ML19317E850

Tech Spec 1.4,App B, Fish Impingement on Intake Screens & Entrainment of Fish Eggs & Larvae. Revision Should Include Meaningful Counting & Analysis Methods & Realistic Limit Number Based on Unit Time for Licensee Reporting

ML19317E850
Person / Time
Site:	Browns Ferry, Oconee
Issue date:	09/11/1974
From:	Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Jennifer Davis US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML19317E849	List: ML19317E848 ML19317E850 ML19317E853
References
NUDOCS 8001031022
Download: ML19317E850 (3)

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$Y 11Td!N J. G. Davis, Deputy Director for Pield Operationc, Directorate of Regulatory Operations, !!oadquarters tu:vISIO:t OF TECICTICAL SPECIFICATION, DUKU POUER COi!PAliY, OCO:IEE SITE Enclosed is a copy of Appendix B Technical Specification 1.4, FIS11 IrtPIt:CCr!CIO O!! IrrrAKR SCREntis AND E TrnAItatnic Or risti nGOS A!!D IAnvAn, of the Envirorcental Technical specifications for Oconao 1, 2 and 3.

This specification, as written,'is inadequato as shcwn by the following:

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In the first sentence of Item A, the count nado vookly by visual inspection from the intako structuro is alnost mean-ingicss nince one cannot so i ucll enough tnrough 50-60 foot of vator to nako a roanor.nble count.

2.

Por the count and anal, _;is conducted when scrcons aro pulled (second n:ntonco of Iten A), there is no tino interval shown.

Further, while this may bo tha bent nothod'for freque.nt counts, it in really a count nado of fish that arc on the ceroen when it in pulled out of the water and raicos tha question of how nany dead fish nero lont fron the ccreen during the pulling process.

3.

The quarterly underwater visual inspection (third sentenco of Iten A) appears to be the nost valid, but quarterly is too in-frequent we believo. Further, this nethod nay be nora tin,e-taking and laborious considering that there aro 24 of the

' npproximato 9' x 12' fired screens and a diver is required.

4.

The limit of 100 shown in the accond paragraph of Iten A is not related voll enough to tino. The licensco is pulling scrcons cvery tuo ticoks to'ncot an n'/L' om'abl Pmuckn Agency (EPA) requirement and is naking counts then, but our own specification chould better relate thn linit to time.

Since early July 1974, the licensco has bacn in the COG-3500 count range cvory tse ucchs when the screens are pulled. These aro being reported as required and since they c::cccd the linit of 100 by many factorc, we are naking public inforcation releas'es. Liconsea repro-sentatives have told us that the 100 linit uas usnd becauce due to g

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temperaturo ntratification, they did not c:<pect to con any impinged finh.

It la now apparent t' tat during the hot su:=or nonths the a::pected temperaturo stratification breaks down. U0 believe it likely that. the c:tconsivo counts will bo soon until the end of the hot voathor season.

O no havo told the licensee to purcuo the revici.on of this technical cpecification and us havo diccucced this with Dino Scalletti of

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Licensing who agress that the specification in very po'or in its procont for:a and says that he will contact the licensao about its

• e revinion. Based on our c:merie-:e in nattoro like this, wo, are concerned about prompt action and 2cosolution. Unless there is prompt action and resolution, we shall be forced to continue to receive reports of excessivo fish portalities and to nahe pross

- releasas as a result of this specification which is inadequato to a point of projecting a poor imago of tha ne-3ulatory process.

Wo roquent that you have socoono expedito the revision of thin technical cpecification. The revision should incledo a neaningful unthod for counting and analyaic and a realistic 1 Lit number biced on unit tino for licenceo reporting.

Mornan C.'Moceloy Director

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s c-Enclosuret As etnted

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' OM eet ive :

To detect r.nu qucntify (1) floh icpingement upoa' the lutake

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r;creena cud (2) entrcinnent of fich eggu cnd latvne in the cooling voter cycte;:.

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Fich inpinged upon the intake acrecnn of Oconec nuclear JhN ificcqj on:

Station ohn11 be identified to cpecies uhen ponsibic, counted, and the length cotfr.ated once cach t:ech by vicuc1 inspection.from the intake structure., A detailed umlycio of the fish impinged upon the intche acreens phall be conducted by specico, siv.c, and qucatity each tine a set of.cercena is pulled.

An underwater vicual inspection chall, be. carried out' quarterly to deternine the' cpecies and quantity of fish inpinged upon the intake The data co11ceted fron these studies chall be -

acreens.

recorded in tabular. form.

Any cignificcnt nortalitica 'of fich and in c11 cases, cny nortalitica that involve 100 or nor.e fich, shall be reported to the responsible-representatives of' t'ha South Carolina Uildlife and Marine Resources Departnant and to

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Region II; Directorate, of 1;cgulctory Operationn uithin 24 hourn of itc discovery. - A uritten. report concerning nny cignificcat floh nortalitica chall be oubmitted to

.AEC/ DOL w*. thin.10 days.

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The entrain: cat of fish eggo and larvae in the cooling.

unter cyste: chall be monitored biucekly (cVery other ucek) during the najor spawning period of April through July and an esticate unde of the totel number of fish cggs and larvac entrained and thdir curvival.

J If the quani.ity or type of fish, or their eggc o$- larvae, C.

in deternined to be of significance or to hava a signifi-cant detricental icpact on the propagation of fish of recreational inportcnce, then plans for corrective action j

uill be developed.

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Ennic:

The cpecified' study vill detcrcine the nortality of fich impinged upon the intcke screens and the numbers of fish eggc and Inrvce entrain :d in the coolidg.uater cycten re-culting from the operation,of Oconca Huclear Statica.

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