Text

Transmittal of the National Pollution Discharge Elimination System Permit Renewal Application for Wolf Creek Generating Station I-NE07-PO02
	ML23045A195
Person / Time
Site:	Wolf Creek
Issue date:	02/14/2023
From:	Hamman D; Wolf Creek
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	RA 23-0010, I-NE07-PO02
	Download: ML23045A195 (1)
	v • d • e

Dustin T. Hamman Manager Nuclear and Regulatory Affairs February 14, 2023 RA 23-0010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Docket No. 50-482: Transmittal of the National Pollution Discharge Elimination System Permit Renewal Application for Wolf Creek Generating Station I-NE07-PO02 Commissioners and Staff:

In accordance with Wolf Creek Generating Station (WCGS) Renewed Facility License No.

NPF-42, Appendix B Section 3.2, the enclosure to this letter provides a copy of the National Pollution Discharge Elimination System (NPDES) permit renewal application sent to Kansas Department of Health and Environment (KDHE). The NPDES permit application is for renewal only. A copy of this transmittal should have been sent to the Nuclear Regulatory Commission (NRC) at the same time the application was submitted to KDHE. This has been documented in WCGS corrective action program, condition report 10021857.

On August 26, 2021, Evergy, Inc. applied on behalf of Wolf Creek Nuclear Operating Corporation (WCNOC) to renew the Water Pollution Control Permit for WCGS. The current permit was set to expire on February 28, 2022. The renewal application was submitted at least 180 days prior to the permit expiration (September 1, 2021). KDHE is still currently reviewing the application. Upon approval of the NPDES renewal, the NRC will be notified within 30 days as required by WCGS Renewed Facility License No. NPF-42, Appendix B Section 3.2.

There are no commitments contained in this correspondence. If you have any questions concerning this matter, please contact me at (620) 364-4204.

Sincerely, Dustin T. Hamman P.O. Box 411 l Burlington, KS 66839 l 620-364-8831

DTH/jkt

Enclosure:

NPDES Permit Renewal Application, dated August 26, 2021 (96 pages) cc: S. S. Lee (NRC), w/e R. J. Lewis (NRC), w/e G. E. Werner (NRC), w/e Senior Resident Inspector (NRC), w/e P.O. Box 411 l Burlington, KS 66839 l 620-364-8831

Enclosure to RA 23-0010 NPDES Permit Renewal Application, dated August 26, 2021 (This enclosure contains 96 pages)

P.O. Box 411 l Burlington, KS 66839 l 620-364-8831

August 26, 2021 KDHE - Bureau of Water Technical Services Section 1000 SW Jackson St., Suite 420 Topeka, KS 66612-1367 RE: NPDES Permit Renewal Application Wolf Creek Generating Station I-NE07-PO02 Evergy, Inc. on behalf of Wolf Creek Nuclear Operating Corporation is applying to renew the Water Pollution Control Permit for the Wolf Creek Generating Station. The current permit is set to expire on February 28, 2022 and in compliance with standard permit conditions, this renewal application is being submitted at least 180 days prior to permit expiration (September 1, 2021).

The renewal package includes:

1. KS Combined Long Form 1/2E

2. Site Flow Diagram

3. Chemical Feed Summary Table

4. 316(b) Requirements as listed in paragraph 2 under C. Schedule of Compliance in the current permit.

If you have any questions or require additional information, please feel free to contact me by phone at (785) 231-9577 or by e-mail at jared.morrison@evergy.com.

Sincerely, Jared Morrison Director, Water and Waste Programs

KS0079057 KS COMBINED FORM 1/2CE I-NE07-PO02 Federal Permit No. Kansas Permit No.

STATE OF KANSAS WATER POLLUTION CONTROL PERMIT APPLICATION FOR INDUSTRIAL MECHANICAL WASTEWATER TREATMENT FACILITIES This is your Wastewater Treatment Facility permit renewal application. This application should be returned to the address shown at the end of this application by March 1 2021. Please review the information provided here and

make corrections / additions / deletions as appropriate. If any changes require more space than provided, continue the explanation on another piece of paper attached to the back of this form.

Pursuant to K.S.A.65-164 and 65-165, the undersigned representing WOLF CREEK NUCLEAR OPERATING CORPOR. WASTEWATER TREATMENT Facility Name: FACILITY Facility Address: 1550 OXEN LANE NE Facility City: ------------

BURLINGTON State ----------

KS Zip 66839 Permittee Name: WOLF CREEK NUCLEAR OPERATING CO Permittee Address: ---------------------------------

PO BOX 411 Permittee City: ------------

BURLINGTON State ---------

KS Zip 66839 Contact Name: Jared Morrison Contact Address: 818 S. Kansas Ave.

Contact City: ------------

Topeka State Kansas 66612 Zip -------

Contact Phone: (Land Line#) - - - ------- (Cell#) -------------

(785) 508-2443 (785) 231-9577 Contact Email: Jared.Morrison@evergy.com Hereby makes application for a permit to treat wastewater at to discharge wastewater into:

Neosho River via Wolf Creek via Wolf Creek Cooling Impoundment Name of river, stream, late, etc.

Number of employees/contractor personnel at this

1. site: 850

2. Type of Industrial Wastewater Discharged t-0 Waters of the State: (check all that apply)

_ _ x_ _ _ Non-Contact Cooling Water

Contact Cooling Water

Cooling Tower Slowdown Process Wastewater including Boiler Slowdown, Washdown Water, Water Softening x

and Reverse Osmosis Regenerate, Dewatering operations, Condensate, etc.

Other, Describe

3. How are domestic (human) wastes handled?

Connected to a City Sewer

Routed to a Separate Mechanical Wastewater Treatment Plant

Routed to the Industrial Wastewater Treatment Plant

Separate Septic Tank and Lateral Field

x Separate Wastewater Stabilization Lagoon

No domestic wastewater is generated at this site

- - - - Portable toilets

- - - - - Other, Describe:

x x

I-NE07-PO02 001X 001X - Two cell domestic waste ponds intermittent discharge x 7.5 x 30.3 x 135 x

x x <5.0 x 1.8 x 212 x 0.36 x 0.1 MGD x 0.3 MGD x 1.5 x <0.10 x 8.0 x

x x <1.0 x 14.8 x <0.50 x <0.50 x <1.0 x <1.0 x <1.0 x <0.20 x <1.0 x <1.0 x <0.50 x <1.0 x <10.0

I-NE07-PO02 002X 002X - Storm water runoff through oil water separator x <2.0 x 29.7 x 31 x

x x <5.0 x 81.8 x 25.9 x 0.58 x

x x <0.10 x 0.11 x

x x

x <1.0 x 1.7 x <0.50 x <0.50 x 1.8 x 2.3 x <1.0 x <0.20 x 1.9 x <1.0 x <0.50 x <1.0 x 10.5

I-NE07-PO02 002A 002A - Power block sumps x <2.0 x <5.7 x 288 x

x x <5.1 x 116 x 37.7 x 0.61 x 0.463 MGD x 0.808 MGD x <0.10 x 0.22 x 8.3 x

x x <1.0 x <1.0 x <0.50 x <0.50 x 2.0 x <1.0 x <1.0 x <0.20 x <1.0 x <1.0 x <0.50 x <1.0 x <10

I-NE07-PO02 003X 003X - Circ water, service water and 003A and 003B discharges x <2.0 x 19.5 x 10 x TRO = 86 x

x <4.9 x 91.9 x 30.4 x 0.82 x 639.6 MGD x 843.0 MGD x <0.10 x <0.10 x 8.49 x 26.3 Deg. C x

x <1.0 x 1.7 x <0.50 x <0.50 x 1.2 x 2.6 x <1.0 x <0.20 x 1.4 x <1.0 x <0.50 x <1.0 x <10

I-NE07-PO02 003A 003A - processed radioactive wastewater x 8.2 x <8.1 x <10 x

x x <5.0 x <1.0 x <1.0 x <0.20 x 0.194 MGD x 0.321 MGD x <0.10 x <0.10 x

x x

x <1.0 x <1.0 x <0.50 x <0.50 x <1.0 x <1.0 x <1.0 x <0.20 x <1.0 x <1.0 x <0.50 x <1.0 x <10

I-NE07-PO02 003B 003B - water treatment plant and wastewater treatment system discharge x <2.0 x <6.2 x <10 x

x x 5.5 x 49.2 x 15.4 x 0.42 x 0.206 MGD x 0.261 MGD x <0.10 x 0.21 x 7.74 x

x x <1.0 x <1.0 x <0.50 x <0.50 x <1.0 x 597 x <1.0 x <0.20 x 11.0 x <1.0 x <0.50 x <1.0 x 45.9

I-NE07-PO02 004A 004A - Wolf Creek Cooling Impoundment discharge x <2.0 x <6.5 x <10 x

x x <5.0 x 95.1 x 31.3 x 0.82 x 2.99 MGD x 5.81 MGD x <0.10 x <0.10 x 8.53 x 20.8 Deg. C x

x <1.0 x 1.6 x <0.50 x <0.50 x <1.0 x 1.3 x <1.0 x <0.20 x <1.0 x <1.0 x <0.50 x <1.0 x <10

I-NE07-PO02 005A 005A - Lime Sludge Pond Discharge to Wolf Creek Cooling Impoundment x 3.2 x <6.0 x 20 x

x x <4.9 x 160 x 22.4 x 0.50 x 8.03 MGD x 13.7 MGD x <0.10 x <0.10 x 7.5 x

x x <1.0 x 3.1 x <0.50 x <0.50 x <1.0 x <1.0 x <1.0 x <0.20 x 1.2 x <1.0 x <0.50 x <1.0 x <10

I-NE07-PO02 006A 006A - Service and Essential Service Water System to Ultimate Heat Sink x <2.0 x 15.2 x <10 x

x TRO = 197 x <5.6 x 93.5 x 30.9 x 0.83 x 33.7 MGD x 35.1 MGD x <0.10 x <0.10 x 8.56 x

x x <1.0 x 1.7 x <0.50 x <0.50 x 1.2 x 1.7 x <1.0 x <0.20 x 1.4 x <1.0 x <0.50 x <1.0 x <10

I-NE07-PO02 007X 007X - Circulating Water Intake Structure x <2.0 x 18.1 x <10 x

x x <5.0 x 95.0 x 31.0 x 0.83 x

x x <0.10 x <0.10 x

x 12.85 Deg. C x

x <1.0 x 1.8 x <0.50 x <0.50 x 1.2 x 2.3 x <1.0 x <0.20 x 1.5 x <1.0 x <0.50 x <1.0 x <10

I-NE07-PO02 008X 008X - Settling Basins Discharge during dredging of Ultimate Heat Sink x <2.0 x 8.8 x <10 x

x x <5.0 x 26.1 x 22.8 x 0.69 x

x x <0.10 x <0.10 x

x x

x <1.0 x 6.4 x <0.50 x <0.50 x <1.0 x <1.0 x <1.0 x <0.20 x 1.0 x <1.0 x <0.50 x <1.0 x <10

WOLF CREEK AVERAGE WATER USE FLOW DIAGRAM 08/2021 RURAL WATER DISTRICT #3 JOHN REDMOND MAKE UP WATER WOLF CREEK NEOSHO RIVER RESERVOIR LAKE POTABLE WATER NaOCl FeCl3 335670 GPM SERVICE WATER NaBr RO & EDI SYSTEM HFUF SYSTEM MAKE UP SYSTEM Nalco 3DT 199 NaOCl Nalco H150M REJECT, BACKWASH & CHEMICAL CLEANING Thruguard NaHSO3 VENDOR SUPPLIED DEMIN WASTES Thruguard WATER SKID 80 GPM CONTINUOUS NaOCl HCl .195 MGD MAXIMUM NaBr ESSENTIAL SERVICE NaOH CORS SYSTEM DEMIN WATER CIRC WATER WATER SYSTEM SYSTEM NaCl WASTEWATER TREATMENT WASTE STABILIZATION POND PAB VARIOUS PLANT FACILITY

OUTFALL 001A STORM DRAINS SYSTEMS OUTFALL 003(B) 1.25 MGD BATCH RELEASES (INTERMITTENT)

@ 900 GPM SITE OIL/WATER POWER BLOCK TURBINE BLDG SEPARATOR SUMPS OIL INTERCEPTOR OUTFALL 006A 32.4 MGD OUTFALL 003X 715 MGD POWERBLOCK STEAM GENERATOR LIME SLUDGE POND DRAINDOWN &

AND/OR OUTFALL 005A WOLF CREEK BLOWDOWN 5.8 MGD LAKE (INTERMITTENT)

OUTFALL 002 OUTFALL 004A AND 002(A) WOLF CREEK RADWASTE OUTFALL 003(A) SITE 2.9 MGD 0.070 MGD PROCESSING 100 300 GPM STORM DRAINS (INTERMITTENT)

NEOSHO RIVER ABNORMAL OPERATIONS

ELEMENTARY NEUTRALIZATION FACILITY CONTINGENCY PLAN A & B BASINS

PERMIT APPLICATION CHEMICAL ADDITIVES EVALUATION LOG Chemical Name Operating Outfall Toxicity Data***

Dosage* Dosage**

Concentration Concentration Lowest Aquatic Species (mg/I) (mg/I) Toxicity (mg/I)

Thruguard 404 -0.10 < 0.10 mg/I 1,098 (LC50) Fathead Minnow Circulating water @003X system ( circ) 682 (EC50) Daphnia magna Continuous feed Thruguard 404 -0.10 < 0.10 mg/I Same as above Same as above Service water @006A/003X system (service)

Continuous feed 1

§ 316(b) 40 CFR §122.21(r)

Information for the Wolf Creek Generating Station Rev 1 8/18/2021

§ 316(b) 40 CFR § 122.21(r)

Information for the Wolf Creek Generating Station prepared by Evergy Wolf Creek Generating Station Burlington, Kansas Rev 1 8/18/2021

INDEX AND CERTIFICATION Evergy

§ 316(b) 40 CFR § 122.21(r) Information for the Wolf Creek Generating Station Report Index Chapter Number Number Chapter Title of Pages 1.0 Introduction 5 2.0 Source Water Physical Data 6 3.0 Cooling Water Intake Structure Data 8 4.0 Source Water Baseline Biological Data 19 5.0 Cooling Water System Data 2 6.0 Chosen Method of Compliance 2 7.0 Entrainment Performance Studies 1 8.0 Operational Status 2 9.0 Literature Cited 3 Appendix A Engineering Drawings 5 Certification I hereby certify, as a Certified Fisheries Professional, that the information in this document was assembled under my direct personal charge.

Certificate # 3713 Date:8/18/21

WCGS 316(b) Information Rev 1 Table of Contents TABLE OF CONTENTS Page No.

1.0 INTRODUCTION

...................................................................................................................................... 1 1.1 Final Rule Requirements ................................................................................................................... 1 1.2 Final Rule Applicability....................................................................................................................... 2 1.3 Report Organization .......................................................................................................................... 3 2.0 SOURCE WATER PHYSICAL DATA ...................................................................................................... 5 2.1 Source Waterbody Description .......................................................................................................... 5 2.2 Hydrologic and Geomorphological Features ................................................................................... 10 3.0 COOLING WATER INTAKE STRUCTURE DATA................................................................................. 11 3.1 Configuration ................................................................................................................................... 11 3.3 Operations ....................................................................................................................................... 16 3.4 Flow Distribution and Water Balance............................................................................................... 18 3.5 Engineering Drawings ..................................................................................................................... 18 4.0 SOURCE WATER BASELINE BIOLOGICAL DATA ............................................................................. 19 4.1 Unavailable Data ............................................................................................................................. 20 4.2 Species in the Vicinity of the CWIS ................................................................................................. 20 4.3 Species and Life Stages Most Susceptible to Impingement and Entrainment ................................ 21 4.4 Primary Period of Reproduction, Larval Recruitment, and Peak Abundance for Relevant Taxa .... 30 4.5 Seasonal and Daily Activities........................................................................................................... 31 4.6 Protected Species Susceptible to Impingement and Entrainment ................................................... 34 4.7 Public Participation or Consultation with Federal or State Agencies ............................................... 36 4.8 Field Studies. ................................................................................................................................... 36 4.9 Protective Measures and Stabilization Activities Implemented ........................................................ 36 4.10 New Fragile Species ........................................................................................................................ 36 4.11 Incidental Take Exemption or Authorization .................................................................................... 37 5.0 COOLING WATER SYSTEM DATA .................................................................................................... 38 5.1 Cooling Water System Description .................................................................................................. 38 5.2 Design and Engineering Calculations .............................................................................................. 38 5.3 Description of Existing Impingement and Entrainment Technologies or Operational Measures ..... 39 6.0 CHOSEN METHOD OF COMPLIANCE WITH THE IMPINGEMENT MORTALITY STANDARD ....... 40 7.0 ENTRAINMENT PERFORMANCE STUDIES ...................................................................................... 42 8.0 OPERATIONAL STATUS .................................................................................................................... 43 8.1 Unit Operating Status ...................................................................................................................... 43 8.2 Completed, Approved or Scheduled Upgrades ............................................................................... 43 8.3 Plans or Schedules for Unit Decommissioning or Replacement ..................................................... 43 8.4 Current and Future Production Schedules ...................................................................................... 44 8.5 Plans or Schedules for New Units ................................................................................................... 44 9.0 LITERATURE CITED ........................................................................................................................... 45 APPENDIX A - ENGINEERING DRAWINGS Evergy TOC-1

WCGS 316(b) Information Rev 1 Table of Contents LIST OF TABLES Page No.

Table 1-1: Report Organization ...................................................................................................................... 3 Table 3-1: Through-Screen Velocity at the Traveling Screens at WCGS ..................................................... 12 Table 3-2: Station Average and Range of Annual Intake Flow Rates .......................................................... 16 Table 3-3: Station Average and Range of Monthly Intake Flow Rates ......................................................... 16 Table 4-1: List of Fish and Shellfish Species in the Vicinity of the WCGS CWIS ......................................... 20 Table 4-2: List of Fish Species in CCL not in the Vicinity of the WCGS CWIS ............................................ 21 Table 4-3: Estimated Annual Impingement of all Fish Species at WCGS .................................................... 23 Table 4-4: Early Life History Information of Most Abundant Fish Species and Susceptibility to Entrainment ................................................................................................................................. 29 Table 4-5: 2016-2020 Exit Creel at CCL ...................................................................................................... 29 Table 4-6: Protected Species in Coffey County, Kansas Potentially Susceptible to Impingement and Entrainment ................................................................................................................................. 35 Table 8-1: Unit Capacity Utilization .............................................................................................................. 43 Evergy TOC-2

WCGS 316(b) Information Rev 1 Table of Contents LIST OF FIGURES Page No.

Figure 1-1: 50-mile radius vicinity map around WCGS .................................................................................... 4 Figure 2-1: CCL, WCGS, and vicinity .............................................................................................................. 7 Figure 2-2: Average monthly water temperature in CCL in the vicinity of CWIS ............................................. 8 Figure 2-3: Long-term water temperature in CCL in the vicinity of CWIS ........................................................ 8 Figure 2-4: Average monthly conductivity measured in CCL ........................................................................... 9 Figure 3-1: Schematic of the CWIS at WCGS ............................................................................................... 13 Figure 3-2: WCGS trash basket for the rotating screen-wash (left), and location on the CWIS (right) .......... 14 Figure 3-3: WCGS CWIS along the shoreline of CCL ................................................................................... 15 Figure 3-4: WCGS daily intake flow 2018-2020............................................................................................. 16 Figure 3-5: WCGS flow diagram .................................................................................................................... 18 Figure 4-1: All species estimated impingement by week of year ................................................................... 24 Figure 4-2: Strausss linear index of selectivity for fish species in CCL impinged on the CWIS .. ................. 24 Figure 4-3: Length frequency of freshwater drum collected during the WCGS impingement study .............. 25 Figure 4-4: Length frequency of gizzard shad collected during the WCGS impingement study.................... 25 Figure 4-5: Length frequency of white crappie collected during the WCGS impingement study ................... 26 Figure 4-6: Length frequency of bluegill collected during the WCGS impingement study ............................. 26 Figure 4-7: Typical fish spawning months in Kansas (KDWPT) .................................................................... 30 Figure 4-8: Freshwater drum estimated impingement by week of year ......................................................... 32 Figure 4-9: Gizzard Shad estimated impingement by week of year .............................................................. 32 Figure 4-10: Bluegill estimated impingement by week of year ........................................................................ 33 Figure 4-11: White crappie estimated impingement by week of year .............................................................. 33 Evergy TOC-3

WCGS 316(b) Information Rev 1 Table of Contents LIST OF ABBREVIATIONS Abbreviation Term/Phrase/Name

ºC degrees Celsius

§ Section AIF actual intake flow BTA best technology available CCRS closed-cycle recirculating system CFR Code of Federal Regulations cfs cubic ft per second CWA Clean Water Act CWIS cooling water intake structures DIF design intake flow EPA U.S. Environmental Protection Agency ESA Endangered Species Act FE Federally Endangered fps feet per second ft feet ft2 square feet gpm gallons per minute HZI hydraulic zone of influence Evergy TOC-4

WCGS 316(b) Information Rev 1 Table of Contents Abbreviation Term/Phrase/Name IM impingement mortality IPaC Information for Planning and Conservation KDHE Kansas Department of Health and Environment KDWPT Kansas Department of Wildlife, Parks & Tourism WCGS Wolf Creek Generating Station MGD million gallons per day mm millimeter(s)

MSL mean sea level MW megawatt NMFS National Marine Fisheries Service NPDES National Pollutant Discharge Elimination System SE State Endangered ST State Threatened USFWS U.S. Fish and Wildlife Service Evergy TOC-5

WCGS 316(b) Information Rev 1 Introduction

1.0 INTRODUCTION

1.1 Final Rule Requirements On August 15, 2014, the U.S. Environmental Protection Agency (EPA) published in the Federal Register the National Pollutant Discharge Elimination System - Final Regulations to Establish Requirements for Cooling Water Intake Structures at Existing Facilities and Amend Requirements at Phase I Facilities: Final Rule 40 CFR Parts 122 and 125 (Final Rule) (EPA, 2014). The Final Rule establishes requirements under Section (§)

316(b) of the Clean Water Act (CWA) to ensure that location, design, construction, and capacity of cooling water intake structures (CWIS) reflect the best technology available (BTA) for minimizing adverse environmental impacts. The purpose of this action is to reduce impingement and entrainment of fish and other aquatic organisms at CWIS used by power generation and manufacturing facilities to withdraw cooling water.

The Final Rule became effective on October 14, 2014. EPA defines impingement, impingement mortality (IM),

and entrainment as the following:

Impingement occurs when any life stage of fish and shellfish are pinned against the outer part of an intake structure or against a screening device during intake water withdrawal. Impingement may also occur when an organism is near a screen but unable to swim away from the intake structure because of the water velocity at the CWIS.

IM is the death of fish or shellfish due to impingement. Impingement may cause harm to the organism, which results in mortality at some time after impingement. EPA has defined IM as the death of those organisms collected or retained by a sieve with a maximum opening of 0.56 inch.

Entrainment occurs when any life stage of fish and shellfish are drawn into the intake water flow entering and passing through a CWIS and into a cooling system.

The regulations apply to facilities that use CWIS to withdraw water from waters of the U.S. and have or require a National Pollutant Discharge Elimination System (NPDES) permit. The Final Rule establishes requirements for facilities that are designed to withdraw more than 2 million gallons per day (MGD) of water from waters of the U.S. and use at least 25 percent or more of the water withdrawn exclusively for cooling purposes.

The Final Rule requires that certain permit application requirements, consisting of data and studies, be provided by affected facilities to the Director (i.e., permitting authority) as part of the NPDES permit renewal application. The applicable permit application requirements as described in § 122.21(r) of the Code of Federal Regulations (CFR) are dependent upon the cooling system type, design intake flow (DIF) and actual intake flow (AIF).

1

WCGS 316(b) Information Rev 1 Introduction 1.2 Final Rule Applicability Evergy, owns and operates the Wolf Creek Generating Station (WCGS) located approximately 3.5 miles northeast of the city of Burlington, in Coffey County, Kansas. WCGS is located on the east bank of Coffey County Lake (CCL) (Figure 1-1). WCGS is a nominal 1,250-megawatt (MW) generating facility that uses steam from nuclear energy to drive electrical generators.

The Final Rule applies to WCGS due to the following:

WCGS has a NPDES permit and is a point source for industrial discharge of wastewater. The NPDES permit effective date is March 1, 2017, and the expiration date is February 28, 2022.

WCGS uses one CWIS and is a closed-cycle recirculating system. WCGS uses CCL, a 5,090-acre impoundment, designed and built to be part of the cooling water system. CCL is the source and receiver of the cooling system circulating water. The DIF at WCGS is greater than 800 MGD, which is greater than the 2 MGD threshold. The AIF, as defined in § 125.92(a) of the Final Rule, is the average volume of water withdrawn on an annual basis by the CWIS over the past three years. Based on the three-year period of January 1, 2018, through December 31, 2020, the AIF at WCGS is 765 MGD.

WCGS uses 100.0 percent of the water withdrawn from CCL for cooling water purposes; therefore, greater than 25 percent of flow withdrawn from CCL is used exclusively for cooling purposes.

To initiate discussions regarding 316(b) compliance at WCGS, Evergy sent a letter dated July 18, 2017, to the Kansas Department of Health and Environment (KDHE) requesting a determination that the impoundment serving WCGS (CCL) represents a closed-cycle recirculating system. In a letter dated September 25, 2017, KDHE concluded that the facility meets the definition of a closed-cycle recirculating system and that CCL was designed and constructed to impound water for cooling purposes for WCGS.

Based upon the determination, KDHE has waived the information required by 40 CFR 122.2196)(i) and (6)(ii), (9), (10), (11), (12), and (13) but expects that Evergy prepare and submit the following with the WCGS NPDES permit renewal application permit:

Source Water Physical Data (§ 122.21(r)(2))

Cooling Water Intake Structure Data (§ 122.21(r)(3))

Source Water Baseline Biological Characterization Data (§ 122.21(r)(4))

Cooling Water System Data (§ 122.21(r)(5))

Chosen Method of Compliance with Impingement Mortality (IM) Standard (§122.21(r)(6))

Entrainment Performance Studies (§ 122.21(r)(7)) Operational Status (§ 122.21(r)(8))

2

WCGS 316(b) Information Rev 1 Introduction Evergy has identified continued operation of its closed-cycle recirculation system as the chosen method of compliance with the impingement mortality standard at the WCGS.

1.3 Report Organization The report elements contained in this document are intended to meet the § 122.21(r) permitting requirements (2) through (8) for WCGS. Table 1-1 shows the organization of this report.

Table 1-1 Report Organization Section Relevant Permit Requirement Report Chapter Title Chapter 2 § 122.21(r)(2) Source Water Physical Data Chapter 3 § 122.21(r)(3) Cooling Water Intake Structure Data Chapter 4 § 122.21(r)(4) Source Water Baseline Biological Data Chapter 5 § 122.21(r)(5) Cooling Water System Data Chapter 6 § 122.21(r)(6) Chosen Method of Compliance with Impingement Mortality Standard Chapter 7 § 122.21(r)(7) Entrainment Performance Studies Chapter 8 § 122.21(r)(8) Operational Status Chapter 9 NA Literature Cited Appendix A NA Engineering Drawings Appendix B NA Water Balance Diagram 3

WCGS 316(b) Information Rev 1 Introduction E 2200 Rd E 2400 Rd E 2350 Rd E 2400 Rd Figure 1-1 50-mile radius vicinity map around WCGS.

4

WCGS 316(b) Information Rev 1 Source Water Physical Data 2.0 SOURCE WATER PHYSICAL DATA This chapter provides the following permit application requirements in the Final Rule under § 122.21(r)(2),

Source Water Physical Data:

i. A narrative description and scaled drawings showing the physical configuration of all source water bodies used by the facility, including areal dimensions, depths, salinity and temperature regimes, and other documentation that supports the determination of the water body type where each cooling water intake structure is located.

ii. Identification and characterization of the source waterbodys hydrological and geomorphological features, as well as the methods used to conduct any physical studies to determine the intakes area of influence within the waterbody and the results of such studies; and iii. Locational maps 2.i Source Waterbody Description The following information provides the physical descriptions of CCL and the WCGS CWIS, including cooling water system data as required in 40 CFR 122.21 (r) (2), (3) and (5). These include source water physical data, CWIS data, and cooling water system data. CCL is an impoundment located on the WCGS site 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 managed by WCGS, the site occupies 9,818 acres, and 1,844 acres lie outside of the site boundary (Figure 2-1). 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 5,090 acres for the cooling impoundment. The main earth dam completed in 1981 was constructed across Wolf Creek and five saddle dams built along the periphery of the impoundment form 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 (ft) above mean sea level (MSL) to provide freeboard. Service and auxiliary spillways with ogee crests of 1,088 ft MSL and 1,090.5 ft MSL respectively are located on the east abutment of the main dam to prevent overtopping of the dams by a design probable maximum flood, including wave action. The normal operating elevation of the cooling impoundment is 1,087 ft MSL, which was first reached in June 1982. At this elevation the impoundment has a capacity of 111,280 acre-ft, a surface area of 5,090 acres, with an average depth of 21.9 ft. The CCL is characterized as a mesotrophic freshwater reservoir (EA1988) and supports a warm water fishery. Surface water is warmed by WCGS operation, as designed, and on average in the CWIS area, increased by 1C to 3C over preoperational periods. Temperature profiles indicate a generally decrease with depth in deeper portions of the lake, but the difference in most months were small and short-lived. This indicates that thermal stratification occurs but is not prevalent. Stratification in the CWIS area has not been observed, likely due to shallower water, wind effects, and intake flows. Sources of makeup water to the cooling impoundment include water stored in the conservation pool of John Redmond Reservoir, natural flow of the Neosho River, and the Wolf Creek watershed. The topography within Wolf Creek watershed varies from undulating hills upstream of WCGS to a floodplain area shared with the 5

WCGS 316(b) Information Rev 1 Source Water Physical Data 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 is upstream of the main dam. The cooling impoundment has altered the drainage pattern of the watershed. Two baffle dikes and two channels were built to prevent short circulating of the water flowing from the circulating water discharge to the CWIS (Figure 2-1). These channels are 215 ft wide with slopes of the channel sides at 1 foot vertical per 3 foot horizontal. The volumetric water flow rates in these channels is assumed to be 1,256 cubic feet per second (cfs) at a water velocity of 0.87 ft per second (fps) when the impoundment water level is at 1087 ft MSL [U. S. Nuclear Regulatory Commission (USNRC) 1981].

CCL is a purpose-built cooling reservoir that was constructed in 1981 as the source and receiver of water for WCGS. The cooling reservoir is formed by impounding Wolf Creek in Coffey County. CCL water temperature data is continuously collected on site (WCGS actual intake data). Water temperature demonstrated seasonal variation with the lowest temperatures in the winter and highest temperatures in summer (Figure 2-2 and 2-3). Average monthly water temperature ranged from approximately 30.0 degrees Celsius (ºC) in the summer (June through August) to 7.0 ºC in winter (December through March) (Figure 2-2 and 2-3). Conductivity is determined by collecting a grab sample upstream of the CWIS. Then, the sample is analyzed in the lab with a Dipcell. Conductivity in CCL remains relatively consistent throughout the year and is typical of a freshwater system (Figure 2-4) 6

WCGS 316(b) Information Rev 1 Source Water Physical Data Figure 2-1 CCL, WCGS, and vicinity 7

WCGS 316(b) Information Rev 1 Source Water Physical Data Average Monthly Intake Water Temperature 2016-2020 30 Water Temperature Degrees Celisus 25 20 15 10 5

0 Figure 2-2 Average monthly water temperature in CCL in the vicinity of CWIS.

Weekly Intake Water Temperature 2016-2020 35 Water Temperature Degrees Celsius 30 25 20 15 10 5

0 1/4/2016 1/4/2017 1/4/2018 1/4/2019 1/4/2020 Figure 2-3 Long-term water temperature in CCL in the vicinity of CWIS.

8

WCGS 316(b) Information Rev 1 Source Water Physical Data Intake Water Conductivity 2016-2020 670 660 Conductivity Microsiemens 650 640 630 620 610 600 590 580 Figure 2-4 Average monthly conductivity measured in CCL.

9

WCGS 316(b) Information Rev 1 Source Water Physical Data 2.ii Hydrologic and Geomorphological Features CCL is formed by impounding Wolf Creek in Coffey County. The headwaters for Wolf Creek are located seven miles north of CCL in Coffey County, Kansas. Wolf Creek above and below CCL can be categorized as intermittent and incised. CCL is held in place by a main dam and two saddle dams. Three additional saddle dams are located adjacent to the west shoreline. The main dam is 100 ft high on the south end of the lake (WC EAP). CCL maintains an average normal lake level of approximately 1087 ft (ft) mean sea level (MSL),

and a maximum water depth of 75 ft. Total reservoir area is approximately 5,090 acres.

The hydraulic zone of influence (HZI) refers to the portion of the source water body hydraulically affected by the CWIS withdrawal of water, as defined by EPA (2001) in the preamble to the Phase I rule for new facilities. The HZI extends to the approximate boundary where hydraulic velocities from the CWIS fall below the ambient hydraulic velocities in the waterbody resulting from river currents or tides. The HZI is based on the ambient hydraulic characteristics of the source waterbody and the facility withdrawal rate. No physical studies have been performed to determine the WCGS CWIS HZI. However, considerable research, from a radiological perspective, has been conducted on ground water movement within and away from the site.

The CWIS has no effective HZI in soils and rocks in the adjoining areas. Groundwater levels around the plant site are primarily influenced by the cooling lake elevation. The cooling water system discharges back to the cooling lake and has no impact on cooling lake level or groundwater levels. The geology at the CWIS is a residual silty clay over sedimentary bedrocks, which are primarily shale. Around the CWIS, the overburden and bedrock are relatively impervious except for weathered portions of the bedrock, which are still mostly impervious. The only relatively permeable soil is the crushed rock aggregate used as structure backfill and pipe bedding, which is confined to areas around the buildings and pipe trenches. If the cooling lake elevation changes, groundwater elevations around the site will lag due to the impermeability of the natural soils and the relatively small areas of the more permeable aggregate backfills.

2.iii Locational Maps The WCGS is located on the east bank of CCL in Coffey County, Kansas. CCL is a purpose-built cooling reservoir constructed in 1977-1982 to act as the source and receiver of water for the station (Figure 2-1).

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WCGS 316(b) Information Rev 1 Cooling Water Intake Structure Data 3.0 COOLING WATER INTAKE STRUCTURE DATA This chapter provides the following permit application requirements in the Final Rule under § 122.21(r)(3),

Cooling Water Intake Structure Data:

i. A narrative description of the configuration of each cooling water intake structure and where it is located in the waterbody and in the water column; ii. Latitude and longitude in degrees, minutes, and seconds for each cooling water intake structure; iii. A narrative description of the operation of each of cooling water intake structure, including design intake flows, daily hours of operation, number of days of the year in operation and seasonal changes, if applicable; iv. A flow distribution and water balance diagram that includes all sources of water to the facility, recirculating flows, and discharges; and

v. Engineering drawings of the cooling water intake structure 3.i Configuration The CWIS is a shoreline intake structure located on the east central shoreline of CCL. The CWIS has three bays, each containing a circulating water pump and two traveling screens. Under normal operations all three pumps produce a total capacity of 1,116 (cfs). Occasionally, circulating water pump operation is reduced to two, facilitating maintenance requirements. The flow rate for two pumps is 744 (cfs). The CWIS also has three service water pumps and one low flow service water pump. Two service water pumps in one of the three bays. A service water pump and a low flow service water pump in another bay. The design flow of one service water pump is 56 (cfs). It is possible that two service water pumps would be in operation with suction from the same bay along with a circulating water pump. In this alignment, the velocity through traveling screen is calculated at 2.3 fps. In addition, fire protection diesel and electric pumps are in the CWIS, using water from the CWIS bays as needed. Capacity of the combined pump rates could pump the volume of CCL approximately once every 38 days. Based on the total (three circulating water and three service water pumps combined) flow rate of 1,283 (cfs), the most conservative inlet water velocities were calculated as:

Velocity through the bar grills 1.5 fps Velocity through the traveling screens 2.3 fps 11

WCGS 316(b) Information Rev 1 Cooling Water Intake Structure Data The CWIS contains a bar grill, conventional traveling screens, and strainers (Figure 3-1). When CCL water temperature is below 40F, WCGS uses a frazil-ice control system in front of the CWIS recirculating warm water from the steam condenser and air bubbles. The CWIS sump floor is 19 ft below the normal operating level of CCL (1087 ft MSL) at an elevation of 1058 ft MSL (Figure 3-1). Figure 3-1 uses an elevation system specific to plant design and is 900 greater than MSL. A steel plate, at the sump inlet of CWIS, functions as a weather protection device. This steel plate extends downward from the CWIS operating floor (1092 ft MSL) to 1075.5 ft MSL. This plate facilitates intake flows 12 ft. below normal operating level. Smaller flows are obvious around the bar grill edges at the surface. Except for these small flows, the velocities of the circulating and service water downstream of the steel plate are essentially independent of CCL water level.

Circulating and service water flows from CCL through bar grills (trash racks) into the bays. The bar grills are 1/2-inch vertical bars spaced at three-inch intervals and are designed to remove larger debris. Two vertical traveling screens in each bay with a standard 0.375-inch mesh, made by Envirex, collect smaller debris. The traveling screens, operated intermittently, are backwashed with water from CCL. This screen-wash system is activated by a timer or automatically from a high-differential pressure switch. Typical screen wash operating frequency is once per eight hours per screen. Debris collected on the traveling screens are backwashed to a trash basket on the outside of the CWIS (Figure 3-2). This debris is manually disposed of at the Coffey County Landfill. Fish that survive impingement and are small enough to pass through the trash basket openings are returned to CCL. The through-screen velocity at CWIS was estimated at 2.3 ft per second (fps). Additional screen details are presented in table 3-1.

Table 3-1: Through-Screen Velocity at the Traveling Screens at WCGS.

Parametera CWIS Number of screens 6 Screen width (ft) 10 Bottom of screen elevation (ft) 1058 Low water elevation (ft) 1075.5 Low water submergence depth (ft) 17.5 Low water effective screen height (ft) 17.5 Low water effective screen area (ft2) - per bay 210 Screen open area percentage 60%

Low water effective screen open area (ft2) - per bay 210 Intake capacity (gpm) - per bay 217,000 Intake capacity (cfs) - per bay 483.5 Through-screen velocity (fps) 2.3 (a) ft = feet; ft2 = square ft; gpm = gallons per minute; fps= ft per second 12

WCGS 316(b) Information Rev 1 Cooling Water Intake Structure Data Figure 3-1 Schematic of the CWIS at WCGS.

13

WCGS 316(b) Information Rev 1 Cooling Water Intake Structure Data Figure 3-2 WCGS trash basket for the rotating screen-wash (left), and location on the CWIS (right). Note screen-wash flow, grating and water return to CCL.

14

WCGS 316(b) Information Rev 1 Cooling Water Intake Structure Data 3.ii Latitude and Longitude The center of CWIS is located at 38 14 00 latitude and 95 41 15 longitude (Figure 3-3).

Figure 3-3 WCGS CWIS along the shoreline of CCL.

15

WCGS 316(b) Information Rev 1 Cooling Water Intake Structure Data 3.iii Operations Cooling water flows on a continuous basis, except during infrequent outages usually a few weeks or less, concurrent with WCGS refueling, around once every 18 months. Daily pumping rates for the circulating water pumps were obtained from the facility from January 1, 2018, through December 31, 2020, to evaluate the CWIS and plant operations and determine the AIF (Figure 3-4). The AIF, as defined in § 125.92(a) of the Final Rule, is the average volume of water withdrawn on an annual basis by the CWIS over the past three years. Based on the three-year period of January 1, 2018, through December 31, 2020, the AIF at WCGS is 765 MGD (Table 3-2). The maximum intake flow rate recorded over the three-years was 841 MGD. Variation in average annual AIF ranged from 732 MGD in 2018 to 825 MGD in 2020 (Table 3-2). The average monthly AIF ranged from 781 MGD in January to 833 MGD in May (Table 3-3).

Intake Flow 900 800 700 Million Gallons a Day 600 500 400 300 200 100 0

Figure 3-4 WCGS daily intake flow 2018-2020 Table 3-2: Station Average and Range of Annual Intake Flow Rates (WCGS actual intake data).

Year Average (MGD)Minimum (MGD)Maximum (MGD) 2018 732 0 840 2019 737 0 841 2020 825 551 837 Average 765 16

WCGS 316(b) Information Rev 1 Cooling Water Intake Structure Table 3-3: Station Average and Range of Monthly Intake Flow Rates (WCGS actual intake data)

Month Average (MGD)Minimum (MGD)Maximum (MGD)

January 781 544 834 February 821 782 829 March 827 518 834 April 830 12 835 May 833 0 841 June 831 801 840 July 829 808 836 August 828 802 839 September 829 15 838 October 829 0 840 November 829 794 835 December 829 791 835 17

WCGS 316(b) Information Rev 1 Cooling Water Intake Structure 3.iv Flow Distribution and Water Balance. Operations One hundred percent (100%) of the cooling water flow is used for cooling purposes.

Figure 3-5 WCGS flow diagram 3.iv Engineering Drawings Engineering drawings of the CWIS are provided in Appendix A.

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WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data 4.0 Source Water Baseline Biological Data This chapter provides the following permit application requirements in the Final Rule under

§122.21(r)(4), Source Water Baseline Biological Data:

i. A list of the below data that are not available and efforts made to identify sources of the data; ii. A list of species (or relevant taxa) for all life stages and their relative abundance in the vicinity of the cooling water intake structure; iii. Identification of the species and life stages that would be most susceptible to impingement and entrainment. Species evaluated must include the forage base as well as those most important in terms of significance to commercial and recreational fisheries; iv. Identification and evaluation of the primary period of reproduction, larval recruitment, and period of peak abundance for relevant taxa;

v. Data representative of the seasonal and daily activities (e.g., feeding and water column migration) of biological organisms in the vicinity of the cooling water intake structure; vi. Identification of all threatened, endangered, and other protected species that might be susceptible to impingement and entrainment at your cooling water intake structures; vii. Documentation of any public participation or consultation with Federal or State agencies undertaken in development of the plan; and viii. If you supplement the information requested in paragraph (r)(4)(i) of this section with data collected using field studies, supporting documentation must include a description of all methods and quality assurance procedures for sampling, and data analysis including a description of the study area; taxonomic identification of sampled and evaluated biological assemblages (including all life stages of fish and shellfish); and sampling and data analysis methods.

ix. Identification of protective measures and stabilization activities that have been implemented, and a description of how these measures and activities affected the baseline water condition in the vicinity of the intake.

x. For the owner or operator of an existing facility, a list of fragile species, as defined at 40 CFR 125.92(m), at the facility. The applicant need only identify those species not already identified as fragile at 40 CFR 125.92(m).

xi. For the owner or operator of an existing facility that has obtained incidental take exemption or authorization for its cooling water intake structure(s) from the U.S. Fish and Wildlife Service or the National Marine Fisheries Service, any information submitted to obtain that exemption or authorization may be used to satisfy the permit application information requirement of paragraph 40 CFR 125.95(f) if included in the application.

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WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data 4.i Unavailable Data and Data Search Effort Relevant data to characterize the biological community in CCL is provided in the proceeding sections.

Entrainment data is not available. Biological community data for Wolf Creek above CCL is not available.

Efforts made to identify sources of data include literature search and personal communication Kansas Department of Wildlife Parks and Tourism (KDWPT) and KDHE.

4.ii Species Relative Abundance for all Life Stages in the Vicinity of the CWIS CCL supports a diverse fishery. Fish species abundance fluctuates across the reservoir and over-time depending on abiotic and biotic conditions. Fisheries management and annual standardized sampling is conducted by WCGS in consultation and partnership with (KDWPT) through a Memorandum of Understanding.

Aquatic ecology reports are produced by WCGS annually (Zebra Mussel, Water Quality and Aquatic Vegetation Monitoring Report and Plan). Fisheries management reports are produced every three years by WCGS, based on annual data collected by KDWPT and WCGS (WCGS 2018 Fisheries Report and 2019-2021 Plan). Initial and all maintenance stockings were conducted by WCGS. To evaluate species relative abundance for all life stages in the vicinity of the CWIS a focused, site specific study was conducted from 2004-2007. Additional data were compiled from site-specific reports, online sources, and recent literature. The fish and shellfish species with potential to be in the vicinity of the WCGS CWIS (Table 4-1) were identified based on the following available information sources:

Section 316(b) Impingement Characterization Study for the Wolf Creek Generating Station (Unpublished data presented to KDHE in Letter RA 08-0098, 2008)

Zebra Mussel, Water Quality and Aquatic Vegetation Monitoring Annual Report(s)

Thirteen fish and one shellfish species were identified with the potential to be near the CWIS (Table 4-1).

Additional, fish species are present in CCL (WCGS Fisheries Reports and Plans) (Table 4-2).

Table 4-1: List of Fish and Shellfish Species in the Vicinity of the WCGS CWIS Common Name Scientific Name Relative Abundance (%)

White Crappie Pomoxis annularis 28.1 Bluegill Lepomis macrochirus 26.2 Freshwater drum Aplodinotus grunniens 22.8 Gizzard shad Dorosoma cepedianum 15 Channel catfish Ictalurus punctatus 2.9 White bass Morone chrysops 2.7 Smallmouth buffalo Ictiobus bubalus 0.6 Smallmouth bass Micropterus dolomieu 0.5 Brook silverside Labidesthes sicculus 0.4 Walleye Sander vitreus 0.4 Blue catfish Ictalurus furcatus 0.1 River carpsucker Carpiodes carpio 0.1 Flathead catfish Pylodictis olivaris 0.1 Zebra mussel Dreissena polymorpha 20

WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data Table 4-2: List of Fish Species in CCL not in the Vicinity of the WCGS CWIS Common Name Scientific Name Walleye Sander vitreus Hybrid striper Morone saxatilis X Morone chysops Common carp Cyprinus carpio Largemouth bass Micropterus salmoides Green sunfish Lepomis cyanellus Black crappie Pomoxis nigromaculatus Bigmouth buffalo Ictiobus cyprinellus Bullhead minnow Pimephales vigilax Logperch Percina caprodes 4.iii Species and Life Stages Most Susceptible to Impingement and Entrainment The fisheries community in the vicinity of the WCGS intake structures was evaluated as part of an impingement characterization study. Impingement monitoring was initiated at WCGS in December 2004 and continued through August 2007. Efforts were divided into two phases. The first was December 2004 through March 2006, and the second September 2006 through August 2007. To measure impingement, a wire basket with 1/4-inch mesh was placed in the trash basket of the CWIS (Figure3-2), to collect debris, including fish, from all rotating screen-wash water before it returned to CCL. All fish were removed, identified to species, measured (total length in mm). In the first phase fish were removed from the basket every eight hours for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and once every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the second phase. Intake water volumes were obtained from WCGS computer logging data (WCGS actual intake data). Sample data were multiplied by daily intake flow and extrapolated into a weekly impingement estimate (Table 4-3). Data were also extrapolated to unsampled weeks. Week-of-year average estimates were used to characterize seasonal impingement conditions and provided estimates of impingement based on multiple years of data.

Strausss linear index of selectivity was used to calculate species most susceptible to impingement (Strausss L; Strauss 1979). Strausss L was calculated as L = ri - pi, ri is the relative abundance of fish species collected in the impingement study and pi is the relative abundance of fish species collected by standard sampling methods in CCL. The index ranges between -1.0 and 1.0. A positive value indicates that the fish species is susceptible to impingement. A negative value indicates the fish species avoids impingement. Fish species relative abundance in CCL was determined using data available from routine fishery sampling (WCGS Fisheries Report and Plan 2006, 2007, 2008). This data was derived from annual standardized sampling (KDWPT sampling protocol 2006-2008) concurrent with the impingement study. Standardized sampling included electrofishing, trap netting, standardized-mesh gill nets, and small-mesh gill netting as presented in WCGS Fisheries Reports and Plans 2006, 2007, and 2008.

A total of 835 fish representing 13 species were collected from 32 separate 24-hour impingement monitoring 21

WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data samples (Tables 4-1 and 4-3). The total estimated impingement for all species combined was 8,573 fish per year (Table 4-3 and Figure 4-1). Four species comprised 92.1 percent of estimated impingement, and included white crappie, bluegill, freshwater drum, and gizzard shad (Table 4-1). These four species also had noticeable, positive Strausss L values (Figure 4-2). Therefore, these four species, one forage and three of recreational importance, are considered relevant taxa. Relevant taxa are included for further analysis below and in section 4.iv and 4.v. The life stage primarily observed in impingement monitoring samples was smaller fish, considered the current years production, or young-of-year (Figures 4-3 through 4-6).

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WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data Table 4-3: Estimated Annual Impingement of all Fish Species at WCGS Week of Year 2004 2005 2006 2007 Total Average MGD Flow Estimated Annual Impingement 1 429 2 429 3 5 5 5 554.8 35 4 72 5 23 8 31 15.5 554.8 109 6 103 7 103 8 2 26 28 14 554.8 98 9 12 12 12 554.8 84 10 5 5 5 554.8 35 11 1 1 1 554.8 7 12 4 13 0 0 0 554.8 0 14 4 15 1 1 1 554.8 7 16 810.3 11 17 11 18 11 19 2 2 2 810.3 14 20 32 21 32 22 32 23 32 24 7 7 7 810.3 49 25 144 26 27 41 68 34 810.3 238 27 242 28 35 35 35 810.3 245 29 170 30 7 20 27 13.5 810.3 95 31 114 32 114 33 23 15 38 19 810.3 133 34 86 35 86 36 5 6 11 5.5 810.3 39 37 19 38 19 39 0 0 0 810.3 0 40 3 3 3 810.3 21 41 1 1 1 810.3 7 42 252 43 252 44 71 71 71 810.3 497 45 58 58 58 810.3 406 46 86 86 86 554.8 602 47 651 48 100 100 100 554.8 700 49 385 50 10 10 10 554.8 70 51 174 61 235 117.5 554.8 823 52 429 Total 8,573 23

WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data All Species Estimated Impingement 900 800 700 Total Impinged 600 500 400 300 200 100 0 1 3

5 7

9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 Week Figure 4-1. All species estimated impingement by week of year.

Strauss's Linear Index of Selectivity for Fish Species in Coffey County Lake Impinged on the Cooling Water Intake Structure 0.250 0.200 0.150 0.100 Strauss's L 0.050 0.000 Wiper Bluegill Blue Catfish White Bass Walleye Green Sunfish White Crappie Black Crappie Channel Catfish Brook Silverside Smallmouth Bass Freshwater Drum Gizzard Shad River Carpsucker Flathead Catfish Largemouth Bass Common Carp Smallmouth Buffalo Bullhead Minnow Bigmouth Buffalo

-0.050

-0.100

-0.150

-0.200

-0.250 Figure 4-2 Strausss linear index of selectivity for fish species in CCL impinged on the CWIS.

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WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data Freshwater Drum 40.0 35.0 30.0 Relative Frequency 25.0 20.0 15.0 10.0 5.0 0.0 10 30 50 70 90 110 130 150 170 190 210 230 250 270 290 310 330 350 370 390 410 430 450 Total length (mm)

Figure 4-3 Length frequency of freshwater drum collected during the WCGS impingement study Gizzard Shad 35.0 30.0 25.0 Relative Frequency 20.0 15.0 10.0 5.0 0.0 10 30 50 70 90 110 130 150 170 190 210 230 250 270 290 310 330 350 370 390 410 430 450 Total length (mm)

Figure 4-4 Length frequency of gizzard shad collected during the WCGS impingement study 25

WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data White Crappie 45.0 40.0 35.0 30.0 Relative Frequency 25.0 20.0 15.0 10.0 5.0 0.0 10 30 50 70 90 110 130 150 170 190 210 230 250 270 290 310 330 350 370 390 410 430 450 Total length (mm)

Figure 4-5 Length frequency of white crappie collected during the WCGS impingement study.

Bluegill 60.0 50.0 40.0 Relative Frequency 30.0 20.0 10.0 0.0 10 30 50 70 90 110 130 150 170 190 210 230 250 270 290 310 330 350 370 390 410 430 450 Total length (mm)

Figure 4-6 Length frequency of bluegill collected during the WCGS impingement study.

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WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data Entrainment data is not available for the WCGS CWIS. A desktop analysis of the reproductive strategy, spawning, and larval habitat of relevant taxa was conducted to evaluate their susceptibility to entrainment at the WCGS CWIS. The following provides key life history characteristics for freshwater drum, gizzard shad, bluegill, and white crappie, including habitat preferences, patterns of abundance and distribution, and temporal activities expected to occur near the WCGS CWIS. The results of the desktop analysis are described below.

Freshwater Drum Freshwater drum is a common native species (Cross and Collins) regularly encountered by recreational anglers on CCL (Table 4-5). They spawn between May and July in open water (Cross and Collins). Their eggs are buoyant and drift freely near the water surface (Cross and Collins). In South Dakota, Swedberg and Walburg 1970 reported fecundity of females measuring 307 to 386 mm long and 6 to 9 years old ranged from 34,000 to 66,500 eggs. This species feeds primarily on benthic macroinvertebrates, and mollusks (Coss and Collins).

Gizzard Shad Gizzard shad represent an important forage base for recreational species (Cross and Collins). Furthermore, Haines 2000 reported, in CCL gizzard shad are important forage to maintain predator-prey balance. Willis 1987 observed the spawning period of gizzard shad to last from May 9 to June 30, in Melvern Reservoir. They broadcast spawn in open water (Cross and Collins). In Melvern, Willis 1987 observed larval gizzard shad in the top one meter of the water column. When they reach a length of about 25 mm their diet changes from zooplankton to phytoplankton and zooplankton (Cross and Collins). They also relocate to nearshore habitat (Willis 1987).

Bluegill The bluegill is a common, native recreation species that also provides a forage base to large predators (Cross and Collins). Bluegill build nests in aggregations in shallow water and exhibit quite the variety in age at maturation and unique spawning behaviors (Oplinger and Wahl 2013 and Ehlinger 1997). They feed on small crustaceans and insects and do best when aquatic vegetation is present (Cross and Collins).

White Crappie The white crappie is an important, native recreational species and maybe the most caught in Kansas (Cross and Collins). White crappie spawn in the spring (Cross and Collins). Siefert 1968 observed white crappie spawning behavior in a controlled pond. Primarily male, but females also contributed to nest building on a variety of habitats in shallow water (Siefert 1968). The adhesive eggs incubated from 42 to 103 hours0.00119 days 0.0286 hours 1.703042e-4 weeks 3.91915e-5 months and were aggressively guarded by males (Siefert 1968). The average time between hatching and nest departure was 95 hours0.0011 days 0.0264 hours 1.570767e-4 weeks 3.61475e-5 months (Siefert 1968). Early in life they move to open water and feed primarily on zooplankton (OBrien 27

WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data et. al.). As adults they feed on fish in open water (Cross and Collins).

Susceptibility of fish eggs and larvae to entrainment was qualitatively assessed into three categories (High, Moderate, Low) based on the physical attributes of the lake in the vicinity of the WCGS CWIS; egg, larvae, and juvenile sizes; reproductive strategy; and other key early life history information. Reproductive strategy was evaluated based on the following reproductive guild descriptions from Balon (1981) and Simon (1999):

Pelagophils: Fishes that are non-guarding, egg scattering, pelagic (open water) spawners. Eggs are typically numerous and either float in the water column or move along the bottom. Free embryo stages swim constantly.

Phytolithophils: Fishes that are nonobligatory plant spawners. Eggs are deposited on submerged structures. Larvae hatch late, and free embryos have cement glands. Larvae have somewhat developed respiratory structures.

Table 4-4 provides a summary of the desktop analysis and key life history characteristics of relevant taxa.

The desktop analysis indicates that bluegill and white crappie, were considered to have low susceptibility to entrainment. Freshwater drum and gizzard shad have moderate susceptibility to entrainment.

Bluegill are phytolithophils, spawning in nests nearshore on rock, gravel, leaves, or twigs that are guarded by the male parent, which keeps the early life stages confined to a relatively small area (Pflieger, 1997). White crappie are phytolithophils, having adhesive eggs that stick to rocky or gravel substrate (Pflieger, 1997). Due to these life history characteristics bluegill and white crappie have low susceptibility for dispersal into the area of the CWIS. Freshwater drum and gizzard shad were considered moderately susceptible to entrainment as pelagophilic species that are relatively indiscriminate broadcast spawners (Pflieger, 1997).

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WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data Table 4-4: Early Life History Information of Most Abundant Fish Species and Susceptibility to Entrainment Average Size Common Eggs (total length mm)a Susceptibility to Name Spawning Period Size (mm)a Demersal Adhesive Larvae Juvenile Reproductive Guild and Key Early Life History Information Entrainment Freshwater June and July when water 1.39-1.57 <19 <200 Pelagophil. Pelagic, broadcast spawner. Eggs drift on the surface of the water until they hatch, Moderate drum temperatures reach 18 ºC approximately 2 weeks later.

Gizzard shad April to June with a range from 0.2-1.1 X X <30 <180 Pelagophil. Pelagic, broadcast spawner. High fecundity and spawns multiple times per season. Eggs sink Moderate mid-March to late August slowly towards the bottom or drift with the current and adhering to any surface encountered. Eggs hatch within 3-4 days.

Bluegill Late May to August when 1.2-1.4 X <7 <95 Phytophils. Pelagic, benthic nester. Nests protected by males who stay with deposited eggs for 6-7 days Low temperatures reach 20 ºC until fry can swim free.

White April to June when 0.60-0.64 X X <21 <147 Phytophils. Neritic, benthic nester. Nests in protected areas under cover. Male guards nest area where eggs Low crappie temperatures reach 13 ºC are attached with adhesive. Eggs hatch within 3 days; fry remain attached with adhesive for 2-3 more days before swimming free.

Sources: Balon 1981, Diaber 1953, Dubuc and DeVries 202, Hansen 1951, Oplinger and Wahl 2013, Oplinger and Wahl 2015, Overmann 1979, Partridge and DeVries 1999, Pflieger 1997, Simon 1999, Sullivan et al. 2012, Swedberg and Walburg 1970, Willis 1987 (a) mm = millimeters Table 4-5: 2016-2020 Exit Creel at CCL 2016-2020 Exit Creel at CCL Released Fish Year Number Hours Largemouth Smallmouth Walleye White Crappie Channel Blue Flathead Wipers Common Freshwater Party Average Closures in Party Fished Bass Bass Bass Cat Cat Carp Drum Hours Evaluation (Days) 2016 5845 15932 6552 32514 1319 7468 1393 2221 1665 85 3034 234 n/a 31259 3.14 2017 6413 17778 7932 33105 1494 13074 2412 2772 2114 102 2176 143 2082 35405 3.15 2018 4436 12364 3074 5661 1176 13601 921 3233 2525 69 1634 120 2660 20515 2.97 2019 4825 13656 686 3720 1508 13413 1863 5252 3242 71 1846 119 5421 26449 3.00 2020 3374 9598 612 1159 1093 8252 771 3968 2374 15 925 65 5910 16374 2.96 42 Totals 24,893 69,328 18,856 76,159 6,590 55,808 7,360 17,446 11,920 342 9,615 681 16,073 130,002 3.04 Kept Fish 2016 22 32 30 1487 1050 916 554 16 73 15 n/a 2017 27 68 16 2053 1049 1440 643 26 51 33 101 2018 9 12 34 1341 386 1363 509 18 57 25 56 2019 7 20 83 2702 1012 2099 753 15 49 6 177 2020 1 19 66 1827 390 1709 508 7 30 20 264 Totals 66 151 229 9,410 3,887 7,527 2,967 82 260 99 598 Grand 18,922 76,310 6,819 65,218 11,247 24,973 14,887 424 9,875 780 16,671 Total 29

WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data Only one shellfish species is recorded in CCL. The zebra mussel was first observed in CCL in 2012 (Zebra Mussel, Water Quality and Aquatic Vegetation Monitoring Report and Plan 2006-2018). The following is a brief description of mussel sampling effort 2006-2018. Substrate searches and settlement monitors were initiated in 2006. Then, in 2007 plankton monitoring for zebra mussel veligers was initiated. Adult density monitoring was initiated in 2012 and continued through 2017. In 2017, zebra mussels were sampled by removing all mussels from a 0.252m quadrat placed in two sample locations. Mussels were then subsampled, weighed, counted, and measured for length.

KDWPT considerers the zebra mussel an aquatic nuisance species (KDWPT). Another shellfish species that has been observed is the Asiatic clam. This species is considered non-native (Great Plains Nature Center).

4.iv Primary Period of Reproduction, Larval Recruitment, and Peak Abundance for Relevant Taxa Relevant taxa in CCL spawn as early as mid-spring for white crappie and into mid-summer for bluegill. Figure 4-7 provides a general guideline for fish spawning in Kansas (KDWPT). Annual variability in fish recruitment is common (Sissenwine et al. 1988) and high mortality rates during early life stages causes much of this variation. Therefore, peak abundance occurs at the fertilized egg stage. Growth is rapid, but mortality rates remain high through most of the first year.

Figure 4-7 Typical fish spawning months in Kansas (KDWPT)

Sullivan et al. 2012, observed peak freshwater drum larval catch rates in June in the open water at Harlan County Reservoir, Nebraska. Larval freshwater drum catch rates were highly variable across years (Sullivan 2012). Swedberg and Walburg 1970 observed a similar decline, but variable catch rates of juvenile freshwater 30

WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data drum through the summer across three years of sampling in Lewis and Clark Lake. This suggest that year-class strength might be more influenced in the larval stage than the juvenile stage (Swedberg and Walburg 1970).

Willis 1987, observed peak gizzard shad larval catch rates in June in the open water at Melvern Reservoir.

Predation on gizzard shad can considerably reduce young-of-the-year abundance (Haines 2000) or eliminate the year class (Willis 1987).

Welker et al. 1994, observed several peaks in bluegill larval density throughout the summer. Peak juvenile abundance was observed in July (Welker et al. 1994). Competition and prey population dynamics can influence bluegill growth and abundance (Welker et al 1994).

Overmann 1979 observed peak larval white crappie larval catch rates in June in Kentucky. A variety of variables influence white crappie larval growth and recruitment in Chickamauga Reservoir (McDonugh and Buchanan 1991).

4.v Seasonal and Daily Activities in the Vicinity of CWIS The WCGS impingement study indicates all but four fish species present in the lake avoid impingement.

These four species are considered the relevant taxa and their seasonal and daily activities were previously discussed.

Data representing the seasonality of relevant taxa impingement is presented below (Figure 4-8 through Figure 4-11). Most impingement occurred during late fall through winter and no relationships were observed between nocturnal and diel impingement.

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WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data Freshwater Drum 400 Estimate Number of Freshwater Drum 350 300 250 200 Impinged 150 100 50 0

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43 46 49 52 Week of Year Figure 4-8 Freshwater drum estimated impingement by week of year Gizzard Shad 400 Estimated Number of Gizzard Shad 350 300 250 200 Impinged 150 100 50 0

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43 46 49 52 Week of Year Figure 4-9 Gizzard Shad estimated impingement by week of year 32

WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data Bluegill 400 Estimated Number of Bluegill Impinged 350 300 250 200 150 100 50 0

1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 Week of Year Figure 4-10 Bluegill estimated impingement by week of year White Crappie 400 Estimated Number of White Crappie 350 300 250 200 Impinged 150 100 50 0 1 3

5 7

9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 Week Figure 4-11 White crappie estimated impingement by week of year 33

WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data 4.vi Protected Species Susceptible to Impingement and Entrainment The Final Rule does not authorize the take of federally endangered or threatened species. Under the Endangered Species Act (ESA), take is defined as harassing, harming, pursuing, hunting, shooting, wounding, killing, trapping, capturing, or collecting, or attempting to engage in any such conduct, of endangered or threatened species. Federal agencies comply with the ESA through consultation under Section 7 of the ESA, which applies to NPDES permits through which the § 316(b) requirements are implemented.

The Final Rule requires that facilities identify all federally listed threatened and endangered species and designated critical habitat that are present in the action area. The action area, as defined by the U.S. Fish and Wildlife Service (USFWS) and National Marine Fisheries Service (NMFS) under Section 7, includes all areas that may be directly or indirectly affected by the operations of a facility. Therefore, the action area for a CWIS is not merely the immediate area involved in the action because the USFWS and NMFS may consider that the effects of CWIS can extend well beyond the footprint of the CWIS.

Federally listed threatened and endangered species were identified using the following online resources:

Species by County Report for Coffey, Kansas (USFWS Information for Planning and Consultation

[IPaC] system, 2021)

KDWPT Coffey County Threatened and Endangered Species (2021)

One federally listed fish, two federally listed shellfish, and two state listed shellfish were identified as potentially occurring in Coffey County, Kansas: Neosho Madtom (Noturus placidus), Neosho Mucket (Lampsilis rafinesqueana), Rabbitsfoot Mussel (Quadrula cylindrica), Western Fanshell (Cyprogenia aberti), and Ouachita Kidneyshell Mussel (Ptychobranchus occidentalis) (USFWS, 2021; KDWPT, 2021) (Table 4-3). The Flutedshell Mussel (Lasmigona costata) is also designated as a state threatened species in Coffey County.

However, designated critical habitat is in the southern part of the county several miles down-stream of the confluence of Wolf Creek and the Neosho River. No federally or state protected fish or shellfish species have been documented in surveys of CCL.

The Neosho Madtom occurs in moderately large rivers, specifically in riffles. Therefore, it is unlikely to disperse to CCL. Furthermore, dispersal to the CWIS would require traversing expansive open water or miles along the reservoir shoreline. All mussels were determined to have an unlikely or low susceptibility to impingement due to their reproductive cycle and preferred habitats (Table 4-6). Their larvae (glochidia) could be affected when the larvae are attached to host fish that become impinged. All other life stages would not be susceptible to impingement or entrainment.

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WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data Table 4-6 Protected Species in Coffey County, Kansas Potentially Susceptible to Impingement and Entrainment Common Name Scientific Name Statusa Potential to occur in the vicinity of the CWIS Susceptibility Impingement Entrainment Neosho Madtom Noturus placidus FT Unlikely - occurs in relatively clear, moderately-large Low Low rivers in riffles Neosho Mucket Lampsilis FE Unlikely - Obligate river species, occurs in shallow clean Low Low rafinesqueana water with medium to fine substrate Rabbitsfoot Mussel Quadrula cylindrica FT Unlikely - Occurs in clear water with moderate stable Low Low currents and gravel substrate Western Fanshell Cyprogenia aberti SE Unlikely - Occurs in shallow water in mud, sand, gravel, Low Low and cobble substrate Ouachita Kidneyshell Ptychobranchus ST Unlikely - Occurs in gravel substrate in clean flowing Low Low Mussel occidentalis water Source: KDWPT, 2021; USFWS, 2021 a FE= Federally Endangered, FT= Federally Threatened, SE= State Endangered, ST= State Threatened 35

WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data Numerous other protected terrestrial animal and plant species can occur within Coffey County, but their habitats are not in the vicinity of the WCGS CWIS. Therefore, it is unlikely that any of their respective life stages would be subject to impingement or entrainment at WCGS, and the WCGS CWIS will not impact their critical habitat. These protected species were not considered for further evaluation.

4.vii Public Participation or Consultation with Federal or State Agencies No pertinent public participation was undertaken in the development of this plan.

Previous correspondence with Kansas Department of Health and Environment and KDWPT regarding this regulation includes:

Telephone Call Record dated August 4, 2005, from D. Haines (WCNOC) to S. Adams (KDWP), Fish Kills Reporting Expectations Telephone Call Record dated August 4, 2005, from D. Haines (WCNOC) to S. Haslouer (KDHE), Fish Kills Reporting Expectations Letter dated January 23, 2007, from E. Staab (KDHE-BOW) to K. Moles (WCNOC), MUSH Intake Not Subject to 316(b) Requirement Letter dated March 8, 2007, from E. Staab (KDHE-BOW) to K. Moles (WCNOC), CWIS Exempt From Entrainment Study Requirements Letter RA 08-0098, dated November 11, 2008, from R. Flannigan (WCNOC) to D. Carlson (KDHE), Clean Water Act (316b) - Cooling Water Intake Structures Phase II Comprehensive Demonstration Study for NPDES Permit I-NE07-PO02 Letter RA 17-0089, dated July 18, 2017, from J. Rudeen (WCNOC) to D. Carlson (KDHE), 316(b) Information Submittal Letter 17-00433, dated September 25, 2017, from D. Carlson (KDHE) to J. Rudeen (WCNOC), Kansas Water Pollution Control Permit I-NE07-PO02 WCNOC CWA 316(b) Regulatory Requirements 4.viii Field Studies No new field studies were conducted to generate the source water baseline biological characterization data for WCGS.

4.ix Protective Measures and Stabilization Activities Implemented No protective measures or stabilization activities have been implemented in the vicinity of the WCGS CWIS.

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WCGS 316(b) Information Rev 1 Source Water Baseline Biological Data 4.x New Fragile Species No new fragile species are being proposed for this evaluation at WCGS.

4.xi Incidental Take Exemption or Authorization WCGS has not obtained an incidental take exemption or authorization for its CWIS from the USFWS, nor have any USFWS consultations for the WCGS indicated a need for an incidental take exemption or authorization.

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WCGS 316(b) Information Rev 1 Cooling Water System Data 5.0 COOLING WATER SYSTEM DATA This chapter provides the following permit application requirements in the Final Rule under

§122.21(r)(5), Cooling Water System Data:

i. A narrative description of the following:

Operation of the cooling water system and its relationship to cooling water intake structures;

The proportion of the design intake flow that is used in the system including a distribution of water used for contact cooling, non-contact cooling, and process uses;

A distribution of water reuse (to include cooling water reused as process water, process water reused for cooling, and the use of gray water for cooling);

Description of reductions in total water withdrawals including cooling water intake flow reductions already achieved through minimized process water withdrawals;

Description of any cooling water that is used in a manufacturing process either before or after it is used for cooling, including other recycled process water flows;

The proportion of the source waterbody withdrawn (on a monthly basis);

The number of days of the year the cooling water system is in operation and seasonal changes in the operation of the system, if applicable; ii. Design and engineering calculations and supporting data to support the description above; iii. Description of existing impingement and entrainment technologies or operational measures and a summary of their performance, including but not limited to reductions in entrainment mortality due to intake location and reductions in total water withdrawals and usage.

5-i Cooling Water System Description WCGS is a base-load station, generating a continuous supply of electricity throughout the year. The CWIS provides condenser cooling water to the generating unit. WCGS reuses 100.0 percent of the water for non-contact cooling within the station. Water is pumped through the condenser, to the outfall structure, and back to CCL. CCL is a reservoir designed and built for the purpose of serving as part of the cooling process for WCGS. The proportion of CCL withdrawn monthly is 65%.

All the DIF is used for non-contact cooling and recycled in a closed loop. During the three-year period of January 1, 2018, to December 31, 2020, WCGS condenser cooling water systems were down for a total of 11 days. In 2018, intake flow was zero from May 4th through May 7th due to scheduled refueling outage. In 2019, intake flow was zero from October 17th through October 23rd due to scheduled refueling outage 5-ii Design and Engineering Calculations 38

WCGS 316(b) Information Rev 1 Cooling Water System Data The CWIS at WCGS serves the cooling water system; therefore, no design and engineering calculations are required to partition water from the CWIS to multiple end uses.

5-iii Description of Existing Impingement and Entrainment Technologies or Operational Measures At WCGS impingement and entrainment technologies, as well as operation measures include the physical nature of the CWIS, fish habitats in the vicinity of the CWIS, and the fishery management techniques implemented in CCL.

The CWIS contains a bar grill, conventional traveling screens, and strainers (Figure 3-1). The CWIS sump floor is 19 ft below the normal operating level of CCL (1087 ft MSL) at an elevation of 1058 ft MSL (Figure 3-1).

A steel plate, at the sump inlet of CWIS, functions as a weather protection device. This steel plate extends downward from the CWIS operating floor (1092 ft MSL) to 1075 ft MSL. This plate facilitates intake flows 12 ft below normal operating level. Circulating and service water flows from CCL through bar grills (trash racks) into the bays. The bar grills are 1/2-inch vertical bars spaced at three-inch intervals and are designed to remove larger debris. Two vertical traveling screens in each bay with a standard 0.375-inch mesh, made by Envirex, collect smaller debris. The traveling screens, operated intermittently, are backwashed with water from CCL.

Debris collected on the traveling screens are backwashed to a trash basket that drains to the CCL on the outside of the CWIS (Figure 3-2). Per the KDHE letter dated September 25, 2017, the existing cooling water system meets the definition of a closed-cycle recirculating system in the Final Rule.

Habitat in the CWIS area is designed for cooling water intake purposes and therefore, a deterrent to most aquatic species. The CWIS is situated at the end of an excavated channel adjacent to designed slope shorelines. Aquatic species that use littoral habitats avoid the area because the CWIS protrudes away from the shoreline and the excavated channel is over 20 deep. Additionally, impact to aquatic species that use pelagic habit is reduced due to the steel plate that facilitates intake flows 12 below the water surface at normal operating lake elevation.

Current fishery management techniques, and those implemented in CCL prior to WCGS operations, are designed to promote a sustainable recreational fishery and reduce impingement. CCL was initially stocked with a diversity of large predators. In recent year, supplemental forage and predator species were stocked to diversify forage and maintain predator-prey balance.

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WCGS 316(b) Information Rev 1 Method of Compliance 6.0 Chosen Method of Compliance with the Impingement Mortality Standard This chapter provides the appropriate permit application requirements in the Final Rule under

§122.21(r)(6), Chosen Method of Compliance with the IM Standard. The following subsections provide a review of the IM compliance options in the Final Rule, and rationale for selection.

The Final Rule requires that existing facilities subject to the rule must comply with one of the following seven options:

1. Operate a closed-cycle recirculating system as defined by the Final Rule (at §125.92)

2. Operate a CWIS that has a maximum design through-screen design intake velocity of 0.5 fps;

3. Operate a CWIS that has an actual through-screen intake velocity of 0.5 fps;

4. Operate an offshore velocity cap that is a minimum of 800 ft offshore;

5. Operate a modified traveling screen that the Director determines meets the definition of the rule (at

§125.92(s)) and that the Director determines the BTA for impingement reduction;

6. Operate any other combination of technologies, management practices, and operational measures that the Director determines is BTA for impingement reduction; or

7. Achieve the specified IM performance standard of less than 24 percent.

EPA determined in the Final Rule that the operation of a closed-cycle recirculating system (CCRS) achieves the necessary reductions in IM and thus meets the IM standard (EPA, 2014). To use this IM compliance option, a facility must operate a CCRS as defined at § 125.92(c). The EPA defines a CCRS as:

a system designed and properly operated using minimized makeup and blowdown flows withdrawn from a water of the US to support contact or non-contact cooling uses within a facility, or a system designed to include certain impoundments. A closed-cycle recirculating system passes cooling water through the condenser and other components of the cooling system and reuses the water for cooling multiple times. A closed-cycle recirculating system includes a facility with wet, dry, or hybrid cooling towers, a system of impoundments that are not waters of the US, or any combination thereof. A properly operated and maintained closed-cycle recirculating system withdraws new source water (make-up water) only to replenish losses that have occurred due to blowdown, drift, and evaporation.

Includes a system of impoundments of waters of the United States where they were constructed prior to October 14, 2014 and created for the purpose as part of the cooling water system as documented in the project purposes statement for section 404 permit obtained. If no 404 permit is in place, documentation of the projects purpose must be demonstrated for the NPDES permit renewal.

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WCGS 316(b) Information Rev 1 Method of Compliance WCGS reuses the water in CCL for non-contact cooling within the station. CCL is a 5,090-acre designed impoundment that was constructed as part of the WCGS cooling water system. CCL also supports a fishery, developed, and maintained by WCGS with consultation from KDWPT. This fishery is maintained to reduce fish impingement, maintain power plant efficiency, and provide recreational angling. CCL is the source and receiver of cooling water for the station. Per the KDHE letter dated September 25, 2017, the existing cooling water system meets the definition of a closed-cycle recirculating system in the Final Rule.

As such, Evergys chosen method of compliance at WCGS is IM Option 1.

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WCGS 316(b) Information Rev 1 Entrainment Performance Studies 7.0 Entrainment Performance Studies This chapter provides the following permit application requirements in the Final Rule under

§122.21(r)(7), Entrainment Performance Studies:

The owner or operator of an existing facility must submit any previously conducted studies or studies obtained from other facilities addressing technology efficacy, through-facility entrainment survival, and other entrainment studies.

a. A description of each study, together with underlying data, and a summary of any conclusions or results.

b. Studies conducted at other locations must include an explanation as to why the data from other locations are relevant and representative of conditions at your facility.

c. In the case of studies more than 10 years old, the applicant must explain why the data are still relevant and representative of conditions at the facility and explain how the data should be interpreted using the definition of entrainment at 40 CFR § 125.92(h).

No entrainment performance studies have been conducted at WCGS or at nearby existing facilities.

Therefore, no entrainment data relevant to WCGS are available to discuss or submit.

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WCGS 316(b) Information Rev 1 Operational Status 8.0 OPERATIONAL STATUS This section provides the following permit application requirements in the Final Rule under

§122.21(r)(8), Operational Status:

i. Descriptions of individual unit operating status including age of each unit, capacity utilization (or equivalent) for the previous 5 years, and any major upgrades completed within the last 15 years, including but not limited to boiler replacement, condenser replacement, turbine replacement, or changes to fuel type; ii. Descriptions of completed, approved, or scheduled upgrades and NRC relicensing status of each unit at nuclear facilities; iii. Descriptions of plans or schedules for decommissioning or replacement of units; iv. Descriptions of current and future production schedules at manufacturing facilities; and

v. Descriptions of plans or schedules for any new units planned within the next 5 years.

8.i Unit Operating Status WCGS has one nuclear powered electricity generating unit. This unit became operational in 1985 and is 36 years old at the time of this submittal. Table 8-1 provides the unit capacity utilization for the last 5 years at each unit.

Table 8-1: Unit Capacity Utilization Unit Year Capacity 2016 87.9%

2017 86.5%

2018 90.1%

2019 90.7%

2020 90.9%

Source: Evergy, (2016-2020)

No major upgrades including boiler replacement, condenser replacement, or changes to fuel type have occurred at WCGS over the past fifteen years. Most of the upgrades and changes at WCGS in this period have been minor and did not affect the CWIS.

8.ii Completed, Approved or Scheduled Upgrades Evergy has no additional completed, approved, or scheduled upgrades at WCGS at the time of this submittal.

8.iii Plans or Schedules for Unit Decommissioning or Replacement Evergy has no plans to decommission or replace the existing units at the time of this submittal.

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WCGS 316(b) Information Rev 1 Operational Status 8.iv Current and Future Production Schedules This requirement is not applicable to WCGS.

8.v Plans or Schedules for New Units Evergy has no plans to add new units at WCGS at the time of this submittal.

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WCGS 316(b) Information Rev 1 Operational Status 9.0 Literature Cited Balon E.K. 1981. Additions and amendments to the classification of reproductive styles in fishes.

Environmental Biology of Fishes 6:377-389.

Cross, F. B. and J. T. Collins. 1995. Fishes in Kansas, Second Edition. University of Kansas Natural History Museum. 315pp.

Daiber, F. C., 1953. Notes on the spawning population of the Freshwater Drum (Aplodinotus grunniens Rafinesque) in Western Lake Erie. The American Midland Naturalist 50: 159-171.

Dubuc, R. A., D. R. DeVries. 2002. An exploration of factors influencing Crappie early life history in three Alabama impoundments. Transactions of the American Fisheries Society. 131:476-491.

EA (EA Engineering, Science, and Technology, Inc.). 1988. Wolf Creek Generating Station Operational Phase Environmental Monitoring Program, Final Report. Prepared for WCNOC by EA Engineering, Science, and Technology, Great Plains Regional Office, Lincoln Nebraska.

Ehlinger, T. J. 1997. Male reproductive competition and sex-specific growth patterns in bluegill. North American Journal of Fisheries Management 17:508-515.

Great Plains Nature Center (GPNC). 2021. Unionid Mussels in Kansas. Retrieved June 2021 from https://gpnc.org/mussels/.

Haines, D. E.. 2000. Biological control of Gizzard Shad impingement at a nuclear power plant. Environmental Science and Policy. Vol 3, p 275-281.

Hansen, D. F, 1951. Biology of the White Crappie in Illinois. Natural History Survey Division. Vol. 25 Article 4.

Kansas Department of Wildlife, Parks, and Tourism (KDWPT). 2021. Stop Aquatic Hitch Hickers. Retrieved June 2021 from https://ksoutdoors.com/Fishing/Aquatic-Nuisance-Species/Aquatic-Nuisance-Species-List/Zebra-Mussels.

Kansas Department of Wildlife, Parks, and Tourism (KDWPT). 2021. Threatened and Endangered Wildlife.

Retrieved June 2021 from https://ksoutdoors.com/Services/Threatened-and-Endangered-Wildlife/List-of-all-Kansas-Counties/Coffey.

McDonough, T. A., J. P. Buchanan. 1991. Factors affecting abundance of White Crappies in Chickamauga Reservoir, Tennessee, 1970-1989. North American Journal of Fisheries Management. 11: 513-524.

OBrien, 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: 341-349.

Oplinger, R.W., D. H. Wahl. 2013. Parental influence on the size and age at maturity of Bluegills. Transactions of the American Fisheries Society 142:1067-1074.

Oplinger, R.W., D. H. Wahl. 2015. Egg characteristics and larval growth of bluegill from stunted and non-stunted populations. Journal of Freshwater Ecology, 30:2, 299-309 Overmann, G. 1979. The early life history of the White and Black Crappie in Rough River Lake, Kentucky.

Masters Theses & Specialist Projects. Paper 1799. http://digitalcommons.wku.edu/theses/1799 Page, L.M. and B.M. Burr. (1991). A field guide to freshwater fishes of North America north of Mexico.

Houghton Mifflin Company, Boston. 432 p.

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WCGS 316(b) Information Rev 1 Operational Status Partridge, D. G., D. R. DeVries. 1999. Regulation of growth and mortality in larval Bluegills: implications for juvenile recruitment. Transactions of the American Fisheries Society. 4: 625-638.

Pattillo, M.E., T.E. Czapla, D.M. Nelson, and M.E. Monaco. (1997). Distribution and Abundance of Fishes and Invertebrates in the Gulf of Mexico Estuaries Volume II: Species Life History Summaries. 377 pp.

ELMR Rep. No. 11. Silver Springs, MD: NOAA/NOS Strategic Environmental Assessments Division.

Pflieger, W.L. (1997). The Fishes of Missouri. Jefferson City, MO: Missouri Department of Conservation.

Ross, S.T. (2001). The Inland Fishes of Mississippi. 624 pp. Mississippi Department of Wildlife, Fisheries and Parks. University Press of Mississippi.

Rypel, A.L., D.R. Bayne, and J.B. Mitchell. (2006). Growth of Freshwater Drum from Lotic and Lentic Habitats in Alabama. Transactions of the American Fisheries Society, 135:987-997.

Schramm H.L, Jr. (2004). Status and Management of Mississippi River Fisheries. In R. Welcomme and T. Petr (Eds.), Proceedings of the Second International Symposium on the Management of Large Rivers for Fisheries (pp 301-333). Volume 1. RAP Publication 2004/16. Bangkok, Thailand: FAO Regional Office for Asia and the Pacific.

Siefert, R. E. 1968. Reproductive behavior, incubation, and mortality of eggs, and postlarval food selection in the White Crappie. Transactions of the American Fisheries Society 97: 252-259 Simon, T.P. (1999). Assessment of Balons reproductive guilds with application to Midwestern North American Freshwater Fishes, pp.97-121. In: Simon, T.L. (ed.). Assessing the sustainability and biological integrity of water resources using fish communities. CRC Press. Boca Raton, Florida. 671 pp.

Sissenwine, M. P., M. J. Fogarty, and W. J. Overholtz. 1988. Some fisheries management implications of recruitment variability. Pages 129-152 in J. A. Gulland, editor: Fish populations dynamics, second edition. Wiley, New York.

Smith, P.W. (2002). The Fishes of Illinois. Urbana and Chicago, IL: University of Illinois Press.

Strauss, R. E. 1979. Reliability estimates for Ivlevs electivity index, the forage ratio, and a proposed linear index of food selection. Transactions of the American Fisheries Society 108:344-352.

Sullivan, C. L., K. D. Koupal, W. W. Hoback, B. C. Peterson, C.W. Schoenebeck. 2012 Food habits and abundance of larval freshwater drum in a South Central Nebraska irrigation reservoir. Journal of Freshwater Ecology. 27:1, 111-121.

Swedberg, D.V., C.H. Walburg. (1970). Spawning and Early Life History of Freshwater Drum in Lewis and Clark Lake, Missouri River. Transactions of the American Fisheries Society 99:560-570.

United States Environmental Protection Agency (EPA). (2001, November). Phase INew Facilities, Technical Development Document for the Final Regulations Addressing Cooling Water Intake Structures for New Facilities. Office of Water. EPA-821-R-01-036. U.S. Washington, D.C.:

Environmental Protection Agency.

United States Environmental Protection Agency (EPA). (2014). National Pollutant Discharge Elimination SystemFinal Regulations to Establish Requirements for Cooling Water Intake Structures at Existing Facilities and Amend Requirements at Phase I Facilities; Final Rule. 40 CFR Parts 122 and 125. August 15, 2014. EPA-HQ-OW-2008-0667, FRL-9817-3.

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WCGS 316(b) Information Rev 1 Operational Status United States Fish and Wildlife Service (USFWS). 2021 Information for Planning and Consultation. Coffey County, Kansas. Retrieved June 2021 from https://ecos.fws.gov/ipac/location/TNHU2RZZYFC4XGMBTTCT2ACREU/resources.

United States Fish and Wildlife Service (USFWS). (2018). Information for Planning Conservation (IPaC).

Retrieved online April 2018 at:

https://ecos.fws.gov/ipac/project/4TEYWRHIY5EEZNQD46QUK7QJH4/resources.

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APPENDIX A ENGINEERING DRAWINGS

ML23045A195

Text

Subject:

Enclosure:

1.0 INTRODUCTION

1.0 INTRODUCTION

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