ML11299A177
| ML11299A177 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/22/2011 |
| From: | Crocker J US Dept of Commerce, National Oceanographic and Atmospheric Administration |
| To: | Stuyvenberg A Office of Nuclear Reactor Regulation |
| References | |
| Download: ML11299A177 (38) | |
Text
Green, Kimberly From: Julie Crocker [Julie.Crocker@Noaa.Gov]
Sent: Thursday, September 22, 2011 5:06 PM To: Stuyvenberg, Andrew
Subject:
Fwd: RE: Schedule for final BO Attachments: sr90fnlrprt.pdf; Julie_Crocker.vcf Follow Up Flag: Follow up Flag Status: Flagged
Original Message --------
Subject:
RE: Schedule for final BO Date:Thu, 22 Sep 2011 14:09:31 -0400 From:Trach, William J <WTrach@goodwinprocter.com>
To:Julie Crocker <Julie.Crocker@Noaa.Gov>
CC:Zoli, Elise N <EZoli@goodwinprocter.com>
Hi Julie. Attached are the referenced documents. I apologize for the delay.
- Thanks, BJ William J. Trach Goodwin Procter LLP Exchange Place Boston, MA 02109 T: 617-570-1586 F: 617-523-1231 wtrach@goodwinprocter.com www.goodwinprocter.com From: Julie Crocker [1]
Sent: Thursday, September 22, 2011 11:19 AM To: Zoli, Elise N Cc: Stuyvenberg, Andrew; Trach, William J; Gray, Dara F; Julie.Williams@Noaa.Gov; Sutton, Kathryn M.; Dacimo, Fred R.; Mark Mattson; Imboden, Andy; BUCKLEY, RICKY N; Dowell, Kelli; pbessette@morganlewis.com; Turk, Sherwin; Balsam, Briana; Logan, Dennis; Glew Jr, William; Fitzgerald, Robert H; Larry Barnthouse; Mayer, Donald M
Subject:
Re: Schedule for final BO Elise -
Thank you for providing this information. I look forward to receiving the 2010 REMP and the NY State report you reference in your email below. No need to send the FSEIS as I have that already.
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We will be in touch re. the schedule soon.
Julie On 9/21/2011 6:33 PM, Zoli, Elise N wrote:
Julie, consistent with my discussion today with Julie Williams, we very much appreciate NMFS' interest in receiving information relevant to Riverkeeper's September 15, 2011 correspondence, and provide the relevant information below. We request that Riverkeeper's correspondence be addressed, consistent with law, on a courtesy basis, as their correspondence is not authorized by the Section 7 consultation process and we are concerned otherwise may delay conclusion of a process that already has undergone a substantial extension. See Final ESA Section 7 Consultation Handbook, March 1998, p. 1-14 (citing 50 CFR 402.14(g)(5)). Moreover, while we understand that NMFS may require additional time to issue a final BO, based on NRC's September 20th correspondence (following its September 6th comments) and are willing to allow a reasonable extension there (one that terminates prior to September 30th), we cannot agree to an extension to respond to Riverkeeper's September 15th correspondence.
As Julie Williams and I discussed, NMFS has requested information on two matters: (1) radionuclide discharges; and (2)
Indian Point 1's intake system. Each is addressed below, with specific reference to the NRC's Final Supplemental Environmental Impact Statement ("FSEIS").
Radionuclides With respect to issue #1, radionuclide discharges from Indian Point have been thoroughly assessed, and it has been determined by Entergy, New York and NRC that there are no identified or probable impacts to fish. The matter is addressed in detail in the FSEIS for Indian Point, in Section 2.2.7, pp. 2-104 through 2-114. It expressly reflects analysis of environmental impacts, including potential impacts to "Hudson River water, fish and invertebrates, aquatic vegetation, bottom sediment and shoreline sediment," p. 2-105, and reaches the following conclusions:
(1) that all reviews of radionuclides in the environment (as broadly defined to include aquatic considerations) were found to be non-detectable, naturally occurring or "significantly less than those from" natural background conditions or other anthropogenic conditions" (including "residual levels from atmospheric weapons testing," p. 2-106), p. 2-109; and, more specifically, with respect to the 2009 REMP:
(2) that "[n]o radionuclides other than those naturally occurring were detected in the Hudson river water samples," p. 2-107 (quoting 2009 REMP report);
(3) that "fish and invertebrate sample analysis results showed there were no plant-related gamma emitting radionuclides detected in 2009," p. 2-107. In this discussion, NRC notes that some of the REMP samples were reported as "not reliable and under review," p. 2-107, with the result that Entergy would submit an addendum . Entergy did address the matter in the 1010 REMP, for which it established a new testing protocol to resolve the 2009 indeterminate results. The 2010 REMP results established no radionuclides in fish above background. (A copy of the 2010 REMP follows, as noted below.)
and, in addition, with respect to Hudson River fish:
(4) that New York State Department of Health (NYSDOH) conducted multi-media investigations, including of fish, confirming that radionuclide levels in the environment in fish in the vicinity of Indian Point were below detection limits or consistent with background radiation, p. 2-109; and (5) that NYSDOH and the New York State Department of Environmental Conservation (NYSDEC) evaluated radionuclide conditions in fish in the vicinity of Indian Point, and determined that radionuclide levels in fish were no higher than in those fish collected from background locations in other areas of the Hudson River, p. 2-112. (A copy of this assessment follows, as noted below.)
Based upon this information, we believe there is no reasonable or credible basis for concluding any potential risk to fish, including sturgeon. BJ Trach is copied here, and he or I will provide the links to the FSEIS, 2010 REMP and the New York report on fish for your review and records.
Indian Point 1 intake structure As you are aware, Indian Point 1 (IP1) is retired from electrical generation. On p. 2-13 of the FSEIS, NRC discusses the current use of the IP1 intake structure, which provides some nonessential service water to IP2 on a periodic basis (typically, during some summer months). The IP1 intake structure is in the middle of the same shoreline bulkhead containing the IP2 and IP3 intake structures, but unlike the IP2 and IP3 intakes, the IP1 intake forebays are underneath an existing post and piling dock structure. The IP1 intake structure has two redundant forebays (#11 and #12), each with a maximum or design flow of 10,000 gallons per minute (gpm), employing a dual flow traveling screen equipped with fine mesh screen (1/8 inch; 3.2 mm) panels. While a combined potential flow of 20,000 gpm is theoretically possible, the system as currently configured for IP2 is employed in a redundant matter, such that the maximum flow is from a single forebay, i.e., 10,000 gpm. Further, typical peak operating flow for IP1 is 5,500 gpm, and 6,000 gpm is the limit of the IP2 load, with the result that maximum flow should be considered 6,000 gpm. Employing the 6,000 gpm rate, the maximum pump flow rate represents merely 0.34% of Indian Point's total maximum flow of 1.746 million gpm (IP2 and 2
IP3 combined circulating and service flows), and we suggest would be considered de minimis by any standards. Moreover, each dual flow traveling screen at IP1's intake has an estimated design through-screen velocity of less than the 0.50 feet per second (fps) through-screen velocity that the United States Environmental Protection Agency (EPA) determined to be protective of 96% of swimming organisms, many smaller and more fragile than shortnose sturgeon. Dr. Mattson, copied here, has confirmed that any healthy sturgeon in the Hudson River of a size subject to impingement could easily escape impingement on the IP1 dual flow traveling screens by swimming away from the low design flow. As NMFS is aware, based on analysis of more than 30 years of extensive river monitoring data, sturgeon eggs and larvae are not present in the vicinity of the Indian Point intake structures and therefore not exposed to entrainment through any screens, including the IP1 dual flow traveling water screens. For completeness sake, please also note that four screen washwater pumps are employed for this system and total 8,000 gpm, although operating procedures rarely employ all four pumps. Based upon this information, we believe that NMFS' draft BO remains correct and comprehensive despite Riverkeeper's correspondence, that no further assessment of IP1's intake is warranted, and that IP1's intake cannot reasonably be construed to cause a separate incidental take of sturgeon. That said, we have agreed to discuss with NMFS a monitoring program, and certainly believe that any such program might include reasonable monitoring requirements for IP1, should NMFS consider such monitoring valuable.
I trust this responds to NMFS' questions, and look forward to issuance of the final BO. Our thanks for your efforts here, and my regards, Elise Zoli Elise N. Zoli GOODWIN PROCTER LLP Exchange Place, Boston, MA 02109 l T:617.570.1612 l F:617.227.8591 l M:617.461.7062 ezoli@goodwinprocter.com Assistant: Kathleen Casey - 617-570-1648 IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
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From: Zoli, Elise N Sent: Tuesday, September 20, 2011 10:09 PM To: 'Stuyvenberg, Andrew'; Julie Crocker Cc: Gray, Dara F; Julie.Williams@Noaa.Gov; Sutton, Kathryn M.; Dacimo, Fred R.; Mark Mattson; Imboden, Andy; BUCKLEY, RICKY N; Dowell, Kelli; pbessette@morganlewis.com; Turk, Sherwin; Balsam, Briana; Logan, Dennis; 'Glew Jr, William'; Fitzgerald, Robert H
Subject:
RE: Schedule for final BO Julie, thanks very much for your email; we appreciate your indicating that NMFS may need additional time to issue its final Biological Opinion (BO). The relevant portion of our extension agreement is quoted below. Based on its language, the extension agreement contemplates that the final biological opinion will be issued no later than September 20th. We, therefore do not read the extension agreement as being effective after that date, consistent with 50 CFR 402.14(e), which both requires a finite deadline and sets a limit on the timeframe within which a final BO must be issued. As importantly, we believe the extension agreement did not guarantee NRC or Entergy comments, but allowed NRC or Entergy to choose what, if anything, they wanted to submit in the timeframe authorized, i.e., by September 6th. As such and as indicated in NRC's email earlier today on this subject, we 3
understand NRC's submission of technical comments on the draft BO on September 6th constituted its position on the issues, as did our submission by that date on behalf of Entergy.
That said, we understand that NMFS is interested in the benefit of NRC's process-related thoughts, which we understand were received by NMFS today. To that end, we are willing to extend issuance of the deadline for the final BO to Monday, September 26th, to allow NMFS a reasonable opportunity to consider NRC's September 20, 2011 correspondence. Because Entergy's express agreement is required to effect such an extension, we wanted you to have it in writing.
Further, we understand NMFS has two process-related questions, and we believe we can provide relevant assurances to NMFS on those issues, facilitating issuance of the final BO in a timely fashion:
(1) Entergy is willing to include the key elements of the proposed draft biological opinion, as finalized, in its proposed technical specifications to the licenses for IPEC. If we make such a commitment, we believe this provides NMFS with the requisite assurances regarding enforceability of the final BO (conforming to the draft BO while accounting for NMFS' response to comments received to date from Entergy and NRC). While we understand from NRC and our review of applicable regulation that this is not required by law, we believe such an approach is consistent with Entergy's commitment to environmental stewardship.
(2) In my conversation with Julie Williams, I also clarified that we can see no reasonable basis for amendment of the current NRC license renewal application with respect to cooling water intake technology that could trigger reinitiation of consultation under 50 CFR 402.16. To the contrary, consistent with NRC's September 20, 2011 correspondence, the ASLB determined that SPDES issues -
- specifically, Section 316(a and b) issues -- will be resolved in the pending NYSDEC proceeding, not before the ASLB on license renewal. If a final Section 316(a, b) decision in the SPDES proceeding requires NRC approval to implement, Entergy would submit such a new application to NRC, as a result of which we understand from NRC 's September 20, 2011 correspondence may precipitate a new consultation with NMFS on that amendment at that time. Likewise, CWIS modifications requiring US Army Corps approval would also trigger consultation with NMFS. For these reasons, we can foresee no situation in which NMFS consultation would not be sought, where required.
Finally, lest there be any confusion, we believe that NMFS' draft biological opinion addressed, within its authority, the proper species, i.e., short-nose sturgeon, and that the absence of discussion of Atlantic sturgeon is appropriate as a matter of law. To that end, while we appreciate that NRC may have an interest in NMFS' views on Atlantic sturgeon, we have identified no legal basis for the proposed further exchange of information, potential initiation of a new or different consultation, or the delay that would almost certainly result from either of those actions.
As noted above, the extension language is as follows:
"Ten calendar days after NMFS provides a draft BO to NRC (likely September 6 - first working day after Labor Day) - NRC provides comments from NRC and from Entergy, if any, on the draft BO to NMFS at the end of this 10-calendar day period. If there are no substantive comments, then NMFS prepares the final BO within several days of September 6. If NRC or Entergy submit substantive comments, then NMFS will either prepare a final BO within ten working days (September 20) or NMFS will notify NRC and Entergy of a need for additional time."
As always, I am happy to discuss the above, and my regards, Elise From: Stuyvenberg, Andrew [2]
Sent: Tuesday, September 20, 2011 8:37 AM To: Julie Crocker Cc: Gray, Dara F; Julie.Williams@Noaa.Gov; Zoli, Elise N; Sutton, Kathryn M.; Dacimo, Fred R.; Mark Mattson; Imboden, Andy; BUCKLEY, RICKY N; Dowell, Kelli; pbessette@morganlewis.com; Turk, Sherwin; Balsam, Briana; Logan, Dennis
Subject:
RE: Schedule for BO (revised proposal)
Julie -
The NRC staff transmitted all of its draft BO comments to NMFS on September 6, per our agreement. We have completed our letter in which we respond to Ms. Kurkuls cover letter and will issue it today.
Best regards, Drew 4
From: Julie Crocker [3]
Sent: Monday, September 19, 2011 4:41 PM To: Stuyvenberg, Andrew Cc: Gray, Dara F; Julie.Williams@Noaa.Gov; Zoli, Elise N; Sutton, Kathryn M.; Dacimo, Fred R.; Mark Mattson; Imboden, Andy; BUCKLEY, RICKY N; Dowell, Kelli; pbessette@morganlewis.com; Turk, Sherwin; Balsam, Briana; Logan, Dennis
Subject:
Re: Schedule for BO (revised proposal)
- All, Given that NMFS has not yet received all of NRC's comments related to the draft Biological Opinion distributed to NRC on August 25, apparent disagreement regarding the schedule, and in light of the possibility of NMFS needing to address substantive comments, in an abundance of caution, NMFS is writing to indicate that additional time is needed for the consultation to be completed.
Julie On 6/29/2011 5:31 PM, Stuyvenberg, Andrew wrote:
Dara, others -
The following summarizes my understanding of the schedule for the ongoing ESA Section 7 consultation as agreed-to by NRC, NMFS, and Entergy on this afternoons teleconference.
T (likely July 5; not before July 5) - Entergy submits information on benthic resources in the action area as discussed on the June 22 teleconference (i.e., information on the biofouling community at the IP intakes, information on the entrainment of amphipods and published studies related to the distribution of the benthic community in the Hudson River). Entergy is also to provide to NRC any relevant thermal information for NRCs revised BA T+20 calendar days (likely July 25, depending on T) - NRC staff submits BA supplement to NMFS focusing on the assessment of the thermal discharge on shortnose sturgeon.
One month after NRC submits BA supplement to NMFS (likely August 25) - NMFS provides a draft Biological Opinion (BO) to NRC. In completing its BO, NMFS will: (a) review the information provided in the supplemental BA, (b) incorporate the new information on the thermal plume (Swanson et al.
2011, and other sources of information as appropriate) into the draft Opinion, (c) incorporate additional technical information provided by Entergy on the June 22 conference call, (d) make a draft determination as to whether the proposed action is likely to jeopardize the continued existence of shortnose sturgeon and provide justification for this determination, (e) prepare a draft Incidental Take Statement with draft Terms and Conditions and Reasonable and Prudent Measures, as appropriate.
Following receipt of the BO, it is NMFS understanding that NRC will distribute the draft BO to Entergy and request that Entergys comments be submitted to NRC for transmittal to NMFS pursuant to 50 CFR 402.14(g)(5).
Ten calendar days after NMFS provides a draft BO to NRC (likely September 6 - first working day after Labor Day) - NRC provides comments from NRC and from Entergy, if any, on the draft BO to NMFS at the end of this 10-calendar day period.
If there are no substantive comments, then NMFS prepares the final BO within several days of September 6. If NRC or Entergy submit substantive comments, then NMFS will either prepare a final BO within ten working days (September 20) or NMFS will notify NRC and Entergy of a need for additional time.
I believe that captures our agreed-upon timeline, but please reply if Ive missed or misconstrued anything.
Best regards, Drew
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- This message is intended only for the designated recipient(s). It may contain confidential or proprietary information and may be subject to the attorney-client privilege or other confidentiality protections. If you are not a designated recipient, you may not review, copy or distribute this message. If you receive this in error, please notify the sender by reply e-mail and delete this message. Thank you.
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Measurement of strontium-90 (90Sr) and other radionuclides in edible tissues and bone/carapace of fish and blue crabs from the lower Hudson River, New York Lawrence C. Skinner Timothy J. Sinnott New York State Department of Environmental Conservation Division of Fish, Wildlife and Marine Resources 625 Broadway Albany, New York 12233 November 2009
Table of Contents INTRODUCTION .......................................................................................................................... 2 METHODS ..................................................................................................................................... 2 RESULTS ....................................................................................................................................... 4 DISCUSSION ................................................................................................................................. 5 CONCLUSIONS............................................................................................................................. 8 ACKNOWLEDGMENTS .............................................................................................................. 8 REFERENCES CITED................................................................................................................... 9 Table 1: 90Sr concentrations in edible tissues of fish taken from the lower Hudson River in 2006
....................................................................................................................................................... 11 Table 2: 90Sr and other radionuclide concentrations in edible tissues of fish and blue crab from three locations on the lower Hudson River in June 2007. ............................................................ 12 Table 3: 90Sr and other radionuclide concentrations in bone of fish and carapace of blue crab from three locations on the lower Hudson River in June 2007..................................................... 13 Table 4: Radionuclide concentrations measured in bone of fish from three locations on the lower Hudson River in June 2007........................................................................................................... 14 Table 5: Comparison of 90Sr concentrations in bone and edible flesh of fish. ............................. 15 Figure 1 ......................................................................................................................................... 16 1
INTRODUCTION In 2005, Entergy Nuclear Operations, Inc. (Entergy), the owner of the Indian Point Nuclear Power Plant located at Buchanan, NY on the Hudson River, discovered a spent fuel pool water leak to groundwater while installing a new crane to facilitate transfer of Unit 2 spent fuel to dry cask storage. This leak was determined to have generated a groundwater plume of tritium (3H).
During efforts to track the 3H plume, 90Sr was discovered in a downgradient portion of the plume and traced back to a leak in the Unit 1 spent fuel pool.
Because site groundwater flows to the Hudson River, the 2006 Radiological Environmental Monitoring Program (REMP) conducted by Entergy was modified to include 90Sr as an analyte in fish samples. 90Sr was detected in four of 10 samples of fish taken from the river in the vicinity of the power plant, and in three of five samples from an upstream reference location near the Roseton Generating Station in Newburgh, NY (Table 1). The tissues analyzed were composites of edible flesh from fish representing several species.
The data was reviewed by Entergy and compared with data for other facilities and historical information. Entergy concluded that the 90Sr levels were low and may be indistinguishable from background levels from fallout from nuclear weapons testing in the 1950s and 1960s (Entergy 2007). The New York State Departments of Health (NYSDOH) and Environmental Conservation (NYSDEC) (the Agencies) concurred. However, the Agencies were concerned that the home ranges of several sampled species, and all striped bass, may overlap at the two sampling sites. In order to assure independence of sampling sites, the Agencies initiated this one time enhanced radiological surveillance for 2007.
The objectives of the enhanced radiological monitoring effort were to:
- gain information about the levels, impacts, and possible 90Sr sources at the reference locations and the indicator station,
- determine if significant spatial differences in 90Sr concentrations were present,
- to assess whether or not 90Sr concentrations in the bones and flesh of fish signify heightened risk either to aquatic life in the Hudson River, and
- provide information for an independent assessment of potential public health impacts.
METHODS Part of Entergys REMP requirements is to conduct routine radiological surveillance using composite samples of edible tissues of fish two or more important commercial and/or recreational fish or invertebrate species. Possible target species include striped bass (Morone saxatilis), white perch (Morone americana), American eel (Anguilla rostrata), white catfish (Ictalurus catus) or channel catfish (Ictalurus punctatus), sunfishes including pumpkinseed (Lepomis gibbosus), bluegill (L. macrochirus) or redbreast sunfish (L. auritus), and blue crab (Callinectes sapidus). Sampling occurs in spring and fall of each year at two locations, i.e., in 2
the vicinity of Indian Point Nuclear Power Plant (approximately river mile 42) and the vicinity of Roseton Generating Station (the traditional reference station at approximate river mile 65). One composite sample of each species is collected at each location and is analyzed for a host of radionuclides.
Sampling is conducted by Normandeau Associates, Inc. under contract with Entergy, and samples consist of by-catch of fish or blue crabs taken as a consequence of sampling for other purposes. All samples were collected in June 2007 and were frozen (- 20º C) in a locked freezer until prepared for shipment for chemical analyses. The prepared sample mass is a minimum of 1600 g and a maximum of 2000 g. This sample mass is split three ways. The first split of 1000 g went to Entergys contract laboratory, AREVA, Inc. The second split of 300 to 500 g went to the Nuclear Regulatory Commission for analysis at the Oak Ridge Institute for Science and Education (ORISE). The third split (300 to 500 g) was sent to the NYSDOH Wadsworth Center for Labs and Research. Collection records and chain of custody are maintained for all samples (Appendix A).
The one-time design modifications for the 2007 effort included: the addition of carp (Cyprinus carpio) - a benthic feeder - to the target species list; adding 90Sr to the list of radionuclide analytes; analysis of fish bone or crab carapace; and sampling fish at a third location, i.e., the Catskill Region between river miles 107 and 125 (Figure 1). This upstream location assures appropriate separation of fish populations that are resident to the river, and, consequently, assures isolation of resident fish populations from the potential influence of the Indian Point Nuclear Power Plant.
Normandeau Associates, Inc. prepared the samples of edible portions of fish and blue crabs.
Skinless filets were excised from each specimen, composites by species were made, and each composite was thoroughly ground and homogenized. Subsamples were developed for each laboratory. These were double packaged in food grade plastic bags, labeled, frozen, and shipped to each participating laboratory.
The remaining carcasses of the fish and blue crabs were provided to the NYSDECs laboratory at the Hale Creek Field Station, Gloversville, NY where they were prepared for radiological analyses by the NYSDOH Wadsworth Center for Labs and Research. In addition to the required species, samples of other fish species were provided to Hale Creek including yellow perch (Perca flavescens), rock bass (Ambloplites rupestris), smallmouth bass (Micropterus dolomieui),
largemouth bass (Micropterus salmoides), black crappie (Pomoxis nigromaculatus), and brown bullhead (Ameiurus nebulosus).
Preparation of bone and carapace samples was conducted in several steps. First, the samples were cleaned to remove as much muscle, skin, scales or other tissues as possible. The resulting bone samples were placed in a fume hood and air dried for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, then each sample was individually bagged, labeled and stored in a locked freezer until they were sent for further cleaning by dermestid beetles maintained by the New York State Museum at their Rensselaer Technology Park offices in Troy, NY. Each bone sample was maintained in an individual labeled sample container while undergoing dermestid cleaning. Following this process, each sample was frozen to kill the dermestids, rethawed, and the frass (dermestid larval carcasses and 3
fecal material) was removed from the bone. Finally, the skeletal and cranial bones (fins were excluded) were placed in food grade plastic bags, labeled and submitted to the NYSDOH Wadsworth Center for Labs and Research. Continuing chain of custody was maintained throughout the process (Appendix B).
Analysis of radionuclides were conducted by NYSDOH using two methods:
90
- Sr analyses of fish bone were conducted by USEPA Method 905.0 (Krieger and Whittaker 1980b). Steps in this method include isolation of strontium, measurement of total strontium, hold the strontium for decay to allow time for the ingrowth of the yttrium-90 daughter, isolate and measure yttrium-90.
- Common indicator radionuclides (134Cs, 137Cs, 60Co, and 40K) were analyzed using USEPA Method 901.1 (Krieger and Whittaker 1980a).
Concentrations reported in Tables are the value for the sample +/- the analytical standard error.
For example, a value of 8 +/- 2 pCi/kg would mean the best estimate concentration is 8 pCi/kg although the concentration may be as little as 6 pCi/kg or as much as 10 pCi/kg.
Statistical tests for spatial differences in concentrations employed the Kruskal-Wallis test when there were three comparisons. The Mann-Whitney test was used when there were only two comparisons (Conover 1980). These non-parametric tests were chosen because of their ability to reduce the influence of outlier data. A difference was considered significant when the probability was less than 0.05 (P < 0.05).
RESULTS Edible Tissue Samples 90 Sr was detected in only one sample of edible tissues, i.e., 8 +/- 3 pCi/kg in blue crab taken from the vicinity of the Indian Point facility. Detection limits ranged between 3 and 6 pCi/kg (Table 2). Only the determinations made by the NYSDOH Wadsworth Center for Labs and Research are reported since their analytical methods were the most sensitive of the three laboratories conducting the analyses. No detectable radionuclides were reported by the other two laboratories.
Bone and Carapace Samples 90 Sr concentrations in bone of fish or the carapace of blue crabs are shown in Table 3. 90Sr concentrations are relatively consistent among all fish species, including striped bass, within locations. Mean and standard deviation concentrations for all fish at the three locations were:
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90 Location n Sr Concentration (pCi/kg)
Indian Point 10 199 +/- 58 Roseton 10 222 +/- 67 Catskill 10 271 +/- 69 The single blue crab sample, taken from the Roseton area, had 760 pCi/kg of 90Sr in the carapace. This is the highest 90Sr concentration reported, and twice the highest fish concentration of 360 pCi/kg in yellow perch from the Catskill area.
Among other radionuclides analyzed, 134Cs, 137Cs, 58Co and 60Co were not detected in bone or carapace of any sample. Detection limits ranged from 0.2 to 80 pCi/kg for 134Cs, 137Cs and 60Co, and an order of magnitude greater for 58Co. 40K was present in nearly all samples within a limited range of concentrations and with mean and standard concentrations by area in fish as follows:
40 Location n K Concentration (pCi/kg)
Indian Point 9 2840 +/- 678 Roseton 10 3540 +/- 978 Catskill 10 2740 +/- 614 Table 4 presents concentrations of other radionuclides that were detected in bones of fish.
DISCUSSION 90 Sr in bone versus edible tissues Whicker et al. (1990) compared 90Sr concentrations in bone and edible flesh of fish taken from a cooling water pond at the USDOE Savannah River nuclear power plant. Similar comparisons were made for fish in waters downstream of the Nuclear Fuels Services Inc. nuclear waste treatment plant in West Valley, NY, and in Lake Ontario (NYSDEC 1971) (Table 5). In these studies the ratio of 90Sr in bone to that in edible fish tissue (90Sr bone:flesh ratio) ranged from less than one to 1198. The highest value is considered an outlier. The mean 90Sr bone:flesh ratio, excluding the outlier, was about 35. (The mean must be viewed with caution since the West Valley study did not indicate whether the 90Sr quantification method was the same as that used in the Savannah River study; wet weight versus dry mass in flesh, or original mass versus ash weight of bone. If the methods used are not the same the ratios may not be comparable.) If it is assumed that the two studies are comparable, and we apply this ratio to bone in the present study, the 90Sr concentration in edible tissues would very near or below the detection limit. This tends to confirm the reported lack of detection of 90Sr in edible flesh of fish from the lower Hudson River (Tables 2 and 5) in 2007.
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Spatial differences There were no significant differences (P = 0.096) in 90Sr concentrations between the three locations for resident fish. Looking at reference stations only, there was no significant difference in 90Sr at Catskill and Roseton. Inclusion of striped bass, a migratory fish species, would not have changed the overall conclusion because of the similarity of 90Sr concentrations.
In contrast, 40K was statistically greater (P = 0.018) at the Roseton station than at either Indian Point or Catskill (which were equivalent) despite the small difference in average 40K concentrations. Inclusion of striped bass would not have changed the finding. 40K is a naturally occurring primordial radionuclide (Copplestone et al. 2001) which is expected to be found at these concentrations in fish and is not associated with nuclear waste for power production or fallout from weapons testing (Eisler 1994). The differing levels, albeit they are small differences, have no known significance.
Lastly, there were no differences between stations for 224Ra. There were insufficient data to assess spatial differences for other radionuclides.
Relationship to criteria The U.S. Department of Energy (USDOE) developed ecological standards for the protection of terrestrial animals, terrestrial plants, and aquatic animals based on published literature reviews of the effects of ionizing radiation on biota (NCRP 1991; IAEA 1992; UNSCEAR 1996). The standard for the protection of aquatic animals is:
The absorbed dose to aquatic animals should not exceed 1 rad/day (10 mGy/day or 400 Gy/hr1) from exposure to radiation or radioactive material releases into the aquatic environment.
This dose is specified in DOE Order 5400.5 (USDOE 2002). This standard is designed to protect populations of aquatic organisms, not individuals. At absorbed dose rates below the standard, populations will be maintained but some individual animals can suffer adverse impacts.
USDOE (2002) provides dose conversion factors (DCF) which can be used to estimate the absorbed dose from the internal abundance/activity of a radionuclide accumulated by an aquatic organism. The DCF calculations are conservative in that they assume all of the energies of radioactive decay are retained in the tissue of the organism, and that the radionuclides were presumed to be homogenously distributed in tissue. They are expressed in units of Rad/day per pCi/g wet weight. Using the DCFs it is possible to estimate the absorbed dose from the internal radionuclide concentration. Additional conversions were employed to express the total dose in 1
A Gray (Gy) is a standard international unit of absorbed dose of radiation adopted by the International Commission on Radiological Protection in 1977. 1 Rad = 0.01 Gy; conversely, 1 Gy = 100 Rads.
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the Standard International (SI) units for chronic absorbed dose rates of Gy/hr. USDOE (2002) did not report DCFs for 224Ra and 40K.
The highest tissue/bone concentrations of radionuclides listed in Tables 1 - 4 are the upper bound concentrations (i.e., measured concentration plus the 95% confidence interval) of 809 pCi/kg of 90Sr from blue crab carapace (Table 3), 370 pCi/kg of 238U and 320 pCi/kg 232Th measured in the bones of striped bass (Table 4). All three samples were collected from the Roseton Generating Station (River Mile 65). Using the DCFs from (USDOE 2002), these concentrations can be converted to an internal dose rates:
809 pCi/kg of 90Sr would result in an estimated internal dose rate of 0.02 Gy/hr; 370 pCi/kg of 238U would result in an estimated internal dose rate of 0.7 Gy/hr; and 320 pCi/kg of 232Th would result in an estimated internal dose rate of 5.5 Gy/hr.
All of these dose rates range from about two to five orders of magnitude below the USDOE (2002) standard of protection for aquatic animals. While the highest internal dose to striped bass from a single radionuclide was from 232Th. However, to estimate the total internal dose, the internal doses from all radionuclides present must be summed. Using the upper bound concentrations for 226Ra, 232Th, and 238U with the DCFs from (USDOE 2002), the total internal dose to striped bass collected at the Roseton Power Generating Station can be estimated to be 8.4 Gy/hr. A DCF for 224Ra is not available, probably because this is a short-lived radionuclide with a half-life of only 3.7 days (Eisler 1994). 224Ra disintegrates rapidly through a series of seven daughter radionuclides to the stable nuclide 208Pb with a total half-life for the whole series of about 65 minutes (Nebergall et al. 1968).
The standards of protection published in USDOE (2002) were derived from a qualitative evaluation of radiological effects data. The European Union (EU) took a more quantitative approach to deriving ecological standards. EU assembled a large database of the impacts of ionizing radiation to biota and evaluated the studies to identify critical toxicity endpoints. Once the critical toxicity endpoints were determined, they were used with standard EU risk assessment protocols to derive a chronic Predicted-No-Effect-Dose Rates (PNEDR) screening value of 10 Gy/hr for freshwater, terrestrial, and marine/estuarine ecosystems (Garnier-Laplace and Gilbin 2006). The total absorbed dose from the internal concentration of 232Th, 226Ra, and 238U in striped bass is less than the chronic screening no effects dose rate derived by the EU.
The internal dose rate conversion factors from USDOE (2002) are conservative, but they do not take into account absorbed doses received from external sources, such as radionuclides in the water and sediment. There is no way to estimate those dose rates without measurements.
USDOE (2002) provides a method for estimating the total absorbed dose to biota from both external and internal sources. This approach uses Biota Concentration Guides (BCG)s which are concentrations of 23 different radionuclides in water, soil, and sediment. If the BCG concentrations are not exceeded, the total absorbed dose will not exceed the USDOE (2002) standards of protection. In order to utilize this method, simultaneous samples of water and sediment must be collected and analyzed in the immediate vicinity of suspected unregulated releases of radioactive materials into the Hudson River.
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No excursions above ecological standards for the protection of aquatic animals appear to have occurred. However, the current monitoring effort does not allow for the full assessment of risks to aquatic animals. To fully evaluate the risks, the concentrations of the full range of 23 radionuclides listed in USDOE (2002) in both water and sediment samples collected from the same location simultaneously should be sampled. This would allow for the full use of the Graded Approach for Evaluating Radiation Doses to Aquatic and Terrestrial Biota as described in USDOE (2002) to be employed to evaluate and assess risks to aquatic biota.
The 23 radionuclides which should be sampled include: 241Am, 144Ce, 135Cs, 137Cs, 60Co, 154Eu, 155 Eu, 3H, 129I, 131I, 239Pu, 226Ra, 228Ra, 125Sb, 90Sr, 99Tc, 232Th, 233U, 234U, 235U, 238U, 65Zn, and 95 Zr.
CONCLUSIONS Two conclusions can be made.
- 1. There are no apparent excursions above criteria for the protection of biota based on the radionuclide data available. The levels of radionuclides - including 90Sr - were two to five orders of magnitude lower than criteria established for protection of freshwater ecosystems.
- 2. There were no spatial differences in concentrations of 90Sr and 224Ra in resident fish from the three locations sampled in the lower Hudson River (i.e., Indian Point Nuclear Power Plant, and the reference sites at the Roseton Generating Station and at Catskill). In contrast, 40K levels were somewhat greater in the vicinity of Roseton Generating Station, but the differing concentrations have no known significance.
ACKNOWLEDGMENTS The authors gratefully acknowledge the assistance and cooperation of a number of people during the conduct of this study. These include: Michael Ritchie and his staff at Normandeau Associates Inc. who provided the carcasses of fish and blue crabs used in this study; Anthony Gudlewski, Brian Buanno and John Finn at the NYSDECs Hale Creek Field Station who conducted the initial cleaning and drying of carcass samples; and Joseph Bopp of the NYS Museum who maintained and oversaw use of the dermestid beetle colony. Helpful comments on manuscript were provided by Larry Rosenman (NYSDEC), Anthony Forti, Edward Horn, Robert Snyder and Stephen Gavitt (NYSDOH), and Kathleen Skinner (Russell Sage College).
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REFERENCES CITED Conover, W. J. 1980. Practical Nonparametric Statistics, second edition. John Wiley and Sons, New York.
Copplestone, D., S. Bielby, S. R. Jones, D. Patton, P. Daniel, and I. Gize. 2001. Impact Assessment of Ionizing Radiation on Wildlife. R&D Publication 128. Environment Agency, Bristol, UK. Updated March 2003. ISBN: 1 85705590 X. 222 pp.
Eisler, R. 1994. Radiation hazards to fish, wildlife and invertebrates: A synoptic review.
Biological Rep. 29, National Biological Service, US Department of the Interior, Washington, DC. 124 p.
Entergy. 2007. Annual Radiological Environmental Operating Report. January 1 - December 31, 2006. Entergy, Indian Point Energy Center, Buchanan, NY.
Garnier-Laplace, J., and Gilbin R. (Eds), 2006. ERICA Deliverable 5: Derivation of Predicted-No-Effect-Dose-Rate values for ecosystems (and their sub-organizational levels) exposed to radioactive substances. ERICA contract number FI6R-CT-2004-508847, date of issue: 28 2006, Project Coordinator: Swedish Radiation Protection Authority.
IAEA, 1992. Effects of Ionizing Radiation on Plants and Animals at Levels Implied by Current Radiation Protection Standards. International Atomic Energy Agency Technical Reports Series No. 332, Vienna, 1992.
Joshi, S. R. 1991. Radioactivity in the Great Lakes. The Science of the Total Environment 100:61-104.
Krieger, H. L., and E. L. Whittaker. 1980a. Prescribed procedures for measurement of radioactivity in water. Section 4. Gamma emitting radionuclides in drinking water. Method 901.1. EPA-600/4-80-032. US Environmental Protection Agency, Cincinnati, OH.
Krieger, H. L., and E. L. Whittaker. 1980b. Prescribed procedures for measurement of radioactivity in water. Section 9. Radioactive strontium in drinking water. Method 905.0.
EPA-600/4-80-032. US Environmental Protection Agency, Cincinnati, OH.
NCRP. 1991. Effects of Ionizing Radiation on Aquatic Organisms. National Council on Radiation Protection and Measurements (NCRP) Report No. 109, NCRP, Bethesda, Md.
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Nebergall, W. H., F. C. Schmidt, and H. F. Holtzclaw, Jr., 1968. General Chemistry, Third Edition. D. C. Heath and Company, Lexington, Massachusetts.
Neel, J. W., and K. H. Larson. 1963. Biological availability of strontium-90 to small native animals in fallout patterns from the Nevada test site. Pp. 45-49. In: V. Schultz and A. W.
Klement, Jr. (eds.), Radioecology. Reinhold, NY.
NYSDEC. 1971. 1970 Annual report of environmental radiation in New York State. New York State Department of Environmental Conservation, Albany, NY. 58 p.
USDOE, 2002. A Graded Approach for Evaluating Radiation Doses to Aquatic and Terrestrial Biota. U.S. Department of Energy, DOE-STD-1153-2002, July 2002.
UNSCEAR, 1996. Sources and effects of ionizing radiation. United Nations Scientific Committee on the Effects of Atomic Radiation, UNSCEAR 1996 Report to the General Assembly, with Scientific Annex. United Nations, New York, 1996.
Whicker, F. W., W. C. Nelson, and A. F. Gallegos. 1972. Fallout 137Cs and 90Sr in trout from mountain lakes in Colorado. Health Physics 23:519-527.
Whicker, F. W., E. Pinder III, J. W. Bowling, J. J. Alberts, and I. L. Brisbin, Jr. 1990.
Distribution of long-lived radionuclides in an abandoned reactor cooling reservoir. Ecological Monographs 60:471-496.
Wrenn, M. E., J. E. Lentsch, M. Eisenbud, G. J. Lauer, and G. P. Howells. 1971. Radiocesium distribution in water, sediment, and biota in the Hudson River estuary from 1964 through 1970.
Pp. 334-343. In: D. J. Nelson (ed.), Radionuclides in ecosystems. Volume 1. Proceedings of the Third National Symposium on Radioecology, 10-12 May 1971, Oak Ridge, TN.
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90 Table 1: Sr concentrations in edible tissues of fish taken from the lower Hudson River in 2006.
90 Sr concentration (pCi/kg wet weight)
Measured Location Species detection limit Sample1 (DL)
Indian Point Striped bass 8.5 <DL Nuclear Power Plant Blue crab 5.7 <DL (indicator site) American eel 7.1 <DL Catfish 6.4 <DL Sunfish 15 <DL White perch 9.0 18.8 Roseton Generating Striped bass 4.2 <DL Station Blue crab 11.0 13.6 (reference site) American eel 4.3 <DL Catfish 7.6 <DL Sunfish 9.6 17.1 White perch 8.7 24.5 1
Analyses by Entergy Nuclear Operations, Inc. contract laboratory, i.e., AREVA, Inc.
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90 Table 2: Sr and other radionuclide concentrations in edible tissues of fish and blue crab from three locations on the lower Hudson River in June 1
2007 .
No. in Concentration (pCi/kg wet weight)2 Location Species 90 134 137 58 60 40 sample Sr Cs Cs Co Co K Indian Point Blue crab 62 8+/-3 <3 <3 <3 <4 2510 +/- 180 Nuclear Power Striped bass 7 <4 <1.9 <2 <2 <2 2400 +/- 150 Plant White perch 57 <3 <2 <3 <3 <3 2750 +/- 170 (RM 42)3 Catfish 15 <4 <1.9 <2 <3 <2 2580 +/- 150 American eel 19 <4 <2 <3 <3 <2 2320 +/- 150 Carp 2 <5 <1.7 <2 <3 <1.8 2590 +/- 150 Sunfishes 79 <6 <2 <2 <3 <2 2660 +/- 170 Roseton Striped bass 1 NA4 NA NA NA NA NA Generating White perch 116 <5 <2 <3 <3 <2 2440 +/- 160 Station Catfish 45 <3 <1.8 <2 <2 <1.8 2620 +/- 150 (RM 65) American eel 15 <4 <2 <3 <3 <2 2490 +/- 160 Carp 4 <4 <1.7 <1.9 <3 <1.8 2480 +/- 150 Sunfishes 30 <3 <3 <3 <3 <3 2590 +/- 170 Catskill Region White perch 108 <4 <2 6+/-3 <3 <2 2390 +/- 160 (RM 107 - 125) Catfish 18 <3 <1.9 9+/-3 <3 <1.9 2640 +/- 160 American eel 15 <4 <2 <3 <3 <2 2000 +/- 140 Carp 2 <4 <2 <2 <3 <2 2450 +/- 150 Sunfishes 18 <4 <2 <3 <3 <2 2620 +/- 170 1
All analyses by the New York State Department of Healths Wadsworth Center for Labs and Research.
2 A less than (<) value indicates the concentration is less than the specified detection limit for the sample.
3 RM = Approximate location in river mile(s).
4 NA = Not analyzed. Analyses by the Nuclear Regulatory Commissions laboratory, Oak Ridge Institute for Science and Education
[ORISE], reported 90Sr at <4 pCi/kg, and 134Cs, 137Cs, 58Co and 60Co as <10 pCi/kg each; no analyses were conducted of 40K.
90 Table 3: Sr and other radionuclide concentrations in bone of fish and carapace of blue crab from three locations on the lower Hudson River in June 2007.
No. in Concentration (pCi/kg wet weight)1 Location Species 90 134 137 58 60 40 sample Sr Cs Cs Co Co K Indian Point Nuclear Striped bass 7 96 +/- 89 <4 <4 <21 <4 2710 +/- 190 Power Plant White perch 28 190 +/- 34 <5 <4 <21 <3 2240 +/- 170 (River Mile 42) Yellow perch 27 240 +/- 50 <7 <6 <30 <6 2600 +/- 200 Brown bullhead 8 220 +/- 62 <7 <6 <30 <6 4100 +/- 300 Channel catfish 1 230 +/- 48 nd nd nd nd nd White catfish 7 160 +/- 46 <5 <4 <20 <5 3000 +/- 200 American eel 21 150 +/- 31 <9 <9 <41 <8 3200 +/- 300 Carp 2 290 +/- 62 <3 <3 <17 <3 1670 +/- 130 Pumpkinseed 5 250 +/- 58 <20 <16 <100 <19 2800 +/- 400 Sunfishes 35 160 +/- 32 <7 <6 <30 <6 3200 +/- 300 Roseton Generating Blue crab 6 760 +/- 49 <11 <9 <90 <9 3800 +/- 300 Station Striped bass 1 140 +/- 57 <7 <5 <60 <6 2030 +/- 160 (River Mile 65) White perch 55 270 +/- 62 <9 <7 <80 <8 3100 +/- 300 White perch 70 270 +/- 39 <8 <8 <70 <8 3000 +/- 300 Brown bullhead 6 250 +/- 72 <5 <4 <40 <4 3110 +/- 180 Brown bullhead 33 220 +/- 63 <6 <6 <60 <5 3400 +/- 300 Channel catfish 5 130 +/- 79 <6 <6 <60 <6 4900 +/- 300 American eel 15 140 +/- 78 <10 <9 <90 <10 3500 +/- 300 Perch 9 260 +/- 42 <12 <10 <100 <10 3100 +/- 300 Sunfishes 26 210 +/- 66 <10 <10 <90 <8 3900 +/- 400 Rock bass 1 330 +/- 310 <80 <60 <600 <80 5400 +/- 100 Catskill Region White perch 74 310+/- 46 <8 <6 <70 <6 2300 +/- 200 (River Miles 107 - 125) Brown bullhead 6 300 +/- 50 <10 <7 <90 <8 2700 +/- 200 Channel catfish 11 220 +/- 83 <4 <4 <60 <4 2800 +/- 200 American eel 16 120 +/- 77 <11 <8 <90 <9 3300 +/- 300 Sunfishes 23 290 +/- 95 <10 <8 <90 <10 4000 +/- 400 Carp 2 260 +/- 31 <4 <4 <40 <3 2050 +/- 180 Largemouth bass 6 220 +/- 38 <3 <2 <40 <2 2530 +/- 130 Smallmouth bass 2 330 +/- 45 <10 <13 <170 <15 2800 +/- 300 Black crappie 1 300 +/- 120 <30 <20 <200 <20 3000 +/- 400 Perch 17 360 +/- 41 <12 <9 <140 <10 1900 +/- 200 1
A less than (<) value indicates the concentration is less than the specified detection limit for the sample. nd = not determined.
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Table 4: Radionuclide concentrations measured in bone of fish from three locations on the lower Hudson River in June 2007.
No. in Concentration (pCi/kg wet weight)
Location Species 224 226 232 238 sample Ra Ra Th U Indian Point Nuclear Striped bass 7 26 +/- 9.0 21 +/- 9.0 47 +/- 15 Power Plant White perch 28 33 +/- 9.0 25 +/- 9.0 (River Mile 42) Yellow perch 27 31 +/- 13 30 +/- 14 Brown bullhead 8 23 +/- 10 22 +/- 12 White catfish 7 17 +/- 8.0 Roseton Generating Striped bass 1 105 +/- 14 153 +/- 19 290 +/- 30 290 +/- 80 Station White perch 55 31 +/- 17 28 +/- 17 (River Mile 65) White perch 70 47 +/- 16 Brown bullhead 33 24 +/- 11 50 +/- 20 Perch 9 59 +/- 17 34 +/- 18 Catskill Region White perch 74 40 +/- 20 (River Miles 107 - 125) Brown bullhead 6 60 +/- 20 Sunfishes 23 48 +/- 18 Carp 2 16 +/- 7.0 19 +/- 9.0 Perch 17 21 +/- 18 <20 50 +/- 30 14
Table 5: Comparison of 90Sr concentrations in bone and edible flesh of fish.
Concentration Ratio State/Site Location Species n Reference Bone Edible flesh bone:flesh South Carolina/ Pond B Largemouth bass 28 ~ 14.5 Bq/g ash 0.47 Bq/g dm1 31 Whicker et al. 1990 USDOE Savannah Yellow bullhead 28 ~ 13 0.086 151 River Plant New York/ Cattaraugus Cr. NYSDEC 1971 Nuclear Fuel Services, - Rt. 16 bridge Suckers nr2 228 pCi/kg 82 pCi/kg 2.8 Inc.
- Springville Dam Suckers nr 10491 1679 6.2 Suckers nr 31000 500 62
- mouth (Sunset Bay) Rainbow trout nr 127 3 42 Carp nr 606 23 26 Suckers nr 9587 8 1198 Salmon nr 173 246 0.7 New York/ Buttermilk Cr. Trout nr 320,000 pCi/kg 5400 pCi/kg 59 NYSDEC 1971 Nuclear Fuel Services, - at Bond Road Suckers nr 620,000 12,000 52 Inc. Suckers nr 89,537 14,456 6.2 New York Lake Ontario Bass nr 1410 pCi/kg < DL nc4 NYSDEC 1971
- at Brockwood Bluegill nr 312 62 pCi/kg 5.0 (Wayne County) Bullhead nr 330 24 14 Sunfish nr 89 17 5.3 Perch nr 3516 40 88 Sucker nr 497 15 33 Black crappie nr 671 < DL3 nc Perch nr 271 29 9.3 Largemouth bass nr 408 10 41 Rock bass nr 270 25 11 Silver bass nr 485 13 37 Carp nr 898 15 60 New York/Indian Point Hudson River 5 species 5 204 <6 34 This study Nuclear Power Plant New York/Roseton Hudson River 4 species 5 204 <5 41 This study Generating Station New York Hudson River 5 species 5 240 <4 60 This study
- at Catskill 1 2 3 4 dm = dry mass. nr = Not reported. DL = Detection limit. nc = Not calculated; detection limit not reported.
15
Figure 1 16
17 18 19 20 21 22 23 24 25 26 27 28 29 30 Green, Kimberly Full Name: Julie Crocker Last Name: Crocker First Name: Julie Job
Title:
Fisheries Biologist Department: Protected Resources Division Company: NMFS Northeast Regional Office Business Address: 55 Great Republic Drive Gloucester, MA 01930 Business: 978-281-9300 x6530 Other Fax: 978-281-9394 E-mail: julie.crocker@noaa.gov E-mail Display As: Julie Crocker (julie.crocker@noaa.gov) 1