ML25114A136
| ML25114A136 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/24/2025 |
| From: | NRC |
| To: | NRC/NMSS/DREFS |
| References | |
| Download: ML25114A136 (14) | |
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Pitcher's Thistle Survey Report Attachments:
Final Holtec Palisades_Pitcher's Thistle Survey Report.pdf
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Pitcher's Thistle Survey Report HOLTEC PALISADES Palisades CPA Covert Township Van Buren County, Michigan Apri I 1, 2025 Prepared by:
.:d ENE RC ON Excellence-Every project. Every day 500 Townpark Lane, Kennesaw, GA 30144 I (770) 919-1930 I www. enercon.com
Palisades CPA Pitchers Thistle Survey Report 1
Table of Contents I. INTRODUCTION.................................................................................................................. 2 II. PURPOSE........................................................................................................................... 2 III. PITCHERS THISTLE (CIRSIUM PITCHERI)..................................................................... 2 IV. PALISADES TERRESTRIAL HABITATS.......................................................................... 3 V. HISTORICAL OBSERVATIONS AT PALISADES.............................................................. 4 VI. 2024 PITCHERS THISTLE SURVEY AT PALISADES - METHODOLOGY..................... 4 VII. FINDINGS......................................................................................................................... 4 VII. REFERENCES.................................................................................................................. 5 PITCHERS THISTLE PHOTOLOG......................................................................................... 9 List of Figures Figure 1 Palisades Habitat Overview Map....................................................................... 6 Figure 2 Palisades Dune Slopes and Dune Blowouts Map............................................ 7 Figure 3 Pitchers Thistle Specimen Map........................................................................ 8
Palisades CPA Pitchers Thistle Survey Report 2
I. Introduction Enercon Services, Inc. (ENERCON), on behalf of Holtec International, Inc. (henceforth Holtec), prepared this Pitchers Thistle Ecological Survey Report for the proposed Palisades CPA (Construction Permit Application) project. The project involves the development of a two-unit small modular nuclear power plant on the existing Palisades Nuclear Power Plant (Palisades) property located at address 27780 Blue Star Highway in the township of Covert, Van Buren County, Michigan. The approximately 432-acre property was utilized as the project study area for the survey described in this report. ENERCON conducted an initial site reconnaissance on March 18-21, 2024, to characterize terrestrial habitats within the project study area. Subsequent field surveys were then conducted to document the presence/absence of Pitchers thistle (Cirsium pitcheri) within the study area.
II. Purpose The purpose of this report is to provide a baseline terrestrial ecological characterization of the project study area based on the results of Pitchers thistle surveys. This report also provides a basis to propose and discuss future studies and survey methods and to inform design, siting, construction, and operation of the project in a way that minimizes potential impacts to the species.
III. Pitchers Thistle (Cirsium pitcheri)
Pitchers thistle is listed as threatened species at the state and federal levels. The range of this endemic plant falls mainly within Michigans borders, occurring along the entire shoreline of Lake Michigan. (MNFI 2024) According to the U.S. Fish and Wildlife's (USFWS) Information for Planning and Consultation (IPaC) online tool, this species potentially occurs within the project area (USFWS 2024) and has previously been observed within the property (see Historical Observations section below). This plant is a distinctive stout dune species that can grow up to 40 inches or more in height, though stunted individuals as small as four inches may flower. The leaves and entire plant are blue green in color and densely covered with white woolly hairs. The mature leaves are deeply divided into narrow, spine-tipped segments.
The prickly, spine-tipped flower heads are relatively large and cream-colored, though they may occasionally have a slight pinkish tint, yielding seeds with feathery bristles. The species may take up to ten years to flower. Pitchers thistle is most easily recognized during the principal flowering and fruiting period from late-June to early September. (MNFI 2024)
Pitchers thistle typically grows on open sand dunes and occasionally on lag gravel associated with shoreline dunes. Habitat occurs along Great Lakes shores, or in very close proximity on dune slopes. Associated plants include common dune species such as American beach grass (Ammophila breviligulata), little bluestem (Andropogon scoparius), wild rye (Elymus canadensis), bearberry (Arctostaphylos uva-ursi), sand reed grass (Calamovilfa longifolia), dune wheat grass (Agropyron dasystachyum), and common milkweed (Asclepias syriaca). The species is most common in Michigan along the extensive dune systems on the northern and northeastern shores of Lake Michigan. It is scattered along the perimeters of southeastern Lake Michigan and northern Lake Huron. (MNFI 2024)
Palisades CPA Pitchers Thistle Survey Report 3
IV. Palisades Terrestrial Habitats The Palisades Nuclear Power Plant site (Palisades) is characterized as having five distinct terrestrial habitat types: forested areas, wetlands, disturbed/maintained areas, dune slope and dune blowout areas, and lake shoreline (Figure 1). Among these, both the dune slope/blowout areas and the lake shoreline meet the habitat requirements for Pitchers thistle.
Dune Slope and Dune Blowout Habitat Six areas totaling approximately 23 acres within the project study area have been identified as dune slope and dune blowout areas (Figure 2): (1) northwest blowout; (2) central dune slope; (3) main parking dune slope; (4) Cooling Tower A dune slope/blowout; (5) Cooling Tower B blowout; and (6) south blowout. These areas are the result of erosion via wind and precipitation. Wind erosion creates bowl-shaped cutouts in dunes (called blowouts) and precipitation erosion tends to cause slips on poorly stabilized dunes that in turn creates steep slopes with limited vegetation. As opposed to the forested dune habitats, vegetation within dune slopes and dune blowout areas tend to lack mature trees. Instead, these areas are dominated by low-growing herbaceous vegetation as they generally lack the soil stability necessary for the mature growth of woody vegetation. Dominant vegetation observed within these areas include American beachgrass (Ammophila breviligulata), spotted knapweed (Centaurea stoebe), field mugwort (Artemesia vulgaris), and bunchgrasses such as little bluestem (Schizachyrium scoparium), broomsedge bluestem (Andropogon virginicus), and yellow Indiangrass (Sorghastrum nutans). Prevalent vegetation generally includes beach plum (Prunus maritima), dogwoods (Cornus spp.), yellow salsify (Tragopogon dubius), and limited tree saplings and immature specimens.
Dune slope and dune blowout habitat support wildlife such as coyote and deer. The sparsely vegetated nature of the habitat means that resources in the form of food and shelter for wildlife are less abundant compared to other habitats within the project study area.
Nevertheless, these areas can host specialized dune-inhabiting species, including the state and federally listed Pitchers thistle. Additionally, the open nature of the habitat provides easy navigation for foraging deer and hunting coyotes.
Lake Shoreline Habitat The shoreline of Lake Michigan at Palisades constitutes approximately 10.6 acres. This habitat consists of gently sloping flat sandy terrain that is sparsely vegetated. Shorebirds including gulls, cormorants, and ducks were observed in this habitat. The shoreline is wider at the north end than at the south end. The dune terrain east of the shoreline is steeper at the south end than the north end. Shoreline habitat was observed to be sparsely vegetated with primarily American beachgrass, spotted knapweed, field mugwort, and yellow Indiangrass, as well as small clusters of common milkweed (Asclepias syriaca) at the north end. Vegetation within the area only grows upslope and east of Lake Michigan such that wave flow does not typically reach.
This habitat area provides food and nesting resources for a variety of shorebirds. The sparsely vegetated and open nature of the shoreline provides easy navigation for predators
Palisades CPA Pitchers Thistle Survey Report 4
such as coyotes. The shoreline habitat also provides potential habitat for the listed Pitchers thistle.
V. Historical Observations at Palisades Pitchers thistle has historically been documented at Palisades. From the early 1980s until the late 1990s, the species had been observed in an area of the dune blowout located southwest of the existing switchyard (near the cooling towers) but was not present at this location in 2005 (NRC 2006). However, surveys in 2005 found more than 100 individual Pitchers thistle specimens on the northern end of the Palisades site, on stabilized dunes and flats just south of Van Buren State Park. (NRC 2006)
VI. 2024 Pitchers Thistle Survey at Palisades - Methodology Using survey methods recommended by the Michigan Natural Features Inventory (MNFI) species profile, presence/absence surveys for Pitchers thistle were conducted by walking transects at intervals of approximately three meters within portions of the project study area that could reasonably provide viable habitat for the species. Specifically, survey transects were walked along the Lake Michigan shoreline north and south of the developed areas of Palisades, as well as by walking the non-forested, exposed dune blowout and dune slope areas within the project study area. Surveys for Pitchers thistle were conducted within the seasonal timeframe recommended by the MNFI species profile which ranges from the third week of June through the third week of September (MNFI 2024).
VII. Findings Seasonal field surveys for Pitchers thistle were conducted in 2024 during the following dates:
May 6-8 June 18-22 July 22-24 Figure 2 details the areas surveyed for Pitchers thistle on the Palisades property. Careful attention was paid to surveying areas where Pitchers thistle had been previously documented (northwest blowout; Figure 2). No specimens were evident in these areas during the 2024 seasonal survey events. However, 64 specimens were found in the south dune blowout location on July 23, 2024. Figure 3 maps the observed locations of these individual specimens. Individuals and clusters of individuals were indirectly marked with flagging tape and geo-located with a GPS unit. Two of the observed specimens were in a reproductive state (flowering), although the flowers had gone to seed by the time of the observation. No Pitchers thistle specimens were observed in any other dune slope/dune blowout areas or the lake shoreline areas. Representative photographs of selected observed specimens are attached to this report below.
New development onsite is not anticipated to have any impacts on this isolated population as the project is being planned to avoid impacts in the Critical Dune habitat area, and further,
Palisades CPA Pitchers Thistle Survey Report 5
Holtec will employ required best management practices during the construction and operation phases of this project.
VII. References Michigan Natural Features Inventory (MNFI). 2024. Pitchers thistle (Cirsium pitcheri).
Retrieved from <https://mnfi.anr.msu.edu/abstracts/botany/Cirsium_pitcheri.pdf> (accessed December 4, 2024).
Nuclear Regulatory Commission (NRC). 2006. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Regarding Palisades Nuclear Plant. NUREG 1437, Supplement 27, Final Report. October 2006. ADAMS Accession No. ML062710300.
U.S. Fish and Wildlife Service (USFWS). 2024. Information for Planning and Consultation (IPaC) Tool - Van Buren County, Michigan. Retrieved from
<https://ipac.ecosphere.fws.gov/location/ZRSGAK3A4REKTDTMO7BROZSVUI/resources>
(accessed December 4, 2024).
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Pitchers Thistle Photolog
Palisades CPA Pitcher's Thistle Survey Report Photograph 1: (7-25-2024) Representative View of Pitcher's Thistle Specimen within
_ South Dune Blowout Area of the Palisades Propert Photograph 2: (7-25-2024) Representative View of Flowering Pitcher's Thistle Specimen within South Dune Blowout Area of the Palisades Property 10
Palisades CPA Pitcher's Thistle Survey Report Photograph 3: (7-25-2024) Representative View of Flowering Pitcher's Thistle Specimen within South Dune Blowout Area of the Palisades Pro erty Photograph 4: (7-25-2024) Representative View of Pitcher's Thistle Specimen within South Dune Blowout Area of the Palisades Property 11