ML18094B121

Discusses Biological Assessment of Impacts on Marine Turtles Per Util June 1989 Rept,Per NRC Telcon Notifying State of Rept.State Initiated Discussions W/Util Last Summer to Reduce Mortality of Turtles Impinged at Plant

ML18094B121
Person / Time
Site:	Salem
Issue date:	10/05/1989
From:	Oberthaler R NEW JERSEY, STATE OF
To:	Stone J NRC
References
NUDOCS 8910180301
Download: ML18094B121 (5)

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DEPARTMENT OF ENVIRONMENTAL PROTECTION DIVISION OF WATER RESOURCES CN029 Eric J. Evenson Trenton, N.J. 08625-0029 (609) 292-1637 Acting Director Fax# (609) 984-7938 Mr. James C. Stone, Licensing Project Manager United States Nuclear Regulatory Commission OCT 5 1989.*

Mail Stop 14E21 Washington, DoC. 20555

Dear Mr. Stone:

Re: Biological Assessment of Impacts on Marine Turtles, Salem Nuclear Generating Station 1 Public Service Electric and Gas Company, NJPDES No. NJ0005550 Thank you for telephoning Mr. Delgado to alert the Division of Water Resources of the existence of Public Service Electric and Gas Company's (PSE&G) June 1989 Biological Assessment Report

("Assessment of the Impacts of the Salem and Hope Creek Generating Stations on Kemp's Ridley (Lepidochelys kempi) and Loggerhead (Caretta caretta) Sea Turtles").

Background

The Division of Water Resources accepted delegation of the National Pollutant Discharge Elimination System permit program in April 1982 from the U.S. Environmental Protection Agency, Region II. As a result of the program delegation, among other things, the Division is responsible for reviewing demonstrations submitted by PSE&G to request a thermal effluent limitation variance and to support PSE&G's position that the cooling water intakes conform to the requirements of Section 316 of the Federal Clean Water Act. Section 316 deals with thermal discharges and cooling water intake structures. A final decision pertaining to this matter has not yet been made.

\.)

Last summer we initiated discussions with PSE&G in an attempt to reduce the mortality of marine turtles impinged at the Salem Nuclear Generating Station. These discussions are summarized in an August 10, 1988 letter to Mr. James Shissias of PSE&G (copy enclosed). Our discussions focused upon interim or operational procedures which could be implemented quickly without the large magnitude of expenses associated with capital facilities, such as recirculating . cooling towers or wedge wire screens. Also enclosed is a copy of PSE&G' s September 8, 1988 response which New Jersey is an Equal Opportunity Employer

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indicates that recommended interim measures to reduce sea turtle mortality would be considered during the review process.

Area of Evaluation The June 1989 report assesses loss of marine turtles upon the Southeast U.S. population (for Loggerhead turtles) or upon the world (Atlantic Ocean/Gulf of Mexico) population (for Kemp's Ridley turtles). The report does not assess loss upon populations in the Delaware Bay. Given the known keen navigational abilities of marine turtles, it is possible that a sub population (s) of turtles migrates to the Delaware Bay. To be conservative, it would appear appropriate to also assess the effect of the Salem Nuclear Generating Station loss upon summer resident populations within Delaware Bay.

Interim Measures to Reduce Marine Turtle Mortality Section 7 and Appendix B of the report discuss the operation of the Salem Nuclear Generating Station intakes. The report does not indicate which of the measures suggested in the August 10, 1988 letter have been implemented, partially implemented, and/or rejected. PSE&G should be requested to implement the following:

1. During periods when marine turtles are likely to be impinged, trash rack cleaning should be initiated early in the morning. Until more information is obtained as to when turtles are initially impinged, trash rack cleaning should be initiated at 7 am, at least during the months of June, July, August, and September.

2. As it is possible that turtles may become impinged at times other than early morning, PSE&G should increase the cleaning frequency (i.e., that minimum cleaning frequency be increased to twice daily-at least once in the morning and once in the afternoon) regardless of trash load from July through September. It is understood that the racks are now cleaned only at the beginning of the "first shift" and if water stage (elevation of water surface) differentials between the front and back of the trash racks become excessive.

3. PSE&G employees at SNGS who might encounter an impinged sea turtle are annually issued a handout which includes pictures or drawings of threatened/endangered species which may be encountered/impinged (including marine turtles) and phone numbers of responsible parties to be called in the event of an impingement. Timely issuance of such annual instructions is to be continued. PSE&G should also conspicuously post appropriate instructions in the vicinity of the trash racks. In addition, PSE&G should train and periodically retrain all employees likely to encounter an impinged marine turtle in techniques of sea turtle resuscitation.

4. PSE&G personnel should be requested to frequently observe the intakes (at least once per hour). Given existing lighting conditions, it appears extremely difficult to note impinged turtles at the water surface during non-daylight hours. Therefore, we emphasize the critic al nature of observations made around sunset and sunrise; a thorough inspection should be conducted to try to note impinged turtles at such times. Lighting may be an area for further improvement. Any lighting improvements, however, should be designed so as to not significantly increase the number of organisms drawn toward the intakes.

5. On July 12, 1988, PSE&G personnel found two impinged marine turtles as well as heavy trash loadings on the trash racks. Additional personnel were requested and assigned to assist in continuing the cleaning of the circulating water system intake trash racks in a manner faster than possible with normal personnel assignments. Two additional impinged marine turtles discovered after the arrival of the additional personnel were removed dead. Assignment of additional personnel to trash rack cleaning under similar circumstances is necessary as it may permit more timely removal of impinged turtles, decreasing the probability of mortality.

6. Dip nets or other equipment which could remove smaller marine turtles without the trauma which may be induced by the trash rack cleaning mechanism were not in evidence during a 1988 site visit. Such suitable equipment should be provided in a manner convenient to personnel observing/cleaning the trash racks. Obviously, the cleaning mechanism was not designed primarily to handle turtles gently. Injury could result from shear along the face of the trash rack and from being dropped into the debris bucket. On a more long term basis, PSE&G may also be able to modify this mechanism to reduce such trauma.

7. PSE&G appears to be following guidelines for sea turtle resuscitation advocated by the National Marine Fisheries Service (NMFS) for use by commercial fisherman, especially in the southeast U.S. These procedures include turning a comatose turtle on its back (carapace) and pumping its plastron (belly) by hand or foot. If pumping the plastron several times produces no apparent results, PSE&G personnel apparently implement the following:

A. Place the turtle on its plastron.

B. Prop up the rear end of the turtle (several inches, higher up with larger turtles) .

C. Keep the turtle shaded and wet or moist.

(Observations on July 15, 1988 suggest procedure for the latter leaves room for improvement.)

PSE&G should investigate the advisability of continuing active resuscitation efforts for more than the minute or so apparently now used for apparently lifeless sea turtles which are not obviously beyond resuscitation.

8. In addition to the above, PSE&G should also statistically study turtle impingement correlation with factors which may help predict when marine turtle impingement is most likely.

9. Finally, marine turtles removed from the cooling water intake structures should be monitored closely so that appropriate action is taken if condition deteriorates following removal. Such deterioration may result from stress during impingement and/or from trauma associated with removal from the intake. Action which may be needed would include preventing a turtle which loses consciounsness from drowning and/or initiating resuscitation if indicated by loss of vital signs.

It appears that PSE&G has partially implemented the above. Such partial implementation, including early cleaning of the circulating water system intake and improved intake observation, may be why four (4) of the five (5) marine turtles impinged in July and the first half of August 1989 survived. It is our opinion that the remaining items would be both relatively low in cost and effective in further reducing mortality by reducing the length of time which could pass between initial impingement and removal from the intake and initiation of resuscitation efforts, if appropriate.

Appropriate Regulatory Agency Action The primary conclusion drawn by PSE&G in the June 1989 report is that operation of the Salem Nuclear Generating Station does not appreciably reduce the likelihood of survival and recovery of marine turtles.

While the annual loss of marine turtles appears to be a small percentage of the total of the animal populations in question, we must view any loss of marine turtles, especially loss of the severely endangered Kemp's ridley, as being important. Clearly the Federal Endangered Species Act, in Section 2, mandates the Nuclear Regulatory Commission to use its authority to conserve endangered and threatened species and to conserve the ecosystems upon which these species depend. Therefore, PSE&G should be required to reduce loss of endangered and threatened marine turtles to the maximum extent practicable (i.e., to the greatest extent possible with reasonable and prudent alternatives), and should reasonably mitigate any unavoidable loss.

The Division of Water Resources would also appreciate your keeping us informed of developments in this matter so as to have the opportunity to participate in subsequent actions.

We have also advised other agencies of the existence of the June 1989 report. Agencies which we believe have an interest in this matter include:

Delaware River Basin Commission New Jersey Division of Fish, Game and Wildlife U.S. Fish and Wildlife Service (Delaware Fisheries Cooperative Program)

Delaware Department of Natural Resources &

Environmental Control Given our somewhat late notification of the above, it is our expectation that they will not comment at this time.

If you would like to discuss this matter further, you may contact Mr. Richard R. Delagdo at (609) 292-4860.

rely,

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t Oberthaler, Chief Bureau of Industrial Discharge Permits WFM14:CDG Enclosure