ML20087D671
| ML20087D671 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/08/1984 |
| From: | Kenney D ILLINOIS, STATE OF |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8403130474 | |
| Download: ML20087D671 (4) | |
Text
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Illinois Departmentof Conservation lifeord land together LINCOLN TOWER PLAZA + 524 SOUTH SECOND STREET + SPRINGFIELD 62706 CHICAGO OFFICE - ROOM 100,160 NO. LASALLE 60601 David Kenney, Director + James C. Helfrich. Assistant Director March 8, 1984 U. S. Nuc1 car Regulatory Commission Washington, D.C.
20555 Attn:
Director, Division of Licensing
Dear Director:
The Department has reviewed the Draft Environmental Statement (DES) related to the operation of Braidwood Station Units 1 and 2.
Generally, we are pleased to note that major environmental concerns we had identified during the early 1970s, and appropriate mitigating actions to alleviate these
- concerns, are adequately reflected in this DES.
During our review of the DES, however, we did note the tendency to present general statements relative to impacts without a thcrough presentation of data or references to support these statements.- It is our opinion much more data relative to aquatic imp-acts has been collected than is presented or referenced in this DES.
S,ecific comments on the DES follow:
Section 5.5.2.2 Kankakee River On page 5-2, last paragraph, it is
- stated, "The water quality standards also require that.the discharge structure must be designed to ensure that the mixing zone allows a reasonable zone of passage for aquatic life and must not encompass more than 25%
of the cross-sectional area or volume of flow, except in those instances where the dilution ratio is less than 3:1 (ER-OL Section 5.1))"
On page 5-13, first paragraph, it is stated, "The thermal plume is projected to extend to 28% of the river width in August, 33% in September, and 22%
in December--."
CooA Ill 8403130474 840300
/
PDR ADOCK 05000456 D
U.
S. Nuclear Regul atory Commission March 8, 1984 These two statements appear to be in conflict; therefore, further clarification should be presented in the Final Environmental Statement (FES).-
-Acccrding to the DES (page 5-13, first paragraph),
"the thermal plume should not act as a barrier to up or.
downstream movement by mobile aquatic biota."
The DES further states (page 5-13, fourth paragraph)
" Larval fish could be stressed on passage through the thermal plume;
- however,
---larval mortality associated with the thermal plume should not be significant."
The DES rationalizes these conclusions on the basis of short residence time in the plume and the statement " natural mortality of larval fish can reach more than 99%."
(page 5-13, paragraph 4).
It seems appropriate here to point out that because year class strength is determined by the success in survival of eggs and larval fish and natural factors alone can account for 99%
l mortality, additional stress on the remaining 1%
from removal by entrainment or mortality from a thermal plume should not be so easily dismissed.
Here,.
- also, the size and shape of the thermal plume may come into play..
If egg and/or larval drift is not evenly or randomly distributed throughout the cross section of the
- river, then there i s-a.
possibility that a disproportionate amount of' drift is passing along the shore of the station and subject to entrainment or thermal stress.- There may be particular species of fish more affected than
- others, i.e.
species whose entire driet would be concentrated into the river area where it will be entrained or pass through the thermal plume.
For these reasons. we suggest the FES assessment of impacts on eggs and larval fish include a discussion of studies Commonwealth Edison has conducted to determine distribution of larval drift across-the-cross-section of the river.
We are most interested in learning if an analysis by species and percent of drift already dead was conducted so a meaningful comparison can be made by species prior to entering the intaMe and/or heated water area and after passing through these hazards.
'If these studies have not been conducted at this ' site then the FES should include a
definite statement-relative to the need for such studies after plant start-up.
s U. S. Nuclear Regulatory Commission March 8, 1984 Based on the-information presented in table 5.4 g
(page 5-16), and contrary to impingement losses at plants on other rivers where numbers of gizzard shad are commonly 50-80% of the loss, sport fish comprised the large share of impinged fish - 17.8%
of the total number were rock bass, 11.1% channel catfish, 8.4% bluegill, 8.2% smallmouth bass, 6.1%
white
- crappie, 4.2%
black
- crappie, and 2.4%
pumpkinseed for close to 60% of the total number impinged.
Gizzard shad numbers were only
.4%
of the total.
We are aware that impingement mortality of large numbers of forage fish, such as gizzard shad, are dismissed each year without much concarn because of their great reproductive potential; however, predator fish do not have that same poten t i al.
Gizzard shad f emales average 375,000 eggs per fish as compared to an average 5,000 per female rock bass.
Thus a loss of tens of thousands of shad each year from impingement is of much less concern than the Icss of thousands of predator / sport fish
-such as rock bass.
The assumption of highesst mortality in winter (page 5-17 first paragraph),
again ignores differences between species or families of fish.
During closed cycle operation of the Quad-Cities Station in
- 1976, 63%
of the shad impinged (shad were 86% of total impingement) were lost in Decembr e,
- January, and February.
However, only 14% of ihe annual loss of crappie occurred in the December-February period.
It seems logical to expect that impingement at Braidwood may actually be much higher outsice the winter period since it includes such a
small proportion of shad and large proportions of centrarchids such as crappies.
For the above reasons, we suggest the FES fully discuss Commonwe al th Edison's commitment to conduct 12 month impingement entrainment studies after plant star t-up.
We look to this study to provide answers to the aforementioned concerns.
Section 5.6.2 Aquatic The DES (page 5-18) discusses the pallid shiner.
The document correctly points out that this fish is "a rare species in Illinois" (page 5-18).
In
- fact, according to Smith in The Fishes of Illinois, it "is one of the rarest and least krown American-fishes."
For this reason, the discovery of more than 17 individuals of this species at one of the Braidwood monitoring stations is noteworthy l=
i
U. S. Nuclear Regulatory Commission March 8, 1984 Q
and deserves further attention and study.
The FES should address Commonwealth Edison's specific plans for river monitoring and study of this species prior to and following plant start-up.
The Department appreciates the opportunity to comment on the DES.
Sincerely,
'W
& :=t'7 David Kenney DK:RWL:alc cc:
Commonwealth Edison Co.
f l
.