ML15138A081

Comment (2) of Nathan Grider on NRC-2013-0169-0014, Exelon Generation Company, LLC; Braidwood Station, Units 1 and 2; Draft Supplemental Generic Environmental Impact Statement

ML15138A081
Person / Time
Site:	Braidwood
Issue date:	05/12/2015
From:	Grider N State of IL, Dept of Natural Resources
To:	Cindy Bladey Division of Administrative Services
References
80FR15824 00002, NRC-2013-0169
Download: ML15138A081 (5)

Text

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5j 10: ~3 PUBLIC SUBMISSION As of: 5/13/15 10:32 AM Received: May 12, 2015 Status: PendingPost Tracking No. ljz-8it7-y6yq Comments Due: May 12, 2015 Submission Type: Web Docket: NRC-2013-0169 Notice of Intent to Prepare an Environmental Impact Statement Comment On: NRC-2013-0169-0014 Exelon Generation Company, LLC; Braidwood Station, Units 1 and 2; Draft Supplemental Generic Environmental Impact Statement Document: NRC-2013-0169-DRAFT-00 13 Comment on FR Doc # 2015-06878 Submitter Information Name: Nathan Grider

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One Natural Resources Way Springfield, IL, 62702 Email: nathan.grider@illinois.gov General Comment Comments from IDNR on the Braidwood Station, Supplemental Generic Rnvironmental Impact Statement Attachments Braidwood license Renewal, EIS, IDNR Comments SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 Add-https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=0900006481 adca86&for...

05/13/2015

Ai Illinois Department of Natural Resources Bruce Rauner. Governor One Natural Resources Way Springfield. Illinois 62702-1271 Wayne A. Rosenthal. Director

.NATURAL wxv.dnr.illinois.gov RESOURCES May 12, 2015 Cindy Bladey, Chief Rules, Announcements, and Directives Branch (RADB)

Office of Administration Mail Stop: OWFN-12-H08 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Braidwood Station License Renewal Generic Environmental Impact Statement Docket ID: NRC-2013-0169

Dear Ms. Bladey:

The Illinois Department of Natural Resources (Department) has reviewed the above-mentioned Document regarding the license renewal of the Braidwood Station owned by Exelon Generation Company, LLC.

The Department is concerned about impingement and entrainment of state-listed species, which can occur when makeup water is drawn from the Kankakee River into the cooling pond or from the cooling pond into the Braidwood station. The Department has no record of Incidental Take Authorization (ITA) being granted to the Braidwood facility for state-listed species suffering mortality as a result of impingement and entrainment. Currently, Exelon Generation Company, LLC. may be at risk of penalties under the Illinois Endangered Species Protection Act [520 ILCS 10/11]. The document clearly indicates that "take" has and likely is still occurring for the state-endangered pallid shiner (Hybopsis amnnis) and state-threatened river redhorse (Moxostoma carinatum), and likely for other state-listed species as described in the following comments:

Fishes Three impingement studies have been conducted at the Kankakee River intake: Commonwealth Edison Company conducted a study during 1980 through 1981, EA Engineering during1 988 through 1989, and again during 1991. Based on these studies, the state-endangered pallid shiner and state-threatened river redhorse were being impinged at the Kankakee River intake.

Impingement (and possibly entrainment) is likely ongoing based on recent records near the Kankakee River intake for pallid shiner (2013) and river redhorse (2014).

Larvae of pallid shiner and river redhorse may also be entrained. The Department notes from page 4-56 that entrained pallid shiner larvae may have been collected, but misidentified as cyprinids. It is unclear from the document if river redhorse larvae are being entrained.

4 Mentioned on page 4-47 is:

"However, in its Kankakee River Area Assessment, the IDNR (1998) indicates that the pallid shiner is "'on the verge of extinction " in Illinois and that the Kankakee River population is the only large population remaining in the state. Based on this information, any losses of pallid shiner to impingement at Braidwood could result in a decreased ability for the Illinois population to survive and reproduce. "

Further, page 4-48 explains potential impacts to the river redhorse as:

"If the [river redhorse] species' status changes during the proposed license renewal term, impingement at Braidwood could contribute more significantly to endangering the Illinois population's continued existence.

Catosomids (sucker family, including redhorse spp.) appear to have decreased alarmingly from the 1980's to present in monitoring samples taken in the vicinity of the Braidwood intake and discharge (pages 3-58 & 3-62). The Department has not observed a similar decline in other parts of the Kankakee River. The Braidwood station came online in the late 1980's and the decline in catostomids could be correlated to impingement, entrainment, and thermal discharge from the facility. The Department recommends this issue be investigated further and mitigation measures adopted if correlations exist to the facilities operations.

No entrainment or impingement studies have been conducted at the cooling pond intake (page 4-40). Older records exist in the cooling pond for pallid shiner (1989) and river redhorse (1999).

However, according to the Department's Fisheries Division, these species have not been collected during routine samples of the cooling pond in recent years. These species may have been impinged or entrained in the past and some risk may still exist as individuals are entrained from the Kankakee River intake and established in the cooling pond.

Older records for western sand darter (1992, Ammoctypta claruim) also exist in the project area.

An ITA was secured for this species in 2009 when Braidwood installed a discharge diffuser in the Kankakee River. Some risk of mortality may exist for this species as a result of entrainment and impingement. Exelon Generation Company, LLC. should evaluate potential impacts to the western sand darter and consider ITA. The Department recommends Exelon Generation Company, LLC. apply for ITA for the pallid shiner and river redhorse for the reasons stated above. Please direct all matters pertaining to ITA to Jenny Skufca (Jenny.Skufca@illinois.gov) with the Department's Office of Resource Conservation.

Additionally, the catadromous American eel (Anguilla rostrate) was recently approved by the Illinois Endangered Species Protection Board to be added as a state-threatened species. This change will take affect once published in the Illinois Register. This species is known to be vulnerable to impingement and entrainment. Exelon Generation Company, LLC. should evaluate potential impacts to this species and consider ITA.

Mussels Recent records exist in the Kankakee River near the intake for the state and federally-endangered sheepnose mussel (2008, Plethobasus cyphytus), as well as state-threatened black sandshell

(2010, Ligumnia recta), spike (2008, Elliptio dilatata), and purple wartyback (2010, Cyclonaias tuberculata). The Department notes that ITA was granted to Exelon Generation Company, LLC.

for these four mussel species in 2009 for the construction of the discharge diffuser in the Kankakee River.

The only known host for sheepnose glochidia is the sauger (Stizostedion canadense). Glochidia hosts for the black sandhell include bluegill (Lepomis macrochirus), largemouth bass (Micropterus salmoides), sauger, and white crappie (Pomoxis annularis). Glochidia hosts for the spike mussel include gizzard shad (Dorosoma cepedianum), flathead catfish (Pylodictis olivaris),

white crappie, black crappie (P. nigromaculatus), and yellow perch (Percaflavescens).

Glochidia hosts for the purple wartyback include channel catfish (Ictahlrus punctatus), yellow bullhead (Aineiurus natalis), flathead catfish, and black bullhead (A. melas).

When comparing the glochidia hosts information to data collected from all three impingement studies (pages 4-40 through 4-50), fishes which serve as glochidia host to black sandshell, spike, and purple wartyback mussels were known to be impinged at the Kankakee River intake. These fishes were also collected in Kankakee River monitoring samples from 2009 through 2013 (pages 3-59 through 3-61) Therefore, individuals of these mussel species are likely being taken as a result of host mortality. It appears no saugers were collected in previous impingement studies or the recent Kankakee River samples. However, due to records of this mussel species in the vicinity, the host fish must also be present and subject to certain impingement risks. The Department recommends Exelon Generation Company, LLC. apply for ITA for the sheepnose, black sandshell, spike, and purple wartyback mussels for the reasons stated above.

Mentioned on page 3-65 is:

"[Mussel] species abundance, however, appears to be lower in the vicinity of Braidwood that? in other regions of the Kankakee River... HDR (2008) indicates that the lower species abundance near Braidwood is likelv the result of unsuitable or marginal habitat. "

The Department is concerned that the lower mussel species abundance, as mentioned above, may be directly correlated to the operation of the Braidwood facility. The Department recommends this issue be investigated further and mitigation measures adopted if correlations exist to the facilities operations.

Amphibians Recent records also occur near the Kankakee River intake for the state-threatened mudpuppy (2012, Necturus maculosus). It unclear if this species is subject to impingement and entrainment risks at the Kankakee River intake. Exelon Generation Company, LLC. should evaluate potential impacts to this species and consider ITA.

The Department looks forward to further coordination on this issue. Please contact me if you have any questions regarding this review.

Nathan Grider Impact Assessment Section 217-785-5500 cc: Jenny Skufca - IDNR, ORC Shawn Cirton - USFWS Elizabeth Poole - USEPA