ML20072Q392

Forwards Oyster Creek Nuclear Generating Station,Sea Turtle Surveillance,Handling & Reporting Instructions for Operations Personnel, Rev 0

ML20072Q392
Person / Time
Site:	Oyster Creek
Issue date:	08/31/1994
From:	J. J. Barton GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20072Q393	List: ML20072Q392 ML20072Q425
References
6530-94-2105, NUDOCS 9409120029
Download: ML20072Q392 (7)

Text

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GPU Nuclear Corporation y 3 J QQgf Post Office Box 388 Route 9 South j l

Forked River, New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number: I l

August 31, 1994 I 6530-94-2105  !

l U.S. Nuclear Regulatory Commission )

Att: Document Control Desk Washington, DC 20555

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Sea Turtle Assessment Report GPU Nuclear (GPUN) submits the attached information in response to the NRC staff request for additional information regarding our draft Biological Assessment entitled " Assessment of the Impact of the Oyster Creek Nuclear Generating Station on Kemp's ridley and Loggerhead Sea Turtles", dated March 1994.

Attachment I provides the information requested in each of the general and detailed comments or describes how the Biological Assessment will be revised to address those comments.

Attachment II is the newly developed Sea Turtle Surveillance, Handling, and Reporting Instructions for Operations Personnel. These instructions were prepared in order to define the responsibilities of operations personnel with regard to sea turtles as well as to provide for the documentation of those activities. GPUN believes that these instructions address many of the questions and concerns raised in the comments from the NRC and the National Marine Fisheries Service. The revised Biological Assessment will include these instructions as an Appendix to the document.

Given the need to gather the requested additional information from a variety of outside sources as well as the need to develop new drawings and photographs, we anticipate that we will be able to complete the revision of l the Biological Assessment on or before October 31, 1994.

bbOf G 9409120029 940831 PDR ADOCK 05000219 th P PDR A 8 GPU Nuclear Corporation is a subsidiary of Genera! Puchc Ubbties Corporabon I

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6530-94-2105 Paae 2 i

' If you have any questions concerning this information, please contact Malcolm Browne (609-971-4124) or Jay Vouglitois (609-971-4021) of our Environmental Affairs Department.

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John J.

7M W W arton Vice Pr ident and Director Oyster reek l

Attachment cc: Mr. Douglas Beach U.S. Department of Commerce l Nat'l Oceanic & Atmos. Admin.

National Marine Fisheries Ser.

l Habitat Protected Res. Div.

One Blackburn Drive Gloucester, MA 01930 Administrator, Region 1 Senior NRC Resident Inspector Oyster Creek NRC Project Manager Mr. Michael Masnick, NRC Mr. John Moulton, NRC Mr. Richard Hyjack, NJDEPE i

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ATTACHMENT I GPUN Responses to Request for AdditionalInformation and Revisions Regarding Bioloeical Assessment of Sea Turtles 4

General Comments s

1. Update the assessment to include information on recent sea tunle takes at Oyster Creek and any completed necropsy repons.

RESPONSE: This information will be included in the revised Biological Assessment.

2. Revise document such that metric units are followed by English equivalents in parenthesis.

RESPONSE: The document will be revised as requested.

3. Address the capability to adequately observe the intake stmetures during mking operations and the ability to see below the surface, especially at night. Does someone observe the trash rake while operating so that it can be stopped if a sea tunle is sighted?

Also, lighting at the intake does not appear adequate. Are there any plans to upgrade the lighting? Are portable spot lights utilized? l RESPONSE: The trash rake units are designed to allow the operator to observe the l trash bars as they are cleaned. Newly developed Sea Turtle ,

Surveillance, Handling and Reponing Instructions for Operations l 1

Personnel (Attachment II; Section 4.0) direct personnel cleaning the 3 trash bars to observe the rake during the cleaning operation so that it i may be stopped if a sea turtle is sighted. The trash rake units are fitted  !

with floodlights which provide adequate lighting of the intake bays as I they are cleaned; the floodlights can be seen in the photographs that will be provided in response to detailed comment #4. There are no plans to install additional lighting. The Sea Tunie Surveillance, Handling, and Reponing Instructions direct operations personnel to utilize portable spot lights during night inspections of the intake trash bars. The ability to see below the surface, however, is limited by l 1

water column transparency (average Secchi depth approximately 1.14 m or 3.7 ft.) and the amount of debris on the trash bars. The Biological Assessment will be revised to include this information.

4. Provide details of the location that turtles have been found in the intake bays as well as their orientation and behavior when found.

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i RESPONSE: To the extent that this information is available, it will be included in Section 6.0 of the Biological Assessment. However, when turtles are mmoved from more than a few feet below the surface or if they are obscured by debris, 6etailed information on their exact location and orientation may not be available. The OCNGS Sea Tunie Incidental Sighting / Capture Report Form, an attachment to the Sea Turtle Surveillance, Handling and Reporting Instructions (Attachment II), was developed in order to standardize the gathering of data related to future

. incidental captures.

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5. Explain in more detail the trash raking process. Also, are inspections performed on the trash that is dumped from the trash bars to ensure that tunles are not confused with J i

horseshoe crabs?

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RESPONSE: The description of the trash raking process in the Biological Assessment will be expanded to include more details such as the use of the floodlights installed on the trash rake unit, the requirement to observe j the trash rake during the cleaning operation, etc. In addition, as indicated in Section 4.0 of the Sea Tunle Surveillance, Handling and l Reponing Instmetions (Attachment II), the debris removed from the 3

trash bars is hand raked into the trash car hopper. Operators are l instructed to observe the material during this process to ensure that sea turtles are not present and that they am not mistaken for horseshoe crabs. The Biological Assessment will be revised to include this j information.

l Detailed Comments J

l. Page 1-3, third complete paragraph. Delete the word " Mitigating" from the first

, sentence. The development of reponing/ notification procedures do not mitigate. i

, RESPONSE: The Biological Assessment will be revised as requested.

2. Figure 3-2 is very difficult to understand. A better schematic is needed.

RESPONSE: A better schematic is being developed and will be included in the revised Biological Assessment.

3. Page 4-1, Sectiou 4.1.1. Indicate and discuss the maximum permissible delta T, under the existing NPDES permit.

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! RESPONSE: The Biological Assessment will be revised to include a discussion of the j NPDES permit temperature limits, including the maximum permissible j delta T of 12.8'C (23 F) under normal operating conditions.

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4. Page 4-2, Section 4.1.1.1. Provide a drawing of the trash bars and trash rake apparatus.

Describe in more detail the current trash bar inspection program. Who p

rforms the e inspections and how are they performed? How does he/she know what to look for, how

! are results recorded and reponed. What is he/she supposed to do with a captured l specimen (include specific handling procedures).

RESPONSE: Drawings and/or photographs of the trash bars and trash rake apparatus

! are being prepared and will be included in the revised Biological l Assessment.

} The tmh bar inspection program is described in detail in l Attachment II, "Sca Turtle Surveillance, Handling, and Reponing i Instructions for Operations Personnel." These instmetions were developed in order to define the surveillance, handling and reponing requimments for operations personnel as well as to provide for the

documentation of the results of those activities. The instructions are

! being adopted as a Standing Order for Oyster Creek Station personnel j and will be included as an appendix to the revised Biological j Assessment. GPUN believes that these instmetions address all of the l questions raised in this comment, j

i Please note that the Sea Tunie Surveillance, Handling, and j Reponing Instmetions call for the conduct of two inspections of the j trash bars and intake bays at both the Circulating Water Intake and

Dilution Pump Intake Structures during each 8-hour work shift (Section j 3.1 of Attachment II) throughout the sea tunle season. This represents i an increase in the frequency of intake stmeture inspections previously l described in Section 7.3.6 of the Biological Assessment. This inemase

in the frequency of inspections is a response to the incidental capture j of two Kemp's ridley sea turtles during July of this year. Previously,

! incidental captures of this species had only occurred during the month i of October and we had proposed increasing the frequency of inspections j during that month. The most recent data suggest that we could expect

{ to find Kemp's ridley sea tunles in the vicinity of our intake structures i throughout the June-October period. Section 7.0 of the Biological

Assessment will be revised accordingly.

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5. Page 4-4, section 4.1.2. Expand the dilution pump explanation. This is an unusual

system unlike any other nuclear plant. Provide an explanation of the operating schedule i

and explain when the dilution pumps are used. Provide a better drawing than Figure 4-5,-

l more along the lines of Figures 4-3 and 4-4. Include a better line drawing of the trash i bars.

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J RESPONSE: A detailed explanation of the operation of the dilution pumps, including l, the operational schedule, will be included in the revised Biological Assessment. As required by the Station's NJPDES Permit, when the temperature in Oyster Creek exceeds 87 F, as measured at the U.S.

a Route 9 bridge, one dilution pump will be put into operation. If, after

one dilution pump has been in operation for at least two hours, the

temperature measured at such point continues to exceed 87*F, a second j dilution pump will be put into operation. Also, when the ambient (intake) water temperature is less than 60 F, two dilution pumps are put into operation.

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Improved drawings of the dilution pumps and trash bars am i being developed and will be included in the revised Biological Assessment.

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6. Figures 4-6 and 4-7 are not applicable and can be deleted.

RESPONSE: These figures will be deleted.

7. Page 5-1, section 5-1, third paragraph. It should either be "...and the genus a Dermochelys..." or "Q. coriacea" or "Dermochelys sa". The genus Dermochelvs is monotypic so it would be acceptable use "D. coriac_ea".

RESPONSE: The Biological Assessment will be revised to reflect this comment.

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8. Page 5-5, section 5.2.5, f~irst sentence of the fifth paragmph. Delete the word "Although", and insert the word "and" after "(Frazer,1986),".

j RESPONSE: The Biological Assessment will be revised accordingly.

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9. Figure 5-1, Is there stranding data for 19937 If so, provide this information (by county, if available).

RESPONSE: GPUN is attempting to obtain this information and will include j whatever is available in the revised Biological Assessment.

10. Figure 5-5. Is there nesting information for 1992, and 1993? If so, provide this information, as well as delineating any New Jersey specific nests.

2 RESPONSE: GPUN is attempting to obtain this information and will include whatever is available in the revised Biological Assessment.

I1. Table 6-1. Include time of day and water temperature for each collection date.

RESPONSE: Table 6-1 has been revised to include time of day and water temperature for each collection date.

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12. Page 7-6, section 7.3.2. The dip net mentioned was not observed at the intake structure.

Where is it kept and how accessible is it to the individuals inspecting the trash bars?

Also it is not clear whether the dip net is only adequate for retrieving turtles fmm the surface. Explain.

RESPONSE: As indicated in Section 4.1.1 of the Sea Turtle Surveillance, Handling, ,

and Reporting Instructions (Attachment II), a rescue sling suitable for j larger turtles (in excess of 40 pounds) is kept in the fish sampling pool at the Circulating Water Intake stmeture. Long handled dip nets suitable for the smaller turtles most commonly encountered are also available. We are pmsently working with the Security Department to  !

provide for their storage, attached to the security fence adjacent to the l sea turtle identification /msuscitation postings at the Circulating Water j and Dilution Pump intake stmetures.

Both the rescue sling and the long handled dip nets are only '

adequate for retrieving turtles from the surface or 2-3 feet below the I l surface because the use of either device requires that the sea turtle be visible from the surface.  ;

13. Page 7-7, section 7.3.5. Update section to reflect comments made at our meeting. We are concerned about shift surveillances made more or less at the same time. Perhaps it l would be best to propose some wording and discuss it with the staff befom submitting l a revision.

l l RESPONSE: As indicated in Section 3.2 of the Sea Turtle Surveillance, Handling, and Reporting Instructions (Attachment II), the first inspection should i normally be conducted one to two hours into each 8-hour work shift; the second inspection should normally be conducted five to six hours l into each 8-hour work shift. This should prevent the successive surveillances from being made more or less at the same time. Note that the instructions also call for documenting the time that each inspection is completed. Section 7.3.5 of the Biological Assessment will be revised to reflect these instmetions and the instmetions will be

' included as an Appendix to the document. We welcome comments from the NRC and NMFS staff regarding the proposed wording.

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