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

41Page 1 of 1HUES i.4 CT11 ESF -f,, 5j 10: ~3PUBLIC SUBMISSION As of: 5/13/15 10:32 AMReceived:

May 12, 2015Status: PendingPost Tracking No. ljz-8it7-y6yq Comments Due: May 12, 2015Submission Type: WebDocket: 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 GenericEnvironmental Impact Statement Document:

NRC-2013-0169-DRAFT-00 13Comment on FR Doc # 2015-06878 Submitter Information Name: Nathan Grider /& /7Address:One Natural Resources WaySpringfield, IL, 62702Email: nathan.grider@illinois.gov General CommentComments from IDNR on the Braidwood

Station, Supplemental Generic Rnvironmental Impact Statement Attachments Braidwood license Renewal, EIS, IDNR CommentsSUNSI Review CompleteTemplate

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05/13/2015 AiIllinois Department ofNatural Resources Bruce Rauner. GovernorOne Natural Resources Way Springfield.

Illinois 62702-1271 Wayne A. Rosenthal.

Director.NATURAL wxv.dnr.illinois.gov RESOURCES May 12, 2015Cindy Bladey, ChiefRules, Announcements, and Directives Branch (RADB)Office of Administration Mail Stop: OWFN- 12-H08U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Braidwood Station License RenewalGeneric 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, whichcan occur when makeup water is drawn from the Kankakee River into the cooling pond or fromthe cooling pond into the Braidwood station.

The Department has no record of Incidental TakeAuthorization (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 ILCS10/11]. 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:

FishesThree impingement studies have been conducted at the Kankakee River intake: Commonwealth Edison Company conducted a study during 1980 through 1981, EA Engineering during1 988through 1989, and again during 1991. Based on these studies, the state-endangered pallid shinerand state-threatened river redhorse were being impinged at the Kankakee River intake.Impingement (and possibly entrainment) is likely ongoing based on recent records near theKankakee River intake for pallid shiner (2013) and river redhorse (2014).Larvae of pallid shiner and river redhorse may also be entrained.

The Department notes frompage 4-56 that entrained pallid shiner larvae may have been collected, but misidentified ascyprinids.

It is unclear from the document if river redhorse larvae are being entrained.

4Mentioned on page 4-47 is:"However, in its Kankakee River Area Assessment, the IDNR (1998) indicates that the pallidshiner is "'on the verge of extinction

" in Illinois and that the Kankakee River population is theonly large population remaining in the state. Based on this information, any losses of pallidshiner to impingement at Braidwood could result in a decreased ability for the Illinoispopulation 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 Illinoispopulation's continued existence.

Catosomids (sucker family, including redhorse spp.) appear to have decreased alarmingly fromthe 1980's to present in monitoring samples taken in the vicinity of the Braidwood intake anddischarge (pages 3-58 & 3-62). The Department has not observed a similar decline in other partsof the Kankakee River. The Braidwood station came online in the late 1980's and the decline incatostomids could be correlated to impingement, entrainment, and thermal discharge from thefacility.

The Department recommends this issue be investigated further and mitigation measuresadopted 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 beencollected during routine samples of the cooling pond in recent years. These species may havebeen 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 inthe 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 thewestern 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 statedabove. 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 theIllinois Endangered Species Protection Board to be added as a state-threatened species.

Thischange will take affect once published in the Illinois Register.

This species is known to bevulnerable to impingement and entrainment.

Exelon Generation

Company, LLC. should evaluatepotential impacts to this species and consider ITA.MusselsRecent 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 theKankakee 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 thespike 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),

yellowbullhead (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. Thesefishes 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 takenas 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 inthe vicinity, the host fish must also be present and subject to certain impingement risks. TheDepartment 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? inother 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, maybe 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 thefacilities 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 youhave any questions regarding this review.Nathan GriderImpact Assessment Section217-785-5500 cc: Jenny Skufca -IDNR, ORCShawn Cirton -USFWSElizabeth Poole -USEPA