ML18094B122

Instructs Util to Implement Procedures to Reduce Mortality of Impinged Marine Turtles.Util Should Also Statistically Study Turtle Impingement Correlation W/Factors Which May Help Predict When Impingement Most Likely

ML18094B122
Person / Time
Site:	Salem
Issue date:	08/10/1988
From:	Cattaneo L NEW JERSEY, STATE OF
To:	Shissias J Public Service Enterprise Group
References
NUDOCS 8910190107
Download: ML18094B122 (4)

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&tate of Nrw Jlersru DEPARTMENT OF ENVIRONMENTAL PROTECTION DIVISION OF WATER RESOURCES CN 029 TRENTON, NEW JERSEY 08825 GEORGE G. McCANN, P.E. 01 RK C, HOFMAN, P.E.

DIRECTOR DEPUTY 01 RECTOR AUS 10 1988 Mr. James A. Shissias, General Manager CERTIFIED M..A.IL Environmental Affairs RETURN RECEIPT REQUESTED Public Service Electric and Gas Company P.O. Box 570

• Newark, New Jersey 07101

Dear Mr. Shissias:

Re: Interim measur~s to reduce mortality of marine turtles PSE&G Salem Nuclear Generating Station NJPDES No. NJ0005550 This letter is written to instruct PSE&G to implement procedures to reduce mortality of impinged marine turtles. Several of these procedures were discussed at a meeting held on July 15, 1988 between PSE&G and NJDEP personnel. In attendance at the meeting, held at Salem Nuclear Generating Station (SNGS) to discuss the problem of marine turtle impingement and mortality on the cooling water intake trash screens, were Charles Susino, Ken Strait, James Eggers (all PSE&G), David Jenkins (NJDEP, Division of Fish, Game and Wildlife, Endangered and Nongame Species),* Me~edith Lavery and Richard R. Delgado (NJDEP, Division of Water Resources, Thermal Discharge Program).

This meeting focused upon operational procedures which could, for the most part, be implemented quickly and do not entail the large magnitude of expenses associated with capital facilities, such as recirculating cooling towers, which would be effective in reducing impingement and entrainment loss (mortality) of many aquatic species (including marine turtles).

I Sea turtles commonly impinged at SNGS, the loggerhead C'i.I (Caretta caretta) and Kemp's ridley (Lepidochelys

' "":::i kempi) turtles, typically spend morning hours foraging for oruz

• ..-.oo.. horseshoe crabs and/or blue crabs. This may lead them to-the roo 00 vicinity of the trash racks at SNGS where these 0:11.n invertebrates may themselves be commonly impinged. The roo turtles may subsequently become impinged as a result of these r--::s:: foraging activities. As sea turtles are air breathing reptiles OU

-iO and cannot remain submerged for extena.ed periods of time,

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impinged, it is ~ssential that PSE&G make an effort to reduce the length.of .time which could pass between initial impingement and removal from the trash rack (and initiation of resuscitation efforts., if --,appropriate)

• It is PSE&G's responsibility to take effective measures to minimize the adverse environmental impa~t of your cooling water .

intakes (including drowning of threatened and endangered .

species)

• At a minimum, PSE&G should immediately institute the following interim.measures:

• 1. During periods when marine turtles *are l*ikely to be* -* * ** -*

impinged,. trash rack cleaning should be initiated earlier 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 i t 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 morni~g 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 pressure differentials between the front and back of

.the trash racks become too great. .*

3. It was.made known to us by James Eggers that PSE&G employees at SNGS who might encounter an impinged sea turtle are annually issued a handout that includes pictures or drawings of threatened/endangered species which may be encountered/impinged (including marine turtles), phone numbers of responsible pa~ties to be called in the event of an impingement, and emergency resuscitation techniques to be employed in the case of impingement of a seemingly comatose-turtle. 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.

4. Mr. Eggers also indicated that appropriate PSE&G personnel have been requested to frequently observe the int.akes and that he understood such visual inspection is conducted at least once per hour. This effort should continue.

Given existing lighting conditions, it appears extremely difficult to note impinged turtles (at the water surface) during non-daylight hours. Therefore, we emphasize the critical nature of observations made around sunset and sunrise, a thorough inspection s11.ould be conducted to try to note impinged turtles at such~times. (Lighting may be an area for further improvement. Any lighting

v' improvements, however, should be designed so as to not significantly increase the number of organisms drawn toward.

the intakes.)

S. Mr. Eggers indicated that on July 12, 1988, PSE&G personnel found 2 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 clea.ning 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.

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 fishermen (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 1£, 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 appa~ently now used for apparently lifeless sea turtles which are not obviously beyond resuscitation.

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

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other things, *correlation with river flow, intake salinity, temperature, and phase of the moon (which affects tides and the movement of species which turtles may utilize for prey) , and combinations of the above variables should be studied.

On a substantially longer term basis, it may also be appropriate to conduct scientific studies of sea turtles which may become involved with your intake. (Additional agencies, such as NMFS, may need to be consulted if such studies are to be conducted. )

In conclusion, PSE&G should investigate and implement earlier and more frequent trash rack cleaning in an effort to reduce mortality (drowning) of impinged marine turtles listed as*

threatened and endangered species.

Failure by PSE&G to institute the interim measures above will result in further action by the Department.

Should you wish to discuss this matter further, plea~e _call Richard R. Delgado, Project Manager of the Thermal Discharge Program.* .He may be: reached at (609) 292-4860.

Sincerely, .

~~y/r:~.E.

AcFi;;fg Assistant Director Wa ewater Facilities Management Element WFM14:CDG c: Douglas Beach Bob Schoelkopf David Jenkins Charles A. Susino

,Joe Miller Mark Blosser Roy Miller Larry Niles Bruce Freeman Clifford Day

.Stanley Gorski Pat* Harvey Donald Fischer Kenneth Strait Richard Albert bee. fY\, w; Iv~ 'L B- C:c~\.. 1~

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