ML12018A446
| ML12018A446 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 01/11/2012 |
| From: | Pantazes J Public Service Enterprise Group |
| To: | Balsam B Division of License Renewal |
| References | |
| Download: ML12018A446 (6) | |
Text
NRR-PMDAPEm Resource From: Pantazes, Jeffrey J. [Jeffrey.Pantazes@pseg.com]
Sent: Wednesday, January 11, 2012 5:36 PM To: Balsam, Briana Cc: Strait, Kenneth A.
Subject:
FW: Draft Biological Opinion for Salem/Hope Creek Attachments: EEP11169.doc Briana: As discussed, attached are the PSEG comments on the draft NMFS BO / ITS. Most are editorial in nature. Also, I recommend that we meet to discuss the comments and potentially to tour / review the intake as a means to provide a better context for finalizing the NMFS document and conditions. We believe many of the physical conditions that existed in the 1980s and 1990s when the prior ITS was developed have been addressed through plant modifications and operational changes. A tour / discussion should provide a clear picture of what is necessary to assure the protection of the resources in the river. Please call with any questions. Thanks.Jeff Jeff Pantazes PSEG Nuclear LLC Manager - Nuclear Environmental Affairs 856-339-7900 609-440-0236 Cell 877-229-9973 Pager jeffrey.pantazes@pseg.com From: Perkins, Leslie [1]
Sent: Thursday, December 08, 2011 2:31 PM To: Pantazes, Jeffrey J.
Cc: Imboden, Andy; Logan, Dennis; Balsam, Briana
Subject:
Draft Biological Opinion for Salem/Hope Creek Good Afternoon Jeff, Attached is the draft biological opinion for Salem and Hope Creek for PSEG to review. As I mentioned on your voicemail, Briana Balsam from the Environmental Review Branch will be the NRC point of contact for the ongoing consultation with NMFS. Please review the draft BO and provide comments to Briana before or by December 22nd. If PSEG cannot provide comments by December 22nd please contact Briana to discuss a different due date.
You can contact Briana at 301-415-1042 or at the email address above.
- Thanks, Leslie Perkins Project Manager Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-2375 1
The information contained in this e-mail, including any attachment(s), is intended solely for use by the named addressee(s). If you are not the intended recipient, or a person designated as responsible for delivering such messages to the intended recipient, you are not authorized to disclose, copy, distribute or retain this message, in whole or in part, without written authorization from PSEG. This e-mail may contain proprietary, confidential or privileged information. If you have received this message in error, please notify the sender immediately. This notice is included in all e-mail messages leaving PSEG. Thank you for your cooperation.
2
Hearing Identifier: NRR_PMDA Email Number: 229 Mail Envelope Properties (A420DA7E700C0F418B725B20C04D5C83417E890184)
Subject:
FW: Draft Biological Opinion for Salem/Hope Creek Sent Date: 1/11/2012 5:36:21 PM Received Date: 1/11/2012 5:39:45 PM From: Pantazes, Jeffrey J.
Created By: Jeffrey.Pantazes@pseg.com Recipients:
"Strait, Kenneth A." <Kenneth.Strait@pseg.com>
Tracking Status: None "Balsam, Briana" <Briana.Balsam@nrc.gov>
Tracking Status: None Post Office: NJNBUMX06.enterprise.pseg.com Files Size Date & Time MESSAGE 2548 1/11/2012 5:39:45 PM EEP11169.doc 115776 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
NOAA NMFS Draft Biological Opinion 12-08-11 PSEG Nuclear Comments Section Page No. Para. Line(s) Comment Cover letter 1 1 4 Delete reference to OCNGS Cover letter 1 2 3-6 As indicated in the ITS, NMFS recognizes that a number of the shortnose sturgeon and loggerhead sea turtles impinged on the Salem intake were previously dead and may not have been killed by the operation of the facility itself, but has insufficient information to predict the percentage that were previously dead.
The calculated take specified by the ITS therefore assumes all impinged specimens were killed by the facility. PSEG Nuclear accepts the basis for the calculated take; however, respectfully requests that rotten and/or partial carcasses that were obviously dead before impingement on the facility trash bars be included as an exempted take, but excluded from the specified numeric take.
Biological Opinion 2 2 16 The current ITS does not include a requirement that impinged live sturgeon are to be tagged prior to release Biological Opinion 2 3 3 Since 1978, a total of 68 loggerheads have been captured or impinged at the Salem intake Biological Opinion 2 3 5 Since monitoring of the intake was initiated in 1978, 20 shortnose sturgeon have been recovered.
Biological Opinion 4 1 1 Change NYDEP to NJDEP Biological Opinion 4 3 8 Correct sentence to read From the steam generator, the steam is directed to the turbine Biological Opinion 4 3 10 Change in to into Biological Opinion 6 4th bullet 3-4 Delete fish and other organisms caught in the fish bucket slide along a horizontal catch screen. As the traveling screen continues to rotate, Biological Opinion 6 4th bullet 5 Replace and they slide through a flap into with and they slide across a flap seal into Biological Opinion 6 4th bullet 10 Delete the last sentence of this bullet since it does not accurately reflect current plant conditions Biological Opinion 6 2 3 Replace via a pipe with via pipes Biological Opinion 6 4 1 Replace the word design with permitted Biological Opinion 7 4 1 Change from Salem is discharged to from each Salem Unit is discharged Biological Opinion 7 4 6-7 Sentence should read At full power, Salem in permitted to discharge up to 3,024 MGD (11.4 million m3/day)
Biological Opinion 11 5 3-4 A renewed NJPDES Permit for Hope Creek was issued by the NJDEP with an effective date of July 1, 2011.
Biological Opinion 15 4 1 The proposed action has potential to affect New Jersey and Delaware state waters.
Biological Opinion 55 2 1-2 A five year research permit issued in December 2004 would have expired in December 2009.
Biological Opinion 60 2 3 Please correct the reference to Barnegat Bay since the action area for this BO is the Delaware Bay.
Biological Opinion 65 1 1 Please delete this reference to the Hudson River as the action area.
Biological Opinion 65 2 All This paragraph appears to discuss the effect of climate change in the Hudson River. A shift in the salt wedge in the Delaware River would not result in an increase in the number of spawning shortnose sturgeon in the action area, and would in fact have the opposite effect.
Biological Opinion 65 3 16 Change i.e., through 2041 to i.e., through 2040 to correctly reference the time period considered in this consultation for the Salem and Hope Creek facilities Biological Opinion 66 1 8 There little to no sea grass in the Delaware Estuary due to the EEP11169 Page 1 of 3
Section Page No. Para. Line(s) Comment high water turbidity.
Biological Opinion 66 2 16 Change i.e., through 2041 to i.e., through 2040 to correctly reference the time period considered in this consultation for the Salem and Hope Creek facilities Biological Opinion 72 Table 1 Correct the Total row in this table. The correct totals for Loggerhead should be 68(25) and overall totals should be 94(37). In addition, one of the Kemps ridley turtles from 1994 was a recapture and could be footnoted as such.
Biological Opinion 74 2 4 Insert at least before three times Biological Opinion 75 2 1-2 The data does not support this statement that nearly all of the sea turtles removed from Salem, including those recovered alive, have had evidence of injury sustained from contact with the trash bars.
Biological Opinion 76 3 7 Change (1993-July 2011) to (1993-November 2011)
Biological Opinion 76 3 20 While it is true that no Kemps ridley or green sea turtles have been impinged since 1993, it is likely that one or more of these species will be impinged over the remaining life of the facility.
PSEG respectfully requests that the ITS exemption include this possibility and allow for the take of at least one of each species.
Biological Opinion 77 1 11 Insert Unit 1 after :Salem Biological Opinion 77 1 12 Insert Unit 2 after :Salem Biological Opinion 78 1 All This discussion on potential sea grasses is not applicable for the Salem and Hope Creek action area. There is no sea grass in this region of the Delaware Estuary due to the high water turbidity.
Biological Opinion 80 4 6 Sentence should read At full power, Salem in permitted to discharge up to 3,024 MGD (11.4 million m3/day)
Biological Opinion 81 2 7-10 Delete the last two sentences of this paragraph since the referenced figures will not be included within this BO Biological Opinion 89 3 3 Please delete the reference to Barnegat Bay since the action area for this BO is the Delaware Bay.
Biological Opinion 91 4 9 Change the death of 1 loggerheads to the the death of 8 loggerheads Biological Opinion 93 4 4 As NMFS has noted elsewhere, shortnose sturgeon impinged at the facility are usually dead prior to their appearance on the facilities trash bars.
Biological Opinion 94 4 10 Please delete the reference to Hudson River since the action area for this BO is the Delaware Bay.
Incidental Take 97 3 All PSEG Nuclear accepts the basis for the calculated take; Statement however, respectfully requests that rotten and/or partial carcasses that were obviously dead before impingement on the facility trash bars be included as an exempted take, but excluded from the specified numeric take.
Terms and 99 1.d. This condition is not necessary and PSEG respectfully requests Conditions modification or deletion. Salem has two trash rakes which provide back-up capability to ensure frequent cleaning of the trash bars. A mechanical failure of one rake does temporarily preclude cleaning of the one intake bay blocked by the failed rake, but the other 11 intakes bays remain accessible. There is no safe, practical alternative method of cleaning the trash bars and PSEG generally must complete repairs to a failed trash rake within a few days to avoid operational impacts.
Terms and 101 13. 5 Change Appendix II to Appendix III Conditions Terms and 102 2 1 Change Condition #6-10 to Condition #7-9 Conditions Terms and 102 3 1 Change Condition #11 to Condition #10 Conditions EEP11169 Page 2 of 3
Section Page No. Para. Line(s) Comment Terms and 102 4 1 Change Condition #12 to Condition #11 Conditions Terms and 102 6 1 Change Conditions #10-12 to Conditions #13-14 Conditions Conservation 103 #1. All This discretionary agency activity is not necessary and could Recommendations potentially cause other adverse impacts to aquatic organisms.
PSEG utilizes portable lighting for night time inspection of the trash bars and increased permanent lighting has the potential to attract sea turtles, fish, and other aquatic organisms to the vicinity of the trash bars.
Conservation 103 #2. All Tissue analysis of dead sea turtles and shortnose sturgeon may Recommendations be a useful scientific exercise, but is unrelated to any potential impact of facility operations on these species.
Conservation 103 #3 All This discretionary agency activity is not necessary and is Recommendations unlikely to provide useful information. PSEG previously conducted radio tagging and satellite tracking of released live sea turtles that had been impinged on the trash bars as requested by the NMFS. Based on its review of PSEGs June 1997 study report and assessment of the causes of loggerhead sea turtle take at the Salem, NMFS revised the ITS to omit the sea turtle study requirement.. None of the tagged turtles returned to the facility, indicating that the Salem region is not preferred habitat for these turtles.
Conservation 103 #4 All In-water assessments, abundance, and distribution surveys for Recommendations shortnose and Atlantic sturgeon are currently being conducted in the Delaware Estuary by other scientific researchers. As indicated by NMFS in its BO, young-of-year, juvenile and adult shortnose sturgeon in the Delaware Estuary primarily use habitat well upstream of facility, and their occurrence in the vicinity of Salem Station is likely to be rare.
Figure 1 124 Please let us know if you need PSEG to provide this figure.
Figure 2 125 Please let us know if you need PSEG to provide this figure.
Appendix IV 135 The morphometric measurements on this figure are missing or illegible. Please provide an enhanced figure or copy of the reference.
EEP11169 Page 3 of 3