ML20009B160
| ML20009B160 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/08/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Muller D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8107140934 | |
| Download: ML20009B160 (5) | |
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, Docket File RLTedesco Attorney, OELD
.NRL PDR DEisenhut/RPurple R. Gilbert LPDR OI&E(3)
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Nos 50-440 /
L1#2 ACRS (16)
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MService TIC R. Ballard DHouston NS.IC HEMORANDUM FOR: Daniel R. Muller, AD for Environaiental Technology, DOE FROM:
Robert L. Tedesco, AD for Licensing, DL
SUBJECT:
REVIEW 0F FR0 POSED CHANGES TO THE PERRY ENVIRONMENTAL MONITORING PROGRAM In a letter dated July 7,1980 (Enclosure 1), Cleveland Electric Illuminating discussed planned changes to the Environmental Monitoring Program which has been and continues to be pursued dt; ring the construction of the two unit Perry NL! clear Power' Plant. Our action on this pmposal was unclear since no fomal NRR approval had been issued oneeither the original program submitted in August,1974 or :its resubmittal in August,1978 (Enclosure 2). Since NRR did not mject or modify that' program, NRC 38'E (Region III) adopted this plan as their basis for auditing the environmental activities at the Perry site. During our recent discussions with CEI, they informed us of their desire to shift some of their environmental resources to prepare for the operation of Unit 1 but that such a shift could only be made if the revisions to the CP program were approved. Furthermore, I&E requires our approval of the proposed program changes before such changes can be factored into their future inspection audits.
Therefore, at this time we request that the Environmental Engineering Branch review
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the changes to the Perry Environmental Monitoring Program and provide us with an evaluation of those changes. If you require further information in regard to this request, please contact Dean Houston (Ext. 28593), Project Manager.
Robert L. Tedesco, Assistant Director for Lice.ising Division of Licensing
Enclosure:
As stated cc w/enclosum:
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NRC FORM 318 810. 00) NRCM O240 '
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Mr. Dalwyn R. Davidson Vice President, Engineering The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 cc: Gerald Charnoff, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N. W.
Washington, D. C.
20036 Donald H. Hauser, Esq.
Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 U. S. Nuclear Regulatory Commission Resident Inspector's Office Parmly at Center Road Perry, Ohio 44081 Donald T. Ezzone, Esq.
Assistant Prosecuting Attorney 105 Main Street Lake County Administration Center Painesville, Ohio 44077 Tod J. Kenney 228 South College Apt. A Bowling Green, Ohio 43402 Daniel D. Wilt Wegman, Hesiler & Vanderberg 7301 Chippewa Road, Suite 102 Brecksville, Ohio 44141 Jeff Alexander 920 Wilimington Ave.
Dayton, Ohio 45420 Terry Lodge, Esq.
915 Spitzer Building Toledo, OH 43604 l
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ENCLOSURE 1 mt..
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w 4 Director of I?aclear Reacter Regulation Attention:
Mr. A. Schwencer, Chief Licensing 3 ranch 2 Division of Licensing U. S. Ihclear Regulatery Ccenission
'n'ashington, D. C.
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Perry IhcLear ?cwer ?lant Docket Nos. 50 kk0 & 50 Lh1 Construction Per=it Ncs.
C??R-lh8 and CP?E-149
Dear lfr. Schwencer:
Invironnental Monitoring hepar The Cleveland Electria Illuninating Cc pany plans to rike the follCwing Changes in the EnVirCnnental MCnitoring Prog 2= during constraction of the two unit Perry Nuclear ?cwer Plant:
1.
Reduce the frequency of lake water sa=pling and analysis frc= =cnthly to quarterly.
2.
Eliminate the quarterly ecliection of benthic samples.
3 Alter the secpe of the cranefly crchid surva="ae prega i
frc= quantitative to qualitative Ocnitoring these plant populations.
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Ter=inate the raptor pre pas following the 1930 breeding season.
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The rationale for these changes are addressed in the attached recon =endations frc: cur environ = ental consultant, the :.!S Corporation.
Very truly yours, 4
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i Dalwyn R. Davidsen Vice President Syste= Engineering and Construction Enclosures (2) cc:
Mr. James G. Keppler Region III Cffice of Inspection and E1 c:ce=ent U. S. Nuclear Regulatory Cc--d ssion Glen Ellyn, IL 60137 I
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February 20,19SO ESG-80-54 PY/NUS-CEl-301 Mr. Carl Banks The Cleveland Electric 111uminating Company 10 Center Road North Perry, Ohio 440S1
Dear Carl:
The terrestrial ecology construction monitoring program was discussed at our meeting in Rockville on January 23,1980, we suggested that this program should be reduced in scope and that the NRC be informed of the reduction.
The current construction monitoring program consists of three sepa ate programs:
(1) cranefly orchid, (2) raptors, and (3) vegetauon. Because we have shown no statistical differences between years,it is concluded that construction has had no effect on the cranefly orchid populations; therefore, we recommend that this program be terminated. As par: of a limited surveillance effort in conjunction with vegetation monitoring, we can continued to qu.ilitatively monitor the orchid populations and detect deliterious changes should they occur.
The raptor program should be continued through the 1980 breeding season and
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then termir ated. This would hopefully refute or substantiate a correlation between a declining screech owl population and severe winters.
The vegetation monitoing program consists of annually photographing the site with color infrared film in late summer. Combined with ground reconnaissance, this is a means by which to Jetect vegetative stress and it also provides a permanent record of natural succession /Jand use conditions. We recommend that this program be continued until the preoperational monitoring program is initiated.
If there are any questions relative to these tasks please let me know.
Sincerely, Q
.9 Rodney J. Davis Project Manager -
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CEI/NED G. Friday R. Pellek
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- " 54S.7010 March 19,1980 E5G-80-79 PY-NUS/CEI-306 Mr. Carl Banks The Cleveland Electric Illuminating Company 10 Center Road North Perry, Ohio 44081
Dear Carl:
The aquatic ecology construction monitoring program was discussed at our meeting 15.1980. It is 23,1980 and in your letter of February in Rockville on January suggested that this program be reduced in scope and that the NRC be informed of the reduction.
CEI initiated construction at Perry late in October 1974 and initiated construction monitoring in November 1974. The monitoring program was submitted to NRC (then AEC). The general thrust of the monitoring program was to study those water parameters which would indicate deviations from ambie enough to allow corrective action to be taken.
Since 1974 to the present the PNPP construction monitoring program included i
l the following physical, chemical and biological parameters:
l Monthly pH, temperature, dissolved oxygen, total solids, dissolved solids, suspended solids, turbidity, oil and' grease, BOD, nitrates, phosphates and 1) j bacteria.
2)
Spring, summer and fall benthic macroinvertebrates.
l All samples are collected at stations 1,5 and 9. During barge slip construction and dredging, the sampling frequency was increased to weekly. Monthly status l
reports of the water analysis were submitted to CEIin support of their overall l
monitoring programs.
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',a. ch 19,1930 Fage Two During the five year monitoring program at the PNPP only slight deviations from ambient water quality were detected. Elevated levels of suspended solids and turbidity in the water column was observed during periods of surhce run-off and construction and dre j ing of the barge slip. These slight deviations from the g
norm were very localized and temporary, and further, were to be expected. No significant impact would be expected from these slight changes. Occasionally, elevated levels of fecal coliform and streptococcus appeared from time to time, but these too, were localized and temporary. In all cases, the water column returned to ambient within a month. CEIis to be commended for its realistic attempt to minimize construction impacts to the lake during a period of major construction activities.
In view of the fact that five years of construction monitoring data has indicated no significant construction impacts, and further, that sufficient data has been collected at the site since 1971, we concur with CEI that
.aduction in the monitoring program is in order at this time. Therefore, we recommend that quarterly benthic sampling be dropped and monthly physical and chemical parameters be reduced to quarterly. These recommendations should remain in affect until the preoperational monitoring phase at which, time appropriate changes in aquatic monitoring of the lake will be considered.
Sincerely, K?er I
Rodney J. Davis Project Manager cc:
c.El/NED D. Caf aro l
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4 ENCLOSURE 2
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Di_ etor of helear Reactor Resule+.icn Atta: Mr. William H. Regan, Jr., Chief Envirec:nental Projects Ersuch 2 Divisien of Site Safety & 3:rrirer=w=tal Analysis U.S. Nuclear Regulatory Cc:missica Washington, D.C.
20555 Perry Nuclear Power Plant Docket Nos. 50 hhO & 50 khl
Dear Mr. Regan:
In accordance with the.My 7,1978 telephene eenversatten hetween Carl h Ire af our Ccapa=y a:d Ecbert A. Gilbert of ycur office, a copy of the cur:ent Envirc=: mental Mcoitering Prc6rsa developed for construction of the Perry P'*'*ar Pcwer Plant is enciesed for ycur review and approval.
Please feel free to ecstaet us if ycu have a=y questions.
l Very t:9217 yours, i.
C,'.;. S 6,
',JI 4-Dalwyn'R. tavidson Vice President - Engi:ter'4 l
Enclosure (1)
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ENVIRONMENTAL MONITORING pROGRAY DURING CONSTRUCTION OF PERRY NUCLEAR POWER PLANT UNITS 1 AND 2 For the protection of the environment during construction of the Perry Nuclear Power Plant, a three-part Monitoring Program will be followed.
Part One relates to general work practices and addresses vehicle movement, dust control, noise control, and chemical and solid waste management.
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Part Two covers specific construction activities which merit special attention because of potential impact.
Part Two includes site clearing and grubbing, excavation, de-watering, barge slip and of f-shore structures.
Part Three involves an ecological monitoring program to observe im-pacts of construction in adjacent areas or to confirm that such impacts have not occurred.
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l This program describes construction practices and monitoring l
programs which must be followed to limit environmental im-pact.
The Applicant will provide administrative controls which assure prompt corrective action when any departure from described practices occurs.
Compliance with Parts One and Two will be assured by a weekly reconnaissance of the site by the Applicant's inspector (s).
In addition.
_ag the first two years of construction when most of the site I
clearing will take place, a reconnaissance of erosion and
sedimant control structures will be made within three working days after every rainstorm exceeding.2 inches of precipitation.
Observations on each of the points covered in the program will be maintained in written records which will be kept up-to-date and available for inspection by the Regulatory Staff at all times during normal working hours.
These records shall indicate the corrective actions prescribed by the Applicant's inspector (s) for any noted deviation from this program.
Completion of the prescribed corrective action as noted during subsequent inspections will be documented therein.
Applicant's management will receive monthly reports during the first two years of construction and every two months (bi-monthly) thereafter with respect to Parts One and Two of the Environmental Mocite. ring Program from its own inspector (s).
A summary of these reports will be submitted to the NRC Region III Office of Inspection and Enforcement and to Applicant's management on a semi-annual basis.
The Applicant will assure that contractors and subcontractors are familiar with and that their construction practices are in accordance with the Environmental Monitoring Program as described in Parts One and Two.
Steps will be taken by the Applicant to familiarize contractors with the Environmental Monitoring Program.
The Environmenta' Report submitted at the Operating 'icense Stage will contain a discussion of the Construction Impact Control Program including observations of environmental effects observed during the course of construction.
Changes in the philosophy or scope of the Environmental Monitoring Program will be made only with the approval of the Regulatory Staff.
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pART ONE - GENERAL PRACTICES 1.
Vehicle Movement Areas where uncontrolled traffic can cause severe damage, such as undisturbed open spaces, will be off limits to all construction vehicular traffic.
For woodland areas, al'1 vehicular traffic will stay within the roadway, access corridor, or utility rights-of-way.
Traffic will be restricted from crossing streams or stabilized drainageways, except at approved stabilized
' crossing locations.
The construction area will be fenced to establish control over access and to implement a construction security program.
Cyclone fencing topped with three strands of barbwire will be utilized.
2.
Dust Control i
Dust, smoke, engine exhausts and concrete plant opera-i l
l tions represent air pollution potentials which can be controlled.
Dry-weather wetting or the paving of the most traveled conscruction roads will reduce dust f
generated by vehicular traffic.
Bare areas will be seeded to provide a ground cover where necessary.
Fuel l
burning equ',pment will be maintained in good mechanical l
order to reduce excessive emissions.
The concrete batch l
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plant will be equipped with a dust-control system to l
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avoid excessive releases of cement dust.
Open burning will be prohibited at the construction site.
Dust resulting from vehicular traffic on unpaved haul roads and access roads during dry weather will be controlled by spraying problem areas with water as necessary.
Dust from wind action on off-road, cleared areas will be minimized by the reseeding of bare areas as part of erosion control efforts.
Uses of gravel on heavily traveled roads and parking areas during early construction activities will further eliminate potential dust problems.
Visual observations for excessive dust will be made by the Applicant's inspector (s) during the weekly recon-naissance inspections and more frequently during the initial stages of construction activity when the potential for dust problems is increased due to site clearing and grubbing.
Existing dust control measures will be modified if necessary.
3.
Noise Control Standard noise control devices on trucks and other equip-ment will be maintained in effective condition to reduce excessive and objectionable vehicular noise.
Noise levels at the site boundary will be documented by surveys using a portable sound level meter.
Surveys will be conducted every two conths during the first two.
years of construction and semi-annually thereafter.
The semi-annual surveys will be conducted in the spring and fall.
4.
Chemical and* Solid Waste Management A settling basin will be constructed in the rechanneled stream east of the plant to intercept runoff from that Basins of similar design will be constructed area.
northwest of the concrete batch plant area to handle runoff from that area.
Groundwater pumped from con-struction excavations will be discharged to these basins.
The basins have been sized to permit settling of run-off and wastes prior to discharge of the decantate to Lake Erie.
Liquid wastes such as fuels, lubricants, and bitumens, will be deposited in containers for subsequent removal to of f-site locations for disposal in accordance with l
appropriate standards.
Adequate care will be taken to limit the handling or storing of liquids of this nature I
in close proximity to major drainage areas, thereby minimizing the possibility of damaging spills to site streams.
Construction scrap and debris will be collected at designated on-site areas for salvage or burial.
Burial of solid wastes will take place at designated on-site landfill areas in accordance with standard cut and fill practices. _.
i pART T'40 - SPECIFIC CONSTRUCTION ACTIVITIES 1.
Site Clearine and Grubbing
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structures will be installed concurren't with Sediment clearing and grading operation.
Stream stabilization work will be performed concurrent with clearing and l
grading operations in the watershed.
Clearing and grubbing of the site will be liiS_ted to the area needed to construct the facility, store construction materials and plant equipment and dispose of solid construction waste materials within the con-fines of the site.
Unmerchantable timber, timber wastes (slash), brush and tree limbs will be shredded and used as mulch for erosion control on spoil disposal areas.
Erosion in the construction area will be controlled by providing piped drainage, intercept and berm ditches, and ground l
cover where necessary.
Earth materials will be deposited in selected areas and protected by reseeding where necessary to minimize sediment transport of surface l
runoff to Lake Erie.
Drainage into Lake Erie will be maintained during construction.
permanently established spoil areas will be graded and landscaped to natural drainage patterns.
l Settling ponds will be provided.
l -
Three sedimentation ponds er impoundments will be established to minimize the runoff of turbid water to Lake Erie.
A dam on the larger stream draining the western portion of the site will establish a pond of approximately 900,000 cubic feet.
A dam in the northwest drainage area will establish a pond of about 90,000 cubic feet, and a dam in the re-channeled stream east of the plant will establish a pond of approximately 150,000 cubic feet.
If upon visual inspection the capacity of a sedimentation pond appears significantly reduced, it will be dredged to restore its capacity.
Settling ponds will be maintained for the duration the ground is uncovered.
2.
Excavation and Soil Deposition One of the first major operations required under the excavation program is the construction of principal sediment control structures and the implementation of an overall soil erosion control program to stabilize the site during construction.
The excavation program will include rerouting of the stream east of the plant, subgrades for railroads and access roads, drainage structures and channels, excavation and drainage of the power block area structures, circulating water lines and pump house, intake and discharge tunnels, and auxiliary and containment buildings.. -. _..
Excess spo t1 removed by excavation will be utilized to construct berms along Parmly Road and to fill a depressed area north and east of the concrete batch plant.
During and i= mediately following the fi111ng of each spoil disposal area, the fill will be graded to acceptable slopes to minimize potential erosion problems before turf cover is established.
Until the vegetation has stfoilized the disposal areas, maintenance will be performed to correct local areas of excessive erosion.
The drainage from spoil areas, during and after construction, will be des Ined to follow the natural drainage patterns now existing.
Diversion dikes will be constructed to form the settling basins.
Spoil areas and other areas subject to erosion will be graded to divert surface flow to the settling basins.
Spoil areas will be graded and maintained to minimize erosion.
l 3.
Dewatering As the lacustrine deposits are the primary water-bearing stratum and are of variable permeability, groundwater j
will be intercepted near the base of the deposit by a l
series of interceptor drains and sumps.
Additional l
interceptor drains and sumps may be required; however, the amount of groundwater infiltration within the upper and lower till deposits is expected to be minimal. l
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Experience with similar excavations in the Cleveland area indicates that the above measures will be ade-quate to control the groundwater within the excavated Should zones be encountered where 'ad'dit'ional areas.
measures are required, cutoff walls of sheet piling or of slurry will be installed to control the ground-water intrusion.
Groundwater and precipitation collected in the inter-ceptor drains and excavation sumps during construction will be conveyed to the surface run-off settling basins.
Possible dewatering effects on groundwater levels will be monitored at test wells set up around the periphery of the plant site excavation.
This will be done once every two weeks during the first three years of con-struction and once every two months thereafter.
4.
Barge Slip Dredging in Lake Erie will be required in 1976 to coustruct the channel for a barge slip, and limited redredging may be required in subsequent years for silt removal.
This barge facility will be used to deliver heavy components, including reactor pressure vessels, to the site.
Initially, material dredged l
from barge slip and approach channel construction will be disposed of on-shore.
Materis. removed from the slip and approach channel during subsequent maintenance dredgiag may be used to replenish shore-line lost due to erosion and wave action in the w =
vicinity of the slip.
Due to the limited extent and frequency of this dredging, there should be no signif-icant environmental impact from this construction activity.
5.
Off-Shore Structures Construction of the intake and discharge facilities will be carried out by means of a drilling platform.
These platforms will be positioned near the center of the hole to be drilled and then hydraulically jacked up from the lake bottom into the working position.
The drilling of the intake and discharge riser tunnels will require 6-foot diameter shafts.
The drilling will be accomplished inside of a casing anchored to the lake bottom, such that all spoils material will be brought up the casing above water and can be loaded into barges for disposal either on-shore or at an approved lake disposal site.
By means of this con-struction technique, only a minimal lake bottom area will be affected and, therefore, this operation should have no significant environmental impact.
PART THREE - ECCLOGICAL MONITORING PROGRAM 1.
Terrestrial This monitoring program is designed to detect changes in sensitive para =eters at the Perry Nuclear Power Plant site.
Its functions will be two-fold; to provide information needed to decide whether an observed change is caused by construction-related activities or by other environmental factors not related to cocstruction; and, in the case of deleterious changes which are caused by construction, to provide guidance in recommending changes in procedure to minimize or eliminate, if practicable, the causes of the observed changes.
Populations of Tipularia discolor will be marked for easy location during semi-annual visits.
Individuals of each population will be counted in t'ae spring of esen year.
Individuals which blocm will be counted when blooming occurs in the summer to discover if the popula-tions are stable, increasing, or decreasing.
Because the densities of these populations are very low and individuals are represented only by single leaves, density and cover will not be calculated.
Reports at the end of the first year of orchid monitoring will describe and locate the Tipularia populations.
In later years of study, reports will cite evidence of any and all observed changes, whether related to disturbance or not.
Raptors will be censused in the spring of each year to determine if site populations are increasing, decreasing or stable.
Yearly reports will show approximate raptor territories observed in the field.
2.
Aquatic The basic objective of, establishing a const".ction aquatic monitoring program is ultimately to prevent unnecessary stress brought about by plant construction activities and to protect the aquatic environment.
The program is designed to be sufficiently comprehensive in monitoring all major elements of the aquatic system that could reasonably be expected to detect effects from plant construction.
As construction monitoring data are obtnined, data evaluation will be accomplished early enough to implement remedial actior., should such action be required, before permanent damage to the ecosystem has occurred.
As noted in Chapter 4 of the PNPP Environmental Report, the primary effects of construction of the pNPP on Lake Erie will be the disturbance of the benthic community due to increased turbidity from construction of the j
barge slip and approach channel.
In addition, sanitary i
t wastes from the factory-built sewage treatment units I
will be discharged into Lake Erie.
During the construction of the pNPP, the following physical
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and chemical parameters will be analyzed on a monthly basis:
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PE, total solids, dissolved solids, suspended solids, turbidity, oil and grease, BOD, nitrates and phospho-rous.
The samples will be collected along transects 1, 5 and 9.
If monthly samples show unusual or un-anticipated results during b,arge slip construction and dredging, the sampling frequency will be increased to weekly during these activities.
The biological monitoring program will include benthic invertebrates and bacteria.
Benthos samples will be taken in spring, summer and fall at the inner and outer-most locations of transects 1, 5 and 9, when possible, realizing that the lake bottom in this area is not suitable for sampling benthos using conventional methods.
Bacteriological sampling will be performed at the same time water quality sa=ples are taken and will include analyses for standard plate count, coliform, fecal coliform and fecal streptococcus..
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