ML19350B298
| ML19350B298 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/13/2019 |
| From: | Livergood A US Dept of Commerce, National Marine Fisheries Service |
| To: | Briana Grange Office of Nuclear Material Safety and Safeguards |
| Briana Grange 301-415-1042 | |
| References | |
| Download: ML19350B298 (2) | |
Text
From:
Audra Livergood - NOAA Federal To:
Grange, Briana Cc:
Jennifer Moore
Subject:
[External_Sender] St. Lucie, Request for Additional Information Date:
Friday, December 13, 2019 11:03:00 AM
Dear Briana,
The National Marine Fisheries Service (NMFS) has reviewed the Nuclear Regulatory Commissions (NRC) November 18, 2019 request to reinitiate Endangered Species Act Section 7 consultation with NMFS for the continued operation of Units 1 and 2 at Florida Power and Lights (FPL) nuclear power plant located in St. Lucie County, Florida.
In addition to the November 18, 2019 request, NMFS also reviewed the NRCs Biological Assessement (BA) that was received by NMFS via email on April 22, 2019. The NRC stated in their November 18, 2019 request that the BA remains relevant to this consultation.
The Proposed Action is described on page 2 of NRCs BA as follows:
The proposed action is the continued operations of St. Lucie and its ocean intake system under the terms of NRC Renewed Facility Operating License Nos. DPR-67 and NPF-16, which authorize operations through March 1, 2036 (Unit No. 1) and April 6, 2043 (Unit No. 2),
assuming FPLs implementation of Option 2, Maintain Programs and Identify and Minimize Negative Impacts Associated with Entrainment and Travel through the Intake Piping, as described in FPLs December 6, 2018, final excluder device test report. In Section 2 of NMFSs 2016 biological opinion, NMFS includes a detailed discussion of St. Lucie operations. This discussion remains relevant to the present reinitiated consultation. In addition to operations as described in the biological opinion, FPL proposes to implement the following actions to reduce or minimize the take of and harm to listed species:
- 1. Perform initial detailed inspection of interior of intake pipes and velocity caps to identify conditions that may cause injury to large marine animals that may travel through the pipes.
- 2. Perform maintenance and modifications to address adverse conditions, to include creation of a smooth transition at the base of the Unit No. 1 velocity caps where the horizontal pipe enters the vertical section of the velocity cap.
- 3. Perform periodic inspections of interior of intake pipes and velocity caps to identify potential conditions that may cause injury to large marine animals.
- 4. Require biologists to inspect and record observations of the intake canal banks for potential turtle nesting and document inspection results in the Annual Environmental Report.
We note that activity #2 (above) is already required in Term and Condition 2 of Reasonable and Prudent Measure 2 in NMFSs 2016 Biological Opinion. Moreover, we note that activity
- 4 (above) is already required in Term and Condition 6 of Reasonable and Prudent Measure 2 in NMFSs 2016 Biological Opinion. Thus, we respectfully disagree with the NRCs characterization of these activities as additional activities in the BA. NMFS considers these activities to be ongoing as part of the continued operations at the power plant. We do not believe these activities represent a change in operations.
NMFS requests the following information to continue our evaluation:
- 1) Page 16 of the BA states FPL has not observed any sea turtle nesting attempts on the intake canal bank since the 2006 event. Please confirm that this statement is still true.
- 2) Please provide NMFS with FPLs 2019 annual environmental operating report when it becomes available. Please email a pdf of the report to Audra.Livergood@noaa.gov
NMFS reserves the right to request additional information based on our review of the information requested herein.
We look forward to hearing from you in 45 days. If we do not receive a response within 45 days from the date of this email, we will assume the consultation is no longer active, and we will close out the consultation. Please note this 45-day period has been established as a national policy.
Kind regards, Audra Audra Banks NOAA National Marine Fisheries Service SERO Protected Resources Division Coral Conservation Branch Looking at them, Jesus said, "With people it is impossible, but not with God; for all things are possible with God." (Mark 10:27)
For since the creation of the world, God's invisible qualities - His eternal power and divine nature -
have been clearly seen, being understood from what has been made, so that people are without excuse (Romans 1:20)