ML19256E149

Discusses Mi Water Resources Commission 790802 Ltr Approving,W/Mods,Study Plan for Evaluating Impingement & Entrainment of Aquatic Organisms at Plant Makeup Cooling Water Intake

ML19256E149
Person / Time
Site:	Fermi
Issue date:	10/17/1979
From:	Courchaine R MICHIGAN, STATE OF
To:	Ballard R Office of Nuclear Reactor Regulation
References
NUDOCS 7910290305
Download: ML19256E149 (3)

Text

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STATE OF MICHIGAN NATURAL REsovRCES wMisslON WATER RESOURCES COMMISS4ON CARL T. JOHNSON -

PATRICIA M. CAYEMBERG E M 'A'TALA WILLIAM G. MILLIKEN, Governor MAX N. CLYDE DEAN PRIDGEON THOMAS C. HOOGERHYDE M'Laar F.$NELL HARRY H. WHITELEY DEPARTMENT OF NATURAL RESOURCES c'5^ *

• E 'av STANLEY OUACMENSU$H JOAN L WCLFE STEVENS T. MASON BUILDING. Box 30028, LANSING. MICHIGAN 48909 HOWARD A TANNER CHARLES G. YOUNGLOVE HoWARD A. TANNER, Derector JOYCE P. VANKEULEN October 17, 1979 Mr. Ronald L. Ballard, Chief Environmental Projects Branch 1 Division of Site Safety and Analysis U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Ballard:

By letter (R. Cot chaine to P. Eisele) dated August 2,1979, the Michigan Water Resources Commission (WRC) approved, with modifications, a study plan for evaluating impingement and entrainment of aquatic organisms at the make-up cooling water intake of the Fermi II Nuclear Power Plant (Luna Pier, Lake Erie; Detroit Edison Company). Copies of the approval letter, the contingent modifications (F. dorvath to R. Courchaine; July 30, 1979) and the proposed study plan ("Enrico Fermi II . . . Entrainment and Impingement Study. . .", June 1979) are attached for your reference.

The study plan was developed after extensive consultation with U.S.

NRC. the Michigan Department of Hetural Resources IMDNR) 316 Review Committee, and Detroit Edise4 Compaay (DECO). Comments by U.S. NRC on the Deco proposed study plan (July 19, 1979 letter from R. Ballard to W. Turney, MDNR) were considered.

Your July 19, 1979, letter indicated that the DECO proposal was deficient since 1) no pre-operational testing was prescribed and the study focused only on entraigment and impingement during the start-up a7d operational phases and 2) because no far-field adult or larval fish census was intended, the biological significance of observed impiugement and entrainment could noe be assessed.

As you know, construction of Fermi II is nearly complete. The plant will use closed-cycle cooling with natural draft towers. Blowdown and makeup water will, therefore, be of low volume relative to a similar capacity plant with once-through cooling. The onshore surface makeup water intake structure is complete and utilizes standard and proven technology. Blowdown will be released through a shoreline surface discharge structure. From several years experience with operating power piants in the Great Lakes including the Western Basin of Lake Erie, we have learned that thermal discharges with similar volumes to Fermi II have insignificant water quality impacts. We, therefore, did not require extensive pre-operational or post-operational water quality studies or monitoring as you recommended.

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We are concerned, however, that the intake structure, even though the volume is low, may have significant impact's through impingement and entrainment induced mortality because of location and design. Power plants with surface onshore intakes from the Detroit River to east of Cleveland experience higa rates of impingement and entrainment. Because of these concerns we have required inte:e monitoring.

Since it is difficult, if not impossible, to precis:1y define the significance of impact through comparisons of source-water population data with intake data, and since a wealth of data on present populations in the lake are available, we have not required source-body fish population studies.

A noteworthy and informed use of yellow perch data has been presented in an analysis by Richard L. Pattersco University of Michigan. Dr.

Patterson mathematically modeled the impacts from power plant intake losses upon yellow perch standing ccops and the fishery of Western Lake Frie. The model used data generated at the DECO Monroe Power Plant during the mid-1970's, by MDNR in 1975 and 1976, and various other State and Federal groups. We believe that this analysis represents state-of-the-art knowledge of the dynamics of the yellow perch fishery, and that the data base for this and other species, derived from a basin-wide study, is superior to that data which could be derived within a se cm appropriate for a closed-cycle plant. These data are available for comparison purposes and for quantification of impingement ar ? entrai: ment impact by Fermi II. We therefore required as a condition of study plan approval that DECO consider these data in their production foregone analysis.

Since the impacts of intake operatic.1 cannot be measured prior to operation of the plant, the Phase I-Phase II study plan will not, and cannot, mot.itor the " pre-operational" period. The approved study plan requires monitoring prior to commercial operation but after commencement cf blowdown. This is the earliest that impingement and entrainment can be measured with confidence that the data would be representative of actual plant operation. A condition of the MDNR study plan approval requires that the Company collect physical and water quality data and relate these data (mathematically or through common sense) to impingement and entrainment rates to determine if lake or meteorological conditions affect these rates . Such a comparison will also elucidate whether blowdown recirculation is influencing rates of impingment and entrainment.

Through the National Pollutant Discharge Elimination System (NPDES) permit process, WRC intends to require intake structure modifications, or a change in the operating mode of the plant, if it is determined that the intake structure does not represent best available technology (by capacity, design, location, or construction) for minimizing adverse environmental impact. That decision will be made following analysis of intake performance data as outlined in the approved study plan.

In summary, the staff of the Water Resources Commission has concluded following their review of all information submitted, including your July 19, 1979 letter, that the approved study plan will provide those 1225 022

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data necessary to describe the impacts of the Fermi II plant on the aquatic bio:a in the .inity of the plant.

Sincerely, WATER RESOURCES COMMISSION Robert J. Cour ine Executive Secretary RJC/FH:cip 1225 023 O