, , , , , , , , , , , , , , , , , , , , , , ,

Generic Environmental Impact Statement for Braidwood Nuclear Power Station – Comment by 12 May 11.59 pm Eastern Time.
Exelon Generation Company, LLC; Braidwood Station, Units 1 and 2; Draft Supplemental Generic Environmental Impact Statement” We encourage you to comment something on this and all dockets. One or two sentences is fine. It can be anonymous. Consider it your right to vote: http://www.regulations.gov/#!docketDetail;D=NRC-2013-0169
Comment: http://www.regulations.gov/#!documentDetail;D=NRC-2013-0169-0014
Draft Report for comment: http://www.regulations.gov/contentStreamer?documentId=NRC-2013-0169-0015&disposition=attachment&contentType=pdf
Chickadee deformed beak USGS
Chickadee deformed beak USGS
This chickadee is not from Braidwood. However, this Environmental Impact Statement does not examine the health of wildlife, nor the amounts of radionuclides in their tissues, but only species diversity, and sometimes abundance. In some instances there has been no followup since the Braidwood Nuclear Power Station opened. Braidwood is an old coal mining area. So, it wasn’t pristine wilderness before the reactor. Even so, the numbers and diversity of wildlife have tended to decline, and there has been a shift to more resistant species. This nuclear reactor only opened in 1988.

From: “Exelon Generation Company, LLC; Braidwood Station, Units 1 and 2; Draft Supplemental Generic Environmental Impact Statement

3.7 Aquatic Resources

The aquatic communities of interest for the Braidwood site occur in the Kankakee River and in the site’s artificial cooling pond. The Kankakee River lies 5 mi (8 km) east of the site. It supplies makeup water to Braidwood’s cooling system and receives cooling system blowdown.

The cooling pond is the site’s main source of cooling water and ultimate heat sink. Section 3.1.3 describes the cooling system in detail, and Section 3.5.1 describes the surface water characteristics of Kankakee River and the cooling pond… The Kankakee River basin supports a large diversity of aquatic biota, including 84 species of fish, 37 mussels, 14 crustaceans, and a variety of aquatic macroinvertebrates…“[Note that this is the entire basin, we will see what is near the nuclear reactor, below.]

A number of impingement and entrainment studies have been conducted to determine the impacts of Braidwood’s cooling system on Kankakee River aquatic organisms.
[…] Kankakee River

Phytoplankton. Phytoplankton are microscopic floating photosynthetic organisms that form one base of aquatic food webs by producing biomass from inorganic compounds. As primary producers, phytoplankton play key ecosystem roles in the distribution, transfer, and recycling of nutrients and minerals
The FES-O (NRC 1984) notes that during the 1974-1975 monitoring period, samples yielded five phyla and 200 species of phytoplankton. Most species belonged to the phyla Bacillariophyta (diatoms) or Chlorophyta (green algae). Diatoms again dominated the phytoplankton community in both Kankakee River and Horse Creek samples. The NRC staff is not aware of any additional phytoplankton surveys that may have been conducted in the vicinity of Braidwood since the plant began operating in 1988
” [Since they haven’t tested since reactor opening, they cannot know the impact of the Nuclear Power Station.]

Periphyton. Periphyton includes a mixture of algae, cyanobacteria, heterotrophic microbes, and detritus that attach to submerged surfaces. Like phytoplankton, periphyton are primary producers and provide a source of nutrients to many bottom-feeding organisms
The FES-O (NRC 1984) notes that diatoms dominated each of these sample periods and that over 400 diatom species were identified across the 11 sample sites. The NRC staff is not aware of any additional periphyton surveys that may have been conducted in the vicinity of Braidwood since the plant began operating in 1988
The NRC staff is not aware of any additional zooplankton surveys that may have been conducted in the vicinity of Braidwood since the plant began operating in 1988
” [Once again, no follow through testing of impacts]

Benthic Macroinvertebrates. Benthic macroinvertebrates include aquatic annelids (aquatic 41 worms, flatworms, and leeches), mollusks, crustaceans, and insect larvae that inhabit aquatic sediments. They accelerate detrital decomposition and nutrient cycling, and serve as a food source for fish and other aquatic biota….
Eleven taxa of Ephemeroptera, Plecoptera, and Trichoptera (EPT) were identified
EA Engineering (2012) concluded that the benthic community had remained similar in the 32 years between the 1979 and 2011 samples. Species richness and density was similar for individual locations across the two sample years, and in both years, taxa that tend to be less tolerant of environmental stressors were generally more abundant at upstream locations, while tolerant species were more abundant downstream. Both surveys attributed these longitudinal differences to differences in substrate composition at upstream and downstream locations.

The largest difference between the two studies appears to be the EPT richness. EPT taxa are generally considered to be intolerant of environmental stress. Thus, a relatively high EPT richness typically represents a high quality benthic community. In 1979, 29 EPT taxa were collected, while in 2011, only 11 EPT taxa were collected. The change in EPT richness appears to contradict EA Engineering’s (2012) conclusions because it signals a possible degradation in water quality. Section 3.5.1 addresses surface water quality…” [This is a 62% decline over 32 years; while they try to blame mercury, the timeline suggests it is more likely radionuclides and hot water.]

Fish. Preoperational fish monitoring began in 1972. However, the only available information is on the 1974-1975 and 1981-1982 sample years. The FES-O (NRC 1984) indicates that during this period, 38 species of fish were collected from the Kankakee River, and 46 species were collected from both the Kankakee River and Horse Creek at the 11 sampling survey locations listed in Table 3–8… Since 1977, 84 species in 19 families have been collected from the Kankakee River and Horse Creek (HDR 2013b). In the past 5 data years (2009 through 2013), HDR (2014) has collected 69 species of fish in 15 families… [This isn’t clear but they seem to mean that species of fish declined from 84 to 69.]
The appearance of an increasing number of walleye is likely due to IDNR’s recent stocking efforts in the Kankakee River (HDR 2013b). Walleye steadily increased in numbers over the 2009-2013 period from 8 individuals (0.5 percent of individuals collected) in 2009 to 50 individuals (2.2 percent) in 2013.” Yes, adding fish tends to increase their numbers, unless they swim away. Also, they need to use upstream as the control and compare to downstream exposure to the hot and radioactive water going into the river.

Historically, the Kankakee River aquatic community in the vicinity of Braidwood was dominated by insectivores and piscivores of intermediate pollution tolerance (as defined in Barbour et al. (1999)). In recent years, insectivores and omnivores of intermediate to high pollution tolerance have dominated the community. Rock bass and white crappie, which were prevalent piscivores in preoperational monitoring sampling, only accounted for 1.8 and 0.3 percent of individuals collected from 2009-2013, while bluntnose minnow and bullhead minnow, both omnivores, have accounted for a combined 23.2 percent of collected individuals in recent years (2009-2013). The increased prevalence of bluntnose minnow and spotfin shiner accounts for the majority of the shift to more pollution-tolerant species. The mimic shiner and rosyface shiner, which are pollution intolerant, were prevalent in preoperational studies, but have only accounted for 0.1 and 0.7 percent of the total catch from 2009-2013” Sensitive species? Adieu.

Another major change in the aquatic community is the significant shift in species distribution towards cyprinids. Cyprinids accounted for 33.1 percent of total collected individuals in 1982, while they accounted for an average of 57.2 percent of fish collected over the 2009-2013 period. Centrarchid abundance has increased slightly from 21.1 percent to 28.8 percent between 1982 and 2009-2013. Catostomids, which accounted for 26.2 percent of the total catch in 1982, have only comprised an average of 5.0 percent in recent years. Percids have also decreased in relative abundance (see Figure 3–16)….

Species composition has also changed. Three families have appeared in recent years that were not present in preoperational sampling: Scianidae (freshwater drum) began appearing in monitoring samples in the early 1990s and Poeciliidae (mosquitofish) and Petromyzontidae (lamprey) began appearing in samples in 2008 and 2010, respectively (HDR 2014). One family (Amiidae or bowfin) has not appeared in samples since Braidwood began operating, and another family (Umbridae or mudminnows) has not appeared in samples since 2001
Figure 3–16.  Comparison of Relative Abundance of Most Prevalent(a) Fish Families in 1 Historic and Recent Kankakee River Monitoring Samples , EIS Braidwood
Figure 3–16. Comparison of Relative Abundance of Most Prevalent(a) Fish Families in Historic and Recent Kankakee River Monitoring Samples” Red boxes added by us.


The FES-O (NRC 1984) indicates that 15 species of mussels were collected from the Kankakee River in the vicinity of Braidwood during preoperational surveys. The majority of mussels were collected in shallow riffles with fast currents, and the predominant species was the mucket. The remaining 14 species are unspecified, but a 1978 study (Suloway 1981) conducted at 13 sites throughout the Kankakee River in Illinois provides insight as to what species were likely present prior to Braidwood operation. Suloway (1981) recorded 20 species among 1,006 live individuals collected in samples. The mucket was the most abundantly collected species, and the fatmucket, which occurred at all sample sites, was the most widely distributed species.

HDR (2008) conducted the first operational mussel survey near Braidwood in 2008 as part of a special study on the presence of State-listed species that could be affected by installation of the multi-port discharge diffuser (described previously). HDR conducted the survey in two phases, both of which occurred on August 8, 2008. In the first phase, six people hand-picked mussels along the shoreline for 2.5 hours each, and in the second phase, nine 220-m (720-ft) brail (a 20 collection device for mussels) runs were conducted in the center of the river. Live individuals were recorded by area and returned to the river upstream of the discharge channel.

HDR (2008) collected 212 live individuals of 15 species and shells of an additional 8 species (see Table 3–11). Mucket, the most commonly collected species, comprised the majority (54.2 percent) of live individuals. Threeridge (Amblema plicata) was the second most commonly collected species (13.2 percent) followed by flutedshell (Lasmigona costata; 6.1 percent) and pimpleback (Quadrula pustulosa; 5.6 percent). The remaining 11 species each accounted for less than 5 percent of live collections. Three live purple wartyback (Cyclonaias 6 tuberculata), a State-threatened species, were collected. Of the eight species collected as 7 shells, one dead sheepnose (Plethobasus cyphyus), a Federally endangered species, was 8 collected (see Section 3.8 for a discussion of Federally listed species) and relict shells of 9 two State-threatened species, spike (Elliptio dilatata) and black sandshell (Ligumia recta), were collected (Section 3.7.5 discusses these State-listed species in more detail).

The vast majority – 74% of the mussels, which were alive, were found upstream from the nuclear reactor discharge! The rest were either from the center of the river OR downstream. Upstream should be the control!

The majority of individuals were collected from hand-picking along the south shore upstream of the effluent pipe (156 live individuals). Hand-picking on the south shore downstream of the discharge and brail runs in the center of the river yielded the remaining live individuals. No mussels were found on the north shore, which HDR (2008) attributed to unsuitable habitat conditions. Table 3–12 lists the habitat attributes, collection method, and number of individuals and species collected at each surveyed location. In October 2008, Ecological Specialists, Inc. (ESI 2009), conducted a more comprehensive dive study to better characterize and map the distribution of freshwater mussels near the Braidwood discharge channel. The study included semi-quantitative, quantitative, and qualitative sampling methods. Ecological Specialists (ESI 2009) used semi-qualitative sampling to assess mussel distribution by surveying five 200-m (670-ft) transects perpendicular to river flow starting approximately 20 to 40 m (65 to 130 ft) upstream of the multi-port discharge diffuser (which had yet to be constructed at the time) (see Figure 3–17). A diver collected all mussels within 1 m (3.2 ft) of the line in 10-m (33-ft) sections for a total of 20 samples per transect. Based on the quantitative samples, qualitative samples were taken in areas with higher mussel density or where State-listed species had been identified.

Ecological Specialists (ESI 2009) collected 126 live individuals of 13 species (see Table 3–11). Mucket was again the most collected species. No unique species were present that had not been collected in the August 2008 survey. Three live State-listed individuals (one purple 5 wartyback and two spike) were collected from upstream portions of the survey transects. In the previous survey, spike had only been collected as relict shells. No black sandshell or sheepnose were collected in the October 2008 survey. Ecological Specialists (ESI 2009) concluded that the mussel community in the vicinity of the Braidwood discharge exhibits moderate to high species richness and relatively low abundance due to lack of suitable substrate.

No juveniles or other indications of recruitment were observed during the survey, which suggests that the mussels in the vicinity of Braidwood likely come from larger, stable, and reproducing upstream populations. Species diversity within the mussel community appears to be relatively high and to have remained similar since Braidwood began operation. Available literature indicates that 20 species were identified as occurring in the Illinois portions of the Kankakee River in the late 1970s (Suloway 1981). The 2008 Braidwood surveys (ESI 2009; HDR 2008) identified 23 species (live individuals of 18 species and shells of 5 additional species). Only three species of mussels from 1978 were not collected in 2008, and it is unknown whether these species historically occurred in the reach of the river near Braidwood. The Braidwood surveys also yielded a higher species diversity than a 2010 INHS mussel survey of the Kankakee River basin (Price et al. 2012). Table 3–13 compares species identified during the historical and recent mussel surveys.

Species abundance, however, appears to be lower in the vicinity of Braidwood than in other regions of the Kankakee River. During the hand-picking portion of the August 2008 survey (HDR 2008), 192 individuals were collected in 15 man-hours, which yields a catch-per-unit-effort (CPUE) of 12.8. Suloway (1981) collected 1,006 individuals in 37 man-hours, which yields a 27 CPUE of 27.2, and Price et al. (2012) reported a CPUE of 40.0 at mainstem locations. HDR (2008) indicates that the lower species abundance near Braidwood is likely the result of unsuitable or marginal habitat.” (pp. 3-53 to 3-65)

[See Mammals, Birds and Amphibians below the explanation of indicator species]

Indicator species are also known as sentinel organisms, i.e. organisms which are ideal for biomonitoring. Organisms such as oysters and mussels have been extensively used as biomonitors in marine and estuarine environments. For example, the Mussel Watch Programme is a world-wide project using mussels to assess environmental impacts on coastal waters. Their well-documented feeding habits, stationary condition and their role as integral parts of the food chain are some of the main reasons why oysters and mussels are widely used biomonitors. A considerable amount of contaminant concentrations are found in the surficial sediments (i.e. the finer-grained particulate matter, usually muds, silts or clays) of marine and estuarine environments. A major physical process governing the transport of fine particulate material and associated particle-bound contaminants in estuarine environments is resuspension. Strong winds create surface waves, which, in shallow water (<5m), project energy to the water-sediment interface resulting in resuspension of fine sediment from the upper layers of the estuary floor. Once in suspension, fine material may be transported by tidal currents to other parts of the estuary and possibly to the ocean during multiple reworking phases. Mussels and oysters are filter feeders and therefore uptake is by ingestion of particulates in the water column. Sediment resuspension is thus very important in the bioaccumulation process which aids the evaluation of possible adverse biological effects of sedimentary contaminants in marine and estuarine environments“.
Mollusca: numerous bivalve molluscs indicate water pollution status Mollusca, and quite often bivalve molluscs are used as bioindicators to monitor the health of an aquatic environment, either fresh- or seawater. Their population status or structure, physiology, behaviour or their content of certain elements or compounds can reveal the contamination status of any aquatic ecosystem. They are extremelly useful as they are sessile – which means they are closely representative of the environment where they are sampled or placed (caging) -, and they are breathing water all along the day, exposing their gills and internal tissues: bioaccumulation. One of the most famous project in that field is the Mussel Watch Programme but today they are used worldwide for that purpose (Ecotoxicology)“. http://en.wikipedia.org/wiki/Indicator_species Animals

[Only one third as many mammal species in 2005 as before Braidwood Nuclear Power Station opened.]


The baseline surveys documented mammals on the site based on observations of tracks, droppings, or individuals during the autumn of 1972 and 1973. ComEd (1973b, 1985) reported 24 species of mammals as occurring on the Braidwood site. White-tailed deer (Odocoileus virginianus), cottontail rabbit (Sylvilagus floridanus), red (Vulpes vulpes) and gray (Urocyon cinereoargenteus) foxes, deer mice (Peromyscus maniculatus), and North American voles (Scalopus aquaticus) were observed in most site habitats. ComEd (1985) noted that strip-mine spoils, though sparsely vegetated, supported a diversity of mammals typical of marshes, ponds, or other semi-aquatic habitats, such as muskrat (Ondatra zibethica), beaver (Castor canadensis), and otter (Lutra canadensis).

The 2005 WHC site assessment reported seven mammal species as occurring on the Braidwood site (Exelon 2013f): groundhog (Marmota monax), striped skunk (Mephitis mephitis), white-tailed deer, raccoon (Procyon lotor), eastern gray squirrel (Sciurus carolinensis), eastern chipmunk (Tamias striatus), and red fox. Six of these species were also reported in the baseline surveys, and one species (the eastern chipmunk) did not appear in baseline surveys.

It is possible that the creation of the cooling pond, which flooded most of the strip-mine spoils, affected the diversity of mammals on the site. However, Exelon’s Wildlife Management Plan (Exelon 2013j) does not specify the methodology of the 2005 site assessment, so a meaningful comparison between the baseline surveys and the 2005 data is not possible.

Bird species declined by 70% – from 91 to 27


The baseline surveys documented birds on the site by visual observations and bird calls during four seasons in two survey years (1972-1973 and 1973-1974). A total of 91 migratory and resident species were identified. The greatest species diversity was found in woodlands (48 species), and fallow fields held the least diversity of birds (6 species). Several waterfowl— including mallard (Anas platyrhynchos), black duck (A. rubripes), blue-winged teal (A. discors), and wood duck (Aix sponsa)—and shorebird species—including green heron (Butorides virescens), sora rail (Porzana carolina), upland sandpiper (Bartramia longicauda), and least bittern (Ixobrychus exilis)—were observed in the ponds formed between strip-mine spoil ridges. Strip-mine spoils were inhabited by birds typical of open or edge habitats. Many species of migratory songbirds occurred on the site on spring and fall survey days including eastern bluebird (Sialia sialis), cedar waxwing (Bombycilla cedrorum), eastern meadowlark (Sturnella magna), American goldfinch (Carduelis tristis), indigo bunting (Passerina cyanea), black-capped chickadee (Poecile atricapillus), eight species of warblers, and nine species of sparrows. Year-long residents included bobwhite (Colinus virginianus), ring-necked pheasant (Phasianus colchicus), mourning dove (Zenaida macroura), horned lark (Eremophila alpestris), blue jay (Cyanocitta cristata), American crow (Corvus brachyrhynchos), field sparrow (Spizella pusilla), and song sparrow (Melospiza melodia). Birds of prey included the eastern screech owl (Megascops asio), osprey (Pandion haliaetus), and six species of hawks.

The 2005 WHC site assessment reported 27 bird species as occurring on the Braidwood site(Exelon 2013f). Eighteen of these species were also reported in the baseline surveys. Notable additions not reported in the baseline surveys include the bald eagle (Haliaeetus leucocephalus), American kestrel (Falco sparverius), and wild turkey (Meleagris gallopavo). As indicated previously, Exelon’s Wildlife Management Plan (Exelon 2013j) does not specify the methodology of the 2005 site assessment, so a meaningful comparison between the baseline surveys and the 2005 data is not possible.

Amphibians and Reptiles are bioindicators. Why didn’t they look for them after the nuclear reactor started operating? Did they look and not find and pretend not to look?

Amphibians and Reptiles.

The baseline surveys documented amphibians and reptiles on the site during spring, summer, and fall of the two survey years (1972-1973 and 1973-1974). A total of 27 species were recorded on the site with the greatest diversity of species occurring in strip-mine spoil habitat (ComEd 1972, 1985). Cricket frogs (Acris crepitans) were the most abundant species, and cricket frogs, chorus frogs (Pseudacris spp.), and American toads (Bufo americanus) were present at all sampling locations. Aquatic turtles—including the painted turtle (Chrysemys picta marginataxbelli), common snapping turtle (Chleydra serpentina), Blanding's turtle, and spiny softshell turtle (Trionyx spiniferus)—inhabited ponds between strip-mine spoil ridges. The ornate box turtle (Terrapene ornate), a terrestrial turtle, was also present. Observed snakes included the eastern garter (Thamnophis sirtalis), eastern hognose (Heterodon platirhinos), eastern yellow-bellied racer (Coluber constrictor flaviventris), northern water snake (Nerodia sipedon). Other species of note included the eastern tiger salamander (Ambystoma tigrinum), five-lined skink (Eumeces fasciatus), and six-lined race runner (Cnemidophorus sexlineatus). The 2005 habitat assessment did not include amphibians or reptiles” (pp. 3-47 to 3-48)
See: http://www.savethefrogs.com/why-frogs/