ML20082A808

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WPPSS Nuclear Projects 1,3,4 & 5 Restoration Plan
ML20082A808
Person / Time
Site: Satsop, Washington Public Power Supply System
Issue date: 03/31/1995
From:
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
Shared Package
ML20082A780 List:
References
PROC-950331, NUDOCS 9504040241
Download: ML20082A808 (50)


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{{#Wiki_filter:- _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ l Washington Public Power Supply System Nuclear Projects 1,3,4 and 5 l SITE RESTORATION PLAN l i

                                                                                                                                .I i

i Prepared For Energy Facility Site Evaluation Council March 1995

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d Washington Public Power Supply System Nuclear Projects 1,3,4 and 5 SITE RESTORATION PLAN l Prepared For  ; Energy Facility Site Evaluation Council i March 1995 l l

SITE RESTORATION PLAN - SUPPLY SYSTEV NUCLEAR PROJECTS NOS.1,3,4, AND 5 March 8,1995

1.0 INTRODUCTION

In 1987 the Energy Facility Site Evaluation Council (EI SEC or Council) adopted changes to its administrative rules requiring site restoration plans for projects authorized under RCW 80.50. The requirements are described in WAC 463-42-655,665,680, and WAC 463-54-080. Initial plans were submitted for Supply System projects and approved by the Council in 1988 (Resolutions 243, 245, and 246). On May 13,1994, the Supply System Board of Directors voted to terminate plans to complete Nuclear Projects 1 and 3. WAC 463-42-665 requires that a detailed site restoration plan be submitted within 12 months after termination. This plan is submitted in fulfillment of that requirement.

2.0 BACKGROUND

The Supply System Board of Directors voted on May 13,1994 to terminate plans to complete Nuclear Projects 1 and 3. In accordance with Article III.A.2 of the Site Certification Agreements, the Supply System notified EFSEC by letter dated May 31,1994, of a significant change in construction schedules. This letter noted the project termination and stated that plans to complete the projects under the existing contractual arrangements had been cancelled. At the time of the termination vote, the Supply System and Bonneville agreed to continue preserving the plants until January 13,1995 in order to explore alternative uses for all or part of the project facilities. It was agreed that if no such uses materialized, the Supply System , would discontinue preservation, liquidate the assets and restore the sites. At the end of calendar year 1994 no new owners or alternative uses for these power plants had been identified. Accordingly, the Supply System has begun a process to close out contracts, reduce staffing, and select a contractor for demolition and site restoration activities at WNP-3/5. Work will begin at WNP-3/5 as soon as a contractor has been selected and mobilized. The beginning of site restoration at WNP-1/4 has been deferred in order to benefit from the experience gained at WNP-3/5. Once confidence in the demolition process has been established, a schedule for the demolition of WNP-1/4 will be set. In the interim, a minimal level of maintenance and security control will continue at WNP-1. 3.0 REQUIREMENTS FOR RESTORATION PLANS WAC 463-42-665 requires the submittal of a site restoration plan containing elements described in WAC 463-42-655. The Supply System's plan for site restoration consists of this report and the attached Performance Standard (Appendix A), i Page1 i l 1

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y  : saws, aren- ene.m.1, s 4 med s The Supply System has used the conditions specified in WAC 463-42-680 as its goal for restoration of Projects I, 3, 4, and 5. This rule describes the return of the site to an approximation of its pre-constructior: appearance. It will require the demolition of structures (Figures 1,2 and 3) and revegetation of the land surface. WAC 463-42-680 Site Restoration-Terminated projects. In the absence of a council determination as to the level of site restoration, restoration of the site to a reasonable approximation of its original condition prior to construction shall be required. Due to the substantial nature of nuclear plant construction (Figures 4 and 5) and limited industry ' experience demolishing such structures, the Supply System is uncertain whether these structures can be reasonably and economically removed. If demolition to grade is much more difficult or costly than anticipated, the Supply System will seek EFSEC approval of a lesser degree of removal. , l . Although an alternate use for the power block buildings has not been identified, it is recognized that the remainder of the plant sites have a high potential for business or industrial uses. As a j result, certain structures and systems may be retained for reuse. Section 3.5 contains additional l information regarding alternative uses. i l 3.1 Selection Process to Determine Level of Restoration A formal selection. process is required by WAC 463-42-655 to select the final level of restoration. Because the Supply System has selected the conditions described in WAC 463 3' 680 as its goal for restoration, no formal selection process has been utilized. Such a process is only judged necessary if a certificate holder is attempting to justify a position less than that described by EFSEC in WAC 463-42-680. 3.2 Cost / Benefit Analysis for Selected Level A cost / benefit analysis is required by WAC 463-42-655 to evaluate the costs and benefits of various restoration options compared to the relative public risk. However, since the Supply . System's plan provides the maximum level of protection for the public, no such cost /beriefit analysis has been provided. Such a study is only judged necessary if a certificate holder is attempting to justify a position less than that described by EFSEC in WAC 463-42-680. 3.3 Public Risk Associated with Site Restoration A risk is defined as an exposure to the chance of injury or loss. The risk from site restoration

          .will be produced by the foreseeable but unavoidable hazards that accompany the work or are created by the physical conditions. During the demolition phase public risk will be at its highest because of the numerous hazards produced by the ongoing work. However, these risks are easily resolved by controlling access to the area.
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  • Site Restoration Flam ,

Offsite hazards of demolition are produced by harder to control effects such as noise, increased traffic and dust. For these hazards, the short-term negative effects are minimized where possible and usually judged acceptable to achieve the final goal. There are few long-term hazards associated with a completely restored site. Because the physical structures have been removed or buried, the risk is very low. However, some risk may still exist from indirect hazards such as ground cracking due to subsidence, collapse of unfilled voids, or the contamination of groundwater by leachate from the demolition debris. These effects can be minimized by specifying the materials that can be used for fill and controlling their placement (see Section 4.2.1). 3.4 Elimination of Hazards to the Public and the Environment The elimination of hazards to the public is the goal of the EFSEC mandated site restoration requirements. The selection of demolition to grade as the final level of site restoration will achieve that goal by removing the hazards and leaving the lowest postible risk to public health and safety. The short-term hazards produced by the restoration work will be controlled and minimized by the conditions specified in the existing Site Certification Agreements and the commitments made in this Plan and the attached Performance Standard (Appendix A). These conditions are I designed to protect the surrounding environment and to minimize the unavoidable effects by pre-planning the work. 3.5 Alternatives to Restoration Although alternative uses for the power block buildings have not been identified, it is recognized that the remainder of the plant sites have value for future power plants or other business / industrial uses. The existing infrastructure of water, power, sewer, and roadways in conjunction with the existing office buildings and warehouses makes these areas adaptable to other uses. This kind of reuse avoids the cost of restoration and may prevent the disruption of undisturbed sites in other offsite locations. The site lands are currently encumbered by multiple owners, commitments, and agreements. It is expected that once these encumbrances are resolved, the Supply System may consider proposals for alternative uses of those lands that are judged to be no longer necessary to support power genemtion. It is the Supply System's position that the retention of these sites for future energy generation is a prudent business decision. To that end, the Supply System will retain ownership and control of all or part of these sites and will consider proposals for purchase or reuse of the land if it does not encumber the viability of future energy projects. The Grays Harbor Regional Planning Commission has notified the Supply System of its interest in reusing portions of the WNP-3/5 site. They have initiated a study known as the "Satsop Adaptive Development Project" to identify potential reuses of the plant site. They are expected to make an alternative use proposal to the Supply System in 1995. Page 3 l l

    -          s.,Wr sin- rwan 1, s. 4 a s There have been few proposals for alternative uses of the WNP-1/4 site. While some interest remains, there are no formal proposals currently being considered. The Supply System is currently using some facilities to support WNP-2 operations (maintenance training facility, paint shop, office space, and utilities) and USDOE contractors (office space). It is expected that the Supply System will continue to use this site to support the operation of WNP-2.

Since most of the existing site infrastructure will continue to be used to support demolition and asset sales, the final decision regarding which structures and utilities (outside the plant island areas) will be saved for future use will be deferred until near the end of the demolition period. 1 Those structures which have not been designated for future use will be removed before tue completion of the demolition work. 3.6 Special Conditions - Satsop The Satsop site is the location of the Supply System's proposed Combustion Turbine (CT) electric generating project (Figure 8). The Supply System has applied to EFSEC for Certification of this two-unit project located within the boundaries of the Cooley I2ydown area (West Layout Area on Figure 7). The operation of this plant will likely require use of the existing WNP-3/5 water withdrawal and water discharge systems. Accordingly, no plans have been made to restore the Cooley area or to remove the systems necessary for the operation of i this plant. l l

The BPA Satsop Substation and associated transmission right-of-ways are located on Supply System property at the WNP-3/5 site (Figure 7). This station will not be removed during site restoration because it is a permanent part of the regional electric distribution system.

3.7 Decommissionine Plans WAC 463-42-655 requires a site restoration plan to parallel a decommissioning plan if such a plan has been prepared for the project. Because these projects have never been operated and are not contaminated with radioactive material, NRC decommissioning plans will not be prepared. 4.0 SITE RESTORA. TION PLAN It is the Supply System's goal to demolish the power block structures at each of the four project sites to grade. If demolition of these structures proves more difficult or costly than anticipated, they will be demolished to a point as close to grade as practicable and buried in accordance with an approved modification to this plan. The major structures scheduled for demolition include the reactor buildings (Figures 9 and 10), reactor auxiliary / general services buildings (Figures 9 and 11), turbine-generator buildings (Figures 12 and 13), and the cooling towers (Figures 14 and 15). The foundations of these structures will be backfilled or buried as appropriate. Other structures such as office buildings, warehouses, pumphouses, shops and storage buildings  ! will be demolished or removed, except those that have been designated for alternative uses or identified by the Supply System as necessary for future energy generation. Following the rese 4 1 1 i I

__ _ . .. ~ ._ ._ __ _ _ _ . _ _ _ __ __ _ _ - __ _ - _ _ sie. a.m.r.d rim. , removal of structures, the site land surface will be graded and vegetation planted or seeded to blend with adjacent areas. Once the growth of vegetation has reduced the erosion potential to a level equivalent to nearby natural areas, the Satsop runoff / erosion control systems may be deactivated. The demolition and site restoration activities will be managed by the conditions specified in the existing Site Certification Agreements, applicable EFSEC Resolutions, and the commitments made in this Plan and the attached Performance Standard. 4.1 Demolition of Structures - All structures that currently exist on these plant sites are planned for removal except those that might be saved for reuse, needed to support transmission (Satsop Substation), or required by the Supply System for future energy generation (see Sections 3.5 and 3.6). The highest level of uncertainty associated with this restoration project is an unknown level of difficulty that will be experienced -in the demolition of the reactor and the reactor auxiliary / general services buildings. These massive structures have been built to nuclear industry standards to guard against reactor accidents and natural phenomena such as earthquakes. The buildings have been designed with many walls, floors, equipment cells, and other structures that are three or more feet in thickness. All of the substantial concrete work has been constructed with multiple layers of reinforcing steel some of which is greater than two inches  ! in diameter (Figures 4 and 5). A review of other discontinued nuclear projects has revealed that ,

no other utility has attempted this level of demolition.

4.1.1 Removal of Equipment Nearly all of the plant equipment and large-bore piping systems have been installed at WNP-1 and WNP-3. The WNP-4 and WNP-5 buildings were stripped of equipment ' during previous salvage operations. Plans to conduct asset sales in advance of demolition at WNP-1 and WNP-3 were considered but not accepted because of the high costs to ~_ extract the equipment. Under the current plan, building demolition will be conducted simultaneously with the removal and sale of equipment. This will maximize the return on the equipment by minimizing the cost of removal. Opportunity sales will be conducted at any time for high value or easily accessible equipment. 4.1.2 Demolition Techniques Work will begin at WNP-5 to determine the most efficient method of demolition for later i application to the other projects. It is expected that demolition will be conducted using a combination of traditional techniques including the use of explosives, wrecking balls, metal shears, and special cutting devices such as torches, water blasters, and diamond wire saws. Blasting will likely be used to fracture the concrete so that a crane and wrecking ball can separate the concrete from the reinforcing steel. Large hydraulic i excavators equipped with special tools (i.e., grapples, shears, hammers, etc.) will likely i be used to separate rubble. Conventional demolition techniques may be enhanced by the use of diamond wire saws to cut the structures into large blocks. l Page 5

e s.,pr s>m w a.s.4 a s It is anticipated that the contractor will work from the top to the bottom by demolishing  ; floor slabs and removing' equipment as it is uncovered. Once all the floors and equipment have been removed to the lowest elevation-(approximately 60 feet below - grade) the structures can be backfilled using the demolition debris. It is expected that additional earth fill may be necessary to complete the backfill. The WNP-3/5 cooling towers may be demolished using explosives. The resulting debris will be used onsite as fill. 4.1.3 Abandonment of_ Underground Utilities l Underground utilities such as water, fire, sewage, electrical, and telephone systems are present at each plant site. If not required for future energy projects or other alternative uses these systems will be abandoned in place following isolation (or deenergization) and removal of surface connections. Abandonment has been chosen because the systems will pose no hazard ifleft in place, because it avoids the effects of excavation (erosion), and because it is cost-effective. t Most of the electrical systems were designed'using underground conduit making the wires available for salvage. The oil-filled 230KV underground feeder at Satsop will be removed for resale or salvage. The remaining utility vaults, conduit, and direct-burial wire will be abandoned in place. Both the Hanford and Satsop projects were constructed using underground piping systems to connect the project to a source of cooling water (Figures 16 and 17). These water j supply aystems extend over several miles and will be left in place for future uses. Most of the makeup water piping at Satsop is planned for use by the CT project. At each plant site, large diameter underground pipes connect the turbine-generator building, circulating water pumps and cooling towers. These pipes can be 10 or more feet in diameter and will either be removed, backfilled, or plugged to eliminate a potential future hazard. The final disposition of these structures will be reviewed with EFSEC. 4.1.4 Demolition of Miscellaneous Structures Ancillary buildings and structures such as office buildings, shops, warehouses, i pumphouses, tanks, and storage buildings are scheduled for removal unless alternative uses have been identified (Section 3.5). Because most of these structures can be used for their intended purpose during the demolition and asset sales period, their removal will be deferred until the end of that period. 4.1.5 Water Withdrawal Structures

                       'Ihe water withdrawal structures at WNP-1/4 consist of a river pumphouse and three submerged water intake screens (Figures 18 through 22). If no longer needed by the Supply System, the pumphouse and its associated river intake structures will be hees

su. a.m n . dispositioned as directed by DNR through the riverbed lease. The buried piping and electrical supply that connects the river pumphouse to the plant site will be retained for future uses. If no such uses materialize, they will be abandoned in place to avoid disruption of the land along the route. At WNP-3/5 there are no water withdrawal structures located in the Chehalis River. The water supply for these projects is obtained from three Ranney wells located along the bank of the river (Figure 23,24 and 25). These wells are constructed as large caissons more than 100 feet deep that employ a radial pattern of horizontal well points installed i near the bottom of the caisson. As stated in Section 3.6 these wells and the connecting . pipelines will likely be used by the Combustion Turbine project and are not scheduled for demolition. i 4.1.6 Water Discharge Structures The WNP-1/4 water discharge structure is a simple pipe opening nearly flush with the - river bottom (Figure 26). As with the other river structures, DNR has jurisdiction and can direct its removal in accordance with the riverbed lease. Less damage is likely if the piping is abandoned in place. l A discharge diffuser has been installed in the Chehalis river for the WNP-3/5 projects (Figure 27 and 28). As with the intake wells, the Combustion Turbine project will be utilizing this structure and the associated piping. Accordingly, it is not scheduled for removal. l 4.1.7 Barge Slip Both a barge slip and a barge mooring facility were constructed by the Supply System on the Chehalis river for the WNP-3/5 project. Section III.H.7 of the Site Certification Agreement requires restoration of the slip once it has served its intended purpose. However, it is anticipated that the slip will be continue to be ust 5 the future by the demolition contractor and later to support the combustion turbine project and other future developments in the area. Accordingly, restoration of this facility is not planned at this time. DNR will direct the final disposition of this structure through the riverbed lease. The barge slip at Richland is located near the Supply System's Corporate Headquarters building in north Richland. This structure was used for the delivery of the major NSSS ccmponents for WNP-2, I and 4. This structure is owned and operated by the Port of Benton. The WNP-1/4 Site Certification Agreement has no conditions for restoration. l 4.1.8 Roads and Parking Lots Asphalt roads and parking lots in the central site area are scheduled for removal unless they are important to the local road network or needed to support an alternative use (Figure 6 and 7).

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The main connecting roads will be retained under the control of the Supply System or L

Page 7

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  • supph System credeses 1. 3,4 and 5 i y: 1 transferred to the county. At Satsop, control of the two access roads (Keys and Lambert) has already been transferred to Grays Harbor County. The Satsop NSSS Haul Road and the main access road to WNP-1 (Power Plant leop) are currently under Supply System control.

4.1.9 Satsop Erosion Control System During the construction of the Satsop site, measures were taken to control erosion of the site area and to rninimize sedimentation of local creeks and rivers. Numerous shallow impoundments were created along stream channels to serve as sedimentation traps or to' , facilitate pumping of terbid water for treatment. The use of these impoundments was . discontinued more than ten years ago. Most are now overgrown and are difficult to iecognize in the field. They will be abandoned in place because of their high value for  ; wildlife and because they pose no hazard from failure. Runoff from the plant island area at Satsop is collected in ditches and routed to a large collection pond. This water is released if necessary to the Chehalis River by way of a flow-through sedimentation pond (NPDES Discharge No. 002). This system will be kept operable during the site restoration period after which it may be converted to a flow-- through type operation if no longer needed. 4.2 Demolition Debris Disn. osal and Hazardous Substance Removal Debris conforming to the definitions of inert and. demolition wastes will be disposed onsite as fill. Those materials not meeting this guidance will be disposed offsite in an approved manner by the demolition contractor. j 4.2.1 Demolition Debris Disposal The guidance prescribed in WAC 173-304 that pertains to inert and demolition landfills will be used to identify the demolition debris that can be used as fill. Only inert (WAC 173-304-100(40)) and demolition (WAC 173-304-100(19)) waste will be used as backfill:  ! (40) " Inert wastes" means noncombustible, nondangerous solid wastes that are likely to retain their physical and chemical structure under expected . conditions of disposal, including resistance to biological attack and j chemical attack from acidic rainwater. (19) " Demolition waste" means solid waste, largely inert waste, resulting from the demolition or razing of buildings, roads and other man-made structures. Demolition waste consists of, but is not limited to, concrete, I I brick, bituminous concrete, wood and masonry, composition roofing and roofing paper, steel, and minor amounts of other metals like copper. Plaster (i.e., sheet rock or plaster board) or any other material, other than wood, that is likely to produce gases or a leachate during the decomposition process and asbestos wastes are not considered to be demolition waste for the purposes of this regulation. rs

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It is expected that.the debris produced by demolition will consist of concrete, concrete - with imbedded steel and some free miscellaneous steel. The demolition contractor will be asked to recycle as much steel as possible to minimize the amount left in the fill. By limiting the debris that can be used as fill to state-defined inert or demolition waste, the possibility of producing harmful gases or leachate upon decomposition is minimized.

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Prior to backfilling, provisions will be made to allow the draining of any. water that collects within the disposal cell. At Satsop, the existing groundwater drainage system will be discontinued and the two outlet tunnels that connect the system with nearby Stein , Creek will be plugged (Figures 29 and 30). This will eliminate a direct pathway for leachate to nearby surface waters. Products of demolition used for fill will not _be limited by size. . Backfilling will be conducted in a manner that eliminates voids that might collapse at a later time. Large blocks or slabs placed as fill may require supplementary soil / rubble backfill between each course to prevent void formation. _ Wood debris will be disposed in accordance with State and local regulations. At WNP-3 3 either the existing incinerator or open burning can be used for the disposal of wood  ! waste. At WNP-1/4, disposal with the demolition debris is currently favored because the Benton County Clean Air Control authority is extremely restrictive of open burning. 4.2.2 Special Disposal Conditions l , The cooling towers on the WNP-1 and WNP-4 sites contain a large quantity of asbestos- j ment fill. This material may not be welcome at a disposal site due to its large volume. i de Supply System will either ship to a disposal site or, if necessary, apply for a permit I to dispose of this material on site in accordance with 40 CFR Part 61 (also refer to WAC 173-303-395(3), WAC 173-401-300(2)(d)(ii), and WAC 173-460-030(2)(d)). 4.2.3 Hazardous Substances Small volumes of hazardous waste are expected to be generated during the site restoration activities. The Supply System currently has hazardous waste disposal programs at each joint site that will be used to control and dispose of any hazardous waste produced by demolition and restoration activities. Reuse or recycle of wastes will be considered before disposal. 4.3 Site iand Reclamation Following the completion of demolition any open foundations will be filled to grade using materials found on site. This fill will likely come from a combination of sources such as q demolition debris from other structures, asphalt from roadways and parking lots, gravel from I the yard areas, or local soil. Once backfilling is complete, the land surface will be graded (if necessary) and vegetation planted or seeded to blend with adjacent areas. Some interim measures may be required to stabilize reclaimed areas from erosion. P.ge 9

L*' - supssy syseem endeens 1. 3. 4 and s 5.0 PROJECT MANAGEMENT ne Supply System will maintain a small project management presence at both sites until the restoration work is completed. Hey will be responsible to manage the project in accordance with the Supply System's ownership responsibilities, the Site Certification Agreement, and the conditions of this plan. 5.1 Worker Safety A worker safety program will be required of the demolition contractor by contract. The contractor will be responsible for conducting the demolition work in compliance with the applicable regulations. 5.2 Site Security A minimal security program will be maintained until the completion of the demolition work. The purpose of this program will be to keep curious members of the public from inadvertently gaining access to the plant sites and suffering harm due to the hazards of the site. A combination of conventional measures such as signs, physical barriers,-locks, and fencing will be used. 5.3 Monitorine Programs The environmental monitoring programs described in the Site Certification Agreement were established to monitor the effects of construction and operation of the projects. The requirements for these programs were suspended by EFSEC when construction was stopped more than ten years ago. Routine sampling required to fulfill permit requirements or special samples to demonstrate compliance with State regulations will continue until the completion of site restoration. For example, water quality sampling in accordance with the WNP-3/5 NPDES permit will continue as long as controlled stormwater discharges occur. 5.4 Spill Plan Provisions Spill plan procedures are currently in place at WNP-1 and WNP-3 and will be continued until the end of site restoration. 5.5 Erosion Control Plans Frosion control plans are currently in place at both sites and are described in the Site Certification Agreements, EFSEC Resolutions, WNP-3 Erosion Control and Sedimentation Specification, and in the Performance Standard attached to this plan. These programs have been demonstrated to be effective during the construction period at each site. The crosional effects produced by demolition are anticipated to be significantly less thvi those previously experienced during construction. Accordingly, no new requirements have been developed. reee le

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During the demolition activities, the concerns related to erosion control are expected to be minimal because of the current stability of the sites. Potential erosion problems are not anticipated until the backfilling and site grading is conducted. 6.0 LICENSING AND PERMITS The existing Site Certification Agreements (SCA) and the powers vested in EFSEC preempt the need for additional permits from other jurisdictions (RCW 80.50.110 and RCW 80.50.120). The adoption of this plan with its attached Performance Standard in conjunction with the Site Certification Agreement and any relevant EFSEC Resolutions will constitute the approval necessary to conduct the site restoration activities. 6.1 State Environmental Policy Act Reauirements EFSEC requires the holders of Site Certification Agreements to restore their sites in accordance with the rules adopted by EFSEC in Chapter 463-42 WAC. The promulgation of these rules by EFSEC constituted a Nonproject Action as defined by SEPA (see WAC 197-11-704(2)(b)(i)

and (iii)). A nonproject action involves a decision on policies, plans, or programs such as the

! adoption or amendment of legislation, ordinances, rules, or regulations that contain standards controlling use or modification of the environment. Such an action could also include the adoption of any policy, plan, or program that will govern the development of a series of connected actions. Since a SEPA action was required for the promulgation of these rules, it could be argued that no further evaluation is necessary for an action to comply with those rules. A SEPA action was taken by the Supply System in advance of its decision to terminate the i projects. As lead agug, a SEPA checklist was used to make a Determination of Nonsignificance (DNS). The DNS was based on a description that included site restoration by stating that: "if no such (alternative) uses materialize, the Supply System will remove the assets and restore the sites by demolition, burial, entombment, or other techniques such that the sites , pose minimal hazard to the public."  ! Accordingly, SEPA compliance for the decision to authorize a site restoration plan has been I achieved by the generic environmental reviews that would have been conducted during rule-making as well as the specific action taken as a part of the Supply System's decision to terminate and restore the projects. EFSEC has determined that its decision to approve the Site Restoration Plan should be based on a current environmental checklist. The Supply System will prepare and submit a revised checklist to EFSEC for its consideration. 6.2 Site Certification Agreement The Site Certification Agreement (SCA) is a contract between the Supply System and the State of Washington that governs the construction and operation of these projects. A joint SCA was j issued for the WNP-1 and WNP-4 projects and a differentjoint SCA was issued for the WNP-3 and WNP-5 projects. Page 11

a' Supply Systems Pnderes 1,3. 4 and 5 Termination of the Supply System's Site Certification Agreements (WAC 463-36-020) is currently judged to be premature because these agreements contain conditions for control or mitigation of effects on the environment. Termination of the SCA's will be requested when the restoration activities are nearly complete.

                    'Ihe standards and environmental issues that were relevant to construction of the projects are also important for site restoration. The hazards to the environment (erosion, noise, dust, traffic, etc.)

are also the same though less in magnitude. The impacts produced by site restoration are expected be small and short in duration when compared to those that were experienced during clearing, excavation, and construction of the projects. The original Site Certification Agreements were issued in contemplation of the effects of construction produced by approximately 4,000 workers. The work force for site restoration will be a small fraction (estimated to be less than 100 workers) compared to those previously amassed for construction. WAC 463-36-070 contains the provision for timely approval of the Supply System's plans for site restoration. The rule states that EFSEC may approve by resolution an amendment which changes a technical provision or requirement within the terms of the existing SCA. This change must not constitute a substantial alteration of any provision of the SCA or have a detrimental effect upon the environment. Because the original issues contemplated for protection by the SCA were more numerous and greater in magnitude than those currently being considered for site restoration, the provisions of WAC 463-36-070 (approval by resolution) are judged an appropriate mechanism for EFSEC adoption of this plan. When approved, EFSEC will control the site restoration activities by the provisions of the existing Site Certification Agreement, EFSEC Resolutions (existing and new), and the commitments made in this plan and the attached Performance Standard. 7.0 FUNDING Funds for restoration of Projects 1 and 3 have been defined in the bond resolutions and net billing agreements as project costs and will be paid by Bonneville and/or the private owners in the case of Project 3. While no funding source has yet been identified for Projects 4 and 5, it is assumed that the cost estimates will be affordable and that the necessary funds will be available to accomplish the work described in this plan. 8.0 COST OF RESTORATION Original engineering estimates for complete restoration of all four projects totalled over $200 million dollars. A more recent opinion suggests that the work can be achieved at significantly less than the original estimate. Because the demolition and salvage contractor will be selected by competitive bid, cost will not be further discussed in this report. Page 12

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9.0 SCHEDULE FOR COMPLETION The amount of time required for completion of site restoration is uncertain because of a lack of industry experience in demolishing these kinds of structures and unknown funding requirements. Current estimates range between three and five years for each twin site or up to six to ten years total for all four projects. It is anticipated that the work will begin slowly and then increase as the best method of demolition is determined. Site restoration work is currently planned to be performed sequentially. However, once confidence has been gained in the demolition process and costs have stabilized, work may be conducted simultaneously at both the Hanford and Satsop plant sites which would shorten the overall time required to complete the restoration. Alternatively, if the cost of demolition is higher than expected, the demolition schedule may need be lengthened because of limited annual funding. Under the sequential plan, work would begin at Satsop (Project 5 first, followed by Project 3) in 1995 and continue until completion (1998 - 2000). Work would then switch and begin at Hanford (Project 4 first, and Project I last) and continue for another three to five years. Limited asset sales will be conducted at both sites before the demolition work begins. Although the demolition contractor will likely be the primary equipment sales agent, the Supply System will capitalize on opportunity sales when available. s l Page 13

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4 e APPENDIX A PERFORMANCE STANDARD FOR SITE RESTORATION March 8,1995 This standard has been developed for the restoration of Supply System Projects 1, 3, 4, and 5. Its terms define a final site condition and describe the conditions by which the restoration activities can be conducted in compliance with the requirements specified by the State of Washington. It applies to those areas and structures that are planned for restoration. DEMOLITION

1. Unless designated otherwise, above grade structures will be removed / demolished and backfilled or buried to a level that blends with the surrounding land. Iesser degrees of demolition may be approved by EFSEC based on the difficulty of demolition, cost, or adverse environmental effects.
2. Below grade floor slabs will be removed as necessary to prevent the formation of voids.

Below grade exterior foundation walls and interior vertical walls may be left in place.

3. Where appropriate, provisions for drainage will be made in structures to be abandoned by burial. '
4. Subsurface structures and openings will be backfilled to grade using methods that minimize the possibility of future subsidence or surface collapse. i
5. Products of demolition used for fill will not be limited by size provided that no significant voids are created by their placement.
6. Debris conforming to the definitions of inert (WAC 173-304-100(40)) and demolition (WAC 173-304-100(19)) waste will be disposed onsite as fill. ,

l

7. Large diameter water pipelines connecting the turbine-generator building, cooling towers l and circulating water pumps will either be removed, backfilled, or plugged.
                                                                                                                            ],
8. Products of demolition not meeting the requirements for backfill will be salvaged or disposed offsite by approved methods. Disposal in flood plains is prohibited.
9. Structural steel not encased in concrete will be removed to the extent practicable.
10. Installed equipment will be removed for sale, salvage, or disposal, unless otherwise approved.

i

11. Blasting shall be conducted under appropriate safety standards required by WAC 296-52.  !

l i Page A1

am m m s n EARTH

1. Reasonable means will be taken to avoid soil erosion.
2. The existing erosion control requirements described in the Site Certification Agreements (or as modified by subsequent EFSEC Resolutions) will remain in effect until the end of the site restoration period. .
3. The existing Satsop runoff collection system will be maintained until the completion of site restoration. No runoff control systems are required at Hanford.
4. The restoration of any newly disturbed stream beds should be accomplished using materials L

and contours compatible with existing materials and contours in order to look like and erode the same as adjacent banks. This is applicable to the removal of structures within stream beds such as outfalls, intakes and landings, bridge piers and culverts; it is not applicable to energy dissipators or other stabilization structures.

5. Runoff control facilities that will be deactivated will be stabilized in such a way to prevent blowouts or failure due to site runoff during heavy rainfall or snow melt. If runoff control facilities are removed the areas will be stabilized to minimize erosion.
6. Areas that will be disturbed due to removal of structures, roads, foundations, etc., will be graded and sloped to blend with the adjacent land.
7. Earth moving should be done in such a way to be minimize fugitive dust and to maximize the stability of fill and cut areas.
8. Finished slopes shall be stabilized as soon as practicable following completion.

AIR

1. Fugitive dust should be confined to immediate areas of structure demolition. Blasting should not be conducted in high winds to minimize the dispersion of fugitive dust beyond the site boundary. Fugitive dust from on-site haul roads should be limited to the site.
2. Any material that may be blown from a vehicle during off-site travel will be covered.
3. On-site burning may be conducted in compliance with EFSEC requirements and local air authority rules.
                                                                                 ? age A2

p t sm - WATER , 1 1

1. Discharges from the site must meet the water quality standards (WAC 173-201 A) at their  !

points of entry into the waters of the state. Proposed in-stream . work must be described ) and waivers of the water quality standards obtained from EFSEC. Surface runoff from disturbed soils must not be discharged directly to any stream.

2. At Satsop, stormwater discharges from erosion control systems will meet the conditions .

described in the NPDES permit, the Site Certification Agreement, and applicable EFSEC resolutions.

3. Deleterious effects from leachate will be avoided by controlling those materials that will i be disposed on site.
4. The existing Oil and Hazardous Substance Spill Plan will be maintained and revised as necessary during the site restoration period.

VEGETATION

1. Planting or seeding with appropriate vegetation shall be required on all restored areas.  ;
2. To the extent practicable, site restoration activities should not disturb areas of the site which were previously stabilized or undisturbed.  ;
3. Surfaces prepared for reclamation should be stabilized with fast growing ground cover, mulch, or soil cement to prevent erosion and siltation.

WILDLIFE

1. In so far as possible, protection of fish and wildlife should be made through programs that control hazards such as adverse water quality, crosion, siltation, hazardous materials, etc. '
2. Disruption of existing wildlife habitat shall be minimized.
3. Any in-stream work shall be conducted during approved times with standard precautions to prevent dewaterings or destruction of fish spawning, rearing and migration areas as well l as preventing excessive siltation or scouring. l I
4. Actions or conditions which may entrap fish such as silting of the entrance to the Satsop barge slip shall be avoided.

F.ee M

     .y                                                                                                                    ;

h .. M l NOISE 1.. In order to minimize noise in off-site residential areas, site restoration activities are restricted at night between the hours of 10:00 p.m. and 7:00 a.m. .

2. The noise limitations do not apply during the day between the hours of 7:00 a.m. and 10:00 p.m. for sounds originating from temporary construction sites as a result of l construction activity (WAC 173-60-050(3)(a)).
3. The noise level ! imitations do not apply between the hours of 7:00 a.m. and 10:00 p.m. .

for sound created by blasting (WAC 173-60-050(1)(c)).

4. Due to the remote location and lack of nearby residential areas, noise limitations will not apply at Hanford.  ;

HAZARDOUS WASTE

1. Hazardous waste shall be handled and disposed in conformance with WAC 173-303.

SOCIOECONOMIC-

1. If the work force on-site equals 1000 or more, the requirements of the site certification agreements shall be followed.

TRANSPORTATION

1. At Satsop, Lambert Road will be specified as the primary access road _for traffic associated i with the site restoration activities. Keys Road will be used as secondary access route.
2. All vehicles hauling materials to or from the sites will operate within the gross weight limits for which each vehicle is licensed and in accordance with the any posted load restrictions.
3. Commercial haulers will obtain county road / hauling permits, if required.

d Page A4

l Pasw c.sa a nd - HEALTH, SAFETY AND SECURITY

1. Efforts will be made to maintain a safe and healthy work environment during the site restoration activities.
2. An appropriate level of security shall be maintained to protect members of the public from potential hazards of the site.
3. The WNP-3/5 cooling tower strobe lights will be operated until the towers are removed.
4. An appropriate level of vector control shall be maintained at each site to prevent the  !

deleterious effects of unwanted birds, pests, and rodents until the end of the site restoration activities. 4 CULTURAL RESOURCES

1. In the event that new ground is disturbed by excavation outside of the previously disturbed site areas, the services of a qualified archaeologist will be retained to inspect the site to determine whether archaeological or historical sites will be disturbed (Site Certification Agreement Section III.K (WNP-3/5) or Section III.J (WNP-1/4)).

3 i Page A5

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