ML20054J714

Environ Protection Control Program,Revision 2

ML20054J714
Person / Time
Site:	South Texas
Issue date:	06/14/1982
From:	Flex B, Lawhu R, Mccullough HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20054J711	List: ML20054J710 ML20054J714
References
PROC-820614, NUDOCS 8206290483
Download: ML20054J714 (21)

Text

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g S0t'TH TEXAS PP0JTCT

!TCLEAR GENERATI::C STATIO:

E:TIR0!!!'E :TAL PROTECTIO:' C0:: TROL PROGFJ.".

Revision ;

Bechtel has reviewed the subject document, and concurs with its contents.

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Proj ect !!anag'er Da t e Houston Lighting & Power has reviewed the subject document and believes that it fulfills the commitments as set forth in the South Texas Project Final Environmental Statement or as amended by the Ibclear Pegulatory Commission.

Any proposed changes to this document must be approved in writing by HL&P prior to amending the document.

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Principal Enhineer, Environmental Planning and Assessment Date UVf0 % l WB/B 2-e Nanager

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I'anager { EnvironmentM Protection Department

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11 Pevision 2 8206290483 820624

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PDR ADOCK 05000498 A

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b ENVIRO 124 ENTAL PROTECTION CONTROL PROGRAM Revision 2 South Texas Project Electric Generating Station H

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TABLE OF CONTENTS SECTION 1.0--INTRODUCTION Page 1.1 Project Description 1

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1.2 Pu rpose 1

1. 2.1 Revisions 1

1.3 Scope 1

1.4 Responsibility 2

1.4.1 Bechtel Project Manager of Construction 2

1.4.2 Bechtel Site Environmental Coordinator 2

1.4.3 Bechtel Engineering Support 2

1.4.4 HL&P Environmental Protection Department 2

1.4.5 Contractors 3

SECTION 2.0--ENVIRONMENTAL PROTECTION METHODOLOGY l

2.1 Plant Site 7

2.1.1 Runoff and Erosion Control 7

2.1. 2 Storage of Fuel, Oils, and Solvents 7

2.1. 3 Solid Waste 8

2.1.4 Sanitary Waste 8

2.1.5 Oil, Chemical, and Hazardous Wastes 8

2.1.6 Air Contaminants Control 9

2.1.7 Noise Control 9

2.1. 8 Traffic Control 9

2.1.9 Protection of Natural Streams 9

2.1.10 Landscape Restoration 10 2.1.11 Wildlife Protection and Control 10 2.2 Transmission Line Construction 11 l

SECTION 3.0-MEASURES AND COPTROLS TO LIMIT ADVERSE ENVIRONMENTAL EFFECTS DURINC CONSTRUCTION i

3.1 Dewa tering 14 3.2 Excavation 14 1

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TABLE OF CONTENTS (Cont'd)

Z8Ee SFCTION 4.0--SITE ENVIRONMENTAL COORDINATOR CENERAL DUTIES 4.1 Monitoring 15

4. 2 Indoctrina tion 15

4. 3 In terface 15 4.4 Documentation 15 4.5 Corrective Action 16 4.6 Reporting 16 i

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LIST OF FIGURES Page 1.1-1 Proj ec t Imcation 4

1.4-1 Site layout 5

1.4-2 EPCP Fesponsibility Flowchart 6

2. 2-1 STP Transmission Routers 13 f

111

SECTION

1.0 INTRODUCTION

1.1 PROJECT DESCRIPTION The South Texas Project (STP or Project) is located on 12,300 acres in Matagorda County, Texas, approximately 15 miles southwest of Bay City I

along the west bank of the Colorado River (Figure 1.1-1).

During the operation of the plant, the Project will contain two 1250-MWe units, a 7,000-acre cooling reservoir. a cooling pond, attendant pumping and dis-charge facilities and approximately 305 miles of new transmission line corridors originating from the STP site.

1.2 PURPOSE i

l The purpose of this Environmental Protection Control Program (EPCP or Program) is to ensure that construction activities at the STP comply with the environmental conditions set forth in the Construction Permit (CP), the Final Environmental Statement (FES) and other environmental commitments and conditions.

1. 2.1 Revisions Revision 1 of the EPCP was issued to incorporate changes in construction practices as a result of modification of construc-tion permit commitments and completion of construction activi-ties.

In May 1978, the NRC amended the STP construction permit to allow the decommissioning of two sedinentation basins and to delete a requirement to cover the barge slip with stabilizing material. Completed construction activities include relocation of Little Robbins Slough and construction of the barge slip.

Revision 2 was issued to reflect the changes that resulted from the change in the management organizations from Brown & Root to Pechtel in the First Quarter of 1982.

Sections, which addressed construction activities completed, were deleted.

1.3 SCOPE j

The scope of the EPCP covers all construction efforts on the l

12,300-acre site and along the new transmission line corridors.

Also included is an ecological monitoring program conducted during the con-struction period.

I 1

1.4 RESPONSIBILITY The South Texas Project (Figure 1.4-1) is jointly owned by Houston Lighting & Pbwer Company (HL&P), Central Bower & Light Company (CP&L),

the City of San Antonio, and the City of Austin. HL&P has been designated as Project Manager for the owners and is responsible for j

implementation of all environmental programs. An EPCP Responsibility Flowchart is provided in Figure 1.4-2; the following descriptions pertain to the key responsible parties.

1. 4.1 Project Manager of Construction (Bechtel)

The Bechtel Project Manager of Construction has overall responsibility for the management of all construction-related activities associated with the STP Project, the EPCP, and with the activities of the Site Environmental Coordinator.

1.4.2 Site Environmental Coordinator (Bechtel)

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The Site Environmental Coordinator (SEC) reports through the Project Field Engineer to the Project Manager of Construction, hence, through the established organizational chain to the Project Manager, and has direct responsibility for monitoring, interfacing, documenting, and reporting on all construction-related activities to ensure compliance with the Program on the 12,300-acre site.

(See Section 4.0 for a discussion of the SEC's general duties.)

1.4.3 Engineering Support (Bechtel)

Bechtel Engineering provides technical assistance to the SEC, when necessary.

1. 4. 4 Enviroprental Protection Departrent (HL&P)

The Houston Lighting & Power Company Environmental Protection De pa r tmen t (EPD) conducts surveillance of EPCP implementation, interfaces with selected regulatory agencies, supervises the construction phase ecological monitoring program (detailed in Section 2.1.11), and reviews the status of commitments listed in l

Section 4.5 of the FES with the SEC and with the HL6P Transmission Department.

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1. 4. 5 Contractors Contractors have tae responsibility to ensure that all phases of the Program are implemented in their area under the guidance of the SEC.

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I T Y C T E I J L O 2 I 2 R B T P 8 I R 4 S A S 1 N H 1 A O C X S P E E T S W R I E O U T N R L G H U F I T P F U C O P S E l l l l lJ_ 1 I la tnt t r non r ce eie Peg e e mtm P g &ja t nct l l 8 a l l oer I. L on i H ra L n S rt a PM H a i op M vre nPD E re l g n ar s a o t o r l t r n i t r nt o ece a t cde ea t t eg M c el e emn c hja f u jen tni a con t or oii i od r era c t rF g Srr t BPM e s P n io n j n E vo o o o nC C r C E P eca f n r o g e i n t t tir n c cre I e eeg / r jea e i onn n c D ria o n P gM e i a l n c s l a E a i l c f v i i r r e n e e v h t p r c n u u e I S S T !lIl ,l! llll'

SECTION 2.0 ENVIRONMENTAL PROTECTION METHODOLOGY 2.1 PLANT SITE 2.1.1 Runoff and Erosion Control The magnitude of clearing and grading activities on the Project requires a significant effort to control runoff and erosion. Existing vegetation and soil are to be removed from required areas on an as-needed basis by stripping, grubbing and excavat-ing to facilitate the grading of the site to design elevations. Excavated materials are then hauled to designated stockpile, spoil, or fill areas. Surface runoff from cuts, fills, spoil areas, etc., is to be controlled by ditches, dikes, and/or berms and directed away from the site to Little Robbins slough or the Colorado River. Runoff from undisturbed areas is to flow natu-rally. Drainage ditches are to be excavated at gradients which make their sides less conducive to erosion; whenever possible, berms, ditches and other disturbed areas are to be protected by seeding with grasses which are adapted to the heavy moist soils of the site. Additionally, long-term construction roads are to be surfaced with stabilized material to resist wear and erosion due to traffic. 2.1.2 Storage of Fuel, Oil and Solvents The SEC will approve Field Requests (F.R. 's) for the purchase of solvents and chenical products. The SEC will provide by memo-randun any special recuirements for storage or handling of the - product to the department initiating the F.F. All storage will be in a bermed area designed to contain a spill from the single largest container in the berm plus additional room for precipita-tion. All drums and bulk storage tanks will be marked or color coded as to their content with indelible marking. Each department will keep accurate inventory of the material stored including an assessment of the general condition of the storage area. These records will be available for inspection by the SEC. 7

Bermed storage areas will be constructed using stabilized mate-rial and designing berm side slope to minimize erosion. Drip pans will be placed under the spigots of solvent drums to pre-vent spills from contaminating the soil. All spills will be reported promptly to the SEC. The SEC will approve all new storage areas prior to construc-tion. 2.1.3 Solid Waste Solid waste generated during construction activities will be collected, stored, and sorted for salvageable items. Merchan t-able waste is to be hauled from the Project and sold to scrap dealers. Waste concrete, brick, non-ferrous metals, PVC pipe, insulation materials, and ash from the incineration of wood, paper, and cardboard will be landfilled in the registered waste disposal pit on-site. The waste disposal pit will be excavated at a gradient which makes it possible to unload into the pit directly from trucks. Trash unloaded near the edge of the pit will be pushed into the pit on a frequent basis. A minimum of six inches of compacted soil cover will be provided weekly to reduce windblown trash. When the pit has received waste up to within two feet of the natural ground surface it will be decom-missioned by covering and compacting at least two feet of clay on top of the pit. 2.1. 4 Sanitary Waste Per EPA and TDWR requirements, sanitary waste receives primary treatment prior to being discharged. The construction phase system (activated sludge) discharges effluent into the Colorado River via a drainage ditch. The opera tional phase system (extended aeration) discharges into the cooling reservoir. Where it is infeasible to provide construction personnel access to restroom facilities connected with these systems, portable chemical toilets are utilized. Wastes from the portable facilities, along with sludge removed from the treatment plants, will be removed from the site by contract carrier for disposal at a local disposal area which has been inspected and approved by a }Stagorda County health official. 2.1. 5 011, Chemical, and Hazardous Wastes During construction hazardous and nonhazardous chemical wastes (i.e., paint thinner) will be collected, stored, and disposed of by method approved by the appropriate state or federal agency. This activity will be under the supervision of the SEC. During the testing and start-up operation of the denineraliza-tion systen, chemical cleaning of the reactor vessels, the pip-8

ing and equipment of the primary coolant, and the secondary feed systems, large volumes of chemical waste will be generated. Petal cleaning wastes and chemical wastes generated prior to completion of the operational chemical waste treatment system will be collected on site and either removed and disposed of by a licensed contractor or collected for treatment and ultimate discharge to a cooling reservoir. Waste oil will either be sold to a commercial operator for L recovery or disposed by a licensed contractor. l 2.1. 6 Air Contaminants Control i Du s t caused by the movement of construction vehicles is con-trolled by periodically spraying unpaved areas with water provid-ed by runoff basins, dewater discharge, and washdown wastewater. The frequencies of spraying and the quantity of water used are to be determined by visual inspections and exist-ing weather conditions as necessary to control dust. l All permanent roads will be paved as soon as practical during i the construction period. Parking and laydown areas will be treated with lime and covered with shell, gravel and/or lime-stone to provide stability and reduce dust. Equipment which emits large quantities of dust, e.g., the batch plant, and storage silos, will be equipped with filter bags and/or water spray systems as required by applicable state per-mits. Burning of-creosoted wood, tires, plastic, and chemical products is prohibited. I 2.1.7 Noise Control Mufflers are to be used wherever practical to reduce noise from construction equipment. Noise abatement equipment is to be main-tained by rechanics at regular intervals. Pile driving is nor-mally to be performed only during daylight hours. 2.1. 8 Traffic Control Traffic control measures will be implemented, as required, to control traffic at the plant site. 2.1. 9 Protection of Natural Strears Wastewater from washing vehicles and equipment will normally be collected in basins located in the concrete production area. The basins will function to capture waste lubricants and reduce the suspended solids. Treated water will be used for dust con-trol by dispersion over construction roads or by other methods 9

approved by the Site Environmental Coordinator. When it is not feasible to bring heavy equipment from remote locations to the assigned washdown areas, portable cleaning equipment are dis-patched to the field and used to clean those parts of the equip-ment encumbered by mud. In this case, the wastewater is direct-ed over land before entering natural or man-made drainage chan-nels. As required by 40 CFR 112, the Project will have a Spill Preven-tion Control and Countermeasure (SPCC) Plan during the construc-tion period. According to the SPCC Plan, bulk quantities of gasoline, diesel, fuel oil, waste oil, and lubricants will be stored within berms capable of containing potential leaks from the storage containers. Point source discharges to natural waterways will be monitored as required by state and federal permits. Samples will be col-lected, stored, and shipped to an approved analytical laboratory according to internal Bechtel procedures. The data will be l transmitted to the HL&P Environmental Protection Department for l reporting to the appropriate agency.

2. 1. 10 Landscape Restoration Cleanup and restoration of areas affected by construction activ-ities will be conducted at the end of the construction period; temporary parking areas, temporary roads, and the land occupied by the batch plant will be cleared and relandscaped to conform with the natural surroundings upon completion of construction.

2.1.11 Wildlife Protection and Control Where possible, periods of peak construction activity will be timed to coincide with the periods of least sensitive phases in the life cycles of the more important animals on the site. As required by specific site conditions, certain wildlife species may need to be controlled during construction of the power block. Control will involve either removal or termination of the problem species. All applicable state and federal regulations must be followed. Chemical sprays for the control of insects or poison for con-trol of rodents are to be used according to manufacturer's speci-fications. The purchase of these chemicals is to be approved by the SEC prior to purchasing. In addition to the above, important species will be monitored during the construction period commencing approximately two years prior to the anticipated approval of the operating license application. The program will be conducted as described in Sec-tion 6.1.4.3.8.2 of the Environmental Report--Operating License. 10

2.2 TRANSMISSION LINE CONSTRUCTION Three new corridors will be required for circuits leaving the STP switchyard. The three corridors are the eastern corridor to Velasco substation, the southern corridor to Plessing substation, and the main corridor to Danevang at which point this corridor branches and continues to Holman and Hill Country substations. shown in Figure 2. 2-1. The transmission corridors are The following mitigative measures will be implemented by STP during the construction of the transnission lines to minimize construction impact on the terrestrial ecosystem. Clearing of vegetation and overgrowth necessary to permit construc-a. tion will be kept to a minimum. TYees, shrubs, and vegeta tion, in areas where clearing is unnecessary, will be protected from damage during construction. Trees of timber quality, that are cleared, will remain the property of the landowner. Other trees, vegetation, and debris will be chipped and spread as mulch or disposed of in accordance with regulations for " Outdoor Burning in Rural Areas" (TACB Regulatior 1, bection 111.2 (6)). b. tb herbicides will be used for clearing purposes, thus avoiding any contamination of water or endangering of wildlife. Where vegetation must be cleared from stream banks and highly erodi-c. ble areas along the transmission right-of-way, these areas will be reseeded with adaptive species of grasses or vegetation to help con-trol erosion. Construction in these areas will be scheduled during seasons of low precipitation. Wherever possible, roots of woody plants in the riparian woodlands will be left intact to help prevent erosion. d. In croplands, construction will be scheduled to avoid agricultural production periods. If field crops are disturbed or destroyed, the f arm operators will be compensated and construction surface marks will be removed by discing. Construction in the known booming ground of Attwater's Prairie e. Chicken will be scheduled to avoid their mating and nesting period, January 1 to June 1. Transnission lines which cross open water of estuarine areas will be visibly flagged with colored balls to mini-mize avian collisions, f. Wherever possible, all-terrain track mounted or rubber tire equip-ment will be utilized in marshlands to mininize the impact on sensi-tive marshland habitat and associated biota. Existing public and private roads will be used for access to the g. transnission corridors. At points where transmission right-of-way intersect public roads, sufficient brush and trees will be arranged to screen the cleared right-of-ways. 11

Transmission line construction will be conducted by each STP partici-

pant, i.e., each u tility will construct the line it owns. Each partici-pant is responsible for conducting periodic surveillance to determine the adequacy of EPCP implementation and shall maintain sufficient records to furnish evidence of compliance with all environmental conditions.

The UL&P Engineering Department will review monthly construction status reports provided by each participant. These reports, which will include a daily compliance checklist for all applicable FES commitments, will be forwarded to the HL&P Environmental Protection Department. Each participant will be responsible for notifying the HL6P Environmental Protection Department of any unevaluated construction activities or of unexpected harmful evidence of irreversible damage pertaining to transmission line construction. i 12 i

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SECTION 3.0 MEASURES AND CONTROI.S TO LIMIT ADVERSE ENVIRO?2fENTAL EFFECTS DURING CONSTRUCTION 3.1 DEUATERING Dewatering for Units 1 and 2 commenced in November,1975, and will extend through 1983. Discharged water from this system will be directed to drainage ditches for use in dust control, and well-jetting, while the remaining flow will be directed into the Colorado River. The zone of dewatering influence will be extended to the extent necessary to adequately control water levels in the power block areas. Once design j and construction requirements are satisfied, the groundwater around the facility will be raised to normal elevations lLn a controlled manner.

3. 2 EXCAVATION Excavated materials will be hauled to designated stockpile, spoil, or fill areas.

Suitable material excavated from the power block and con-struction support facilities will be used to build up the shop area, plant roads, and the railroad. The balance of the material will be spoiled, graded, and seeded with grasses to minimize erosion. l l l 14

SECTIOM 4.0 SITE ENVIRONMENTAL C00RDIMATOR GENERAL DUTIES 4.1 MDNITORINC The monitoring responsibility of the Site Environmental coordinator requires primarily interpr etation and a ecmprehensive understanding of the Program, FES commitme" ts (Section 4.5), and J oen1, state, and feder-al permits / regulations. lased on this interpretation and understanding, the SEC visually inspects the construction, site for both compliant.and noncompliant items. 4.2 INDOCTRINATION Formal and informal meetligs are held by the SEC and the Project Field Engineer with responsible contractor personnel to advise.them of proper environmental /constructio1 protection techniques. 4.3 INTERFACE As directed by the Project Field Engineer the SEC is Tesponsible for interfacing with Project personnel at the following levels : _c 1. Contractors - (1) for interpretation of the Program, co nitments,- permits, regulations and internal Bechtel environmer..1' trotection procedures; (2) for discussion of proper environmental / construction techniques; and (3) for identification and, resolution of 7;- noncompliant items. ^ l 9, 2. Federal, state and local environmental authorities - during inspec-tions. _f 3. Houston Lighting & Power Environmental PrEtection Department - ~ during surveillance and to provide evaluations related to environmental impacts from ongoing activities and scheduled items. d' j. 4.4 DOCUEENTATION r; The Site Environnental Coordinator will maintain a lo'g book which will e be available for review by authorized parties (NPC inspectors. Proj ec t Engineering, Project Field Engineering, FL&P EPD personnel, and HL&P and Bechtel Panagement) during normal working" hours in the presence of the SEC. All activities pertinent to the Program (deviations or compliance - field and laboratory results, monitoring information, and i resolutions / recommendations) will be documented in the log book. Noncompliance with the EPCP shall be noted and classified as either a Minor Deviation or a Violation. ,A minor ' deviation is 9 noah 6mpliant activity which has little impact on'the effectiveness of the EPCP and is t 15 /

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easily corrected without a significant expenditure of manpower and A violation is a noncompliant activity which has a significant cost. impact on the environment, the effectiveness of the EPCP, or will require a significant expenditure of manpower and cost to correct. 4.5 CORRECTIVE ACTION Should construction activity result in noncompliance with the EPCP and commitments made in the FES, formal action as defined in Bechtel internal porcedures will be undertaken. Should a violation occur, the HL&P Site Pepresentative shall be informed of the violation and corrective action planned. 4.6 REPORTING The SEC will submit a weekly report to HL&P; the content of the report will be as defined in internal Bechtel procedures, R / +1 / 16 M &Y p ,y ,h - ,4" ' *;w}}