
NWEA’s comments focus on EFSEC’s failure to evaluate whether the reactor’s discharge complies with downstream water quality standards, including its complete omission of Oregon’s standards. EFSEC also ignored the discharge’s potential impact to populations of fish and mollusks, including some listed under the Endangered Species Act and others which may have been entirely extirpated. The agency also ignored the fact that federal law requires them to take into consideration other sources of pollution, including continuing pollution from the Hanford Nuclear Reservation and unregulated agricultural pollution.
In addition, the comments criticized EFSEC’s failure to determine the best technology available for the water intake system to ensure that fish are not sucked into the cooling system or damaged by the intake structure. These effects to fish are called “entrainment” and “impingement,” respectively. Most remarkably, EFSEC completely ignored the significant concerns expressed by the National Marine Fisheries Service (NMFS), which is in charge of protecting threatened and endangered salmon and steelhead.
