ML20079J122

Plan of Study Summary

ML20079J122
Person / Time
Site:	Crystal River
Issue date:	01/19/1984
From:	FLORIDA POWER CORP.
To:
Shared Package
ML20079J080	List: 3F0184-20, Forwards Second Quarterly Progress Rept,Crystal River Studies & Plan of Study Summary Per Tech Specs,App B, Part Ii,Section 3.2,submitted to EPA ML20079J105 ML20079J122
References
PROC-840119, NUDOCS 8401240219
Download: ML20079J122 (90)

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{{#Wiki_filter:_ l PLAN OF STUDY

SUMMARY

Crystal River 316 Study This docunent presents a summary of the field sampling activities being con-ducted at Crystal River as part of the 316 Study Program. Field sampling has been ongoing at Crystal River since June, 1983, and is scheduled for comple-tion during August, 1984. The Plan of Study (POS) for the 316 Study was submitted to the Environmental Protection Agency (EPA) for approval on November 15, 1982. Subsequent to state and federal approval of the POS, proFram modifications were made to incorporate state-of art analytical techniques and to address new information regarding the Crystal River environment. These changes were presented in the g documents entitled " Proposed Revisions to Plan of Study, Crystal River 1, 2, and 3 NPDES 316" and "Section 3.5: Physical Studies" which were submitted to EPA on Febraary 22, 1983. Rese documents are included in this summary as Attachments 1 and 2, respectively. Following implementation of the 316 Study, some modifications to the sampling program were required to conform the sampling strategy to local conditions. These changes are summarized in the First Quarterly Report. These program changes, when required, were made following discussions of the proposed changes with Agency staff. Written notice was provided to both EPA and the i Florida Department of Environmental Regulation (FDER) following implementa-l tion of a program modification. l . e401240219 y h 2 FDR ADOCK PDR R

PLAN OF STUDY

SUMMARY

e Crystal River 316 Study The Crystal River 316 Study is divided into four study components. These components are I-Benthos, II-Impingement and Entrainment, III-Fi s h e ries, and IV-Physical. A summary of each of these components is provided in Table 1. Figures referenced in Table 1, and provided in this document, reflect existing, updated sampling locations. All source information referenced in Table 1 is provided as Attachments 1 through 7. Specific types of analysis to be performed on the Crystal River data as part of the 316 Study are not discussed in this doc ument. However, a general g guideline to the types of data presentations which are anticipated are presented in the " Proposed Revisions to Plan of Study" and "Section 3.5-Physical Studies". Plans for specific types of data analyses will be formalized as the Study progresses and data trends become evident, probably during the third quarter of data collection. O.- _

TABLE 1

SUMMARY

OF CRYSTAL RIVER 3 tt) (a) and (b) STUDY PROGRAM Figure No. of No. of Total No. St ud y Study Component Number Stations Rep. Fr equenc y Samples Period Source 1. Bent hus A. Benthtc cose 2-1 20 6(+2) Quarterly 600 15 mos 20 6(+2) 6 wks I200 15 mos POS Revisions 1-21-83 p.3, (ATT. 1). B. Aertal photographs 2-2A 1 1 3 t imes 3 15 mos POS Revisions 1-21-83 p.7. Frequency changed as noted in Qt r I l l Re por t, Sect. 2.1.1 (ATT. 3) C. Macrophyte mapping 2-2B1 50 10 Quarterly + 3000 15 mos ! Preliminary 2-2B2 9(antens.) 10 6 wks 900 15 mos 9(inten..) 6 wks 450 15 mos POS Rev i s ion s 1-21-83 p.6 a D. Oysten seef 2-3 9 90 Monthly & 14580 12 mos POS Rev t s sons 1-21-83 p. 7. Y Ramonthly Procedures revised in Qtr i Report, Section 2.1.2 E. Salt marsh piogsam 2-4 8 24 6 wks 1920 15 mos POS Revisions 1-21-83 p.8 F. Physical Chlorophyll "a" 2-1 8 2 depths Weekly 1040 !$ mos POS Revision 1-21-83 p.5. Sampling a. b. Sediment 40 3 Quarterty 1200 15 mos sequence modified for tempet a ure r c. Photometty 40 1 profste Weekly 2600 15 mos measurements per correspondence dated d. Tu m b a d i t y, D.O., 40 multiple Weekly 5200 15 mos 7-18-8 3. ( ATT. 4) ( See a lso Qt r 1 pH, Salanity, depth Re por t, Sect. 2.1.3) Tempe r at ut e c. Sediment Temp-40 1 depth Quarterly 200 15 mos crature, Eh 20 1 dept h 6 n,k s 200 15 nos f. Suspended I.oads 40 4 analyses Riveckly 5120 15 mos

i TABLE I (cont.)

SUMMARY

OF CRYSTAL RIVER 316 (a) and (b) STUDY PROGRAM Figure No. of No. o f Total No. Study St udy Component Number Stations Rep. Frequency Samples Persod Source II. Impingement and Entiainment A. Impingement 3 4 Weekly + 660 12 sion POS submitted 11-15-82 l 3 t imes

p. 11-13 t hrough II-15. (ATT. 5)

J POS Revisions dat ed 1-21-83 p.9. I B. Entaminment 2-5 15 3 Biweekly 2880 15 mas Station locations and gear type were day / night modi fied to bet t er represent control and charge areas as detailed in corres-pondence dated 7-18-83. Station L was wved during October as discussed an the QTR 2 Report, Sect. 2.0 Ill. Fishesses A. Trawl 2-6 9 7 Monthly 756 12 mos POS Revisions dated 1-21 -83 p.12. (night) J. POS Revisions dated 1-21-83 p 12 B. .eines 2-6 4 2 Monthly 96 12 mos Stat ion locations changed per correspondence dated 7-18-83. C. Drop Net 2-6 2 7 Monthly 48 12 mos POS dated 11-15-82 pgs 111-11 thru l III-12 and 111-16 t hru III-17. (ATT. 6) l POS kevastons dated 1-21-83 p.12. l D. Cre(k trawls 2-6 4 7 Monthly 336 12 mos correspondence dated 7-18-83 replaces l (day) block net described in revised POS with l trawls due to cacek characteristics. \\ l

l TABLE I (co7t.)

SUMMARY

OF CRYSTAL RIVER 316 (a) and (b) STUDY PROGRAM Fagure No. of No. o f Total No. Study Study Component Number St at tons Rep. Frequency Samples Petiod Source POS dated 11-15-82, pgs. 111-17 thru E. Camb t raps 2-7 120 1 17 t imes 2040 4 mos 111-19. ( ATT. 6) Trap arrey and be s t type changed per correspondence dated 9-23-83 (ATT. 7) to conform to comm?r-cial iishing effort. F. Crab impingement i I 17 t imes 17 4 mos POS submitted 11-15-82 p.ll!-10, IIIJ IV. Physical Studius A. Bathymetry I survey Section 3.5: Physical Studies (ATT. 2) Since its submittal, some changes to this docisnent have occurred. These changes are listed in the document as B. Shost-ttsn 2-6 16 1 Variable 2 mos marginal notations. i C. long-team 2-9 51 I or 2 Continuous Variable 12 mos D. Meteorology I I Continuous Variable 15 mos E. Modeling F. Temperat ure profiles Varaable 2 Vartable Variable 2 mos Temperature prof ales were added to the (Plume delineation program) short term monit oring proFram to aid in defining the discharge plume and the point of plume bottom separation. The plume delineat ion program is conduct ed concurrent with the short term studies program during AuFust and January. Diurnal and semi-daurnal t ides will be sampled during each month.

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PROPOSED REVISIONS to PIAN OF STUDY (POS) CRYSTAL RIVER 1, 2 and 3 NPDES 316; ECOIOGICAL MONITORING PROGRAMS FIDRIDA POWER CORPORATION August 1979, Resubmitted October 1902 Submitted to: Florida Power Corporation Post Office Box 14042 (} St. Petersburg, FL 33733 Attention: Mr. Paul Behrens Submitted by: s r-Selvakumaran Mahadevan, Ph.D. Principal Investigator William H. Taft, Ph.D. / President Mote Marine Laboratory 1600 City Island Park Saraso ta, FL 33577 January 21, 1983 O

4 e h d TABIZ OF CONTENTS Page 1.0. Introduction 1 2.0. Benthic Monitoring 3 2.1. Benthic Core Program 3 2.2. Benthic Trawl Program 6 2.3. Macrophyte Mapping Program 6 2.4. Aerial Photographs 7 2.5. Oyster Reef Program 7 2.6. Suction Dredge Program 8 2.7 Salt Marsh Program 8 2.8. Artificial Substrate Program 9 2.9. Physical Measurements 9 3.0. Entrainment and Impingement Monitoring 9 3.1. Impingement Program 9 3.2. Entrainment Program 9 r 3.3. Survival, Thermal Simulation and Tolerance \\ Program 10 4.0. Fisheries and Water Quality Monitoring 10 4.1. Fisheries Program 12 4.2. Water Quality Monitoring 12 5.0. Physical Studies 15 5.1. Sediment Survey 15 6.0. General Comments 17 Appendix A: Results of the sediment survey conducted at Crystal River (December 6-9, 1982). Appendix B: Results of the infaunal sampling (for replication evaluation) conducted at Crystal River (December 7-9, 1982). O

i '- 1.0. Introduction In response to the requirements of Part III-H, NPDES Permit No. 7LCOOO159 dated July 9,1979 for Crystal River Power Generation Units 1, 2, and 3, Florida Power Corporation (FPC) submitted an ecological monitoring program to the Environmental Protection Agency and other reviewing agencies to address the requirements of a 316(a) and (b) Demonstration. The plan of study (POS). was resubmitted to the Agencies in October 1982 with some revisions; it addressed the following elements: SECTION I: Benthic Monitoring a) Benthic Core Program b) Benthic Trawl Program c) Macrophyte Mapping Program d) Aerial Photographs e) Oyster Reef Program f) Suction Dredge Program g) Salt Marsh Program h) Artificial Substrate Program i) Physical Measurements () SECTION II: Entrainment and Impingement Monitoring a) Impingement Program b) Entrainment Program c) Survival, Thermal Simulation and Tolerance Program SECTION III: Fish and Water Quality Monitoring a) Fisheries Study (including a blue crab tagging study) b) Water Quality Measurements SECTION IV: Physical Studies a) 11adiematical Modeling b) Physical Measurements c) Sediment Survey Ihe work elements described above were designed to address the following impacts: 1) Thermal impacts from the operation of the Power Plant (316 (a) ). 2) Intake effects in the form of larval entrainment and adult impingenent (316 (b) ). 3) Effects of the Cross Florida Barge Canal (primarily sedimentation) on the magnitude and types of power plant induced impacts (listed above). 1

~. (~% u.) In November 1982, FPC contracted Mote Marine Iaboratory to reevaluate the Plan of Study and review the necessary work elements to reflect: 1) technical applicability and credibility with specific reference to 316 Demonstration requirements; 2) cost-effective redirection of the study design to adequately address thermal and intake related power plant impacts; 3) incorporation of recent scientific knowledge to the study design. This report presents the revisions to the POS proposed by Mote Marine Laboratory utilizing the above three objectives. The revisions follow the same format as the POS and refer to the POS pages when suggesting changes, modifications or deletions. The revisions proposed in this report are based on the following: 1) Our review of existing reports and data from the study area; 2) A reconnaissance trip conducted on December 1, 1982; 3) A meeting with Agency representatives on December 16, 1982: 4) Our interim report to FPC dated December 20, 1982, copies of which were forwarded to Agency Representatives; 5) Our sediment survey at 109 stations in the study area con-ducted during the period December 6 through 9, 1982 to provide a general overview of substratum characteristics in the study area and to enable us to choose specific locations for benthic infaunal studies; 6) Our benthic infaunal studies at three locations during the period December 7 through 9,1982 to provide an evaluation of replication levals necessary for benthic core (faunal) studies in the areas 7) Our draft report (on revisions to the POS) dated January 14, 1983. 8) A meeting with FPC and A ency Representatives on January 18, 1983 9 () regarding the draft report. 2

s i t 4 AQ 2.0. Benthic Monitoring (POS Pages I-l to I-40). 2.1. Benthic Core *>rogram (POS Pages I-6 to I-9 and I-16 to I-18). We propose the following revisions to the Benthic Core Program. 1. Duration of the Sampling Effort to be changed from one year to fifteen months. This will allow the comparison of data from one quarter conunon to two years and enable an evaluation of the magnitude of annual variations. Studies by MML at power plants in Tampa Bay suggest that annual variations can be extremely important when evaluating the magnitude of differences between thermal and non-thermal areas. 2. Frequency of Sampling be changed from monthly to once every six weeks.- Our studies in the region have shown that this frequency would be sufficient to address temporal variations. 3. Sampling Device be changed from the 15 cm x 15 cm post-hole digger to a diver-operated box core (12.5 cm x 12.5 cm surface area; 15 cm depth of penetration). This device will be more efficient in the collection of samples because of the prevalence of unconsolidated sediments in the /O (/ study area. Other investigators and MML have used this device in the region with good results. 4. Sampling Stations be located based on sediment type to enable valid comparisons of thermal and nonthermal areas. Based on our sediment survey (see Appendix A for tables and figures showing results of the sur-vey), we propose that 20 stations be sampled once every six weeks. An additional 20 stations should also be sampled once a quarter. Proposed locations of stations are shown in Figure 1. (The POS recomrended sampl-ing 85 stations bimonthly and 33 of these stations monthly.) The stations proposed are located on seven east-west transects. The two northern tran-sect stations (Stations 1 through 12) will serve as the northern thermal control'and will reflect the combined effects of the Cross Florida Barge Canal and Withlacoochee River. Stations 13 through 30 will serve as possible thermally affecced locations. Stations 31 through 40 will serve as the southern thermal control stetions. In each of these three zones (North Control, Thermal, and South Control), several sets of stations have O 4 .,-.,..-,n,

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g A-similar sediment types; this will facilitate the evaluation and delineation of the thermally affected areas with a reasonable degree of accuracy. 5. Replication Level at each station be changed from 5 samples to 6 samples. Our study on the replication evaluation (see tables and figures showing results of the study in Appendix B) clearly show that six replicates will be sufficient to collect a majority of species at each station and to adequately describe various community parameters.

However, as a precautionary measure, we propose that eight replicates be collected at each station and that two cf these replicates be archived for later analyses if replication is found inadequate during the coarse of the program.

6. Biomass Measurements be deleted, since previous studies in the area have shown that dry weight of each major infaunal group does not add to or detract t.om the trends shown by examining abundance patterns. 7 Abiotic Measurements be made in conjunction with the benthic O) \\_ core sampling program. Specifically, we propose that: a) Temperature, salinity, pH, turbidity, dissolved oxygen and light penetration (photometry) be measured in situ

• at least at the surface and bottom of the water column at each benthic core station on a weekly basis. Water samples also be collected at 20% of the stations for chlorophyll 'a' analyses. This will allow the interpretation of turbidity and chotometry data.

b) Sediment temperature and Eh (Redox potential) be measured in situ at each station, during each trip (once every six weeks). c) Sediment samples (3 replicates / station) be collected on a quarterly basis at each of the 40 stations and analyzed for: 1) Granulometry 2) Silt / Clay Content 3) Total Organic Carbon 4) Sulfide Content. 8. In terms of Data Analyses (POS Pages I-31 and I-32), we propose that the analyses be restricted to the fellowing:

• As a quality assurance measure, we recommend that at least 1.3% of the in situ measurements be checked with laboratory methods.

5

. f) V a) Species Composition (composite species lists) b) Dominant Species Abundance c) Species Richness (no. of species / station) d) Faunal Density (.to. of organisms /m ) e) Species Diversity (Shannon-Weaver Index) and log-normal curves t) Faunal Similarity (Morisita's Index) and subsequen t classification / cluster analysis g) Statistical analyses ('t' tests, analyses of variance, regressions) on selected sets of data, as appropriate for evaluating the significance of differences or correlations. We propose that the analyses be geared to compare the North Control, South Control, and Thermal areas during each sampling period. The overall analyses should also look for shifts in temporal trends in these areas. The usefulness of comparing these data to historical data in the study area will be questionable because of the different methodologies used in the past. General comparisons of shifts in () dominant species may, however, be possible. 2.2. Benthic Trawl Program (POS Pages I-9, I-lO and I-18 to I-21). We feel that this s'.udy component will only duplicate part of the efforts in the Fisheries Program (Section III of the POS) and suggest deletion in its entirety. Moreover, the study area has very few habitats (dense seagrass beds) for which the sampling device would be suit-able. Also, the information that will be generated by this program will not provide the type of data necessary for thermal impact assessment. 2.3. Macrophyte Mapping Program (POS Pages I-10 and I-21 to I-23). For this program, we propose the following revisions: a) Instead of monitoring 300 stations (with divers) on a bimonthly basis, we suggest that 50 stations be ground-truthed* in conjunction with quarterly aerial surveys.

• Diver ground t-uthing with 1 md quadrats, ten replicates at each station,

() for seagrass and macroalgae species composition and seagrass percent cover. 6

b) From information obtained in the preliminary aerial survey and ground truthing we propose (as an addition to' the POS) that 9 intensive monitoring stations be selected with 3 in the thermal area, 3 in the north control area and 3 in the south control area. We suggest that the follow-ing parameters be monitored once every 6 weeks: for 15 months (to address annual variations) at these stations: 1) Seagrass and macroalgae species composition and percent seagrass cover; ten 1 m diver quadrats per station. 2) Seagresses and rhizophytic algal species composition, biocass 2 and blade densities from five 0.25 m quadrat clips. 3) Seagrass growth studies (blade marking and measurements). 4) Species composition of epiphytic algae from subsamples of quadrat clips. This approach will provide sufficiently detailed information to evaluate the thermal effects (if any) on the seagrass/macroalgae popula-tions in the study area. The weekly photometer profiling effort (Section 2.1.) should provide support information to separate sedimentation / turbidity related impacts on macrophytes from thermal impacts. 1 2.4. Aerial Photographs (POS Pages I-ll and I-23). We propose that 6 aerial surveys be conducted (1 preliminary + 5 quarterly) to coincide with the 15-month macrophyte program.

2. 5.. Oyster Reef Program (POS Pages I-ll, I-12, and I-23 to I-25).

l' Instead of the POS described sampling methodology, we propose that caged oysters be used to evaluate the thermal impacts on the oyster reefs of the study area. This approach will eliminate the destructive element of the proposed study and enable a closer temporal evaluation of the effects. . We suggest that preweighed and premeasured oyster clumps *be placed in cages near all of the POS proposed oyster reef stations (POS Fig. I-7, Page I-24), except at the station north of Withlacoochee River (i.e., a total of 9 sta-tions). We suggest two types of sampling: a) Three cages at each station placed and retrieved on a monthly basis for one year; this sampling will address spatial differences in mor-I tality and short-term growth of the oysters and the species composition of .() associated fauna as it relates to the thermal effluent.

• A minimum of ten oysters per clump; at least three clumps in a cage.

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b) "ighteen cages at each station placed during the initiation 1 of the study, three cages )zeing retrieved on a bimonthly basis; for one year. This will address spatial and temporal differences in (1) long-term growth of the oysters: (ii) succession in species composition of associated ~ fauna as it relates to the thermal effluent. Laboratory analyses of retrieved oyster clumps should include: wet weight of clump; size and biomass (dry and wet weight) of adult oysters and spat enumeration and identification of associated fauna. 2.6. Suction Dredge Program (POS Pages I-12 and I-25). Previous FPC monitoring studies (Annual Reports 1978 through 1981) have shown that the suction dredge samples did not add or detract to the trends and species composition obtained by the benthic cores. tMoreover, the use of larger size box-cores (12.5 cm x 12.5 cm) and the seining / trawling sampling in the fisheries program of the proposed study should provide sufficient information.on the larger macroinvertebrates of the study area. Also, the lack of replication and the large sieve size pro-posed for suction dredge samples will negate the value of these data in t thermal impact assessment. Hence, we propose that this program be deleted in its entirety. 2.7. Salt Marsh Program (POS Pages I-12, I-13 and I-27). We propose the following revisions to this program: a) Relocation of the two stations north of the Barge Canal (POS Figure I-9) to Rocky Cove (extra thermal station) and to Salt Creek (additional control station). b) Transect method be retained, with four locations per marsh form (Spartina, Juncus). Each location should be situated in a unique micro-habitat (e.g., creek bank, marsh interior, shell or rock substratum, etc.). This modification is justified by recent evidence for significant microscale 2 variations in standing crop and production. We propose that three 0.25 m quadrats be collected at.each location providing a total of 24 samples per station (instead of 10 samples proposed in the POS). This approach will enable a valid comparison of thermal and nonthermal marshes. l. c) We propose that the salt marsh sampling be conducted once () every six weeks for 15 months (to address annual variations) instead of i bimonthly for one year as proposed in the POS. 8 i

() d) As an addition, we propose that epifloral species composition be qualitatively (presence / absence) described from quadrat subsamples. Previous studies (Kolehmainen et al., 1974; Hoffman and Dawes, 1980) have shown that these species are useful indicators of therral stress, e) As an addition, we propose daat tidal plane determinations be made at the salt marsh stations for referancing sample locations. Also, we propose that two recording bathythermographs be deployed at each salt marsh station for obtaining continuous records of temperature throughcut the study period. 2.8. Artificial Substrate Program (POS Pages I-13, I-14 and I-27 through I-30). Because barnacle growth will overwhelm any community description, we propose that this program be deleted in its entirety. 2.9. Physical Measuraments (POS Pages I-14, I-30 and I-30A1. Section 2.1 of this document (Benthic Core ' Program) describes our () proposed changes to this program. 3.0. Entrainment and Impingement Monitoring (Section II of the POS, Pages II-l through II-50). 3.1. Impingement Program (POS Pages II-3, II-4 and II-13. through II-16). We do not propose any changes to this program. 3.2. Entrainment Program (POS Pages II-4 through II-6 and II-16 through II-23). We propose the following revisions to this program. Kolehmainen, S., T. Morgan, R. Castro. 1974. Mangrove root communities in a daermally altered area in Guayanilla Bay, PR. Therral Ecology, p. 371-391. l l Hoffman, W.E. and C.J. Dawes. 1980. Photosynthetic rates and primary production by two Florida benthic red algae species from a salt marsh and mangrove community. Bull. Mar. Sci. 30:358-364. t 9 l l

a .al Instead of the 25. stations proposed in the POS, we suggest that 13 stations be sampled at the locations shown in Figure 2. We feel th2t this extent of spatial coverage will be sufficient to accurately describe the levels of entrainment, the populations in the plume area and source waters, and spatial variations of meroplankton in the study area. b) For statistical precision, we propose that the number of replicates at each station be increased to 3 (instead of 2 proposed in the POS). This will allow the evaluation of within-station variability with regard to spatial variation. c) Since seagrass areas will harbor different populations of neroplankton, we propose that two seagrass stations (Figure 2) also be sampled in the same frequency as the net samples. These stations can be sampled with a sled fitted with a 505 u mesh net (same mesh size as the net samples), d) We propose that the entrainment sampling program be conducted for fifteen months (to address annual variations) instead of one year as proposed in the POS. 3.3. Survival, Thermal Simulation and Tolerance Program (POS Pages II-7 through II-10 and II-26 through II-40). The information obtained in this program, we feel, will only confirm what has been shown at other power plants (e.g., Tampa Electric Company's Big Bend Station) studies, that is, that planc induced nortality is high, especially for larval fishes and invertebrates. Therefore, we propose that this program be deleted in its entirety. 4.0. Fisheries and Water Quality Monitoring (POS Section III, Pages III-l through III-30). O 10

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['./ h 4.1. Fisheries Program (POS Pages III-8 through III-23). m We propose the following changes in this program: a) We propose the deletion of trammel samples; in the habitats of the study area, we feel that the trammel nets will not be efficient in sampling fish communities, b) We propose the location of trawl stations on three transects and suggest that 7 replicates (2 minute tows) be collected with an otter trawl at each of these stations on a monthly basis during night time only. This approach, we feel, will provide a comprehensive description of adult fish and invertebrate communities in the study area. Proposed location of the stations is shown in Figure 3. The methodology proposed has been used in earlier studies in Tampa Bay, Apalachicola Bay and Biscayne Bay and found to be efficient. c) Instead of block nets proposed in the POS, we suggest that the creeks be sampled by seines after using block nets to isolate a section of the tidal creek. Eight sweeps with a 7.6 m - 6.5 mm mesh seine and 3 over-('] lapping sweeps with a 7.6 m - 1.0 mm mesh seine are proposed for sampling the blocked area. d) We propose that the number of seine stations be reduced to 4 from 6 (by eliminating the northernmcst and southernmost stations). e) We propose several modifications to the locations of crab traps for the tagging program (Figure 4). We propose that crabs be trapped, tagged and released at Transects A through D. Stations E, F, and G can j serve as release points for plant-impinged surviving crabs. No changes in the temporal frequency or the total number of samples is proposed. The j revised locations will better address the objective of the crab tagging

program, i.e., the effect of the intake dikes on the movement of blue l

crabs in.the study area. 4.2. Water Quality Monitoring (POS Pages III-10 and III-23 through III-27). We propose the following revisions to this program: a) Deletion of nutrients (N and P) and silicate as paramett.s for measurement. We feel that these parameter, cannot be related to thermal, , () entrainment or impingement effects and therefore suggest their deletion. 12 I i i I

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,.0 9 z, .,/,' c'e.<,, ,4 ~ e- .c ':ul 1y ( ~ - - J.: i I \\ 1 [ 'r' f ,g( g, f4-l .eaea e>< s\\ 1 _, bv4., tv. s ~ ,i 1 Figure 4, Proposed location o ,_.. N ~~ Sp for crab traps (Transects A j) ks D) and plant-impinged sur- ~, viving crab release points (Stations F, P, and G). I e Y* \\ s% ***** so

_ i- \\_) b) Other parameters listed in this program will be addressed -in the benthic core program on a weekly basis (see Section 2.1. of - this report). Therefore, we propose deletion of the section on water quality measurements in the POS in its entirety.

5. 0.. Physical Studies (POS Section IV, Pages IV-1 through IV-73 and Appendix IV-1).

We did not review the sections on Mathematical Modeling and Physical Measurement # in this program (in accordance with our contract / Scope of Work with FPC). 5.1. Sediment survey (POS Pages IV-26 through IV-33 and IV-50 through IV-62). Sediment depth probes, grab samples cores, traps, photometer profiles and water column samples are proposed in the POS as part of the sediment survey to " determine the relative effects of both the 7-power plant facility and the adjacent Cross Florida Barge Canal on the (-) distribution of sediment in the discharge area and its surrounding environs". From a 316 Demonstration perspective, we feel that the only useful sediment information is as it relates to the fauna and flora of the study area. This type of information will be collected with the benthic core program (see Section 2.1. of this report). Moreoever, if the following reasonable assumptions are made, we feel that measuring suspended loads (organic and total), light penetration (photome te r), chlorophyll 'a' and turbidity may be the best methods to directly evaluate the sources, distribution and Power plant impacts relative to sediments, a) The spoil islands of the Cross Florida Barge Canal and the power plant intake structure are sufficiently stabilized (with vegetation and/or winnowing of fine-grained sediment) at the present eine, that they do not serve as primary sources of suspended sedtment in the study area.

• The long-term physical measurements prog: nm (POS Pages IV-24, 25, 44 to 50) proposes to measure tamperature and salinicy on a biweekly basis for one year at 21 stations. The weekly monitoring proposed in Section 2.1. will ade-

_g-) quately address this program's needs; therefore, we suggest that these (_) measurements be deleted in Section IV of the PCS. 15 o .m,

b nIJ b) Salt marshes and freshwater streams in the study area export considerable amounts of organic detritus to the nearshore waters. ) c) Because of the shallow nature of the system, resuspension of botteen sediments (particularly during storm events) may account for much of the suspended sediment loads in the study area. Therefore, we propose that on a biweekly basis for 15 months, total suspended solids

• and organic suspended solids be measured at the surface and near bottom of the 40 benthic core stations (Section 2.1.).

I.. In addition, we request that at least 3 of these samplings be conducted after storm events and barge traffic in the intake canal. This approach, in conjunction with the weekly photometer, turbidity, and chlorophyll 'a' measurements (Section 2.1.) should identify:

1) areas that have high organic loads:

2) areas that have primarily inorganic. loads: 3) extent of the influence of phytoplankton populations on light penetration in the area 4) extent of sediment resuspension in the area 5) the power plant's role in potentially redistributing sediments in the area. This information will c.lso be useful in explaining macrophytic and faunal distribution in the study area as they relate to sediment loads, t In summary, for the sediment survey program, we propose: 1) Deletion of sediment depth probes, grab samples, cores and sediment traps.

2) Conducting photometer profiles with the benthic core program (Section 2.1. of this report),

i.e., deletion from thic program.

3) Deletion of water column samples.

4) Addition of a suspended load survey (described above).

O

• Incrganic suspended solids are obtained by subtracting organic suspended solids fross TSS.

t 16

4% O 6.0. General Conuments In general, we propose that the surveys described above and in the POS be conducted synoptically, whenever feasible. For example, the benthic infaunal core samples, photometer profiles, suspended solids measurements, turbidity and other h situ parameters, intensive macrophyte monitoring, aerial photography and the salt marsh program should be synoptic whenever possible. Similarly, the mero-plankton and fisheries sampling should coincide whenever feasible. This approach would enabid' cross correlations and the discerning of relationships between the different components relative to the power plant impacts. Table 1 summarizes the proposed changes to the POS. e {

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Table 1. Summary of proposed revisions to th2 Plcn of Stt1dy (POS), Crystal River Units 1,2 ad 3 NPDES 316; Ecological Progra2n. PLAAI CF STiay Pe0PCSED 48VISIQuS ) les. o f Ile. of Total ate. Study Ian, of, see. ef Total leo. Study y St w y component Statione Ass. Prequency secolee Perted Statione neo. Prequency semples Perted a IA sentnie Care 52 5 simonthly 1.560 12 mee 20 6 Quarterly 600 15 aos 33 nonthly 1.900 12 moe 20 6 6 wks 1.200 15 aos a senthat trew! la 3 rionthly 1.294 12 ene 0 0 0

== day /nacht Quarterly + C necrophyte 300 10 Bisonthly + 21.000 12 mas SO 10 1 Prelistnary 3.000 15 aos napping i Preatmanary 9(intene.310 6 wks 900 15 aos 9 tinten6.3 5 6 ute 450 15 aos D Aertal photo-1 1 Quarterar*1 5 12 mos 1 1 Quarterly + 6 15 ene grapne prettaanary 1 Preliminary E Oyster Reef 10 3 Quarterly 120 12 moe 9 3 seonthly 6 466 12 aos atmentaty F suctton Dredge 10 1 nonthly 120 12 une 0 0 0 C Salt marsh 4 10 asamathly 480 12 aos 8 24 6 wte 1,920 15 mes program N art &faCaal 6 S nonthly + 450 12 mes 0 0 0

== Sunstrate 3 tanee 1 Phyescal as chloropnytt *e ' O O 0 0 2 depths tseemly 1.040 15 see bl Sedament SS 2 hace 340 12 aos 40 3 Quarterly 600 15 ees c) Photometry SS 1 proftle monthly 1.020 12 mos 40 1 prottle seemly 2.600 15 ses Ji yurbadaty 0 0 0 40 2 depthe meesty S.200 15 mos 11A tapangement 3 4 weekly + 660 12 me 3 4 weesty + 660 12 aos 3 times 3 tamos a Entraanment 2 5 +4 2 stweemly 3.120 12 aos 15 3. taweetly 2.Seo 15 ees estra day /ntght day /naght dept *e b) C sur...i periale v one 1814 richerles 13 Trawl la 2 nontAly 240 12 moe 9 7 nonthly 156 12 aos Idayl (nighti 21 seines 6 2 nonthly 144 12 aos 4 2 nonthly 96 12 ses 31 trasmet not 10 2 nonthly 240 12 mae 0 0 0 el Drop not 2 2 nonthly 44 12 ene 2 2 nonthly 44 12 see 51 Block not 4 1 nontaly 96 12 mos 4 2 nontAly 96 12 aos nacht/ day (day) 63 Block seines 0 0 0 4 11 montaty $28 12 aos ua y, 71 Crab trape 170 1 17 ttmas 2.040 4 aos 120 1 17 ttmas 2.040 4 ene

4) Crah 1

1 17 times 17 4 mee 1 1 17 times 17 4 aos Lapingement e water Quality 28 1 Se. ore! 15.356 12 mes 0 0 0 Parnmetere SVA Sediment Survey

1) Sediment procee 200 1

Once 200 1 ao 0 0 0

==

2) Grat samplee 100 1

once 100 1 me 0 0 0 Il Sediment coree 64 1 Once 64 1 no 0 0 0 48 Sedlapnt trape 53 1 nonthly 636 12 mos 0 0 0 53 Photometer prottles 64 1 profile monthly 768 12 moe 0 0 0 61 Suspended toede 0 0 0 40 4 e1weesty.. 5.120 15 ees 18

..~. - 3.5 Physical Studies () The Contractor's proposed physical study program differs from the program MODIFIED: + described in the POS in several areas. Each of the changes are necessary See Note.1, to provide the best possible results for the study program. The changes p.31. will not result in additional expense-over the program described in the POS and in some cases will result in significant cost savings. The i Contractor is proposing. these changes with the understanding that FPC is willing to consider more current, state-of-the-art modeling techniques

~

than those described in the POS. It should be noted that these tech-niques have been previously employed at the Big Bend Stations, and the results_have been submitted to EPA, Region IV as part of a successful 316 demonstration. - If FPC requires the use of NYRO-3 and QUAL-3, the Con-tractor is prepared, as an option, to conduct the physical study program as specified 'in the POS, including performing the modeling with HYDRO-3 and QUAL-3. -The cost to perform this option is not included in this pro-posal, but assuming the models are made available to the Contractor, we are prepared to assume the cost of implementing the models on our spstem, qualifying them, and otherwise ensuring that they are available and run-ning properly. The major differences in the proposed programs and the reasons for the j differences are as follows: 1. For the far-field modeling, the. Contractor proposes using CAFE and DISPER, two finite eleesnt models that have been used ex- . ( )F tensively and are familiar to state and federal agencies. These models will be used in place of HYDRO-3 and QUAL-3, the finite difference models described in the POS. The Contractor pro-poses finite element models rather than finite difference models because of the inherent superiority of the finite ele-ment method in several areas, including a)'a much more realis-tic spatial representation of the modeled area, b) more flex-ible use'of boundary conditions and c) variable grid size. The variable grid size is particularly useful for this situation, because it effectively eliminates the need for a separate fine grid application in the vicinity of the station, as proposed in the POS. Basically, the finite element method is a funda-l mentally. more powerful technique for solving partial differen-l tial equations. More detailed discussion on CAFE and DISPER is t. presented in Section 3.5.3. l l 2. The Contractor proposes to use a separate near-field model in l )' the immediate area of the discharge. The study program in the POS proposes using the far-field models, HYDRO-3 and QUAL-3, to predict the temperature distribution in both the far-and near-field regions. This technique een be very expensive and will generally result in poor temperature predictions due to the inability of far-field models to simulate accurately the de-tailed hydrodynamics near the point of discharge.,In addition, the smallest grid spacing specified in the POS, 550 ft, is .still too coarse to obtain the detailed near-field predictions -s typically required by regulatory agencies. I i' C2/5294522/3/2RH 21 i ._.-.___.-.-..__...._......_,..-.,_-....----._,~,._--m..

= 3. The Contractor proposes to specify tidal fluxes as boundary conditions in all applications of the far-field hydrodynamics model, CAFE. The Contractor's experience in dealing with open coastal regions, such as the study area, indicates that the application of tidal heights and zero gradient flux, as sug-gested in the POS, may lead to erroneous results. This is dis-cussed in more detail in Section 3.5.4. 4. The Contractor proposes a different arrangement of current meters and tide gages than that described in the POS. This is due to the different monitoring requirements for the specifi-cation of boundary conditions in the far-field hydrodynamic modeling. The difference in the specification of boundary con-ditions is described above. 3.5.1 Data Collection As described in the POS, the physical monitoring program is divided into MODIFIED: two complimentary subprograms, one long-term and the other short-term. See Mote The long-term program will consist of continuous temperature recording Marine and biweekly temperature and salinity profiling for the period of 1 year Revisions to (Figure'22). An initial reconnaissance of the study area will be per-POS Sect. formed for station selection and marking. Seventy-two stations will be 2.1.7,p5. selected to measure temperature-continuously for 1 year. Ryan J thermo- . graphs will be used, with 36 additional instruments available as backups to insure uninterrupted data yield. Biweekly inspections will be made at O all stations. Instruments will be anchored with steel cable. There will be, in addition to the 72 thermographs, a synoptic temperature MODIFIED: and salinity profile sampling program. In 26 episodes, on a biweekly See Mote basis, salinity and teurperature will be measured in 90-minute windows Marine around a high and low tide at 21 thermograph stations. Measurements will Revisions to be surface, middle, and bottom, with Beckman meters, using three boats, POS Sect. each boat doing seven stations. 2.1.7,p5. Water samples will be collected every 10th measurement as checks on fielo instrument performance. At these stations, air and water temperature, dissolved oxygen, pH, conductivity, salinity and Secchi disk will be measured at surface, middle, and bottom. Hard copies of all field, cal-ibration, and sample custody logs, and all QA forms will be archived at MNL and data transferred to magnetic tape. A weather contingency plan will be in effect to remove the thermographs in the event of a major storm. A bathymetric survey is also included within the long-term program (Figure 23). Channel cross sections will be determined at each tributary and canal station occupied by recording tide gages. Control points will be established on each bank, as near as possible to local benchmarks. Staff gages will be placed at each station prior to cross-section depth measurements. Depth will be measured using Sitex Fathometers verified by hand-held lead lines made of steel tape to avoid elastic error. Depths b will be measured at 3-to 5-m intervals across each stream, or five soundings will be made, whichever is greater. Water level will be read C2/5294522/3/2RH 22

A' at each staff gage before and after soundings, and time f each reading U will-be recorded. Open. water;bathymetry will be established, using electronic surveys reg-istered against surveyed control points. Control points will be chosen among existing and proposed permanent navigation markers, augmented by targets. One target will be located at each seaward corner of the study area. Each ' target will be surveyed for horizontal position by a re-gistered land surveyor.- Results will be transposed to the Florida State Plane' Coordinate System and project base maps. A float plan for onbcard bathymetry will be determined by reviewing existing bathymetric charts and. aerial photographs. The plan will be a grid of rumbered transects with fixed ends and known crossings t, facilitate mapping. The survey will be performed using an automated data system, including a survey precision digital Fathometer, a Hewlett-Packard onboard computer for processing and a Motorola Mini-Ranger electronic rangefinder for hor-izontal control. Primary electronics will be manned by trained.staf f. The vessel will be operated by crew responsible for backup equipment. - Secondary equipment includes Loran C and hand-bearing compass, Sitex Fathometers, and lead lines. Manual checks will be conducted at 5-minute intervals during the survey, including all transect end points.. as quality control measures. The survey will be timed to coincide with semidiurnal high tides on calm days to improve signal reception and read-ability and decrease noise. Output will include real-time fathometric traces registered to horizontal controls and bathymetric contour charts of all navigable water. All land masses, including spoil islands, i marshes, and shoal areas, will be defined on outputs. The Contractor recommends that the temporal extent and level of detail of ' CLARIFICATION: No reduct. ion the long-term program be reduced. In particular, in situ temperature of thermo-data may-be necessary only during the periods of the short-term program (60 days), and the number of stations can be reduced somewhat. This re-graph effort 4 duced level of effort will provide all the necessary data at significant has occurred. cost savings. Although the Contractor has estimated this task as spec-ified in the POS, the Contractor recommends a discussion on scope re-duction for this task following selection of the contractor. The short-4.erm program will provide current and tidal height measurements ' MODIFIED: (Figure 24) necessary to calibrate and verify the hydrodynamic far-field model. CAFE (described in Section 3.5.3). There will be 13 current See Note 2 meters and 6 tidal gages deployed as 'nown in Figure 25. These meters and 3, p.31. will provide continuous data for 1 raath during the siunmer and 1 month 4 during the winter. The arrangement af meters is different from that in 4 the POS because of the Contractor's approach to the specification of i . boundary conditions. This approach is necessary to obtain the best pos-sible results from the hydrodynamic modeling. An initial reconnaissance of the study area will be performed for station e selection and marking. Stations will be selected to measure free surface j! elevation, current speed and direction at fixed depth, temperature at fix,ed depth, and salinity at fixed depth. Stations will be fixed with Loran and visual bearings on primary control points (refer to section on V permanent marker network). C2/5294522/3/2RH 23 _._..e --..,.-,.,,m.,3-. _,c. s ,e e.,..~,_4,.,.w _..,,._y,,.,,,,,,...,,, _. _ ,,,ww-p ,._.,.,,..,,...,,,,.e-

1 After initial acceptance testing, Endeco 174s will be placed on station, with additional instruments available as backups. Instruments will be anchored with steel cable and set a prescribed distance away from visual station markers to minimize loss and/or vandalism. There will be two sampling episodes; 30 days during summer and 30 days ' MODIFIED: i during winter. Instruments will be inspected on a weekly basis. Verti-See Qtr 1 cal velocity profiles will be made with Endeco 110s immediately adjacent Report,p2-3. to the -in situ stations. These vertical profile measurements will be made around the occu:: ence of maximum flood and maximum ebb four times during the summer episode, and four times during the winter episode. Profile measurements will be conducted by two crews working simulta-neously. Three Endeco 110s will be employed, one as a backup. In addi-tion to prefield calibration, meters will be calibrated immediately be-fore each station measurement. Meters will be equipped with shallow water harness, and boats will be fitted with extension booms to minimize hull bias. Boats will anchor bow and stern when necessary to eliminate drift during measurements. At each station, air and water temperature, dissolved oxygen, pH, con-MODIFIED: ductivity, salinity and Secchi disk will be measured at surface, middle, See Mote and bottom. Beckman meters will be used. Water samples will be col-Marine lected every 10th measurement as checks on field instrument performance. Revisions to Hard copies of all field, calibration, and sample custody logs, and all POS Sect. Os QA forms will be archived at MML, and data will be transferred to mag-2.1.7, p5. netic tape. Climatological data will be measured by an automatic weather station (Aanderaa Instruments) set up on the intake jetty near channel markers 25 and 26. It will measure and record on magnetic tcpe the following phys-ical parameters: average wind speed, maximum wind speed, wind direction, air temperature, barometric pressure, solar radiation, and e.infall. Measurements will be at a 1-hour interval for 1 year. Weekly maintenance visits will be made. Dry-bulb and wet-bulb temperatures will be obtained at the weather station by an observer or from the weather station at the l power plant. i l Field measurements for the sediment survey consist of sediment depth, MODIFIED: l sediment cores, sediment grab samples, sediment traps, photometer pro-See Mote filing and water column samples. The Contractor proposes to conduct this Marine survey as presented in the POS. Revisions to POS Section The vertical thickness of unconsolidated sediments between the water-2.1.7, p5 & sediment interface and the underlying consolidated limestone will be mea-5.1, p15. I sured at 200 locations throughout the study area by inserting a measured { steel reinforcing rod into the sediment. Sediment grab samples will be l collected during the initial stages of the field program at 100 sites as l indicated in Figure 26. Collections will be made using a hand-held dredge similar to that described by Cottrell (1978). This instrument will permit the diw r to recover the top 2 cm of sediment. Continuous i sediment cores will be collected at 64 sites, using a piston push-core technique with pipe slips and a portable aluminum tripod for holding the piston. Cores will be drained slowly and returned to the laboratory for C2/5294522/3/2RH 24

L i. description and sampling. Freezing of these cores in the field is not MODIFIED: necessa ry. gee gote Marine Sediment traps will be emplaced at the 50 open water sites where sediment Revisions to cores are collected and at 3 canal and river sites (Figure 27). Traps POS Section will be the same as those described by Cottrell (1978). They will be 5.1,p15-16 made from 10 cm ID PVC pipe cut into 45 cm lengths and set vertically i into square concrete bases. Smaller PVC pipes will be inserted into the large pipe to act as baffles and prevent sediment loss by resuspension. A permanent end cap will be cemented to the bottom of each pipe. A tem-porary cap will be fitted to the top of each pipe prior to removal and return to the laboratory for analysis and cleaning. Monthly, the traps will be removed and replaced with a similar unit. Each trap location will be marked with a float for rapid identification during monthly ser-vicing. In the laboratory, sediment grab samples Ull be prepared for grain, size analysis, percent CACO, and percent organic matter in accordance with 3 the grab sample and sediment core preparation flow diagram. Sediment cores will be sliced lengthwise, described and analyzed for size anal-ysis, percent CACO, and percent organic material every 15 cm, unless 3 texture changes suggest more closely spaced samples. Procedures will be in accordance with the grab sample and sediment core preparation flow diagram. Sediment trap samples will be removed from the trap in the laboratory. Only nonliving material will be processed, i.e., clams and any other living organisms will not be considered a part of the sediment. 3.5.2 Data Analysis 1 l All the data obtained from the current meters and tide ga'ges will be re-l ceived on magnetic tape. These data will be processed and plotted versus time by an existing, Contractor computer plotting program. Vertically i averaged velocities will be obtained from the current meter data by using the velocity profile data as outlined in the POS. Climatological data obtained from the weather station described in the POS will be received on magnetic tape. These data will be processed and tabulated. CLARIFICATION: Final version Data from the bathymetry survey will be received on magnetic tape. These not on tape, data will be processed and a bathymetric contour plot will be developed Product is a from the data. map with depths along Temperature data for all 72 in situ thermographs, located as described in transects. the POS, will be sent to the Contractor on drum charts. The Contractor will then present this data in plotted form. Temperature and salinity profile data for all 21 profiling stations and for all biweekly surveys will be presented in tabular form. A Isothermal contour plots will be developed for eight typical conditions: flood, high water slack, ebb, and low water slack for the summer and winter seasons. In addition to the lateral temperature information, O these figures will contain vertical profile informition. C2/529452273/2RH 25 +-m, e--y ---ry r ,.,,---%m>v,---__,..,-%y,,,,,.,.me, w.y___,- -, .-.e,_ - -.,,.-.-.----,--.,..-.-,,,.#% ~- -. _,. - -

t p The analyses of the 200 sediment probes, 100 grab samples #and 64 sediment MODIFIED: v cores will provide depth of sediment, mineral percentages, percent or-Sec Mote ganic matter and inorganic carbonate, particles size distributions, and Marine standard. statistical measures of mean grain size, sorting, skewness, and Revisions to kurtosis, as described in the POS. Data displays will include geological POS Section cross sections, tabulations of parameters and contour maps of constituent 5.1,p15-16. concentration. The analyses of the sediment trap samples, photometer profiles, and water column aamples will provide mineral percentages, suspended solids con-centrations, t.urbidity, sediment acctmulation rate, and percentage of total organic carbon and calcium carbonate, as described in the POS. Data displays will include contour maps, cross sections of concentration, gradients, and areal variations in concentration. 3.5.3 Descriptions of Mathematical Models i General The models proposed for this study, CAFE & DISPER, are two-dimensional, finite element models that were developed at Massachusetts Institute of Technology (Wang and Connor, 1975; Leimkuhler et al, 1975). CAFE, the hydrodynamic model, is.used to determine water velocities and tide levels in the region of interest. DISPER, the dispersion model, uses the water velocity and tide level data from CAFE in order to determine the tempera-ture distribution or concentration distribution of specific parameters. ' CAFE and DISPER have proven to be an extremely flexible model pair. The applications of these models have included hydrothermal analysis (Galya and Colangelo, 1981; Mangarella, 1979; Kaufman and Adams, 1981), sediment dispersion analysis (Leiskuhler et al, 1975), intake / discharge recircula-tion studies ~(Kaufman and Adams, 1981; Wang and Connor, 1975) and an analysis of hydrodynamic changes due to bathymetric modifications (Graham et al, 1979). [ The large varirbility in the types of water bodies in which CAFE and DISPER have been applied also points out the flexible nature of these models. The applications of these models have included the following c locations: Tampa Bay, Florida (Stone & Webster, 1980a; Galya and Horst, j 1981); Biscayne Bay, Florida (Wang et al, 1978); Apalachicola Bay and l St. George Sound, Florida (Graham et al,1979); off the New Jersey coast near Little Egg Inlet (Wang and Connor, 1975); Massachusetts Bay l (Leimkuhler et al, 1975); Narragansett Bay, Rhode Island (Wang and Con-l

nor, 1975); Hingham, Hull, and Quincy Bays, Massachusetts (Stone &

I' Webster, 1980b); Galya and Colangelo, 1981); Long Island Sound near i Wate rford, Connecticut (Kaufman and Adams, 1981); Mt. Hope Bay, Massa-chusetts (Kaufman and Adams, 1981) and Penobscot Bay, Maine (Stone & J Webs t e r, 1979). The results of studies using CAFE and DISPER have been submitted to state agencies,. including the FDER and federal agencies such as' the U.S. En-vironmental Protection Agency and the U.S. Nuclear Regulatory Commission, h. These results have been included in documents such as 316 a and b j Demonstrations, Environmental Reports, and Plant Feasibility Studies. l l_ C2/5294P22/3/2RH 26 i f

{v') CAFE and DISPER use the finite element method to solve the governing differential equations. The finite element method is in many ways su-perior to the finite difference method. In particular, the finite ele-ment method allows a much more realistic spatial representation of the modeled area, more flexible use of boundary conditions, and variable grid size. CAFE CAFE uses input parameters such as study area geometry, bottom roughness, and boundary conditions (water levels or fluxes) in solving vertically integrated equations of conservation of mass and momentum. The signi-ficant features of CAFE are: Formulation of the governing equations in their most general form, including the effects of advection of momentum, bottom friction, wind stress, barometric pressure variations, rotation of the earth, momentum losses due to study region geometry, pressure gradients, and variable bathymetry. Varying grid size. Flexible use of boundary conditions. Realistic simulation of geometric features of the study region. Time-varying climatology. Input of freshwater runoff, and intake and discharge flow rates. Disc output of tide heights and water velocities for input to DISPER. A detailed description of CAFE and its applicability to modeling situa-tions such as those proposed here are presented by Wang and Connor (1975). DISPER DISPER is a dispersion model which accepts input parameters such as study area geometry, dispersion coefficients, a decay parameter (such as at-mospheric heat exchange for temperature simulations), and time varying values of water velocity and depth from the CAFE output. The model employs these parameters in solving the vertically integrated form of the convective diffusiou equation. DISPER incorporates the following features: Varying grid size. Formulation of the vertically integrated convective diffusion q equation in its most general form, including the effects of O C2/5294522/3/2RH 27

J time-varying flow and water depth conditions, advective trans-s s_) port, anisotropic dispersion, production and decay of non-conservative constituents, and variable bathymetry. Input at each computational time step of calculated velocities and water depth from CAFE. Realistic representation of study area geometry. Generalized boundary conditions which allow the specification of time-varying or constant concentration levels or concentra-tion gradients. In addition to the features of the model mentioned above, DISPER has the capability of representing the dispersion coefficient in the study area by two methods. These methods are 1) calculated from velocity gradients as described by Christodoulos et al (1976) and 2) specifying the disper-sion coefficient throughout the study region. Of these two methods the latter is preferable, as each water body has unique dispersion charac-teristics which are best determined by field measurements. DISPER is applicable for many different types of simulations including temperature, sediment particles, and meroplankton. Details of the model are presented by Leimkuhler et al (1975). Near-Field Model O k/ The use of a near-field model will permit accurate temperature predic-tions in the region of the plume near the discharge structure. The use of a far-field model to predict temperatures in the near-field region of a discharge can be very expensive and will usually result in poor ten-perature predictions due to the inability of far-field models to ac-- curately simulate the detailed hydrodynamics an the vicinity of the dis-charge. Therefore, the Contractor proposes to use a near-field model based on the work of Jirka et al (1981) in order to determine the de-tailed near-field temperature distribution with much greater accuracy. This model is particularly appropriate for the Crystal River discharge because it is applicable for discharges into shallow water. 3.5.4 Application of Mathematical Models Far-Field Models The initial setup of CAFE and DISPER consists of dividing the study re-gion into an array of discrete triangular elements. The finite element models allow the use of variable grid size, thus effectively elizinating the need for a separate fine grid model in the vicinity of the plant. It is anticipated that approximately 300 elements will be required in order to model the study region properly. A representative finite element grid for the study region is shown on Figure 28. C2/5294522/3/2RH 28

CAFE Calibration of CAFE will be accomplished by matching model results to field measurements of water level and current velocity. The bottom fric-tion coefficient will be adjusted throughout the study region until the field and model results com are favorably. The ambient conditions such r as wind velocity, river flow input, and boundary tidal fluxes existing at the time of the field measurements will be generated as input to the mo-del. In order to assure the widest possible applicability, the model will be calibrated using measurements obtained during the summer and verified using measurements obtained during the winter. CAFE will then be used to simulate water velocities and tide heights under average tidal, wind, and fresh water input conditions. Initial water velocites will be set to zero, initial tide levels will be. set to mean low water, and the model will be run until a quasi-steady stat'e sol-ution is reached. A quasi-steady state solution is one in which water velocities and tide heights are repeated from tidal cycle to tidal cycle. The results of the final application of CAFE will be used as input to DISPER. In all applications of CAFE, tidal boundary conditions will be specified in terms of tidal fluxes. The Contractor's experience in dealing with i open coastal regions, such as the study area, indicates that the appli-cation of tidal heights and zero gradient flux for boundary conditions, as suggested in the POS, may lead to erroneous results. This is because numerical far-field hydrodyncaic models, such as proposed here (CAFE) and in the POS (HYDRO-3), are extremely sensitive to tidal height boundary conditions, especially in open coastal areas. In addition, it is dif-ficult to obtain tide data that is detailed and accurate enough to drive such a model properly. A zero flux gradient along the north and south boundaries may be adequate. However, specification of the actual flux will almost certainly result in a better representation of the hydro-l dynamics in those areas. Thus specification of tidal flux along the entire boundary is the preferred method. DISPER l l Calibration of DISPER is accomplished by determining the dispersion co-efficient throughout the modeled region. This method is preferable to using mathematical determinations of dispersion, as it allows a precise i calibration of the unique dispersive characteristics of the area under l study. The calibration effort will consist of adjustment of the dispersion co-efficient until satisfactory agreement is obtained between model results } and temperature rise values derived from field data. The plant heat dis-l charge rate existing at the time of the survey will be i,nput. Current velocities and tide heights in the study region will be obtained from the i results of a CAFE simulation. In addition, ambient meteorological con-y ditions and water temperatures will be used to determine the heat trans-fer coefficient so that the only unknown parameter will be the dispersion C2/5294522/3/2RH 29 i

1 coefficient. This calibation procedure will be performed for a complete ~ {3 tidal cycle using summer field data. As with CAFE, winter field data s_ will be used to verify the model. Application of DISPER will consist of two parts: thermal modeling and meroplankton entrainment modeling. The thermal modeling will predict temperature rise throughout the study region over the period of a tidal cycle under average and worst case conditions. Input conditions specific to this application of DISPER include the plant heat discharge rate and the atmospheric heat exchange coefficient. The initial temperature rise will be set equal to zero and the model will then be run until a quasi-steady state solution is achieved. The results will give the far-field temperature distribution of the plume. Meroplankton entrainment modeling involves a two-phase effort:

1) the specification of ambient concentrations of meroplankton at the open water boundaries without a sink term, in order to simulate the ambient patterns obs e rved and 2) application of a _ conc.entration-dependent sink term (en-trainment loss) to represent the effect of the power plant.

The reduction of n.eroplankton concentration in each element will then indi-cate the effect of the plant on the meroplankton population. Approxi-mately 20 such simulations will be made. The Contractor has extensive experience with this method of analysis. Source Water Body Analysis (~') In order to identify and quantify the source water bodies and their con- \\' tribution to the plant intake flow, CAFE will be used to calculite flow streamlines fer the time-averaged flow velocities in the study area. By integrating the velocities across any two streamlines, the volume flux toward the intake frca various source regions will be determined. This method was proposed in the POS as the second approach to the source water body analysis. The first and third methods proposed in the POS, although relatively easy to apply, are not included in this proposal because they will not provide the desired information. With these methods, the source area flow con-tribution would be calculated from the intake flow rati' and tracer ' con-centrations at the sources and intake locations. The analysis in the POS requires that only advective effects are present. However, the concen-tration at the intake point would be determined by both advective and dispersive effects. Thus the Contractor proposes to use the method de-scribed above for the source water body analysis and the previously de-scribed meroplankton entrainment modeling in order to determine the en-trainment effects of the plant. Near-Field Modeling Calibration of the near-field model will consist of the determination of plume characteristics. This will entail the use of field temperature measurements. As with DISPER, measurements from the summer will be used for calibration and measurements from the winter will be used for veri-() fication. The near-field model will be applied to worst-case and average conditions, comparable to those used in DISPER. The results of the near-C2/5294522/3/2RH 30

i field analysis will then be combined with those from far-field anal- ~ e-)s-ysis in order to obtain the complete temperature of the discharge is_ plume. NOTE 1: (Reference ATT.2, p.21) POS refers to Section 4 of the Plan of Study for the Crystal River 316 Demonstration submitted to EPA on November 16, 1982. The enclosed document "3.5-Physical Studies" was prepared by Florida Power's environmental consultant (Stone & Webster Engineering, Inc.) in response to Section 4 of the Plan of Study. NOTE 2: (Reference ATT.2, p.23) Double line (11) denote changes made to this attachment subsequent to its original submittal on February 22, 1993. NOTE 3: (Reference ATT.2, p.23) Instrumentation for the short-term program was increased from the orignially proposed 13 units to 16 units (tide,

current, temperature, and salinity) in order to provide sufficient

(~') hydrographic data to develop an alternative modeling approach should N# CAFE and DISPER prove inadequate for use at Crystal River. Station locations for each of the 16 units is shown in the text on page 15 as Figure 2-8. This program change was made subsequent to submittal of the Physical Program plan of study on February 22, 1983, and in response to EPA and FDER questions raised at a study planning meeting held in Tallahassee, Florida on April 12, 1983. . Only that data required for development of CAFE and DISPER is being analyzed as part of the present program (13 current meters and 6 tide gauges). Data from the remaining units will be analyzed only if required for alternative models. Y *% >v c2/5294522/3/2RH 31 E

References ) J Christodoulou, G.C. et al. Mathematical Modeling of Dispersion in Stratified Waters, Tech. Report No. 219, R. M. Parsons Laborato ry for Water Resources and Hydrodynamics. Massachusetts Institute of Tech-nology, Cambridge, Massachusetts, 1976.

Galya, D. P.

and Colangelo, P. M. Finite Element Modeling of A Complex Embayment System, Proc. Third Waste Heat Management and Utilization Conference, Miami Beach, Florida, 1981.

Galya, D. P.

and Horst, T. J. Meroplankton Entrainment Modeling in a Coastal Bay, Proc. Third International Conference on State-of-the-Art in Ecological Modeling, Fort Collins, Colorado, 1982.

Graham, D. S.

et al. Predicting Circulation Changes from Bathymetric Modification, Proc. Spec. Conference on Civil Engineering in the Oceans, San Franciso, California ASCE, 1979.

Jirka, G. H.

et al. Buoyant Surface Jets, Journal of the Hydraulics Division, ASCE, New York, New York, November 1981, Vol 107, No. Hy 11, pp 1467-1487. Kaufman, J. T. and Adams, E. E. Compiled Near and Far Field Thermal Plume Analysis Using Finite Element Techniques. Energy Lab Report No. MIT-EL 81-036, Massachusetts Institute of Technology, 1981. Leimkuhler, W. F. et al. Two-Dimensional Finite Element Dispersion Model, Proc. Symp. on Modeling Techniques, Modeling 75. San Francisco, California, 1975. Mangarella, P. A. Thermal Impact Modeling in San Francisco Bay, Proc. Speciality Conference on Conservation and Utilization of Water and Energy Resources, San Francisco, California, 1979. Stone & Webster Engineering Corporation. 316 Demonstration, BA Bend Station - Unit 4_ for Tampa Electric Company, Boston, Massachusetts, 1980a. Stone & Webster Engineering Co rporation. Edgar Station - Plant Feasi-bility Study, Boston, Massachusetts, 1980b. Stone & Webster Engineering Corporation. Report on Calibration of Tidal Circulation Model and Preliminary Assessment o_f Meroplankton Dispersion for Design g 1979 Sampling Program, Boston, Massachusetts, 1979.

Wang, J. D.

and Connor, J. J. Mathematical Modelina g Near Coastal Circulation, Tech. Report No 200, R. M. Parsons Lab for Water Resources and. Hydrodynamics, Massachusetts Institue of Technology, Cambridge, Massachusetts, 1975.

Wang, J. D. et al. Canal Discharae into South Biscayne Bay, Rosentiel School of Marine and Atmospheric Scieace, University of Miami, 1978.

C2/5294522/3/2RH 32

e d IANG-TE184 PHYSICAL SRfDIES Docuograph and Synoptic T-S Soupling Station Selection Mapptng Marking Instrument Prociarament Maintenance Acceptance Testing and W Develorment taboratory Calibration of Instrtements 91-weekly inemtion, Maantenance. Data Collection

91-weekly Synopti

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FIRST QUARTERLY PROGRESS REPORT CRYSTAL RIVER STUDIES OCTOBER 3,1983 O Contractor Stone & Webster Egineering Corporation Subcontractor Note Marine Laboratory Prepared for Florida Power Corporation P. O. Box 14042 St. Petersburg, FL 33733 v., -n,, ,.,,-m----- --e-.m,. e-,--, ,ne---,,.,-.,-----,.--w,-..,-,w,.,,_ n,- --,-n,-------

TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 PROGRAM, MODIFICATIONS 2.1 BENTHOS 2.1.1 -Aerial Photographs 2.1.2 Oyster Reef 2.1.3 Physical Parameters 2.2 IMPINGEMENT AND ENTRAINMENT 2.2.1 Entrainment Stations 2.2.2 Entrainment Sampling in Creeks 2.3 FISHERIES 2.3.2 offshore Seines 2.3.3 Block and Creek Seining 2.3.3 Crab Tagging 2.4 PHYSICAL STUDIES 2.4.1 Current Profiling 3.0

SUMMARY

OF PROGRESS 3.1 MOBILIZATION-3.2 FIELD COLLECTIONS 3.3 LABORATORY ANALYSES 3.4 DATA COMPUTERIZATION 3.4.1 Input 3.4.2 Processing 3.5 PHYSICAL MODELING 4.0 DATA TABLES-NOT INCLUDED IN THf C

4.1 INTRODUCTION

4.2 BENTHOS 4.3 IMPINGEMENT AND ENTRAINMENT 4.4 FISMERIES 9 4.5 PHYSICAL DATA

s

1.0 INTRODUCTION

( ). In response to. the requirements of Par' III-H, NPDES Permit No. FL0000159 dated July 9, 1979 for Crystal River Units 1, 2, and 3, Florida Fuwer Corporation prepared an ecological monitoring program for the area adjacent to the Crystal River power plant site. The ecological monitoring program is designed to address the objectives of a 316 demonstration as set forth in: " Interagency 316(a) Technical Guidance Manual and Guide for Thermal Effects Sections of Nuclear Power Facilities Environmental Impact Statements" and "Guidanca for Evaluating the Adverse Impact of Cooling Water Intake Structures on the Aquatic Environment: Section 316(b) P.L. 92-500." Comparisons of data (control versus effected areas) will be made within the proposed study and with previous studies, where appropriate. The coastal area west of the power plant is characterized by salt marsh dominated by Juncus roemarianus with narrow bands of Spartina alterniflora near the water's edge. The, bottom in the ad]acent coastal marine area is comprised of sand,

mud, shell hash (oyster bars), and exposed lime rock with scattered patches of seagrass, attached benthic ' algae, and attached benthic invertebrates.

The sampling program was designed to address the following impacts: 1. Thermal impacts from the operation 'of the power 'O plant (316 (a)). 2. Intake effects in the form of larval entrairment and adult impingement (316 (b)). The Crystal River monitoring program is summarized in Table 1-1. This table indicates the types of sampling, number of sampling

stations, number of replicates, frequency of sampling, total number of samples, and the overall duration of sampling.

Each element of the program falls under one of four major headings: Benthos, Impingement ar.d Entrainment, Fisheries, and Physical Studies. t 1-1

o o O. 1ABLE 1-1

SUMMARY

Of ECOLOGICAt_ PROGRAM CRYSIAL RIVLR STUDIES No. or No. or Total No. Study Study C_oseo_ntf)1i. Stations Rep. f recuencv _Seasles Period 1. Benthos 4 A. Benthic core 20 6(+2) Quarterly 600 15 mos 20 6(+2) 6 wks 1200 15 mos B. Macrophyte mapping 50 10 Quarterly + 3000 15 mes 1 Pre l imi na ry 9(intens.) 10 6 wks 900 15 mos 9(intens.) 6 wks 450 15 mos I C. Aerial photographs 1 1 3 times 3 15 mos i l D. Oyster rear 9 90 Monthly & 14580 12 mos Bimonthly i l E. Sa l t ma rsh p rog ram 8 24 6 wks 1920 15 mos F. Pt';y s s ca l a. Chlorophyll 'a' 8 2 depths Weekly. 1040 15 mos b. Sediment 40 3 Quarterly 1200 15 mos c. Photometry 40 1 profile Weekly 2600 15 mos d. Turbidity, D.O., 40 multiple Weekly 5200 15 mos pH. Salinity, depth T empe ra tu re e. Sediment Temp-40 1 depth Qua rte rly 200 15 mos 4 e ra tu re, Eh 20 1 depth 6 wks 200 15 mos II. Impingement and Entrainment A. Impingement 3 4 Weekly + 660 12 mos l 3 times B. Entrainment 15 3 Biweekly 2880 15 mos day / night Ill. F i she ries A. Traws 9 7 Monthly 756 12 mos j (night) 8. Seines 4 2 Monthly 96 12 mas C. Drop net e 2 2 Monthly 48 12 mos i 1 of 2 4 1 e i l

O o o i TABLE 1-1 (Cont) No. or No. of Total No. Study Study Componeng Stations Rep. Freauency Samples Pe riod D. Creek trawls 4 7 Monthly 336 12 mos. (day) l E. Crab traps 120 1 17 times 2040 4 mo s * - j F. Crab impingement i I 17 times 17 4 mas IV. Physic.at Studies ] A. Suspended loads 40 4 analyses Biweekly 5120 15 mos l l B. B,nthymetry i 1 servey C. Short-term 16 1 Variable 2 mos 1 D. Long-Term 51 1 or 2 Continuous V&riable 12 mos E. Esteorology' 1 1 Continuous Va riable 15 mos j F. Tempe ra tu re p rof'i les Va riable 2 Va ri ab le Va riable 2 mos l i i 1 4 4 I } 2 of 2 4 i 5 a l

2.0 PROGRAM MODIFICATIONS () Every effort has been made to conduct the Crystal River study as previously planned and approved by agency personnel. At the same

time, it is understood that assumptions were mede during the planning precess concerning conditions which would be encountered and the app opriate sampling methods to be used at the site. The results of initial sampling and other experience gained at Crystal River have been used to evaluate these assumptions.

In several instances, changes to the program have been warranted. In each case, approval has been sought and obtained from Florida Power Corporation prior to instituting the change. The following material summarizes changes, by program component, made since field sampling was initiated. The changes noted are intended to provide data of equal or better quality than would have been provided by the earlier designs to fulfill the needs of the program. Each element of the field program has been carefully reviewed as it was initiated and-changes made if needed. All components have now been conducted at least once so few,' if any, additional chsnges are a.nticipated. Figures 2-1, 2-2, and 2-3 are provided to show revised sampling locations for crab traps, entrainment sampling, and seining. 2.1 BENTHOS 2.1.1 Aerial Photographs Os It has been proven impossible to obtain aerial photographs under summer weather conditions, primarily due to consistent haze. similar problems are anticipated for next year, and the macrophyte program, which uses the photographs, needs only photographs taken in early fall and spring. Thus, program requirements have been reduced to three photographs to be taken between August 1983 and April-May 1984. This level of effort better reflects site conditions. 2.1.2 Oyster Reef No adequate means could be found to clean oyster clumps for studies of associated fauna or to identify, weigh, and measure individual oysters within clumps for mortality and growth studies. Thus, individual oysters are used for the latter studies. These are placed in small wire trays - 10 in each tray, 9 trays for each station. Associated fauna is defined by harvesting three clumps of naturally occurring oysters at each station. These changes provide the desired information while overcoming the logistical problems. 2-1

- =. 2.1.3 Physical Parameters () Weekly temperature and conductivity data is to be collected within 90 minutes centered on a high or low tide. For several ' weeks, the attempt was made to cover 40 stations within this time frame, but while most stations were satisfactorily sampled, some were sample'd'too late. These delays also affected the collection of other water quality parameters within the four hour time frame for photometry, sometimes causing the longer period to be exceeded. Since the prime objective of the temperature data collection involves monitoring the thermal discharge area, the problems were corrected by reducing the number of stations at which temperature and conductivity must be measured within the 90 minute period from 40 to 27 (Stations 4 through 30). The stations remaining encompass all stations between the intake spoil and the barge. canal. The program has successfully met its goals since the change. 2.2 IMPINGEMENT AND ENTRAINMENT 1 2.2.1 Entrainment Stations Station B was intended to be a thermally-affected station, but review of temperature data collected in June indicated the station' was too far north and west. The depth of water at low tide (about 3 feet)-also made sampling impossible. Therefore, the station was moved south and east to coin:ide'with benthic O core station 20 to provide adequate water depth and exposure to the thermal discharge. Stations I and K represent control stations, but they were located beyond the area to be modeled and in an area observed to have different water quality conditions than elsewhere within the study area. To better reflect " control" stations and to permit the data to be used as input to source water body analyses, the stations were moved north and slightly west. 2.2.2 Entrainment1 Sampling in Creeks Towed net samples had been planned for Cutoff and Salt Creeks, however, irregular bottom contours and limiting water depths precluded this technique. To obtain samples representative of organisms moving in and out of the creeks, samples are now being taken at the height of ebb or flood tides using a stationary plankton sled. The sled is the same one used to collect grassbed samples. 2.3 FISHERIES 2.3.1 offshore Seines Bottom conditions precluded seining on either the north or south shores of the intake spoil. Feasible sampling locations, were found at Demory Gap and at Doghead Gap. These stations should f() 2-2

also be,more representative of thermal discharge conditi,ons than praviously planned locations. s I 2.3.2 Block and Creek Seining Initial efforts to conduct this type of sampling was unsuccessful due to creek size. topography, and bottom conditions. Alternative methods were considered at length but many were precluded by local conditions or by the need to provide a fairly representative sample of fish and macroinvertebrates in the creeks. While no gear would precisely substitute for seining, trawling proved to be feasible and will provide appropriate samples. 2.3.3 Crab Tagging On advice from local fishermen and the Department of Natural Resources (DNR), the crab traps are baited with shad rather than cat food. To be consistent with DNR and to reduce manpower ~- requirements, traps are left in place for seven days rather than five. To facilitate analysis and to provide information on crabs just south of the intake spoil, the four transects are now equal in length and Transect B has been relocated south of the intake spoil. 2.4 PHYSICAL STUDIES 2.4.1 Current Profiling A change was made in this component by reallocating the effort. In each of the five channels being sampled (intake, discharge, Crystal and Withlacocchee Rivers, Barge Canal), a transect with five stations is occupied rather than a single station. The effort at the eleven offshore stations will be reduced; each station will be sampled two rather than four times each month. The resulting data is sufficient for redeling, and overall, this change will enhance model input data. i l 2-3 I

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3.0 SU,MMARY OF PROGRESS O 21 ao=1tizirroa Mobilization for the program was completed on June 3, 1983, according to schedule. Mobilization activities completed were: Set up of physical facilities on site, i.e., laboratory trailers, docks, meteorological station, etc. Purchase of all equipment and supplies necessary to commence the project. Reconnaissance surveys and deployment of marker buoys. 3.2 FIELD COLLECTIONS All field collections were made according to schedule. No major problems were encountered. A summary of the field collections made during the first quarter is shown in Table 3-1. 3.3 LABORATORY ANALYSES Laboratory analyses of samples collected in the various components of the program is progressing smoothly. As expected, meroplankton (entrainment) samples are heavy at this time (spawning season) and, therefore, laboratory analysi's is lagging .s well behind the field collections. However, we expect to be caught up before March 1984 (during winter). All other j components are progressing according to schedule. A summary of the status of laboratory analysis is shown in Table 3-2. 3.4 DATA COMPUTERIZATION 3.4.1 Input l Acquisitien of suitable computer hardware to ensure compatibility between MML (input) and SWEC (processing) and placing the equipment on line occupied much of the first quarter. Establishment of standard data formats and initial input of various types of data took place primarily during August. To date, machine compatibility has been firmly established, but problems have risen in the development of standard formats for j the many types of data. The philoscphy has been to use input formats clo:,ely resembling or identical with field log records. Development of these new formats, rather than using existing ones, and incorporating the formats into the activities of each program component have taken a considerablo amount of time. This j effort has also been accomplished in parallel with field j collections and laboratory analyses. Problems have both delayed j input of some types of data and necessitated reentry o,f data i sets. O 3-1 I l

The problems now have been solved and we expect to be op schedule before the end of October 1983. Data has been entered (to date) () for the following samples Benthic core samples from July 25 (1983) sampling. a. b. Oyst'er reef samples from the first retrieval sampling (August 8 and 9,1983). c. Salt marsh samples from the first sampling'(June 13 through 17, 1983). d. Macrophyte samples from the first sampling (June 20 through 30, 1983). e. Photometry, temperature, salinity, and pH measurements from the first eight samplings (June 9 through July 26, 1983). f. Turbidity and chlorophyll "a" samples from the first eight samplings (June 9 through July 26, 1983). g. Icipingement samples from the first eight samplings (June 6 through July 26, 1983). h. Entrainment samnles from the first sampling (June 23 through 25, 1983). i. Fisheries samples from the first two samplings (June and July 1983)*. j. Suspended solids samples from the first four samplings (June 9 through July 20, 83). 3.4.2 Processing Data files are received by SWEC on diskettes, logged in, and read into the SWEC computer. To

date, files referenced in Section 3.4.1, as well as species codes and scientific names, have been received. Data for crab trapping and recapture, as well as data on length-weight, fecundity, and parasitism of selected fish and invertebrate species are not scheduled until the second quarter.

The data files received by SWEC were checked for completeness and accuracy with the eid of a computerized summary and variable range review. Data of almost all types have been checked. Problems have been identified as have the means to resolve them. At this writing, revised data sets are being produced to conform to agreed upon formats. 3-2 L

. s 3.5 PHYSICAL MODELING l )- The primary objective during this quarter has been to effect modifications to-the finite elementi model in order to better simulate critical features at the Crystal River site. The modifications, considered characteristically avoid changes within the central computational scheme, thus preserving the model's cualification derived from its wide use within the scientific community. The original model provided open-water boundary input of current or tide height in.the form of a sinusoidal function. The modifications are now complete which' allow tabular input of current and/or tide height ar9und the open boundaries. The model

can, therefore, be driven by _any periodic function which is derived from the field data collection program.

Modifications to better simulate the hydrodynamic behavior near oyster bars is in progress. In the presently favored scheme, the' sides of elements are to be locally aligned with the axis of the oyster bars. Nodal values are assign &d on each side in order to allow discrete longitudinal current and tide heights to be simulated on each side. Of course, the lateral current across the oyster bar applies to ~ elements on both sides and is calculated by a function describing flow through openings and overtopping, all. controlled by the tide height on,each side of the oyster bar. To date, 16 simplified finite element grid arrangements have been employed in an effort to ' systematically explore the properties of this scheme. l Another scheme is under consideration at this time wherein a flow restriction through the element side is effected by employing a single line ~ of nodes along the axis of the oyster bars. This scheme does not permit the discrete changes in longitudinal currents and tide heights available in the previous scheme, and this loss would have to be evaluated. Lateral currents would be simulated in eith'er case. Such a scheme is commonly employed in finite difference models. The bathymetry data collected has been reduced, and three separate source maps can be employed in determining local depths. All maps have been reproduced on mylar to the same scale in preparation for grid construction for the site. A primary purpose for the August short term surveys was plume delineation in the near field. Although the data have not been reduced, preliminary results of the August 13 survey have been prepared and included as ' Figures 4-1 through 4-8. The tide condition at that time was semidiurnal and plant conditions showed three units in operation. l 3-3 ..,. -.. - - - ~ ~ ~ ~ ~ - - - - - - - - - - - - - - " - - - ^ - - ^ - - - - - -

-U O O TABLE 3-1 FIRST QUARTER FIELD COLLECIl0NS, CRYSTAL RIVER STUDIES I 4 No. of No. of Collection Stations Samples T a sit Dates Sampled Collected CommenL3 1.A. Benthic Core 06/13-14/83 40 320 No problems 07/25/83 20 160 No problems i 1.B. Oyster Roer 07/11-15/83 9 5670 Deployed 08/08-09/03 9 810 Deployed 2 08/08-09/83 9 810 Retrieved ] i.C. Sa l t Ma rsh 06/13-17/83 8 192 No problems 07/24-29/83 8 192 No problems 4 ] 1.0 Mac rophytes 1. Cround truthing 06/20-24/83 50 500 No problems 2. Insensitive moni toring 06/27-30/83 8 40 Unable to find 3 seagoass bed ~ stations in thermal a rea 08/01-05/83 9 45 No problems 3. Seagrass growth 06/21-30/83 8 8 Clipped 07/11-15/83. 8 8 Retrieved 08/01-05/83 9 9 Clipped 08/15-19/83 8 8 Retrieved (1 sta. lost) 1.E. Aerial Photog raphy 08/27/83 1 1 No photography + during May-July because of 9round hato j l F. Photometry 1. Light, temp., sal., pH 06/09/83 40 Light window not met 06/15/83 40 Window not met i 06/22/83 40 Window met 06/30/83 40 Window met l 07/07/83 40 Window met t 07/12/83 40 Window met 07/20/83 40 Window met 07/26/83 40 Window met } 08/03/83 40 Window met 08/10/83 40 Window met 08/19/83 40 Window met 08/24/83 40 Window met 08/30/83 40 Window met I e i 1 1 or 4 i

TABLF 3-1 (Cont) No. of No. of Collection Stations Samples Task Jales Sampled Collected Comments 2. Turbidity 06/09/83 40 73 No problems 06/15/83 40 73 No problems 06/22/53 40 78 -No problems 06/30/83 40 71 No problems 07/07/83 40 78 No problems 07/12/83 40 74 No problems 07/20/83 40 81 No problems OT/26/83 40 76 No problems 08/03/83 40 77 No problems '08/10/83 40 75 No problems 08/19/83 40 85 No problems 08/24/83 40 93 No problems 08/30/83 40 66 No problems 3. Chlorophyl l "a" 06/09/83 8 15 No problems 06/15/83 8 17 No problems 06/22/83 8 16 No problems 06/30/83 8 15 No problems 01/07/83 8 15 No problems 07/12/83 8 16 No problems 07/20/83 8 15 No problems 01/26/83 8 11 No problems 08/03/83 8 15 No problems 08/10/83 8 16 No problems 08/19/83 8 20 No problems 06/24/83 8 14 No problems 08/30/83 8 16 No problems I.C. Sediments 1. IOC and granulometry 06/13-17/83 40 120 No problems 09/05-09/83 40 120 No problems 2. Sulfides 06/13-21/83 40 120 No problems 08/29-09/02/83 40 120 No problems 3. Temp., Th 06/13-14/83 40 40 No problems 07/25/83 20 20 No problems II.A. lapingement 06/06-07/83 2 8 No problems 06/13-14/83 2 8 No problems 06/23-24/83 1 4 Basket broke 01/01-02/83 2 8 No problems 07/05-06/83 2 8 No problems 01/14-15/83 2 8 No problems 07/19-20/83 3 10 No p*oblems 01/25-26/83 3 12 No problems 08/04-05/83 3 12 No problems 08/09-10/83 3 10 Operator error 08/15-16/83 3 12 No psoblems 2 or 4 1

l O O o a TABLE 3-1 (Cont) No. of No. of Collection Stations Samples Task Dates Sampled Collected Ccaments 08/25-26/83 3 12 No problems impingement ( 3 mm) 07/01/83 2 2 No problems 07/25/83 3 3 No problems 08/26/83 3 3 No problems 18.8. Entrainment 06/23-25/83 15 120 No problems 01/06-08/83 15 120 No problems 07/21-22/83 15 120 No problems 08/01-02/83 15 120 No problems 08/15-1?/83 15 120 No problems 08/31-09/01/83 15 120 No problems lit. F i she rie s 1. Trawl 06/21-30/83 9 63 No problems OT/26-27/83 9 63 No problems 08/23-24/83 9 63 No problems 2. Seines 06/28-07/07/83 4 8 No problems i 07/26-28/83 4 8 No problems + 08/22-23/83 4 8 No problems 3. Drop net 01/05-06/83 2 4 No problems i 07/27-28/83 2 4 No problems 08/22-23/83 2 4 No problems 4. Creek trawls 07/26-2T/83 4 28 No problems 08/22-24/83 4 28 No problems iV.A.1. Bathymetry 06/06-0T/83 1 survey Westher problems 06/13-14/83 1 survey Ha l f comp le te 06/28-30/83 1 survey All complete IV.A.2. Short Term 1. Tide gauges 08/01-30/83 16 16 75 percent data recovery 2. Current meters 08/01-30/83 16 16 95 percent data recovery j 3. Vertical profiles 08/01-30/83 64 64 No problems 4. Stream cross sections 08/01-30/83 4 4 No problems IV.A.3. Lor *J Term 06/06-10/83 51 72 Deployed 07/04-08/83 49 69 Hetrieved (3 lost) 01/04-08/83 51 72 Deployed 08/01-05/83 43 60 Retrieved (12 lost) 08/01-05/83 43 60 Deployed i 08/08-12/83 5 7 Deployed I j 3 of 4 i i

O O O. TABLE 3-1 (Cont) ] No. of No. of Collection Stations S9mples Task Dates Samoled Collected Commerits 08/15-16/83 3 5 Deployed IV.S. Suspended Load 06/09/83 8so 74 No problems 06/22/83 40 79 No problems 07/07/83 40 80 No problems 07/20/83 80 83 No problems 8 08/02/83 40 77 No problems 08/19/83 40 85 No problems ~ ,08/30/83 40 70 No problems IV.C. Meteorology Station fully og,erational except for the period 08/05-25/83 when lightning struck and damaged the system. r I i .l t \\ i t 4 or 4 1 I l l l l l l

o O O TABLE 3-2 STATUS Of LABORATORY ANALYSES TO DATE (09/26/83) CRYSTAL RIVER STUDIES Samples Samples Samples Collected to be Analyzed Task _to Date Analvied to Date Comments i 1.A. Benthic Core 1. Rough sorting 800 600 360 No problems 2. Identifications 800 600 300 No problems l 1.B. Oyster Reer 1 Oysters 10,620 10,620 10,620 No problems 2. Associated fauna 54 54 27 (clumps) 8.C. Sa l t Ma rsh 576 576 384 No problems l.D. Ma rcophytes ] 1 Ground truthing 1,000 1,000 1,000 No problems 2. Intensive monitoring 130 130 85 No problems 3. Seag ra ssi g rowth 16 16 16 No problems 4 r. Photometry 1. Turbidity 1,220 1,220 1,220 No problems 2. Chlorophyll "a" 251 251 251 No problems 1.G. Sediments ~ 1. TOC and granulometry 240 240 120 No problems 2. Sulfides 240 240 240 No problems ll.A. Impingement 1. Regula r 166 166 122 No problems 2. 3 mm 8 8 8 No problems i ll.B. Entrainment 840 630 180 No problems l 118. Fisheries 1. Trawl 252 ~ 252 126 No problems i i 2. Seines 32 32 24 No problems 3. Drop net 16 16 12 No problems 4. Creek trawls 84 84 28 No problems s l IV.8. Suspended Solids 1. ISS 616 616 616 No problems 2. VSS 616 616 616 No problems t l r 1 or I l l l

bec: N. B. Spake J. A. Hancock W. S. Wilgus ,H. A. Evertz, III o M. B. Foley U R. E. Parnelle D. K. Voigts File i u........ CERTIFIED / RETURN RECEIPT REQUESTED July 18, 1983 Mr. Paul J. Traina, Director Water Management Division U. S. Environmental Protection Agency 345 Courtland Street NE Atlanta, GA 30365

Subject:

Crystal River 316 Study

Dear Mr. Traina:

The first full month of field sampling for the Crystal River 316 Study was O recentir cemP eted. is a resuit of this samPlins. and numeteus l discussions between FPC, Stone and Webster, and Mote Marine Lab staffs, the following changes have been made to the entrainment and fisheries programs: Plankton Station B has been moved to deeper water, nearer the discharge (see figure 2-5). Plankton Stations I and K, which were located outside the southern boundry of the study area, have been moved into the area to be modeled. This provides far greater utility of the resulting data. The plankton stations in Cutoff and Salt Creeks are now sampled by means of a stationary net set to sample the tidal flow. Pushing the net was not feasible. Offshore seine stations planned along the north and scuch sides of the intake dike could not be seined and have been replaced by stations at Demory Gap and offshore of new Station B. Trawls will now be used to replace block and sweep seining in the tidal creeks as the latter have not worked successfully or are simply not feasible in appropriate locations.- Gear and location selection will be confirmed prior to the initiation of O 3"tr samPti==- General Office 32oi in.rry.eourtn street Soutn. P o so 54o42 si Petersourg Fer.ca 33733. sta-ses.sist

Mr. Paul J. Traina July 18, 1983 Page 2 In addition to the above, difficulties have been encountered in obtaining temperature and salinity data at the 40 designated stations (see Figure 1) within the allotted 90-minute sampling window. Mr. Paul Behrens discussed this problem with Mr. Charles Kaplan by phone on June 29th. Subsequent to this conversation, the following procedural modification was incorporated into the program to correct this problem: Stations 4-30 (discharge stations) are sampled within the 90-minute window, providing synoptic sampling of the plume areas. Stations 1-3 and 31-40 are sampled immediately before or after data collection at stations 4-30. All stations are sampled within the same four-hour time window used for photometry sampling. The Plan of Study and Quality Assurance Manuals will be revised to reflect each of the changes discussed above. If you have any questions or comments, please call Mr. Paul Behrens at 813/866-5521. Sincerely, _O ggf William S. O'Brien Director Environmental & Licensing Affairs W30/md cc: D. H. Hicks C. H. Kaplan J. P. Subramani e O

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3.0 WORKSCOPE 3.1 Impingement Program Samplina Gear. Samples will be collected in 3/8 inch wire mesh baskets designed specifically to fit over the existing trash baskets in the screen wash collection sumps of each unit. The sample baskets will be of sufficient strength and size to nold the animum expected weight of an unsorted sample (based on previous experience at the plant). f For the comparison study of 3/8 inch mesh vs. 3 mm mesh (the mesh size used in previous impingement studies at the site) a secon'd basket (of 3 mm mesh screening) will be constructed to fit beneath the routine-ly used (3/8 inch mesh) sample basket. The second basket will be of a strength and design sufficient to hold the maximum sample weight anti-cipated. Water hoses, located at each sampling site,'will be available to prevent clogging and facilitate cleaning of the collection baskets. Sampling Locations. Impingement samples will be collected from the screen wash flow at Units 1, 2 and 3. Sample baskets will be placed in the screen wash collection sumps at the end of the screen wash sluice-ways at each of the units so that separate samples can be obtained.for each unit. To assure complete separation of the screen wash debris from Units 1 and 2, a barrier will be placed in the common sluiceway of these units'at an appropriate point. Frequenev. Organisms will be collected at Units 1, 2 and 3 for one 24 hr period each week for 12 months. The day of the week on which sam-pling is conducted will be randomly chosen from among six possible days (Monday through Saturday). During each 24 hr sampling period, samples will be taken at each unit at 6 hr intervals for a total of four samples per unit. The traveling screens will be rotated so that each sample O contains the er anisms im,inied durin. the 6 hr intervat immediate1x ~ II-13

preceding the collection. The screens on Units 1 and 2 will be cleaned at 0900 hr (the beginning of the first sampling interval) and then ro-tated every six hours so that collections can be made at 1500 hr, 2100 hr, 0300 hr, and 0900 hr. Unit 3 will be cleaned at 1000 hr and sampled at 1600 hr, 2200 hr, 0400 hr, and 1000 hr. Field Procedures. Te assure that all organisms are washed from the intake screens at the time of sampling, the screen wash system will be operated for 30 minutes before the collection of each sample. Should it become necessary to clean the screens before the end of a 6 hr sampling period, the material washed from the screens at that time will be re-tained and counted with other organisms obtained during that sampling period. Project personnel will be present throughout the 24 hr sampling period in case any sample basket must be emptied before the end of any interval due to unusually large quantities of debris in the screen wash. 1 During the previous Crystal River impingement study, this situation occurred frequently dur'ing certain times of the,y' ear. In this case, all (} material will be retained and included in the total collection of that particular sampling interval. After the material from the screen wash has been collected in the sampling baskets, fish and macroinvertebrates will be separated from seagrass and other debris. "he samples till then be transferred to the on-site laboratory for analysis. Should an excessively large sample be encountered, it will'be necessary to subsample the material prior to removing the fish and macroinvertebrates. This will be done using a sample splitter consist-ing of a 12 inch high square frame of adjustable dimensions to accommo-data various sample sizes. The unsorted sample will be removed from the sampling basket and placed evenly in the splitter in a random faJhion. The material will then be divided into four equal quadrants using twine drawn across the splitter from the center of each side.,Each quadrant will be numbered and the portion or portions of the sample to be analyzed () will be chosen randomly from among the four quadrants. The amount of 1 sample to be analyzed will be determined by estimating the quantity that II-14

l can be analyzed in approximately two hours. The previous impingement r). study at the site indicates, not only that subsampling will be occasion-(_ ally required, but also that this method is appropriate. Physical measurements (water temperature, dissolved oxygen, turbid-icy,.and conductivity-salinity) will be taken one foot below surface, mid-depth, and one foot above the bottom at each unit upon initial cleaning of the intake screens and at the end of each sampling period. Data on barge traffic, tidal stage, wind, weather conditions and amount of seagrass in the sample will also be recorded at each sampling time. Plant operational data (e.g., number of c1Tculating water pumps and screens operating) will also be noted. Individual weights and sizes will be taken on representatives of selected taxa of economic or ecological importance (see Sec. tion 2.5) collected during one 6 hr interval during each 24 hr sampling period. One such sampling will be made for each of the three units for a total of three during each 24 hr period. The sampling intervals that are chosen will be selected at random beforehand from the four possible intervals. Sampling for the collection basket mesh comparison (3/8 inch vs. 3 mm) will be carried out once a month at each unit during one of the 6 hr intervals (a total of three collections per month). The interval will be selected at random beforehand for each unit from all of the possible sampling periods in each month. The 3 mm mesh basket will be placed beneath the 3/8 inch basket so that organisms that pass through the larger mesh will be collected in the lower basket. All fish and macro-invertebrates collected in the 3 mm basket will te sorted and analyzed separately. () II-15

s O 2.1.5.5 Block wees Block nets will be placed in tidal creeks to assess the fish and macro-invertebrates using the heated and unheated tidal marshes. This technique has been successfully used in the region. 2.1.5.6 Blue Crab Collection Gear Commercial-type baited crab traps will be used to capture blue crabs from the experimental and control areas. Crabs from the plant intake screens (impingement collections) will also be used to increase the number of marked individuals released. Use of a combination of collection gear will ensure adequate numbers of crabs available for tagging. The marking techniques (rubber band tags and internal anchor tags) are proven methods for marking crabs. ~ 2.2 Water Quality A water quality program has been designed consistent with the guidelines for 316(a) demonstration programs for nuclear power plants.* The study will provide data for evaluating the effects of power plant operation on water quality in the plant vicinity and evaluating the effects of the Cross-Florida l Barge Canal on water quality. Sampling stations have been selected to pro-vide north and south controls and discharge, intake, and barge canal experi-l mental samples. This will provide mari== potential for evaluation of plant and Cross-Flcrida Barge Canal effects. The water quality program has been developed to yield data to determine whether there are differences bastween surface and bottom waters, what dif-farenges in water quality exist between inshore and offshore waters, and to J what extent tidal changes affect water quality. The varied aspects of these data will provide additional information as to the effects of cooling-water intake and discharge. i III-10

e 3.0 '40RK SCOPE 3.1 Fisheries Study Design Using the questions posed for each study element, an analytical design was developed that permitt rigorous statistical testing of the hypotheses. This design incorporates consideration of desirable gear types, restriction. of number of species to be subjected to detailed analysis, limitations of the sampling areas, definition of an appropriate statistical model, and de-termination of the number of samples necessary. The Crystal River Plant study area is illustrated in Figure III-1. The proposed fisheries sampling stations and gear types to.be employed at each station are indicated. Table III-l summarizes the samples to be taken. Table III-l Fisheries Sample Number Analysis for

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Crystal River Monitoring Program Total Gear Tvue Stations . Days /Mo. - Rep / Day /S ta. Months Samples MODIFIED: Trawl 10 1 2 12 240 See Mote Marine Tra=mel Nee 10 1 2 12 240 Lab Seine 6 1 2 12 144 revisions Drop Net 2 1 2 12 48 p 2 and Block Net 4 2* 1 12 - 96 ATT. 4. Crab Traps 120 4(5)** 1 4 2040 Crab Impingement 1 4(5)** 1 4 17 One day, one night. One month with five samples. p III-11 ~

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-a straight line with the wind or current (providing dupl'icate ISO-foot net samples). Following trammel not deployment, single bottom trawls will be made at a distance of 250 to 300 feet on each side of and parallel to the set trammel nets for a distance of 300 feet (the length of the two tranniel nets). Trammel nets will be retrieved after approximately 1 hour. Tranumal net catch data will be used to investigate gross seasonal pat-terns of species distribution; to compare patterns of diversity, density, and composition within stations near to and remote from the plant vicinity and Cross-Florida Barge Canal; and to investigate patterns of abundance and apparent movement in relation to plant intake and cooling watt.r intake struc-tures (dikes), plant thermal discharge, and barge canal operation. Trawl catch data will be used to evaluste seasonal patterns of species distribution, diversity, and abundance within starions in the vicinity of the Crystal River site, Cross-Florida Barge Canal, and control areas. Trawl-ing information will also permit a degree of continuity and comparability with trawl catches taken by previous researchers (Mountain 1972) in the Crystal River site area. 3.1.2.2 Seines / Drop Nets A 50-foot-long x 6-foot-deep nylon seine with 1/8-inch delta mesh will be used at the stations identified in Figure III-1. To maintain a degree of comparability between this study and previous programs, the drop net design and technique described and used by the Uni-versity of Florida at Gainesville (FPC 1974) during its fish survey in the 1 Crystal River Plant vicinity will be used. i 1 Duplicate beach seine collections will be made at each station (Figure III-1) during the day monthly over the 12-month study period. Seines will be deployed in a straight line from shore and then walked in a quarter circle toward shore until the distal wing is on the beach. The catch will then be O III-16 . - + -,.

P A,.- l ~ concentrated in the net and the sample analyzed. Drop n'ets will be de-played as described by the University of Florida at Gainesville (FPC 1974) in the immediate discharge area and the inshore south control area (Figure III-1). In light of possible alterations of these shallow nursery areas and their attendant communities by barge traffic and plant operation (i.e., en-trapment/entraitment and thermal effects), seine and drop net catch data vill be used to monitor the abundance, seasonal variation, mo rement, and species composition of juvenile and small fishes. Comparisons of catch data obtained at the intake and in thermally affected areas, areas in the vicinity of the Cross-Florida Barge Canal, and in nearfield control areas will provide in-sight into the nature, extent, and degree of plant / canal-induced effects on juvenile and small fish inhabiting the shore zone and shallow areas in the vicinity of the Crystal River site. 3.1.2.3 Block Nets O At high tide (high-slack), the net (1/8-inch mesh nylon seine) will be placed across the full width of the creek upstream from the. low-cide mark so that the not will census the population above that point as the tide ebbs. All fish and macroinvertebrates will be identified, counted, and weighed; the important species, as previously defined, will be treated as in the crawl and seine collections. Nets will be deployed twice each month - once during day-light hours and once at night to assess the day / night differences in use of the tidal creeks. 3.1.2.4 Crab Traps Crabs will be trapped and marked during September-December, the peak period of crab movement in the Crystal River area. To document longshore movements in the study area, crab traps will be baited and set along 5-mile-long traplines perpendicular to the shore in the northern and southern con- ~ trol areas (30 traps per line) and along the north and south faces of the O III-17 _,-~._, _

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d5 R. k-C o m e o m a t i o se September 23, 1983 Mr. Paul J. Traina, Director Water Management Division U. S. Environmental Protection Agency 345 Courtland Street NE Atlanta, Georgia 30365

Subject:

Crystal River 316 Study

Dear Mr. Traina:

In accordance with the Plan of Study for the Crystal River 316 Study, a blue crab tagging program was initiated during September, 1983. q As a result of conversations with the Florida Department of Natural Resources v (DNR) and local commercial crab fishermen, several modifications to the tag-ging program were made prior to the start of the field effort. These modifi-cations are as follows; Traps will be set along four transects of equal length (see attached Figure). Transect D will remain unchanged. Transect C will remain north of the intake spoil and will be expanded to equal D in length. Transect B will be moved to a location immediately south of the intake spoil and be extended. Transect A will remain in Crystal Bay but it will be extended offshore. These changes will provide a better basis for comparison of data betwe,en transects and provide for data from the key area south of the intake. ) Traps will be set in six clusters of five traps spaced along each transect. This array is sufficient to document movements of crabs and will avoid problems in analyzing low catch rates in individual traps. Traps will be fished for seven days; they will be set on either Monday or Tuesday of each week and retrieved on the same day of the following week. Duration of sets varies locally but DNR has successfully used seven day sets. Cannibalism is limited by large O trap size. V ) l 1 General Office 3201 innty iourtti sir.si souin. P O Som 14042. St Petersburg. Fcres 33733 813-866-5151

Mr. Paul J. Traina Page 2 (s September 23, 1983 Shad will be substituted for cat food as bait. This is being done on advice of the local fishermen and the DNR. Florida Power is working closely with the DNR on this crab tagging effort. Data collected at Crystal River as part of this study will be directly available to DNR biologists for incorporation into their ongoing blue crab investigations. Should you wish further discussion on this program seguent, let me know. Sincerely, o D At L ar= -L/ Williar S. O'Brien Director Environmental & Licensing Affairs WSO/ad Attachment cc: D. B. Hicks J. P. Subramani D. Farrell L. A. Olsen e O

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