ML20207A447

Comment Supporting NUREG-1437,Suppl 1, Generic Environ Impact Statement for License Renewal of Nuclear Plants, Calvert Cliffs Nuclear Power Plant. State of MD Concurs with Staff Conclusion

ML20207A447
Person / Time
Site:	Calvert Cliffs
Issue date:	05/19/1999
From:	Mclean R MARYLAND, STATE OF
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-64FR11071, RTR-NUREG-1437 64FR11071-00015, 64FR11071-15, NUDOCS 9905260336
Download: ML20207A447 (8)

Text

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. M49 [ 3 ycerye *"4 Offf' 1999 HAY 20 PH 3: q3 g um RULES & Da B,rw;gg US NRC Parris N. Glendening John R. Grimn ,

covernor Maryland Department of Natural Resources secretary l

Kathleen Kennedy Townsend POWER PLANT ASSESSMENT DIVISON Stanley K. Arthur Lt. Governor Tawes State Ofnce Building, B-3 Deputy Secretary Annapolis, Maryland 21401-2397 l

May 19,1999 Chief Rules Review and Directives Branch Division of Administrative Services Mailstop T 6 D 59 U.S. NRC Washington, DC 20555-0001

Dear Sir:

We have reviewed the draft document entitled Generie Environmental hnpact Statementfor License RenewalofNuclear Plants: Calvert Cli[fs Nuclear Power Plant (NUREG-1437, Supplement 1)), and have prepared the attached comments on the document. On behalf of the State of Maryland, the Department of Natural Resources (DNR) Power Plant Research Program has been involved with various studies at the Calvert Cliffs Nuclear Power Plant (CCNPP) since the plant was commissioned in 1974. DNR has coordinated the involvement of Maryland state agencies throughout the CCNPP relicensing process, and has solicited feedback from them on this draft supplemental environmental impact statement (SEIS). Our comments on this document as provided below reflect our knowledge of CCNPP and of power station operations in general -

fossil-fired as well as nuclear - and the input we have received from other Maryland agencies.

Based on 25 years of operational history with minimal impact to the State's natural resources, the State of Maryland concurs with Staffs conclusion that adverse environmental impacts of CCNPP license renewal are not so great that preserving the option oflicense renewal would be unreasonable. This letter presents information that may be useful to Staffin updating and g finalizing the document. Our comments fall into the following categories: 1) fisheries valuation; \

2) EMF research; 3) alternatives to license renewal; and 4) miscellaneous comments. \

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9905260336 990519 PDR NUREC 1437 C PDR www dnr state md tahav/ogg Telephoneyin) 76n R667 PPADmnil@dnr state md us DNR TDY for the Deaf:(410) 260-8835 TOLL FREE l-877-260-8367

May 19,1999

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Page 2 Fisheries Valuation Section 4.1.2 of the SEIS presents estimates of fisheries losses caust J by impingement at CCNPP, including the monetary values of those losses (page 4-9) liowever, there are more up-to-date estimates of these losses that should be incorporated inte ;he document. Attached to this letter, DNR is providing relevant summary tables with estimates of the value of fish killed from impingement at CCNPP in 1993,1994 and 1995. The tables present the most common species impinged each year (the listed species account for 99% of the fish impinged). The estimated number cf fish impinged as well as the estimated weights were obtained from the Ademy of Natural Sciences annual impingement studies (references 1 - 3). BGE estimat:s of percent survival for impinged species were incorporated into the assessment.

Following the methods described in the draft SEIS, no value was estimated Ik species with survival rates greater than 99% (Callinectes sapidus and Trinectes maculatus). Because there were no known survival estimates for three species (Morone americana, Morone saxatilis, and Cynoscion regalis), our percent survival for these species wastimated to be the mean survival of other species impinged that year (78% for M. americana and M. 3aratilis, 82% for C. regalis).

Valuation ofindividual species involved two sources: The first set of tables uses American Fisheries Society (reference 4) valuation factors (attachment 1), while the second set (attachment

2) uses factors established in the' Code of Maryland Regulations (references 5,6) and an inflated dollar value (1993,1994,1995) based upon the consumer price index (CPI). When the COMAR value varied with size of fish, an estimate oflikely mean size was developed by comparing the approximate weight per fish (from the estimated weight and number of fish of each species per unit per year) to known size weight relationships. The assumptions in this valuation are believed to be conservative, thereby potentially overestimating the value of fish killed each year.

Using these updated impingement data and valuation methods, it appears that the draft SEIS  !

actually overstates the monetary value ofimpingerant losses. We concur with Staff's ,

conclusion that potential impacts of the cooling water intake system on the impingement of fish  !

and shellfish are small, and mitigation is not warranted.

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Electric and Magnetic Fields (EMF) Research  !

l We concur with Staffs conclusion in Section 4.2.2 that epidemiological and experimental evidence regarding the chronic health effects of exposure to electric and magnetic fields (EMF) is inconclusive. For your information, the Maryland Power Plant Research Program also prepares summary reports of scientific evidence concerning the possible adverse health effects  !

from EMF produced by electric power lines. In our latest report, the State of Maryland i concludes that "scien% 's have been unable to develop a consensus that there is a definite link  ;

between EMF exposure t.nd adverse public health" (reference 7). Maryland continues to monitor and study the results of EMF research.

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May 19,1999 Page 3 Alternatives to License Renewal Important changes affecting Maryland's electric power industry have taken place since preparation of the draft SEIS began. While these changes do not change the fundamental

' conclusions in the report, they serve as important background for inclusion in the SEIS and are q briefly described in the following paragraphs.

In April 1999, the Maryland General Assembly approved the Electric Cuciemer Choice and

. Competition Act of 1999, signed into law by Governor Glendening shortly %rofter. During -

the past year, BGE and other parties (including Maryland DNR) have occa % gating a transition to retail competition. While that case is not yet concluded, it now appears likely that CCNPP will be transferred to an unregulated affiliate. (BGE itselfis now a subsidiary of the newly

. created holding company, Constellation Energy Group, an exempt holding company under the Public Utility Holding Company Act.) There is one exception to this likely arrangement. BGE, as a utility " wires company", will continue to remain responsible for the funding of decommissioning of the plant. This is an important change, because previously there had been consideration of retaining CCNPP (Maryland's sole nuclear power plant) as a regulated asset and -

deregulating only fossil / hydro capacity.

Restructuring means that CCNPP will no longer be required to serve its Maryland customers (except perhaps in the early years of restructuring when BGE retains a " default" or Standard ,

Offer obligation). As _a general matter, in a restructured world, CCNPP will serve the regional, i mid-Atlantic market. However, due to transmission constraints for imports into Maryland, if the plant were to be retired, either some of the replacement capacity must be sited in Maryland, or .

transmission intertie transfer capacity must be expanded to allow more imports. Although  !

Maryland would need either replacement capacity or expanded transmission capability if Calvert <

Cliffs is retired, the new resources need not be sited in Southern Maryland (i.e., near the present  ;

Calvert Cliffs' site). This is because there is already substantial generation in Southern Maryland 1 at Potomac Electric Power Company's (PEPCO) Morgantown and Chalk Point Plants. Maryland j load centers are primarily north of the Calvert Cliffs site. Ultimately the retirement of Calvert l Cliffs will necessitate replacement resources in the form of new generation and/or transmission in Maryland; it will be supplied by the market, not necessarily BGE.'

There is another issue referenced on page 8-2 of the SEIS which requires update. The report correctly notes the facility's importance to Calvert County as a source of property tax revenue.

However, utility tax legislation enacted in the most recent session of the Maryland General Assembly sharply reduces (on a phase-in basis) property tax revenue from Maryland power l

The SEIS partially recognizes this in referring to replacement resources that "BGE may not be the ultimate supplier of power " (page 8-1)

May 19,1999 Page 4 plants. CCNPP's property tax payments will decline over time by 60 percent. Moreover, restructuring and accounting write-offs could lead to further reductions in property taxes from the plant. Calvert County will receive some compensation from the State to cushion the property tax loss, but that compensation is unrelated to license renewal. In summary, the property tax benefit from the plant will in the future be dramatically smaller than at the present time.

The report mentions coal- and gas-fired plants as being the primary replacement resources if CCNPP were to be retired. This view is reasonable, although it is very difficult to make predictions on preferred technology extending to 2014 and beyond. Based on current economics, we would emphasize gas-fired os er coal-fired generation as the most likely capacity replacement.

We have some observations on the air emissions analysis. The discussion of air emissions needs to recognize that a major new combustion facility in Maryland would have to acquire " offsets" for nitrogen oxides (NO,) and allowances for sulfur dioxide (SO2 ). Effectively, thir, means no significant net increase in emissions for those pollutants on a regional basis. In the case of natural gas, even the " moderate" impact in the SEIS may be an overstatement. On the other hand, the SEIS does not consider greenhouse gases (most notably, carbon dioxide) from the replacement fossil capacity, which are not subject to offsets (at this time). Replacement of CCNPP's capacity with a coal-fired plant at the same site would certainly have local impacts with respect to concentrations of NO,, SO 2, Particulate matter, carbon monoxide, mercury and other trace metals and organic compounds.

With respect to gas-fired generation, the SEIS correctly notes that combined cycle units are the technology of choice for most new capacity additions presently and for the foreseeable future.

The analysis assumes that only a short pipeline spur would be needed to serve the site, and that plenty of spare capacity on the interstate pipeline is available. Since we are talking about the time period after 2014, and natural gas demands are growing rapidly, this is clearly an uncertainty. Also, importantly, there is no mention of the need at a major gas-fired facility for backup oil storage tanks and the impacts they might have.

The SEIS discusses conservation programs as a means of replacing CCNPP. The report notes that conservation efforts merely slow growth in demand rather than reducing it, and therefore cannot directly substitute for CCNPP's capacity. Since the SEIS was prepared BGE (with the concurrence of the Maryland Public Service Commission, PSC) has eliminated nearly all ofits ongoing conservation programs. Maryland's restructuring legislation requires that the PSC review the need for conservation programs according to certain criteria. The review will take place in consultation with the Maryland Energy Administration (MEA). The outcome of such a PSC review cannot be predicted at this time. The present outlook is that utility-sponsored conservation programs in the future will likely be smaller in scope than in the past.

With reduced utility efforts and investment in conservation programs, it is unclear whether market forces under a restructured environment will enhance or retard customer conservation

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May 19,1999 Page 5 I efforts. Ilowever, to the extent restructuring leads to lower retail rates, this will encourage greater demand for electricity (price elasticity effects), thereby undermining or offsetting the possibility that conservation programs could substitute for or replace CCNPP.  ;

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Miscellaneous Comments Page 1-5, line 24: The plant is located approximately 40 miles southeast of Washington, DC,  !

not southwest as currently stated in the draft. ,

Page 1-7, line 22: NPDES stands for National Pollutant Discharge Elimination System, not

" Pollution" as stated in the draft.

Page 6-7, l nes J through 7: There appears to be a word or words missing from this sentence, j which are needed to make it grammatically correct and complete.

<fppendix D, Organizations Contacted: It would be more appropriate to refer to the overall l Power Plant Research Program of DNR in this list of organizational contacts (i.e., on line 38 of page D-1, please delete the phrase " Transmission Programs").

We appreciate the opportunity to comment on the draft SEIS. The State of Maryland will continue to be actively involved in the characterization of natural resource impacts from life extension at CCNPP as this license renewal proceeds.

Sine rely, I Richard I. McLean Manager, Nuclear Programs RIM:rd

ATTACHMENT 1 1993 No.hsn Lstimated No.hsn Estimated Percent 1 otal F ish Iotal Weight Value Value of Unit 1 Weight (g) Unit 2 Weight (g) Survival Killed of Fish Kill Fish Kill Soecies Name Anchoa mitchelle 92784 225308 323428 721555 0 68 133187.8 0 08 per fish 10655 02 Brevoortia tyrannus 5836 417521 3329 519678 0 52 4399 2 989.7 0.2 per pound a 197 94 Callinectes sapidus 353488 29364686 305732 27937212 0 99 NE Gobecsom strumosus 2174 11101 538 2514 0 93 189 8 0 08 per fish b 15 19 Leiostomus xanthurus 4601 74654 4076 59433 0 84 1388 3 47.2 011 per pound e 5 19 Menidia spp. 13874 131174 5041 49497 0.54 8700 9 0.08 per fish 696 07

%cropogonias undulatus 49403 74605 54 5096 0 19 40060 2 142.0 011 per pound c 15 62 Syngnathus fuscus 9883 9281 4332 4307 0 85 2132.3 0 08 per fish b 170 SE Trinectes maculatus 115023 2842983 71959 2141773 0 99 NE TOTAL VALUE OF 1993 ctSH KILL ,

1175562 l

1994 No. Hsh Estirrmed No hsh Estimaterf Percent Total hsn Iotal Weignt Value Va:ue of Unit 1 Weignt (g) Unit 2 Weight (g) Survival Killed of Fish Kill Fish Kill Species Name Alosa aestwalis in55 90129 22931 147885 0.47 19549 6 277.5 U A' per pound d 88 81 Anchoa matchilli 7445 19194 13910 34615 0 68 6833 6 0 08 per fisn $46 69 Caliinectes sapidus 250584 12339168 297042 11394457 0 99 NE Gasteresteus aculeatus 1317 6260 2289 9308 0 91 324.5 0 08 per fish 25 96 Leiostomus xanthurus 6602 537943 3520 196222 0 94 1619 5 258.4 0.11 per pound c 28 43 Menedia spp 3105 23934 11345 80193 0 54 6647.0 0 08 per fish 531.7C Morone amencana

• 385 2457 2078 25099 0 78 532 6 13.1 0.3 per pound 3 93 l

297 33932 1473 62428 9 78 3828 45 8 1 per pound 45 84 Morone saxatdis

• Syngnatnus fuscus 3004 3300 4423 4017 0 85 1114 1 0 08 per fish b 89 12 7nnectes maculatus 18325 588346 21090 685403 0 99 NE 1271 74 TOTAL VALUE OF 1994 FISH KILL 1995 No. hsn Estimateo No.Hsn Estimated Percent Iotalhsn TotalWeight Value Value of Unit 1 We:ght (g) Unit 2 Weight (g) Survival Killed of Fish Kill Fish Kill Specres Name Alosa aestivahs 2265 11839 1777 10802 0 47 2142 3 26.4 0 44 per pound a 11 62 74321 209496 78010 217264 06S 48745 9 0.08 per fish 3899 67 Anchoa mitchilh Oa!!inectes sapidus 133430 7514383 107809 6404294 0 99 NE 3700 52429 1388 26671 0 82 908 6 31.1 0.11 per pound c 3 42 Cynoscion regalis

• Gobiesox strumosus 2689 14575 1019 5190 0 93 259 6 0.08 per fish b 20.7C 52472 6177 47520 0 84 2138.9 0 08 per fish 171.11 Menidia spp. 7191 Syngnathus fuscus $253 4975 3358 3160 0 85 1291.7 0.08 per fish b 103 33 Trinectes maculatus 8246 249608 8620 254699 0 99 NE 4209 91 TOTAL VALUE OF 1995 FISH KILL NE . Not Estimated, fish mortality assumed to be negligible because survival rate is 99%

• . Percent survival estimated as mean of other known species.

a . Average size of 4-6 inches assumed for vtluation purposes.

b Value assigned to forage. fish.

c.Value for freshwater drurn (the only Sciaenidae for which a value exists); average $:ze 14 inches assumed for va!uation purposes

d. Average size of 4 6 inches assumed for valuation purposes

y ATTACHMENT 2 e

1993 4QMAR Species COMAR Adjusting for No Fish No Fish Perceit Total Fish Value in Value Before Adjustment COMAR CPI encrease Species Name und 1 Und 2 Survivv Killed Dollars Adjustment Factor Value (2 69)

Anchoa matchelh 92784 323428 0 68 133187.8 1 perInousand 133 19 0 75 99 89 268 71 l Brevooriaa tyrannus 5836 3329 0 52 4399 2 01 eacn 439 92 1 439 92 1183 3e l Oallmectes sapadus 353488 305732 0 99 NE 0 25 eacn 1 l GobiesoA Strumosus 2174 538 0 93 189 8 1 perinousand 0 19 0 75 0 14 0 38 Leiostomus manthurus 4601 4076 0 84 1388 3 015 eacn 208 25 08 166 60 448 15 Menedia spp. 13874 5041 0 54 8700 9 1 per thousand 8 70 0 75 6 53 17.55 weropogonias undulatus 49403 54 0 19 40060 2 015 each 6009 03 1 6009 03 16164 26 Syngnathus fuscus 9883 4332 0 85 2132 3 1 per thousand 2 13 0 75 1 60 4 3C l 7nnectes maculatus 115023 71959 0 99 NE 1 per tnousand 0 75 TOT At VAL UE OF 1993 FISH kill l 6773 70 18086 7f 1994 COMA 8 Soecies COMAR Adjusting for No Fish No. Fish Percent Total Fish Value m 'Value Before Adjustment COMAR CPI increase Species Name Und t Unit 2 Survival Kdied Doltars Adjustment Fador Value (2 75)

Alcsa nestivahs 13955 22931 0 47 19549 6 01 ea:n 1954 96 1 1954 96 5376 13 An:hoa milchdll 7445 13910 0 68 6833 6 1 per thousand 6 83 0 75 5.13 14 09 Callinectes sapidus 250584 297042 0 99 NE O 25 esca 1 Gasteresteus aculeatus 1317 2289 0 91 324 5 1 per tnousand 0 32 0 24 0 67 0 75~

.eiostomus mantnurus 6602 3520 0 84 1619 5 015 eacn 242 93 08 194 34 53444 Menidia spp 3105 11345 0 54 66470 1 per thousand 6 65 0 75 4 99 13 7.1 , <

Vorone amencana

• 385 2078 0 78 532 6 015 each 79 89 79 89 1 219 71 6, i Vorone sanatdes

• 297 1473 0 78 382.8 0 75 each 287 07 1 287 07 789 45 l Syngnathus fuscus 3004 4423 0 85 1114 1 1 per tnousand 1.11 0 75 0 84 2 30 7rmectes maculatus 18325 21090 0 99 NE 1 perinousand 0 75 total. VA . sti OF 1994 FISH Kill 7577 46 6950 K 1995 GOMAR Species COMAR Adjusting for No Fis't No. Fish Percent Total Fish Value in Value Before Adjustment COMAR CPI increase Species Name Unit 1 Und 2 Survival Killed Dollars Adjustment Factor Valve (2 83)

Atosa nestivahs 2265 1777 0 47 2142.3 01 eacn 214 23 1 214 23 606 26 Anchos mdchdli 74321 78010 0 68 48745 9 1 per tnousand 48.75 0 75 36 56 103 46 2alknectes sapidus 133430 107809 0 99 NE 0 25 each 1 Oynoscion Ws

• 3700 1388 0 82 908 6 0 25 eacn 227.14 1 227 14 642 81 3cDres:ss- ws 2589 1019 0 93 259 6 1 per tnousand 0 26 0.75 0 19 0 55 Venidia s;p 7191 6177 0 84 2138 9 1 pertnousand 2 14 0 75 1 60 '4 54 Syngnathus fuscus $253 3358 0 $$ 1291 7 1 per thousand 1 29 0 75 0 97 2 74 Trrectes maculatus 8246 8620 0 99 NE 1 perinousand 0 75 TOTAL VALUF OF 1995 FsSH Kit L 480 70 1360 3r

' P9' cent surysval estimated as fnean of other known species N6

• Species with known impmgement sgrvival of 99% were ehminated from evaluation.

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.g REFERENCES

1) liixson, J.fl. Ill and D.L. Breitburg. 1993. 1993 Impingement Studies at Calvert Cliffs Nuclear Power Plant for Baltimore Gas and Electric Company. Estuarine Research Center, St. Leonard, Maryland, of The Academy of Naturla Sciences, Philadelphia, Pennsylvania. Report No. 94-28.

2) liixson, J.11.111 and D.L.13reitburg. 1994.1994 Impingement Studies at Calvert Cliffs Nuclear Power Plant for Baltimore Gas and Electric Company. Estuarine Research Center, St. Leonard, Maryland, of The Academy of Naturla Sciences, Philadelphia, Pennsylvania. Report No. 95-13.

3) Hixson, J.II.111 and D.L. Breitburg. 1995. 1995 Impingement Studies at Calvert Cliffs Nuclear Power Plant for Baltimore Gas and Electric Company. Estuarine Research Center, St. Leonard, Maryland, of The Academy of Naturla Sciences, Philadelphia, Pennsylvania. Report No. 96-12.

4) American Fisheries Society.1992. Investigation and valuation of fish kills. American Fisheries Society Special Publication 24. Bethesda, Maryland.

5) COMAR Title 08, Subtitle 02, Chapter 09, Section 01 - Monetary Value of Tidal Water and Non-tidal Water Aquatic Animals.

6) COMAR Title 26, Subtitle 08, Chapter 03, Section 05 - Cooling Water Intake Structures.

7) Patty, S.1999. Status Report on Potential Human llealth Effects Associated with Power Frequency Electric and Magnetic Fields. Maryland Power Plant Research Program.

Report No. PPSE-T-42