ML19340A364

Discusses Doi Evaluation of Vols 1,2 & 3 of Environ Rept. Ref to Facility Impact on Coastal Environ & Supporting Data for Studies Omitted from Rept.Discharge of Heated Water Into Lagoon Should Be Discussed in Detail

ML19340A364
Person / Time
Site:	Crystal River
Issue date:	05/25/1972
From:	INTERIOR, DEPT. OF
To:	Muntzing L US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 8003250658
Download: ML19340A364 (14)

Text

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/s J,r AEC DISTRIBUTION FOR PART 50 DOCKET MATERIAL j (TEMPORARY FORM) CONTROL NO: 2876 2 1

ENVIRO FILE FROM: DATE OF DOC: DATE REC'D LTR MEMO RPT OTHER U. S. Department of Interior Washington D. C. 20240 99579 9 26 79 X TO: dRIC CC OTHER SENT AEC PDR V Mr. Muntzing SENT LOCAL PDR v )

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CLASS: R0P INFO INPUT NO CYS REC'D DOCKET NO:

2 50-302 DESCRIPTION: ENCLOSURES:

Ltr re: March 21 meeting..... furnishin6 Ltr dtd April 28, 1972 from the Bureau of comants on Enviro Report for Crystal EMEX Sport Fisheries & Wildlife to Florida River Unit 3, & trans the following: Power Corp.trans comments on proposed study of Thermal effects g g PLANT NAMES: Crystal River

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Dear Mr. Munt:

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Following the March 21 meeting of members of your staff, Environmental Protection Agency, National Marine Fisheries Service, and this Depart-ment, we have reviewed Florida Power Corporation's Environmental Report, Volumes 1, 2, and 3, concerning operation of Unit 3.

We find that significant omissions occur throughout the report regard-ing the impact of the project on the coastal environment. Supporting data from studies performed are not included. We have identified the most glaring deficiencies in the following comments.

Florida's present water quality criteria for temperature are general in nature, and the aegree of protection to aquatic life depends on the size and reasonableness of the mixing zone. No damage or harm to aquatic life outside the mixing zone is allowed. The size of an approved mixing zone for the Crystal River plant is not indicated.

It should be noted that new temperature criteria are under considera-tion by the State of Florida. These will likely be far more specific .

than present criteria.

It ic indicated on Inge V-25 that an average area of 900 acres will be  ;

incleded within a 5 F. incremental isotherm as a result of operation i of Units 1, 2, and 3. Based on temperature tolerance work in the I

literature, there appears te be ample reason to conclude that Unit 3 will cause damage to aquatic resources in the area outside The 54.

isotherm. However, projections of the area to be impacted ay Unit 3 I become academic in view of the proposed addition of Unit 4 at this i site. This addition will cause yet another significant increase in l the area impacted by the plume. It appears entirely leasonable that  !

the discussions of environmental effects and alternative cooling i

. methods should include recognition of Unit 4 as an additional incre-ment. This would provide a far more adequate basis for consideration of probable ultimate environmental impacts at the site by AEC when it begins preparation of its environmental impact statement for Unit 3 only.

It is recognized on page V-25 that cooling water may be withdrawn from the area' south and west of the intake canal. However, the effects of induced currents in the coastal environment, caused by l l

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, .s such withdrawals, are not adequately considered. Currents and tempera -

ture play a vital role as a stimulus or cue to larval fishes and crus-taceans that migrate seasonally to the coa.stal nursery areas. Thus, artificially induced currents may_ function as a stimulus to local populations. - If. this is the case, it would actively encourage entrainment and should be thoroughly evaluated as regards alternative design modifications which would tend to minimize the occurrence of

this_ phenomenon. The extent of this phenomenon would depend largely on the seasonal occurrence 9nd abundance. of larval and juvenile fishes and crustaceans. These are not adequately treated in the report. It j-should be noted that the dikes of the intake canal will not act as a

barrier to exclude fishes as is claimed on page XIII-19.

I In any comprehensive environmental evaluation, the effects of the spoil from channel construction extending 5 miles into the Gulf of 4

_ Mexico must be thoroughly evaluated, especially with regard to effects on normal near-shore current patterns. "

It appears to us that the information presented in support of the conclusion on page VIII-l that no significant effects will occur is hypothetical and conjectural for the following reacons. Page V-12

, states that quantitative data substantiating the significance of the impact of the original dredging and plant site construction are not available. Page V-81 states that an objective assessment of the impact of entrapment in the_ intake is difficult to obtain because of, among ot'r- things, the lack of realistic data concerning fish and macroinvertebrate populations in the area. The bulk, if not all, of the studies directed at other aspects of plant impact apparently were conducted after operation of the fossil plant commenced. Therefore, it appears logical to us that the ' significance or insignificance of the impact of plant operation on original conditions cannot be sub-t stantiated either. However, adequate studies of the aquatic eco-system will provide a baseline which would include present fossil plant _ effects. This would serve as a point of departure for evaluating the impact of the nuclear units.

Discharging heated water into what could be classified as an artifici-ally created lagoon should be discussed in more deteil and accompanied by supporting data. The planktonic organisms killed by heat, pressure, and/or injury from abrasion as they pass through the cooling system and the consequent sedimentation of organic matter to the floor of the receiving water is not adequately treated. Although the quantity of organic matter contained in irdividual planktonic orcanisms is low, the total mass that-will pass through the condensers into the receiving water is significant.

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S Dr. J. Kneeland McNulty of NMFS is preparing a brief report on the calculated volumes of water passing through the plant and the estim-ated amount of zooplankton killed. Preliminary calculations indicate that a volume of water equivalent to that of Crystal Bay now psses through the existing plant in about 24 days. With the addition of Units 3 and 4, the time will be only 8 days. Based on estimates of zooplankton density in the area, and assuning total kill after passage through the condensers, the dead organisms now accumulate at the rate of about'one cubic yard (0 7 ton) per day. With the nuclear units in operation the accumulation will be about three cubic yards (2.2 tons) per day. Calculations of the accumulation of dead phytoplankton have not been made. The often considerable mortality of plankton entrained in the plume, but not passing through the plant is ignored here, as it was in Section V of the applicant's report.

The effects Sf the sedimentation of organic matter to the floor of the receiving water and its consequent accumulation in this protected area should be thoroughly studied. If the so-called " loop reward"  ;

(Section XI) from the release of the component elements of organic l decay expresses itself in the manner encountered from treatment of domestic wastes, the mass of organic material thus produced will be several times greater than the original mass. This mass may not consist of desirable forms.

On the other hand, if the effects of the soluble nutrients released are indeed beneficial, will the benefits outweigh the benthic productivity lost through blanketing by dead organic material? How will the dissolved

- nutrients express themselves, and what assets or liabilities will accrue to the coastal environment? The concept of loop reward also ignores the fact that the nutrients represented by live planktonic organisms are directly available to consumers without going through death and breakdown.

Of major significance is the need to determine the percentage of the plankton loss represented by eggs and larval forms of fish, crabs, shrimp, mollusks and other larger forms of life.

The discussion in Section V assumes that the organisms entrained will l be replaced by others of the same generation carried in the water

that replaces that pumped through the condensers. The statement that

!' offshore plankton laden waters" will replenish the planktonic popula-tion, reduced as a result of pssing through the condensers, should be supported by data or referencad.

The behavior of heated condenser cooling water in the receiving waters is not adequately discussed (see page V-2h). No discussion of the anticipated effects of the " sinking plume" phenomenon on the benthic environment or its inhabitants is included.

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Section VII states that the additional heat discharged from Unit 3 will increase the effect of present discharges by a "small amount."

This appears to cenflict with Section V, which says that with Unit 3 in operation, the area covered by the 5 F. incremental isotherm will Le about 2 times that area for the existing plume.

A closed cycle system using cooling towers or spray ponds is not discussed in Section IX. Such a discussion should be included.

While cooling towers as part of a once-through system would t.11evi-ate thermal problems, they will not necessar$1; '.essen entrainment and impingement damages.

Section X ascribes a 40-year plant life to Unit 3 We recognize that for practical ard economic purposes, this is a logical term.

However, since power production is not likely to cease at this site, and capacity may well be increased, we think that it should be recognized that this plant c: its replacement is likely to exist at this site for the foreseeable future.

1 While Section X describes the 1cng-term productivity of the plant itself, it fails to discuss the cumulative and long-term effects of the plant on natural productivity of the area as required by the impact statement preparation guidelines of the Council on Environ-mental Quality. For example, the discussion of sport fishing in the discharge canal expresses productivity in terms of harvest only.

It fails to note that inducing fish to swim from one place to another I does not constitute biological productivity.

1 We also believe that Section X should discuas the plant's relationship i to trends of similar actions which would significantly affect ecologi- l l

cal interrelationships. In this case, the similar action would be the construction and operation of Unit 4 l

We de not agree that taxes paid by Florida Power Corporation must be '

recognized as a public benefit, unless public costs are also discussed.

As the applicant points out on page X-7, Crystal River Unit 3 is expected to stimulate real estate development, housing, and commercial development, and it has the potential of providing an influx of visitors.

All of these directly stimulated developments increase the need for roads, water and sewers, schools, police and fire protection, social and health services, etc. The statement fails to recognize the costs of these items. Furthermore, if the benefits and costs are evaluated on a service area basis, as described on page XIII-1, the taxes should not be included at all since the customers ultimately pay these taxes.

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_- The socio-econonic assessment of over one billion dollars as the total present value of benefits from the plant as expressed on page XIII-4, obviously did not recognize the potential adverse impact of the plant on natural resources. Until adequate environmental studies are con-ducted on which to base an assessment of the total environmental inmet of the plant, no adequate assessment of even the economic impacts of the plant on natural resources can be made, let alone the environ-mental losses.

We are attaching a copy of a letter of April 28, 1972, from the Bureau of Sport Fisheries and Wildlife to the Florida Power Corpora-tion, which transmits' comments on the proposed study of thermal effects at the Crystal River Power Plant. The Bureau thinks that the studies to date are not adequate to support valid conclusions for an environmental impact statement. Further, unless more adequate baseline data of effects from the existing fossil plants and other physical changes in the Crystal River area are developed, there will be no validity to the assessments of the impact of the nuclear plants on the environment.

Where pertinent, the comments included in the Bureau's letter may be considered as applicable to these environmental docunents.

We appreciate the opportunity to provide these comments on the environmental report on Crystal River. We hope that they will be helpful in your coordination with the Compny and in pregration of the Atomic Energy Commission's environmental statement.

We will be happy to discuss this matter further with you, if you feel it is desirable.

Sinceyyyours,

$7~ _L o mism Secretary of the Interior Mr. L. Manning Muntzing Director of Re6ulation U.S. Atonic Energy Commission Washington, D.C. 20545 Enclosure T

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hd DEPARTMENT OF THE ' INTERIOR g; FISH AND WILDLIFE SERVICE 7

BUREAU OF SPORT FISHERIES AND WILDLIFE

. WASHINGTON. D.C. 20240

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• J Mr. Joel Rodgers Assistant Vice President Florida Power Corporation -

l_ 3737 38th Avenue N.

l St. Petersburg, Florida 33710

Dear Mr. Rodgers:

Pursuant to discussions at the St. Petersburg meeting of February 17, 1972, this letter constitutes our comments on your proposed study of thermal effects at the Crystal River Power Plant, Florida. The study l

1s an expansion of the existing monitoring program at the Crystal River site.

General Comment: The several Interior representatives left the meeting at the plant in November with the impression that very little coordina-tion between segments of the study was taking place. Since a number of agencies and institutions are involved, we recognize that this presents a logistics problem. However, free interchange of information and findings is essential to a well-rounded study.

l Reliability of the dsta obtained and of the con lusions drawn from those

! data would be. improved _by simultaneous field investigation on the several l physical and biological segments of the study.

I.- Initial Survey A. Extensive survey .of the area to define the benthic habitats

'(grass beds, algae beds, mud areas, sand areas, an'd marshland creeks adjacent to the near. shore marine environment) . (Figure I.)

B. Determine the exact location of these habitats by mapping.

i ~ Comment: In our view the initial benthic ~ survey and mapping should be extended somewhat beyond the present areas given in

, Figure I, both offshore and southward.- Salinity, temperature,

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dissolved oxygen and other parameters of water quality could conceivably be affected by the presence of the spoil dike to

'the. north of the shipping channel and.by_the volumes of water o

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t now(pulled through th'e plant. This volume w?ll of course double and~ triple if units 3 and 4 become operable with once through cooling. Thesa changes could effect benthic organisms over these extensive areas.

Similar surveys and mapping should be conducted in the discharge area north of the dike and extending offshore for some distance, probably well beyond the end of the spoil bank since shore paralleling currents are affected i

at least thst _ far out by the dike. The discharge areas may be affected by turbidity as well as temperature, salinity, dissolved oxygen and other parameters of quality -

' plume.an area affected by both the dike and the discharge over organisms.

Any or all of these factors could effect benthic' II.

' Location of Sampling Stations with Regard to:

C.

Assumption that control stations are representative of

" normal" uninfluenced habitats in the area.

Comment:

We believe control stations representative of uninfluenced habitats will be difficult if not impossible to locate in the study areas indicated. The plant facil-ities and operation have altered babitat in the plcat vicinity.

The intake and discharge canal dikes interrere with normal along-shore water movements, and result in a relatively unstable situation with continuing turbidity.

• Artificial currents and addition of heat cansed be plant operation have also altered the situation. the inshore area south of the, intake dike probably experiences dif-ferent salinities'than the project area did before construction because of Crystal River. If the intake water is from offshore as indicated in your reports, then salinities in the Crystal Bay Arca may be lower because the area of fresh water distribution from Crystal River

' discharge has been made smaller by the spoil dike. Salin-ities may be higher-and fluctuation may be greater if under some the plant conditions intake. the Crystal River discharge is included in.

These uncertainties should be resolved by investigations. The area north of the plant has been '

altered by- construction of the Barge Canal includin6 dredging, spoiling, and diversion of part of the Withlacoochee River flow and by cooling water discharges.

III.. Physical Parameters:.

A. Temperature .

B..-Salinity .

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C. Turbidity 4

5. Sediment Analysis Temperature, salinity', and. turbidity recordings would be obtained at each station for each sampling period. These data voul( be considered with regard to_ tidal condition, time'of day, intake and discharge temperatures, plants on line, load and discharge rates. Tnis.information would be utilized in conjunction with plume (temperature, salinity, and turbidity) studies of the USF Marine Science Institute.

Sediment analyses would be performed for each of the sampling stations.

Comment: If a significant portion of the intake water is coming from 5 miles out into the Gulf, there should be an .

analysis of the effect this water will have on the dis-charge area; the more saline water may be adversely affecting some zones in the area impacted by the plume.

It would also be better if temperatures were taken at the plant. There sho'uld be a continuous recording of what is being discharged, recorded automatically Current veloci-ties at various points in the canals should be measured under all likely ranges of tide and wind conditions. Bottom, surface, sides and mid depth should be monitored.

IV. Biological Parameters:

A. Emphasis would be placed on studying the benthic com-i munities.

_ Comment: While we have no quarrel with emphasizing benthic communities, we contend that other forms should be observed.-

It appears to us that fish populations in general--their

- abundance, distribution, and condition--are largely ignored.

Gill nets and pound nets could be used to supplement trawl samples. Such nets could probab,1y be fished in such a way

, as to identify main direction ofifish movement. Special emphasis should be given studies of fish movements in re-lation to currents in the intake canal. Night and' day and various phases of the moon warrant sampling efforts.

Another serious deficiency is.the inadequacy of phytoplankton studies in the plant vicinity and in the intake and discharge canals. ,

B'. Day and night samples would be taken on month'ly basis for at least one year. .

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s Comment _: The coverage affor'ded by one day and night sampling per month is thin, and should be expanded if possible. Care should be taken to sample the full range of, operating conditions and climatic conditions.

- s. C. Benthic infauna (invertebrates and small fishes--

tiose fishes which are associated with the habitat (i.e., grass, algae, etc.) whether as juveniles or

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adults or both.

2. Information to be obtained .

a. Benthic invertebrates (1) Species .

(2) Numbers of individuals per area (3) Diversity

b. Fishes

- (1) Species ,

(2) Numbers of individuals .

Comment: The apparent lack of observations on condition is a glaring deficiency. Sub-lethal effects may be more in-portant in the long run than direct mortality. Special atten-

. tion should focus on disease and other condition factors.

D. Benthic flora

1. Seagrasses and macroalgae

a. Sampling techniques

.(1) Bottom samplers (2) Meter squares visual counts

b. Information to be obtained (1) Seagrasses (a) Species (b) , Density (number of blades per area)

(c) Cover -

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(2) Macroalgae

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' (b) Number of individuals per area (c) Cover i e (d) Diversity Comment: Again, no observations of condition are proposed.

University of Miami researchers at Turkey Point have made this an important part of.their* studies. " Cover" is ambiguous.

It is not clear whether this means percent coverage of an area by types or safety refuge for small fishes and organisms.

V. Analysis of Data:

A. Study to be designed for statistical analyses. The specific tests to be employed would be determined prior to initiation of the study.

B. Information that could be used to determine areas under stress.

l. Reduction in species diversity

a. Benthic invertebrates

b. Macroalgae

2. Reduction in relative abundance

a. Fishes .

3. Reduction in density'

a. Seagrasses Comments: B.l. should include' plankton. Species shift in.

planktonic forms is highly important, perhaps more signifi-cant than reduction in number of individuals in some cases.

Special attention should focus on egg and larval stages of l larger species, as fish, crabs, shrimp, mollusca, etc. I Condition of the organisms observed is also an invaluable indicator of areas under stress, and should be studied.

Welalso suggest, perhaps as a sub-heading under condition, )

i- observations be made on diseases and fungus infestations. 4 It has been our experience that in dense grasses in dis-

, charge areas, fungus infestations in fish located in the

. plume have been noted, whereas no fungus was observed in .

fish outside of plume.

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f f- SUPPLEM"yARY ZOOPLANKTON SURVEY AT TSE CRYSTAL RIVER PLMT SITE

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I.- Determine the presence of major food chain species and the planktonic forms of commercially important finfish and shellfish in the area adjacent to the Crystal River Plant site.

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~ Comment:. Density is also important. Specific entrainment '

studies should'be made.

Procedures

! I. From a general knowledge of th'e reproductive cycles _of-l the endogenous adults, establiah a plankton sampling survey which may be used to identify.the presence of the planktonic forms. - This survey will be qualitative and cover an area ~'

south of the intake canal,-which is the source of cooling water. Figure 1 is a diagram of the general region, indicating that area south of the inuie canal which would be qualitatively surveyed and the intake turning basin from which' quantitative as well as qualitative samples would be taken.

Comment: 11here are no stations in'the canal itself. Studies are needed in the channel, especially near the south dike and near the mouth of the intake.

II. ' Sampling should be established at monthly .'ntervals or at periods indicated by reproductive cycles and extend over a two-year period.

' Comment: Monthly sampling is, thin. Care should be taken to sample night and day as well as during different tide phases and different moon phases.

III. Sampling strategies will be determined by the contracted research team.

Comment: ' Sampling should be done in both intake and discharge canals on the bottom, next to banks, and in the center (center

' flows). The intake and discharge facilities should be checked

=under a variety.of, conditions. There should be a lot of em-phasis on eggs and larval forms that are actually entering into the canals.

SUPPLEMENTARY STUDY OF FAUNAL ENTRAPMENT ON THE INTAKE SCREENS AT

THE CRYSTAL RIVER POWER PLANT

- Obj e'ctive

'To. assess.the biomass of commercially important or food chain ,

species entrapped on the intake screens at the Crystal River

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.  : . e Plant in order to more accurately estimate the impact of this

, facility on the marine productivity of the area.

' Comment: The intake screens should be looked at mois than once a month. A representative sample of entrapped spea.1-mens should be:

< 1. Weighed '

2. Sorted out by -

a. Species -

b. Size Additionally, there should be periods in which the screens are monitored daily and all the entrapped fish are recorded.

' Morning and evening surveillance should show whether entrap-

, ment occurs during the day or night.

There should be a detailed determination cf what is occurring in the intake, not just a superficial look. This is the corporation's responsibility to the public for use of their resources. The estuary cannot be replaced. Therefore, all avenues of environmentaJ protection should be explored explicitly.

Procedure 1

1. Establish a sampling strategy that reflects the seasonal impact of plant operation.

2. To assess entrapped biomass, all material should be removed from the collection bin and the faunal component isolated. From this, determine the following:

a. Total faunal biomass,

b. Total biomass of the commercial fraction j and the species represented. '

c.

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Total biomass of other important food chain organisms and the species represented. i

' Comment: An attempt should be made to postulate the impact of i the addition of units 3 and 4, i.e., would doubling the flow l substantially increase the nu'.ber of organisms on the screens?

Any significant fish kills should be reported by species to the j-i Environmental Protection Agency. '

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- -* Wi na.co that a'similar study. dealing with commercial species

.only is covered in your Environmental Report. Assumptions

'1 2, and 6 on pages V-81 and 82 of that report appear to be ~

-- invali .. There is no basis in demonstrated fact for these assumptions; therefore, any_ analysis based on them is highly

- conjectural and hypothetical.

We. appreciate _the opportunity to comment on the proposed research studies, and hope that continued cooperation.between private and governmental interests can result in a mutually satisfactory program.

Sincerely yours, j$' L.Y 4. A'Y.* Lu .-

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U2istM1 Director

- cc: Atomic Energy Cocmission i

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