ML20079M956

Response to NUMARC Auquatic Resource Questions,Socioeconomic Questions for All Utils & Waste Mgt Questions

ML20079M956
Person / Time
Site:	Pilgrim
Issue date:	11/11/1991
From:	BOSTON EDISON CO.
To:
References
RTR-NUREG-1437 AR, S, WM, NUDOCS 9111110018
Download: ML20079M956 (16)

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62JATIC RESOURIE 00ESTIONS "4 R I M Question 1:

Post-licensing nodifications and/or ch4nges in operations of intake and/or discharge systems may have altered the effects of the power plant on aquatic resources, or it.ay have been made specifically to mitigate impacts that were not anticipated in the design of the plant. Describe any such mod!fications and/or operatio d changes to the condenser rooling water intake and discharge systems since *ie issuance of the Operating License, hsponse

1. In 1973, a fish barrier net was added to the Pilgrin, Nuclear Power Station (PNPS) discharge canal following a gas bubble disease mortality of approximately 43,000 Atlantic menhaden in the canal. In 1976 a sill was installed in the discharge canal to anchor the fish barrier net after the mortality of 5,000 Atlantic menhaden which bypassed the net in 1975.

Since 1976 there have been no further documented gas bubble disease mortalities of fishes which are excluded from the discharge by the barrier net system. The net is required to be in place, at all times, while PNPS is operating.

2. In 1979, an intake sluiceway was installed at PNPS to meet best available technology requirements as requested by the U.S. EPA and Hass. Division of Hater Pollution Control. The intake sluiceway accepts screenwash water from the four vertical traveling water screens, and was designed to

- maximize marine biota survival both in its construction and return of marine life to ambient temperature intake waters. Previously, the discharge sluiceway would transport impinged biota to the discharge canal where survival was Complicated by elevated effluent temperatures.

3. In 1983, the PNPS National Pollutant Discharge Elimination System (NPDES)

Permit approved continuous chlorination of the Station's salt service water system for biofouling control. The source of screenwash water for the traveling water screens is the chlorinated salt service water system bays. A dechlorination system was added for the screer; wash water, at the screenwash pumps, so as not to impact the survival of impinged marine biota.

4. Horseshoe crab intake barriers, consisting of I-beams installed in stop log guides, were designed to address trab biofouling concerns. The crab barriers are installed annually from April through September, and in addition to reducing crab biofouling also serve to mitigate impingement impact on this species.

Question 2:

Summarize and describe (or provide documentation of) any known impacts on aquatic resources (e.g., fish kills, violations of discharge permit conditions) or NPDES enforcement actions that have occurred since issuance of the Operating License. How have these been resolved or changed over time?

(The response to this question should indicate whether impacts are ongoing or were the result of start-up problems that were subsequently resolved.)

Page 1

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6QUATIC RESOUR E OVESTIONS (Cont.)

Bl.liAQDit:

1. On a scale encompassing the more immediate vicinity of PNPS, certain site specific or occasionally occurring effects were documented. Most notable were mortalities due to " gas bubble disease", periodic incidences of finfish impingement on the cooling water intake traveling screens, near-field alterations of the benthic and epibenthic communities in the vicinity of the cooling water discharge, and entrainment of phytoplankton, zooplankton, and ichthyoplankton in the cooling water flow.

In general, there havr been no major disruptions of western Cape Cod Bay ecology as a result of construction and operation of PNPS. However, on a smaller scale adjacent to the plant there have been documented local biotic changes and environmental disruptions.

2. Periodic fish kills of more than 1,000 individuals per incident have occurred at PNPS involving gas bubble disease, impingement or thermal stress. Table i summarizes these occasions which are unpredictable and sporadic in nature. The barrier net and intake sluiceway additions, addressed in response to Question 1, have helped mitigate these impacts on marine biota.

3. The release of large volumes of warmed cooling water at considerable velocity alters the condition and nature of benthic and epibenthic communities on the bottom near the PNPS discharge canal. Near-field benthic com., unity effects of the PHPS cooling water discharge are revealed in a 1000 m " denuded" zone and a more peripheral area of " stunted" algal growth approxima M y 2000 2m . Configuration and extent of the " denuded" zone varies season y and appears attributable to scour in the immediate path of the disc h e9plume, while the more distal " stunted" area appears due primarily to thermal effects of the plume. Figure 1 illustrates the extent of denuded and stunted benthic areas over time and in relation to station operation, as an ongoing impact.

4. Entrainment of phytoplankton, zooplankton, ichthyoplankton and lobster larvae is a continuing impact at PNPS. The ubiquitous nature of phytoplankton and zooplankton makes their entrainment mortality relatively insignificant. Ichthyoplankton entrainment losses to natural fish populations is a very small percentage and very few lobster larvae are entrained. Occasionally, "unusuall/ abundant" entrainments are noted for some fish species as documented in Table 2, but these cases occur infrequently and are monitored closely.

5. There have been only a few A T (>32*F) and chlorine (>0.1 ppm) NPDES Permit violations since PNPS operation commenced in 1972. These have been promptly reported to the U.S. EPA with follow-up documentation in Quarterly Discharge Monitoring Reports (DMRs) as required. In all cases, the discharge limit excursions were investigated and resolved, or station operational characteristics changed to b9 in conformance.

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l 60VALIC RESOURCE OUEST10NjLLCQDid Question 3:

Changes to the NPDES permit Juring operation of the plant could indictte whether water quality parameters were determined to have no significant impacts (and were dropped from monitoring requirements) or were subsequently raised as a water quality issi:e. Provide a brief summary of changes (and when they occurred) to the NPDiS nermit for the plant since issuance of the Operating License.

Resconse:

1. In 1980, the condition to return impinged biota to ambient temperature waters was added to the PNPS NPDES Permit.

2. The intake screenwash effluent was added to the PNPS NPDES Permit as a numbered discharge point in 1980.

3. The PNPS NPDES Permit radwaste system effluent discharge point was excluded from the Permit in 1983 on the condition that radioactive waste discharge shall be in conformance with regulations promulgated by the Nuclear Regulatory Commission,

, 4. In 1983, for the PNPS discharge canal, dissolved nitrogen saturation levels of less than 115% at the surface were required and added to in the NPDES Permit.

5. Continuous chlorination of the PNPS salt service water system was allowed by addition to the NPDES Permit in 1983, at levels not to exceed 0.25 ppm daily average and 0.50 ppm daily maximum prior to mixing with other streams.

6. In 1983, a concition was added to the NPDES Permit requiring annual review and submittal of PNPS marine ecology environmental monitoring programs, which are incorporated as part of the Permit each year.

7. PHPS discharge canal barrier net deployment and maintenance at all times during station operation was made a requirament of the NPDES Permit in 1983.

Question A-An examination of trends in the effects on aquatic resources monitoring can indicate whether impacts have increased, decreased, or remained relatively stable during operation. Describe and summarize (or provide documentation of) results of monitoring of water quality and aquatic biota (e.g., related to NPDES permits, Environmental Technical Specifications, site-specific monitoring required by federal or state agencies). What trends are apparent over time?

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A00ATIC RESOURCE 00ESTIONS (Cont.)

Enp_qnig:

1. In most cases, PNPS studies compare environmental control areas with sampling sites potentially within the influence of the power station (that is, habitats likely to receive warmed cooling waters from the discharge flow), or study ecological community components having either immature stages or adults drawn into the cooling water system and either impinged on traveling screens or forced through the heat exchanger condenser cooling system. Aside from observed results near the power station and readily attributable to its operation, the examination of long term relative abundance indices for fish and invertebrates provide the best means of discerning impacts. Because the amplitude of natural population variation is an unknown for many species, it is not possible to separate wholly, natural variation from possible plant effects in most cases. On balance, however, the term of most studies is long enough to show general natural variation separate from disruptive perturbations attributable to plant operation. Factors such as gear bias, seasonal migrations and natural variability in population densities allow only the general conclusions.

2. Occasional high fish mortalities from impingement, entrainment, thermal stress or gas bubble disease have occurred at PNPS as discussed in the Question 2 response but, for the most part, marine biota impacts have been relatively stable and inconsequential to natural populations in Cape Cod Bay. Attached Tables 3 and 4 provide fisheries and benthic monitoring results for the last several years in the context of PNPS impact on marine biota, which shows no apparent increasing or decreasing trends during station operation.

Question 5:

Summarize types and numbers (or provide documentation) of organisms entrained and impinged by the condenser cooling water system since issuance of the Operating License. Describe any seasonal patterns associated with entrainment and impingement. How has entrainment and impingement changed over time?

Resoonse:

1. Table 5 provides a breakdown of PNPS fish impingement over the years since operation commenced, including the dominant species sampled each year.

The Pilgrim Station impingement rate for all fishes for 1973 to 1980 was 2.39 fish / hour; the total weight of all fishes collected was 660 kg. Five species, Atlantic herring, rainbow smelt, Atlantic silverside, alewife, and cunner, accounted for about 907. of the total impinged from 1976 to 1980.

Since 1981, the numbers of fishes impinged has been less with the overall rate from 1973 to 1989 dropping to 1.96 fish / hour. The composition of the impingement catch has reflected basically the same species during their particular seasons of occut rence.

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&OUATIC RESOURCE OVESTIONS (Cont.)

2, Figures!2 and 3 give a overview of dominant ichthyoplankton species entreinment by egg and larvae stage, respectively. Both seasonality and density ranges of eggs and larvae are presented for each species from 1975 to 1988, with 1989 represented individually. Phytoplankton and zo(nlankton entrainment monitoring were terminated in 1975 as the regulators felt impact was negligible on the natural populations of these blots. Lobster larval entrainment is still monitored although very few have been re:orded in samples. Both impingement and entrainment have been fairly consistent over time as regards species composition and numbers, with infrequent incidents being noted as addressed in the Question 2 response.

Question 6:

Aquatic habitat enhancement or restorat W efforts (e.g., anadromous fish runs) during operation may have enhancec % biological communities in the vicinity of the plant. Alternatively, deg.adation of habitat or water quality may have resulted in loss of biological resources near the site. Describe any changes to aquatic habitats (both enhancement and degradation) in the vicinity of the power piant since the issuance of the Operating License including those that-may have resulted in different plant impacts than those iMtially predicted.

Resoonse:

1. The breakwater system constructed around PNPS enhances the marine habitat in an othecwise open coastal region by creating niches for marine biota among the tip rap. Marine flora inhabits breakwater areas which also attract fish and invertebrate species.

2. The effluent current emanating from tge discharge canal has created a denuded area of approximately 1,000 m imttediately off its terminus. This has resulted in a relatively small loss of marine habitat for resident flora, invertebrates and fishes.

Ouestion 7:

Plant operations may have had positive, negative, or no impact on the use of aquatic resources by others. Harvest by commerical or recreational fishermen may be constrained by plant operation. Alternatively commercial harvesting may be relatively large compared with fish losses causen by the plant.

Describe (or provide documentation for) other nearby uses of waters affected by cooling water systems (e.g., swimming, boating, annual harvest by commercial and recreational fisheries) and how these impacts have changed since issuance of the Operating License.

Resoonse:

1. There are commercial fisheries in Cape Cod Bay for both groundfish (i.e.,

flounder) and pelagic fish (i.e., herring) beyond the influence of PNPS operation. Harvest rate for these fisheries has not been affected by plant operation.

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A00ATIC RESOURCE OVESTIONS (Cont.)

2. PNPS appears to have a displacement affect on the American lobster in the thermal plume area (near-field). However, commercial harvest of lobsters in the western Cape Cod Bay area does not appear to be impacted.

3. The PNPS discharge effluent has impacted the Irish moss in an area of approximately 1,000-2,000 m 2 immediately off the discharge canal. This is the result of habitat loss because of discharge current scouring and thermal influence. The Irish moss is commercially harvested in the Station environs.

4. A shorefront visitors' area was established which provides open coast access for sportfishermen who harvest various fishes from the Station intake and discharge. Table 6 provides creel survey data for the PNPS shorefront area. The sportfishery is valued at approximately $40,000 per year based on fisherman trips. The shorefront also hosts several thousand tourists annually and has a nature trail for their recreational use.

5. Commercial lobstermen are allowed to launch their boats on a daily basis from the PNPS intake embayment. This is a valuable usage for them as sheltered boat ramps are not available in the Station area.

Question 8:

Describe other sources of impacts on aquatic resources (e.g., industrial discharges, other power plants, agricultural runoff) that could contribute to cumulative impacts. What are the relative contributions by percent of these sources, including the contributions due to the power plant, to overall water quality degradation and losses of aquatic biota?

Resoonse:

PNPS is an open coastal power plant on Cape Cod Bay in an area of the highest possible classificacion for State water quality standards. Impacts of PNPS on marine resources, as previously discussed, are isolated from any other impact sources that could contribute to cumulative impacts on water qualtty or marine biota.

Question 9:

Provide a copy of your Section 316(a) and (b) Demonstration Report required by the Clean Waste Act. What Section 316(a) and (b) determinations have been made by the regulatory authorities? m Res oonLq:

1. The PNPS Section 316 Demonstration Report (1975) and Supplement (1977) are attached.

2. NPDES Permit adjudicatory hearings on Section 316 determinations for PNPS were held in 19TI. The U.S. EPA, Region I, and Mass. Division of Water Control granted v emptions for the "once-through" cooling system and intake structure at PNPS in that they do not threaten the protection and propogation of shellfish, fish and wildlife populations in receiving waters of Cape Cod Bay.

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SOCIOECONOMIC OUESTIONS FOR ALL UTILITIES Cuestion 1:

To understand the importance of the plant and the degree of its socioeconomic impacts on the local region, estimate the number of permanent workers on-site for the most recent year for which data are available.

Response

As of June 25, 1990, there were 731 permanent workers at Pilgrim Station.

Question 2:

To understand the importance of the plant to the local region, and how that has changed over time, estimate the average number of permanent workers on site, in five-year increments starting with the issuance of the plant's Operating License. If possible, provide this information for each unit at a plant site.

Response

Data-is not available for 1972 through 1974. The available data for the remaining years includes the entire Nuclear Organization, although a variable proportion of those personnel usually worked at locations off-site. The estimated averages for the Nuclear Organization are as follows:

1975-79 220 1980-84 405 1985-89 700 QL_' tion 3:

To unue. stand the potential impact of continued operation for an additional 20 years beyond the original licensing term, please provide for the following three cases:

a) a typical planned outage; b) an ISI outage; and c) the largest single-outage (in terms of the number of workers involved) that has occurred to date, an estimate of additional workers involved (for the entire outage and for each principal task), length of outage, months-and . 7ar in which work occurred, and costs. Also, estimate occupational doses received by permanent and temporary workers during each principal task.

Resoonse:

Not applicable, as we do not have plans for license renewal at this time.

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4 SOCIOECONOMIC OVESTIONS (Cont.)

Ouestion_4:

To understand the plant's fiscal importance to specific jurisdictions, for 1930, 1985, and the latest year for which data are available, estimate the entire plant's taxable assessed value and the amount of taxes paid to the state and to each local taxing jurisdiction.

Resconse:

Taxes paid to and assessed value by the Town of Plymouth are:

Town of Plymouth, assessed valuation for Pilgrim Nuclear Power Station YgAI Assessment 1980 $295,647,000 1985 $321,210,000 1989 $581,898,000 1990 $763,797,000 Property taxes paid by Boston Edison to the Town of Plymouth (see attached graph for additional information):

lair Taxes Paid 1980 $6,460,000 1985 $7,709,000 1989 $8,589,000 1990 $9,531,000 Page 2

TAXES PAID BY BOSTON EDISON TO THE TOWN OF PLYMOUTH 1

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- Years 0 TaxesTown N TAXESBOSTCtJEDISCri I

y"TE MANAGEHfNT QULSIERS A. SPENT FUEL @ESTIONS:

Question 1:

Which of the following current techniques for at-reactor storage are you using and how?

A. Re-racking of spent fuel.

B. Above ground dry storage.

C. Longer fuel burnup. p D. Other (please identify).

Resoonta:

Re-racking of spent fuel and longer fuel burrup. There are presently 1320 fuel assemblies in the spent fuel pool. The station is licensed to store 2320 spent fuel assemblies.

Question 2:

Do you plan on continuing the use of these tyrrent techniques for at-reactor storage of spent fuel during the remaining time of your operating license or do you expect to change or modify them in some way?

ResDonse:

He plan on continuing the use of current teenaiques, coupled with a future change to the present capacity limitation of fuel assemblies stored in the spent fuel pool.

Question 3:

~

Which of the following techniques for at-reactor storage do you anticioate using until off-site spent fuel storage becomes available and how?

A. Re-racking of spent fuel.

B. Above ground dry storage.

C. Longer fuel burnup.

D. Other (please identify).

Resoonse:

He currently anticipate using option A, re-racking of spent fuel, and option C,-longer fuel burnup, until off-site spent fuel storage becomes available.

Question 4:

Will the techniques described above be adequate for continued at-reactor storage of spent fuel for the operating lifetime of the plant, including a 20-year period of license renewal, or are you developing other plans?

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t HASTE 'c: MENT OUESTIONS (Cont.)

Resoonse:

Re-racking coupled with increased capacity of spent fuel storage, plus longer fuel burnup will accommodate storage needs for the present operating life of the plant. Regarding future storage needs, we do not have plcns for license renewal at this time.

Question 5:

Do you anticipate the need to acquire additional land for the storage of spent-fuel for the operating lifetime of the plant, including a 20-year period of license rer.ewal? If so, how much laiid? When would thic acquisition occur? Hnere? (If answer is "yes", 3-4 sentences)

Response. .

Not applicable, see response to question 4.

Question 6:

Do you anticipate any ittIditional construction activity on-site, or immediately adjacent to the power plant site, associated with the continued at-reactor storage of spent fuel for the operating lifetime of the plant, including a 20-year period of license renewal? (yes/no)

Resoonse:

Not applicable, see response to question 4.

Question 7:

If you answered yes to question 6, bricfly describe this construction l activity (e.g., expansion of fuel storage pool, building above ground dry storage facilities).

Resoonse:

Not applicable.

B. LOH-LEVEL RADI0 ACTIVE MANAGEMENT QUESTIONS:

Ouestion 1:

Under the current scheme for LLRH disposal (i.e. LLRH Policy Amendments Act of 1985 and regional compacts) is there currently or will sufficient capacity for wastes generated during the license renewal pericd be available to your plant (s)? If so, what is the basis for this conclusion?

Resoonse:

Not applicable, we do not have pl6ns for lir.ense renewal at this time.

Page 2

tBSTE MANAGBENT 00ESIIONS (Cont.)

Question 2:

If for any reason your plant (s) is/are denied access to a licensed ,

disposal site for a short period of time, what plans do you have for continued LLRH disposal?

Resconse:

To date, the state of Massachusetts has met each of the 1985 LLRH Policy Amendment Act milestones. Although the State will not have a low-level radioactive waste disposal facility in operation by the January 1993 milestone, a schedule has been developed to have a disposal facility operational by September 30, 1995, if the State Low-Level Radioactive Haste Management Board determines such a facility is needed.

However, because the law allows the three states currently providing disposal to restrict access to their facilities after January 1, 1993 Massachusetts has developed an interim plan for the years 1993-1995. The interim plan is comprised of three components. These are:

• Contracting for cut of state disposal

• On-site storage by all generators

• On-site storage for major generators; ano interim centralized storage facility for certain small generators The state agencies responsible for low-level radioactive waste management are developing the necessary regulations for the 1993 '.995 Interim Plan, and the long-term management plan regarding a permanent disposal facility.

Question 3:

In a couple of pages, please describe the specific methods of LLRH management currently utilized by your plant. What percentage of your current LLRH (by volume) is managed by:

A. Haste compaction?

B. Haste segregation (through special controls or segregation at radiation check point)?

C. Decontamination of wastes?

D. Sorting of waste prior to shipment?

C. Other (please identify)

Resconse:

A. Haste compaction: 25%

B. Haste segregation: 0%

C. Decontamination of wastes: 25%

D. Sorting of waste prior to shipment: 100%

E. Other - offsite incineration: 25%

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~. - -. . . . -.- --

MASTE MANAGEMENT 00ESlIONS (Coatd Question 4:

In a couple of_pages, please describe the anticioated plans for LLRH management to be utilized by your plant (s) during the remainaer of the operating license and through the license renewal term. What percentage of your anticioated waste (by volume) will be managed by:

A. Haste compaction?

B. Haste segregation (through special controls or segregation at radiation check points)?

C. Decontamination of wastes?

D. Sorting of waste prior to shipment?

E. Other (please identify)

Resoonse:

Our anticipated plans for LLRH management during the remainder of the operating license include:

A. Haste compaction: 10%

B. Haste segregation: 0%

C. Decontamination of wastes: 25%

0. Sorting of waste prior to shipment: 100%

E. Other - offsite incineration: 40%

Question 5:

Do you anticipate the need to acquire additional land for the storage of ,

LLRH for the operating lifetime of the plant, including a 20-year period of license renewal? If so, how much land? When would this acquisition occur? Where? (If answer is "yes", 3-4 sentences)

Resoonse:

No additional land is anticipated for the storage of LLRH for the operating lifetime of the plant.

Regarding future storage needs, we do not have plans for license renewal at this time.

Question 6:

To provide information on the timing of future low-level waste streams, if you answered yes to question 9, over what periods of time are these activities contemplated?

Resoonse:

Not applicable see response to question 9.

Page 4

MASTE MANAGEMENT 00ESTIONS (Coald Ouestion 7:

Do you anticipate any additional conitryttion' activity, on-site, or immediately adjacent to the power plant site, associated with temporary LLRH. storage for the operating lifetime of the plant, including a 20-year period of license renewal? (yes/no)

Response

les (with respect to LLRH storage for the operating lifetime of the olant).

Question 8:

If you answered yes to question 7, briefly describe this construction ,

activity (e.g., storage areas for steam generator components or other  !

materials exposed to reactor environment).

Resoonse:

He anticipate the construction of a temporary on-site storage container (OSSC) facility for interim low-level waste storage until the Commonwealth of Hassachusetts finalizes its plans for a permanent LLRH facility. (See response to question 2).

Question 9:

To provide information on future low-level waste streams which may effect workforce levels, exposure, and waste compact planning, do you anticipate any major plant modifications or refurbishment that are likely to generate unusual volumes of low-level radioactive waste prior to, or during, tne relicensing period for the plant? If so, please describe these

-activities. Also -what types of modifications do you anticipate to be

-necessary to achieve license renewal operation through a 20-year license renewal term?

Resoonse:

He do not have plans for license renewal at this time.

C. MIXED LOH-LEVEL RADI0 ACTIVE HASTE QUESTIONS Ouestion 1:

This question was deleted by NUHARC clarification letter, dated 6/15/90.

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