ML12244A570

Enclosure 3: Response to 04/16/2010 Letter Re License Renewal Process

ML12244A570
Person / Time
Site:	Callaway
Issue date:	06/14/2010
From:	Catherine Scott US Dept of Interior, Fish & Wildlife Service
To:	Lynn K Office of Nuclear Reactor Regulation, AmerenUE
Shared Package
ML122440687	List: ML12244A568 ML12244A569 ML12244A570 ML12244A571 ML12244A572 ML12244A574 ULNRC-05902, Callaway, Unit 1 - Enclosure 1: Responses to Environmental RAI Set 2 ULNRC-05902, Callaway, Unit 1, Enclosure 5: Telecon Record Re Pallid Sturgeon in Missouri River ULNRC-05902, Callaway, Unit 1, Enclosure 7: Preliminary Jurisdictional Wetland & Stream Determination Report for the Callaway Nuclear Plant ULNRC-05902, Enclosure 6: Ameren Transmission Vegetation Management Program
References
ULNRC-05902
Download: ML12244A570 (6)

Text

Kenneth W. Lynn United States Department of the Interior FISH AND WILDLIFE SERVICE Columbia Ecological Services Field Office 101 Park DeVille Drive, Suite A Columbia, Missouri 65203-0057 Phone: (573) 234-2132 Fax: (573) 234-2181 June 14,2010 Consulting Environmental Scientist AmerenUE PO Box 66149 St. Louis, Missouri 63166-6149

Dear Mr. Lynn:

ULNRC-05902 This is in response to your April16, 2010, letter pertaining to the Callaway Unit !license renewal process. In late Fall2011, AmerenUE plans to apply to the U.S. Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Callaway Unit 1 in Callaway County, Missouri. Your letter specifically requested information from the U.S. Fish and Wildlife Service (Service) pertaining to species listed under the Endangered Species Act that may occur on the project site. This information will be used by NRC and AmerenUE in the environmental assessment of the license renewal, including consultation under section 7(a)(2) of the Endangered Species Act.

The Callaway Unit 1 site encompasses 7,350 acres of which 512 acres is occupied by the power generating facilities and associated infrastructure. The Missouri Department of Conservation manages 6,300 acres of the site as the Reform Conservation Area. The site is predominately rural lands composed of deciduous forests, grassland/pasture, and cropland.

During the term of the license renewal, there are no plans to expand beyond existing facilities and no structural modifications or refurbishment activities have been identified.

Maintenance activities would be restricted to previously disturbed areas.

We have reviewed the information in your letter relating to threatened and endangered species. Based on this information you state that continued operation of the facility under the term of the license renewal is unlikely to adversely affect any threatened or endangered species. The Service has no major concerns with the effects of continued operation of the Callaway Unit 1 on federally listed species and concurs with your assessment that adverse effects are unlikely to occur.

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We appreciate the opportunity to review this action. Please contact us if you have any questions or require additional assistance.

Field Supervisor 0 :\\STAFF Folders\\Scott\\Letters\\AmerenUE.CallawayUniti.TESpeciesResponse.doc 2

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Kenneth W. Lynn Missouri Department of Conservation Heritage Review R~port April 26, 2010- Page 1 d4 Polley Coordination Unit P. O.Box180 Jefferson City, MO 65102 heritage.revieW@mdc.mo.aov 573-522-4115 X 3367 One Ameren Plaza 1901 Chouteau Avenue PO Box66149 St. Louis, MO 63166 County: I t;auawa; I

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?al~~~!="~~~ 1 License Renewal have been located close to and'or potentially affec1ed by file piOpOSfd project Ofl.&lte verifcBIIon Is the responslbllty d the prqea Hetttage I8COids 118t8ldenllfed at sane dlie 8lld localioll. Tlis t8pOit consldets I8COt'ds near but not necessatfly at the~

site. Animas

~"'*:U-2~!0 by. SMnnon c-move and, owrt/me, so do pant conrnunities.. To say 1hn Is a I9CCXrf does not ITI68n the ~Bt Is stJJI thete. To say that 1here Is no I9COITf' does not mean a protected species wll not be enoounteted. The$e reconJs only ptrNide ooe f8felence 8l1d <<her Information (e.g. Wflll811d or soils maps, OIK/te Inspections or SlllftYS) shotid be considered. Look for 8dcftlonallnfotmatlon about the~

and h8tittt needs of I8CMts listed In orcter to avoid or rririmize inpacts. M019lnfotmation mav be found It www.mdc.mo. qo_yff1if!Jjs/~ and Level 3 and level 2 issues, plant site - Records of federal-listed or state-listed species or critical habitats near the plant site:

Heritage records identify no federal or state designated wildlife preserves, wilderness areas or critical habitats, or, eradangered-llst species records within the public land survey sections indicatea on the map at right.

The Missouri River is home to a~oumber of spepies of state and federal concern, induding paiUd sturgeon ( Scaphirhynchus a/bus, federal/state endangered), lake sturgeon (Acipenser fu/vescfins, state enda~red), and others. Lake sturgeon have been recorded near the cooling plant ouftll

};~> Pallid sturgeon are big ~ver fish that range widely in the Mississippi and Missouri River system (inCluding parts of major tributaries). Much is unknown about the habitat needs and range of-the species, so any project that modifies big river habitat or impacts water quality should consider the possible impact to pallid sturgeon populations. See http://mdc.mo.gov/124 for best management recommendations.

};~> The river's banks and floodplain are places one might encounter1gr.ay bats (Myotis grisescens, federal & state endangered),lli1diana*bats:'(Myoiis ~a/is, federal & state endangered), bald eagles (Hali~eetbs feticoceph'iilu1, ~t6 Anrh:annAMri\\ and others. althouah there are no soecific records within a mile of Prepared by Shannon Cave, April 26. 2010, Lynn_ Callaway_Ameren License Renewal. doc, page 1 of 4 21

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any of these sections.

~ Terrestrial projects that manage construction and indude operation plans to avoid runoff of sediment or pollutants are unlikely to affect the aquatic species. Projects that place fill in or discharge water to the river are subject to federal permits, and strict observance of conditions required in those permits is important to minimize risk of damage to endangered species.

);~> Reform Conservation Area and Hams Prairie Access are in or near the project zone.

FEDERAL UST S118Cieslhablals are DfOiected under the Federal E r SDecies M. Consult with U.S. Fish and Melle Setvte, 101 Perl< Deville OM Suite A, QUnbie, Missolli 65203-0007; 573-234-2132 Records along powerline corridors:

Species Common Name Federal State State location/County Quadrangle Twp/Rng Section last Status Status Rank seen Leptodea leptoclon Scaleshell E

E 51 Gasconade River T44N R06W 29 2005 Lampsilis abrupta Pink Mucket E

~ E 52 Gasconade River T44N R06W 29 1994 Cumberlandia monodonta 5pectaclecase c

S3 Gasconade River T44N R06W 29 1994 Cumberlandia monodonta Spectaclecase c

S3 Gasconade Riyer T44N R06W 29 2005 Eiliptio crassldens Elephantear J

E Sl Gasconade River T44N R06W 29 1994 Fusconaia ebena Ebonyshetl E

Sl Gasconade RiVer

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T44N R06W 29 1994 ligumia recta Black Sandshell 52 Gasconade River -

T44N R06W 29 1994 Ugumla recta Black Sand shell S2 Gasconade River T44N R06W 29 2005 Nothocalais cuspidata Prairie Dandelion S2 Mont~omery Montg_omery City T48N R06W 36 2006 Hlodon tergisus Mooneye S3 Gasconade River T45N Rf17W 6 1989 Macrhybo_psis meeki Sicklefin Chub J S3 Missouri River

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T45N ROSW 1 2003 Macrhybopsis meeki 5icklefin Chub 53 Missouri River

'A T45N ROSW 1 2003 Macrhybopsis meekl Sicklefin Chub S3 Missouri RiVer T45N R08W 1 2003 Macrhybopsis meeki Sicklefin Chub i

S3 Missouri River T45N R07W 6 2003 Malvastrum hispidum Yellow False Mallow i

53 Montsomery

' Montgomery City T48N R06W 36 2007 Floerkea proserpinacoides False Mermaid su Montaomerv Montgomery City T48N R06W 34 2000 Community Limestone glade S2 Montgomery

~Mont~omery City T48N R06W 36 1999 Community Wet-mesic bottomland forest 52 Montgomery..,

Montgomery City T48N R06W 33 2000 Community Dry-mesic limestone/dolomite woodland S3 Montgomery,

Montgomery City T48N R06W 36 1999 Community Mesic limestone/dolomite forest S3 Callaway Mokane East T46N R08W 36 1999 Federal slatns is tede4 E ~

r (lbreateMI) or C (Candidate~ rtplaled by tile &dalgered Species Act I -

S~ite Status is eitber E (eadugnl) or blank. rse ud !Ui~t of all wildlife species are regwlated.in lhe lfN!!pri fi'dile flllie willl elda,lgeret! spe~;ies Sllbjectto specialllllrktius.

State Rank codes: Sl (sitically illperiled); S2 Q11periled) or S3 (VIIneRble). 1\\ese m tr.ded due to their mity and saijettto ~en! nptl~

in llle fildlie Code.

Prepared by Shannon Cave. April 26, 2010, Lynn_ Callaway_Ameren License Renewal. doc, page 2 of 4

Level1 recommendations: Unlisted species/habitats tracked due to their rarity, but not listed as endangered or threatened or subject to special regulations.

The following records occur in the section outlined above:

$pedes Common Name State Rank Twp/Rnc Section Last seen Notropis heterolepis Blacknose Shiner 52 T46N R07W 19 1995 Slale luk eodes: SJ (l)itically imperiled): S2 ~~~periled) or S3 (VIiltenble~ 1\\ese are !racked die Ill their rarity Dolomite glade 53 T46N ROBW 25 1999 ud Wjeclto aeamJ regalalions ia tle Vddlfe Code.

Mesic limestone/dolomite forest 53 T46N ROBW 36 1999 The s11te lraclcs many species not listed as endBnger9d, but sutrlciefitt l8f8 or challenged thBt special etrDtts to COOS8IV9 them may be ;,ponant to their sUIVNal tlfld to BVOid futurelisllng.

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consetV800n d them l encounteted. The Missoutl 'Midlif9 aide Mllacls all wildlle spec;itJs 81Kll irclJdes no lliecid for thes8.

Ongoing coordination: This review provides a "snapshot" of natural heritage concerns as we have them recorded today in the vicinity of the plant premises. New species-related concerns may arise i!.S the project matures, and there may be other conservation issues unrelated to at-risk species. Ongoing coordination of environmental issues should be conducted through Doyle Brown in MDC's Policy Coorf!ination Unit (Doyle.Brown@mdc.mo.gov, 573-522-4115 ext. 3355). Issues that may affect public use of the Reform Conseryation Area (managed under lease from Ameren) should be coordinated with area manager Jeff Demand (Jeff.Demand@mdc.mo.aov. 573-254-3330).

rl General recommendations related to this project or site, or based on lnfonnatlo11about the historic range of species (unrelated to any specific heritage records):

> Bald eagles (Ha/iaeetus leucocephiilus) may nest near streams or water bodies in the projectarea. Nests are large and fair1y easy to identify. While no longer listed *~s endangered, eagles continue to be protected by the feC:ieral,govemment under the Bald and Golden Eagle Protection Act. W'Qri< managers should be alert for nesting areas within 1500 meteFs of project activities, and follow federal guidelines at httQ:/Iwww.fws.gov/migrato[Ybirds/issues/BaldEagle/NationaiBaldEagleMa'hagementGuidelines.~f if eagle nests are seen. See also MDC's best management recommendations at httQ://mdc.mo.gov/87.

> Callaway County has kn,9Wn,Karst geologic features (e.g. caves, springs, ancrsinkholes, all characterized by subterranean water movement). Few karst*features are recordEkt in heritage records, and ones.not noted here may be encountered at the project site or affected by the projeCt. **Cave fauna (many of which are species of conservation concern) are influenced by changes to water quality, so check your project site1for any karst features and make every effortto'prolect groundwater in the project area. See httQ://mdc.mo.gov/nathis/caves/manag construc.htm for best management infonna~on.

> Gray bats (Myot/s grisescens, federally and state listed "endangered") are likely to occur in the project area, as they forage over streams, rivers, and reservoirs in this part of Missouri. Avoid entry or disturbance of any cave inhabited by gray bats and when possible retain forest vegetation along the stream and from the gray bat cave opening to the stream. See httQ://mdc.mo.gov/104 for best management recommendations.

> The project should be managed to minimize erosion and sediment~tibntrunotfto nearby streams and lakes, induding adherence to any *aean Water Permlr conditions. Revegetate areas in which the natural cover is disturbed to minimize erosion using native

_plant species compatible with the local landscape and wildlife needs. Use silt fences and/or vegetative filter strips to buffer streams Prepared by Shannon Cave, April 26, 2010, Lynn_Callaway_Ameren License Renewal.doc. page 3 of 4

and drainages, and monitor those after rain events and until a well-rooted ground cover is reestablished.

.> Upstream from the powerline crossing point, the Gasconade River is known to indude or to provide habitat suitable for Ozark hellbenders ( cryptobranchus al/eganiensis bishop/, state-listed endangered and candidates for federal listing) or eastern hellbenders ( ayptobranchus al/eganiensls al/eganiensis, state-listed endangered). Hellbenders are strictly aquatic salamanders whose well-being is dependent on high-quality water systems with constant levels of dissolved oxygen, temperature, and flow. These unusual animals are in serious decline, and information about best-management is available at http://www.mdc.mo.gov/documents/nathis/endangered/hellbender.odf. Activities that change physical characteristics of rivers and streams'( especially Introducing silt loads or destabilizing gravel bars) or alter the flow of water should be avoided.

> Streams in the area should be protected from sail erosion, water pollution and i,n-stream activities that modify or diminish aquatic habi¥~ts :- Best management recommendations relating to streams and rivers may be found-at http://mdc.mo.gov/79.

> Invasive exotic species are a significant lssue.for fish, wildlife and agriculture in Missouri.

There is a 1999 record of purple loosestrife (Lythrum sal/carla) In Mollie Dozier Ct:tute,.so the species could be encountered, especially in wetland sites, within the project boundaries.

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_..r This is only one of several dangerous.invasives of concern and it should be eliminated If

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encountered (see http://mdc.mo.gov/9633 and

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_. U http://mdc.mo.gov/nathis/plantpage/flora/purple/ for more information). Seeds, eggs, and

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r larvae of many invasives may be moved to new sites on boats or construction equipment, so inspect and dean equipment thoroughly before moving between project sites.

• Remove any mud, soil, trastJ~ plants or animals from equipment before leaving any water bOdy or work area.

• Drain water from boats and-machinery that has operated in water, checking motor cavities, live-well, bilge and transom wells, tracks, buckets, and anyrother water r:eservoirs.

• When possible, wash andl'inse equipment thoroughly with hard spray or*HOT water (~104° F, typically available at do-it-yourself carwash sites), and dry in th8 hot sun before using again.

Prepared by Shannon Cave, Apri/26, 2010, Lynn_Callaway_Ameren License Renewal. doc, page 4 of 4

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