ML071450153

Responses A68 - A69 and A71 - A75 to Additional Information Needs Identified During Audit of NRC Request for Additional Information Related to License Renewal Application

ML071450153
Person / Time
Site:	Wolf Creek
Issue date:	05/09/2007
From:	Garrett T J Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 07-0018
Download: ML071450153 (260)

Text

A68 DOCUMENT CONTROL NUMBER WCEM-06-001 Document Control Revision 0 WOLF CREEK GENERATING STATION WATERFOWL DISEASE CONTIGENCY PLAN REV. 05/01 APPROVED: Supervisor'Environmenta Date RELEASE DATE: (PIX1o l Page 1 of I Waterfowl Disease Contingency Plan The heated condition of Coffey County Lake (CCL) may enhance the potential for development of waterfowl disease pathogens (Final Environmental Statement

-Operating License Stage, NUREG 0878). This contingency plan is to provide guidance to mitigate or control any epidemic waterfowl disease outbreak attributable to the operation of Wolf Creek Generating Station (WCGS) in accordance with the Environmental Protection Plan, Section 2.2 (d). In the event of a serious disease problem, actions specified in Section 6.1 of the FES-OLS will be initiated as required.Bird mortality around CCL will be investigated by WCGS Environmental personnel to determine necessary actions. Several of the carcasses observed will be collected and returned to the lab. If only a few birds are found, attempts will be made to determine the cause of death.If results of this autopsy show evidence of disease or if there are numerous dead birds discovered, the following steps shall be taken: 1. Immediate notification, following disease problem identification, will be made to the U.S.Fish and Wildlife Service or the Kansas Department of Wildlife and Parks in the following order until one is contacted:

(1) Contaminant Specialist, USFWS Manhattan, KS (785)539-3474 (2) Flinthills National Wildlife Refuge, USFWS Hartford, KS (620) 392-5553 (3) Kansas Department of Wildlife and Parks New Strawn, KS (620) 364-2522 (4) Kansas Department of Wildlife and Parks Pratt Headquarters Pratt, KS (620) 672-5911 2. Information needed prior to notification includes location, species, number of dead birds involved, estimated population in the area, date problem observed, and suspected cause of death.3. If determined to be necessary after notification, WCGS Environmental personnel will assist appropriate Wildlife Agency personnel in collecting, preparing, preserving, and transmitting waterfowl specimens for further analyses.4. If epidemic waterfowl disease problems are verified, WCGS Environmental personnel will conduct, assist, and/or escort appropriate Wildlife Agency personnel in mitigating any confirmed disease outbreaks attributable to station operation.

This may include, but not be limited to, waterfowl dispersal on the cooling lake in close proximity to WCGS.

A69 Hooper Diane M f "-.- I From: Haines Daniel E Sent: Wednesday, May 09, 2007 2:10 PM To: Hooper Diane M

Subject:

Seepage data sheets Diane, For references purposes, the quarterly seepage data sheets for the weir at the base of the Main Dam (Surveillance Form H) are from WCNOC 55, Periodic Surveillance Inspections for Main Dam and Non-safety Related Water Control Structures, per Specification Number C-403.Thanks Dan I Page 35 SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Year 2002 Quarter I st I Weir Location and Stationing:

Coordinates:

N82839.25/E100448.25 Toe of Main Dam Station 56 + 96.354 feet Right 2 Date 3/28/02 3 Tim 1400 e: 4 Weather Conditions:

Clear. No precipitation 5 Recent Precipitation:

0.19 on 3/9/02, 0.2 "on 3/10/02 and, 0.12 "on 3/17/02 6 Staff Gage Reading at Weir: H (feet) =0.06 7 Computed Discharge at Weir: (CFS) = 1.25H 2.= <0.01 CFS 8 Clarity of Discharge at Water (clear or turbid): Clear 9 Comment Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.s: EXAMINERDan Haines DATE: 3/28/02 Sheet I of I Specification C-403 43'5 Attachment to RP 02-0075 SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Page 35 Year_2002:3'3 N Quarter 2nd 1. Weir Location and Stationing:

Coordinates:

N82839.25/E100448.25 Toe of Main Dam Station 56 + 96.354 feet Right 2. Date: 6128/02 3.4.Time: 1430 Weather Conditions:

Clear. No precipitation

5. Recent Precipitation:

0. 15 on 6/12, 0.02 on 6/15, 0.07 on 6/16, and 0. 13 and 6/28/02.6. Staff Gage Reading at Weir. H (feet) =0.07 7... Computed Discharge at Weir: (CFS) = 1.25H 2.5 = <0.01 CFS 8. Clarity of Discharge at Water (clear or turbid): Clear 9. Comments: Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER Dan Haines DATE: 6/28/02 Sheet 1 of 1 Specification C-403 Enclosure to RA 02-0042 SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Page 35 Year 2002 Quarter 3rd I Weir Location and Stationing:

Coordinates:

N82839.25/EI00448.25 Toe of Main Dam Station 56 + 96.354 feet Right 2 Date 9/17/02 3 Tim 1500 e: 4 Weather Conditions:

Clear. No precipitation 5 Recent Precipitation:

0.01" on 9/11, 0.01" on 9/12, 0.06" on 9/13, 0.07" on 9/14, 0.08" on 9/15, 0.18" on 9/16, and 0.17" on 9/17. No runoff was observed.6 Staff Gage Reading at Weir: H (feet) =0.04 7 Computed Discharge at Weir: (CFS) = 1.25H 2.5= <0.01 CFS 8 Clarity of Discharge at Water (clear or turbid): Clear 9 Comment Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.s: EXAMINER Dan Haines DATE: 9/17/02 Sheet I of I SURVEILLANCE FORM H Year 2002 DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Quarter 4th Weir Location and Stationing:

Coordinates:

N82839.25/E 00448.25 Toe of Main Dam Station 56 + 96.354 feet Right 2 Date 12/26/02 3 Tim 1205 e: 4 Weather Conditions:

Cloud cover, no recent rain.5 Recent Precipitation:

Trace on 12/17/02.6 Staff Gage Reading at Weir: H (feet) = None (frozen), Ice level at 0.08 7 Computed Discharge at Weir: 0 (CFS) = 1.25H 2.5 (CFS) = less than 0.01 (based on ice level)8 Clarity of Discharge at Water (clear or turbid): Clear (mostly frozen)9 Comment Weir pool frozen. No flow observed.

Ice level read on weir staff.s: EXAMINER Dan Haines DATE: 12/26/02 Page 35 SURVEILLANCE FORM 1-1 DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL I Weir Location and Stationing:

Coordinates:

N82839.25/E 100448.25 Year 2003 Quarter I " Toe of Main Dam Station 56 + 96.354 feet Right 2 Date 3/28/03 3 Tim 1600 e: 4 Weather Conditions:

No rain during inspection.

5 Recent Precipitation:

2.74" on 3/17, 0.4" on 3/18, 0. " on 3/19, 0.1" on 3/25, .01" on 3/25, 0.1" on 3/26, 0.1" on 3/27, and 0.1" on 3/28 recorded from Met Tower.6 Staff Gage Reading at Weir: H (feet) =0.04 7 Computed Discharge at Weir: (CFS) = 1.25H 2.5 <0.01 CFS 8 Clarity of Discharge at Water (clear or turbid): Clear 9 Comment Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.s: EXAMINER Dan Haines DATE: 3/28/03 Sheet I of I SURVEILLANCE FORM 1-1 DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Weir Location and Stationing:

Coordinates:

N82839.25/E100448.25 Toe of Main Dam Station 56 + 96.354 feet Right Page 35 Year 2003 Quarter 2nd 2 Date 6/20/03 3 Tim 1300 e: 4 Weather Conditions:

No rain during inspection.

5 Recent Precipitation:

0.05" on 6/5, 0.02" on 6/11, and 0.03" on 6/12/03, recorded from Met Tower.6 Staff Gage Reading at Weir: H (feet) =0.06 7 Computed Discharge at Weir: (CFS) = 1.25H 2.5= <0.01 CFS 8 Clarity of Discharge at Water (clear or turbid): Clear 9 Comment Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.s: EXAMINER Dan Haines DATE: 6/20/03 Sheet I of I Specification C-403 Page 35 SURVEILLANCE FORM I-1 DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Year 2003 Quarter 3rd I Weir Location and Stationing:

Coordinates:

N82839.25/EI00448.25 Toe of Main Dam Station 56.+ 96.354 feet Right 2 Date 9/23/03 3 Tim 1145 e: 4 Weather Conditions:

No rain during inspection.

5 Recent Precipitation:

0.2" on 9/11, 0.3" on 9/12, 0.3" on 6/13, 0.6" on 9/14, 0.4" on 9/15, 0.1" on 9/19, and 0.1" on 9/21/03 as recorded from Met Tower.6 Staff Gage Reading at Weir: H (feet) =0.07 7 Computed Discharge at Weir: (CFS) = 1.25H 2..= <0.01 CFS 8 Clarity of Discharge at Water (clear or turbid): Clear 9 Comment Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.s: EXAMINER Dan Haines DATE: 9/23/03 Sheet I of I SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Year 2003 Quarter 4th I Weir Location and Stationing:

Coordinates:

N82839.25/E100448.25 Toe of Main Dam Station 56 + 96.354 feet Right 2 Date 12/24/03 3 Tim 1100 e: 4 Weather Conditions:

Clear, no recent rain.5 Recent Precipitation:

0.26" on 12/9, 0.27" on 12/10, 12/11, and 12/12, 0.2" on 12/13, 0.17" on 12/22 and 12/23.6 Staff Gage Reading at Weir: H (feet) = 0.06 7 Computed Discharge at Weir: 0 (CFS) = 1.25H 25 (CFS) = less than 0.01 8 Clarity of Discharge at Water (clear or turbid): Clear 9 Comment Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER Dan Haines DATE: 12/24/03 Sheet I of I Specification C-403 H-il Q)SURVEILLANCE FORM H 4C fiti DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Page 35 Year 2004 Quarter 1st 1. Weir Location and Stationing:

Coordinates:

N82839.25/E100448.25 2.Toe of Main Dam Station 56 + 96.354 feet Right Date: 3/11/04 Time: 0900 Weather Conditions:

No rain during inspection.

Recent Precipitation:

0.6" on 2/29, 0.6" on 3/1, 0.1" on 3/3, 3.6" on 3 /4, and 3.6" on 3/5/04, measured at Met Tower.Staff Gage Reading at Weir: H (feet) =0.17 Computed Discharge at Weir: (CFS) = 1.25H 25= 0.01 CFS Clarity of Discharge at Water (clear or turbid): Clear Comments:

Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER DATE: Dan Haines 3/111/04 Sheet 1 of 1 Specification C-403 Page 35 SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Year 2004 Quarter 2nd 1. Weir Location and Stationing:

Coordinates:

N82839.25/E100448.25 2.3.4.Toe of Main Dam Station 56 + 96.354 feet Right Date: 6/30/04 Time: 1400 Weather Conditions:

No rain during inspection.

Rain threatening.

5. Recent Precipitation:

0.4 inches

on 6/21/04, 0.5 inches on 6/27/04, as measured at John Redmond Dam.6. Staff Gage Reading at Weir: H (feet) =0.09 7. Computed Discharge at Weir: (CFS) = 1.25H 2.5= < 0.01 CFS 8. Clarity of Discharge at Water (clear or turbid): Clear 9. Comments: Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER DATE: Dan Haines 6/30/04 Sheet 1 of 1 Specification C-403 Page 35 SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Year 2004 Quarter 3rd 1. Weir Location and Stationing:

Coordinates:

N82839.25/E100448.25 2.3.4.5.6.7.8.9.Toe of Main Dam Station 56 + 96.354 feet Right Date: 9/16/04 Time: 1430 Weather Conditions:

No rain during inspection.

Recent Precipitation:

0.01 inches on 9/9/04, 0.03 inches on 9/11/04, as measured at John Redmond Dam.Staff Gage Reading at Weir: H (feet) =0.02 Computed Discharge at Weir: (CFS) = 1.25H 2.5 = < 0.01 CFS Clarity of Discharge at Water (clear or turbid): Clear Comments:

Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER DATE: Dan Haines 9/16/04 Sheet 1 of I Specification C-403 SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Year 2004 Quarter 4th 1. Weir Location and Stationing:

Coordinates:

N82839.25/E100448.25 Toe of Main Dam Station 56 + 96.354 feet Right 2. Date: 12/30/04 Time: 1300 Weather Conditions:

Clear, no recent rain per USCOE data at John Redmond Reservoir.

Recent Precipitation:

Staff Gage Reading at Weir: H (feet) = 0.07 Computed Discharge at Weir: 0 (CFS) = 1.25H 2.5 (CFS) = less than 0.01 Clarity of Discharge at Water (clear or turbid): Clear 9. Comments: Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER Dan Haines DATE: 12/30/04 Sheet 1 of 1 Specification C-403 Page 35 SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Year 2005 Quarter 1st 1. Weir Location and Stationing:

Coordinates:

N82839.25/E100448.25 Toe of Main Dam Station 56 + 96.354 feet Right Date: 3/31/05 Time: 1530 Weather Conditions:

No rain during inspection.

Recent Precipitation:

0.35 inches on 3/21/05, 0.54 inches on 3/22/05, as recorded at WCGS Met Tower.Staff Gage Reading at Weir: H (feet) =0.09 Computed Discharge at Weir: (CFS) = 1.25H 2.5 = < 0.01 CFS Clarity of Discharge at Water (clear or turbid): Clear Comments:

Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER DATE: Dan Haines 3/31/05 Sheet 1 of 1 Specification C-403 Page 35 SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Year 2005 Quarter 2nd 1. Weir Location and Stationing:

Coordinates:

N82839.2 5/El 00448.25 Toe of Main Dam Station 56 + 96.354 feet Right Date: 6/29/05 Time: 1000 Weather Conditions:

No rain during inspection.

Recent Precipitation:

1.32on 6/11, 3.12" on 6/12, 1.84" on 6/13, 0.59" on 6/14, 0.13" on 6/16/05, as reported at John Redmond Dam.Staff Gage Reading at Weir: H (feet) =0.11 Computed Discharge at Weir: (CFS) = 1.25H 2.5= < 0.01 CFS Clarity of Discharge at Water (clear or turbid): Clear Comments:

Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER DATE: Dan Haines 6/29/05 Sheet 1 of 1 Specification C-403 SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Page 35 Year 2005 Quarter 3rd 1. Weir Location and Stationing:

Coordinates:

N82839.25/E100448.25 Toe of Main Dam Station 56 + 96.354 feet Right 2. Date: 9/29/05 3.4.5.6.7.8.Time: 1600 Weather Conditions:

No rain during inspection.

Recent Precipitation:

0.01 inches on 9/29/05, as reported at John Redmond Dam.Staff Gage Reading at Weir: H (feet) =0.03 Computed Discharge at Weir: (CFS) = 1.25H 2.5 = < 0.01 CFS Clarity of Discharge at Water (clear or turbid): Clear 9. Comments:

Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER Dan Haines DATE: 9/29/05 Sheet I of 1 Specification C-403 SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Year 2005 Quarter 4th 1. Weir Location and Stationing:

Coordinates:

N82839.2 5/El 00448.25 Toe of Main Dam Station 56 + 96.354 feet Right Date: 12/21/05 Time: 1440 Weather Conditions:

Clear, no recent rain.Recent Precipitation:

None recorded at John Redmond dam for two weeks previous to inspection.

Staff Gage Reading at Weir: H (feet) = 0.04 Computed Discharge at Weir: 0 (CFS) = 1.25H 2.5 (CFS) = less than 0.01 Clarity of Discharge at Water (clear or turbid): Clear 9. Comments: Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER Dan Haines, Terry Berland DATE: 12/21/04 Sheet 1 of 1 Specification C-403 Page 35 SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Year 2006 Quarter 1st 1. Weir Location and Stationing:

Coordinates:

N82839.2 5/El 00448.25 Toe of Main Dam Station 56 + 96.354 feet Right Date: 3/30/06 Time: 1000 Weather Conditions:

No rain during inspection.

Recent Precipitation:

0.01 on 3/18, 0.29 on 3/19, 0.27 on 3/20, 0.28 on 3/21, and 0.01 inches on 3/27/0 6, as reported at John Redmond Dam.Staff Gage Reading at Weir: H (feet) =0.08 Computed Discharge at Weir: (CFS) = 1.25H 2.5= < 0.01 CFS Clarity of Discharge at Water (clear or turbid): Clear Comments:

Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER DATE: Dan Haines 3/30/06 Sheet 1 of 1 Specification C-403 Page 35 SURVEILLANCE FORM H Year 2006 DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Quarter 2nd 1. Weir Location and Stationing:

Coordinates:

N82839.25/E100448.25 2.3.4.5.6.7.8.9.Toe of Main Dam Station 56 + 96.354 feet Right Date: 6/30/06 Time: 1300 Weather Conditions:

No rain during inspection.

Recent Precipitation:

0.6 on 6/17, 0.6 on 6/22, as reported at Met Tower.Staff Gage Reading at Weir: H (feet) =0.04 Computed Discharge at Weir: (CFS) = 1.25H 2.5= < 0.01 CFS Clarity of Discharge at Water (clear or turbid): Clear Comments:

Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER DATE: Dan Haines 6/30/06 Sheet 1 of 1 Specification C-403 Page 35 SURVEILLANCE FORM H DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Year 2006 Quarter 3rd 1. Weir Location and Stationing:

Coordinates:

N82839.2 5/El 00448.25 Toe of Main Dam Station 56 + 96.354 feet Right Date: 9/27/06 Time: 1100 Weather Conditions:

Dry.Recent Precipitation:

0.47 on 9/22/06.Staff Gage Reading at Weir: H (feet) =0.01 Computed Discharge at Weir: (CFS) = 1.25H 2.5 = < 0.01 CFS Clarity of Discharge at Water (clear or turbid): Clear Comments:

Flow is not considered excessive until greater than 0.02 CFS per Spec C-403. Virtually no flow was present on this inpection.

EXAMINER DATE: Dan Haines 9/27/06 Sheet 1 of 1 Specification C-403 SURVEILLANCE FORM H Year 2006 DISCHARGE RATE MEASUREMENTS AT WEIR IN DRAINAGE CHANNEL Quarter 4th 1. Weir Location and Stationing:

Coordinates:

N82839.25/E100448.25 2.3.4.5.6.7.8.9.Toe of Main Dam Station 56 + 96.354 feet Right Date: 12/20/06 Time: 1330 Weather Conditions:

Clear Recent Precipitation:

0.18 on 12/20/06 per John Redmond Corp of Engineers website Staff Gage Reading at Weir: H (feet) = 0.02 Computed Discharge at Weir: 0 (CFS) = 1.25H 2.5 0 (CFS) = <0.01 cfs Clarity of Discharge at Water (clear or turbid): clear Comments:

Flow is not considered excessive until greater than 0.02 CFS per Spec C-403.EXAMINER Dan Haines DATE: 12/20/06 Sheet 1 of 1 Specification C-403 A71 I.H 3]D mr 0 DOCUMENT CONTROL NUMBER WCEM-08-004 DOCUMENT CONTROL REVISION 0 0 0\WOLF CREEK GENERATING STATION FIRING RANGE MANAGEMENT PLAN FOR SOIL LEAD CONTAMINATION Rev. 02/04 APPROVED: Superviso Regulatory Support Date RELEASE DATE:-b'650. t4 Fs 104 February 2004 o Wolf Creek Generating Station Firing Range Management Plan for Soil Lead Contamination 0 Introduction o This plan has been developed to satisfy action item 2 of PIR 2003-0831.

There are currently'no regulatory requirements for the development of any management or usage plans for active firing ranges. There are also no requirements which would apply to dealing with lead bullets deposited in soil at active firing ranges. However, once a firing range hasbeen closed, consideration for clean up of the area is necessary.

Lead contamination of the soil must be considered, and it is possible that lead and lead contaminated soil from the firing range might have to be managed as hazardous waste.Therefore, it is only prudent that some thought be given to the long term management of a firing range, and a plan for managing the environmental considerations should be developed.

Any such plan should take into account the following:

1. how the range is used -types and quantities of ammo, types of targets, types of shooting 2. location and topography of the range with particular attention to storm water runoff 3. where bullets are deposited after firing 4. climatological conditions with particular attention to annual precipitation

5. soil type and conditions

6. area affected by lead deposition After consideration of these issues, a plan should be developed which will minimize further lead contamination of the soil and limit the spread of the lead contamination.

The plan should also address any need to clean up current lead contamination and the recommended frequency of such.Discussion Wolf Creek's firing range has been in use since 1983. From 1983.through 2003, approximately 100,000 rounds of ammunition have been fired at the range each year. If we assume that the average round is a 150 grain lead bullet, it would be reasonable to conclude that more than 21 tons of lead has been deposited in the firing range backstop berms or in the immediate area. Some of the shooting at the range involves firing at steel targets which are placed just to the north of the west part of the berm. As the bullets strike the steel, they fragment to various rn degrees. This fragmentation of the bullets may be the most important factor in 0how much lead soil contamination there is, and it certainly is a factor in how much and how far lead is transported from the firing range area bystorm water runoff. Visual inspections of the area found intact or nearly intact bullets as well as bullet fragments on the ground in the area where the steel targets are situated o for shooting.

Some fragments were found along the storm water runoff flow path 0 to the lake.Advances in bullet technology have resulted in more user- and environment-kil friendly ammunition.

Frangible bullets are now being used by many in law enforcement and the military for at least some training applications.

Frangible-bullets are lead-free and are designed to burst into relatively harmless powder--W like particles upon impacting a hard surface. The composition of frangible bullets can vary, but copper/tin powder frangibles are fairly common. Frangible bulls may be an option for training use at WCGS.Soil samples were taken in September 2003. These samples were analyzed for total lead concentration and Toxicity Characteristic Leaching Procedure (TCLP)lead concentration.

TCLP is the test which would determine if a solid waste is a hazardous waste. A TCLP lead concentration greater than 5 mg/I would require the waste to be managed as a hazardous waste. The results of the soil sample testing are in Table 1. The locations where the soil samples were taken are marked on Attachment

1. The testing shows that, if the soil were to be removed, the soil in the immediate vicinity of the firing range would have to be managed as hazardous waste. While some lead contamination is found in the soil in the storm water runoff path down to the lake (Attachment 2), the concentrations decrease greatly with distance from the firing range proper. Soil pH was also measured in the area, and the results are included in Table 1. In other studies, it has been shown that there is an optimal soil pH range of 7.0-8.5 in which lead particles are not broken down as quickly and therefore the lead is not as mobile in the soil. Testing indicates that the soil pH at the firing range is already in this preferred range.The soil in this area would be classified as a Kenoma silty loam jKb). The typical profile for Kb soils is a fine silty soil with low clay content from the surface down to about 12 inches. Below that, there is a layer with a much higher clay content.The slopes for this type of soil are very moderate (1-3%). Even with the slight slopes, the 37 inches of annual precipitation can cause fairly severe soil erosion especially to the surface layer of soil with its fine silty composition.

Below the surface layer, the higher clay content does not allow for good percolation of water or any water borne materials.

At this time, some surface erosion is evident in the immediate vicinity of the firing range. This can be attributed at least in part to the lack of good ground cover (vegetation) in this area.

H C)0 N)0 W3 Firing Range Soil Testing Results Sample Total Lead Concentration TCLP Lead Concentration Soil Location (mg/I) (mg/l) pH 1 21,400 714.0 7.5 2 138 33.8 8.4 3 6,260 335.0 NT 4 27,500 1560.0 NT 5 10,100 251.0 NT 6 779 54.8 8.1 7 2,110 11.7 NT 8 119 1.1 NT 9 129 0.3 NT 10 235 2.7 NT 11 15.4 N D NT 12 16.5 ND NT 13 22.2 ND NT 14 17.9 ND 8.2 15 33.3 ND NT 16 19.3 ND NT 17 111 0.4 NT 18 26.8 ND NT 19 10.7 ND NT 20 11.2 ND NT ND = not detected, NT = not tested TABLE 1 z I -- Z: o .,- +1 0 0 ZýAttachment 1 J It;Attachment 2-runoff 4-Lake Plans and Recommendations There is no requirement to remove lead that has been deposited in the soil at an active firing range. And, because the lead's deposition in the soil is a result of 0 the bullets being used for their intended purpose, the deposition is not 0 considered waste disposal.

In the present regulatory climate, any removal of lead contaminated soil would result in the generation of extremely large quantities of hazardous waste. While lead recovery/recycling is feasible with this 0 type of material, any such project would involve a considerable cost. The cost of K) separating the lead from the soil would be at least $50/ton <of soil), and there would be additional costs for transportation and reclamation of the recovered lead. It is possible that the regulatory considerations for lead contaminated soil W at firing ranges could change to allow the contaminated soil to not be managed as hazardous waste. As technology advances, it might also be possible that lead recovery/recycling could be less cost prohibitive..

For all of the aforementioned reasons, it is recommended that no removal of lead contaminated soil from the WCGS firing range be conducted so long as the range remains active.It is important to minimize the future deposition of lead at the firing range and limit the area of lead soil contamination.

To that end, there are many things which can be done. One such thing shall be considered mandatory.

Establishing and maintaining good ground cover in the area shall be a priority.Seeding the area with a cool season grass such as tall fescue should be sufficient.

Seeding shall be accomplished with minimal soil disturbance to avoid further spreading of lead contaminated soil from storm water runoff. Periodic monitoring of the area shall be conducted to ensure that good ground cover is established.

Any bare spots or areas where grass has not been established will be reseeded.

The area where this ground cover should be established includes the firing range proper as well as the storm water runoff paths.The following practices and changes should be considered for possible implementation:

1. Control shooting, to the extent possible, so that bullets are fired into the same place(s) and therefore minimize the area where bullets are being deposited in the soil.2. Eliminate use of steel targets and/or 3. Use frangible ammunition when shooting at steel targets and in any other circumstances where it is possible Both the Security organization and the Environmental Management group shall continue to benchmark use and management practices employed at other nuclear power plants' firing ranges as well as those at non-nuclear facilities.

A72 W4FO CREEK'NUCLEAR OPERATING CORPORATION AI 07D-001 RESOURCE MANAGEMENT AND ECOLOGICAL MONITORING PROGRAMS Responsible Manager Manager Regulatory Affairs Revision Number 8 Use Category Reference Administrative Controls Procedure No Management Oversight Evolution No Program Number 07D DC38 8/7/2006 Revision:

8 RESOURCE MANAGEMENT AND ECOLOGICAL AI 07D-001 MONITORING PROGRAMS Reference Use Page 1 of 9 TABLE OF CONTENTS SECTION TITLE PAGE 1.0 PURPOSE 2 2.0 SCOPE ..2

3.0 REFERENCES

AND COMMITMENTS 2 4.0 DEFINITIONS 3 5.0 RESPONSIBILITIES 3 6.0 PROCEDURE 5 7.0 RECORDS 9 8.0 FORMS 9 Revision:

8 RESOURCE MANAGEMENT AND ECOLOGICAL AI 07D-001 MONITORING PROGRAMS Reference Use Page 2 of 9 1.0 PURPOSE 1.1 This procedure defines the intent and format for the Lake and Land Management Programs, and Ecological Monitoring Programs administered by Wolf Creek Nuclear Operating Corporation (WCNOC)personnel.

These programs are designed to meet requirements in the Environmental Protection Plan (EPP).2.0 SCOPE 2.1 This procedure is applicable to Environmental Management personnel responsible for land management activities at WCGS, excluding transmission line right-of-way maintenance.

2.2 This procedure is applicable to Environmental Management personnel responsible for fisheries management activities at WCGS.2.3 This procedure is applicable to Environmental Management personnel responsible for ecological monitoring including, but not limited to zebra mussel monitoring, waterfowl disease contingency plan, avian protection plan, and water quality monitoring.

3.0 REFERENCES

AND COMMITMENTS

3.1 References

3.1.1 APPENDIX

B TO FACILITY OPERATING LICENSE NPF-42, ENVIRONMENTAL PROTECTION PLAN (EPP) (NONRADIOLOGICAL) 3.1.2 WOLF CREEK UPDATED SAFETY ANALYSIS REPORT (USAR)3.1.3 AP 15A-003, RECORDS 3.1.4 AP 26A-003, 10 CFR 50.59 REVIEWS 3.1.5 MEMORANDUM OF UNDERSTANDING (MOU) -OPENING LAKE FOR PUBLIC RECREATION AND FISHING -JUNE 20, 1996 3.1.6 PIR 95-2462, AGRICULTURAL LEASE EXPENSE ACCOUNTING IMPROVEMENT 3.1.7 NRC INFORMATION NOTICE 02-014 EVALUATION 3.1.8 NUREG-0878, FINAL ENVIRONMENTAL STATEMENT RELATED TO THE OPERATION OF WOLF CREEK GENERATING STATION, UNIT NO. 1 (FES-OLS)3.1.9 WOLF CREEK GENERATING STATION ENVIRONMENTAL REPORT-OPERATING LICENSE STAGE (ER-OLS)

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8 RESOURCE MANAGEMENT AND ECOLOGICAL AI 07D-001 MONITORING PROGRAMS Reference Use Page 3 of 9 3.1.10 PIR .2002-3053, VAULTING FARM LEASE AGREEMENTS 3.1.11 Letter 05-00616, dated 11-14-05 from United States Department of the Interior regarding WCGS License Renewal 3.2 Commitments 3.2.1 ET 97-0021, R. A. Muench (WCNOC) To U.S. Nuclear Regulatory Commission (NRC), March 7, 1997 (RCMS #1985-092) 3.2.2 ITIP 02047, NRC INFORMATION NOTICE 92-49: RECENT LOSS OR SEVERE DEGRADATION OF SERVICE WATER SYSTEMS 4.0 DEFINITIONS

4.1 Owner

Controlled Area 4.1.1 Property contiguous to the reactor site and acquired by fee title or easement for Wolf Creek Generating Station for which public access is limited.4.2 Ecological Monitoring

4.2.1 Ecological

monitoring refers to field research or monitoring activities completed to measure environmental impacts in the vicinity of Wolf Creek Generating Station to support licensing requirements.

This definition does not include monitoring required for specific permits such as the Air Operating Permit or NPDES permit.5.0 RESPONSIBILITIES

5.1 Supervisor

Regulatory Support 5.1.1 Directs the revision and implementation of the land management plan, the fishery management plan, the waterfowl disease contingency plan, and ecological monitoring plan(s).5.1.2 Directs the preparation of lease agreements with tenants to implement the land management plan.5.1.3 Directs the preparation of necessary reports which summarize land management activities.

5.1.4 Directs

the preparation of necessary reports which summarize fisheries management activities.

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8 RESOURCE MANAGEMENT AND ECOLOGICAL AI 07D-001 MONITORING PROGRAMS Reference Use Page 4 of 9 5.1.5 5.1.6 5.2 Manager 5.2.1 5.2.2 5.2.3 Administers disposition of income and expenses associated with the land management program.Directs the preparation of the ecological monitoring plan(s).Regulatory Affairs Reviews and approves the land management plan and reports.Reviews and approves the fisheries management plan and reports.Reviews and approves the ecological monitoring plan(s).

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8 RESOURCE MANAGEMENT AND ECOLOGICAL AI 07D-001 MONITORING PROGRAMS Reference Use Page 5 of 9 6.0 PROCEDURE 6.1 Land Management 6.1.1 Land management activities shall attempt to achieve a balance between production and conservation values through the implementation of conservation and wildlife management techniques.

6.1.2 To facilitate proper management of WCGS property, an annual land management plan will be formulated which may include, but is not limited to wildlife habitat enhancement, land improvements, controlled burning, grazing, haying and crop activities, and other conservation measures projected for the applicable year.1. This annual plan will be implemented to the maximum extent possible through agreements with tenant.s farming WCGS lands.2. The land management plan and associated report will be submitted to the Supervisor Regulatory Support and Manager Regulatory Affairs for approval.3. A copy of the land management plan shall be sent to Document Services for incorporation into the WCNOC Environmental Permits and Plans Manual.6.1.3 In accordance with the USAR, all land management activities will prohibit oil or gas exploration, mining and/or drilling on WCGS lands.6.1.4 In accordance with the EPP, land management activities will maintain a minimum of 500 acres of WCGS lands surrounding the cooling lake in naturally occurring biotic communities.

6.1.5 Tenants

and cooperating elevators shall be instructed to transmit income payments to Environmental Management.

6.1.6 Land management income shall be processed and tracked for each tenant and forwarded to the Accounting group by Environmental Management.

6.1.7 Purchase

Orders / Agreement will be used for local agricultural vendors to cover the plant's share of expenses as stated in applicable lease agreements if rent is based on a share of the production (refer to Step 3.1.6).

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8 RESOURCE MANAGEMENT AND ECOLOGICAL AI 07D-001 MONITORING PROGRAMS Reference Use Page 6 of 9 6.1.8 The Supervisor Regulatory Support or designee shall approve all invoices for lease expenses before payments are made. This includes deductions to rents received due to a tenant's improvement of a lease.6.1.9 Lease expenses will be recorded and verified for each tenant to ensure that expenses are legitimate for the crops planted on WCNOC land if rent is based on a share of the production.

6.2 Temporary

Access 6.2.1 Activities on company lands that are not related to the agricultural lease agreements or are not related to normal work activities will be documented with Form AIF 07D-001-01, TEMPORARY LAND USE PERMIT, and approved by the Supervisor Regulatory Support or designee.1. The permittee on the Form AIF 07D-001-01 shall be made aware of the emergency planning information provided to the general public at public access facilities or through handouts.2. A copy of each Form AIF 07D-001-01 should be provided to Security for information purposes.3. In order to facilitate emergency notification, a pager, tone alert radio, or other suitable means of notification will be provided to the permittee.

6.3 Agricultural

Tenants 6.3.1 Agricultural tenants will be informed of emergency plan evacuation expectations while on company lands.1. Evacuation expectations will follow, to the extent possible, the information provided to the public at the local recreational areas.2. A pager, tone alert radio, or other suitable means of notification will be provided to the agricultural tenants leasing WCNOC managed lands that are within the Owner Controlled Area.3. Environmental Management will provide emergency information to the tenants within lease agreements, mailings or other suitable means of notifications.

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8 RESOURCE MANAGEMENT AND ECOLOGICAL AI 07D-001 MONITORING PROGRAMS Reference Use Page 7 of 9 6.4 Fisheries and Lake Management 6.4.1 Lake management activities shall optimize lake use, enhance fisheries and improve water quality.6.4.2 To facilitate proper management of Coffey County Lake, an annual fisheries management plan will be formulated which may include, but is not limited to young-of-year gizzard shad changes, adult shad and predator fish population dynamics, angler harvest impacts to the fishery and other similar projects for the applicable year.1. This annual plan will be implemented to the maximum extent possible through agreements with county, state and federal agencies.2. The fisheries management plan and associated report will be submitted to the Supervisor Regulatory Support and Manager Regulatory Affairs for approval.3. A copy of the fisheries management plan shall be sent to Document Services for incorporation into the WCNOC Environmental Permits and Plans Manual.6.4.3 During late summer of each year the growth of aquatic weeds will be surveyed [Commitment Step 3.2.2]. The survey will target three primary areas as follows: 1. Immediately upstream from the Circulating Water Screenhouse.

2. In the vicinity of the Essential Service Water System Screenhouse.

3. The buoyed Owner Controlled Access Boundary approximately one-half mile south of the Circulating Water Screenhouse.

6.4.4 IF the survey indicates that mechanical removal of the aquatic weeds is not deemed necessary based on weed composition, concentration, or area covered, THEN justification will be documented and transmitted to Operations and Maintenance Support.

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8 RESOURCE MANAGEMENT AND ECOLOGICAL AI 07D-001 MONITORING PROGRAMS Reference Use Page 8 of 9 6.4.5 IF the survey indicates that removal of the aquatic weeds may be necessary to prevent excessive weed buildup on the rotating screens, THEN Environmental Management will inform Operations and Maintenance Support of the weed buildup potential and removal needs.6.5 Memorandum of Understanding (MOU)6.5.1 The MOU for opening the lake to public access will be reviewed periodically.

This review may include, but is not limited to fishery management, public access, buoy replacement and any other measures projected for the future (refer to Step 3.1.5) [Commitment Step 3.2.1.].6.6 Ecological Monitoring

6.6.1 Ecological

monitoring or study activities shall attempt to measure impacts from Wolf Creek Generating Station to answer specific environmental questions to support plant operations and licensing (refer to Steps 3.1.1, 3.1.8, and 3.1.9).1. As environmental questions arise a monitoring plan will be developed to guide field data collection activities to answer the operational or licensing needs.2. IF the type of monitoring is ongoing, such as zebra mussel presence or absence monitoring, THEN the plan should be updated annually.3. Reports shall be prepared according to the frequency specified in the applicable monitoring plan.4. The monitoring.plan and associated reports shall be submitted to the Supervisor Regulatory Services and Manager Regulatory Affairs for approval.5. A copy of the ecological monitoring plan shall be sent to Document Services for incorporation in the WCNOC Environmental Permits and Plans Manual.6.7 Waterfowl Disease Contingency Plan 6.7.1 The Waterfowl Disease Contingency Plan shall be updated periodically on an "as needed" basis to provide guidance in the event of a waterfowl disease outbreak at the cooling lake.

Revision:

8 RESOURCE MANAGEMENT AND ECOLOGICAL AT 07D-001 MONITORING PROGRAMS Reference Use Page 9 of 9 1. A copy of the Waterfowl Disease Contingency Plan shall be sent to Document Services for incorporation into the WCNOC Environmental Permits and Plans Manual.6.8 Avian Protection Plan (Reference Step 3.1.11)6.8.1 The Avian Protection Plan shall be updated periodically on an "as needed" basis toprovide guidance in the event of bird electrocutions or collisions events.1. A copy of the Avian Protection Plan shall be sent to Document Services for incorporation into the WCNOC Environmental Permits and Plans Manual.7.0 RECORDS 7.1 The following QA records are generated by this procedure and are vaulted via the Permits and Plans Manual 7.1.1 Fisheries Management Report 7.1.2 The Land Management Plan and Report 7.1.3 The Fisheries Management Plan 7.1.4 The Zebra Mussel Monitoring Plan and Report 7.1.5 The Waterfowl Disease Contingency Plan 7.1.6 The Ecological Monitoring Plan and Report 7.1.7 The Avian Protection Plan 7.2 The following Corporate records are generated by this procedure 7.2.1 AIF 07D-001-01, TEMPORARY LAND USE PERMIT 7.2.2 The Farm Lease Agreements

8.0 FORMS

8.1 AIF 07D-001-01, TEMPORARY LAND USE PERMIT-END -

A73 1 LAND MANAGEMENT AT WOLF CREEK GENERATING STATION 2005 PROGRESS REPORT and 2006 LAND MANAGEMENT PLAN March 2006 Prepared by: Supervisor Regulatory Support Approval: Dan Haines Robert Hammond 3/16/06 Date 3/20/06 Date Manager Regulatory Services Approval: 03/20/06 Date Kevin J. Moles 2 EXECUTIVE

SUMMARY

This document provides a summary of the Wolf Creek Generating Station (WCGS) Land Management Program for 2005 and review of 2006 plans. The Land Management Program is designed to preserve and improve agricultural and natural resources while maintaining rent income. It fosters good relations with agricultural and natural resource agencies and plant neighbors.

Demonstrating proper resource management in an educational setting at the Wolf Creek Environmental Education Area (EEA) is another benefit. Finally, the Land Management Program also meets Wolf Creek's Environmental Protection Plan (EPP) requirements by maintaining a natural buffer strip around the lake and balancing agricultural and conservation values.Rent income from the 2005 crop year ($50,621) was less than in 2004 ($60,714).

This was primarily due to serecia lespedeza control and terrace repair deductions from 2005 lease rents.Conservation practices included controlling rangeland brush, prescribed burning of grassland, and planting wildlife food plots.

3

1.0 INTRODUCTION

This document presents the Wolf Creek Generating Station (WCGS) Land Management Program activities for 2005 and plans for 2006. The Environmental Protection Plan (EPP, Section 4.2.3), Appendix B to the Facility Operating License, requires a land management program that will balance production and conservation values. Procedure Al 07D-001, Resource Management and Ecological Monitoring Programs, specifies that this requirement be met through this report and plan. Beyond regulatory compliance, this report and plan reflect Wolf Creek Nuclear Operating Corporation's (WCNOC) dedication to proper stewardship of the natural resources for which it is responsible.

The Environmental Management Group is responsible for the program described in this plan.The objectives of the Land Management Program are: 1. to conserve and/or improve both agricultural and natural resources;

2. to foster positive relationships with local agricultural and natural resource communities;

3. to enhance, for educational purposes, the natural resources on the EEA;4. to meet license requirements;

5. to maintain rent income at maximum levels while placing the higher priority on the above objectives.

The immediate area around the power block, switchyard and plant support buildings is not part of this program. Vegetation management on the Wolf Creek Lake (WCL) dams is included.

A strip around the WCL shoreline has been maintained in a naturally occurring biotic community to comply with Section 2.2(b) of the EPP. Some land areas have been maintained as wildlife habitat or reserved for educational purposes.

The remainder of the land has been leased for grazing, hay, and crop production.

2.0 RESOURCE

MANAGEMENT This section addresses how the land will be managed to continue to conserve and/or improve both agricultural and natural resources, foster positive relations with local agricultural and natural resource communities, and meet licensing requirements.

The primary focus areas are grassland and cropland management and improvement.

Rent was received from grazing, haying, and crop leases at rates at, or slightly below, average amounts for this area. Grazing rent was charged per animal unit ($12/animal unit/month), while hay and crop lease rents were charged on a per acre basis ($12 and $30/acre, respectively).

The grazing and hay rent amounts have not changed since 1991. Cropland rent amount was set at $30/acre in 1998, with modifications based on growing conditions considered each year.2.1 GRASSLAND Grasslands at WCGS consist of areas leased for grazing, hay production and areas maintained in a natural state for soil conservation, wildlife, and regulatory compliance.

Most areas consist of native tallgrass vegetation common to eastern Kansas. Some areas consist of tame grasses, a shrub/grass mixture, or woodlands.

4 2.1.1 Grazing Approximately 1422 acres of native rangeland were leased for grazing in 2005 to eight tenants (Table 1). Grazing leases in 2006 will be the same as in 2005 and specify maximum grazing animal allotments, grazing rotation programs, and season durations.

By controlling these variables, range quality will be maintained to provide optimum wildlife value and long term rent generation.

Grazing rent totaled $ 13,886 in 2005 (Table 2). Estimated grazing lease income for 2006 is $16,728. Some reductions in rent may occur due to tenant expenses with serecia and brush control Grazing animal allotments expressed as animal units are determined for each lease. An animal unit (nearly always cattle) is one grazing animal weighing greater than 700 pounds and is based on potential grazing needs of a grazing animal of that size. For example, a 500-pound weaned calf is considered

0.8 animal

units, while a cow with calf is considered

1.2 animal

units. Allotted animal units on the leases range from 4.5 to 6.7 acres per animal unit. These rates vary depending on the amount of trees and brush in a pasture, the composition of grasses present, and the grass productivity on each lease. Visual inspections in 2005 were completed to give indications of excessive grazing. More detailed rangeland evaluations for some leases are planned in 2006 (Tables 3 and 4)using methods adapted from Tallgrass Prairie Range Assessment Techniques (Wilk S. A., 1984, Master's Thesis, Emporia State University).

Table 5 shows the results of visual 2005 evaluations.

Two deferred rotational grazing systems will be continued through 2006 to enhance range quality and wildlife habitat. The tenants involved with these systems understand the intent of them and have participated with interest.Grazing rotation will be in the Sharpe Unit 2 and West Units 4 and 5 (Table 1, Figure 1). One-half of each area will be grazed from May 1 through July 15.Tenants will then move their cattle to the other half until the end of the grazing season (October 31). This pattern will be reversed the following season. Fall is when native grasses store root reserves needed for long-term productivity.

Rotational grazing allows the grasses a fall rest every other year. Visual inspections indicate increased native grass production on these leases resulting in increased ground cover and wildlife habitat.The grazing season duration specified for the remaining grazing leases typically extends from May 1 through October 31 of each year. An allowance is provided in most leases for a shorter grazing season from May 1 through July 15 of each year at twice the grazing animal allotment.

This provision allows the tenants an option to tailor their grazing needs to fit their operation while not jeopardizing WCGS grassland quality. Some allowance is provided for grazing of tame cool-season grasses earlier than May 1 of each year. Removal of grazing animals no later than the specified date is monitored each season. Compliance by the tenants has been good in recent years.

5 2.1.2. Haying Approximately 508 acres were leased for hay production in 2005 to 12 tenants.An additional 32 acres (approximately) will be rented in the Main Dam area during the spring of 2006. (Table 6). Hay meadows will be managed to maintain native grass species by requiring hay to be cut by July 31 and bales removed by August 31. To verify continued health of the native grasses meadows, vegetation composition on selected meadows were viewed in 2005, which will continue in 2006 (Table 3 and 4). Methods similar to the rangeland evaluations cited above will be used when practical.

Hay lease rents totaled $5,496 in 2005 (Table 2). The expected amount was$6,516. The received amount was less due to not leasing the Main Dam area, and tenant expense with serecia lespedeza control, and dove habitat management.

The 2006 estimated hay lease income is $6,516.2.1.3 Buffer Zone Management The EPP [Section 2.2 (b)] states that the vegetation within a buffer zone surrounding the cooling lake will be retained in or allowed to develop toward a natural state. The size of this buffer zone is to be 500 acres, as referenced in NUREG-0878 (Section 5.5.1.1, Final Environmental Statement Related to the Operation of Wolf Creek Generating Station, Unit No. 1). In practice, a buffer zone of approximately 1,440 acres surrounding the lake has been and will continue to be managed with native vegetation for wildlife benefits.

These areas are situated to reduce deposition of eroded soil in the lake. Natural habitats in the buffer zone include areas of native grasses, grass/woodland mixes, and mature woodland.

The grassland areas are maintained with periodic controlled burns (Table 7). Forested areas are allowed to develop towards mature woodlands.

Periodic practices, such as mowing and spraying, are completed for native plant enhancement and wildlife benefits.2.1.4 Controlled Burning Spring burning has been used to control brush invasion, control less desirable cool-season grasses or weeds, increase wildlife value, and to enhance prairie vigor and production.

It is a relatively inexpensive and environmentally compatible method of obtaining these objectives.

Native grassland areas will be lost to natural tree and brush growth in the absence of fire.Most grassland units are typically scheduled to be burned once every third year.Dry conditions in some years prompted Coffey County to ban burning, which prevented many planned burns. Consequently, increased prescribed burn frequencies are planned for some grassland areas. A total of 1,997 acres were burned in 2005. During 2006, a total of 2,315 acres are listed for prescribed burning (Table 7).For safety reasons, burns will only be attempted when proper manpower and wind conditions exist. Coffey County and Kansas Department of Health and Environment prescribed burning regulations (KAR 28-19-648) will be followed.

6 These requirements include permit acquisition, notifying local fire control, traffic safety, and airport authorities.

Burns may be canceled if weather conditions do not allow completion primarily during Mid-March through April.2.1.5 Tree and Brush Control Tree and brush control has been necessary to preserve some of the WCGS native grass prairie areas. Herbicide and mechanical removal is planned for selected areas (Table 4). Through natural succession, trees and brush tend to become established in native grass areas and eventually dominate, thus turning the prairie area to woodland.

Frequent burns help prevent this; however, not all areas are burned frequently enough to prevent tree and brush growth. When some trees become large enough, particularly osage orange and honey locust, they are not impacted by some springtime burns. On grazing leases, cattle typically graze around the trees, removing fuel for fire, thus allowing the trees to resist control by fire alone. In addition, some brush species like roughleaf dogwood can be difficult to completely control with fire. Selected herbicide or mechanical removal has been beneficial to maintaining prairie areas.For wildlife such as whitetail deer and bobwhite quail, tree and brush presence in grass areas is beneficial because it maximizes edge habitats.

Some WCGS areas have been managed for this purpose. As these areas mature toward woodlands, they will lose transitional habitat characteristics.

Consequently, to maximize wildlife diversity on WCGS land, selected mechanical tree removal and herbicide brush control is planned (Table 4).Tree control along the WCGS access road will also be completed to discourage deer from areas close to the road and increase traffic safety. This practice is not likely to prevent all deer/vehicle collisions; however, past efforts have helped, either by making deer more visible to drivers, or by reducing the number of deer near the access road.2.1.6 Noxious Weed Control Kansas law requires landowners to control weeds designated by the state as noxious. Four noxious weed species common to the area occur on Wolf Creek lands: musk thistle, Johnson grass, serecia lespedeza, and field bindweed.Field bindweed occurs sparingly on cropland and, with attention, can be controlled by WCGS tenants during their normal farming practices.

Supplemental spraying may be necessary.

Musk thistle patches were small in 2005 and were clipped during June.Continued observation for new infestations will be completed.

Spot spraying with herbicide may be necessary to maintain control. Herbicides recommended by the Coffey County Noxious Weed Department will be used if necessary.

Control of Johnson grass has succeeded in the past few years to a point similar to musk thistle where infestations have been small and easily controlled.

During late summer 2005, two small Johnson grass areas were sprayed.

7 Serecia lespedeza is a relatively new invader and expanded quickly.Approximately 250 acres were spot sprayed during 2005 in areas adjacent to the plant site, causeway, main dam, and East Unit 2 (Figure 1). Good control was achieved, however seed dispersal by birds and deer make serecia lespedeza difficult to eradicate.

Inspection and spraying of new infestations on company lands will continue to control the weed on WCGS land. Table 4 lists areas to be sprayed in 2006.2.1.7 Fencing Most fences on WCGS property have been constructed to allow for continued leasing. Some have been built to fulfill a landowner's legal obligation to maintain half of a property boundary fence (K.S.A.29-301). Replacing fence has been an ongoing effort, and most are now in good shape.Fencing during 2006 will be manage livestock access to a pond which will increase wildlife habitat, improve water quality, and preserve dam integrity (Table 4).2.1.8 Vegetation Control on Dams and Dikes The main dam and saddle dams will be scheduled for mowing once during May/June and once during August/September time periods. This schedule will allow dam safety and integrity inspections to be most effective.

Mowed grass makes it easier to inspect for seeps and settlements on the dam.Weeds control is important in the gravel areas, including the gravel road on top of the Main Dam, Saddle Dam IV and V, and the Baffle Dikes, gravel drainage blankets along the toe of the Main Dam and Saddle Dam IV, as well as gravel and rip-rap areas in the vicinity of the Blowdown Structure.

Spraying, with an appropriate residual bare-ground herbicide, will be scheduled as needed.2.2 CROPLAND Cropland is managed to conserve soil, maintain rent income, and provide wildlife benefits.

Conservation farming, terracing, and wildlife strip management will be continued to help achieve these objectives.

Participation by tenants in USDA programs for field border, buffer strip, wet soil, and other conservation practices will be encouraged.

2.2.1 Crop Production A total of 1,282 acres of cropland was leased to 12 local farmers in 2005 (Table 6). Consistent with past years, the cropland lease contracts require that common conservation practices be followed.

On fields with appropriate terraces to follow, contour farming will be required.

Double-cropping, producing two crops on the same acreage during the same season, will generally be prohibited because this practice usually increases soil loss. Fall tillage of crop residues will be prohibited except for certain instances, which will be considered on a case-by-case basis. These will generally include tillage necessary for fall planting of 8 wheat, plowing of terraces, and deep tillage practices to improve productivity.

Compliance by tenants of these conservation requirements has been good.2.2.2 Wildlife Habitat Improvement Existing weed and grass strips, and the practice of leaving edge grain, all of which provide wildlife benefits, will be continued.-

An existing two-acre food plot will be expanded along the Stringtown Cemetery road in a predominately brome-grass area. This area has not been used for agricultural production and is lacking in habitat diversity, and this food plot should increase late winter food sources for birds wintering in the area.2.3

SUMMARY

Grassland and cropland land management, as presented in this section, promotes the conservation of agricultural and natural resources on WCGS land, the primary objective of the Land Management Program. Grazing rate control, hay harvest requirements, fencing improvement, and soil conservation requirements will ensure long-term productivity of the agricultural resources.

Buffer zone management, controlled burning, tree and brush control, and wildlife habitat improvement will promote stewardship of the natural resources on WCGS land. Control of serecia lespedeza will continue.

Together, these activities will balance production and conservation values to meet regulatory requirements that apply to the Land Management Program.3.0 ENVIRONMENTAL EDUCATION AREA (EEA)Land management activities on the EEA have been designed to enhance natural resource education.

Improvement of the wildlife habitat will increase the public's chances to view a greater variety of wildlife.

Continued modifications and habitat improvements have been planned to keep the area attractive for wildlife and interesting for visitors.3.1 CONTROLLED BURNING The native grass areas will be burned in a manner to enhance prairie management education for EEA visitors.

As with burning of other areas, EEA burns in 2006 will be dependent on manpower and safe conditions.

The long range-burning plan will provide burned areas contrasted by unburned areas along the trails (Figure 3, Table 8). Plans are to burn each area once every third year. Some areas requiring tree and brush control may be burned during consecutive years if weather conditions allow.Environmental Management will observe woody growth annually to determine if control measures to maintain wildlife habitat diversity may be required.

Mechanical removal or herbicides are two other control options available.

3.2 WILDLIFE

FOOD PLOT A three-acre food plot has been planted with birdsfoot trefoil and ladino clover along the Kansas Nature Trail. Native plants have become established in this plot, thus new plantings will be necessary.

The planting of this food plot is a condition of an adjacent cropland lease.

9 An additional 3.5-acre wildlife food plot and habitat was established along the north edge of the EEA in Cropland Unit E (Figure 2). This area was specifically planted to enhance bobwhite quail, but will benefit all low growth edge habitat species. Four rows of mixed shrubs, including choke cherry, aromatic sumac, and sand plum were planted.Adjacent to the shrubs was planted one acre of Illinois bundleflower, as a perennial food source and brood habitat. The remaining acreage was planted to native tallgrass species with wild forbs included.

This area will increase edge and provide high quality brood habitat, which enhances the escape and cover habitats already present. This area will be maintained through 2006.3.3 CONSERVATION DEMONSTRATION PLOT Development of a demonstration area for conservation practices will continue into 2006.This demonstration plot has been planted with the Coffey County Conservation District and Natural Resource Conservation Service (NRCS). Single species native grass areas were established to aid visitors with grass identification.

3.5

SUMMARY

The management activities presented in this section enhance the natural resources and the environmental education opportunities at the EEA. This is an objective being met by using controlled burning to demonstrate the role of fire in prairies.

The wildlife food plot and conservation demonstration plot will also increase wildlife habitat diversity at the EEA. Boardwalk improvements and raised viewing blinds will increase visitors' access to wetland and woodland habitats, thus increase educational opportunities.

The conservation demonstration area will be completed in cooperation with local civic groups and natural resource agencies, which will strengthen positive relationships, another program objective.

4.0 REVIEW

OF OBJECTIVES This report and plan demonstrates how the objectives of the Land Management Program were achieved during 2005 and how they will be will continue to be achieved through 2006. These objectives are: 1. To conserve or improve both agricultural and natural resources, This primary objective was achieved through proper grassland and cropland management.

Through lease contracts with local farm tenants, grazing and haying management requirements will preserve the native prairie grasses and wildlife associated with them. Likewise, cropland lease requirements serve to minimize soil erosion. Controlled burning and selected tree and brush control will maintain prairie habitats.2. To foster positive relations with local agricultural and natural resource communities, This objective was achieved in the past as evidenced by a partnership with the U.S. Fish and Wildlife Service, Kansas Department of Wildlife 10 and Parks (KDWP), Ducks Unlimited, Westar Energy, Kansas City Power and Light, and the Natural Resource Conservation Service to develop wetland cells on WCGS land. The EEA has been listed as an Outdoor Wildlife Learning Site (OWLS) by the KDWP. The Edison Electric Institute National Land Management Award was received in 1997 in part due to EEA accomplishments.

In addition, the Wildlife Habitat Improvement Award sponsored by the Kansas Banker's Association, KDWP, and Quail Unlimited was received in 1995.Activities indicating ongoing achievement of this objective include a partnership with the NRCS and Coffey County Conservation District to develop a conservation demonstration area at the EEA. A Conservation Reserve Program project with the NRCS, complete with wetland cells, was designed to help alleviate flooding problems on neighboring land, and continued development of the soil conservation benefits of the project will continue through 2004. Long-term lease relationships with area farmers have created positive working relationships providing for continued agricultural production compatible with conservation efforts.Involvement by an Environmental Biologist as an officer of the Kansas Chapter of The Wildlife Society and Coffey County Conservation District will keep communication avenues open to help achieve this objective in the future.3. To enhance for educational purposes the natural resources on the EEA, Controlled burning .plans will demonstrate fire's role in a prairie. The legume food plot and conservation demonstration plot will enhance educational opportunities and wildlife habitat diversity.

Boy Scout Eagle candidate projects will improve boardwalks to enhance visitor access to the EEA.4. To satisfy licensing requirements, Approximately 1,440 acres around the cooling lake will continue to be managed in a variety of naturally occurring habitats.

This exceeds the 500-acre buffer zone required in the licensing documents.

Noxious weeds will be controlled on company land to comply with Kansas regulations.

5. To maintain rent income at maximum levels while placing the higher priority on the above objectives.

Rent income from grazing and hay leases has remained similar to past years. Table 2 indicates past income and expense amounts.

11 Table 1. Allowed grazing allotments on WCGS locations.

rangeland during 2006. See Figure 1 for lease Animal Units (A.U.) (1)/Season 3 mo 6 mo Deferred Area Unit Tenant Acres option option Rotation(2)

North 3 E. Madden 192 58 (3)29 6 E. Madden 148 46 (3)23 Sharpe 1 Le. Skillman 40 12 6 2a W. Madden 142 7/15-10/31 Na 40 2b W. Madden 130 5/1-7/15 Na 40 16 R. Anderson 49 14 7 East 2 J. Salava 78 30 15 4 J. Salava 120 40 20 5 J. Salava 90 34 17 South 8, 9 J. Salava 94 30 15 West 2 J. McBride 30 4 4 E. Madden 80 7/15-10/31 na 29 5 E. Madden 80 5/1-7/15 na 29 8 J. Jaurenig 110 40 20 Northwest 2 La. Skillman 39 16 8 Total acres 1422 (1) 0.8 A. U.1.0 A. U.1.2 A. U.1.3 A. U.Weaned calf 500 lbs. or less (average) at turnout Dry cow, other cattle greater than 700 pounds (average)Cow/calf pair (fall or spring calf)Bull (2) Deferred rotation means grazing one unit for a portion of the season, then another unit for the remainder.

Animal units remain constant.

12 Table 2. WCGS agricultural tenant expected and received income for 2005 and expected income for 2006. See Figure 1 and Figure 2 for lease locations.

2005 2005 2006 Lease Tenant Area Field Expected Received Expected Graze R. Anderson J Jaurenig E. Madden W. Madden J. McBride J. Salava Le. Skillman La. Skillman Sharpe West North North West Sharpe West East South Sharpe Northwest Graze total 16 8 3 6 4,5 2 2 2,4,5 8,9 1 2$ 504 1,440 2,088 1,656 2,088 2,880 240 3,744 1,080 432 576$16,728$ 504 1,440 2,088 333 2,088 1,361 240 3,744 1,080 432 576$13,886$ 504 1440 2,088 1,656 2,088 2,880 240 3,744 1,080 432 576$16,728 Haying K. Clark L. Hermon E. Herr H. Hess J. Iseman J. McBride C. Rich La. Skillman R. Skillman T. Skillman J. Trager B. Smith Undetermined West Sharpe South Northwest Southeast East East North Northwest Northwest North Sharpe East East Southeast South Hay total 6 4 1 9 2 3,10,11 1 2, 4 6 7,10 6,8 7$ 360 120 600 456 360 1,572 672 288 240 336 360$ '3'360 120 600 456 360 1,572 672$ 360 120 600 456 360 1,572 672 288 (4)0 336 360 732 288 240 336 360 732 8,9 7 5,6 732 420$ 6,516 (5)0$ 5,496 420$ 6,516 Cropland F. Crooks K. Gunlock L. Hermon H. Hess J. Iseman W. Madden M. Meats T. Romig M Seaman Le. Skillman NN 00 W RR, QQ EE -II L-T JJ-MM B,C A, E, H U,V,X,AA$ 2,001 1,620 330 2,370 6,348 6,606 4,383 762 2,511 5,919$ 2,001 1,620 330 2,370 6,348 6,606 4,383 762 2,511 2,349$ 2,001 2,268 330 2,370 6,348 6,606 4,383 762 2,511 5,919 13 Table 2. (cont.)2004 2004 2005 Lease Tenant Area Field Expected Received Expected R. Skillman PP 1,221 (7)0 1,221 T. Skillman F,I-L,BB-DD 4,374 (8)1,959 4,374 Crop total $ 39,093 $31,239 $ 39,093 Graze total $16,728 $13,886 $16,728 Hay total 6,516 5,496 6,516 Crop total 39,093 31,239 39,093 Grand total $ 62,337 $ 50,621 $ 62,337 (1) $1323 deducted for serecia lespedeza control expenses on this lease.(2) $1519 deducted for fence/catch pen improvements on this lease.(3) $360 deducted for serecia lespedeza control expenses on this lease.(4) $240 deducted for youth mourning dove hunt habitat management.

(5) This area was not leased due to weather constraints during preferred hay cutting dates.Grass allowed to rest.(6) $3570 deducted for terrace repair on this lease.(7) $1221 deducted for youth mourning dove hunt habitat management.

(8) $2415 deducted for terrace repair on this lease.

14 Table 3. 2005 land improvement and maintenance items and costs. Numbers indicate grassland areas in Figure 1. Letters indicate cropland areas in Figure 2.2005 Activity Area Unit 2005 Cost Noxious Weed Control $1500 Musk thistle Sharpe 2, 10, 11 Northwest 10 Johnson grass Plant area South 5 Serecia lespedeza North 2 Sharpe 2, 3 East 1,2,6,8 Plant area Southeast 2 South 5, 6 Railroad Wildlife Habitat Management

$500 Food plots EEA Sharpe 10 Southeast 5 West. 7 Strip-discing Sharpe 10 West 3 Tree/brush Control $3000 Clip/mow EEA 8, 10 Southeast 7 Spray Sharpe 2, 3, 5, 6, 13 (blackberry)

East 13 South 5, 6 West 7, 9 Northwest 8 EEA miscellaneous

$1500 Boardwalk/blind preservative Conservation demo area Fencing $1100 Evans/Hermon line Sharpe 4 Field Access Improvement 0 Romig lease North B, C 15 Terraces 0 Gunlock/Stohs 00 Soil Conservation Structures

$850 Shallow-water area North F Sheet-flow restoration Northwest 11 Terrace Repair North J Gully repair Railroad Rangeland Evaluations Grazing leases Sharpe 1, 2 West 4, 5 Hay leases Northwest 2 Total $ 8,450 16 Table 4. 2006 land improvement and maintenance items with estimated costs. Numbers indicate grassland areas in Figure 1. Letters indicate cropland areas in Figure 2.2006 Planned Activity Area Unit Estimated Cost Noxious Weed Control $1500 Musk thistle Sharpe 2, 10, 11 Northwest 10 Johnson grass Plant area South 5 Serecia lespedeza North 2 Sharpe 2, 3 East 1,2,6,8 Plant area Southeast 2 South 5, 6 Railroad Wildlife Habitat Management

$1000 Food plots EEA/wetland Sharpe 10 Southeast 6 West 7 Strip-discing Sharpe 5, 10 West 3 Tree/brush Control $6,500 Clip/mow EEA 8, 10 Southeast 7 Spray North 5 Sharpe 2,3,5,6, 13 (blackberry)

East 13 South 5, 6 West 7, 9 Northwest 8 EEA miscellaneous

$2000 Boardwalk/blind preservative Elevated viewing blind Eagle projects Fencing $2,000 Pond dam North 6 Stream crossing 17 2006 Planned Activity Area Unit Estimated Cost Stream crossing $500 Romig B, C Terraces $1500 Gunlock/Stohs 00 Skillmans F, J, U, V, X, AA, BB, DD, CC Railroad $2500 Culvert logjam clearing Railroad Rangeland Evaluations 0 Grazing leases West 4, 5, 8 0 Hay leases West 6 0$17,500 18 Table 5. Grazing and hay land evaluations completed during 2005.Grazing % Plants Grazing Rate Area Unit % Utilization Grazed recommendation Sharpe 1 Ungrazed Ungrazed Continue current rate 2 <25 <25 West 1 <25 <25 Continue current rate 2 50 50 Continue current rate Hay Ground cover Condition Management Area Unit (%)- Classification recommendation Northwest 2 >50 (est) Excellent Maintain current cutting requirements 19 Table 6. WCGS haying and cropland tenant list for 2006. Numbers indicate grassland areas in Figure 1. Letters indicate cropland areas in Figure 2. Grazing lease tenants are listed in Table 1.Lease Type Area Unit Acres Tenant Hay Leases North 2 12 Larry Skillman 7 12 Travis Skillman Sharpe 4 10 Larry Hermon 6, 8 16 Travis Skillman East 1 56 Clarence Rich Sr.3, 10, 11 131 Jack McBride 7 30 Jim Trager 8, 9 61 Brad Smith Southeast 2 30 Jim Iseman 7 15 Undetermined South 1 50 Elmer Herr 5, 6 17 Undetermined West 6 30 Karen Clark Northwest 4 12 Larry Skillman 6 20 Roy Skillman 9 38 Harold Hess Total acres 540 Crop Leases na A, E, H (1)83.7 Mark Seaman B, C 25.4 Terry Romig F, I, J, K, 145.8 Travis Skillman BB -DD D, L- T 220.2 Wayne Madden U, V, X, Y, AA 197.3 Levan Skillman W 12.0 Larry Hermon EE -II 211.6 Jim Iseman JJ -MM 146.1 Mike Meats NN 66.7 Free Crooks 00 53.7 Kent Gunlock PP 40.7 Roy Skillman QQ, RR 79.0 Harold Hess Total acres 1,282.2 20 Table 7.Grassland areas listed for prescribed burning during 2006.Completion is dependant on safe weather conditions available from mid-March through early May. See Fig.ure 1 for exact locations.

Area Field Acres Area Field Acres North 2 45 South 1 50 3 216 ____ __2 18 5 50 3 39 6 148 4 51 14 34 5 28 6 35 Sharpe 1 40 10 24 2 262 3 32 West 2 21 4 12 7 41 5 37 ______8 110 11 28 9 62 12 14 14 20 Northwest 1 46 15 15 2 39 3 16 East 1 82 4 15 6 49 5 59 9 87 6 21 10 10 9 44 11 80 12 26 Cropland 00 78 13 15 Plant Area 40 Southeast 3 41 4 12 Total Acres 2,355 5 39 6 54__ __ _ __ _7 46 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

21 Table 8. Controlled burning schedule for the Wolf Creek Environmental Education Area, 2006 -2009. See Figure 3 for locations.

Area 2006 2007 2008 2009 1 X x 2 X X 3 X 4 X X 5 X 6 X X 7 X X X 8 X X X 9 X 10 X X X X 22 Figure 1. Grassland units at WCGS.

23 Figure 2. Cropland units at WCGS.

24 NORTH Figure 3. Grassland units on Wolf Creek Environmental Education A74 Draft WOLF CREEK GENERATING STATION WOLF CREEK COOLING IMPOUNDMENT CLEAN WATER ACT 316(b) -COOLING WATER INTAKE STRUCTURES COMPREHENSIVE DEMONSTRATION STUDY Prepared by: Supervisor Regulatory Support Approval: Manager Regulatory Affairs Approval: Ralph Logsdon Bob Hammond Date I Kevin Moles Date Executive Summary Impingement studies conducted at WCGS over the December 2004 -March 2006 period suggest that impingement rates were very low in both absolute (number of fish) and comparative terms (relative to other nuclear plants of similar design), as was impingement mortality.

Impingement was selective for certain species (freshwater drum, white crappie, gizzard shad) and certain size and age classes (small fish that were not aged but were presumed to be young-of-year).

More than half of fish impinged were "rough fish" that are not avidly sought by recreational fishermen.

The white crappie was the only recreationally important species impinged in significant numbers. Most recreationally important species, including smallmouth bass and walleye, were impinged in very low numbers.Available data suggests that impingement has had little or no effect on fish populations in Coffey County Lake. Coffey County Lake, with its thriving populations of channel catfish, white crappie, smallmouth bass, walleye and wipers, has become a popular destination for Kansas's anglers. Kansas Department of Wildlife and Parks (KDWP) issues annual Fishing Forecasts for public waters in Kansas, which are in effect ratings of public fishing areas.Coffey County Lake received biologists' rating of Excellent for walleye (the only state reservoir to receive this ranking for walleye) and smallmouth bass (the only state reservoir to receive this ranking for smallmouth bass) (KDWP 2004).Channel catfish, white crappie, white bass, and wiper fishing were all rated Good.

TABLE OF CONTENTS 1.0 PLANT COOLING SYSTEM AND WATER INTAKE STRUCTURE SCREEN A LTER NA T IV ES ...........................................................................................

1 1.1 COOLING SYSTEM ALTERNATIVES

........................................................

2 1.1.1 C O O LING LAKE .................................................................................

2 1.1.2 NATURAL DRAFT WET COOLING TOWERS .............................................

3 1.1.3 MECHANICAL DRAFT WET COOLING TOWERS ........................................

4 1.1.4 EVALUATION OF COOLING SYSTEM ALTERNATIVES

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..5 1.2 INTAKE SCREEN ALTERNATIVES

.............................................................

5 1.2.1 CONVENTIONAL VERTICAL TRAVELING SCREENS ... ..............................

5 1.2.2 R EVO LV ING SC REENS ..............................................................................

5 1.2.3 EVALUATION OF INTAKE SCREEN ALTERNATIVES

.................................

5 1.3 NEW TECHNOLOGIES AND OPERATIONAL MEASURES EVALUATION

...... 6 1.3.1 N EW TEC HNO LO G IES ..............................................................................

6 1.3.1.1 FINE-MESH TRAVELING SCREENS ..................................

7 1.3.1.2 FISH BARRIER NET ..............................................................................

7 1.3.1.3 BEHAVIORA L BARIERS .........................................................................

7 1.3.2 O PERATIO NAL M ESURES .........................................................................

8 1.3.2.1 CIRCULATING WATER FLOW REDUCTION/CAPS

....................

8 1.4 RESTORA TION EVALUATION

............................................................................

8 1.5 OTHER COMPLIANCE OPTIONS .......................................................................

9 1.5.1 SITE-SPECIFIC BTA DETERMINATION

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9 1.5.1 1 CO ST/CO ST TEST ........................................................................................

9 1.5.1.2 COST/BENEFIT TEST ..................................................................................

10 1.5.2 EVALUATION OF A SITE-SPECIFIC BTA ............

..........................................

10 2.0 SOURCE WATER PHYSICAL DESCRIPTION

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11 3.0 CIRCULATING WATER INTAKE STRUCTURE DESCRIPTION

.........................

15 4.0 HISTROY OF AQUATIC BIOTA STUDIES ........................................................

23 5.0 PROPOSAL FOR INFORMATION COLLECTION

........................................

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26 5.1 SAMPLING PLAN AND A STUDENT REASEARCH AND TRAINING GRANT ...... 26 5.2 WOLF CREEK FISH AND SHELLFISH IMPINGEMENT STUDY .......................

27 5.2.1 STUDY O BJECTIVES

......................................................................................

27 5.2.2 STUDY PROCEDURES

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27

6.0 IMPINGEMENT

MORTALITY CHARACTERIZATION STUDY ..............

29 7.0 RESTO RA TIO N PLAN .......................................................................................

29 8.0 VERIFICATION MONITORING PLAN .................................................................

30 9.0 CWIS IMPINGEMENT 316(B) DETERMINATION

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31 9.1 IMPACT OF FISH AND SHELLFISH RESOURCES FROM IMPINGEMENT

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31 9.1.1 A SS E SS M ENT ................................................................................................

33 9 .1.2 R E S U LT S .............................................................................................................

34 9.2 IMPINGEMENT AT WCGS RELATIVE TO CCL FISHERY ...................

36 9.2.1 IM PO RTANT SPEC IES .....................................................................................

36 9.3 IMPINGEMENT AT WCGS COMPARAED TO SIMILAR PLANTS .....................

40 10.0 C O N C LU S IO N .................................................................................

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41 11.0 LITERATURE C ITED ........................................................................................

50 FIGURES Figure 2-1 50-M ILE VIVINITY MAP ............................................................................

12 Figure 2-2 6-M ILE VIVINITY MAP ..............................................................................

13 Figure 2-3 SITE-BOUNDARY MAP ...........................................................................

14 DRAWINGS CIRCULATING WATER SCREENHOUSE DRAWING (2) ....................................

17 & 18 CIRCULATING WATER SCREEHOUSE TRAVELING SCREENS DRAWING ...... 19 CIRCULATING WATER UNDERGROUND PIPING DRAWING (2) ......................

20 & 21 CIRCULATING WATER DISCHARGE PIPING DRAWING .....................................

22 TABLES STOCKING RECORD OF COFFEY COUNTY LAKE ...............................................

25 APPENDICES APPENDIX A IMPINGEMENT DATA APPENDIX B SUPPORT DOCUMENTS APPENDIX C CORRESPONDENCE AND TELEPHONE CALL RECORD CONCERNING COFFEY COUNTY LAKE AND FISHERY APPENDIX D MAKEUP WATER SCREENHOUSE 316(b) DETERMINATION Comprehensive Demonstration Study 1.0 Plant Cooling System and Water Intake Structure Screen Alternatives In selecting a nuclear power plant site, it is necessary to determine what heat dissipation or cooling system is to be incorporated in the overall design. The cooling system to be used is a primary determinant of the size and character of the site required for the plant.In Kansas, particularly in the southeastern region, the limited availability of cooling water and the requirement to optimize water resource conservation and management are overriding considerations leading to the selection of the plant site. Natural stream flows in the region tend to be low during the summer and fall months and during periods of drought. Normal stream flows are periodically inadequate to supply makeup for a power-plant cooling system and the power plants must be sited on or in proximity to an existing reservoir, or on a reservoir that has been constructed to provide cooling water for the plant.Therefore, long-range water resources planning and wisest possible use and conservation of available water resources are absolutely necessary in the development of new generating capacity.

Each of the alternative cooling system discussed below offers somewhat different advantages and disadvantages with the respect to the requirements for effective water resource management.

The second major consideration in the selection of the alternative cooling systems is the reliability and maintenance problems of the system in question.No matter how effective a design might be in its net consumptive use of water, the system is not a valid alternative if it is not highly reliable for the operation of a base load nuclear power generating station. Systems that require additional routine maintenance or periodic heavy maintenance may cause disruption of power generation and cutback of power delivery, key factors in the question of system reliability.

The third criterion to be considered in the selection of the cooling system is cost.An economic comparison of the alternative cooling system involves estimation of differences in the construction costs (for example, initial costs of equipment-and land acquisition for the cooling facilities), and operating cost (for example, maintenance, fuel costs, net send-out capabilities, makeup and water treatment costs).To enable a direct comparison between the alternative cooling system, the Wolf Creek site has been assumed to be the location for all the systems. In this way, secondary variables such as pipeline and transmission line distances and access routes for road and railroad transportation are kept constant, along with other site-sensitive environmental characteristics not inherently related to the type of cooling system used.1

1.1 Cooling

System Alternatives The heat dissipation system is an integral part of the power generating station and is designed to dissipate or transfer wasted thermal energy to the environment.

Even under ideal conditions, no thermodynamic process can convert more than 60 percent of a fuel's thermal energy into mechanical energy used to power the electrical generators.

The total amount of heat or thermal energy that is released and the amount of heat that must be dissipated through the cooling system are functions of the type, size, and efficiency of the plant.The nuclear steam supply system (NSSS) chosen for Wolf Creek has a full load thermal output equivalent to 3,425 Mwt. Approximately 67 percent of the heat generated will be rejected or dissipated to the environment.

To accomplish this heat transfer, the required circulating water flow through the condenser will be 1,225 cubic feet per second (cfs) at a temperature rise of 30.40 F at full load (Sargent & Lundy, 1974). The principal types of cooling systems currently being used or planned for power generating stations include: 1. Cooling lake;2. Mechanical draft wet cooling tower: 3. Natural draft wet cooling towers.1.1.1 Cooling Lake The surface of a cooling lake dissipates waste heat to the atmosphere by four heat transfer mechanisms:

Evaporation, 40 percent; radiation, 30 percent;conduction, 25 percent; and advection, 5 percent; all working as functions of climatic conditions (Koflat, 1971). Thus, the lake depends upon natural conditions and phenomena to remove heat transferred to it by the circulation of cooling lake water through the condensers.

The size of the lake required is determined by such criteria as local climatic conditions, heat load, and effective cooling area of the lake.The cooling lake system alternative is an off-stream cooling water impoundment created by damming Wolf Creek, a minor tributary of the Neosho River. The plant draws circulating water fro the cooling lake, passes it through the condensers, where it picks up heat, and returns it to the lake. The circulating water intake and discharge structure are separated by sufficient distance and baffle dikes to avoid recirculating of the warm water directly back to the condenser.

Most of the water required both for the original filling and the makeup water requirements of the lake arrive by pipeline from John Redmond Reservoir on the Neosho River. The remaining small portion of the water requirements comes from Wolf Creek.2 A lake surface of about 2,630 acres would be required to meet the temperature limitations of the condenser.

However, during drought conditions equivalent to one occurrence of a 5-year duration in 50 years, the makeup water from John Redmond Reservoir (JRR) would be limited to an average of 40 cfs to meet the water quality flows in the Neosho River. With makeup limited to an average rate of 40 cfs, alake with a 5,960-acre surface area would be required to provide for the 2,630-acre surface area after maximum drawdown.A significant advantage of the cooling lake system as compared with the alternative is that, except for the circulating water pumps, no additional equipment is necessary for plant operation.

Plant reliability is not jeopardized by the possible mechanical failure of cooling tower fans as in the case with cooling tower systems. In addition, plant maintenance costs and spare parts inventories for cooling lake systems are lower than with other systems. The major cost associated with this system is the construction of the retaining dam, the intake and discharge structures, and the water diversion and return pipelines required to maintain necessary water level and water quality.Note: By definition, Wolf Creek's cooling lake system can be also considered as a "recirculating water" system as water from Coffey County Lake (also known as Wolf Creek Lake) is pumped through the plant condensers for the purpose of removing waste heat, passed through a cooling device (lake) for the purpose of removing such heat from the water and then passed again through the condensers (40 CFR Part 423.11 (h)).1.1.2 Natural Draft Wet Cooling Towers A wet cooling tower system is a direct contact evaporative cooling device.Circulating water from the condenser is cascaded down through the tower, passing over baffle plates, which break the flow into drops. Air is drawn across the baffle plates, cooling the water by evaporation.

The cooled water is then pumped back through the condenser.

The required airflow is created by either by fans (mechanical draft) or by a tall shell in which the heated air rises (natural draft) because of the chimney effect (Parker and Krenkel, 1969).The volume of airflow and the cooing efficiency of a natural draft lower depends on the temperature differences betweens the air in the shell and the ambient air.Higher effluent air temperature are normally encountered in natural draft towers than in mechanical draft towers, and natural draft towers are not generally considered suitable for hot climates in which the air density and humidity differences between inside and outside would at times be too small to achieve the minimum required air flow and rate of evaporation of the circulating cooling water (National Academy of Engineering, 1972).Inherently, these conditions tend to reduce the cooling efficiency of a natural draft cooling tower during the hotter, drier months of the year. For example, 3 meteorological data for the southeastern Kansas region indicate that, on the average, a wet-bulb temperature of 750 F would be exceeded at least 10 percent of the time. At such conditions of temperature and humidity, cooling efficiency would drop far below acceptable levels. Because of these atmospheric conditions, the natural draft wet cooling system was not considered practical and was discarded from further consideration.

1.1.3 Mechanical

Draft Wet Cooling Towers In considering mechanical draft cooling towers, it was concluded that the induced draft tower would be preferable to the forced draft type, because higher efficiencies are achievable with the former.Of the cooling tower options, the mechanically induced draft wet tower appears most viable for the plant operation.

However, this alternative would have as high a total water consumption as the cooling lake system and, subsequently, would require a storage lake of at least as great an area as the cooling lake system to provide for storage of makeup water during drought conditions equivalent to one occurrence of 5-year duration in 50 years. The lake is required because the maximum water rate demand during summer drought conditions may exceed the average rate of availability (40 cfs) from JRR. Therefore, the wet cooling tower system also requires stored water at Wolf Creek for use as makeup to the cooling towers to replace water lost by evaporation and blowdown.

The location of the Wolf Creek storage. lake, makeup water source, and the conveyance of blowdown water to the Neosho River for this alternative would be similar to that of the cooling lake system described above.Water treatment requirements are also an important consideration in the analysis of cooling tower operation.

Biocide treatment of the circulating water is required in all cooling systems to prevent the growth of biological organisms (slimes) in the cooling system. However, cooling towers with considerable water surface exposed to air and sunlight may require additional biocide treatment to control the growth of algae. For the control of metal corrosion and scaling, cooling towers system may require additional chemical treatment, depending on the quality of the circulating water and the particular materials used in the tower and related construction and equipment.

Because the wet cooling tower requires a storage lake with as much heat dissipating surface as the cooling lake system, there seems no reason to use the wet cooling tower. Particularly, the wet cooling water system is less attractive on the basis of costs and reliability when compared with the cooling lake system because there would be added capital costs, higher operating cost, and other penalties.

There would be power penalties as well, because of additional auxiliary machinery power requirements.

Added maintenance associated with the cooling tower is also a concern. Routine maintenance would be required on the cooling tower fans, gear reducers, drive shafts, motors, water pumps, valves, 4 piping and headers, and other mechanical components.

Maintenance would also be required on such components as louvers and fill material, in addition to the maintenance of a storage lake and pumping facilities similar to the ones required for a cooling lake system.1.1.4 Evaluation of Cooling System Alternatives Through careful consideration of the basic characteristics of each of the cooling system alternatives described above, it was determined that only the cooling lake system would be considered in the design of Wolf Creek Generating Station.The environmental impact, economic and reliability considerations associated with these alternatives indicate that the cooling tower alternatives would cause more depletion of available natural resources by using such resources for the construction of towers, basins, piping, and associated electrical and mechanical equipment.

In addition, the cooling tower options would require the highest manpower expenditure during construction and would result in the poorest utilization of fuel resources.

Also, the cooling lake system would be the most desirable system from an aesthetic standpoint.

Therefore, the cooling lake alternative conclusively offers significant environmental advantages over both of the cooling tower options (WCGS-ER, 1974).1.2 Intake Screen Alternatives

1.2.1 Conventional

Vertical Traveling Screens The conventional vertically rotating single entry band type screen is the most common mechanically operated screen in U.S. power plant intakes. It performs efficiently over a long service life and requires relatively little operational and maintenance attention.

It is applicable to almost all water screening situations and adapts easily to changing water levels. At present there is no provisions for returning fish greater then 100 mm in size that survive impingement to the cooling lake.1.2.2 Revolving Screens Three major types of revolving screens were considered:

vertical revolving drum screens; horizontal revolving drum screens; and revolving disk screens.Revolving drum screen provide the possibility of returning fish to the body of water. But in the case of CCL, this would not be effective since there is no flow to carry the fish away. Revolving disk screens offer no advantage over other common screens for fish protection, while requiring a very large screen structure to limit approach velocities to species of fish apt to being impinged.1.2.3 Evaluation of Intake Screen Alternatives 5

Regardless of the alternative being selected, the intake velocity will be limited to 1.0 ft/sec at low water level. The sustained swimming speed of the adult species of fish expected to inhabit the lake is sufficient to minimize involuntary impingement at water velocities to or less than 1.0 ft/sec. Phytoplankton, zooplankton, juvenile fish, and fish eggs will undoubtedly be subject to passage through the circulating water intake structure.

The alternative structures are similar in terms of potential effects to biota and thus comparisons are not warranted.

The conventional vertical traveling screen was selected as the type of screening mechanism to be use at the CWlS (WCGS-ER, 1974). Further discussion on the CWIS screening system is described in Section 3.0.Note: The Makeup Water Screenhouse (MUSH) on the Neosho River is used on occasion to add water to Coffey County Lake (CCL). Coffey County Lake was constructed as a cooling lake for the WCGS and is considered a Water of the State. The transfer of water from the Neosho River to CCL is a transfer from a Water of the State to another Water of the State. This is a water transfer and not a direct use of water by WCGS. At this time water transfers are not covered by NPDES permitting, and therefore exempt from 316(b) coverage (USEPA, 2006).See Appendix F for more detailed information.

1.3 New Technologies and Operational Measures Evaluations The Environmental Protection Agency (EPA) 316(b) Phase II regulations

[40 CFR 125.95(b)(I)(i)]

requires that the 316(b) determination include a description of technologies and operational measures, which will be evaluated further to determine feasibility of implementation and effectiveness in meeting impingement standards.

Several technologies and measures have been developed/conducted and have proven effective, in certain circumstances, in reducing impingement at various CWIS. The feasibility of implementation and the performance of such technologies and operational measures are highly site-specific.

The design and capacity of the existing CWIS, as well as source waterbody physical and biological characteristics, including additional power requirements and loss in generating capacity and unit availability will determine which technologies and/or operational measures are practical for implementation and effective in reducing impingement at WCGS.1.3.1 New Technologies A screening of technologies has been conducted to determine which technologies offer the greatest potential for application at WCGS and therefore would warrant further evaluation.

Technologies have been screened based upon feasibility for implementation, biological effectiveness (i.e., ability to achieve reductions in impingement mortality), and cost of implementation (including capital, installation, and annual operations and maintenance costs).6 Based upon the results of the technology screening process discussed above, the following is a list of technologies evaluated to reduce impingement and achieve a performance standard, in whole or in part, for reduction in impingement.

Following is a list of those technologies:

1. Fine-mesh traveling screens 2. Fish barrier net; and 3. Behavioral barriers.1.3.1.1 Fine-Mesh Traveling Screens.Fine-mesh traveling screens require an approach velocity no greater than 0.5 ft/s to handle the higher potential clogging rate, which would be inherent with the finer mesh-screening medium. This technology is not viable for WCGS intake system due to high screen flow velocities of the existing system. Further evaluation of this technology is not warranted.

1.3.1.2 Fish Barrier Net A fish net barrier is a mesh curtain installed in the waterbody in front of CWIS.All flow to the intake passes through the net so all-aquatic life forms of a certain size are blocked from entering the intake. The net barrier is sized large enough to have very low approach and through net velocities f 0.1 ft/s of less to preclude impingement of juvenile fish with limited swimming ability. The mesh size must be large enough to preclude fouling during normal station operation while at the same time small enough to effectively block passage of organisms into the intake. These conditions typically limit the mesh size such that adult and a percentage of juvenile fish can be blocked.A typical design-loading rate for fish barrier nets is 20-gpm ft 2.Therefore, a barrier net to handle the CWlS flow would require a net area of approximately 7,200 ft 2 for WCGS CWlS (based upon existing facility design capacity).

Maintaining such a fish barrier net in the open lake moored around the existing intake is not practical and would be an operational and mechanical nightmare to upkeep. Further evaluation of this technology is not warranted.

1.3.1.3 Behavioral Barriers A behavioral barrier relies on avoidance or attraction responses of the target aquatic organism to a specific stimulus to reduce the potential of impingement.

Most of the stimuli tested to date are intended to repulse the organism from the vicinity of the intake structure.

Nearly all the behavioral barrier technologies are considered to be experimental or limited in effectiveness to a single target species. Further evaluation of this technology is not warranted.

7 None of the above listed technologies would further limit the limited amount of impingement seen at WCGS as determined by the impingement monitoring, result analysis and conclusions drawn in Sections 9.0 and 10.0 but these technologies would in turn be impractical as to capital, operational and maintenance cost.1.3.2 Operational Measures Only one operational measure has proven effective in reducing impingement at the CWIS and that is by reducing the flow through the CWlS.1.3.2.1 Circulating Water Flow Reduction/Caps Circulating water flow caps are an operational control measure which would include administratively limiting the total withdrawal of cooling water from CCL to an agreed upon value. The flow reduction may be schedules for periods of the year when impingement are highest to achieve a greater reduction to impingement.

There are two reasons why this operational measure will not work. First, the impingement rate for any particular time or month during the year was not high enough to warrant this type of operational control to reduce impingement.

Secondly, nuclear power plant do not run effectively by having to reduce power generation because of reduce flows through the CWlS. Nuclear power plant cannot be operated as peaking units.Note: In Section 1.0 of this position paper the architect/contactor during the construction of WCGS used the best technology and operational measures available at that time. There was no requirement to perform an impingement study at WCGS. KDHE position as indicated in a letter sent by M.W. Gray, Director, Division of Environment, dated February 21, 1975, to M. Miller (KGE)stated "It is in our opinion (KDHE) that Kansas Gas and Electric Company shall not be held responsible for the loss of fish in the lake due to cold shock kill, impingement, or entrainment".

A copy of this letter can be found in Appendix E.1.4 Restoration Evaluation The EPA 316(b) Phase II regulation

[40 CFR 125.95(b)(I)(i)]

allows consideration of restoration measures as one of the options that may be implemented, either alone or in combination with technology and/or operational measures, to achieve performance standards for reduction of impingement.

Facilities may propose restoration measures that will result in an increase in the number of fish and shellfish in the waterbody that would be similar to those achieved with meeting performance standards through the implementation of technologies and/or operational measures.

A further look at restoration as a tool to offset impingement rates can be found in Section 7.0.8

1.5 Other

Compliance Options One additional compliance alternative that WCGS may pursue includes a site-specific determination of best technology available (BTA). The site-specific determination option would be undertaken only in the event the implementation of some combination of an intake technology, operation change or restoration is significantly greater in cost than anticipated by EPA at this time.1.5.1 Site-Specific BTA Determination The intent of the WCGS approach to compliance is to meet the impingement performance standard established by the EPA when the new rule was promulgated.

However, WCGS also recognizes that if the cost of reaching these goals cannot reasonably be achieved that the EPA 316(b) Phase 11 regulation allows a somewhat lower impingement standard.

Specifically the new rule would allow WCGS to demonstrate that WCGS is eligible for site-specific determination of BTA to minimize impingement if WCGS has selected, installed, and properly operating and maintaining measures that the director has determined to be the BTA to minimize adverse environmental impact of WCGS cooling water operations.

This compliance alternative allows WCGS to request a site-specific determination of BTA for minimizing impingement if WCGS can demonstrate that the cost for compliance with the new rule are significantly greater than those considered by EPA in the development of the new rule (cost/cost test) or that the costs associated with compliance are significantly greater than the benefits (cost/benefit test) that would accrue to the environment.

1.5.1. 1 Cost/Cost Test If WCGS chooses to seek a site-specific determination of BTA, a cost/cost test has to be performed to compare the cost of implementing options to achieve full compliance with the 316(b) Phase II standards to costs estimated by the EPA for the WCGS facility for achieving full compliance.

In the 316(b) Phase II rule, the EPA has assumed that the WCGS facility has already meet the performance standards based on existing technologies and measures already in place.Therefore EPA has projected zero compliance cost for the WCGS facility (Federal Register, Vol. 69 -7/9/2004, page 41678 -see Facility ID# DUT1 105).One thing that has not been fully resolved by EPA is what constitutes "significant" compared to zero dollars that the EPA projected for WCGS. Any cost associated with power reduction or plant shutdown (> $100,00/day) to make changes plus the cost of those changes to the OWlS or traveling screens will fall upward into the significant range even though "significant" has not been defined.9 1.5.1.2 Cost/Benefit Test A cost/benefit test may also be performed for WCGS to compare the total costs of achieving compliance with the environmental benefits through implementation of the required technologies, operational, and/or restoration measures.

Costs are the sum of direct costs and indirect costs of any intake, operational, and/or restoration mitigation actions. Direct costs include the costs of implementing compliance alternatives, including capital, O&M, and lost generation revenue due to extended outages. Indirect costs include any costs associated with impairments of higher energy prices, and negative ecological effects of the mitigation actions on the waterbody.

The benefits arise from reducing impingement by the full amount of the 316(b)Phase II rule's performance standard relative to baseline conditions.

The economic benefits of reduction in impingement have been specified by the EPA in its evaluation of the national benefits of the rule. The classes of benefits identified by EPA in its assessments include direct use benefits (e.g., those form commercial and recreational fishing), indirect use benefits (e.g., increased forage organisms), and existence, or passive use benefits (e.g., improved biodiversity).

Restoration is a component of the cost/benefit approach.

The ability of a restoration project(s) to generate benefits to offset impingement must be demonstrated.

This requires a method that can be used to quantify restoration benefits in a manner comparable to impingement effects in the ecosystem.

WCGS restoration method and measures are described in Appendix B. Kansas Department of Wildlife and Parks (KDWP), formerly known as Kansas Fish and Game Commission, have accepted this methodology, the use of CCL as a fishery under a re-stocking program, being used by WCGS. KDWP's letters asserting that CCL is a fishery can be found in Appendix E.1.5.2 Evaluation of a Site-Specific BTA None of these methods described in the above paragraphs are viable and a site-specific BTA is not sought along with the use of other technologies and operational measures to meet compliance with the 316(b) Phase II rule. A restoration measure is the only true alternative resource left for WCGS to implement.

WCGS use of a restoration measure is described in Section 7.0, Restoration Plan and will be use to offset impingement losses.10

2.0 Source

Water Physical Description The Coffey County Lake (CCL), sometimes referred to as Wolf Creek Cooling Impoundment, is located on Wolf Creek Generation Station (WCGS) site. WCGS is located in Township 20 and 21 South, Range 16 East of the Sixth Principal Meridian, and Township 20 and 21 South, Range 15 East of the Sixth Principal Meridian.

Of the 11,662 acres possess by our owners, the site occupies 9818 acres, and 1,844 acres lie outside of the site boundary.

The acreage not used for WCGS is managed for wildlife and agricultural purposes.

Areas modified by construction of WCGS include 135 acres for the station, 60 acres for the cooling impoundment dams and dikes, and 5090 acres for the cooling impoundment.

A "main" earth dam constructed across Wolf Creek and five saddle dams built along the periphery of the impoundment forms CCL. The main dam is located about seven stream miles from the Wolf Creek and Neosho river confluence.

The tops of the dams are at an elevation of 1,100 feet above mean sea level (MSL) to provide sufficient freeboard.

Service and auxiliary spillways with ogee crests of 1,088 feet MSL and 1,090.5 feet MSL respectively are provided on the east abutment of the main dam to prevent overtopping of the dams by the probable maximum flood and wind and wave action. The normal operating elevation of the cooling impoundment is 1,087 feet MSL. At this elevation the impoundment has a capacity of 111,280 acre-feet and a surface area of 5,090 acres.A major source of makeup water to the cooling impoundment is the conservation storage of the John Redmond Reservoir, providing that the low flow downstream requirements are satisfied.

Additional makeup water is supplied by natural runoff from the Wolf Creek watershed and direct precipitation on the cooling impoundment surface.The topography within Wolf Creek watershed varies from undulating hills upstream of the station site to a floodplain area shared with the Neosho River.The Wolf Creek watershed has a drainage area of 35 square miles. About 27.4 square miles of the 35 square mile Wolf Creek watershed will be upstream of the main dam. The cooling impoundment has altered the draining pattern of the watershed.

Within the impoundment two baffle dikes and two canals having inverts at 1,070 feet MSL are built to prevent short circulating of the water flowing from the circulating water discharge to the Circulating Water Intake Structure.

The impoundment canals are 215 feet wide with slopes of the canal sides at 1 foot vertical per 3 foot horizontal.

The volumetric water rates in these canals are assumed to be 1256 cfs at a water velocity of 0.87 fps when the impoundment water level is at 1087 MSL.11

7 N W+E 8 0 0.5 1 2 3 LEGEND= County Boundary Lakes and Water'/Urban Areas I

3.0 Circulating

Water Intake Structure (CWIS) Description The CWIS is a shoreline intake structure located at 380 14' 00" latitude and 950 41' 15" longitude.

One hundred percent (100%) of the cooling water flow is used for cooling purposes.

The CWIS is in use providing cooling water flow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven days a week. The only time there is no flow through the CWIS is when both the circulating water and service water system are inoperable.

The CWIS houses three circulating water pumps situated one to each of its three bays. Under normal conditions all three pumps will be operating at a total capacity of 1178 cubic feet per second (cfs). Three service water pumps are also housed in the CWIS. Normally, two service water pumps will be operating at a total capacity of 90 cfs, with one pump serving as a standby. A low-flow and startup pump with a capacity or 14.5 cfs is also provides for the service water system. In addition, the fire protection diesel and electric fire pumps are locates in the CWIS, which will draw water from the MWIS bays. The CWIS contains a bar grill, conventional traveling screens, and strainers.

Also, WCGS employs an ice control system in front of the CWIS using hot water recirculation from the steam condenser and air bubbles.The CWIS sump floor is located at an elevation of 1058 feet MSL. A steel plate is provided at the sump inlet of the CWIS as a weather protection device. This steel plate extends downward from the MWIS operating floor (1092 feet MSL) to 1075 feet MSL. The velocities of the circulating water and service water flow downstream of the steel plate are essentially independent of the cooling impoundment water level.The circulating water and the service water flow from the cooling impoundment through bar grills (trash racks) into bays where the traveling screens are located.The bar grills are used for removing the larger debris. Smaller debris is collected on the traveling screens. The traveling screens, operated intermittently, are backwashed with water drawn from WCCI. This screen wash system is activated normally by a timer or automatically from a high-differential pressure switch.Trash collected on the traveling screens is backwashed to a trash basket. This trash is manually disposed of at Coffey County Landfill.

There are no provisions for returning fish that survive impingement to WCCI unless they are small enough to pass through the trash basket openings.The circulating water is pumped from the intake structure bays through a 12 foot-diameter inlet pipe to the steam condenser, which is designed to increase the circulating water temperature 340 to 420 F at full operating load. The warmed water then will be flow from the condenser through a 12 foot-diameter outlet pipe to the outfall structure.

At the discharge structure the circulating water will be released into a well. The water will then flow over the crest of this well into the cooling impoundment.

Hold up times of the circulating water in the inlet pipe, the condenser, and the outlet pipe are about 3 minutes, 18 seconds, and 2 minutes, 15 respectively.

The discharged water takes approximately 38 days to travel from the discharge outfall to the intake structure.

The service water is pumped from the intake structure bays through a 42 inch-diameter pipe to the station's heat exchangers.

There it will be heated about 100 F and discharged into the 12 foot-diameter pipe containing the circulating water flowing from the steam condenser to the outfall structure.

The service water also supplies cooling water to the essential service water system during normal operations.

Water returning from the essential water system is returned to CCL.Based on the total (circulating water and service water combined) flow rate of 1256 cfs, the average inlet water velocities are calculated to be: Approach velocity to the CWlS: 0.87 feet per second Velocity through the bar grills: 1.06 feet per second Approach velocity to the traveling screens: 1.06 feet per second Velocity through the traveling screens 1.95 feet per second The CWIS bar grill, located at the inlet of the intake bays, is comprised of 1-inch vertical bars spaced at 3-inch intervals.

There are six traveling screens with two traveling screens per bay. The traveling screens are of a vertical single entry/exit type with a standard 0.375-inch mesh made by Envirex in 1982.16

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4.0 History

of Aquatic Biota Studies WCNOC conducted pre-operational (1973-1984) and operational (1985-1987) monitoring studies of Neosho River and Wolf Creek fish populations.

These studies were intended to establish baseline conditions with regard to Neosho River and Wolf Creek fish populations and, later, to identify possible changes in these populations associated with construction and operation of WCGS.WCNOC surveys of the Neosho River (from John Redmond Reservoir tailwaters to below Wolf Creek) over the 1973-1987 period yielded 52 fish species, with 13 species appearing in samples in every year. Electrofishing and seine data from pre-operational period (1977-1982) and an operational period (1985-1987) were pooled to examine species composition and relative abundance.

In all years, collections were dominated by Cyprinids (minnows and common carp) and Clupeids (gizzard shad). Cyprinids made up 61.2 percent of all fish collected in the 1977-1982 pre-operational period and 73.0 percent of all fish collected in the 1985-1987 operational period. Shad made up 16.4 percent of fish collected in the pre-operational period and 16.8 percent of the fish collected in the operational period. Comparisons of other groups (Ictalurids, Catastomids, and Centrachids) showed relatively small shifts in the abundance between pre-operational and operational phases.Having monitored Neosho River fishes from 1973 to 1987, WNCOC concluded that construction of Coffey County Lake (CCL) and operation of WCGS had little of no effect on Neosho River fishes. Changes in relative abundance were seen between the years, but were relatively small and related to factors entirely outside of WCNOC's control. Weather, in particular, appeared to influence fish populations in the Neosho River downstream of John Redmond Reservoir.

Rainfall up-river in the basin determined the volume of water released downstream into the Neosho River. The amount (and timing) of water released downstream affects reproductive success of species that spawn in the river, survival and growth of larval and juvenile fish, age and growth of adult fish, movement of all ages and stages of fish, and predator-prey relationships.

All of these elements shape fish populations in the Neosho River in the vicinity of WCGS.Having established the WCGS was having little of no impact on the Neosho River fish populations, WCNOC shifted its focus in 1988 from the Neosho River to CCL. Just as significantly, WCNOC transitioned from monitoring fish populations for possible station-related changes to monitoring fish populations in order to more effectively manage them. The primary fishery management goal in the years after Coffey County lake filled (reached normal operating level in 1982)was gizzard shad control; specifically limiting numbers of young shad in the lake because they were vulnerable to cold shock. The concern was that cold-killed and cold-stunned gizzard shad could clog WCGS's intake screens. Sudden plant 23 shutdowns and cold shock are more of an issue at single unit nuclear plants, like WCGS, than multiple-unit plants because there are no additional units to moderate the sudden temperature change.Before CCL reached full pool in 1982, WCGS embarked on an "aggressive" stocking program with the goal of establishing a fishery with a diversity of predators.

Species stocked in smaller impoundments within basin to be flooded included largemouth bass, smallmouth bass, channel catfish, blue catfish, bluegill, black crappie, and walleye. Once filled, more of these species and wipers (stripped bass/white bass hybrids) were added. Gizzard shad larvae were unavoidably introduced to the lake from the. Neosho River when water was pumped to fill the lake. White bass and white crappie also appeared after the lake filled, and are presumed to have been introduced the same way. No fishing was allowed in the lake in the 1980s, so there was no risk of sport fish populations being overfished.

The ultimate goal was a "cropped" prey (gizzard shad) population with a relatively high proportion of larger, older, individuals and low reproductive potential and a diverse, fast-growing community of predators with the ability to take different ages and sizes of shad occupying different parts of Coffey County Lake.After the lake was opened to fishing (October 1996), gamefish populations were managed both to control shad and provide local and regional anglers with high-quality fishing. In June 1998, Coffey County assumed responsibility for managing public use of the Wolf Creek Cooling Impoundment and changed the name of the lake to Coffey County Lake (CCL).Coffey County Lake, with its thriving populations of channel catfish, white crappie, smallmouth bass, walleye and wipers, has become a popular destination for Kansas's anglers. WCNOC closely monitors fish populations in CCL in order to draft annual fisheries management plans that will satisfy the complementary goals of controlling gizzard shad numbers and maintaining healthy population of gamefish.

WCNOC uses a variety of gear types (e.g., electrofishing, fyke netting, gill netting, and seining) and sample CCL in systematic fashion to ensure that species of interest are effectively sampled and sampling results area amenable to statistical analysis.

Fish are collected in spring, summer, or fall, depending on the species and its seasonal habitat preferences.

Sampling is intended to gather information on gizzard shad reproduction, survival, and abundance and predator (largemouth bass, smallmouth bass, white bass, wiper, and walleye) age and growth, condition, and abundance.

Having established population characteristics (size and age distribution, year class strength, actual and relative abundance) and compared population data to previous years, WCNOC submit annual fisheries monitoring reports and management recommendations to WCGS's Manager of Regulatory Affairs.These findings are also discussed with Kansas Department of Wildlife and Parks fishery biologist, who then draft regulations for CCL for WCNOC review. When 24 both organizations are satisfies with the proposed regulations, KDWP biologist submit these regulations to the Kansas Wildlife and Parks Commission, which typically approved them. Regulations approved by the Commission are adopted and made enforceable by order of the Secretary of Wildlife and Parks.Stocking Record of Coffey County Lake Species Date(s) Number Location Flathead Minnow 08/78 56,000 Subimp.Largemouth Bass 08/78 3,500 Subimp.Flathead Minnow 09/79 75,000 Subimp 11/79 52,000 Subimp.Bluegill 09/79 5,000 Subimp.Smallmouth Bass 11/79 40 Subimp.Largemouth Bass 09/79 2,400 Subimp.Flathead Minnow 05/80 90,000 UHS 06/80 65,000 UHS 08/80 270,000 Subimp.09/80 57,500 Subimp.Bluegill 05/80 130 Subimp.06/80 3,150 UHS 08/80 16,000 Subimp.09/80 12,700 Subimp.Red-ear Sunfish 08/80 2,000 Subimp.Black Crappie 10/80 1,000 Subimp.Smallmouth Bass 08/80 500 Subimp.Largemouth Bass 06/80 6,000 UHS 10/80 1,000 Subimp.Striped Bass 06/80 1,200 UHS Walleye 06/80 7,000 UHS 07/80 5,000 UHS Blue Catfish 10/80 35,000 CCL Channel Catfish 05/80 100 Subimp.06/80 3,100 UHS 08/80 25,000 Subimp.10/80 25,000 CCL Striped X White Bass Hybrid 05/81 50,000 CCL Subimp = Sub-impoundment of CCL UHS = Ultimate Heat Sink Basin CCL = Coffey County Lake 25

5.0 Proposal

for Information Collection Development of a restoration plan is proposed by Wolf Creek Nuclear Operating Corporation (WCNOC) to meet applicable Clean Water Act 316(b) requirements.

WCNOC proposes to continue the current fishery management program that monitors and promotes relatively high predator species densities compatible with the ecology of Coffey County Lake (CCL). High predator densities have discouraged large concentration of small forage fish, primarily gizzard shad, which in turn has supported WCGS operation by keeping impingement rates low.The fishery also provides regional recreational benefits.Fishery management has involved periodic stocking to support predator fish populations.

The need for future stockings will be determined based on annual monitoring data. Other restoration measures, such as habitat enhancement or nuisance species removal, will be considered as needed to support the current fishery.5.1 Sampling Plan and a Student Research and Training Grant Wolf Creek Nuclear Operating Corporation (WCNOC) entered into a graduate level research project with Pittsburg State University to help quantify environmental interfaces with Wolf Creek Generating Station (WCGS) operation.

This partnership enhanced WCNOC's ability to address these issues in a cost efficient manner. For the university, it helped prepare the students in a field where such skills will likely be in demand in the utility industry.

The environmental interfaces that were researched are industry wide issues, with many utilities likely to contract with consultant firms, which will need biologists to conduct similar research.For WCNOC, primary issues include recently promulgated Clean Water Act 316(b) regulations, and station re-licensing issues with impingement and entrainment aspects of fish and aquatic organisms at the cooling water intake.Information on impingement and entrainment effects will also be useful for fishery management considerations to maintain low gizzard shad densities.

Impingement refers to impacts to the environment due to larger fish and other organisms being trapped on the traveling screens, which is both a 316(b) and re-licensing issue. Entrainment refers to impacts due to smaller aquatic organisms being pumped through the plant, which is primarily a re-licensing issue. Note: For the purposes of this Comprehensive Demonstration Study (CDS) submittal only impingement will be discussed.

An entrainment study is not required for an intake structure on lake and reservoir.

The product desired from the graduate research will be to collect, analyze, and prepare a manuscript suitable for submittal to a peer-reviewed publication.

All research is to be conducted in an unbiased manner. WCNOC will reserve the right as a coauthor for any publication.

26 As required in 40 CFR 125.95(b)(3), the results of the impingement sampling program will be summarized in this submittal that will answer the following environmental question: What is the fish mortality rate due to impingement at WCGS? This would include; fish density estimates by species in the intake area of CCL, determination of fish numbers at the intake screens that were dead before being impinged on the screens, and annual impingement rates sufficient to confidently extrapolate total plant impacts to the fishery.5.2 Wolf Creek Fish and Shellfish Impingement Study 5.2.1 Study Objectives A. Determine fish community vulnerable to impingement B. Determine impingement C. Evaluate water quality D. Evaluate the factors contributing to impingement

5.2.2 Study

Procedures A. In order to determine the fish community vulnerable to impingement:

1. Existing WCNOC fish data will be used to establish historical trends for seasonal changes in: a. species composition

b. relative abundance c. length frequency 2. Ongoing sampling by WCNOC along with some targeted efforts using electro-fishing, trap-nets, gillnets and hydro-acoustics (if practical) will be used to establish current seasonal changes in the intake area.B. In order to determine impingement rates: 1. Screen-wash catch basket surveys will be conducted every eight hours for a 24-hour period on a monthly basis, with more frequent surveys during peak impingement periods. Information collected will include: a. species composition

b. length frequency 27

c. pre-impingement mortality C. In order to evaluate water quality influences, measurements will be taken to determine:

1. DO profiles 2. Temp profiles 3. Turbidity D. In order to evaluate the factors contributing to impingement:

1. Vulnerable species composition, length frequencies, and density estimates will be compared to: a. time of year b. time of day c. dissolved oxygen d. Water temp e. WCGS operating conditions

f. Screen-wash number g. Screen-wash species composition

h. Screen-wash length frequencies

i. Natural mortality, as measured at screen-wash

j. Water clarity k. upstream temperature I. upstream dissolved oxygen m. upstream water clarity n. plant operating conditions 28

6.0 Impingement

Mortality Characterization Study Wolf Creek's quantitative impingement study is described below, and is designed to review fish impingement over the spring, summer, fall and winter periods.Precision and reliability of reduced sampling designs may be affected by the number of sampling days selected at various times of the year, particularly if the impingement rates of individual fish species are of interest.Intuitively, we suspect that impingement of key species in WCCI tends to be highest in the winter and lowest in the spring. Sampling may therefore be more intense (2-3 days/month) during the key impingement months (December

-February), and less intensive during other seasons (1 day/month).

This sampling design would allow about 15 days of sampling and ensure reasonable precision and reliability.

Sampling over a 24-hour period will measure any diurnal influence to impingement.

The research is scheduled for two years to account for any weather variations.

7.0 Restoration

Plan Wolf Creek can use restoration measures when design and construction and/or operational measures are less feasible, less cost-effective or less environmentally desirable.

Wolf Creek's restoration plan is basically a restocking program designed to maintain a desirable fishery in WCCI based on our annual fishery monitoring report (see Appendix A). The WCCI restocking program was initiated in 1978 and continues today. The Environmental Management group prepares the annual fishery monitoring report.This report targets three issues that need to be addressed prior to restocking WCCI. They are; (1) young-of-year (YOY) gizzard shad changes, (2) adult shad and predator fish population dynamics, and (3) angler harvest impacts to the fishery.First, knowledge of YOY shad production is important because these fish pose the most immediate impingement threat to plant operations.

Identifying increases in YOY numbers before winter temperatures make them vulnerable to impingement will allow operational preparations to compensate for the increased risk of impingement.

Second, the characteristics of the adult fish population provide long-term data to evaluate if YOY shad control benefits will continue.

Higher numbers of shad growing to reproductive size is an indication that less predation is occurring.

Likewise, fewer predator fish growing to reproductive size would indicate declining shad control capabilities.

Increased predator fish health would also indicate this. Stocking recommendations also are derived from the adult fish characteristics 29 Lastly, the adult fishery monitoring will provide information on angler harvest impacts to the fishery. Proper length limit recommendations can be derived from the monitoring data to ensure that public angler harvest and the plant's gizzard shad control efforts remain compatible.

Creel census data collected by Coffey County at the lake access park will be reviewed and compared with the other fishery sampling data.8.0 Verification Monitoring Plan The purpose of the verification-monitoring program is to provide the Environmental Management group with information regarding the WCCI fishery.A variety of sampling gears are used to assess the condition of adult and juvenile classes of both prey and predator species to provide information on potential impingement impacts to station operation.

In addition, the methods employed will assess the effects of station operation and angler harvest on the fish populations in WCCI.An annual report, the Fishery Monitoring Report, detailing the fishery monitoring activities and results are compiled.

Any trend's influence on the ability of the fishery to control fish impingement events, which may affect WCGS operations, will be identified.

In addition, WCGS Operations will be notified, if necessary, of the possibility of increased shad impingement that may be expected during the winter. Any adjustments to angling length and creel limits will be proposed.Recommendations that may include increased monitoring or stocking needs will be presented.

A summary of the fishery monitoring activities will be completed by April of each year.30 9.0 CWIS Impingement 316(b) Determination Kansas Department of Health and Environment (KDHE), Bureau of Water (BOW), has not as of this time, made any Clean Water Act 316(b) determination for cooling water intake structures on either a river, lake or reservoir.

The recently renewed NPDES permit, February 1, 2005, for WCGS takes into account the new EPA 316(b) Phase II regulations, 40 CFR Part 125.95 et seq.requirements for once-through cooling systems. The permit requires the applicant to conduct a study of the cooling-water intake for potential adverse environmental impacts in accordance with Section 316(b) of the Clean Water Act and to submit to KDHE the required information by June 2008. Any requirements resulting from the water intake study would be reflected in future NDPES permits.9.1 Impact of Fish and Shellfish Resources from Impingement Cooling Water Source The Circulating Water System (CWS), Service Water System (SWS), and the Essential Service Water System (ESWS) at WCGS all draw from and discharge to Coffey County Lake (CCL), formerly known as the Wolf Creek Cooling Lake.CCL is located on the WCGS site. A "main" earth dam constructed across Wolf Creek and five saddle dams built along the periphery of the impoundment forms CCL. The main dam is located about seven stream miles from the Wolf Creek and Neosho river confluence.

The tops of the dams are at an elevation of 1,100 feet above mean sea level (MSL) to provide sufficient freeboard.

Service and auxiliary spillways with ogee crests of 1,088 feet MSL and 1,090.5 feet MSL respectively are provided on the east abutment of the main dam to prevent overtopping of the dams by the probable maximum flood and wind and wave action. The normal operating elevation of the cooling impoundment is 1,087 feet MSL .At this elevation the impoundment has a capacity of 111,280 acre-feet and a surface area of 5,090 acres.This 5,090-acre reservoir is designed to provide adequate cooling water to the plant during a one-in-fifty-year drought. To maintain the water level in the CCL, it is sometimes necessary to pump makeup water to the CCL from the Neosho River, just below the John Redmond Reservoir dam.Within the impoundment two baffle dikes and two canals having inverts at 1,070 feet MSL were built to prevent short-circuiting of the water flowing from the circulating water discharge to the Circulating Water Intake Structure.

The impoundment canals are 215 feet wide with slopes of the canal sides at 1 foot vertical per 3 foot horizontal.

The volumetric water rates in these canals are assumed to be 1256 cfs at a water velocity of 0.87 fps when the impoundment water level is at 1087 MSL. WCGS cooling water system configuration is considered a once-through cooling water system. Figures 1, provides a simplified drawing of the cooling lake and John Redmond Reservoir System.31 Circulating Water System The Circulating Water Screenhouse (CWSH) is located in the southeast corner of the main plant area on the shore of the cooling lake. The screenhouse contains the major equipment associated with the circulating water system (CWS) and the service water system (SWS).The CWS operates continuously during power generation, including startup and shutdown.

Three one-third capacity motor-driven, vertical, wet-pit circulating water pumps pump the circulating water from the cooling lake to the main condenser.

They are designed to operate through-the expected range of cooling lake levels. The heated water discharged from the condenser is returned to the cooling lake through a CWS discharge structure.

The main circulating water pipes from the circulating water screenhouse to the power block and from the power block to the discharge structure have an inside diameter of 144 inches.Freeze protection to prevent ice blockage at the circulating water screenhouse is accomplished by a warming line that routes a portion of the circulating water condenser discharge to the inlet of the screenhouse pump bays.The SWS consists of three one-half capacity service water pumps and one low flow and startup pump, traveling screens and automatic backwash strainers, all located in the screenhouse.

During normal plant operation, the SWS supplies cooling water to the turbine plant auxiliary equipment, steam generator blowdown nonregenerative heat exchanger, and CVCS chiller, as well as components served by the ESWS. The service water system is the normal water supply for the Demineralized Water Makeup System.The circulating water and the service water flow from the cooling impoundment through bar grills (trash racks) into bays where the traveling screens are located.The bar grills are used for removing the larger debris. The CWIS bar grill, located at the inlet of the intake bays, is comprised of 1-inch vertical bars spaced at 3-inch intervals.

There are six traveling screens with two traveling screens per bay. The traveling screens are of a vertical single entry/exit type with a standard 0.375-inch mesh made by Envirex in 1982. Smaller debris is collected on the traveling screens.The traveling water screens are operated as per system operating procedures.

The traveling water screens can be rotated and backwashed, manually or automatically, due to differential pressure across the screens. Debris is automatically deposited in a basket for periodic removal by plant personnel.

The plant service water return discharges into the circulating water discharge.

This discharge is directed to the station cooling lake. Each service water pump is sized to deliver 25,000 gpm (-58 cfs) of service water at a discharge pressure of approximately 185 feet. Each circulating water pump has a design capacity of 32 167,000 gpm (-372 cfs) at a corresponding developed total head of 74 feet of water.The CWIS sump floor is located at an elevation of 1058 feet MSL. A steel plate is provided at the sump inlet of the CWIS as a weather protection device. This steel plate extends downward from the CWIS operating floor (1092 feet MSL) to 1075 feet MSL. The velocities of the circulating water and service water flow downstream of the steel plate are essentially independent of the cooling impoundment water level.Three pumps provide the design flow rate of approximately 500,000 gallons per minute when lake water temperatures are greater than 50 OF. Because condenser cooling is more efficient with colder intake water, only two pumps are operated with a design flow of 365,000 gallons per minute when lake temperatures are below 50 OF. At these pumping rates, design flow across the rotating screens at the point of impingement is less than 1.0 fps.9.1.1 Assessment Data from impingement surveys conducted monthly at WCGS over the December 2004 through March 2006 period were used for this assessment.

A fine-mesh (0.25 inch bar mesh) collection basket was placed in a catch basin to collect all fish washed from traveling screens over a given 24-hour period. The basket was necessary because small fish are able to move through the grate at the base of the catch basin and re-enter the CCL.Fish were removed from the basket every eight hours and identified, measured, and examined in order to ascertain their condition.

Each fish was classified as"live," "recently dead," or "dead" based on its physical condition.

All fish categorized as "dead" based on examination were considered dead before they were impinged on the traveling screens. These fish represented natural mortality in CCL. Fish categorized as "recently dead" were assumed to have been alive when impinged, and died in the collection basket as a result of exposure and oxygen deprivation.

Because the traveling screen wash passes though a trash grating (with 1 inch by 3.75 inch openings or 2.54 centimeters by 9.53 centimeters) at the point at which it leaves the Circulating Water Screenhouse (CWSH) and flows into CCL, the following assumptions were employed in extrapolating monthly and annual rates of impingement mortality from basket surveys:* All fish greater than 100 mm total length (TL), no matter their condition in the collection basket, would die under normal circumstances because they would not likely pass through the openings in the trash grating.33

• All fish in the collection basket less than 100 mm TL categorized as "live" or "recently-dead" would, under normal circumstances, return to the CCL and survive.Table 1 shows how length and condition of fish were used to "bin" fish in order to extrapolate monthly and annual impingement totals based on fish length.Table 1. Basis for adjusting monthly and annual estimates of impingement samples due to fish length and condition.

Fish Length Condition Assumption

> 100 mm TL Dead Natural mortality Recently dead Impingement mortality Live Impingement mortality* 100 mm TL Dead Natural mortality Recently dead Would have survived Live Would have survived Fish size and condition were subsequently used to determine if fish would have returned to the reservoir and survived, had the collection basket not been in place. After these adjustments, data from 24-hour basket surveys served as the basis for estimates of monthly and annual impingement mortality rates, and their impact to the CCL environment.

To extrapolate monthly and annual impingement rates, the number of fish/shellfish collected over a given 24-hour period was multiplied by the number of days in a month. The monthly totals were summed to calculate annual totals. Because no data were available from April 2005, when the plant was down for re-fueling, the impingement rates for March and May 2005 were evaluated for use as surrogates:

the May data was ultimately used because it reflected a much higher rate of impingement, thus was conservative.

Similarly, March 2006 data were used for February 2006 extrapolation.

For annual impingement rates, only 2005 data were used to capture all four seasons and corresponding lake conditions.

9.1.2 Results

9.1.2.1 Data The following overview represents simple gross numbers observed, and is not from data adjusted for non-impingement impact considerations.

Consequently, this general review is a conservative assessment only. A total of 420 fish and 104 shellfish (crayfish and Corbicula, (Asiatic clam)) were collected in impingement samples at WCNOC over the December 2004 -March 2006 period (Table 2). Five fish species represented 93 percent of all impinged fish: freshwater drum (33 percent of fish collected), white crappie (23 percent), gizzard shad (21 percent), bluegill (11 percent), and channel catfish (6 percent).

Smaller numbers of white bass, buffalo, walleye, smallmouth bass, and flathead catfish 34 were also collected, but none of these species comprised more than four percent of the total. Eighty-seven Corbicula and 17 crayfish were also collected over the 16-month period. Both operators of power plants and fish and game agencies regard the non-native Corbicula as a nuisance species across the U.S. This species clogs power plant cooling water systems and out-competes and displaces native freshwater mussels. Any Corbicula losses at WCGS are regarded as beneficial.

The small number of crayfish impinged (approximately one per day) is presumed to be less than the number consumed by a single, actively feeding adult smallmouth bass per day. Because all shellfish were small enough, and were considered hardy, none were considered as impacted by impingement.

Approximately 52 percent of all fish and shellfish impinged were found dead in the collection basket. Gizzard shad, a species known to be fragile and subject to winter-kills (Scott and Crossman 1973; Klemesrud 2003; Schoenung 2003), showed the highest mortality rate, 63 percent. Freshwater drum also showed a fairly high rate of mortality, 58 percent. Mortality rates for bluegill, channel catfish, and white crappie were 48 percent, 46 percent, and 31 percent, respectively.

Catfish species are exceedingly hardy and able to tolerate low levels of dissolved oxygen (SRAC 1988; Smitherman and Dunham 1993; Pennsylvania Angler &Boater 2001) so it is not surprising that they showed lower rates of mortality.

9.1.2.2 Analysis For actual impact, data were adjusted by removing the fish justified as being non-impingement related, the daily (actual) impingement rates of fish in Table 3 yielded estimated monthly impingement rates ranging from 0 to 1,612. A annual total of 957 fish and no shellfish were estimated to have died as a result of being impinged (Table 3). This corresponds to impingement mortality rates of 30.8 percent for finfish and zero percent for shellfish.

The highest rates of impingement were observed in late spring-early summer (May and June) and fall-early winter (November and December).

Water temperatures in the 30s and low 40s OF were generally associated with higher rates of impingement and impingement mortality for all fish species, but trends were less than clear-cut.

The lowest temperature observed over the 16-month period (37.5 °F in January 2005) was associated with a fairly low impingement.

Although no statistical tests were performed, there appeared to be no correlation between cooling water withdrawal rates and impingement mortality (Figure 1). Highest impingement rates were often associated with operation of two circulating water pumps; lowest impingement rates were often associated with operation of three circulating water pumps. This suggests that environmental factors influence impingement as much or more than operational factors. These environmental factors include meteorology (frontal movement, specifically air temperature, wind speed, wind direction), water quality (water temperature, dissolved oxygen levels at depth), and biology (distribution and abundance of species that are vulnerable to impingement, such as gizzard shad; overall health of the fish community; size 35 and age composition, as smaller fish are more vulnerable, relatively, than larger fish, which are stronger swimmers).

9.2 Impingement

at WCGS Relative to CCL Fishery 9.2.1 Important Species in CCL To determine the fishery's susceptibility to WCGS impingement impacts, a review of species present and those considered important for long term recreational and commercial (industrial) value is necessary.

Fish species present are common to reservoirs in Kansas (Cross and Collins 1995) and are listed in Table 4. The present fishery reflects WCNOC management efforts to biologically control impingement rates by promoting predator species. This continuing effort was undertaken to minimize impingement impact to the lake environment, and to prevent the economic and operational difficulties that could be caused by excessive impingement, particularly gizzard shad. Problem impingement on intake screens can develop because gizzard shad have difficulty avoiding intake flows when they naturally become weakened, and eventually die, as winter water temperatures fall below approximately 40 'F (Bruce NGS 1977, Ontario Hydro 1977, Olmstead and Clugston 1986, White et al 1986). Predator (game) species that are considered important at WCGS to control impingement include species that are also important for recreational purposes.

These include channel catfish, white bass, wiper hybrids, smallmouth bass, largemouth bass, white crappie, and walleye (Tables 5 and 6). WCNOC's fishery management efforts revolve around eliminating excessive gizzard shad wintertime impingement events that can create operational challenges to the circulating water screens. This effort has been successful with shad densities kept low (Table 7). Still, shad are an important forage species in CCL, and critical for the well being of predators in the lake. Reductions caused by natural predation, or other influences, such as winter die-offs or WCGS impingement, cannot be greater than the population can recover from. Extremely low shad densities would cause subsequent reduction in important predator species (Haines 2000). Consequently gizzard shad are considered an important species in CCL, and potential impacts from impingement must be balanced.

There are no listed threatened or endangered fish species known to be present in CCL, nor are any expected.

For the purpose of this evaluation, the commercially important species are considered those important for electricity production at WCGS as explained above. Species used for the commercial food market include buffalo species and common carp.However, there is currently no plans to allow commercial harvest on CCL, thus there should be no impingement impacts expected, and no further assessment will be needed. Additional details on CCL fishery can be found in WCGS's Annual Fishery Monitoring Report and Plans (WCNOC 2006).9.2.1.1 Channel Catfish As previously established, channel catfish are typically hardy, and all but one that were sampled were < 100 mm TL, and thus would have returned to CCL alive 36 (Table 3). For assessment purposes on an annual basis (2005 data), adjusted estimates indicate no mortality attributable to WCGS. Thus, impingement impacts to the channel catfish population in CCL were considered inconsequential.

9.2.1.2 White bass White bass are common to reservoirs in Kansas, and can be highly productive (Colvin 1993). They are a pelagic (open water) species, highly mobile, and are common in the vicinity of the circulating water intake. This may tend to expose them to impingement.

This is reflected by the annual adjusted impingement estimate of 122 (Table 3), and these were all judged to be young-of-year fish.Based on annual catch frequencies, the white bass population in CCL has remained relatively consistent, with normal fluctuation (Table 7). Extrapolating total white bass densities in CCL to estimate impingement percentage was not possible due to the passive sampling gear used (gill nets). Survival rates for CCL white bass were unavailable, but average survival in regional reservoirs ranged from 21 to 52 percent and averaged 35 percent (Colvin 1993). Growth rates in CCL, as well as regionally (Colvin 1993), indicate that it would take approximately three years for white bass to reach 12 inches (305 mm) TL, which is the current minimum length for recreational harvest. Using average survival of 35 percent, the 122 white bass removed from the CCL population by impingement would be 5.2 fish by the time they are available for harvest. This would be from 0.3 to 1.4 percent of the annual recreational harvest from 1999 through 2005 (Table 5). Because white bass are highly productive, and the small percentage of the fish made unavailable, impingement is judged to not pose a threat to the fishery in CCL.9.2.1.3 Wiper Hybrids, Smallmouth bass, and Largemouth Bass Of the important predator species, there were no wiper hybrids or largemouth bass found in the impingement samples, and only one smallmouth bass observed, which was judged as dead before being impinged (natural mortality).

Fishery sampling by WCNOC indicates catch rates for these species to vary (Table 7). The wiper hybrids were hatchery spawned, and their densities were controlled by WCNOC stocking, which was based on shad control needs. As hybrids, they have not reproduced sufficiently to maintain a population.

Largemouth bass have experienced a long-term decline typical of aging reservoirs (Kimmel and Groeger 1986, Willis 1986). Because these species were not found in the catch basket, they are not considered to be adversely impacted by impingement.

9.2.1.4 White Crappie White crappie is the game fish species with the highest adjusted annual impingement estimate of 185 fish (Table 3). It is an important recreational 37 species, however, because of its current creel limit of only two fish per day, it is not a species sought after for consumption.

It is a species important for WCGS, though, because gizzard shad is major forage item (Cross and Collins 1995, Muoneke et al 1992). Most of the crappies impinged were slightly greater than the 100 mm TL used for data adjustment, and were young-of-year fish. O'Brien et al (1984) determined that crappie 80 to 170 mm TL were wholly pelagic.Smaller crappies have also been more often taken in open water than along the shoreline (Grinstead as cited in Carlander 1977). WCNOC observation also indicates such small crappie distribution in CCL. This would tend to explain the higher impingement for white crappie. The fish would be in the deeper, open water similar to that adjacent to the cooling water intake, and thus more susceptible to impingement.

Annual survival rates ranged from 23 to 29 percent for three Kansas reservoirs after length limits were instituted (Mosher 2000), and 46 percent for Lake Carl Blackwell in north-central Oklahoma (Muoneke 1992).Annual survival rates for CCL have not been calculated, however, it is believed to likely be toward the higher range due to relatively larger, longer-lived crappie present. The current length limit before crappies are available for recreational harvest is 14 inches (356 mm) TL, which is restrictive.

Average growth rates for CCL crappies indicate that they typically reach the length limit at four years of age. Applying the higher 46 percent survival rate to the adjusted impinged fish yields reductions from 185 after year one, to 85 after year two, to 39 after year three, and to 18 after year four. Accordingly, impingement would cause 18 crappies to be unavailable for recreational harvest. This represents from 2.5 to 9.8 percent of crappies harvested (Table 5). As stated earlier, restrictive creel and length limits suppress harvest rates for CCL crappies.

A more applicable impact comparison would be for recreational caught-and-released data, for which 18 impinged fish represents from 0.2 to 0.4 percent of the annual recreational catch (Table 6). In summary, white crappie was shown to be relatively vulnerable to impingement, and was the game species most impinged.

The relative percentage of crappie surviving to sizes available for recreational harvest was higher than other CCL species. However, due to restrictive harvest limits, these percentages may be inflated.

Percentages of the recreationally caught-and-released remained low. Consequently, impingement is not expected to adversely impact the CCL fishery, but this species may be more susceptible than other species evaluated.

9.2.1.5 Walleye Walleye is an important species both for WCGS operations and recreation.

During the entire impingement sampling period, only one was considered impinged, and this extrapolates to 30 walleye per year (Table 3). Catch curve regressions for 2003 and 2004 indicate total annual survival estimates for walleye of 41 and 17 percent, respectively.

Averaging these yields a total survival rate of 29 percent. At the current slot limit (18 to 26 inch protected) and at growth rates present in 2003 and 2004, the 30 walleye at 388 mm TL (length of impinged specimen) would remain available for recreational harvest for 38 approximately two years. Applying the 29 percent survival estimate, reductions to the extrapolated 30 impinged walleye would be 21.3 fish the first year, and an additional 6.2 fish the second year. This means that of the 30 impinged walleye, if similar impingement, survival, and growth continued annually, estimated annual loss to the recreational fishery would be 11.2 walleye (8.7 fish remaining after first year, plus 2.5 remaining after second year). This represents

<1.0 percent of the recreationally harvest annually (Table 5), and < 0.2 percent of the walleye caught and released by anglers (Table 6). Because a passive gear type (gill nets) was used to monitor walleye in CCL, total lake population density could not be estimated, only relative catch frequency changes (Table 7). Extrapolating these numbers based on one fish impinged is not statistically defensible, but it will provide in this circumstance a relative measure to assess impacts to walleye in CCL. Because the percent removed from the population was very small, there is no impingement impacts expected to the CCL walleye.9.2.1.6 Gizzard Shad Based on adjusted impingement data, gizzard shad represented the largest number of fish impinged on an annual basis (2005 data, Table 3). An adjusted total of 496 were considered impingement mortality during the sampling period.Using 2005 data as representative of annual mortality, the adjusted impingement mortality was 341 gizzard shad. An estimate of the total gizzard shad estimate from CCL could be derived from midsummer seine hauls from 1983 through 1997 (Haines. 2000). Average density estimates in CCL of similar sized shad over the 1983 through 1997 period were 3.005 million. Mortality attributable to impingement represents 0.01 percent of this average young-of-year population estimate.

Observed length of impinged shad would tend to further reduce any potential impingement influences.

Scale aging indicate that the larger adult brood fish achieved first year growth to approximately 200 mm TL, which is above normal growth (Haines 2000 and Appendix C). These fish were suspected to have been spawned in the heated discharge from WCGS earlier than normal, and were able to grow sufficiently to not be as susceptible to cold induced mortality (White et al 1986), were too large for predators, and not as susceptible to impingement.

All shad in the impingement samples were smaller young-of-year (approximately 100mm TL), and not as likely to survive in CCL to reach reproductive age. Thus, evidence shows that the sizes impinged would not be as likely to contribute on a long-term basis to the CCL fishery. In summary, gizzard shad is considered one of the most important species in CCL, and had the highest annual (2005) adjusted impingement rates. It was not considered impacted by impingement due to the extremely low percentage removed from the estimated population density. Shad age, growth and size distribution data also imply that the most important shad to the predator fishery were the earlier spawned fish that were able to recruit to reproductive sizes, and were not susceptible to impingement.

Therefore, impingement at CCL does not appreciably impact gizzard shad.3.9 Note: In the mid-80's LMS conducted a study where they captured gizzard shad heading into the intakes at the Quad Cities nuclear plant. The study found that during November through March, only 4 percent of the gizzard shad collected were healthy, the rest were dead or dying. Based on this result and a review of the low temperature physiology of gizzard shad, they recently proposed that 96.percent of shad collected in November through March be excluded from the calculation baseline.

John Dunn at EPA Region VII has concurred with this proposal.

There is no reason why this policy should not apply to the other states in Region VII. This policy is directly applicable to WCGS intake structure on Coffey County Lake. It is contended that none of the gizzard shad should be counted because mitigating for the impacts to these fish is likely to be counter to the fishery and management goals for CCL. See Appendix D.9.2.1.7 Other Species The remaining species were either considered as rough fish, or were infrequently found in the impingement catch basket. Consequently, these were not considered as recreationally of commercially important species as they relate to CCL and impingement.

9.3 Impingement

at WCGS Compared to Similar Plants 9.3.1 V.C. Summer Station (South Carolina)VC Summer Nuclear Station (VCSNS), in South Carolina, may be the nuclear plant most similar to WCGS in terms of design and cooling system. Both plants are single-unit Westinghouse PWRs with once-through cooling systems that withdraw and discharge to small cooling reservoirs.

Coffey County Lake, at 5,090 acres, is slightly smaller than Monticello Reservoir (6,500 acres). The 316(b) Demonstration for VCSNS indicated that an estimated 85,000 fish weighing 515 kilograms were impinged annually, which amounted to less than one percent of the reservoir's standing crop (Dames & Moore 1985). Highest rates of impingement were observed in winter, when large numbers of cold-shocked gizzard shad were impinged.

More than 80 percent of fish impinged over the 12 months of the study (October 1983 through September 1984) were gizzard shad. Other species commonly impinged were yellow perch, white catfish, bluegill, and channel catfish. Based on these impingement rates, which were approximately 20 times those seen at WCGS, the Dames & Moore 316(b)Demonstration concluded that "the number of fishes impinged by VCSNS appear sufficiently low so as to have minimal effect on the fish community." In April 1985, the South Carolina Department of Health and Environmental Control determined that the "location, design, construction, and capacity of the VCSNS cooling water intake structure reflects the best technology available for minimizing adverse environmental impact" (SCE&G 2002). This determination has been made a part of all NPDES permits issued since that time.40

9.3.2 North

Anna Power Station (Virginia)

North Anna Power Station, a two-unit Westinghouse plant near Mineral, Virginia, uses a once-through condenser cooling system that withdraws from and discharges to Lake Anna, a 9,600 acre cooling reservoir.

Virginia Power conducted impingement studies over the 1978-1983 timeframe to characterize impingement and entrainment at the plant. The total number of fish in screen wash samples ranged from 11,063 (1983) to 148,995 (1979) per year, which translated into impingement estimates of 45,591 and 583,530 fish, respectively.

Sixty-one percent of fish impinged were gizzard shad, many of which were cold-stressed.

Yellow perch (15.8 percent) and black crappie (15.7 percent) were the other species impinged in significant numbers. The authors of the NAPS 316(b)demonstration observed that total impingement and entrainment rates tended to track with abundance of gizzard shad, and declined markedly as the gizzard shad became less numerous in collections.

10.0 Conclusion Impingement studies conducted at WCGS over the December 2004 -March 2006 period suggest that impingement rates were very low in both absolute (number of fish) and comparative terms (relative to other nuclear plants of similar design), as was impingement mortality.

Impingement was selective for certain species (freshwater drum, white crappie, gizzard shad) and certain size and age classes (small fish that were not aged but were presumed to be young-of-year).

More than half of fish impinged were "rough fish" that are not avidly sought by recreational fishermen.

The white crappie was the only recreationally important species impinged in significant numbers. Most recreationally important species, including smallmouth bass and walleye, were impinged in very low numbers.Available data suggests that impingement has had little or no effect on fish populations in Coffey County Lake. Coffey County Lake, with its thriving populations of channel catfish, white crappie, smallmouth bass, walleye and wipers, has become a popular destination for Kansas anglers. Kansas Department of Wildlife and Parks (KDWP) issues annual Fishing Forecasts for public waters in Kansas, which are in effect ratings of public fishing areas.Coffey County Lake received biologists' rating of Excellent for walleye (the only state reservoir to receive this ranking for walleye) and smallmouth bass (the only state reservoir to receive this ranking for smallmouth bass) (KDWP 2004).Channel catfish, white crappie, white bass, and wiper fishing were all rated Good.Therefore, WCNOC concludes that impacts to fish and shellfish in the Coffey County Lake from impingement are SMALL and that mitigative measures are not warranted.

41 Figure 1 Simplified Drawing of Coffey County Lake and John Redmond Reservoir/ ~RU.NO)FY

& ED1RE.(T 4A.91:VP TO,, ST RUC T UV.R JOHN E COOLIr tAKE r PLANT""0LTJMATE RELEASFS EAT SINK MA (I )AýI SPILL F FLUENT$COOING LAXE -JOHN REDMOG4D RESERVOIR SYSTEM 42 Table 2. Total number of fish in im pinement samples.I Monthly Temp Date (1) GS RCS SBF CC FC WB BG SMB WC WAE FWD C. f. CR sp. Total OF Dec-04 30 0 3 7 0 8 12 0 27 0 98 2 1 188 38.5 Jan-05 20 1 0 2 0 0 0 0 0 0 0 0 2 25 37.5 Feb-05 0 0 0 1 0 0 0 0 0 0 1 0 1 3 45.2 Mar-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 47.5 Apr-05 0 0 0 0 0 0 0 0 1 0 0 0 0 1 64.9 May-05 0 0 0 0 0 0 1 0 1 0 0 33 1 36 70.2 Jun-05 22 0 0 0 0 0 5 0 0 0 0 20 1 48 81.8 Jul-05 3 0 0 0 0 0 1 0 1 0 2 6 2 15 85.8 Aug-05 2 0 0 0 0 3 0 1 10 0 7 1 2 26 80.7 Sep-05 0 0 0 0 0 0 1 0 1 0 3 15 1 21 79.9 Oct-05 0 0 0 0 0 1 0 0 0 1 1 4 0 7 67.6 Nov-05 1 0 0 1 0 2 26 0 33 1 0 2 0 66 57.8 Dec-05 10 0 3 5 1 2 2 0 19 0 19 0 4 65 40.5 Jan-06 0 0 0 3 0 0 0 0 1 0 1 3 2 10 45.1 Feb-06 0 0 0 0 0 0 0 0 0 0 0 0 0 0 42.0 Mar-06 0 0 0 5 0 1 0 0 2 0 4 1 0 13 46.4 2005 1 88 1 6 24 1 1 17 148 1 95 2 1 137 87 1 17 524 (1) Fish species abbreviations:

Gizzard Shad River carpsucker Smallmouth buffalo Channel catfish Flathead catfish White bass Bluegill GS RCS SBF CC FC WB BG Smallmouth bass White crappie Walleye Freshwater drum Corbicula fluminea Crayfish sp.SMB WC WAE FWD C.f.CRsp.43 Table 3. Estimated monthly impingement mortality for WCGS adjusted for fish considered live and likely returned to the lake unharmed.

CR F Date [1) GS RCS SBF CC FC WB BG SMB WC WAE *FWD C.f. sp. Total Dec-04 (21 155 0 93 0 0 186 0 0 62 0 1116 0 0 1612 Jan-05 341 31 0 0 0 0 0 0 0 0 0 0 0 372 Feb-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Mar-05 0 0 0 0 0 0 0 0 0 0 31 0 0 31 Apr-05 0 0 0 0 0 0 0 0 31 0 0 0 0 31 May-05 0 0 0 0 0 0 0 0 31 0 0 0 0 31 Jun-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Jul-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Aug-05 0 0 0 0 0 0 0. 0 0 0 0 0 0 0 Sep-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Oct-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Nov-05 0 0 0 0 0 60 0 0 30 30 0 0 0 120 Dec-05 0 0 31 0 0 62 31 0 93 0 155 0 0 372 Jan-06 0 0 0 0 0 0 0 0 31 0 0 0 0 31 Feb-06 0 0 0 31 0 0 0 0 31 0 31 0 0 93 Mar-06 0 0 0 31 0 0 0 0 31 0 31 0 0 93 12005 1 341 131 31 0 0 122131 0 185~ 30 1186 0 01 9 5571 ALL 496 31 124 62 0 308 31 0 340 30 1364 0 0 2786 (1) Fish species abbreviations:

Gizzard Shad GS Smallmouth bass SMB River carpsucker RCS White crappie WC Smallmouth buffalo SBF Walleye WAE Channel catfish CC Freshwater drum FWD Flathead catfish FC Corbicula fluminea C. f.White bass WB Crayfish sp. CR sp.Bluegill BG (2) All fish in impingement samples (Table 3) that were < 100 mm (TL) and were considered likely to have returned to the lake alive.44 Table 4 Fish Species List for Coffey County Lake.Common Name Scientific Name Gizzard shad Dorosoma cepedianum Common carp Cyprinus carpio Golden shiner Notemigonus crysoleucas Ghost shiner Notropis buchanani Red shiner Cyprinella lutrensis Fathead minnow Pimephales promelas River carpsucker Carpiodes carpio Bigmouth buffalo Ictiobus cyprinellus Smallmouth buffalo Ictiobus bubalus Black bullhead Ameiurus melas Yellow bullhead Ameiurus nattalis Channel catfish Ictalurus punctatus Blue catfish Ictalurus furcatus Flathead catfish Pylodictis olivaris Blackstripe topminnow Fundulus notatus Mosquitofish Gambusia affinis White bass Morone chrysops Striped bass Morone saxatilis Wiper hybrid na Brook silverside Labidesthes sicculus Green sunfish Lepomis cyanellus Longear sunfish Lepomis megalotis Orange-spotted sunfish Lepomis humilis Bluegill Lepomis macrochirus Smallmouth bass Micropterus dolomieu Largemouth bass Micropterus salmoides White crappie Pomoxis annularis Black crappie Pomoxis nigromaculatus Walleye Sander vitreum Logperch Percina caprodes Freshwater drum Aplodinotus grunniens 45 Table 5. Selected fish species harvested by anqlers at Coffey County Lake.Chan. White Wiper Smallmouth All Anglers catfish bass hybrid Bass LM Bass J Crappie Walleye fish 1999 9008 No. 1628#/hour 0.03#/acre 0.32 No. 2258#/hour 0.07#/acre 0.44 2000 6865 2001 7449 No. 2779#/hour 0.08#/acre 0.55 4227 No. 1161#/hour 0.08#/acre 0.23 2002>12" 1149 0.02 0.23 859 0.02 0.17 1046 0.03 0.21 378 0.02 0.07 1233 0.05 0.24 1494 0.05 0.29 1281 0.04 0.25>24" 7<0.01<0.01 3<0.01<0.01 12<0.01<0.01 7<0.01<0.01 16<0.01<0.01 18<0.01<0.01 8<0.01<0.01<13" 356 0.01 0.07 198 0.01 0.04<13" 126 0.01 0.02 85<0.01 0.02<16"_364 0.01 0.07 371 0.01 0.07 303 0.01 0.06>18" 116<0.01 0.02 20<0.01<0.01>16" 69<0.01 0.01 62<0.01 0.01>20" 24<0.01<0.01 0 0 0 10<1.01<0.01>21" 14<0.01<0.01 10<0.01<0.01 4<0.01<0.01 7<0.01<0.01 1<0.01<0.01 3<0.01<0.01 6<0.01<0.01>14" 725 0.01 0.14 316 0.01 0.06 415 0.01 0.08 184 0.01 0.04 234 0.01 0.05 386 0.01 0.07 325 0.01 0.06>18" 1669 0.03 0.33 533 0.01 0.10<18"_ >18" 1609 36 0.05 <0.01 0.32 0.01 862 326 0.04 0.01 0.17 0.06<18" >26" 1244 26 0.05 <0.01 0.24 <0.01 2327 7 0.08 <0.01 0.46 <0.01 2441 8 0.08 <0.01 0.48 <0.01 6007 0.13 1.15 4366 1.13 1.35 6291 0.18 1.23 3841 0.18 0.83 5638 0.49 0.93 7662 0.25 1.51 6981 0.24 1.37 2003 4751 No. 2457#/hour 0.10#/acre 0.48 2004 2005 5674 No. 2989#/hour 0.10#/acre 0.59 5287 No. 2541#/hour 0.09#/acre 0.50 46 Table 6.Selected fish species caught and released by anglers at Coffey County Lake.# Chan. White Wiper Smallmouth All Anglers catfish bass hybrid Bass LM Bass Crappie Walleye fish 1999 9008 No.#/hour#/acre 2000 6865 No.#/hour#/acre 2001 2002 2003 7449 4227 4751 5674 5287 No.#/hour#/acre No.#/hour#/acre No.#/hour#/acre No.#/hour#/acre No.#/hour#/acre 6928 0.15 1.36 5191 0.15 1.02 5623 0.16 1.10 3949 0.19 0.77 6057 0.25 1.19 7175 0.23 1.41 10,619 0.37 2.09 15,171 0.32 2.98 7838 0.23 1.54 8777 0.25 1.72 3623 0.17 0.71 8489 0.34 1.67 6748 0.22 1.33 8048 0.28 1.58 3503 0.07 0.69 2267 0.07 0.45 1810 0.05 0.35 1649 0.08 0.32 6838 0.27 1.34 4553 0.15 0.89 2683 0.09 0.53 17,482 0.37 3.43 12,579 0.36 2.47 10,136 0.28 1.99 8097 0.38 1.59 8527 0.35 1.67 8989 0.29 1.77 7785 0.27 1.53 3885 0.08 0.76 4918 0.14 0.97 4736 0.13 0.93 874 0.04 0.17 3193 0.13 0.63 3096 0.10 0.61 1420 0.05 0.28 7382 0.15 1.45 5536 0.16 1.09 7457 0.21 1.47 4563 0.22 0.90 5739 0.23 1.13 6386 0.21 1.25 4370 0.15 0.86 31,027 0.65 6.10 21,599 0.63 4.24 20,911 0.59 4.11 11,785 0.56 2.31 6740 0.27 1.32 10,016 0.33 1.97 9457 0.33 1.86 86,464 1.82 16.99 61,102 1.77 12.00 60,417 1.70 11.87 31,807 1.65 6.84 45,895 1.86 9.02 47,229 1.55 9.28 44,629 1.54 8.77 2004 2005 47 Table 7. Catch-per-unit-of-effort (CPUE) of selected fish species in Wolf Creek Lake. Fall gill net, electrofishing data were not collected in 2001 due to the September 11 events.Fyke net, and Gizzard Gizzard Smallmouth Largemouth White Shad Shad (YOY) White bass Wiper Bass Bass Crappie Walleye 1983 (1)7 (1) 23 (1) 15 (2) 24.5 (3) 0 (1) 4 1984 25 18 11 45.0 6 29 1985 3 6 22 45.3 5 26 1986 32 25 14 (2) 1.3 34.5 5 9 1987 10 18 21 8.5 18.8 12 16 1988 12 28 26 10.5 22.0 9 19 1989 18 17 23 14.8 32.3 4 22 1990 10 34 12 12.0 14.0 5 13 1991 14 45 22 20.5 5.5 4 19 1992 19 17 9 10.8 8.3 6 22 1993 11 52 8 15.0 5.0 5 12 1994 9 61 11 12.5 2.0 4 23 1995 25 29 11 6.3 2.0 5 16 1996 9 (4) 22.9 19 3 10.8 0.3 9 20 1997 19 77.0 60 8 5.5 1.3 4 28 1998 18 39.9 45 6 10.5 1.5 3 16 1999 15 9.9 37 4 11 3.3 6 14 2000 18 29.4 36 13 21.5 3.0 (5)9 28 2001 -----2.0 -2002 11 3.5 32 4 2.0 1.0 6 8 2003 10 1.9 54 9 8.0 2.0 7 14 2004 12 5.5 33 6 34 0.8 -20 2005 11 0.3 37 4 16 0.0 13 9 (1)(2)(3)(4)(5)Data from fall standard gill netting. Units equal number per gill-net-complement-night

> stock size.Data from spring electrofishing.

Units equal number per hour shocked > stock size. Shocking efforts starting in 2004 targeted prime habitats rather than standard locations as completed during prior years.Data from spring Fyke netting. Units equal number per trap-net-night

> stock size.Data from smallmesh gill net. Units equal number per net complement of one 0.5 and one 0.75 mesh net.Data beginning in 2000 were from fall Fyke netting. Netting not completed during 2004 due to adverse weather. Units equal number per trap-net-night

> stock size.48 Figure 2 Total of All Impinged Species OK 4:~ ,~ 0 0 i 3 a-7____ -~t -~I I I I ~2 :~ir-WOWS Pur 4stl;* J*qwU rw 49 11.0 Literature Cited Bruce Nuclear Generating Station. 1977. Fish Impingement at Bruce Nuclear Generating Station. Ontario Hydro Electric Company. 26 pp.Carlander, K. D. 1977. Handbook of Freshwater Fishery Biology Volume Two. The Iowa State University Press, Ames, Iowa.Colvin, M. A. 1993. Ecology and management of white bass: a literature review.Missouri Department of Conservation, Dingell-Johnson project F-1-R-42, Study I-31, Job 1, Final Report.Cross, F. B. and J. T. Collins. 1995. Fishes In Kansas. second edition. University of Kansas Natural History Museum. 315 pp.Dames & Moore. 1985. 316(b) Demonstration for the Virgil C. Summer Nuclear Station.Prepared for South Carolina Electric & Gas Company by Dames & Moore, Atlanta, Georgia. March.Edwards, T. J. , W. H. Hunt, L.E. Miller and J. J. Sevic. 1976. An Evaluation of the Impingement of Fishes at Four Duke Power Company Steam-Generating Facilities.

In Thermal Ecology II. Esch, G. W. and R. W. McFarlane, Editors. Technical Information Center of Energy Research and Development Administration.

Pp 373-380.Federal register.

July 9, 2004. 40 CFR Parts 9, 122 et al. National Pollutant Discharge Elimination System -Final Regulations to Establish Requirements for Cooling Water Intake Structures at Phase II Existing Facilities; Final Rule.Haines, D. E. 2000. Biological control of gizzard shad impingement at a nuclear power plant. Environmental Science & Policy 3: S257-S281.

Kansas Department of Health and Environment.

1975. Letter dated February 21, 1975 to M. Miller, Kansas Gas and Electric Company.Kansas Gas and Electric Company. 1975. Letter KLKAN-039 form M. E. Miller (KGE) to M. Gray of Kansas Department of Health and Environment.

KDWP (Kansas Dept. of Wildlife and Parks). 2004. Kansas Fishing Forecast.Kimmel, B. L. and A. W. Groeger. 1986. Limnological and Ecological Changes Associated with Reservoir Aging. Pages 103-109 in G. E. Hall and M. J Van Den Avyle, Editors. Reservoir Fisheries Management:

Strategies for the 80's.Reservoir Committee, Southern Division American Fisheries Society.Klemesrud, M. 2003. "Winter stress is causing gizzard shad to die. " From Iowa Outdoors, a publication of Iowa Department of Natural Resources.

http://www.iowadnr.com/news/io/03feb25io.pdf.

50 Mosher, T. D. 2000. Assessment of a 254-mm Minimum Length Limit for Crappie in Three Northeastern Kansas Reservoirs Final Report. Kansas Department of Wildlife and Parks. Federal Aid Project No. FW-9-12 and F-30-R-1.Muoneke, M. I., C. C. Henry, and 0. E. Maughan. 1992. Population structure and food habits of white crappie Pomoxis annualris Rafinesque in a turbid Oklahoma reservoir.

Journal of Fish Biology. Volume 1 Page 647 -October.O'Brien W. J., B. Loveless, and D. Wright. 1984. Feeding Ecology of Young White Crappie in a Kansas Reservoir.

North American Journal of Fisheries Management; 4: p 341-349.Olmstead, L.L. and J.P. Clugston.

1986. Fishery Management in Cooling Impoundments in Reservoir Fisheries Management:

Strategies for the 80's. G.Hall and M. Van Den Avyle, Editors. American Fisheries Society. Bethesda, MD.327 pp.Ontario Hydro. 1977. Winter studies of gizzard shad at Lambto GS-1976-77.

Ontario Hydro Research Division Report. No. 77-400-K.

47pp.Pennsylvania Angler & Boater. 2001. "The Basics of Water Pollution in Pennsylvania." http://www.fish.state.pa.us/anglerboater/2001/jf2OO1/wpollbas.htm.

Pennsylvania Angler & Boater Magazine (online), a publication of the Pennsylvania Fish & Boat Commission.

Schoenung, B. 2003. Fish and Wildlife Research and Management Notes. Indiana Department of Natural Resources, Division of Fish and Wildlife.

Available online at http://www.state.in.us/dnr/fishwild/publications/notes/boggs.htm.

Scott, W.B., and E. J. Crossman.

1973. Freshwater Fishes of Canada. Bulletin 184, Fisheries Research Board of Canada. Ottawa.Smitherman, R.O., and R. A. Dunham. 1993. Relationships Among Cultured and Naturally Occurring Populations of Freshwater Catfish in the United States. In (Collie and McVey, Eds) Proceedings of the Twenty-Second U.S.-Japan Aquaculture Panel Symposium, August 21-22, 1993, Homer, Alaska.South Carolina Electric & Gas Company. 2002. Appendix E --- Applicant's Environmental Report, Operating License Renewal Stage, Virgil C. Summer Nuclear Station. August.United States Environmental Protection Agency (EPA). 2006. Letter dated November 22, 2006, from J. Dunn (EPA) to J. Werner (KCPL)United States Environmental Protection Agency (EPA). 2006. Letter dated November 27, 2006, from J. Dunn (EPA) to S. Williams (IDNA)United States Nuclear Regulatory Commission (NRC). 1975. Final Environmental Statement (FES) for Wolf Creek Generating Station. NUREG-75/096 51 Virginia Power. 1985. Impingement and Entrainment Studies for North Anna Power Station, 1978-1983.

Prepared by Virginia Power Water Quality Department, Richmond.WCNOC. 2006. 2005 Fishery Monitoring Report and 2006 Plan. Internal documents.

Wellborn, T. L. 1988. Channel Catfish: Life History and Biology. Southern Regional Aquaculture Center, Texas A&M University, College Station, Texas. SRAC Publication No. 180.White, Andrew M., F. D. Moore, N. A. Alldridge, and D. M. Loucks. 1986. The Effects of Natural Winter Stresses on the Mortality of the Eastern Gizzard Shad, Dorosoma cepedianum, in Lake Erie. Environmental Resource Associates, Inc. and John Carrol University, for The Cleveland Electric Illuminating Company and The Ohio Edison Company. 208 pp.Willis, D. W. 1986. Review of Water Level Management on Kansas Reservoirs.

Pages 110-114 in G. E. Hall and M. J Van Den Avyle, Editors. Reservoir Fisheries Management:

Strategies for the 80's. Reservoir Committee, Southern Division American Fisheries Society.52 APPENDIX A Impingement Data Raw Impingement Collection Data Dead, Recently Dead and Living Impingement Data 53 Raw Impingement Collection Data Impingement Data L = Live RD = Recently Dead D = Dead Date: 12/1912004 Wash Time: 1800 Temp: 38.5F White Crappie Length Status 92 RD 62 RD 90 RD 100 RD 91 RD 107 RD Freshwater Drum Length Status 111 RD 89 RD 119 L 125 RD 124 RD 117 D 136 RD 94 RD 118 RD 114 D 149 RD 75 D 146 RD 142 D 129 RD 92 D 99 RD 119 D 116 RD 129 RD 82 RD 134 L 113 RD 130 RD 109 RD 69 RD 75 RD 57 D Channel Cat Length Status 83 L Bluegill Crayfish Length Status Length Status 56 RD 83 L Corbicula Quanity Status 2 L Raw Impingement Collection Data Date: 12/20/2004 Wash Time: 445 Temp: 38.5F White Crappie Length Status 80 D 98 RD 76 RD 79 RD 81 RD Fre eshwatei Length 147 119 89 82 445 90 112 101 110 109 115 93 115 110 106 114 112 131 132 126 121 96 102 103 111 102 115 125 r Drum Status RD D D D D D RD RD D D D D D D D D D D RD RD D D D D RD D RD RD Channel Cat Length Status 84 RD 79 D Bluegill Length 50 White Bass Length 253 202 195 73 Status D Gizzard Shad Length Status 125 D Buffalo Length Status 145 RD 115 RD Status RD RD RD RD Raw Impingement Collection Data Date: 12/20/2004 Wash Time: 1300 Temp: 38.5F White Crappie Length Status 205 RD 99 D 106 D 83 D 90 RD 85 RD 86 RD 93 RD 85 RD 86 RD 101 RD 83 RD 87 RD 81 RD 55 RD 58 RD Freshwater Drum Length Status 123 RD 109 D 99 D 140 L 116 D 132 RD 107 D 123 RD 143 RD 115 D 114 D 141 D 142 D 142 RD 169 D 116 RD 113 D 118 D 115 D 121 D 115 D 103 D 114 D 113 RD 96 RD 107 D 130 RD 109 D 95 D 103 D 110 RD Channel Cat Length Status 95 D 78 RD 86 RD 90 RD Bluegill Length 51 56 59 51 94 60 61 51 56 51 White Bass Length Status 223 RD 121 RD 111 D 103 RD Gizzard Shad Status Length Status RD 96 D RD 109 D RD 91 RD D 104 D RD 100 D RD 95 D RD 103 RD RD 113 D D 79 D RD 96 D 93 D 82 D 95 D 101 D 122 RD 109 D 104 RD 101 D 99 D 104 D 96 RD 93 RD 107 RD 94 D 99 RD 103 D 112 RD 92 D 97 RD Buffalo Length 142 Status RD Raw Impingement Collection Data Date: 12/20/2004 Wash Time: 1300 (Cont.) Temp: 38.5F Freshwater Drum Length Status 91 D 119 D 109 D 115 RD 105 D 119 D 121 RD 109 D 126 D 124 D 123 RD Impingement Data L = Live RD = Recently Dead D = Dead Date: 01/30/2005 Wash Time: 1330 Temp: 37.5F Gizzard Shad Length Status 109 RD 113 D 107 RD 109 RD 104 RD 108 D 108 RD Date: 01/30/2005 Wash Time: 2200 Temp: 37.5F Gizzard Shad Length Status 101 D 107 RD 109 D 102 RD 105 RD 97 D 108 RD Date: 01/31/2005 Wash Time: 600 Temp: 37.5F Gizzard Shad Length Status 95 RD 383 D 91 RD 104 RD 100 D 102 RD River Carp Sucker Length Status 318 RD Channel Cat Length 78 81 Status RD RD Crayfish Length 84 107 Status L L Impingement Data Date: 02/20/2005 No fish in basket Date: 02/20/2005 No fish in basket.Date: 02/21/2005 Freshwater Drum Length. Status 112 D L = Live RD = Recently Dead D = Dead Wash Time: Wash Time: Wash Time: Channel Cat Length 89 1030-1830 1830-0230 230-1030 Status L Temp: 45.2F Temp: 45.2F Temp: 45.2F Crayfish Length 72 Status L Impingement Data Date: 03/13/2005 No fish in basket Date: 03/13/2005 Freshwater Drum Length Status 122 RD L = Live RD = Recently Dead D = Dead Wash Time: 1050-1850 Wash Time: 1850-0250 Temp: 47.5F Temp: 47.5F Temp: 47.5F Date: 03/14/2005 Wash Time: 0250-1050 No fish in basket Impingement Data Date: 04/17/2005 Wash Time: Plant Shutdown -Circulating Water System Out of Service L = Live RD = Recently Dead Temp: 64.9F D = Dead Impingement Data L = Live RD = Recently Dead D = Dead Date: Bluegill Length 59 05/12/2005 Wash Time: 1130-1930 Temp: 21.2 C Status D Date: 05/12/2005 Wash Time: 1930-0730 Temp: 21.4 C Crayfish Length 86 Status L Date: 05/13/2005 White Crappie Length Status 110 RD Wash Time: 0730-1000 Temp: 20.3 C Corbicula Number 10 23 Status L D Impingement Data L = Live RD = Recently Dead D = Dead Date: 06126/2005 Wash Time: 1100-1900 Temp: 81.8F Gizzard Shad Length Status 70 RD 59 RD 39 D 50. D 55 RD 46 D 44 D 38 D Date: 06/26/2005 Gizzard Shad Length Status 50 D 50 D 45 D 40 D.44 RD 40 RD 40 D 40 RD 40 RD 40 RD 47 D 50 D Wash Time: 1900-0300 Crayfish Length Status 55 D Temp: 81.8F Date: 06/2712005 Gizzard Shad Length Status 46 D 46 D Wash Time: 0300-1100 Bluegill Length Status 42 D 50 D Temp: 81.8F Corbicula Number 20 Status D 41 43 41 RD D RD Impingement Data Date: 07/24/2005 L = Live RD = Recently Dead D = Dead Wash Time: 1000-1900 Temp: 85.8F No fish in basket Date: 07/24/2005 Gizzard Shad Length Status 69 RD Wash Time: 1900-0300 Temp: 85.8F Bluegill Length 68 Status D Crayfish Length 70 Status RD Corbicula Number 1 Status L Date: 07/25/2005 Wash Time: 0300-1000 Temp: 85.8F Gizzard Shad Length Status 56 D 54 D Crayfish Length 75 Status L Corbicula Number 2 3 Status L D Freshwater Drum Length Status 297 D 46 RD White Crappie Length Status 59 D Impingement Data Date: 08120/2005 Gizzard Shad Length Status 75 D L = Live RD = Recently Dead D = Dead Wash Time: 1030-1830 Temp: 80.7F White Crappie Length Status 71 D Corbicula Number Status 1 L 50 69 68 D D D Date: 08/20/2005 Wash Time: 1830-0230 Temp: 80.7F White Crappie Length Status 66 RD Freshwater Drum Length Status 56 RD Small Mouth Bass Length Status 69 D White Bass Length 61 Status D 68 60 180 RD RD D Date: 08/21/2005 Gizzard Shad Length Status 62 .D Wash Time: 0230-1030 Temp: 80.7F White Crappie Length Status 65 D 59 D 61 RD 67 RD 65 RD Freshwater Drum Length Status 43 D 85 RD White Bass Length Status 75 D 51 D Crayfish Length 89 85 Status L D 41 D Impingement Data L = Live RD = Recently Dead D = Dead Date: Crayfish Length 68 09/1012005 Status L Wash Time: 0930-1730 Temp: 79.9F Corbicula Number Status 1 1 L D Date: 09/10/2005 Wash Time: 1730-0130 Temp: 79.9F Freshwater Drum Length Status 60 D 301 D Date: 09/11/2005 Freshwater Drum Length Status 84 RD Corbicula Number Status 6 1 L D Wash Time: 0130-0930 Temp: 79.9F White Crappie Length Status 47 D Bluegill Length 88 Status D Corbicula Number 3 3 Status L D Impingement Data L = Live RD = Recently Dead D = Dead Date: Corbicula Quantity 1 Date: Corbicula Quantity 1 Date: Corbicula Quantity 2 10/07/2005 Wash Time: 1030-1830 Temp: 67.6F Status D 10/07/2005 Status D Wash Time: 1830-0230 Wash Time: 0230-1030 Walleye Length(mm)

Status 460 D Temp: 67.6F 10/08/2005 Temp: 67.6F Status D Freshwater Drum Length(mm)

Status 280 D White Bass Length(mm) 100 Status D Impingement Data L = Live RD = Recently Dead D = Dead Date: 11/12/2005 Wash Time: 1000-1800 Temp: 57.8F Crayfish Length 71 Date: Bluegill Length 29 58 64 51 52 50 44 60 56 55 50 Status L Corbicula Quantity 1.5 Status D White Crappie'Length Status 93 D 52 D 53 D 11/13/2005 Wash Time: 1800-0200 Temp: 57.8F Status RD D D RD D D D RD RD RD RD Channel Cat Length 56 Status D White Crappie Length Status 91 RD 93 RD 95. RD 91 D 91 RD 86 87 RD RD 87 RD 92 RD.91 RD 94 RD 90 74 RD RD Date: 11113/2005 Wash Time: 0200-1000 Temp: 57.81F Bluegill Length 53 48 48 56 55 54 46 59 58 54 49 46 56 47 Head only Status RD D RD RD D D RD RD RD D D D RD D D Gizzard Shad Length 122 Status RD White Crappie Length Status 101 RD 97 RD 79 RD 92 RD 89 RD 76 RD 95 RD 86 RD 88 RD 93 RD 96 RD 100 RD 94 RD 92 RD 90 RD 87 RD 91 RD White Bass Length 105 209 Corbicula Quantity 1 Status RD RD Status D Walleye Length 388 Status RD Impingement Data L = Live RD = Recently Dead D = Dead Date: 12119/2005 Wash Time: 1000-1800 Temp: 40.5F Freshwater Drum Length Status 172 D 179 D 99 D 104 D 101 RD 85 D 95 RD 9Q D Crayfish Length 90 109 99 104 Status L D L D White Crappie Length Status 330 RD 220 L 92 RD 59 )Gizzard Shad Length Status 110 D 108 D 105 D 107 D 104 D 107 D 109 D White Bass Length Status 169 D Buffalo Length Status 125 RD Date: 12/20/2005 Wash Time: 1800-0200 Temp: 40.5F Freshwater Drum Length Status 350 RD 179 RD 158 RD 101 D*111 D 95 D Channel Catfish Length Status 85 86 110 D D D White Crappie Length Status 100 D 90 D 81 RD 98 D Gizzard Shad Length Status 102 D Buffalo Length Status 535 D White Bass Length Status 168 RD Bluegill Length Status 98 D Flathead Catfish Length Status 102 D 77 96 81 D D D 107 61 84 90 96 96 96 39 91 98 RD D RD D D D D D D D 173 D Date: 12/20/2005 Freshwater Drum Length Status 103 RD 91 D Wash Time: 0200-1000 Temp: 40.5F Channel Catfish Length Sta White Crappie Length S 96 half itus D D 94 tatus RD Gizzard Shad Length Status 116 D 113 D Bluegill Length Status 162 RD Impingement Data L = Live RD = Recently Dead D = Dead Date: 01/1612006 Wash Time: 1020-1820 Temp: 45.1F Channel Catfish Length Status 57 D Corbicula Quantity 1 1 Status L D White Crappie Length 206 Status RD Date: 01117/2006 Wash Time: 1820-0220 Temp: 45.1F No fish in basket Date: 01/17/2006 Wash Time: 0220-1020 Temp: 45.1F Channel Catfish Length Status 76 D 80 D Corbicula Quantity 1 Status L Freshwater Drum Length Status 90 D Crayfish Length Status 130 L 85 L Impingement Data Status L=Live RD-Recently Dead D=Dead Date: 03/04/2006 Wash Time: 1030-1830 Temp: 46.4 White Crappie Length(mm) 330 Status L White Bass Length(mm) 188 Status RD Date: 03/04/2006 Wash Time: 1830-230 Freshwater Drum Length(mm) 346 72 Status L D Channel Catfish Length(mm) 97 86 Temp: 46.4 Corbicula Quantity 1 Status L RD Status D Date: 0310512006 Wash Time: 230-1030 Freshwater Drum Length(mm) 114 97 Status D RD Channel Catfish Length(mm) 113 94 95 Temp: 46.4 White Crappie Length(mm)

Status 216 D Status L L RD Dead, Recently Dead and Living Impingement Sample Data Sample 12-19 to 12-20-2004 Drum Dead Recently Dead Living Total Impinged 55 40 3 98 Channel Cat Dead Recently Dead Living 2 4 1 7 White Crappie Dead Recently Dead Living 4 23 0 27 Bluenill Dead Recently Dead Living 3 9 0 Gizzard Shad Dead Recenly Dead Living 20 10 0 30 12 Sample 01-30 to 01-31-2005 Drum Dead Recently Dead Living Total Impinged 0 0 0 0 Channel Cat Dead Recently Dead Living 0 2 0 2 White Crappie Dead Recently Dead Living 0 0 0 0 Bluegill Dead Recently Dead Living 0 0 0 0 Gizzard Shad Dead Recenly Dead Living 7 13 0 20 Sample 02-20 to 02-21-2005 Drum Dead Recently Dead Living Channel Cat 1 Dead 0 Recently Dead 0 Living 0 0 1 White Crappie Dead Recently Dead Living 0 0 0 Blueaill Dead Recently Dead Living 0 0 0 Gizzard Shad Dead Recenly Dead Living 0 0 0 Total Impinged 1 ToalImined I1 000 0 0 Dead, Recently Dead and Living Impingement Sample Data Sample 12-19 to 12-20-2004 Buffalo Dead Recently Dead Living 0 3 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 0 0 1 Corbicula Dead Recently Dead Living 0 0 2 2 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 Total Impinged 3 Sample 1-30 to 1-31-2005 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 1 0 1 Crayfish Dead.Recently Dead Living 0 0 2 2 Corbicula Dead Recently Dead Living 0 0 0 0 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Sample 2-20 to 2-21-2005 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 Crayfish Dead Recently Dead Living 0 0 1 Corbicula Dead Recently Dead Living 0 0 0 Small Mouth Bass Dead Recently Dead Living 0 0 0 Total Impinged 0 ToalImined 00 100 0 0 Dead, Recently Dead and Living Impingement Sample Data Sample 12-19 to 12-20-2004 White Bass Dead Recently Dead Living Total Impinged 1 7 0 8 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 1-30 to 1-31-2005 White Bass Dead Recently Dead Living Total Impinged 0 0 0 0 Walleve Dead, Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 2-20 to 2-21-2005 White Bass Dead Recently Dead Living 0 0 0 Walleye Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Dead, Recently Dead and Living Impingement Sample Data Sample 03-13 to 03-14-2005 Drum Dead Recently Dead Living Total Impinged 0 1 0 1 Channel Cat Dead Recently Dead Living 0 0 0 0 White Crappie Dead Recently Dead Living 0 0 0 0 Bluegill Dead Recently Dead Living 0 0 0 0 Gizzard Shad Dead Recenly Dead Living 0 0 0 0 Sample 04/17 to 04-18-2005 Plant Shutdown -Circ Water Out of Service Sample 05-12 to 05-13-2005 Drum Dead Recently Dead Living Total Impinged 0 0 0 0 Channel Cat Dead Recently Dead Living 0 0 0 0 White Crappie Dead Recently Dead Living 0 1 0 Blu euill Dead Recently Dead Living I 0 0 Gizzard Shad Dead Recenly Dead Living 0 0 0 0 1 I Sample 06-26 to 06-27-2005 Drum Dead Recently Dead Living 0 0 0 Channel Cat Dead Recently Dead Living 0 0 0 White Crappie Dead Recently Dead Living 0 0 0 Bluegill Dead Recently Dead Living 3 2 0 Gizzard Shad Dead Recenly Dead Living 14 8 0.Total Impinged 0 Total~ Imige 0 52 5 22 Dead, Recently Dead and Living Impingement Sample Data Sample 3-13 to 3-14-2005 Buffalo Dead Recently Dead Living Total Impinged 0 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 0 0 0 0 Corbicula Dead Recently Dead Living 0 0 0 Small Mouth Bass Dead Recently Dead Living 0 0 0 Sample 4/17 to 4-18-2005 Plant Shutdown -Circ Water Out of Service Sample 5-12 to 5-13-2005 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 0 0 1 Corbicula Dead Recently Dead Living 23 0 10 33 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Sample 6-26 to 6-27-2005 I Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 Crayfish Dead Recently Dead Living 1 0 0 Corbicula Dead Recently Dead Living 20 0 0 Small Mouth Bass Dead Recently Dead Living 0 0 0 Total Impinged 0 0 1 20 0 Dead, Recently Dead and Living Impingement Sample Data Sample 3-13 to 3-14-2005 White Bass Dead Recently Dead Living Total Impinged 0 0 0 0 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 4/17 to 4-18-2005 Plant Shutdown -Circ Water Out of Service Sample 5-12 to 5-13-2005 White Bass Dead Recently Dead Living Total Impinged.0 0 0 0 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 6-26 to 6-27-2005 White Bass Dead Recently Dead Living 0 0 0 Walleye Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Dead, Recently Dead and Living Impingement Sample Data Sample 07-24 to 07-25-2005 Drum Dead Recently Dead Living Total Impinged 1 0 2 Channel Cat Dead Recently Dead Living 0 0 0 0 White Crappie Dead Recently Dead Living I 0 0 Bluegill Dead Recently Dead Living 1 0 0 Gizzard Shad Dead Recenly Dead Living 2 1 0 3 1 1 Sample 08-20 to 08-21-2005 Drum Dead Recently Dead Living Total Impinged 3 4 0 Channel Cat Dead Recently Dead Living 0 0 0 0 White Crappie Dead Recently Dead Living 6 4 0 Bluegill Dead Recently Dead Living 0 0 0 0 Gizzard Shad Dead Recenly Dead Living 2 0 0 2 7 10 Sample 09-10 to 09-11-2005 Drum Dead Recently Dead Living 2 1 0 Channel Cat Dead Recently Dead Living 0 0 0 White Crappie Dead Recently Dead Living 1 0 0 Bluegill Dead Recently Dead Living 1 0 0 Gizzard Shad Dead Recenly Dead Living 0 0 0 Total Impinged 3 0 1 1 0 Dead, Recently Dead and Living Impingement Sample Data Sample 7-24 to 7-25-2005 Buffalo Dead Recently Dead Living Total Impinged 0 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living Corbicula Dead Recently Dead Living 1 1 3 0 3 6 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 2 Sample 8-20 to 8-21-2005 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 1 0 1 2 Corbicula Dead Recently Dead Living 0 0 1 Small Mouth Bass Dead Recently Dead Living I 0 0 Total Impinged 0 Sample 9-10 to 9-11-2005 1 I Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 Crayfish Dead Recently Dead Living 0 0 1 Corbicula Dead Recently Dead Living 5 0 10 Small Mouth Bass Dead Recently Dead Living 0 0 0 Total Impinged 0 ToalImined

00. 1 1 15 0 Dead, Recently Dead and Living Impingement Sample Data Sample 7-24 to 7-25-2005 White Bass Dead Recently Dead Living Total Impinged 0 0 0 0 Walleye Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 8-20 to 8-21-2005 White Bass Dead Recently Dead Living Total Impinged 3 0 0 3 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 9-10 to 9-11-2005 White Bass Dead Recently Dead Living 0 0 0 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Dead, Recently Dead and Living Impingement Sample Data Sample 10-07 to 10-08-2005 Drum Dead Recently Dead Living Total Impinged 1 0 0 Channel Cat Dead Recently Dead Living 0 0 0 0 WhiteCrappie Dead Recently Dead Living 0 0 0 0 Bluegill Dead Recently Dead Living 0 0 0 0 Gizzard Shad Dead Recenly Dead Living 0 0 0 0 I Sample 11-12 to 11-13-2005 Drum Dead Recently Dead Living Total Impinged 0 0 0 0 Channel Cat Dead Recently Dead Living 1 0 0 White Crappie Dead Recently Dead Living 4 29 0 33 Bluegill Dead Recently Dead Living 13 13 0 Gizzard Shad Dead Recenly Dead Living 0 1 0 1 0 1 Sample 12-19 to 12-20-2005 Drum Dead Recently Dead Living 13 6 0 Channel Cat Dead Recently Dead Living 5 0 0 White Crappie Dead Recently Dead Living 12 6 1 Blueoill Dead Recently Dead Living 1 0 Gizzard Shad Dead Recenly Dead Living 10 0 0 Total Impinged 19 ToalImined 195 19 21 2 10 Dead, Recently Dead and Living Impingement Sample Data Sample 10-07 to 10-08-2005 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 0 0 0 0 Corbicula Dead Recently Dead Living 4 0 0 4 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Sample 11-12 to 11-13-2005 Buffalo Dead Recently Dead Living 0 0 0 River CarDsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 0 0 0 0 Corbicula Dead Recently Dead Living 2 0 0 2 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Sample 12-19 to 12-20-2005 Buffalo Dead Recently Dead Living 2 1 0 River Carpsucker Dead Recently Dead Living 0 0 0 Crayfish Dead Recently Dead Living 2 0 2 Corbicula Dead Recently Dead Living 0 0 0 Small Mouth Bass Dead Recently Dead Living 0 0 0 Total Impinged 3 ToalImined 30 4 0 0 Dead, Recently Dead and Living Impingement Sample Data Sample 10-07 to 10-08-2005 White Bass Dead Recently Dead Living Total Impinged 1 0 0 1 Walleve Dead Recently Dead Living 1 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 1 Sample 11-12 to 11-13-2005 White Bass Dead Recently Dead Living Total Impinged 0 2 0 2 Walleve Dead Recently Dead Living 0 1 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 12-19 to 12-20-2005 White Bass Dead Recently Dead Living 1 1 0 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 1 0 0 Total Impinged 2 1 Dead, Recently Dead and Living Impingement Sample Data Sample 01-16 to 01-17-2006 Drum Dead Recently Dead Living Total Impinged 1 0 0 Channel Cat Dead Recently Dead Living 3 0 0 3 White Crappie Dead Recently Dead Living 0 1 0 1 Bluegill Dead Recently Dead Living 0 0 0 0 Gizzard Shad Dead Recenly Dead Living 0 0 0 0 1 Sample 02-XX to 02-XX-2006 Unable to Collect Samples Sample 03-04 to 03-05-2006 Drum Dead Recently Dead Living Channel Cat 2 Dead 1 Recently Dead 1 Living 0 2 3 White Crappie Dead Recently Dead Living 1 0 1 Bluegill Dead Recently Dead Living 0 0 0 Gizzard Shad Dead Recenly Dead Living 0 0 0 Total Impinged 4 ToalImined 45 200 0 0 Dead, Recently Dead and Living Impingement Sample Data Sample 01-16 to 01-17-2006 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 0 Crayfish Dead Recently Dead Living 0 0 2 2 Corbicula Dead Recently Dead Living 1 0 2 3 Small Mouth Bass Dead Recently Dead Living 0 0 0 0 Total Impinged 0 Sample 02-XX to 02-XX-2006 Unable to Collect Samples Sample 03-04 to 03-05-2006 Buffalo Dead Recently Dead Living 0 0 0 River Carpsucker Dead Recently Dead Living 0 0 0 Crayfish Dead Recently Dead Living 0 0 0 Corbicula Dead Recently Dead Living 1 0 0 Small Mouth Bass Dead Recently Dead Living 0 0 0 Total Impinged 0 0 0 Totl mpige 0 01 0 Dead, Recently Dead and Living Impingement Sample Data Sample 01-16 to 01 2006 White Bass Dead Recently Dead Living Total Impinged 0 0 0 0 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Sample 02-XX to 02-XX-2006 Unable to Collect Samples Sample 03-04 to 03-05-2006 White Bass Dead Recently Dead Living 0 1 0 Walleve Dead Recently Dead Living 0 0 0 0 Flathead Catfish Dead Recently Dead Living 0 0 0 0 Total Impinged 1 APPENDIX B SUPPORT DOCUMENTS Coffey County Lake 2005 Fishery Monitoring Report and 2006 Plan Biological Control Of Gizzard Shad Impingement At A Nuclear Power EPA Region VII Policy on Gizzard Shad Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)54 f WOLF CREEK GENERATING STATION Wolf Creek Lake 2005 FISHERY MONITORING REPORT AND 2006 PLAN Prepared by: Supervisor Regulatory Support Approval: Manager Regulatory Affairs Approval:~ 1 2/16/06 Dan Haines Date) 02/17/06 Robert Hammond Date 1 02/21/06 Kevin Moles Date EXECUTIVE

SUMMARY

Monitoring during 2005 demonstrated that the fishery in Wolf Creek Lake remained in good condition with no adverse trends identified.

Fish predation pressure on the gizzard shad population continued to prevent excessive shad impingement problems at the circulating water intake. Fishery monitoring activities in 2006 as outlined in this report will continue to measure long-term trends and help Wolf Creek Generating Station prepare for any short term changes, particularly for any changes in the potential for shad impingement events.Public angling on the lake did not impact the fishery's function of supporting plant operations.

The catch and release philosophy promoted when the lake was opened for the public has been compatible with gizzard shad control objectives.

Monitoring data from 2004 warranted management activities to improve the fishery for public use. The following were recommended to the Kansas Department of Wildlife Parks (KDWP): 1. Increase of the creel limit for crappie greater than 14 inches from two to ten fish per day to increase angler use and increase harvest of older crappie.2. Increase the catfish creel limit from five to ten fish per day to be consistent with statewide creel limits. Catfish are not considered a significant predator of gizzard shad.3. Decrease the wiper length limit from 24 to 21 inches to increase harvest of older fish.The KDWP accepted and changed the following beginning for 2006: 1. Crappie creel limits were not changed due to perceptions of angler dissatisfaction.

2. Increased catfish creel limit to ten per day.3. Decreased wiper length limit from 24 to 21 inches.Based on 2005 monitoring, the following are recommended:

1. Maintain current 2006 creel and/or length regulations through 2007.2. Investigate walleye age structure, total annual mortality, and mortality caps to determine if current size and creel regulations are appropriate.

3. Stock a 2006 wiper year-class within budget constraints, and budget for a 2007 stocking at a rate of 10 two-inch fish per acre (50,000).2 2005 FISHERY MONITORING REPORT AND 2006 PLAN INTRODUCTION This report presents the results of fishery monitoring activities on Wolf Creek Lake (WCL). Data are summarized in table form to document long-term trends and demonstrates that the fishery has functioned as desired through 2005. The goal is to increase public safety and plant operating efficiency by reducing the potential for excessive gizzard shad young-of-year (YOY) impingement on the Circulating Water System intake screens. Shad impingement problems to date have not occurred due largely to the characteristics of the current fishery.Public use of the fishery is also important to maintain community relations and local economic benefits.

Consequently, maintaining and/or enhancing public enjoyment of the fishery that is compatible with the shad impingement control are other important goals of this program. Creel and length limits were determined jointly with the Kansas Department of Wildlife and Parks (KDWP). The catch-and-release strategy employed appears to have succeeded with no detrimental changes to the fishery observed through 2005.Fishery monitoring activities in 2006 will be similar to 2005 to maintain long-term trending.

Short-term changes will also be detected to ensure WCGS can be prepared if impingement potential increases.

METHODS The monitoring methods used during 2005 allowed for continued analyses of important long-term trends. Gill netting was used at long-term sites on WCL (Figure 1). Spring electrofishing effort targeted smallmouth and largemouth bass habitat by shocking in shoreline transects until a minimum number of fish or a designated length of shore was sampled. Small-mesh gill netting replaced shoreline seining in 1998 to better assess young-of-year (YOY) gizzard shad densities and recruitment (Boxrucker et al -1991). Important species to the fishery were targeted when expected to be efficiently sampled.Sampling efforts are listed in Table 1. Fish sampled were weighed to the nearest gram, and measured (total length, TL) to the nearest millimeter.

Proportional stock density (PSD, Anderson 1980), incremental relative stock density (RSD, Gablehouse 1984), and relative weight (Wr, Wege and Anderson 1978) were indices applied. Length-weight equations adopted by KDWP were used.The 2006 efforts will be completed as scheduled in Table 2. These efforts are the same as for 2005. Anglers using the lake park report the number of fish caught and released, the number kept for personal use, and angler satisfaction.

These creel sheets are collected and tabulated by Coffey County. Data from the census sheets will be used to determine if harvest rates change dramatically and to measure angler success.Increasing walleye size variability and maximum size is advantageous to diversified shad control, as well as angler compatibility and success. Consequently, walleye age structure, total annual mortality, and mortality caps will be determined using methods similar to Quist et. al. (2004). The current management objective is to produce larger walleye (>26 inches total length) by encouraging harvest of smaller walleye from a stable population with good recruitment, thus reducing intraspecific competition allowing surviving individuals to grow larger. A slot limit prohibiting harvest of fish between 18 and 26 inches was set to accomplish this. Assessing mortality caps will determine if walleye die of natural mortality before reaching 26 inches, if harvest of smaller individuals is necessary, if decreasing interspecific competition for available prey would 3 be effective, and if regulating length of harvest is applicable given current lake biology and angler impacts. University graduate students will be solicited and supported with research grant funding to complete this task. Available scale and fishery data will be used.RESULTS AND PLANS The fishery in Wolf Creek Lake continued to function as desired. It exhibited signs of low prey densities, which is preferred to minimize fish impingement at the circulating water intake. The potential for excessive gizzard shad impingement remained small due to relatively low YOY densities going into the winter months. The shad appear to be limited by predation, as indicated by the population indices of the predator species. Gizzard shad typically has been an important forage species in most reservoirs (Carlander 1969, Pflieger 1975, Stein and Johnson 1987, Colvin 1993). For shad to be compatible with WCGS operation, low YOY shad densities must be maintained.

Periodic recruitment of shad young to reproducing adults also must occur to maintain the predators, which in turn control shad numbers. These conditions currently exist in WCL, and benefit WCGS.Catch densities of remained similar to past years for adult gizzard shad, white bass and wiper;increased for white crappie, and decreased for smallmouth bass and walleye (Table 3). Fall densities of small gizzard shad remained low. Density changes for smallmouth bass is likely due to sampling variation.

Walleye changes may be due to sampling variation because catch densities were within past ranges. Increased angler harvest for two consecutive years may also have contributed (Table 7)Fish length frequencies in 2005, as shown by the PSD/RSD indices (Table 4), showed no major changes to past years, except for gizzard shad. A higher PSD indicates fewer shad recruiting to mid-size due in part to predation, and an older population existing.

Continued recruitment and growth of important species were evident with most showing good percentages of mid-sized individuals (RSDS-Q, RSD Q-P, and RSD M-T size ranges). For wipers, the sizes increased slightly showing continuing maturation of the latest 2001 year-class stocking.

Because of this, budgeting for potential wiper stocking in 2006 is recommended to ensure continued presence.There was a small shift to larger walleye, possibly due to the current regulations, but this shift is not definitive.

Walleye research referenced earlier should determine any relationships.

Body conditions as indicated by Wr indices (Table 5) remained similar to past years for gizzard shad, smallmouth bass, and white crappie; increased for white bass, wiper; and decreased for walleye. All species showed adequate body conditions to maintain their populations.

Large increases or decreases in body condition were not evident for most species. The white bass increase may be attributable to decreasing wiper competition, as the 2001 year-class matures.Overall, this indicates that no large changes in prey availability occurred, primarily gizzard shad densities.

No detrimental impacts due to angler harvest of the predator populations controlling gizzard shad have been observed.

Harvest rates were slightly lower, but still similar for most species, except walleye (Table 6 and 7). Harvest of walleye under 18 inches nearly doubled in 2004, and slightly more in 2005. Because the population indices for catch frequency, length frequency, and body conditions remained similar to past years, influence by angler harvest was not apparent.There are no fish creel and length limit changes recommended for 2007. The current smallmouth bass and walleye slot limits were imposed to increase body condition and growth. These limits should remain in effect until more data is collected to assess their impacts. The current minimum length limit (12 inches) for white bass was set to protect younger wipers. Since a wiper year class stocking is planned for 2006 and 2007, the white bass minimum length should remain in effect.The crappie is an important littoral predator of gizzard shad in the absence of high largemouth 4

densities, so the minimum length limit (14 inches) was set to protect a majority of the larger individuals.

A large proportion of crappie were near the limit (PSD M-T of 28, Table 4), consequently the limit should remain the same.PLAN RESULTS To ensure 'continued WCGS support and public use, the fishery program will accomplish the following:

1. Continue monitoring as outlined.2. Maintain current 2006 creel and/or length regulations through 2007.3. Investigate walleye age structure, total annual mortality, and mortality caps to determine if current size and creel regulations are appropriate.

4. Stock a 2006 wiper year-class within budget constraints, and budget for a 2007 stocking at a rate of 10 two-inch fish per acre (50,000).5 LITERATURE CITED Anderson, R. 0. 1980. Proportional stock density (PSD) and relative weight (Wr): interpretive indices for fish populations and communities.

Pages 27-33 in S. Gloss and B. Shupp, editors. Practical fisheries management:

More with less in the 1980's. New York Chap., Amer. Fish. Soc., Workshop Proceedings.

Boxrucker, J., D. Degan,.D.

DeVries, P. Michaletz, M. J. Van Den Avyle, B. Vondracek.

-1991 (year not specified).

Sampling Shad in Southern Impoundments.

U.S. Fish and Wildlife Service, Reservoir committee of the Southern Division-American Fisheries Society, Coop agreement No. 14-16-0002-91-216.

22 pp.Carlander, K. D. 1969. Handbook of Freshwater Fisheries Biology, Vol. 1. Iowa State University Press, Ames, Iowa. 752 pp.Colvin, Mike. 1993. Ecology and management of white bass: a literature review. Missouri Department of Conservation, Dingell-Johnson Project F-1-R-42, Study 1-31, Job 1, Final Report.Gablehouse, D. W., Jr. 1984. A length-categorization system to assess fish stocks. North American Journal of Fisheries Management.

Vol. 4. P 273-285.Pflieger, W. L. 1975. The Fishes of Missouri.

Missouri Department of Conservation.

343 pp.Quist, M. C., J. L. Stephen, C. S. Guy, and R. D. Schultz. 2004. Age Structure and Mortality of Walleyes in Kansas Reservoirs:

Use of Mortality Caps to Establish Realistic Management Objectives.

North American Journal of Fisheries Management, 24:990-1002.

Stein, R. A. and B. M. Johnson. 1987. Predicting carrying capacities and yields of top predators in Ohio impoundments.

Ohio Department of Natural Resources, Division of Wildlife.Federal Aid in Fish Restoration Project F-57-R-5 through R-9, Study 12. 144 pp.Wege, G. J. And R. 0. Anderson.

1978. Relative weight (Wr): a new index of condition for largemouth bass. Pages 79-91 in G. D. Novinger and J. G. Dillard, editors. New approaches to the management of small impoundments.

North Central Division, American Fisheries Society. Special Publication 5, Bethesda, MD.6 Table 1. Fishery sampling effort by gear type used at Wolf Creek Lake during 2005.Water Gear Date (1) Location Effort Temp :F Electrofishing

ý2)Standard Gill Netting (4)Small Mesh Gill Netting (6)5/27 10/11 10/12 10/13 10/14 10/26 10/27 10/26 NA (J)0.75 2 (5)1 9 1 6 1 8 1 2 1 9 1 6 1 8 1 72 66-69 77-86 65-67 64-65 68 70-85 67 64 59-62 59 60 57 Fyke Netting 6 8 6 8 2 6 8 2 6 8 (7)2 2 2 2 (8) 1 1 1 56 62 59 60 60 57 10/27 1 1 1 (1) See Figure 1 for locations.

(2) Equipment consisted of a boat-mounted Smith-Root unit operated at 220v, 9-10 amp, DC current pulsed 120 cycles/second (3) Shock effort shown as hours water was energized.

(4) Standard gill nets consisted of a complement of four 8'x100' monofilament nets, one each of 1", 1.5", 2.5", and 4" uniform mesh.(5) Standard gill netting effort listed as number of net-complement-nights set.(6) Small-mesh gill nets consisted of a complement of two 8'xl 00' monofilament nets, one with 0.5", and the second with 0.75" uniform mesh.(7) Small-mesh gill netting effort listed as number of small-mesh-complement-nights set.(8) Fyke netting effort listed as number of trap-net-nights.

7 Table 2. Fish Sampling Schedule at Wolf Creek Lake during 2006.Minimum Information Needed to Assess Fishery Method Preferred Time Frame 1.2.3.4.5.6.7.8.Gizzard shad recruitment through winter White crappie population characteristics and health Largemouth bass population characteristics and health Smallmouth bass population characteristics and health White bass population characteristics and health Wiper survival and health Walleye population characteristics and health Gizzard shad YOY reproduction and densities going into winter Electrofishing Fyke netting/Gill netting Electrofishing Electrofishing Gill netting Gill netting Gill netting Small Mesh Gill Netting April/May October/November April/May April/May October October October September/October 8

Table 3. Catch-per-unit-of-effort (CPUE) of selected fish species in Wolf Creek Lake. Fall gill net, Fyke net, and electrofishing data were not collected in 2001 due to the September 11 events.Gizzard Gizzard Smallmouth Largemouth White Shad Shad (YOY) White bass Wiper Bass Bass Crappie Walleye 1983 (1)7 (1) 23 (1) 15 (2) 24.5 (3) 0 (1) 4 1984 25 18 11 45.0 6 29 1985 3 6 22 45.3 5 26 1986 32 25 14 (2) 1.3 34.5 5 9 1987 10 18 21 8.5 18.8 12 16 1988 12 28 26 10.5 22.0 9 19 1989 18 17 23 14.8 32.3 4 22 1990 10 34 12 12.0 14.0 5 13 1991 14. 45 22 20.5 5.5 4 19 1992 19 17 9 10.8 8.3 6 22 1993 11 52 8 15.0 5.0 5 12 1994 9 61 11 12.5 2.0 4 23 1995 25 29 11 6.3 2.0 5 16 1996 9 (4)22.9 19 3 10.8 0.3 9 20 1997 19 77.0 60 8 5.5 1.3 4 28 1998 18 39.9 45 6 10.5 1.5 3 16 1999 15 9.9 37 4 11 3.3 6 14 2000 18 29.4 36 13 21.5 3.0 (5)9 28 2001 ----2.0 --2002 11 3.5 32 4 2.0 1.0 6 8 2003 10 1.9 54 9 8.0 2.0 7 14 2004 12 5.5 33 6 34 0.8 -20 2005 11 0.3 37 4 16 0.0 13 9 (1) Data from fall standard gill netting. Units equal number per gill-net-complement-night

> stock size.(2) Data from spring electrofishing.

Units equal number per hour shocked > stock size. Shocking efforts starting in 2004 targeted prime habitats rather than standard locations as completed during prior years.(3) Data from spring Fyke netting. Units equal number per trap-net-night

> stock size.(4) Data from smallmesh gill net. Units equal number per net complement of one 0.5 and one 0.75 mesh net.(5) Data beginning in 2000 were from fall Fyke netting. Netting not completed during 2004 due to adverse weather. Units equal number per trap-net-night

> stock size.9 Table 4. Proportional Stock Density (PSD) and Relative Stock Density (RSD) for selected fish species at Wolf Creek Lake.Stock (S), quality (Q), preferred (P), memorable (M), and trophy (T) size ranges are per Gablehouse (1984). Fall gill net, Fyke net, and electrofishing data were not collected in 2001 due to the September 11 events.Species Index 88 89 90 91 92 93 94 95 96 97, 98 99 00 01 02 03 04 05 Gizzard shad (1)(2)White bass (1)(2)PSD RSD-P 85 90 100 70 81 93 59 69 84 15 10 0 30 19 7 41 31 16 75 94 81 30 25 6 19 70 Wiper(1)PSD RSD S-Q RSD Q-P RSD P-M RSD M-T RSD T+PSD RSD S-Q RSD Q-P RSD P-M RSD M-T RSD T+PSD RSD S-Q RSD Q-P RSD P-M RSD M-T RSD T+77 85 27 59 80 23 15 73 41 20 9 7 2 10 36 39 62 21 34 35 29 15 4 15 9 31 89 63 56 69 11 37 44 5 12 8 51 24 55 45 0 2 22 11 4<1 57 59 43 41 4 11 53 45<1 2 1 88 89 12 11 32 11 33 73 23 5 45 65 55 35 3 4 40 55 2 7 100 100 91 58 9 42 100 97 96 100 100 100 100 85 30 3 4 .15 70 1 10 14 3, 42 40 28 47 39 21 6 4 58 50 53 53 61 76 92 81 30 1 1 2-87 49 47 83-13 51 53 17-48 33 53 41-52 67 47 59-10 1 5 3-34 29 43 32 4 3 5 5<1 100 100 100 100 24 3 31 20 65 55 45 80 33 39 2 88 83 66 50 13 17 34 50 38 17 22 17 50 63 36 25 4 8 8 Smallmouth Bass(4), (5 after 2003)29 37 40 61 40 71 63 60 39 60 8 25 10 22 26 17 10 27 32 13 4 5 4 6 1 1 44 40 52 58 56 60 48 42 17 20 28 28 20 12 20 26 7 8 4 5 50 52 77 70 50 48 23 30 23 29 34 28 18 21 36 40 9 2 7 2 60 50 100 100 40 50 50 20 17 50 40 33 100 Largemouth PSD Bass (5) RSD S-Q RSD Q-P RSD P-M RSD M-T RSD T+92 99 97 100 82 85 88 100 100 8 1 3 18 15 12 .19 28 19 5 12 10 13 13 72 71 80 95 71 71 75 88 100 88 50 100 13 25 38 25 17 50 50 83 (7) (7)10 Table 4. (cont.)Species Index"88 89 90, 91 92 93 94 95 96 97-,, 98 99 00 01 02 03 04 05 White PSD crappie (6)(8) RSD S-Q RSD Q-P RSD P-M RSD M-T RSD T+99 100 100 100 100 95 100 100 99 100 100 100 82 1 5 1 18 2 12 9 3 3 2 8 1 9 9 9 43 4 10 13 7 26 14 44 11 12 15 12 13 11 85 60 70 87 63 75 41 87 72 71 74 77 28 10 21 10 3 8 4 7 1 6 5 5 1 1 94 93 96 77 93 90 52 83 73 31 55 74 78 6 7 4 23 7 10 48 17 27 69 45 26 22 81 80 95 59 74 67 41 82 67 28 51 74 75 14 13 1 18 19 22 10 1 6 3 4 3-98 99 97 87-2 1 3 13-34 48 32 53-11 29 15 6-52 21 47 28 1 1 3 47 60 69 62 53 40 31 38-40 57 66 54 8 3 3 7 Walleye (1)PSD RSD S-Q RSD Q-P RSD P-M RSD M-T RSD T+(1) Data from fall gill netting.(2) Corrected for gill net efficiency (Willis et al 1985)(3) Data from spring electrofishing.

(4) Data from fall electrofishing.

(5) Data from spring Fyke netting.(6) Data from spring Fyke netting 1999 and earlier, from fall Fyke netting 2000 and later.(7) Insufficient data to calculate.

(8) 2004 data from fall gill netting.11 Table 5. Relative weight (Wr) of selected fish species in Wolf Creek Lake. Wr formulas from KDWP were used. Per Wege and Anderson (1978), Wr values of 100 and higher represent fish at or above the 75 percentile, values of 93 to 100 are between the 50 and 75 percentile, values of 86 to 93 are between the 25 and 50 percentile, and values less than 86 are below the 25 percentile.

Fall gill net, Fyke net, and electrofishing data were not collected in 2001 due to the September 11 events.Gizzard Smallmouth Largemouth White Shad White bass Wiper Bluegill Bass, Bass Crappie Walleye 1983 (1) 85 (1) 78 (1) 90 (2) 107 (2) (4) 107 ( 78 1984 87 94 86 103 98 93 82 1985 88 89 78 102 97 94 83 1986 85 86 84 111 93 93 81 1987 89 93 89 105 (3) 97 88 89 80 1988 90 94 85 108 92 92 102 81 1989 104 95 80 96 92 87 88 88 1990 100 99 82 121 104 84 98 85 1991 93 93 78 111 91 79 99 86 1992 93 92 88 102 91 84 95 86 1993 93 94 88 92 91 80 85 85 1994 93 90 75 104 86 75 97 85 1995 88 97 88 124 90 89 105 85 1996 89 106 100 121 100 57 104 94 1997 89 97 89 105 81 90 99 88 1998 81 90 83 83 86 91 95 76 1999 82 93 83 105 90 78 97 81 2000 76 86 77 106 85 78 (5)88 80 2001 -102 -84 2002 87 88 75 110 82 89 (5) 95 77 2003 85 88 68 116 88 83 96 86 2004 81 87 72 107 84 (5) M')91 86 2005 83 95 80 (5) 84 (5) 89 81/,1) uata Trom Tall gill netting.(2) Data from spring electrofishing.

(3) Data from spring Fyke netting.(4) Data from fall Fyke netting.(5) Insufficient sample size to calculate.

12 Tnhla A.h fish caugnht and released by analers at Wolf Creek Lake.# Chan. White Wiper Smallmouth All Anglers catfish bass hybrid Bass LM Bass Crappie Walleye fish Anlr cafsTasIWp I Bs 1999 9008 2000 6865 2001 7449 2002 4227 No.#Ihour#/acre No.#/hour#Iacre No.#/hour#/acre No.#/hour#/acre No.#/hour#/acre No.#/hour#/acre No.#/hour#/acre 6928 0.15 1.36 5191 0.15 1.02 5623 0.16 1.10 3949 0.19 0.77 6057 0.25 1.19 7175 0.23 1.41 10,619 0.37 2.09 15,171 0.32 2.98 7838 0.23 1.54 8777 0.25 1.72 3623 0.17 0.71 8489 0.34 1.67 6748 0.22 1.33 8048 0.28 1.58 3503 0.07 0.69 2267 0.07 0.45 1810 0.05 0.35 1649 0.08 0.32 6838 0.27 1.34 4553 0.15 0.89 2683 0.09 0.53 17,482 0.37 3.43 12,579 0.36 2.47 10,136 0.28 1.99 8097 0.38 1.59 8527 0.35 1.67 8989 0.29 1.77 7785 0.27 1.53 3885 0.08 0.76 4918 0.14 0.97 4736 0.13 0.93 874 0.04 0.17 3193 0.13 0.63 3096 0.10 0.61 1420 0.05 0.28 7382 0.15 1.45 5536 0.16 1.09 7457 0.21 1.47 4563 0.22 0.90 5739 0.23 1.13 6386 0.21 1.25 4370 0.15 0.86 31,027 0.65 6.10 21,599 0.63 4.24 20,911 0.59 4.11 11,785 0.56 2.31 6740 0.27 1.32 10,016 0.33 1.97 9457 0.33 1.86 86,464 1.82 16.99 61,102 1.77 12.00 60,417 1.70 11.87 31,807 1.65 6.84 45,895 1.86 9.02 47,229 1.55 9.28 44,629 1.54 8.77 2003 4751 2004 5674 2005 5287 13 Table 7. Selected fish sDecies harvested bv analers at Wolf Creek Lake............... .......... .' " Chan. White Wiper Smallmouth All Anglers catfish bass hybrid Bass JLM Bass] Crappie Walleye fish 1999 9008 6865 No.#/hour#/acre No.#/hour#/acre 2000 2001 7449 No.#/hour#/acre 4227 No.#/hour#/acre 2002 1628 0.03 0.32 2258 0.07 0.44 2779 0.08 0.55 1161 0.08 0.23 2457 0.10 0.48 2989 0.10 0.59 2541 0.09 0.50>12" 1149 0.02 0.23 859 0.02 0.17 1046 0.03 0.21 378 0.02 0.07 1233 0.05 0.24 1494 0.05 0.29 1281 0.04 0.25>24" 7<0.01<0.01 3<0.01<0.01 12<0.01<0.01 7<0.01<0.01 16<0.01<0.01 18<0.01<0.01 8<0.01<0.01<13" 356 0.01 0.07 198 0.01 0.04<13" 126 0.01 0.02 85<0.01 0.02<16" 364 0.01 0.07 371 0.01 0.07 303 0.01 0.06>18" 116<0.01 0.02 20<0.01<0.01>16" 69<0.01 0.01 62<0.01 0.01>20" 24<0.01<0.01 0 0 0 10<1.01<0.01>21" 14<0.01<0.01 10<0.01<0.01 4<0.01<0.01 7<0.01<0.01 1<0.01<0.01 3<0.01<0.01 6<0.01<0.01>14" 725 0.01 0.14 316 0.01 0.06 415 0.01 0.08 184 0.01 0.04 234 0.01 0.05 386 0.01 0.07 325 0.01 0.06>18" 1669 0.03 0.33 533 0.01 0.10 2003 4751 No.#/hour#/acre<18" 1609 0.05 0.32 862 0.04 0.17<18"_1244 0.05 0.24 2327 0.08 0.46 2441 0.08 0.48>18" 36<0.01 0.01 326 0.01 0.06>26" 26<0.01<0.01 7<0.01<0.01 8<0.01<0.01 6007 0.13 1.15 4366 1.13 1.35 6291 0.18 1.23 3841 0.18 0.83 5638 0.49 0.93 7662 0.25 1.51 6981 0.24 1.37 2004 5674 No.#/hour#/acre 5287 No.#/hour#/acre 2005 I ________ L ________ .~ _______________

J L L 14 N I 1 1 Main Lake Area 6 Figure 1. Fishery sampling location on Wolf Creek Lake.15 Environmental Science & Policy ELSEVIER Environmental Science & Policy 3 (2000) S275-S281 www.elsevier.com/locate/envsci Biological control of gizzard shad impingement at a nuclear power plant Dan E. Haines*Wolf Creek Nuclear Operating Corporation, 1550 Oxen Lane, Burlington, KS 66839, USA Abstract Biological control of gizzard shad (Dorosoma cepedianum) using predator fish species was managed to reduce impingement on cooling water intake screens at Coffey -County Lake (CCL), Kansas. Long term shad and predator proportional stock densities (PSD) and body conditions (Wr) were used to characterize this fishery. Comparisons were completed between the lake's primary productivity (mg/mi 3 chlorophyll-a), catch-per-unit-effort (CPUE) of young-of-year (YOY) and adult gizzard shad, and body conditions of predator species. No relationships were found between the lake's productivity and gizzard shad densities indicating that other mechanisms control shad numbers, likely predation.

Body conditions of the prevalent predator species in CCL were positively compared with the previous year's production during a short-lived increase in shad densities.

It is well documented that shad are an important food source for most predator species present in the lake. It is believed that the predator species present played a significant role in reducing YOY shad densities each year. Body conditions of predators did not indicate a surplus of a primary prey species. High shad growth rates and PSD indices promote survival of sufficient shad to adults, thus making this fishery nearly self-sustaining, and beneficial for plant operation.

© 2000 Elsevier Science Ltd. All rights reserved.Keywords:

Gizzard shad; Cooling lake; Impingement; Fishery; Predation; Biological control 1. Introduction Excessive fish impingement on intake screens can cause costly equipment damage and power production delays. In the mid-west, gizzard shad (Dorosoma cepe-dianum) can produce large numbers of young and typically reach high densities in impoundments (Pflie-ger, 1975; Willis and Jones, 1986; Dettmers and Stein, 1991). Gizzard shad, especially the young-of-year (YOY), are susceptible to winter mortality, usually as water temperatures fall below approximately 4°C (38°F) (Nebraska Public Power District (NPPD), 1985;Willis, 1987; Jester and Jensen, 1972). Impingement problems on power plant intake screens develop because these shad cannot avoid intake flows during* Tel.: + 1-316-364-8831, ext. 4672; fax: + 1-316-364-4154.

E-mail address: dahaine@wcnoc.com (D.E. Haines).such natural winter die-offs (Olmstead and Clugston, 1986; White et al., 1986).Gizzard shad is also an important forage species in most reservoirs (Pflieger, 1975; Carlander, 1969; Stein and Johnson, 1987; Colvin, 1993). Some predator in-fluences have been documented (Dettmers and Stein, 1991), but typically shad have not been controlled by predation (Putman and DeVries, 1994). It would be an obvious advantage in a power plant cooling lake, to have predator species reduce gizzard shad YOY abun-dance to densities low enough to prevent excessive impingement on intake screens, on an annual basis. In* addition, adverse environmental, public relation, and regulatory impacts associated with large impingement events could also be avoided.In 1977, early during the construction of CCL, it was expected that gizzard shad could not be excluded from, and would flourish in the lake. Consequently, an aggressive stocking program was completed, with the goal of limiting winter survival of YOY gizzard shad.1462-9011/00/$

-see front matter © 2000 Elsevier Science Ltd. All rights reserved.PII: S1462-9011(00)00067-8 S276 D.E. Haines / Environmental Science & Policy 3 (2000) $275-S281 Using management techniques not uncommon for lakes managed for sport fishing, a fishery was estab-lished with a diversity of predators.

Angler harvest was not a factor initially as no fishing was allowed.The fishery's ability to eliminate gizzard shad impin-gement events depends to a large degree on the inter-actions between the array of predator and prey species. Typical prey species tend to produce a large number of young each year. Characteristics of an annually cropped prey population, such as in CCL, would be a high relative percentage of larger, older in-dividuals, fast growth of YOY, and good health of in-dividuals.

Recruitment would also be low, which would limit the ability of the population to produce.the number of YOY needed to support the predators (Eichner and Ellison, 1983). Characteristics of predator populations in a low-prey fishery would include low recruitment due to predation or cannibalism, large per-centages of older individuals, and poor health of adults.2. Study area Coffey County Lake was constructed to provide once-through cooling water for Wolf Creek Generating Station (WCGS), an 1150 Mw, single unit nuclear power plant in east-central Kansas (Fig. 1). The lake first reached full pool in 1982, is 2060 ha (5090 acres), and has an average depth of 6.5 m (21.5 ft). It impounds an intermittent stream with a small drainage of 5050 ha (19.5 -square miles). The lake was initially filled, and subsequently maintained, via makeup water pumping from the nearby Neosho River. Two rip-rapped dikes totaling 3.6 km (2.25 miles) in length serve to disperse water flows to maximize cooling effi-ciency. WCGS cooling water is pumped at a rate of approximately 2006 m 3 (530,000 gpm) through self-cleaning rotating screens.2.1. Fishery establishment The fishery was initially established with a stocking program funded and completed by the utility, with technical advice from the Kansas Department of Wild-life and Parks (KDWP). The goal was to establish a predator population with as much species diversity as possible.

Prior to lake filling, basin preparation included comprehensive removal of undesirable.

fish species from ponds and pool areas of Wolf Creek. Fol-lowing renovation, and prior to inundation, selected ponds within the basin were stocked with fathead min-nows (Pimephales promelas) for initial forage, then with predator species selected for shad control benefits.These primarily included largemouth bass (Micropterus salmoides), smallmouth bass (M. dolomieu), black crappie (Pomoxis nigromaculatus), walleye (Stizoste-dion vitreum), striped bass (Morone saxatilis), and hybrid striped bass (wipers, M. saxatilis x M. chry-sops). The objectives of the basin stockings were to provide adults capable of spawning as the lake filled.Presence of adult predators in the young fishery also would reduce the production of initial large year classes of undesirable, rough-fish species. Predator stockings during and shortly after lake fill were com-pleted to bolster year class strength and maintain pre-dator species diversity.

Gizzard shad larvae were unavoidably introduced to the lake from the Neosho River when water was pumped to fill the lake. White bass (M. chrysops) and white crappie (P. annularis) were likely introduced in this way. These two species added to the diversity of the predator populations.

3. Methods The methods employed from 1983 to 1998 allowed for continued analyses of important long term trends.Trap (Fyke) netting, electrofishing, and gill netting were used at long-term sites on CCL (Fig. 1). Four III Fig. 1. Coffey County Lake, Kansas with fishery sampling areas identified.

S278 D.E. Haines/ Environmental Science & Policy 3 (2000) S275-S281 chi depth measurements taken concurrent with chlorophyll a (mg/mr 3) monitoring were compared.This relationship was significant (r = -0.71, n = 24, p.<0.05).

Therefore, secchi depths were reflective of CCL primary productivity, and could be used in place of chlorophyll a measurements.

A similar relationship was identified for some Missouri reservoirs (Michaletz, 1999).To determine if YOY shad densities were influ-enced by CCL productivity, secchi depths measured concurrent with seine efforts were compared with YOY shad catches per seine haul. These compari-sons were segregated by lake location and month.No significant relationships were found between any of the comparisons.

This indicates that gizzard shad in CCL have not been limited by. lake productivity, and have been limited by other limiting factors, likely by predation.

Predation influences on shad YOY densities were tested by comparing the predator Wr indices (Table 1)with the previous year's YOY CPUE from seine efforts. Only data from 1993 to 1997 were used to bracket the largest rise and fall of YOY shad densities (Fig. 2). Largemouth bass data were not analyzed because too few specimens were collected to obtain a confident Wr average. Significant relationships (p<0.05) were identified for white bass (r = 0.92), wiper hybrid (r = 0.83), smallmouth bass (r = 0.72), white crappie (r 0.97), and walleye (r = 0.79). This is evidence demonstrating that predator species respond to larger increases and subsequent decreases in shad YOY densities.

Such relationships were not as evident for the other years sampled. It is possible that other prey species, or cannibalism were relied upon during periods of low shad production, and predator Wr may reflect variations in those prey sources.4.2. Long term maintenance via recruitment The long term maintenance of the predator-prey balance of this fishery depends on the continued recruitment of sufficient gizzard shad, as stated above.In CCL, shad survival to reproducing adults may have depended on how quickly they were able to grow too large to be eaten. Typically, gizzard shad grow quickly to sizes large enough to escape significant predation, and this has been considered a detriment to sport fish management (Putman and DeVries, 1994). However, this was not considered detrimental in CCL, but rather beneficial to maintaining low shad densities vulnerable to impingement.

There were inferences that many of the reproducing sized shad were recruited from the -fas-ter growing YOY identified in scale age analyses.Many of the larger fish sampled in 1998 had back-cal-culated first-year growth from 200 to 230 mm (Table 2). Because of the heated water discharge, past monitoring has shown that these larger, first-year shad were likely spawned earlier in the year, and their growth was enhanced by a longer growing season (Nuclear Regulatory Commission, 1982). The first year-growth shown in Table 2 also implies that few of the smaller (90-150 mm TL) YOY shad survived to recruit to reproducing size, and heavy predation was a likely cause. Once the larger YOY grew large enough to escape the majority of CCL predators, consumption of the smaller shad should have intensified from late summer to early autumn. Apparently, the faster grow-ing shad were the ones that successfully recruited, and comprised the majority of the reproducing sized adults that support the predator populations.

Without the thermal discharge influences, length frequency distri-butions of YOY shad would likely be more com-pressed, similar to other area lakes (Willis 1987).J Gizzard Shad Catch-Per-Unit-Effort for Coffey County Lake Z 50 5 F 45 40-E J 35 a.E 30 0 S25 Z 20'L 15 01 C* , Adult shad YOY shad \I \I\\I 60 50 40 30 >.20.-°10 0 0- Go0 0 0 0 0 0) 0 F 0 CD 0 co 0 o co o)0 0 0 0) S a Fig. 2. Gizzard shad catch-per-unit-effort for adults from standard gill net complements and young-of-year from seine efforts at Coffey County Lake, Kansas.

D.E. Haines / Environmental Science & Policy 3 (2000) S275-S281 S277 primary lake locations were consistent from year to year and chosen to sample the upstream, main-body, plant cooling water intake, and the plant discharge areas. Important species to the fishery were targeted when they were expected to be most efficiently sampled.Two Fyke nets were set at each location during two nights for a total of four net-nights per location per year. Locations included the upper and main body during 1983, with the intake area being added during 1984, and the discharge area in 1986. These nets were set near shore in 4-6 ft of water as spring-time water temperatures approached 12'C (55°F), usually during early April of each year. Fyke nets targeted primarily crappie and walleye. Important information was also provided about the winter survival and recruitment of the previous year's gizzard shad production.

The CPUE was calculated as the number of fish of a tar-geted species per trap net-night.

A Smith-Root boat mounted shocker with circular electrode arrays, operated at approximately 10 A and 220 V of pulsed DC current, was used for electrofish-ing samples. Four efforts each year, two in the spring (May-June), and two in the autumn (September-Octo-ber) were completed.

Locations included the upper and main body during 1983, with the intake area added during 1984, and the discharge area in 1986. Two 15 min (energized time) subsamples at each location were shocked each time. This gear type targeted large-mouth bass and bluegill (Lepomis macrochirus) in the spring. Fall shocking targeted smallmouth bass, and provided indications on shad YOY production.

Elec-trofishing efforts were also completed during other months at the same locations during some years to provide YOY gizzard shad data. Electrofishing CPUE was calculated as the number of fish per hour shocked.Gill netting was an extensive, two night effort in October of each year. Locations included the upper, main body, and intake areas during 1983, with the dis-charge area being added during 1986. The gill nets were used to sample white bass, wiper, walleye, and gizzard shad. One gill net complement was set at lo-cations consistent over the years during two consecu-tive nights for a total of eight complement net-nights each year. A standard gill-net complement included four nets, one each of 25.4, 38.1, 63.5, and 101.6 mm mesh (bar measure).

Each was a 30.5 x 2.4 m uniform mesh monofilament net. The CPUE was calculated as the number of a species sampled per standard comp-lement night.Seine hauls were completed monthly (June-August) from 1983 to 1993. From 1994 to 1997, only June and July samples were taken. Effort consisted of two hauls per location per month from 1983 to 1984. Five hauls per location per month were completed from 1985 to 1997 (Fig. 1). The upper and main body locations were sampled since 1983, while the intake area was included since 1984. The discharge area was sampled beginning in 1985 and ending in 1996. Seine dimen-sions were 15.2 x 1.8 m, with a 1.8 x 1.8 m bag. A seine haul consisted of one 90° arc along the shoreline.

The CPUE was reported as the number of fish per seine haul.Fish sampled were weighed to the nearest gram, and measured (total length (TL)) to the nearest millimeter.

Secchi depth measurements were taken concurrent with most fishery sampling efforts. Proportional stock density (PSD, Anderson, 1976) was calculated for all species. PSD is the proportion of a sample that are lar-ger than a predetermined length. Fish smaller than a minimum size are excluded.

Relative weight (Wr, Anderson, 1980) indices were calculated for each species and used to assess the health of a species rela-tive to its capability in this region. Length-weight equations for Wr adopted by the KDWP were used.Gill net efficiency adjustments to the PSD indices were completed for gizzard shad, white bass, and walleye (Willis et al., 1985).Primary productivity expressed as chlorophyll a con-centrations (mg/mi 3) were. determined for upper, main body, and intake areas of CCL roughly corresponding to fishery sampling locations (Fig. 1). Chlorophyll a values were corrected for phaeophytin, and determined using flourometric methods per American Public Health Association et al. (1981). Secchi depth measure-ments were taken concurrent with most chlorophyll a samples. Pearson correlation coefficients were calcu-lated to determine relationships between chlorophyll a, CPUE, and Wr. Paired student's t-tests were used to test significance at p < 0.05.4. Results and discussion

4.1. Influence

on and control of gizzard shad YO Y densities Gizzard shad production of YOY were measured using mid-summer seine efforts throughout 1997 (Fig. 2). Results from these efforts were highly vari-able, which is inherent to this gear type (Ploskey et al., 1990). This variability from CCL in itself indicates low densities because sampling the sparse schools of shad created a 'hit or miss' result. Despite the variability, the results provide an approximation of YOY shad production trends and were of value in some of the comparisons.

To ensure that the survival of YOY shad was not limited by lake productivity, shad densities were compared with secchi depth measurements.

Secchi depths were used as indices of primary productivity of CCL. To confirm this relationship for CCL, sec-Table 1 Catch-per-unit-effort (CPUE), proportional stock density (PSD), and condition indices (Wr) for gizzard shad and predator fishes sampled from 1983 to 1998 at Coffey County Lake Species 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 Gizzard shada CPUE PSD Wr White bassa CPUE PSD Wr Wiper hybrid'CPUE PSD Wr Largemouth bassb CPUE PSD Wr Smallmouth bassc CPUE PSD Wr White crappied CPUE PSD Wr Walleye'CPUE PSD Wr 10.5 24.8. 3.0 32.1 9 24 31 84 85 87 88 85 9.7 12.3 20.5 10.1 16.6 21.3 11.5 92 96 97 100 92 93 ,98 89 90 104 100 93 93 93 9.5 25.5 10.4 20.1 18.9 51 75 96 94 99 t 93 88 89 89 81 23 100 78.15 100 90 18 94 94 11 100 86 6 100 89 22 100 78 25 34 86 14 100 84 18 92 93 28 74 94 17 82 95 23 97 80 34 35 99 12 96 82 45 63 93 17 82 92 52 43 94 61 85 90 21 26 100 100 89 85 22 9 8 11 100 100 .100 100 78 88 88 75 5.5 8.3 5.0 2.0 100 82 85 88 79 84 80 75 32.0 42.3 45.3 35.4 18.8 22.0 32.3 14.0 41 76 92 91 93 92 99 97 97 98 97 93 88 92 87 84 29 19 60 45 !" 76 58 46 61 2 97 106 97 90 !1 11 3 8 6 85 30 88 89 .88 100 89 83 2.0 0.3 1.3 1.5 " 100 100 60 50 R 89 57 90 91 , 6.3 10.8 5.5 10.5 52 58 50 52 4 90 100 81 86 5 9 4 3 87 72 71 74 105 104 99 95 16 20 28 16 83 73 31 55 85 94 88 76 6.5 50 96 5.0 5.3 1.3 8.5 10.5 14.8 12.0 20.5 10.8 15.0 12.5 67 33 80 55 29 37 40 61 40 44 40 99 95 93 97 92 92 104 91 91 91 86 0 6-94-93 5 20 94 26 75 83 5 52 93 9 74 81 12 9 68 85 89 102 4 60 88 22 94 88 5 70 98 13 96 85 4 87 99 19 77 86 6 63 95 22 93 86 5 75 87 12 90 85 4 41 97 13 52 85 4 29 78 29 75 82 16 100 80 19 95 81 Data from fall gill netting, CPUE = Ol/gill net complement net night.b Data from spring electrofishing, CPUE I=/h.C Data from fall electrofishing, CPUE = Il/h.d Data from spring Fyke netting, CPUE = 0l/trap net night.Cd, t'J-J "S280 D.E. Haines/ Environmental Science & Policy 3 (2000) S275-S281 Table 2 Gizzard shad back-calculated lengths from scale samples collected during October, 1998 at Coffey County Lake. Final entries for each year class represents total length at capture. Size at scale formation assumed at 30 mm Year class Total length at annulus formation 1 2 3 4 5 6 1993 (n = 5)Average 257 346 378 400 430 450 Range 234-297 317-371 352-398 386-421 414-445 428-463 1994 (n = 10)Average 226 337 385 416 437 Range 151-317 279-374 351-407 394-407 415-455 1995 (n = 14)Average 222 353 390 414 Range 120-329 274-397 302-424 310-448 1996 (n = 16)Average 196 297 327 Range 82-275 246-337 296-358 1997 (n = 2)Average 132 189 Range 115-148 184-194 Consequently, the power plant discharges contribute to both the recruitment of the faster growing YOY, and the annual consumption of YOY shad vulnerable to impingement.

5. Conclusions The dynamics of the CCL fishery demonstrate that impingement can be biologically controlled in certain instances.

Impacts from the intake of cooling water, both to impinged fish and to plant operating efficiency can be reduced. Fishery management techniques can be used to promote predator prey balances that enhance the compatibility of cooling lakes for power plants and a sustainable fishery.References American Public Health Association, American Water Works Association, Water Pollution Control Federation, 1981. Standard Methods for the Examination of Water and Wastewater, 15th ed.APHA, Washington.

Anderson, R.O., 1976. Management of small warm water impound-ments. Fisheries 1(6), 5-7, 26-28.Anderson, R.O., 1980. Proportional Stock Density (PSD) and Relative Weight (Wr): Interpretive Indices for Fish Populations and Communities.

In: Gloss, S., Shupp, B. (Eds.) Practical Fisheries Management:

More With Less in the 1980's. New York Chap., American Fisheries Society, Workshop Proceedings, pp.27-33.Carlander, K.D., 1969. Handbook of Freshwater Fisheries Biology, vol. 1. Ames, Iowa: Iowa State University Press.Colvin, M., 1993. Ecology and Management of White Bass: a Literature Review. Missouri Department of Conservation, Dingell-Johnson Project F-I-R-42, Study 1-31, Job 1, Final Report.Dettmers, J.M., Stein, R.A., 1991. Controlling Gizzard Shad Populations via Introduced Predators.

Ohio Department of Natural Resources, Division of Wildlife.

Federal Aid in Sport Fish Restoration Project F-57 and F-69, Study 19, 185 pp.Eichner, D., Ellison, D.G., 1983. Lake McConaughy Fishery Investigations.

Study VI. Nebraska Game and Parks Commission, Fisheries Division.

Federal Aid in Fish Restoration, Dingell-Johnson Project F-51-R-5, 66 pp.Jester, D.B., Jensen, B.L., 1972. Life History and Ecology of the Gizzard Shad, Dorosoma cepedianum (LeSueur)

With Reference to Elephant Butte Lake. New Mexico Agricultural Experiment Station Research Report 218.Michaletz, P.H., 1999. Influence of reservoir productivity and juven-ile density on first-year growth of gizzard shad. North American Journal of Fisheries Management 19, 842-847.Nebraska Public Power District (NPPD), 1985. Gerald Gentleman Station Impact Assessment of the 1984 Year-class, Sutherland Reservoir.

Prepared by EA Engineering, Science, and Technology, Inc. EA Report NPP52G.Nuclear Regulatory Commission, 1982. Final Environmental Statement Related to the Operation of Wolf Creek Generating Station, Unit No. 1, NUREG-0878.

Washington, DC.Olmstead, L.L., Clugston, J.P., 1986. Fishery management in cooling impoundments.

In: Hall, G., Van Den Avyle, M. (Eds.), Reservoir Fisheries Management, Strategies for the 80's.American Fisheries Society, Bethesda, MD, p. 327.Pflieger, W.L., 1975. The Fishes of Missouri.

Missouri Department of Conservation.

Ploskey, G.R., Stephen, J.L., Gablehouse Jr, D.W., 1990. Evaluation of Summer Seining in Kansas Reservoirs.

Proceedings of the Annual Conference Southeastern Association of Fish and Wildlife Agencies 44, 76-88.Putman, J.H., DeVries, D.R., 1994. The Influences of Gizzard Shad (Dorosoma cepedianum) on Survival and Growth of Largemouth Bass (Micropterus salmoides), Bluegill (Lepomis machrochirus), and White Crappie (Pomoxis annularis).

Alabama Department of Conservation and Natural Resources.

Investigation of Management Techniques for Public Waters, Study XIV. Federal Aid in Fish Restoration Project F-40-R, Study XIV.a D.E. Haines / Environmental Science & Policy 3 (2000) S275-S281 S281 Stein, R.A., Johnson, B.M., 1987. Predicting Carrying Capacities and Yields of Top Predators in Ohio Impoundments.

Ohio Department of Natural Resources, Division of Wildlife.

Federal Aid in Fish Restoration Project F-57-R-5 through R-9, Study 12, 144 pp.White, A.M., Moore, F.D., Alldridge, N.A., Loucks, D.M., 1986.The Effects of Natural Winter Stresses on the Mortality of the Eastern Gizzard Shad, Dorosoma cepedianum, in Lake Erie. The Cleveland Electric Illuminating Company and The Ohio Edison Company, Cleveland, Ohio. Environmental Resource Associates, Inc. and John Carrol University.

Report 78. 208 pp.Willis, D.W., 1987. Reproduction and recruitment of gizzard shad in Kansas reservoirs.

North American Journal of Fisheries Management 7, 71-80.Willis, D.W., Jones, L.D., 1986. Fish standing crops in wooded and nonwooded coves of Kansas reservoirs.

North American Journal of Fisheries Management 6, 393-425.Willis, D.W., McCloskey, K.D., Gablehouse Jr, D.W., 1985.Calculation of stock density indices based on adjustments for gill net mesh size efficiency.

North American Journal of Fisheries Management 5, 126-137.Dan E. Haines received a BSc degree from Emporia State University, Emporia, Kansas and a MSc degree from Emporia State University in Environmental Biology. He has been employed as an Environmen-tal Biologist at Wolf Creek Nuclear Operating Corporation since 1983. Responsibilities include natural resource and fishery manage-ment of the cooling lake to support operation of the electric generat-ing plant.

APPENDIX D EPA Region VII Policy on Gizzard Shad Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)56 SUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION VII 901 NORTH 5TH STREET KANSAS CITY, KANSAS 66101 27 NOV 20 Mr. Steve Williams Bureau of Water, NPDES Permits Iowa Department of Natural Resources Wallace State Office Building 502 East 9th Street Des Moines, IA 50319

Dear Mr. Williams:

The Iowa Department of Natural Resources (IDNR) forwarded a report to the Environmental Protection Agency (EPA) which was submitted by Muscatine Power and Water titled Analysis of Gizzard Shad Winter Die-Off and Its Relevance to315('o).

Muscatine Power and Water has indicated that dead and moribund gizzard shad should not be counted as part of the impingement calculation baseline.

The report proposes a methodology for the accounting for dead and moribund gizzard shad in the determination of the impingement calculation baseline.'

This is a very important question, because impingement of fish is dominated by moribund gizzard shad at several powerplants in Region 7. Based on our discussions and research, you asked that I send a letter to show EPA's position.We agree that moribund fish should not be counted in the impingement calculation baseline.

Sampling of impingement should count all fish, but moribund fish should not count toward the calculation baseline.As defined in the 316(b) Regulations at 40 CFR § 125.93, the "Calculation Baseline means an estimate of impingement mortality" (emphasis added). The definition goes on to describe that the baseline estimate is based on a certain configuration of a once-through cooling water intake. With this in mind, the primary guide of setting the baseline calculation is the impingement mortality associated with a baseline intake configuration.

The rule does not directly show how moribund fish should be considered in setting the baseline estimate, although it does allow for consideration of moribund fish in the Verification Monitoring Plan. As emphasized above, the baseline calculation is an estimate of impingement mortality, the mortality that would occur due to impingement on the intake screens. Therefore, the calculation baseline should be an estimate of impingement mortality based in the impingement and harm of healthy fish, not the incidental capture of moribund and dying fish.The paper submitted by Muscatine Power and Water provides a good overview of the natural history of the gizzard shad, a description of the biological mechanisms of the winter die-off, and the field conditions that precipitate the die-off.RECYCLED a-,M %FrBER 2 The Muscatine Power and Water paper lines up several points to make an estimate of moribund vs. healthy gizzard shad on a seasonal basis. Here are the main points: " Description of the monthly conditions associated with the die-off; i.e., the site specific calendar dates where die off conditions are observed." An estimate of the percentage of kill during die-off events. Even in the cold months, there are some healthy individuals and the report uses data to make an estimate of healthy fish.* The report assumes that gizzard shad are healthy during the warm months of the year..The EPA Region 7 supports the Muscatine Power and Water approach and we believe that the logic of this methodology could be used at other sites in Region 7.Thank you for your help in working through this approach.

If you have any questions, please call me at 913-551-7594.

Sincerely, 2 oh A. Dunn Environmental Engineer Wastewater and Infrastructure Management Branch cc: Daryl Jahn, Muscatine Power and Light August 9, 2006 Mr. Daryl K. Jahn Environmental Specialist Muscatine Power and Water 3205 Cedar Street Muscatine, Iowa 52761-2204

Dear Mr. Jahn:

HDRILMS is pleased to submit the final version of the report that describes the winter die-off of gizzard shad in the more northerly portions of its geographical range. This is an annual phenomenon which often strains the capability of water traveling screens when large numbers of dead and dying shad are brought in through the :intake structures of electric generating facilities.

The relevance of these dead and dying fish to the determination of the calculation baseline in the Section 316(b) Phase II Rule is not addressed in the Rule which sets forth a Performance Standard for reduction of 'impingement mortality of fish on the traveling screens. The key term is impingement mortality which should not apply to fish that are dead or irreversibly dying before they reach the traveling screens.We are confidant that the information put forth in this report will be considered by the Iowa DNR as it deliberates this issue.If you have any questions, please do not hesitate to contact me after my return from vacation on August 22, 2006.Very truly yours, Bruce L. Lippincott, Ph.D.Manager Mid West Operations (lau6).HDR I LMS HDR Engineering.

Inc.10207 Lucas Road Woodstock.

IL 60(97445 Phone. 18151334.9511 Fax: 18151334-9514 wwwv hdrinc.com Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)Prepared for Muscatine Power and Water 3205 Cedar Street Muscatine, Iowa 52761 August 2006 HDRILMS 10207 Lucas Road Woodstock, Illinois 60098 Table of Contents 1 Introduction..........................................................................................................

I 1.1 Background

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1 1.2 Question ...........................................................................................................

1 1.3 Objective

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2 2 Gizzard Shad Range Extension and W inter Mortality

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2 3 Synopsis of Physiological and Biochemical Studies on Gizzard Shad Collected During the W inter Season ...................

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3 3.1 Use of Total Lipids as Energy Source .................................................................

4 3.2 Effects of Starvation on Lipid Reserves, Serum Glucose, and Total Serum Protein4 3.3 Cystolic Lactate Dehydrogenase

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5 3.4 Serum and Brain Glucose ....................................................................................

5 3.5 Cholesterol

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6 3.6 Summary ...........................................................................................................

7 3.6.1 Total Lipids ..................................................................................................

7 3.6.2 Cystolic Lactate Dehydrogenase

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7 3.6.3 Serum and Brain Glucose ...........................................................................

8 3.6.4 Cholesterol

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8 4 Quad Cities Nuclear Generating Station Intake Studies ............................................

8 5. Impingement Data Collected During W inter 2005/2006

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10 6. Relevance to 316b Phase II...... .... *...... .........................

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19 7. Recommendations

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.....1...... ...................................................................

19 8. References

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20 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)Analysis of Gizzard Shad Winter Die-Off and Its Relevance To 316(b)1 Introduction

1.1 Background

Following several years of discussion, review, and revision by both regulators and the regulated community, USEPA published the Clean Water Act, Section 316(b) Phase II Rule on July 9, 2004. This rule is directed primarily at existing electric generating facilities with the objective of reducing the numbers of fish and shellfish that are removed from the source water body by the Cooling Water Intake System (CWIS) through impingement on the traveling water screens and/or entrainment of early life stages in the cooling water stream.The Rule defines Performance Standards to be met for both impingement and entrainment, criteria for qualifying for each standard, a roadmap by which to navigate through the process, generic groupings of compliance measures that are to be considered, economic valuations, and a general instruction directed at monitoring effectiveness of compliance measures selected.

The Rule is clear that all facilities must comply with the impingement standard but some are exempted from the entrainment standard.Central to the Rule is the determination of the calculation baseline which estimates the numbers of organisms that are impinged and/or entrained.

This is the set of numbers against which the .Performance Standard is measured and influences compliance measures selected to satisfy the'Performance Standard.

Nearly all affected facilities have needed to conduct impingement studies" (and some have needed to conduct entrainment studies) to provide current.data for determination of the calculation baseline.The Rule and the text which surrounds it are silent on one aspect of counting impinged fish for computation of the calculation baseline; namely, the treatment of fish that are dead or moribund before they reach the traveling water screens during periods of winter die off. (Moribund fish are mentioned in the verification monitoring section of the Rule but only to the extent that they will need to be addressed at that time.) By its silence, the Rule infers that this decision is to be made by state Directors, who are defined in the Rule. It appears, then, that each state will need to decide how to treat these fish within the context of the Rule. More specifically, decisions need to be made about the treatment of gizzard shad in those states that are located within the northern portion of this species' geographical range and that experience large, natural winter die off of gizzard shad on an annual basis.1.2 Question The salient question is: Should dead and moribund gizzard shad be counted in determination of the impingement calculation baseline?HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)The simplest answer is "yes;" but that contradicts the intent of the Rule which is to reduce the numbers of live fish lost to the environment through compliance with the Performance Standard using one or several compliance measures.

That is, mortality caused by impingement is to be reduced by at least 80% and there is no benefit to be gained by including already dead or moribund gizzard shad in the computations.

Assigning some calculated monetary value to fish that have already died or are close to death is a questionable exercise that places an undue burden on the applicant.

A more practical response is "no" in those cases where a large portion of the total annual impingement, either by numbers or by weight, is composed of gizzard shad and most of them are collected in a moribund state during the cold weather period between November 1 and March 31.The latter response needs to be supported by scientific data that documents the percentages of healthy, dead, and moribund gizzard shad that are found in the vicinity of the CWIS traveling screens during the winter months and provision of physiological information that explains cold death in this species and its irreversible path in moribund specimens.

1.3 Objective

The objective of this "white paper" is to provide scientific information that can be used in the decision-making process to answer the question.

This will include a brief history of the northerly range extension of gizzard shad and observations on winter behavior, results of a winter study conducted at an electric generating station located on the Mississippi River which documents percentages of healthy, dead, and moribund gizzard shad collected before the trash racks,.and a synopsis of critical physiological and biochemical pathways that. are disrupted by cold ambient: water temperatures leading to death in this more southerly species.2 Gizzard Shad Range Extension and Winter Mortality Gizzard shad, Dorosoma cepedianum, is a southerly species that began to radiate northward sometime after 1820 when it was first reported in the Ohio River near Cincinnati (Kirtland, 1844). The species continued to migrate northward through the remainder of the 1800's; and by 1900 had reached Lake Erie and southern Lake Michigan (Miller, 1960). During the second half of the 20'h Century, gizzard shad were reported from the Upper Great Lakes (Scott and Crossman, 1973; Becker, 1983) and Eddy and Underhill (1974) reported a collection being made during the decade of the 1960's in the Minnesota portion of the Upper Mississippi River.Concurrent with this range extension, gizzard shad populations in established areas began to explode during the 1950's. This trend continued for a period of over 30 years and continues today. A number of authors have suggested possible reasons for this range extension and population explosion including increased phytoplankton availability (Trautman, 1956), increased spawning habitat (Bodola, 1955), a decreased number of predators (White et al., 1975), increased areas of thermal discharge (Becker, 1983), and a documented warming trend between 1950 and 1980 (Assel, 1980). While it is difficult to separate these factors, White et al. (1986) suggest that the warming trend was a central cause. The warming that is attributed to the greenhouse gasses continues to contribute to the success of this species widely in range extension and population numbers. On a more local level, warm water discharges provide winter sanctuaries that shelter gizzard shad during the cold weather period which allows them to survive to the following season.2 HDRILMS August 2006 Analysis ofGizzard Shad Winter Die-Offand .Its Relevance to 316(b)Numerous authors have reported periodic die off of this species that occurs always during the winter. Kirtland (1844) reported heavy winter kills in the Ohio River and White et al. (1986)described the winter kills as often being massive and population dependent.

Most authors noted that the die offs occurred in December during periods of rapidly declining temperatures.

This was observed annually in Crab Orchard Lake in southern Illinois (Wehr, 1976).However, rapid temperature declines were not the only phenomenon observed to be associated with the die offs. Heidinger (1983) indicated that winds that cause turnover at 40 C contribute to the die off in lakes suggesting that this may be a tipping point temperature.

Walberg (1964)reported that 100% of the 0+ age class of gizzard shad died after ice covered a South Dakota Lake for more than 103 days. Not all authors agree on specific temperatures at which these fish become disoriented and die and recovery has been observed following exposure to low temperatures for short periods of time (Neumann et al., 1977). All this suggests that several temperature parameters work in concert to cause death. In addition to rapid temperature declines, low temperatures and duration of the low temperature period both play a role in the winter mortality.

The last parameter that appears to play a role in winter mortality is size of the individual fish (Heidinger, 1983; Mayhew, 1983). Most observers have noted that the smaller individuals die first in the earlier part of the winter and the larger individuals die later in the season. This has'been documented by Trautman (11981) who reported the young-of-year (YOY) gizzard shad in Lake Erie ranged in size from 64 t'o 10 mm in length' in November but ranged from 100 to 230 mm in length by annulus formation in the Spring. Caroots (1976) showed that Lake Erie gizzard shad YOY.::.measured from 30 to 160 mm in October but from 95 to 165 mm by about the first of April.'While acclimation may play some role in -these observations, it does not fully explain-the' observations.

Furthermore, this is essentially a no growth period for these fish. These data suggest. that high mortality is 'size selective and that YOY gizzard shad are especially vulnerable to winter mortality.

All authors report that, after May 1, mortality rates in the gizzard shad populations return to normal levels.Information presented in this section has been observed over a long period of time and leads to two questions.

First, what causes such large numbers of gizzard shad, particularly YOY shad, to die during the cold weather period? Second, what percentage of gizzard shad coming into CWIS are healthy during the winter months?3 Synopsis of Physiological and Biochemical Studies on Gizzard Shad Collected During the Winter Season White et al. (1986) conducted the seminal study that investigated many physiological and biochemical pathways in YOY gizzard shad during the winter period to determine why and how these fish die. They determined from literature that the YOY size range for Lake Erie gizzard shad was40-160 mm SL which, using information presented in Carlander (1969), converts to a range of approximately 50-210 mm TL.It is not the intent of this synopsis to summarize each pathway investigated; but rather, to present information concerning those that are most critical to death of individual shad. These include: 3 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)* Use of Total Lipids as Energy Source* Effects of Starvation on Lipid Reserves, Serum Glucose, and Total Serum Protein* Cystolic Lactate Dehydrogenase

• Serum and Brain Glucose* Cholesterol 3.1 Use of Total Lipids as Energy Source Cold-blooded organisms survive winter in one of three ways. One is to cease feeding and become totally inactive.

A second is to remain active and feed opportunistically and the third is to cease feeding but remain somewhat active. In all three survival mechanisms, lipids are used as energy sources with some catalysis of other tissues as emergency sources of energy when lipids are depleted.

These other tissues are quickly regenerated when ambient temperatures begin to rise in the spring.Gizzard shad is a species that appears to use the third survival strategy, i.e. it remains active until temperatures approach freezing but discontinues feeding when water temperatures reach approximately 11 0 C (Bodola, 1966). White et al. (1986) reported that total lipid content in gizzard shad taken from LakeErie during the October-November period ranged from 23 to 41%of dry weight but that this percentage did not decrease over the winter and the total lipid content actually increased slightly by March 1 which was contrary to the survival strategy.A time series experiment was then designed to sample gizzard shad bi-weekly throughout the following winter season to identify the water temperature at which lipid utilization ceases and the results indicated that, when water temperatures are below 80 C, lipids are no longer utilized for energy. The result is that gizzard shad, particularly YOY shad, begin to starve in spite of relatively high lipid reserves.

Liver and muscle glycogens are quickly exhausted and this is followed by tissue catalysis to provide energy. Liver tissue is broken down first and is accompanied by loss of liver functions including elimination of ammonia, breakdown of bilirubin, and red blood cell lysis. By the end of winter, the liver is not recognizable and the total physiologic failure of individuals causes continuous mortality throughout the winter season. This catalysis is not reversible following long periods of cold weather.Small YOY shad were observed dying in November before water temperatures declined below 80 C and assays of these fish revealed that they had no lipids stored. It was concluded that they were hatched late in the season and food was used entirely for growth with very little being converted to lipids.3.2 Effects of Starvation on Lipid Reserves, Serum Glucose, and Total Serum Protein White et al. (1986) designed a series of laboratory experiments to determine whether gizzard shad utilize lipids at water temperatures greater than 110 C when they are starved. Results of these tests showed that that death occurred daily after about 22 days of starvation at room temperatures (20-220 C). Fish were randomly selected throughout the experiments and assayed. Data from one such experiment showed that serum glucose declined by 29.3%, total serum protein by 21.6%, and lipids by 37.9%, while serum ammonia remained essentially constant.

In a separate 4 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 3 16(b)experiment, serum glucose concentrations as low as 1.68 and 2.52 mg/dl were recorded.Collectively, these experiments indicated that practically all available energy substrates were used before death in water temperatures in the 20-22* C (68-72' F) range.The authors conclude that these data, coupled with the inability to use lipids at water temperatures below 8* C, areconsistent with a species living near the northerly edge of its range.3.3 Cystolic Lactate Dehydrogenase Cystolic lactate dehydrogenase (LDH) is an important enzyme (organic catalyst) that is an integral part of temperature adaptation in cold-blooded organisms.

This enzyme is associated with energy activation in tissues and is used to evaluate thermal adaptation.

Certain enzymes may be membrane bound and others may be soluble. LDH is a soluble, multimeric enzyme meaning that it exists in multimeric forms called isozymes which are genetic variants of the proteins which form the enzyme. The survival strategy of adaptable organisms is to have isozymes that function under different physiologic situations.

Thermally adapted organisms possess one isozyme that functions at higher temperatures, one that functions in the intermediate temperature range, and one that functions near the bottom of their environmental temperature range.Assays of shad transported to the labqoratory from various locations on Lake Erie (White et al., 1986) indicated that gizzard shad:are: " Genetically variable within populations, meaning that some individuals were-capable of adapting while others were not." Maximum LDH activity in muscles occurred in January well after lake water had~cooled below i100 C (the temperature which required enzymatic adaptation) indicating that enzymatic adaptation occurred too late in the season." Maximum LDH activity in the brain occurred in March, much too late in the season for survival." Maximum levels of LDH activity were most likely the result of those individuals that survived rather than a true acclimation within the population to the colder temperatures.

This suggests that poorly adapted individuals are selected out.* LDH adaptation may be the most important factor influencing early winter survival.* Lactic acid should have been processed later in the winter but was not, indicating that a factor other than LDH acclimation was in play later in the winter season. This was indicative of a lack of membrane permeability.

These results indicate that early winter season mortality is attributable to the inability of LDH to adapt to the colder temperatures quickly and that mortalities which occur later in the winter are caused by other physiologic failures.3.4 Serum and Brain Glucose White et al. (1986) collected gizzard shad from Lake Erie and assayed them for serum and brain glucose during periods of active feeding in the fall and throughout the winter for three winters.Serum glucose levels were established for actively feeding individuals as the baseline against which levels recorded for non-feeding individuals could be measured as the winter season.5 HDR/LMS August22006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)progressed.

This baseline ranged from 35 to 40 mg/dl and concentrations measured during the winter months continually rose and reached levels that were about 10 times those of the active feeding periods. These high levels were indicative of some physiologic failure and the authors investigated and dismissed several possible causes including adrenal collapse, which controls catabolism of muscle tissue to serve as an energy substrate, and starvation.

As they systematically tested possible failures, it became evident that increased serum glucose levels were indicative of cell membrane transport failures, i.e. substances were not being diffused either in or out of cells and glucose was building up as a result. Cell membranes had become rigid at lower water temperatures.

Of all the body tissues, those of the central nervous system, including the brain, are the most demanding for a steady supply of energy. Due to loss of permeability of the membranes, these cells, particularly brain cells, are deprived of this energy supply. If this occurs rapidly, then the brain loses its ability to function which is manifested in loss of locomotion function and quickly thereafter by loss of equilibrium.

Individuals are observed to be swimming erratically and/or on their sides. This is often followed by a comatose condition.

is this loss of locomotion and equilibrium attributed to a hyperglycemic or a hypoglycemic condition?

Unfortunately, both conditions manifest in similar observable behavior and the investigators found that both existed during different die-offs, Therefore, the condition is, attributable to a difference in concentrations across the membranes rather than either too much or too-little glucose in the brain. This suggests membrane failure orý the. loss of memnbrane fluidity.Thermal shock that may be experienced by shad swimming into and out of thermally enhanced'areas would result in a hyperglycemic condition.

Because the, hypoglyc~emic condition was also.do~cumented, the authors concluded that die-offs are not caused by thermal -sh ock.Combining the observations of substantial increases in serum glucose with a hypoglycemic condition in the brain indicates that shad attempt to compensate the loss of membrane fluidity or transport by increasing concentrations outside the brain cells. This is the physiologic failure that leads to erratic swimming and the comatose condition which is quickly followed by death.3.5 Cholesterol The basic premise of functionality of biological membranes is the ability to maintain a constant fluidity, irrespective of temperature.

This fluidity is a function of the types of lipid molecules in the membrane and can be tested by measuring the cholesterol content of the serum and cell membranes, with higher, relatively constant levels being associated with individuals that are adapted and survive the winter. Conversely, individuals that exhibit low serum cholesterol concentrations at any given time during the winter are at greatest risk of dying. This, coupled with shad having the greatest degree of liver degeneration, provides the best predictor of risk of death.Shad assayed for serum cholesterol throughout the winter including prior to, during, and following die off events indicated that those which died had lower serum cholesterol concentrations than those that survived.

Because serum cholesterol levels are not quickly modified, it is possible to predict which subsets of the population are at risk by knowing the serum cholesterol concentrations.

6 HIDR/LMS August 2006 Analysis of GizzardShad Winter Die-Off and Its Relevance to 316(b)White et al. (1986) then investigated cholesterol levels on cell membranes to determine their fluidity because results of the serum -cholesterol levels did not explain the apparent problem of diffusing glucose into brain cells. Shad cell membrane cholesterol concentrations were compared to those of a cold adapted species, yellow perch. The investigators found that yellow perch increased theircell membrane cholesterol levels as the winter season progressed but shad did not.Membrane -cholesterol is necessary to maintain fluidity and the yellow perch acclimated.to colder temperatures by producing more membrane cholesterol.

Shad, on the other hand, failed to make this adjustment and cell membranes became too rigid to accommodate the glucose diffusion transport phenomenon except at the lowest concentrations.

This led to brain glucose deprivation and subsequent death in a short period of time.3.6 Summary Investigation of biochemical pathways in gizzard shad. beginning in the fall and extending through the entire winter period has revealed several physiologic failures which are responsible for winter mortality on an annual basis.3.6.1 Total Lipids.Gizzard shad store lipids, primarily during Septembr -andmost individuals enter the'early winter period with a lipid content of 23-41% of dry weight which should be sufficient to survive the winter..Late hatch cohorts convert food into growth 'rather than lipids during September and are not prepared to survive the winter.Shad stop feeding when water temperatures decline below 11 0 C but they remain active and use lipids for energy until water temperatures reach 8 0 C.* Late hatch cohorts exhaust limited lipid resources before water temperatures reach 8 0 C and can die as early as late October.* Conversion of lipids to energy -ceases when water temperatures drop below 8

• C and other energy sources are used resulting in starvation while lipids are still present.* Liver and muscle glycogens are exhausted quickly and tissue catalysis follows.* Liver tissue is catabolized initially and continually during the winter season as a source of energy. This is tracked by increases in bilirubin, ammonia, and red blood cell lysis -all indicative of loss of liver function.

By late winter (January/February), livers are degenerated beyond recognition and irreversibly lost in YOY shad. This loss of liver and its functions is one of several causes of winter mortality in gizzard shad.3.6.2 Cystolic Lactate Dehydrogenase" Lactate dehydrogenase (LDH) is an important enzyme that is an integral part of temperature adaptation in cold-blooded organisms.

This enzyme is associated with energy activation in tissues and is used to evaluate thermal adaptation." Timely elevated concentrations of LDH indicate adaptive response that facilitates energy use." LDH is essential for early winter survival.7 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)" Maximum concentrations in muscles of YOY shad were measured in January which is too late in the winter to promote survival.

This indicates a delayed acclimation typically associated with a species living at or near the northerly edge of its range." Maximum LDH activity in the brain occurred in March which is much too late for survival.3.6.3 Serum and Brain Glucose* Assays showed that serum glucose levels increased by ten fold during the winter over those measured during the active feeding season.* This increase of serum glucose is a response to an inadequate supply of glucose in the brain cells.* Hypoglycemic and hyperglycemic conditions in the brain cause similar swimming behavior that includes erratic swimming, apparent loss of equilibrium, and a comatose state.* Both hypoglycemic and hyperglycemic conditions were observed in the brain tissue indicating that cell membrane failure was the probable cause and that differences in concentrations across the membrane were the cause of the observed behavior.3.6.4 Cholesterol a Functionality of cell membranes is maintained by their fluidity.* Serum and cell membrane cholesterol concentrations are elevated and remain reasonably constant during the winter in cold adapted fish such as yellow perch. This maintains fluidity of the cell membranes." Assays of gizzard -shad indicated that serum cholesterol concentrations were lower in those individuals that died and the cell membrane cholesterol concentrations did not increase which indicates a loss of cell membrane fluidity and, thus, function." Loss of cell membrane fluidity prevents glucose from entering the brain cells which leads to erratic swimming, a comatose state, and then death.Combining all the observations leads to the conclusion that gizzard shad do not use lipids for energy when water temperatures drop below 8

• C; utilize liver tissue as a compensatory energy source with livers becoming almost unrecognizable and irreversibly degraded by late winter, the temperature acclimation to produce LDH occurs too late in the winter to benefit YOY gizzard shad; and cell membranes lose fluidity and the ability to diffuse glucose into brain cells. This combination of dysfunctional biochemical pathways causes death, particularly in YOY gizzard shad.These phenomena have been documented in water bodies that do not have thermal discharges and operate independent of electric generating stations.4 Quad Cities Nuclear Generating Station Intake Studies During the period in which Quad Cities Nuclear Generating Station(Navigation Pool 14)transitioned from closed cycle cooling to open cycle cooling (1979-1984), concern was expressed 8 HDRALMS August 2006 Analysis of Gizzard'Shad Winter Die-Off and Its Relevance to 316(b)about the numbers of gizzard shad that would be impinged during the winter period after open cycle 'cooling was implemented.

One of the questions asked was: what percentage of gizzard shad that are impinged during the winter are dead before reaching the water traveling screens?Several pilot studies were conducted during the period of partial open -cycle cooling. These determined mesh size and placement of barrier nets as well as determined difficulty of raising these nets during the winter months. Results of these pilot studies were used to design a study that was conducted when open cycle cooling was implemented in 1984.Samples were scheduled to be collected weekly January through March and November through December 1984 using 0.75 in. bar mesh barrier nets that were placed upstream of the trash racks on a boom equipped with winches that lowered and raised the barrier net (Lawler, Matusky &Skelly Engineers, 1985).Nets were raised and cleaned prior to sampling and two 2-hr sets were made each week. A 24-hr set was also made each week. Gizzard shad were removed and categorized as alive-healthy; alive-moribund; dead; decayed; and gilled. Gilled fish were small specimens that were gilled in the 0.75 in. mesh net and could not be counted as dead or alive when free swimming.

Decayed fish were those that were partially decomposed.

Dead fish exhibited no movement during the observation period. Moribund fish exhibited erratic swimming behavior, seeming loss of equilibrium, or only gill movement.

Healthy fish exhibited no~ne of the characteristics of moribund fish during the observationperod. " .i Results of the 2-hr samples are presenied in Table 4-1. No samples were collected during January due to heavy ice conditions (Lawler, Matusky & Skelly Engineers, 1985). Data from the 2-hr sets were deemed to be more appropriate for this discussion because they best describe the c6idition of fish as they approach the intake and minimize the interaction of gear, time, and fish condition.

A total of 12 samples were taken during the February -March period and five samples were collected during the November-December period. Number of fish caught per hour is presented by month to offset the disparity in sampling effort and these results are as expected, i.e. few gizzard shad were collected in November and the numbers increased through February.

No gizzard shad were collected on the nets during the month of March.While it may seem to the casual observer that all gizzard shad are dying during the winter, the percentage of healthy fish reported in this study ranges between 3.5 and 3.6% in the coldest months and was reported at 33.3% for November when the number of shad collected was low.Although no data are reported for January, it can reasonably be assumed that the percentage of healthy shad was similar to those of December and February.The percentage of dead shad in November (20.8%) was substantially higher than December (1.1%) even though the total catch in December was approximately 15 times greater than the November catch. In February, dead shad accounted for 30.6% of the catch, which is not unexpected.

Moribund shad comprised the highest percentage of the total shad collected in each month and were inversely proportional to the percentage of dead shad but showed no consistent relationship to healthy shad in the collections, suggesting that there is a relationship between moribund and dead gizzard shad rather than between healthy and moribund shad as the winter season 9 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)progresses.

The biochemical information discussed in the previous chapter supports this observation.

Viewing the totals for the entire study period, 4.1% were deemed healthy while 71.1% were moribund and 22.3% were classified as dead. The remaining small percentage was either decayed or gilled.In summary, this study documents the percentages of healthy, moribund, and dead gizzard shad that were intercepted before reaching the traveling water screens during most of the cold weather period (with the exception of January).

It is reasonable to assume that the percentage of healthy shad in January was very similar to December (3.6%) and February (3.5%) and that the sum of moribund and dead shad in January was also similar to those of December (94.7%) and February (95.0%).5. Impingement Data Collected During Winter 2005/2006 As stipulated in the Muscatine Plant's(Navigation Pool 17) PIC, impingement collections were made weekly between June 2005 and May 2006 at all three units. When more than 30 specimens of a species were collected in a sample, a subsampling routine which selected the first 30 specimens was used to satisfy the length and weight requirements of the program. When less"'than 30 individuals of a species were collected, all were measured and weighed.Impingement species composition and abundance data is presented by month for actual numbers counted at each intake (Tables 5-1 through 5-3) and extrapolated to estimated total numbers and Table 4-1 Condition of Gizzard Shad Entrapped on the Barrier 'Net During 2-hr Sets.Quad Cities Nuclear Station -1984 Healthy No. %Moribund Dead Decayed No. % No. % No. %Gilled No. %Total No. Effort Date Feb Fish/hr.2-hr 34 3.5 March 2-hr 0 0.0 November 2-hr December 2-hr 8 33.3 13 3.6 619 64.4 0 0.0 11 45.8 334 93.6 964 71.1 294 30.6 0 0.0 5 20.8 4 1.1 303 22.3 14 1.5 0 0.0 0 0.0 0 0.0 14 1.0 0 0.0 0 0.0 0 0.0 6 1.7 6 0.4 0 12.0 24 4.0 961 12.0 80.1 0.0 6.0 357 6.0 59.5 Totals 2-hr 55 4.1 1356 34.0 39.9 10 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-1. SPECIES COMPOSITION AND ABUNDANCE OF IMPINGED FISH SAMPLED FROM THE TRASH BASKET AT MPW UNIT 7 INTAKE, JUNE 2005 -MAY 2006.TAXA JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY TOTAL Gizzard shad Mooneye Cyprind spp.Silvery minnow Silver chub Emerald shiner Sniped shiner River shiner Spotfin shiner Sand shiner Fadhead minnow Bullhead minnow River carpsucker Channel catfish Stonecat Flaithad catfish White bass Yellow, bass Pumpkinseed Orangespotted sunfish Bluegill Freshwater drum No. of fish No. of taxa Sample volume (MGF)3 4 1 5 368 9104 10,412 8063 7999 1 233 I I I 3 1 4 7 36198 1 5 4 8 0 2 2 1 4 1 5 1 I I t 4 2 2 1 2 1 16 14 4 1 1 1 I 2 1 4 2 .3 1 1 4I 3 .4 13 4 3 9 20 4 6 13 1 4 8 11 65! 2 6 3 S 25 1 .5 I 13 5 1 1.1 3 7 1 2 4 1 I5 24 15 45 69 T5 '27 23 '1l 10 6 198.6 206.1 271 .37 4 5 272.8 167.8 16 385 ` 9128 40441 5 8 *68 8 ,109.3 -136.8 i206.1 *109.9 8S082 4 108.8 8071 12 145.8 322 34 36583 9 4 .21 109.2 1 4.4 i885.6 11 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-2. SPECIES COMPOSITION AND ABUNDANCE OF IMPINGED FISH SAMPLED FROM THE TRASH BASKET AT MPW UNIT 8 INTAKE, JUNE 2005 -MAY 2006.TAXA JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY TOTAL Gizzard shad Silvery minnow Silver chub Emerald shiner Striped shiner Bullhead mamow Channel catfish Flathead catfish White bass Bluegill Largemouth bass Freshwater drum 2 6 2519 9,852 1252 686 1 11 14328 1 1 2 I I 3 6 3 1 1 I I I 4 0 I 1 7 2 1 7 1 1 94 1 2 1 1 2 1 56 2 10 18 I 3 I No. of fish No. of taxa Sample voulune (MGW)4 1 8 9 6 9 2523 9911 1254 697 33 2 14457 3 1 4 3 3 4 5 4 2 3 5 2 II 369.8 360.3 518.3 418.5 288.4 288.0 48.0 170.7 219.2 223.8 215.3 174.5 .3294.7 12 HDR/ILMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-3. SPECIES COMPOSITION AND ABUNDANCE OF IMPINGED FISH SAMPLED FROM THE TRASH BASKET AT MPW UNIT 9 INTAKE, JUNE 2005 -MAY 2006.TAXA JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY TOTAL Gizzard shad Common carp Silvery minnow Silver chub Emerald shiner Striped shiner River shiner Bullhead minnow River carpsucker Channel catfish Sfnecat Tadpole madtom FRahead catfish White bass Yellow bass Green sunfish Orangespotted sunfish Bluegill Logperch Freshwater drum No. of fish No. of tan Sample voulume (MGW)I 10 33 9573 6,757 2690 181 12 1 2 1 1 3 1 i I 1 I 2 1!1 2 I t92-59 I 2 1 9 5 1 S 0 t 1 1 1 14 107 2 7 2 4 66 5 3 1 2 1 9 15 11 2 2 1 2 7 5 17 3 13 6 7 9 18 4 4 9 6 2 1 4 2 6 1 i*I 2 2 1 3 2 1 3 "23 18 4 1 2 12 11: 12 9 15 15 4 .26 83 71 73 104 7 11 88 411 4 12 7 31 39 83 68 9629' 6855 2777 282 156 ,47 19986 8 5 8 5 It 9 8 7 7 7 9 12 19 685.3 55ý6.7 696.06 5`57.5 554.6 550.6 2i0;6: 279.4 359.7 207.1 556.9 556.8 5771.2 Four sampling events at Unit 9 were missed between 28 February and 19 March due to a scheduled maintenance outage.13 IHDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)weights for the year based on intake flow (Tables 5-4 through 5-6). Lengths are presented as a length frequency table (5-7) that begins with June 2005 and extends through May 2006 and combines all the fish measured at the three units. This is intended to aid the reader in following the 2005 year class through the winter season.Inspection of Tables 5-1 through 5-3 shows the expected pattern of low gizzard shad impingement from June through the October/November period followed by dramatic increases of shad impingement during the December through March period. Based on information gathered from the literature, discussion of the breakdown of biochemical pathways and enzymes, and results of the winter study at the Quad Cities Nuclear Station on Pool 14 of the Mississippi River, it is reasonable to conclude that the preponderance of these shad were either dead or moribund at the time they were impinged during these winter months. Tables 5-4 through 5-6 show that shad impinged during the cold weather months comprised in excess of 95% of the total annual impingement collection of all species by both numbers and weight at each intake.Investigators have determined that most of the winter mortality occurs in YOY gizzard shad.White et al. (1986) defined YOY shad is those between 40 and 160 mm SL which converts to about 52 to 210 mm TL. Table 5-7 presents length frequency data (TL) by size category.

The majority of the fish that were measured were within this YOY range and as the season progressed the mean size of the fish increased.

This is consistent with the observation that smaller individuals have smaller livers and die earlier in the winter as a result of liver failure..Conversely, larger individuals die later in the winter because they have larger livers to provide energy for a longer period of time.This information supports the observation that gizzard shad in Iowa are living in the northerly portion of their geographical range and die off in great numbers when water temperatures decline first below '8 C.White et al. (1986) concluded that winter mortality is high, natural (particularly YOY), and is caused by the failure of the species to adapt to long-term cold stress in the northerly portions of its geographical range. Impingement during this winter period is composed largely (>95%) of shad that have died from long-term cold stress and other natural causes prior to being impinged.14 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-4. TOTAL ESTIMATED IMPINGEMENT (BASED ON FLOW) OF FISH COLLECTED AT MPW UNIT 7, JUNE 2005 THROUGH MAY 2006 NUMBER WEIGHT TAXA TOTAL PERCENT TOTAL (kg) PERCENT AVERAGE(g)

Gizzard shad Freshwater drum White bass Bluegill Cyprinid spp.Channel catfish Emerald shiner Silvery minnow Mooneye Yellow bass Orangespotted sunfish Pumpkinseed Silver chub Flathead catfish River carpsucker Stonecat Sand shiner River shiner Fathead minnow Spotfin shiner Bullhead minnow 373,248 1,854 105 122 4 428 45 35 6 8 56 8 ,"27 .....222 4 12 17 4 6 8 18 99.2%0.5%<0.1%<0.1%<0.1%0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%-22,743.8 48.0 5.2 0.5 0.0 12.0 0.1 0.2 1.1 0.1 0.3 0.0 0.3-'1.5" 0.0 0.1 0.1 0.0 0.0'0.0 0.0 99.7%0.2%<0.1%<0.1%<0.1%0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%60.9 25.9 49.7 4.0 4.3 27.9 2.1 4.4 197.1 15.3 4.5 2.6 A11.0 6.7 4.3 11.3 3.3 2.9 2.1 2.9 1.3 Total Total taxa 376,237 21 22,813.4 15 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-5. TOTAL ESTIMATED IMPINGEMENT (BASED ON FLOW) OF FISH COLLECTED AT MPW UNIT 8, JUNE 2005 THROUGH MAY 2006 NUMBER WEIGHT TAXA TOTAL PERCENT TOTAL (kg) PERCENT AVERAGE(g)

Gizzard shad Freshwater drum White bass Bluegill Channel catfish Emerald shiner Largemouth bass Silvery minnow Silver chub Flathead catfish Bullhead minnow Total Total taxa 155,324 836 7 59 126 24 10 10 5 28 6 156,434 11 99.3%0.5%<0.1%<0.1%0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%9,308.7 16.5 0.0 0.4 0.6 0.0 0.1 0.0 0.0 0.2 0.0 9,326.8 99.8%0.2%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%59.9 19.8 2.0 6.7 4.9 2.0 12.0 3.0 6.0 7.5 1.0 16 HD1ILMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-6. TOTAL ESTIMATED IMPINGEMENT (BASED ON FLOW) OF FISH COLLECTED AT MPW UNIT 9, JUNE 2005 THROUGH MAY 2006 NUMBER WEIGHT TAXA TOTAL PERCENT TOTAL (kg) PERCENT AVERAGE(g)

Gizzard shad Freshwater drum White bass Bluegill Common carp Channel catfish Emerald shiner Silvery minnow Yellow bass Orangespotted sunfish Silver chub Flathead catfish Tadpole madtom Logperch River carpsucker Green sunfish Stonecat River shiner Bullhead minnow 170,370 2,900 39 598 12 774 33 58 27 71 35..497.13 8 6 14 48 7 6 175,514 19 97.1%1.7%<0.1%0.3%<0.1%0.4%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%9,432.6 62.7 3.9 4.0 0.1 5.2 0.1 0.3 0.5 0.3 0.2 8.1 0.1 0.1 2.5 0.1 0.3 0.0 0.0 9,521.1 99.1%0.7%<0.1%<0.1%<0.1%0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%.<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%<0.1%55.4 21.6 101.9 6.7 5.3 6.7 2.6 4.6 19.0 4.0 5.1.. .16.3 7.6 7.0 418.0 7.3 6.2 5.0 5.0 Total Total taxa 17 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)TABLE 5-7. LENGTH FREQUENCY OF GIZZARD SHAD SUBSAMPLED FROM MPW IMPINGEMENT COLLECTIONS, JUNE 2005 THROUGH MAY 2006 TOTAL MONTH LENGTH (mm) JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY<60 60-69 70-79 80-89 90-99 100-109 110-119 120-129 130-139 140-149 150-159 160-169 170-179 180-189 190-199 2oD-209 210-219 220-229 230-239 240-249 250-259 260-269 270-279 280-289 290-299 300-309 310-319 320-329 330-339 340-349> 350 TOTAL 3 1 3 7 1 1 4 11 6 5 5 1 l 2 2 4 7 10*I I 2 5 2 4 1 15 2 22 39 1 22 30 1 10 8 2 2 2 1 8 7 3 1 3 5 3 2 8 11 2 5 9 6 10 13 12 37 24 15 44 48 50 56 47 56 45 67 52 53 37 40 24 36 29 5 22 8 4 6 8 1 5 I 1 1 2 1 5 2 7 5 3 5 3 6 2 5 2 3 3 1 3 2 1 3 1 1 1 1 2 3 5 2 1 4 1 1 7 6 3 12 11, .1 29 17 38 28 70 23 66 15 1 23 12 1 14 2 1 1 4 1 I 1 I 1 2 1 3 6 4 5 2 2 I 1 4 4 31 0 17 196 336 359 314 2 294 126 8 88 121 123 409 322 201 194 183 154 MINIMUM 129 62 143 -64 61 75 109 104 MAXIMUM 204 78 295 -203 297 406 397 427 MEAN 167 68 194 -104 166 179 190 191 18 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevanoe to 316(b)6. Relevance to 316b Phase II The impingement performance standard set forth in the Phase II Rule states that impingement mortality must be reduced or offset by a minimum of 80% of the calculation baseline.

A number of operational and technological measures are available to accomplish this reduction, along with possible restoration measures should they survive the court challenge.

One technological measure is a class of technologies that return fish alive to the source water body. Returning fish that were dead or moribund before being impinged returns energy to the waterway system but has no bearing on reducing impingement mortality as stipulated in the Rule, i.e. the intended benefit is not available at the beginning of the process; and, therefore, can not be accomplished.

Similarly, implementing operational measures to reduce impingement based on these numbers of dead/dying fish also will not accomplish the intended goal of the Rule to reduce impingement mortality.

Designing restoration programs to offset losses of fish that are dead or moribund would place an undue financial burden on the applicant by necessarily over-designing the restoration program to account for dead and dying fish that were merely removed from the waterway much the same as a vacuum cleaner does its job. Besides, .restoration should offset mortality losses that result from impingement.

The question then becomes. how to best approach integrating this information into either determining the .calculation baseline or satisfying the performance.

standard, the objective of which is to reduce impingement mortality.

7. Recommendations There may be different approaches to answering the question; but the most-direct and simplest is to eliminate dead and moribund gizzard shad collected during the winter months from the calculation baseline.

Recognizing that not all gizzard shad die during the winter, it is recommended that 4% of the numbers impinged during the November through March period be considered alive and healthy (the average for this period in the Quad Cities Station study); and therefore, included in the calculation baseline for a.generating facility.Although a late season hatch may die off during late October, it is recommended that all shad impinged from April through October be included in the calculation baseline.This approach includes those portions of the gizzard shad population which are truly at risk to impingement mortality without inflating the calculation baseline with irrelevant dead or moribund shad whose mortality is attributed to natural causes induced by long-term cold stress.The State of Illinois which shares a common border with Iowa along the Mississippi River is taking this approach.19 HDR/LMS*Augtust 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)8. References Cited Assel, Raymond A. 1980. Maximum freezing degree-days as a winter severity index for the Great Lakes, 1897-1977.

Monthly Weather Review, 108:1440.Becker, G.C. 1983. Fishes of Wisconsin.

Univ. of Wisc. Press. Madison, Wisc. Pp. 273-277.Bodola, A. 1955. Life history of the gizzard shad, Dorosoma cepedianum (LaSeuer) in Western Lake Erie. PhD Dissertation, Ohio State University.

Columbus, Ohio.Bodola, A. 1966. Life history of the gizzard shad, Dorosoma cepedianum (LaSeter) in Western Lake Erie. US Fish Wildl. Sere. Bull. 65(2):391.

Carlander, K.D. 1969. Handbook of freshwater fishery biology. Vol. 1. The Iowa State University Press. Ames, Iowa. pp. 82-89.Caroots, M.S. 1976. A study of the Eastern Gizzard Shad, Dorosoma cepedianum, from Lake Erie. MS Thesis, John Carroll University.

University Heights, Ohio.Eddy, S. and J. Underhill.

1974. Northern Fishes. University of Minnesota Press. Minneapolis, MN. P. 147.Heidinger, Roy C. 1983. Life history of the gizzard shad and threadfin shad as it relates to the ecology of small lakes fisheries.

Proc. Of Small Lakes Management Workshop -Pros and Cons of Shad. Iowa Conservation Commission and Sport Fishery Institue, Des Moines, Iowa.198 pp.Kirtland, J.P. 1844. Descriptions of fishes of Lake Erie, the Ohio River and its tributaries.

Article 7. Boston Journal of Natural History, No. 4. p. 231.Lawler, Matusky & Skelly Engineers.

1985. Quad Cities Aquatic Program, 1984 Annual Report.Submitted to Commonwealth Edison Company, Chicago, IL.Mayhew, J. 1983. Proc. Of Small Lakes Management Workshop -Pros and Cons of Shad. Iowa Conservation Commission and Sport Fishery Institue, Des Moines, Iowa. 198 pp.Miller, R.R. 1960. Systematics and biology of the gizzard shad, (Dorosoma cepedianum), and related fishes. Fishery Bull., US Fish Wild] Serm. 60:371.Neumann, David A., W.J. Wachter, E.L. Melisky and D.G. Bardarik.

1977. Filed and laboratory assessment of factors affecting the occurrence and distribution of gizzard shad (Dorosoma cepedianum) at Front Street Steam Electric Generating Station, Erie, Pennsylvania.

Pennsylvania Electric Company.Scott, W.B. and E.J. Crossman.

1973. Freshwater Fishes of Canada. Fish Res. Bd. Canada, Ottawa. BulletinNo.

184. pp. 133-137..20 HDR/LMS August 2006 Analysis of Gizzard Shad Winter Die-Off and Its Relevance to 316(b)Trautman, M.B. 1956. The Fishes of Ohio. Ohio State University Press. Columbus, Ohio.p. 182.1981. TheFishes of Ohio. Ohio'State University Press. Columbus, Ohio. p.201-204.

Walburg, C. 1964. Fish population studies,Lewis and Clark Lake, Missouri kiver, 1956-1962.

Spec. Sci. Rpt., US Fish Wild]. Serv. No. 482: 1-27.Wehr, Larry W. 1976. Osmotic variation of serum of gizzard shad, Dorosoma cepediamim, in relation to seasonal temperature changes. PhD Dissertation, Southern Illinois University.

Carbondale, IL.White, A.M., M.B. Trautman, EJ. Foell, M.P. Kelty and R. Gaby. 1975. Water Quality Baseline Assessment for the Cleveland Area -Lake Erie. Vol. 11. The fishes of the-Cleveland metropolitan area including the Lake Erie shoreline.

USEPA Report: EPA-905/75-001.

White, A.M., F.D. Moore, N.A. Alldridge and D.M. Loucks. 1986. The Effects of Natural Winter Stresses on the Mortality of the Eastern Gizzard Shad, Dorosoma cepedianum, in Lake Erie. Submitted to The Cleveland Electric Illuminating Company, Cleveland, Ohio and The Ohio Edison Company, Akron, Ohio. 209 pp.21 HDR/LMS August 2006 APPENDIX C CORRESPONDENCE AND TELEPHONE CALL RECORDS CONCERNING COFFEY COUNTY LAKE AND FISHERIES Letter dated December 13, 1974, from M. Gray (KDHE) to G. Koester (KG&E), "Exemption from 316(a) Requirements" Letter dated February 21, 1975, form M. Gray (KDHE) to M. Miller (KG&E),"KDHE Opinion on Recreational Uses of the Wolf Creek Facility" Letter dated April 4, 1975, from G. Koester.(KG&E) to M. Gray (KDHE),"KG&E Reply to December 13, 1974 letter".Letter dated April 10, 1975, from D. Carlson (KDHE) to G. Koester (KG&E),"No Limitation on the Discharge of Heat" Letter dated February 3, 1976, from D. Carlson (KDHE) to M. Miller (KG&E),"Water Quality Criteria" Letter dated May 24, 1983, from B. Taggart, Kansas Fish and Game, to G.Wedd (KG&E), "Initiate an Cooperative Agreement between KG&E and Kansas Fish and Game Commission to Allow Access to Cooling Reservoir' Letter dated September 10, 1984, from L. Jirak, Kansas Fish and Game, to G. Webb, KG&E), "Request to Collect Largemouth and Smallmouth Bass from Cooling Reservoir" Letter dated October 15, 1984, from B. Taggart, Kansas Fish and Game, to G. Webb (KG&E), "Letter of Appreciation for Obtaining Bass" Letter dated April 29, 1985, from B. Taggart, Kansas Fish and Game, to G.Webb (KG&E), "Letter of Appreciation for Obtaining Black Crappie" Letter dated June 13, 1985, form L. Jirak, Kansas Fish and Game, to G.Webb (KG&E), "KG&E Commended for Fishery in the Cooling Reservoir' Letter dated September 11, 1985, from B. Taggart, Kansas Fish and Game, to G. Webb (KG&E), "Request to Collect Several Species of Fish from Cooling Reservoir" Letter dated February 17, 1986, from B. Taggart, Kansas Fish and Game, to G. Webb (KG&E), "Request to Collect Striped Bass from Cooling Reservoir" 55 Letter dated March 27, 1986, from B. Taggart, Kansas Fish and Game, to G.Webb (KG&E), "Letter of Appreciation for Obtaining Fish from Wolf Creek" Letter dated March 273 1987, from B. Taggart, Kansas Fish and Game, to G.Webb (WCNOC), "Letter of Appreciation for Obtaining Fish from Wolf Creek" Letter dated June 24, 1987, from L. Jirak, Kansas Fish and Game, to G.Webb (WCNOC), "Letter of Appreciation for Providing Fish for the John Redmond Kid's Fishing Derby" Letter dated February 23, 1988, from L. Jirak, Kansas Fish and Game, to G.Webb (WCNOC), "Request to Collect a Several Species of Fish from Wolf Creek to Stock Four Kansas Lakes" Letter dated January 22, 1991, from R. Sanders (KDWP) to B. Loveless (WCNOC). "Letter of Appreciation for Supplying Several Species of Fish for the Topeka Boat Show Letter dated February 26, 1993, from R. Sanders (KDWP) to B. Loveless (WCNOC). "Letter of Appreciation for Supplying Several Species of Fish for the Topeka Boat and Outdoor Show Letter dated August 31, 1993, from D. Nygren (KDWP) to B. Loveless (WCNOC), 'Request to Collect Walleye Eggs fro Wolf Creek Letter dated August 10, 1995, from W. Wood (WCNOC) to D. Nygren (KDWP), "Proposed Wolf Creek Lake Angling Regulations Letter dated April 1, 1997, from R. Frigger (KDWP), to B. Loveless (WCNOC), "Letter of Appreciation for Obtaining Smallmouth Bass to Stock Bone Creek Lake" Letter dated May 8, 1997, from D. George (KDWP) to B. Loveless (WCNOC),'Request to Collect Smallmouth Bass to Stock LaCygne Reservoir" Letter dated April 15, 1998, from D. George (KDWP) to D. Williamson (WCNOC), "Request to Collect Smallmouth Bass to Stock LaCygne Reservoir" Letter dated July 25, 2005, from N. Clough, BASS/ESPN Outdoors, to M.Smith, USEPA, "Support for 316(b) Restoration Option in Final Rule" Telephone Call Record dated August 4, 2005, from D. Haines (WCNOC) to S. Adams (KDWP), "Fish Kills Reporting Expectations" 56 Telephone Call Record dated August 4, 2005, from D. Haines (WCNOC) to S. Haslouer (KDHE), "Fish Kills ReportingExpectations" Letter RA 07-0010 dated January 24, 2007, from K. J. Moles (WCNOC) to E.Staab (KDHE-BOW), "CWIS Entrainment Study Exemption Request" Letter dated March 8, 2007, form E. Staab (KDHE-BOW) to K. Moles (WCNOC), "CWIS Entrainment Study Exemption Request Response" 57 V/; " , State of Kansas S' DEPARTMENTOF HEALTH & ENIONMENT , .* I Thoo.Ic Kansas S *" r .. .* ....* ;. ,4 .* (l'..7 1.',', fL .x.(7-h- ". v ,:, 13 December 1974 M~lr. Glenn Koester 'Kansas Gas & Electric Co."P.O. Box 208 Wichita, Kansas 67201 Re: Wolf Creek Generating Station IV E-~ I WGS K1~ IM!.1:.j4:::~

r -J.UM

Dear Mlr. Koester:

Wie e * .-.dur rb tatu s inf ri a io e o t a u I o bi .

ation., Supplemental to the information provided, copies of the actual contractual agreements are desirable for documentation purposes.

This request of course excludes any confidential informa-tion.* or~ eef-that o reek generatng staion has i -e&n stiu t as-.defikned-in,.

Set 3 raX2Oad~~~~n , The federal standards of performance for"new sources" of the Electric Power Plant Generating Guidelines pub-lished in the Federal Register in October 1974, Volue 39,,,'No.Section 423. 13(1) states that 5XfuiuQUO S of.,.e V e ': !: vve -: .": e r~ ce .r g ation= -zhal -.be vjf6em-pt~~&1~~di ~ -be-riferenced regulabnhUb Xrp f i h.e 1 ph ovis0ns " ctidn' 6(')' P92?-5O, as cintrdction

.,begun jrioi to.-the. effective'..

dte. ae.are. there"fQ't you We appreciate very much your cooperation in this matter.Very truly yours, Melville W. Gray, P. E.Director Division of Environment AIWG:ht cc: Ralph Langemeier South Central District Office.1 State

'0-,ý Stal of ansa ... ROIRERT F. SENNETT, Go erneir DEPATM, ENT OF HEALTH IAND ENVIIOrIMEIlT DWIGHT F. METZLER. Secretary Topeka. Kansas 66620 " February 21, 1975.Hr. Mike Miller Environmental Coordinator

'Kansas Gas & Electric Company Post Office Box 208 Wichita, Kansas 67201 Re: Wolf Creek Generating Station

Dear Mr. Miller:

.In response.

to your request for a formal statement by the Kansas Department of Health and Environment on the possible recreational uses of the Wolf Creek facility, the following is offered.It is the Department's hope that the impounded water and the adjacent land to the lake will be utilized to its fullest extent from the standpoint of providing a public recreational area and/or a fish rearing facility for the Kansas Fish and Game Commission.

As stated in the previous meetingsconcerning the Wolf Creek Generating Station, we are of the opinion that the Kansas Gas and Electric Company controls the impounded water and thus will not be held responsible If its degradation is such that the water becomes unsuitable, as outlined by Regulation 28-16-28 of the Kansas Department of Health and Environ-ment, for body contact sports or fishing. As I have expressed in previous meetings, the water quality of the cooling lake shall be maintained so as to not adversely affect, in the judgement of ,the Kansas Department of Health and Environment, the ground water. It is also our opinion that the Kansas Gas and Electric Company shall not be held responsible for the loss of fish in the lake due to cold shock kill, impingement, or entrainment.

4 Sincerely your Melville W. Gray, P. ' " Director Division of Environment A.." .'\' '.l I'G : jac '*. " .S.' 'o'..

VW. low.*6bc:'Gerald Charnoff KANI GAS ANO ELECTRIC COMPANY RFos-ter P.DP. 0ox 208 ,Wicha. Kansas 67201 RVoh s r-c rfLCT.,c com--Y M"1Iarr is.Ellall .JOArterburn RHagan CBoyer -;: ý ,/ i44 M4r.,i 1ier r".April- 4, 1975 Mr. Melville W. Gray, P.E.-Director Division of: Environment State Department of Health and Environmenc Forbes Air Force Base, Building 740 Topeka-"Kansas 66620 Re: Wolf Cre'ek Generating Station ,

Dear Mr. Gray:

We have r.eceived your letter of Dec ,'mber 13, 1974, and note your:finding that the Wolf Creek Generatinrg Station began construction, as defined in Section 306(a) of PL.92-500 (the Federal Water Pol-lution Contro~l Act, as amended),-'of it's -cooling impoundment. .system prior t.o the effective date of 40 CFR §423. We further note your concurrence with our conclusions set forth in my letter to you of November 14, 1974.Therefore, we are relying on your letter of December 13, 1974, as indicating that, pursuant to Effluent Cuidel.ines and Standards for the Steam Electric Generating Point Source Category promulgated by the United States Environmental Protection Agency on October 8, 1974.(39 F.R. 36186), as corrected (40 P.R. 7095),..the Wolf Creek Generating Station is exempt from any limitation on the discharge of heac.Sec tion 316(s) of the FWPCA contains no effluent limitations.

Section 316(a) provides procedures pursuant to which a permittee may obtain the relaxation of a propoeed thermal effluent limitation which is --,or- stringent than necessary to insure the protection and propagation of a ba.snced, indigenous popuilation of shellfish, fish, and wildlife in aad on the body of water into which the discharge is to be akqde. Because the Wolf Creek Generating Station is exempt from acy limitation on thermal discharge, Kansas Gas and Elcctric Company is not planning to develop the type of demonstration required by Section 316(a).Sincerely yours, GL.K:bb Stlte of Aatisas ..*ROBERT f. BET.NETT.

'Governor DEPAflTN1,HIT OF HEALTH ANB ENVIHONIENIT DWIGHT F. -L!ETZLER, Secretary Topeka. Kansas .66620 H :. 7 I *", =April 10, 1975 cc: Gerald Charnoff RFoster Mr. Glenn L. Koester RVohs Kansas Gas & Electric Company ,I11arris.

Post Office Box 208 .ES1aIll Wichita, Yansas 67201 JOArterburn

.'" -----1 Rilagan j .*Re: Wolf Creek Generating Station CBoyer ..... i" I e r -:. ...-

Dear Mr. Koester:

.....e /75.bb We are in receipt of your letter addressed to Mr. Melville N. ray, dated '"..April 4, 1975. In your letter the following statement appears."Therefore, we are relying on your letteir of December 13, 1974, --- -----;as indicating that, pursuant to Effluent Guidelines Point Source _._. .Category promnulgated by the United States Environmental Protectio

.-Agency on October 8, 1974, (39 F.R. 36186) as corrected (40 F.R.7095), the Wolf Creek Generating Station is exempt from any limitation on the discharge of heat." This statement is essentially correct in that Mr. Gray's'letter, to you da-ted December 13, 1974, is intended to exempt. the Wolf Creek Generating Station from only the Federal limitations dealing with the discharge of heat from Steam Electric Generating Point Sources. As we have pointed out in previous meetings, between the Kansas Gas and Electric Company and the Kansas Depart-ment of Health and Environment, the exemptionfrom any'Federal limitation on the discharge of heat does not in any way exempt or imply that the Wolf Creek Generating Station is exempted from the Water Quality Criteria for Interstate and Intrastate Waters of Kansas as outlined in Regulation 28-16-28.

A copy of this regulation is enclosed.If you have any questions, please contact our office. Telephone number (913)296-3825.Sincerely yours, Division of Environment , ,& 4 /"I /. ....Donald R. Carlson Sn iitary "FngineLr 1.a t%:r Polluuion nControl DRC:.jac-i" , * .'Li.- ": ",

S" Sl ahi- K nODERT F. SENNETT. Govarnor ..'_ DWIGHT F. METZLER. Secretary Topeka. Kansas 66620 3 Cc -C L Koester J 0 Arterburn February 3, 1976 G D Boycr R Hagan/A Snyde: R Foster R Vohs r. Micael Hiler ,. D T 14cPhee (4)Hr.Micael!filer" ./" "'-= "" ': Charn~off.

Enviror-mental Coordinator I l .h o , *,' °. --m Impor~tant Kansas Gas and Electric Company L" : '"u -Fl".:! Documen~t File-Post Office Box 208 'r. Suman i.ehta Wichita, Kansas 67201

Dear Mr. Miller:

In response to your inquiry concerning the clarification of the locations at which the Kansas !.Water Quality Criteria and the proposed 'National Pol-lutant Discharge Elimination System (NPDES) permit will be enforced, the following is offered: The Water Quality Criteria of the State of Kansas will be enforced in the Neosho River, below the confluence of the W.olf Creek, except for an appropriate mixing-zone.

The State Water Qualiy. -Criteria will not apply to the Wolf Creek, which is unclassified under the State Water Quality Criteria.In general, the effluent limitations to be stipdlated in the National Pollutant Discharge Elimination System .(NPDES) permit will apply at the point the cooling lake discharges into Wolf Creek.If you have any questions, please contact our office. (913) 296-3325.Sincerely yours,-.Division of Environment DonaLd R. Carlson Snaitary Engincr Water Pollution Control DRC:nb REGIONAL OFFICES: Northwest Regional Southwest Regional Office 5R. 2. 183 Bypass 808 Highway 86 yGase K.ans 67601 Dodge City. Kansas,,,o, Northcentrl Regional Office Southcentral Regional Office Box 489, 511 Cedar Box 764. 204 West Sixth BOX 54A. RURAL ROUTE 2. PRATT. KANSAS 67124 Concorda Kan 8890! Newton, Kansas 67114 Nor6heast Regionl Of1e Southeat Regional Office (316) 672-5911 3300 S W. 29th Street 222 West Slain Building Topeka. Kansas 66614 Suite C & D Chanute. Kansas 66720 May 24, 1983 Mr. Greg Wedd K G & E Education Center P.O. Box 309 Burlington, KS 66839

Dear Greg:

This letter is to initiate a cooperative agreement or understanding between your agency and the Kansas Fish and Garme Commission to allow access for Fish and Game personnel to the cooling reservoir.

This request is made based on the past demonstrated cooperation between our agencies.

It also has foundation in that the Kansas Fish and Game Commission, primarily through the efforts of Leonard Jirak, have played an integral part in the development of the reservoir fishery which in-cluded 1) direct assistance in literature review, rehabilitation, stocking and sampling, 2) technical assistance in management decisions, S 3) location of private fish stocking sources and assisting in. fish trades, 4) savings in stocking costs of several hundred thousand dollars, 5) assistance in generating a positive image through programs and news media concerning the project. 6) advice in development of a fishery designed to benefit the operation of the plant.We request agency access for and through Leonard Jirak to the reservoir for the following purposes:

1) collecting fish for brooders and other Fish and Gawe management needs such as special species stockings, 2)access for education purposes to allow demonstration of the effective-ness of the inplenented fishery management plan of the reservoir to other professionals and adninistrative personnel that would be beneficial in advancing the knowledge and effectiveness of fish management prac-tices.All visits to the reservoir would be preceded by contact with you at least one week in advance for your concurrence.

Sampling gear utilized would include standard fisheries managenent gear and would include some angling.Certain areas could be designated as off-limits if necessary.

Hopefully, some arrangement for access without going through the actual "plant site" could be considered.

I Tb: Greg Wedd From: Bruce Taggart May 24, 1983 Page 2, continued The entire management concept for the current existing fishery was based on our recamendations fran years of management experience.

We feel the request for our agency's access will enable us to build on that management experience.

We appreciate your cooperation and consideration on this request.Please advise us as soon as possible of your decision.Regional Fisheries Supervisor Southeast Region ST/kg Kansas tish& Game BOX 54A, RURAL ROUTE 2, PRATT, KANSAS 67124r572-5911 REGIONAL OFFICES:@Northwest Regional Office Rt. 2, 183 Bypass Hays, Kansas 7601 Northcen truE Re1ona! Office Box 489, 511 Cedar Concordia, Kansas 66901 Northeast Regional Office.3300 S.W. 29th Street Topeka, Kansas 66614 Southwest Regional Office 808 Highway 56 Dodge City, Kansas 67801 Southcentral Regional Office Box 764, 204 West Sixth Newton, Kansas 67114 Southeast Regional Office 222 West Main Building Suite C & D Chanute, Kansas 66720 September 10, 1984 Mr. Greg Wedd KG&E Education Center P.O. Box 309 Burlington, KS 66839

Dear Greg:

By way of this letter we -Are requesting p sion to collect 2,000 adult largemouth bass and 500 :adult, smallmouth'bass from your cooling reservoir.

In order to collect these f ish, efficiently, we would like to bring in our three electrofishing boats and:a hitche-rytruck to haul fish. We would also appreciate your partiipation and yoIurelectrofishing equipment, how-ever, this ise not a-pre-requisite for our needs.We would request to collect these fish during a two-week period fran October 1 through October12, 1984. ,Depending upon our success, we may need to return' in April of 1985:to 6coiect dd*itional fish.Please advise us as soon as possible on Yourrconsideration of this request.Thanks.Sincerely, Leonard Jirak District Fisheries Biologist...::New Strawn District Office LJ/kg cc:. Bruce Taggart Kansas fish BO .Game BOX 54A, RURAL ROUTE 2, PRATT, KANSAS 67124 (316) 672-5911 REGIONAL OFFICES:10 Northwest Regional Office Rt. 2, 183 Bypass Hays, Kansas 67601 Northcentral Regional Office Box 489, 511 Cedar Concordia, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeha, Kansas 66614'Southwest Regional Office 808 Highway 56 Dodge City, Kansas 67801 Southcentral Regional Office Box 764i 204 West Sixth Newton, Kansas 67114 Southeast Regional Office 222 West Main Building Suite C & D .Chanute, Kansas 66720 October 15, 1984 Greg Wedd Envirormrntal Biologist Wolf Creek Power Plant Box 444 Lebo, KS 66856

Dear Greg:

I want this letter to express, our appreciation for Kansas Gas and Electric Ccxpany and assistance in obtaining the 655 adult black bass- from cooling reservoir last Friday.Fish and Game staff involved were not only drpressed with the lake and its fish populatIon, ýbut-, also the very efficient and hardworking Kansas Gas and Electric Caopany staff.This type of project persgkqfies the type of cooperation that has existed between-our agencies "on fish management activities on your In my opinion, the sportfish population in the reservoirn bestn: in the state, Kansas Gas and Electric Conpany has indeed done :an extremely ccmrendable job on the fishery.Once again, thanks, Ifor the fish and:the good help.Sincerely, BkTaggart.

Regional Fisheries Supervisor Southeast Region BT/kg cc: JiM Beam Leonard Jirak Kansas Aish& Game BOX 54A, RURAL ROUTE 2, PRATT, KANSAS 67124 (31*6) 672-5911 REGIONAL OFFICES: North west Regional Office Rt. 2, 183 Bypass Hays, Kansas 17601 Northcentral Regional Office Box 489, 511 Cedar Concordia, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeka, Kansas 66614 Southwest Regional Office 808 Highway 56 Dodge City, Kansas 67801 Southcentral Regional Office Box 764, 204 West Sixth Newton, Kansas 67114 Southeast Regional Office 222 West Main Building.Suite C & D Chanute, Kansas 66720 April 29, 1985 Greg Wedd P.O. Box 444 Lebo, KS 66856

Dear Greg:

.This letter is to acknowledge and. thank you for your assistance in obtaining black crappiebroe'dfish forour hatchery needs at Farlington.

Once again assistnce" is very much appreciated.

Sincerely, S Bruce Taggart Magina Fisheries Supervisor Southeast Region BT/kg q~ib ~ REGIONAL OFFICES:-Northwest Regional Office Southwest Regional Office RKt. 2, 183 Bypass 808 Highway 56 Hayso., _ ,, Kanas...1 odeCt, Kansa 6780 Northcentral Regional Office Southcentral Regional Office Box 489, 511 Cedar Box 764, 204 West Sixth BOX 54A, RURAL ROUTE 2, PRATT, KANSAS 67124 Coneordla, Kansas 66901 Newton, Kansas 67114 Northeast Regional Office Sbutheast Regional Office (316) 672-5911 3300 S.W. 29th Street 222 West Main Building Topeka, Kansas 66614 Suite C & D_ _ _ _ _ _ _ _Chanute, Kansas 66720 June 13, 1985 Mr. Greg Wedd Section Kansas Gas & Electric Company Wolf Creek Generating Station Box 444 Lebo, KS 66856

Dear Greg:

..... ..The fishery in the Wolf-CreekI Cooling ,Reservoir, has developed as planned and even better than The Kansas Gas and Electric Caopany staff is to be camndedfor their concern and response indeveloping the reser-voir resource to its ful-lest potential.,.,

plan was to build a high density predator fish population t6,-:control rough fish and gizzard shad densities..

..This preciselywhat.

ha .taken place. The plan also called for use of the prtfishfor brod6.stocd in other state waters and this has als occurred.

-,Thelk was 'als to be used by the public for fishing if NRC .and KG&E regulations would a ilow it.The survival and the subsequentidensity of -prdacious fish has been ex-trerrely high and initial, growth was excellent., and has remained good.The fishery has now reached aouatipondensity and biomass where some type of major harvest would.be :::beneficial.,..

.:The lake has been full for four years and. the.bicmass of the sportfish population-has reached or is near its peak. At the :,same time the lake.'s :ýcarrying capacity is most likely declining-., it is my concern that these fish havexreached

'a critical biomass that the aquatic system will , now be hard pressed- to maintain.

Growth of inter-mediate size and smaller gamefish has slowed and will become severely depressed.

I expect that the body:-condition of all but the very largest predacious fish will decline noticeably by late summer. Considering the decreased body condition and high density there is a strong potential for winter stress, disease transmission, and significant fish mortality.

This is a problem that is poorly documented in any literature.

This problem is rare because very few fisheries managers have been successful in producing such a high biomass of sportfish.

Most that have, intended the fishery for public use and angler harvest has prevented the fish population from reaching the proportions of the standing crop at Wolf Creek. Those that have not allowed public utilization most likely did not expend the effort to have a quality fishery as you have.

I..To: Greg Wedd Fran: Leonard Jirak June 13, 1985 Page 2, continued The potential problem that exists needs to be anticipated in time to re-medy the situation.

Once a massive die off is observed, little can be done to change the situation.

As in most animal populations the end result is a lower population than would have occurred if moderate removal had occurred.The action necessary is much like the initiation of the pre-inpoundment management program where problems were circumnvented and management strategies were designed to take advantage of opportunities as they becamre available.

I suggest that the fish population be monitored closely over the next several months to observe if this problem continues to develop, and that remedial action be taken before a very valuable resource is lost. If the Kansas Fish and Game Conmmission can be of any assistance, please feel free to request our help.Sincerely, Leonard Jirak District Fisheries Biologist New Strawn District Office LJ/kg cc: Bruce Taggart Kansas Pish BO .Game BOX 54A. RURAL ROUTE 2, PRATT, KANSAS 67124 0316) 672-5911 REGIONAL OFFICES: Northwest Regional Office Rt. 2, 183 Bypass Hays, Kansas 67601 Northcentral Regional Office Box 489, 511 Cedar Concordia, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeka, Kansas 66614 Southwest Regional Office 808 Highway. 56 Dodge City, Kansas 67801 Southcentral Regional Office Box 764, 204 West Sixth Newton, .Kanss 67114 Southeast Regional Office 222 West Main Building Suite C & D Chanute, Kansas 66720 September 11, 1985 Greg Wedd P.O. Box 444 Lebo, KS 66856

Dear Greg:

We would like to electrofish and transport fish from your lake on the 19th and 20th of September, 1985. We have a need for 1,000 largemouth bass adults, 200: -salliwuth bass adults, 1,000 wipers, 200 black crappie and ý200 white crappie. If we are unsuccessful or incmplete in our rults, we would also like to try again in October after it cools off..... Thanks for your consideration of this request.Bruce Taggart Regional Fisheries Supervisor Southeast Region BT/kg Kansas Ash& Game BOX 54A, RURAL ROUTE 2, PRATT, KANSAS 67124 (316) 672-5911 REGIONAL OFFICES: Northwest Regional Office Rt. 2, 183 Bypass Hays, Kansas ?7601 Northeentral Regional Office Box 489, 511 Cedar Concordia, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeka, Kansas 66614 Southwest Regional Office 808 Highway 56 Dodge City, Kansas 67801 Southcentral Regional Office Box 764, 204 WestSixth Newton, Kansas 67114 Southeast Regional Office 222 West Main Building.Suite C & D Chanute, Kansas 66720 February 17, 1986 Greg Wedd Wolf Creek Educational Center Box 309 Burlington, KS 66839

Dear Greg:

We would like to obtain twelve (12) lage female and four (4) male striped bass fran your/lake the Apil. ' .These fish will be spawned for striped bass production In Kansas. Please let me know if this can be worked in. Thanks.., Sincerely, Bruart Regional Fisheries Supervisor Southeast Region BT/kg CC: Leonard Jirak Kansas I sh& Game BOX 54A, RURAL ROUTE 2, PRATT, KANSAS 67124 (316) 672-5911 REGIONAL OFFICES: 0 Northwest Regional Office Rt. 2, 183 Bypass Hays, Kansas 67601 Northcentral Regional Office Box 489. 511 Cedar Concordia, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeka, Kansas 66614 Southwest Regional Office 808 Highway -56 DodgeCity, Kansas 67801 Southcentral Regional Office Box 764, 204 West'Sixth Newton, Kansas 67114 Southeast Regional Office 222 West Main Building Suite C & D Chanute, Kansas 66720 March 27, 1986 Greg Wedd Wolf Creek Educational Center Box 309 Burlington, KS 66839

Dear Gregg:

Thank you for your assistance in obtaining largemouth bass from Wolf Creek. We stocked 455 largemouth that averaged two pounds each. The following is a breakdown of where the fish went: Montgarery State Fishing Lake -150 Neosho State Fishing-Lake

-250 Neosho Rearing Pond -55 The fish in the Neosho Rearing Pond will be used to evaluate mor-tality and survivors will be stocked at the Mined Land Wildlife Area.Sincerely, Bruce Taggart Regional Fisheries Supervisor Southeast Region BT/kg Kansas Fish 4 S2WOUTHEAST REGIONAL OFFICE& Gam~e .22 W. MAIN BLDG. SUITE C&D, CHANUTE, KS 66720 (?7 ,6~ /(316) 431-0380 March 23, 1987 AR 2 497 Greg Wedd Wolf Creek Educational Center Box 309 Burlington, KS 66839

Dear Gregg:

Thank you for your assistance in obtaining fish from The following is a breakdown of where the fish went: Date Location 2-25-87 MLWA MLWA Farlington 3-5-87 NOSL NOSL WOSL Big Hill Ponds Species LM B Wipers Stripers Number 366 33 21 Wolf Creek.Size 2-7 1 bs.3 lb. ave.5 lbs. ave.C CAT LM B LM B 11 59 135 117 2-10 lbs.2 lb. ave.2 lb. ave.2 lb. ave.LM B All of the stripers died at Farlington.

It is believed that hauling stripers and largemouth together from where they were collected to the hatchery truck caused the mortalityyw.

In the future, striper brooders will be moved independently.

The only other fish loss was about six largemouth bass..Sorry for the delay in getting this information to you.Sincerely, Bru Regional Fisheries Supervisor Southeast Region BT/kg ec: Steve Mense Leonard Jirak Rob Friggeri EQUAL OPPORTUNITY EMPLOYER Kansas Fish SOUTHEAST REGIONAL OFFICE e 22T2 W. MAIN BLDG. SUITE C&D, CHANUTE, KS 66720 le- o i,-/ i L/oi- LA) fipc&A4V I'1RM5 (316) 431-0380 June 24, 1987 Greg Wedd and Staff Wolf Creek Education Center Box 309 Burlington, KS 66839

Dear Gregg and Staff:

We commend your effort in helping supply quality fish for the John Redmond Kid's Fishing Derby. It has become a huge success mainly due to the qualiity of fishing experienced by those young children that participate.

Most of the fish in the pond a big thanks from the Kansas fishing kids.were provided from W.C.G.S. Again, Fish & Game Commission and all the Sinc Il Leoo Jirak District Fisheries Biologist New Strawn, KS 66839 LJ/kg cc: Bruce Taggart E'QUAL OPPORTUNITY EMPLOYER Kansas Ailsh&B Game BOX 54A, RURAL ROUTE 2. PRATT, KANSAS 67124 (316) 672-5911 REGIONAL OFFICES: 0 Northwest Regional Office Rt. 2, 183 Bypass Hays, Kansas 67601 Northcentral Regional Office Box 489, 511 Cedar Concordla, Kansas 66901 Northeast Regional Office 3300 S.W. 29th Street Topeka, Kansas 66614 New Strawn February 23,1988 Southwest Regional Office 808 Highway -56 Dodge City, Kansas 67801 Southcentral Regional Office Box 764, 204 West Sixth Newton, Kansas 67114 Southeast Regional Office 222 West Main Building Suite C & D Chanute, Kansas 66720 Mr. Greg Wedd Environmental Section Kansas Gas & Electric Company Wolf Creek Generating Station Box 44 Lebo, KS 66856 Dear Greg;Following our:discussion on moving fish from Wolf Creek to our public fishing lakes I.have compiled the following list: Montgomery SFL 250 Largemouth bass Woodson SFL 250 Largemouth bass Strewn City Lake 50-'Largemouth bass 50 wipers 25 large channel cat Lairds Pond 50wipers 100 channel cat The largemouth need to be a minimum of 12 inches to be in the protected size range. The wipers and:-channel catfish can be any size with the larger catfish going to Strawn city lake. We would be ready to move these fish at your convenience.

Thanks in Advance!.isnc rely Leonard Ji ak District Fisheries Biologist REGION 2 OFFICE 3300 SW 29TH LTOPEKA, KS 66614 (913) 273-6740 Equal Opportunity Employer WILDLIFE<bPARKS Richard Sanders 2512 Cimarron Dr.Lawrence, KS 66046 January 22, 1991 Brad Loveless Wolf Creek Nuclear Operating Corp.P.O. Box 411 Burlington, KS 66839

Dear Brad,

Your cooperation in supplying fishes for-the Topeka Boat Show made the display tank a success. Species and numbers of fishes displayed included: 1. Morone spp.- 8 2. Drum -I 3. Bluegill -I 4. Black Crappie -1 5. Walleye -6 6. Flathead Catfish -3 7. Channel Catfish -3 8. Smallmouth Bass -5 9. Largemouth Bass -15 Thanks, for your assistance.

Sincerely, 441ý-Richard Sanders.cc: Steve Hawks KANSAS OUTDOORS "America's Best Kept Secret"

[!iEN REGION 2 OFFICE .3300 SW 29TH TOPEKA, KS 66614-2053 ( t (913) 273-6740 MIAR2 Equal Opprounio Emploer 91L IFE~PLARKS Richard Sanders 2512 Cimarron Drive Lawrence, KS 66046 February 26, 1993 Brad Loveless Wolf Creek Nuclear Operation Corporation P.O. 411 Burlington, KS 66839

Dear Brad,

Thanks, for allowing Kansas Department of Wildlife & Parks to collect display fish from Wolf Creek for use at the Topeka Boat and Outdoor Show. Dan put us on the fish right away and we got a good representation of Kansas sportfish.

The display was a hit with the public. If my memory is correct, the following fish were used in the display: Species Number Largemouth Bass 13 Smallmouth Basss 5 Wiper 5 White Bass 2 Blue Catfish 1 Flathead Catfish 1 Common Carp 2 Smallmouth Buffalo 1 Bigmouth Buffalo .1 Again, thanks for your cooperation.

Sincerely, Richard Sanders cc: Leonard Jirak Steve Hawks KANSAS OUTDOORS 'America's Best Kept Secret" STATE OF KANSAS g93- 020 9 Joan Finney Governor DEPARTMENT OF WILDLIFE & PARKS OPERATIONS OFFICE Rt. 2, Box 54A Pratt, KS 67124 -9599 (316) 672-5911 / FAX (316) 672-6020 Theodore D. Ensley Secretary Brad Loveless Supervisor, Environmental Management Wolf Creek Nuclear Operating Corp.P.O. Box 411 Burlington, KS 66839 August 31, 1993

Dear Mr. Loveless,

The recent flooding appears to have had a detrimental affect on the Department's walleye management programs.

Our biologists have reported that Glen Elder and Lovewell reservoirs, our primary sources for walleye egg collection, have experienced severe losses of adult fish.Complicating the situation is the fact that many other State Fishing Lakes and federal reservoirs also lost walleye. This will result in sharply increased stocking requests to rebuild these populations.

We would like to explore the possibility of collecting walleye eggs from the Wolf Creek Cooling Lake next spring. Our biologists would capture walleye using modified fyke nets, strip the eggs, and then release the fish. The eggs would then be transported to our Milford Hatchery for production of stockable fry.Department policy has been to stock fry back into lakes where egg taking occurred to insure we have no negative impact on donor lakes' recruitment.

We would gladly set aside a portion of the fry produced for return to Wolf Creek.The Department and the anglers of Kansas would be grateful to Western Resources for considering this request. Please contact me if you have any questions.

Sincerely, Douglas D. Nygren Fisheries Management Liaison xc: Joe Kramer Jim Beam Steve Adams Leonard Jirak Larry Tiemann W~&LF CREEK NUCLEAR OPERATING CORP ATO warr B. wood August 10, 1995 Genera Couvae and Secsm!" GC 95-0132 File No. 40.004.01 Kansas Department of Wildlife and Parks Route 2, Box 54A Pratt, Kansas 67124-9599 Attention:

Mr. Doug Nygren:

Subject:

Proposed Wolf Creek Lake Angling Regulations

Dear Mr. Nygren:

Wolf Creek Nuclear Operating Corporation (WONOC) proposes that the angling regulations that appear on Exhibit 1 attached to this letter be adopted by the Kansas Department of Wildlife and Parks (KDWP) beginning in 1996 for Wolf Creek Lake. These regulations were designed by WCNOC and KDWP biological staff with the primary goal of preserving the existing fishery.This fishery supports power plant operation by biologically controlling excessive numbers of gizzard shad in the cooling lake. The proposed regulations will also allow for a small amount of harvest from a primarily catch-and-release fishery that many anglers can enjoy for a long time.We look forward to working with KDWP to provide this recreational opportunity to the general public. If you have any questions on the proposed regulations, please feel free to contact Brad Loveless (316) 364-8831 extension 4530.Very truly yours, Warren B. Wood WBWrjaf cc: Leonard Jirak (KDWP)James Cambell (Coffey County Attorney)P.O. Box 411 / Burlington, KS 66839/ Phone: (316) 364-4105 AnmEqual Opportunity Employer M/F/HCN/ET EXHIBIT 1 to GC 95-0132 PROPOSED CREEL AND SIZE REGULATIONS FOR WOLF CREEK LAKE August 8, 1995 Maximum Minimum Total SpcisDaily Creel Lengt fnchW Channel, blue and flathead catfish (any combination) 2 any size White bass 2 14 Wiper hybrid 1 24.Largemouth bass 1 21 Smallmouth bass 1 18 Crappie (black or white) 2 14 Walleye 1 21 No creel or minimum length limits will be imposed on any other species.

0[REGION 5 OFFICE P.O. Box 777 Chanute, KS 66720 316-431-0380 Equal Opportunity Employer WILDLIFE tbPAIKS I ~ Zc~L AA.~~-4~'e.-, \z'~2 p\\April 1, 1997 q1.- 00665 Brad Loveless We)f rreek Lake% Leonard Jirak 540 i6th Road NW Hartford, Ks. 66854 Brad, On behalf of Public Wholesale Water Supply District #11 and the anglers of southeast Kansas, I would like to whole-heartedly thank you for permitting us to collect smallmouth bass adults from Wolf Creek Lake for stocking into the recently constructed Bone ek Lake (540 acres). Hopefully these fish will soon sg provide an exciting sportfishery in two years when the lake opens to fishing.Leonard was able to collect a total of 40 fish ranging in size from 8-15 inches. The fish hauled very well and looked to be in excellent condition when stocked into Bone Creek Lake.Again, thanks for providing us with these fish. Anglers should reap the benefits of your generosity for many years to come.Sincerely, Rob Fri ggeTi Dist. Fisheries Biologist Pittsburg//~1~>-~/KANSAS OUTDOORS "America's Best Kept Secretn Mound City District Office Courthouse, 315 Main I Mound City, KS 66056 7q Ph. 913/795-2218 FAX 913/795-2889 To: Wolf Creek Nuclear Generating Plant Brad Loveless, Chief Biologist Burlington, KS.From: Don George, District Fisheries Biologist Mound City, KS.Topic: Smallmouth Bass Request Date: 05-08-97 Mr. Brad Loveless: With this letter I am requesting permission from the Managers of Wolf Creek to obtain 250 adult Smallmouth Bass. These bass will be transported and stocked into La Cygne Reservoir.

As the Department's Liaison to the Wolf Creek Nuclear Generating Plant is Leonard firah, I am sending this request through him. With this letter I am asking Leonard to forward this request and obtain permission from the proper authorities in scheduling this project.Thank you for your assistance with this project.

-STATE OF YKANSAS DEPARTMENT OF WILDLIFE & PARKS Mound City Dis't'ctOffice Courthouse.

315 Main Mound City, KS -66056 PH: 913.795.2218 FAX 913.795.2889 LIPA To:. Wolf Creek Nuclear Operating Station Dan Williamson, Environmental Section Burlington, KS From: Don George Fisheries Biologist KS. Dept. Of Wildlife&

Parks 315 Main Mound City, KS. 66056 Date: 04-15-1998

Dear Mr. Williamson:

I am requesting permission to obtain up to 75 smallmouth bass adults from Wolf Creek Reservoir.

This mission will be conducted by Leonard Jirah and I will assist. It is my goal to obtain this sample before these fish spawn. The smallmouth bass collected will be placed into LaCygne Reservoir to compliment the stocking that occurred in 1997. Thanks for your assistance with this project.

The Worldwide Authority on Bass Fishing P.O. Box 10000 b Lake Buena Vista, Florida 32830. (407) 566 2277

• FAX 1407) 566 2072 Monday, July 25, 2005 U.S. Environmental Protection Agency Office of Water Engineering and Analysis Division Attn: Mary Smith, Director 1200 Pennsylvania Avenue NW Washington, DC 20460

Dear Mrs. Smith:

BASS/ESPN Outdoors, the worldwide authority on bass fishing, has a 35-year history of supporting fisheries and aquatic resource conservation.

We represent over half a million bass anglers across the United States. Through our BASS/ESPN Outdoors Conservation program, we work closely with state and federal agencies to protect and promote sportfishing and to conserve and improve our nation's fisheries resources.

Because of this interest, I am writing to express our concerns and opinion regarding selected provisions of the final Phase II rule under Section 316(b) of the Clean Water Act. We are aware that several concerned stakeholders groups, including Riverkeeper, have filed suit to prevent implementation of the Phase II rule in its current form. BASS is not party to any of these filings. Conversely, there are specific elements of the Phase II rule we support.Trillions of aquatic organisms are killed annually by impingement and entrainment (I&E) in power plant cooling-water intake systems. Compliance with Phase II rule provisions could achieve dramatic reductions in aquatic organism mortality.

The intent of the rule is to protect aquatic organisms from the impacts of large power plant coolant-water intake systems (CWIS), approximately 135 of which are located on lakes or reservoirs.

As we understand the rule, Phase II establishes three categories for covered electric power plants, as well as three compliance alternatives.

The second category (lakes and reservoirs other than the Great Lakes), and the compliance alternative allowing for selection and implementation of restoration measures, are the focus of our comments.Despite the contentions of Riverkeeper and others, BASS feels strongly that the restoration option in the Phase II rule will be appropriate in some cases, and can be very beneficial for some lake and reservoir systems. We feel it should remain an option, as currently stated in the regulations.

According to a 2001 U.S. Fish and Wildlife Service survey, 85% of the nation's anglers fish on lakes, reservoirs or ponds, excluding the Great Lakes. It cannot be denied that impingement in power plant cooling-water intake systems on power generation reservoirs can have a substantial effect on fisheries and the overall ecosystem.

However, habitat decline is the real culprit in the decline of sport fisheries on most reservoirs, especially those built prior to the 1960's. Flooded terrestrial vegetation that provided excellent habitat for juvenile and adult fish has long since decayed, leaving many reservoirs without physical I==.E I Bassmaster-Magazine

• BASS Times. # Fishing Tackle Retailer'

1. Bassmoster's.

Techniques

• The Bassmasters on ESPN2 e bassmaster.comr habitat. On these reservoirs, with the exception of high water years that flood terrestrial vegetation, there is little or no cover for young fish to use to escape from predators, resulting in low recruitment.

Other reservoirs have become overrun with aquatic nuisance vegetation, impacting all recreational uses.States lack the money or resources to implement massive habitat restoration efforts on these large waterbodies.

Federal agencies responsible for many of these reservoirs receive little funding to enhance recreational fishing. Hydropower, navigation and flood control receive priority.BASS feels that all alternatives need to be available to mitigate for the impacts of power plants.Restoration should be available as a compliance alternative, especially if there are not readily available technological or operational fixes. Using habitat restoration as a compliance alternative will yield net benefits to the fishery resource, increasing survival of spawned fish, leading to increased recruitment, which essentially contributes to replacing organisms lost by impingement.

Indirect benefits of habitat restoration can include increased fishable areas; improved angling success; added habitat for waterfowl, birds and other animals; and improved water quality and aesthetics.

Habitat restoration can provide benefits in perpetuity, with decreasing cost to the utility over time.In many cases, restoration will be a better option than actually reducing impingement mortality.

Most reservoir fisheries have evolved under the influence of these power generation facilities.

Your own estimates are that 98% of the fish affected by facilities in inland waters are non-game species. Often these are species whose impingement numbers are low in relation to their overall population size. While many are important forage species, they are species having typically high reproductive rates, and their abundance is generally limited by other factors such as habitat availability.

In some cases, natural and other mortality actually exceeds impingement mortality.

In one study of two Texas reservoirs, the number of fish consumed by cormorants exceeded the number of fish impinged by power plants [PBS&J. 2003.Comprehensive Aquatic Surveys of Braunig and Calaveras Lakes Data Report. Prepared for City Public Service of San Antonio].The need to revitalize habitat on aging reservoirs is an overwhelming problem. If restoration remains a compliance alternative in both Phase II and Phase III rules, the potential outcome could be millions of dollars for aquatic habitat restoration.

This would represent only a fraction of the costs of retrofitting or changing operational practices.

Without the restoration alternative, consumers will likely absorb the expense of modifications that have no measurable benefit to reservoir fisheries.

Loss of fish habitat across the nation is recognized as a critical issue for fish and wildlife managers.

Lost habitat undermines the health and productivity of aquatic systems and dependant fish populations.

Declining fish habitat also diminishes aesthetic and angling opportunities, undermining the ability of states to deliver quality public outdoor recreational opportunities.

In recognition of this, in 2003 the International Association of Fish and Wildlife Agencies committed to taking a leadership role in the development of a National Fish Habitat Initiative (NFHI), modeled after the highly successful North American Waterfowl Management Plan. BASS is proud to serve as a member of the NFHI Partnership Council, working to develop a comprehensive national strategy to conserve and enhance fish habitat. We feel that all options for enhancing fishery resources need to be available as part of this national strategy, including a restoration alternative for I&E impacts.Thank you for the opportunity to comment. If you would like further discussion, I can be reached at noreen.k.clough@bassmaster.com, or 334-551-2422.

Sincerely,/s/NOREEN K. CLOUGH Conservation Director BASS/ESPN Outdoors DATE: 8/4/05 TIME: 1330 TE: TE: Telephone Call Record TO: Steve Adams FROM: Dan Haines COMPANY: ADDRESS:-Kansas Dept of Wildlife and Parks-Office of the Secretary, Topeka, KS TELEPHONE NO: 785-296-0019

SUBJECT:

Steve Adams was called to -confirm KDWP reporting expectations for fish kills on Coffey County Lake due to cold shock or impingement.

KDWP partners with the Kansas Department of Health and Environment of fish kill investigations.

It was explained that such events are not currently reported based on: 1. KDHE position that lake is private, thus fish are not regulated.

2. KDHE 1975 letter stating that WCGS is not responsible for the loss of fish in the lake due to cold shock kill or impingement.

3. NRC FES evaluation expecting such cold shock events, and subsequent NRC direction to not report unless significantly greater than evaluated.

In addition, procedures direct WCNOC to report such events if significant using these guidelines:

1. event possibly receiving news media attention 2. event offsite 3. event greater than previously evaluated Steve Adams agreed with the current reporting procedures, and stated that there are no KDWP regulations requiring WCNOC to reportcold-shock fish kill events. KDWP would like a courtesy call if such events might be observed by the public.ACTION REQUIRED AND DATE: No actions required.DISTRIBUTION:

Bob Hammond (CC EM)Records Management File 21.16 Ralph Logsdon (CC-EM)(Signature)

DATE: 8/4/05 TIME: 1400 TE: TE: Telephone Call Record TO: Steve Haslouer FROM: Dan Haines COMPANY: ADDRESS: TELEPHONE NO:

SUBJECT:

Kansas Dept of Health and Environemtn Topeka, KS 785-296-0079 Steve Haslouer was called to confirm KDHE reporting expectations for fish kills on Coffey County Lake due to cold shock or impingement.

Steve Haslouer works with fish kill investigations for the KDHE, which partners with KDWP. It was explained that such events are not currently reported.based on: 1. KDHE position that lake is private, thus fish are not regulated.

2. KDHE 1975 letter stating that WCGS is not responsible for the loss of fish in the lake due to cold shock kill or impingement.

3. NRC FES evaluation expecting such cold shock events, and subsequent NRC direction to not report unless significantly greater than evaluated.

In addition, procedures direct WCNOC to report such events if significant using these guidelines:

1.2.3.event possibly receiving news media attention event offsite event greater than previously evaluated Steve Haslouer agreed with the current reporting procedures, and stated that there are no KDHE regulations requiring WCNOC to report cold-shock fish kill events. He agreed with Steve Adams of the KDWP that a courtesy call if such events might be observed by the public would be appropriate.

ACTION REQUIRED AND DATE: No actions required.DISTRIBUTION:

Bob Hammond (CC EM)Records Management File 21.16 Ralph Logsdon (CC-EM)' A 4 C (Signature)

W ILF CREEK NUCLEAR OPERATING CORPORATION Kevin J. Moles Manager Regulatory Affairs'JAN 2 4 200 RA 07-0010 Kansas Department of Health and Environment Bureau of Water -Industrial Programs 1000 SW Jackson St., Suite 420 Topeka, Kansas 66612-1367 Attention:

Mr. Eric Staab

Reference:

69FR41576 "Final Regulations to Establish Requirements for Cooling Water Intake Structures at Phase II Existing Facilities; dated July 9, 2004

Subject:

Entrainment Study Exemption Request.D-ear Mr. Staab: Based on a conversation with Ralph Logsdon on January 23, 2007, Wolf Creek Nuclear Operating Corporation (WCNOC) requests a letter confirming Kansas Department of' Health and Environment's (KDHE) position on exempting Wolf Creek Generating Station cooling water intake structure from an entrainment study.Under the final rule, Environmental Protection Agency has established performance standards for the reduction of impingement mortality and, when appropriate, entrainment.

The type of performance standard to a particular facility is based on several factors, including the facility's location (i.e., source waterbody).

Exhibit V-I, Performance Standards Requirement, summarizes the performance standards based on waterbody type. For lakes and reservoirs Exhibit V-1 only requires an impingement mortality study to be performed.

WCNOC understands that Environmental Protection Agency final rule referenced above does not require an entrainment study on lake and reservoirs and, therefore exempt from that portion of 316(b) performance standards.

WCNOC is requesting written confirmation of this position stated in the reference.

If you have any questions regarding this request, please contact Mr.Ralph Logsdon at (620) 364-8831, extension 4730.Sincerely, Kevin J M KJM/rll P.O. Box 411 / Burlington, KS 66839 / Phone: .(620) 364-8831 An Equal Opportunity Employer M/F/HC/VET

.

Kathleen Sebelius, Governor K A N SA S Roderick L. Bremby, Secretary DEPARTMENT'OF HEALTH AND ENVIRONMENT www.kdheks.gov March 8, 2007 Mr. Kevin J. Moles Wolf Creek Nuclear Operating Corporation i)/-&'O /3f P.O. Box 411.Burlington, KS 66839 RE: Wolf Creek Generating Station (WCGS) 316(b) Entrainment Study Requirements NPDES Permit No. I-NE07-PO02

Dear Mr. Moles:

KDHE has reviewed the letter transmitted by e-mail from Ralph Logsdon on January 24, 2007, regarding performance standard requirements for existing cooling water intake structures at the referenced facility.KDHE concurs with WCGS's finding that entrainment study requirements as described in the 316(b)Final Rule do not apply to the intake on Wolf Creek Reservoir (a.k.a. Coffey County Reservoir).

Wolf Creek Reservoir is a Lake or Reservoir type water body and as such Exhibit V- I indicates the performance standard for this intake is impingement only. As previously discussed, the entrainment data being gathered by WCNOC for this intake is voluntary and has been requested to be included in the study documentation information only.In light of the Court remands which essentially "gut" the 316(b) regulations, KDHE will require the permittee to finish out the sampling work. already started and await EPA's response to the remand and directions from the Court. Once you have the sampling work completed we believe a meeting would be appropriate to present the information and hopefully by then we will be able to provide additional direction.

If you have any questions in regard to this issue, please feel free to call me at (785) 296-4347.Sincerely,7 r Eric C. Staab, P.E.Industrial Programs Section Bureau of Water ECS:es pc:. Northeast District Office Ralph Logsdon, WCGS John Dunn, EPA Region VII KDHE, BOW, IPS CURTIS STATE OFFICE BUILDING, 1000ISW JACKSON ST., STE. 420, TOPEKA, KS 66612-1367 Voice 785-296-554:5 Fax 785-296-5509 APPENDIX D MAKEUP WATER SCREENHOUSE (MUSH) 316(b) DETERMINATION Letter dated January 23, 2007, form E. Staab (KDHE-BOW) to K. Moles (WCNOC), "MUSH Exemption for 316(b) Requirement' Letter dated January 17, 2007, from K. Moles (WCNOC) to E. Staab (KDHE-BOW), "Water Transfer Vs. 316(b) Requirement on the MUSH" Letter dated November 22, 2006, from E. Staab (KDHE-BOW) to J. Werner (KCP&L), "Makeup water Intake Structure to LaCygne Exempt from 316(b)" Letter dated November 15, 2006, from J. Dunn (USEPA) to J. Werner (KCP&L), "Makeup water Intake Structure to LaCygne Exempt from 316(b)" 58 0"I- 4oo 6 KANSAS Kathleen SeweliusdGovernor Roderick L Bremby, Secretary DEPARTMENT OF HEALTH AND ENVIRONMENT www.kdheks.gov January 23, 2007 Mr. Kevin J. Moles Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 RE: Wolf Creek Generating Station (WCGS) 316(b) Water Transfer Information NPDES Permit No. I-NE07-PO02

Dear Mr. Moles:

KDHE has reviewed the letter dated January 17,2007 regarding the referenced facility.

KDHE concurs with WCGS's finding that the intake on John Redmond Reservoir constitutes a water transfer and not a direct use of water by the power plant. As such, the John Redmond Reservoir intakes are not-cooling water intakes subject to 316(b).If you have any questions in regard to this issue, please feel free .to call me at (785) 296-4347.Sincerely, Eric C. Staab, P.E.Industrial Programs Section Bureau of Water ECS:es pc: Northeast District Office Ralph Logsdon, WCGS John Dunn, EPA Region VII KDHE, BOW, IPS CURTIS STATE OFFICE BUILDING, 1000 SW JACKSON ST., STE. .420, TOPEKA, KS 66612-1367 Voice 785-296-5545 Fax 785-296-55,09 W LF CREEK'NUCLEAR OPERATING COPRTO Kevin J. Moles Manager Regulatory Affairs JAN I 72D RA 07-0004 Kansas Department of Health and Environment Bureau of Water -Industrial Programs.1000 SW Jackson St., Suite 420 Topeka, Kansas 66612-1367 Attention:

Mr. Eric Staab

Reference:

Letter from E. C. Staab (KDHE) dated 11/22/06 to J. E. Werner (KCPL) confirming makeup to La Cygne Lake from the. Marais des Cygnes River constitutes a water transfer.

Subject:

Request for a letter from KDHE confirming makeup from the Neosho River to Coffey County Lake is a water transfer.;

Dear Mr. Staab:

Based on a conversation with Ralph Logsdon on January 9, 2007, Wolf Creek Nuclear Operating Corporation (WCNOC) requests a letter confirming Kansas Department of Health and Environment's (KDHE) position on water transfers.

The Wolf Creek Generating Station (WCGS) Makeup Water Screenhouse (MUSH) on the Neosho River is used on occasion to add water to Coffey County Lake (CCL). Although Coffey County Lake was constructed as a cooling lake for the WCGS it is considered a Water of the State. The pumping of water from the Neosho River to CCL is a transfer from a Water of the State to another Water of the State. Therefore, this is actually a -water transfer and not considered a direct use of water by WCGS.WCNOC understands that water transfers are not governed by NPDES permitting, and therefore exempt from the requirements of 316(b). WCNOC is requesting written confirmation of this position similar to that sent to Kansas City Power and Light in the reference.

If you have *any questions regarding this request, please contact Mr. Ralph Logsdon at. (620) 364-8831., extension 4730.Sincerely, Kevin J. Moles KJM/rll cc: Don Cadson/KDHE-BOW P.O. Box 411 / Burlington.

KS'66839 / Phone:'(620) 364-8831 An Equal OpportunityEmployer M/F/HC/VET KANSAS RODERICK L.BREMBY, SECRETARY KATHLEEN SEBEUUS, GOVERNOR DEPARTMENT OF HEALTH AND ENVIRONMENT November 22, 2006 Mr. Joseph E. Werner KCP&L P.O. Box 418679 Kansas City, MO 64141-9679 RE: LaCygne 316(b) Proposal Information NPDES Permit No. I-MC 18-POO1

Dear Mr. Werner:

KDHE has reviewed the Proposal for Information Collection PIC) dated March 31, 2006 for the referenced facility and the Errata transmitted by letter dated-October 16,2006. Additional clarifications are included KCP & L's letter to EPA datedOctober 18,2006 and EPA's response dated November 15, 2006..., KDHE concurs with EPA's finding that the intake on the Marais des Cygnes Riverconstitutes a water transfer and not a direct use of water by the power plant. As such, the Marais des Cygnes River intakes are not cooling water intakes subject to 316(b).KDHE approves the errata modifying the original PIC. KDHE understands that KCP & has proceeded with implementation of the PIC. However, the issue of how the sampling data will be used to develop the calculation baseline and demonstrate impingement mortality reduction remains-somewhat unclear.This issue in part remains unresolved in EPA guidance on the subject. It is anticipated that this issue will be resolved as data is generated, evaluated and presented as part of the Comprehensive DemonstrationStudy.

Once KCP & L resolves the issue of how the sampling data will be calculated to demonstrate-compliance, the PIC will be approved.If you have any questions in regard to this issue, please feel free to call me at (785) 296-4347.Sincerely, .Eric C. Staab, P.E.Industrial Programs Section Bureau of Water ECS:es pc: Northeast District Office John Dunn, EPA Region VII KDHE, BOW, IPS DIVISION OF ENVIRONMENT Bureau of Water -Industrial Programs Section CURTIS STATEOFFICE BUILDING, 1000 SW JACKSON ST., STE 420, TOPEKA, KS 66612-1367 Voice 785-296-5545 Fax 785-296&0086 http://www.kdhe.state.ks.us UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION VII 901 NORTH 5TH STREET KANSAS CITY, KANSAS 66101 I V 2006 Mr. Joseph E. Werner Senior Environmental Biologist Kansas City Power and Light P.O. Box 418679 Kansas City, MO 64141-9679

Dear Mr. Werner:

In your letter, dated October 18, 2006, you requested clarification on the applicability of the Phase 11 316(b) regulations to a water intake on the Marais des Cygne River. The Kansas Department of Health and Environment (KDHE) is the permitting authority for the National Pollutant Discharge Elimination (NPDES) permit program in the state of Kansas. I did some regulatory research and discussed my findings with Eric Staab with KDHE. The KDHE agrees with the finding that I am sharing in this letter.The intake on the Marais des Cygne River is used on occasion to add water to La Cygne Lake. The La Cygne Lake was constructed as a cooling lake for the La CygneGenerating Station and is a Water of the State. The KCPL provided basic data on the operation of the river intake and asserted that the intake was a water usage commensurate with a closed-cycle system, and therefore, exempt from 316(b) coverage.The transfer of water from the Marais des Cygne River to La Cygne Lake is a transfer from a Water of the State to another Water of the State. This is a water transfer and not a direct use of water by the powerplant.

At this time, water transfers are not covered by NPDES permitting.

Recently, EPA public noticed a rulemaking which confirmed that NPDES regulations would not apply to water transfers.

The public comment period has closed and the rule is expected to be finalized in early 2007.La Cygne Lake is a Water of the State, so the 316(b) rules still apply to the cooling water intake for the La Cygne powerplant.

If.you.hav.equestions, please. callme at 913-551-759.

Sin ely, hnA. Dunn Enviror~nmental Engineer Wastewater and infrastructure Management Branch cc: Eric Staab, KDHE"-

October 18, 2006 John Dunn U.S. Environmental Protection Agency, Region VII 901 North Fifth Street Kansas City, KS 66101 RE: Clean Water Act 316(b) "Proposal for Information Collection" Kansas City Power & Light La Cygne Generating Station La Cygne, Kansas

Dear Mr. Dunn:

To aid in your evaluation of Kansas City Power and Light's request to have the Marais des Cygne River intake exempt from Section 316(b) requirements, the following additional information including historical data on withdrawals and river flows is provided, as you requested.

The La Cygne Generating-Station uses La Cygne Lake as the source and receiver of once-through condenser cooling water. Sometimes, water outputs from the lake exceed water inputs. To maintain the water level in La Cygne Lake for normal plant operations, recreational use, and fish and wildlife habitat, water is occasionally pumped from the Marais des Cygne River to La Cygne Lake. If flow in the Marais des Cygnes River will not support pumping, then assurance releases are requested.

This withdrawal is supported by the purchase of assurance storage space in Melvem and Pomona lakes.Withdrawal rates range from approximately 25.8 MGD with one pump to approximately 38.7 MGD for two pumps. Historic water withdrawal rates, as reported to the Kansas Department of Agriculture, Division of Water Resources, from the Marais des Cygnes River were evaluated for the period of 2002 through 2005. Daily river flow data from the U.S. Geological Survey river gaging station 06915800 Marais des Cygnes River at La Cygne, Kansas were obtained for the same period. This gaging station is located where State Highway 152 crosses the Marais des Cygnes River just west of La Cygne and approximately

5.7 river

miles upstream of the La Cygne Lake intake (Figure 1).Monthly withdrawals from the Marais des Cygne River ranged from 0 to 1,122.41*million gallons (MG) (Figure 2a) and averaged 207.44 MG. No withdrawals occurred in 31 of the 48 months during this period. Concurrently, monthly flows in the Marais des Cygnes River ranged from 1,162 to 274,014 MG (Figure 2b) and averaged 31,368 MG.Over the period of record, total flow in the river was 1,505,650 MG and total withdrawal was 9,957 MG or 0.66 percent of the river's flow.

A. Withdrawal from Marais des Cygne River 6 1,200 -C 0 E 1,0o0 L 800 0 c 0= 600 ca'0 400 O 200 0 300,000 0 E 250,000 a-4 200,000 0 o 150,000100,000 0= 50,000 S 0 B. Flow in Marais des Cygnes River l!LA III (N 9 C-4 (N N ~ cn M co) 19t 1q, .I. ,I LO LO LO U -)099ý99 -9999999992 75 C C cj Figure 2 Monthly withdrawals from and flow in Marais des Cygnes River, 2002 through 2005 The design intake rate for the cooling water intake at the La Cygne Generating Station is 1,186 million gallons per day. This daily cooling water intake rate is slightly -greater than the maximum monthly withdrawal rate from the Marais des Cygne River recorded during 2002 through 2005 (1,122.41 MG). The maximum monthly river withdrawal rate is 3.2 percent of the monthly design cooling water intake rate (1,186 X 30 = 35,580 MG).The average Marais des Cygne River monthly withdrawal rate (207.44 MG) is only 0.6 percent of the open-cycle cooling withdrawal rate. The relative amount of water withdrawn for closed-cycle cooling (i.e., cooling towers) is typically about 5 percent of that used for open-cycle (i.e., once-through) cooling. Even at the maximum rate, therefore, the withdrawal rate by Marais des Cygne River intake is commensurate with a typical closed-cycle cooling system. As such, the Marais des Cygne River intake complies with Section 316(b) performance standards at 40 CFR 125.94(a)(1)(i) and should be exempt from the Section 316(b) Comprehensive Demonstration Study.As we have previously discussed, we also wish EPA Region VII to consider the fact that the Marais des Cygne River intake is part of a water transfer system and that the water transfer system was not a point source of pollution.

As such, the water transfer system and the intake are not subject to the National Discharge Pollutant Elimination System (NPDES). Because Section 316(b) regulations are administered under the NPDES, the Marais des Cygne River intake cannot be considered subject to the Section 316(b)regulations.

I hope you will find this information useful in evaluating our request to have the Marias des Cygne River intake exempt from Section 316(b) requirements.

Please call me at 816-654-1741 if you have any additional questions regarding this request. I look forward to your decision.Sincerely, KANSAS CITY POWER & LIGHT Joseph E. Werner Senior Environmental Biologist Cc: Chris Dubinick (KCP&L)Greg Howick (Bums and McDonnell)

A75 Question 42 -Coffey County Lake Spillway Discharges to Wolf Creek Spillway discharge records are kept in Chemistry's Data Management System (0DM).Spillway elevation is 1088.0 feet. A strong north wind will cause waves to break over spillway thus causing a release of water to Wolf Creek. The sample frequency is on the first day of discharge and weekly thereafter during discharge.

A list of the discharges that has occurred to Wolf Creek since January 1997 is catalogued below: Date Flow in Lake Level Temperature pH Chlorides Sulfates MGD In 0 C Inp~pm In ppm 04/16/97 0.195 1087.4 11 8.5 27.5 104 05/08/97 0.195 1087.3 16 8.4 26.4 105 11/06/97 0.195 1086.8 8 8.4 26.8 99.2 12/11/97 10.8 1087.7 7 8.4 26.1 100 12/23/97 0.192 1087.7 8 8.3 26.2 99.3 12/30/97 4.42 1087.9 4 8.4 26.2 97.1 01/08/98 4.4 1087.8 6 8.3 22.8 107 01/22/98 6.18 1087.7 4 8.3 26.2 102 01/29/98 0.55 1087.7 6 8.3 26.2 100 02/12/98 0.195 1087.6 8 8.4 26.8 105 02/26/98 1.6 1087.5 13 8.4 26.2 97.0 03/05/98 2.87 1087.4 8 8.3 25.5 101 03/19/98 23.0 1087.8 7 8.4 24.8 100 03/26/98 0.55 1087.9 13 8.2 25.5 106 04/02/98 4.42 1087.9 11 8.4 24.8 102 04/09/98 4.4 1087.8 11 8.3 25.8 101 04/16/98 12.5 1087.8 14 8.4 25.8 107 04/30/98 1.56 1087.9 16 8.4 25.8 103 05/07/98 1.02 1087.9 21 8.6 25.8 102 07/02/98 1.56 1087.9 27 8.3 25.1 98.5 07/09/98 0.553 1087.8 27 8.5 25.8 1 101 07/16/98 11.5 1087.7 27 8.4 25.8 92.0 07/23/98 23.0 1087.5 26.5 8.3 26.5 103 07/30/98 17.48 1088.2 26 8.2 26.5 93.8 08/06/98 8.13 1088.0 25 8.4 25.1 90.3 08/13/98 0.6 1087.9 26.5 8.5 26.0 98.1 10/01/98 1.56 1088.0 22 8.5 27.2 101 10/08/98 23.0 1088.4 19 8.2 25.8 99.6 10/15/98 8.125 1088.1 20 8.2 32.0 90.3 10/22/98 2.87 1088.1 18 8.3 22.6 85.6 10/29/98 23.0 1087.9 18 8.1 22.0 80.0 11/05/98 65 1088.9 14 8.2 24.4 94.4 11/12/98 23.0 1088.3 13 8.1 20.9 82.1 11/19/98 8.125 1088.1 14 8.2 20.9 82.1 11/25/98 4.42 1088.0 15 8.0 17.9 87.8 12/03/98 8.125 1088.2 14 8.3 24.2 *12/10/98 23.0 1088.3 11 8.2 23.4 88.4 12/17/98 14.9 1088.2 9 8.3 23.5 90.2 12/22/98 8.125 1088.1 8 8.1 23.8 92.5 12/30/98 2.055 1088.0 5 8.2 24.2 94.9 01/07/99 0.049 1087.8 3 8.1 24.5 95.6 02/04/99 1.59 1087.9 7 8.5 24.2 99.9 02/11/09 17.5 1088.1 10 8.3 21.6 89.3 02/18/99 4.42 1088.0 11 8.3 24.2 103 02/25/99 1.56 1085.8 8 8.3 24.5 93.2 03/11/99 1.56 1087.8 7 8.5 22.4 94.0 03/18/99 1.56 1085.9 10.5 8.5 24.9 108 04/15/99 30 1088.0 12 8.4 24.5 90.8 04/22/99 8.1 1088.o 15 8.3 24.2 90.8 04/29/99 4.4 1088.2 17 8.4 24.9 92.6 05/06/99 42 1088.2 16 7.9 11.9 88.0 05/13/99 8.13 1088.0 17 8.4 21.2 87.4 05/20/99 1.55 1088.1 20 8.3 **95.0 05/27/99 8.13 1088.1 21 8.7 21.2 90.5 06/03/99 8.1 1088.1 22 8.5 32.0 79.0 06/10/99 1.56 1087.9 22 8.5 34.6 104 06/17/99 1.55 1087.7 23 8.4 23.3 105 11/23/99 0.16 1086.7 13 8.4 27.0 102 12/09/99 0.15 1087.0 8 8.4 26.2 96.7 01/13/00 0.005 1086.0 7 8.3 24.5 105 03/09/00 0.300 1085.9 12 8.4 26.2 108 03/16/00 1.560 1085.9 10 8.4 24.5 105, 05/22/01 0.058 1086.7 21 7.9 35.3 122 06/11/05 5.8 1087.5 25 8.6 32.0 132 06/16/05 30 1088.7 25 8.4 28.8 i11 06/23/05 4.4 1088.1 26 8.5 28.9 103 06/30/05 0.6 1087.9 26 8.5 29.8 118 07/07/05 8.1 1088.0 27 8.4 29.4 115 07/14/05 0.55 1087.2 28 ***07/21/05 2.1 1087.9 29 ***01/05/06 0.55 1087.0 8 8.4 30.3 131 03/16/06 10.20 1086.2 13 18.3 1 36.0 1 130 pH-, cnioriaes ana SUI~ates are oniy required to De** Sample error preformed once per month