ML19259A746
| ML19259A746 | |
| Person / Time | |
|---|---|
| Site: | Phipps Bend  |
| Issue date: | 01/03/1979 |
| From: | Gilleland J TENNESSEE VALLEY AUTHORITY |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7901100254 | |
| Download: ML19259A746 (12) | |
Text
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 07401 500C Chestnut Street Tower II January 3, 1979 Mr. Harold R. Denton, Eirector Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Denton:
In the Matter of the Application of ) Docket Nos. STN 50-553 Tennessee Valley Authority
)
STN 50-5514 As a result of TVA's continual review of its environmental obligations pertaining to the Phipps Bend Nuclear Plant (PBNP), we have identified some comitunts which we plan to change pending your review and approval.
The co=mitments, reference (s), the proposed changes, and supporting remarks are contained in Enclosure 1. identifies minor commitments that are not being implemented as stated but rather as discussed under the heading Commitment as Presently Being Implemented.
Very truly yours, f
,f
$Act J. E. Gilleland Assistant Manager of Power Enclosures Mr. James P. O'Reilly, Director (Enclosures) ec:
U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303 I
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CB 7901106299' s\\
N An Equal Opportunity Employer
ENCLOSURE 1 d
1.
Commitment Revegetation efforts in rights-of-way will include the reestablishment of some native species, as well as the establishment of grasses (especially fescue) and other vildlife food and cover.
References FRC FES Section 4.1.3.1, p. 4-3, first complete paragraph, second sentence.
Proposed Change Revegetation efforts in rights of vay will include the establishment of Grasses (especially fescue) and other vildlife food and cover (refer to ER Sections 4.3.2, 4.3.8, Appendix N1, and Questions b.9 and b.41 of Supplement 1).
Remarks Since native species will naturally reinvade the area, the discussion regarding reestablishment of native species is not necessary and should be removed.
2.
Commitment Therefore, at least 6 months prior to construction of the Phipps Bend transmission facilities or immediately after the final route is determined, TVA vill be required to perferm a ground survey of the proposed routes for protected biota (both flora and fauna).
References NRC FES Section h l.3.1, p. h h, first complete paragraph, seventh sentence.
Proposed Change After the location of the rights of way have been determined, TVA biologists will review any deviations ir ae route by helicopter not previously assessed in the initial survey to determine if field surveys of any identified sensitive areas are warranted.
Remarks TVA has a comprehensive siting approach for transmission lines which is designed to identify and eliminate potential conflicts with sensitive or unique natural and cultural resource features in the earliest phases of the transmission line routing process. This is accomplished through a combination of helicopter observations and ground inspections of proposed corridors before final route selection. Areas which are known to support oopulations of State or Federally listed threatened, endangered, or otherwise sensitive wildlife and plant species are identified and carefully avcided during the initial phases of line siting. Corridors are then flown to determine the presence of possible critical or sensitive habitats (i.e., caves, cedar glades, bogs, etc.), which could support previously unknown populations of threatened or endangered species. If such habitats are identified during the overflights, the areas are relocated on the ground and inspected to determine whether or not sensitive
vildlife and plant species are present or if the habitat is actually suit-able for such species. In either case, these areas are also avoided during the early siting phase.
After the location of the rights of way has been determined, TVA biologists vill review any deviations in the route by helicopter not previously assessed in the initial survey, to determine if field surveys of any identified sensitive areas are warranted. If any such areas may be jeopardized, steps vill be taken to avoid t=pacting the areas of concern.
TVA believes that this comprehensive approach to transmission line routing should satisfy the staff concerning the routing of TVA transnission lines and their potential for adverse impacts to populations of State or Federally listed threatened or endangered species. TVA biologists who regularly deal with TVA's transmission line siting projects believe that the current procedures are more than adequate to protect sensitive species and critical habitats.
Furthermore, additional ground inspection, as proposed in the conmitment, o* several hundred miles of transmission line corridors, which have b
.2 previously evaluated, is considered time-consuming, costly and provides no additional degree of assurance.
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3.
Commitment Terdon 101 vill be used at the rate of 10 lbs/ acro--which is within the present EPA allowable limits.
Reference ER Appendix N2; Construction Permit Appendix A, p. 3, item 23; HRC FES Section 4.5.1.1, p. 4-14, item 23; FES Section 5.6.1, p.
5-30.
Proposed Chance Tordon 101 vill be used at the rate of 10 lbs/ acre--unich is within the present EPA allowable limits or similar approved herbicides vill be used within the limits established by EPA.
Remarks If different EPA approved herbicides are used for the PB:iP transmission lines, TVA vill provide inforration to the staff similar to that previously provided to the Federal Working Group on Pest Management relating to the use of the herbicides (refer to Enclosure 1, items 8 and 10 of a letter from J. E. Gilleland to H. R. Denton dated June 30, 1977).
4.
Commitment -
Acreages of aquatic habitat lost due to construction (dredging or filling) of intake and discharge facilities will be documented utilizing measurements from aerial photographs. Baseline (Section 2.7, Appendix F) and preoperational information (Section 6.2) vill permit quantification and evaluation of these losses.
Reference ER Section 6.1.1.2.1, p. 6.1-3, second paragraph, first and second sentences.
Pronosed Change Acreages of aquatic habitat lost due to construction (dredging or filling) of intake and discharge facilities vill be minimal and will not result in significant losses. If at some future date, the acreage of aquatic habitat lost to permanent structures is required for impact assessment, such a determination could adequately be made from existing engineering drawings, maps, or those color aerial photographs now being taken on an annual basis to monitor construction effects on aquatic macrophytes near the site (ER Section 6.1.1.2.3, p. 6.1-5).
Remarks The small area of aquatic habitat permanently lost was determined to be insignificant in terms of fish population reductions (PBUP ER Section 4.1.2.2).
It is our understanding that the NRC has concurred with this assessment (NRC FES Section 4.3.2.1).
Since habitat (and ultimately fish biomass) loss was determined to be insignificant, documentation of such losses vould not appear to provide useful information.
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In an'y event, aerial photography would reveal only areas lost to permanent structures above water, and would not reveal any damage to spawning habitat outside these structures.
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5.
Commitment.
A set of five ground water observation vells was installed at the site in 1974. Collections will begin before initial clearing and construction. Quarterly grab samples will be collected from these wells and analyzed for the following parameters: Temperature, pH, conductivity, alkalinity, solids (dissolved and suspended), chemical oxygen demand, nitrogens (nitrate plus nitri+; trganic, and ammonia), phosphorus (soluble and total), fecal coliforms, copper, nickel, zinc, chromium, boron, sodium, sulfate, manganese, cadmium, and lead.
Reference ER Section 6.1.2.1, first paragraph; NRC FES p. 6-5, first paragraph.
Proposed Change Ground water monitorinq vill not be conducted during the construction phase.
Remarks TVA has determined that acquisition of ground water data during the construction phase at Phipps Bend is not necessary; therefore, we are raquesting that the ground water quality monitoring be deleted as a required activity during this phase.
E:ICLOSURE 2 1.
Co==itment As Presently Cited All potentially hazardous vastes vill be handled and stored in accordance with applicable regulations to ensure the protection of the e=ployees, public, and environment. These vastes vill be collected and transported to disposal facilities by a qualified solid vaste manage =ent contractor, in accordance with applicable require =ents of EPA's " Regulation for Acceptance and Reco== ended Procedures for Disposal and Storage (May 1,197h)."
Reference Construction Permit Appendix A, p. 3, ite: 8; IiRC FES Section h.5.1.2,
- p. h-15, ite: 8; E3 p. h.1-13, first complete paragraph.
Cc==it=ent As Presently Being I=plemented All potentially hazardous vastes vill be handled and stored in acecrdance with applicable regulations to ensure the protection of the employees, public, and environment. These vastes vill be collected and transported to an approved disposal facility by a qualified solid vaste management contractor or by TVA in accordance with applicable laws and regulations.
Remarks EPA " Regulations for Acceptance and Reco== ended Procedures for Disposal and Stora6e (May 1, 197h)" pertains only to pesticides and pesticide containers and not all potential hazardous vastes.
2.
Commitnent As Presently Cited Observations of waterfowl, shore birds, and other vetland species are made by bimonthly flights in a small, single-engine aircraft each year during the period November-April..
Reference ER Section 6.1.3, p. 6.1-6, Migrant and Wintering Waterfowl - Wetlands Investigations, first sentence Commitment As Presently Being 1molemented Observations of waterfowl, shore birds, and other vetland species are made every two weeks by flights in a small single-engine aircraft each year during the period November-April.
Remarks TVA's aerial surveys have always been performed every two weeks rather than bimonthly.
3.
Commi~tment'as Presently Cited Observations of vsterfowl, shcre birds, and wetland birds are obtained by an observer and a pilot-observer from a small helicopter.
durveys are conducted at 20-50 feet above the surface at an air speed of 25-30 miles per hour. Bimonthly counts from April through October cover all vetland habitats within a 5-mile radius of the plant site.
Surveys begin at sunrise and end before 11 a.m. EDT. Waterfowl are classified by sex and age; sLmilar criteria are applied to other fauna when possible.
Reference ER Section 6.1.3
- p. 6.1-6/-7, Spring-Summer Waterfowl-Wetlands 3
Investigations, second paragraph.
Commitment As Presently Being Implemented Observations of waterfowl, and other birds are obtained by an observer and a pilot-observer from a small helicopter. Surveys are conducted at 20-50 feet above the surface at an air speed of 25-30 miles per hour. Counts which are conducted every two weeks from April through October cover all vetland habitats within a 5-mile radius of the plant site. Waterfowl are classified by sex and age; similar criteria are applied to other fauna when possible.
Remarks See remarks to Commitment 2.
The statement regarding the time period in which surveys are performed is a holdover from boat censusing which TVA no longer performs (see remarks Commitment k).
h.
Con =itment As Presently Cited During overflights and boat censusing general condition of riparian and other vetland habitat will be evaluated for construction impacts.
Reference ER Section 6.1.3, p. 6.1-6/-7, spring-summer Uaterfoul-Wetlands Investications, fourth paraCraph, first sentence.
Proposed Revision During overfli hts general condition of riparian habitat vill be C
evaluated for construction i= pacts.
Connitment As Presently Being Inplemented The use of boats in the spring of 1974 was changed to the use of helicopters beginning in the spring of 1975 and has thus presented advantages over the use of a boat. The helicopter has enabled the survey radius to be extended which better reflected the daily mobility of waterfowl and therefore =casure a more realistic inpact area.
In addition, there has been a significant tine saving in that previously a boat required one full day to survey a site; whereas, with a helicopter, lh sites can be surveyed in 3 days.
In sunnary, data collection from a helicopter enhances TVA's observation capabilities and also has proven to be highly cost efficient.