ML100970076

Response to Request for Additional Information for Review of License Renewal Application - Environmental Review

ML100970076
Person / Time
Site:	Crystal River
Issue date:	04/01/2010
From:	Franke J Florida Power Corp, Progress Energy Co, Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0410-03, TAC ME0278
Download: ML100970076 (18)

Text

Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10CFR54 April 1, 2010 3F0410-03 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Response to Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0278) - Environmental Review

References:

(1) CR-3 to NRC letter, dated December 16, 2008, "Crystal River Unit 3 -

Application for Renewal of Operating License" (2) NRC to CR-3 letter, dated March 5, 2010, "Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0278)"

Dear Sir:

On December 16, 2008, Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc. (PEF), requested renewal of the operating license for Crystal River Unit 3 (CR-3) to extend the term of its operating license an additional 20 years beyond the current expiration date (Reference 1). Subsequently, the Nuclear Regulatory Commission (NRC), by letter dated March 5, 2010, provided a request for additional information (RAI) concerning the CR-3 License Renewal Application and a request for documents (Reference 2). The Enclosure to this letter provides the response to the RAI. A response to the request for documents is being provided in a separate letter (CR-3 letter 3F0410-04 dated April 1, 2010).

No new regulatory commitments are contained in this submittal.

If you have any questions regarding this submittal, please contact Mr. Mike Heath, Supervisor, License Renewal, at (910) 457-3487, e-mail at mike.heath@pgnmail.com.

Jo A. Franke" ice President Crystal River Unit 3 JAF/dwh

Enclosure:

Response to Request for Additional Information xc: NRC CR-3 Project Manager NRC License Renewal Project Manager NRC Regional Administrator, Region II Senior Resident Inspector Progress Energy Florida, Inc.

Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428

U. S. Nuclear Regulatory Commission Page 2 of 2 3F0410-03 STATE OF FLORIDA COUNTY OF CITRUS Jon A. Franke states that he is the Vice President, Crystal River Nuclear Plant for Florida Power Corporation, doing business as Progress Energy Florida, Inc.; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.

C AAl Franke SVice President

'* Crystal River Nuclear Plant The foregoing document was acknowledged before me this day of

-- "entI , 2010, by Jon A. Franke.

Signature of Notary Public State of Florida (Print, type, or stamp Commissioned Name of Notary Public)

Personally Known Produced

-OR- Identification

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ENCLOSURE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

U. S. Nuclear Regulatory Commission Enclosure 3F0410-03 Page 1 of 15 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION The following requests for additional information are needed by the U.S. Nuclear Regulatory Commission (NRC) staff to complete its review of the Crystal River Nuclear Generating Plant, Unit 3 (CR-3) application for license renewal and prepare the draft supplemental environmental impact statement. To support the staff's continued review of the CR-3 environmental report (ER), please provide the information and documents described below. Those items marked with letter and number (i.e., AQ-1, H-2, etc.) refer to corresponding items in the Revised Environmental Site Audit Needs List dated October 6, 2009.

RAI I - Cumulative Impacts NRC staff must evaluate the cumulative impacts of extended operation of all reasonably foreseeable activities. The following information is needed to complete the cumulative impact evaluation.

1. Provide information on the status of the refurbishment activities discussed in Section 3.2 of the ER. Also, provide information on when the power uprate amendment is expected to be submitted.

Response

The Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GELS) describes true refurbishment activities as those "...undertaken to prepare a nuclearpower plant for operation following license renewal." The License Renewal Environmental Report listed the following refurbishment activities in Section 3.2:

• Transport of the new steam generatorsfrom Babcock & Wilcox to the CR-3 site for temporary storage;

• Removal of old steam generators through the new construction opening in the Reactor Building (RB), and transport to mausoleum (Once-through Steam Generator building) using a multi-axle crawler;

• Transport of the new steam generatorsfrom the terminus of the on-site railroadspur to the containment building using a crawler;

" Passing the steam generators into containment through the new construction opening in the RB; and,

• Installation of the new steam generators.

These activities were completed during the fall 2009 Refueling Outage, according to schedule.

Activities associated with the proposed Extended Power Uprate (EPU), such as upgrades of high- and low-pressure turbines, are not refurbishment per se, as they would be intended to increase the plant's generatingcapacity ratherthan allow the unit to operate for an additional20 years beyond the originallicense term.

U. S. Nuclear Regulatory Commission Enclosure 3F0410-03 Page 2 of 15 Progress Energy Florida, Inc. (PEF) will submit the Extended Power Uprate License Amendment Request priorto June 1, 2010.

2. Provide information on the resources that would be affected by the construction of the proposed Levy County nuclear plants' cooling tower discharge line to the CR-3 discharge canal. Also provide a summary of impacts the potentially chemically-treated cooling water from the Levy County plants may have on the CR-3 discharge canal.

Response Part I - Affected Resources:

The Levy Nuclear Plant Units 1 and 2 (LNP) Combined OperatingLicense (COL) Environmental Report (ER) considers impacts of construction of the proposed cooling tower blowdown line on a range of resources including Land Use, Cultural Resources, Water Resources, Ecological Resources, and Socioeconomic Resources. In every case but one (Traffic and Transportation),

the LNP COL ER concludes that impacts from construction of the blowdown line would be temporary and mitigable, therefore SMALL.

Background

The proposed LNP blowdown line(s) would extend south approximately four miles from the LNP site to the Cross Florida Barge Canal (CFBC), then move in a southwesterly direction for approximately 5.5 miles, parallelingthe north bank of the CFBC, then veer south three miles to the Crystal River discharge canal (PEF 2010, Figure 2.3-13. See references below). The total length of the blowdown pipeline(s) would be approximately 12.5 miles (Sargent & Lundy 2009,

p. 10). Based on the conceptual design study (Sargent & Lundy 2009), there would be a dedicated blowdown line for each set of mechanical-draftcooling towers. Each blowdown line would be constructed of 54-inch diameter high-density polyethylene (HDPE)pipe and installed in an approximately 4-to-6-foot-deep backfilled trench.

Schedule/Workforce A firm schedule for construction of the blowdown line(s) has not been established. However, based on the over-archingproject schedule, as presented in Section 4.2 of the LNP COL ER, it appears that construction of the blowdown line(s) could begin as early as 2012 or as late as 2016. For this response, 2012 was assumed which is extremely conservative. Based on large natural gas pipeline construction projects, a reasonable analogue, the blowdown pipeline is likely to be built in phases, with separate crews engaged in (1) land clearing for the pipeline corridor, (2) grading the pipeline corridor, (3) trenching, (4) installing pipe, and (5) cleanup and restoration.

The total number of pipeline workers in the field at any given time could range from 50 to 200, depending on the stage of the project. The size of the construction workforce would be determined by the firm that ultimately wins the contract to build the blowdown line(s), as would the number of crews working simultaneously and the heavy equipment used. The size of the workforce and number of crews would also determine how quickly the project is completed.

Typically, land (tree) clearing is carried out by crews using feller-bunchers ("timberjacks') and skidders, grading is handled with bulldozers and motor-graders, trenches are excavated using tracked excavators ("trackhoes') and pipe is installed using a side boom or similar equipment.

U. S. Nuclear Regulatory Commission Enclosure 3F0410-03 Page 3 of 15 Land Use The LNP COL ER estimated that 34 hectares (84 acres) of natural habitat/undeveloped land (including forest land, wetland, shrub/brush rangeland,ponds, streams and canals) would be converted to the blowdown pipeline corridor consisting of open land with low-growing grasses and forbs (PEF 2010, Table 4.1-5). However, much of the land in the region was converted from native upland forest and prairie to pine plantation and pastureland in the 1 9 th and 2 0th centuries. Silviculture, agriculture,residentialdevelopment, and mining now predominate where forest and prairieonce existed (PEF2010, pp. 4-14 and p. 4-44; PEF 2010, Table 4.1-5).

CulturalResources With regard to culturally significant properties, PEF conducted cultural resources surveys in 2007-2008 of the LNP site and support facilities, including the (preliminary)blowdown pipeline route, and determined that the project's Areas of Potential Effect (APEs) "did not include any resources that were listed in or eligible to be listed in the National Register of Historic Places" (PEF 2010, p. 4-15). Moreover, PEF concluded that "the LNP site lies within an area of low probabilityfor containing significant archaeologicalresources"(PEF2010, p. 4-17).

Water Resources The LNP COL ER evaluated potential impacts of building LNP and support facilities, including the blowdown line(s), on water quality of the Withlacoochee River and CFBC. The ER acknowledged that construction would be associated with a temporary increase in stormwater runoff, erosion, and sedimentation, but asserted that any changes in water quality would be temporary, lasting only as long as it took to establish/re-establish vegetative cover in the disturbed areas. Impacts to down-gradient water quality would also be mitigated by proper erosion control measures and stormwater best managementpractices.

Ecological Resources The LNP COL ER noted that construction of support facilities (including the blowdown pipeline corridor)would result in the loss or alteration of less than a hundred acres of wildlife habitat,but placed these losses in a regionaland historicalcontext, noting that areasthat would be affected by construction had already been disturbed "through silviculture and other anthropogenic activities" (PEF2010, p. 4-44). The LNP COL ER noted also that impacts to aquatic organisms from pipeline construction (canal/stream crossings) would be "localized and temporary" and mitigated by best management practices (PEF2010, pp. 4-50 and 4-5 1).

Socioeconomic Resources Social and economic impacts from the blowdown line construction would be mostly positive.

The current economic slowdown has idled large numbers of construction workers in the Crystal River region, and the LNP project is expected to improve this situation. Construction workers will in turn purchase goods and services in the region, further benefitting the regional economy.

Impacts on water and wastewater services/availabilityare expected to be small. No decline in the quality of public facilities and services is anticipated. Construction impacts on traffic as a result of increased volume from construction activities are expected to be SMALL to MODERATE, however.

U. S. Nuclear Regulatory Commission Enclosure 3F0410-03 Page 4 of 15 Virtually all of the activities associatedwith CR-3 Steam GeneratorReplacement (completed in December 2009), CR-3 EPU (scheduled to be completed in 2012), and development of the CR-3 Independent Spent Fuel Storage Installation (scheduled for completion in 2012) will have been completed by the time construction begins in earnest on Levy Nuclear Plant Units I and 2.

Thus there would be few, if any, cumulative construction impacts. There would, however, be several short periods (2013, 2015, and 2017) when refueling outages at CR-3 coincide with construction of the LNP. During these brief periods (-40 days), there would be additionaltraffic congestion in the Crystal River area, and particularly along US Highway 19/98. The primary impact would be to prolong the daily commute of CR-3 permanent employees and outage workers.

Response Part2 - Impact of Water Discharge The combined discharge from the LNP would consist of cooling tower blowdown (28,260 gallons per minute (gpm)), Sanitary Waste Treatment Plant effluent (62.5 gpm), effluent from the Wastewater Retention Basin (850 gpm), and liquid radwaste (75 gpm) (Sargent & Lundy 2009).

The total discharge flow would therefore be 29,248 gpm per unit or 58,496 gpm (i.e.,

approximately 84 million gallons per day (MGD) for both units. The LNP discharge flow would equal 4.4 percent of the Crystal River Energy Complex (CREC) permitted flow of 1,898 MGD in summer and 5.2 percent of the CREC permitted flow of 1,613 MGD in winter. Any chemicals/

constituents in the LNP discharge would therefore be diluted 19 to 23 times upon merging with the CREC discharge flow, which consists of once-through cooling water from CR-1, -2, and -3 and cooling tower blowdown from CR-4 and -5.

As discussed in considerable detail in the ProgressEnergy RAI Revised Response No. L-0521 (July 29, 2009) to NRC RAl 9.4.2-1 for the LNP, regulatory requirements and the Florida Department of Environmental Protection (FDEP)-issued National Pollution Discharge Elimination System (NPDES) criteria were addressed as follows:

The addition of LNP wastewater to the CREC discharge canal is projected to result in compliance with all regulatory requirements prior to release into the Gulf of Mexico via the final outfall... There are no outstanding water quality issues with the current CREC, other than the need to maintain the thermal limit at the point of discharge {point of compliance], which requires constant monitoring and operatorattention.

For wastes discharged to surface waters, PEF must comply with an NPDES permit issued by FDEP. The chemicals that will be used {and discharged] will be subject to review and approval for use by the FDEP.

Another Progress Energy RAI Revised Response (No. L-0399, dated June 12, 2009) to NRC RAl 2.3.1-3 addresses more specifically the applicableFloridaAdministrative Code (F.A. C.) and federal regulatoryrequirements:

The dischargerequirements of the LNP blowdown are still under considerationby FDEP as part of the state-administeredNPDES permitting process. It is anticipatedthat the combined LNP discharge will be required to meet the federal 40 CFR 423 effluent criteria requirements for new steam electric power generating plants, which are incorporatedby reference in Florida Rule 62-660.400 F.A. C. Typically, compliance with 40 CFR 423 requirements is required based on monitoring at an internal outfall prior to commingling with another waste stream. The combined LNP-CREC discharge will also

U. S. Nuclear Regulatory Commission Enclosure 3F0410-03 Page 5 of 15 be required to be compliant with water quality-based effluent limitations prior to its release into the Gulf of Mexico in accordancewith Rule 62-650, F.A.C.

References PEF, 2010. Levy Nuclear Plant Units I and 2 COL Application. Part 3, Applicant's Environmental Report - Combined License Stage. Revision 1. October Sargent & Lundy, 2009. Conceptual Design of the Circulating Water Blowdown Being Discharged at the Crystal River Plant Site. Report No. LNG-CWS-GER-005 Rev 2.

November 23.

RAI 2 - Air Quality and Meteorology

1. Provide documentation demonstrating that Progress Energy submitted an application to renew its Title V permit to the Florida Department of Environmental Protection (FL DEP) on or before the renewal application due date of July 5, 2009, specified in the permit and that the renewal application was accepted by FL DEP, allowing the Title V Permit to remain in effect past its expiration date during FL DEP's processing of the renewal application.

Response

This request pertains to existing or public documentation, and the requested documentation is provided in a separate letter.

RAI 3- Aquatic Ecology

1. Provide a summary of releases from the Progress Energy Mariculture Center 1992-2008.

Response

This request pertains to existing or public documentation, and the requested documentation is provided in a separate letter.

2. Progress Energy 2009 - Environmental Support Document Crystal River Unit 3 South Cooling Tower Laydown Area, Citrus County, Florida;

Response

This request pertains to existing or public documentation, and the requested documentation is provided in a separate letter.

3. Ager et al. 2008 - Crystal River Power Plant Fish Impingement Study Report. Please provide the entire report, ifpossible. Otherwise provide the following:

• Executive Summary

• Chapter 2 (including the figures and tables)

• Tables 4 through 11, 13 through 20, and 34 through 40

U. S. Nuclear Regulatory Commission Enclosure 3F0410-03 Page 6 of 15

• Figures 3 through 4, 6 through 19

• Appendices 1 through 32

Response

This request pertains to existing or public documentation, and the requested documentation is provided in a separate letter.

4. Copies of the 1993-1995 Seagrass Monitoring Reports, November 2001 Seagrass Recovery Report, the 2008 Seagrass Quantification Report, and the final report of the Seagrass Technical Advisory Committee.

Response

This request pertains to existing or public documentation, and the requested documentation is provided in a separate letter.

5. TP-042 Marine Turtle Permit (the current annual permit).

Response

This request pertains to existing or public documentation, and the requested documentation is provided in a separate letter.

6. AQ-1 (Also T-20) - The response letters from National Marine Fisheries Service (NMFS) and Florida Wildlife Commission regarding listed species and sensitive habitats were not provided (only the Fish and Wildlife Service (FWS) response letter was provided).

Correspondence from NMFS and Florida or a statement that none exists should be provided.

Response

The letter from the NMFS has been included in a separately-filed letter transmitting the response to the request for documents. No response to the correspondencesent to the State of Florida could be found.

7. Provide copies of the reports prepared by Applied Biology, Inc (1983), Florida Power Corporation (FPC) (1978b), FPC (1 982b). Complete citations for these reports are listed on page 4-2 of the 316 Study.

Response

The requested report "Florida Power Corporation (FPC) (1978b)" has been included in a separately-filed letter transmitting the response to the request for documents. The other two requested documents could not be located.

U. S. Nuclear Regulatory Commission Enclosure 3F0410-03 Page 7 of 15 RAI 4- Hydrology

1. H-9 (also H-5) - Quarterly National Pollutant Discharge Elimination System, Industrial Waste Water, Domestic Waste Water monitoring reports (for past 5 years) with cover letters to the FL DEP. Provide the full reports and cover letters. Spreadsheets of sampling data were previously submitted, however the reports provide more comprehensive information on what was sampled, standards measured against, exceedances, explanations for exceedances, and corrective actions as well as maps and other useful information.

If the quarterly data is summarized in annual reports, then the annual reports may be submitted instead of the quarterly reports. Because these documents can be large, electronic files can. be submitted in lieu of hardcopies.

Response

This request pertains to existing or public documentation, and the requested documentation is provided in a separate letter.

RAI 5- Terrestrial Ecology

1. T Provide the tables, figures, and appendices from the report "Environmental Support Document, Crystal River Unit 3, South Cooling Tower Laydown Area, Citrus County Florida."

Response

This request pertains to existing or public documentation, and the requested documentation is provided in a separate letter.

2. T The November 5, 2009, request for additional information response provided a map of the percolation ponds and an FWS wood stork colonies core foraging areas map, but there is no explanatory text provided.

Provide a brief description of wood stork use of the site along with an explanation of how the two figures relate to that use.

Provide the source for the FWS wood stock map so it can be properly cited.

Response

The wood stork is a gregariousspecies that nests in colonies and roosts and feeds in flocks, often in associationwith other species of water birds. Wood storks nesting in central Floridaare known to disperse during non-breedingseasons as far north as southern Georgia.

Wood storks use freshwater and estuarine wetlands as feeding, nesting, and roosting sites.

Storks are especially sensitive to environmental conditions at feeding sites, and thus birds may fly relatively long distances either daily or between regions annually, seeking adequate food resources.

U. S. Nuclear Regulatory Commission Enclosure 3F0410-03 Page 8 of 15 Storks are especially sensitive to any manipulation of a wetland feeding site that results in either reduced amounts, or changes in the timing, of food availability. Storks feed primarily on small fish between one and eight inches in length and successful foraging sites are those areas where the water is shallow, between two and 15 inches deep. Topminnows and sunfish are the most common prey items of wood storks.

Nesting wood storks do most of their feeding in wetlands between five and 40 miles from the colony, with some being seen to travel as much as 75 miles. During breeding season, wood storks may utilize anywhere from 50 to 200 different feeding sites. If surrounding conditions are poor (e.g., droughts reducing the number of wetlands in a region), storks will shift nesting sites or not nest. Non-breeding storks are free to travel much greater distances and remain in a region only for as long as sufficient food is available. Differences between years in the seasonal distribution and amount of rainfall usually mean that storks will differ between years in where and when they feed.

In the central Florida region, wood storks typically nest in spring and summer, with young fledging during July and August. Core foraging areas are considered to be within a 15-mile radius of nesting colonies in central Florida. There are no known nesting colonies or core foraging areas identified in or around the CREC site. Wood storks have been observed around the property, and have been observed occasionally foraging in site ponds, impoundments, ditches; as well as in creeks, and wetland areas surroundingthe CREC property.

Due to the rather specific food requirements, and the need for shallow or draining wetlands where fish tend to become concentrated or trapped in isolated pools, it is unlikely that small impoundments within the CREC provide significant or valuable foraging habitat for wood storks.

Rapid changes in water levels, vegetation maintenance, industrial activity (movement and noise), pond maintenance, and pond physical characteristicsall reduce the amount of prey availabilityand suitability of the ponds as foraging habitatfor wood storks.

It is more likely that wood storks transit the property as they seek more naturaland productive shallow-water foraging habitat to the north and south along the central west Florida coast. The use of CREC water habitats by wood storks would be limited to those infrequent times when water levels, prey abundance, and site activities were all at acceptable level, as to allow wood storks the ability to successfully forage.

Regarding the source for the "Florida Wood Stork Colonies Core Foraging Areas Map," the source is from the North Florida Ecological Services Office website. It may be found in the

'Wood Storks" area of the site (see www.fws.gov/northflorida/WoodStorks/wood-storks.htm).

3. T No information was provided on measures to protect threatened or endangered species during transmission line ROW maintenance. The letter from the FWS to Progress Energy (October 28, 2008) regarding impacts to the listed eastern indigo snake provides recommendations for mitigation for this species when carrying out transmission line maintenance, including the submission of a protection/education plan that, if implemented, would result in a "may affect, not likely to adversely affect" determination.

Provide a transmission line ROW maintenance plan per the recommendations of the FWS to protect the eastern indigo snake and its habitat that includes the protection/education plan referenced above.

U. S. Nuclear Regulatory Commission Enclosure 3F0410-03 Page 9 of 15

Response

PEF has developed pamphlets in Spanish and English (see below) that educate personnel engaged in Right-of-Way (ROW) vegetation management and transmission system maintenance on the Eastern indigo snake and the laws that protect this species. These pamphlets are provided to ROW maintenance personnel employed by PEF and contractors.

The pamphlets contain color photographs of Eastern indigo snakes, and provide detailed information on the indigo snake's identification, habitat, and life history. The pamphlets also provide information on the snake's legal status and applicable prohibitions, and include instructions on what to do if ROW maintenance personnel encounter an Eastern indigo snake, including names and telephone numbers of points of contact (Regional Environmental Coordinators).

One of the pamphlets describes how to visually differentiate between the Eastern indigo snake and the black racer.

Because Eastern indigo snakes commonly use gopher tortoise burrows for refuge and egg laying, PEF has also created a "Gopher Tortoise and Eastern Indigo Snake Protection Awareness" pamphlet (see below) for Transmission Delivery staff that contains photographsof the two species and directs Transmission Delivery staff to stop work and contact a supervisorif either of these species is observed in an area slated for construction or vegetation management. The same pamphlet calls for gopher tortoise burrows to be marked as the centers of 25-foot radius exclusion areas.

Furthermore, all ROW maintenance personnel (PEF as well as contractors) receive training regarding the identification of the Eastern indigo snake, gopher tortoise, and gopher tortoise burrows, as well as other sensitive environmental issues and permit requirements.

Finally, the Eastern indigo snake (as well as other federally listed and state listed plant and animal species) are discussed during annual environmental awareness training for ROW maintenance personnel.

The table that follows compares the PEF protection measures (trainingand pamphlets) to the U. S. Fish and Wildlife Service (USFWS) Standard Protection Measures for the Eastern indigo snake (as modified in the USFWS-to-Progress Energy letter of October 28, 2008). As indicated in the table and described above, PEF training and training materials follow USFWS guidelines and PEF'sprotection measures provide the same level of protection as those recommended by the USFWS.

U. S. Nuclear Regulatory Commission Enclosure 3F0410-03 Page 10 of 15 Comparison of USFWS Standard Protection Measures for the Eastern Indigo Snake to Those of Progress Energy USFWS StandardProtectionMeasures ProgressEnergy ProtectionMeasures An eastern indigo snake protection/educationplan The ProgressEnergy protection/educationplan shall be developed for all maintenancepersonnel to consists of initial and annualtraining.

follow. Pertinentdetails are below.

1. Include educationalmaterialssuch as posters, 1. Training consisting of lectures and pamphlets videos, pamphlets, and lectures. is provided.

2. Informationalsigns are not necessaryfor a 2. ROW maintenance activities do not typically trained crew unless more than three individuals occur within a given area for more than one are working in the same area for more than day, so signs are not typically applicable.

one day.

3. All subcontractedmaintenance personnel must 3. All ROW maintenancepersonnel receive have received the trainingor a sign must be trainingon Eastern indigo snakes. Signs are placed every 100 linearfeet on the ROW; the not posted (see above), but two educational signs must be in a language that all personnel pamphlets (in Spanish and English) are can read, and must contain: provided to maintenancepersonnel.

a) A color photo of the Eastern indigo snake. a) The pamphlets include color photos of the b) A description of the Eastern indigo snake, its Easternindigo snake.

habits, and protection under Federallaw. b) A description of the Eastern indigo snake, its c) Instructions not to injure, harm, harassor kill habits, andprotection under Federallaw are this species; and a description of the legal provided in the pamphlets.

restrictionson take and potential legal c) The pamphlets include instructionsnot to consequences for take. injure, harm, harassor kill this species, and d) Directionsto cease clearing activities and include a description of legal restrictions on allow the Eastern indigo snake sufficient time take and potential legal consequences for take.

to move away from the site on its own before d) The two pamphlets direct personnel to stop resuming clearing. work upon seeing an Eastern indigo snake, e) A telephone number to reportdead Eastern and wait until it leaves the area before indigo snakes. resuming work.

e) The pamphlets provide telephone numbers of ProgressEnergy personnel to be contacted to report dead or live Eastern indigo snakes; Progress Energy personnel will then contact USFWS.

If not currently authorized through an Incidental As indicated in the two pamphlets, maintenance Take Statement in associationwith a Biological personnel are not to handle, harm, harass,or have Opinion, only individuals who have been either any contact whatsoever with an Eastern indigo authorizedby a section 10(a)(1)(A) permit issued snake. This information is also emphasized during by the Service, or by the State of Floridathrough annualtraining of ROW maintenance personnel.

the FloridaFish Wildlife Conservation Commission (FWC) for such activities,are permitted to come in contact with an Eastern indigo snake.

(1) USFWS, 2004. Standard Protection Measures for the Eastern Indigo Snake, available at www.fws.gov/northflorida/lndigoSnakesl2004O212 gd EIS Standard Protection Measures.pdf, as modified by letter of October 28, 2008 to James W. Holt, Progress Energy, Crystal River Nuclear Plant.

• c)

Lo6 THREATS AND LEGAL PROTECTION:

The Easlern Indigo Snake is listed as a threatened species by both the U.S. Fish and Watch Out For WIdk*feService (50 CFR -11)and the Florida INDIGO

.N-9 Fish and Wikiffe Consenalion Cornmissiom C)

(68&427.004 Florida Administrative Code).. CD o

The pdrmew cause of decline of Indigo Snake populations is desbruclion and fragmectaltom of the habdat it occupies. Indigo Snakas were SNAKES o also once heavily collecdel for the pet trade, 0 but prolection under the Endangered Species Act has largely elirnitedte threat.

0 3

The 'Taking' of Indigo Snrews is prohibited by 3 the Endangered Species Acl, as amended, (n without a penit from the US Fish and WIldIfe, 0 Service. The USFWS defines 'Take' as; :3 harass, harm, pursue, hunt. shoot, wound.

kill, trap, capture, collet, or attempt to, engage in any such conduct. Penalties for vioialion of the Endangered Species Act ame a maximnum fne of $25,00D for civil vlotions-and a maximum fine or $50,000 and/or, imnilionmeut for up to ore year for crimninal vioMtion, i1fconvicted. Penalties for vioations, of Florida Law prohlbiing the 'Ta74 of Indigo Snakes are mnaxhn"i fines of $500 and/or 60 days 1rnpusonneot for ae first offense.

Stiffer penalties are Imposed for additional violations.

Progress Energy Wayne Richardson Progross Energy Floridaf Inc.

PR. Box 14042, PEF 903 St. Petersbwg, FL 33733 Phone: (727) 820-5148 Mabie; (727) 330-0637 Progress Enegy (00 0)

U~C)

Email; wayne.lchardson@pmnrnaii.com www.progress-eherrgy~cm.camn a-(

WC Indigo Snakes -ri.

o00 IF YOU SEEAN INDIGO SNAE Inthe area (C) that is belng cleared, iis uider- cnstruc~ion,

ýor where ithesnake may be in danger:-

(0 C)0 1, Stop work immediatly until the snake has 5-safely left the area. -

0

2. Report Ithe snake immnediately to your ,2 0

Supervisor, and,

~I~nD hnfmrlg c~ch~g ~ moIesL1~ 1M~go~

(n 0

3. Contact the site environmental biologist

-or Wayne Richardsoli with Progress Energy ii

-h at 727-330.0637 to report the obiervaton. ,snakes also spend *such*"wner In holes.

other ProgresEinern y will request informbtiin S-Vunder und retreats, as stump

about Where arid'when the snakeý was

,obseirved arid forward the inrftrmation to the Indigo Snakeseat-a wide variety of prey.

Fish and Wldlife Service.and other agencies, "'iincluding' frogs; toads, rodents, bbirds andi as appropriate. "otheii snikes (16ciIidring rattlesnakes). Prey I'.overpo-wesed and generally ealen alive.

DESCRIPTION: Indigo Snakes may grow 'Indigo Snakes do not constrict.!hel prey to, flarge (oer 8 feet in length), are heavily from the, U.S. Fi'sh and Wildlife. Service "kill it the way, ary other, snakes do-lbodied and are glossy black, Indigo Snakes or F,o6ridai Fish and Wildlife Conservatiorn frequently have red or orange coloration under omni _`s.o.,

-Remule Indig0 Snakes lay their eggs duringi 1he chin. When approached or distu rbed, Ihis IMay or June'in'a gopher tortoise burrow or snake typically Is not aggressive and will SIMILAR SNAKES: The only other solidi 'some0other typeo area who:ere the eggs will;

.attempt to crawl away frorn the disturbahce. black snake occurring InFlorid* is :the B1-ack. ,stlay warm and, mfcist. The eggs hatc after Indigo Snakes rarely bile but should not be Racer, typically mruch smalier and thinner approximately .60 days,: Hatching Indigo

,captlured or handled without auttiorization than an InIdigo Snake. The chin of the-Black,.,

Racer is white, as compared tb'tie dark 6r

. r$nokesare 'sirmilar to adults in appearance-reddish chin of the Indigo Snake. Black

• and are ibOut 2 feet long.

Racers will bite repeatedly if restrained, LIFE HISTORY: Indico Snakes may occur In almost any type of natural habitat. Dutingi the summer months., thay are frequently found (D m near wet areas, indfgo Snakes frequently 0

take refuge in gopher tortoise burrows, 0 0 particularly during the winter months. The. Cn CD

What to do if Mooseeo e of these animals? (A C::

n-I I. Stop work and contact your supervisor. Your supervisor will contact Progress Enrgy.

CD

2. Do not try to handle, vemove or hwa"s the anlmal, (0

3. Wait until animal leaves area. PrminisEnerny Contacts:

4. Burrow must be marked with 25 foot 0:

radius exclusion area - Progress Mr. Jim Wdicard 0 Energy will determine. G&TC Construction Envlmnmegnjal*Mec 0

5. Be aware of your surrounding - your 352-5632943_x5006 work area could contain several ,Jim.richardManmailgorn other species of snakes.

G. Report any mortalities Immediately Ms. ynthia Wi kinison to Progress Energy Crystal River Plant Environmental Spec Mr, Michael Sh*rader Environmental Health and Safety Seo Mikhael.shrader)uanmaii~com:

Mr. David Bruzek (0 Environmental Health ond Safety Serý Florida Adminetrative Code 8SA,27O041 Designation of Threatened DavWd,br uzekig.PnmaiLcom 8,pec Pfhibiilons; t Pennts.

(1) The 1folovt spaes are heeby declared to be fteatgned, and shall be aflrd*ed

-the pmtelive pnbuins specified.

Wopher Tor-toi-le burrOw (a) No Pemon shal tae, Possess, ftasspaI1 (note: Burrows are protected as wellI mnabet, harass or sm any thtatened spwes included in this mbsection or parts fhiemoi or their nests or eW e=apt as authorkzed by Link to all IFlorida Erndangered and Threatened i Progress Energy specific perat fron the Executive Directo, 1peanits bein issued only for saientitkr or oanservalaon Species. tpuqimes and only upon a showing

by the applicant tha the pemiltnd aclltvity http

',//myfwc,con/imfperiledspecfeslpdf/Thre 'AU] not have a nagative impaacllahe sunivgl atened-ind-a ndangeged-S$e ies--Q7,*d iputenal of the Wpoges, CD MC

gopher Tortoise Gopherus pot yporemus. astrn .India nakeOrymarrhon coas habitats, such as pine flatwoods, scrubby pine The gopher tortoise is a moderate-sized, couperi Eastern Indigo snakes were federally flatwoods, high pine, dry prairie, tropical terrestrial turtle, averaging 23-28 cm (9-11 listed as a threatened species on January 31, hardwood hammocks, edges of freshwater inches) in length. The species is identified by its 1979, pursuant to the Endangered Species Act. marshes, forested wetlands, streams, and IC stumpy, elephantine hind feet and flattened, pasture. Eastern indigo snakes are prone to 0 shovelike forelimbs adapted for digging. The 'The eastern indigo snake is a large, docile, non- desiccation and almcst always are found near shell Isoblong and generally tan, brown, or gray poisonous snake growing to a maximum length wetlands or moist, hamid protective cover such In coloration. of about 8 feet. The color in both young and as gopher tortoise butrows, windrows, or adults is shiny bluish-black, including the belly, decayed stumps or logs. Breeding occurs 1-with some red or cream coloring about the chin November through March with peak activity 0

and sides of the head, occurring in December, Eggs are laid in May with the hatchlings emerging from August 30 through September. ii-W 3

Other nrotemd mods Wand nfearGOoher Tortoise burrows Include the Floida, Mouse T)

Podomysftoridammv and the Goober FrMg Rana 0 The present range of the gopher tortoise n includes much of the southeastern coastal plain, capito. The Florida Mouse and Gopher Frog of the United States from eastern Louisiana to! are listed as a Species of Special Concern and

.Habitat have a significant vulnerability to habitat southeastern South Carolina arid throughout, Florida. Gopher tortoises typically inhabit deep 'This species is currently known to occur modification, enviromnental alteration, human sandy soils in longleaf pine-s:rub oak habitats, throughout Florida and in the coastal plain of disturbance, or human exploitation which, in with a canopy and understory sufficiently open Georgia. Historically, the range also included the foreseeable future, may result In Its to support the growth of low growing. southern Alabama, southern Mississippi, and becomin;g a threatened species unless herbaceous vegetation. Grasses, legumes, and the extreme southeastern portion of South appropriate protective or ma nagement other plant materials are the nain food items of Carolina. techniques are initiated of maintained; This is gopher tortoises, but they have been known toL reason to why the Gopher Tortoise Burrows are, eat small amounts of animal matter as well as 'The eastern indigo snake seems to be strongly protected as well.

indigestible items such as charcoal and pebbles. associated with high, dry, well-drained sandy The gopher tortoise is highly colonial and soils, closely paralleling the sandhill habitat preferred by the gopher tortoise. During spends a major portion of its lifetime, generally estimated at 40-S0 years, in and around a ,warmer months, this snake species also burrow that it excavates. Burrows may be 5 to frequents streams and swamps, and individuals 10 feet deep and 20 or more ;eet long and may- are occasionally found in flat woods. Gopher tortoise burrows and other subterranean Florida be utilized to varying degrees by other

,cavities are commonly used as dens and for egg invertebrate and vertebrate species. Gopher iaying.

tortoises may be active year round and breeding occurs from May to June over most of its range. The egg clutches are frequently laid The eastern indigo snake has one of the largest

-u 0) at the mouth of the burrow with young home ranges (4.8 hectares during the winter hatching In August and September- and 97.4 hectares during the summer) of any rT1 native snake species. The indigo snake is a diurnal species that can be found In a variety of Frog 0

--h ()

(C)

U. S. Nuclear Regulatory Commission Enclosure 3F0410-03 Page 15 of 15

4. T Provide information on the potential effects of cooling tower drift on terrestrial vegetation of the CR-3 site. Has deposition of particulates (salt drift) from cooling towers plumes resulted in any damage to vegetation or increased salinity of soils? Provide salt drift study reports for the years when helper towers were added. If no reports exist, then a statement that no such information exists should be provided.

Response

The CR-3 salt drift studies focused on vegetation ratherthan soil salinity. Although there might be some increased salinity of soils as a result of cooling tower operation, such incremental increases would not be expected to be significant compared to naturally occurring soil salinity values. Additionally, the effects of soil salinization, as evidenced in vegetation, is not unlike what would be observed from salt drift settlement on leafy parts: leaf burn, plant wilt, stunted growth, and plant necrosis. As noted in the documentation provided, while some damage was recorded, no significant impacts to vegetation have occurred that are attributable to salt drift from the cooling towers.

The reports requested pertain to existing or public documentation, and the requested documentation is provided in a separateletter.

5. T-20 (Also AQ-1) - Provide all responses from correspondence with the State of Florida regarding threatened and endangered species. If no responses were received from the State, provide a statement to that effect.

Response

Two letters regarding threatened or endangered species were received from the Florida Natural Areas Inventory (FNAI). These letters have been included in a separately-filed letter transmitting the response to the request for documents. No response to the correspondence sent to the Florida Fish and Wildlife Conservation Commission regarding the License Renewal project could be found.