NRC-2009-0039, Comment (6) of Joyce Stanley on Behalf of the Dept. of Interior on Draft Supplemental Environmental Impact Statement for Crystal River Unit 3
| ML11208C270 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/25/2011 |
| From: | John Stanley US Dept of Interior (DOI) |
| To: | Cindy Bladey Rulemaking, Directives, and Editing Branch |
| References | |
| 76FR32237 00006, NRC-2009-0039 | |
| Download: ML11208C270 (5) | |
Text
Jul 25 11 03:13p Joyce Stanley 4043311736 p.1 US Deatmn of th Inero Fax To: RADB From: Joyce Stanley Fax: 301-492-3446 Fax 404-331-1736 Phone: Phone: 404-331-3567 Re: Docket ID NR( -2009-0039 Pages: 5 (including cover page) 13 Urgent 13 For Review E0 Please Cominent 0 Please Reply 13 Please Recycle
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Jul 25 11 03:13p Joyce Stanley 4043311736 p.2 United States Department of the Interior TAKE PRIDE9 INAMERICA OFFICE OF THE SECRETARY Office of Environmental Policy and Compliance Richard B. Russell Federal Building 75 Spring Street, S.W.
Atlanta, Georgia 30303 ER 11/485 9043.1 July 25, 2011 Cindy Bladey Chief, Rules, Announcements and Directives Branch (RADB)
Office of Administration U.S. Nuclear Regulatory Commission Mail Stop: TWB-05-BOIM Washington, DC 20555-0001.
Re: Comments and Recommendations on the Draft Supplemental Environmental Impact Statement (DSEIS) for the Florida Power Corporation, Crystal River Unit 3 Nuclear Generating Plant; Notice of Availability of Draft Supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants and Public Meetings for the License Renewal - Docket ID NRC-2009-0039
Dear Ms. Bladey:
The United States Department of the Interior (Department) has reviewed the subject Draft Supplemental Environmental Impact Statement (DSEIS) and offers the following comments.
Page 4.7.1.1 The information on macrophytes in Crystal Bay is approximately 50 years old. Suggest the EIS reference more recent (1992) data on submerged aquatic vegetation, available from the USGS and described in metadata at:
http://sabdata.cr.usgs.gov/sabnet/priv/net pub products/METADATA!2005-16-0163.HTML and http://sdms.cr.usgs.gov/data/metadataicry92.html.
Section 4.7.1.1 The document states that "Studies conducted at the CREC resulted in no observations or collections of Gulf sturgeons or small tooth sawfish (Grimes and Mountain, 1971), (AEC, 1973),
(NUS Corporation, 1978), (Progress Energy, 2008a). The NMFS (2002) does not believe that Gulf sturgeon would stray from mud and sand bottom foraging areas to enter the rocky bottomed substrates found within the CREC intake canal. Based on this information, the NMFS (2002)
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concluded that the change of the operation of the CREC affecting the Gulf sturgeon is discountable." However, most of the cited studies (4 of 7) occurred when the Gulf Sturgeon was unprotected by the State of Florida (harvest ban issued in 1984) or by the Federal ESA listing (1991 - 1992) during a period when the Suwannee River population was depressed by decades of commercial fishing (Huff 1975). The Department is currently working in this area and has presented updated information at national and international sturgeon symposia. We suggest the EIS include more recent information on Gulf sturgeon abundance, and life history.
The early 1990s population of Gulf Sturgeon was estimated at 2000-3000 individuals in scientific journal literature. Current Department mark and recapture estimates numbered the net-vulnerable (> 1.0 m total length) Suwannee River population at 14,000 in 2006-2007, using open population models (a Program Mark, Jolly-Cormac-Seber closed-model population estimate based on USGS population census sampling in 2006-2007) (Sulak, 2009; Sulak and Randall, 2008). Increasing population has expanded habitat us, so that 1990s data on habitat use is not a reliable guide to habitat use in 2011. During the winter nearshore marine feed period, juveniles and adults are found in the nearshore coastal area in depths less than 10 m, typically in depths less than 3 m. USGS remote acoustic receivers deployed off the end of the Crystal River can in 2010 have detected acoustically tagged sturgeons in the vicinity of the intake canal (Sulak, pers comm). Small sturgeons have been reported as impinged on intake screens at the St. Lucie generating plant on the Florida East Coast in the past. Thus, the NMFS 2002 determination may be flawed due to dependence to a major degree on data from the period of very low Gulf Sturgeon abundance prior to protection and subsequent population rebound.
Moreover, despite the presence of more than 14,00 Gulf sturgeons feeding in the nearshore zone north and south of the mouth of the Suwannee River (Tampa to Apalachicola) in winter, Gulf sturgeons are difficult to capture in conventional scientific sampling gear used by the Florida FWCC or other scientific institutions, particularly with the Florida net ban in effect. They are capable trawl avoiders. Absence of collections does not equate to absence of sturgeons in this regard, particularly in the period prior to 2002 when population abundance was low. It is reasonable to state that the NMFS 2002 conclusion that there is no chance of operation affecting the Gulf sturgeon maybe in need of revision in 2011. A robust program of acoustic tagging of Suwannee River juveniles (most likely to feed in very shallow nearshore areas), accompanied by deployment of a grid of remote datalogging acoustic receivers deployed in the vicinity of the CREC intake canal would be needed to address potential impact under the current conditions of population abundance, based on recent scientific publications that are not cited in 4.7.1. 1, and based on expanded use of habitats.
Thank you for the opportunity to review and comment on the DEIS. If you have questions concerning these comments, please contact Gary LeCain on (303) 236-1475 or via email
.gdlecain(,usgs.gov. I can be reached on (404) 331-4524 or via email at Joyce stanleyO&ios.doi. gov.
Sincerely, Joyce Stanley, MPA Regional Environmental Protection Assistant
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References Huff, J.A., (1975). Life history of Gulf of Mexico Sturgeon, Acipenser oxyrhynchus desotoi in the Suwannee River, Florida. Florida Marine Research Publications, No. 16, 1-32.
Sulak, K.J., & Randall, M.T. (2008) Synopsis of population trends in the Suwannee River Gulf sturgeon. Oral paper presented at the I0h Gulf Sturgeon Research and Conservation Workshop, Ocean Springs, MS, 28-30: September 2008.
Sulak (2009). Status of knowledge, recovery progress, and future research directions for the Gulf Sturegeon. Oral paper presented at the 6' International Sturgeon Symposium, Wuhan, China: October 20-25, 2009.
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for Gregory Hogue Regional Environmental Officer cc: Jerry Ziewitz - FWS Brenda Johnson - USGS David Vela - NPS Chester McGhee - BIA OEPC - WASH