ML18282A169
| ML18282A169 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/09/2018 |
| From: | McCorkle R US Dept of Interior, Fish & Wildlife Service |
| To: | May Ma Office of Administration |
| References | |
| 83FR45692 00003, NRC-2018-0130 | |
| Download: ML18282A169 (9) | |
Text
PUBLIC SUBMISSION As of: 10/9/18 11:06 AM Received:
October 09, 2018 Status: Pending_Post Tracking No.
1k2-95vp-h2ma Comments Due:
October 10, 2018
Submission Type:
Web Docket: NRC-2018-0130Exelon Generation Company, LLC; Peach Bottom Atomic Power Station Units 2 and 3 Comment On:
NRC-2018-0130-0003Exelon Generation Company, LLC; Peach Bottom Atomic Power Station, Units 2 and 3Document:
NRC-2018-0130-DRAFT-0003 Comment on FR Doc # 2018-19462 Submitter InformationName: Richard McCorkleAddress: U.S. Fish & Wildlife Service
110 Radnor Road, Suite 101
State College, PA, 16801Email: richard_mccorkle@fws.gov General CommentPlease see uploaded comment letter from USFWS.
Attachments Peach_Bottom_NRC_scoping_comments final 1 United States Department of the Interior FISH AND WILDLIFE SERVICE Pennsylvania Field Office 110 Radnor Road, Suite 101 State College, Pennsylvania 16801-4850 October 9, 2018 May Ma Office of Administration Mail Stop TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Docket Nos. 50-277 and 50-278; NRC-2018-0130; Exelon Generation Company, LLC; Notice of Intent to prepare an Environmental Impact Statement and Conduct Scoping Process for Peach Bottom Atomic Power Station, Units 2 and 3 (EPID NO. L-2018-RNW-0013).
Dear Chief Ma:
The U.S. Fish and Wildlife Service (Service) has reviewed the September 10, 2018 NOTICE OF INTENT TO PREPARE AN ENVIRONMENTAL IMPACT STATEMENT AND CONDUCT SCOPING PROCESS FOR PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 (EPID NO. L-2018-RNW-0013). Exelon Generation Company, LLC (Applicant) has applied for Subsequent Renewed Operating Licenses for Units 2 and 3 of the Peach Bottom Atomic Power Station (PBAPS) in Peach Bottom Township, York County, and Drumore and Fulton Townships, Lancaster County, Pennsylvania. The PBAPS is located on the west shore of the Conowingo Pond at the mouth of Rock Run Creek. The Conowingo Pond is formed by the backwater of the Conowingo Dam on the lower Susquehanna River. The Applicant is requesting that the Nuclear Regulatory Commission renew the operating terms for the two units by 20 years beyond the current license expiration dates. In addition to continuing operation and maintenance activities, nuclear power plants may conduct refurbishment activities to support extended operation during the license renewal term. Refurbishment is not anticipated for PBAPS. No other plant modifications to support extended operations that could directly affect the environment or plant effluents are planned. The following comments are provided pursuant to the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.) and the Endangered Species Act of 1973 (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.). The Service has focused its review and comments on the issues of (1) impingement of fish on cooling water intake structure screens, (2) possible thermal impacts to fish and macroinvertebrate communities, (3) effects of the PBAPS discharge on dissolved oxygen and possible associated impacts to fish, and (4) potential effects to federally listed threatened and endangered species.
2 For the first three issues referenced above, the Applicant has concluded that environmental impacts over the Second License Renewal term would be SMALL. The Service does not agree with these conclusions, as discussed in the following comments. Fish Impingement at Cooling Water Intake Screens (Section 4.6.2.1 in AEnvironmental Report) Chesapeake Logperch: The calculated annual impingement (trapping fish against screens) at the PBAPS outer intake is 221,421 fish (URS and Normandeau 2008). Neither the inner structure nor the outer structure has a fish handling system, the result being 100 percent impingement mortality (IM) for fish that are impinged at the facility The Chesapeake logperch (Percina bimaculata), a species that is listed as threatened in Maryland and Pennsylvania and is currently under review for possible Federal listing under the Endangered Species Act (ESA), is among the species that have been documented to be impinged on the Peach Bottom screens. To 2017, which established a new tool to engage landowners in voluntary conservation efforts to -risk species (and candidate species) before listing, or to preclude the need for listing, under the ESA1. Chesapeake logperch Conservation Actions recommended by the Pennsylvania Fish and Boat Commission (PFBC) include working with Federal and State government agencies to minimize impingement and entrainment (drawing fish, eggs, or larvae into power plant systems).2 Alternatives to the existing PBAPS CWIS and cooling approach should be explored in order to address Chesapeake logperch conservation. In their response to Exelon request for consultation, the PFBC expressed concern about potential effects to Chesapeake logperch, but they stated that they intend to address impingement and entrainment concerns during the National Pollution Discharge Elimination System (NPDES) permit renewal process. Anadromous Fish: The Service has been working with the Maryland Department of Natural Resources, PFBC, Pennsylvania Department of Environmental Protection, Susquehanna River Basin Commission, National Marine Fisheries Service, and the owners of hydroelectric facilities on the lower Susquehanna River to restore populations of migratory fish species including American shad (Alosa sapidissima). Although only a small number of American shad currently migrate through the Conowingo Pond, with annual totals at the Conowingo Dam East Fish Lift ranging between 6,992 and 16,608 from 2013 through 2018, the Service is concerned that IM impacts at the PBAPS CWIS could hinder these restoration efforts. Recent American shad annual IM estimates, based on sampling of screens during the period August 30, 2005 through November 16, 2006, adjusted for sub-sampling, gear efficiency (i.e., screen impingement efficiency) and 1 https://www.fws.gov/endangered/improving_ESA/prelisting-conservation.html 2 http://www.fishandboat.com/Resource/Documents/species-plan-chesapeake-logperch.pdf 3 days when there was no sampling, were 552 juveniles during the October to November outmigration and 77 adults during the spring spawning migration, for a total estimated annual IM of 629 American shad (URS and Normandeau 2008). More recently, during intake screen sampling at PBAPS, from November 2 to November 25, 2015, during which time there were 11 sampling events for each unit, 62 juvenile American shad were collected from the screens (Normandeau 2015). It is important to note, however, that this collection was based on sorting of only 20 percent of the debris removed from the screens and placed in dumpsters. Adjustments for sub-sampling and gear efficiency would result in a much larger estimate of impinged juvenile American shad. Because there are no efforts to enumerate emigrating juvenile American shad, the percentage of emigrating juveniles that are impinged at the PBAPS CWIS is unknown. However, given the many factors affecting the Susquehanna River American shad population, some of which may be hindering restoration efforts, it is important to identify all sources of mortality that can be controlled, and make every effort to address those factors. Observations of alosines (American shad, blueback herring, and alewife) in PBAPS impingement collections appear to be correlated with the abundance of alosines passed by fish lifts and the abundance of early life stage American shad stocked annually by the PFBC (URS and Normandeau 2008). If there is a correlation, then impingement numbers may increase for these species as their populations increase due to ongoing restoration efforts. Alosines exhibit schooling behavior, and there is the potential for a disproportionate IM impact on emigrating approach may be needed to reduce relative IM rates for these species. Section 4.6.2.1.1 of the Environmental Report presents results of earlier impingement studies. For impingement sampling results during the fall of 1999, it was concluded that the number of American shad impinged was very small compared to the number of fry and fingerlings stocked in the Susquehanna River and tributaries during the previous summer, and numbers of American shad and blueback herring impinged were very small compared to numbers of spawning adults captured and passed at Conowingo Dam in the spring of 1999, particularly considering the reproductive potential of these species. It was concluded that impingement losses were not sufficiently high to adversely affect Susquehanna River shad and river herring populations and did not represent a threat to ongoing restoration efforts. However, this impingement sampling was conducted at a time when the numbers of adult American shad and river herring entering the Conowingo project tailrace were an order of magnitude higher than numbers passing the Conowingo Dam in recent years. During the 2018 migration season, the number of American shad passed at the Conowingo East Fish Lift represented approximately 10% of the number of American shad passed in 1999. Although the final East Fish Lift passage report for 2018 is not yet available, daily reports for the 2018 season documented only 1 blueback herring passing the East Fish Lift, compared to 130,625 blueback herring passed in 1999. The situation for blueback herring and American shad has drastically changed since the 1999 study, and populations of both species are critically low. Recent documented impingement of either of these species at PBAPS should be viewed in this 4 context. Given the critical state of the populations of American shad and river herring in the Susquehanna River, any source of mortality is a concern and should be addressed. Therefore, the Service does not agree with the conclusion that the environmental impact of impingement over the Second License Renewal term would be SMALL. Exelon is not proposing any new technologies or operational changes to address IM because they argue that they have already achieved a significant reduction from the Calculation Baseline, primarily through installation of the outer intake. More specifically, the outer intake has reduced approach and through-screen velocities, and has flush alignment of screens with the shoreline with lateral fish escape passages. In addition, through flow is reduced by not operating all water pumps during late fall and winter months (i.e., less cooling needed in colder months), and by recirculating warm discharge water to the intake basins in the winter. There is also an air bubbler system in front of trash racks (although meant to prevent ice formation), which may encourage fish avoidance behavior. The outer intake structure was specifically designed and installed to prevent IM, based on studies of fish swim speeds. It was designed and installed to achieve an approach velocity of < 0.75 feet per second (fps; maximum velocity tolerated by the most sensitive species - e.g., young white crappie). Exelon also feels that the elimination of intake canals eliminated fish entrapment and therefore, the calculated credit, using only approach velocity, is likely underestimated. In addition, Exelon points to studies showing exponential increase in IM with increasing approach velocities above 1 fps, which means estimated IM at the inner intake would be underestimated, resulting in an underestimate of the efficacy of the outer screen. In recent inter-agency discussions, it was suggested that a closed-loop (i.e., recirculating) cooling system may be cost-prohibitive for a project the size of PBAPS. However, water withdrawal would be reduced by about 90 percent, as would impingement of fish and debris, and entrainment of fish eggs and larvae. Alternatives to a closed-loop cooling system include installation of a cylindrical wedge wire screen CWIS, to replace the existing traveling screens, which would remain submerged and drastically reduce IM, or installation of a fish handling system on the traveling screens, which would gently remove impinged fish, thus reducing IM. The existing traveling screens and maintenance of the screens result in 100 percent mortality of impinged fish. However, even with the addition of a fish handling system, there is no guarantee ,rican shad and other alosines. Regarding either the cylindrical wedge wire screen approach or a fish handling system, it is important to note that screens typically need to be replaced periodically. In the absence of closed-loop cooling, the Service supports a replacement of the traveling screens with a cylindrical wedge wire screen intake, or addition of a fish handling system. We also support requirements for the continued use of the helper cooling towers, according to the current schedule based on water temperature thresholds. Possible Thermal Impacts to Fish and Macroinvertebrate Communities (Section 4.6.2.2 of A The Service has identified a number of issues of concern for consideration in the scoping process. Fish community monitoring data suggest a possible thermal influence on fish populations. The Final Report for Post-EPU Thermal and Biological Monitoring, PBAS 5 (Thermal Monitoring Report; Normandeau and ERM 2017), concluded that non-native gizzard shad were collected in greater numbers at thermally-influenced monitoring stations than at non-thermal stations, including large numbers of individuals less than 100 mm, suggesting possible spawning activity near thermally affected areas or use of these areas as a thermal refuge. It is noted in the Thermal Monitoring Report that studies of gizzard shad die-offs due to cold water temperatures indicate that juveniles are more susceptible to winter die-offs than are adults. Electrofishing relative abundance of gizzard shad was much higher than historical observations, and the documented long-term increase corresponds with a long-term decrease in relative abundance of white crappie, suggesting negative thermal impacts to the balanced indigenous community. The large gizzard shad population also poses challenges to fish passage efforts and migratory fish population restoration efforts at lower Susquehanna River hydropower projects (e.g., Conowingo and Holtwood). The large numbers of gizzard shad that enter fish passage facilities can result in the exclusion of target species (i.e., American shad, river herring), or a reduction in the number of target species successfully entering fishways and passing these dams during migration. There are also concerns related to temperature differences between the Conowingo tailrace where fish enter the fishway, and water in the fishway that originates in Conowingo Pond. At times a significant temperature differential has been noted, and there is concern that higher temperatures in the fishway, due to elevated water temperature in Conowingo Pond, may deter fish from entering the fishway or cause them to fall back and return to the tailrace, resulting in reduced or delayed migration and associated reduction in spawning success. This issue has been documented at other fishways that are fed by impoundments with elevated or stratified water temperatures (e.g., Caudill et al. 2013). In terms of macroinvertebrate richness, according to results presented in the Thermal Monitoring Report, the one monitoring station that is clearly not affected by the Peach Bottom thermal plume had the lowest habitat score for macroinvertebrates, but nevertheless scored highest for all overall measures of macroinvertebrate community, suggesting possible detrimental thermal effects on the Conowingo Pond macroinvertebrate community (i.e., monitoring stations with higher habitat scores scored lower for number of macroinvertebrate species, presumably due to thermal impacts) (Normandeau and ERM 2017). Therefore, the Service does not agree with impacts to aquatic organisms in Conowingo Pond. Dissolved Oxygen (DO) (Section 4.6.2.2 of Appli period [August and September] needs to be protective of only juvenile/adult life stages of fish which can tolerate DO less than 5.0 mg/L for short periods of time without measurable negative In general, prolonged exposure to 4 mg/L causes acute mortality in many invertebrates and non-salmonid fish embryos (Gray et al. 2002). Severe production impairment of early-life-stage non-salmonid species occurs when oxygen falls below 4.5 mg/L (EPA 1986). A literature 6 review by Chamberlain et al. (1980) found that juvenile largemouth bass demonstrated reduced swimming speed at DO concentrations of less than 5.0 to 6.0 mg/L (temperature = 25 degrees C). Stewart et al. (1967) observed reduced growth of juvenile largemouth bass at 5.9 mg/L and lower concentrations, with significant growth reductions at concentrations below 5.5 mg/L. The Habitat Suitability Index Model for largemouth bass considers a DO concentration of 5 to 8 mg/L as providing a suitability of 80 percent during midsummer within pools or littoral areas, and a concentration of 8 mg/L as being optimal (suitability rating of 100 percent) (Stuber et al. 1982). Therefore, an optimal DO range for successful growth and reproduction in Conowingo Pond is likely greater than or equal to 7 mg/L for many target fish species, and the Service does in SMALL impacts to aquatic organisms in Conowingo Pond. Federal-Status Species (Section 3.6.1.4.1 of A In-scope transmission line right-of-way (ROW) maintenance for the two 500-kV generator tie lines between the main plant and the PBAPS substation includes periodic or as-needed controls such as herbicide application, mechanical clearing, hand clearing, pruning, and/or tree removal. Federal trust species that could be adversely affected by vegetation management are addressed below. Bog Turtle: The PBAPS falls within the range of the federally listed threatened bog turtle (Glyptemys [Clemmys] muhlenbergii). evaluate all wetlands within 300 feet of the project area. The survey was conducted in August, 2017. None of the five wetlands on site provide suitable habitat, and in a November 2, 2017 letter, the Service concurred with this habitat determination and concluded that relicensing of the for 2 years from the date of the letter. If the Phase 1 habitat assessment did not include all wetlands in all areas that may be directly or indirectly affected by future activities associated with continued operation of the PBAPS, the scope of the Phase 1 survey should be expanded to Field Office for review. Bald Eagle: The bald eagle (Haliaeetus leucocephalus) was removed from the Federal Endangered Species List on August 8, 2007, and is no longer protected under Section 7 of the ESA; however, bald eagles are still protected under the Bald and Golden Eagle Protection Act (16 U.S.C. 668-668d). As of 2015, there were three active bald eagle nests on or in the vicinity of the PBAPS site. Exelon Generation has submitted to the Service a signed Bald Eagle Project Screening Form indicating that all recommended avoidance measures will be followed for any future activities associated with continued operation of the PBAPS that could harm or disturb nesting eagles. As a reminder, if ROW maintenance activities or other activities that may disturb eagles are 7 undertaken in the future, the applicant should follow the Bald Eagle Management Guidelines 3 prior to commencement of work.
Indiana Bat:
The PBAPS project area falls within the range of the Indiana bat (Myotis sodalis), but not within a swarming buffer or within any known maternity roost buffer. However, as stated in the Environmental Report (Section 3.6.2.3.1), Indiana bats have been live-captured in summer in York County (Butchkoski 2010). Therefore, the Service recommends that any tree removal or pruning of large limbs be carried out between November 15 and March 31 in order to avoid potential adverse effects to this species during the summer roosting season. The applicant
activities to confirm that they will adhere to this time of year restriction.
Northern long-eared bat:
The PBAPS project area falls within the range of the northern long-eared bat (Myotis septentrionalis). However, the project is not located within 0.25 mile of a known northern long-eared bat hibernaculum or within 150 feet from a known, occupied maternity roost tree; therefore, any incidental take that may occur is not prohibited in accordance with the conservation rule (i.e., 4(d) rule) specific for this species.
More information on the northern long-eared bat and the 4(d) rule can be found at: http://www.fws.gov/midwest/endangered/mammals/nleb/. Additionally, when tree removal occurs throughout the northern long-eared bat range, and the project is authorized, funded, or carried out by a Federal agency, consultation under section 7 of the ESA is required.
The Service completed a nationwide biological opinion that fulfills this requirement, provided the conditions of the 4(d) rule are implemented.
More information about the programmatic consultation and the streamlined procedures to meet this requirement are detailed at: http://www.fws.gov/midwest/endangered/mammals/nleb/
.
Thank you for your consideration of these comments. If you have any questions regarding this matter, please contact Richard McCorkle of my staff at 814-234-4090.
Sincerely,
Sonja Jahrsdoerfer Project Leader Attachment (Literature Cited)
3 http://www.fws.gov/northeast/EcologicalServices/eagle.html
8 Literature Cited Butchkoski, E. 2010. Pennsylvania Game Commission Factsheet for the Indiana Bat, Myotis sodalist, Website: http://www.pgc.pa.gov/Wildlife/EndangeredandThreatened/Pages/IndianaBat.aspx February 10, 2010. Accessed October 4, 2018. Caudill, C.C., M.L. Keefer, T.S. Clabough, G.P. Naughton, B.J. Burke, and C.A. Peery. 2013. Indirect Effects of Impoundment on Migrating Fish: Temperature Gradients in Fish Ladders Slow Dam Passage by Adult Chinook Salmon and Steelhead. PLoS ONE 8(12): e85586. Doi:10.1371/journal.pone.0085586. Chamberlain, A.J., T. Kellar, and D. Maraldo. 1980. Water Quality Requirements for Sport Fishes of the Grand River Watershed: A Literature Review. Grand River Water Management Study Technical Report Series, Report # 13. Ontario Ministry of Natural Resources, Ontario, Canada. EPA. 1986. Quality Criteria for Water. EPA: 440/5-86-001. Gray, J.S., R.S. Wu, and Y.Y. Or. 2002. Effects of hypoxia and organic enrichment on the coastal marine environment. Mar Ecol Prog Ser 238: 249-279. Normandeau Associates, Inc., and ERM, Inc. 2017. Final report for post-EPU thermal and biological monitoring, Peach Bottom Atomic Power Station. Prepared for Exelon Generation. Normandeau Associates, Inc. 2015. Data Report on American Shad Sampling at Peach Bottom Atomic Power Station in 2015. Stewart, N.E., D.L. Shumway, and P. Doudoroff. 1967. Influence of oxygen concentration on the growth of juvenile largemouth bass. J. Fish. Res. Board Can. 24:475-494. Stuber, R.J., G. Gebhart, and O.E. Maughan. 1982. Habitat suitability index models: Largemouth bass. U.S. Dept. Int. Fish Wildl. Serv. FWS/OBS-82/10.16. 32 pp. URS Corporation and Normandeau Associates, Inc. 2008. 316(b) Compliance Report with Source Waterbody Information, Impingement Mortality Characterization Study, and Design and Construction Technology Plan for Peach Bottom Atomic Power Station, prepared by URS Corporation for Exelon.