ML20070A224

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Affidavit of Rs Nugent Supporting NRC 821112 Motion for Summary Disposition of Issue 7.Likelihood of Asiatic Clams Establishing in Lake Erie Is Low But Util Will Monitor for Clams.Prof Qualifications Encl
ML20070A224
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 12/03/1982
From: Nugent R
CLEVELAND ELECTRIC ILLUMINATING CO., NUS CORP.
To:
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ML20070A209 List:
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NUDOCS 8212090201
Download: ML20070A224 (12)


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December 2,1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of THE CLEVELAND ELECTRIC Docket Nos. 50-440 ILLUMINATING COMPANY, et al 50-441 (Perry Nuclear Power Plant, Units 1 and 2)

AFFIDAVIT OF DR. RICHARD S. NUGENT IN SUPPORT OF NRC STAFF'S MOTION FOR

SUMMARY

DISPOSITION OF ISSUE NO. 7 Dr. Richard S. Nugent, being duly sworn, deposes and says as follows:

1. I, Richard S. Nugent, am Consulting Scientist, NUS Corporation. My business address is 2536 Countryside Boulevard, Clearwater, Florida 33515. A summary of my professional qualifications and experience is attached hereto as Exhibit "A". I have personal knowledge of the matters set forth herein and believe them to be true and correct.
2. I have review'd the NRC Staff's Motion for Summary Disposition of Issue No.

7, dated November 12, 1982, and supporting documents, including the Affidavit of C. R. Hickey, Jr. and N. E. Fioravante in Support of Summary Disposition of Issue 7. I agree with the statements contained therein and give this Affidavit in support of the Staff's Motion.

BIOLOGY OF CORBICULA

3. The Asiatic clam, Corbicula, is a bivalve mollusc that was introduced to North America from Asia. It was first reported in the United States in 1938 from the Columbia River near Knappton, Washington and is now found in at least 33 states. At the present time, there is some disagreement among tax-onomists as to which species is found in the U.S. or whether more than one species may be represented. The generic names that have been most commonly used for the American populations are Corbicula fluminea, C.

manilensis and C. leana (Britton and Morton 1979), with C_. fluminea being employed by most recent authors.

8212090201 821207 PDR ADOCK 05000440 G PDR g NUS COAPORATION

4. The Asiatic clam in North America is considered primarily a freshwater species. It has been found in a wide range of aquatic habitats: estuaries, rivers, streams, canals, lakes and reservoirs. In general, Corbicula is considered an "infaunal" or burrowing species (Sinclair 1971). Investigators have indicated a preference for fine sand, coarse sand and mud in decreasing order (Sickel and Burbank 1974); but it has also been reported from a variety of substrate types ranging from mud, sand and gravel to rock and rubble (Gardner et al.1976).
5. C. fluminea is monoecious (i.e., a single organism possesses organs of both sexes and can sexually reproduce by itself) and incubates the fertilized eggs and early larval stages inside pouches in the inner gill. The larvae are released as veligers at a size of about 0.22 mm (Sinclair and Isom 1963) and after about 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> they drop from the water column and assume a benthic existence. Once on the bottom, the young clam develops rapidly and may produce loose byssal lines for temporary attachment to some solid substrate (Sinclair 1971). These lines usually dissolve by the time the clam reaches a size of about 6 mm (Imbro and Giannelli 1981). The clams may reach sexual maturity within the first year (Imbro and Giannelli 1981) or possibly the second (Sinclair 1971). Size at sexual maturity ranges from about 7.5 mm to 13.5 mm (Gardner et al 1976). In the United States, sgawning is initiated in spring when water temperatures first exceed about 60 F (16 C) and continue until temperatures fall below that level in the autumn. Young may be released throughout this period. Corbicula may live from two to four years and reach a maximum length of 60 mm (Imbro and Giannelli 1981).
6. Temperature appears to be a limiting factor in the distribution of the clam in the United States. It occurs in North America principally south of 40 Latitude (Britton and Morton 1979), primarily because its lower lethal temperature is about 36 F (2 C)(Mattice and Dye 1976) and it cannot survive winter freezes. Its occurrence in colder areas is limited to artificial environments such as within the thermal effluent of power plants. Growth of Corbicula is very slow in water temperatures below about 57 F (14 C). As noged above, spawning is limited to months when temperatures exceed about 60 F (16 C) (Eng 1979). Laboratory experimgnts have shown virtually instantaneous mortality for Corbicula at 43 - 50 C (109 - 122 F) (Goss et al.1979). Exposure of the clam to 43 C for 30 minutes will result in 100%

mortality (Mattice 1979).

Occurrence in Lake Erie

7. There are only three reports of Corbicula being found in Lake Erie. The first occurrence was in the western basin at Sterling State Park in Monroe County, Michigan in 1980 (Clarke 1981). Two living juveniles (8.0 mm and 8.6 mm) were taken from a sand bottom in an area within the thermal plume of the Monroe Power Plant. Subsequent investigations in 1981 revealed the presence of Corbicula in the thermal plumes of the Bay Shore and Acme Generating Stations, also in the extreme western end of the lake (Scott-Wasilk et al.1982). All three of these plants have once-through condenser cooling water systems and discharge their hea+ed effluent on the surface at the shoreline. The thermal plumes are in contact with the bottom. No Corbicula were found in the adjacent lake areas outside of those influenced by the thermal plumes of the three plants. These plants are located approximately 125 miles west of PNPP.

2 NUS COAPOAATION

8. Investigations specifically designed to collect Corbicula have been conducted at Davis-Besse Nuclear Power Station, Eastlake Power Plant and Perry Nuclear Power Plant. Davis-Besse Station uses a closed-cycle condenser cooling system and blowdown is discharged to Lake Erie through an offshore diffuser. Davis-Besse is about 115 miles west of PNPP. Eastlake Plant is a coal-fired plant and has a once-through cooling water system which dis-charges heated effluent at the shoreline through a canal. Eastlake is approximately 17 miles west of PNPP. e>erry Nuclear Power Plant has no operating water systems at this time. No Asiatic clams have been found at any of these locations.

PNPP Site-Specific Considerations

9. It is unlikely that Corbicula_ populations will become established in Lake Erie in the vicinity of PNPP. There are several reasons for this:
a. The occurrence of the clam in Lake Erie is presently limited to three small areas in the western basin which are under the influence of thermal plumes from electric power plants. No Corbicula have been found in areas adjacent to the plumes.

Apparently, the harsh winter conditions on the lake, particularly prolonged cold water temperatures, prevent survival of the clams from one year to the next in unheated areas.

b. The discharge structure of PNPP is located in about 19 f t. of water and is designed so that the portions of the thermal plume warmer than 3 F will come in contact with the bottom in limited areas within about 100 f t. for the discharge point (see, PNPP Environmental Report, Operating License Stage, Chapter 5).

Accordingly, there will be only small areas of bottom where warm temperatures could provide protection for Corbicula during the winter. In addition, thermal plume created by the PNPP dis-charge will be smaller than those created by the coal-fired plants where Corbicula have been found.

c. Another factor that mitigates against the establishment of Corbicula in the vicinity of PNPP is the nature of the bottom in this area. Studies carried out for the Applicant indicate that the bottom is predominantly rocky with sand and soft sediment only present in small quantities between the cobbles and larger rocks.

This is not preferred Corbicula habitat.

d. The conditions at Eastlake Power Plant, located about 17 miles west of Perry, are more conducive to Corbicula colonization than those in the vicinity of the site. The heated water plume at Eastlake is discharged into Lake Erie via a shallow canal. The plume is in contact with the bottom in the canal and adjacent inshore areas. The discharge is about 16 F (9 C) warmer than ambient lake water temperatures and the sediments within the plume area are predominantly sand. This combination of condi-tions would be favorable to Corbicula, yet none have been found there during recent sampling efforts it is likely, given the more favorable conditions at Eastlake, that Corbicula would become established there before appearing near PNPP.

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NUS COAPO AATION

LAKE MONITORING I

10. In June 1982, at CEI's request, NUS Corporation under my direction designed and initiated a sampling program designed to monitor for the presence of adult and older juvenile Corbicula in Lake Erie in the vicinity of the Perry t

Nuclear- Power Plant. The rationale for the design of the lake monitoring program is as follows: the source of any infestation of PNPP by Corbicula would be larvae resulting from the spawning of adult (s)in the vicinity of the

' site; by sampling the lake bottom twice-a-year both within about a two-mile area around PNPP and at Eastlake (a location conducive to colonization by Corbicula), it is highly likely that any populations of the Asiatic clam will be detected promptly. The following is a description of this program.

1 Commitrnent to NRC j 11. CEI has made the commitment to the Nuclear Regulatory Commission to j monitor for Corbicula in the lake as described in the April 29,1982 letter to Mr. A. Schwencer, Chief, Licensing Branch No. 2, Division of Licensing, USNRC, from Mr. Dalwyn R. Davidson, Vice President, System Engineering 1

and Construction, CEI. The commitment calls for CEI to conduct compre-hensive semi-annual (late spring and early fall) sampling of areas adjacent to

the Perry intake and discharge structure and CEI's Eastlake plant intake and discharge. If Asiatic clams are found at either the Eastlake plant or the Perry plant, a program to control the clams will be developed and submitted for NRC review. The development of this program will be based on the

, immediacy of the problem.

I

Monitoring Efforts Completed to Date
12. Two monitoring surveys were conducted during 1982. The first was carried 1

out from June 23-25, 1982. Twenty-two locations were sampled: 16 in the vicinity of PNPP and 6 at Eastlake. The second survey was conducted from

, September 3-10, 1982. Samples were collected at 24 locations: 17 locations in the vicinity of PNPP and 7 near Eastlake.

No Corbicula were found at any location in either June or September.

i Description of Monitoring Program

13. A boat-mounted benthic pump system is used in conjuntion with SCUBA divers to collect sediment from the lake bottom at selected locations along

, three transects near PNPP, at the PNPP intake and discharge structures and in the intake and discharge canals of the Eastlake Plant. The sediment brought up from the bottom is discharged through a series of four sieves and the retained material is examined for bivalve shells or shell fragments.

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NUS CORPORATION_,

14. The pump used is a portable, gasoline-powered model manufactured by Homelite. It has a maximum pumping rate of about 350 gal / min. and is mounted on the rear deck of a 40 ft. steel-nulled work boat. A 60 ft. section of flexible, reinforced hose with an inside diameter of 2 in. is used to draw the sediment from the bottom. The intake end of the hose is covered by a small cylindrical cage with openings of about 1 in. square which prevents larger rocks from entering and possibly plugging the suction hose. Another flexible, reinforced hose is connected to the discharge side of the pump and conducts the water and sediment to the collection boxes.
15. The collection boxes are constructed of metal and have the following dimensions: 36 in, long by 16 in, wide by 6 in, deep. The bottom of each is open and covered with screening of one of the following mesh sizes: 1/2 in.,

1/4 in.,1/8 in, and I mm. The four boxes are arranged in a metal frame, one on top of the other, in sequence with the largest mesh on top and the smallest on the bottom. When nested together, the vertical distance between the j mesh bottom of a box and the one above it is about 4 in. Material contained in the water discharged into the uppermost -box is retained on the mesh according to particle size.

16. The sediment samples are collected in the following manner at the PNPP

- (Lake Erie) stations. The station locatien is identified by means of a i combination of visual sighting of shoreline structures and depth finder readings. The boat is anchored and a SCUBA diver descends to the bottom with the suction end of the intake hose. The pump is started and the flow of i water and sediment from the discharge hose is directed into the collection boxes. The diver moves about on the bottom near the boat guiding the hose

along the bottom so that the upper 1 in. or so of sediment is drawn into the

! open end. The diver continues to collect sediment for a period of five minutes (as timed by the biologist on deck) and then the pump is turned off.

The sediments retained in the four boxes are removed and placed in a labelled container for later analysis in the laboratory.

i 17. The samples from the Eastlake intake and discharge canals are collected in ,

basically the same manner except that one or two smaller skiffs are used in place of the 40-f t. workboat due to limitations in space and shallow water depths.

13. In the laboratory, the sediment samples are examined for bivalve shells or shell fragments. Any that are found are measured and identified, and are l retained in a reference collection.
19. Sampling is conducted twice yearly: once in late Spring (June) and once in early Fall (September). The spring survey will detect any clams that may be present early in the spawning season and therefore capable of producing i larvae that could expand the infestation to other areas. The fall collections will detect any clams that might result from reproduction during the early
l summer.

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All stations can be sampled in a three-day period, weather permitting.

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NUS CORPORATION

20. Samples are collected at 22 locations as follows: (See Figures 1 & 2).

e Transect 1 (about I mile West of PNPP site) at about the 3, 4, 6,3 m depths 3 e Transect 5 (in front of PNPP) at about the 3,4,6,3 m depths e Transect 9 (about I mile East of PNPP site) at about the 3, 4, 6, 8 m depths e At least two locations adjacent to the PNPP intake structure e At least two locations in the vicinity of the PNPP discharge structure e At least two locations in the Eastlake Plant intake canal e At least four locations in the Eastlake Plant discharge canal

21. The composition of the typical field crew making the sample collections typically is as follows:

e One or more trained biologists e 2 to 3 professional SCUBA divers e Boat captain (when using 40 f t workboat) e Crew chief - in charge of divers and non-scientific equipment (also a SCUBA diver)

22. The monitoring program as designed and executed will detect adult and juvenile Asiatic clams promptly should they invade the PNPP area. To date, Corbicula has been found in Lake Erie only in the western end, in areas affected by heated discharge water. Should the clam invade the PNPP a ea, the most probable source would be these existing populations. Accordingly, the thermal effluent at the Eastlake Power Plant (located about 17 miles west of PNPP) is a likely location for Corbicula to appear if colonization of Lake Erie widens. Hence, the sampling at this location. To monitor for the appearance of Corbicula in the vicinity of PNPP itself, the sampling locations have been selected to cover both the lake areas nearest to the site as well as some more distant from it. One transect is directly in front of the site and is sampled at four depths that are different distances offshore. In addition, at least two samples are taken at both the intake and the discharge structures.

Thus, the areas from which the clams could most readily enter the plant are well monitored. The transects to the east and west, which are also sampled at four depths and distances from shore, provide for coverage in the farfield.

6 NUS CORPORATION

FIGURE I Locations of Transects for Corbicula Monitoring Survey in vicinity of Perry Nuclear Power Plant Site g

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i NORTH PERRY e SAMPtlMG LOCATIONS O I/2 i Mile h SURVEY TRANSECT SCALE I

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- 1 FIGURE 2 Typical Sampling Locations for Corbicula_ Monitoring Survey at Eastlake Power Plant LAKE ERIE INTAKE 6

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23. By locating the stations in this manner, a wide area is monitored and a variety of sediment types and water depths can be sampled. The number of stations, together with the variety of habitats sampled, inc eases the likelihood that Corbicula will be detected if they invade this area of Lake Erie.

~4. Another factor that will allow for the early detection of the clam is the use of the 1 mm mesh sieve through which the sediment is discharged onboard the boat (see Equipment section above). The Corbicula can be collected at this small size early in their life cycle, well before they reach the adult stage when reproduction will take place.

LITERATURE CITED Britton, 3. C. and B. Morton. 1979. Corbicula in North America: The evidence reviewed and evaluated. In: 3. C. Britton (ed.), Proceedings, First International Corbicula Symposium, pp. 249-238.

Clarke, A. H.1981. Corbicula fluminea, in Lake Erie. Nautilus 95(2):33-84.

Eng, L. L.1979. Population dynamics of the Asiatic clam, Corbiula fluminea in the concrete-lined Delta-Mendota Canal of Central California. In: 3. C. Britton (ed.),

Proceedings, First International Corbicula Symposium, pp. 39-68~

Gardner, 3. A., W. R. Woodall, A. A. Staats and 3. F. Napoli. 1976. The invasion of the Asiatic clam (Corbicula manilensis) in the Altamaha River, Georgia. Nautilus 90(3):117-125.

Goss, L. B., 3. M. Jackson, H. B. Flora, B. G. Isom, C. Gooch, S. A. Murray, C. G.

Burton and W. S. Bain 1979. Control studies on Corbicula for steam-electric generating plants. In: 3. C. Britton (ed.), Proceedings, First International Corbicula Symposium, pp. 139-152.

Imbro, E. V. and J. M. Giannelli. 1981. Report on Service Water System Flow Blockages by Bivalve Mollusks at Arkansas Nuclear One and Brunswick. Office for Analysis and Evaluation of Operational Data. Nuclear Regulatory Commission. 34 pp.

Mattice, 3. S. and L. L. Dye. 1975. Thermal tolerance of the adult Asiatic clam. In:

G. W. Esch and R. W. McFarlane (eds.), Thermal Ecology II. CONF-750425, NTIS, pp.

130-135.

9 NUS COAPORATION

Mattice, 3. S. 1979. -Interactions of Corbicula sp. with power plants. In: 3. C.

Britton (ed.), Proceedings, First International Corbicula Symposium, pp. 119-138.

Scott-Wasilk. J., G. G. Downing and 3. S. Lietzow. 1982. Evaluation of the Asiatic clam, Corbicula fluminea, in the western basin of Lake Erie. I_nn press, 7. Great Lakes Research.

Sickel, 3. B. and W. D. Burbanck. 1974 Bottom substratum preference of Corbicula manilensis in the Altamaha River, Georgia. Assoc. Southeastern Biologists Bulletin 2J2h34.

Sinclair, R. M. and B. G. Isom. 1963. Further studies on the introduced Asiatic clam (Corbicula) in Tennessee. Tennessee Stream Pollution Control Board. Tennessce Department of Public Health. November 1963. 80 pp.

Sinclair, R. M. 1971. Annotated Bibliography on the Exotic Bivalve Corbicula in North America, 1900-1971. Sterkiana 4_3: 3 11-18.

t Richard S. N nt' Subscribed and swgo n to before me this a day of December,1982.

t -,

' ' (L.1) > k - k Nota Public //

My Commission Expires:

Notary Pishbr, State of Fla. at Large My Comm:ssion Expires

( August 22nd,1984.

10 NUS CO APORATION

EXHIBIT A Resume of Richard S. Nugent, Jr.

EDUCATION Boston College. Chestnut Hill, Massachusetts. B.S. Biology,1964 Boston College. Chestnut Hill, Massachusetts. M.S. Biology,1967 University of Miami, School of Marine and Atmospheric Sciences. Miami, Florida.

Ph.D. Marine Sciences,1970.

j EXPERIENCE NUS Corporation,1977 - Present United National Educational, Scientific and Cultural Organization (UNESCO),1973-1977 Stone & Webster Engineering Corporation, 1970-1973 NUS - Consulting Scientist on the staff of the Clearwater (Florida) Environmental Center of Environmental Services Division.

Is the principal consultant to three energy companies on an NUS project to obtain the environmental permits required to withdraw water from the Colorado River for oil-shale development.

Serves as Project Manager of five-year water quality monitoring and thermal plume mapping studies associated with a combined pumped-stored / nuclear power plant project for South Carolina Electric and Gas Co. Monthly water quality sampling includes measurement of 30 parameters at 8 locations in a reservoir and river. The quarterly thermal mapping surveys employ a small boat towing a thermister string and

, utilizing portable small radar units (" Mini-Rangers") to determine the exact position of survey vessel.

Served as Project Manager for preparation of an Environmental Impact Statement for Big Bend Unit 4 (Tampa Electric Company) utilizing the Third Party Consultant arrangement with EPA Region IV. Headed the multidisciplinary team of NUS experts who prepared the EIS for this coal-fired power plant located on Tampa Bay. In addition to the DEIS and FEIS, the team prepared a 1700 page technical support document as part of the project effort.

Was the Project Manager of an investigation of the impacts of a hydroelectric project located in Western Venezuela. Field studies were conducted to gather information to be used to assess the impacts of the project on the terrestrial and aquatic ecology of the area. A team of NUS experts and Venezuelan scientists were assembled to carry out this project.

' Served as Project Manager of an impingement study for Florida Power Corporation's Crystal River Plant. The study consisted of weekly 24-hour sampling of fish and commercially important macroinvertebrates. Project Manager of entrainment and impingement studies of Florida Power Corporation's Higgins Power Plant located on Tampa Bay. The studies involved bi-weekly inplant and water body sampling over a nine month period.

NUS CORPOAATION

Managed a two year intensive ichthyoplankton, fish and bentos invest gation carried out on the southern shore of Lake Ontario near the site of a proposed nuclear power station in order to support intake and discharge permit applications. The ichthyo-plankton study involved collecting approximately 5,000 samples with towed nets at 11 stations between April and October of 1977 and 1978. Small fish were collected by gill 1 nets and seines. Benthos were collected using a specially-designed pumping system. l Analyses of the data involved the development of several models to project impacts of '

plant and plume entrainment of ichthyoplankton.

From 1973 to 1977, with the United Nations Educational, Scientific and Cultural Organization (UNESCO), employed as an expert in marine biology assigned to the Centro de Ciencias del Mar y Limnologia of the Universidad Nacional Autonoma de Mexico in Mexico City. Responsibilities included collaborating with other personnel of the Centro in programs of investigation in various parts of Mexico including studies in the following areas: assessment of the impact of a nuclear power plant, pollution of coastal areas, resource assessment of coral reefs, ecology and fishery potential of fishes and invertebrates of coastal lagoons, and semi-culture of Pacific lobster.

Taught graduate level courses in several fields of marine biology; and advised graduate students in masters and doctoral degree programs.

From 1970 to 1973, served as Ecologist with Stone & Webster Engineering Corporation, Environmental Engineering Division. Responsibilities included: designing, coordi-nating and evaluating the results of, preoperational and operational ecological studies of aquatic and marine environments near electric power plants; and preparing those sections of Environmental Impact Statements and other federal and state permit applications pertaining to aquatic and marine ecology. Worked in one or more of these capacit ies at the following locations: Millstone Point Nuclear Power Station Canal Electric Plant (Massachusetts-Cape Cod Canal), River Bend Nuclear Power Station (Louisiana-Mississippi River), Beaver Valley Power Station (Pennsylvania-Ohio River),

Upper Peninsula Power Plant (Michigan-Lake Superior), Stamford Power Plant (Connecticut-Long Island Sound).

From 1967 to 1970, carried out research for doctoral dissertation at Turkey Point Power Plant near Miami, Florida. The investigation was designed to determine what effect, if any, the heated discharge water had upon the fish and larger invertebrates in the mangrove areas adjacent to the site. Field sampling, which included gill netting, trapping, fouling panels and water quality measurements, was carried out once each week for approximately 14 months. The research was sponsored by a grant from Florida Power and Light Company.

MEMBERSHIPS American Society of Limnology and Oceanography Estuarine Research Society Gulf Estuarine Research Society NUS CORPO AATION

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