ML20096G793
| ML20096G793 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/07/1984 |
| From: | Higgins B COMMERCE, DEPT. OF, NATIONAL MARINE FISHERIES SERVICE |
| To: | Doolittle E Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8409110144 | |
| Download: ML20096G793 (2) | |
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f Services Division Habitat Protection Franch 14 Elm Street Cloucester, MA 01930 September 7, 1984 Q Ms. Elizabeth L.~Doolittle y division of Licensing Nuclear Regulatory Commission Washington, D.C. 20555
.f D -Dear Ms. Doolittler p"
The National Marine Fisheries Service (NMFS) has reviewed the Draft Environmental Irpact Statement (DEIS) concerning the operation of Millstone Nuclear Power Station, Unit No. 3, at Waterford, Connecticut, and has the following consents:
e Section 5: Environmental Consecueneen and Mitigation Actions q
The NNFS finds that the document inadequately discusses the potential impacts of entrainment/icpingement and particulate erosion of the coppe.*/ nickel condenser tubes and their associated sacrificial rino blocks.
Unit 3's consumptive water use increase is noted on page 5-9 or the DEIS j
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as constituting approximately 4% of the tidal exchange.- Since average water 3
flows are reported to be 57 m /sec (2,000 cfs, it can be concluded that with allthreeunitsoperatingandconsuming118m]/seo,thetotalon-lineuse
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g would be alightly nore than 8% of the tidal exchnnge of the area. Thus, full operation of. Unit 3 would virtually double the consumptive use of water removed from this corner of Niantic Bay. We reconmend that the cumulative j
consumptive 'use value.of 8% and its subsequent lepset value be used in tha discussions of topics such as entrainment and impingement,-not the isointed 45 value routinely used in the present BIS.
The isolation of impacts at Unit 3 from those of other operating units at Millstone is also found in the specific assessment diecussions of entrainnent and impingement _of fish such as tho' winter flounder (Pseudepleuronectes americanus). The DEIS reports at page 5-11 that population rodaling of virter flounder reveals a potential 5% to 6% reduction of the population due to larval entrainment. The next discussion focuses on future 1epingement
. impacts. These impacts are reported as being beld stable at existing levels by having the intake systees of Units 1 and 3 either retro-fitted or initially
' installed with fish return systems.
8409110144 840907 PDR ADOCK 05000423 D
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l-i The Clean Water Act (the Act) (33 U.S.C. 466 e_t, seq.) has two relevant sections that bear en these two topics: Section 4C2 regarding the National Pollutant Discharge Elimination System permits, and Section 316 regarding there:al discharges. Section 402 is heavily cross-referenced to other sections of the Act. At each cross-referencing, the Act requires the protection and propagation of a balanced population of shellfish, fish, and wildlife in and on the subject water body. Section 316 of the Act eakes the same demand. The NITS believes that the Nuclear Regulatory Commission and the applicant should be aware of and responsive to the federal mandates related to operation of a power generation facility that presently dees, and apparently will continue to, affect adversely the protection and propagation of a balanced population of shellfish, fish, and wildlife in Hiantic Bay. In this regard, we believe Q the authors should discuss these issues and the applicant should be required U to undsrtake steps to further lessen the entrainment-and impingement-relsted lepacts at all three units of Millstone. Such action would help the operator of Millstone Units 1-3 comply fully with the reandates of the Clean Water Act.
Additionally, the NMPS is concerned about the method used on page 5-11 to h
evaluate plant-related fichery losses. In the case of winter flounder, the n
$ g impacts associated with cdult-equivalent losses are compared with the 1979 J
State of Connecticut recreational and commercial catches. It is well known R
g" that the winter flounder is a parochial species; as such, winter flounder tend R
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to occur in rather distinct localized populations, not in con: mingled passes that " rapidly" react to losses in cne portion of their overall habitat.
$ p Therefore, it is not appropriate to apply state-wide statistics te a problem 9
E that will be virtually confined to the winter flounder of the Niantic Bay and
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% Estuary cocplex.
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Page 5-4 of the DEIS discusses the impact of copper, nickel, and 5
sacrifical zine losses frcci the condenser tubes. In that discussion, it is s
noted that the rajority of the increases in discharges were of particulate R ].,
sampling would provide instantaneous metal levels but do nothing toward y
fractions. The sampling, however, was directed toward water semples. Such a providing insights regarding cumulative, long-term deposition levels. This deficiency should be corrected in future versions of the EIS.
5 Section 6: Evaluation of the Proposed Action
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The intentional destruction of an identifiable portion of a living marine d-resource population and the unquantified icpacts associated with depositing toxic particulates of copper, nickel, and zine in the thernal plu:-e of the three Millstone units is both an unavoidable adverse impact and an irretrievable committent of resources. The resident and migratory resources of the Niantio Bay /Two Tree Island region of Long Island Sound are reported to be impacted to ecce degree by the facility. Because of that iepact, those resources merit some consideration at this point in the EIS, particularly in light of our previous comments en the operation of the nuc1 car units at Millstone.
Sincerely, Eruce E. HiFgins Acting Uranch Chief N
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