ML19291D072
| ML19291D072 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/26/1980 |
| From: | Gonzales R Office of Nuclear Reactor Regulation |
| To: | Lear G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19291D071 | List: |
| References | |
| NUDOCS 8012170587 | |
| Download: ML19291D072 (10) | |
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NUCLEAR REGULATORY COMMISSION 3',c.
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l WASMNGTON, D. C. 20555 NOV G iS60 Docket Nos.:
50-483/486 MEMOPANDUM FOR: George E. Lear, Chief Hydrologic and Geotechnical Engineering Branch Division of Engineering William S. Bivins, Leader, Hydrologic Engineering Section[/
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Hydrologic and Geotechnical Engineering Brancff
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Division of Engineering FROM:
Raymond O. Gonzales, Hydraulic Engineer Hydrologic and Geotechnical Engineering Branch Division of Engineering
SUBJECT:
MEETING AND SITE VISIT TO THE CALLAWAY PLANT On November 18, 1980, I visited the Callaway Plant along with Clarence Hickey the Environmental Review Coordinator, Gerry La Roche of the Environmental Engineering Branch, Alex Dromerick of Licensing Branch No.1 and the Argonne National Lab team that is conducting the major portion of the Callaway Environmental Review.
The purpose of this site visit was to obtain environmental infornation for use in reviewing the Envirenmental Report and in preparing the DES.
The morning of November 18 was spent looking at the physical plant layout, particularily the structures located in the floodplain.
I wanted to see how the executive order on floocplain management applies a: Callaway. The intake structure and the discharge pipe outlet encroach very little on the. floodplain because these structures are located in an opening within the cxisting rock reverment on the north bank of the Missouri River. The river in this area is about 1400 feet wide. By comparison, the intake structure occupies less than 100 feet of this width. This means that construction activities have not adversely affected the floodplain.
I also took a close look at the emergency cooling pond. At the present time, it is partially filled with water which was obtained from an onsite well. The applicant's consultant, Dames and Moore, is currently conducting tests to determine the amount of seepage from this pond. Several ciezometers have been installed around the perimeter of the pond.
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George E. Lear NCY 2 6 7eSO The afternoon of November 18 was spent conducting an aerial reconnaissance of the area from a helicopter and discussing acceptance review questions with the utility and its consultants.
The helicopter ride provided an excellent opportunity to get a broad overview of the area. This overview showed that the plant is located on the topographic high point in the area. Surface runoff flows radially away from the plant.
The questions which we (HES) had asked previously were discussed with representatives of Union Electric and Dames and Moore. Satisfactory responses were provided to all our questions. This will permit us to canpence with our review of the ER.
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Raymond Ecorales, Hydraulic Engineer Hydrologic and Geotechnical Engineering Branch Division of Engineering cc:
J. P. Knight W. Bivins A. Dromerick C. Hickey R. Gonzales Local PDR NRC PDR ACRS (16)
ATTACHMENT 5 I.
CP Followup 1.
Logan Creek Disturbance during Construction The design of the Callaway Plant required placement of cooling water pipelines and an access road across Logan Creek, in association with operation of the cooling water intake and discharge structures on the north bank of the Missouri River. Reports on these activities were suomitted to NRC during 1975 and 1976, with additional data on associated monitoring included in the ER-OL.
Discussions between Rosmarie Cesine (ANL Aquatic Ecologist) and C. Hickey revealed that examinations thus far by ANL indicate the ER-OL has treated the Logan Creek proolem reasonably. ANL will analy e this further during the environmental review.
Inspection of the Creek crossings by helicopter overflight occurred on Wednesday, November 19, 1980. The Creek flow was low. Creek banks appeared stable with no erosion. Creek banks were vegetated.
Vertical bridge supports of the access road were on either side of the Creek and not within the water.
II. New Informatinn 1.
Archaeological and Cultural Resources Tours cnd examination of the site properties by Sue Ann Curtis (ANL) and Michael Weichman (Division of Parks and Historic Preservation, M0 DNR) revealed that significant archaeological sites have not been protected properly during construction. Additionally, eight previously unrecorded sites were found during the tiurs; and i.he presence of other existing sites is likely.
Mr. Weichman stated that the initial archaeological study conducted during 1973 was inadequate to identify all of the cultural resources contained witnin the Callaway property. Mr. Weichman was asked ta forward his findings in writing to NRC. A letter dateo November 20, 1980 from Weichman to Hickey has been received and is enci sed as Attachment 7.
In the letter are reconnendations for a re-assessment of the resources on the Callaway property and for NRC's coordination under the National Historic Preservation Act. A long-term management plan probably will be needed to protect certain sites.
2.
NPDd5/Slucge Pond Construction The NPDES permit for Callaway does not per nit discharges into the Missouri River of clarifier sludge cart.:ulate matter. As a result, the applicant must build a series of large settling ponds. Three conds are under c nstruction and were examined on Wecnesday, Novemoer 19. Four additional poncs will be built every ten years.
All totalled, 200-.100 acres of ponds will be needed during the
operating life of Callaway. The ponds are in an area cnat had been pasture and farmland. Topsoil has been stockpiled and will be placed on the berms of the ponds and seeded.
The disturbance of land for placement of the ponds has not been examined. The applicant stated : hat no survey of the pond area was conducted for cultural and archatological resources. A management plan for the ponds will be included in Revision 1 to the ER-OL.
A telephone communication on November 25, 1980 between C. Hickey and Monte Phillips, OIE Region III Inspector, revealed that the inspector was not aware of the need for the ponds or tne ongoing construction of the ponds. During the July 1980 annual inspection, the inspector did not see the ponds. The NPDES permit that restricted the discharge (and thus necessitated the use of ponds) was issued in August 1980. Construction of the ponds, therefore, has occurred subsequent to the annual inspection and the submittal of the ER-OL. The 3pplicant stated that Revision I to the ER-0L will contain information on the NPDES / sludge pond problem, but Revision 1 will not be submitted until the ER-OL is accepted and docketed.
3.
Emergency Buildings Requirements resulting from the TMI accident will result in the placement of additional ouildings onsite to be used during an emergency. Two buildings vill be in areas already disturbed by construction. A third building (training center and simulator) will be on presently unused farmland. The Emergency Offsite Facility will be on land presently uncisturbed by construction.
4 Prime and Unique Farmland Since the CP permit was granted, the U.S. Department of Agriculture has become concerned about Prime and Unique Agricultural Land (Feceral Register Tuesday, January 31,197E, 43(21):4030-4033).
Gerry LaRoche has coordinated the NRC needs with Bernie Jaroslow who has requested specific information from the Soil Conservation Service in Fulton, Missouri.
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My s.rrary assess -ot of the Callaway site visit :n ':cvember 13 and 19, 1930, is that i: 2s unsatisf actory because the applicant did rot receive the lis of infar al luestions un.il 9:20 a. n.
- n 'bcday, *;cverter 17.
. sere.as, theref;ce, insuf ficient time for the acclicant to pre-care res; nses prior :: the visit, and e were ;rable to dis;uss the re-5;0nses in Order to ! car up residual misur. cars andings. As a conse-
- puence, any of the ap:licant's s:aff and :.ns al: ants, and also the state efficials, aere not ef'ectively used, 3rd an :pcortunity was missed.
It is unlikely that all cf 'ne *alent tra:.as available at the site
- n Tuesday will acain be as;me led :cce:her at the same place and tire.
There '..ere other ;roblems which, even thcugh they sere not of major
- nsequence for the site tisit, were sympt:ratic of the ;r:blems.ve have encountered in planning cur z.crk.
'Je did not find out until " nday evening that Richard Stark, tre lim, would not attend.
(One of the ajor riai:ns cited far rest,;ning the visit, criginally scheduled for Oct:bar 27, c.as that Stark wculd not have been able to attend. That postponement required cancellation of a meeting with local officials, anich could not be r2 scheduled for the site visit and aill require an additional trip to Jef ferson City in Decer.ber.)
Alex Dracerick, who sucstituted for Stark, Jid not arrise until 2 p.m. an Tuesday, and as not in a pcsition to answer questiens regarding scheduling or to make cecisions because he was not familiar with the project.
The site visit was, in my jutigement, wortn the cost and effort in spite of the deficiencies notad abe.e.
M wever, I believe that-if it were not for the efforts of Clarence Hickey, the environrental review c ordinator, who has been very cooperatise and heloful and impressed me aith his competence and canscientiousness, the accenplishments might not have been sufficient to justify the cost.
The following trip report is a callection of my impressions and the matters which occupied qy attentien, not a balanced act:Unt.
I have de-sated considerable space to tne issues related to cultural resources because concerns expressed by a state official led to discussions in-scl.ing a number of ANL, NRC and UE personnel and ;3ve me reason to beideve that there are potential prcblems in this area.
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- ov..cer 21, 1:-30 he meting cn Tuasday 0;cventer 18).ms att m j by.1 NEC 5taff
( Alex Crcrerick, 'arpurary LTM; Clarence u c' ay, ERC :nd.nauatic ecol;;y; Ser ain La::che, terrestrial ecology; and :ay 'i.:nzales, hydrc'ogy and
.ater use) and $ ;NL staff e-cers (T;m Gilbert, project leader; D. A.
Srednick, assistant project le3 der and socic.:ccr< mics; Lee Eusch, reed for ;cwer and cost-benefit; Eue 'nn Curtis, cultural retources; cse-
-arie Devine, a.uatic +cology; Scenie Carosicw, tarr?strial eco'ogy; Gary "arrer, noisa and thermal discharge; and AT Jcna Sic:ck,..ater
- uality). Nnald F. Scnnell, General."anager, Trerations, for Union Electric ard ;^ af nis staf f enters; 7 state at ficials (6 from Misscuri Capartrent af '
- atural bscurces and 1 9 m the lis 7 2ri Occartment of 0
Onservation) and 3 c:nsaltants for Union Electric ce alsc ;-esent.
On 'icnday a f terncon ;"ovember 17) it a p.m. Sue 'no Nrtis 3nd I met ai th Micnael S.1.'eichran, Senior Archeci: gist. C-fice of Historic Pas arva ticas, *!i s scuri Ce;a rtment of Na tural k v-'s.
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ressed i"e c3ncerns th ;t, in his coinion, the site c.as not in cmpliance. vita Sec. IC6 af the Mational Historic Preservation *et liite 20,.h'ch had been identified by a Unica Electric consultant as' meting eligibility requirements for the Naticnal Register had not bcen Nninated for One hgister and the state.nd *.dvisory Council *ad not car.mented on the
- tner sites tnat
.ght ba :n the 7000 scre plant cr: erty); the survey
..as pr:bably iradequata (a site that had been e.arlded by the con-sultant had been fcund cr the Callaway property); and a program for mcnitoring and protecting incwn sites had not been submitted or approved.
Mr. 'deichran had been invited to participate in the site visit en Tuesday.
I told him "at af tar he had i.mected the site and had an c;;ortunity to meet with the applicants cultural rascurce car.sultants an Tuesday rarning I anted to meet with him, the NRC manager and co-ordinator and Union Electric Of ficials in arder to detenaine whether there was a potcntial problem and what c:urse of action should be taken.
The meeting at the site opened at about 3:30 a.m. en Tuesday morning, with everycne present e.vcept the NRC staff.
(Gerry and Ray arrived around 9 a.m.; Clarence and Alex arrived around 2 p.n.)
Af ter a brief review of tne history and ;; resent status of the project by Ocnald F.
Schnell, General Manager of Operations for Union Electric, we br ke up into grcups for consultation and site tcurs.
Union Electric officials were very cooperative, and provided all the assistance we could ask for to see everything we.. anted to see: by air (a helicopter was available all day); by water (a boat was available all day) and by ground (en foot or by car).
In additi:n to a general overview by means of a supervised plant tour, gr:und tours, beat teurs and aerial tours, WL staf f merters net individually with the appropriate Union Electric <taf f and Ccosultants and State Officials.
A very limited amount of infer-ation was provided Wediately; the additional infor.ation needed will be arevided in pending revisiens af the F1virenncntal 'te; ort which shouiJ 'o emdy for -e' ease wi thin two mecks (-ame ravi.,iens are ready. cw) er.s nnses to One f rmi T.,est ens.
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. 'es to rece,ee tr.e cart.culate ate-ial w.t must be rc..c ed fccm the r ver catar refcre it cnters the
'1:nt cooling system (in cne nylitary agencies do not aliew it :o
- e r turned to river;;,n e v mcy c era ticn. a:1,ii ty
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f Le Mit cutside the castric'.-d r:3 for use as a c;cor.d facili y in ase of a T:U-tj;e : vent; a ts s.' nical supp;ct : enter; and :?c:rery access facilities to faci;ita
..nt anca and exi d' ring sr.c;ancy situa:'ons.
I t uces not ac..i;,s tr *. hat Bese chances will pri:ent any ;roblems.
The Callaway CL review bcs nct yet been docketed.
The holdup ap-ears to be due to legal problems associated with resciution of the
- ne-uni t/ two-uni t ;rati em.
Ecth the idL staff and the NRC staff have racommended acceptance of the envircnmental re;crt.
The applicant is arailling to submit the ER revisions until notificaticn is received that the ER has been accepted and the case has been d:cketed. Ciarence Hickey and Alex Dr:merick are going to check into the matter.
If there are further delays in decketinc, Clarence and Alex are going to check into the possibility of providing "si:n Electric with the formal ques-tions and enabling Unicn Eicctric
'.o provide us with informal copies of the revisions prior to decu m in ceder to expedite pre;sration of the 05 FES CP.
I tol d Clar. ne: '.nat I planned to have the list of fermal questions ready far c. ailing to him cn Friday, ';overter 21.
The revisicns to Chapter 1 of tne ER (need for power) are massive and :.ill require a great dcal c; ef fort to make the DS FES CP timely It ap; ears li' ely that this unexpected new development, and accurate.
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- 0gether witn the celays frca.ue original schedule in acquiring all of the information needed for i reparing the DS FES CP, will probably
- 1. sad to slippage in the schedule.
(This possibility was pointed out in attachment I cf my letter of September 9,1930, to Clarence Hickey.)
It is too early to tell t.nat this slippage might be; we will do our best to minimize it.
It appears, en the basis ef concerns expressed by the state ar-chaeolcgist, P.ichael ;:eichman, at a meeting with Cromerick, Hickey, Gilbert, Erodnick, Curtis, Farmer and (later) Schnell and several of his staff that there may te a jiotential problem in the area cf cul-tural resources. During their reennaissance of the site en Tuesday morning Michael 1:eichman and Sue Ann Curtis, independently, found evidence that cultural resource sites had been overlocked, including an additional site that may be eligible for the National Register, and that sites have bean exposed that will suffer darage and destruc-tica during operaticn of the plant unless an adec,uate protection and monitoring program is designed and implemented.
"r. 'deichman stated that his concern is to protect the remaining sites.
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'tr. '..'aicnnan agreed to do ;nis 2nc :: send us a c0py.
Sir. '.ieich an e,prassed a number of c:ncerns, based on his kn wledge af the situation and One information he ained during tne site visit, and raised a nurber of questions that will "3ve to be resolved by con-r ul:3 tion bet..een the sta te and the NFC tefore.ve tan proceed.vith pre-
- aration af the section on cultural re
- curces.
enald Schneli was rather upset by the c:molaints made and questi:ns ra::2d by Mr. '..'ei f man.
We requested that they be rescived as 50cn as
- ssible.
One of the ccrolaints that disturbed 'tr. Schnall us that a survey of One entire 7000 acres should be dcne.
The survey done by his con-sultant was limitad to the assumed c:nstruction areas. fir. Schnell told me that his censultant had told him that a survey of the 7000 acres
..culd cost up to 5500,000.
M '- Weichman infor ad me later that 1e t;;al cast far sucn a survey and the prepara:icn af a ;rotection and
- ni taring plan would be about 550,000 and could not reascratly exceed il 'n, X0.
':ei ther the cons ul tant's nor 'tr..:eic - an's fi;ures incluced
-< u cat';n af archeological sites, in the unin21y event tr :t this s ~.culd be necessary.
Cre of the problems is that the distincticn between.vhat is cen-sidered an :;erating phase irpact and.vhat is Considered a construction
- nase impact has not been clearly defined.
The far er would be of im-
?diate c:ncern for us in preparing the DS FES CP.
Sue Ann met again with Mr. Weichran en Wednesday morning, at his of fice, to obtain from him any relevant.naterial in nis file pertaining to the Callaway project.
She was allcwed to Xerox any aterial that she found to be of interest, and will send a copy cf this to Clarence Hickey.
Sue Ann deserves commencation for handling herself in an exemplary and professicnal manner in a difficult situation.
Clarence Hickey also ccmrented that she has done an excellent job and expressec appreciaticn for her efforts.
If the potential pr:blems concerning cultural re-scurces had ct been brought to light for approoriate action at this time, they mignt have led to sericus problems that could have reflectec cn the professional quality of the Callaway DS FES CP.
The entire ANL teem met ith Clarence Hickey Alex Oracerick and 2erry LaRcche :n Tuesday evening in order te review the develcpments Of t e day.
Several team me-bers expressed c:ncern re ardino. the de-1 y in f0rsar-ing informal questions to the applicant..
'Mrce NRC staff (Alex, Clarence and Gerry) and three ANL staff
(:er,ie, Ocse arie, and myself) went back to the site en Wednesday
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- r a-ins ection of features thit had been -issed (the ex-
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n 1150 visited ::t ert ' ant:es. Chief of the Permit Iec-tien,.h... Quali ty F-ogram, Di vi sion of Envi ronr _ntal Quality, *tissouri Cipart s a. of ';atural :nources (acc ;anied by avid '.'ntold, a l'ni;n Electric biologist) on '4cdnesday morning.
Bernie arranged to have soil maps of the Callaway site mailed to him by a state official in Fulton, thereby avoiding a side trip to fulton, Mo.
I discussed with Clarence the matter that the D5 FES C? cutline orovided for Callaway was different fra.a the outline that e.as being
,.r:vided for other OL projects.
Clarence is going to leak into inis and also : neck into the matter of a budget letter for Callaway.
He entioned tne lack of a budget letter to Dan "uller around 'cverber 3.
Clarence will also check with Rich Stark to ;btain parmission for us t:, c:ntact *:eal Slaten ('lE, Su:ervising Engincur, Envir:nm2n al) directly :n te:Snical matters.
D. A. Erodnick and I oill pr:bably.:o tack to Jefferson Ci y on C+ camber 17, the date of tSe monthly meeting of the Mid-tiisscuri Council of Governments, to collect s:cicecononic inf:.rmation fr om local Offi-ciais. A special meeting ud teen arranged to acc
..c !a te us in the site visit e.as scheduled for the..eek of Oct:ber 27.
This e::fc;
- e. a s cancelled wnen the site visit was called off (af ter the invita:icns had been sent out), and it ceas not possible to reschedule a s;'ecial meeting during One week of "cvember 17.
':eal Slaten will arrange a conference call with L:ott +..;r:c's.+n and Times and." core c:nsul tants on Thursday, ' ove..;er JD, to ::s ;ss c:aling t:wer questions.
I especially appreciated the help and cooperation I received from the team, and the very comoetent mar.ner in anich they carried through tnair assignments.
(Both NRC and UE officials comented to me on their professional competence.)
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D. A. 3rodnick A. J. Dvorak L. 5. Busch A. Dromerick
":RC J. E. Carson W. J. "alletc S. A. Curtis C. 8 ey - $RC R. L. Devine P. F. Gustafsen R. F. Freeman R. Stark - NRC
- 5. A. Humrickhouse W. S. 'Whi te S. N. Jarosicw G. J. Marmer J. Milsted A. A. Sic:ek
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Car:ers were ;resen; as,.eil as : ave ',:entcic ('.'E) and, yself. The majority of the discussion was bs:we m 2:c and Dave.
Ecb stated that he was initially dissatisfied wita the impingement
. that :".e design oss as previousty 3;pr:'.ec anu, pa s s '. a i i i t,i e s, gu: icur:
s thers'c re nt: suoject :: ce stion. He feels Ine fisn gates may r:.e to be r
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I did acree that the bcnthos and : cplankt;n studies could pr;bably be s
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.r:pped, espe:131 which are more meaningful.
There is a public hearing December 3 for an 2: peal of the NIDES, but
' ertges does not anticipa'.c any ra'. arse judgement because *he NF:E5 permit
.is sufficiently strinc. tot to er:tect the d:wnstream drinking water fr:m ir;2ct by the UE Callaway operatirns.
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