ML20098B414
| ML20098B414 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/07/1984 |
| From: | Higgins B COMMERCE, DEPT. OF, NATIONAL OCEANIC & ATMOSPHERIC |
| To: | Doolittle E Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20098B401 | List: |
| References | |
| NUDOCS 8409260075 | |
| Download: ML20098B414 (2) | |
Text
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a UNITED CTATE3 DEPARTMENT CF C MMERCE N'
National Oceanic and Atmospheric Administration
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NATIONAL MARINE FISHERIES SERVICE Services Division Habitat Protection Branch 14 Elm Street Gloucester, MA 01930 September 7, 1984 Ms. Elizabeth L. Doolittle Division of Licensing Nuclear Regulatory Commission Washington, D.C. 20555
Dear Ms. Doolittle:
The National Marine Fisheries Service (NMFS) has reviewed the Draft Environmental Impact Statement (DEIS) concerning the operation of Millstone Nuclear Power Station, Unit No. 3, at Waterford, Connecticut, and has the follo.,ing comments:
Section 5: Environmental Consequences and Mitigation Actions The NMFS finds that the document inadequately discusses the potential impacts of entrainment/ impingement and particulate erosion of the copper / nickel condenser tubes and their associated sacrificial zino blocks.
Unit 3's consumptive water use increase is noted on page 5-9 of the DEIS as constituting approximately 4% of the tidal exchange. Since average water 3
flowsarereportedtobe57m/sec(2,000ofsj,itcanbeconcludedthatwith all three units operating and consuming 118 m /sec, the total on 1.ine use would be slightly more than 8% of the tidal exchange 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 recommend that the cumulative consumptive use value of 8% and its subsequent impaut value be used in the discussions of topics such as entrainment and impingement, not the isolated 4%
value routinely used in the present EIS.
The isolation of impacts at Unit 3 from those of other operating units at Millstone is also found in the specific assessment discussions of entrainment and impingement of fish such as the winter flounder (Pseudopleuronectes americanus). The DEIS reports at page 5-11 that population modeling of winter flounder reveals a potential 5% to 6% reduction of the population due to larval entrainment. The next discussion focuses on future impingement impacts. These impacts are reported as being held stable at existing levels
'by having the intake systems of Units 1 and 3 either retro-fitted or initially installed with fish return systems.
8409260075 840924 PDR ADOCK 05000
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The Clean Water Act (the Act) (33 U.S.C. 466 g seq.) has two relevant sections that bear on these two topics: Section 402 regarding the National Pollutant Discharge Elimination System permits, and Section 316 regarding thermal 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 makes the same demand. The r -
NMFS believes that the Nuclear Regulatory Commissien and the applicant should be aware of and responsive to the federal mandates related to operation of a power generation facility that presently does, and apparently will continue to, affect adversely the protection and propagation of a balanced population of' shellfish, fish, and wildlife in Niantic Bay. In this regard, we believe the authors should discuss these issues and the applicant should be required to undertake steps to further lessen the entrainment-and impingement-related impacts at all three units of Millstone. Such action would help the operator j
-of Millstone Units 1-3 comply fully with the mandates of the Clean Water Act.
Additionally, the NMFS is concerned about the method used on page 5-11 to evaluate plant-related fishery losses. In the case of winter flounder, the impacts associated with adult-equivalent losses are compared with the 1979 State of Connecticut recreational and commercial catches. It is well known.
that the winter flounder is a parochial species; as such, winter flounder tend' to occur in rather distinct localized populations, not in commingled masses that " rapidly" react to losses in one portion of their overall habitat.
Therefore, it is not appropriate to apply state-wide statistics to a problem that will be virtually confined to the winter flounder of the Niantic Bay and Estuary complex.
Page 5-4 of the DEIS discusses the impact of copper, nickel, and sacrifical zine losses from the condenser tubes. In that discussion, it is noted that the majority of the increases in discharges were of particulate fractions. The sampling, however, was directed toward water samples. Such a sampling would provide instantaneous metal levels but do nothing toward providing insights regarding cumulative, long-term deposition levels. This deficiency should be corrected in future versions of the EIS.
Section 6: Evaluation of the Proposed Action The intentional destruction of an identifiable portion of a living marine resource population and'the unquantified impacts associated with depositing toxic particulates of copper, nickel, and zinc in the thermal plume of the three Millstone units is both an unavoidable adverse impact and an frretrievable commitment of resources. The resident and migratory resources of the.Niantic Bay /Two Tree Island region of Long Island Sound are reported to be impacced to some degree by the facility. Because of that impact, those resources merit some consideration at this point in the EIS, particularly in
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f light of our previous camments on the operation of the nuclear units at Millstone.
Si erely,
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-BrucefE./
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ctirig Branch Chief s
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