ML20205F520

Rev 3 to Environ Protection Control Program. Related Correspondence

ML20205F520
Person / Time
Site:	South Texas
Issue date:	06/30/1986
From:	Lawhn R HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20205F490	List: ML20205F520 ST-HL-AE-1701, Forwards Rev 3 to Environ Protection Control Program. Document Completely Replaces Rev 2.Related Correspondence
References
OL, PROC-860630, NUDOCS 8608190231
Download: ML20205F520 (22)

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I ENVIRONMENTAL PROTECTION CONTROL PROGRAM Revision 3

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SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION I

ENVIRONMENTAL PROTECTION CONTROL PROGRAM Revision 3 I

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 (Construction Permit Stage, March 1975) or as amended by the Nuclear Regulatory Commission.

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Qm\\L C, 74 86 Mar % Enviroiiiiifntal Protection Department Date I

k /Jw s-a -ac, Manager, Environmental Planning & Assessment Date I

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P1 anager Date I

AL au/n Deputy ~ Project Manager Date I

E Controlled Copy No.

Revision 3 I

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E TABLE OF CONTENTS

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SECTION 1.0 - INTRODUCTION.

Page 1.1 Project Description 1

1.2 Purpose 1

1.2.1 Revisions 1

1.3 Scope 1

1.4 Responsibility 2

I 1.4.1 HL&P Environmental Protection Dept.

2 s 1.4.2 HL&P Site Personnel 2

1.4.3 Contractor.s 2

I SECTION 2.0 - HL&P SITE SUPPORT GENERAL DUTIES 6

2.1 Monitoring 6

2.2 Indoctrination 6

2.3 Interface 6

2.4 Documentation 6

2.5 Corrective Action 7

2.6 Reporting 7

l 2.7 Attachments 7

SECTION 3.0 - ENVIRONMENTAL PROTECTION AND CONTROL 12 I

3.1 Plant Site 12

l 5 3.1.1 Runoff and Erosion Control 12 3.1.2 Storage of Fuel, Oils, and Solvents 12 3.1.3 Construction Debris (Class III Wastes) 13 1

3.1.4 Sanitary Waste 13 3.1.5 Oil, Chemical, and Has:ardous Wastes 13 3.1.6 Air Contaminants Control 14 5

3.1.7 Protection of Natural Streams 14 3.1.8 Landscape Restoration 15 3.1.9 Wildlife Control 15 I

3.1.10 Dewatering 15 3.1.11 Excavation 15 3.2 Transmission Line Construction 15 l

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5 LIST OF FIGURES Page 1.1-1 Project Location 3

1.4-1 Site Layout 4

1.4-2 EPCP Responsibility Flowchart 5

g 3.2-1 STP Transmission Routes 18 7

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I SECTION

1.0 INTRODUCTION

1.1 PROJECT DESCRIPTION I

The South Texas Project (STP or Project) is located on 12,300 acres in Matagorda County, Texas, approximately 15 miles southwest of Bay City along the west bank of the Colorado River (Figure 1.1-1).

The Project I

consists of two 1250-MWe units, a 7,000-acre cooling reservoir, a cooling pond, attendant pumping and discharge facilities and approximately 305 miles of transmission line corridors originating from the STP site.

I 1.2 PURPOSE I

The purpose of the 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),

I the Final Environmental Statement-Construction Permit Stage (FES), and other environmental commitments and conditions.

1.2.1 Revisions Revision 1 of the EPCP was issued to incorporate changes in I

construction practices as a result of modification of construction permit commitments and completion of construction activities.

In May 1978, the NRC amended the STP construction permit to allow the decomissioning of two sedimentation basins and to delete a I

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 I

Bechtel in the First Quarter of 1982.

Sections, which addressed construction activities completed, were deleted.

Revision 3 was issued to address organizational changes and to I

provide a general document update.

HL&P site personnel have assumed responsibility for duties previously assigned to the Bechtel Site Environmental Coordinator.

Some sections of the I,

document have been modified or deleted to reflect completion of certain construction activities.

1.3 SCOPE The scope of the EPCP covers all construction efforts on the 12,300-acre site and along the transmission line corridors.

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I 1.4 RESPONSIBILITY The South Texas Project (Figure 1.4-1) is jointly owned by Houston I

Lighting & Power (HL&P), Central Power & 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 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 Environmental Protection Department (HL&P)

The HL&P Environmental Protection Department (EPD) conducts I

surveillance of EPCP implementation, interfaces with selected regulatory agencies, and coordinates construction phase environ-mental monitoring programs.

1.4.2 Site Personnel (HL&P)

HLAP site management will designate the HL&P NPOD and Construction I

personnel responsible for conducting EPCP activities. These H14P site personnel will be responsible for monitoring, interfacing, documenting, and reporting on environmental-related construction I

activities at the Project site.

These individuals will continue to perform their primary functions and report directly to their respective departments, however, the HIAP EPD will provide I

guidance relative to environmental-related activities to ensure compliance with the Program.

1.4.3 Contractors I

Contractors have the responsibility to ensure that all phases of the Program are implemented in their area under the guidance of HL&P.

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c SOUTH TEXAS PROJECT EPCP RESPONSIBILITY FLOW CHART FIGURE 1.4-2 I

y HL8P PLANT DEPUTY PROJ.

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SECTION 2.0 HMP SITE SUPPORT GENERAL DUTIES I

2.1 MONITORING The monitoring responsibility of HMP site personnel requires primarily a basic understanding of the Program, FES commitments (Section 4.5), and I

local, state, and federal permits / regulations. Based on this understanding, HMP site personnel visually inspect the construction site for both compliant and noncompliant items.

2.2 INDOCTRINATION Formal and informal meetings are held by HMP site personnel with responsible contractor personnel to advise them of proper environmental /

construction protection techniques.

2.3 INTERFACE I

HMP site personnel are responsible for interfacing with Project personnel at the following levels:

1.

Contractors - (1) for interpretation of the Program, commitments, permits, regulations and environmental protection procedures; (2) for discussion of proper environmental / construction techniques; and (3)

I for identification and resolution of noncompliant items.

2.

Federal, state and local environmental authorities - during inspections.

3.

HMP Environmental Protection Department - during surveillance and to provide evaluations related to environmental impacts from ongoing I

activities and scheduled items.

2.4 DOCUMENTATION All activities pertinent to the Program (deviations or compliance, field I

and laboratory results, monitoring information, and resolutions /

recommendations) will be documented by HMP site personnel.

HMP site personnel will document the following environmental-related I

incidents:

• Any activity which results in offsite impacts I

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• Any activity that could have resulted in significant offsite impacts.

• Any activity that requires a significant expenditure of manpower and cost to correct.

• Any activity which may be reportable to a state or federal agency.

• Any activity which results in a permit violation.

HMP site personnel will use the EPCP implementation checklist (Section 2.7) to document compliance with environmental commitments set forth in the CP and FES.

This activity will be performed on a weekly basis and the checklists will be included in monthly reports (Section 2.6).

2.5 CORRECTIVE ACTION Should construction activity result in noncompliance with the EPCP or commitments made in the FES, formal action as defined in site procedures will be undertaken.

Should a noncompliance occur, HMP EPD shall be informed and corrective action initiated.

2.6 REPORTING HMP site personnel will submit monthly reports to the HMP EPD. The reports will reflect the following information:

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1) Status of any construction activities of environmental interest.

2) Descriptions of any noncompliant activities for the month.

3) Copies of each weekly EPCP implementation checklist for the month.

4) Any other pertinent environmental information.

2.7 ATTACHMENTS a)

EPCP Implementation Checklist w

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Surveillant:

Date:

$tatus Comttment Remarks Satisfactory tmsatisfactory 1.

In an effort to control erosion following inttf al clearing and grading activities, surface drainage from cuts, fills, spoil areas, etc.. will be controlled by ditches dikes, berms, and sedimentation basins with controlled outlets (ER, p. 4.1 3).

2.

Due to the flat nature of the terrain and the lack of natural drainage streams !' the testadiate vicinity of the water away from the site (plant site, dratnage ditches will be construdted to carry stom ER,p.4.1-4).

3.

Scrap material generated during construction activities will be sorted for salvageable items.

l All chemical, petroleum, and nonsalvageable items will be hauled from the plant site and disposed of in accordance with local regulations (ER. p. 4.1-5).

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Te w orary roads will be watered during any' dry period as necessary to control dust (ER.

p. 4.1 5).

5.

Earth fill for the embankment will be obtained from the cooling lake site to the maximum extent possible, thus mintmfring the construction igacts on the areas surrounding the lake (ER.p.4.1-6).

T 8.

Eneankment fill material will be wetted to reduce dusting (ER, p. 4.1-6).

l 7.

No waste construction materials or dirt will be disposed of by dumping into the river (ER. p. 4.1-6).

I 8.

Tegorary parking areas tegarary roads, and the land occupied by the batch plant, upon cogletion of construction activities, wl11 Le cleared and relandscaped to confom with the i

natural surroundings (ER

p. 4.1-7).

9.

Where possible. In order to mSimf re fgact periods of peak construction activity will be tised to coincide with the periods of least sensitive phases in the life cycles of the acre t@ortant animals on the site (ER. p. 4.1-10).

10.

In order to mintefre the impact of noise on the local populace, pile driving operations will normally be performed only during daylfght hours over a period of approximately sf x months (ER. p. 4.1 10a).

17.

Construction will be scheduled to avoid unharvested fields whenever possible. Whenever it is necessary to disturb or destroy field corps, all syrface construction marks will be removed by disking, and farm operators will be adequately cogensated (ER. p. 4.2-14).

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No herbicides will be used during the course of clearing or construction activities, thus avoiding any contamination of water or danger to wildll(e (ER. 4.2-15).

20.

Traffic control measures will be Iglemented as required to control truck traffic and assure safe operations in the vicinity of small local communities, presently uncontrolled in rural areas and school bus pickup points (ER. p. 4.1-11).

EPCP IMPLEMENTATION CllECKLIST surveillant:

Date:

status Remarks Comitment Satisfactory Unsatisfactory Withdrawal of water' from the Colorado River for filling (of the cooling lake will be avoided' 21'.

to the maximum extent possible during low-flow periods ER, p. 2.4-12).

22.

Excavation materials will be hauled to designated stockplie, spoll, or fill areas.

23.

The side slopes of the excavation of the plant will be designed to have hatural stability and the surface will be seeded with grass to prevent surface erosion. The flow of water down the side slope surface will be controlled by berms and directed by ditches and gutters to areas to be pumped foto storm drains.

24.

Outer slope surfaces of the reservoir will be seeded to reduce erosion, and the interior slopes will be stabilized by the use of soll cement.

25.

The construction of the river makeup pug station and screening structures will not cause additional slitation or slough-off losses to the river, to 26.

The bottom of the barge siip will be graded and covered with crushed stone, gravel, or shell to stabilize the bottore and reduce 511tation and erosion. Clearing of trees and vegetation will be confined to a small area.

27.

A sheet pile retalning wall will be constructed to loca11re disturbance of aquatic habitat in the barge slip construction area.

31.

Cleanup and restoration of areas affected by clearing and construction will be conducted.

32.

All areas which are tegorarily altered during construction will be seeded with grasses which are adapted to the heavy moist soils of the site to prevent erosion.

33.

The temporary road extending from FM 521 to the north and south of the Station area on cogletion of the clant construction will be elfminated and the rights-of-way graded and replanted to blend with natural surroundings.

34.

.Heasures will be taken to maintain the existing drainage routes in the bottomland when the intake and discharge Ifnes are laid in place.

35.

No direct discharge of wastes into the Colorado River during construction is planned. Wastes from a small sewage treatment plant (2.000 employees /10 hours / day) will be treated in accordance with state and local laws and returned to the relocated Little Robbins Slough at rates varying from 40 to 200 gpm. ( Applicant modified - see Sect.11.3.1.3) 36.

Long-term te g orary construction roads will be surfaced with a stabilized material to resist wear and erosion due to traffic, e

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M EPCP IMPLEMENTATION CilECKLIST Surveillant:

Date:

Cormritment Remarks Satisfactory Unsatisfactory Staff evaluation 1.

Total suspended soltds in construction runoff dtscharged to the Colorado River shall not exceed the TSS levels in the river at the time of discharge or sedirentation basins, stred to hold the water from a 10 year-24 hour rafnfall event, shall be utillred prior to discharge.

2.

Sewage waste shall be discharged after treatment to the Colorado River.

3.

A study shall be perforved to detemine the eeed for diverston of water from the Colorado River to Little Robbins Slough and the parameters required to minimize trnpacts on the marsh congles. Any water so diverted shall be Ilmited to no more than 150 ppm T55 and 1500 ppm TDS, Construction shall be performed to minimize watershed removal as spectfled in Sect.

6.1.3.2.

7.

The appiteent shall limit the strafghtening and channeltration of Little Robbins Slough in the area within the site boundary, o

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EPCP IMPLEMENTATION CifECKLIST Sur eillant:

Date:

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Comt tment Remarks Satisfactory t> satisfactory 1.

During permanent drainage installation, the last 1/2 mile of the Plant Area crainage Oltch will not be disturbed.

l 2.

The Permanent Plant Area Dralnage Ditch will be constructed l

from the downstream side toward the Plant $lte.

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3.

Essf as will be backfl11ed and stabfll ed.

4 The West $ poll Area will be stab 11tred by grass prior to decomissioning of the West Sedimentation Basin.

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I SECTION 3.0 ENVIRONMENTAL PROTECTION AND CONTROL

'I 3.1 PIANT SITE I

3.1.1 Runoff and Erosion Control I

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 excavating to facilitate the I

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, I

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 naturally.

Drainage ditches are to be excavated at gradients which make their sides less conducive to erosion; whenever possible, berms, I

ditches and other undisturbed 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.

3.1.2 Storage of Fuel, Oil and Solvents Storage of fuel, oil, and solvents will be in bermed areas designed to contain a spill from the single largest container in the berm plus additional room for precipitation.

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 HL&P.

Bermed storage areas will be constructed using stabilized material and designing berm side slope to minimize erosion. Drip pans will be placed under the spigots of solvent drums to prevent spills from contaminating the soil. All spills will be reported promptly to designated HIAP site personnel.

H14P will approve all new storage areas prior to construction.

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3.1.3 Construction Debris (Class III Wastes)

Construction debris generated during construction activities will be collected stored, and sorted for salvageable items.

Merchantable waste is to be hauled from the Proj e :t and sold to

-2 scrap dealers.

Waste concrete, brick, non ferrous metals, PVC pipe, and insulation materials will be disposed of in the registed onsite Class III landfill.

The landfill will be excavated at a gradient which makes it possible to unload into the landfill pit directly from trucks.

Trash unloaded near the edge of the landfill will be pushed into the pit on a frequent basis. A gg minimum of six inches of compacted soil cover will be provided weekly to reduce windblown trash.

When the landfill has received waste up to within two feet of the natural ground surface it will be decommissioned by covering and compacting at least two feet of

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clay on top of the landfill.

3.1.4 Sanitary Waste Four onsite sewage treatment plants treat sanitary wastes prior to discharge.

The one construction phase system discharges effluent into the Colorado River via a drainage ditch.

The three operational phase systems discharge into the Main Cooling Reservoir (MCR).

j Where it is infeasible to provide construction 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 licensed contract carrier for disposal at approved offsite facilities.

3.1.5 Oil, 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 HL&P site ii personnel.

Metal 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 the Main Cooling Reservoir (MCR).

m Waste oil will either be sold to a commercial operator for recovery; disposed of by a permitted disposal facility; or used ar fuel for fire brigade training.

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3.1.6 Air Contaminants Control Dust caused by the movement of construction vehicles is controlled by periodically spraying unpaved areas with water provided by runoff basins, dewater discharge, and washdown wastewater. The I

frequencies of spraying and the quantity of water used are to be determined by visual inspections and existing weather conditions as necessary to control dust.

All permanent roads will be paved as soon as practical during the construction period.

Parking and laydown areas will be treated with lime and covered with shell, gravel and/or limestone to I

provide stability and reduce dust.

Equipment which emits large quantities of dust, e.g., the batch I

plant, and storage silos, will be equipped with filter bags and/or water spray systems as required by applicable state permits.

I Burning of creosoted wood, tires, plastic, and chemical products is prohibited.

3.1.7 Protection of Natural Streams I

Wastewater from washing vehicles and equipment will normally be collected in basins. The basins will function to capture waste g

lubricants and reduce the suspended solids. Treated water will be 1

E used for dust control by dispersion over construction roads or by other methods approved by Hi4P. When it is not feasible to bring heavy equipment from remote locations to the assigned washdown I

areas, portable cleaning equipment are dispatched to the field and used to clean those parts of the equipment encumbered by mud.

In this case, the wastewater is directly over land before entering natural or man made drainage channels.

As required by 40 CFR 112, the Project will have a Spill Prevention Control and Countermeasure (SPCC) Plan during the construction period.

According to the SPCC Plan, bulk quanticites 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 I

required by state and federal permits.

Samples will be collected, stored, and shipped to an approved analytical laboratory in accordance with established procedures. The data will be transmitted to the H14P Environmental Protection Department for I

reporting to the appropriate agency.

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a" 3.1.8 Landscape Restoration Cleanup and restoration of areas affected by construction activities 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 allowed to conform with the natural surroundings.

L 3.1.9 Wildlife Control As required by specific site conditions, certain wildlife species may need to be controlled during construction of the power block.

I Control will involve either removal or termination of the problem species. All applicable state and federal regulations will be followed.

Chemical sprays for the control of insects or poison for control of rodents are to be used according to manufacturer's specifications.

L 3.1.10 Dewatering Dewatering for Units 1 and 2 commenced in November, 1975, and will continue through 1989.

Discharged water from this system will be directed to drainage ditches for use in dust control, and I

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 I

power block areas. Once design and construction requirements are satisified, the groundwater around the facility will be raised to normal elevations in a controlled manner.

3.1.11 Excavation Excavated materials will be hauled to designated stockpile, spoil, I

or fill areas.

Suitable material excavated from the power block and construction 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.

3.2 TRANSMISSION LINE CONSTRUCTION Three corridors will be required for circuits leaving the STP switchyard.

I The three corridors are the eastern corridor to Velasco substation, the southern corridor to Blessing substation, and the main corridor to Danevang at which point this corridor branches and continues to Holman and Hill Country substations. The transmission corridors are shown in Figure 3.2-1.

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The following mitigative measures will be implemented during the construction of the transmission 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. Trees, shrubs, and vegetation, in areas where clearing is unnecessary, will be protected from damage during construction.

Trees of timber quality, that are cleared, I

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 Regulation 1, Section 111.2(6)).

b.

No 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 c.

erodible areas along the transmission right-of-way, these areas will be reseeded with adaptive species of grasses or vegetation to help I

control 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 I

production periods.

If field crops are disturbed or destroyed, the farm operators will be compensated and construction surface marks will be removed by discing, e.

Construction in the known booming ground of Attwater's Prairie Chicken will be scheduled to avoid their mating and nesting period, January 1 to June 1.

Transmission 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 equipment will be utilized in marshlands to minimize the impact on sensitive marshland habitat and associated biota.

g.

Existing public and private roads will be used for access to the transmission 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.

I I

I I

16

FL Transmission line construction will be conducted by each STP participant, i.e.,

each utility will construct the line it owns.

Each participant 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 HIAP Engineering Department will review monthly construction status reports provided by each participant. These reports, which will include a daily compliance 7

checklist for all applicable FES commitments, will be forwarded to L

the HL&P Environmental Protection Department. Each participant will be responsible for notifying the HiAP Environmental Protection Department of any unevaluated construction activities or of unexpected harmful evidence of irreverrible damage pertaining to transmission line construction.

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