ML20206K693

Discusses EPA Review of Fes.Recommended Studies Should Provide Data Prior to Commitments Re Addl Reactors.Thermal Effects,Entrainment of Irish Moss & Lobsters & Biological Fouling Discussed

ML20206K693
Person / Time
Site:	Pilgrim, 05000000
Issue date:	10/17/1972
From:	Harrison J ENVIRONMENTAL PROTECTION AGENCY
To:	Muntzing M NRC
Shared Package
ML20204E974	List: 05000000/LER-1975-004, Forwards LER 75-004-00.Conclusions of Investigation Will Be Submitted in 10-day Rept BECO-82-194, Responds to Confirmatory Action Ltr 82-19 Re Identification of Spent Resin on Roof Tops & Pavement within Protected Area on 820611.Condensate Demineralizer Sys Identified as Resin Source & Secured.Related Documentation Encl IR 05000293/1975002 ML20204E969 ML20204J237 ML20206F330 ML20206K250 ML20206K259 ML20206K286 ML20206K305 ML20206K341 ML20206K353 ML20206K363 ML20206K365 ML20206K385 ML20206K423 ML20206K439 ML20206K444 ML20206K449 ML20206K480 ML20206K485 ML20206K494 ML20206K504 ML20206K510 ML20206K520 ML20206K526 ML20206K530 ML20206K548 ML20206K555 ML20206K564 ML20206K579 ML20206K598 ML20206K616 ML20206K635 ML20206K639 ML20206K659 ML20206K688 ML20206K693 ML20206K698 ML20206K704 ML20206K709 ML20206K731 ML20206K743 ML20206K748 ML20206K754
References
FOIA-86-58 NUDOCS 8606300163
Download: ML20206K693 (3)

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%# JOHN F. KENNEDY FEDERAL DUILDING - ROOM 2303, BOSTON MASS ACHUSETTS 02203 October 17, 1972 50-293 U

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n M Hr. Manning L. riuntzing Director of Regulation h 9

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Dear rir. Muntzing:

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'k Im, The following comments are the result of the Environmenta T tection Agency's review of the Pilgrim fin'al environmental impact statement. These comments are of particular importance since the applicant has announced plans to construct two additional units 1150 liv cach at the Plynouth site. The studies ue have recommended, as well as other nost construction investiga-tions indicated in the statement, should provide suf ficient answers prior to -

making ccmmitments concerning additional units. Uc rcquest that the resulting data be submitted to us for our review as soon as possible.

OETAILED COZENTS Thermal Effccts The draft impact statement indicates that the site is_ unable. due to environmental limitation, to accept a coolina e ~'e r . The predicted tempera-ture rise witn the present cooling system is 29 0F. He are concerned about the ef f ect of this temrcrature rise oa the Irish Moss beds, and on the lobster population. Furthermore, page 53, paragraph 4, states that the thermal impact on planktonic organisms cannot oc ascertained until primary production studies are underway. These studies, alonc uitn specific tests

' en the Irish ;iosa and lobsters, must be completed before conmitnent is made to additional units.

We are a',.are that the applicant has requested approval of the Atomic Energy Conmission to operate their temperatures higher than the predicted tenperature rise during certain seasons of the year.. We agree with the Division of .iarine Fisheries that this proposal is unacceptable and the applicant should be required to operate at a 29 F temograture rise or below.

This seems especially important since the effect of 29 F temperature rise is still unknown. No higher temperature rise should be allowed until the proposed studies are completed.

Entrainment I

Although the intake velocity is alow (1 fps or less), entrainment of marine organisms may occur. The applicant has designed a discharge channel 8606300163 860613 5727  ;

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Mr. Manning Huntzing October 17, 1972 Page Tuo to minimize entrainment. We request that additional information be sent to us as soon as the success or f ailure of the design is determined.

Irish ibss -- We are particularly concerned about the potential effects of. the Irish Hoss sporeling entrainment. The fact that no sporcs were found in plankton samples taken during the fall of 1972 is inconclusive. To our knowledge tuere is no certainty that nethods which were used by the applicant

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are effective in collectin6 these spores. The method used by Prince in 1971 correlated the' number of sporcs settling upon some substrate, such as glass slides, with the number of snores uithin the water colunn at that tine. ine results pf his studies of the Pilgrim site indicated significant concentrations of Irish Hoss spores. Ec fouad that spore settlement occurred at a nearly constant rate fron August to late November of 1970, and that tetrasporic reproduction exhibited peaks in day and October, while carnosporic repro-duction commenced in mid-June and increased until early October.

Prince's laboratory investigations have also determined that nearly 100 per cent spore nortalitics occur with exposure to 95 F for 6 minutes. Similar investigations were not rade for other possible tine-at-tenperature conditions ,

(although Pritchard--1972--has predicted exposure times of about 3-11 ninutes at 200F or nore above ambient).

Since it is a nell-known fact that the movenent of overlying water nasses determines tue distribution of these sporclings from their point of release, and since the power plant circulating unter flou of 690 cfs will create a one-directional current toward the station intake, it seems highly nrobable that larne nuchera of Irish ross spores vill enter into the nouer plant's coolinc unter systen. Ue recomend more detailed studies of the concentrations of Irish Hoss and the ef fect of tenperature rise on its nortality. If Irish Moss sporeling entrainment mortalitics snould nrove to be excessive, an alternativo solution vould oc an of fshore intahe. If heavy nortality occurs due to the temnerature rise, alternative cooling methods must be considered.

Lobstera -- We are not convinced that the scope of the proposed lobster inveatigations is adequate to answer all pertinent questions. For examnic, to date, very few lobster larvae have been collected in the nuncrous toun -

made off Rocky Point; houcver, large nucacts of adult lobsters have been collected in this study area over the sanc period of time (Fairbanks,tet.al.,

1972). The significance of this data has yet to be determined, but 1.f the adult lobster population depends heavily on the success of these relatively j few larvac, any losses by way of entrainment would certainly effect the entire population. betailed information on the exact location of any special spawning, feeding, or nurscry areas for these animals uould be helpful in assessing such design alternatives as of fshore intake or discharge. It is, therefore, recommended that the habits and life history of the lobster be further investigated in association with this project.

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f Ilr.14anning Iluntzing October 17, 1972 Page 'ihree Biological Foulinn We do not feel tuat the final impact statenent properly addressed our recotracadation that more consideration be givea to alternate techniques for biological fouling control. Because of the many reports of chlorine caused fish-kills associated with operational failures, and increasing evidence tiaich indicates that chlorine may form highly persistent and toxic chlorinated-organic-connounds, we recommend alternative biological fouling control methods utilizing physical methods or safe chemicals.

Tne additional infornation from the studies we have recounended, and from the studics that tiere indicated in the final statement, should be sent to us for our review. This informatica should be assembled early enough r.o that it will oe the basis for deciding tincther to go ahead with additional units.

Sincercly yours,

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. q, j . _ / 4LL L( / d' <. t Joan Harrison Environmental Inpact Coordinator 9

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