ML13196A186

Email from B. Balsam, NRR to J. Crocker, NOAA on Pilgrim: Nrc'S Complete Responses to 4-9-12 Nmfs Questions

ML13196A186
Person / Time
Site:	Pilgrim
Issue date:	04/12/2012
From:	Balsam B A Office of Nuclear Reactor Regulation
To:	Crocker J G US Dept of Commerce, National Oceanographic and Atmospheric Administration
References
FOIA/PA-2013-0135
Download: ML13196A186 (6)

Text

Craver, PattiFrom:Sent:To:Cc:

Subject:

Attachments:

Balsam, BrianaThursday, April 1 2012 12:51 PMjulie.crocker@nmfs.gov Logan, Dennis; Susco, Jeremy; Smith, Maxwell; jeganl@entergy.com Pilgrim:

NRC's complete responses to 4-9-12 NMFS questions NRC Responses to NMFS 4-9-12 Questions-Complete 4-12-12.pdf Julie,I attached the NRC's completed responses to the questions on Pilgrim that you sent in your April 9 email tofollow-up on our partial response dated April 10.I will also be forwarding several zip files containing the documents referenced in the responses in subsequent emails. I tried to send them all as one zip folder, but it seems as if my agency's email attachment size limit is abit higher than yours-the last email I was able to send, but it came back undeliverable.

All of the references should also be publically available in our ADAMS system also, and I have included the accession number foreach in the attached responses, so that would be another way for you to access those documents if emaildoesn't work.BrianaBriana A. BalsamBiologist Division of License RenewalOffice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-1042 briana.balsam Onrc.goV.Blis,1 NRC Responses to NMFS's Questions on PilgrimApril 12, 2012Prepared by:Briana BalsamEnvrionmental Review BranchDivision of License RenewalNote: A number of answers refer to the following

studies, which are being provided to NMFSwith these responses:

1. [EG&G] Global Environmental and Ocean Services.

1995. Pilgrim Nuclear StationCooling Water Discharge Bottom Temperature Study, August 1994. Final Report toBoston Edison Company,

Plymouth, Massachusetts.

June 1995. 116 p. ADAMS No.ML061450065.

2. ENSR Corporation.

2000. 316 Demonstration Report for Pilgrim Buclear Power Station,Redacted Version.

Prepared for Entergy Nuclear Generation Company.

March 2000.357 p. ADAMS No. ML061390357.

3. Hartwell AD, Mogolesko FJ. Three-dimensional field surveys of thermal plumes frombackwashing operations at a coastal power plant site in Massachusetts.

10 p. ADAMSNo. ML061420520.

4. Normandeau Associates, Inc. 1977. Thermal Studies of Backwashing Operations atPilgrim Station During July 1977. Prepared for Boston Edison Company, Boston,Massachusetts.

82 p. ADAMS No. ML061560291.

5. Normandeau Associates, Inc. 2011. Ichthyoplankton Entrainment Monitoring at PilgrimNuclear Power Station, January-December 2010. Submitted to Entergy Nuclear.April 27, 2011. 323 p.6. Normandeau Associates, Inc. 2011. Impingement of Organisms on the Intake Screens atPilgrim Nuclear Power Station, January -December 2010. Submitted to EntergyNuclear.

April 22, 2011. 35 p.1. Are there any In-water acoustic Impacts of the Pilgrim facility?

Have any in-watermeasurements of underwater noise been taken here or at similar plants?The NRC is unaware of any studies of underwater noise at Pilgrim or any other nuclear facilityor evidence that nuclear facilities might cause elevated underground noise levels.The EIS states that "noise has not been found to be a problem at operating plants and isnot expected to be a problem at any plant during the license renewal term. The staff hasnot identified any new and significant information during its independent review of thePNPS ER, the site visit, the scoping process, evaluation of other available information, or consideration of public comments.

Therefore, the staff concludes that there would be noimpacts of noise during the license renewal term beyond those discussed in the GELS."This statement makes it unclear whether there is underwater noise associated withPilgrim, but it would not rise to the level of being a concern, or whether there is notactually any underwater noise associated with operations.

Could you clarify?NRC evaluates above-ground noise as it relates to humans. The text that you reference in thePilgrim supplemental environmental impact statement (SEIS) is based on Section 4.3.7 of thegeneric environmental impact statement (GElS), which discusses noise impacts as a humanhealth issue. For issues that the NRC concluded generically in the GELS, the NRC does notrepeat the analysis in the SEIS. You can access the discussion of noise in the GElS on theNRC's public website:

http://www.nrc.,Qov/readin-g-rm/doc-collections/nuregQs/staff/sri437/.

During the NRC's review of Pilgrim, the staff did not find any new and significant information thatwould call into question the GEIS's conclusion, which is SMALL for all nuclear facilities.

Click on"Volume 1, Main Report."2. The dimensions of the thermal plume appear to be described in terms of delta T. Isthe IC delta T the extent change that is detectable?

We are trying to use the size of thethermal plume as part of the description of the action area.Both the surface and benthic thermal plume have been characterized in 1 0C increments fromA 10C through A 90C. The 2000 316 Demonstration characterizes the thermal plume inSection 5.1. Several tables beginning on page 5-45 in this report also provide the plume area,depth, and volume at both the surface and bottom:Table 5.1-1. Measured Surface Plume Area, Depth, And Volume Enlcosed by Various Delta TIsotherms During High Tide-MIT

Studies, 1973.Table 5.1-2. Model Predicted Plume Area, Measured Depth, and Corresponding VolumeEnclosed by Various Delta T Isotherms During High Tide-MIT

Studies, 1973.Table 5.1-3. Measured Benthic Plume Dimensions (EG&G, 1995)Two previous reports also studied the Pilgrim thermal plume. A 1974 study by Massachusetts Institute of Technology (MIT) studied the thermal plume at the surface, and a 1995 study byGlobal Environmental and Ocean Services (EG&G) studied the thermal plume at the bottom.Unfortunately, I cannot locate a copy of the MIT study, but this study is summarized in Section5.1 of the 2000 316 Demonstration.

The EG&G study is being provided with these responses.

Section 4 of the 1995 EG&G report summarizes the findings of the study and characterizes thebottom thermal plume. Figures 22, 23, and 25 in this report graphically display the bottomthermal plume under various conditions.

3. Section 4.1.3 discusses the 1974 thermal plume study that characterized the surfaceplume. It states, "For example, water with a delta T of 3C (37.4F) covered approximately 216 acres (ac) in August when the ambient temperature was 17.OC (62.6F),

but only 14 acin November when the ambient temperature was 8.5C (47.3F)."

The first part of that sentence is confusing, do you mean that the 216 acre area had water that was 3C greaterthan ambient or 37.4F greater than ambient or something else??The sentence you reference contains a temperature conversion error. The corrected sentenceshould read:For example, water with a delta T of 3°C (delta T of 5. 40F 3 ) covered approximately 216 acres (ac) in August when the ambient temperature was 17.0°C (62.67F),

but only 14 ac inNovember when the ambient temperature was 8.5°C (47.37F).

Also, can you provide the description of the size of the area that had a delta T of IC atthe surface (later text in the EIS describes that area for the bottom)?The sections and tables of the 316 Demonstration and EG&G study mentioned on the previouspage provide this description.

4. I also have a question about this statement

-- "At the bottom, similar to the surface, thesmallest temperature increment measured (1C or 33.8F) covered the largest area (up to1.2 ac), and water with higher temperatures relative to ambient covered much smallerareas. For example, the highest delta T measured, 9C (48.2F),

covered less than 0.13 acof the bottom" (in 4.1.3) Did that heated area (1.2 acres) have temperatures that were ICabove ambient or 33.8F above ambient, because those would be two very different scenariosl The 1.2-ac area had temperatures 1°C (1.80F) above ambient temperatures.

It appears that thetemperature units were converted assuming a temperature rather than a change in temperature.

5. Thermal backwash

-Can you describe the size of the plume? The EIS says it is thinand only lasts a few hours but can you describe how far from the discharge canal itextends and its temperature profile (e.g., the size of area with delta T of 3C, 1C etc.)During July 1977, a study by Normandeau characterized the thermal plume created frombackwash (which Pilgrim conducts at 1- to 2-week intervals).

Section 6 of the Normandeau study provides a description of the backwash thermal plume and summarizes the study'sfindings.

In a summary of the 1977 Normandeau study (Hartwell and Mogolesko 1977) characterize thebackwash thermal plume as follows:These surveys showed that backwashing operations at Pilgrim Station form arelatively thin thermal plume averaging 3 to 5 ft (0.9 to 1.5 m) thick. Highertemperatures were observed during the low-water backwashing than duringthe high-water backwashing, presumably due to lesser amounts of available entrainment water. During the first survey the thermal plume persisted forabout 2 to 2.5 hrs before being completely dissipated.

The second weekendmore heat treatment was required due to accumulated biofouling and thethermal plume persisted for almost 4 hrs. Initial momentum effects of the backwashing flows apparently tend to carry the thermal plume northward andalong the outer breakwater, with little tendency for warmed water to impingethe shoreline in front of Unit 1. During both surveys local winds also appearedto play a role in pushing the thermal plume seaward.

Finally, observed near-bottom ambient temperature variations suggest that some water from theplant discharge can recirculate into the intake area.3. Have there been any jellyfish (leatherback turtle prey) impinged or entrained atPilgrim?

I do not see any listed on table 4-3 on the EIS but it is not clear to me if thattable includes invertebrates.

Is there a list of the invertebrates that have been impingedor entrained?

If it is in the EIS I am having trouble finding it.The 2010 Normandeau impingement report indicates that Pilgrim impinged 744 jellyfish (PhylumCnidaria) in 1981 and 940 jellyfish in 1983 based on extrapolated totals (see Table 9). However,no jellyfish have appeared in impingement samples since 1983.4. Zooplankton

-As you know, right whales feed on copepods (mostly Calanus spp.).The EIS states, "Entrainment of phytoplankton and zooplankton has not been found tobe a problem at operating nuclear power plants and is not expected to be a problemduring the license renewal term." Does this mean that no zooplankton is entrained atPilgrim?No, this does not mean that no zooplankton are entrained at Pilgrim.

This statement refers tothe fact that the NRC considers the entrainment of phytoplankton and zooplankton is a genericlicense renewal issue, so the analysis appears in the GElS rather than the individuals SEISs (asdescribed above for noise). Section 4.2.2.1.1 of the GElS discusses entrainment ofphytoplankton and zooplankton in more detail. The GElS concludes that this issue would haveSMALL impacts because there is no evidence of reductions of populations of phytoplankton orzooplankton at nuclear plants.And if it Is entrained, are there estimates of the annual loss?The Pilgrim entrainment monitoring program only monitors for ichthyoplankton.

The NRC is notaware of any studies that estimate annual losses of zooplankton at Pilgrim.Also, the EIS refers to studies to characterize the zooplankton in the area conducted inthe 1970s (2.2.5.3.3).

Have there been similar studies carried out since Pilgrim becameoperational?

The NRC staff is not aware of any studies on zooplankton beyond those referenced in the SEIS.Could you clarify what evidence was reviewed to make this determination....

"However, based upon the review conducted by the NRC staff, there is no evidence that theoperation of the PNPS cooling system has had an impact on phytoplankton orzooplankton communities, or any resultant effects on the aquatic food web, in Cape CodBay." (from 4.8.1 Cumulative Impacts)

This statement refers back to the conclusion in Section 4.1 of the SEIS, which is based on theconclusion in Section 4.2.2.1.1 of the GElS and the lack of new and significant information onthis issue that would call into question whether the GElS conclusion should apply to Pilgrim.5. Crabs -The EIS states that cancer crabs (Cancer spp.) were the second mostimpinged invertebrate.

Can you provide information on the number of crabs impingedper year?Pilgrim impinged a mean of 273 cancer crabs (Cancer spp.) per year from 1980 through 2010based on extrapolated annual totals (see Table 9 in the 2010 Normandeau impingement monitoring report).

However, impingement has varied widely annually.

Pilgrim impinged cancercrabs in only 2 year from 1980 to 1999, but from 2000 to 2010, Pilgrim impinged cancer crabs 9out of the 10 years.6. Atlantic herring:

The EIS states, "and based on the 2005 Pilgrim monitoring data, theloss to the stock due to entrainment by PNPS appears to be significantly less than Ipercent (Normandeau 2006a)."

Was an actual percentage provided in Normandeau 2006a?Yes, the referenced Normandeau report provided a percentage.

The most recent 2010Normandeau ichthyoplankton entrainment report indicates that the 2010 equivalent adult valueresulting from Pilgrim entrainment and impingement would account for about 0.01 percent of thespawning stock by biomass (see pages 84-86 of the report).For more information on Atlantic herring impingement, refer to Figure 4 in the 2010Normandeau impingement monitoring report, which depicts the extrapolated totals of Atlanticherring impinged per year from 1980 through 2010 and Table 3, which provides the extrapolated total number of Atlantic herring impinged each year from 1980 to 2010.7. sand lance -Has there been an assessment of the effects of removal of sand lance likethere is for some of the other fish species (i.e., less than 1% of the population or similartypes of conclusions?).

No, Normandeau did not calculate such a percentage for sand lance. Page 34 of the 2010Normandeau ichthyoplankton entrainment report notes that "sand lance have little to nocommercial or recreational value, and therefore abundance data are unavailable to compare tothe entrainment estimates."

However, the 2010 Normandeau ichthyoplankton entrainment reportincludes entrainment numbers for the sand lance.The 2010 Normandeau impingement monitoring report also includes information on sand lance.This report indicates that American sand lance (Ammodytes americanus) is impinged in onlysome years and at very low numbers (see Table 3). Other species in the genus Ammodytes aremore commonly impinged and also appear in Table 3.