ML20148Q476

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Forwards Review of the Preliminary Draft Environ Statement. Finds Pdes Unnecessarily Wordy.Believes Impact Sections Should Only Focus on Real Potential or Probable Areas
ML20148Q476
Person / Time
Site: New England Power
Issue date: 11/17/1978
From: Samworth R
Office of Nuclear Reactor Regulation
To: Ballard R
Office of Nuclear Reactor Regulation
References
NUDOCS 7811300053
Download: ML20148Q476 (13)


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ER5305B15.E EeAe ms Egyig===mment Pro.! acts Breach Bo.1 PaeJEC:t wasacesn ynia n 1. cote uncar:Pr3cu or 33spemene neyter of PDES EErtM $2MUSt aq=a*4e Emesuress e==*1a=, ES843meplete "L.y . .,, -- /,- .

h Aquatie Bassessee Seetion ESE,.has revissed the Septmaber 1978 FDES for Mr. Im gamed om found the desement to be unnecessarily wordy in the deser4M4=er (Sectima 2) and faceet americes (4 and 5). The length of those oestimes emeld he trimaned of all the detaile (which appear in the ER) and stume feeus em the eensatials measssary for the impact assosoments. Sections  !

A sad 5 einheente et seus leasth eu, many potential impact categories and then l

. and rich a fee -- or peangtephe disuniesing east or all of them. "1bose

===*4a== should faeus only se the reet petame4=1 or probable impact areas.  ;

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Im seistiam 5,. It is stoted thns the staff's emerae-t model for cunner  !

yielde em anyest estimate of 20% of the pepeletion after 40 years of station i g -

rim Omusarmely, Appliemat's model (need by EPA in its analysis) yields

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a 4E Wi==- The tem endels have set been compared by staff with respect j to the ressoas for tha 5-fold difference. This question might arise at the '

hearing, and justifiably es, aimes 20% could be a significant effect while 4% could be lesignifiennt. This difference should be evaluated and presented sa the ras. .

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NRC FOR.M 318 (9 76) NRCM 0240 TT u. s. oovenwaswv pesurine orricas neve- saa-aa4

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DETAILED COMMENTS _ l i

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,2. 7. 2 (p. 2-30) ]

In addi*. ion to the absence of federally-recognized endangered species, no ,

state-recognized endangered species exist, as per the attached letter of August 17, 1976 from Cronan to Hickcy. State-recognized endangered species (or their absence) should be mentioned.

2. 7.2. 2 (p. 2-44 to 2-47) _-

In the description of Block Island Sound zooplankton, no discussion is presented on the larvae of lobster or squid. Lobster larvae are discussed in detail in Section 5.5.2.2 under entrainment impacts. Most of that descriptive. material should appear in Section 2. Post ER-CP studies of larval lobsters and squid were required by staff and ORNL and should be properly addressed in the PDES.

2. 7. 2. 2 (p. 2-60)

Paragraph 2 states that no juvenile squid were collected by otter trawl or plankton sampling. Raytheon studied squid larvae in BIS during 1977 and prepared a report dated January 1978 on the results. That study did capture squid larvae by plankton sampling and the results should be included in the PDES.

4.1.1 (p . 4-1)

The second paragraph states that " impacts to recreation will occur", but no specifics are given. Such impacts should be described.

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4. 3.2 - (p. 4-24 . to 4-29)

.It is' stated.that "the potentia 1' exists for long-term responses by the

. biological communities" as a result of construction activities (p. 4-25) and that "the potential for significant environmental damage caused-by ,

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. turbidity and sedimentation exists" (p. 4-29) . In contrast, the impacts j

j were analyzed to be " minor and localized" (p. 4-26) and that " recolonization of the affected areas is likely to be rapid" (p. 4-29) and "no unacceptable adverse impacts are expected" (p. 4-29) . These inconsistencies should be corrected. <

This is further confused by the statement that "the impact of turbidity and sedimentation on the biological communities [of Point Judith Pond] cannot be assessed at this time" (p. 4-29), while p. 4-26 sta tes that "because of the small area involved in present plans for dredging in Point Judith Pond, aquatic impacts are expected to be minor and localized." This should be resolved and the impact probability should be clearly stated. If indeed the impact is expected to be minor, the need for the sediment analyses (p. 4-29) should be re-evaluated.

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5. 5. 2.1 (p. 5-63) '

It is stated that the velocity cap design has not been tested on the Atlantic Coast. This is incorrect since the St. Lucie Plant on Florida's east coast t

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uses an offshore intake with a velocity cap. Impingement during 1976 and 1977 included'some species similar to those at NEP (e.g. , lobster, crabs, herring, anchovy, flatfish). A summary is attached. This experience should be included in the NEP impingement assessment. f l

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1 5.5.2. 2 (p. 5-70)

It is stated that the potential entrainment losses or lobster larvae on the subsequent adult-lobster stocks is impossible to predict. Using a method similar to that shown on p. 5-67 (for meroplanktonic molluse larvae), Stone and Webster (copy attached) conservatively predicted that 24,000 entrained lobster larvae at Pilgrim could result in a loss of 490 adult lobsters.

By comparison, this PDES suggests that 240,000 larvae could have been entrained.by NEP during 1977 (p. 5-70), potentially resulting in an adult 4 loss.of 4900 lobsters (assuming that the factor of 10 appliee). This I

method should be reviewed and, if reasonable, used to analyze potential e

Lapacts at NEP.

  • It is further stated that entrainment effects on lobster populations cannot be evaluated until more data are obtained on lobster larval distributions, i

etc. .Since Scarratt (p. 5-7,0) was unable to detect a close correlation between lobster larval production and subsequent lobster stocks after 15 years of study, it is questionable whether further data collection at NEP will be of value. This apparent requirement (p. 5-72) for further study ,

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should be reconsidered in that light.

y 5.5.2. 2 (p. 5-72 to 5-82) i With respect to the impact of entrainment on ichthyoplankton, the following items need to be clarified:

(a) p. 5-78. The plankton net gear efficiences of 0.75 and 0.5 have no stated basis. Since applicant used standard plankton sampling techniques, the basis (and references) for these numbers should be provided, i

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l (b) p. 5-81. Tautog and cunner are' wide ranging species (as are mackerel) and the impacts should-be evaluated in this light. The areal distribu-tion over which the 20% reduction will occur should be stated.

Additiont,11y, the following items relevant to entr+1nment need clarification:-

(a) p. 5-102. The staffts entrainment model for cunner yields an impact estimate about 5 times that of the model utilized by EPA and Applicant, but no attempt has been made by staff to resolve this difference.

  • This is an important point and should be addressed in the FES. The importance of a 20% impact on this non-economic and wide ranging ,

species should be considered.

Chl p. C-21. It is stated that the location of the intake farther out to sea would lessen the entrainment impact to cunner. How much less of an impact and at what distances offshore or what water depths are not discussed. If this concept is important and is a real possibility for impact minimization, the idea should be brought forward and highlighted in Section 5 of the document, as is done in Section 9.2 (p. 9-91 to 9-93). n ..

9.2 (p. 9-48)

Applicant should be referred to as "he" or '"his" and not "it".

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TATE OF RHODE ISLAND AND PROVIDENCE PLAN ATIONS Department of Natural Resources

, ' DIVISION OF FISH AND WILDLIFE '

83 Park Street '

Providence, R. I. 02903. ,

i l August 17, 1976  !

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. l Mr. Clarence R. Hickey, Jr. I i

Fishery Biologist Div. of Site Safety & Env. Analysis Office of Nuclear Reactor Regulations Nuclear Regulatory Commission Washington, D. C. 20555 ,

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Dear Mr. Hickey:

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We do not have any species of fish that are ' re cognized I as threatened in Rhode Island. Our laws, however, are identical to those of the Federal Government when it comes to threatened or endangered species of any type.

Sincerely yours, -

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John M. Cronan Chief (f .

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i ECOLOGICAL MONITORING  !

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POWER & LIGHT'CO.  !

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I ANNUAL REPORT l

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1977 4

VOLUME 1 i h

i Prepared for j 1

FLORIDA POWER & LIGHT COMPANY ]

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ATLANTA, GEORGIA -

i March 1978 i

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TABLE B-2 .

TOTAL NUMBER OF INDIVIDUALS, WEmHT IN GRAMS AND PERCENTAGE COMPOSITION BY TAXON OF SHELLFIS!!ES AND FISHES COLLECTED DURING IMPINGEMENT SAMPLING ST. LUCIE PLANT 1976 - 1977 ,

1976d 1977D No. of  % by Wei9ht  % by. No. of  % by Weight  % by Taxon individuals numbers (g) weight individuals numbers (g) weigg shrimp 2525 78 1 8499 23.9 6390 88.7 12955 42'.1 blue crab 690 21.4 26821 75.3- 727 10'.1 '16913 54.9~

stone crab 13 0.4 265 0.7 59 0.8 710 2.3 spiny lobster 4 <0.1 17 0.1 26 0.4 227 0.7

[ herring 152 0.9 623 1.2 618 2.9 2644

  • 110 anchovy 8776 54.4 12327 22.9 6049 28.0 jack 8319 3.1 4962 30.8 6575 12.2 1019 4.7 108062 40.9 ~-

mojarra 365 2.3 2918 5.4 1435 6.6 9876 3.7 grunt 453 2.8 5743 10.7 10855 50.3 82150 31.1 croaker 309 1.9 2444 4.6 327 1.5 cutlassfish 9449 3.6 458 2.8 2423 4.5 9 <0.1 2573' 1.0 flatfishc 112 0.7 1562 2.9 182 0.8 2001 0.7 other fish 542 3.4 19149 35.6 1110 5.1 39380 14.9 TOTAL SHELLFISH 3,232 100.0 35,602 100.0 7,202 100.0 30,805 100.0 TOTAL FISH 16,129 100.0 53,764 100.0 21,604 264,454 100.0 100.0 a To'al of 45 24-hour sampling periods. -

b Total of 97 24-hour sampling periods. -

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.. SUPPLbMENTAL ASSESSMENT IN' SUPPORT OF THE 316 DEMONSTRATION PILGRIM NUCLEAR POWER STATION i UNITS 1 AND 2

, BOST"N EDISON COMPANY G

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PREPARED BY d ENVIRONMENTAL ENGINEERING DIVISION STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS

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6.5 AMERICAN LOBSTER (Homarus americanus) y . .. i The lobster is a subtidal, mobile benthic species found offshor C-a :' of the Pilgrim Station. As an offshore species, lobster are les subject to power s tation effects than inshore species Monitoring studies at the site by the Mass. Div. of Mariw

" .i Finheries lobster is not (MDMF) , have indicated that the local population o a self-sustaining population and relies o-spawning elsewhere in Cape Cod Bay. Morrissey (1971) indicate.

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that there was some movement of egg-bearing females from th-northeastern. shore of Cape Cod to this area. About 310 of 45,75 lobsters or about 7 in 1,000 handled during the 1972-1976 studie were egg-bearing females. Thus, the localypulat4m in i.h -

vicinity of Pilgrim Station is a nonsustaining population.

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6.5.1 Thermal Plume

/ Two monitoring studies by the MDMF have been conducted t<

determine the impact of station operation on lobster- A harvest-m t per pot study monitored lobster catch within grid area:

.d" ~ (Figure 6-8) in the vicinity of the station. Figure 6-9 show.

the catch per pot for grids in the discharge area and catch pe; pot at Manomet Point (control area). There are no apparen'

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r, station-related eff ects since such stresses would appear as non-

, parallel time paths of the control and affected areas.

j A second study monitored lobster migration in control am

) affected areas. The discharge area did not seem to present at unmanageable stress on lobster because the patterns of migratior

were similar for Rocky Point (discharge area) and Manomet Point c j (control area) .

The seasonal effects from the predicted thermal pluma

,! (Appendix A) of Units 1 and 2 are shown in Figure 6-10. Based or i thermal tolerance data for lobster (Appendix A) , permanent residence of adult and juveniles will be excluded from the arei (2.1 acres) immediately adjacent to the discharge canal durins the summer months . The area beyond will maintain temperature:

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promoting (68 0-77 0F) maxi. mum growth for adults and juvenile:

7 during the summer months. During other seasons, the temperatur<

will stimulate growth in th a summer exclusion area (15 N isotherm). Growth of lobster to harvestable " size has bee:

reduced from 7 to 2 years in some heated waters (Hughes et a2 I

1972). Lobster are mobile and can thus migrat.. to the therma]

plume when temperatures are suitable , and migrate out of the l

thermal plume if temperatures are less than optimal.

6.5.2 Entrainment

, Prior to 1975, no lobster larvae were collected in th(

en trainment study by MRI at Pilgrim Unit 1. Therefore, th original 316 Demonstration utilized a very conservative approach c E31 6.5-1 P.

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n assuming that the density of lobster larvae entrained was the h same as the density of lobster larvae in the Bay near Pilgrim.

In 1975, a modified entrainment sampling program by MRI was initiated. As a result of this modified program, one larva was collected in the entrainment studies at Pilgrim during 1975 and ,

two were found in the- 1976 studies. The analysis in this W therefore, based on these recent P supplemental report is, entrainment figures. Based on an extrapolation of the two lobster larvae collected in the 1976 Unit 1 entrainment study, an f estin te of the. total number of larvae which and 2 would have been was developed by

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entrained during operation of Units 1 integrating through the sampling dates before and af extrapolationter each of l

were collected. A linear d the lobster larvae This projection was about

'be' tween sampling points was utilized.

24,000 lobster larvae entrained for full time operation of mQ ts 1 and 2.

ine number of adults that could have been recruited into the adult population from 24,000 larvae is calculated as follows. _

Af ter determining the number of larvae potentially entrained, the -

equivalent number of eggs from which 24,000 larvae would have survived is computed. Assuming a survivorhsip of 0.01 from eggs to stage IV larvae, the equivalent of 2,400,00,0 eggs would have been entrained. An estimate of loss of harvestable adults (see Section 6.1) assuming 100 percent entrainment mortality can be I made based on average harvest size (1.2 lb) and fecundity (10e eggs /f emale) for this year class (Saila et al 1969)

N (no. of adults) =

2.4 x 106 eqqs x 10-* females x 2 adults y 490. adults 'l i yr egg female This estimate, although based on conservative assumptions, is the -

most reasonable estimate of the effects of en trainment on the ,

lobster. The number of harvestable lobster potentially lost K

$q represents about 0.07 percent of the average yearly harvest' for Plymouth County (Beals et al 1970) . [

6.5.3 Entrapment s,

Prior to 1975, lobsters were n_ot collected in the impingement g nonitoring study. In 1976 four lobsters were collected from the -

intake. screens during 2,022 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of monitoring. Assuming the number impinged is proportional to the volume of water withdrawn, 23 lobsters could have been entrapped in 1976 by Unit 1 and 98 Ic entrapped by Units 1 and 2 if Units 1 and 2 were operating continuously. Impingement monitoring study data (particularly .

from other marine organisms) suggest that a linear prediction is Q highly conserva i. ive . Therefore, entrapment of lobsters will be 7 begligible when Units 1 and 2 are operating. L

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5.5.4 Cumula'tive Impact

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( 7. . Minimal impact on lobster is expected due to entrapment 4 years of because Unit 1 during b very few (4)' have been collected operation.

f Based on thermal tolerances during the summer months,immediatelyadult ancf juvenile lobsters will be excluded from 2.1 acres E

ad jacent to the discharge canal.

During the spring and f all of Since the year, growth should be stimulai.ed within th'is area.

lobsters could avoid less than optimal temperatures, no mortality as a result of the predicted thermal plume is expected.

lobstes larvae, or En .tn en gures, indicate about 24,00entraine,d ynits tr. per year potential ab6 t 490 a is number of adults represents only aboQt O. percen, and .

Considering these prediction '

of the Plymouth County harvest. used, the effect of th-and the conservative assumptions operation of Units 1 and 2 in the Cape Cod Bay lobster populatio: ~'

f m hould s be negligible.

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