ML19319C190

Responds to AEC Requests for Comments on OL Application. Opposes CP Issuance Until Proper Assurances Received Re Water Quality,Fish & Wildlife.Forwards Diversion & Collection of Juvenile Fish W/Traveling Screens.

ML19319C190
Person / Time
Site:	Davis Besse
Issue date:	07/14/1970
From:	Meachum C INTERIOR, DEPT. OF, FISH & WILDLIFE SERVICE
To:	Price H US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML19319C189	List: ML19319C190 ML19319C191
References
NUDOCS 8001310599
Download: ML19319C190 (5)

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4 IN REPLY REFER Tor UNITED STATES Y* W- J"* $ DEPARTMENT OF THE INTERIOR kG FISH AND WILDLIFE SERVICE

% WASHINGTON. D. C. 20240 JUL 141970 Mr. Harold L. Price

, Director of Regulation U.S. Atmic Energy Comission Washington, D.C. 20545

Dear Mr. Price:

This is in reply to Mr. Boyd's letters of August 20 and December 29, 1969, and March 10, April 24, and June 3, 1970, requesting our ec=ments on the application and amendments Nos.1, 2, 3, and 4 by the Toledo Edison Company and the Cleveland Electric Illuminating Company for a construction permit for the proposed Davis-Besse Nuclear Power Station, Ottawa County, Ohio, AEC Docket No. 50-3h6.

The project would be constructed on a 900-acre tract of land on the

, southwest shore of Lake Erie about 65 miles west of Cleveland, and would use a pressurized water reactor designed for an ultimate outpt of 2,772 MWT(906 MWE). Condenser cooling water would be pumped through an intake structure from Lake Erie, passed over the condensers, and discharged back into the lake. We understand that the design criteria for the condenser cooling water system have not yet been developed and that the applicants are preparing a report on alternative methods of dissipating waste heat.

Radioactive wastes would be disposed of through a system designed to pro-vide controlled handling of liquid, gaseous, and solid radioactive vastes resulting frca plant operations.

The west 2rn Lake Erie marshes are a pivotal point for migrating water-fowl and the project area accommodates most of the waterfcwl species common to the Lake Erie region. The lake adjacent to the plant site supports a variety of game and foodfish species and has been an active sport fishing area.

The preservation and enhancement of the quality of our environment is a prima y concern of the Fish and Wildlife Service. A proper concern i

for the environ =ent requires that particular attention be given to fish I and wildlife resources durirg the construction and operational phases of a nuclear power facility. This is expr_ssed in the National  ;

Envircnmental Policy Act of 1969 '

I The applicantsindicate that the release of radioactive wastes would ,

not exceed maximum permissible concentrations prescribed in title 10, part 20, of the Code of Federal Regulations, which are considered ad-equate to safeguard man frm undue radiation exposure. However, the P 22Gu I

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W radiosensitivity of fish and wildlife organisms is poorly understood and acceptable radiation dose rates and body burdens for fish and wildlife have not been established. Pending such establishment, the applicant should conduct a radiological monitoring program to detect possible radiation buildup in the environment.

We are concerned that the discharge of heated, chemically treated water into Lake Erie may place undue biological stress on the local environ-ment. The cooling water system also poses a potential hazard to the fish resources of the lake. A substantial number of organisms may be attracted to or drawn into the intake structure with the water and de-stroyed. (Remedies for these situations are discussed in an appendix to this report.)

Therefore, we oppose the issuance of a construction permit for this project until the applicants provide the Commission with assurance satisfactory to the Secretar/ of the Interior that the project will be constructed and operated in a manner which will neither reduce the water quality of Lake Erie nor create adverse effects on fish and wildlife re-sources. This assurance should describe specific measures such as cool-ing towers or cooling ponds which the applicants plan to include in the plant structure to prevent harmful effects on fish and wildlife frce the discharge of heated water into the lake. It should also describe specific measures, such as a traveling screen, which will be installed in the plant to protect aquatic organisms of the lake from de struction by being drawn into the plant with the cooling water. We understand that such measures can be installed during plant construction at a substantially lower cost than after the plant has been completed.

Sincerely yours, e' [ -

Corr:issioner Attachment 4

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1 APPENDIX TO FISH AND WILDLIFE SERVICE REPORT ON THE APPLICATION FOR A CONSTRUCTION PERMIT FOR THE DAVIS-BESSE NUCLEAR POWER STATION, AEC DOCKET NO. 50-346 Lake Erie adjacent to the plant site supports a variety of game and foodfish species including freshwater drum, white bass, yellow perch, channel catfish, carp, gizzard shad, alewife, goldfish, and walleye.

The western Lake Eric marshes are a pivotal point for migrating water-fowl. Segments of the Mississippi and Atlantic flyvay populations separate in the vicinity of the marshes on their southward fall migra-tions and rejoin in their northward spring flights. The project area accommodates most species of waterfowl common to the Lake Erie region.

Several thousand Canada Geese and coots use the marshes and open water.

Mergansers and whistling swans use the adjacent lake and shoreline ponds.

In addition, approximately 250 species of birds have been observed, in-cluding the endangered bald eagle. Resident m - 1s include cottontail rabbit, muskrat, squirrel, woodchuck, raccoon, weasel, fox, and occasion-ally white-tailed deer.

The region in the vicinity of the project site has been an active hunt-ing, trapping, and sport fishing area. Construction and operation of the nuclear powerplant facility will curtail these activities.

About one-half of the 900-acre project site is marshland acquired by the applicants from the Bureau of Sport Fisheries and Wildlife. Under an agreement between the two parties the unused marsh areas will be leased back to the Bureau for management under the Ottawa National Wildlife Refuge program. The upland area is now farmland and will continue to be farmed after the station is built. There will be no domestic residence and no activities other than leased farming and management of the marsh-lands when the facility becomes operational.

While the project has the potential of having a significant adverse im-pact on area ecology, we believe that by careful design of the condenser cooling water system major difficulties can be avoided. The use of large volumes of lake water for cooling purposes may have a significant effect on local fish populations as fish eggs and larvae, and fish food organisms may become entrained in the cooling water and destroyed. It may be appro-priate to consider the installation of a horizontal traveling screen at the cooling water inthke structure similrr in design to the one the Fish and Wildlife Servide proposes for the Leaburg hydroelectric powerplant intake canal at Eugene, Oregon. This plant has been licensed by the Federal Power Commission. A report describing this screen is included st the end of this appendix.

The discharge of large volumes of chemically treated, heated water into the lake may have significant adverse effects on fish and wildlife re-sources. The walleye population has been low during recent years in the ae b $m. b U

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western basin of Lake Erie. It is important that existing high quality spawning areas some ten miles offshore from the project site be preserved.

Though prevailing west to east currents usually carry the heated water eastward along the shore away from the spawning reefs, it is possible that one or more instantaneous 4 to 50 F. temperature fluctuations across the reefs might be exerted upon fish during the critical April-May period of egg development, spawning, and hatching.

Measures must be taken to avoid this situation.

Extensive algae blooms occurred in the western basin of Lake Erie during August and September 1969 Heavy growths of a least two types, Microcystis and Aphanozomanon, were e,pparent. Although blooms have occurred for de-cades, they were never as extensive as those observed in 1969 We are concerned that the plant's heated effluent may aggravate the algal prob-lem in the vicinity of the project site.

In addition, increased lake temperatures in the late fall and winter may result in attracting and holding a substantial number of waterfowl in the project area, which otherwise would have migrated southward, thereby endangering the lives of these birds when the weather becomes severe and the food supply is diminished. To protect the fish and wildlife resources of the area, it may be necessary to install some fonn of cooling facility to reduce the temperature of the plant's thermal effluent. The results of pre-operational and post-operational environmental monitoring should be used in determining the need for further project modification.

We understand that the applicants plan to conduct a comprehensive environ-mental survey of the lake beginning 15 months before reactor operation

, and that limnological research is being conducted by the University of Michigan's Great Lakes Research Division which includes studies of radio-nuclide concentrations at various trophic levels in the aquatic environ, ment. We further understand that currently fish populations, plankton, and benthic organisms are being sampled and studied under Ohio's Federal <

Aid to Fisheries Project F 41-R, "EnWanmental Evaluation of a Nuclear Power Plant."

In addition to the above-mentioned studies, we believe that plant operations present a unique opportunity to study mineral ecology in a marsh environ-ment and the effects of radionuclides and temperature on marsh physiology.

Intensive studies of marsh radioecology would greatly increase our know-ledge of the distribution of nuclear powerplant radioactive wastes en-abling the Service to better insure the safety of fish and wildlife re-sources. We propose that the applicants engage'in a joint effort with the Ohio State University, the USPHS Radiological Training Center, and the Service in a study and analysis of marsh radioecology.

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The applicants have stated that they will cooperate fully with the Fish and Wildlife Service, the State, and local authorities in developing and carrying out a program for the protection and preservation fish and wild-life resources, the natural terrestrial and aquatic environment, and asr.ociated recreational pursuit.

Nevertheless, we recommend that the Toledo Edison Company and the Cleveland Electric Illuminating Company:

1. Continue to cooperate with the Fish and Wildlife Service, the Federal Water Quality Administration, and other interested State and Federal agencies in the development of planned radio-logical and ecological monitoring programs.

2. Conduct pre-operational radiological and ecological surreys developed in cooperation with the above-named agencies. Prepare a report of these surveys, and provide six copies of each to the Secretar/ of the Interior for evaluation prior to project operation.

3 Meet with the above-named agencies at frequent intervals to discuss any new or modified plans and the progress of the ecologi-cal and radiological surveys.

4 Conduct post-operational radiological and ecological surveys in accordance with plans developed under recommendation 1 and as may be modified under 3 above. Prepare reports annually or until it has been conclusively demonstrated that no significant adverse conditions exist, and submit six copies of these reports to the Secretary of the Interior for evaluation. j

5. Make such modifications in project structures and operations, i including facilities for cooling discharge waters and protective

1. screening devices, as may be necessary to protect the fish and 1 wildlife resources of the area. {

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