ML20136E196

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Comments on 811119 Proposed Plan for Redress & Restoration Work at Site Submitted by Util.Review of Natl Park Svc Comments on Restoration Work Reveals No Mention of Methods to Control Erosion in Const Areas Having Little Vegetation
ML20136E196
Person / Time
Site: 05000000, Bailly
Issue date: 02/03/1982
From: Ballard R
Office of Nuclear Reactor Regulation
To: Lynch D
Office of Nuclear Reactor Regulation
Shared Package
ML20136E200 List:
References
FOIA-85-362 NUDOCS 8202240236
Download: ML20136E196 (2)
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) Docket No. 50-367 MEMORANDUM FOR: Dave Lynch, Project Manager

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i Licensing Branch 2. DOL J FROM: Ronald L. Ballard, Chief Environmental Engineering Branch DE SU8 JECT: ENVIRONENTAL ENGINEERING BRANCH REVIEW 0F REDRESS OF 8AILLY SITE i

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We have4eviewed the proposed plan for redress and restoration work at the

Bailly site submitted by Northern Indiana Public Service Company on i November 19, 1981. Since the preservation and integrity of the Cowles Bog

! Wetland Complex, a Natural Landnark, was a major concern of the U.S.

Department of Interior. National Park Service (NPS), during NRC's licensing i activities at the Bailly site, we also reviewed the NPS consnents on the' proposedrestorationplan(December 23.1981)(attached). Our comments are as follows:

1) There appears to be no mention of methods to control erosion in
construction areas having little or no vegetative ground cover, i, .

Reseeding or otner planned methods of soil stabilization should be addressed.

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! 2) With reference to the ongoing concerns of the NPS over Cowles Bog, the Hydrology and Geotechnical Engineering Branch should review NPS connents and concerns about:

! (a) Sealing and capping of wells, 1 (b) Backfill material.

i Furthennore, we have been unable to detennine the specific NPS concerns in regards to the proposed use of the slagged laydown area and railroad spur.

NPS indicates that they have insufficient data to address this issue. We i suggest that the Division of Licensing (DOL) request that the Applicant

! provide suitable maps identifying the slagged laydown and railroad spur

areas and that the NPS be asked to specify their concerns about this part of the Bailly redress plan.

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I Dave Lynch FEB 3E We question the need for NIPSCO to backfill the excavation to th4 original profile unless water levels at Cowles Bog will be otherwise affected. Such action could require obtaining fill material from other areas including Lake Michigan. Our concerns under NEPA should be adequately met if readily available excavation material in the vicinity of excavation is used to partially fill the excavation and if measures are taken to control erosion.

Further action may require additional pemits and result in greater environ-mental impacts than settling for a partially filled excavation. Thus, while we find the Applicant's proposal to fill the excavation acceptable, it does not appear appropriate for the NRC to actually require complete filling of the excavation.

If you require further assistance, please contact G. Gears (X24807) of this Branch.

Originalsigned b'y Ronald L Dallard Ronald L. Ballard, Chief Environmental Engineering Branch Division of Engineering

Attachment:

As stated

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$N ESPLY RSFER 70; TM DEC 2 31981  : A

.hf ' Jo R l -l Mr. Harold R. Dentcn Director, Office of Nuclear Beactor Begulaticn U.S. Nuclear Begulatory Ccrrmi"im ,

Washington, D.C. 20555

Dear Mr. Denten:

In respcnse to your letter of November 20, 1981, in which you requested our ocxments on the progened milly Nuclear One site restoraticn plan, we offer the following ccrtments:

1. sealing and capping of wells: We are unclear about the extent of proposed wiing/cappina of wells, sump casings, tran%ms, etc.,

before backfilling in the excavaticn and in areas separated from the excavaticn. We rewmami that all Unit 3 wells in the excavation be filled with v nd.e before be.ckfilling. Because of the hydrologic ccnnection between Units One and 'Ihree at the excavaticn site, wells which are not vrai= Red are potential avenues for flow between the lower sand and upper sand aquifers. hhile this would probably not appreciably alter the ficw system in either aquifer unit, it could allcw any future contaminaticn that might occur in the lower sand aquifer to migrate more easily into the upper sand near the excavaticn site. In such a case, the west end of the Cowles Dog Wetland Ocxuplex could be impacted if water of undesirable quality would Inwe through the slurry wall or the sheet pilings on the northeast part of the excavation.

tenitoring wells outside the excavaticn which are necessary to future m:nitoring should not be capped.

2. H-Piles: We see no problems arising frcm the leaving-in-place of
the H-Piles after cutting them off at +8 feet. 'Iheir total removal l might destroy the integrity of the hydrologic regime of the area.
3. Slagged Lay-Down and Railroad Spur Areas: 'Ibere is inadequate

( information for us to be able to ccmnent on the proposal for the slagged l

lay-down area and railroad spur area. 'Ihis area, frcm the plan description, appears to be adjacent to Lakeshore property. We w:uld need more information, including a map, to evaluate this part of the proposed plan.

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Backfill Material: Groundwater flow near the excavation could also be affected by the nature of the backfill material. If this material differs apprar-iably in hydrologic conductivity fran the original material, the water table altitude may differ, which could slightly alter the shallow groundwater regime. 'Ibe mineralogical and cWie=1 conposition of the backfill maearial could affect groundwater quality near the Cowles Bog Wetland Ctmplex if the material is significantly different frca the original material. Even if the water is potable, the c h iatry of dimanived constituents may differ enough to have an inpact on plants

~in the wetlaM.s. 'Ihus, quartz sand such as oriainally was cresent, is the most desirable fill material. 'Ibe following backfill materials appear suitable:

a. Material removal fran the excavation or other clean, inorganic fili materials of a character not appreciably different in hydrologic cmductivity or quality fran the original material.
b. Sand, presently located on the' Bailly site which is silicima in ecmposition and arenaceous in size, or sand of the type generally found in the area surrounding the nailly site.

We are assured that the Nuclear Regulatory N iaainn will retain its regulatory respanaihility through.ccupletion of the Bailly Nuclear One site restoration. We are pleased with NRC's and NIPSCO's intention to restore the p Ay and we appreciate this vwvitanity to make catments on the plan.

Sincerely, 7

PA a . a f ACW.;c y *'

Director I

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