ML11301A073
| ML11301A073 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/24/2011 |
| From: | Grout D E State of NH, Dept of Fish & Game |
| To: | Bladey C K Rulemaking, Directives, and Editing Branch |
| References | |
| 76FR47612 00012, NRC-2010-0206 | |
| Download: ML11301A073 (6) | |
Text
Page 1 of I As of: October 25, 2011 Received:
October 24, 2011 PUBLIC SUBMISSION PendingPost PUBLC SU MISSONTracking No. 80f5a480 Comments Due: October 26, 201 Submission Type: Web Docket: NRC-2010-0206 Notice of Receipt and Availability of Application for Renewal of Facility Operating License Comment On: NRC-2010-0206-0013 NextEra Energy Seabrook, LLC; Notice of Availability of Draft Supplement 46 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants and Public Meetings for the License Renewal of Seabrook Station, Unit 1 Document:
NRC-2010-0206-DRAFT-0022 Comment on FR Doc # 2011-19875 1... 1._3 Submitter Information
.-.Address: 225 Main Street Durham, NH, 03824,*'I Organization:
NH Fish & Game Department
,&)Government Agency Type: State CO General Comment Comment attached Attachments Ltr to NRC Seabrook Station relicensing2-2 Ltr to NRC Seabrook Station relicensing 1-2-/2/3-~. :3-Lu https://fdms.erulemaking.netlfdms-web-agency/component/contentstreamer?objectld=0900006480f5a48...
10/25/2011 IC New Hampshire Fish and Game Department HEADQUARTERS:
11 Hazen Drive, Concord, NH 03301-6500 www.WildNH.com (603) 271-3421 e-mail: info@wildlife.nh.gov FAX (603) 271-1438 TDD Access: Relay NH 1-800-735-2964 October 21, 2011 Cindy Bladey Chief, Rules, Announcements, and Directives Branch Division of Administrative Services Office of Administration Mail Stop: TWB-05-B0IM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Ms. Bladey,
The New Hampshire Fish and Game (NHF&G), Marine Fisheries Division has reviewed the subject document NUREG-1437-Supplemental 46 (NRC-2010-0206) and wants to comment on both multiple errors and omissions as well as one singular point that we consider of greatest importance.
This letter focuses on the single issue; that being what might be a measurable response by NextEra, Seabrook Station to mitigate NRC identified large cumulative impacts if the renewed operating license is to be issued. We will follow this communication with a more expansive letter of comment.The NRC staff, in their review of the total record of environmental study that encompasses the first two decades of Seabrook Station operation, identifies three large cumulative impacts and these three may require some level of mitigation or correction should the station operate for an additional 20 years. Specifically theses large impacts are near-station decreases in:-Winter Flounder-Rainbow Smelt and-Certain Kelp species The impact of Seabrook Station operation on the abundance of certain fish species identified in the document is something that NHF&G as the state agency responsible for the protection of our wildlife resources must take seriously.
The two species involved, Winter flounder and Rainbow smelt, are ones identified early on in the required environmental monitoring as species of special concern as they support both commercial and recreational fisheries in New Hampshire.
Winter flounder is a species targeted by mobile gear and fixed gear commercial fishers as well as it being a very popular target REGION 1 REGION 2 REGION 3 REGION 4 629B Main Street PO Box 417 225 Main Street 15 Ash Brook Court Lancaster, NH 03584-3612 New Hampton, NH 03256 Durham, NH 03824-4732 Keene, NH 03431 (603) 788-3164 (603) 744-5470 (603) 868-1095 (603) 352-9669 FAX (603) 788-4823 FAX (603) 744-6302 FAX (603) 868-3305 FAX (603) 352-8798 email: regl @wildlife.
nh.gov email: reg2@wildlife.nh.gov email: reg3@wildlife.nh.gov email: reg4@wildlife.
nh.gov species for recreational hook fishers and spearfishers.
Rainbow smelt supports an ice fishing activity enjoyed by our states recreational anglers. In addition, smelt are an important prey item for Atlantic cod, striped bass, bluefish and seals and are listed as a Species of Concern by the National Marine Fishery Service. The loss of these fish as a result of Seabrook Station by entrainment and impingement should be addressed and NHF&G has two mitigation ideas that deserve further consideration.
These are explained below: 1) NextEra could fund activities and projects that would reduce the point and non-point sources of nitrogen loading in the Great Bay Estuary System (GBES)watershed.
GBES has been identified as nitrogen impaired by NH Department of Environmental Services.
The increased levels of nitrogen have been identified as a potential cause of recent reductions in the abundance of eel grass in the GBES and eel grass is an important habitat for both juvenile winter flounder and rainbow smelt.Providing financial assistance to programs directed at reducing non-point sources of nitrogen and to municipal projects that reduce nitrogen input into GBES would be appropriate mitigation as it would improve conditions for growth and survival of eel grass that are important habitat for these species.2) NextEra Seabrook station could compensate businesses that rely on winter flounder catch for a portion of their annual income. Possible mechanisms for such mitigation could include providing a financial donation to the permit bank for XL Northeast Fisheries Sector Inc.. This permit bank is used to purchase federal fishing permits with quota for groundfish species including winter flounder.
The groundfish allocations (or quotas) associated with permits purchased by the permit bank would be distributed to members of New Hampshire's commercial groundfish sectors to help maintain the economic viability of the State's small boat commercial fishing fleet. In addition, some party and charter boat businesses in New Hampshire rely on winter flounder for a portion of their business.
Those businesses with documented historical winter flounder harvest via federal vessel trip reports could also be compensated.
Finally, NHF&G, Marine Fisheries Division believes the localized loss of certain kelp species (i.e. Laminaria digitata and Saccharina lattisima) has been accurately documented.
However, to suggest some form of mitigation for this seems to be of little importance because of the replacement of these species by other somewhat comparable kelps in the area (i.e. Agarum clathratum and Alaria esculenta).
These replacement kelps probably provide comparable ecological services in comparison to the loss of abundance of L. digitata and S. lattisima including habitat formation, primary productivity, and as forage for coastal herbivores.
This concludes our comment on the issue of NRC identified large impacts. Our letter with additional comments will follow. If there are questions on the matter covered herein please contact me.Yours truly, Douglas E. Grout Chief of Marine Fisheries Cc: Glenn Normandeau, Executive Director Carol Henderson, Environmental Review Coordinator K. Allen Brooks, NH Attorney Generals Office Thomas Burack, Commissioner NHDES
?New Hampshire Fish and Game Department.HEV ADQUARTERS:
11 Hazen Drive, Concord, NH 03301-6500 www.WildNH.com (603) 271-3421 e-mail: info@wildlife.nh.gov FAX (603) 271-1438 TDD Access: Relay NH 1-800-735-2964 October 24, 2011 Cindy Bladey Chief, Rules, Announcements, and Directives Branch Division of Administrative Services Office of Administration Mail Stop: TWB-05-BOIM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Ms. Bladey,
As indicated in our earlier communication to NRC relative to the Seabrook Station rel icensing document NUREG-1437 Supplement 46 (Docket ID NRC 2010-0206), New Hampshire Fish and Game, Marine Fisheries Division now offers the following specific comments: Section 1.7 Consultations-Comment- NRC fails to mention NHF&G as a state agency consulted in its review of the Seabrook Station Environmental Monitoring Program. NHF&G staff met with NRC at the station in the fall of 2010 and offered their opinion of the overall environmental study program and its findings.Page 1-8 Permits Comment- The Permit to Display Finfish and Invertebrates issued by NHF&G shows the number MFDO8 1. This permit expired at the end of 2008 and is reissued annually.
The current permit for this is MFD 1101.Section 2 Page 2-15 Re: NPDES temperature limits.Comment- The temperature limit is 5°F within 300 feet from the discharge.
This is measured at the surface and the 5'F is for a monthly average.p. 2-24 line 20-21 Comment- Peirce Island is the correct name.p.2-31 Misspell of M. octodecemspinosus
- p. 2-32 Misspell of C. maenas p. 2-41 Re: cunner/yellowtail Cunner/yellowtail eggs were lumped together because of uncertain differentiation between the two. It would be best not to express these two separated by a comma but with a slash.
- p. 2-48 line 7 Re: statement "Crane Pond hosts some spring- migrating waterfowl including woodcock, grouse and turkey." This is a curious and confusing characterization of the term waterfowl as the three birds mentioned are not considered waterfowl.
Section 4 Line 44 Comment- NHF&G has several times, urged more sampling of fish likely to be exposed to discharge waters. These comments have been communicated to the Station in letters detailing our review of the Annual Radiological Program Reports.4-66 Line 34 Misspell of Schiller Station Section 8 p. 8-9 Re: Cooling tower blowdown Comment- It should be mentioned that blowdown of hypersaline waters would alter the discharge plume dispersal.
NHF&G has expressed this negatively buoyant sinking plume concern at other New Hampshire power plants.p. 8-9 Lines 28-42 Re: Cooling tower terrestrial effects Comment- Natural draft cooling towers were reviewed in the initial Seabrook licensing and the putative effects on near-by apple orchids, vehicular traffic on Rte 1-95 and US 1 and a persistent cloud over Hampton Beach received attention.
This concludes our specific comment on Docket ID NRC 2010-0206.
If you have questions do not hesitate to contact me.Sincerely, Douglas E. Grout Chief of Marine Fisheries DEG/bws/jld Cc: Glenn Normandeau, Exec. Director Carol Henderson REGION 1 REGION 2 REGION 3 REGION 4 629B Main Street PO Box 417 225 Main Street 15 Ash Brook Court Lancaster, NH 03584-3612 New Hampton, NH 03256 Durham, NH 03824-4732 Keene, NH 03431 (603) 788-3164 (603) 744-5470 (603) 868-1095 (603) 352-9669 FAX (603) 788-4823 FAX (603) 744-6302 FAX (603) 868-3305 FAX (603) 352-8798 email: regl @wildlife.nh.gov email: reg2@wildlife.nh.gov email: reg3@wildlife.nh.gov email: reg4@wildlife.nh.gov