ML18192A186

Response to NRC Comments on the Construction-Phase Groundwater and Ecological Monitoring Programs. Also Enclosed Are 3 Additional Pages to the Program Submitted on 4/5/1976

ML18192A186
Person / Time
Site:	Palo Verde
Issue date:	05/19/1976
From:	Van Brunt E Arizona Nuclear Power Project
To:	Gilbert R Office of Nuclear Reactor Regulation
References
ANPP-4517
Download: ML18192A186 (14)

Text

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trans the following:

ENCLOSURE I

Replies to NRC comments on the, Construction-Phase Groundwater

& Ecological Monitoring Programs for the PaloUerde Station......

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100% RKCYClKO'~~R ARIZONANUCLEA+POWER PROJECT Post Office Box 2166~oenix, Arizona 85036 May+.9i~, 1976

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5.1-7 Dr.. Robert A. Gilbert 8

Project Manager Environmental Projects Branch 3.",

U. S. Nuclear Regulatory Commission Washington, D.

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20555

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p,~~0 RE:

Docket Nos.

STN-50-528/529/530

'.ia

'.""'RC Comments on the Construction-Phase Groundwater and Ecological

.Monitoring Programs for the Palo Verde Nuclear Generating, Station

Dear Dr. Gilbert:

In your telephone conversation of May 10, 1976, you stated that the Staff had the following comments on the referenced monitoring programs:

'1.

The groundwater monitoring program should include sulfates in the list of chemical parameters to be monitored shown in Table 2.

2.

3.

The groundwater monitoring program should include addi-tional,monitoring points at the 910 foot contour near the northeast portion of the site and at the 890 foot contour near the southwest corner of the site.

The ecological monitoring program's description o'f a gen-eral ecological field survey under "Field Surveys" on page 3 is not specific nor sufficient information for staff review.

A clarification of what is intended should include a listing or discussion of the parameters to be surveyed, the frequency of sampling and a brief description of the methods to be used.

We have discussed these comments with Dr. Ron Zussman,, Argonne National Laboratory via telephone on May 14, 1976.

Based upon these telephone conversations, we offer the following replies to your comments:

1.

We will include sulfates in the water quality parameters to be analyzed.

M68 ANPP participants: Arizona Public Service Company

~ Tucson Gas 5 Electric Company

~ Salt River Project Arizona Electric Power Cooperative, Inc. ~ Public Service Company of New Mexico ~ EI.Paso Electric Company

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Dr. Robert A..'Gilbert Project Manager ANPP-4517 May 17, 1976 Page 2

2.

The suggestion for additional.monitoring points is to ensure an adequate data base for,comparison with water quality after PVNGS is operational.

We propose to. do this by sampling 'four additional,. existing wells:

two near the 910 foot contour just south of the storage reservoir location, and two wells near the 890 foot contour at -the south and southwest part of the site.

Water level has been. measured in these wells,previously, water quality samples will be, taken within the next two months and again during the winter months to establish a,data base.

This procedure is agreeable to Dr. Zussman.

3.

Our reply to this comment is enclosed as three additional pages to the'onstruction-Phase Ecological Monitoring Program submitted.on April 5, 1976.

Please substitute the

,enclosed pages 3,

4 and 5 for these pages of the existing

program, and add Table 1 to the existing program, 10 cop-ies of which are now in your possession.

Very truly, yours, 7.%. V~~V~~~

E.

E'. Van Brunt, Jr.

APS Vice President Nuclear.Services ANPP Project Director EEVBJr/JRM:skc Enclosures CC:

A. C. Gehr B. Norton W. M. Petro Admin. Committee W. H.. Wilson w/enclosure C.

G. Mattsson w/enclosure T. Hudgins w/enclosure J.

M. Allen

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Construction-Phase logical Monitoring Program Page 3

FIELD SURVEYS Ecologica1 field surveys will be conducted in order to (1) provide ground verification of photo-interpretation

studies, (2) identify ecological impacts which are imminent or which have occurred and can be mitigated, and (3) document the actual ecological impacts of construction activity.

Table 1 lists the major characteristics to be analyzed, the frequency of observation, and explains the rationale for including the specific char-acteristics.

Also included in the survey will be a check on the condition of the salt monitoring, study plots which have already been established.

These fenced plots will,remain as undisturbed as possible during construction activity.

Due to the many environmental protection controls which APS has committed to, including constructing sediment basins to trap sediment from worksite run-off and implementing a comprehensive environmental control program (see below), no major ecological problems're anticipated.

The surveys will be made by trained plant and animal ecologists who are familiar with the desert ecosystem at PVNGS and with the construction

plans, and by the Site Advisor for the General Environment (SAGE).

Not included in Table 1 are the ecological characteristics to be evaluated with respect to the transmission and water pipeline corridors, or to the pre-operational monitoring studies noted in Table 6.3 of the FES.

The latter program will become a part of the technical specification of the Operation L'icense as stated in Section 6.1.3.3. of the FES.

AERIAL RECONNAISSANCE SURVEYS In order to help document ecological impacts of construction and to obtain information useful in making mitigation suggestions, aerial photography (1" 2,000') will bh flown and interpreted before and after major con-struction activities, at least once per year.

The aerial reconnaissance surveys. will provide a regional overview of the impacts of construction activities on and near the PVNGS site.

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Construction-Phase logical Monitoring Program Page 4

The photography will be interpreted.immediately after it is developed and printed in order to aid in developing mitigation plans which will be re-sponsive to actual environmental conditions at the site.

The number of acres disturbed and levels of di+turbance wi'll be identified and evalu-ated.

CONSTRUCTION-PHASE ENVIR0%iENTAL CONTROL PROGRAM As required by the FES, Summary and Conclusions, Paragraph 7.b, a control program including written procedures and instructions to control all con-struction activities has been developed.

It provides for periodic manage-ment audits to determine t'e adequacy of implementation of environmental requirements.

Sufficient records to furnish evidence of compliance with all FES commitments will be maintained.

Many of these control programs are ecological in nature; e.g., stockpiling topsoil, safe disposal of chemicals and wastewater, and recycling organic materials to the soil.

SALT MONITORING STUDY PLOTS The FES requires the establishment of additional soil and biotic sampling stations which will not be disturbed, by construction activities.

These plots "are to be used as reference plots for future'studies concerned with cooling-tower drift salt deposition",

(page 6-5).

Six plots have been es-tablished (see Figure 1).

Descriptions of these plots are as follows:

Plot Ill - 100 meters x 100 meters.

Creosotebush Cacti Hill and Bajada.

Contains Barrel and Hedgehog Cacti.

Plot l/2 200 meters x 100 meters.

Saltbush Plant merging into Creosotebush Plain.

Contains a small wash.

Plot II3 100 meters x 100 meters.

Creosotebush Plain with Cholla and scattered Mesquite trees along a small wash+

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Construction-Phase logical'onitoring Program Page 5

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Plot

//4 100 meters x 100 meters.

Creosotebush Plain-Bajada

~ with many Cacti including Cholla, Barrel and Hedge-hog e Plot i/5 100 meters x 100 meters.

Mesquite Wash with Salt-bush.

Very dense, although recent fire has cleared out some undergrowth.

Part. of plot goes into adja-cent old field.

Plot

//6 100 meters x 100 meters.

Creosotebush Cacti Hill with Hedgehog and Cholla.

The criteria used in selection of these plots were:

,a.

Predicated salt.isopleths of on-site solids ground deposition and total and annual mean airborne con-centrations of dry salt particles from round multi-fan,cooling towers',

based on a 0.01% drift rate.

1 b.

Existing vegetation types.

'A wide diversity of habitat types were selected which are not anticipated to. be directly disturbed by construction activities.

The three northern plots are expected t'o receive the heaviest salt deposition of up to 12 lbs/acre-year; and the three southern plots, only 2 lbs/acre-year.

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t TABLE 1

t MAJOR ECOLOGICAL OBSERVATIONS TO BE ANALYZEI)

AT A4D IN THE GENERAL REGION OF THE PVNGS SITE

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Day-to-day observation of these items will be done by the Site Advisor for the General Environment and his staff.

Semi-annual observations, will be made by trained ecologists.

Observation Habitat Alteration, for example:

a.

Status of existing drainage

courses, particularly East and Winter's Wash and location of new drainage courses.

b.

Amount and kind of habitat disturbed, including accumu-lative amount of habitat lost and any habitat lost due to construction e'quipment and ve-hicles outside of designated work areas.

c.

Apparent amount of

~ soil erosion.

d.

New species habitat formation.

2.

Revegetation Practices-How and where they, are being carried out.

3.

Presence of any rare, endangered, threatened, or state-protected fauna~.

Rationale Habitat alteration will be the major detectable impact..

Alteration of East Wash course represents a major.habitat mod-ification.

According to FES, an upper limit of 2,500 acres is to be cleared at PVNGS.

Soil conservation practices can result in preventing the loss of valuable seed reserves.

and growth media and can prevent soil sedi-mentation.

'Creation of new habitat, including shallow pools of water could re-sult in the use of the site by new species.

In certain cases, control measures are practical.

Properly carried out revegetation efforts can be an important miti-gative action for the original vegetation lost.

In certain instances, for example with Gila monsters and desert tortoises, special mitigative measures can be developed to pro-tect,these species to insure that they are disturbed as little as possible.

• All state-.protected plants on the PVNGS site will be transplanted or otherwise protected prior to construction.

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