining the larger site boundary (which encompasses CCL) showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains.

-Any available information identifying natural communities and dominant species of plants and animals that utilize terrestrial habitats of the site and the transmission line ROWs, as well as semiaquatic species such as waterfowl that use Lime Sludge Pond and CCL.

Terrestrial Ecology 118 Provide additional data on the avian collision studies that were ceased in 1986. Section 2.4 of the ER (WCGS, 1980) states that sufficient data had been collected by 1986 -was there regulatory involvement and concurrence in this determination of sufficiency?

Transmission line collision monitoring was conducted from 1983 through 1988.This period of time included three years of monitoring following plant start-up in 1985. WCGS staff continued to conduct seasonal surveys of avifauna using the cooling lake through 1996. In 1997, WCNOC notified the NRC (see attached letter WO 97-0048) that the requirement for monitoring wildlife (primarily waterfowl, water birds, and bald eagles) use of the cooling lake, because of potential concerns for transmission line collisions, crop depredation, and disease outbreaks, had been met. It had been determined that there was no sigificant problem with any of the potential concerns.

WCGS staff ceased formal wildlife monitoring after 1996. The Kansas Department of Wildlife and Parks (KDWP)had been doing waterfowl, water bird, and bald eagle surveys of the cooling lake since 1981, and they continue to do these surveys. The KDWP surveys are provided to WCGS staff for review to determine if any notable increases in usage might warrant additional monitoring by WCGS. Usage has not changed appreciably and has generally decreased for most species (notably bald eagles)since 1996. A table showing lake usage by selected species through 2006 is attached.A copy of the 1987-1988 Operational Wildlife Monitoring Report, which addresses the conclusion of transmission line collision monitoring, is attached.

A copy of the 1995-1996 Operational Wildlife Monitoring Report, which addresses the conclusion of formal avifauna lake usage monitoring by WCGS staff, is attached.

A copy of the Avian Protection Plan at Wolf Creek Generating Station-August 2006, which addresses transmission line collision monitoring, is attached.

Finally, a copy of the Wolf Creek Generating Station Annual Environmental Operating Report 2005, which documents notification to the NRC that WCNOC is continuing to review avifauna lake usage data provided by the KDWP, is also attached.

H° 1.5'°WLF CREEK 0 NUCLEAR OPERATING CORPORATION LClay C. Warn.Chief Operating OfA2e1r~April 29, 1997 WO 97-0048 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C. 20555

Subject:

Docket No. 50-482: Change in Waterfowl Monitoring Program Gentlemen:

As discussed in NUREG-0878, "Final Environmental Statement Related to the Operation of Wolf Creek Generating Station, Unit 1," Section 5.5.1.2, a general survey program to monitor waterfowl.

collision events (with. plant.transmission lines) was recommended for implementation at the beginning of plant operation and conducted for a minimum of two years. This program was incorporated Into the wildlife monitoring program discussed in Section 2.2 (e)of Appendix B (Environmental Protection Plan) to Facility Operating License No. NPF-42.The purpose of this letter is to inform the NRC of changes Wolf Creek Nu.lear Operating Corporation has implemented in the methods used to monitor Waterfowl collision events. Details on the results of monitoring waterfowl collisions, as well as justification for modifying this portion of the wildlife monitoring program, are provided in the attachment.

If you have any questions concerning this matter, please contact me at (316) 364-8831, extension 4485, or Mr. Brad S. Loveless, at extension 4530.Very truly yours, Clw C. Warren CCW/jad cc: E. W. Merschoff(NRC)

W. D. Johnson (NRC)J. F. Ringwald (NRC)J. C.. Stone (NRC)RO. Box 411 Burlington, KS 66839, Phone: (316) 364-8831 An Equal Opportunity Employer MTF HC.VET H Attachment to WO 97-0048 Page 1 of 2 m 0WOLF CREEK GENERATING STATION WATERFOWL MONITORING PROGRAM CHANGES 0 Ui

Reference:

1) NUREG-0878, Final Environmental Statement Related to the Operation of Wolf Creek Generating Station, Unit 1, June 1982-2)*Wolf Creek Generating Station, Unit No. 1, Environmental KReport, Operating License Stage (ER-OL)NBACKGROUND Section 4.2.2 of Appendix B to Facility Operating License No. NPF-42 contains a requirement concerning the monitoring of waterfowl usage of the Wolf Creek Lake. The requirement states, "A general survey program shall be accomplished to document significant waterfowl collision events and determine if mitigation is warranted." Section 2.2(e) of Appendix B to NPF-42 states, "The need for a wildlife monitoring program which includes a general survey program for waterfowl collision events be accomplished." Section 5.5.1.2 of Reference 1 states, "...given that the applicant has committed to.monitoring wildlife use of the lake (ER-OL, Sec. 6.2.4.2), the staff recommends that general survey program for waterfowl collision events be incorporated into the proposed monitoring program to determine if mitigation is warranted." Section 6.2.4.2 of Reference 2 states, "Operational monitoring studies will be conducted annually for a minimum of two years following station start-up.".

Section 6.2.4.2 of Reference 2 also states, "...operational studies will include seasonal waterfowl and water bird censuses of the cooling lake,..", and, "Since eagles are known to winter at John Redmond Reservoir, emphasis will be placed on determining eagle use of the cooling lake." Further references focus on other areas of potential concerns regarding waterfowl and bald eagles. Section 2.2(d) of Appendix B states, "That in the event a serious disease problem involving waterfowl attributable to station operation occurs, the actions specified in the reference will be initiated.

Discussion on potential for waterfowl depredation on local agricultural crops and potential for disease outbreaks can be found in Section 5.5.1.1 of Reference

1. Section 4.1 of Appendix B also states "Any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to plant operation shall be recorded and promptly reported to the NRC... examples:

excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or unusual occurrence of any species protected by the Endangered Species Act of 1973." RESULTS OF MONITORING Seasonal monitoring of waterfowl, waterbird, and bald eagle usage of the cooling lake has been conducted for each of the past eleven operational winters. Dead bird searches under transmission lines adjacent to where the lines crossed over the lake were discontinued after the first two operational winters. It was determined that the number of collisions, occurring was insignificant when compared to the number of birds using the cooling lake. It was concluded that further dead bird searches would be unnecessary unless waterfowl usage increased significantly.

Operational monitoring (including regularly scheduled waterfowl counts and casual observations of waterfowl flights in the vicinity of the transmission lines) of the cooling lake has shown no trends of increasing usage by waterfowl, waterbirds, or bald eagles.After the 1995-1996 monitoring season, WCNOC again modified the waterfowl monitoring program to discontinue waterfowl counts by WCNOC personnel.

"1 Attachment to WO 97-0048 Z Page 2 of 2 M Waterfowl counts are currently conducted by Kansas Department of Wildlife and QParks personnel, and this data is obtained and reviewed by the WCNOC Environmental Management Department.

0 As noted earlier, two other potential concerns associated with large waterfowl 1 concentrations are disease outbreaks and crop depredation.

No disease outbreaks have been documented in the populations of waterfowl, waterbirds, or bald eagles using the cooling lake. There has been some localized crop depredation, but it has not been significant and has been primarily limited to cropland on owner-controlled property.

Further, the larger concentrations of geese and mallards (Canada geese, snow geese and mallards are the species most likely to cause crop depredation problems, because of their feeding habits and the relatively high number of individuals) in the area typically utilize John Redmond Reservoir more often than Wolf Creek Lake.REQUIREMENT MET Appendix B of NPF-42 required that a wildlife monitoring program be conducted for a minimum of two years following station start-up.

This requirement has been met. Continued monitoring has further established that transmission line collision mortality is not a significant concern for waterfowl, waterbirds, or bald eagles using Wolf Creek Lake. Crop depredation has not been considered a problem in the area surrounding the lake. No disease outbreaks have been identified in the populations of waterfowl, waterbirds, or bald eagles utilizing the lake. For theaforementioned reasons, it has been determined that regularly scheduled seasonal monitoring is no longer required.FUTURE MONITORING Future surveys and/or transmission line collision monitoring may be conducted by WCNOC staff if it appears that atypically high numbers of waterfowl or bald eagles are using Wolf Creek Lake. As required by Section 6.1c of Reference 1, any significant changes in waterfowl usage of Wolf Creek Lake that result in adverse environmental effects will be reported to the NRC.

1993-1994 1994-1995 1995-1996 1996-1997 1997-1998 1998-1999 1999-2000 2000-2001 2001-2002 2002-2003 2003-2004 2004-2005 2005-2006 Mallard 1258 1148 2722 1946 713 4505 197 996 1492 2590 1903 187* 3541 Snow Goose 3584 5069 2427 538 3012 1491 1455 29 6284 9200 5153 3358* 13165 Canada Goose 655 460 1181 866 482 964 148 889 1050 460 1210 105* 1178 Bald Eagle 18 2 14 1 1 <1 <1 <1 1 2 2 1* 1 Mean number per survey of selected avian species using Coffey County Lake (* = incomplete data) 1982-1983 1983-1984 1984-1985 1985-1986 1986-1987 1987-1988 1988-1989 1989-1990 1990-1991 1991-1992 1992-1993 Mallard 5219 527 3035 2803 6206 4751 9067 5087 2632 1719 1082 Snow Goose 90 39 477 336 1457 439 2392 1674 787 2325 8987 Canada Goose 86 115 202 386 470 522 1700 779 498 460 887 Bald Eagle 3 2 4 2 1 15 18 6 8 2 2 Mean number per survey of selected avian species using Coffey County Lake (* = incomplete data) o*b.ID I z 0 WOLFCREEK GENERATING STATION S19 8 7-1988 WILDLIFE MONITORING' REPORT WOLF CREEK NUCLEAR.OPERATING CORPORATION.

A I I I..I I I I I I U ENGINEERING AND TECHNICAL SERVICES ENVIRONMEN-,T:A.L MANAGEMENT GROUP NOVEMBER 1.988 8 I I i I I 1 I I I I I I I 0 WCNOC: EM06-88 WOLF CREEK GENERATING STATION 1987-1988 OPERATIONAL WILDLIFE MONITORING REPORT Daniel.E.

Haines Environmental Management Section Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839 Published November 1988 Annual Report for October 1987 -March 1988 9 5 Table of Contents 0 Page List of Figures .....................................

....... v List of Tables ..................

....... .vi INTRODUCTION

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KETHODS ........................

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.9 RESULTS AND DISCUSSION

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.... ...... .. ., 0..... 14 3 CONCLUSIONS

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aa 53 I LITERATURE CITED o.....................

....... .. ... .... 56 I I I i I I i i n During transmission line collision studies, there has been no increase in impaction mortality as a result of station operations.

No threatened or endangered species were found. Inherent biases with making collision estimates using dead bird searches were identified, measured, and results were adjusted.

Based on the low percentage that the estimated collision rate .comprised of the' total usage of WCCL, it was concluded that mortality caused by the transmission facilities associated with the station was not sufficient to be considered problematic thus no mitigative measures were deemed necessary.

Originator's .Wolf Creek, Operational effects, Wildlife, Threatened and endangered, Bald eagle, Waterfowl, Waterbirds, Heated effluent REPORT DOCUMENTATION PAGE Report No. I Report Date WCNOC EM06-S8 November 1988.Title and Subtitle Wolf Creek Generating Station 1987-1988 Operational Wildlife Monitoring Report Author(s)Daniel E. Haines.Performing Organization Name and Add'ress Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Abstract Waterbird, waterfowl and bald eagle usage and bird collisions with transmission line were monitored on* Wolf Creek Cooling Lake (WCCL) from October 1987 through March 1988. This report compares three seasons of operational data with preoperational data.Thirty nine species of waterbirds and waterfowl were observed with mallard and American coot being most abundant, as was the case during most previous seasons. During the first two operational seasons, increasing numbers of mallards, Canada geese and snow geese were attracted to the ice-free water.However, because the generating station was not continuously operational through the winter of 1987-1988, bird usage was similar to preoperational seasons. During operational winters, the heated effluent provided previously unavailable open water habitat on WCCL which attracted wintering ducks, predominently mallards.

This in combination with seclusion and close abundant food supplies, kept ducks on WCCL longer than during preoperational seasons. Significant (p<O.05) preferences for areas of WCCL providing these were found for these 'wintering concentrations.

No disease or crop depredation problems were observed.The bald eagle, an endangered species, was a common winter residents.

During the first two operational winters (1985-1986 and 1986-1987), bald eagle usage of WCCL declined from preoperational levels. Responsible for this was the heated effluents from continuous station operations which reduced the quantity of winter-stressed fish, an important eagle food source. Also, the normally prevalent thawing and refreezing of the surface waters exposing these fish were absent further discouraging eagle usage.However, because the plant operated-intermittently through much of the 1987-1988 winter, the quantity and to a greater extent the availability of these fish were increased and consequently attracted and held larger numbers of eagles than observed previously.

Author Q A Daniel E. Haines Supervisory Approval Managerial Approval O rt 0 to Mayi rd' V List of Figures Figure Page 1. Wolf Creek Cooling Lake and associated structures

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3 2. Wolf Creek Cooling Lake and John Redmond Reservoir, Coffey County, Kansas .. ...................

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5 3. Transmission line tower configurations in the waterfowl collision study areas at Wolf Creek Generating Station ..... 7 4. Bald eagles per survey at Wolf Creek Cooling Lake and John Redmond Reservoir compared with mean winter air tempe~ratures

....... ...... ..... ........ 0..... ,. 21 5. Preoperational and operational bald eagle usage of Wolf Creek Cooling Lake and John Redmond Reservoir

....... ...... 22 6. Annual combined duck and mallard comparisons between Wolf Creek Cooling Lake and John Redmond Reservoir

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28 7. Preoperational and operational combined duck usage of Wolf Creek Cooling Lake and John Redmond Reservoir

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31 8. Biweekly lake level elevation averages for Wolf Creek Cooling Lake and John Redmond Reservoir

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32 9. Length of migration season for mallards on Wolf Creek Cooling Lake and John Redmond Reservoir

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... 36 10. Preoperational and operational mallard usage of Wolf Creek Cooling Lake and John Redmond Reservoir

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39 11. Annual snow goose and Canada goose usage comparisons between Wolf Creek Cooling Lake and John Redmond Reservoir

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42 12. Preoperational and operational Canada goose usage of Wolf Creek Cooling Lake and John Redmond Reservoir

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43 vi List of Tables Table Page 1. Wildlife monitoring schedule, 1987-1988

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11 2. Waterbird and waterfovl census data collected during ground surveys of Wolf Creek Cooling Lake ....................

15 3- Ground count frequency and percent composition of waterfowl and vaterbirds using Wolf Creek Cooling Lake ...... 17 4. Significant differences (p<.O.05) between rank location means of bald eagles using Wolf Creek Cooling Lake ..........

26 5. National Weather Service monthly average air temperatures for Topeka, Kansas 9.................

29 6. Ground count frequency and percent composition of ducks using Wolf Creek Cooling Lake ... ....... 30 7. Significant differences (p0O.05) between ranked location means of mallards and Canada goose using Wolf Creek Cooling Lake .. 39 8. Ground count frequency and percent composition of geese using Wolf Creek Cooling Lake ............................

41 9. Species list, location, and number of mortalities observed during collision surveys of Wolf Creek Cooling Lake ... .... 45 10. Searcher recovery of planted birds during collision studies at Wolf Creek Generating Station ............................

47 11. Scavenger removal rates of planted dead birds in the trans-mission line study areas at Wolf Creek Generating Station ... 48 12. Total estimated transmission line collisions and bias estimates at Wolf Creek Generating Station ............................

50 1987-1968 Operational Wildlife Monitoring Report Page I of 59 INTRODUCTION Objectives This report presents results of the operational wildlife monitoring program conducted in the vicinity of Wolf Creek Generating Station (WCGS) from October 1987 through March 1988. Wildlife studies were initiated in 1973 to fulfill commitments made by Kansas Gas and Electric Company (KG&E) to the Nuclear Regulatory Commission (NRC) as a condition of the construction permit. The WCGS operational program presented here was conducted in accordance with the Final Environmental Statement (NRC 1982) and Sections 2.2 and 4.2 of the Operating License No. NPF-42, Appendix B, Environmental Protection Plan.The general objectives 6f the 1987-1988 monitoring program were to -document and assess any trends or changes due to station operation from those results reported during preoperational studies. Specific objectives were to: 1. document and assess use of Wolf Creek Cooling Lake (WCCL)by waterfowl, waterbirds, and bald eagles (Haliaeetua leucocephalus)

2. document and assess mortality due to collisions by waterfowl, waterbirds, and bald eagles with transmission facilities in the vicinity of WCCL 1987-1938 Operational Wildlife Monitoring Report Page 2 of 59 Description of Study Area Station Description Wolf Creek Generating Station is located in Coffey County approximately 5.6 km (3-5 miles) northeast of Burlington, Kansas and is operated by Wolf Creek Nuclear Operating Corporation (WCNOC). The area within the WCGS site boundary encompasses 3973 ha (9818 acres)., composed primarily of range, cropland, and woodland habitats typical of southeastern Kansas. Surrounding land-use within five miles of WCGS was composed of 40 percent agricultural land, 40 percent rangeland, nine percent woodland, five percent built-up area, and six percent miscellaneous (KGaE 1981). The power block area, including a switchyard and lime sludge pond, covers nearly 100 ha (250 acres) while the cooling lake inundates 2060 ha (5090 acres) at normal pool. A once-through cooling system pumping water from WCCL is used by the station.During its second refueling and maintenance outage, WCGS was not operating from September 28, 1987 through January 4, 1988. After achieving and operating at 100 percent, the plant was again shut down for unexpected maintenance on January 22 through February 17, 1988. The plant was then brought on line and operated at or near 100 percent capacity throughout the remainder of the study period.Wolf Creek Cooling Lake Description The cooling lake for WCGS was formed by an earth-rolled main dam approximately 3.7 km (2.3 miles) long (Figure 1), with a crest of 331.3m (1100 feet) MSL. The dam, along with five perimeter saddle dams, impounds Wolf Creek approximately 8.8 km (5.3 miles) above its confluence with the Neosho River. The upstream slopes of the main dam and saddle dams were riprapped for protection against wind-generated wave erosion while downstream slopes were seeded with an adapted native grass seed mix.

-ii 1987-1988 Op Wildlife Monitori Page 2 //,Firing RangeCove Cemetary Cove'P Locati n A eLime Sludge Location B on I Bf e Transmission affle Disc argeLines P lan Site-.ntak Location E L cationC 3 Baffle Location D Dike A i Cooling. Lake 3 jMain. Dam 3.Figure 1. Wolf Creek Cooling Lake and~ associated structures.

S I erational ng Report..3 of 59 1987-1988 Operational Wildlife Monitoring Report U Page 4 of 59 At an elevation of 331.3 m (1087 feet) MSL the cooling lake has a mean depth of 6.6 m (21.5 feet). It has a limited drainage of 50.4 sq km (19.5 sq.miles), not including the surface area of WCCL, which will not provide adequate run-off to maintain the water level during plant operation (KG&z 1974). -Additional water is pumped from industrial storage in John Redmond I Reservoir (JRR) as needed. However, no appreciable amounts of water were pumped during this study period. The cooling lake has maintained relatively I constant levels (less than one foot fluctuation) throughout the study period.The most influential structures on the cooling lake are associated with the circulating water system for WCGS. Capable of dissipating station operating heat, the system was designed for an expected maximum 17.6 C (30 F) increase in discharge water temperature.

Slightly higher discharge temperatures were actually experienced, however the influence on waterfowl and waterbirds was considered undetectable.

Baffle Dikes A and B (Figure 1) force heated I water to travel nearly the length of WCCL before being pumped through the station again. This allows for maximum heat dissipation thus increasing the 3 cooling lake's efficiency.

These dikes provided improved access which allowed for almost complete waterfowl surveys of the lake shorelines.

John Redmond Reservoir, a flood c6ntrol project controlled by the U.S. Army Corps of Engineers was completed in 1964 on the Neosho River, and lies approximately 5.9 km (3.6 mi) vest of the station and, at their closest points, less than 3.2 km (2 mi) from WCCL (Figure 2). John Redmond Reser-voir has a surface area of 3,804 ha (9,400 acres) at conservation pool and a total project area of 12,829 ha (31,700 acres). The lake is relatively shallow with an average depth of approximately 1.4 m (4-5 feet). Flint Hills National Wildlife Refuge, managed by the U.S. Fish and Wildlife Service as'part of the national migratory waterfowl program, occupies 7,487 ha (18,500 acres) in the upper reaches of the project. For the purposes of*this report, all reference to JRR includes the Flint Hills National Wildlife Refuge.

= 0 m m -n -mmm m m -I~?1'1 ED Ni c;~ '-'I ft'<0 0,flS ID Li 0 F a ID 0'1 ID 1<00.o -.00m%D 't ta 1987-1988 Operational Wildlife Monitoring Report Page 6 of 59 Transmission Line Collision Study Concern was expressed by the NRC (NRC 1982) of possible significant waterfowl collision events caused by the transmission facilities at WCGS.Incidences of bird mortality caused by impaction on transmission lines are widespread and have been studied to varying degrees (Anderson 1978, Meyer 1978, Northern States Power Company 1978, James and Haak 1979, Beaulaurier 1981, Willdan Associates 1982, and Faanes 1987). The need for monitoring the collision potential was identified in the WCGS Operating License. To detect, document, and assess the presence or lack of collision events, systematic dead bird searches were performed prior to the operation of the station. The results obtained from these were compared with those obtained during the first three.years of operation to determine if the plant caused any changes.Study Area Description Transmission facilities crossing portions of WCCL where collisions by waterfowl and vaterbirds were considered most likely to occur consisted of three 345 kv highlines and one 69 kv highline (Figure 1). The upstream portions of two WCCL coves and a lime sludge pond are traversed by these lines. From the plant switchyard, one 345 kv line (Benton line) runs in a northerly direction across the lime sludge pond then turns northwesterly across the "Cemetary Cove" of WCCL. The remaining two 345 kv lines (LaCygne and Rose Hill lines) and the 69 kv line (Wolf Creek tap of Athens -Burlington line) head in an easterly direction and cross the "Firing Range Cove" of WCCL.The portion of the Benton line of interest to this study consists *of three paired transmission wires positioned in two tiers, one pair over two, all of which were under two static wires. These lines are supported through the study area on one side of three double circuit steel towers (Figure 3) and 1987-1988 Operational Wildlife Monitoring Report Page 7.of 59 I I I U 345 kv DOUBLE CIRCUIT STEEL TOWER 346 kv" SINGLE CIRCUIT STEEL TOWER U I I U I I I 345 kv WO-OD H-FRAME STRUCTURE 69 kv STEEL POLE Figure 3. Transmission line tower configurations in the waterfowl collision study areas at Wolf Creek Generating Station.

1987-19S8 Operational Wildlife Monitoring Report Page 8 of 59 traverse approximately 214 m (700 ft) of water across the lime sludge pond and 100 m (328 ft) of the "Cemetary Cove". Vegetation surrounding this area consists of trees, unharvested native tall grass, and mowed cool season grasses in approximately equal' proportions.

Both the LaCygne and Rose Hill 345 kv power lines are configured identically with each consisting of one tier with three pairs of transmission wires positioned under two static wires. These lines are supported over the study area by five wood H-frame structures and one single circuit steel tower (Figure 3). The Wolf Creek Athens -Burlington 69 kv tap consists of three single transmission wires separated vertically and all under a single static wire and supported by two steel poles (Figure 3). The portions of these three lines of concern during this study were parallel to each other with the 69 kv line the southern-most.

The LaCygne and Rose Hill lines traverse approximately 63 m (206 ft) and 88 m (290 ft) of water across the "Firing Range Cove", respectively.

The 69 kv crosses 125 m (410 ft) of the same cove (Figure i). Vegetation surrounding this cove is largely unharvested native tall grass.

I 1987-1988 Operational Wildlife Monitoring Report Page 9 of 59 METHODS Bird Usage Usage of WCCL by waterfowl, waterbirds, and bald eagles was surveyed during the migratory season from October 1987 through March 1988. Waterbird, for the purposes of this report, refers to any bird that lives part of its life in or around water, especially the swimming, diving, and wading birds (Terres 1980), excluding waterfowl (ducks and geese). Four ground counts were scheduled each month. Of the ground surveys, two were morning counts completed by mid-morning.

The remaining ground surveys were evening counts starting during -mid-day and continuing through the evening hours.Individual species, total numbers, and distribution on the cooling lake and adjacent shoreline areas were determined with the aid of binoculars or a spotting scope. Estimates were made when large numbers prohibited actual counts of individuals.

To allow for comparisons between JRR and WCCL bird usage, ground count data of JRR was obtained from the Kansas Department of Wildlife and Parks and the U.S. Fish and Wildlife Service. These counts were usually bi-weekly morning counts conducted from September 1987 through March 1988.To test for differences between waterfowl usage between WCCL and JRR, 95 percent confidence intervals (Sokal and Rohlf 1981) were computed.Intervals were figured for. the species present in large numbers or for those which were of greatest concern with respect to station operation.

Wolf Creek Cooling Lake was divided into five separate locations, identified as A through E (Figure I), to assess waterfowl and waterbird usage. With Duncan's New Multiple Range Test (Duncan 1955), preferences for these WCCL locations were tested using ground count results. All count totals to be 1987-1988 Operational Wildlife Monitoring Report Page 10 of 59 tested were converted to number of birds per acre. Location preferences were evaluated for species that were present in large numbers or were considered most likely to cause disease, crop depredation, or collision problems.Transmission Line Collision Surveys Waterfowl and waterbird collisions with transmission facilities (Figure 1)were monitored as scheduled in Table 1. Each study area was searched for dead or wounded birds three times per month. The cove shorelines were searched as well as portions under each transmission line adjacent to the lake. The areas under the lines were searched by one observer walking in a zig-zag fashion under one side of the line and returning on the other. For each specimen found, the location, cause of death or injury if possible, and degree of scavenging were recorded.

Feather spots (feathers left after bird was consumed or removed from study area by scavengers) was treated equally with whole specimens as a collision event.Search bias and scavenger removal rates were estimated for each study area.A known number of dead birds were randomly planted under the lines and along the shorelines to simulate actual collisions.

The principal observers, not knowing the locations, then searched the areas. The number of birds found of the total placed provided an estimate of how many birds that observers normally were unable to find. The same planted birds were subsequently monitored for three consecutive days and again on the sixth-and ninth days to determine the rate of scavenger removal. Data collected were used to refine collision estimates from the dead bird searches.

Formulas used were adapted from Faanes (1987) and were as follows:

1987-1988 Operational Wildlife Monitoring Report Page 11 of 59 TABLE 1. WILDLIFE MONITORING SCHEDULE, OCTOBER 1987 THROUGH 4ARCH 1988.Oct Nov Dee Jan Feb Mar Waterfowl, Waterbird X X X X X X and Bald Eagle Survey (A)Transmission Line() x x X X Collision Survey I (A) Includes four ground surveys per month (B) Includes three surveys per month 1987-1988 Operational Wildlife Monitoring Report Page 12 of 59 Search bias SB TDBF -(TDBF)PBF where SB -search bias TDBF a total dead bird found PBF -proportion of birds found of those placed during the bias study Removal bias Rb.-TDBF SB (TDBF +SB)PNE where RB -removal bias caused by scavengers PNR = proportion of the planted birds not removed by scavengers Zuring the bias study Crippling bias CB TDBF + SB + RB -(TDBF + SB

• RB)PFA where.CB Crippling bias PBK = Proportion of birds killed and fell within the study area.Estimated total collisions ETC -TDBF + SB + RB + CB where ETC a Estimated total number of birds colliding based on dead birds found plus the study biases.

1987-19S8 Operational Wildlife Monitoring

'Report Page 13 of 59 To identify any possible correlation between the number of collisions and the number of birds using the lake, all waterfowl and waterbirds were counted before each dead bird search. Only the birds in the coves in close proximity with the study areas were counted.

.1987-1988 Operational Wildlife Monitoring Report Page 14 of 59 RESULTS AND DISCUSSION Thirty-nine species of waterfowl and waterbirds were observed during ground surveys (Table 2). Species diversity ranged from 18 species during February to 25 in October. Comprising 58 and 14 percent, respectively, mallard (Anas platyrynchos) and American coot (Fulica americana) were the most abundant species observed (Table 3). This compares closely to 54 and 18 percent respectively for mallards and coots observed during the 1986-1987 monitoring period.WCCL Bird Usage Twenty-five ground counts were completed during the 1987-1988 program. Two morning and two evening counts were performed each month from October 1987 through March 1988, except December.

Three morning and two evening surveys were completed during that month. All morning surveys were initiated during the first hour following sunrise, and ranged from 65 to 160 minutes in duration for an average of 118 minutes. All evening surveys were initiated between 1230 and 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br />, and ranged from 60 to 180 minutes for an average of 100 minutes.Of the five WCCL locations designated to assess area preferences by birds, each had unique components.

Location A represents the northern and upstream reaches of WCCL. It has a surface area of 142 ha (352 acres) which includes approximately 28 ha (70 acres) of inundated deed timber. Shorelines are associated primarily with cropland and grassland.

Prominent aquatic macrophytes consisted of narrow-leafed pondveed (Potamogeton foliosus), American pondweed (P. nodosus), and smartweed (Polygonum sp.).Approximately, seven percent (9.8 ha, 24.4 acres) of the surface area was

• - -- m.mm- m m m m m U..i TAIBLE 2. WAT'FIII.RD AND WATERFOWL CENSUS DATA COb1,RCTlD DURING GROUND SURVEYS OF WOLF CREEK COOLING LAKE, FROM OCTOBER 19137 THROUGH MARCH 1988.1981 1988 Species Oct Nov Dec Jan Feb Mar Common loon 1 1 1 7 -3 0) ---4 Pied-billed grebe 7 5 19 1 I 10 12 -I --6 Horned grebe -------2 5 Eared grebe ... .-.. .1 2 White pelican --19 .. ..- --Dbl.-cres ted cormorant 119 160 15. 10 15 11 1 20 49 Great blue heron 13 2 ---.-Great egret 16 8 ... .. .. .. .Tundra swan --1 ... .. .Gr. vhite-frtd.

goose --39 215 37 31 5 21 -100 --Snow goose -1 338 1 85 660 1392 1255 -1425 --Canada goose 109 17 240 578 417 877 1178 770 1365 528 14 Green-winged teal 35 31 48 11 17 37 -4 46 Black duck ---I 1 1 --.--Mallard 129 .659 133t 6283 8732 12471 5326 7430 9602 1113 20 60 Northern pintail 6 2 1 27 13 33 13 ---- 40 Blue-winged teal 3. 1 ---.6 -12 Northern shoveler -1 4 2 2 .. --12 Cadvall -2 34 3 1 9 -8 626 American wigeon -190 70 17 5 13 1 2 ---254 Canvasback

-60 58 1 3 9 3 2 1 ---Redhead 1 12 4 --32 14 -Ring-necked duck- 6 12 ---8 .. .. .-Lesser scaup ---I --5 4573 -Common*goldeneye

-1 21 4 20 4 10 5 14 1 I a Burflehead

-6 5 41 15 8 10 16 10 21 7 8 -00 0 o 0 o3 m -m -m m m --~ ...~ .." 0 ~TABKE 2. (Cont.)1987 1988 Species Oct Nov Dec Jan Feb Mar flooded merganser

--4 29 21 48 12 34 35 26 2 -Common merganser

---3 4 364 338 594 310 148 12 13 Red-breasted merganser

.... -.. .. 1 --Ruddy duck ---1 -.. .. .5 -Unidentified duck 143 115 55 "39 7 95 ---2 65 Osprey ---...Bald eagle --1 3 7 10 32 39 40 46 9. 1 American coot 10763 1559 255 61. 13 -2 131 1120 Killdeer 8 -8 ...- -.4 14 Long-billed dowitcher I --.. .. .. ..Common snipe 1 1 -. .. ... ---Franklin's gull 4731 498 364 .... ... .. .Ring-billed gull 36 69 172 354 729 154 36 30 9 552 53 132 Number of Species 25 28 22 20 18 24 (1) Mean.of two weekly surveys (2) Mean of three weekly surveysI-.4 M Co M 0 o C+00 0 0 :3 81S eq i. I I.I U 1987-1988 Operational Wildlife Monitoring Report Page 17 of 59 TABLE 3. GROUND COUNT FREQUENCY AND PERCENT COMPOSITION OF WATERFOWL AND WATERBIRDS USING WOLF CREEK COOLING LAKE FROM OCTOBER 1987 THROUGH MARCH 1988.Total Count species Frequency

% Total Mallard 118,777 58"American coot 27,845 14 Canada goose 13,058 6 Franklin's gull 11,184 5 Snow goose 10,974 5*Ring-billed gull 4,804' 2 Lesser scaup 4,630 2 Common merganser 3,935 2 American wigeon 1,539 1 Gadwall .1,516 1 Gr. Wh.-ftd. goose 928 (1 Unidentified duck 904 <1 Double-crested cormorant 784 01 Green-winged teal 549 <1 Misc. ducks 526 <0 Hooded merganser 471 <1 Misc. waterbirds 425 <1 Bald eagle 384 (1 Bufflehead 316 (1 Northern pintail 301 <1 Canvasback 283 <1 Total 204,133 <96 I I U I U I I I 1987-19S8 Operational Wildlife Monitoring Report Page IS of 59 covered by these plants. The area is protected from harsh winds, especially from the north, and ice cover during the 1987-1988 winter was 50 to 100 percent from the December 29, 1987 through the February 16, 1988 surveys.Location B is the area of WCCL which was expected to be and was most affected by thermal discharges and flow during WCGS operations.

The surface area is 500 ha (1234 acres) and has approximately 12 ha (30 acres) of flooded trees and brush. Shorelines are adjacent primarily to cropland and grassland.

Aquatic macrophyte growth consisted of narrow-leafed pondweed, American pondweed, trace amounts of Chars app., and smartweeds.

These made up about six percent (31.1 ha, 76.9 acres) of the total surface area. Wind-protected areas are numerous in this area. Heat and flow from the circulating water discharge kept greater than 95 percent of the area ice-free during the first two operational winters. During the 1987-1988 winter, it was kept mostly open, however, when WCGS was not operational during January and February 1988, a short-lived ice cover approached 95 percent on February 9, 1988.Location C is the largest location (913 ha, 2,255 acres) and represents the main body of the lake. There is very little inundated timber and all of the shorelines are either adjacent to grassland, including native and domestic, or rip-rap. Macrophyte growth consisted of narrow-leafed and American pondweed.

These weed beds made up approximately one percent (9 ha, 22.3 acres) of the total surface area. Few wind-protected areas exist within this location.

Thermal discharge inputs and wave action kept this location virtually, ice free during the first two operational seasons. Ice cover development during this season was approximately 50 percent or more from the January 13 through January 27, 1988 surveys.Location D comprises 331 ha (817 acres) in the southeast part of WCCL and consists of approximately 49 ha (20 acres) of flooded timber. Large areas of cropland surround this area and much of the location is protected from 1987-1988 Operational Wildlife Monitoring Report Page 19 of 59 0 north winds. Macrophyte composition was narrow-leafed and American pondweed.

Surface area of these weeds was approximately five percent (.17.8 ha, 44.1 acres) of the total area. Station thermal inputs during the first two -operational years kept a large portion of this area ice-free during the mild winters experienced.

Only recessed, wind protected portionrs(less than 25 percent) formed an ice cover. During the 1987-1988 season, greater than 50 percent ice cover was noted from January 5 through February 9, 1988.Location E is the area of WCCL which was expected to be most affected by circulating water intake flows. This area encompasses 175 ha (432 acres)and has little flooded timber. Pondweed beds were well developed in this area with almost all of the shoreline and littoral areas supporting some growth. Composition of the aquatic plants was narrow-leafed and American pondweed and Chara sp. Weed surface area was about seven percent (13.ha, 32 acres) of the total surface area. Native grasslands border much of this location.

Refuge areas from most winds are abundant.

Approximately 75 percent of this area froze during earlier operational winters. Ice cover during the 1987-1988 monitoring was relatively extensive with 50 to 100 per-cent cover present from January 5 through February 16, 1988.Threatened and Endangered Species Since 1973, several threatened and endangered birds have been observed.These include the white-faced ibis (Plegadis chihi), bald eagle, peregrine falcon (Falco peregrinus), and interior least tern (Sterna antillarum).

The prairie falcon (Falco mexicanus), previously listed as threatened and 3observed within the WCGS area, was removed from the threatened list as of..May 1, 1987 (Kansas Administrative Regulations 1987). Similarly the white-faced ibis was added. During the 1987-1988 winter, only the bald eagle was confirmed on the site environs.

The ibis was observed on WCCL during 1987-1988 Operational Wildlife Monitoring Report Page 20 of 59 September of 1983, however not since that time. Only the bald eagle used WCCL consistently.

during the winters. The others may be expected to be occasional visitors in the future and station operation is not expected to impact this.The bald eagle, considered endangered on Kansas and federal lists (Kansas Administrative Regulations 1987, U.S. Department of Interior 1987), was a common winter resident on WCCL. They were first observed during mid-November 1987 with the largest count being 48 observed on February 5, 1988.A peak count of 104 were counted on the JRR and Neosho River area on February 23, 1988. Of the birds observed on WCCL, adults and juveniles comprised 57 and 43 percent, respectively.

There was a higher percentage of juvenile birds than observed during previous monitoring.

Eagle usage of WCCL prior to plant operation was as a feeding and loafing site. In this respect, use during operational monitoring did not appear to change. During the first two years of operations, eagle numbers declined (WCNOC 1987a). However, eagle numbers increased during the 1987-1988 monitoring enough (Figure 4) that when averaged with the previous operational seasons, an overall increase is obvious (Figure 5). Average operational usage on WCCL approached that on JRR. Peak numbers, occurring during February, were still greater on JRR, but because the count totals for JRR comprising the average presented (Figure 5) were variable, no statistical differences (p_<O.05) could be detected.Three primary components of eagle winter habitat includes communal nocturnal roost sites, diurnal perch (loafing) sites, and a readily available food source (Steenhof 1978). No nocturnal nest sites have been identified on or around WCCL. Diurnal perch sites are present on both reservoirs and the quantity and quality of these have not changed appreciably after plant oper-ation. Since these two winter habitat uses or requirements have been con-sistent throughout preoperation and operation, they were not considered to have contributed to changes in eagle usage of WCCL.

1987-1988 Operational Wildlife Monitoring Report Page 21 of 59 351 I LL.'-30 z w 50ol I K\.3 0 YEAR MEAN I WCCL JRR ..........

I U Z 40> 30-J<c20 z U'1 I 1 81-82 82-83 83-84 84-85 85-86 86-87 MIGRATION SEASON 87-88 I i Figure 4.Bald eagles per survey for Wolf Creek Cooling Lake and John'Redmond Reservoir compared with. mean winter air- temperatures and the 1951-1980 30 year mean (December through February) in Topeka, Kansas. Temperature data obtained from the National Weather Service. Confidence limits for the bald eagle data were illustrated only if significantly (pLO.05) different.

I 1987-1988 Operational Wildlife Monitoring Report Page 22 of 59 PREOPERATIONAL-OP E R A T IO0 N A L ......5 z< 4 w w>3 cc-J n 0 101 N D J F M MONTH Figure 5. Preoperational and operational (three year means) bald eagle usage of Wolf Creek Cooling Lake and John Redmond Reservoir.

Confidence limits not illustrated were not significant (p'<O.05).

.... I 1987-1988 Operational Wildlife Monitoring Report Page 23 of 59 Of the requirements, food availability between the reservoir areas differed the most. Bald eagles have opportunistic foraging habits with waterfowl and fish being major components.

Eagles often shift from one to the other during the course of a winter (Southern 1963, 1964, Lish and Lewis 1975, Steenhof 1978, Meyer 1980, Griffin et al. 1982, Ecological Analysts 1983, Griffin and Basket 1985, Kiester et al. 1987).Waterfowl should not be overlooked although they probably weren't as important as fish in the distribution of eagles during operation.

As refer-enced above, eagles commonly exploit waterfowl resources, but usually only when fish become unavailable.

Bald eagles seem to be inefficient predators 4 on healthy waterfowl (Steenhof 1978, Griffin et al. 1982) although weakened, crippled,and dead waterfowl are readily taken (Lish and Lewis 1975, Griffin et al. 1982, Steenhof 1978, Todd et al. 1982, Kiester et al. 1987). The frequency of crippled waterfowl, especially hunter-caused was not known in the study area, but because hunting was permitted in the JRR area, except park areas and large portions of the Flint Hills National Wildlife Refuge, and not allowed on the WCCL proper, it may be assumed that greater numbers were available to eagles on JRR.- However, because waterfowl hunting seasons closed for most species during January, the importance of hunter crippled waterfowl during February, when eagle numbers were greatest (Figure 5)should have been reduced. Also, fluctuations in waterfowl numbers on WCCL during the operational winters were not necessarily followed by corresponding changes in eagle numbers further indicating that waterfowl as a food source was not of primary importance for this wintering bald eagle population.

Fish appear to be preferred when available.

Gizzard shad (Dorosoma cepedianum) in this region are susceptible to winter kill and this species occurs in much greater numbers in JRR and the Neosho River than WCCL (WCNOC 1987b). Shad are highly'preferred by bald eagles, probably because of its vulnerability especially during winter in the ice-free head waters and 1987-1988 Operational Wildlife Monitoring Report Page 24 of 59 tailwaters of lakes (Lish and Lewis 1975, Steenhof 1978, Ecological Analysts 1983). Fish disoriented or killed as they pass through flood gates below dam" projects are easy prey for eagles. John Redmond and the associated Neosho River reaches provide these types of areas. The cooling lake, on the other hand, does not have a major drainage stream flowing into it, thus continuous discharges below the dam exposing these fish are not present. In addition, *the availability to eagles of winter-killed fish, mainly shad, increases in the main bodies of reservoirs as the ice cover thaws (Steenhof 1978., Meyer .1980, Griffin et al. 1982). Since the addition of heated effluents from plant operations, this condition .is almost lacking on WCCL while still prevalent on JRR. Thus, during the first two years of operations, it was evident that fish resources for eagles occurred in both greater concentrations and, because they were more vulnerable, were easier to obtain on JRR and the Neosho River than WCCL.The 1987-1988 winter was not appreciably colder nor warmer than the previous two operational seasons (Figure 4). It was shown that during mild winters combined with the heated effluents, WCCL did not provide as readily avail-able forage as did JRR (WCNOC 1987a). This was because of the relatively short-lived ice-cover on JRR during those winters which continuously thawed and refroze exposing winter killed shad on the main-body of the reservoir.

Changes in availability of food between the reservoirs was likely respons-ible for the large increase of eagles observed during the 1987-1988 winter.Ice-cover was much more extensive on WCCL during this winter due to the absence of continuous heated effluents.

When JRR was ice-covered, circulating water flows and intermittent heated discharge from the station forced the ice-cover on WCCL to thaw, break-up, and refreeze at varying intensities throughout the winter. As stated above, winter-killed fish which are continuously exposed like this are known to attract bald eagles In addition, the power level transients experienced by WCGS during January and February, attracted and concentrated gizzard shad in WCCL where normal 1987-1988 Operational Wildlife Monitoring Report Page 25 of 59 winter shad mortality combined with the open water/ice-cover interspersion likely increased attractiveness to those eagles. A documented fish kill, cause suspected to be cold shock, during mid-February in the circulating water discharge area undoubtably provided easily obtained and abundant food resources for bald eagles. The presence of shad remains. under perch trees used for feeding by the eagles in this area supports this assumption.

These factors were the most obvious differences in food availability during the 1987-1988 winter from the previous operational years. Bald eagles, having very opportunistic feeding habits, took advantage of these circumstances.

The discharge area (Location B) had higher eagle usage, significantly (p<O.05) greater to all other areas except Location A (Table 4). The lack of any consistent location significantly attracting eagles from year to year demonstrates that usage was variable around the lake. The usage during 1987-1988 shows that numbers were much greater than past seasons in an area most vulnerable to station operational impacts. It is expected that during normal to mild winters, continuous operation will not attract these numbers. During colder winters, the JRR eagles will likely be forced to range over a greater area to find food thus usage of WCCL may become greater while at- the same time become more variable on JRR. This will cause statistical differences to be harder to detect. It appears, based on the above discussions, that intermittent plant operations which attract and concentrate WCCL fishes, possibly exposing them to cold shock, will attract area bald eagles. This will be especially true if JRR maintains an ice-cover for an extended period. Usage during severe winters with the plant operating cannot be determined at this time. It has been 6hown, however, that heated water was not of greater importance to wintering bald eagles during cold as opposed to mild winters (Ecological Analysts 1983).

1987-1988 Operational Wildlife Monitoring Report Page 26 of 59 TABLE 4. SIGNIFICANT DIFFERENCES BETWEEN RANK LOCATION MEANS OF BALD EAGLES USING WOLF CREEK COOLING LAKE.Winter 1983-1984 1984-1985 1985-1986 1986-1987 1987-1988 Total.Counted 51 115 82 44 395 Location Preference AC BD E E B,C A D C B D A E CBEAD E CD A B (i) Line underscores ranked (lease to greatest) location means that were not significantly different (p<O.05).

1987-1988 Operational Wildlife Monitoring Report Page 27 of 59 Duck Usage Total ducks counted on WCCL and JRR during the 1987-1988 season was simlar to that observed during most winters monitored (KG&E 1983, 1984, 1986a, 1986b, and WCNOC 1987a; Figure 6). Although JRR attracted higher annual averages than WCCL, the differences were not significant (p!O.05) except during the 1983-1984 winter. ' Due to severe weather conditions during December 1983 (Table 5) the normally high late winter concentrations (predominantly mallards) were not present on WCCL during that winter.Conversely, better than normal waterfowl

abitat conditions existed on JRR during that season which attracted many earlier migrating ducks.Of the ducks observed on WCCL, 92 percent were dabblers, seven percent divers, and one percent unidentified ducks (Table 6). This in very similar to past. seasons. As during all past monitoring seasons, mallard was most common comprising 89 percent of total. Lesser scaup (Aytya affinis), common merganser (Mergus merganser), American wigeon (Anas americana), and gadwall (Anas strepera) were other common ducks observed, however, making up collectively only eight percent of the total.As during preoperational monitoring, John Redmond attracted the largest por-tion of fall (October and November) migrating ducks (Figure 7). On WCCL most of these ducks were comprised of blue-winged teal (Anas discors), American wigeon, and gadwall. These species plus large numbers of northern pintail (Anas acuta) were present on JRR. The attraction to JRR over WCCL of larger numbers of ducks during the fall represents a pattern obvious during all years monitored.

Although more prevalent in past seasons, natural lake level increases during the fall of 1987 were present (Figure 8)which providbd higher quality duck habitat than the constant lake level of WCCL. The increasing levels of JRR created newly flooded shallow areas.Water bodies with these recently flooded areas have been found to be preferred by waterfowl over those with stable water levels (Chabreck et al.1974, Gasaway et al. 1977, Johnson and Swank 1981).

1987-1958 Operational Wildlife Monitoring Report Page 28 of 59 40 30 WC CL'" JRR .........MALLARD I I U I U I I I U I I I 0%0 z z 2 10 3.0 20 0 COMBINED DUCK 1 Figure 6.81-82 82-83 83-84 84-85 85-86 86-87 .87-88 MIGRATION SEASON Annual combined duck and mallard usage comparisons between John Redmond Reservoir and Wolf Creek Cooling Lake. Confidence limits not illustrated were not significant (p=0.05).

Combined duck data includes September through March surveys except during 1987-1988 season where October through March surveys were used.Mallard data includes November through February surveys.

1987-1988 Operational Wildlife Monitoring Report Page 29 of 59 AVERAGE AIR TEMPERATURES FOR Table 5. NATIONAL WEATHER SERVICE MONTHLY TOPEKA, KANSAS.Temperature (oF)Winter of Dec Jan Feb Preoperational 1981-1982 30.1 (.1.7)(1) 21.9 (-4.1) 28.5 (-4.0)1982-1983 35.8 (+4.0). 32.5 (+6.5) 36.1 (+3.6)1983-1984 14.4 (-17.4) 26.0 (0.0) 40.2 (+7.7)1984-1985 36.8 (+50.) 19.9 (-6.1) 25.6 (-6.9)Operational 1985-1986 25.1 (-6.7) 35.8 (+9,8) 32.5 (0.0)1986-1987 34.6 (+2.8) 29.7 (+3.7) 40.3 (+7.8)1987-1988 35.9 (+4.1) 28.0 (+2.0) 30.8 (-1.7)(1) Variance from 30 year average, 1951 through 1980.

1987-1988 Operational Wildlife Monitoring Report Page 30 of 59 TABLE 6. GROUND COUNT FREQUENCY AND PERCENT COMPOSITION OF DUCKS USING WOLF CREEK COOLING LAKE FROM OCTOBER 1987 THROUGH MARCH 1988.Total Count Species Frequency

% Total Mallard 118,777 89 Lesser scaup 4,630 3 Common merganser 3,935 3 American wigeon 1,539 1 Gadwall 1,516 .Unidentified duck 904 1 Green-winged teal 549 <1 Hooded merganser 471 <1 Bufflehead 316 (1 Northern pintail 301 .<Canvasback 283 <1 Redhead 190 <1 Common goldeneye 181 .0 Ring-necked duck 49 <1 Blue-winged teal 44 <1 Northern shoveler 43 <1 Ruddy duck 13 <1 Black duck 4 <1 Red-breasted merganser 2 <(Total 133,747 <98 I 1987-1988Operational Wildlrfe'Monitoring Report Page 31 of 59 F II 40 30 WCCL-,---JRR ......PREOPERATIONAL I I I I%0 z IC UJ C*z 0 2>;20 10*

eo* 0* ,": .... W I i 3 2 1!OPERATIONAL I U I I.1 0 N D J F M MONTH Figure 7. Preoperational and operational (three year means) combined duck usage of Volf Creek Cooling Lake and John Redmond Reservoir.

Confidence limits not illustrated were not significant (piO.05).I

-m mmONE -,d 10 &M 1Wj 1090 1080 1070 1060---a (I)-J w WýWCCL.JRR* Uo.,,,. ~ o *0 1040 14 0 28 11 N 26 a 23 -8 20 3. 17 2 16 30 D J F M H 1 ID:3 kO* -IM~*: Mi! 0 MJ .DATE Figure 8. Biweekly lake level elevation

('NSL) averages for Wolf Creek Cooling Lake and John Redmond Reservoir.

1987-1988 Operational Wildlife Monitoring Report Page 33 of 59 An increase of pondweed (Potamogeton spp.) on WCCL was noted during the fall of 1985. The surface area covered by pondweed during the fall of 1986 was similar to that noted during 1985 (KG&E 1986a). Mechanical removal.of selected pondweed areas to reduce plant operating problems took place during the fall of 1987. However, because of the relatively small area involved, no waterfowl usage changes were observed.

Since pondweed is an important natural food item of the most numerous ducks counted during early fall 3 (Kieth and Stanislawski 1960, Thompson 1973, Duke and Chabreck 1975, Bellrose 1976, Johnson and Swank 1981, Paulus 1982) it was expected that a corresponding increase in early migrant numbers would happen. This was not realized as September and October usage declined 71 percent from 1985 to 1986. Although no September surveys were completed in 1987, October numbers increased by 41 percent of October 1986 numbers. Even with this increase, it is still apparent that the fluctuating water levels provided by JER was more attractive to early season ducks than the existence of extensive natural aquatic plants offered by WCCL. Greater duck usage, however, would probably occur on WCCL if autumn lake level fluctuations are absent on JRR.3 Winter duck usage in the area was almost entirely made up of mallards which will be discussed separately below. Spring usage in the vicinity of WCGS I was similar to past studies, preoperational and operational.

John Redmond Reservoir attracted most of the ducks in the area (Figure 7). Future station operation is not expected to alter this.Mallard: 3 A total of 118,777 mallards was observed during the 1987-1988 monitoring accounting for 89 percent of all ducks observed (Table 6). A peak of 26,510 was counted on December 17, 1987. Contrary to the first two operational winters, the 1987-1988 survey average (November through February) for WCCL 1987-19S8 Operational Wildlife Monitoring Report Page 34 of 59 was smaller than that on JRR. Although no significant (p<O.05) differences were present, mallard usage of the two reservoirs this season was closer to.the preoperational winters (Figure 6).Station operation was expected to preclude ice formation on most of WCCL during the winter and as a result, larger number of some waterfowl species may be induced to remain in the area longer (NRC 1982). Longer usage periods of fall migrating ducks (wigeon, gadwall, blue-winged teal, and.others) were not observed during all operational winters. These species left the area, during both preoperational and operational studies before ice-cover preclusion would have played a role, usually during early December.

Most ducks having peak uses on both JRR and WCCL during October or ilovember were not present in large numbers when normal weather conditions would cause ice formation (early December).

Principal food resources of these species are natu'ral aquatic items (Bellrose 1976), likely Potamogeton spp. in WCCL and these are not as readily available in large quantities as winter progresses, even with heated effluents.

Based on this, it is suspected that station operation will not induce most of these species to stay in the area any longer than before. It is reasonable to assume that in this case the birds' inherent need to migrate coupled with declining natural food resources and increasing energy demands played a greater role in the longevity of each species usage of WCCL than did ice-cover preclusion by station operation.

Mallards, however, were present! throughout the winter season and have commonly wintered in the area (KGa& 1983, 1984, 1986a, and 1986b). This species relies heavily on cultivated grains during winter and to a lesser extent on natural foods (Bellrose 1976). Since this species occurs in the greatest numbers during winter and does not depend to a large extent on natural food resources, the winter mallard population was considered most likely to be influenced by the lack of ice-cover on WCCL. For the purposes of illustrating this, a winter population.was considered present when at 1987-1988 Operational Wildlife Monitoring Report Page 35 of 59 least 8,000 were counted for two consecutive counts. A season ended when less than 8,000 birds were counted for two consecutive surveys. Surveys totalling more than 10,000 were used in past studies to illustrate this (WCNOC 1987a), however, because consistent usage greater than 10,000 was not present during the 1987-1988 monitoring, 8,000 was used to better reflect WCCL usage longevity.

This was shown for JRR and WCCL data (Figure 9).None of the operational seasons (1985-1986 through 1987-1988) were consistently longer than the preoperational winters (1981-1.982 through 1984-1985). ° Large numbers of mallards have basically stayed throughout the winters, usually on JRR. What is evident is the time the -larger mallard concentrations in the area were present on WCCL than on JER during the operational seasons. This coincided with freeze-up of JRR 'during 1985-1986. Less than 10 percent of WCCL froze during the same time. Complete ice-cov.er, though present for a short duration (less than one week) was not as extensive during the 1986-1987 winter on JRR and almost lacking on WCCL, on which only the upstream reaches of the coves developed ice cover. Except for December 1986, monthly average temperatures since plant operation have generally been above normal (Table 5). Even with the relatively mild operational winters, the heated effluents did preclude the formation of extensive ice-cover on WCCL when compared with JRR and this condition greatly influenced the observed increase in late winter mallard attraction to WCCL during the first two operational years. The 1987-1988 mallard usage however, was more similar to preoperational seasons. This was because WCGS was not operating through much of the winter. When the operational average is compared to the preoperational average (Figure 10) it is still apparent that JRR attracts the earlier migrants and WCCL the later migrants and winter residents.

This appears primarily a function of ice-free water on WCCL caused by heated effluents from station operation.

Other factors attracting these birds should not be overlooked.

These include seclusion, wind protection, and the proximity of available food resources.

It should not be inferred here that these factors were not m -~ -in ~~ o ~ ~L 87-S0 80-8 7 z 0\W co*Z 84-85 0 83-84 82-83 81-82 111111111 iIIpIpIIIlIIIIIiIjpphiiiiiiUA WCCL JRR inipmiH a 8 IIItllll 0 ...-.9 NO SURVEY8 >o000 9.... i M I-CD-3'*03 10 c+ 00 0 (DP I'0*)~ 03%nI P, P%.D 41.-1 16 31 0 1 15 31 1 16 31 1 15 31 1 15 31 1 15 31 N4 D J F M DATE Figure 9. Length of migration season for mallards on Wolf Creek Cooling Lake and John, Redmond Reservoir.

1.987-1988 Operational Wildlife Monitoring Report Page 37 of 59 40 30 WCCL-JRR ..........

PREOPERATIONAL I I 2 0 Zi 2'2 Figure 10.OPERATIONAL I I I 0 N D J F M MONTH Preoperational and operational (three year means) mallard.usage of Wolf Creek Cooling Lake and John Redmond Reservoir.

Confidence limits not illustrated vere not significant (piO.05).I 1987-1988 Operational Wildlife Monitoring Report Page 38 of 59 present or comparable on JRR and the Flint Hills National Wildlife Refuge.In fact, it is probable that these areas provided more of these factors than WCCL. However, these were present on and around WCCL and will be considered as they relate to the cooling lake. Since WCCL was closed to public access, harassment of these mallard concentrations was minimal. The cooling lake served as a refuge for these wintering birds. Aside from the lack of hunter disruption, protection from winter winds were available to mallards since the larger coves offered escape from both north and south winds. Probably most important, however, was the combination of these factors with the presence of an available food supply adjacent to WCCL.Agricultural crops are heavily used by wintering mallards (Bellrose 1976, Jorde.et al. 1983, Baldassare and Bolen 1984). Harvest of fall crops, primarily soybeans, milo, and to a lesser degree,' corn was delayed by wet weather accompanied by the lack of substantial ground freezing during the first two operational years. Harvest attempts in some fields were delayed well into January of each season. Many of these fields were within 300 meters (328 yards) from the WCCL shoreline.

Weather conditions were closer to normal during the fall of 1987 which allowed harvest to be completed, for the most part, before December.

Waste grains were still heavily, used, however.The importance that these factors had in affecting the mallard distribution is reinforced by the area on WCOL these birds used most frequently.

Of the five designated areas, Location D was significantly (p<O.05) preferred over all other WCCL locations (Table 7) during the first two operational winters. Although not to the same extent, this area was preferred during the 1987-1988 season also. Large wind-protected coves and adjacent cropland characterize this area. Thus, the suggested factors contributing to the late winter mallard attraction to WCCL were present to the greatest degree in the area of WCCL these mallards preferred to be.

I.I I 1987-1988 Operational Wildlife Monitoring Report.Page 39 of 59 TABLE 7. SIGNIFICANT DIFFERENCES BETWEEN RANKED LOCATION MEANS OF MALLARDS.AND CANADA GEESE USING WOLF CREEK COOLING LAKE.Total Location Species Winter Counted Preference Mallard 1983-1984 16,878 C E B D A 1984-1985 97,118 C B D E A 1985-1986 84,103 C E A B D 1986-1987

.192,380 E B A B D 1987-1988 118,777 C E A B D Canada goose 1983-1984 3668 C D A E B 1984-1985 6453 A C B D E 1985-1986 11,587 C A B E D 1986-1987 14,584 C B E D A 1987-1988 13,058 C D B A E (1) Line underscores ranked significantly different (least to greatest)(p<O.05)location means that are not 0 1987-1988 Operational Wildlife Monitoring Report Page 40 of 59 Goose Usage The snow goose (Chen caerulescens) and Canada goose (Branta canadensis) were the most common geese observed.

This has been consistent with past seasons on both WCCL and JRR. Snows and Canadas on WCCL comprised 44 and 54 percent of the total geese observed (Table 8). The greater white-fronted goose (Anser albifrons) was the only other goose species observed.

This species has not been prevalent on WCCL, however, it was present at times in large numbers in the JRR area.Snow goose usage of WCCL has been low when compared to JRR, especially before plant operation (Figure 10). Use of WCCL can be characterized as being sporadic.*

Usually one or two large groups used the cooling lake for a short time period compared to consistently using JRR throughout, the winters. Since the existence of WCCL until plant start-up, JRR had significantly (p=O.05) greater numbers. However, these differences were not significant (p=O.05) during the first two operational seasons. The 19S7-1988 winter showed numbers closer to preoperational years.A total of 13,058 Canada geese was observed on WCCL during the 1987-1988 season (Table 8). This represents 10 percent fewer birds than in 1986-1987. The 1987-1988 total on JRR was 3.3 times greater than the previous winter (Figure 11). The increasing trend identified on WCCL.(WCNOC 1987a)was not maintained during the 1987-1988 winter. This may be because conditions were closer to those during operational season because WCGS was not producing power during much of the winter. The operational monthly average differences were not as great between the reservoirs signifying increased usage of WCCL after operations began (Figure 12). Present .during the preoperational period, however to a much greater degree during operational monitoring, was the late winter Canada increase on WCCL not evident on JRR.

1987-1988 Operational Wildlife Monitoring Report Page 41 of 59 TABLE 8. GROUND COUNT FREQUENCY AND PERCENT COMPOSITION OF GEESE USING WOLF CREEK COOLING LAKE FROM OCTOBER 1987 THROUGH MARCH 1988.Total Count Species Frequency

% Total Canada goose 13,058 54 Snow goose 10,974 44 Gr. wh.-ftd. goose 928 4 Total 24,960 100 1987-1988 Operational Wildlife Monitoring Report Page 42 of 59--100 0 0 x< 75> 50 M 25 z I WCCLV=U=JRR ..........

CANADA GOOSE II ID I I I ,I ,I II 11 II II II ID gI g**1.1* 4 I a-u 0 0 z ,cc co-j z z 15 10 5 SNOW GOOSE I 5* I 1 10 * .81-82 82-83 83-84 .84-85 86-86 86787 87-88 MIGRATION SEASON Annual snow goose and Canada goose usage-comparisons between Wolf Creek Cooling Lake and John Redmond Reservoir.

Data includes November through February surveys. Confidence limits not illustrated were not significant (piO.05).Figure 1 1.0 B 40 30 I 1987-1988 Operational Wildlife Monitoring Report Page 43 of 59!6497*1*

• JRR ......*. e PREOPERATIONAL

,, .*,,, r %--..,, -,.1 t' r 0 0 0 C,,)q-z z 0.22'.1 0 U OPERATIONAL

...........

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

10 Figure 12.Preoperational and operational (three year means) Canada goose usage of Wolf Creek Cooling Lake and John Redmond Reservoir.

Confidence limits not illustrated were not significant (pO.05).

1987-1988 Operational Wildlife Monitoring Report tI *Page 44 of 59 0 Agricultural grains are used heavily by Canadas, even when natural foods are abundant, and especially when these grain fields are large and open with an 0 undisturbed body of water nearby (Bellrose 1976, Craven and Hunt 1984).This type of area was provided-by WCCL, especially along the eastern coves.Canadas, however, did not significantly (p<O.05) use these areas (Location D and E) of WCCL (Table 7). It appears that Canada usage of the five lake locations was consistent with no single location being preferredesignifican-tly year after year. This seems to fit with the way these birds used crop fields surrounding WCCL. Smaller groups, -when compared to mallards or snow geese, fed more opportunistically and did not concentrate in any particular area of WCCL for long periods.1 Transmission Line Collision Study 3 A total of 21 carcasses representing 8 species were found during the 1987-1988 monitoring (Table 9). None of these were listed as threatened or 3 endangered species. The most common species found was the mallard. Most specimens were either partially or totally scavenged with some being 3 represented by feathers only. Almost all of the birds found fresh had injuries considered typically caused by colliding with power lines. These 3 included broken necks, various head and breast abrasions, and broken wings.Since the specimens were found under the highlines and assuming worst case, death of all birds, scavenged or not, was considered to have been caused by line impaction unless causes by other means could be identified.

Several variables in monitoring waterfowl collisions by searching for victims were recognized and attempts were made to account for some of 3 these. Search bias, scavenger removal, and crippling bias are inherent variables which tend to cause dead bird searches, like the ones completed at WCGS, to underestimate actual collision mortality (Anderson 1978, Northern States Power Company 1978, Meyer 1978, James and Haak 1979, Beaulaurier

• 1981, Willdan Associates 1982, and Faanes 1987).

1987-1968 Operational Wildlife Monitoring Report Page 45 of 59 TABLE 9. SPECIES LIST, LOCATION, AND NUMBER OF MORTALITIES OBSERVED DURING COLLISION SURVEYS OF WOLF CREEK COOLING LAKE FROM NOVEMBER.1987 THROUGH FEBRUARY 1988.Cemetary Lime Sludge Firing Range Month Species Cove Pond Cove November Double-crested cormorant 3 Black-crowned night heron 1 Mallard 2 Duck op. 1 Coot 2 1 Passerine sp. 1 December Mallard I January Double-crested cormorant' I Mallard 2 Red-winged blackbird February Double-crested cormorant 1 Mallard Cadvall 1 Common crow 1 Bird sp. 1 Totals 7 2 12 21 1987-1958 Operational Wildlife Monitoring Report Page 46 of 59 Search bias refers to the number of collision mortalities that are assumed to be in the area, but the observers normally are unable to find. Seventeen dead birds were planted to measure the searcher recovery in the WCGS studies. Four gadwall, one hooded merganser (Lophodytes cucullatus), tio greater prairie chicken (Tympanuchus cupido), and 10 northern bobwhite (Colinus virginianus) were used. Recovery in each area was 37.5, 33.3, and 50.0 percent in the Firing Range Cove, Lime Sludge Pond, and the Cemetery Cove respectively (Table 10). With all areas combined, 41.2 percent of the planted birds were found.Scavenger removal was measured using the same planted birds. By day six of the removal monitoring, all planted birds were scavenged (Table 11). A high percentage were eaten by the third day. Scavenged birds in all areas vanishing without a trace comprised 58.8 percent. Common mammalian predators or scavengers either seen or leaving tracks in the study areas were coyote (Canis latrans), raccoon (Procyon lotor), opossum .(Didelphie marsupialis), and striped skunk (Mephitis mephitis).

Red-tailed hawk (Buteo jamaicensis);

northern harrier (Circus cyaneus) and bald eagle were common birds of prey frequenting the areas.Crippling bias refers to the number of birds colliding with the transmission lines and falling outside of the study area. Dead bird searches would not account for these. Formal collision observations were not completed at WCGS. Observed crippling rates reported by Meyer (1978) was 75 percent. and by James and Haak (1979) was 73 percent. Both of these studies were completed in Oregon and Washington.

Assuming that birds in this area were as likely to sustain similar injuries by striking a transmission line as those reported by those studies, an average between these (74 percent) was used to compute the crippling adjustments for the this study. Based on this, 74 percent of the birds colliding with the lines did not fall in the study areas. Incidental collision sitings by station biologists suggested slightly higher percentages may actually be able to fly away for some distance after colliding.

p j I 0 II I I U I I I I I I I I 1987-1988 Operational Wildlife Monitoring Report Page 47 of 59 TABLE 10. SEARCHER RECOVERY OF PLANTED BIRDS DURING COLLISION LINE STUDIES AT WOLF CREEK GENERATING STATION Location Number Planted Number Found Percent Found Firing Range Cove 8 3 37.5 Cemetery Cove 6 3 50.0 Lime Sludge Pond 3 1 33-3 All Locations Combined 17 7 41.2 1987-1988 Operational Wildlife Monitoring Report Page 48 of 59 TABLE 11 .SCAVENGER REMOVAL RATES OF PLANTfD DEAD BIRDS IN THE TRANSMISSEON LINE STUDY AREAS AT WOLF CREEK GENERATING STATION.Cumulative Cumulative Cumulative.

Days Number Number Removed Percent Location Elapsed Planted Scavenged No Trace Removed Firing Range Cove 8 5 3 37.5 2 5 3 37.5 3 6 3. 37.5 6. 8 3 37.5 9 8 3 37.5 Cemetery Cove 1 6 4 4 66.7 2 5 4. 66.7 3 6 5 83.3 6 6 5 83.3 9 6 5 83.3 Lime Sludge Pond 1 3 1 1 33.3 2 2 1 33.3 3 2 1 33.3 6 3 2 66.7 9 3 2 66.7 All Locations Combined 1 17 10 8 47.1 12 8 47.1 3 14 9 52.9 6 17 10 58.8 9 17 10 58.8 1987-1988 Operational Wildlife Monitoring Report Page 49 of 59 Another possible bias was. unsearchable habitat (James and Hank 1979, Beaulaurier 1981, Willdan-Associates 1982, and Faanes 1987). This refers to the proportion of habitat in each study area that was not searchable, such as the areas under the lines crossing over water and very dense vegetation.

Parts of all study areas at WCGS crossed over water. Those collisions landing in the water were certainly subjected to being blown away from the study areas. On the same token, winds blowing towards the study areas would concentrate collisions along the shorelines which were searched.

Also, when ice cover was present, those areas were easily scanned for dead birds.Dense vegetation was also very prevalent in the study areas. In the Firing Range Cove area, strips were mowed under the transmission lines during, the 1985-1986 and the 1986-1987 monitoring.

This was done to aid in finding collisions.

However, no increase in observed collisions were .evident.Also, it was felt that the planted bird study would measure the searchers' abilities to recover collision victims and account for the unsearchable habitat bias. For these reasons and the logic used for birds falling in the water, it was felt that the biases presented by unsearchable habitat was of minor concern at the WCGS study sites.After making adjustments to the total dead birds found to account for the search bias, scavenger removal bias, and crippling-bias, an estimate of the total transmission line collisions can be.derived (Table 12). Because many assumptions have to be made when making these adjustments and the sample size used to measure the biases was small, a large amount of variation.

exists. Care must be taken in relying heavily on these estimates because of this large chance of error involved.

However, it is felt that these estimates represent maximum numbers which are worthy to assess the significance of transmission line collision mortality at WCGS.

m im m m m m-i o.n TABLE 12. TOTAL ESTIMATED TRANSISSI[ON LINE STATION FROM 1984 THROUGH 1988.COLLISIONS AND BIAS ESTIMATES AT WOLF CREEK GENERATING Dead Birds Search Removal Crippling Estimated Percent of Winter of Location Pound Bias Bias Bias Total Collisions Count Frequency 1983-1984 Firing Range Cove 23 61.3 50.6 383.9 518.8 Cemetery Cove 1 1.0 10.0 34.2 46.2 Lime Sludge Pond 1 2.0 6.0 25.6 34.6 Combined 25 35.7 86.6 419.2 566.5 0.5 1984*-1985 Firing Range Cove 26 43.3 41.6 315.6 426.5 -Cemetery Cove 3 3.0 29.9 102.3 138.2 Lime Sludge Pond I 2.0 6.0 25.6 34.6 -Combined 30 42.8 103.9 502.9 679.6 0.2 1985-1986 Firing Range Cove 26 43.3 41.6 315.8 426.7 Cemetery Cove 22 22.0 219.5 749.9 1013.4 Lime Sludge Pond 12 24.0 72.1 307.7 415.8 Combined r 85.6 207.8 1005.8 1359.2 0.5 1986-1987 Firing Range Cove 9 15.0 14.4 109-3 174.7 -Cemetery Cove 6 6.0 59.9 204.6 276.5 Lime Sludge Pond 13 26.0 78.1 333.3 450.4 -Combined 28 40.0 97.0 469.6 634.6 0.2 1987-1988 Firing Range Cove 12 20.0 19.2 145.7 196.9 Cemetary Cove 7 7.0 69.8 238.6 322.4 Lime Sludge pond 2 4.0 12.0 51.2 69.2 Combined 21 30.0 72.8 352.4 476.2 0.2-.4:5 M~0 a -0 0 1987-1988 Operational Wildlife Monitoring Report Page 51 of 59 Anderson (1978) reported that 0.2 to 0.4 percent of the peak bird usage on Lake Sangchris, Illinois, were killed by colliding with transmission lines during each fall. Rusz et al. (1986) had similar collision rates at the Midland Energy Center in Michigan as Anderson (1978), however, the percentage of the peak usage count was not reported.

For two study seasons, Faanes (1987) estimated that 1332 birds were killed by transmission line collisions.

The fall collision percentage of the fall peak count was roughly 6 percent. Meyer (1978) at Lower Crab Creek in Washington estimated 40 birds collided with the highlines and a maximum of 9000 were estimated to be using the area. The estimate represents 0.4 percent of this peak. At Bybee Lake'in Oregon, (Meyer 1978) estimated that a maximum of about 12,500 birds were using the area and estimated 28 ducks collided in the study area. This represents about 0.2 percent. James and Haak (1979), Beaulaurier (1981) and Willdan Associates (1982) all reported similar results as Meyer (1978).At WCGS the collision estimated percentage of the total birds counted using WCCL each year ranged from 0.2 to 0.5 percent (Table 12). These rates are similar to those referenced above, however they are not presented as a percent of peak usage, but as the percentage of the sum of all counts.These are considered comparable because no correlation was present between the number of birds using each study area and the number of dead birds found. Increasing bird usage did not correspond to increased collision mortality.

Likewise, greater evidence of collisions was not necessarily during peak usage periods. Anderson (1978) did find such relationships.

Aside from this, care must also be taken when comparing the studies above with each other and with this study. Weather conditions, transmission line positions to waterfowl concentrations and flights, species compositions, among other factors were likely to have been different from study to study.However, it is felt that they do show that the order of magnitude of the estimates are close, which implies that they are somewhat useful in comparing similarities.

1987-1988 Operational Wildlife Monitoring Report Page 52 of 59 The significance of the estimated collisions to the waterfowl and waterbird populations using WCCL is not considered very great. Stout and Cornwell (1976) contributed only 0.1 percent of the total of non-hunting waterfowl mortality to collisions.

Disease and poisons were responsible for 87.7 percent. Humberg et. al. (1983) also contributed a large portion of the non-hunting waterfowl mortality to disease and lead poisoning, however, transmission lines were not involved with the study. A total first year mortality rate of 60 to 70 percent for juvenile ducks and a subsequent.

rate of loss of 35 to 45 percent was reported by Bellrose (1976). Based on the small percent that the estimated collisions at WCGS comprised of the total population on the cooling lake and the high mortality percentage normally experienced by waterfowl and waterbird populations, it was concluded that deaths caused by WCGS transmission facilities was insignificant.

No substantial increases or decreases were noticed between preoperational and operational seasons. Since no threatened or endangered species were found during the dead bird searches, WCCS transmission facilities have not posed any threat to those populations.

A comparatively larger number of bald eagles, however, were observed in the Cemetery Cove area during the 1987-1988 winter than the previous winters. No problems with collisions or near misses were observed.

Eagles seemed to use the ice-free areas south of the highlines and did not routinely cross the lines. Because bald eagles have keen eyesight, fly relatively slow, and maneuver well, highline collisions should be reduced. However, as noted by Kroodsma (1978), they often fly during poor visibility and may not be attentive when concentrating on hunting causing their collision potential to increase.

Steam fog from station operation is common in the Cemetery Cove study site which would reduce visibility thus further tend to increasing collision potential.

Despite these factors, no eagle mortality from WCGS lines have been observed and given similar WCCL usage in the future, no problems with collision mortality is expected.

M1987-1988 Operational Wildlife Monitoring Report j Page 53 of 59 CONCLUSIONS Avian density and diversity observed during operation of WCGS were similar Mto preoperational studies. Establishment of WCCL has resulted in an increase in species diversity observed in the local area. Annual species diversities have increased approximately 50 percent above those observed prior to lake filling. This was expected as the lake provided numerous waterbird habitats -while upland areas supported similar bird populations that were present prior to lake filling. Detectable differences due to station operation were not found.Threatened or endangered species observed since 1973 included the White-.faced ibis, bald eagle, peregrine falcon, prairie falcon, and interior least Itern. Bald eagles werie common winter residents using WCCL primarily as a feeding and loafing site. The prairie falcon was removed and the white-faced ibis was added to the Kansas threatened list as of May 1987. These species migrate through or infrequently visit.the area and can be expected 3 to be observed in the future.Bald eagle usage on WCCL declined initially since plant operation began while remaining constant on JRR. A large increase was observed during the 1987-1938 winter. Initial operational usage on WCCL declined primarily U because of the two mild winters which caused gizzard shad, a more vulnerable and preferred food resource, to be more available on JRR than WCCL. Because 3 WCGS was not operating during much of the 1987-1988 monitoring, usage tended to be influenced by the continuous freezing and thawing of the ice-cover on WCCL. This exposed winter killed gizzard shad not usually abundant on WCCL. Intermittent operations through a normal winter period appears to cause WCCL to be an attractive bald eagle feeding location.

Bald eagle usage during severe winter periods with WCGS operating continuously could not be characterized.

.I 1987-1988 Operational Wildlife Monitoring Report-Page 54 of 59 Waterbird usage between the two lakes was similar to past years. American coots used WCCL to a much greater extent than JRR. Pondweed development was thought to be the primary reason for this. Double-crested cormorants used both lakes similarly.

It was apparent that JRR provided easier foraging habitat while WCCL supplied roosting and nesting sites.Of the ducks observed on both reservoirs, fluctuating water levels on .JRR appeared to greatly influence the distribution between the lakes of early fall migrants.

During periods of little fluctuation on JRR, WCCL with'its aquatic macrophyte growth appeared to attract these ducks, especially during the 1984-1985 preoperational study. Continued heavy use of these weed beds was not evident during operational studies. With high water levels on JRR, this influence was over-shadowed by the attractiveness of JRR. The operation of WCGS greatly influenced the duck distribution between the two lakes during late winter. The heated effluent kept most of WCCL ice-free, providing previously unavailable late winter habitat. This, in combination with seclusion and close abundant food supplies, appeared to keep ducks on WCCL longer than during preoperational seasons. Because WCGS did not operate continuously during the 1987-1988 monitoring, this pattern was not as distinct.

Spring ducks were attracted to JRR almost exclusively over WCCL as during preoperational seasons.Goose distribution between the two reservoirs was similar to preoperational seasons. The increasing trend evidenced during previous years was not continued during the 1987-1988 operational year possibly because WCCL reflected preoperational conditions.

It was shown that WCCL usage, mallards, snow geese, and to a lesser extent, Canada geese increased initially after operations during winter periods when ice formation on JRR was present. However, usage during the 1987-1988 study compared to preoperational studies due to an extended plant outage.Although ice-free condition was probably a major factor, it was evident that 1987-1988 Operational Wildlife Monitoring Report Page 55 of 59 wind protection, hunter refuge, and/or high food availability contributed.

The area where these factors were most prevalent on WCCL was preferred by mallards and snow geese. These types of waterfowl concentrations are known to cause problems with crop depredations and disease outbreaks (Bellrose 1976, Hawthorne 1980, Frederick and Klaas 1982, Kahl and Samson 1984, Frederick et al. 1987). However, the concentrations as of this report have not reached levels high enough .to cause wide-spread crop depredation problems.

Given similar usage patterns in the future, mallards and snow geese may be expected to have the greatest potential for causing depredation problems around WCCL. This is because. these species occur in large concentrations.

Although snow geese usage from year to year has been-highly variable, they have crowded in areas of WCCL at times when late-harvested crops were most vulnerable.

Canada geese, although using the same crop types and present on the lake during the same time periods, at this time should not cause problems because they have tended to occur in smaller concentrations around the cooling lake. Any Canada depredation problems would likely be highly localized.

Although waterfowl disease outbreaks have not been observed, potential areas of concern will be similar as for crop depredation events because of the consistent usage of the same areas.Results of collision surveys revealed similar mortality rates to those-previously documented.

Eight species were identified during the study. No threatened or endangered species were found during these surveys. Inherent biases were identified and measured.

It was concluded that collisions with transmission facilities associated with WCCL during peroperational and operation monitoring did not cause sufficient avian mortality to be considered problematic.

Also, it was concluded that because of the colli-sion consistency observed between years, the collision potential of WCGS has been characterized and that no further studies are needed. This statement-is valid only if usage of WCCL, especially that of bald eagles, remains similar to that reported.

1987-1988 Operational Wildlife Monitoring Report Page 56 of 59 LITERATURE CITED Anderson W.L. 1978. Waterfowl collisions with power lines at a coal-fired powei plant. Wildlife Society Bulletin, 6(2): 77-83.Baldassarre, G.A. and E.G. Bolen. 1984. Field-feeding ecology of waterfowl wintering on the southern high plains of Texas. Journal of Wildlife Management.

48(1): 63-71.Beaulaurier, D.L. 1981. Mitigation of bird collisions with transmission lines. Report for Bonneville Power Administration.

Portland, Oregon.84 pp.Bellrose, F.C. 1976. Ducks, Geese and Swans of North America. Stack-pole Books, Harrisburg, Pa. 540 pp.Chabreck, R.H., R.K. Yancey, and L. McNease. 1974. Duck usage of management units in the Louisiana coastal marsh. Proc.. 28th Annual Conf. of Southeastern Fish and Wildlife Agencies.

35: 38-48.Craven, S.R. and R.A. Hunt. 1984. Fall food habits of Canada geese in Wisconsin.

Journal of Wildlife Management.

48(1): 169-173.Duke, R.W. and R.H. Chabreck.

1975. Waterfowl habitat in lakes of the Atchafalaya Basin, Louisiana.

Proc. Annual Conf. of Southeastern Fish and Wildlife Agencies.

29: 501-512.Duncan, D.B. 1955. Multiple range and multiple F tests. Biometrics 11: 1-42.Ecological Analysts.

1983. An evaluation of historical flow conditions in the Platte River as related to vegetation growth and habitat use by the endangered whooping crane and bald eagle and the threatened interior least tern. A report prepared for the Central Platte Natural Resources District, Lincoln, NB. 93 pP.Faanes, C.A. 1987. Bird behavior and mortality in relation to power lines in relation to power lines in prairie- habitat. Fish and Wildlife Technical Report No. 7. Supt. of Docs. No.: 14910088.

24 pp.Frederick, R.B., W.R. Clark, and E.E. Klaas. 1987. Behavior, energetics, and management of refuging waterfowl:

a simulation model. Wildlife Monograph No. 96. 35 PP.Frederick, R.B., and E.E. Klass. 1982., Resource use-and behavior of migrating snow geese. Journal of Wildlife Management, 46(3): 601-614.

1987-1988 Operational Wildlife Monitoring Report Page 57 of 59 CGasaway, R.D., S. Hardin, and J. Howard. 1977. Factors influencing wintering waterfowl abundance in Lake Males, Florida. Proc. Annual Conf. of Southeastern Fish and Wildlife Agencies.

35: 38-48.Griffin, C.R. and r.S. Baskett 1985. Food availability and winter range sizes of immature and adult bald eagles. Journal of Wildlife Management.

49(3): 592-594.Griffin, C.R., T.S. Baskett, and R.D. Sparrowe.

1982. Ecology of bald eagles wintering near a waterfowl concentration.

U.S. Fish Wildlife Service Spec. Sci. Rep.-Wildl.

No..247. 12 pp.Hawthorne, D.W. 1980. Wildlife damage and control techniques, in Wildlife Management Techniques Manual, S.D. Schemnits, ed. The Wild ife Society publ. p. 411-439.Humberg, D., DoGraber, S. Sheriff, and T. Miller. 1983. Estimating autumn-spring waterfowl nonhunting mortality in north Missouri.

Transactions of the forty-eighth North kmerican Wildlife and Natural Resources Conference.

p. 241-256.James, B.W. and B. A. Hank. 1979. Factors affecting avian flight behavior and collision mortality of transmission lines. Report for Bonneville Power Administration.

Portland, Oregon. 110 pp.Johnson, F.A. and W.G. Swank. 1981. Waterfowl habitat selection on a multi-purpose reservoir in East Texas. Proc. Annual Conf. of Southeastern Assoc. of Fish and Wildlife Agencies 35: 38-48.Jorde, D.C., G.L. Krapu, and R.D. Crawford 1983. Feeding ecology of mallards wintering in Nebraska.

Journal of'Wildlife Management.

47(4): 1044-1053.

Kahl, R.B. and F.B. Samson. 1984. Factors affecting yield of winter wheat grazed by geese. Wildlife Society Bulletin.

12(3): 256-262.Kansas Administrative Regulations.

1987. Article 23-17-1. Endangered and Threatened Species.Kansas Gas and Electric.

1974. Wolf Creek Generating Station Environ-mental Report (Construction Permit Stage). Wichita, Kansas. 4 Vols.-1981. Wolf Creek Generating Station Environmental Report (Operating License Stage). Wichita, Kansas. 2 Vols.

1987-1988 Operational Wildlife Monitoring Report Page 58 of 59-1983. Wolf Creek Generating Station Construction Phase Wildlife Monitoring Program, May 1982-April 1983. 35 PP--1984. Wolf Creek Generating Station 1983-1984 Preoperational Phase Wildlife.Monitoring Report. 48 pp.-1986(a).

Wolf Creek Generating Station 1985-1986 Operational Wildlife Monitoring Report. 92 pp.--1986(b).

Wolf Creek Generating Station 1984-1985,Preopera-tional Wildlife Monitoring Report. 66 pp.Keister, G.P., R.G. Anthony, and E.J. O'neill 1987. Use of communal roosts and foraging areas by bald eagles wintering in the Klamath Basin.Journal of Wildlife Management.

51(2): 415-420.Keith, L.B., and R.P. Stanislawski.

1960. Stomach contents and weights of some flightless adult pintails.

Journal of Wildlife Management.

24(0): 95-96.Kroodsma, R.L. 1978. Evaluation of a proposed transmission line's impacts on waterfowl and eagles. In Impacts of Transmission Lines on Birds in Flight, M.L. Avery, ed. U.S. Fish and Wildlife Service. FWS/OBS-78/48 pg. 69 to 76.Lish, J.W. and J.C. Lewis. 1975. Status and ecology of bald eagles wintering in Oklahoma.

Proc. Southeastern Assoc. Came and Fish Comm.29: 415-423.Meyer, J.R. 1978. .Effects of transmission lines on bird flight behavior and collision mortality.

Report for Bonneville Power Administration, Portland, Oregon. 202 pp.Meyer, J.R. 1980. A study of wintering bald eagles to assess potential impacts from a proposed 230-kV transmission line in A Workshop on Raptors and Energy Development.

ed R.P. Howard and J.P. Gove. p.87-103.Northern States Power Company. 1978. Prairie Island Nuclear Generating Plant, Environmental Monitoring Program. 1978 Annual Report.Minneapolis, Minnesota.

Paulus, S.L. 1982. Feeding ecology of Gadwalls in Louisiana in winter.Journal of Wildlife Management 46(i):p. 71-79.

.1987-1988 Operational Wildlife Monitoring Report Page 59 of 59 Rusz, P.J., H.H. Prince, R.D. Rusz, and G.A. Dawson. 1986. Bird collisions with transmission lines near a power plant cooling pond. Wildlife Society Bulletin.

14(4): 441-444.'Sokal' R.R. and F.J. Rohlf, 1981. Biometry.

W.H. Freeman and Company,;59 Pp-.Southern, W.E. 1963. Winter populations, behavior and seasonal dispersal of bald eagles in northwestern Illinois.

Wilson Bulletin.

75(1): 42-55.--------1964. Additional observations on wintering bald eagle populations:

including remarks of biotelemetry techniques and immature~plumages.

Wilson Bulletin.

76(2); 121-137.I1 Steenhof, K. 1978. Management of wintering bald eagles. U.S. Fish and I Wildlife Service. FWS/005-78/29.

59 pp.Stout, I.J. and G.W. Cornwell.

1976. Nonhunting mortality of fledged North 3 IAmerican Waterfowl.

Journal of Wildlife Management.

40(4): 681-693.Terres, J.K. 1980. The Audubon Society Encyclopedia of North American Birds. Alfred A. Knopf, Inc.., NewlYork.

1110 pp.Thompson, D. 1973. Feeding ecology of diving ducks on Keokuk Pool, Mississippi River. Journal Wildlife Management.

37(0): 367-381.Todd, C.S., L.S. Young, R.B. Owen, and F.S. Gramlich.

1982. Food habits of bald eagles in Maine. Journal of Wildlife Management.

46(3): 636-645.3U.S. Department of Interior.

1987. Endangered and threatened wildlife and plants. Code of Federal Regulation, Title 50, part 17.U.S. Nuclear Regulatory Commission.

1982. Final Environmental Statement Related t6 the Operation of Wolf Creek Generating Station, Unit No. 1.Docket No. STN 50-482, NUREG-0878.

Willdan Asociates, 1982. Impact of the Ashe-Slatt 500-kv transmission line on birds at Crow Butta Island: Post-construction study finallreport.

Report for Bonneville Power Adminstration.

Portland, Oregon. 155 pp.Wolf Creek Nuclear Operating Corp. 1987a. Wolf Creek Generating Station 1986-1987 Operational Wildlife Monitoring Report. 65 pp.Wolf Creek Nuclear Operating Corp. 1987b. Wolf Creek Generating Station 1985/1986 Operational Fishery Monitoring Report.I S I t-)Ri ii a ii I I I U I I I I WOLF CREEK GENERATING STATION 1995-1996 OPERATIONAL WILDLIFE MONITORING REPORT WOLF CREEK NUCLEAR OPERATING CORPORATION a.\7"It-I I I I I I0 ENVIRONMENTAL MANAGEMENT GROUP RESOURCE PROTECTION OCTOBER 1996 I I I>I I I I I I I I I I WOLF CREEK GENERATING STATION 1995-1996 OPERATIONAL WILDLIFE MONITORING REPORT Don Eccles Environmental Management Group Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839 Published October1996 Annual Report for October 1995 -March 1996 Author Supervisory Approval Managerial Approval Don Eccles Date Dan Williamson Date Brad Loveless Date I Abstract II Waterbird.

waterfowl and bald eagle usage was monitored on Wolf Creek Lake (WCL) from October 1995 through March 1996. This report compares eleven seasons of operational monitoring and characterizes patterns that have developed.

Thirty-four species of waterbirds and waterfowl were observed during the 1995-1996 monitoring period with mallard, snow goose, and Canada goose being most abundant.

No disease or crop depredation problems were observed during the 1995-1996 monitoring season. No significant transmission line collision events nor increased potential for such were observed.During operational winters, the heated effluent has provided previously unavailable open water habitat on WCL. This, in combination with seclusion and close abundant food supplies, has made WCL attractive to waterfowl during cold winters when other area lakes are frozen over.Significant (p<0.05) preferences for areas of WCL providing these factors have been found. The relatively mild winters of the past several years have negated the attractiveness of WCL resulting from the heated effluent.

Mallard usage of John Redmond Reservoir (JRR) has been consistently higher than usage of WCL during these mild winters.IDuring operational winters, WCL does not normally attract a disproportionate number of area bald eagles. The seasons of highest usage are associated with plant trips or power reductions causing cold shock fish kills resulting in a food resource not typically available in such quantity at WCL. Even then, eagles have sometimes utilized JRR nearly as much or more than they did WCL. Recent trends seem to indicate that area bald eagles prefer JRR over WCL even when JRR is ice-covered and WCL is largely ice-free.

Thus, WCL does not appear to be affecting the area bald eagle population so as to attract such high numbers that transmission line mortality could be a problem.I I I I I I I I I I Table of Contents 0 Page List of Figures .............................................................................................

... iv 0 List of Tables ................................................................................................

.... v t Introduction

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

1 M ethods .......................................................................................................

.... 3\ Results and D iscussion

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

4 I Conclusions

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

.... 9 Literature Cited .............................................................................................

... 10 I I I I I I I I I I!l "ii o k eLIST OF FIGURES I Wolf Creek Lake and associated structures 19 2 Wolf Creek Lake and John Redmond Reservoir, Coffey County, Kansas 20 3 Annual bald eagle usage comparisons between Wolf Creek Lake and 21 John Redmond Reservoir**

4 Monthly operational bald eagle usage of Wolf Creek Lake and John 22* Redmond Reservoir I Annual combined duck usage comparisons between Wolf Creek Lake 23 and John Redmond Reservoir 6 Annual mallard usage comparisons between Wolf Creek Lake and John 24 Redmond Reservoir 7 Monthly operational combined ducks usage of Wolf Creek Lake and 25 John Redmond Reservoir g Monthly operational mallard usage of Wolf Creek Lake and John 26 Redmond Reservoir 9 Annual snow goose usage comparisons between Wolf Creek Lake and 27 John Redmond Reservoir 10 Monthly operational snow goose usage of Wolf Creek Lake and John 28 Redmond Reservoir 1 Annual Canada goose usage comparisons between Wolf Creek Lake and 29 John Redmond Reservoir 12 Monthly operational Canada goose usage of Wolf Creek Lake and John 30 Redmond Reservoir.

I!I I I I I iv TLIST OF TABLES Tabl. e Page I Waterbird and waterfowl census data collected during ground surveys of 12 Wolf Creek Lake 2 Ground count frequency and percent composition of waterfowl and 13 waterbirds using Wolf Creek Lake 3 National Weather Service monthly average air temperatures for Topeka, 14 Kansas 4 Significant differences between ranked location means of wintering bald 15 Ieagles using Wolf Creek Lake 5 Ground count frequency and percent composition of ducks using Wolf 16 3 Creek Lake 6 Significant differences between ranked location means of mallards using 17 Wolf Creek Lake 7 Significant differences between ranked location means of Canada geese 18 using Wolf Creek Lake I I I I 3 I I I I I 1995-1996 Operational Wildlife Montioring Report* Page I INTRODUCTION This report presents results of the operational wildlife monitoring program conducted at Wolf Creek Generating Station (WCGS) from October 1995 through March 1996. This program was conducted by Wolf Creek Nuclear Operating Corporation (WCNOC) to monitor wildlife issues identified in the WCGS Environmental Protection Plan (EPP), which is Appendix B of the Facility Operating License.This program represents further refinements to the operational monitoring efforts committed to in the Final Environmental Statement (U. S. Nuclear Regulatory Commission 1982).The general objectives of the program were to document and assess any trends or impacts that may be due to station operation.

The greatest potential for impacts is to migrating or wintering populations of waterbirds, waterfowl and threatened or endangered species. Use of Wolf Creek Lake (WCL) by these birds may expose them to transmission line collision mortality or to disease outbreaks.

Damage to local agricultural crops by large waterfowl concentrations using WCL is also a concern. To document and assess such occurrences or increased potential for such, specific objectives of the program were to monitor how many and where waterbirds, waterfowl, and threatened and endangered species used WCL during the winter migration season and compare these to the norm observed since station operation began.Section 4.2.2 of the EPP specifies that a general survey program shall be accomplished to document significant waterfowl collision events and determine if mitigation is warranted.

Upon analysis of data collected during the 1987-1988 dead bird searches, it was concluded that enough data had been collected to sufficiently characterize line impaction mortality of birds using WCL. The conservatively estimated collision mortality rate was not considered significant (WCNOC 1988). As a result, dead bird monitoring has not been conducted as a separate activity since 1988. Instead, collision monitoring has been covered by the general waterfowl usage surveys. The results presented in this report satisfy EPP collision monitoring requirements.

Description of Study Area WCGS is located in Coffey County approximately 5.6 km (3.5 miles) northeast of Burlington, Kansas and is operated by WCNOC. The area within the WCGS site boundary encompasses 3,973 ha (9,818 acres) composed primarily of range, cropland, and woodland habitats typical of southeastern Kansas. Surrounding land-use within five miles of WCGS is composed of 40 percent agricultural land, 40 percent rangeland, nine percent woodland, five percent built-up area, and six percent miscellaneous (Kansas Gas & Electric 1981). The power block area, including a switchyard and lime sludge pond, covers nearly 100ha (250acres) while the cooling lake inundates 2,060ha (5,090 acres) at normal pool. A once-through cooling system pumping water from and back into WCL is used by the station.* The cooling lake for WCGS was formed by an earth-rolled main dam approximately 3.7 km (2.3 miles)long (Figure 1). The dam, along with five perimeter saddle dams, impounds Wolf Creek approximately 8.8 kin (5.3 miles) above its confluence with the Neosho River. At an elevation of 331.3 m (1,087 feet)MSL the cooling lake has a mean depth of 6.6 m (21.5 feet). It has a limited drainage of 50.4 sq. km (19.5 sq. miles) not including the surface area of WCL, which will not provide adequate run-off to maintain the water level during plant operation (Kansas Gas & Electric 1974). Additional water is pumped as needed from industrial storage in John Redmond Reservoir (JRR). The cooling lake is maintained at a relatively constant level (within a two foot range) throughout the year. The most influential structures on the cooling lake are associated with the circulating water system for WCGS.Baffle Dikes A and B (Figure 1) force heated discharge water to travel nearly the length of WCL before being pumped through the station again. This allows for maximum heat dissipation thus increasing the I 1 1995-1996 Operational Wildlife Monitoring Report Page 2 lake's cooling efficiency.

These dikes provided access which allowed for almost complete waterfowl surveys of the lake shorelines..i Of the five WCL locations designated to assess area preferences by birds, each had unique components.

Location A represents the northern and upstream reaches of WCL. It has a surface area of 142 ha (352 acres) which includes approximately 28 ha (70 acres) of flooded dead timber. Shorelines are associated primarily with cropland and grassland.

Prominent aquatic macrophytes include cattails (Typha sp.), narrow-leafed pondweed, (Potamogeton foliosus , American pondweed (P. nodosus), Lotus (Nelumbo lutea) and smartweed (Polygonum sp.). The area is protected from harsh winds, especially from the north.Location B is the area of WCL which is most affected by thermal discharges and flow during WCGS operation.

The surface area is 500 ha (1,234 acres) and has approximately 12 ha (30 acres) of flooded trees and brush. Shorelines are adjacent primarily to cropland and grassland.

Aquatic macrophyte growth includes narrow-leafed pondweed, American pondweed, cattails, trace amounts of Chara spp., and smartweeds.

Wind-protected areas are numerous in this area. Heat and flow from the circulating water discharge keep this location generally free of ice when WCGS is operating.

Location C is the largest location (913 ha, 2,255 acres) and represents the main body of the lake. There is very little inundated timber and all of the shorelines are either adjacent to native and domestic grassland or rip-rap. Macrophyte growth consists of narrow-leafed and American pondweed.

These weed beds cover less than one percent of the total surface area. Few wind-protected areas exist within* this location.Location D comprises 331 ha (817 acres) in the southeast part of WCL and includes approximately 49 ha (20 acres) of flooded timber. Large areas of cropland surround this area and much of the location is protected from north winds. Macrophyte composition is narrow-leafed and American pondweed.Location E is the area of WCL which was expected to be most affected by circulating water intake flows. This area encompasses 175 ha (432 acres) and has little flooded timber. Pondweed beds are well developed in this area with most of the shoreline and littoral areas supporting some growth.Composition of the aquatic plants was narrow-leafed and American pondweed and Chara sp. Native grasslands border much of this location.

Refuge areas from most winds are abundant.I*JRR, a flood control project which is controlled by the U. S. Army Corps of Engineers, was completed during 1964. This reservoir, which is on the Neosho River, lies approximately 5.9 kin (3.6 miles) west of the station. At their closest points, JRR is less than 3.2 km (2 miles) from WCL (Figure 2). JRR has a surface area of 3,804 ha (9,400 acres) at conservation pool and a total project area of 12,829 ha (31,700 acres). The lake is relatively shallow with an average depth of approximately 1.4 m (4.5 feet).Flint Hills National Wildlife Refuge, managed by the U. S. Fish and Wildlife Service (USFWS) as part of the national migratory waterfowl program, occupies 7,487 ha (18,500 acres) in the upper reaches of the project. For the purposes of this report, all reference to JRR includes the Flint Hills National Wildlife Refuge.I I I I 11995-1996 Operational Wildlife Monitoring Report IPage 3 METHODS I') JBird Usage Usage of WCL by waterfowl, waterbirds, and bald eagles (Haliaeetus leucocephalus) was surveyed during the migratory season from October 1995 through March 1996. Waterbird refers to a bird that lives part of its life in or around water, especially the swimming, diving, and wading birds (Terres 1980).For the purposes of this report, waterbirds will exclude waterfowl (ducks and geese). Two ground counts were conducted each month. Two additional counts were completed in January and February to increase statistical accuracy during peak usage periods by bald eagles. Counts were timed to coincide with surveys completed by the Kansas Department of Wildlife and Parks (KDWP) and the USFWS on JRR. All usage data for JRR were supplied by these two agencies.

Individual species, total numbers, and distribution on the cooling lake and adjacent shoreline areas were determined with the aid of binoculars or a spotting scope. Estimates were made when large numbers prohibited actual counts of 3 individuals.

To detect annual usage trends for WCL and JRR, the average numbers of selected species counted on each survey were compared.

To determine the changes in seasonal patterns the monthly survey averages for the 1994-1995 season were compared to the combined monthly averages of prior operational seasons. Ninety-five percent confidence intervals (Sokal and Rohlf 1981) were used to determine if differences between both annual and monthly averages were significant.

I WCL was divided into five separate locations, identified as A through E (Figure 1), to assess waterfowl and waterbird usage. With Duncan's New Multiple Range Test (Duncan 1955), preferences for these WCL locations were tested. All count totals to be tested were converted to number of birds per acre.Species selected to assess station impacts were the bald eagle, mallard (Anas Rlatvrhvnchos , Canada goose (Branta canadensis), and snow goose (Chen caerulescens).

These were used because they regularly occur in relatively high numbers, are a threatened or endangered species using WCL consistently, or have the greatest potential for serious disease outbreaks, significant transmission line collision events, or to cause serious crop depredation problems.

All other species observed were I recorded and any unusual concentrations or occurrences were noted.Collision mortality events had the greatest potential in areas of WCL traversed by the transmission lines (Figure 1). These areas were targeted during past dead bird searches (WCNOC 1988). Usage patterns were observed in these areas during the waterfowl surveys to determine if changes might be taking place which would increase collision potential.

Observers focused on such things as feeding flight patterns, excessive loafing under the lines, land use changes, and/or unusual traversing or concentrating of bald I eagles in these areas to determine if further study or mitigative action may be required.I U I I I 1995-1996 Operational Wildlife Monitoring Report Page 4 RESULTS AND DISCUSSION FJ WCL Bird Usage Sixteen ground counts were completed during the 1995-1996 program. Surveys ranged from 60 to 135 minutes and averaged 93 minutes in duration.

Thirty-four species of waterfowl and waterbirds were observed during ground surveys (Table 1). Species diversity ranged from 18 species in February 1996 to 25 in January 1996. Comprising 37, 33 and 16 percent respectively, mallard, snow goose, and Canada goose were the most abundant species observed (Table 2).Threatened and Endangered Species Threatened and endangered species observed in the past around WCGS include the white-faced ibis (Plegadis chihi), bald eagle, peregrine falcon (Falco erecrinus , and interior least tern (Sterna antillarum

.Of these species, only the bald eagle was observed on the site environs during the 1995-1996 winter. The other species may be expected to be occasional visitors in the future, and station operation is not expected to impact this.The bald eagle, considered endangered by the state of Kansas (Kansas Administrative Regulations 1989)and threatened by the United States government, (U. S. Department of Interior 1995), has been a common winter resident on WCL. Migrating eagles are usually first observed during mid-November.

A peak count of 82 bald eagles was made on February 6, 1996 for WCL. The largest single count on JRR indicated 8 bald eagles present on January 5, 1996. Of the birds observed on WCL, adults and juveniles each comprised 50 percent of the total.Eagle usage of WCL prior to plant operation was primarily as a feeding and loafing site. In this respect, use during operational monitoring has not appeared to change. The flooded timber provides numerous daytime perch sites. Although not verified, roosting overnight probably also occurs. Normal operation of WCGS does not appear to affect bald eagle usage of WCL. While it had been thought that the open water, present because of the heated discharge, may attract eagles when JRR is ice-covered, this does not appear to be the case. WCL usage rates, while usually lower than JRR usage rates, typically follow the same annual and seasonal patterns as JRR's (Figures 3 & 4). This apparent preference for JRR can probably be attributed to the higher availability of gizzard shad (Dorosoma cepedianum at JRR during the winter. The management of the WCL fishery results in a depleted gizzard shad population during the winter.In order to better understand the differences in usage between the two reservoirs, bald eagle habitat requirements should be discussed.

Three primary components of eagle winter habitat include communal nocturnal roost sites, diurnal perch (loafing) sites, and a readily available food source (Steenhof 1978).Nocturnal and diurnal perch sites are present on both WCL and JRR reservoirs and the quantity and quality of these have not changed appreciably since monitoring began. Since these two winter habitat resources have been consistent throughout preoperation and operation, they were not considered to have been factors in eagle usage of WCL and JRR.Of the requirements, food availability between the reservoir areas differed the most. Bald eagles have opportunistic foraging habits, with fish and waterfowl being major components.

Eagles often shift from one to the other during the course of a winter (Southern 1963, 1964, Lish and Lewis 1975, Steenhof 1978, Meyer 1980, Griffin et al. 1982, Ecological Analysts 1983, Griffin and Baskett 1985, Keister et al. 1987). Waterfowl probably weren't as important as fish in the distribution of eagles during operation.

Eagles commonly exploit waterfowl resources, but usually only when fish become unavailable.

Bald eagles seem to be inefficient predators on healthy waterfowl (Steenhof 1978, Griffin et al. 1982, Frenzel and Anthony 1989) although weakened, crippled, and dead waterfowl are readily taken (Lish and Lewis 1975, Griffin et al. 1982, Steenhof 1978, Todd et al. 1982, Keister et al. 1987).I 1995-1996 Operational Wildlife Monitoring Report The frequency of hunter crippled waterfowl was not known in the study area, but because M t g R hunting was permitted in several areas of JRR and only in one small area of WCGS property, it may be 3 assumed that greater numbers were available to eagles on JRR.However, since hunting seasons closed for most species during January, the importance of hunter crippled waterfowl during February should have been reduced. Also, fluctuations in waterfowl numbers on WCL during the operational winters were not necessarily followed by corresponding changes in eagle numbers. This indicates that waterfowl as a food source was not of primary importance for this area's wintering bald eagle population.

Fish appear to be the preferred food source, when available.

Gizzard shad in this region are susceptible to winter kill, and this species occurs in much greater numbers in JRR and the Neosho River than in WCL (EA Engineering, Science, and Technology Inc. 1988, WCNOC 1991a). Shad are highly preferred by bald eagles, probably because of their vulnerability, especially during winter in the ice-free headwaters and tailwaters of lakes (Lish and Lewis 1975, Steenhof 1978, Ecological Analysts 1983).Fish disoriented or killed as they pass through flood gates below dam projects are easy prey for eagles.JRR and the associated Neosho River reaches provide these types of areas. The cooling lake, on the other hand, does not have a major drainage stream flowing into it. Consequently, continuous discharges below the dam exposing these fish are not present. In addition, the availability to eagles of winter-killed fish, mainly shad, increases in the main bodies of reservoirs as the ice cover thaws (Steenhof 1978, Meyer 1980, Griffin et al. 1982). Since the addition of heated effluents, ice cover has been almost lacking on WCL during mild winters while still prevalent on JRR. Relatively low gizzard shad numbers and available warm water are also factors contributing to the reduced food availability at WCL. Thus, during station operation, it has been evident that fish resources for eagles occurred in greater concentrations at JRR and because they were more vulnerable, were typically easier to obtain on JRR and the Neosho River than on WCL. However, when annual usage of the two lakes is compared (Figure 4), there does not initially appear to be a consistent pattern of favoring one lake or the other from year to year. Even considering the severity of the winter (Table 3), which factors in the availability of open water at JRR, no correlation is evident between this and bald eagle usage of the two reservoirs.

I There does, however, appear to be a correlation between increased bald eagle usage of WCL and winters when cold-shock events affected the fishery in WCL. These cold-shock events occur when the temperature of the circulating water discharge drops suddenly as a result of a plant trip or a rapid reduction in power generation.

Documented fish kills caused by cold-shocks or events that likely resulted in fish kills provided abundant and easily obtained food resources for eagles during the winters of 1987-1988, 1988-1989, 1989-1990, 1990-1991, 1993-1994, and 1995-1996.

The presence of shad I and other fish remains under perch trees used for feeding by the eagles supports the assumption that bald eagles took advantage of these circumstances.

The impact of cold-shock events is limited to the circulating water dischage area (Location B), therefore, it would be expected that bald eagle concentrations occur at Location B -or Location A, which provides the nearest abundance of perching sites for feeding or loafing behavior.During the 1995-1996 study period, Location A received the most usage by bald eagles, followed by Location B (Table 4), although there was no significant (p > 0.05) difference in usage among any of the five locations.

During the six winters when cold-shock events occurred, Location B either received the highest usage by eagles or was second and not significantly (p > 0.05) lower than the location receiving* the highest usage. During the seven winters when cold-shock events were not a factor, Location D received the most use by bald eagles five of those years and was second for one of the remaining two years.3 Higher bald eagle numbers at WCL increase the chances for transmission line collision problems.

No bald eagles were found during routine dead bird searches done in past seasons (WCNOC 1988). When the large concentrations were present during the 1988-1989 and 1993-1994 seasons, several eagles were observed flying over, with some actually passing through, transmission lines. The line most frequently crossed was the LaCygne-Benton 345 kV as it heads northwest from the power plant across the eastern I 1 1995-1996 Operational Wildlife Monitoring Report Page 6 coves of Location B (Figure 1). Because of these observations, a dead bird search was conducted during the 1988-1989 season to determine if bald eagle collision events were occurring.

No evidence of bald eagle collisions was found. Usage patterns observed during the 1995-1996 monitoring period revealed no differences which increased collision potential over past seasons. Considering these monitoring results, collision mortality of bald eagles from WCGS transmission lines has not been and is not expected to become a serious threat to them.* During the 1992-1993 winter, a pair of bald eagles constructed a nest structure on WCL. No attempt at* nesting was observed during the spring of 1993. However, during the winter of 1993-1994, construction of the nest continued, and in March 1994, a pair of adult bald eagles were observed exhibiting Iincubating behavior.

This pair of eagles succeeded in hatching and fledging two eaglets. The eaglets were banded, by the U. S. Fish and Wildlife Service (USFWS), before they left the nest The pair of adults has remained at WCL since the initial nesting. They constructed a new nest during the 1994-1995 winter and successfully raised one eaglet in 1995 and two eaglets in 1996 from that nest. These eaglets were also banded by the USFWS.3 Duck Usage The duck total counted on WCL during the 1995-1996 winter was up from the previous year and was at the highest number since the 1990-1991 season (Figure 5). T6tal duck usage was much higher for JRR.Of the ducks observed on WCL, 91 percent were dabblers and 9 percent divers (Table 5). Mallards accounted for 89 percent of the total.The total number of ducks using JRR during the 1995-1996 season was down slightly from the previous season (Figure 5), and mallard numbers were down accordingly (Figure 6). Total duck usage was higher at JRR than WCL throughout the season except for January (Figure 7). JRR was completely or partially ice covered in January while WCL remained mostly ice-free.Station operation was expected to preclude ice formation on most of WCL during the winter, and as a result, larger numbers of some waterfowl species were anticipated to remain in the area longer (U. S.Nuclear Regulatory Commission 1982). Longer usage periods of fall migrating ducks, such as American wigeon (Anas americana), gadwall (-. streve a, blue-winged teal (A, discors , and others, have not been observed during any operational winters. These species left the area during both preoperational and operational studies before ice-cover preclusion would have played a role, usually during early December.

Most ducks having peak usage on both JRR and WCL during October or November were not present in large numbers when normal weather conditions would cause ice formation.

Principal food resources of these species are natural aquatic items (Bellrose 1976) such as Potamogeton spp. in WCL which are not as readily available in large quantities as winter progresses, even with heated effluents.

Because of this, it is suspected that station operation will not induce most of these species to stay in the area any longer than before. It is reasonable to assume that in this case the birds' inherent need to migrate coupled with seasonally declining natural food resources and increasing energy demands played a greater role in the length of time waterfowl used WCL than did ice cover preclusion by station operation.

In contrast to these fall migrating species, mallards have commonly wintered in the area. They rely heavily on cultivated grains during winter and to a lesser extent on natural foods (Bellrose 1976). The annual average at WCL for 1995-1996 was down from the previous year and was at its highest point since the 1989-1990 season (Figure 6). A major difference since operation began has been how these birds are distributed between WCL and JRR as each winter progresses.

Past monitoring has shown that, since the addition of heated effluent, local mallards tend to concentrate on WCL when other area reservoirs freeze (WCNOC 1991b). Until the 1994-1995 season, monthly averages had shown that mallard numbers typically peaked on JRR during November, but not until December on WCL. For the last two winters, mallard usage of JRR has peaked in December.

Mallard usage of WCL also peaked in December during the 1994-1995 winter, but peaked in January during this monitoring period (Figure 8).January was the only month, during the 1995-1996 winter, when mallard usage was higher on WCL than I 1995-1996 Operational Wildlife Monitoring Report.* Page 7 on JRR. JRR was completely or mostly frozen over for most of January while WCL was mostly ice-free.Mallard usage was highest at Location B, and Location A had the next highest usage (Table 6).o Mallards may be attracted to Locations A and B, at least in part, because of the ice-free effects from heated effluent.

Other factors do contribute, and these include seclusion, wind protection, and the proximity of available food resources.

Since only one small area around WCL was open to hunting, harassment of mallards at WCL was minimal. The cooling lake served as a refuge for these wintering birds. Aside from the lack of hunter disruption, protection from winter winds was available to mallards since the larger coves offered escape from both north and south winds. Probably most important, however, was the combination of these factors with the presence of an available foodsupply adjacent to WCL.Agricultural crops are heavily used by wintering mallards (Bellrose 1976, Jorde et al. 1983, Baldassarre and Bolen 1984). This is typically represented by utilization of waste grains in harvested fields. Large wind-protected coves and adjacent cropland characterize Locations A, B, and D. Thus, the factors suggested to be contributing to the late winter mallard attraction to WCL are present to the greatest degree in the areas of WCL these mallards generally prefer.The snow goose and Canada goose were the most common geese observed (Table 2). This has been consistent with past seasons on both WCL and JRR. The greater white-fronted goose (An= alhifkonh was the only other goose species observed.

It has not been prevalent on WCL, but in the JRR area it has been present in large numbers at times.Snow goose usage of WCL had been consistently lower than usage of JRR until the 1993-1994 winter when it was higher. Usage of WCL was again higher than usage of JRR for the 1994-1995 and 1995-1996 winters (Figure 9). Snow goose usage has typically peaked on JRR during the first half of the monitoring period and has peaked on WCL during the last half of the monitoring period. 1995-1996 usage of the two reservoirs was consistent with this pattern as snow goose usage peaked on JRR in November and on WCL in January (Figure 10).A total of 18,905 Canada geese was observed on WCL during the 1995-1996 season (Table 2). This represents a marked increase from the previous year and represents the second highest total recorded, second only to the 1988-1989 monitoring period when 20,395 Canada geese were counted during that winter (Figure 1I). Normally, more Canadas have used WCL during January (Figure 8), when ice-free waters were more prevalent on WCL than on JRR. During the 1995-1996 monitoring period, once again, January was the month of peak usage for Canada geese on WCL (Figure 12).Location A was used by Canada geese more than any other location, although there was no significant (p> 0.05) difference in usage among any of the five locations (Table 7) during the 1995-1996 season.Location A has been ranked first for Canada usage eight of the last ten years and was second for the two other years. Agricultural grains are heavily used even when natural foods are abundant.

This has been shown to be especially true when these grain fields are large and open with an undisturbed body of water nearby (Bellrose 1976, Craven and Hunt 1984). This seems to fit with the way these birds used crop fields surrounding WCL. As with mallards, proximity to grain fields and shelter from north winds appear to be key factors for location usage preference by Canadas at WCL. Location A provides very good shelter from north winds and proximity to grain fields. Smaller groups, when compared to mallards or snow geese, fed more opportunistically and did not concentrate in any particular area of WCL for long periods. It appears that, although heated effluent may be a factor, other winter habitat resources available around WCL may be more important in determining usage by Canada geese.I 1995-1996 Operational Wildlife Monitoring Report 5Page a Transmission Line Collision Mortality The usage patterns of waterfowl and waterbirds in the WCL coves traversed by trammission lines did not change sufficiently to increase collision potential.

The collision estimates made from past dead bird monitoring (WCNOC 1988) remain valid for the bird usage observed during this study period.;Consequently, no mitigative actions were necessary.

I, I I I I I I I I I I I I I. 1995-1996 Operational Wildlife Monitoring Report Page 9 CONCLUSIONS Bald eagle usage of WCL during the 1995-1996 monitoring period was at the third highest level recorded since monitoring began in 1981-1982.

This represented a sharp increase in usage from the previous winter. Bald eagle usage of JRR, on the other hand, was comparable to the previous year's usage. Usage data from previous study periods suggests that JRR usage is typically higher than that of WCL, as a result of increased prey availability at JRR. The exception to this pattern has occured when localized fish kills have occurred at WCL as a result of cold shock events. The sudden concentration of the bald eagles' primary food source attracts a majority of the eagles wintering in the area. There continues to be no evidence of transmission line collisions or of increased potential for such.Additionally, operation of WCGS does not appear to be affecting the area's wintering bald eagle population so as to attract such high numbers that transmission line collision mortality could be a problem.3 The operation of WCGS does influence the duck distribution between the two lakes during late winter.The heated effluent has kept most of WCL ice-free, providing previously unavailable late winter habitat when other area lakes are frozen over. This, in combination with seclusion and close abundant food supplies can make WCL attractive to ducks during cold winters. Fall migrating species have typically used JRR more than WCL. Wintering populations have used JRR early, then switched to WCL. Spring ducks have been attracted to .RR almost exclusively over WCL, as during preoperational seasons.During mild winters, when JRR is not frozen over for any extended period of time, WCL does not appear to have any specific late winter attractiveness for ducks, and JRR receives consistently higher usage throughout the winter. Again, if JRR does freeze over and open water is available on WCL, ducks that had been using 3RR may move over to WCL.It has been shown that WCL usage by mallards, snow geese, and to a lesser extent, Canada geese increased initially after operation during winter periods when ice-cover on JRR was present. Although ice-free conditions contributed, it was evident that wind protection, refuge from hunters, and high food availability were other factors. The areas where these factors were most prevalent on WCL were preferred by mallards and Canada geese. Waterfowl concentrations are known to cause problems with crop depredation and disease outbreaks (Bellrose 1976, Hawthorne 1980, Frederick and Klaas 1982, Kahl and Samson 1984, Frederick et al. 1987). However, the concentrations observed on WCL to date have not caused wide-spread crop depredation problems.

Given similar usage patterns in the future, depredation potential will be greatest for mallards and snow geese. This is because these species occur in large concentrations.

Although snow geese usage from year to year has been highly variable, they have crowded in areas of WCL at times when late-harvested or fall planted crops were most vulnerable.

Canada geese feed on the same crops and are present on the lake during the same time periods as mallards and snow geese but should not cause as great of a depredation risk because they tend to occur in smaller concentrations.

Any crop depredation problems caused by Canadas would likely be high1y localized.

Although waterfowl disease outbreaks have not been observed, potential areas of concern will be similar as for crop depredation events because of the consistent usage of the same areas.Transmission line mortality potential did not increase during the 1995-1996 season. No conditions 3 developed that required further investigation.

No mitigative actions to prevent or reduce collision events were necessary.

I I I 1! 1995-1996 Operational IWildlife Monitoring Report Page 10 LITERATURE CITED o3 Baldassarre, G. A. and E.G. Bolen. 1984. Field-feeding ecology of waterfowl wintering on the southern j high plains of Texas. Journal of Wildlife Management.

48(1): 63-71.Bellrose, F. C. 1976. Ducks, Geese and Swans of North America. Stackpole Books, Harrisburg, Pa.540 pp.Craven, S. R. and R. A. Hunt. 1984. Fall food habits of Canada geese in Wisconsin.

Journal of Wildlife Management.

48(1): 169-173.Duncan, D. B. 1955. Multiple range and multiple F tests. Biometrics 11: 1-42.EA Engineering, Science, and Technology, Inc. 1988. Wolf Creek Generating Station Operational Phase Environmental Monitoring Program, Final Report. Prepared for Wolf Creek Nuclear Operating Corporation.

191 pp.Ecological Analysts.

1983. An evaluation of historical flow conditions in the Platte River as related to vegetation growth and habitat use by the endangered whooping crane and bald eagle and the threatened interior least tern. A report prepared for the Central Platte Natural Resources District, I Lincoln, NB. 93 pp.Frederick, R. B., W. R. Clark, and E. E. Klaas. 1987. Behavior, energetics, and management of refuging waterfowl:

a simulation model. Wildlife Monograph No. 96. 35 pp.Frederick, R. B., and E. E. Klaas. 1982. Resource use and behavior of migrating snow geese. Journal of Wildlife Management, 46(3): 601-614.Frenzel, R. W. and R. G. Anthony 1989. Relationship of diets and environmental contaminants in wintering bald eagles. Journal of Wildlife Management.

53(3): 792-802.I Griffin, C. R. and T. S. Baskett 1985. Food availability and winter range sizes of immature and adult bald eagles. Journal of Wildlife Management.

49(3): 592-594.3 Griffin, C. R., T. S. Baskett, and R. D. Sparrowe.

1982. Ecology of bald eagles wintering near a waterfowl concentration.

U. S. Fish Wildlife Service Spec. Sci. Rep.-Wildl.

No. 247. 12 pp.Hawthorne, D. W. 1980. Wildlife damage and control techniques, in Wildlife Management Techniques Manual, S. D. Schemnitz, ed. The Wildlife Society publ. p. 411-439.Jorde, D. C., G. L. Krapu, and R. D. Crawford 1983. Feeding ecology of mallards wintering in Nebraska.

Journal of Wildlife Management.

47(4):1044-1053.

Kahl, R. B. and F. B. Samson. 1984. Factors affecting yield of winter wheat grazed by geese. Wildlife Society Bulletin.

12(3): 256-262.Kansas Administrative Regulations.

1989. Article 23-17-1. Endangered and Threatened Species.Kansas Gas & Electric.

1974. Wolf Creek Generating Station Environmental Report (Construction Permit Stage). Wichita, Kansas. 4 Vols.I I 1 1995-1996 Operational D) Wildlife Monitoring Report~Page I I 1981. Wolf Creek Generating Station Environmental Report (Operating License Stage). Wichita, Kansas. 2 Vols.Keister, G. P., R. G. Anthony, and E. J. O'Neill 1987. Use of communal roosts and foraging areas by bald eagles wintering in the Klamath Basin. Journal of Wildlife Management.

51(2): 415-420.Lish, J. W. and J. C. Lewis. 1975. Status and ecology of bald eagles wintering in Oklahoma.

Proc.Southeastern Assoc. Game and Fish Comm. 29: 415-423.Meyer, J. R. 1980. A study of wintering bald eagles to assess potential impacts from a proposed 230-kV transmission line in A Workshop on Raptors and Energy Development.

ed R. P. Howard and J.\ F. Gove. p.87-103.Sokal, R.R. and F. J. Rohlf, 1981. Biometry.

W. H. Freeman and Company, 859 pp.* Southern, W. E. 1963. Winter populations, behavior and seasonal dispersal'of bald eagles in northwestern Illinois.

Wilson Bulletin.

74(1): 42-55.-1964. Additional observations on wintering bald eagle populations:

including remarks of biotelemetry techniques and immature plumages.

Wilson Bulletin.

76(2): 121-137.Steenhof, K. 1978. Management of wintering bald eagles. U. S. Fish and Wildlife Service. FWS/005-3 78/29. 59 pp.Terres, J. K. 1980. The Audubon Society Encyclopedia of North American Birds. Alfred A. Knopf, Inc., New York. 1110 pp.Todd, C. S., L. S. Young, R. B. Owen, and F S Gramlich.

1982. Food habits of bald eagles in Maine.Journal of Wildlife Management.

46(3): 636-645.I U. S. Department of Interior.

1995. Endangered and threatened wildlife and plants. Code of Federal Regulation, Title 50, part 17.U. S. Nuclear Regulatory Commission.

1982. Final Environmental Statement Related to the Operation of Wolf Creek Generating Station, Unit No. I. Docket No. STN 50-482, NUREG-0878.

Whitmore, Scott 1996. National Weather Service, Topeka, Kansas. Personal communication.

Wolf Creek Nuclear Operating Corp. 1988. Wolf Creek Generating Station 1987-1988 Operational 3 Wildlife Monitoring Report. 59 pp.Wolf Creek Nuclear Operating Corp. 1991a. Wolf Creek Generating Station 1989-1990 Operational Wildlife Monitoring Report. 33 pp.Wolf Creek Nuclear Operating Corp. 1991b. Wolf Creek Generating Station 1990 Operational Fishery Monitoring Report. 78 pp.I Wolf Creek Nuclear Operating Corp. 1992. Wolf Creek Generating Station 1991-1992 Operational Wildlife Monitoring Report. 31 pp.I I I 1995-1996 Operational Wildlife Monitoring Report Page 12 TABLE i. WATERBIRD AND WATERFOWL CENSUS DATA COLLECTED DURING GROUND SURVEYS OF WOLF CREEK LAKE, FROM OCTOBER 1995 THROUGH MARCH 1996 195 1996 Species Oct Nov Dee Jan Feb Mar Greater white-frontled gooe 4 15 6 I ._. 28 Snow goose 650 7200 480 18100 2300 2100 3800 2450 1150 350 160 95 Canada goose 115 60 220 295 137 35 117 8859 570 6963 1400 44 61 15 14 Green-winged teal 5 I 1 II .6 5 10 6 12 30 Blue-winged teal 19 51 I _Mallard 2 174 2843 2463 2562 1033 2024 16525 2094 10011 3796 9 18 Northern pintail 15 ..Gadwall 37 27 79 4 .2 34 16 8 4 American wigeon 39 142 25 6 14 4 87 4 2 15 Canvasback 2 7 22 8 2 6 Redhead 7 It I Ring-necked duck 8 120 5 2 1 8 Lesser scaup -50 1 4 14 6 3 12 6 -- 10 Common goldeneye I 2 1 23 12 141 8 4 6 16 23 14 BulfTehead I 10 3 4 6 13 1 18 12 Ruddy duck 3 Hooded merganser 22 14 2 6 I 94 46 1 Common merganser 9 5 50 83 3090 124 298 45 26 5 -9 Red-breasted merganser 2 2 10 10 6 American coot 2549 798 20 9 6 1 12 8 9 6 110 240 47 Double-crested cormorant 84 172 269 log 42 60 48 27 13 32 4 15 3 4 I 22 Pied-billed grebe Is 2 I 3 1 1 1 1 Homed grebe I I 1 4 Common loon 7 2 I 2 2 3 5 1 Great blue heron II 9 I 3 2 i 5 1 5 1 Franklin's gull 1326 Ring-billed gull 3 88 111 479 373 7 37 219 320 31 65 39 258 124 392 Herring gull- 3 12 12 4 36 Forster's tern I I Killdeer 1 2 5 Osprey 3 1 I Bald eagle -1 24 12 _ 14 8 9 82 22 26 16 1 2 White plican 124 272 67 61 82 58 64 37 4 25 87 22 Total Species/Month 19 24 19 25 .8 23 I I,[-, t I I I I I I'I 1995.1996 Operational Wildlife Monitoring Report Page 13 TABLE 2. GROUND COUNT FREQUENCY AND PERCENT COMPOSITION OF WATERFOWL AND WATERBIRDS USING WOLF CREEK LAKE Total Count Frequency Percent Total Mallard 43,554 37 Snow goose 38,835 33 Canada goose 18,905 16 American coot 3815 3 Common merganser 3745 3 Ring-billed gull 2552 2 Franklin's gull 1326 1 Double-crested cormorant 904 < I White pelican 903 <1 American wigeon 338 < 1 Common goldeneye 251 < 1 Bald eagle 226 < 1 Gadwall 216 <1 Hooded merganser 186 <1 Ring-necked duck 144 < I Lesser scaup 106 < I Green-winged teal 96 < I Blue-winged teal 70 < I Bufflehead 68 < I Herring gull 67 < I Greater white-fronted.goose 54 <1 Canvasback 47 <Great blue heron 39 < I Red-breasted merganser 30 < 1 Pied-billed grebe 25 < I Common loon 23 < I Redhead 19 <.Northern pintail 15 < 1.Killdeer 8 < I Homed grebe 7 < 1 Osprey 5 < I Ruddy duck 3 < I Forster's tern 2 < I Total 116,584 ,--I I I I I t ii t I)1995-1996 Operational Wildlife Monitoring Report Page 14 TABLE 3. NATIONAL WEATHER SERVICE MONTHLY AVERAGE AIR TEMPERATURES FOR TOPEKA, KANSAS (Whitmore 1996)Temperature

(*F)Jan Winter of Dee Feb Preoperational I I I I I 1981-1982 1982-1983 1983-1984 1984-1985 Operational 1985-1986 1986-1987 1987-1988 1988-1989 1989-1990 1990-1991 1991-1992 1992-1993 1993-1994 1994-1995 1995-1996 30.1 (-0.7) *35.8 (+5.0)14.4 (-16.4)36.8 (+6.0)25.1 (-5.7)34.6 (+3.8)35.9 (+5.1)35.5 (+4.7)21.0 (-9.8)29.6 (-1.2)37.4 (+6.6)32.6 (+1.8)34.8 (+4.0)36.0 (+5.2)30.6 (-0.2)21.9 (-4.8)32.5 (+5.8)26.0 (-0.7)19.9 (-6.8)35.8 (+9.1)29.7 (+3.0)28.0 (+1.3)38.0 (+11.3)37.3 (+10.6)25.2 (-1.5)37.2 (+10.5)26.4 (-0.3)26.1(-0.6) 29.3 (+2.6)24.5 (-2.2)28.5 (-3.7)36.1 (+3.9)40.2 (+8.0)25.6 (-6.6)32.5 (+0.3)40.3 (+8.1)30.8 (-1.4)22.9 (-9.3)36.2 (+4.0)41.3 (+9.1)41.9 (+9.7)29.9 (-2.3)29.9(-2.3) 37.1 (+4.9)34.9 (+2.7)* Number in parenthesis is the variance from 30 year average, 1966 through 1995.I I I I I I I I 11995-1996 Operational 3D Wildlife Monitoring Report Page 15 I TABLE 4. SIGNIFICANT DIFFERENCES BETWEEN RANKED LOCATION MEANS OF WINTERING BALD EAGLES USING WOLF CREEK LAKE.Winter Total Counted Location Preference

• 1983-1984 51 ACBDE 1984-1985 115 EBCAD 1985-1986 82 CBDAE 1986-1987 44 CBEAD 1987-1988 395 ECDAB 1988-1989 212 EDCAB 1 1989-1990 89 CAEBD 3 1990-1991 120 ACEDB 1991-1992 32 CEABD 3 1992-1993 32 ECABD 1993-1994 287 ECDBA 1 1994-1995 37 ECBAD 1 1995-1996 226 ECDBA*Line underscores ranked (least to greatest) location means that were not significantly different I (p_0.05).1 I I I I I I I f-I I I: U I I I 1995-1996 Operational Wildlife Monitoring Report Page 16 TABLE 5. GROUND COUNT FREQUENCY AND PERCENT COMPOSITION OF DUCKS USING WOLF CREEK LAKE FROM OCTOBER 1995 THROUGH MARCH 1996.Species Total Count Frequency Percent Total Mallard 43,554 89 Common merganser 3745 8 American wigeon 338 1 Common goldeneye 251 1 Gadwall 216 < 1 Hooded merganser 186 < I Ring-necked duck 144 < I Lesser scaup 106 < I Green-winged teal 96 < I Blue-winged teal 70 .< I Bufflehead 68 < I Canvasback 47 < I Red-breasted merganser 30 < I Redhead 19 < I Northern pintail 15 < I Ruddy duck 3 < I Total 48.888 I I I I I I I I I 11995-1996 Operational Wildlife Monitoring Report I " Page 17 TABLE 6. SIGNIFICANT DIFFERENCES BETWEEN RANKED LOCATION MEANS OF MALLARDS USING WOLF CREEK LAKE.Winter Total Counted Location Preference

• 1 1983-1984 16.878 1984-1985 97,118 rfR.t).EA I 1985-1986 84,103 CEARD 1986-1987 192,380 CEARD 1 1987-1988 118,777 C.EA B. D 1988-1989 108,800 CEHAD 1989-1990 71,212 rFDAR 5 1990-1991 42,116 CEDAR 1991-1992 27,507 rEDAR 1992-1993 17,317 rADBE 1993-1994 20,131 EDCA-1994-1995 18,371 E- B A 1995-1996 43,554 FrnAR Line underscores ranked (least to greatest) location means that were not significantly (p > 0.05) different.

I I I I U I I 1 1995-1996 Operational Wildlife Monitoring Report I Page 18'a TABLE 7. SIGNIFICANT DIFFERENCES BETWEEN RANKED LOCATION MEANS OF CANADA GEESE USING WOLF CREEK LAKE.1983-1984 3,668 CD A E B 1984-1985 6,453 ACBDE 1985-1986 11,587 CABED 1986-1987 14,584 C B ED A 1987-1988

.13,058 CDBAE 1988-1989 20,395 CEDBA 3 1989-1990 10,903 CDBEA 1990-1991 7,974 EDCAB 3 1991-1992 7,365 C D B E A 1992IM993 14,197 CDEBA 1 1993-1994

.10,480 CDEBA 3 1994-1995 7,360 ECDBA 1995-1996 18,905 DCEBA 3 Line underscores ranked (least to greatest) location means that were not significantly different (p > 0.05).I I I I I I I I!I: II Ii I;I I I I I I I I 1995-1996 Operational Wildlife Monitoring Report Page 19 11£1 Lime Sludge Pond Cooling Lake S.ManDam p.Figure 1. Wolf Creek Lake and associated structures.

I 1995-1996 Operational Wildlife Monitoring Report Page 20---. .. .,,'I .* .k. ____----____ --" "'-' ----r FLN~ -IIL. ,.* *- a___A ' m *- .. m: mi, " ,., "- " Figre2.Wof Cee LkeandJon ed Ond ReeviC e o NtKns 1995-1996 Operational Wildlife Monitoring Report Page 21 Bald Eagle C CO, 40 35 30 25 20 15 10 5 0-. WCCL 85-96.............

JRR 85-96 Nov Dec Jan Feb Mar M onth Figure 3. Annual bald eagle usage comparisons between Wolf Creek Lake and John Redmond Reservoir.

Data includes December through March surveys.__6 A 0 =7 -'iW -" M M M M M -M = M m m 1995-1996 Operationai Wildlife Monitoring Report Page 22 Bald Eagle c C 4 30 25 20 15 10 5..J RWCCL--I*- JR R 0 04 co (0 co 0ý N 40 00 CD 0) 00 0) 0)Migration Season Figure 4. Monthly operational bald eagle usage of Wolf Creek Lake and John Redmond Reservoir.

A M& D M" mI ft. ---m 1995-1996 Operational Wildlife Monitoring Report Page 23 Combined Ducks'U'U 0 U)(U C C 20000.18000 16000 14000 12000 10000 8000 6000 4000 2000 0--wCH7 0M C?Go co co ) 0V 0) 0)A~ 1 U t~-0)( £o cO G o 0) 0) 0D M igration Season Figure 5. Annual combined duck usage comparisons between Wolf Creek Lake and John Redmond Reservoir.

Data includes September through March surveys until after the 1987-1988 season when September surveys were excluded.i iD ' COW- -m -m -m m me ME M 1995-1996 Operational Wildlife Monitoring Report Page 24 Mallard C'U 4, C, (0'U 25000 20000 15000 10000 5000 0W-.--WCCL

.-U-JR R 0 0'4 Co co a?U')co 0 Go 00 Migration Season 04 0.0)(q)CD (D 0)U)0)Figure 6. Annual mallard usage comparisons between Wolf Creek Lake and John Redmond Reservoir.

Data includes November through February surveys.

1995-1996 Operational Wildlife Monitoring Report Page 25 Combined Ducks C (U 0 0 Co 14000 12000 10000 8000 6000 4000 2000 0* .WCCL 95-96 SJRRWCCL 85-96 A JRR 85-96 0>0 z M0 ()1-.M onth Figure 7. Monthly operational combined ducks usage of Wolf Creek Lake and John Redmond Reservoir.

ftb1 A c' E:, M2 -h 1995-1996 Operational Wildlife Monitoring Report Page 26 Mallard 40000 35000 30000 C 25000 20000 15000 10000 5000.0 Oct-JWCCL 95-96_- -J RR.. 95-96 Nov Dec Jan Feb Month Mar Figure 8. Monthly operational mallard usage of Wolf Creek Lake and John Redmond Reservoir.

D ow -~m--- mw 1995-1996 Operational Wildlife Monitoring Report Page 27 Snow Goose'U'U C)U)£20000 18000 16000 14000 12000 10000 8000 6000 4000 2000 0 1--- JR R N a?(D 0o Nco A O V) 0) V) 0 )co) CD t5. co C)c) CD Milgration Season Figure 9. Annual snow goose usage comparisons between Wolf Creek Lake and John Redmond Reservoir.

b bl1 : 1 a n "? W --"/6 -, , w e W = = M M 1995-1996 Operational Wildlife Monitoring Report Page 28 Snow Goose C U 0 0 C', 16000 14000 12000 10000 8000 6000 4000 2000 0~.---WCCL 95-96--M.WCCL 85-96 A R 85-96 0 c .0 &05 8 ) cc 0 z a U!M onth Figure 10. Monthly operational snow goose usage of Wolf Creek Lake and John Redmond Reservoir.

~~1 ~ ~ -- ~ m m m m -m m m 1995-1996 Operational Wildlife Monitoring Report Page 29 Canada goose U Ga 0 (0'U C C 6000 5000 4000 3000 2000 1000 0 J~ JR R C.,4 t D0 ('4 C? o oo Go Oe CDa o M igration Season Figure 1; Annual Canada goose usage comparisons between Wolf Creek Lake and John Redmond Reservoir.

A & M2 M~ M~ M M M M M M 1995-1996 Operational Wildlife Monitoring Report Page 30 Canada Goose 4500 4000 3500 3000 0) 2500 0 2000 to 1500 1000 500 0 01 0 I. _.... WCCL 95-96-MWCCL 85-96--A- JRR 85-96 0 .Z 0 --M onth Figure 12. Monthly operational Canada goose usage of Wolf Creek Lake and John Redmond Reservoir.

a-m- A I I I I I I I I -I -m I 15 Avian Protection Plan Attachment Review of Bird Collision Data on Transmission Facilities at Wolf Creek Generating Station (WCGS)With emphasis on the Lime Sludge Pond (LSP)

Background:

.

The Nuclear Regulatory Commission (NRC) in 1982 reviewed potential impacts to waterfowl due to collisions with electric transmission facilities adjacent to the cooling lake (Section 5.5.1.2, Final Environmental Statement related to the Operation of WCGS, NUREG 0878). The NRC recommended that a general survey program for waterfowl collision be completed to determine if mitigation was warranted.

This recommendation was included in the Environmental Protection Plan, Appendix B to Facility Operating License NPF-42. This required a general survey program be accomplished to document significant waterfowl collision events and determine if mitigation was warranted.

Consequently, a collision survey was initiated in February, 1983, and continued through February, 1988. Surveys included dead bird searches of transmission lines crossing the cooling lake. All birdspecies were included, including bald eagles. These areas included the Firing Range Cove traversed by two 345 kV and one 69 kV line, and the Cemetery Cove, traversed by one 345 kV transmission line. These surveys occurred during the winter-spring migration seasons during each year.The LSP is adjacent to the Cemetery Cove and was searched during each survey. Data was combined in annual reports with the Cemetery Cove through the 1985-86 migration survey season, but collisions around the LSP was available from the field data sheets. Table 1 shows the numbers and species of transmission mortalities found. Table two lists the live birds present immediately before each dead bird search. Records were kept for live bird usage beginning with November 1985 surveys. Comparing these tables demonstrates that no threatened or endangered birds were found to have collided with the associated transmission line. Unknown feathers were not from threatened or endangered birds. A few bald eagles were observed using the adjacent Cemetery Cove, but none were found during dead bird searches.Tables I and 2 also demonstrate that species found during dead bird searches did not necessarily correspond to live species found using the area, indicating that collisions tended to be incidental, with no detrimental patterns present. To test this further, monthly totals of dead birds, pooled from the three search locations, were compared with the total waterfowl and waterbird numbers surveyed during the same months, assuming that the more birds in the area would mean higher collision mortality and greater impact from the transmission facilities.

However, no relationship was found between collision frequency and bird usage of the cooling lake and LSP (Figure 1). Collision mortality was incidental to bird usage in the area, indicating that bird activity was not greatly impacted by the lines.Since the transmission lines did not appear detrimental to general bird usage of the cooling lake, more localized usage data were analyzed.

Beginning in November 1985, live bird usage in each search area was surveyed immediately prior to each dead bird search. This would show any adverse impacts at the LSP. The live bird data were compared to subsequent collisions found, again assuming that the greater the usage in the area, the greater the collision pattern would be.No relationships were found for any location, including the LSP (Figure 2). The more birds using the LSP did not increase transmission line collisions there.

16 A third comparison was made between the species diversity of dead birds found and the diversity of live birds surveyed in the search areas immediately prior to the searches.

This was done assuming that the greater the number of species present would mean a greater number of species vulnerable to collision.

There were no relationships found for all locations except the LSP (Figure 3). Approximately one third of the species using the LSP were consistently found during the dead bird searches.

This suggests that of the birds using the LSP, more species were susceptible to collision not based on total numbers as shown above, but on the kinds of birds. Mallard was the primary species found at the LSP (Table 1).In the 1987-1988 Annual Wildlife Monitoring Report, a review of the total collision results in relation to the total birds using the cooling lake was completed.

Estimates of common biases were used to ensure worst case was evaluated.

As shown in the report, total estimated collisions comprised a small percentage (0.2 to 0.5) of the total using the lake. This was very comparable to other collision impact assessments cited in the report, and well within published non-hunting mortality estimates.

Consequently, no impacts were found to bird populations by the transmission facilities at WCGS.To detect any changes in this assessment, bird usage surveys completed by the Kansas Department of Wildlife and Parks are reviewed annually.

A summary of these reviews are provided in the Annual Environmental Operating Report provided to the NRC each year. No changes have been observed to date that would warrant any mitigative actions.

17 Table 1. Bird species, number of birds found during dead bird searches, and live birds using each search area immediately prior to each search for transmission facilities at Wolf Creek Generating Station.Firing Cemetery Range Year Month Species LSP Cove Cove 1983 February European starling 1 3 Unidentified duck sp. 1 Great blue heron 1 3 Red-winged blackbird 3 Brown-headed cowbird 1 April Blackbird spI Great blue heron 3 Unidentified duck sp 1 Upland sandpiper 1 Sandpiper sp American coot I Red-winged blackbird I Ruddy duck I September Unidentified feathers 2 Blue-winged teal 1 Mallard 1 November Unidentified feathers 5 Gull sp.Song sparrow I Unidentified duck sp I Red-winged blackbird 1 Rusty blackbird I 1984 February Meadowlark I Mallard I American coot 1 Unidentified duck sp. 2 Red-winged blackbird 1 April Blue-winged teal 1 Killdeer 1 Greater prairie chicken I American crow September Blue-winged teal 2 Great blue heron 1 November Blue-winged teal 1 Unidentified duck sp. 7 Gadwall 2 Unidentified feathers 1 American coot 1 18 Table 1. (cont)Firing Cemetery Range Year Month Species LSP Cove Cove 1985 February Red-tailed hawk American crow American tree sparrow Greater prairie chicken Unidentified duck sp.1 April September November Great blue heron Eastern meadowlark Unidentified feathers Mallard Brown thrasher Great blue heron American coot Ovenbird Brown-headed cowbird Red-winged blackbird American coot Ring-billed gull Bufflehead Unidentified duck sp.Red-winged blackbird Unidentified feathers Mallard Blue-winged teal 1 2 1 2 2 2 1 2 1 1 2 1 1 2 2 2 I I I 2 2 1 I December Double-crested cormorant American coot Mallard 1 1 1 1986 January Ring-billed gull American coot Mallard Pigeon Red-winged blackbird I 2 1 1 2 4 4 4 I 1 I 1~4 February Mallard Unidentified feathers Bufflehead American coot Red-winged blackbird Red-bellied woodpecker 1 April Red-winged blackbird Blue-wing teal 1 1 19 Table 1. (cont)Firing Cemetery Range Year Month Species LSP Cove Cove 1986 April Gadwall 1 American coot 1 3 Greater yellowlegs 1 Unidentified feathers 2 Shorebird sp. 1 October Pied-billed grebe I White pelican Blue-winged teal I November Mallard 2 Ring-billed gull 1 Red-winged blackbird December Mallard 2 1 Red-winged blackbird 1987 January Mallard 2 February Mallard 1 4 3 Lesser scaup 1 April White pelican Yellow rail Lesser yellowlegs 1 Pectoral sandpiper 2 Red-winged blackbird 1 November Double-crested cormorant 3 Black-crowned night heron 1 Mallard 2 Unidentified duck sp. 1 American coot 2 1 Passerine sp. 1 December Mallard 1988 January Double-crested cormorant 1 Mallard 2 Red-winged blackbird 1 February Double-crested cormorant 1 Mallard 1 Gadwall 1 Common crow I Unidentified feathers 20 Table 2. Monthly bird numbers surveyed using areas adjacent to transmission facilities immediately prior to dead bird searches at Wolf Creek Generating Station.Firing Cemetery Range Year Month Species LSP Cove Cove 1985 November Hooded mergansers 15 American coots 155 199 Canada goose 40 Mallards 25 124 161 December 1986 January American wigeon Bufflehead Green-winged teal Ring-billed gull Mallard Bufflehead American coot American widgeon Green-winged teal Gadwall Unidentified duck sp Common merganser Pintail Bald eagle Mallard Pintail Bufflehead American widgeon Green-winged teal Ring-billed gull Canada goose American crow American coot 12 122 2 3 787 6 99 55 25 14 21 7 42 2 585 1 8 13 25 2 1 304 15 3 79 9 226 93 10 2 27 12 2 2 123 6 18 31 3 1 February Mallard Bufflehead Pintail Goldeneye Ring-billed gull American widgeon American coot Green-winged teal Killdeer Common merganser Canvasback Redhead duck 32 8 31 3 2 140 April Mallard Lesser scaup 4 2 6 2 21 Table 2. (cont.)Year Month Species.American coot Blue-winged teal Double-crested cormorant Killdeer Shorebird sp.Greater yellowlegs Gadwall LSP 8 6 Cemetery Cove 156 2 3 2 Firing Range Cove 142 9 12 4 1 October Blue-winged teal Great egret Great blue heron Osprey American coot Killdeer Sandpiper sp.Mallard Bufflehead American widgeon 2 12 20 60 3 2 1 1002 8 12 58 1 3 44 2 4 November December 1987 January Goldeneye Bufflehead American widgeon American coot Mallard Hooded merganser Ring-billed gull Gadwall Pied-billed grebe Green-winged teal Canada goose Mallard Buffledhead Great blue heron American widgeon Hooded merganser Canada goose Green-winged teal Goldeneye Mallard Hooded merganser Canada goose Bufflehead 1 120 267 26 9 6 15 250*150 505 2 12 80 30 1239 12 2 12 2 42 97 2145 30 12 3 72 19 3 21 259 2 6 9 300 10 7 90 35 22 Table 2. (cont.)Firing Cemetery Range Year Month Species LSP Cove Cove February Mallard Canada goose Green-winged teal American coot Ring-necked duck Bufflehead Goldeneye Redhead duck Lesser scaup April Mallard Greater yellowlegs Sandpiper sp.American coot Bufflehead Killdeer Blue-winged teal Northern shoveler Gadwall Wilson's phalarope Lesser yellowlegs Pectoral sandpiper Willet Forster's tern 891 61 84 3 69 14 3 16 46 1 33 8 35 2 20 16 2 150 30 5 9 16 15 835 15 5 4 11.12 1320 382 6 2 247 24 11 2 1 November December 1988 January Mallard American coot Canvasback Bufflehead Redhead duck Mallard Hooded merganser Great blue heron American coot Canada goose Goldeneye White-fronted goose Bald eagle Canada goose Mallard Great blue heron 167 21 110 2 1055 15 145 1 3 14 305 895 4 115 3 1 30 6 35 90 23 Table 2. (cont.)Firing Cemetery Range Year Month Species LSP Cove Cove February Ring-billed gull 150 Mallard 10 30 Bald eagle 2 Bufflehead 15 Canada goose 200 Snow goose 30 American coot 10 24 Figure 1. Dead birds found adjusted for common search biases compared with total bird usage of the cooling lake.Monthly estimated bird collissions with transmission lines compared to total bird usage at Wolf Creek Lake 250000 200000.* 150000-o ~0 0.0 50.0 100.0 150.0 200.0 250.0 300.0 350.0 400.0 Estimated total bird collisions 25 Figure 2. Live birds found in search areas immediately prior to dead bird searches.

These totals do not reflect common search biases.Live bird usage vs bird collisions Lime Sludge Pond 3.5~ 25 2 3"0 2.5.0 1.5 0 0 200 400 600 Live bird usage Live bird usage vs bird collisions Cemetary Cove 7- R 2 --07 6-S4-3 3 M S2 0 0 200 400 600 800 1000 1200 Live bird usage 26 Figure 2. (cont).Live bird usage vs bird collisions All combined 6 5 4 3 e=2 1 0 0 200 400 600 800 1000 1200 Live bird usage 27 Figure 3.Species diversity of dead birds found compared to species diversity of live birds surveyed prior to searches.Collision Species Numbers vs Live Lime Sludge Pond Bird Usage R 2= 0.6752 0=U)_>12 10 8 -6 4 2 0 2 3 4 5# collision species Collision Species Numbers vs Live Bird Usage Cemetery Cove R2= 0.0388 12 -, 10-i S 8 -U) 6.4 24 L ~ -------0 0 1 2 3 4# collision species 5 Collision Species Numbers vs Live Bird Usage Firing Range Cove R 2 0.1801 10 RA 8 0 6 ->2 0 +0 1 2 3 4 5 6# collision species 14 Figure 5. Typical bushing and conductor insulation present on WCGS transformers to prevent animal electrocutions.

13 Figure 2. Poles where bald eagles have been observed roosting.

These poles are considered safe due to well separated vertical conductors and pole tops available for perching.Figure 3 Pole 20 of the 13.8 kV distribution power loop where center phase conductor insulation is recommended to prevent potential bald eagle electrocution.

Note close horizontal cross-arm configuration.

12 Figure 1. Typical poles of 69 kV WCGS tap of the Athens line showing eagle safe separated conductors and insulated guy hardware.

11 Table 1 (cont)(1) Pole design features ranked from highest to lowest potential for electrocution hazards to bald eagles are as follows: A. End pole three phase w/horizontal cross-arm, transformer and associated hardware.B. Line pole three phase w/horizontal cross-arm, transformer, underground drops and associated hardware.C. Corner/end pole three phase w/horizontal cross-arm D. Line pole w/horizontal three phase cross-arm E. Corner pole three phase w/vertical conductors, transformer and grounded guys.F. Corner pole three phase w/vertical conductors and grounded guys.G. End pole three phase w/vertical conductors, grounded guys and underground feed hardware.H. End pole three phase w/vertical conductors and grounded guys.I. Line pole three phase w/vertical conductors, transformer, and underground drop hardware.J. Line pole three phase w/vertical conductors and transformer.

K. Line pole three phase w/vertical conductors and underground feed hardware.L. Line pole three phase w/vertical conductors and switch hardware.M. Corner/end pole three phase w/vertical conductors and non-grounded guys.N. Line pole two phase w/horizontal cross-arm and two conductors.

0. Line pole three phase w/vertical conductors.

(2) Pole numbers correspond to poles numbered in the field, and to WCNOC drawing number 8025-E-1 021, Rev 42.

10 Table 1. Susceptibility of bald eagles to electrocution on the 13.8 kV power distribution line at Wolf Creek Generating Station.Pole Design (1) Pole nun Higher-a 0 CL a 0-a o.0 CO)Lows w w*0 (U Lowest Factors Related to Bald Eagle Safety Less Safe 4

• Safer_ Detriment Benefit a1) a-- a) 76 a (U a) -= 0)'a Cl 72 CU° 0:3 Cd ZZa -C t5 Cfl zo ~00 a- 2ux~ CL -= 0 a)~ :3CL 0)>,CL-E 0 2 CtCa--O Co 0 00 0 M xW cn 2 E ".UCC Z.2 c 0. -n -0 DofCo~ a) 0 C 0 0___x x x x x _ _ _ x _ _ __ _ _x x x x x x x x x __x x x x x x x x .x x x x x x x x x x x__ x x x __x x x x__x x __ x x. x x x x x x x x x x x __ x x __ x x x x _ __ x __ x x x x x x x _ __x x x x x x x x x x x x x x x x__ x x x x __x x x x__ x x x x x x x x x__x x x x x x x x__x x x __x x x x_ __x x x __x x x x___x __x x x x x x __ _ _ x _x x x x x X x x 9 5.3.2 Waterfowl Disease Contingency Plan The heated condition of CCL may enhance the potential for development of waterfowl disease pathogens (NRC, 1982). This contingency plan is to provide guidance to mitigate or control such outbreaks on CCL, whether attributable to WCGS operation or not.Initial investigation will be conducted by WCNOC biologists to determine the scope of the event. The USFWS and KDWP are the agencies responsible for such wildlife issues, and will be contacted for assessment and recommended actions if disease is suspected, or numerous carcasses are involved.

WCNOC will assist these agencies as needed.Immediate notification, following disease problem identification, will be completed by WCNOC at the numbers listed below until at least one is contacted:

1. US Fish and Wildlife Service Contaminant Specialist, Manhattan, (785) 539-3474 Flinthills National Wildlife Refuge, Hartford, (620) 392-5553 2. Kansas Department of Wildlife and Parks District Wildlife Biologist, New Strawn, (620) 364-2522 Natural Resource Officer, New Strawn, (620) 364-3418 Region 5 Office, Chanute, (620) 431-0380 Pratt Headquarters, Pratt, (620) 672-5911 6.0 LITERATURE CITED Avian Power Line Interaction Committee (APLIC). 1994. Mitigating bird Collisions with Power Lines: The State of the Art in 1994. Edison Electric Institute.

Washington, D.C.Avian Power Line Interaction Committee (APLIC). 1996. Suggested Practices for Raptor Protection on Power Lines: The State of the Art in 1996. Edison Electric Institute and the Raptor Research Foundation.

Washington, D.C.APLIC and USFWS, 2005. Avian Power Plan (APP) Guidelines, a Joint Document Prepared By The Edison Electric Institute's Avian Power Line Interaction Committee (APLIC) and U. S. Fish and Wildlife Service (USFWS). April 2005.NRC, 1982. Final Environmental Statement Related to the Operation of WCGS, Unit No. 1.NUREG 0878.USFWS, 2003. Migratory Bird Permit Memorandum on Nest Destruction.

MBPM-2, April 15, 2003.

8 mitigation was wariranted.

Consequently, transmission lines traversing the areas of high waterfowl and bald eagle usage were monitored and assessed for actual and potential collision problems beginning in 1983 and continued into 1985.The research determined that collision mortality at WCGS was not considered significant for waterfowl.

No bald eagle collisions were observed.

See attached collision survey summary for more detail. Increased collisions, or waterfowl use changes indicating increased potential for collisions, will be assessed by WCNOC per NRC (1982).Mitigation needs will be addressed with Westar Energy's APP.5.1.3 Chemical or Thermal Water Quality Affects to Fish Prey Base The Kansas Department of Health and Environment (KDHE) regulates water quality discharges from WCGS with a National Pollutant Discharge Elimination System (NPDES) permit. All chemical additions are reviewed and approved by the KDHE prior to use. Periodic bioassays are also completed to demonstrate no impacts to aquatic biota, including fish. Adherence to this permit will ensure continued water quality, thus preclude any degradation to the bald eagle fish prey base.There are no thermal discharge changes expected due to license extension.

Currently, thermal effluents from WCGS concentrate fish and waterfowl during winter periods, thus increasing foraging opportunities for wintering bald eagles.5,2 Improvements for Avian Protection The assessment of potential avian impacts, particularly to bald eagles, has identified two areas where mitigation is recommended to prevent potential impacts in the future. These involve electrocution hazards at portions of the distribution power loop identified above.Modifications include: 1. Install insulation on the center conductor on pole 20 from the bushing approximately three feet (Figure 3) to eliminate potential for bald eagle electrocution.

2. Install perch deterrents and/or insulate center conductors on poles 54 through 59 (Figure 4). These modifications will reduce electrocution potential caused by the closely spaced horizontal conductors.

5.3 Future Contingencies for Avian Protection 5.3.1 Electrocution and Collision Events Based on past experience, bird mortality due to electrocution or collision is not expected to increase in the future at WCGS. In the event electrocution or collision events increase, mortalities will be investigated, recorded and reported in accordance with the current USFWS salvage permit. Consultation with APLIC and USFWS will help determine any mitigation activities if such events become problematic.

APLIC (1994 and 1996) guidelines will be followed when practical.

If electrocution or collision events involve Westar Energy or KEPCo lines, then the respective company will be notified, and remediation activities will be determined by applicable APP's. WCNOC will assist where needed.

7 beneficial for reducing electrocution potential offset many of the potential detrimental conditions (Table 1).Protected Bird Interactions Typically, electrocution threats to birds are greatly influenced by conductor spacing (APLIC 1996). In the vicinity of WCGS, the bald eagle has been the largest species likely to use utlility poles, and because of its large wingspan, would be able to bridge larger conductor spacings.

Consequently, conductor configurations and distances judged safe for bald eagles would also be safe for smaller birds.However, roosting behavior differences of various species may cause different susceptibilities.

On the distribution power loop, various switches, breakers, and pole-mounted transformers may provide suitable roosts, and some species smaller than bald eagles, can and may prefer to get among the hardware, rather than on pole tops. Insulated bushings and jumpers on pole-mounted transformers, etc are present, thus reducing electrocution potential in such instances.

It was found that line spacing and configuration on pole numbers 54 through 59 (Figure 4) may pose potential electrocution threats to some birds, particularly red-tailed hawks, great-horned owls, and flocking blackbird species. Review of past reports for the USFWS salvage permit maintained for WCGS identified one great-horned owl electrocution since 1985. Electrocution of mixed blackbirds on portions of this line has been suspected as causing service outages on this line, but specific evidence has not been confirmed.

5.1.1.4 480 Volt Distribution Lines Low voltage distribution lines do not typically pose electrocution hazards (APLIC 1996). At WCGS, such 480 volt lines provide electricity for lighting and outbuildings, and are typically mounted underneath the 13.8 kV power loop lines. Conductors are insulated preventing electrocutions.

No modifications to these lines were considered necessary.

5.1.1.5 Transformers There were no transformers at WCGS that were deemed as potential electrocution hazards to bald eagles. The pole mounted transformers associated with the 13.8 kV distribution power loop were evaluated with each pole (Table 1), and all had bushing insulators, thus eliminating electrocution potential for all birds. The larger 345 kV transformers require conductor separation beyond the reach of a bald eagles wingspan, thus all smaller species. Intermediate transformers associated with WCGS have covered conductors and bushings to prevent animal caused system outages and damage Figure 5). Some transformers in the switchyard are owned by Westar Energy, consequently are covered by their APP.5.1.2 Collision Potential The NRC in 1982 reviewed potential impacts to waterfowl due to collision with electric transmission facilities adjacent to the cooling lake (NRC 1982). The NRC recommended that a general survey program for waterfowl collisions be completed to determine if 6 5.1.1.2 69 kV Transmission Lines There has been bird electrocutions observed associated with WCGS. The WCGS tap of the Athens line is owned and operated by Westar Energy thus is part of its APP. Due to the design of this line, this line will not be dangerous to bald eagles.Design includes well-separated conductors on typical line poles, and non-grounded hardware and guys making phase to ground electrocutions unlikely (Figure 1). Poles also have safe tops available for perching, which bald eagles prefer.The WCGS to Sharpe line is owned and operated by the Lyon/Coffey County Rural Electric Cooperative, and is thus included in its policy for prevention of wildlife contacts.

This line is not expected to pose electrocution hazards to birds, including bald eagles. Design benefits included sufficient conductor separation and non-grounded insulator hardware reducing phase-ground electrocution potential.

Safe pole tops are also available for perching.

The line is also not located in habitat frequented by bald eagles.5.1.1.3 13.8 kV Distribution Power Loop Bald Eagle Interactions There has been no bald eagle electrocutions observed on the 13.8 kV Distribution Power Loop, sometimes called the "construction loop". This power loop surrounds the WCGS proper consisting of 64 poles spanning approximately 2.1 miles (reference WCNOC drawing 8025-E-1021).

It distributes power to various buildings and facilities, and is maintained by WCNOC. It consists of numerous pole-mounted transformers, jumper leads to under ground services, cutoff fuses, switches, and corners. These types of electric setups are known to present electrocution hazards to birds (APLIC 1996).. Electrocution hazards were considered for each pole, with emphasis on bald eagle susceptibility.

Table 1 lists the benefits and detriments that each pole has, and prioritizes them as to their potential for eagle electrocutions.

For assessment of bald eagle electrocution potential, poles were prioritized from highest to lowest as; (1) known eagle roost poles, (2) likely roost poles, and (3)unlikely roost poles. As shown in Table'1, eagles have been known to roost on two poles, which were considered safe for bald eagles (Figure 2). No mitigation is recommended for these poles.Of the likely roost poles identified in Table 1, only pole 20 was considered potentially dangerous to bald eagles (Figure 3). This pole has close conductors and a horizontal cross-arm configuration.

The pole is also adjacent to water habitats, and may be an attractive roost site, especially for wintering bald eagles foraging around the lake. All remaining poles judged as likely roosts were not considered hazardous to bald eagles due to the multiple factors beneficial for preventing eagle electrocution as identified in Table 1.The remainder of the distribution power loop poles were considered unlikely to be used by bald eagles, and thus were not judged to pose significant electrocution threats. These poles are distant from likely foraging habitat, are around high human activity, in parking lots, or along mowed lawn areas. In addition, factors judged 5 November 14, 2005 letter from M. J. LeValley, USFWS, to K. J. Moles, WCNOC). In addition bald eagles are large birds, and may be more susceptible to electrocution and collisions (APLIC 1994, 1996).To ensure WCGS exists with minimal impact to birds, and to address license extension concerns, this APP includes three main phases; (1) assessment, (2) improvement, and (3)future contingency plans.5.1 Assessment Phase for Avian Protection The assessment of power lines and facilities presented below were completed by WCNOC biologists using APLIC (1994, 1996) guidelines.

Biologists from two current APLIC member utilities, Great Plains Energy and Westar Energy assisted with this assessment.

Applicable reports and literature were used to address collision and water quality concerns.5.1.1 Electrocution Potential All lines were inspected for electrocution hazards using criteria in APLIC (1996). There are four primary types of aerial power lines, in addition to transformers, associated with WCGS. They include:.1. 345 kilovolt (kV) transmission lines owned and operated by Westar Energy, including the LaCygne to Benton, and Wolf Creek to Rose Hill lines..2. 69 kV transmission lines, including the WCGS tap of the Athens line (approximately four miles) owned and operated by Westar Energy, and the WCGS to Sharpe line (approximately 2.5 miles), owned and operated by Lyon-Coffey Electric Cooperative.

3. 13.8 kV distribution power loop operated by WCNOC.4. 1000 volt or less (typically 480 volt) distribution lines operated by WCNOC.5. Transformers at WCGS operated by WCNOC and Westar Energy.5.1.1.1 345 kV Transmission Lines There were no electrocution hazards to bald eagles and other birds identified at WCGS from the 345 kV transmission lines. The lines are owned, inspected, maintained, and operated by Westar Energy. As such, they are covered by Westar Energy's Avian Protection Plan (APP) which includes documentation and reporting to the USFWS of bird mortalities associated with the lines. The APP provides for retrofitting or modifying lines, poles, and equipment to bird safe standards where mortalities are known.In general, the conductor separation required for the 345kV transmission lines are more than can be spanned by birds, including the bald eagle, thus eliminating electrocution potential.

Insulator fouling by feces streaming, or nest construction may pose electrocution hazards (APLIC 1996). These types of bird interactions are inspected for and addressed by Westar Energy's routine inspections and APP.

4 4 birds may cause phase-ground or phase-phase shorts. This also protects birds from electrocution.

2. Cliff swallows commonly attempt to nest on plant buildings causing significant housekeeping and disease concerns associated with the mud nest colonies.

Control activities include netting or sheeting to eliminate nesting sites prior to active nesting. In areas where this isn't feasible, nest starts are removed before eggs are laid, thus preventing establishment of a nesting colony. Active colonies exist at the CCL spillway and the causeway bridge providing nearby colonies for displaced birds, thus preventing take. Nest starts are not considered active (without eggs or young), thus no permitting is required (USFWS 2003). Active, or suspected active nests are allowed to stay unless significant hazards are involved.

After evaluation by WCGS biologists, a permit from the USFWS will be obtained before nest removal in such instances.

3. Barn swallow nests tend to pose similar housekeeping concerns as Cliff swallows, except on a smaller scale. If nest site modification isn't feasible, then inactive nest start removal is completed.

Suspected or actual active nests are allowed to stay unless significant hazards are involved.

Such hazards may include safety concerns to personnel by adult birds protecting nests around ladders and stairs. WCGS biologists will evaluate on a case-by-case basis, and obtain specific USFWS permits before nest removal.4. Miscellaneous bird interactions in the past have included.high bird activity in security motion detection areas, usually by swallows and mixed blackbird species. Noise and distress calls have been used to discourage bird activity and help reduce this problem.Eastern kingbird nesting has periodically caused personnel safety concerns at the meteorological tower and plant buildings.

When necessary, to remove such birds, specific permits from the USFWS are required.5.0 POTENTIAL IMPACTS TO BIRDS The potential impacts to protected bird species due to the presence and operation of WCGS include: 1. Electrocution with power-lines, poles and transformers

2. Collision on aerial lines 3. Chemical or thermal water quality impacts, particularly to the fish prey base of bald eagles 4. potential increase for waterfowl disease pathogens in the warm water discharge to CCL.Impacts to bald eagles are emphasized in this APP because this species is currently listed as threatened, thus protected by the ESA, as well as the MBTA and BGEPA. Removal fro the threatened list is currently being considered by the USFWS. As a threatened species, it deserves greater attention during the WCGS operating license extension process. The extension is an federal action by the Nuclear Regulatory Commission (NRC), and as such will require USFWS and Kansas Department of Wildlife and Parks consultation.

Potential impacts were identified by the USFWS during pre-submittal consultation with WCNOC (see attached 3 5. The Endangered Species Act (16 U.S.C. 1531-1544:

ESA), prohibits the take of a listed species. Take is defined as "...to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect or attempt to engage in any such conduct." 6. The Kansas Nongame and Endangered Species Conservation Act (K.S.A. 32-1009 to 32-1011) prohibits take and possession of state listed nongame, threatened or endangered species.7. The USFWS Migratory Bird Permit MB715225, and current revisions, has been issued for migratory bird salvage and mortality investigation at WCGS. This permit does not provide for take.8. The Kansas Department of Wildlife and Parks (KDWP) Scientific Collecting and Salvage Permit (currently SC-066-2006), and current renewals, is maintained for bird possession and mortality investigation at WCGS.3.0 BIRD ENHANCEMENT ACTIVITIES Offsetting potential adverse impacts to birds by WCGS, various enhancement activities have been completed at WCGS. The existence of the CCL has created excellent habitat for many bird species. In addition, WCNOC's land conservation and wildlife stewardship activities provide bird habitats.

These include shallow water wetland development, native grassland and forb management, and maintenance of forested habitats.WCNOC partnerships with wildlife agencies have also attempted to enhance regional bird diversity and habitat use. Ospreys were released in an attempt to promote a breeding population in Kansas. This was done in partnership with the KDWP from 1996 though 2000.Peregrine falcons were released in 2004 and 2005 in an ongoing attempt to promote nesting on plant facilities.

This was completed with KDWP and USFWS permitting and support.A pair of bald eagles have nested since 1994 in a tree inundated by the CCL. An area around the nest is buoyed off and human disturbance is prohibited within 300 yards of the nest site.WCNOC helps monitor this nest for the USFWS. Thermal effluents also provide foraging habitat for wintering bald eagles, which was not available prior to CCL.Enhancements for nesting around WCGS and the lake include. placement of eastern bluebird, wood duck, American kestrel, and Canada goose structures.

4.0 BIRD IMPACTS TO WCGS Nuisance bird issues at WCGS involving protected species include perching/roosting, nesting attempts, and motion activity in security areas. Except for house sparrows, starlings and pigeons, lethal control methods are not considered for use at WCGS without specific permitting from the USFWS. Specific bird impacts to WCGS and preferred method for control are as follows: 1. Mixed blackbird flocks attracted to the lake typically roost on the construction power distribution loop in such numbers causing occasional electric service disruption to WGCS administration buildings.

Common practice is to insulate potential areas where 2 Avian Protection Plan at Wolf Creek Generating Station

1.0 INTRODUCTION

It is the policy of Wolf Creek Nuclear Operating Corporation (WCNOC) to operate Wolf Creek Generating Station (WCGS) in a manner protecting environmental quality through implementation of an environmental protection program (Corporate Policy 5, Environmental Stewardship).

This environmental policy includes actions beyond regulatory compliance, some of which are identified within this Avian Protection Plan (APP).This APP addresses interactions with protected birds at WCGS. House sparrows, European starlings, and pigeons are not protected, are considered non-native pest species, and thus are not included within this APP. Addressed are current regulations and issues, WCGS bird enhancements activities, and nuisance situations and impacts to WCGS caused by protected species. However, the primary goal of this APP is to assess potential adverse impacts of WCGS to birds, identify improvements to minimize these impacts, and present contingency plans for potential future events.This APP is site-specific for WCGS, which is a nuclear electric generating station in east-central Kansas. Associated with WCGS are transmission lines, distribution lines, transformers, buildings, and a cooling lake (Coffey County Lake, CCL). Potential impacts to WCGS from bird interactions include electric service disruption to plant facilities, interruption of plant operation, personnel safety and health, and cleanliness.

Potential impacts to birds include electrocution, power line collision, prey base alterations, and disease pathogen presence.2.0 REGULATORY BASIS For WCGS, several regulatory concerns or permits are applicable to this APP and are as follows: 1. Appendix B to the Facility Operating License No. NPF-42, referencing the Final Environmental Statement, Operating License Stage (NUREG 0878), for WCGS, recommends a disease contingency plan for preventing or controlling a waterfowl disease episode. This APP includes a waterfowl disease contingency plan.2. Potential impacts were identified by the U. S. Fish and Wildlife Service (USFWS) during pre-submittal consultation with WCNOC for WCGS license extension action (see attached November 14, 2005 letter from M. J. LeValley, USFWS, to K. J. Moles, WCNOC). This APP addresses potential bald eagle impacts.3. The Migratory Bird Treaty Act (16 U.S.C. 703-712: MBTA) prohibits the taking, killing, possession, transportation and importation of migratory birds, their eggs, parts, and nests without USFWS permitting.

4. The Bald and Golden Eagle Protection Act (16 U.S.C. 668-668d:

BGEPA) provides additional protection to bald and golden eagles above that in the MBTA.

Avian Protection Plan at Wolf Creek Generating Station with emphasis of potential impacts to the Bald Eagle from License Renewal at Wolf Creek Generating Station Wolf Creek Nuclear Operating Corporation August, 2006 YN-d17 W4LF CREEK'NUCLEAR OPERATING CORPORATION 2 2 Of 0'3 Kevin J. Moles Manager Regulatory Affairs April 26, 2006 RA 06-0065 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482: 2005 Annual Environmental Operating Report Gentlemen:

Enclosed is the Annual Environmental Operating Report, which is being submitted pursuant to Wolf Creek Generating Station (WCGS) Facility Operating License NPF-42, Appendix B. This report covers the operation of WCGS for the period of January 1, 2005, through December 31, 2005.No commitments are identified in this correspondence.

this matter, please contact me at (620) 364-4126, or Ms.If you have any questions concerning Diane Hooper (620) 364-4041.KJM/rIt 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 RO. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HC/VET 4 I M A 1G E 0 4/2 6/2 0 0 6 WOLF CREEK GENERATING STATION ANNUAL ENVIRONMENTAL OPERATING REPORT 2005 ENVIRONMENTAL MANAGEMENT ORGANIZATION WOLF CREEK NUCLEAR OPERATING CORPORATION P.O. BOX 411 BURLINGTON, KANSAS 66839 April 2006 TABLE OF CONTENTS G 4/6

1.0 INTRODUCTION

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

3/2.0 ENVIRONMENTAL MONITORING

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

3 Q 2.1 AQUATIC [Environmental Protection Plan (EPP) Section 2.11 ..... 3 , 2.1.1 Impacts of Water Withdrawal on the Neosho River .........

3 2.1.2 Oxidizing Biocide Discharges to Coffey County Lake ....... 3 2.1.3 Cold Shock ...................................

4 2.1.4 Impingement and Entrainment

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

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

4 2.1.5 Impacts of Coffey County Lake Discharges

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

5 2.2 TERRESTRIAL

[EPP Section 2.21 .........................

5 2.2.1 Control of Vegetation in the Exclusion Zone .............

5 2.2.2 Vegetation Buffer Zone Surrounding Coffey County Lake .........

5 2.2.3 Herbicide Use for Maintenance of WCGS Structures

....... 5 2.2.4 Waterfowl Disease Contingency Plan and Monitoring

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

6 2.2.5 Fog Monitoring Program [EPP Subsection 4.2.1] ...................

6 2.2.6 Wildlife Monitoring Program [EPP Subsection 4.2.2] .............

6 2.2.7 Land Management Program [EPP Subsection 4.2.3] .............

7 3.0 ENVIRONMENTAL PROTECTION PLAN REPORTING REQUIREMENTS........

7 3.1 PLANT DESIGN OR OPERATION CHANGES [EPP Section 3.1] ..........

7 3.2 NON-ROUTINE ENVIRONMENTAL REPORTS .................

7 3.2.1 Submitted Non-routine Reports ..............................................

7 3.2.2 Unusual or Important Environmental Event Evaluations

........ 7 3.3 Environmental Noncompliances

[EPP Subsection 5.4.11 ........3..........

7 4.0

SUMMARY

OF ENVIRONMENTAL INVESTIGATIONS AT WOLF CREEK GENERA TING STATION ....................................................................................

8 4.1 2005 Land Management Activities

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

8 4.2 2005 Zebra Mussel Monitoring Activities

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

9....................9 4.3 2005 Fishery Monitoring Activities

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9 2 t1" A

1.0 INTRODUCTION

E The 2005 Annual Environmental Operating Report is being submitted in accordance with the[i objectives of the Environmental Protection Plan (EPP), Appendix B to the Facility Operating License NPF-42. The purpose of this report is to demonstrate that the Wolf Creek Generating 4 Station (WCGS) operated during 2005 in a manner protective of the environment 2 2.0 ENVIRONMENTAL MONITORING 6/ 2.1 AQUATIC [EPP Section 2.11 2 O 2.1.1 Impacts of Water Withdrawal on the Neosho River 0The WCGS Final Environmental Statement/Operating License Stage (FES/OLS, Section 5.6), NUREG-0878, postulated that makeup water withdrawal of 41 cubic feet per second during drought conditions would extend the duration and severity of low-flow conditions below John Redmond Reservoir (JRR). This, in turn, was expected to reduce riffle habitat that would adversely affect the Neosho madtom, a federally listed threatened species.Neosho River flows at Burlington were maintained during makeup withdrawal activities.

Therefore, there were no adverse impacts to the Neosho River or Neosho madtom habitats attributable to WCGS water withdrawal during 2005.The owners of WCGS have contracted with the Kansas Water Resources Board to pump up to 9.672 billion gallons of water per calendar year to Coffey County Lake (CCL), formerly known as Wolf Creek Lake, from the tailwaters of the JRR.A total of 3.703 billion gallons, or 38 percent of the contracted allotment, was used for WCGS purposes during 2005. The makeup water for CCL was pumped from January 1 through January 12, May I through May 2, June 19 through June 27, and November 4 through December 31, 2005. Measurements at Burlington, Kansas, taken during 2005 by the United States Geological Survey, indicate that flows downstream of the WCGS withdrawal station in the Neosho River were not reduced by makeup pumping activities.

2.1.2 Oxidizing Blocide Discharges to Coffey County Lake Circulating Water System (CWS) Discharge:

Biocide use at WCGS was predicted to cause periodic, appreciable mortality in a conservatively estimated

,40 acres of the discharge area to CCL. However, these impacts were not expected to meaningfully affect the overall biological productivity of the lake (FES/OLS, Section 5.5.2.2).

The postulated biocide levels expected to cause the impacts were from 0.68 to 1.08 mg/I of total residual chlorine at the CWS discharge (FES/OLS, Section 4.2.6.1).

Three 30-minute doses per day of 411 pounds of chlorine per dose were projected to produce these concentrations.

Impacts from actual biocide use during 2005 were considered to be less than postulated in the FES/OLS. A sodium hypochlorite and sodium bromide formulation was used to control biological fouling in WCGS cooling water systems during 2005. Evaluations completed at WCGS demonstrated that the sodium hypochlorite and sodium bromide formulation would not have greater impacts to the cooling lake environment than those expected from the level of 3 chlorine use identified in the FES/OLS. All changes were reviewed and G E approved by the Kansas Department of Health and Environment (KDHE) prior to implementation.

The WCGS National Pollutant Discharge Elimination System (NPDES, Number I-4 NE07-PO02) permit limits biocide discharges to levels lower than postulated in the FES/OLS. This permit was administered by the KDHE. The biocide level for 2 the CWS was limited to a maximum of 0.2 mg/I, total residual oxidant (TRO), for a maximum of two hours per day. Compliance during 2005 was 100 percent.Actual oxidizing biocide dosages averaged approximately 27.6 pounds per day 2) and the daily average TRO was 0.06 mg/l.0 Essential Service Water System (ESWS) Discharge:

During 2005, a continuous diversion of approximately 17,000 gallons per minute of WCGS Service Water System flow to the ESWS was completed to provide microbiologically induced corrosion protection and sedimentation control. The KDHE established a 1.0 mg/I TRO limit for the SWS flow diversion through the ESWS. Actual measurements of TRO averaged <0.09 mg/l, and compliance with the NPDES limit in 2005 was 100 percent. No fish mortality or water quality changes attributable to ESWS biocide discharges were observed.

Based on this information, permitted biocide discharge during 2005 did not have appreciable effects on the cooling lake environment.

2.1.3 Cold Shock In the event of a rapid decline in plant power level during winter, fishes attracted to the WCGS heated discharge could experience mortality due to a quick reduction in body temperature (cold shock). In reference to licensing document evaluations, the WCGS EPP Section 2.1 (c) states, "Cold shock effects on fish due to reactor shutdowns could cause significant mortality to aquatic species in the cooling lake." No adverse impacts due to cold shock mortality events occurred during 2005.There were two plant shutdowns during 2005. The first was from January 22 through February 4, and the second from April 9 through May 19, 2005. Both shutdowns, but primarily the first, were during cold periods when fish have generally been attracted to the warm water discharges, thus susceptible to cold-shock events. No fish mortality attributable to cold-shock effects were observed following these plant shutdowns.

2.1.4 Impingement and Entrainment Impacts of entrainment and impingement of fish and aquatic organisms due WCGS cooling water pumping were projected to be significant, as indicated in the WCGS EPP, Section 2.1 (d). EPP Section 2.1 states that the NRC relies on the State of Kansas for determination of the need for monitoring entrainment and impingement impacts. Although the State of Kansas has not required WCGS to monitor entrainment and impingement impacts, periodic observations during 2005 indicated that fish impingement at the WCGS circulating water intake was negligible.

4 I 2.1.5 Impacts of Coffey County Lake Discharges to the Neosho River El The WCGS NPDES permit requires that CCL discharges be sampled on the first day of each discharge and weekly thereafter until the end of each respective 4 discharge.

Discharge limits were set for chlorides, and pH (NPDES Outfall 004).Lake discharges typically have occurred at the Blowdown Spillway and Service 2 Spillway.

During 2005, no discharges occurred at the Blowdown Spillway.

There were no NPDES violations from discharges from the Service Spillway, and no detrimental effects have been identified to the Neosho River water quality in 2 2005.'0 2.2 TERRESTRIAL

[EPP Section 2.2]6 2.2.1 Control of Vegetation in the Exclusion Zone The composition and structure of vegetation in the 453 hectare (1120 acre)exclusion zone were selectively controlled to be compatible with the function and security of station facilities.

Most areas in the immediate vicinity of the power block have been planted and maintained in a lawn-type condition.

Other areas within the exclusion area have been mowed for security and aesthetic purposes.There were no changes in overall vegetation management of the exclusion zone during 2005.2.2.2 Vegetation Buffer Zone Surrounding Coffey County Lake.To create a buffer zone of least 500 acres around CCL, as specified in EPP Section 2.2 (b), agricultural production activities were curtailed in 1980 within a border ranging from approximately 200-400 feet adjacent to the lake shoreline.

This area is approximately 1440 acres. Previously grazed or hayed native grass areas were left undisturbed.

Previously cultivated lands were allowed to advance through natural succession stages, or native grasses were established in these areas. Land management activities included controlled burning to enhance and/or maintain the designated buffer zone with a naturally occurring biotic community.

2.2.3 Herbicide Use for Maintenance of WCGS Structures Herbicides were used on transmission line corridors, gravel areas, railroad easements, and various land areas associated with WCGS. Application rates followed label instructions.

All herbicides used were registered by the Kansas Department of Agriculture when purchased.

No environmental impacts from herbicide treatment of WCGS facilities were identified.

A summary of herbicide application is provided below.The Lacygne to Benton 345 kilovolt (KV) transmission line corridor on property associated with WCGS was sprayed to control undesirable brush and tree growth. Herbicides included Tordon 22K (EPA Reg. No. 62719-6), Escort (EPA Reg. No. 352-439), and Arsenal (EPA Reg. No. 241-346).In areas where bare-ground control was desired, a herbicide mix of Karmex DF (EPA Reg. No 352-508) and Oust (EPA Reg. No. 352-401) was used. Roundup Ultra (EPA Reg. No 524-475), or comparable substitutes, was also used for 5

.problem weed areas. These herbicides were used on various gravel areas, E including the switchyard, protected area boundary, meteorological tower, storage tank berms, railroad beds, and storage yards.Nuisance tree and brush growth was controlled with Tordon 22 K, Tordon RTU 4 (EPA Reg. No. 62719-31), Remedy (EPA Reg. No. 62719-70), Weed Pro 2,4-D (EPA Reg. No. 10107-31), and Roundup Ultra. Areas treated included the dam, 4. spillways, railroad easements, and selected grassland areas around the cooling lake./2 Four plants listed as noxious weeds by the Kansas Department of Agriculture were controlled on WCGS lands. These were serecia lespedeza, musk thistle, Johnson grass, and field bindweed.

Serecia lespedeza was treated with 63 Pasturegard (EPA Reg. No. 62719-477), Remedy, and Weed Pro 2, 4-D. Musk thistle was controlled with mechanical means. Johnson grass was controlled with Roundup Ultra while. field bindweed was controlled through normal farming practices by the tenants of the agricultural leases.2.2.4 Waterfowl Disease Contingency Plan and Monitoring A waterfowl disease contingency plan was maintained to provide guidance for station biologists in the event of suspected or actual disease outbreaks.

The contingency plan lists appropriate federal and state wildlife agency contacts to be made by WCNOC in the event of such problems.

During routine environmental monitoring and surveillance activities taking place over this reporting period, no waterfowl mortality attributable to disease pathogens was identified.

2.2.5 Fog Monitoring Program [EPP Subsection 4.2.1]Visibility monitoring was initiated in December, 1983, and continued through 1987. The purpose of this study was to evaluate the impact of waste heat dissipation from CCL on fog occurrence along U. S. 75 near New Strawn, Kansas. The program was required through one year of commercial operation that started in September, 1985. Upon conclusion of 1987 data collection, sufficient information was available to evaluate cooling lake fogging, and all commitments relevant to fog monitoring had been satisfied.

The fog monitoring study concluded that operation of WCGS did not appreciably increase fogging incidents from that measured before operation.

During 2005, there were no reports of fogging incidents in the vicinity of nearby U. S. 75 from individuals or local agencies responsible for traffic safety. Periodic fogging caused by the cooling lake did occur during the winter months of 2005, but was restricted to the plant site. No mitigation actions or further monitoring were warranted.

2.2.6 Wildlife Monitoring Program [EPP Subsection 4.2.2]A wildlife monitoring program was initiated in 1982 to monitor and assess waterfowl, waterbird, and bald eagle usage of CCL. This program included transmission-line collision surveys to assess collision mortality and determine potential mitigation needs. This wildlife monitoring program was to continue for at least two years following WCGS start-up (FES-OLS Section 5.5.1.2), which occurred during September, 1985. Upon completion of 1996 monitoring, sufficient data had been collected to determine waterfowl, waterbird, and bald 6 I A eagle usage of CCL. Consequently, the scope of the wildlife monitoring program b was reduced. The current program consists of reviewing CCL waterfowl and E bald eagle survey data collected by the Kansas Department of Wildlife and Parks Dl (KDWP). If review of the KDWP's data indicates usage has changed from that 0 previously documented, then additional monitoring may be initiated, if warranted.

4 This additional monitoring may include collision mortality monitoring.

2 Review of waterfowl and bald eagle monitoring data from the KDWP indicate that no significant usage changes occurred during 2005. No disease outbreaks or/ widespread crop depredation attributable to waterfowl use of CCL was observed 2 in 2005. No changes to the wildlife monitoring program were warranted.

2.2.7 Land Management Program [EPP Subsection 4.2.3]6 Land management activities on all company-owned lands except within the 453 hectare (1120 acre) WCGS exclusion area were designed to achieve balances between agricultural production and conservation values. An annual management plan addressed needs and accepted techniques for land maintenance, soil conservation, and wildlife management.

These included the repair or construction of soil conservation structures, wetland areas, and permanent vegetative covers. An environmental education area was improved and maintained as part of the land management program. A summary of the year 2005 land management activities appears in Section 4.1 of this report. The land management program continued in 2005 to balance agriculture production and conservation values.3.0 ENVIRONMENTAL PROTECTION PLAN REPORTING REQUIREMENTS 3.1 PLANT DESIGN OR OPERATION CHANGES [EPP Section 3.1]Proposed plant design and operational changes which have the potential to affect the environment must receive an environmental evaluation prior to implementation.

There were no changes in station design or operation nor were there tests or experiments that required a evaluation for the presence of an un-reviewed environmental question during 2005.3.2 NON-ROUTINE ENVIRONMENTAL REPORTS 3.2.1 Submitted Non-routine Reports There were no environmental reports involving significant non-routine impacts submitted to the NRC during 2005.3.2.2 Unusual or Important Environmental Event Evaluations No unusual or important environmental events reportable according to specifications in the EPP were identified during 2005.3.3 ENVIRONMENTAL NONCOMPLIANCES

[EPP Subsection 5.4.1]Potential non-radiological environmental noncompliances or noteworthy events were documented and evaluated in accordance with WCNOC's Corrective Action Program, using Performance Improvement Requests (PIRs). A PIR is WCNOC's administrative 7

A process for corrective action and improvements.

Events evaluated during 2005 G included improvements to the refrigerant and chemical control programs.

All the E documented enhancement and reviews were determined not to be reportable pursuant U to EPP criteria., 4.0

SUMMARY

OF ENVIRONMENTAL INVESTIGATIONS AT WOLF CREEK GENERATING

• 4 STATION 2 4.1 2005 LAND MANAGEMENT ACTIVITIES 6/ The EPP requires a land management program that will implement conservation and 2 wildlife management techniques to attempt to balance production and conservation O values (EPP Section 4.2.3). The land management program at WCGS satisfied this.o requirement.

Specific program objectives were to: 6 a. conserve or improve both agricultural and natural resources, b. foster good relations with local agricultural and natural resource communities, c. satisfy licensing requirements, d. improve the appearance of the company's lands, and e. enhance, for educational purposes, the natural resources of the Environmental Education Area (EEA).These objectives were attained as explained below.Grasslands at WCGS consisted of areas leased for grazing and hay production and other areas maintained for regulatory compliance, soil conservation, and wildlife.

Areas adjacent to CCL, approximately 1500 acres, exceeded the 500 acre buffer zone of"naturally occurring biotic communities" referenced in the EPP. Approximately 1,930 acres of native rangeland were leased for grazing and haying in 2005. Leases specified rotation programs, season lengths, maximum grazing rates, and hay cutting dates.Fire has always been an integral part of the prairie and was used to control woody brush invasion, control less desirable cool-season grasses or weeds, increase wildlife value, and to increase prairie vigor and production.

Prescribed burning was completed on approximately 1997 acres during 2005.Management of cropland reduced soil erosion, maintained rent income, and increased wildlife benefits.

Conservation farming, terracing, and wildlife strip management continued to help achieve the objectives.

A total of 1282 acres of cropland was leased in 2005. Consistent with past years, the cropland lease contracts specified that common conservation practices be followed.

On fields with appropriate terraces to follow, contour farming was required.

Double-cropping, i.e., producing two crops on the same acreage during the same season, was generally prohibited because this practice usually increases soil loss. Fall tillage of crop residues was prohibited except for certain instances, such as tillage necessary for fall planting of wheat, plowing of terraces and deep tillage practices to improve productivity.

Activities at the EEA were designed to improve wildlife habitat and increase the public's chances to view a greater variety of wildlife.

Tree and shrub planting, wildlife food plots, controlled burning, and trail improvements were a few of the techniques employed.

The EEA has drawn a large amount of attention and continues to be well suited for educational purposes.8 I A G E 4.2. 2005 ZEBRA MUSSEL MONITORING ACTIVITIES Zebra mussels were not observed during 2005 monitoring of the Neosho River and 0 CCL. Monitoring was completed to provide early detection of the presence of zebra 4 mussel in the vicinity of WCGS. Efforts included substrate and shoreline searches of/ the Neosho River upstream of JRR and immediately downstream of JRR in the vicinity 2 of the Makeup-water Screen House (MUSH), where water is pumped from the Neosho b River to CCL. Settlement monitors were placed and substrate scrapes were conducted/ at plant structures on the Neosho River and CCL. Inspections of fishing boats were also 2 continued through 2005.0 Zebra mussels were discovered at El Dorado Lake on August 25, 2003, approximately b80 miles southwest of WCGS in the Walnut River drainage, which is immediately west of the Cottonwood/Neosho watershed..

During 2005, the mussels expanded their range downstream to Oklahoma.

None have been observed in the Neosho watershed in Kansas.The Neosho River and CCL would be conducive for zebra mussel survival and growth based on water quality conditions present. Introduction to CCL will most likely be caused by WCGS pumping activities from the Neosho River. Boat inspections will likely prevent mussel introduction via recreational boats. Monitoring was designed to help ensure that zebra mussels would be detected as early as practical in the WCGS area.4.3 2005 FISHERY MONITORING ACTIVITIES Monitoring during 2005 demonstrated that the fishery in CCL 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 as outlined in this report were designed to continue to measure long-term trends and help WCGS 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 did warrant management activities to improve the fishery for public use. These recommendations to the KDWP were: 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.9 cA SCHEDULE OF WORK TO BE DONE (For Herbicide Based Right-of-Way Line Clearance)(Attachment 1)Contractor shall furnish all labor, tools, equipment, materials, expenses, transportation, and supervisionto perform transmission line clearance through the application of herbicide and/or mechanical hand cutting. Clearing shall be done to the full width of the right-of-way on the transmission line segments specified in Exhibit A, Schedule of Units. All trees and brush (e.g.plum species) regardless of size with trunks inside the right-of-way shall be treated in accordance with the specifications of this contract.

Side pruning branches from a tree whose trunk is outside of the right-of-way is not included in the basic contract.

Line clearance work performed outside the parameters of the Contract shall be approved by the Company prior to the work being performed and shall be paid in addition to .the lump sum bid. Contractor shall provide a time and equipment rate schedule with the lump sum bid.All woody vegetation greater than 12 feet in height shall be hand-cut flat, leaving a stump 2 inches in height or less. With the prior written approval of the property owner, Contractor may windrow the hand-cut material at the edges of the right-of-way or leave the material where it is cut down. Contractor shall treat each stump that is hand-cut with an approved herbicide contain-ing a brightly colored dye (visible for at least one week after application) to prevent re-sprouting of the cut stumps. All cut stumps shall be treated within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after being cut.All woody vegetation less than or equal to 12 feet in height on the right-of-way shall be treated with an approved herbicide or hand-cut, as required.

Contractor shall spray all trees, brush and vines within the rights-of-way utilizing high volume foliar, low volume foliar, low volume basal, or cut stump treatments unless the Company authorizes other procedures.

When foliar spraying, there shall be a 10 foot setback from intermittent streams, and all rivers, reservoirs, impounded and natural lakes, all wells including drainage wells, abandoned wells and sink holes. Vegetation located within this setback shall be basal treated or hand-cut with the stumps treated with an approved herbicide.

Trees located on and 10 foot back from edge of steep banks of streams, creeks, and rivers shall be hand cut and treated with an approved herbicide and leave the small growth species (e.g. plums and dogwood) to prevent possible bank erosion. With the prior written approval of the property owner, Contractor may windrow the hand-cut material at the edges of the right-of-way or leave the material where it is cut down, provided that all such material is kept clear of existing paths, trails, driveways or field roads. Contractor shall perform work so that a clear strip is maintained down the right-of-way to facilitate future line mainte-nance work. Contractor shall treat each stump that is hand-cut with an approved herbicide containing a brightly colored dye (visible for at least one week after application) to prevent re-sprouting of the cut stumps. All cut stumps shall be treated within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after being cut.Contractor shall be required to obtain a vegetation control level of at least 95% based on target woody vegetation stem count the full width of the right-of-way within each span (structure to structure).

This includes complete control of the woody vegetation, Each line will be inspected by Company a minimum of 30 days after completion of the work to judge 95% target vegetation kill effectiveness.

Any line section on which spraying is completed after August 27 will be inspected by Company after the trees leaf out the following spring to judge 95% target vegeta-tion kill effectiveness.

The contract balance retained by Company will be released upon the satisfactory results of said inspections.

The Contractor shall employ supervisory and field personnel who are knowledgeable and exper-enced and thoroughly trained in right-of-way vegetation management techniques and safety precautions.

Contractor shall follow all Company safety rules applicable to line clearance work.If Contractor's safety rules are more restrictive than the comparable Company safety rules, Contractor's safety rules shall govern. All Contractor employees shall perfonn the work in accordance with all applicable federal, state and local regulations, and all work shall be done in accordance with regulations listed in OSHA 29 CFR 1910.269 and with the latest revision of ANSI Z-1 33.1. Contractor shall follow the Kansas Department of Transportation (KDOT)requirements, including work permits when performing line clearance work on state and inter-state highway rights-of-way.

Company representative will provide copy of Company standing permit for working on KDOT rights-of-way.

The Contractor shall meet the criteria established by the Environmental Protection Agency for the certification of pesticide applicators as set forth in Part 171 of Title 40 of the Code of Federal Regulations.

Before beginning work, Contractor shall provide Company a copy of the applicator license for each employee required to be so licensed.The Company shall approve all herbicides used on Company rights-of-way before the contract is awarded. The Contractor shall follow all manufacturers' label instructions for the herbicides used. No excess materials or containers shall be left or disposed on Company property or rights-of-way.

The Contractor shall notify in writing all property owners along each line right-of-way.

This notification letter shall describe the work to be performed and shall include the Contractor's name, contact person name and telephone number so that the property owner can contact Contractor with any questions or concerns related to the proposed work. If any property owner refuses to allow the Contractor to perform the appropriate line clearance work in accordance with these specifications and any specific exceptions noted by Contractor in the bid documents, Contractor shall promptly contact the Company representative to work out options available to clear the right-of-way to the satisfaction of all parties. This notification of Company representa-tive shall not relieve Contractor of the obligation to make a good faith effort to meet with the landowner to resolve any issues that make the landowner unwilling to allow the work to be completed in accordance with these specifications.

All exceptions to the contract shall be provided with the structure number and/or legal description of the property, including estimated cost for each location.

Generalized exceptions will not be accepted.

Work done to satisfy a landowner concern that does not conform to these specifications shall be approved in advance by Company representative.

Said work shall be paid on an hourly rate basis and the value of the deleted work included in Contractor's lump sum bid shall be deducted from this contract.The Contractor shall check that all work has been performed pursuant to these contract specifica-tions before moving from each transmission line segment and shall notify Company representa-tive of the date that work on each line segment begins and is completed.

The Contractor shall also immediately notify the Company of any incidents involving electric interruptions, electrical contacts by employees, employee accidents or injuries (non-electrical), damage to Company or.private property, and herbicide or oil spills. The Contractor shall be completely responsible for all damage claims or other incidents arising from runoff, drift, or contacts outside of the rights-of-way.

Contractor shall send the white copy of the Westar Energy Weekly Contract Crew Forestry/Time Report to the Company representative within 10 days of the workweek completed.

Contractor shall report total removal units and man-hours, total trim units and man-hours, equipment hours, total acreage cleared and the total amount of herbicide product applied for each line cleared.Contractor shall fill in all information (including telephone numbers) requested on the Field Information Sheet and shall mark through and correct any such information which is found to be incorrect.

Company hereby permits Contractor access to public and private easements utilized by the Company for transmission of electricity as necessary to perform line clearance work. Contractor shall make all necessary arrangements with property owners for access route to transmission rights-of-way during performance of work. Company assumes no responsibility for damage resulting from Contractor gaining access to work locations.

Prior to work being awarded on this Contract, Contractor shall furnish a proposed schedule for completion of each line segment awarded. This schedule shall include a list of the number of personnel and equipment Contractor proposes to use to perform the work being awarded.Company will furnish a route map for each line listed in Exhibit A, Schedule of Units. The plan and profile maps for each line listed in Exhibit A, Schedule of Units may be viewed at the Westar Energy office on the 3rd Floor, 818 Kansas Avenue, Topeka, Kansas.

SCHEDULE OF WORK TO BE DONE (For Mechanical Mowing and Side Pruning)(Attachment 1)Contractor shall furnish all labor, tools, equipment, materials, expenses, transportation, and supervision to perform transmission line clearance through mechanical methods and/or manual hand cutting and side pruning. All trees and brush (e.g. plum species) regardless of size with trunks inside the right-of-way shall be cleared in accordance with the specifications of this contract.

Clearing shall be done to the full width of the right-of-way from the ground to the sky utilizing proper arboricultural practices, where practical, to direct tree growth away from the transmission line segments specified in Exhibit A, Schedule of Units. All potential danger or hazard trees outside of rights-of-way shall be evaluated and marked for possible removal accord-ingto International Society of Arboriculture's "A Handbook of Hazard Tree Evaluation for Utility Arborists" dated June 1993. The Contractor shall promptly contact the Company for appropriate action when a potential danger tree is identified.

Removal of danger trees and line clearance work performed outside the parameters of the Contract shall be approved by the Company prior to the work being performed and shall be paid in addition to the lump sum bid.Contractor shall provide a time and equipment rate schedule with the lump sum bid.Contractor shall clear the right-of-way using mechanical mowing and side pruning methods so that only small sized mulched debris (smaller than a baseball bat) is left on the right-of-way floor. All mowed stubs shall be.3 inches or less in height. Trees around steel towers shall be hand cut and the stumps treated inside the tower footprint and extending at least two feet outside the perimeter of the tower legs. All trees and brush that are hand cut inside and around the perimeter of the tower legs shall be removed from the tower footprint and mowed to specifica-tions. All trees with a diameter greater than the mechanical ax can efficiently mow shall be hand cut flat, leaving a stump 2 inches in height or less. Contractor shall treat each stump that is hand cut with an approved herbicide containing a brightly colored die (visible for at least one week after application) to prevent re-sprouting of the cut stumps. All stumps shall be treated within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after being cut. Contractor shall dispose of all trees, limbs, brush, and debris to the satisfac-tion of all parties concerned, including the Company's representative.

With the prior written approval of the property owner, Contractor may windrow the hand-cut or mowed material at the edges of the right-of-way, provided that all such material is kept clear of existing paths, trails, driveways or field roads. Contractor shall perform work so that a clear strip is maintained down the right-of-way to facilitate future line maintenance work.The Contractor shall employ supervisory and field personnel who are knowledgeable and experi-enced and thoroughly trained in right-of-way vegetation management techniques and safety precautions.

Contractor shall follow all Company safety rules applicable to line clearance work.If Contractor's safety rules are more restrictive than the comparable Company safety rules, Contractor's safety rules shall govern. All Contractor employees shall perform the work in accordance with all applicable federal, state and local regulations, and all work shall be done in accordance with regulations listed in provide copy of OSHA 29 CFR 1910.269 and with the latest revision of ANSI Z-133.1. Contractor shall follow the Kansas Department of Transportation (KDOT) requirements, including work permits when perfbrming line clearance work on state and interstate highway rights-of-way.

Company representative will Company standing permit for working on KDOT rights-of-way.

The Contractor shall meet the criteria established by the Environmental Protection Agency for the certification of pesticide applicators as set forth in Part 171 of Title 40 of the Code of Federal Regulations.

Before beginning work, Contractor shall provide Company a copy of the applicator license for each employee required to be so licensed.The Company shall approve all herbicides used on Company rights-of-way before the contract is awarded. The Contractor shall follow all manufacturers' label instructions for the herbicides used. No excess materials or containers shall be left or disposed on Company property or rights-of-way.

The Contractor shall notify in writing all property owners along each line right-of-way.

This notification letter shall describe the work to be performed and shall. include the Contractor's name, contact person name and telephone number so that the property owner can contact Contractor with any questions or concerns related to the proposed work. If any property owner refuses to allow the Contractor to perform the appropriate line clearance work in accordance with these specifications and any specific exceptions noted by Contractor in the bid documents, Contractor shall promptly contact the Company representative to work out options available to clear the right-of-way to the satisfaction of all parties. This notification of Company representa-tive shall not relieve Contractor of the obligation to make a good faith effort to meet with the landowner to resolve any issues that make the landowner unwilling to allow the work to be completed in accordance with these specifications.

All exceptions to the contract shall be provided with the structure number and/or legal description of the property, including estimated cost for each location.

Generalized exceptions will not be accepted.

Work done to satisfy a landowner concern that does not conform to these specifications shall be approved in advance by Company representative.

Said work shall be paid on an hourly rate basis and the value of the deleted work included in Contractor's lump sum bid shall be deducted from this contract.The Contractor shall check that all work has been performed pursuant to the contract specifica-tions before moving from each transmission line segment and shall notify Company representa-tive of the date that work on each line segment begins and is completed.

The Contractor shall also immediately notify the Company of any incidents involving electric interruptions, electrical contacts by employees, employee accidents or injuries (non-electrical), damage to Company or private property, and herbicide or oil spills.Contractor shall send the white copy of the Westar Energy Weekly Contract Crew Forestry/Time Report to the Company representative within 10 days of the workweek completed.

Contractor shall report total removal units and man-hours, total trim units and man-hours, equipment hours, total acreage cleared and the total amount of herbicide product applied for each line cleared.Contractor shall fill in all information (including telephone numbers) requested on the Field Information Sheet and shall mark through and correct any such information which is found to be incorrect.

Company hereby permits Contractor access to public and private easements uitilized by the Company for transmission of electricity as necessary to perform line clearance work. Contraclor shall make all necessary arrangements with property owners for access route to transmission rights-of-way during performance of work. Company assumes no responsibility 1or d amilage resulting from Contractor gaining access to work locations.

Prior to work being awarded on this Contract, Contractor shall furnish a proposed schedule for completion of each line segment awarded. This schedule shall include a list of the number of personnel and equipment Contractor proposes to use to perform the work being awarded.Company will furnish a route map for each line listed in Exhibit A, Schedule of Units. The plan and profile maps for each line listed in Exhibit A, Schedule of Units may be viewed at the Westar Energy office on the 3rd Floor, 818 Kansas Avenue, Topeka, Kansas.

MATERIAL SAFETY DATA SHEET Emergency Phone: 800-992-5994 Dow AgroSclences LLC Dow AgroSciences Indianapolis, IN 46268 Effective Date: 5/10/05 GARLON* 4 HERBICIDE Product Code: 38322 MSDS: 004788 1. PRODUCT AND COMPANY IDENTIFICATION:

I5. FIRE FIGHTING MEASURES: PRODUCT: Garlon* 4 Herbicide COMPANY IDENTIFICATION:

Dow AgroSciences LLC 9330 Zionsville Road Indianapolis, IN 46268-1189 FLASH POINT: 147°F (640C)METHOD USED: TCC FLAMMABLE LIMITS LFL: Not determined UFL: Not determined

12. COMPOSITION/INFORMATION ON INGREDIENTS:

EXTINGUISHING MEDIA: Water fog, foam, C0 2 , and dry Triclopyr

((3,5,6-trichloro-2-pyridinyl)oxy) acetic acid, butoxy ethyl ester Balance, total, including:

Kerosene CAS# 064700-56-7 CAS# 008008-20-6 61.6%chemical.FIRE & EXPLOSION HAZARDS: Combustible.

Toxic, 38.4% irritating vapors may be produced if product is involved in fire.13. HAZARDOUS IDENTIFICATIONS:

EMERGENCY OVERVIEW Amber liquid. Combustible.

Kerosene-like odor. May cause eye and skin irritation.

Toxic to aquatic organisms.

EMERGENCY PHONE NUMBER: 800-992-5994 j FIRE-FIGHTING EQUIPMENT:

Use positive pressure self-contained breathing apparatus and full protective clothing.F6. ACCIDENTAL RELEASE MEASURES: ACTION TO TAKE FOR SPILLS/LEAKS:

Keep out of streams and domestic water supplies.

Absorb small spills in inert material such as sand. For large spills, dike the area] and contact Dow AgroSciences at 800-992-5994.

j4. FIRST AID: EYES: Flush eyes thoroughly with water for several minutes. Remove contact lenses after initial 1-2 minutes and continue flushing for several minutes. If affects occur, consult a physician, preferably an ophthalmologist.

SKIN: Wash skin with plenty of water.INGESTION:

Do not induce vomiting.

Call a physician and/or transport to emergency facility immediately.

INHALATION:

Move to fresh air. If not breathing, give artificial respiration.

If breathing is difficult, oxygen should be administered by qualified personnel.

Call a physician or transport to a medical facility.7. HANDLING AND STORAGE: PRECAUTIONS TO BE TAKEN IN HANDLING AND STORAGE: Keep out of reach of children.

Do not use near heat or open flame. Harmful if swallowed, inhaled, or absorbed through skin. Avoid contact with eyes, skin and clothing.

Avoid breathing mists and vapors. Avoid contamination of food. Store above 28 0 F or agitate before use. Users should wash hands before eating, drinking, chewing gum, using tobacco, or using the toilet. For handling relative to end-use of this product, read the product label for further information concerning the use of personal protective equipment (PPE) under the Worker Protection Standard of 1993. Store in the original container.

NOTE TO PHYSICIAN:

The decision of whether to induce vomiting or not should be made by a physician.

If lavage is performed, suggest endotracheal and/or esophageal control. Danger from lung aspiration must be weighed against toxicity when considering emptying the stomach.No specific antidote.

Treatment of exposure should be directed at the control of symptoms and the clinical condition of the patient.*Trademark of Dow AgroSciences I

MATERIAL SAFETY DATA SHEET Emergency Phone: 800-992-5994 Dow AgroSciences LLC Dow AgroSciences Indianapolis, IN 46268 Effective Date: 5/10/05 GARLON* 4 HERBICIDE Product Code: 38322 MSDS: 004788 8. EXPOSURE CONTROLS/PERSONAL PROTECTION:

1[9. PHYSICAL AND CHEMICAL PROPERTIES These precautions are suggested for conditions where a potential for exposure exists. Emergency conditions may require additional precautions.

EXPOSURE GUIDELINE(S):

3,5,6-Trichloro-2-pyridinyloxyacetic acid, Dowanol EB ester: Dow AgroSciences Industrial Hygiene Guide is 2 mg/M 3 as acid equivalent, Skin.Kerosene:

Dow AgroSciences Industrial Hygiene Guide is 10 mg/M 3.A "skin" notation following the exposure guideline refers to the potential for dermal absorption of the material.

It is intended to alert the reader that inhalation may not be the only route of exposure and that measures to minimize dermal exposures should be considered.

ENGINEERING CONTROLS:

Provide general and/or local exhaust ventilation to control airborne levels below the exposure guidelines.

RECOMMENDATIONS FOR MANUFACTURING, COMMERCIAL BLENDING, AND PACKAGING WORKERS: RESPIRATORY PROTECTION:

Atmospheric levels should be maintained below the exposure guidelines.

When respiratory protection is required for certain operations, use a NIOSH approved air-purifying respirator.

SKIN PROTECTION:

Use protective clothing chemically resistant to this material.

Selection of specific items such as faceshield, gloves, boots, apron, or full body suit will depend on operation.

Remove contaminated clothing immediately, wash skin area with soap and water, and launder clothing before reuse or dispose of properly.EYE/FACE PROTECTION:

Use safety glasses.APPLICATORS AND ALL OTHER HANDLERS:

Refer to the product label for personal protective clothing and equipment.

BOILING POINT: >302°F (150'C) initial VAPOR PRESSURE:

0.1 mm @ 37.8°C (kerosene)

VAPOR DENSITY: >1 SOLUBILITY IN WATER: Emulsifies SPECIFIC GRAVITY: 1.08 APPEARANCE:

Amber liquid ODOR: Kerosene-like

10. STABILITY AND REACTIVITY:

STABILITY: (CONDITIONS TO AVOID) Combustible.

Avoid sources of ignition if temperature is near or above flash point. Stable under normal storage conditions.

INCOMPATIBILITY: (SPECIFIC MATERIALS TO AVOID)Acid, base, and oxidizing material.HAZARDOUS DECOMPOSITION PRODUCTS:

Nitrogen oxides, hydrogen chloride, and phosgene may result under fire conditions.

HAZARDOUS POLYMERIZATION:

Not known to occur.F11. TOXICOLOGICAL INFORMATION:

POTENTIAL HEALTH EFFECTS: This section includes possible adverse effects, which could occur if this material is not handled in the recommended manner.EYE: May cause slight temporary eye irritation.

Corneal injury is unlikely.SKIN: Prolonged or repeated contact may cause skin irritation.

Prolonged or frequently repeated skin contact may cause allergic skin reactions in some individuals.

With the dilute mix, no allergic skin reaction is expected.Prolonged skin contact is unlikely to result in absorption of harmful amounts. Repeated skin contact may result in absorption of harmful amounts. The LD 5 0 for skin absorption is >2000 mg/kg (rabbits) and >5000 mg/kg (rats).*Trademark of Dow AgroSciences 2

MATERIAL SAFETY DATA SHEET--Emergency Phone: 800-992-5994 Dow AgroSciences LLC ( oDow AgroSciences Indianapolis, IN 46268 Effective Date: 5/10/05 GARLON* 4 HERBICIDE Product Code: 38322~MSDS: 004788 INGESTION:

Low toxicity if swallowed.

The oral LD 5 0 for rats is 1581 mg/kg (males) and 1338 mg/kg (females).

Small amounts swallowed incidental to normal handling operations are not likely to cause injury; however, swallowing larger, amounts may cause injury. Aspiration into the lungs may occur during ingestion or vomiting, causing lung damage or even death due to chemical pneumonia.

INHALATION:

Excessive exposure may cause irritation to upper respiratory tract (nose and throat). Kerosene may cause central nervous system effects.SYSTEMIC (OTHER TARGET ORGAN) EFFECTS: Triclopyr BEE, in animals, effects have been reported on the following organs: blood, kidney, and liver.CANCER INFORMATION:

Triclopyr BEE did not cause cancer in laboratory animals. In a lifetime animal dermal carcinogenicity study, an increased incidence of skin tumors was observed when kerosene was applied at doses that also produced skin irritation.

This response was similar to that produced in skin by other types of chronic chemical/physical irritation.

No increase in tumors was observed when non-irritating dilutions of kerosene were applied at equivalent doses, indicating that kerosene is unlikely to cause skin cancer in the absence of long-term continued skin irritation.

In long-term animal studies with ethylene glycol butyl ether, small but statistically significant increases in tumors were observed in mice but not rats.The effects are not believed to be relevant to humans. If the material is handled in accordance with proper industrial handling, exposures should not pose a carcinogenic risk to man.TERATOLOGY (BIRTH DEFECTS):

For triclopyr BEE, birth defects are unlikely.

Exposures having no effect on the mother should have no effect on the fetus. Did not cause birth defects in animals; other effects were seen in the fetus only at doses which caused toxic effects to the mother.MUTAGENICITY:

For triclopyr BEE, in-vitro and animal mutagenicity studies were negative.12. ECOLOGICAL INFORMATION:

ENVIRONMENTAL FATE: MOVEMENT & PARTITIONING:

Bioconcentration potential is moderate (BCF between 100 and 3000 or Log Pow between 3 and 5).Measured log octanol/water partition coefficient (Log Pow)is 4.09.Log air/water partition coefficient (Log Kaw) is -4.0.DEGRADATION

& PERSISTENCE:

Biodegradation under aerobic static laboratory conditions is moderate (BOD20 or BOD28/ThOD between 10 and 40%).ECOTOXICOLOGY:

Material is highly toxic to aquatic organisms on an acute basis (LCr 0/EC 5 0 is between 0.1 and 1 mg/L in most sensitive species).13. DISPOSAL CONSIDERATIONS:

DISPOSAL METHOD: If wastes and/or containers cannot be disposed of according to the product label directions, disposal of this material must be in accordance with your local or area regulatory authorities.

This information presented below only applies to the material as supplied.The identification based on characteristic(s) or listing may not apply if the material has been used or otherwise contaminated.

It is the responsibility of the waste generator to determine the toxicity and physical properties of the material generated to determine the proper waste identification and disposal methods in compliance with applicable regulations.

If the material as supplied becomes a waste, follow all applicable regional, national and local laws and regulations.

REPRODUCTIVE EFFECTS: Triclopyr BEE, in laboratory animal studies, effects on reproduction have been seen only at doses that produced significant toxicity to the parent animals.*Trademark of Dow AgroSciences 3

MATERIAL SAFETY DATA SHEET Emergency Phone: 800-992-5994 Dow AgroSciences LLC C§0Dow AgroSciences Indianapolis, IN 46268 Effective Date: 5/10/05 GARLON* 4 HERBICIDE Product Code: 38322 MSDS: 004788 14. TRANSPORT INFORMATION:

U.S. DEPARTMENT OF TRANSPORTATION INFORMATION FOR ALL NON-BULK PACKAGES SHIPPED BY AIR, LAND OR WATER: This material is not regulated for transport.

FOR BULK PACKAGES SHIPPED BY LAND: COMBUSTIBLE LIQUID, N.O.S. (CONTAINS KEROSENE)/COMBUSTIBLE LIQUID/NA1993/PGIII 115. REGULATORY INFORMATION:

] STATE RIGHT-TO-KNOW:

The following product components are cited on certain state lists as mentioned.

Non-listed components may be shown in the composition section of the MSDS.CHEMICAL NAME Kerosene CAS NUMBER 008008-20-6 LIST PAl NJ3 NJ3=New Jersey Workplace Hazardous Substance (present at greater than or equal to 1.0%).PAl =Pennsylvania Hazardous Substance (present at greater than or equal. to 1.0%).NOTICE: The information herein is presented in good faith and believed to be accurate as of the effective date shown above. However, no warranty, express or implied, is given.Regulatory requirements are subject to change and may differ from one location to another; it is the buyer's responsibility to ensure that its activities comply with federal, state or provincial, and local laws. The following specific information is made for the purpose of complying with numerous federal, state or provincial, and local laws and regulations.

U.S. REGULATIONS SARA 313 INFORMATION:

To the best of our knowledge, this product contains no chemical subject to SARA Title III Section 313 supplier notification requirements.

SARA HAZARD CATEGORY:

This product has been reviewed according to the EPA "Hazard Categories" promulgated under Sections 311 and 312 of the Superfund Amendment and Reauthorization Act of 1986 (SARA Title III) and is considered, under applicable definitions, to meet the following categories:

OSHA HAZARD COMMUNICATION STANDARD:

This product is a "Hazardous Chemical" as defined by the OSHA Hazard Communication Standard, 29 CFR 1910.1200.

NATIONAL FIRE PROTECTION ASSOCIATION (NFPA)RATINGS: Health 2 Flammability 2 Reactivity 1 COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION AND LIABILITY ACT (CERCLA, or SUPERFUND):

To the best of our knowledge, this product contains no chemical subject to reporting under CERCLA.16. OTHER INFORMATION:

MSDS STATUS: Revised Sections:

3,11, 13

Reference:

DR-0196-5102 Replaces MSDS dated: 2/22/02 Document Code: D03-102-003 Replaces Document Code: D03-102-002 An immediate health hazard A delayed health hazard A fire hazard ,TOXIC SUBSTANCES CONTROL ACT (TSCA): All ingredients are on the TSCA inventory or are not required to be listed on the TSCA inventory.

The Information Herein Is Given In Good Faith, But No Warranty, Express or Implied, Is Made. Consult Dow AgroSciences for Further Information.

• Trademark of Dow AgiroSciences 4

6Al Specimen Label*f Dow AgroSciences 4 Personal Protective Equipment (PPE)WPS Uses: Applicators and other handlers who handle this pesticide for any use covered by the Worker Protection Standard (40 CFR Part 170) -for this product, forestry sites -must wear:* Long-sleeved shirt and long pants" Shoes plus socks Non-WPS Uses: Applicators and other handlers who handle this pesticide for any use NOT covered by the Worker Protection Standard (40 CFR Part 170) -for this product, non-forestry sites -- must wear: " Long-sleeved shirt and long pants" Shoes plus socks Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for washables are given, use detergent and hot water.Keep and wash PPE separately from other laundry.Engineering Controls When handlers use closed systems, enclosed cabs, or aircraft in a manner that meets the requirements listed in the WPS (40 CFRF 170.240(d)(4-6), the handler PPE requirements may be reduced or modified as specified in the WPS.Specialty Herbicide lTrademark of Dow AgroSciences LLC For the control of woody plants and annual and perennial broadleaf weeds in non-crop areas, including industrial manufacturing and storage sites, rights-of-way such as electrical power lines, communication lines, pipelines, roadsides, railroads, fence rows, non-irrigation ditch banks, forests and in the establishment and maintenance of wildlife openings.

Use on these sites may include application to grazed areas.Active Ingredient:

triclopyr:

3,5,6-tdchloro-2-pyridinyloxyacetic acid, butoxyethyl ester .............................

61.6%Inert Ingredients

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

38.4%T otal ............................................................................................

100.0%Contains petroleum distillates Acid equivalent:

triclopyr

-44.3% -4 lb/gal EPA Reg. No. 62719-40 Keep Out of Reach of Children CAUTION PRECAUCION Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not understand the label, find someone to explain it to you in detail.)Precautionary Statements Hazards to Humans and Domestic Animals Causes Moderate Eye Irritation 9 Harmful If Swallowed 9 Prolonged Or Frequently Repeated Skin Contact May Cause Allergic Reactions In Some Individuals Avoid contact with eyes or clothing.

Wash thoroughly with soap and water after handling and before eating, drinking, chewing gum, or using tobacco.First Aid If In eyes: Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a poison control center or doctor for treatment advice.It swallowed:

Immediately call a poison control center or doctor. Do not induce vomiting unless told to do so by a poison control center or doctor. Do not give any liquid to the person. Do not give anything by mouth to an unconscious person.Note to Physician:

This product may pose an aspiration pneumonia hazard. Contains petroleum distillates.

Have the product container or label with you when calling a poison control center or doctor, or going for treatment.

You may also contact 1-800-992-5994 for emergency medical treatment information.

Environmental Hazards This pesticide is toxic to fish. Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwater or rinsate.This chemical has properties and characteristics associated with chemicals detected in groundwater.

The use of this chemical in areas where soils are permeable, particularly where the water table is shallow, may result in groundwater contamination.

Physical or Chemical Hazards Combustible.

Do not use or store the product near heat or open flame.

Notice: Read the entire label. Use only according to label directions.

Non-Agricultural Use Requirements Before using this product, read Warranty Disclaimer, Inherent The requirements In this box apply to all use sites on this label Risks of Use, and Limitation of Remedies elsewhere on this label. except for forestry uses.If terms are unacceptable, return at once unopened.The requirements in this box apply to uses of this product that are In case of emergency endangering health or the environment involving NOT within the scope of the Worker Protection Standard for Agricultural this product, call 1-800-992-5994.

If you wish to obtain additional Pesticides (40 CFR Part 170). The WPS applies when this product product information, visit our web site at www.dowagro.com.

is used to produce agricultural plants on farms, forests, nurseries, or greenhouses.

Agricultural Chemical:

Do not ship or store with food, feeds, drugs or clothing.

Entry Restrictions for Non-WPS Uses: For applications to non-cropland areas, do not allow entry into areas until sprays have dried.Directions for Use It is a violation of Federal law to use this product in a manner inconsistent Storage and Disposal with its labeling.

Do not contaminate water, food, or feed by storage and disposal.Read all Directions for Use carefully before applying.

Open dumping is prohibited.

Do not apply this product in a way that will contact workers or other Pesticide Storage: Store above 28sF or agitate before use.persons, either directly or through drift. Only protected handlers may be Pesticide Disposal:

Wastes resulting from the use of this product in the area during application.

For any requirements specific to your state (that cannot be used according to label instructions) may be disposed or tribe, consult the agency responsible for pesticide regulation, of on site or at an approved waste disposal facility.Container Disposal:

Triple rinse (or equivalent).

Then offer for recycling or reconditioning, or puncture and dispose of in a sanitary landfill, or by Agricultural Use Requirements incineration, or, if allowed by state and local authorities, by burning. If The requirements in this box apply to forestry uses. bumed, stay out of smoke.Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170. This standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of agricultural pesticides.

Use Garlon 4 specialty herbicide for the control of woody plants and It contains requirements for training, decontamination, notification, annual and perennial broadleaf weeds in non-crop areas, including and emergency assistance.

It also contains specific instructions and industrial manufacturing and storage sites, rights-of-way such as exceptions pertaining to the statements on this label about personal electrical power lines, communication lines, pipelines, roadsides and protective equipment (PPE) and restricted-entry interval.

The railroads, fence rows, non-irrigation ditch banks; forests and in the requirements in this box only apply to uses of this product that are establishment and maintenance of wildlife openings.

Use on these covered by the Worker Protection Standard.

sites may include application to grazed areas.Do not enter or allow worker entry into treated areas during the restricted General Use Precautions and Restrictions entry interval (REI) of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.In Arizona: The state of Arizona has not approved Garlon 4 for use PPE required for early entry to treated areas that is permitted under the on plants grown for commercial production; specifically forests grown Worker Protection Standard and that involves contact with anything that for commercial timber production, or on designated grazing areas.has been treated, such as plants, soil, or water, is: " Coveralls When applying this product in tank mix combination, follow all applicable" Chemical-resistant gloves use directions, precautions, and limitations on each manufacturer's label." Shoes plus socks Protective eyewear Chemigation:

Do not apply this product through any type of irrigation system.Do not apply Garlon 4 directly to, or otherwise permit it to come into direct contact with, grapes, tobacco, vegetable crops, flowers, or other desirable broadleaf plants. Do not permit spray mists containing Garlon 4 to drift onto such plants.It is permissible to treat non-irrigation ditch banks, seasonally dry wetlands (such as flood plains, deltas, marshes, swamps, or bogs)and transitional areas between upland and lowland sites where surface water isnot present except in isolated pockets due to uneven or unlevel conditions.

Do not apply to open water (such as lakes, reservoirs, rivers, streams, creeks, salt water bays, or estuaries).

2 Specimen Label Revised 01 07 Do not apply on ditches currently being used to transport irrigation water. Do not apply where runoff or irrigation water may flow onto* agricultural land as injury to crops may result.Do not apply this product using mist blowers unless a drift control additive, high viscosity inverting system, or equivalent is used to control spray drift.Sprays applied directly to Christmas trees may result in conifer injury. When treating unwanted vegetation in Christmas tree plantations, care should be taken to direct sprays away from conifers.Garlon 4 is formulated as a low volatile ester. However, the combination of spray contact with impervious surfaces, such as roads and rocks, and increasing ambient air temperatures, may result in an increase in the volatility potential for this herbicide, increasing a risk for off-target injury to sensitive crops such as grapes and tomatoes." Apply no more than 1/2 gallon of Garlon 4 (2 lb ae of triclopyr) per acre per growing season on range and pasture sites, including rights-of-way, fence rows or any area where grazing or harvesting is allowed." On forestry sites, Garlon 4 may be used at rates up to 6 quarts (6 lb ae of triclopyr) per acre per year." Garlon 4 may be used at rates up to 8 quarts (8 lb ae of triclopyr) per acre per year on non-crop areas including industrial manufacturing and storage sites, rights-of-way such as electricalpower lines, communication lines, pipelines, roadsides and railroads, fence rows, non-irrigation ditch banks.Grazing and Haying Restrictions Except for lactating dairy animals, there are no grazing restrictions following application of this product." Grazing Lactating Dairy Animals: Do not allow lactating dairy animals to graze treated areas until the next growing season following application of this product." Do not harvest hay for 14 days after application." Grazed areas of non-cropland and forestry sites may be spot treated if they comprise no more than 10% of the total grazable area.Slaughter Restrictions:

During the season of application, withdraw livestock from grazing treated grass at least 3 days before slaughter.

Avoiding Injurious Spray Drift Make applications only when there is little or no hazard from spray drift. Small quantities of spray, which may not be visible, may seriously injure susceptible plants. Do not spray when wind is blowing toward susceptible crops or ornamental plants that are near enough to be injured. It is suggested that a continuous smoke column at or near the spray site or a smoke generator on the spray equipment be used to detect air movement, lapse conditions, or temperature inversions (stable air). If the smoke layers or indicates a potential of hazardous spray drift, do not spray.Aerial Application (Helicopter Only): For aerial application on rights-of-way or other areas near susceptible crops, apply through a Microfoil' or Thru-Valve boom', or use an agriculturally labeled drift control additive.Other drift reducing systems or thickened sprays prepared by using high viscosity inverting systems may be used it they are made as drift-free as mixtures containing agriculturally labeled thickening agents or applications made with the Microfoil or Thru Valve boom. Do not use a thickening agent with the Microtoil or Thru Valve booms, or other systems that cannot accommodate thick sprays. Spray only when the wind velocity is low (follow state regulations).

Avoid application during air inversions.

It a spray thickening agent is used, follow all use recommendations and precautions on the product label.Reference within this label to a particular piece of equipment produced by or available form other parties is provided without consideration for use by the reader at its discretion and subject to the reader's independent circumstances, evaluation, and expertise.

Such reference by Dow AgroSciences is not intended as an endorsement of such equipment, shall not constitute a warranty (express or implied) of such equipment, and is not intended to imply that other equipment is not available and equally suitable.

Any discussion of methods of use of such equipment does not imply that the reader should use the equipment other than is advised in directions available from the equipment's manufacturer.

The reader is responsible for exercising its own judgment and expertise, or consulting with sources other than Dow AgroSciences, in selecting and determining how to use its equipment.

Spray Drift Management Avoiding spray drift at the application site is the responsibility of the applicator.

The interaction of many equipment and weather related factors determine the potential for spray drift. The applicator and the grower are responsible for considering all these factors when making decisions.

The following drift management requirements must be followed to avoid off-target drift movement from aerial applications:

1. The distance of the outer most operating nozzles on the boom must not exceed 3/4 the length of the rotor.2. Nozzles must always point backward parallel with the air stream and never be pointed downwards more than 45 degrees.Where states have more stringent regulations, they should be observed.The applicator should be familiar with and take into account the information covered in the following Aerial Drift Reduction Advisory.[This information is advisory in nature and does not supersede mandatory label requirements.]

Aerial Drift Reduction Advisory Information on Droplet Size: The most effective way to reduce drift potential is to apply large droplets.

The best drift management strategy is to apply the largest droplets that provide sufficient coverage and control. Applying larger droplets reduces drift potential, but will not prevent drift if applications are made improperly, or under unfavorable environmental conditions (see Wind, Temperature and Humidity, and Temperature Inversions).

3 Specimen Label Revised 01 07 Controlling Droplet Size: " Volume -Use high flow rate nozzles to apply the highest practical spray volume. Nozzles with higher rated flows produce larger droplets." Pressure -Do not exceed the nozzle manufacturer's recommended pressures..

For many nozzle types lower pressure produces larger droplets.

When higher flow rates are needed, use higher flow rate nozzles instead of increasing pressure." Number of Nozzles -Use the minimum number of nozzles that provide uniform coverage.* Nozzle Orientation

-Orienting nozzles so that the spray is released parallel to the airstream produced larger droplets than other orientations and is the recommended practice.

Significant deflection from horizontal will reduce droplet size and increase drift potential." Nozzle Type -Use a nozzle type that is designed for the intended application.

With most nozzle types, narrower spray angles produce larger droplets.

Consider using low-drift nozzles. Solid stream nozzles oriented straight back produce the largest droplets and the lowest drift.Boom Length: For some use patterns, reducing the effective boom length to less than 3/4 of the wingspan or rotor length may further reduce drift without reducing swath width.Application Height: Applications should not be made at a height greater than 10 feet above the top of the largest plants unless a greater height is required for aircraft safety. Making applications at the lowest height that is safe reduces exposure of droplets to evaporation and wind.Swath Adjustment:

When applications are made with a crosswind, the swath will be displaced downwind.

Therefore, on the up and downwind edges of the field, the applicator must compensate for this displacement by adjusting the path of the aircraft upwind. Swath adjustment distance should increase, with increasing drift potential (higher wind, smaller drops, etc.).Wind: Drift potential is lowest between wind speeds of 2 to 10 mph.However, many factors, including droplet size and equipment type determine drift potential at any given speed. Application should be avoided below 2 mph due to variable wind direction and high inversion potential.

Note: Local terrain can influence wind patterns.

Every applicator should be familiar with local wind patterns and how they affect spray drift.Temperature and Humidity:

When making applications in low relative humidity, set up equipment to produce larger droplets to compensate foe evaporation.

Droplet evaporation is most severe when conditions are both hot and dry.Temperature Inversions:

Applications should not occur during a local, low level temperature inversion because drift potential is high.Temperature inversions restrict vertical air mixing, which causes small suspended droplets to remain in a concentrated cloud. This cloud can move in unpredictable directions due to the light variable winds common during inversions.

Temperature inversions are characterized by increasing temperatures with altitude and are common on nights with limited cloud cover and light to no wind. They begin to form as the sun sets and often continue into the morning. Their presence can be indicated by ground fog; however, if fog is not present, inversions can also be identified by the movement of the smoke from a ground source or an aircraft smoke generator.

Smoke that layers and moves laterally in a concentrated cloud (under low wind conditions) indicates an inversion, while smoke that moves upward and rapidly dissipates indicates good vertical air mixing.Sensitive Areas: The pesticide should only be applied when the potentialfor drift to adjacent sensitive areas (e.g., residential areas, bodies of water, known habitat for threatened or endangered species, non-target crops) is minimal (e.g., when wind is blowing away from the sensitive areas).Ground Equipment:

To aid in reducing spray drift, Garlon 4 should be used in thickened (high viscosity) spray mixtures using an agriculturally labeled drift control additive, high viscosity invert system, or equivalent as directed by the manufacturer.

When using a spray thickening or inverting additive, follow all use directions and precautions on the product label.With ground equipment, spray drift can be reduced by keeping the spray boom as low as possible; by applying 20 gallons or more of spray per acre; by keeping the operating spray pressures at the lower end of the manufacturer's recommended pressures for the specific nozzle type used (low pressure nozzles are available from spray equipment manufacturers);

and by spraying when wind velocity is low. Do not apply with nozzles that produce a fine droplet spray. Select nozzles and pressures which provide adequate plant coverage, but minimize the production of fine spray particles.

High Volume Leaf-Stem Treatment:

To minimize spray drift, keep sprays no higher than brush tops and keep spray pressures low enough to provide coarse spray droplets.

An agriculturally labeled thickening agent may be used to reduce drift.Plants Controlled by Garlon 4 Woody Plant Species alder arrowwood ash aspen bear clover (bearmat)beech birch' blackberry blackgum boxelder'Brazilian pepper buckthorn cascara Ceanothus cherry chinquapin choke cherry cottonwood Crataegus (hawthorn) dogwood Douglas-fir elderberry elm gallberry gorse hazel hickory hornbeam kudzu" locust madrone maples mulberry oaks persimmon pine poison ivy poison oak poplar salmonberry salt-bush (Braccharis spp.)salt-cedart sassafras scotch broom sumac sweetbay magnolia sweetgum sycamore tanoak thimbleberry tree-of-heaven (Ailanthus)'

tulip poplar wax myrtle wild rose willow winged elm t For best control, use either a basal bark or cut stump treatment."For complete control, re-treatment may be necessary.

4 Specimen Label Revised 01-24-07 Tank Mixing: As a low volume foliage spray, up to 12 quarts of Garlon 4 may be applied in tank mix combination with labeled rates of Tordon K or Tordon 101 Mixture in 10 to 100 gallons of finished spray. Tordon 101 Mixture and Tordon K are not registered for use in the states of California and Florida.Broadcast Applications With Ground Equipment Apply using equipment that will assure thorough and uniform coverage of the spray volumes applied. See Table 1 for relationship between mixing rate, spray volume and maximum application rate.Woody Plant Control Foliage Treatment:

Use 4 to 8 quarts of Garton 4 in enough water to make 5 gallons or more of total spray per acre, or 1 1/2 to 3 quarts of Garton 4 may be combined with labeled rates of 2,4-D low volatile ester, Tordon 101 Mixture, or Tordon K in sufficient water to make 5 gallons or more of total spray per acre. Tordon 101 Mixture and Tordon K are not registered for use in the states of California and Florida.Broadleaf Weed Control Use Garlon 4 at rates of 1 to 4 quarts in a total volume of 5 gallons or more per acre as a water spray mixture. Apply anytime weeds are actively growing. Garlon 4 at 0.25 to 3 quarts may be tank mixed with labeled rates of 2,4-D amine or low volatile ester, Tordon K, or Tordon 101 Mixture to improve the spectrum of activity.

For thickened (high viscosity) spray mixtures, Garton 4 can be mixed with diesel oil or other inverting agent. When using an inverting agent, read and follow the use directions and precautions on the product label.Tordon 101 Mixture and Tordon K are not registered for use in the states of California and Florida.Aerial Application (Helicopter Only)Aerial sprays should be applied using suitable drift control.(See General.Use Precautions and Restrictions.)

Foliage Treatment (Utility and Pipeline Rights-of-Way)

Use 4 to 8 quarts of Garlon 4 alone, or 3 to 4 quarts of Garlon 4 in a tank mix combination with labeled rates of 2,4-D low volatile ester, Tordon 101 Mixture or Tordon K and apply in a total spray volume of 10 to 30 gallons per acre. Use the higher rates and volumes when plants are dense or under drought conditions.

Tordon 101 Mixture and Tordon K are not registered for use in the states of California and Florida.Basal Bark and Dormant Brush Treatments Mixing Directions To control susceptible woody plants in rights-of-way other non-crop areas, and forests, use Garlon 4 in oil or oil-water mixtures prepared and applied as described below. Prepare oil-based mixtures using either diesel fuel, No. 1 or No. 2 fuel oil, kerosene or a commercially available basal oil. Substitute other oils or diluents only as recommended by the oil or diluent's manufacturer.

When preparing an oil mixture, read and follow the use directions and precautions on the manufacturer's product label.See Table 1 for relationship between mixing rate, spray volume and maximum application rate.Note: All basal bark and dormant brush treatment methods may be used to treat susceptible woody species on range and permanent pasture land provided that no more than 2 quarts. of Garlon 4 are applied per acre.Large plants or species requiring higher rates of Garlon 4 may not be completely controlled.

Oil Mixture Sprays Add Garlon 4 to the required amount of oil in the spray tank or mixing tank and mix thoroughly.

If the mixture stands over 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, reagitation is required.Oil Mixtures of Garlon 4 and Tordon K: Tordon K and Garlon 4 may be used in tank mix combination for basal bark treatment of woody plants.*These herbicides are incompatible and will not form a stable mixture when mixed together directly in oil. Make a stable tank mixture for basal bark application by first combining each product with.a compatibility agent prior to final mixing in the desired ratio. (See product bulletin for mixing instructions.)

Tordon K is not registered for use in the states of California and Florida.Oil-Water Mixture Sprays Prepare a premix of oil, surfactant and Garlon 4 in a separate container.

Do not allow any water or mixtures containing water to get into the premix or Garlon 4 since a thick "invert" (water in oil) emulsion may form that will be difficult to break. Such an emulsion may also be formed if the premix or Garlon 4 is put into the mixing tank before the addition of water. Fill the spray tank about one-half full with water, then slowly add the premix with continuous agitation and complete filling the tank with water.Continue moderate agitation.

Basal Bark Treatment To control susceptible woody plants with stems less than 6 inches in basal diameter, mix 1 to 5 gallons of Garlon 4 in enough oil to make 100 gallons of spray mixture. Apply with knapsack sprayer or power spraying equipment using low pressure (20 to 40 psi). Spray the basal parts of brush and tree trunks to a height of 12 to 15 inches from the ground, thoroughly wetting the indicated area. Spray until runoff at the ground line is noticeable.

Old or rough bark requires more spray than smooth young bark. Apply anytime, including the winter months, except when snow or water prevent spraying to the ground line.Low Volume Basal Bark Treatment To control susceptible woody plants with stems less than 6 inches in basal diameter, mix 20 to 30 gallons of Garlon 4 in enough oil to make 100 gallons of spray mixture. Apply with a backpack or knapsack sprayer using low pressure and a solid cone or flat fan nozzle. Spray the basal parts of brush and tree trunks in a manner which thoroughly wets the lower stems, including the root collar area, but not to the point of runoff.Herbicide concentration should vary with size and susceptibility of species treated. Apply anytime, including the winter months, except when snow or water prevent spraying to the ground line or when stem surfaces are saturated with water. See Table 1 for relationship between mixing rate, spray volume and maximum application rate. Note: The addition of a soil active herbicide to a basal bark mixture with Garlon 4 may result in damage to surrounding non-target vegetation.

Care should be taken to assess the areas in which these soil active herbicides are used in combination with Garlon 4 in basal bark applications.

6 Specimen Label Revised 01 07 Garlon 4 Plus Tordon K In Oil Tank Mix: Garlon 4 and Tordon K may be used in tank mix combination as a low volume basal bark treatment to improve control of certain woody species such as ash, elm, maple, poplar, aspen, hackberry, oak, oceanspray, birch, hickory, pine, tanoak, cherry, locust, sassafras, and multiflora rose. (See product bulletin for mixing instructions.)

Tordon K is not registered for use in the states of California and Florida.Streamline Basal Bark Treatment (Southern States)To control or suppress susceptible woody plants for conifer release, mix 20 to 30 gallons of Garlon 4 in enough oil to make 100 gallons of spray mixture. Apply with a backpack or knapsack sprayer using equipment which provides a directed straight stream spray. Apply sufficient spray to one side of stems less than 3 inches in basal diameter to form a treated zone that is 6 inches in height. When the optimum amount of spray mixture is applied, the treated zone should widen to encircle the stem within approximately 30 minutes. Treat both sides of stems which are 3 to 4 inches in basal diameter.

Direct the spray at bark that is approximately 12 to 24 inches above ground. Pines (loblolly, slash, shortleaf, and Virginia) up to 2 inches in diameter breast height (dbh) can be controlled by directing the spray at a point approximately 4 feet above ground. Vary spray mixture concentration with size and susceptibility of the species being treated. Best results are achieved when applications are made to young vigorously growing stems which have not developed the thicker bark characteristic of slower growing, understory trees in older stands. This technique is not recommended for scrub and live oak species, including blackjack, turkey, post, live, bluejack and laurel oaks, or bigleaf maple. Apply from approximately 6 weeks prior to hardwood leaf expansion in the spring until approximately 2 months after leaf expansion is completed.

Do not apply when snow or water prevent spraying at the desired height above ground level.Low Volume Stem Bark Band Treatment (North Central*and Lake States)To control susceptible woody plants with stems less than 6 inches in basal diameter, mix 20 to 30 gallons of Gardon 4 in enough oil to make 100 gallons of spray mixture. Apply with a backpack or knapsack sprayer using low pressure and a solid cone or flat fan nozzle. Apply the spray in a 6- to 10-inch wide band that completely encircles the stem. Spray in a manner that completely wets the bark, but not to the point of runoff.The treatment band may be positioned at any height up to the first major branch. For best results, apply the band as low as possible.

Spray mixture concentration should vary with size and susceptibility of species to be treated. Applications may be made anytime, including winter months.Thinline Basal Bark Treatment To control susceptible woody plants with stems less than 6 inches in diameter, apply Garton 4, either undiluted or mixed at 50 to 75% v/v with oil, in a thin stream to all sides of the lower stems. The stream should be directed horizontally to apply a narrow band of Garton 4 around each stem or clump. Use a minimum of 2 to 15 milliliters of Garlon 4 or oil mixture with Garlon 4 to treat single stems and from 25 to 100 milliliters to treat clumps of stems. Use an applicator metered or calibrated to deliver the small amounts required.Dormant Stem Treatment Dormant stem treatments control susceptible woody plants and vines with stems less than 2 inches in diameter.

Plants with stems greater than 2 inches in diameter may not be controlled and resprouting may occur.This treatment method is best suited for sites with dense, small diameter brush. Dormant stem treatments of Garlon 4 can also be used as a chemical side-trim tar controlling lateral branches of larger trees that encroach onto roadside, utility, or other rights-of-way.

Mix 4 to 8 quarts of Garlon 4 in 2 to 3 gallons of crop oil concentrate or other recommended oil and add this mixture in enough water to make 160 gallons of spray solution.

Use continuous adequate agitation.

Apply with Radiarc, OC or equivalent nozzles, or handgun using 70 to 100 gallons of spray per acre to ensure uniform coverage of stems.Garlon 4 may be mixed with 4 quarts of Weedone 170 herbicide to improve the control of black cherry and broaden the spectrum of herbicidal activity.

In western states, apply anytime after woody plants are dormant. In other areas apply anytime within 10 weeks of budbreak, generally February through April. Do not apply to wet or saturated bark as poor control may result.Cut Stump Treatment To control resprouting, mix 20 to 30 gallons of Garlon 4 in enough oil to make 100 gallons of spray mixture. Apply with a backpack or knapsack sprayer using low pressures and a solid cone or flat fan nozzle. Spray the root collar area, sides of the stump, and the outer portion of the cut surface, including the cambium, until thoroughly wet, but not to the point of runoff.* Spray mixture concentration should vary with the size and susceptibility of species treated. Apply anytime, including in winter months, except when snow or water prevent spraying to the ground line.Cut Stump Treatment in Western States To control resprouting of salt cedar and other Tamarix species, bigleaf maple, tanoak, Oregon myrtle, and other susceptible species, apply undiluted Garlon 4 to wet the cambium and adjacent wood around the entire circumference of the cut stump. Treatments may be applied throughout the year; however, control may be reduced with treatment during periods of moisture stress as in late summer. Use an applicator which can be calibrated to deliver the small amounts of material required.Forest Management Applications For broadcast applications, apply 1 to 6 quarts of Garlon 4 per acre in a total spray volume of 5 to 25 gallons per acre by air or 10 to 100 gallons per acre by ground. Use spray volumes sufficient to provide thorough coverage of treated foliage. Nozzles or additives that produce larger droplets of spray may require higher spray volumes to provide adequate coverage.7 Specimen Label Revised 01-24-07 Forest Site Preparation (Not for Conifer Release)Southern States including Alabama, Arkansas, Delaware, Florida, Georgia, Louisiana, Maryland, Mississippi, North Carolina, Oklahoma, South Carolina, Tennessee, Texas, and Virginia:

To control susceptible woody plants and broadleaf weeds, apply Garlon 4 at a rate of 4 to 6 quarts per acre. To broaden the spectrum of woody plants and broadleaf weeds controlled, apply 2 to 4 quarts of Garlon 4 per acre in tank mix combination with labeled rates of Tordon 101 Mixture or Tordon K. Tordon 101 Mixture and Tordon K are not registered for use in the state of Florida. Where grass control is also desired, Garlon 4 alone or in tank mix combination with Tordon K or Tordon 101 Mixture may be applied with labeled rates of other herbicides registered for grass control in forests. Use of tank mix products must be in accordance with the most restrictive of label limitations and precautions.

Do not exceed labeled application rates. Garlon 4 cannot be tank mixed with any product containing a label prohibition against such mixing.Western, Northeastern, North Central, and Lake States (States not Listed Above as Southern States): To control susceptible woody plants and broadleaf weeds, apply Garlon 4 at a rate of 3 to 6 quarts per acre. To broaden the spectrum of woody plants and broadleaf weeds controlled, apply 1.5 to 3 quarts of Garlon 4 per acre in tank mix combination with labeled rates of Tordon 101 Mixture, Tordon K, or 2,4-D low volatile ester. Tordon 101 Mixture and Tordon K are not registered for use in the state of California.

Where grass control is also desired, Garton 4 alone or in tank mix combination with Tordon 101 Mixture or Tordon K may be applied with labeled rates of other herbicides registered for grass control in forests. When applying tank mixes, follow applicable use directions and precautions on each product label.Southern Coastal Flatwoods:

To control susceptible broadleaf weeds and woody species such as gallberry and wax-myrtle, and for partial control of saw-palmetto, apply 2 to 4 quarts of Garlon 4 per acre.To broaden the spectrum of species controlled to include fetterbush, staggerbush, titi, and grasses, apply 2 to 3 quarts of Garlon 4 per acre in tank mix combination with labeled rates of Arsenal Applicator's Concentrate herbicide.

Where control of gallberry, wax-myrtle, broadleaf weeds, and grasses is desired, apply 2 to 3 quarts of Garlon 4 per acre in tank mix combination with labeled rates of Accord Concentrate or Accord SP herbicide.

These treatments may be broadcast during site preparation of flat planted or bedded sites or, on bedded sites, applied in bands over the top of beds. For best results, apply in late summer or fall. Efficacy may not be satisfactory when applications are made in early season prior to August. Note: Do not apply after planting pines.Note: Conifers planted sooner than 1 month after treatment with Garlon 4 at less than 4 quarts per acre or sooner than 2 months after treatment at 4 to 6 quarts per acre may be injured. When tank mixtures of herbicides are used for forest site preparation, labels for all products in the mixture should be consulted and the longest recommended waiting period before planting observed.Directed Spray Applications for Conifer Release To release conifers from competing hardwoods and brush such as red maple, sugar maple, striped maple, sweetgum, red and white oaks, ash, hickory, alder, birch, aspen, pin cherry, Ceanothus spp., blackberry, chinquapin, and poison oak, mix 4 to 20 quarts of Garlon 4 in enough water to make 100 gallons of spray mixture. This spray mixture should be directed onto foliage of competitive hardwoods using knapsack or backpack sprayers with flat fan nozzles or equivalent any time after the hardwoods and brush have reached full leaf size, but before autumn coloration.

The majority of treated hardwoods and brush should be less than 6 feet in height to ensure adequate spray coverage.

Care should be taken to direct spray away from contact with conifer foliage, particularly foliage of desirable pines. See Table 1 for relationship between mixing rate, spray volume and maximum application rate.Note: Spray may cause temporary damage and growth suppression.

where contact with conifers occurs; however, injured conifers should recover and grow normally.

Over-the-top spray applications can kill pines.Broadcast Applications for Mid-Rotation Understory Brush Control in Southern Coastal Flatwoods Pine Stands (Ground Equipment Only)For control of susceptible species such as gallberry and wax-myrtle and broadleaf weeds, apply 2 to 4 quarts of Garlon 4 per acre. To broaden the spectrum of woody plants controlled to include fetterbush, staggerbush, and titi, apply 2 to 3 quarts of Garlon 4 per acre in tank mix combination with labeled rates of Arsenal Applicator's Concentrate.

Saw-palmetto will be partially controlled by use of Garlon 4 at 4 quarts per acre or by mixtures of Garton 4 at 2 to 3 quarts per acre in tank mix combination with either Arsenal Applicator's Concentrate or Escort herbicide.

These mixtures should be broadcast applied over target understory brush species, but to prevent injury to pines, make applications underneath the foliage, of pines. Apply sprays in 30 gallons or more per acre of total volume. For best results, apply in late summer or fall. Efficacy may not be satisfactory when applications are made in early season prior to August.Broadcast Applications for Conifer Release in the Pacific Northwest and California Dormant Conifers Before Bud Swell (Excluding Pines): To control or suppress deciduous hardwoods such as vine maple, bigleaf maple, alder, scotch broom, or willow before leaf-out, or evergreen hardwoods such as madrone, chinquapin, and Ceanothus spp., use Garton 4 at 1 to 2 quarts per acre. Use diesel or fuel oil as a diluent, or use water plus 1 to 2 gallons per acre of diesel oil or a suitable surfactant or oil substitute at manufacturer's recommended rates.Conifer Plantations (Excluding Pines) After Hardwoods Begin Growth and Before Conifer Bud Break ("Early Foliar" Hardwood Stage): Use Garlon 4 at 1 to 1.5 quarts alone or with 2,4-D low volatile ester herbicide in water carrier to provide no more than 3 lb ae per acre from both products.

After conifer bud break, these sprays may cause more serious injury to the crop trees. Use of a surfactant may cause unacceptable injury to conifers especially after bud break.8 Specimen Label Revised 01-24-07 qlq Conifer Plantations (Excluding Pines) After Conifers Harden Off in Late Summer and While Hardwoods are Still Actively Growing: Use Garlon 4 at rates of 1 to 1.5 quarts per acre alone or with 2,4-D low volatile ester to provide no more than 3 lb ae per acre from both products.Treat as soon after conifer bud hardening as possible so thal hardwoods and brush are actively growing. Use of oil, oil substitute, or surtactant may cause unacceptable injury to the conifers.Broadcast Applications for Conifer Release in the Eastern United States To release spruce, fir, red pine, and white pine from competing hardwoods such as red maple, sugar maple, striped maple, alder, birch (white, yellow, and grey), aspen, ash, pin cherry, and Rubus spp.and perennial and annual broadleaf weeds, use Garlon 4 at rates of 1.5 to 3 quarts per acre alone or with 2,4-D amine or low volatile ester to provide no more than 4 lb ae per acre from both products.

Apply in late summer or early fall after conifers have formed their overwintering buds and hardwoods are in full leaf and prior to autumn coloration.

Broadcast Applications for Conifer Release in the Lake States Region To release spruce, fir, and red pine from competing hardwoods such as aspen, birch, maple, cherry, willow, oak, hazel, and Rubus spp. and perennial and annual broadleaf weeds, use Gadon 4 at rates of 1.5 to 3 quarts per acre. Apply in late summer or early fall after conifers have formed their overwintering buds and hardwoods are in full leaf and prior to autumn coloration.

Inherent Risks of Use It is impossible to eliminate all risks associated with use of this product.Plant injury, lack of performance, or other unintended consequences may result because of such factors as use of the product contrary to label instructions (including conditions noted on the label, such as untavorable temperature, soil conditions, etc.), abnormal conditions (such as excessive rainfall, drought, tornadoes, hurricanes), presence of other materials, the manner of application, or other factors, all of which are beyond the control of Dow AgroSciences or the seller. All such risks shall be assumed by buyer.Limitation of Remedies To the extent permitted by law, the exclusive remedy for losses or damages resulting from this product (including claims based on contract, negligence, strict liability, or other legal theories), shall be limited to, at Dow AgroSciences' election, one of the following:

1. Refund of purchase price paid by buyer or user for product bought, or 2. Replacement of amount of product used.Dow AgroSciences shall not be liable for losses or damages resulting from handling or use of this product unless Dow AgroSciences is promptly notified of such loss or damage in writing. In no case shall Dow AgroSciences be liable for consequential or incidental damages or losses.The terms of the Warranty Disclaimer, Inherent Risks of Use and this Limitation of Remedies cannot be varied by any written or verbal statements or agreements.

No employee or sales agent of Dow AgroSciences or the seller is authorized to vary or exceed the terms of the Warranty Disclaimer or this Limitation of Remedies in any manner.

of Dow AgroSciences LLC Dow AgroSciences LLC -Indianapolis, IN 46268 USA Label Code: D02-102-025 Replaces:

D02-102-024 Loes Number: 010-00085 EPA-Accepted 01/12/06 Revisions:

1. Revised grazing and haying restrictions.

2. Added spray drift management guidance.Terms and Conditions of Use If terms of the following Warranty Disclaimer, Inherent Risks of Use, and Limitation of Remedies are not acceptable, return unopened package at once to the seller for a full refund of purchase price paid. Otherwise, use by the buyer or any other user constitutes acceptance of the terms under Warranty Disclaimer, Inherent Risks of Use and Limitation of Remedies.Warranty Disclaimer Dow AgroSciences warrants that this product conforms to the chemical description on the label and is reasonably fit for the purposes stated on the label when used in strict accordance with the directions, subject to the inherent risks set forth below. Dow AgroSciences MAKES NO OTHER EXPRESS OR IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR ANY OTHER EXPRESS OR IMPLIED WARRANTY.9 Specimen Label Revised 01 07

67. Any available studies or other information about the issues raised in the letter from the U.S. Fish and Wildlife Service (November 14, 2005) regarding terrestrial threatened andendangered species.For example: -- Any assessments of the transmission lines for conformity with "Suggested Practices for Raptor Protection on Power Lines" (Raptor Research Foundation 1996)? Please provide any such assessments and details of transmission line construction relevant to raptor protection.

Also provide a copy of "Suggested Practices," if available.

Any special ROW maintenance procedures used to reduce the potential for impacts to Mead's milkweed or animals with federal or state listing status.

Terrestrial Ecology Page 1 of 1 e Clarify discussions regarding site boundaries, land ownership, and land use within Section 2.4 and Figure 2-3 of the ER (WCGS, 1980). Clarify the difference between"Site Boundary" and the "Plant Site" on the map, with respect to whether these are a land ownership distinction, a physical fencing distinction, or some other regulatory or access distinction.

Please claarify whether or not the referenced agricultural production areas are within the "Site Boundary" as shown on Figure 2-3. Identify any areas fenced to restrict human access and any areas fenced that may restrict wildlife access.* Additional data on the avian collision studies that were ceased in 1986. Section 2.4 of the ER (WCGS, 1980) states that sufficient data had been collected by 1986. Provide any documentation of regulatory involvement and concurrence in this determination of sufficiency.

• Details on the power transmission system, including information on the design of the towers, the number and configuration of the lines on the towers within each right-of-way (ROW).-Details regarding the maintenance procedures used in the transmission line ROWs, including mechanical, chemical, and biological control methods for vegetation management.

-More detailed maps/aerial photos of the transmission line ROWs showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains, and the location of the Sharpe Generating Station.* Please provide information on the locations of transmission line ROWs crossings with parks, wildlife refuges, or wildlife management areas, or any major lakes (in addition to CCL), ponds, or streams? If so, please provide information on these crossings and their locations.

-Any available studies or other information about the issues raised in the letter from the U.S. Fish and Wildlife Service (November 14, 2005) regarding terrestrial threatened and endangered species.For example:-- Any assessments of the transmission lines for conformity with "Suggested Practices for Raptor Protection on Power Lines" (Raptor Research Foundation 1996)? Please provide any such assessments and details of transmission line construction relevant to raptor protection.

Also provide a copy of,"Suggested Practices," if available.

-- Any special ROW maintenance procedures used to reduce the potential for impacts to Mead's milkweed or animals with federal or state listing status.* Any available maps and aerial photographs of the WCGS plant site and the area within and adjoining the larger site boundary (which encompasses CCL) showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains.

-Any available information identifying natural communities and dominant species of plants and animals that utilize terrestrial habitats of the site and the transmission line ROWs, as well as semiaquatic species such as waterfowl that use Lime Sludge Pond and CCL.

Terrestrial Ecology Audit Needs request #85"Please provide any available studies or other information about the issues raised in the letter from the U. S. Fish and Wildlife Service (No. 14, 2005)regarding terrestrial threatened and endangered species. For example: Have there been any assessments of the transmission lines for conformity with "Suggested Practices for Raptor Protection on Power Lines" (Raptor Research Foundation 1996)? Please provide any such assessments and details of transmission line construction relevant to raptor protection.

Is a copy of "Suggested Practices" available?

Are there any special ROW maintenance procedures used to reduce the potential for impacts to Mead's milkweed or animals with federal or state listing status?" Raptor protection:

The transmission lines, distribution lines, transformers, and associated hardware at Wolf Creek Generating Station (WCGS) have been assessed.

An Avian Protection Plan (APP), with emphasis on potential impacts to the Bald eagle has been completed as a result, and documents this assessment (see attached APP). This APP addresses electrocution, collision, chemical impacts, and disease pathogen concerns.Copies of applicable APP's for Westar Energy and Lyon-Coffey Rural Electric are also attached.

These documents cover bird interactions on transmission lines associated with WCGS that are maintained by these utilities.

A copy of "Suggested Practices for Raptor Protection on Power Lines" (Raptor Research Foundation 1996) is attached for reference.

Right-of-way (ROW) Maintenance:

There are no special ROW maintenance procedures used to reduce the potential for impacts to Mead's milkweed or animals with federal or state listing status. Any listed birds are included in applicable APP's.

Avian Protection Plan at Wolf Creek Generating Station with emphasis of potential impacts to the Bald Eagle from License Renewal at Wolf Creek Generating Station Wolf Creek Nuclear Operating Corporation August 2006 Prepared by: Supervisor Regulatory Support Approval: Manager Regulatory Affairs Approval:-N 2/15/07 Dan Haines Date 2/15/07 Robert Hammond Date KevinJ.Molee02/15/07 Kevin J. Moles Date 2 at Wolf Creek Generating Station

1.0 INTRODUCTION

It is the policy of Wolf Creek Nuclear Operating Corporation (WCNOC) to operate Wolf Creek Generating Station (WCGS) in a manner protecting environmental quality through implementation of an environmental protection program (Corporate Policy 5, Environmental Stewardship).

This environmental policy includes actions beyond regulatory compliance, some of which are identified within this Avian Protection Plan (APP).This APP addresses interactions with protected birds at WCGS. House sparrows, European starlings, and pigeons are not protected, are considered non-native pest species, and thus are not included within this APP. Addressed are current regulations and issues, WCGS bird enhancements activities, and nuisance situations and impacts to WCGS caused by protected species. However, the primary goal of this APP is to assess potential adverse impacts of WCGS to birds, identify improvements to minimize these impacts, and present contingency plans for potential future events.This APP is site-specific for WCGS, which is a nuclear electric generating station in east-central Kansas. Associated with WCGS are transmission lines, distribution lines, transformers, buildings, and a cooling lake (Coffey County Lake, CCL). Potential impacts to WCGS from bird interactions include electric service disruption to plant facilities, interruption of plant operation, personnel safety and health, and cleanliness.

Potential impacts to birds include electrocution, power line collision, prey base alterations, and disease pathogen presence.2.0 REGULATORY BASIS For WCGS, several regulatory concerns or permits are applicable to this APP and are as follows: 1. Appendix B to the Facility Operating License No. NPF-42, referencing the Final Environmental Statement, Operating License Stage (NUREG 0878), for WCGS, recommends a disease contingency plan for preventing or controlling a waterfowl disease episode. This APP includes a waterfowl disease contingency plan.2. Potential impacts were identified by the U. S. Fish and Wildlife Service (USFWS) during pre-submittal consultation with WCNOC for WCGS license extension action (see attached November 14, 2005 letter from M. J. LeValley, USFWS, to K. J. Moles, WCNOC). This APP addresses potential bald eagle impacts.3. The Migratory Bird Treaty Act (16 U.S.C. 703-712: MBTA) prohibits the taking, killing, possession, transportation and importation of migratory birds, their eggs, parts, and nests without USFWS permitting.

4. The Bald and Golden Eagle Protection Act (16 U.S.C. 668-668d:

BGEPA) provides additional protection to bald and golden eagles above that in the MBTA.

3 5. The Endangered Species Act (16 U.S.C. 1531-1544:

ESA), prohibits the take of a listed species. Take is defined as "...to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect or attempt to engage in any such conduct." 6. The Kansas Nongame and Endangered Species Conservation Act (K.S.A. 32-1009 to 32-1011) prohibits take and possession of state listed nongame, threatened or endangered species.7. The USFWS Migratory Bird Permit MB715225, and current revisions, has been issued for migratory bird salvage and mortality investigation at WCGS. This permit does not provide for take.8. The Kansas Department of Wildlife and Parks (KDWP) Scientific Collecting and Salvage Permit (currently SC-066-2006), and current renewals, is maintained for bird possession and mortality investigation at WCGS.3.0 BIRD ENHANCEMENT ACTIVITIES Offsetting potential adverse impacts to birds by WCGS, various enhancement activities have been completed at WCGS. The existence of the CCL has created excellent habitat for many bird species. In addition, WCNOC's land conservation and wildlife stewardship activities provide bird habitats.

These include shallow water wetland development, native grassland and forb management, and maintenance of forested habitats.WCNOC partnerships with wildlife agencies have also attempted to enhance regional bird diversity and habitat use. Ospreys were released in an attempt to promote a breeding population in Kansas. This was done in partnership with the KDWP from 1996 though 2000.Peregrine falcons were released in 2004 and 2005 in an ongoing attempt to promote nesting on plant facilities.

This was completed with KDWP and USFWS permitting and support.A pair of bald eagles have nested since 1994 in a tree inundated by the CCL. An area around the nest is buoyed off and human disturbance is prohibited within 300 yards of the nest site.WCNOC helps monitor this nest for the USFWS. Thermal effluents also provide foraging habitat for wintering bald eagles, which was not available prior to CCL.Enhancements for nesting around WCGS and the lake include placement of eastern bluebird, wood duck, American kestrel, and Canada goose structures.

4.0 BIRD IMPACTS TO WCGS Nuisance bird issues at WCGS involving protected species include perching/roosting, nesting attempts, and motion activity in security areas. Except for house sparrows, starlings and pigeons, lethal control methods are not considered for use at WCGS without specific permitting from the USFWS. Specific bird impacts to WCGS and preferred method for control are as follows: 1. Mixed blackbird flocks attracted to the lake typically roost on the construction power distribution loop in such numbers causing occasional electric service disruption to WGCS administration buildings.

Common practice is to insulate potential areas where 4 birds may cause phase-ground or phase-phase shorts. This also protects birds from electrocution.

2. Cliff swallows commonly attempt to nest on plant, buildings causing significant housekeeping and disease concerns associated with the mud nest colonies.

Control activities include netting or sheeting to eliminate nesting sites prior to active nesting. In areas where this isn't feasible, nest starts are removed before eggs are laid, thus preventing establishment of a nesting colony. Active colonies exist at the CCL spillway and the causeway bridge providing nearby colonies for displaced birds, thus preventing take. Nest starts are not considered active (without eggs or young), thus no permitting is required (USFWS 2003). Active, or suspected active nests are allowed to stay unless significant hazards are involved.

After evaluation by WCGS biologists, a permit from the USFWS will be obtained before nest removal in such instances.

3. Barn swallow nests tend to pose similar housekeeping concerns as Cliff swallows, except on a smaller scale. If nest site modification isn't feasible, then inactive nest start removal is completed.

Suspected or actual active nests are allowed to stay unless significant hazards are involved.

Such hazards may include safety concerns to personnel by adult birds protecting nests around ladders and stairs. WCGS biologists will evaluate on a case-by-case basis, and obtain specific USFWS permits before nest removal.4. Miscellaneous bird interactions in the past have included high bird activity in security motion detection areas, usually by swallows and mixed blackbird species. Noise and distress calls have been used to discourage bird activity and help reduce this problem.Eastern kingbird nesting has periodically caused personnel safety concerns at the meteorological tower and plant buildings.

When necessary, to remove such birds, specific permits from the USFWS are required.5.0 POTENTIAL IMPACTS TO BIRDS The potential impacts to protected bird species due to the presence and operation of WCGS include: 1. Electrocution with power-lines, poles and transformers

2. Collision on aerial lines 3. Chemical or thermal water quality impacts, particularly to the fish prey base of bald eagles 4. potential increase for waterfowl disease pathogens in the warm water discharge to CCL.Impacts to bald eagles are emphasized in this APP because this species is currently listed as threatened, thus protected by the ESA, as well as the MBTA and BGEPA. Removal fro the threatened list is currently being considered by the USFWS. As a threatened species, it deserves greater attention during the WCGS operating license extension process. The extension is an federal action by the Nuclear Regulatory Commission (NRC), and as such will require USFWS and Kansas Department of Wildlife and Parks consultation.

Potential impacts were identified by the USFWS during pre-submittal consultation with WCNOC (see attached 5 November 14, 2005 letter from M. J. LeValley, USFWS, to K. J. Moles, WCNOC). In addition bald eagles are large birds, and may be more susceptible to electrocution and collisions (APLIC 1994, 1996).To ensure WCGS exists with minimal impact to birds, and to address license extension concerns, this APP includes three main phases; (1) assessment, (2) improvement, and (3)future contingency plans.5.1 Assessment Phase for Avian Protection The assessment of power lines and facilities presented below were completed by WCNOC biologists using APLIC (1994, 1996) guidelines.

Biologists from two current APLIC member utilities, Great Plains Energy and Westar Energy assisted with this assessment.

Applicable reports and literature were used to address collision and water quality concerns.5.1.1 Electrocution Potential All lines were inspected for electrocution hazards using criteria in APLIC (1996). There are four primary types of aerial power lines, in addition to transformers, associated with WCGS. They include: 1. 345 kilovolt (kV) transmission lines owned and operated by Westar Energy, including the LaCygne to Benton, and Wolf Creek to Rose Hill lines..2. 69 kV transmission lines, including the WCGS tap of the Athens line (approximately four miles) owned and operated by Westar Energy, and the WCGS to Sharpe line (approximately 2.5 miles), owned and operated by Lyon-Coffey Electric Cooperative.

3. 13.8 kV distribution power loop operated by WCNOC.4. 1000 volt or less (typically 480.volt) distribution lines operated by WCNOC.5. Transformers at WCGS operated by WCNOC and Westar Energy.5.1.1.1 345 kV Transmission Lines There were no electrocution hazards to bald eagles and other birds identified at WCGS from the 345 kV transmission lines. The lines are owned, inspected, maintained, and operated by Westar Energy. As such, they are covered by Westar Energy's Avian Protection Plan (APP) which includes documentation and reporting to the USFWS of bird mortalities associated with the lines. The APP provides for retrofitting or modifying lines, poles, and equipment to bird safe standards where mortalities are known.In general, the conductor separation required for the 345kV transmission lines are more than can be spanned by birds, including the bald eagle, thus eliminating electrocution potential.

Insulator fouling by feces streaming, or nest construction may pose electrocution hazards (APLIC 1996). These types of bird interactions are inspected for and addressed by Westar Energy's routine inspections and APP.

6 5.1.1.2 69 kV Transmission Lines There has been bird electrocutions observed associated with WCGS. The WCGS tap of the Athens line is owned and operated by Westar Energy thus is part of its APP. Due to the design of this line, this line will not be dangerous to bald eagles.Design includes well-separated conductors on typical line poles, and non-grounded hardware and guys making phase to ground electrocutions unlikely (Figure 1). Poles also have safe tops available for perching, which bald eagles prefer.The WCGS to Sharpe line is owned and operated by the Lyon/Coffey County Rural Electric Cooperative, and is thus included in its policy for prevention of wildlife contacts.

This line is not expected to pose electrocution hazards to birds, including bald eagles. Design benefits included sufficient conductor separation and non-grounded insulator hardware reducing phase-ground electrocution potential.

Safe pole tops are also available for perching.

The line is also not located in habitat frequented by bald eagles.5.1.1.3 13.8 kV Distribution Power Loop Bald Eagle Interactions There has been no bald eagle electrocutions observed on the 13.8 kV Distribution Power Loop, sometimes called the "construction loop". This power loop surrounds the WCGS proper consisting of 64 poles spanning approximately 2.1 miles (reference WCNOC drawing 8025-E-1021).

It distributes power to various buildings and facilities, and is maintained by WCNOC. It consists of numerous pole-mounted transformers, jumper leads to under ground services, cutoff fuses, switches, and corners. These types of electric setups are known to present electrocution hazards to birds (APLIC 1996). Electrocution hazards were considered for each pole, with emphasis on bald eagle susceptibility.

Table 1 lists the benefits and detriments that each pole has, and prioritizes them as to their potential for eagle electrocutions.

For assessment of bald eagle electrocution potential, poles were prioritized from highest to lowest as; (1) known eagle roost poles, (2) likely roost poles, and (3)unlikely roost poles. As shown in Table 1, eagles have been known to roost on two poles, which were considered safe for bald eagles (Figure 2). No mitigation is recommended for these poles.Of the likely roost poles identified in Table 1, only pole 20 was considered potentially dangerous to bald eagles (Figure 3). This pole has close conductors and a horizontal cross-arm configuration.

The pole is also adjacent to water habitats, and may be an attractive roost site, especially for wintering bald eagles foraging around the lake. All remaining poles judged as likely roosts were not considered hazardous to bald eagles due to the multiple factors beneficial for preventing eagle electrocution as identified in Table 1.The remainder of the distribution power loop poles were considered unlikely to be used by bald eagles, and thus were not judged to pose significant electrocution threats. These poles are distant from likely foraging habitat, are around high human activity, in parking lots, or along mowed lawn areas. In addition, factors judged 7 beneficial for reducing electrocution potential offset many of the potential detrimental conditions (Table 1).Protected Bird Interactions Typically, electrocution threats to birds are greatly influenced by conductor spacing (APLIC 1996). In the vicinity of WCGS, the bald eagle has been the largest species likely to use utility poles, and because of its large wingspan, would be able to bridge larger conductor spacings.

Consequently, conductor configurations and distances judged safe for bald eagles would also be safe for smaller birds.However, roosting behavior differences of various species may cause different susceptibilities.

On the distribution power loop, various switches, breakers, and pole-mounted transformers may provide suitable roosts, and some species smaller than bald eagles, can and may prefer to get among the hardware, rather than on pole tops. Insulated bushings and jumpers on pole-mounted transformers, etc are present, thus reducing electrocution potential in such instances.

It was found that line spacing and configuration on pole numbers 54 through 59 (Figure 4) may pose potential electrocution threats to some birds, particularly red-tailed hawks, great-horned owls, and flocking blackbird species. Review of past reports for the USFWS salvage permit maintained for WCGS identified one great-horned owl electrocution since 1985. Electrocution of mixed blackbirds on portions of this line has been suspected as causing service outages on this line, but specific evidence has not been confirmed.

5.1.1.4 480 Volt Distribution Lines Low voltage distribution lines do not typically pose electrocution hazards (APLIC 1996). At WCGS, such 480-volt lines provide electricity for lighting and outbuildings, and are typically mounted underneath the 13.8 kV power loop lines. Conductors are insulated preventing electrocutions.

No modifications to these lines were considered necessary.

5.1.1.5 Transformers There were no transformers at WCGS that were deemed as potential electrocution hazards to bald eagles. The pole mounted transformers associated with the 13.8 kV distribution power loop were evaluated with each pole (Table 1), and all had bushing insulators, thus eliminating electrocution potential for all birds. The larger 345 kV transformers require conductor separation beyond the reach of a bald eagles wingspan, thus all smaller species. Intermediate transformers associated with WCGS have covered conductors and bushings to prevent animal caused system outages and damage Figure 5). Some transformers in the switchyard are owned by Westar Energy, consequently are covered by their APP.5.1.2 Collision Potential The NRC in 1982 reviewed potential impacts to waterfowl due to collision with electric transmission facilities adjacent to the cooling lake (NRC 1982). The NRC recommended that a general survey program for waterfowl collisions be completed to determine if 8 mitigation was warranted.

Consequently, transmission lines traversing the areas of high waterfowl and bald eagle usage were monitored and assessed for actual and potential collision problems beginning in 1983 and continued into 1988.The research determined that collision mortality at WCGS was not considered significant for waterfowl.

No bald eagle collisions were observed.

See attached collision survey summary for more detail. Increased collisions, or waterfowl use changes indicating increased potential for collisions, will be assessed by WCNOC per NRC (1982).Mitigation needs will be addressed with Westar Energy's APP.5.1.3 Chemical or Thermal Water Quality Affects to Fish Prey Base The Kansas Department of Health and Environment (KDHE) regulates water quality discharges from WCGS with a National Pollutant Discharge Elimination System (NPDES) permit. All chemical additions are reviewed and approved by the KDHE prior to use. Periodic bioassays are also completed to demonstrate no impacts to aquatic biota, including fish. Adherence to this permit will ensure continued water quality, thus preclude any degradation to the bald eagle fish prey base.There are no thermal discharge changes expected due to license extension.

Currently, thermal effluents from WCGS concentrate fish and waterfowl during winter periods, thus increasing foraging opportunities for wintering bald eagles.5.2 Improvements for Avian Protection The assessment of potential avian impacts, particularly to bald eagles, has identified two areas where mitigation is recommended to prevent potential impacts in the future. These involve electrocution hazards at portions of the distribution power loop identified above.Modifications include: 1. Install insulation on the center conductor on pole 20 from the bushing approximately three feet (Figure 3) to eliminate potential for bald eagle electrocution.

2. Install perch deterrents and/or insulate center conductors on poles 54 through 59 (Figure 4). These modifications will reduce electrocution potential caused by the closely spaced horizontal conductors.

5.3 Future Contingencies for Avian Protection 5.3.1 Electrocution and Collision Events Based on past experience, bird mortality due to electrocution or collision is not expected to increase in the future at WCGS. In the event electrocution or collision events increase, mortalities will be investigated, recorded and reported in accordance with the current USFWS salvage permit. Consultation with APLIC and USFWS will help determine any mitigation activities if such events become problematic.

APLIC (1994 and 1996) guidelines will be followed when practical.

If electrocution or collision events involve Westar Energy or KEPCo lines, then the respective company will be notified, and remediation activities will be determined by applicable APP's. WCNOC will assist where needed.

9 If electrocution or collision events involve Westar Energy or KEPCo lines, then the respective company will be notified, and remediation activities will be determined by applicable APP's. WCNOC will assist where needed.5.3.2 Waterfowl Disease Contingency Plan The heated condition of CCL may enhance the potential for development of waterfowl disease pathogens (NRC, 1982). This contingency plan is to provide guidance to mitigate or control such outbreaks on CCL, whether attributable to WCGS operation or not.Initial investigation will be conducted by WCNOC biologists to determine the scope of the event. The USFWS and KDWP are the agencies responsible for such wildlife issues, and will be contacted for assessment and recommended actions if disease is suspected, or numerous carcasses are involved.

WCNOC will assist these agencies as needed.Immediate notification, following disease problem identification, will be completed by WCNOC at the numbers listed below until at least one is contacted:

1. US Fish and Wildlife Service Contaminant Specialist, Manhattan, (785) 539-3474 Flinthills National Wildlife Refuge, Hartford, (620) 392-5553 2. Kansas Department of Wildlife and Parks District Wildlife Biologist, New Strawn, (620) 364-2522 Natural Resource Officer, New Strawn, (620) 364-3418 Region 5 Office, Chanute, (620) 431-0380 Pratt Headquarters, Pratt, (620) 672-5911 6.0 LITERATURE CITED Avian Power Line Interaction Committee (APLIC). 1994. Mitigating Bird Collisions with Power Lines: The State of the Art in 1994. Edison Electric Institute.

Washington, D.C.Avian Power Line Interaction Committee (APLIC). 1996. Suggested Practices for Raptor Protection on Power Lines: The State of the Art in 1996. Edison Electric Institute and the Raptor Research Foundation.

Washington, D.C.APLIC and USFWS, 2005. Avian Protection Plan (APP) Guidelines, a Joint Document Prepared By The Edison Electric Institute's Avian Power Line Interaction Committee (APLIC) and U. S.Fish and Wildlife Service (USFWS). April 2005.NRC, 1982. Final Environmental Statement Related to the Operation of WCGS, Unit No. 1.NUREG 0878.USFWS, 2003. Migratory Bird Permit Memorandum on Nest Destruction.

MBPM-2, April 15, 2003.

10 Table 1. Susceptibility of bald eagles to electrocution on the 13.8 kV power distribution line at Wolf Creek Generating Station.Factors Related to Bald Eagle Safety Less Safe Safer DetrimentI Benefit Pole Design (1)(n0 T: C 0 0 M C--0 C)-.(U 7 0)0 0. C x(0i CA ci, M0 0)ca0 S0)o 0.z .2, 80)-0. cx 0)0L :0 (D)0E )C ci ri (--.0 C.)S0.202 a) 0 (> 0 C O'0.0V (U 0O0Ch 0)-o 0 >(D.-c 0 Eagle Use Pole number I I t I I I I +/- -- I -- I .~ I --Higner iKnown rqoosts.M-. 4b 4K~X X X X~~~~~~ x1 x x 1 EI L ..- -I I-C-O d)0 0!0 C-C.)(D Likely rooQst's'

"C ýC, I20 i I j>-", X X X next~to lake,

$ 'J 14':17, 33,,35, 36,_ x x x x x x habitat .2 A 38, 45,A49 §'H16,25~ X X X X X X-~18;,26~

X X X X X X X X A K 152Kj X X XX X X X"V A.'A A 19 32 ý34A1:37r' XX X used asrbosi 7ýite~est A)e.,,,,,.5913 66'4',ýX X X X X X X X A ~~59A x X X X 555~ X _ X __ _ __X X X fr.A.A62, 631-64, 65'E 4 x X X X X X X X X X G1,,53. X X X X __ X X X X J x x x x x x x x x A 6, 27, 31' 39, 5O``!'ý __ x X X X X X X A5, 12,28,~50A

___ X X X X X X X A61,62,63;-64, 65ý,ý X X _ _ I X X Low-0 2,7, 9,`1,3', 29, 43,, 44 '644,2 X X X X X X X X X X 11 Table 1 (cont)(1) Pole design features ranked from highest to lowest potential for electrocution hazards to bald eagles are as follows: A. End pole three phase w/horizontal cross-arm, transformer and associated hardware.B. Line pole three-phase w/horizontal cross-arm, transformer, underground drops and associated hardware.C. Corner/end pole three phase w/horizontal cross-arm D. Line pole w/horizontal three phase cross-arm E. Corner pole three phase w/vertical conductors, transformer and grounded guys.F. Corner pole three phase w/vertical conductors and grounded guys.G. End pole three phase w/vertical conductors, grounded guys and underground feed hardware.H. End pole three phase w/vertical conductors and grounded guys.I. Line pole three phase w/vertical conductors, transformer, and underground drop hardware.J. Line pole three phase w/vertical conductors and transformer.

K. Line pole three phase w/vertical conductors and underground feed hardware.L. Line pole three phase w/vertical conductors and switch hardware.M. Corner/end pole three phase w/vertical conductors and non-grounded guys.N. Line pole two-phase w/horizontal cross-arm and two conductors.

0. Line pole three phase w/vertical conductors.

(2) Pole numbers correspond to poles numbered in the field, and to WCNOC drawing number 8025-E-1 021, Rev 42.

12 Figure 1. Typical poles of 69 kV WCGS tap of the-Athens line showing eagle safe separated conductors and insulated gu~y hardware.

13 Figure 2. Poles where bald eagles have been observed roosting.

These poles are considered safe due to well separated vertical conductors and pole tops available for Derchina.Figure 3 Pole 20 of the 13.8 kV distribution power loop where center phase conductor insulation is recommended to prevent potential bald eagle electrocution.

Note close horizontal cross-arm configuration.

14 Figure 5. Typical bushing and conductor insulation present on WCGS transformers to prevent animal electrocutions.

15 Avian Protection Plan Attachment Review of Bird Collision Data on Transmission Facilities at Wolf Creek Generating Station (WCGS)With emphasis on the Lime Sludge Pond (LSP)

Background:

The Nuclear Regulatory Commission (NRC) in 1982 reviewed potential impacts to waterfowl due to collisions with electric transmission facilities adjacent to the cooling lake (Section 5.5.1.2, Final Environmental Statement related to the Operation of WCGS, NUREG 0878). The NRC recommended that a general survey program for waterfowl collision be completed to determine if mitigation was warranted.

This recommendation was included in the Environmental Protection Plan, Appendix B to Facility Operating License NPF-42. This required a general survey program be accomplished to document significant waterfowl collision events and determine if mitigation was warranted.

Consequently, a collision survey was initiated in February, 1983, and continued through February, 1988. Surveys included dead bird searches of transmission lines crossing the cooling lake. All bird species were included, including bald eagles. These areas included the Firing Range Cove traversed by two 345 kV and one 69 kV line, and the Cemetery Cove, traversed by one 345 kV transmission line. These surveys occurred during the winter-spring migration seasons during each year.The LSP is adjacent to the Cemetery Cove and was searched.during each survey. Data was combined in annual reports with the Cemetery Cove through the 1985-86 migration survey season, but collisions around the LSP was available from the field data sheets. Table 1 shows the numbers and species of transmission mortalities found. Table two lists the live birds present immediately before each dead bird search. Records were kept for live bird usage beginning with November 1985 surveys. Comparing these tables demonstrates that no threatened or endangered birds were found to have collided with the associated transmission line. Unknown feathers were not from threatened or endangered birds. A few bald eagles were observed using the adjacent Cemetery Cove, but none were found during dead bird searches.Tables 1 and 2 also demonstrate that species found during dead bird searches did not necessarily correspond to live species found using the area, indicating that collisions tended to be incidental, with no detrimental patterns present. To test this further, monthly totals of dead birds, pooled from the three search locations, were compared with the total waterfowl and waterbird numbers surveyed during the same months, assuming that the more birds in the area would mean higher collision mortality and greater impact from the transmission facilities.

However, no relationship was found between collision frequency and bird usage of the cooling lake and LSP (Figure 1). Collision mortality was incidental to bird usage in the area, indicating that bird activity was not greatly impacted by the lines.Since the transmission lines did not appear detrimental to general bird usage of the cooling lake, more localized usage data were analyzed.

Beginning in November 1985, live bird usage in each search area was surveyed immediately prior to each dead bird search. This would show any adverse impacts at the LSP. The live bird data were compared to subsequent collisions found, again assuming that the greater the usage in the area, the greater the collision pattern would be.No relationships were found for any location, including the LSP (Figure 2). The more birds using the LSP did not increase transmission line collisions there.

16 A third comparison was made between the species diversity of dead birds found and the diversity of live birds surveyed in the search areas immediately prior to the searches.

This was done assuming that the greater the number of species present would mean a greater number of species vulnerable to collision.

There were no relationships found for all locations except the LSP (Figure 3). Approximately one third of the species using the LSP were consistently found during the dead bird searches.

This suggests that of the birds using the LSP, more species were susceptible to collision not based on total numbers as shown above, but on the kinds of birds.Mallard was the primary species found at the LSP (Table 1).In the 1987-1988 Annual Wildlife Monitoring Report, a review of the total collision results in relation to the total birds using the cooling lake was completed.

Estimates of common biases were used to ensure worst case was evaluated.

As shown in the report, total estimated collisions comprised a small percentage (0.2 to 0.5) of the total using the lake. This was very comparable to other collision impact assessments cited in the report, and well within published non-hunting mortality estimates.

Consequently, no impacts were found to bird populations by the transmission facilities at WCGS.To detect any changes in this assessment, bird usage surveys completed by the Kansas Department of Wildlife and Parks are reviewed annually.

A summary of these reviews are provided in the Annual Environmental Operating Report provided to the NRC each year. No changes have been observed to date that would warrant any mitigative actions.

17 Table 1. Bird species, number of birds found during dead bird searches, and live birds using each search area immediately prior to each search for transmission facilities at Wolf Creek Generatina Station.Firing Cemetery Range Year Month Species LSP Cove Cove 1983 February European starling 1 3 April Unidentified duck sp.Great blue heron Red-winged blackbird Brown-headed cowbird Blackbird sp Great blue heron Unidentified duck sp Upland sandpiper Sandpiper sp American coot Red-winged blackbird Ruddy duck Unidentified feathers Blue-winged teal Mallard Unidentified feathers Gull sp.Song sparrow Unidentified duck sp Red-winged blackbird Rusty blackbird 1 1 3 3 1 3 1 1 1 1 1 1 1 September November 1 1984 February Meadowlark Mallard American coot Unidentified duck sp.Red-winged blackbird 2 1 1 5 1 1 1 1 1 1 1 2 1 1 1 1 2 1 1 7 2 1 1 April Blue-winged teal Killdeer Greater prairie chicken American crow 1 September November Blue-winged teal Great blue heron Blue-winged teal Unidentified duck sp.Gadwall Unidentified feathers American coot 18 Table 1. (cont)Firing Cemetery Range Year Month Species LSP Cove Cove 1985 February April September Red-tailed hawk American crow American tree sparrow Greater prairie chicken Unidentified duck sp.Great blue heron Eastern meadowlark Unidentified feathers Mallard Brown thrasher Great blue heron American coot Ovenbird Brown-headed cowbird Red-winged blackbird American coot Ring-billed gull Bufflehead Unidentified duck sp.Red-winged blackbird Unidentified feathers Mallard Blue-winged teal 1 1 1 1 1 2 2 1 2 2 1 1 2 1 1 2 1 November I 1 1 1 2 2 2 1 1 December Double-crested cormorant American coot Mallard 1986 January Ring-billed gull American coot Mallard Pigeon Red-winged blackbird 1 2 1 1 1 1 1 2 4 1 4 1 1 1*1 1 4 February Mallard Unidentified feathers Bufflehead American coot Red-winged blackbird Red-bellied woodpecker April Red-winged blackbird Blue-wing teal 1 1 19 Table 1. (cont)Firing Cemetery Range Year Month Species LSP Cove Cove 1986 April Gadwall 1 American coot 1 3 Greater yellowlegs Unidentified feathers Shorebird sp.1 2 1 October Pied-billed grebe White pelican Blue-winged teal 1 1 1 November Mallard Ring-billed gull Red-winged blackbird 2 1 December Mallard Red-winged blackbird 1987 January Mallard February Mallard Lesser scaup 2 2 1 1 1 1 4 3 April November December White pelican Yellow rail Lesser yellowlegs Pectoral sandpiper Red-winged blackbird Double-crested cormorant Black-crowned night heron Mallard Unidentified duck sp.American coot Passerine sp.Mallard 1 1 2 1 1 3 1 2 1 I 2 1 1 1988 January Double-crested cormorant Mallard Red-winged blackbird February Double-crested cormorant Mallard Gadwall Common crow Unidentified feathers 1 2 1 1 1 1 1 1 20 Table 2. Monthly bird numbers surveyed using areas adjacent to transmission facilities immediately prior to dead bird searches at Wolf Creek Generating Station.Firing Cemetery Range Year Month Species LSP Cove Cove 1985 November Hooded mergansers 15 American coots 155 199 Canada goose 40 Mallards 25 124 161 American wigeon Bufflehead Green-winged teal 2 December Ring-billed gull Mallard Bufflehead American coot American widgeon Green-winged teal Gadwall Unidentified duck sp Common merganser Pintail Bald eagle 122 2 3 1 787 6 99 55 25 14 21 7 42 2 585 1 8 13 25 2 1 304 15 3 1986 January Mallard Pintail Bufflehead American widgeon Green-winged teal Ring-billed gull Canada goose American crow American coot 79 9 226 93 10 2 27 12 2 2 123 6 18 31 3 1 February Mallard Bufflehead Pintail Goldeneye Ring-billed gull American widgeon American coot Green-winged teal Killdeer Common merganser Canvasback Redhead duck 32 8 31 3 2 140 April Mallard Lesser scaup 4 2 6 2 21 Table 2. (cont.)Firing Cemetery Range Year Month Species LSP Cove Cove American coot Blue-winged teal Double-crested cormorant Killdeer Shorebird sp.Greater yellowlegs Gadwall 8 6 156 2 3 142 9 2 October Blue-winged teal Great egret Great blue heron Osprey American coot Killdeer Sandpiper sp.Mallard Bufflehead American widgeon 12 4 1 58 1 3 44 2 2 12 20 60 3 2 1 1002 8 12 4 November December 1987 January Goldeneye Bufflehead American widgeon American coot Mallard Hooded merganser Ring-billed gull Gadwall Pied-billed grebe Green-winged teal Canada goose Mallard Bufflehead Great blue heron American widgeon Hooded merganser Canada goose Green-winged teal Goldeneye Mallard Hooded merganser Canada goose Bufflehead 1 120 267 26 9 9 300 10 7 6 15 250 150 505 2 12 80 30 1239 12 2 12 2 42 97 2145 30 12 3 72 19 3 21 259 2 6 90 35 22 Table 2. (cont.)Firing Cemetery Range Year Month Species LSP Cove Cove February Mallard 891 835 1320 Canada goose 15 382 Green-winged teal 6 American coot 5 Ring-necked duck 61 Bufflehead 84 Goldeneye 3 Redhead duck 69 Lesser scaup 14 April Mallard 3 4 2 Greater yellowlegs 16 Sandpiper sp. 46 American coot 1 11 247 Bufflehead 33 Killdeer 8 Blue-winged teal 35 12 24 Northern shoveler 11 Gadwall 2 Wilson's phalarope 2 Lesser yellowlegs 20 Pectoral sandpiper 16 Willet 2 Forster's tern 1 November Mallard 150 167 110 American coot 30 21 Canvasback 5 Bufflehead 9 2 Redhead duck 16 December Mallard 15 1055 115 Hooded merganser 3 Great blue heron 1 American coot 15 Canada goose 145 30 Goldeneye 1 White-fronted goose 3 1988 January Bald eagle 14 Canada goose 305 6 Mallard 90 895 35 Great blue heron 4 23 Table 2. (cont.)Firing Cemetery Range Year Month Species LSP Cove Cove February Ring-billed gull 150 Mallard 10 30 Bald eagle 2 Bufflehead 15 Canada goose 200 Snow goose 30 American coot 10 24 Figure 1. Dead birds found adjusted for common search biases compared with total bird usage of the cooling lake.Monthly estimated bird collissions with transmission lines compared to total bird usage at Wolf Creek Lake 250000 u 200000 U)* " 150000 T E 100000 21 0 50000 0.0 50.0 100.0 150.0 200.0 250.0 300.0 Estimated total bird collisions 350.0 400.0 25 Figure 2. Live birds found in search areas immediately prior to dead bird searches.

These totals do not reflect common search biases.Live bird usage vs bird collisions Lime Sludge Pond 3.5 3 -~R-.9 2.5 2 2 0.5 0200 400 600 Live bird usage Live bird usage vs bird collisions Cemetary Cove 0-0 5 -4)0 3 0 200 400 600 800 1000 1200 Live bird usage 26 Figure 2. (cont).Live bird usage vs bird collisions Firing Range Cove 6 5 4-A- 3 1 02 0 200 400 600 800 1000 1200 Live bird usage 27 Figure 3. Species diversity of dead birds found compared to species diversity of live birds surveyed prior to searches.Collision Species Numbers vs Live Bird Usage Lime Sludge Pond R 2 = 0.6752 12 10 10 4) 4 0.J 0 0 1 2 3 4 5# collision species Collision Species Numbers vs Live Bird Usage Cemetery Cove R 2 0.0388 12 10 8 CL S6 S2 01 0 1 2 3 4# collision species Collision Species Numbers vs Live Bird Usage Firing Range Cove R 2 = 0.1801 10 cc 8 0.4 4.>S2 0 A 0 1 2 34 56# collision species 28 ADDENDUM TO Avian Protection Plan at Wolf Creek Generating Station February 14, 2007 These addendum statuses the improvement items for avian protection identified in Section 5.2.The protection item changes are as follows: 1. Perch deterrents have been installed on Pole 20 to discourage bald eagle roosting (see photo 1). Insulation will be installed on the center conductor from the bushing approximately three feet to further eliminate potential for bald eagle electrocution when scheduling will allow during an upcoming Construction Power Loop outage.2. An alternate "safe" perch was installed on pole 54 (see photo 2). No further work is considered necessary for this pole.Pole 59 was reassessed, and due to conductor spacing, it was considered unlikely to cause bird electrocution.

No further work is necessary for this pole.Plastic bird covers were placed on the center conductors of poles 56 through 58 (see photos 3). These poles are considered safe, and no further work is necessary.

Insulation of the center conductor and jumper on Pole 55 will be installed when scheduling will allow during an upcoming Construction Power Loop outage.

29 t-noto -. bala eagie percn aeterrenis instaiiea on o0o z. ,ross-arm saTe percn instaiiea on ome 04.._.

Photo 3. Plastic bird cover installed on center conductors on Pole 57.protection devices installed on Poles 56 and 58, also.milar bird LYON-COFFEY ELECTRIC COOPERATIVE, INC.POLICY FOR PREVENTION OF WILDLIFE CONTACTS The scope of this policy is to provide direction by the Board of Directors, to prevent wildlife contacts with power lines. This cannot be accomplished in a short period of time as we many older services.

However as time allows we shall continue to improve our system, and update our equipment.

The Board of Directors has determined that wildlife contacts should be eliminated as efficiently as possible.

The outages. to our consumers should be held to a minimum due to wildlife contacts..:

The work practices.

of the Cooperative should change as needed to meet the problems as they occur on our system.The Board of Directors realizes several Federal Laws protect different birds, and to provide a proactive program in the prevention of wildlife electrical contacts the Cooperative should strive to meet the following:

Bald eagles are known to occur in the Lyon-Coffey Service Area. Bald Eagles nest and feed near large bodies of water. To provide protection for these protected species, Lyon-Coffey should use "Suggested Practices for Raptor Protection on Power Lines" for all new construction within one hundred yards of a major river and within one mile of a federal reservoir or major body of water.The cooperative should continue to update, and replace equipment as is economically feasible, with the limited resources and man-hours that are available.

Approved by Board of Directors

/ /President Environmental Services Policies and Procedures Avian Protection Plan Policy 3.01 -Bird Management Policy Effective Date: 05/18/2004 Bird interactions with power lines may cause bird mortalities which, in turn, may result in outages, violations of bird protection laws, or raise concerns by employees, resource agencies and the public.This policy is intended to ensure compliance with legal requirements while improving distribution system reliability.

Westar Energy management and employees are responsible for managing bird interactions with power lines and are committed to reducing the detrimental effects of these interactions.

To fulfill this commitment, Westar Energy will:* Implement and comply with its comprehensive Avian Protection Plan (APP)* Ensure its actions comply with applicable laws, regulations, permits, and APP procedures." Document protected bird mortalities and problem nests." Provide information, resources, and training to improve its employees' knowledge and awareness of the APP." Construct all new or rebuilt lines, where appropriate, to raptor or Kansas raptor-safe standards." Retrofit or modify lines, poles, and equipment where a protected bird has died, in accordance with APP procedures." Participate with public and private organizations in investigations and research to reduce detrimental effects of bird interactions with power lines.Westar Energy's customer service and regulatory compliance will be enhanced and risk to migratory birds will be reduced through the proactive and innovative resolutions of bird/power line interactions guided by this policy.Avian Protection Plan -3.01 -Page 1 Environmental Services Policies and Procedures Avian Protection Plan Policy 3.02 -Bird/Power Line Program Training Effective Date: 05/18/2004 Avian Protection Plan -3.02 -Page 2 Environmental Services Policies and Procedures Avian Protection Plan Policy 3.02 -Bird/Power Line Program Training 3.02.01 -Background Effective Date: 05/18/2004 Westar Energy's service territory includes many resident raptors and smaller birds as well as migratory waterfowl, shorebirds, and raptors, including bald eagles, which overwinter and occasionally nest here. Golden eagles reside year-round in Kansas but are generally rare in our service territory.

All of the birds typically encountered in Kansas are protected by the Migratory Bird Treaty Act except for three non-native invaders.

These are the house sparrow, starling and pigeon (or rock dove).Since original construction, Westar's distribution system design standards have been routinely upgraded to improve reliability.

Both intentionally and unintentionally, these improvements have reduced bird mortalities.

These improvements include use of 10 ft. crossarms, transformer wildlife guards, and insulated jumper wire. Beginning in 2003, Westar Energy has made design changes with avian protection as a goal. Training has been initiated to equip distribution system personnel with the ability to anticipate and avoid problem configurations, remediate proven problem spots and properly handle, report, and remediate when protected birds are killed or protected nests need to be moved.Westar is a member of the Avian Power Line Interaction Committee(APLIC).

As a result, Westar works cooperatively with other utilities and the U.S. Fish and Wildlife Service to identify, understand, and resolve problem interactions between protected birds, their nests, and electric power structures.

Avian Protection Plan -3.02 -3.02.01 -Background Page 3 Environmental Services Policies and Procedures Avian Protection Plan Policy 3.02 -Bird/Power Line Program Training 3.02.02-Training Scope Effective Date: 05/18/2004 Westar distribution system workers and management are trained on the facets of our Bird/Power Line Program and given refresher training as significant program changes are made. These facets include: Regulatory Background and Protected Bird Species -employees are given information on the Migratory Bird Treaty Act and Bald and Golden Eagle Protection Act and a discussion of those birds which they are likely to encounter which are protected and not afforded protection under those acts.-Bird Biology and Behavior -employees are informed of bird biology and behavior as it may cause interactions with power structures.

This includes bird sizes, perching, nesting, hunting and feeding habits, as well as habitat preferences and flight path tendencies.

These all may affect the chances for collision or electrocution.

-Bird/Nest Reporting

-employees are required to report any protected bird species found dead in or around our facilities or active protected nests removed. They are instructed to report these on the Bird Impact Reporting Database (BIRD) via their dispatcher or system operator.Evaluation of bird carcasses and nests to determine species and, where applicable, cause of death, is also covered. This data base is also where the cause of the incident, if it is evident, is recorded along with remedial actions-Distribution Line Construction Standards

-workers are given an overview of Westar construction standards, separation and insulation concepts and specific applications are viewed and discussed.

Separation standards for differing sizes of raptors are reviewed and*hardware to mark and insulate lines and equipment is demonstrated.

Expectations for corrective actions on lines and equipment where mortalities have occurred are discussed.

Specific examples and corrective actions are reviewed, as well as circumstances where, due to weather, unavoidable biological interactions, or very rare contributory factors, no meaningful remedial steps can be reasonably taken. Bird behavior management through items such as perch preventers and substitute perches and nest platforms is also discussed.

Evaluation of High Use Areas -areas of high year-round and seasonal bird concentrations are discussed.

Generically, these may include wetlands for waterfowl, areas of flowing water (rivers or dam tailwaters) for overwintering Bald Eagles, or concentrations of carrion for turkey vultures or eagles. Location -specific solutions such as substitute perches, marking static wires to improve visibility, or perch preventers to direct birds away from conductors Avian Protection Plan -3.02 -3.02.02 Page 4 are reviewed.

Westar will continue to seek to identify sites of potential interaction between high bird concentrations and power structures in an effort to eliminate bird impacts.Avian Protection Plan -3.02 -3.02.02 Page 5 Environmental Services Policies and Procedures Avian Protection Plan Policy 3.02 -Bird/Power Line Program Training 3.02.03 -Permit Compliance Effective Date: 05/18/2004 Per 50 CFR parts 13 and 21, the US Fish and Wildlife Service may issue permits governing the interaction with protected migratory bird species. A Special Purpose Permit is required if a nest containing eggs or young of a protected bird species must be moved. If an imminent danger is posed to birds or eggs, workers, or electrical service, the nest and contents may be removed and US Fish and Wildlife Service contacted afterward.

Avian Protection Plan -3.02 -3.02.03 -Permit Compliance Page 6 Environmental Services Policies and Procedures Avian Protection Plan Policy 3.02 -Bird/Power Line Program Training 3.02.04 -Construction Design Standards Effective Date: 05/18/2004 Avian interactions are considered in the design and installation of new structures as well as operation and maintenance of existing facilities, per the Westar Line Construction Standards (Electric).

While 60 inch separation between energized conductors and/or grounded hardware is an appropriate standard in those isolated areas where eagles are common, the 46 inch separation which applies for raptors up to the size of red-tailed hawks and great homed owls is the more ubiquitous standard across our service territory.

This 46 inch horizontal and 36 inch vertical separation amounts to a "Kansas Raptor Safe" standard, while the 60 inch horizontal and 48 inch vertical separation meets a "Raptor Safe" standard.

The standards manual also includes retrofit devices which may be used on a case by case basis to avoid bird-powerline interactions or remediate where a collision or electrocution has occurred.Where possible, new lines should avoid areas of high bird concentrations and use natural vegetation and features to reduce bird-powerline interactions.

Avian Protection Plan -3.02 -3.02.04 -Construction Design Standards Page 7 Environmental Services Policies and Procedures Avian Protection Plan Policy 3.02 -Bird/Power Line Program Training 3.02.05 -Nest Management Effective Date: 05/18/2004 The Migratory Bird Treaty Act affords protection for... any migratory bird, any part, nest, or eggs of such bird. Because of this, the active (occupied by eggs or young) nests of protected bird species are also protected.

Except for eagles, unoccupied nests which need to be removed can be with no requirement to report. Because eagles have special status under the Bald and Golden Eagle Protection Act and because they may reuse their nests for several years, moving even inactive nests should be done only after consultation with management and permitting via USF&WS unless there is a clearly imminent danger posed to birds or eggs, workers or electrical service. Moving active nests of all types require management discussion and USF&WS permitting, again unless an imminent threat to the eggs, birds, workers, or electrical service exists. When workers are confident that such a threat exists and move the nest immediately.

the USF&WS still must be consulted and a permit created for the incident afterwords.

Westar personnel should be mindful of the options of substitute nests and nest platforms when the species involved and lack of urgency make these options desirable.

Avian Protection Plan -3.02 -3.02.05 -Nest Management Page 8 Environmental Services Policies and Procedures Avian Protection Plan Policy 3.02 -Bird/Power Line Program Training 3.02.06 -Avian Reporting System Effective Date: 05/18/2004 Although Westar Energy is not required to report avian mortalities as a condition of federal or state permits, we choose to voluntarily report through our internal Bird Impact Reporting Database (BIRD). The form (Attachment

1) is used by field personnel for reporting, evaluating, and documenting their recommended remedial action, if any. The system administrator in Environmental Services then reviews the incident and remediation for completeness and can close it out. A year-end report is created, based on this database, and submitted to the USF&WS Special Agent, Topeka, Kansas by January 31 of the following year. The one exception to this end-of-year reporting is for eagles. Because of their special status, Bald and golden eagle mortalities are to be reported to USF&WS, via Environmental Services, without delay.Avian Protection Plan -3.02 -3.02.06 -Avian Reporting System Page 9 Environmental Services Policies and Procedures Avian Protection Plan Policy 3.02 -Bird/Power Line Program Training 3.02.07 -Evaluation of High Use Areas Effective Date: 05/18/2004 The distribution of protected bird species in Kansas varies dramatically seasonally and based on water features.

Passerine and waterfowl species migrate through in the spring and fall.Shorebirds peak in mid-summer whereas Bald Eagles reach their highest Kansas numbers in mid to late winter as they migrate here from the north and concentrate near the outfalls of dams or power plant warm discharges where open water attracts waterfowl and gizzard shad may be caught. Although Bald Eagle nesting numbers have been increasing, the record high of 18 nests reported for 2003 still means a very low incidence once we emerge from our coldest winter period. Golden eagles are not dependent on open water and can be found in middle Kansas in very low numbers with higher numbers in western Kansas in winter. Golden eagles typically nest on rocky bluffs, making power structures unattractive and never used. Bald eagles, in contrast, may use these structures, particularly around reservoirs, wetlands, or streams, as a substitute for the large trees that they typically prefer. Both eagles desire high perches to hunt from and often choose power structures.

As mentioned earlier, waterfowl move through Kansas in high numbers in spring and fall. In reservoir or wetland areas, given appropriate water and vegetation conditions, bird concentrations can number in the tens of thousands for short time periods. This same concentration spike can occur when few areas of open water remain on rivers or large reservoirs in midwinter and ducks and geese, pushed down by colder northern temperatures, congregate there. When high bird concentrations are combined with fog, rain, or snow, power lines in the vicinity of these waters are an increased risk for collisions.

While some species of hawks migrate through Kansas in spring and fall, the most noteworthy potential avian effect is the winter build up of red-tail hawks. Due to typically moderate weather and abundant grassland rodent populations, red-tail populations multiply as do the chances for interactions with power lines. It is impossible to target only certain areas of Westar's service territory for specialized hawk electrocution prevention because distributions of both their resident and winter migrant populations are nearly uniform across our broad warm and cool season grasslands.

Evaluations of our service territory for high bird use areas will continue over time based on scientific literature, input from ornithologists, breeding bird surveys, winter bird counts, and observations by Westar field personnel.

Based on these, steps to insulate and separate equipment and lines, mark and locate lines, and provide substitute perches and nest sites which reduce or eliminate the risk of collision and electrocution will be evaluated and where warranted, implemented.

Avian Protection Plan -3.02 -3.02.07 -Evaluation of High Use Areas Page 10 Environmental Services Policies and Procedures Avian Protection Plan Policy 3.03 -Attachment 1 Bird impact Reporting Database Form Effective Date: 05/18/2004 Attachment 1 .rtf Avian Protection Plan -3.03 -Bird impact Reporting Database Form Page 11 Status: Pending Finder and Location Information Date: Finder's Name: 01/02/2004 Time: Finder's Supervisor:

11:45 Finder's Phone: County: Reference Pts: Line Type: (See below choices)*Phase Type: (See below choices)***

Location: Pole Type: (See blow choices)**

Configuration Type: (See below choices)****

Equipment Attached: (See below choices)*****

Type of incident: (See below choices)******(Comments can be edited until the document is saved;then your name, date timestamp, and comment will be added to the Comments log.)Current Comment: Comments:* Tangent, Running Angle, Corner, Dead End** Single wooden pole, Wooden H-Frame, Wooden 3 -Pole, Steel, Other (use comments)Single phase, Two phases, Three phases Verticle, Horizontal

• No Equipment, 1-Pot, 2-Pot, 3 Pot, More than 3 Dead Bird, Large Injured Bird, Small Injured Bird, Active Nest, Inactive Bald Eagle Nest Created by Dolores D Crabtree on 01/02/2004 at 11:45 AM

68. Any available maps and aerial photographs of the WCGS plant site and the area within and adjoining the larger site boundary (which encompasses CCL) showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains.

Terrestrial Ecology Page I of I* Clarify discussions regarding site boundaries, land ownership, and land usewithin Section 2.4 and Figure 2-3 of the ER (WCGS, 1980). Clarify the difference between"Site Boundary" and the "Plant Site" on the map, with respect to whether these are a land ownership distinction, a physical fencing distinction, or some other regulatory or access distinction.

Please claarify whether or not the referenced agricultural production areas are within the "Site Boundary" as shown on Figure 2-3. Identify any areas fenced to restrict human access and any areas fenced that may restrict wildlife access.-Additional data on the avian collision studies that were ceased in 1986. Section 2.4 of the ER (WCGS, 1980) states that sufficient data had been collected by 1986. Provide any documentation of regulatory involvement and concurrence in this determination of sufficiency.

• Details on the power transmission system, including information on the design of the towers, the number and configuration of the lines on the towers within each right-of-way (ROW).* Details regarding the maintenance procedures used in the transmission line ROWs, including mechanical, chemical, and biological control methods for vegetation management.

-More detailed maps/aerial photos of the transmission line ROWs showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains, and the location of the Sharpe Generating Station.* Please provide information on the locations of transmission line ROWs crossings with parks, wildlife refuges, or wildlife management areas, or any major lakes (in addition to CCL), ponds, or streams? If so, please provide information on these crossings and their locations.

-Any available studies or other information about the issues raised in the letter from the U.S. Fish and Wildlife Service (November 14, 2005) regarding terrestrial threatened and endangered species.For example:-- Any assessments of the transmission lines for conformity with "Suggested Practices for Raptor Protection on Power Lines" (Raptor Research Foundation 1996)? Please provide any such assessments and details of transmission line construction relevant to raptor protection.

Also provide a copy of "Suggested Practices," if available.

-- Any special ROW maintenance procedures used to reduce the potential for impacts to Mead's milkweed or animals with federal or state listing status.* Any available maps and aerial photographs of the WCGS plant *te and the area within and adjoining the larger site boundary (which encompasses CCL showing topographic features, hbitats/vegetation muities, land uses, wetlands, and floodplains."-Any available information identifying natural communities and dominant species of plants and animals that utilize terrestrial habitats of the site and the transmission line ROWs, as well as semiaquatic species such as waterfowl that use Lime Sludge Pond and CCL.

69. Any available information identifying natural communities and dominant species of plants and animals that utilize terrestrial habitats of the site and the transmission line ROWs, as well as semiaquatic species such as waterfowl that use Lime Sludge Pond and CCL.

Terrestrial Ecology Page 1 of I o Clarify discussions regarding site boundaries, land ownership, and land use within Section 2.4 and Figure 2-3 of the ER (WCGS, 1980). Clarify the difference between"Site Boundary" and the "Plant Site" on the map, with respect to whether these are a land ownership distinction, a physical fencing distinction, or some other regulatory or access distinction.

Please claarify whether or not the referenced agricultural production areas are within the "Site Boundary" as shown on Figure 2-3. Identify any areas fenced to restrict human access and any areas fenced that may restrict wildlife access.-Additional data on the avian collision studies that were ceased in 1986. Section 2.4 of the ER (WCGS, 1980) states that sufficient data had been collected by 1986. Provide any documentation of regulatory involvement and concurrence in this determination of sufficiency.

• Details on: the power transmission system, including information on the design of the towers, the number and configuration of the lines on the towers within each right-of-way (ROW).* Details regarding the maintenance procedures used in the transmission line ROWs, including mechanical, chemical, and biological control methods for vegetation management.

• More detailed maps/aerial photos of the transmission line ROWs showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains, and the location of the Sharpe Generating Station.* Please provide information on the locations of transmission line ROWs crossings with parks, wildlife refuges, or wildlife management areas, or any major lakes (in addition to CCL), ponds, or streams? If so, please provide information on these crossings and their locations.

• Any available studies or other information about the issues raised in the letter from the U.S. Fish and Wildlife Service (November 14, 2005) regarding terrestrial threatened and endangered species.For example:-- Any assessments of the transmission lines for conformity with "Suggested Practices for Raptor Protection on Power Lines" (Raptor Research Foundation 1996)? Please provide any such assessments and details of transmission line construction relevant to raptor protection.

Also provide a copy of "Suggested Practices," if available.

-- Any special ROW maintenance procedures used to reduce the potential for impacts to Mead's milkweed or animals with federal or state listing status.* Any available maps and aerial photographs of the WCGS plant site and the area within and adjoining the larger site boundary (which encompasses CCL) showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains.

-Any available information identifying natural communities and dominant species of plants and animals that utilize terrestrial habitats of the site and the transmission line ROWs, as well as semiaquatic species such as waterfowl that use Lime Sludge Pond and CCL.

MAttachment to ET 07-0001 G Page 2 of9 9 0~1 6 Circulating Water Discharge The circulating water is pumped from the Circulating Water Screenhouse (CW'SH) intake LI structure bays through a 12 foot-diameter inlet pipe to the steam condenser.

The warmed-water then flows from the condenser through a 12 foot-diameter outlet pipe to the circulating water discharge structure (CWDS). This structure has a discharge well which overflows into a 40-foot wide apron and then onto the surface of the Lake.

References:

1. Wolf Creek Updated Safety Analysis Report, Section 2.4.8.2.2, =Spillwayso, Revision 19.2. FD-WL-02-WC, Rev 6, Cooling Lake Makeup Water and Blowdown System Makeup Water System, System Description.

3. Wolf Creek Generating Station Environmental Report, Operating License Renewal Stage, 2006, Section 3.1.2.2) Provide information on potential riparian/

wetland communities in the project area, including along the transmission line.WCNOC Response This is a review of the potential riparian and wetland communities in the vicinity of Wolf Creek Generating Station (WCGS). Such communities applicable to WCGS include: 1. The riparian areas of Wolf Creek associated with Coffey County Lake (CCL) and the shoreline and shallow water areas of CCL, 2. Shoreline and shallow water areas of John Redmond Reservoir (JRR), 3. Riparian areas of the Neosho River and, 4. Riparian and wetland areas traversed by applicable transmission lines.This review summarizes these natural communities based on past surveys, current literature, and staff biologist observations.

It is not an exhaustive survey or data presentation, rather a general overview.

Because there are no plans for refurbishment or additional construction, riparian or wetland resources will not be impacted to support WCGS license renewal.Enclosure 2 to this letter contains the tables referenced in the following discussion.

Wolf Creek and Coffey County Lake The riparian areas of Wolf Creek upstream and downstream of CCL are typical of the Oak-Hickory forests found in east-central Kansas. They are medium-tall, multilayered, broadleaf deciduous forests on the first and second terraces adjacent to streams (NRC 1975).Quantitative analyses of the lowland woods within the Oak-Hickory forests were conducted during the initial licensing process for WCGS (Kansas Gas and Electric, KGE, 1982). Table 1 I H A Attachment to ET 07-0001 G Page 3 of 9 D 1 j of Enclosure 2 presents a list of the plant species and their relative abundance that were 6 monitored for the lowland woods, which comprise the riparian areas of Wolf Creek./2 Hackberry (Celtis occidentatlis) was dominant or codomiant within woodlands of Wolf Creek.O Common associates were black walnut (Juglans nigra), American elm (Ulmus americana), white bittemut hickory (Carya cordiformis), silver maple (Acer saccharinum), bur oak (Quercus macrocarpa), green ash (Fraxinus pennsylvanica), and Kentucky coffee tree (Gymnocladus dioica). Inspection of tree species distribution of the lowland woods showed that silver maple, American elm, green ash, and sycamore (Platanus occidentalis) were more common within the frequently inundated sites, whereas hackberry, red bud (Cercis canadensis), Kentucky coffee tree, hickories (Carya spp.).and oaks (Quercus spp.) occurred on higher, well-drained sites (KGE 1982).Shrub component species include coralberry (Symphoricarpos orbiculatus), poison ivy (Rhus radicans), wild gooseberry (Ribes missouriense), hackberry, and elms. Ground layer components included spreading chervil (Chaerophyllum procumbens), wood nettle (Laportea canadensis), Virginia wild rye (Elymus virginicus), clearweed (Pilea pumila), and fescue (Festuca obtpse), all typical floodplain species (NRC 1982).The shoreline and shallow water habitat vegetation of CCL are typical of wet soil or periodically flooded habitats.

Observations of the shoreline vegetation include species tolerant of various degrees of inundation or wet soil conditions.

Initially, cottonwood (Populus deltoides), black willow (Salix nigra), and buttonbush (Cephalanthus occidentalis) are common along the shorelines.

In areas more frequently flooded, shallow water plants such as cattails (Typha spp.), smartweeds (Polygonum spp.), and water primrose (Ludwigia peploides) are common.Emergent and submersed plants in shallow, but slightly deeper water include American lotus (Nelumbo Iutea), pondweeds (Potemogeton spp., primarily nodosus and foliosus), and Naiad (Najas minor).As CCL water level fluctuates, mudflat areas develop. Colonization of these areas by plants are expected to be similar to that studied at JRR (NRC 1975). Table 1 of Enclosure 2 identifies common species and relative abundance within the mudflat areas of JRR. These species are typical for this region, and can be expected along the CCL mudflats.

Initially, two plant communities will occupy the mudflats.

In poorly drained areas, plants typical of wet marshy areas of JRR will dominate.

These include sedges (Carex spp.), cattails, black willow, and arrowhead (Saggitana latifolia).

In areas where re-inundation is infrequent (4 to 5 years), some advance seral communities will replace the pioneer communities.

These include flood tolerant woody vegetation, such as black willow, buttonbush, and cottonwood.

Since WCGS operation began in 1985, riparian protection and enhancement activities have been completed.

These include construction of approximately 25 acres of shallow water ephemeral wetlands,.

protection of -old-growth oak-hickory wcodland, planting.

of bottomland woods, establishment of native grasses for buffers along CCL shorelines, areas preserved for natural succession, and livestock exclusion.

John Redmond Reservoir The wetland and shallow coves of JRR are dominated by swamp smartweed, in addition to other smartweed species (Polygonum spp.), bulrush (Scirpus spp.), cattail, spike-rush (Eleocharis spp.), and sedge (Carex spp.). Some stands of silver maple, black willow, and A Attachment to ET 07-0001 G Page 4 of 9 D 0 21 eastern cottonwood are also present. On the reservoir drawdown areas (mudflats) weedy b annuals such as cocklebur (Xanthium strumarium), foxtail grass (Setaria spp.) and barnyard/ grass (Echinocloa spp.) are common species (U. S. Army Corp of Engineers, USACE, 2002).1. A species list and relative abundance compiled during mudflat vegetation surveys of JRR (KGE 0 1982) is presented in Table 1 of Enclosure 2.7 Neosho River The riparian areas of the Neosho River upstream and downstream of JRR are characterized in USACE (2002). Basically, riparian woodlands are a bottomland hardwood type dominated by American elm, green ash, eastern cottonwood, black willow, black walnut, sycamore (Plantanus occidentalis), silver maple, burr oak, box-elder (Acer negundo), and hackberry.

Downstream from JRR, most of the flood plain vegetation along the Neosho River and its major tributaries can be described as the riparian woodland type. Islands, point bars, and first terraces are dominated by more wet soil tolerant species such as eastern cottonwood, silver maple, and box-elder.

Slightly higher elevation second terraces support eastern cottonwood, green ash, American elm, black walnut, hackberry, and burr oak.Flood plain shrubland (under-story) growing along riparian areas include coralberry, greenbriar, rough-leaf dogwood (Comus drummondi,), American plum (Prunus americana), and wild grape (Vitae spp.). Downriver from JRR, these shrublands occupy recently scoured islands, point bars, and riverbanks.

Sandbar willow (Salix interior), rough-leaf dogwood, and buttonbush invade rapidly and eventually are replced by black willow, silver maple, and eastern cottonwood.

Transmission Line Corridors The transmission lines included in this review of riparian areas traversed include the Wolf Creek-Rose Hill 345 kilovolt (kV) line, the portion of the LaCygne -Benton 345 kV transmission line rerouted for WCGS, the WCGS to Sharpe Kansas Electric Power Cooperative (KEPCO) 69 kV line, and the Wolf Creek tap of the Burlington

-Athens 69 kV line.Wolf Creek -Rose Hill Transmission Line: The Wolf Creek -Rose Hill line extends approximately 98 miles from WCGS in a southwesterly direction toward the Rose Hill substation east of Wichita, Kansas. Easements are 150 feet in width, which totals 1691 acres of right-of-way.

General land use classifications traversed by this line include cropland, grazing, woodland, idle land, waterways and roads. This right-of-way traverses a total of 4,950 feet (18.2 acres) of riparian woods, and 480 feet (1.8 acres) of waterways (Table 2 of Enclosure 2). The riparian and waterways traversed by the line represents approximately 1 percent of the total right-of-way.

Major rivers and associated watersheds traversed by the Wolf Creek -Rose Hill transmission line include the Neosho River primarily in Coffey County, the Verdigris and Fall Rivers primarily in Greenwood County, and the Walnut River primarily in Butler County. Riparian areas within these watersheds are substantially similar to that described for the Neosho River above.LaCygne -Benton Transmission Line (rerouted portion):

M A Attachment to ET 07-0001 G Page 5 of 9 D/ The portion of the LaCygne -Benton 345 kV transmission line rerouted around CCL is approximately 7.7 miles. Most of this line was constructed on WCGS lands. Assuming a 150 b feet wide corridor, this rerouted line encompasses nearly 140 acres. Based on aerial 2 photographs, land use types, including wetland and riparian habitats are presented in Table 3 of O Enclosure

2. There are 12.1 acres of riparian, surface water, shoreline, and wetland acres 0 included in the corridor, or 8.7 percent of the total.7 WCGS Tap of Burlington

-Athens 69 kV Transmission Line: The WCGS tap of the Burlington

-Athens 69 kV transmission line traverses approximately 4.1 miles, most of which are on WCGS lands. There are no streams or associated riparian areas traversed by this line, however, this line does cross over portions of CCL. Applying a corridor width of 150 feet, surface water, shoreline, and wetland acres included in the corridor total 4.7, or 6.4 percent of the total (Table 4 of Enclosure 2).WCGS to Sharpe KEPCo 69 kV Transmission Line: The WCGS to Sharpe KEPCo 69 kV transmission line is approximately 3 miles, and does not cross any wetland, shoreline, or riparian areas. Right-of-way for this line is primarily parallel to local roads.3) Provide the most recent data obtained from any microbiological monitoring program.WCNOC Response Enclosure 3 includes the WCGS Construction Environmental Monitoring Program Report, February 1981 -January 1982 and the WCGS Operational Phase Environmental Monitoring Program Report, Final.4) ER Section 6.2 notes that routine mitigation and monitoring programs are conducted, including effluent chemistry monitoring and water quality and fishery monitoring of Coffey County Lake. Provide at a minimum the most recent set of these data.WCNOC Response Enclosure 4 includes the most recent chemistry effluent monitoring data. Included is a figure and a map of the NPDES Outfall sampling points. WCGS sample analysis results from November-1, 2006-to November 30, 2006-are included in a table format. Also provided in the Enclosure are analytical results from an accredited environmental laboratory, circulating water bromination schedule, and log entries for discharges through outfall 003A and 003B.Enclosure 5 includes fishery monitoring reports for years 2002, 2003, 2004 and 2005.

Enclosure 2 to ET 07-0001 Riparian/Wetland Community Tables Table 1, Plant species within the riparian (lowland woods) of Wolf Creek upstream and downstream of Coffey County Lake (from KGE 1982, Table 2.2-1). Wet and dry mudflat species from vegetation monitoring sites at John Redmond Reservoir.

Table 2, Land uses within the Wolf Creek -Rose Hill transmission line right-of-way (from KGE 1975, Table 3.9-1).Table 3, Land uses within the rerouted right-of-way section of the LaCygne -Benton 345 kV transmission line in the vicinity of Wolf Creek Generating Station.Table 4, Land uses within the right-of-way of the WCGS tap of the Burlington

-Athens 69kV transmission line.Cited Literature TABLE 2.2-1 PHYLOGENTIC LISTING OF PLANT SPECIES SAM4PLED NEAR WCGS, 1973-78 community rypo: 4V Scitntific Nacs Common Name Index Of Relative Community Abundanc*4 8 Cuni terse Cupressacese Cypress ftcily Juniperug virginiana L.. Pastern reticedar Cr..ift~ieZ Grealneae Gross samily n______ tecturus I. Downy chess A-0 I Fr-onus T-Furol's Ieyea. Smooth brome A-D U'romus Tjap-bnrus Thuntb. Japanese brace C A-0 A-0 P-eittwa 1 stior I.. Headov fescue, I Pe'stiuh obus ishiebr Fesceu C Z-atu-csa adx Desv. Fescue Too com So..." Canada bluegrass I I a .Kentucky bluegrass C I-C I;L ot1 Cthti ~rh tu. Purple lovegrbes I rT 3yh Purple top I Fr-u -arssL. Canada wild rye u___1qn~u L. Virginia wild rye 0 C iir, In uus I l Nutt. L ittle barley I C I.-C ifolrera cristata I L.) Pure. Prairie junegrass I 0 wem~t (Wl.1 ks ed top r w aeaI.. Wood reed I.' Hubly I go e mog chrobari G-01. Ninible will T C Ej~iioE0Ius asp r (Xichg-l Kunth. Vailldropasoo I I I____ ngTtu ah DOtpseed I prblsg r Gray Prairie dropsoee 7Cp_*C .1 (a. iav Lotohlo5aaf I C.e tocriloa Isaicuiflrla (Lam.) tray teptochloa C Z;týhu __ t~c41~ (P-ichs.)

Torr. Side-oats gross I iii~lria ir.TiT.iWak

.htaygrazs.i'.aufl au~u~ncea L.Hed canary grases oer1Zv-1r~qar.1~c57-9Ld.

White grass I* , tar~a san,)= na~ltf (L.) Scopu Crab gasI I as alun cm;Elst-inT~

K chit. Panpalms -C I-C P.n EcUm p. r7 Panic grass C VC c 'T~T cflare L.. witch grossI;1?u ~cb9olonm-florwa mIicia. fall panic gra~ss0 A%'niuauravoiS

~th4 Chase Panic grass I--I 00 Cr (D CD3 .-.0 0 3.0=CD CD co ) 0-1 CD-_00 2 CD CD 0~CD CD CD~3 0~o0 _- -CDO~3D C0 Cn r' C -CDW D ,ji N)a)Cl 0 a CD~CD.CL TABLE 2.2-1 (Sheet 2)Scientific Name Lill aceae (continued)

Smilaclina racemosa (L.) ODef.

bitlor-um (walt.) Ell.e x h isp i a I' ll, 7i foia i L.Sallcales Sal lcacese aff ldeltoldes Marsh.Juglandales JUqlandaceac

.3uglbfls figc, 1_r.C a gorilformis tWang.) X. Koch.c IJctnloca (Mlchx. f. Loud Fagales Fagaceae Ouercus macrocarpa Michx.Quercui boreHTis ichx. f.t-r Muenchh.Quercus a weardL Sack Urticales Ulmaceoe UlImus op. L Uiru-% americena L.UI.ue Muhl.Horacese Maclura pomIfera (ROe.) Schneid.Urticaceae Urtics dioica L.LaporLe canadensis (L.) Wedd.Wi1[iamla

_L.. Gray par---etarla penUvnica Muhl.hoebmari ca (flndjTL.)

Sw.Community Types Common Name rales Solomon's seal Solomon'e seal Cceeribrie Greenbrier Willow Family Cottonwood Black vwi low Walnut Family Black valnut Bitternut hickory Shellbark hickory Beech Family Bur oak Red oak Plin oak Shward's oak Elm Family Elm American elm Slippery elm Hackberry Mulberry Family Osage-orange Red mulberry Nettle Familynro etie Wood-nettLe Clearweed* Pellitory False nettle 0 4 b,* 4p Index of Rel)atve Comunitz Abunda ne i-C 0 0.C: C A I A C D I A A, C C C C C I I TABLE 2.2-I (Sheet 3)CD 0 C: CD CL Scientific Name Pol ygonales Polyq onaceae Rwnex acetonella L.P 2 sp. L.P._g L.leyadonum o .Car¥ophyltlles Chenopodlaeeae Poenoonum np. E. l gou bum , .uaypyils etny~m Alo ACranthaceae Amaranthau5

p. L.',-M-MEFti tama iecirus (Nutt.) Wood arantaetroalezu L.Aixosceae Nog verticlllata Portulacaceae Portulaca oloracea L.Caryophyllaceae Stellarla sp. L.-ua Iatum I., 51-ne atellata IL.) Ait. t.Ranalas Ranunrculaceae Ranuncuue upo. L.IMrermeutUs abortlivus L.Community Typet Common Namn, Smartweed Family Red sorrel Curly dock Polygon um Smar tweed Pennsylvana e.ar tweed DOtted smartweed I Lady's thumb Smart*ged C Palse buckwheat I GOO"efOot family Goose root Lamb-9s quarters I plaploloar 9ooseroot E Gooeetoot Amaranth Family Amaranth Water hemp Redroot Carpetwoed Family Carpetweed Purslae, ealily Purslane Springj teuty Pink Chickweed Mouso-ear chickweed Sleepy catchfty Starry camplon Crowfoot Pamily Ruttercup Smail- fovered crowfoot 9 4.b e~J',0 *.~ ~ 04 dt~? '*~' ~~'t'i'(~' ~'indes of Relative Commucit., Ab.lfmdance A 0 C!I C I-C I A A C TABLE 2.2-1 (Sheet 4)CD 0)0 CD 0CL 4 4",~. 40 A' .~P~A 4; .44k Scienttific Name Rarnoncul aceae I cont i nuedj Irescenn Ndutt~.aft Mhl.ftaniapormacoae Me"Ispermu~cnat~sL Cruc i erae L.asidhra aP.Dr i~pfi Gn.) ien 41b~ caaeis L*drlBx~p Rosales acta 0~e~ or.s~aittagacmme 1,ib!Ls missouriense Nutt.PI a FZ0-5caeWe

!_.t~tb'wv occidentalia L , r..arli v ir~niafla Ducheene Cum ernum (Rat.) T. & G, vo-sacaro

£ ma I.!;iueaih serot Ina Ehrit.traraegus sp. L.M~imosaCosa besmanthua illinoensis Willd.Caesalpintaceae Cercis canade mi. L.Xila I. .Koch Community lypes Common Name frairia larkepor Meadowi rue Meadow, rue Ci embt I NO~nsa*,d Family Canada moonseed Mustard family Neppergr aa peppergqeas Drab&Pact cr.,sa Sikis-pod Marsha cress Sasitragje Family istOurl 9,06seberry lafte-Tram Vastly syeemore Rose Family vir~ti,~ strawberry Avans spring 3 avena whit. a~enb Commoo blackberry A.;r imony Carol ina rose cherry Black cherry Mimosoa Vastily Illinois bUndlaflover Rodbu.d HIoney-lIocust sontucky coltab-tree In~dex OfRltie ui u oc t!!A C A-U C C C I t 1 I I C TABLE 2.2-1 (Sheet 5)_CD 0 A CD Commu*nity Typal li V 6k Scientific-Name common Name index of Relativa Coammnitv Abund&Ane Fhbaeeae Dean Family saptiialahusophaea Nu'tt. WI1)Id Ind qo I trtotw rpeo WhI~ite *clover C Keriltuf n61T 18 Maia .) CO8r. leeI ossov etec1iova r psoraeia i-i -ent-a Fr sh .Prairie turnip rsoor'al tenultiora Porsh. Scurfpca I etalost;W

• Op. ichm. Prairit-clover PetATOStmu candidus (14111d.)

Miehii. white prairie-clover L# pd~a mina)~im.

Kborean )&Spode*&

C 0 rtoy eaii~e 5T .Piper W I d be n I S~i~olifl~

T~iTi(.) li. Wild bean UiMO4tu!Sp Dov Tick-trefoil Crii Idacese Wood-sorrel Family 08118i ap. 1 Wood-corroil iT trict. Y. ellow wood-sorrelA O-xalis -violTa-ca L.Violet wood-sorral C-A Oeacaiaceae Geranim ros P.ily Geranium carolinianom L. Crane's-bill raphorbiaceaff spurge Family Croton capitetua Nichal. Croton I AA yphagrii~.Tnn Cray Thrte-eeeded mercury C C I-C Euphorbia A-s* "O SWroddn pg UP40, O t ia. Spurge OT sg a Mcna Wartweed hM ri UWTiatrata engeim. pugC GMporiAi 'crhate I.. Flaowring opurge C.P or$*F** F pllI L, Flre-oe,-the-acunthin I Zolphorble EW -na-ti7-Pursh.

• B ovn-the-mountain Sapinda~ea Apacardiaceae Cashemw Family ltiua radica~m L. Poison Ivy A I hMR RIE~ro L.Smooth 84=40 C-A CalAstraveae Staff-tree Namily Ituonymut atropurpurcoU .Iacq. Ushoo C TABLE 2.2-1 (Sheet 6)CD 0 CD&-b,, Index of Rtelativec Community Abundan~ce Aceraceaq Acer sAccharinut I..XCcie- nequ L Hippocastanaceae Aescujug glabra Willd.Rablami nacease Impatiens biflors Walt.iMamnai es Vitacese VEitS aestivalls Michx.T-r-t E a lssa ua g.uinquefolla (L.) Plarich.Side apin1o5a L..ch&aun trlonum I..99-TTY- th-eiw~asti mtedic.Par ietI a b hyporicaceae flypericu pufletatkn Lam.VioL aceae Viola op. L.Vil T- ii~ae Pursh.V-ioTd- 2idiiTd1;1,;a

a. Don.yil r.-He E pa Schw.Cac tales Cactaceass Opuntia compressa (Salsts.) )tAChr.Myrtales Onagjraceaee Ossnothers bienois L.(Muara hien-niS6

-T.-&frccaQarrieulcata (Mtaxim.)

Frenich £Say.Community Types CoCmUoEn Name Kaple Family Silver maple Boxelder IIors*e-chotnut family Ohio buckeye Touch-me-Not Family Jewelveed Grape Family Grape C Summer grape I Virginia creeper A galbow Pamily Sida Plower of an hour Velvetleaf St. John's wort Pamily Violet Family Violet I Common blue violet Prairie violet Smooth yellow violet A Cactus Family Prickly pear Evenlng Primrose Family Common evenino primrose Biennial gaoira EnChanter's nightshade I I I C I I-C TABLE 2.2-1 (Sheet 7)CD 0 CD Ca 0~ý b, -0 Comunity Tpe; " I Scientific Name Common Name Index of Relative Community Abundance Umbel [ales Umbellitere Paraiey Family Sanicula -yreqaria Bickn. Black anakeroot 0 Cryptaen canadenAi (L.) DC. Honewort I Rieo PRYx *. A&tr .Sweet Clcely I Va:;roC,.Xionb (L.) Crant. Spreading chervil D.c. te L. Wild parsnip Ernum yucc" Jium niche. Rattleonske-manter Cornaceae OO* Family Corau_. sp. L. Dogwood 0eanales Cbenaceae F~eny Family DiOsPYrO Vrginians L. Pera fmon Primulml a Primulaeae Primroae Family Lysimachla quadrifolia L. Whorled loosestrife Centianates Oloaceac Olive Pamily FrsInus ponmoylvaniea Marsh. Croon ash A Apocynaceam Iiegbane Family Apocynom op. i.. Doqbane Aocyn cnnaiu I.. Indian hemp I I I I-CI Asclepiadaceoc lilkweed Familyita ca .I.. Common milkwOed t__ mt,.F Walt. Spider milkweed p sulinx s tuiv )nti Engels. Sullivant's m*L kwsed p AS ZvarifegeL.

White milkweed Polemoniales Coyvolvuiaceae Horning-glory Pamily lp2Eoea Iacunoaa 6. Morning-glory I u L. Bindweed t convolvuiu-3 acpitus L. fedge bindweed I I I 1.-C Oolemoniacceae Phlox Family Phlox dviaricata L. Phlox C Table 2.2-1 (Sheet 8)CD CD 0.Ine fRlt9 4;4 b 4 4ý .Scientific amem HYdrophyllaceae boreg inacede yo.7 ijverna Nutt, Varbonaceae Verbena sp,. L.VerbeQna Canadensis (L..) Drlitt.iLah ia ta Pronalla vulgerig t,.3Scutelarta pervulb HIChx.Lamim alnv ..9-Taretn ae Horneam.i1!VTa `P-ItCFWarI L.T5c rn~fefre~jitrexo (Wait.) Uap._ vcapu athericanua Kuhl.tee ,ya ýtenu* oll Willd.$01 anaceae Ptlfymaceae Phrylaa ltetogtechya L.ScrophularfaCeeaq Penstemon tubseflorus iluit.Veroic5CE~fj~'I T*lia L.veronca rernaL vcronfi-&

e5Th~S La i L.Ace nthacceeq Ituellia strepans L.'lantaginales pianra.ginacear, Pl VICq i5nica L.Pientago ;eriatata

$Micha.Community Typea 4:. ~ 1,.i. fp f'CommOn Name Raterleaf Family Nyctelea Borage Family Porget-me-not Forget-me-not Vervain Family Vervain Large-flowered verbena Hint Family Self-heal Skullcap White dead nettle Sage Pitcher-s sage Mountain mint American bugle-weed 1edge nettle Nightshade Family Ground-cherry Horse-nettle Lopdeed Family'opsoed rigwort Family Penstemon Speedwell Speedveli Speedwell Acanthus Family Spellia Inde offieatie CMuinitV Abnac 1 i C C-A I![C Plantain Family White dvarf plantain C C Ruqel's plantain Common plantain I English plantain buckhorn plantain TABLE 2.2-1 (Sheet 9)a, C: CD, 0.ýCommunity Types Scien~tific Name RubiaL 31*Rubiacese Galluma !zarirm 1'.Caprifol iaceae Sambucus carfidensic L.,yPflOrlc!Ev O~rclutatup Hoesch Cucuebi tal cc Cue urhitacea Stgyos angpusata L..Campanul accae Ca's chula americans L,.Pr odan 5 fotak itL.1 Itiaent.Lobellaceac Lobalia molcatata Lem.Amatrales composit~ac hIelianthus Snfuv, L.RTelianihu-ffeTllolris NHutt.1101 lAnth.9 Thd-EijTlilus Per@.Ilellanthus oaxiajilant Schrader Verbesina hite-rnsfhl BL) ritt.Raibd co~i aNt W oot sStandi ..bluens Rj I~y ha Ske A'M~ins trlidýa L.Kanthil Stuo AV1l L AChMlieC m-rrre-oiflua L.Shtnunt~hcm j l~u0athemhl' Argr ~LIiiovc6ana Hujtt. -Common Name"adder Family Cleavere Honeysuckle Family Common elder Coralberry Gourd ramily our-cuCtmber RarabOli Family Tall bellflower Vvnus' looking gleas Venus' looking gives Lobelia Pamily toobalIs Composite Family Sunflower Common aunflover Sunflower kacimilian sunflower wingstem Prairie coneflover Beggar-ticka Beggar-ticks Begger-ticks Cup plant Rough smpveye Giant ragweed Common ragweed Rag.Ped Western ragweed Common cockhlihur Yarrow Ox-eye delay Louisiana iaen 09 o Relative Community Abundance U I C C-o I-C A I C C-D I I-C I.A-I C I I C I-C C C A tA 0, (D TABLE 2.2-1 (Sheet 10)0 o CD 2.0.community Types V o .Scientific Name Common Namae Index Of Relative Community Abundanco Composites EcontInuedl Goldenrod Sol ldago sp. L.1T3i3 candensis L. Canada goldenrod I Ti rugooa- Mill.. Rough-leaved

?oldenrod I r gE TaMrioli"a (L.) Saliab. warrovleat goldenrod I-C C-A C-A u't"erez iaracinflIOidu* (DC.) Blake DroodmweeA CC-p L.' wild aster I-C Aste- ericoldes L. Heath aster I- C I Vr ,qeon -tril~osus Kohl. Rough fleabane I-4 FiicainIiieiia (L.) Crong. ioreeweed I naTpl i"irLm L. Everlasting rnXtennartha Greene Field pusaytoeu p5rLf purpur'eum L. Joe-pye wee3 I V1pnatortum S ruOUri. 4hlte anakeroot I [r Lm s seroftinur L. Thorough ortI Cicnrt a a Mich.. Blazing star rýJats iunc a a Hook Blazing star I ero7TaT ictiata Hich. Ironweed Vernn7na ba jlflnl Torrp. Ironweed I C

---(l,.) Scop. Canada thistle I Prenanthe SP. L. white lettuce Ta ran CItt offiCi nale Weber ra ndel ton Prickly lettuco I rstuca serriola L. Prickly lettuce I taaýica bien(ni lHoench) Pern. Tall lettuce I a D = community dominant; A abundant; C = cowmmon; i = relatively infrequent.

Table 2. Land uses within the Wolf Creek -Rose Hill transmission line right-of-way (from KGE 1975, Table 3.9-1).WCGS ER* 3.9-1 LAND USE OF TRE ROSE HILL 'TO WOLF CREEK TRANSMISSION LINE RIGHT-OF-WAY Land UsP Type Linear Feet Aoreaqe Percent of Total Cropland Row and Broadcast 04,405 290.7 17.2 Forage 32,390 111.5 6.6 Subtotal 116,795 402.2 23.8 Grazing Pasture 20,850 7.1.8 4.2 Wooded Pasture 4,690 16.2 1.0 Range 299,260 1030.5 60.9 Wooded Range 19,930 6R.6 4.1 Subtotal 344,73D 1187.1 70.2 Woodlands Woods 13,500 46.5 2.8 Riparian Woods 4,190 14.4 0.9 Hedqern'ws 720 2.5 0.1 Subtotal 18,410 63.4 3.8 Idle Land 7,930 27.3 1.6 Waterways 650 2.2 0.1 Roads 2,525 8.7 0.5 TOTALS 491,040 1690.9 100.0 Table 3. Land uses within the rerouted right-of-way section of the LaCygne -Benton 345 kV transmission line in the vicinity of Wolf Creek Generating Station.Linear Percent of Land Use Types Feet Acreage Total Cropland 7,953 27.4 19.7 Grazing 12,646 43.5 31.2 Hay meadow 4,498 15.5 11.1 Woodlands 2,021 6.9 5.0 Riparian 782 2.7 1.9 Shoreline/Wetland/Shallow water 2,216 7.6 5.5 Surface water 521 1.8 1.3 Wildlife lands (1) 6,610 22.8 16.4 Other 2) 3,194 11.0 7.9 Total 40,441 139.3 100 (1.) Includes native grasses, grass-brush mix, and brush habitats.(2) Includes roads, gravel areas, and WCGS yard areas.

Table 4. Land uses within the right-of-way of the WCGS tap of the Athens 69kV transmission line.Burlington

-Linear Percent of Land Use Types Feet Acreage Total Cropland 7,041 24.2 32.9 Grazing 652 2.2 3.0 Hay meadow 3,715 12.8 17.3 Woodlands 65 0.2 0.3 Riparian 0 0 0 Shoreline/Wetland/S hallow water 978 3.4 4.6 Surface water 391 1.3 1.8 Wildlife lands (1) 5,671 19.5 26.5 Other (2) 2,933 10.1 13.4 Total 21,446 73.8 100 (1) Includes native grasses, grass-brush mix, and brush habitats.(2) Includes roads, gravel areas, and WCGS yard areas.

Hooper Diane M From: Haines Daniel E Sent: Monday, March 19, 2007 2:47 PM To: Hooper Diane M

Subject:

Critical and Important Terrestrial Habitats Critical and mportant Terrest...

1 Critical and Important Terrestrial Habitats Need: Provide a discussion of other wildlife, including mammals, reptiles, invertebrates, and birds (other than eagle) that may be present in the transmission line corridor.This is a review of potential terrestrial fauna that may be present within the transmission line corridors related to Wolf Creek Generating Station (WCGS). The transmission lines reviewed include the portion of the LaCygne -Benton 345 kilovolt rerouted around Coffey County Lake (CCL), and the Wolf Creek -Rose Hill 345 kilovolt line. These lines traverse habitat types common to eastern and south-central Kansas, and wildlife species common to these habitats can be expected to occur within the corridors.

Except for invertebrates, potential terrestrial species present are characterized by generic habitat where they may be found.The rerouted LaCygne -Benton line traverses approximately 7.7 miles around the northern reaches of CCL. Habitats traversed include the WCGS site, CCL and shorelines, native tall grass prairie, cropland, grazed rangeland, and hay meadows. The corridor is also adjacent to bottom land woodland and mixed shrub and grass areas.The Wolf Creek -Rose Hill line traverses similar habitats, with much higher proportions of cropland and grazed native rangeland than the LaCygne -Benton line. This line is within Coffey, Greenwood, and Butler counties.

It extends southwestward from WCGS for 98 miles to the Rose Hill Substation.

Terrestrial invertebrate species that may be present in the corridors include primarily arthropods.

Theses include insects, spiders, mites, ticks, scorpions, daddy long legs, and others of the class Arachnida.

A conservative estimate of the number of named species of this class is 30,000. It is not known exactly how many species of insects occur in the WCGS area, or in Kansas. 15,000 to 20,000 insect species may be exist in Kansas (White and Salsbury 2000). A representative checklist of Kansas insects is available online at www..qpnc.orpq (accessed December 15, 2006). There are no invertebrate species federally listed as threatened or endangered within any of the counties traversed by the transmission lines. One insect species, the prairie mole cricket (Gryllotalpa major), is listed by the Kansas Department of Wildlife and Parks (KDWP) as a species in need of conservation and present. within Coffey County (KDWP 2006).Terrestrial vertebrate wildlife includes amphibians, reptiles, birds and mammals. Table 1 summarizes representative amphibian and reptile species that may occur within the Coffey, Greenwood, and Butler Counties, Kansas, which includes WCGS and the applicable transmission line corridor.

This summary is not an exhaustive species list, and some species may well be found in multiple habitat types. References used for this table were from Collins (1993).Potential bird species within the three counties are numerous due to their mobility, and migratory nature, and the diversity of habitats present. Currently up to 465 bird species have been documented in Kansas (Kansas Ornithological Society, KOS, 2003). Table 2 lists common species that may be expected to occur within in the vicinity of WCGS and applicable transmission line corridor.

References used to compile this list include WCGS (1984), Thompson and Ely (1989 and 1992), and KOS (2003).Potential mammal species within the three counties are included in Table 3. Species account records were obtained in Bee et al, (1981), and Timm et al (2006).

Table 1.Representative amphibian and reptile species that may occur in WCGS or within the aoolicable transmission line corridors.

the vicinity of Mixed Wetland/ Wood- woodland/Species aquatic land prairie Prairie Amphibians Smallmouth Ambystora x salamander texanurn Tiger salamander Ambystoma x tigrinurn American toad Bufo americanus x Great plains toad Bufo cognatus x Woodhouse's toad Bufo woodhousli x Northern cricket frog Acris crepitans x Cope's gray treefrog Hyla versicolor x Spotted chorus frog Pseudacris clarkii x Boreal chorus frog Pseudacris maculate Western chorus frog Pseudacris x triseriata Crawfish frog Rana areolata x Plains leopard frog Rana blairi x Bullfrog Rana catesbeiana x Southern leopard frog Rana x sphenocephala Great plains Gatrophryne x narrowmouth toad olivacea Reptiles Snapping turtle Chelydra x serpentina Common musk turtle Sternotherus x odoratus Painted turtle Chrysemys picta x Mississippi Map turtle Graptemys kohnii x False map turtle Graptemys x pseudogeographica River cooter Pseudernys x concinna Eastern box turtle Terrepene carolina x Ornate box turtle Terrepene ornata x Slider Trachemys scripta x Spiny softshell Apalone spinifera x Collared lizard Crotaphytus collaris x x Texas horned lizard Phrynosorna x cornutum Five-lined skink Eumeces fasciatus x Great plains skink Eumeces obsoletus Table 1. (Continued)

Mixed Wetland/ Wood- woodland/Species aquatic land prairie Prairie Southern prairie skink Eumeces x x obtusirostris Ground skink Scincella lateralis x Six-lined racerunner Cnemidophorus x sexlineatus Western slender glass Ophisaurus x x lizard attenuatus Ringneck snake Diadophis x punctatus Eastern hognose heterodon x snake platirhinos Flathead snake Tantilla gracilis x Plains blackhead Tantilla nigriceps x snake Racer Coluber constrictor x Great plains rat snake Elaphe emoryi x Rat snake Elaphe obsoleta x Prairie kingsnake Lampropeltis x x calligaster Common kingsnake Lampropeltis getula x Milk snake Lampropeltis x trangulum Rough green snake Opheodrys x aestivius Gopher snake Pituophis catenifer x x x Ground snake Sonora x semiannulata Plainbelly water snake Nerodia x erythrogaster Diamond back water Nerodia rhombifer x snake Northern Water snake Nerodia sipedon x Graham's crayfish Regina grahamii x snake Western ribbon snake Thamnophis x proximus Plains garter snake Thamnophis radix x Common garter snake Thamnophis sirtalis x x x Lined snake Tropidoclonion x x lineatum Copperhead Agkistrodon x contortrix Massasauga Sistrurus catenatus x x x Table 2. Representative bird species that may occur the associated transmission line corridors.

in the vicinity of WCGS or within Mixed Urban Wetlandi Prairie/ Prairie/ and Species Aquatic Woodland Woodland open area Other Ducks/Geese/Swans Greater white-fronted goose x Snow goose x Canada goose x Trumpeter swan x Tundra swan x Wood duck x x Gadwall x American wigeon x American Black Duck x Mallard x Blue-winged teal x Cinnamon teal x Northern Shoveler x Northern pintail x Green-winged teal x Canvasback x Redhead x Ring-necked duck x Lesser Scaup x Bufflehead x Common goldeneye x Hooded merganser x x Common merganser x Red-breasted merganser x Ruddy duck x Pheasants/Grouse/Quail Ring-necked pheasant x x Greater prairie chicken x Wild turkey x x Northern bobwhite x x Misc waterbirds Common loon x Pied-billed grebe x Horned grebe x Eared grebe x American white pelican x Double-crested cormorant x American bittern x Least bittern x Great blue heron x Table 2. (Continued)

Mixed Urban Wetland/ Prairie/ Prairie/ and Species Aquatic Woodland Woodland open area Other Great egret x Little blue heron x Cattle egret Green heron x Black-crowned night heron x Yellow-crowned night heron x White-faced ibis x Sandhill crane x Hawks/FalconslEaglesNul tures Osprey x Northern harrier x x Sharp-shinned hawk x x Cooper's hawk x Northern goshawk x Red-shouldered hawk x Broad-winged hawk x x Swainson's hawk x x Red-tailed hawk x x Rough-legged hawk x x American kestrel x x Merlin x Peregrine falcon x x Prairie falcon x Bald eagle x x x Turkey vulture x x Rails/Gallinules King rail x Sora x American coot x Plovers/Sandpipers/Shore birds Black-bellied plover x American golden plover x Semipalmated plover x Killdeer x x American avocet x Black-necked stilt x Greater yellowlegs x Lesser yellowlegs x Solitary sandpiper x Willet x Table 2. (Continued)

Mixed 'Urban Wetland/ Prairie/ Prairie/ and Species Aquatic Woodland Woodland open area Other Spotted sandpiper x _Upland sandpiper x Hudsonian godwit x Ruddy turnstone x Sanderling x Semipalmated sandpiper x Western sandpiper x Least sandpiper x Whiter-rumped sandpiper x Baird's sandpiper x Pectoral sandpiper x Dunlin x Short-billed dowitcher x Long-billed dowitcher x Common snipe x American woodcock x Wilson's phalarope x Gulls/Terns Franklin's gull x x Ring-billed gull x x Glaucous gull x Herring gull x Caspian tern x Forster's tern x Least tern x Black tern x Pigeons/Doves Rock dove ,_x Mourning dove _ x x Cuckoos Black-billed cuckoo x Yellow-billed cuckoo x Owls/Goatsuckers_

Barn owl x Great-horned owl x x Snowy owl x Barred owl x Long-eared owl x x -Short-eared owl x Eastern screech owl x x Common nighthawk x

Table 2. (Continued)

Mixed Urban Wetland/ Prairie/ Prairie/ and Species Aquatic Woodland Woodland open area Other Swifts/Hummingbirds Chimney swift x Ruby-throated hummingbird x x X Kingfishers Belted kingfisher x Woodpeckers Red-headed woodpecker x x Red-bellied woodpecker x x Downy woodpecker x x Hairy woodpecker x X Northern flicker x x Pileated woodpecker x Flycatchers Olive-sided flycatcher x Eastern wood-pewee x Willow flycatcher x x Least flycatcher x x Eastern phoebe x Great-crested flycatcher x Western kingbird x x Eastern kingbird x x Scissor-tailed flycatcher x Shrikes Northern shrike x Loggerhead shrike x x Vireos Bell's vireo x Solitary vireo x Yellow-throated vireo x Warbling vireo x x Red-eyed vireo x Jays/Crows Blue jay x x American crow x x Larks Horned lark x Table 2. (Continued)

Mixed Urban Wetland/ Prairie/ Prairie/ and Species Aquatic Woodland Woodland open area Other Swallows Purple martin x Tree swallow x Northern rough-winged x swallow Bank swallow x x Cliff swallow x Barn swallow x x Chickadees/Titmice Black-capped chickadee x Carolina chickadee x Tufted titmouse x Nuthatches/Creepers White-breasted nuthatch x x Brown creeper x Wrens Carolina wren x x House wren x x Winter wren x Kinglets Golden-crowned kinglet x Ruby-crowned kinglet x Gnatcatchers Blue-gray gnatcatcher x Thrushes Eastern bluebird x x Veery x Wood thrush x American robin x x Thrashers Gray catbird x Northern mockingbird x Brown thrasher x Starlings European starling x__________

I. ____ I ____ I ____ I ____ J ____ ]

Table 2. (Continued)

Mixed Urban Wetland/ Prairie/ Prairie/ and Species Aquatic Woodland Woodland open area Other Pipits Water pipit x Waxwings Cedar waxwing x Warblers Nashville warbler x Northern parula x Yellow warbler x Chestnut-sided warbler x Magnolia warbler x Yellow-rumped warbler x Blackburnian warbler x Bay-breasted warbler x Cerulean warbler x Black-and-white warbler x American redstart x Ovenbird x Northern waterthrush x x Kentucky warbler x Common yellowthroat x Wilson's warbler x x Tanagers Summer tanager x Sparrows Rufous-sided towhee (???) x American tree sparrow x Chipping sparrow x x Field sparrow x Vesper sparrow x Lark sparrow x x Savannah sparrow x Grasshopper sparrow x Fox sparrow x x Song sparrow x x Lincoln's sparrow x Swamp sparrow x White-throated sparrow x White-crowned sparrow x Harris' sparrow x x Dark-eyed junco x x Lapland longspur x Table 2. (Continued)

Mixed Urban Wetland/ Prairie/ Prairie/ and Species Aquatic Woodland Woodland open area Other Snow bunting x x GrosbeakslBuntings Northern cardinal x x x Rose-breasted grosbeak x Blue grosbeak x Indigo bunting x Dickcissel X BlackbirdslOrioles Bobolink x Red-winged blackbird x Eastern meadowlark x Western meadowlark x Yellow-headed blackbird x Rusty blackbird x Brewer' blackbird x Great-tailed grackle x Common grackle x x Brown-headed blackbird x.Orchard oriole x x Northern oriole x x Northern finches Purple finch x Pine siskin x x American goldfinch x x House finch x X Old world sparrow House sparrow X Table 3. Representative mammal species that may occur in the vicinity of WCGS or within the associated transmission line corridors.

Mixed Wet- Prairie/ Prairie/ Urban land/ Wood- Wood- open and Species Aquatic land land area Other Virginia opossum Didelphis x x virginiana Southern short-tailed Blarina x x x shrew carolinensis Least shrew Cryptotis paNa x x x Eastern mole Scalopus x x x aquaticus Eastern pipistrelle Pipistrellus x x x subflavus Big brown bat Eptesicus fuscus x x Red bat Lasiurus borealis x Hoary bat Lasiurus cinerus x x x Nine-banded armadillo Dasypus x x novemcinctus Eastern cottontail Sylvilagus x x x floridanus Black-tailed jackrabbit Lepus californicus x Woodchuck Marmota monax x x Thirteen-lined ground Spermophilus x squirrel tridecemlineatus Franklin's ground Spermophilus x squirrel franklin/i Gray squirrel Sciurus x carolinensis Fox squirrel Sciurus niger x x Pocket gopher Geomys bursarius x Hispid pocket mouse Chaetodipus x hispidus Beaver Castor canadensis x Plains harvest mouse Reithrodontomys x montanus Western harvest Reithrodontomys x x mouse megalotis Deer mouse Peromyscus x maniculatus White-footed mouse Peromyscus x x leucopus Hispid cotton rat Sigmadon hispidus x x Eastern wood rat Neotoma floridana x x Prairie vole Microtus x ochrogaster Woodland vole Microtus pinetorum x x Muskrat Ondatra zibethicus x I Table 3. (Continued)

Mixed Wet- Prairie/ Prairie/ Urban land/ Wood- Wood- open and Species Aquatic land land area Other House mouse Mus musculus x x x x Meadow jumping Zapus hudsonius x mouse Coyote Canis latrans x x Red fox Vulpes vulpes x x x Gray fox Urocyon x cinereoargenteus Racoon Procyon lotor x x Long-tailed weasel Mustela frenata x x x Mink Mustela vison x Badger Taxidea taxus x Striped skunk Mehpitis mephitis x Eastern spotted skunk Spilogale putorius x x Bobcat Lynx rufus x White-tailed deer Odocoileus x x virginianus Literature Cited Timm, R. M., N. A. Slade, G. R. Pisani, J. R. Choate, G. A. Kaufman, and D. W.Kaufman. 2006. Mammals of Kansas. website http://www.ksr.ku.edu accessed December 20, 2006.Bee, J. W., G. Glass, R. S. Hoffman, and R. R. Patterson.

1981. Mammals in Kansas.University of Kansas Museum of Natural History, Public Education Seriers No. 7.University of Kansas, Lawrence.

300 pp.Thompson, M. C., and C. Ely. 1989. Birds in Kansas, Volume I. Universtiy of Kansas Museum of Natural History, Public Education Series No. 11. Universtiy of Kansas, Lawrence.

404 pp.Thompson, M. C., and C. Ely. 1992. Birds in Kansas, Volume II. University of Kansas Museum of Natural History, Public Education Series No. 12. University of Kansas, Lawrence.

424 pp.Collins, J. T. 1993. Amphibians and Reptiles in Kansas. University of Kansas Museum of Natural History, Public Education Series No. 13. University of Kansas, Lawrence.397 pp.Salsbury, G. A. and S. C. White. 2000. Insects in Kansas, Third Edition. Kansas Department of Agriculture and Kansas State University.

Topeka, Kansas. 522pp.Kansas Gas and Electric Company. 1984. Wolf Creek Generating Station 1983-1984 Pre-operational Phase Wildlife Monitoring Report. Burlington, Kansas. 48pp.Kansas Department of Wildlife and Parks. 2006. website at http://www.kdwp.state.ks.us Accessed December 20, 2006.Kansas Ornithological Society. 2003. Kansas Ornithological Society Birds of Kanas Checklist.

Tenth Edition. Available on web page http://wwwksbirds.org.

Accessed December 20, 2006.

70 Alternatives Page I of 5 Would additional transmission infrastructure be necessary if purchased power replaced Wolf Creek's capacity, i.e., do existing transmission lines have sufficient capacity to support purchased or imported power? Would any new utility ROW be necessary?

Would existing ROW need to be expanded or otherwise modified?Would existing ROW be retired and return to other uses? What are the impacts of these actions?Response:

As mentioned in Section 7.2.1.3, WCNOC anticipates that additional transmission infrastructure would be needed in the event that the owners of WCGS purchase power to replace WCGS capacity.Given that additional transmission infrastructure would be needed in the event that the owners of WCGS purchase power to replace WCGS capacity, new utility rights-of-way and/or expansion of existing rights-of-way would be needed. Possible routes for new transmission lines are speculative.

However, as much as 250 miles of new transmission line rights-of-way could be needed under the purchased power alternative.

As discussed in Section 3.1.3 of the ER, the existing transmission lines (and rights-of-way) would remain a permanent part of the transmission system after WCGS is decommissioned.

Therefore, if purchased power replaced WCGS capacity, the existing transmission lines and rights-of-way would remain in use.To the extent possible, transmission lines under the purchased power alternative would be routed along existing transmission line or pipeline corridors, rail lines, and roadways.Environmental impacts of construction/expansion of transmission line rights-of-way are well known and would include: Land Use -Land use impacts would be minimal. Transmission lines would be developed primarily on vacant/undeveloped land. Small areas of rangeland used for grazing and forage, agricultural lands, and mining could be permanently removed from production by tower foundations and spur roads, where necessary.

Visual -Visual impacts would increase with effects on views from highways, residences, and recreational areas, as well as on natural scenic quality. The first transmission line or industrial linear feature (i.e., rail line) built in a natural setting usually will cause the most noticeable incremental change because of the contrast of form, line, color, and texture to the surroundings.

Each successive change, such as expansion of an existing transmission right-of way, becomes less noticeable than the first.Cultural Resources

-Construction of new transmission lines would not directly affect cultural resources within the corridor if ground disturbance activities occur outside of the historic/archaeological site boundaries.

To the extent possible, transmission line rights-of-way would be routed to avoid historic properties and archaeological sites. Careful placement of new transmission line towers, work areas, and access roads would reduce incremental impacts to any cultural resources that may occur with the transmission line corridor.Biological Resources

-Biological impacts would occur during construction of new transmission lines, ground disturbance and noise may cause some wildlife in the vicinity of the project to relocate.

However, the impacts would be temporary.

Earth and Water Resources

-The construction of new transmission facilities could increase the potential for wind and water soil erosion, stream bank degradation, and sedimentation in water bodies. The amount of ground disturbance would be minimized by using, to the extent possible, existing rights-of-way that parallel existing roads. The use of silt fences, water sprays and other dust control measures would further reduce impacts to these resources.

Alternatives Page 2 of 5 Can construction begin on a new facility at the Wolf Creek site while WCGS is in operation?

Can a new plant be constructed that would use Wolf Creek's cooling system prior to the retirement of WCGS? Can a new plant be constructed on previously disturbed areas of the site prior to retirement of WCGS? If not, what are the impacts of building a new, alternative plant on a Greenfield site or of constructing and operating a new cooling system?Response:

Electric utilities often co-locate new-generating facilities with existing facilities.

Multi-unit sites generally undergo phased development such that new units are constructed as the need for additional generating capacity arises. Multi-unit sites often share resources such as cooling water systems. With proper planning, new generating units could be constructed and connected to the WCGS cooling water system (during a regularly scheduled outage). It is likely that the new generating unit would be isolated from the WCGS cooling water system, via redundant shut-off valves, until WCGS is retired. Enough previously disturbed land is available at the WCGS site for construction of alternative generating units." What is the current attainment status (Clean Air Act) of the region within which WCGS is situated?Response:

Air quality attainment status is addressed in Section 2.10."Coffey County is in attainment for all air quality standards as are all counties in the State of Kansas (40 CFR 81.317, 70 FR 974, and 70 FR 7070)."* PM2.5 is a Clean Air Act criteria pollutant.

Please provide any available information on how much PM2.5 would be emitted using the coal, oil or gas alternatives to license renewal.Response:

For the coal-fired alternative, PM2.5 emissions would be 0.145 tons per year.In Section 7.2.1.5 of the ER, WCNOC determined that the oil-fired alternative was not a reasonable alternative due to the high fuel cost and lack of obvious environmental advantage.

Consequently, air emissions for the oil-fired alternative were not evaluated.

For the gas-fired alternative, all particulate emissions are less than 1.0 micron; hence, all particulate emissions are PM2.5. Therefore, PM2.5 emissions would be 49 tons per year.* What is the heat rate for Wolf Creek? How would the differential levels of heat rejection from the sited appropriate alternative energy sources affect the heating of CCL? Would you be aware of any significant effects to water quality or ecology should the thermal output to the lake change in conjunction with alternative energy sources?Response:

3565 Mwth (100%power).

It is unlikely that any affect would be observed.

Any generating facility that would replace WCGS would comply with the thermal limits in Section 316(a) of the Federal Water Pollution Control Act, as amended. We are not aware of any significant effects to water quality or ecology.* Provide the annual average capacity factor for WCGS for the ten year period ending in 2006. Please indicate those years during which refueling outages occurred.Response: See attached data Alternatives Page 3 of 5* Provide the gross and net electrical output of WCGS based on summer and winter conditions.

Response:

See attached ýdata" What does WCNOC view to be a realistic schedule for implementing the alternatives evaluated in detail in the ER (gas, coal, nuclear)?

Please provide a simplified permitting, design and construction schedule for each such alternative.

Response: " Provide the range of WCNOC employee salaries.

Also, provide the range of salaries for permanent contract employees at WCGS.Response:

The salary range expressed as an hourly rate for all WCNOC employees is Low=$10.69 and High=$170.00.

No permanent contract employees.

• Is there a gas transmission line in the immediate WCGS vicinity to support a gas-fired alternative?

What is the distance that a new gas line would need to be run to support gas fired operations at the WCGS site and what would be the diameter of the line?Also, is there adequate capacity in the nearest gas transmission lines to support gas-fired operations at the WCGS site?Response:

Coffey County is underlain by a large natural gas reservoir and several well development projects are being implemented in the County to utilize this resource.

A large interstate natural gas transmission line with a general east-west orientation is located approximately 8 miles north of WCGS. There are several other interstate pipelines in the vicinity of WCGS. Due to post 9/11 security issues, the available capacity for these lines is not readily available, but we assume that capacity would be available if the gas-fired alternative was pursued. As discussed in Section 7.2.2.1, WCNOC assumed that a new16-inch diameter pipeline approximately 10 miles long would be required." Please update the information presented in Section 7.2 of the ER to show both Generating Capacity and Generation by fuel type for the years 2000 through 2006 inclusive.

Response:

WCNOC used Generating Capacity and Generation by Fuel Type data from 2002 because it was the most recent data available at the time the ER was drafted. Data for the years 2000 through 2004 are available online from the Energy Information Administration at http://www.eia.doe.qov/cneaf/electricity/st profiles/kansas.pdf.

Data for 2005 and 2006 have not been published." WCNOC has limited its analysis of coal fired alternatives to pulverized coal systems (ER Section 7.2.1). However, the WCGS operating license does not expire until 2025 which is 18 years off. At this point in time integrated gasification combined cycle systems are well under development and it's likely that these and other advanced coal utilization systems will be operational by the time the WCGS license expires.Please provide updated information including a brief assessment of the state of advanced coal utilization technologies, whether such technologies could be employed at the WCGS site and the potential benefits of the new technologies.

In particular, the possible environmental advantages of advanced coal systems should be mentioned including reduced air emission in comparison to pulverized coals burners. The purpose of addressing advanced coal technologies would not be to Alternatives Page 4 of 5 consider those technologies as formal "alternatives" to license renewal but rather to generally update the information presented in the alternatives analysis.Response:

Information on these advanced coal technologies is available from DOE at http:l/www.doe.qov/enercqysources/coal.htm.

There are a number of advanced coal systems that are being developed with funding from the Department of Energy (DOE), including gasification combined cycle and carbon sequestration systems. While many of these systems look promising, a number of technical issues need to-be resolved before they would be considered "reasonable" alternatives.

It is possible that the technical issues for some of these advanced coal systems would be resolved by the time the WCGS license expires, but predictions for when these systems would become viable are speculative.

Most license renewal Environmental Impact Statements contain an analysis of a combination of alternatives to replace the output of a generating station should the operating license not be renewed. Please provide an analysis of at least one combination alternative that WCNOC considers feasible.Response:

We believe evaluation of combination of generating sources is beyond the scope of the ER. In the GElS (NRC 1996, Section 8.1) NRC states: "While many methods are available for generating electricity, and a huge number of combinations or mixes can be assimilated to meet a defined generating requirement, such expansive consideration would be too unwieldy to perform given the purposes of this analysis.

Therefore, NRC has determined that a reasonable set of alternatives should be limited to analysis of single, discrete electric generation sources and only electric generation sources that are technically feasible and commercially viable." In response to public comments on the proposed 10 CFR 51 Rule for Renewal of Nuclear Power Plant Operations Licenses and Supporting Documents, NRC stated: "The NRC agrees that a mix of alternative generating sources-could conceivably replace the generating capacity lost if license renewal were not chosen.However, consideration of all the various mixes of alternative energy sources would logically yield an infinite number of alternatives.

The NRC and CEQ NEPA regulations require the consideration of a reasonable range of alternatives.

Therefore, NRC believes that consideration of discrete alternative sources of energy is reasonable and appropriate given the circumstances

...(I)mpacts from the range of reasonable alternatives will inherently bound all expected environmental impacts from various combinations of alternative energy sources." (NUREG-1 529, Vol. 2, Response to Concern Number ALT.01 1)In addition, we are not aware of any previous applicant for license renewal that has included analysis of a combination of alternatives in their ER.Consistent with the NRC determination and ERs prepared by previous license renewal applicants, WCNOC did not evaluate mixes of generating sources. However, WCNOC did state in Section 7.2.1 that the impacts from coal- and gas-fired generation presented in this chapter would bound the impacts from any combination of the two technologies.

The information provided in the WCGS ER is consistent with that provided by previous applicants for license renewal and determined to be sufficient by NRC Staff.With regard to Section 7.2.1.4, please identify the range of conservation, efficiency and load management programs being conducted in Kansas. This should list each Alternatives Page 5 of '5 program, identify its sponsor and goals, and provide information relative to the success of the effort.Response:

A summary of demand side management programs offered in Kansas is provided in a report prepared for the State entitled "Energy Efficiency and Conservation in the Public, Residential, Commercial and Industrial Sectors." The report is available at http://kec.kansas.qov/reports/EE and C Final%20Report.rpdf.

ER Section 7.2.1.3 addresses purchased power. Please provide a chart showing Kansas power imports for the last ten years. Also, identify transmission line constraints, if any, to importing power into the state.Response:

Net annual energy imports/exports, including electricity, for the years 1990 through 2003 are available from the Energy Information Administration at http://www.eia.doe.qov/emeu/states/sep use/total/pdfluse ks.pdf. Data for the years 2004 through 2006 have not been published.

There are a number of transmission constraints with the Southwest Power Pool (SPP) RTO, which includes the entire state of Kansas. Documents describing the SPP system constraints are available at http://www.spp.org/.

Alternatives Construction Schedule Basis: Construction commences at groundbreaking and ends when plant goes online.Coal -Fired 36 to 42 months (fifth power plan)Gas -Fired 24 months (fifth power plan)Advanced Nuclear 7 to 8 years (Vogtle ESP)

References:

Northwest Power and Conservation Council 2005. "The Fifth Northwest Electric Power and Conservation Plan" May 2005. Available online at http://www.nwcouncil.org/energy/powerplan/plan/Default.htm Vogtle Early Site Permit Application, Revision 1, Part 3, Environmental Report, Section 3.9. NRC Accession

1. ML06321056

Reference:

WCGS Applicant's ER (Operating License Renewal Stage) Chapter 2.1.11,300 owned acres -5090 lake = 6210 acres 6210 acres -135 site footprint

= 6075 acres 6075 acres -60 Dam = 6015 acres Coal -Fired Option would use approx. 5,200,000 tons/year (ER Sec. 7.2.2.2)Typical Railcar holds 100-120 tons of coal.Unit train would have 100-125 rail cars Assuming each unit train has 100 cars and each car holds 100 tonsof coal -10 Deliveries per week.5,200,000tons/year X i year/52weeks X 1 railcar/1 00 tons X 1 train/100 railcar =10 trains per week Assuming each unit train has 120 railcars and each railcar contains 130 tons of coal -6 to 7 deliveries per week 5,200,000tons/year X 1 year/52weeks X 1 railcar/120 tons X 1 train/1 25 railcar =6.7 trains per week

Reference:

Power Engineering 2005. "Bringing Coal Yards into the 21st century" July 2005 Hooper Diane M From: Medenciy Charlie M Sent: Friday, April 20, 2007 3:23 PM To: Hooper Diane M

Subject:

Source of Refueling Outage Dates The WCGS Paperless Environment is the source of the data for WCGS refueling outages.I Refuel Outage Dates Refuel Start Finish Duration 1 10/16/86 12/21/86 66 days. 7 hrs 57 min Time 0201 Time 0958 2 9/27/87 1/05/88 100 days 10 hrs 58 min Time 0201 Time 1330 3 10/07/88 1/04/89 89 days 10 hrs 7 min Time 0200 Time 1207 4 3/09/90 5/16/90 67 days 23 hrs50 min_Time 0027 Time 0017 5 9/20/91 1/15/92 116 days 22 hrs 39 min* Time 0125 Time 0004 6 3/4/93 5/17/93 73 days 8 hrs 26 min Time 2353 Time 0719 7 9/16/94 11/02/94 47 days 12 hrs 30 min Time 0001 Time 1231 8 2/03/96 4/7/96 63 days 17 hrs 13 min Time 1800 Time 1113 9 10/04/97 12/1/97 Time 0001 Time 0539 58 days 5 hrs 38 min-1 Bkr Time 0001 Time 1213 58 days 12 hrs 12 min-2nd Bkr 10 04/03/99 05/09/99 Time 0001 Time 2033 36 days 20 hrs 32 min-1t Bkr 05/10/99 Time 0001 Time 0505 37 days 5 hrs 4 min-2nd Bkr 11 09/29/00 11/07/00 Time 2351 Time 0118 38 days 1 hr 27 min-s t Bkr 11/07/00 Time 0545 38 days 5 hrs 54 min-2nd Bkr 12 03/23/02 04/27/02 35 days 19 hrs 17 min -ist Bkr Time 0005 Time 2022 04/28/02 Time 0702 36 days 5 hrs 58 min -2 nd Bkr 13 10/18/03 12/02/03 Time 0000 Time 1256 45 days 13 hrs 56 min -1st Bkr 12/02/03 Time 1812 45 days 19 hrs 12 min -2 d Bkr.14 04/09/05 05/19/05 40 days 07 hrs 23 min Time 0000 Time 07:23 15 10/7/06 Tim 11/12/06 Time 34 days 07 hrs 8 min I 0000 0708 2 Forced Outage Dates*Year Start Finish Duration Cause 1985 9/23/85 9/23/85 0 day 16 hrs 57 min Reactor trip on S/G 'D' Lo-Lo Time 0350 Time 2047 level after 'D' Main Feed Reg Valve failed shut 10/07/85 10/09/85 2 days 7 hrs 27 min Loss of Circulating Water due Time 1400 Time 2127 to moss buildup on the intake screens.10/10/85 10/10/85 0 day 17 hrs 34 min Turbine trip/Reactor trip on Time 0224 Time 1958 S/G 'C' Hi-Hi level 1986 2/22/86 2/24/86 2 days 9 hrs 16 min Tripped on S/G Lo-Lo level Time 0400 Time 1316 after a speed sensor card in the EHC system failed causing turbine control valves to shut.4/08/86 4/25/86 16 days 15 hrs 0 min Reactor trip by accidentally Time 1037 Time 0137 tripping main generator output breaker in the switchyard.

6/04/86 6/11/86 7 days 20 hrs 19 min Manual shutdown to rewire Time 0128 Time 2147 Limitorque operators 6/30/86 7/01/86 0 day 16 hrs 26 min Reactor trip on loss of all three Time 1331 Time 0557 Condensate pumps 7/01/86 7/01/86 0 day 6 hrs 43 min Reactor trip on S/G 'A' Lo-Lo Time 0625 Time 1308 level during plant startup 7/24/86 7/26/86 2 days 18 hrs 30 min Reactor trip on S/G 'B' Lo-Lo Time 0042 Time 1912 level while reducing power to fix water leaks on Main Gen 12/22/86 12/22/86 0 day 13 hrs 17 min Reactor trip on S/G 'A' Lo-Lo Time 0900 Time 2217 level due to failure of feedwater flow controlling

_channel 1987 1/08/87 Time 1818 1/12/87 Time 1453 2 days 20 hrs 35 min Reactor trip/SI caused by isolating wrong transmitter during STS-IC-507A 1/20/87 1/22/87 1 day 6 hrs 17 min Reactor trip on turbine trip due Time 1800 Time 0017 to Turbine-Generator bearing high vibration 4/19/87 4/19/87 0 day 13 hrs 08 min Reactor trip during LCO Time 0846 Time 2154 ramping down for Rod Control urgent failure 3 4/23/87 4/24/87 1 day 9 hrs 1 min Reactor trip on Hi Neg. flux Time 1223 Time 2124 rate due to failure in Rod control cabinet 5/28/87 5/29/87 0 day 21 hrs 18 min Reactor trip after loss of power Time 1429 Time 1247 to PG1 1k when a spark occurred after shutting a breaker 6/29/87 6/30/87 1 day 13 hrs 58 min Reactor trip on Lo-Lo S/G Time 0649 Time 2047 level after Feedwater Pump 'A'trip 7/20/87 7/26/87 5 days 9 hrs 20 min Reactor trip due to switchyard Time 2306 Time 0826 1 bus failure 9/10/87 Time 2009 9/12/87 Time 0549 1 day 9 hrs 40 min Turbine trip/Reactor trip on Generator phase differential due to phase 'B' line failure going to switchyard 1988 1/21/88 2/16/88 25 days 21 hrs 45 min Manual shut down due to_ Time 2129 Time 1914 Vessel outer O-ring leakage 1989 1/23/89 1/23/89 0 day 9 hrs 8 min Turbine-Generator vibration Time 1322 Time 2230 2/02/89 2/04/89 1 day 18 hrs 6 min 'C' MSIV fast close -'C' S/G Time 1324 Time 0730 LO-LO level 7/11/89 7/11/89 0 day 4 hrs 32 min Turbine off line (Reactor Time 0217 Time 0649 critical)

-repair 'A' Main Feed Reg Valve 1990 2/06/90 2/08/90 2 days 5 hrs 47 min Reactor trip due to RCP 'A'Time 0907 Time 1454 lockout relay picking up 5/17/90 5/18/90 0 days 21 hrs 34 min Reactor trip after taking turbine Time 2146 Time 1920 off line to repair leak on 'A'Main Feed Pump seal water return orifice 5/19/90 5/21/90 1 day 0 hrs 32 min Reactor trip on 1st stage MSR Time 2353 Time 0025 drain tank 'A' level high 1991 (None)1992 2/19/92 3/27/92 35 days 13 hrs 24 min NN Inverter failed, RCS Time 2110 Time 1034 crossover loop saddle block noise 11/10/92 11/11/92 1 day 6 hrs 54 min Rose Hill line fault Time 1103 Time 1757 1993 4 (None)1994 1/15/94 1/17/94 2 days 10 hrs 7 min Planned shutdown to modify Time 0908 Time 1915 Reactor cavity cooling duct work 1/27/94 1/29/94 2 days 11 hrs 11 min T.S. shutdown due to bad Time 0423 Time 1534 thyristor in rod control 1995 3/08/95 3/14/95 6 days 7 hrs 45 min Reactor trip from 100 % power Time 1445 Time 2230 while performing surveillance testing on reactor trip breakers.1996 1/30/96 2/03/96 3 days 14 hrs 13 min Circ Water traveling screens Time 0347 Time 1800 sheared pins and froze due to cold temperatures.

Plant entered NUE due to loss of 'A'ESW by ice blockage.4/20/96 4/20/96 0 days 15 hrs 57 min Manual shutdown for turbine Time 0538 Time 2135 balance shot.6/06/96 6/08/96 2 days 1 hr 1 min Tripped from 100% power due Time 1320 Time 1421 to Lo-Lo level in S/G 'C' when'C' main feed reg valve failed closed due to failure of roll pin connecting stem and plug.8/19/96 8/19/96 0 days 21 hrs 21 min Power reduction to 55% to Time 0137 Time 2258 repair crack in 'B' MFP seal water return line at the connection to the condenser 8/20/96 8/21/96 0 days 16 hrs 53 min Power reduction to 55% due to Time 0840 Time 0133 'A' MFP speed oscillations 10/25/96 10/26/96 1 day 0 hrs 27 min Power reduction to 55% to Time 1617 Time 1653 repair the 120 VAC power supply wire to 'A' MFP speed controller.

Further power reduction for QPTR > 1.02.1997 5/03/97 5/04/97 1 day 9 hrs 29 min Power reduction to 65% to find Time 0359 Time 1328 and plug a tube leak in Low Pressure Feedwater Heater 2C 5/20/97 5/25/97 4 days 8 hrs 4 min Manual reactor trip due to Time 1457 Time 0001 increasing body to bonnet steam leak from AFLV058C.1998 (None)1999 1 1/15/99 1/18/99 12 days 17 hrs 29 min I Power reduction to 70% to find 5 Time 2038 Time 1407 and plug leak in Low Pressure Feedwater Heater 2A 2/08/99 2/10/99 1 day 14 hrs 30 min Power reduction to 92% to find Time 1500 Time 0530 and plug leak in Low Pressure Feedwater Heater 1A.8/05/99 8/06/99 1 day 0 hrs 53 min Reactor trip due to lo lo level Time 1258 Time 1351 in S/G D caused by valve controller circuitry card failure allowing the MFRV to close.8/27/99 8/27/99 0 days 1 hrs 57 min Power reduction to 91% to Time 0305 Time 1502 replace section of line from 1st Stage Reheater Drain Tank D to HP Heater 6B due to minimum wall thickness concerns.

Work was delayed after power reduction and unit returned to 100% at System OPS request due to grid power needs.8/27/99 8/28/99 0 days 12 hrs 35 min Power reduction to 91% to Time 2100 Time 0935 replace section of line from 1st Stage Reheater Drain Tank D to HP Heater 6B due to minimum wall concerns.11/30/99 11/30/99 0 days 12 hrs 59 min Tech Spec shutdown due to Time 0459 Time 1758 failed power supply for SA036D. Power reduction was halted at approximately 30%when the power supply was declared operable after recalibration.

12/01/99 12/10/99 0 days 11 hrs 59 min Tech Spec shutdown due to Time 0219 Time 1318 failed power supply for SA036D. Power reduction was halted at 54% when the power supply was declared operable after being replaced.

Power increase was held at 65% for replacement of failed power supply for steam dump controller card AB PK-507 and then increased to 100%.6 12/31/99 Time 1213 01/01/00 Time 0824 0 days 20 hrs 11 min Precautionary power reduction to 52% for Y2K contingency.

I 4. I --2000 02/02/00 Time 2100 02/03/00 Time 0142 0 days 4 hrs 42 min Power reduction to 97% for repair to cooler on heater drain pump A 02/13/00 02/14/00 0 days 22 hrs 10 min Power reduction to 90% for Time 1230 Time 1040 low pressure heater lB tube repair 5/09/00 5/11/00 2 days 9 hrs 57 min Power reduction to 91% for Time 0903 Time 1900 pipe replacement due to wall thinning on AF32-GBD-6 7/29/00 7/30/00 18 hrs 25 min Rose Hill line off line Time 1235 Time 0700 9/04/00 Time 1123 9/07/00 Time 1305 3 days 1 hr 42 min Phase to phase ground on unit auxiliary transformer

4. 4. I 2001 03/17/01 Time 0430 03/18/01 Time 0849 1 day 4 hrs 19 min Unit auxiliary transformer installation 03/22/01 03/23/01 8 hrs Power reduction to 80% to Time 1742 Time 0142 repair leak on main generator hydrogen cooler 05/11/01 5/11/01 20 hrs Power reduction to 62% to Time 0300 Time 2300 replace speed probes on 'A'________MFWP 05/29/01 05/29/01 4 hrs 32 mins Power reduction to 88% due to Time 0303 Time 0735 failure of the NN14 inverter 10/19/01 10/19/01 7 hrs 30 mins Power reduction to 97% for Time 0830 Time 1600 furmanite of Heater Drain 1 Pump A stuffing box.11/09/01 Time 0805 11/09/01 Time 1230 4 hrs 25 mins Power reduction to 97% for furmanite of Heater Drain Pump A stuffing box.4. 1. I 2002 02/01/02 Time 1146 02/01/02 Time 2346 12 hrs Rose Hill line off line. Power reduction to 80%.05/08/02 05/10/02 40 hrs 52 mins Reactor trip due to S/G "D" Time 1707 Time 0959 Lo-Lo Level. Cause was a failed circuit card in the FRV controller 05/11/02 05/11/02 2 hrs PAFO1A failure of mechanical Time 2100 Time 2300 seal. Power reduction to 97%to secure pump. Return power to 100%.7 A 05/13/02 Time 1617 05/20/02 Time 1206 6 days 12 hrs 52 mins Forced outage to Mode 5 due to identification of loose parts in S/G "D" 4" 4. 4.2003 01/03/03 Time 1101 01/04/03 Time 1206 1 day 1 hr 5 mins Reactor trip caused by opening of the RDMG Set output breaker due to operator error 01/07/03 01/07/03 2 hrs 38 mins Power reduction to 97% to take Time 2000 Time 2238 PAF01A off-line to replace mechanical seal and repair AFLVO001 08/18/03 Time 1558 08/19/03 Time 1107 1 day 19 hrs 9 mins Reactor trip caused by closure of AEHVOO40 2004 02/13/04 02/16/04 2 day 19 hr 30 mins Reactor trip caused by failure Time 0810 Time 0340 of solid pin holding valve plug to stem on Feed Reg Valve AEFCV0540 07/30/04 08/01/04 2 days 6 hrs 52 mins Emergent work due to Time 0301 Time 0953 condenser tube leak. Power reduced to <30% due to Action Level 1 on all four SG'S.08/22/04 08/24/04 1 day 23 hrs 50 mins Reactor trip while improperly TimelOlO Time 1000 restoring from STS IC-21 1B.10/07/04 10/08/04 1 day 04 hrs 58 mins Reactor trip due to Lightning Time 1150 Time 1648 induced EMF causing false signal to Turbine HI-HI Vibration trip.10/11/04 10/12/04 1 day 06 hrs 44 mins Reduced Power to 950Mwe Time 1000 Time 1644 due to loss of switchyard west bus.01/22/2005 02/04/05 12 days 11 hrs 05 mins Reduced Power to take unit Time 1800 Time 0505 off-line to repair water leak in Main Generator.

8 Hooper Diane M From: Medenciy Charlie M Sent: Tuesday, March 20, 2007 9:23 AM To: Hooper Diane M

Subject:

FW: WCSTATS0107.XLS Attached is a spreadsheet of the information requested by the NRC for the Environmental Audit. The information is gathered and compiled by Mary Ballengee for submittal to INPO.What is the heat rate for Wolf Creek?Provide the annual average capacity factor for WCGS for the ten year period ending in 2006. Please indicate those years during which refueling outages occurred.Provide the gross and net electrical output of WCGS based on summer and winter conditions.

---

Original Message -----From: Ballengee Mary E Sent.: Monday, March 05, 2007 3:14 PM To: Medendy Charlie M

Subject:

WCSTATS0107.XLS Charlie -this should take care of your question.Mary WCSTATS0107.XL S 1

'I CAPA CITY FACTOR (DESIGN)NET GEN / (DESIGN ELECT RATING X PER HRS)MO/YR Jan-96 Feb-96 Mar-96 Apr-96 May-96 Jun-96* Jul-96 Aug-96 Sep-96 Oct-96 Nov-96 Dec-96 Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Jan-98 Feb-98 Mar-98 Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 Jan-99 Feb-99 Mar-99 Apr-99 May-99 Jun-99 Jul-99 Aug-99 Sep-99 Oct-99 Nov-99 Dec-99 Jan-00 Feb-00 Mar-00 MONTH 95.1%0.0%0.0%69.1%100.2%91.4%99.6%98.1%100.5%100.0%101.6%101.8%101.7%101.6%101.3%101.2%83.4%100.3%99.6%99.9%100.3%5.6%0.0%95.1%102.2%102.2%102.1%101.8%101.3%100.9%100.1%100.7%101.1%'101.6%101.9%101.9%100.7%100.9%101.90/0 2.5%64.9%101.2%100.4%94.7%101.0%101.6%100.8%100.8%101.7%101.5%101.4%.YTD 95.1%48.2%31.3%40.7%52.8%59.2%65.0%69.3%72.7%75.5%77.8%79.8%101.7%101.7%101.6%101.5%97.8%98.2%98.4%98.6%98.8%89.3%81.1%82.3%102.2%102.2%102.2%102.1%101.9%101.8%101.5%101.4%101.4%101.4%101.4%101.5%100.7%100.8%101.2%76.5%74.2%78.6%81.8%83.5%85.4%87.0%88.3%89.3%101.7%101.6%101.5%CUMULATIVE 77.0%.76.4%75.8%75.8%76.0%76.1%76.3%76.4%76.6%76.8%77.0%77.1%77.3%77.5%77.7%77.8%77.9%78.0%78.2%78.3%78.5%78.0%77.4%77.6%77.7%77.9%78.0%78.2%78.4%78.5%78.6%78.8%78.9%79.1%79.2%79.4%79.5%79.6%79.8%79.3%79.2%79.3%79.5%79.5%79.7%79.8%79.9%80.1%80.2%80.3%80.4%CONSTANT 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170.1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 CAPA CITY FACTOR (DESIGN)NET GEN / (DESIGN ELECT RATING X PER HRS)MO/YR Apr-00 May-00 Jun-00 Jul-00 Aug-00 Sep-00 Oct-00 Nov-00 Dec-00 Jan-01 Feb-01 Mar-01 Apr-01 May-01 Jun-01 Jul-01 Aug-01 Sep-01 Oct-01 Nov-01 Dec-01 Jan-02 Feb-02 Mar-02 Apr-02 May-02 Jun-02 Jul-02 Aug-02 Sep-02 Oct-02 Nov-02 Dec-02 Jan-03 Feb-03 Mar-03 Apr-03 May-03 Jun-03 Jul-03 Aug-03 Sep-03 Oct-03 Nov-03 Dec-03 Jan-04 Feb-04 Mar-04 Apr-04 May-04 Jun-04 MONTH 101.2%100.5%100.5%99.4%99.8%78.4%0.0%73.9%101.9%102.0%102.1%95.8%101.7%100.9%101.4%100.4%100.5%101.3%101.8%101.8%102.0%102.1%101.7%70.0%4.9%71.6%100.9%100.3%100.4%101.0%101.8%101.9%102.0%95.5%101.9%101.7%101.6%101.4%100.9%100.3%92.5%100.7%53.1%0.0%92.8%101.5%88.6%101.3%101.5%101.1%100.5%YTD 101.4%101.3%101.1%100.9%100.7%98.3%88.2%86.9%88.2%102.0%102.1%99.9%100.4%100.5%100.6%100.6%100.6%100.6%100.8%100.9%101.0%102.1%.101.9%90.9%69.4%69.9%75.0%78.7%81.5%83.6%85.5%86.9%88.2%95.5%98.5%99.6%100.1%100.4%100.5%100.4%99.4%99.6%94.8%86.2%86.7%101.5%95.3%97.3%98.4%98.9%99.2%CUMULATIVE 80.5%80.6%80.8%80.9%81.0%81.0%80.5%80.5%80.6%80.7%80.8%80.9%81.0%81.1%81.2%81.3%81.4%81.5%81.6%81.7%81.8%81.9%82.0%82.0%81.6%81.5%81.6%81.7%81.8%81.9%82.0%82.1%82.2%82.3%82.3%82.4%82.5%82.6%82.7%82.8%82.8%82.9%82.8%82.4%82.4%82.5%82.6%82.6%82.7%82.8%82.9%CONSTANT 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 CAPACITY FACTOR (DESIGN)NET GEN / (DESIGN ELECT RATING X PER HRS)MO/YR Jul-04 Aug-04 Sep-04 Oct-04 Nov-04 Dec-04 Jan-05 Feb-05 Mar-05 Apr-05 May-05 Jun-05 Jul-05 Aug-05 Sep-05 Oct-05 Nov-05 Dec-05 Jan-06 Feb-06 Mar-06 Apr-06 May-06 Jun-06 Jul-06 Aug-06 Sep-06 Oct-06 Nov-06 Dec-06 MONTH 96.2%93.1%100.0%95.6%101.7%101.7%71.1%91.1%101.6%24.9%37.8%100.5%99.9%100.1%100.6%101.5%101.8%101.8%101.8%101.8%101.9%101.7%101.5%100.5%.99.9%99.9%100.6%17.8%66.5%101.9%YTD 98.7%98.0%98.2%98.0%98.3%98.6%71.1%80.6%87.8%72.1%65.1%70.9%75.2%78.3%80.8%82.9%84.6%86.1%101.8%101.8%101.9%101.8%101.8%101.5%101.3%101.1%101.1%92.6%90.2%91.2%CUMULATIVE 82.9%83.0%83.1%83.1%83.2%83.3%83.2%83.3%83.3%83.1%82.9%83.0%83.0%83.1%83.2%83.3%83.3%83.4%83.5%83.6%83.6%83.7%83.8%83.8%83.9%84.0%84.0%83.8%83.7%83.8%CONSTANT 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170 1,170.1,170 1,170 GROSS GENERA TION MWH MO/YR Jan-96 Feb-96 Mar-96 Apr-96 May-96 Jun-96 Jul-96 Aug-96 Sep-96 Oct-96 Nov-96 Dec-96 Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Jan-98 Feb-98 Mar-98 Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 Jan-99 Feb-99 Mar-99 Apr-99 May-99 Jun-99 Jul-99 Aug-99 Sep-99 Oct-99 Nov-99 Dec-99 Jan-00 Feb-00 Mar-00 (SYSTEM OPS-WICHITA)

YTD CUMULATIVE 863,196 86,122,116 863,196 86,122,116 863,196 86,122,116 1,478,444 86,737,364 2,386,806 87,645,726 3,191,319 88,450,239 4,094,911 89,353,831 4,985,749 90,244,669 5,868,824 91,127,744 6,777,782 92,036,702 7,668,705 92,927,625 8,590,065 93,848,985 922,233 94,771,218 1,753,796 95,602,781 2,671,535 96,520,520 3,558,093 97,407,078 4,320,480 98,169,465 5,199,510 99,048,495 6,103,530 99,952,515 7,009,310 100,858,295 7,889,578 101,738,563 7,952,799 101,801,784 7,952,799 101,801,784 8,812,529 102,661,514 920,900 103,582,414 1,751,504 104,413,018 2,671,789 105,333,303 3,559,462 106,220,976 4,474,779 107,136,293 5,357,549 108,019,063 6,262,761 108,924,275 7,172,969 109,834,483 8,056,865 110,718,379 8,975,756 111,637,270 9,865,266 112,526,780 10,782,935 113,444,449 908,693 114,353,142 1,730,132 115,174,581 2,647,472 116,091,921 2,680,609 116,125,058 3,277,851 116,722,300 4,163,236 117,607,685 5,072,380 118,516,829 5,932,287 119,376,736 6,817,678 120,262,127 7,739,027 121,183,476.

8,622,309 122,066,758 9,533,108 122,977,557 917,906 123,895,463 1,774,714 124,752,271 2,690,374 125,667,931 MONTHLY AVE. MW 1,160.2 0.0 0.0 855.7 1,220.9 1,117.4 1,214.5 1,197.4 1,226.5 1,220.1 1,237.4 1,238.4 1,239.6 1,237.4 1,233.5 1,233.0 1,024.7 1,220.9 1,215.1 1,217.4 1,222.6 84.9 0.0 1,155.6 1,237.8 1,236.0 1,236.9 1,234.6 1,230.3 1,226.1 1,216.7 1,223.4 1,227.6 1,233.4 1,235.4 1,233.4 1,221.4 1,222.4 1,233.0 46.1 802.7 1,229.7 1,222.0 1,155.8 1,229.7 1,236.7 1,226.8 1,224.2 1,233.7 1,231.0 1,230.7 GROSS GENERA TION MWH MO/YR Apr-00 May-00 Jun-00 Jul-00 Aug-00 Sep-00 Oct-00 Nov-00 Dec-00 Jan-01 Feb-01 Mar-01 Apr-01 May-01 Jun-01 Jul-01 Aug-01 Sep-01 Oct-01 Nov-01 Dec-01 Jan-02 Feb-02 Mar-02 Apr-02 May-02 Jun-02 Jul-02 Aug-02 Sep-02 Oct-02 Nov-02 Dec-02 Jan-03 Feb-03 Mar-03 Apr-03 May-03 Jun-03 Jul-03 Aug-03 Sep-03 Oct-03 Nov-03 Dec-03 Jan-04 Feb-04 Mar-04 Apr-04 May-04 Jun-04 MONTH (SYSTEM OPS-WICHITA)

YTD CUMULATIVE 3,573,517 126,551,074 4,482,658 127,460,215 5,362,383 128,339,940 6,263,001 129,240,558 7,167,928 130,145,485

.7,860,946 130,838,503 7,860,946 130,838,503 8,512,846 131,490,403 9,430,537 132,408,094 919,040 133,327,134 1,750,542 134,158,636 2,615,907 135,024,001 3,502,883 135,910,977 4,413,433 136,821,527 5,298,783 137,706,877 6,206,012 138,614,106 7,113,827 139,521,921 7,998,645 140,406,739 8,917,999 141,326,093 9,807,073 142,215,167 10,725,923 143,134,017

.919,971 144,053,988 1,747,916 144,881,933 2,383,367 145,517,384 2,438,947 145,572,964 3,094,272 146,228,289 3,976,489 147,110,506 4,883,114 148,017,131 5,790,730 148,924,747 6,673,175 149,807,192 7,591,988 150,726,005 8,481,973 151,615,990 9,401,916 152,535,933

%863,453 153,399,386 1,693,905 154,229,838 2,611,955 155,147,888 3,498,875 156,034,808 4,415,226 156,951,159 5,297,326 157,833,259 6,202,882 158,738,815 7,041,717 159,577,650 7,921,816 160,457,749 8,407,466 160,943,399 8,407,466 160,943,399 9,248,002 161,783,935 917,440 162,701,375 1,668,856 163,452,791 2,583,139 164,367,074 3,469,301 165,253,236 4,382,865 166,166,800 5,262,705 167,046,640 MONTHLY AVE. MW 1,228.3 1,222.0 1,221.8 1,210.5 1,216.3 962.5 0.0 905.4 1,233.5 1,235.3 1,237.4 1,163.1 1,233.6 1,223.9 1,229.7 1,219.4 1,220.2 1,228.9 1,234.0 1,234.8 1,235.0 1,236.5 1,232.1 854.1 77.3 880.8 1,225.3 1,218.6 1,219.9 1,225.6 1,233.3 1,236.1 1,236.5 1,160.6 1,235.8 1,233.9 1,233.5 1,231.7 1,225.1 1,217.1 1,127.5 1,222.4 651.9 0.0 1,129.8* 1,233.1 1,079.6 1,228.9 1,232.5 1,227.9 1,222.0 GROSS GENERA TION MWH (SYSTEM OPS-WICHITA)

MONTHLY MO/YR MONTH YTD CUMULATIVE AVE. MW Jul-04 6,133,942 167,917,877 1,171.0 Aug-04 6,978,743 1.68,762,678 1,135.5 Sep-04 7,854,274 169,638,209 1,216.0 Oct-04 662.2 8,720,498 170,504,433 1,162.7 Nov-04 9,609,353 171,393,288 1,234.5 Dec-04 9 10,526,533 172,310,468 1,232.8 Jan-05 650485 650,885 172,961,353 874.8 Feb-05 1,396,020 173,706,488 1,108.8 Mar-05 2,312,338 174,622,806 1,231.6 Apr-05 2,536,058 174,846,526 311.2 May-05 35 2,890,342 175,200,810 476.2 Jun-05 3,769,735 176,080,203 1,221.4 Jul-05 4,673,110 176,983,578 1,214.2 Aug-05 90 5,578,200 177,888,668 1,216.5 Sep-05 6,457,948 178,768,416 1,221.9 Oct-05 7,375,317 179,685,785 1,231.4 Nov-05 8,264,447 180,574,915 1,234.9 Dec-05 f8 9,182,741 181,493,209 1,234.3 Jan-06 917,918 182,411,127 1,233.8 Feb-06 1,746,823 183,240,032 1,233.5 Mar-06 2,666,061 184,159,270 1,235.5 Apr-06 3,552,784 185,045,993 1,233.3 May-06 9. 4,468,022 185,961,231 1,230.2 Jun-06 ..8779 5,345,950 186,839,159 1,219.3 Jul-06 6,249,288 187,742,497 1,214.2 Aug-06 9 7,152,736 188,645,945 1,214.3 Sep-06 8,031,463 189,524,672 1,220.5 Oct-06 8,201,789 189,694,998 228.6 Nov-06 8,791,281 190,284,490 818.7 Dec-06 71 9,708,944 191,202,153 1,233.4 NET GENERA TIONMWH (SYSTEM OPS-WICHITA)

MO/YR Jan-96 Feb-96 Mar-96 Apr-96 May-96 Jun-96 Jul-96 Aug-96 Sep-96 Oct-96 Nov-96 Dec-96 Jan-97 Feb-97 Mar-97 Apr-97 May-97 Jun-97 Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Jan-98 Feb-98 Mar-98 Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-9 8 Nov-98 Dec-98 Jan-99 Feb-99 Mar-99 Apr-99 May-99 Jun-99* Jul-99 Aug-99 Sep-99 Oct-99 Nov-99 Dec-99 Jan-00 Feb-00 Mar-00 Apr-00 MONTH YTD 828,168 811,931 799,354 1,380,875 2,253,066 3,022,669 3,889,806 4,743,969 5,591,000 6,462,848 7,319,018 8,204,868 885,674 1,684,522 2,566,518 3,417,679 4,144,036 4,988,597 5,855,841 6,725,492 7,570,772 7,619,582 7,602,565 8,430,455 889,605 1,692,983 2,581,930 3,438,247 4,320,156 5,170,290 6,041,976 6,918,479 7,769,921 8,655,843 9,514,057 10,400,718 876,962 1,670,034 2,556,762 2,578,114 3,143,342 3,995,436 4,869,113 5,693,186 6,544,179 7,430,124 8,279,306 9,156,619 884,897 1,711,078 2,594,127 3,445,252 CUMULATIVE 82,265,019 82,248,782 82,236,205 82,817,726 83,689,917 84,459,520 85,326,657 86,180,820 87,027,851 87,899,699 88,755,869 89,641,719 90,527,393 91,326,241 92,208,237 93,059,398 93,785,755 94,630,316 95,497,560 96,367,211 97,212,491 97,261,301 97,244,284 98,072,174 98,961,779 99,765,157 100,654,104 101,510,421 102,392,330 103,242,464 104,114,150 104,990,653 105,842,095 106,728,017 107,586,231 108,472,892 109,349,854 110,142,926 111,029,654 111,051,006 111,616,234 112,468,328 113,342,005 114,166,078 115,017,071 115,903,016 116,752,198 117,629,511 118,514,408 119,340,589 120,223,638 121,074,763 MONTHLY AVE. MW 1,113.1-23.3-16.9 808.8 1,172.3 1,068.9 1,165.5 1,148.1 1,176.4 1,170.3 1,189.1 1,190.7 1,190.4 1,188.8 1,185.5 1,183.8 976.3 1,173.0 1,165.7 1,168.9 1,174.0 65.5-23.6 1,112.8 1,195.7 1,195.5 1,194.8 1,191.0 1,185.4 1,180.7 1,171.6 1,178.1 1,182.6 1,189.2 1,192.0 1,191.7 1,178.7 1,180.2 1,191.8 29.7 759.7 1,183.5 1,174.3 1,107.6 1,181.9 1,189.2 1,179.4 1,179.2 1,189.4 1,187.0 1,186.9 1,183.8 NET GENERA TIONMWH (SYSTEM OPS-WICHITA)

MO/YR May-00 Jun-00 Jul-00 Aug-00 Sep-00 Oct-00 Nov-00 Dec-00 Jan-01 Feb-01 Mar-01 Apr-01 May-01 Jun-01 Jul-01 Aug-01 Sep-01 Oct-01 Nov-01 Dec-01 Jan-02 Feb-02 Mar-02 Apr-02 May-02 Jun-02 Jul-02 Aug-02 Sep-02 Oct-02 Nov-02 Dec-02 Jan-03 Feb-03 Mar-03 Apr-03 May-03 Jun-03 Jul-03 Aug-03 Sep-03 Oct-03 Nov-03 Dec-03 Jan-04 Feb-04 Mar-04 Apr-04 May-04 Jun-04 Jul-04 Aug-04 MnNTI4 YTD 4,320,346 5,166,828 6,032,282 6,901,445 7,561,585 7,551,014 8,173,445 9,060,834 888,118 1,691,204 2,525,077 3,380,425 4,258,494 5,112,460 5,986,432 6,860,974 7,714,309 8,601,602 9,459,064 10,346,657 888,357 1,687,623 2,296,568 2,338,087 2,961,705 3,811,498 4,684,325 5,558,222 6,408,689 7,295,664 8,154,031 9,041,702 831,072 1,632,282.

2,517,837 3,372,551 4,254,850 5,105,124 5,977,904 6,783,346 7,631,886 8,094,506 8,081,716 8,889,667 883,896 1,605,194 2,487,171 3,341,088 4,221,051 5,067,961 5,904,966 6,715,060 CUMULATIVE 121,949,857 122,796,339 123,661,793 124,530,956 125,191,096 125,180,525 125,802,956 126,690,345 127,578,463 128,381,549 129,215,422 130,070,770 130,948,839 131,802,805 132,676,777 133,551,319 134,404,654 135,291,947 136,149,409 137,037,002 137,925,359 138,724,625 139,333,570 139,375,089 139,998,707 140,848,500 141,721,327 142,595,224 143,445,691 144,332,666 145,191,033 146,078,704 146,909,776 147,710,986 148,596,541 149,451,255 150,333,554 151,183,828 152,056,608 152,862,050 153,710,590 154,173,210 154,160,420 154,968,371 155,852,267 156,573,565 157,455,542 158,309,459 159,189,422 160,036,332 160,873,337 161,683,431 MONTHLY AVE. MW 1,176.2 1,175.7 1,163.2 1,168.2 916.9-14.2 864.5 1,192.7 1,193.7 1,195.1 1,120.8 1,189.6 1,180.2 1,186.1 1,174.7 1,175.5.1,185;2 1,191.0 1,190.9 1,193.0 1,194.0 1,189.4 818.5 57.7 838.2 1,180.3 1,173.2 1,174.6 1,181.2 1,190.6 1,192.2 1,193.1 1,117.0 1,192.3 1,190.3 1,188.8 1,185.9 1,180.9 1,173.1 1,082.6 1,178.5 621.0-17.8 1,086.0 1,188.0 1,036.3 1,185.5 1,187.6 1,182.7 1,176.3 1,125.0 1,088.8 NET GENERA TION MWH (SYSTEM OPS-WICHITA)

MO/YR Sep-04 Oct-04 Nov-04 Dec-04 Jan-05 Feb-05 Mar-05 Apr-05 May-05 Jun-05 Jul-05 Aug-05 Sep-05 Oct-05 Nov-05 Dec-05 Jan-06 Feb-06 Mar-06 Apr-06 May-06 Jun-06 Jul-06 Aug-06 Sep-06 Oct-06 Nov-06 Dec-06 MONTH YTD 7,557,727 8,390,781 9,247,445 10,132,736 618,685 1,334,766 2,219,478 2,428,713 2,758,070 3,604,557 4,473,932 5,345,221 6,192,562 7,077,126 7,934,773 8,820,945 886,275 1,686,876 2,574,246 3,430,074 4,313,403 5,160,005 6,029,979 6,899,821 7,747,243 7,902,379 8,462,822 9,350,269 CUMULATIVE 162,526,098 163,359,152 164,215,816 165,101,107 165,719,792 166,435,873 167,320,585 167,529,820 167,859,177 168,705,664 169,575,039 170,446,328 171,293,669 172,178,233 173,035,880 173,922,052 174,808,327 175,608,928 176,496,298 177,352,126 178,235,455 179,082,057 179,952,031 180,821,873 181,669,295 181,824,431 182,384,874 183,272,321 MONTHLY AVE. MW 1,170.4 1,118.2 1,189.8 1,189.9 831.6 1,065.6 1,189.1 291.0 442.7 1,175.7 1,168.5 1,171.1 1,176.9 1,187.3 1,191.2 1,191.1 1,191.2 1,191.4 1,192.7 1,190.3 1,187.3 1,175.8 1,169.3 1,169.1 1,177.0 208.2 778.4 1,192.8