RBG-35381, Forwards Response to NRC 910430 Request for Info Re Maint of Transmission Line right-of-way by Periodic Removal of Tall Growing Trees & That Pesticides or Herbicides Will Not Be Used
| ML20077J822 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 07/29/1991 |
| From: | Deddens J GULF STATES UTILITIES CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RBG-35381, NUDOCS 9108050152 | |
| Download: ML20077J822 (18) | |
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GULF STA TES UTILITIES COMPANYn"**y i sus , -e - ,s. .,
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River Bend Station - Unit 1 Docket No. 50-458 Please find enclosed rerponses to the requests for infonmtion contained in your letter of April 30, 1991.
If you have any questions or need further clarification, please contact Mr. J.W. (bok of my staff at (504) 381-4151.
Sincerely,
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.C. Deddens Sr. Vice President
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- IW1DGURB 1 REQUEST FOR INIDPOMTION
'Ihe Final Environnental Statenent (IT.:S) , datcd 1985, Section 5.5.1.2, states that transmission line right-of-way will be naintained by pericdic reroval of tall growing trees and that pesticides or herbicides will not be used.
Section I. A.2.b. (2) of the draft re;rart prepared by the Louisiana Public Service Conirdssion Task Force on Utility Line Clearance states that Gulf States Utilities (GSU), as part of its agreerent with the NIC , is prohibited from using herbicides on the River Bend Station (PBS) transnission lines. The i refemnce for this statcrent is the TES. In a letter dated Dcomier 4, 1990, CSU, in response to the draft report, states that it is no longer prohibited frctn using herbicides on RBS lines. The concern is that GSU is using !
herbicides for transrrission line right-of-way clearance. Use of herbicides is 1 not in accordanx with the conrltrent in the IT:S.
GSU RESPONSE:
According to Section 3.1 of Appendi>: B (Environnental Plutection Plan (EPP)) I to River Eend Station Operating License, GSU nny nake changes in station ;
operation affecting the environnent provided such activities do not involve an unreviewed environmental question and do not involve a change in the EPP.
This section further requires that bafore engaging in additional operational activities which may significantly affect the envirornent, GSU shall prepare and record an environrental evaluation of such activity. When the evaluation indicates that such activity involves an unreviewed environnental question, GSU shall provide a written evaluation of such activity and obtain prior NIC approval.
In March, 3986, CSU evaluated a change concerning the use of herbicides for controlling vegetation on transmission line rights-of-way associated with RBS.
As required, prior to irplecentation an environmental evaluation (copy attached) of this activity was perforned which detentined that use of herbicides under proper conditions would have less adverse environmental I impact than nochanical methods for vegetation control. GSU determined that l
this change does not fit the criteria for an unrevicwx1 envirormental question, and therefore, did not require iJC approval prior to implenuntation.
Also in GSU's detennination, this change does not involve a change in the Environnental Protection Plan;- therefore, a license anenchant is not required.
The contrdtrent was formlly revised in GSU's Novuntrr 23, 1988 suhnittal to the NIC in its Annual Envirorrental Operating Report (Nonradiological).
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USE BLACK BALL POINT PEN ONLY, AND ANY CHANGE CROSS OUT, INITIAL .
USE ONLY IF UEQD REQUIRED PAGE 1 -MR - REV -
RIVER BEND UNIT #1 OTHER DOC. REV -
UNREVIEWED ENVIROMENTAL QUESTION DETERMIN ATION y pp PREPARED (NAME) DATE REMEWED & APPROWD NAME) p 0 h 3
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EHV, PROY PLAN CHANGE O YES INO ENV REPORT-OPUC CHANGE YYES O NO FSAR CHANGE RELARD: O ES #NO TECH SPEC CHANCC D YES #NO FCN/NR /%WR DATE REFERENCES (DRAWING, ETC.) - C FES (NUREC 1073) CHANGE [YES O NO
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not confined to onsite orece previouofy dist. art >ed during site proporo-tion and plant constructont DISCUSSON st k M how;MNsco O YES [NO kor NNk Oarh e 5e 6 AM dre k enL-d d. N b o Oket
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8 ALL RELATED ATTACHMENTS SUBSEOUENT TO PACE 2 MUST BE IDENTIFIED OF AS PAGES' PAGE
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', f a $C du ch db [Gje5 USE OF HERBICIDES ON RIVER BEND STATION TRANSMISSION LINE RIGHTS-OF-WAY LICENSING DOCUMENTS INVORED:E Facility Operating License No. NPF-47, Appendix B " Environmental Protection Plan (Nonradiological)" [El'P), Section 3.1.
" Final Environmental Statement related to the operation of River Bend I Station" [FES), NUREG-1073, rection 5.5.1.2.
" River Bend Station Environmental Report -
Operating License Stage"
[ER-OLS), Sections 5.1.2, 5.6.1, and 5.10.7. l REASON FOR PROPOSsL:
In June 1973, when Gulf States Utilities (GSU) tendered its Construction Pe rmit application for River Bend Station (RBS), GSU was not using herbicides for its system-wide transmission line right-of-way vegetation control and therefore committed in its Environmental Report -
Construction Permit Stage to not use any herbicides on RB1 rights-of-way. The commitment was included in the ER-OLS and was noted oy the NRC Staf f in its FES. The commitment remains in effect for RBS rights-of-way. However, in 1980, GSU began a carefully planned herbicide program for its transmission line rir, hts-of-way not associated with RBS. Technology and herbicide safety have iuproved since GSU's original decision regarding RBS corridors to where GSU n ow has concluded that their careful and planned use are justified for use oc RBS rights-of-way. GSU, therefore, proposes to use herbicides as described herein.
OBJECTIVE:
l Some form of vegetation management on rights-of-way is essential. Trees on l unmanaged corridors eventually grow into the conductors creating a potential hazard to the safe and uninterrupted operation of these lines. In order to operate the RBS transmission lines free of tree-caused interruptions, the objective of GSU's vegetation control program is to promote the growth of low-growing, relatively stable plant communities that are 1) compatible with electrical system reliability requirements, 2) beneficial to wildlife, and
- 3) need relatively little maintenance over the life of the right-of-way.
The proper and controlled use of herbicides is GSU's proposed method of choice for accomplishing this objective. Herbicides have become a standard tool for utility right-of-way vegetation management. Reliance entirely on other methods results in less effective management programs and is prohibitively expensive.
l DESCRIPTION:
GSU presently proposes to use four (4) methods of application on RBS corridors. The methods and formulations below represent those currently planned for use. Other application methods and formulations may be used in g --
. , . ',, puje 1 of S (43c5 the future if de te rmined by CSU to be safe, economical, effective and appropriate.
- 1) Aerial Application Mix - one (1) gallon of Carlon 4 and two (2) gallons of Tordon 101 in twenty (20) gallons of water per acre.
or One (1) gallon of Rodeo in thirty (30) gallons c.i sater per acre.
Prescription - Aerial application will be used on medium to dense brush in non-sensitive areas with poor access for ground equipment and/or areas with a high erosion potential. The Carlon-Tordon mix will be the basic mix used on the right-of-way with the Rodeo mix to be used near streams, swamps, or any other body of water. This mix, although a j broadcast application, is selective only to broad leaf weeds and will j not harm grasses.
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- 2) Ground Foliage Application Mix - one (1) gallon of Garlon 4 in one-hundred (100) gallons of water per acre.
Prescription - ground foliage application will be used in areas of scattered, medium to dense brush with good access where there is a low erosion potential. Although this is also a broadcast application, the use of a hand-held dispenser gives good selectivity around desirable trees and shrubs.
- 3) Basal Application Mix - one (1) gallon of Carlon 4 in three (3) gallons of Ultra-low-volume (ULV) Basal Oil (Backpack application).
Prescription - Basal application will be used in sensitive areas or areas with a low brush density. This is a very selective treatment for control of individual trees only.
- 4) Banding Application Mix - four (4) pounds of Spike 85 DF or 80W in four (4) gallons of water (backpack application applied at 7.5 pounds per acre).
Prescription - Banding application will be used around poles, fencerows, and rights-of-way where cropland is the adjacent land use. It is soil applied and can be applied safely in areas near crops.
To progress toward a low cost, sustained, cyclical maintenance program, CSU expects a . lengthening of the maintenance cycle and increasing use of selective techniques with each successive application until a relatively stable vegetative community is established. The exact interval between successive treatments depends largely on the density, type, and height of l
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the plant community occupying the right-of-way and the aggressiveness of the invading species.
BASES FOR HERBICIDE USE PROPOSAL:
- 1) Erosion Control There are many places on RBS corridors that are subject to erosion, especially when disturbed. Mechanical equipment not only causes disturbance such as ruts and gulleys, it also necessitates more frequent maintenance. The use of herbicides will also preserve the native grasses which provide some of the best erosion control available.
- 2) Improved Wildlife Habitat By using herbicides, GSU can be more selective in leaving desirable wildlife plants. Mechanical methods are non-selective and also disturb nests and dens of many wildlife species found on rights-of-way.
- 3) Aid in Preserving and Beautifying Historical Breastworks in the Port Hudson National Historic Landmark Ref. letter NRC to GSU, August 16, 1979, RBC-10630 Ref. letter GSU to NRC, August 21, 1980, RBC-8366 Ref. letter GSU to NRC, November 2, 1982, RBG-13676 Many of the_ Civil War bretstworks are difficult to see and could easily be damaged bj mechanical equipment. Handcutting of these breastworks is possible, but the bruch quickly resprouts again, hiding the breastworks to where they are again indistinguishable. The use of selective herbicides on the breastworks would prevent physical damage and allow the breastworks to be more visible since grass and vines would be the
! primary cover after the herbicide application.
- 4) Economics The use of herbicides has proven to be more cost-effective _ than mechanical and hand methods, both in initial application and in frequency of maintenance cycles. This is economical for both GSU and our customers.
PRECAUTIONS:
l All applications will be made by experienced, licensed applicators.
Procedures and specifications will be developed and buffer zones will be established to protect sensitive areas and insure that non-target resources will not be contaminated. Applicator training and proper supervision and monitoring .will assure that the work is carried out according to these procedures and specifications. Re gular right-of-way inspections and l
periodic program review will identify necessary adjustments and evaluate effectiveness.
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Only EPA approved formulations will be used and all applications will be
.made according to label instructions to assure minimal adverse effects to the environment. Many years of research and GSU experience on other -i right-of-ways indicates that herbicides, when prescribed properly and used according to label instructions, do not harm the environment. The resulting vegetation control can be beneficial to many forms of wildlife and aid in erosion cotctrol.
ENVIRONMENTAL EVALUATION:
Pursuant to Section 3.1 of the EPP for RBS, CSU may make changes in station operation affecting the environment provided such activities do not involve an unreviewed environmental question and do not involve a change in the EPP.
This Section further requires that before engaging in additional operational activitian which may LIgal:1cantly atfect the environment, GSU shall prepare and record an environmental evaluation of such activity. When the evaluation indicates that such activity involves an unreviewed environmental question, GSU shall provide a written evaluation of such activity and obtain prior NRC approval.
GSU's evaluation of this operational change indicates that if regulations, procedures, and specifications are adhered to, the potet.tial for significant adverse environmental effect is minimal. GSU has determined that the use of herbicides for controlling vegetation on transmission line rights-of-way associated with RBS does not fit the EPP criteria for an unreviewed environmental question, and therefore, does not require NRC approval prior to implementing this change. Also in GSU's determination, this change does not involve a change in the EPP, therefore, a license amendment is not appropriate.
REFERENCES:
Carvell, K.L. and P.A. Johnston. 1978. Environmental Effects of Rights-of-Way Management on Forested Ecosystems. Electric Power Research Institute, Pala Alto, CA, Final Report.
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ENClDSURB 2 REQUEST IVR INFOWATION:
Recently, GSU applied for an energency permit to shore up a transmission tcuer on a 500 kV line,_which was experiencing erosion. (We understand that, over ;
the past 26 years, the river has shifted 200 feet to the w st and is now j affecting the base of the tower.) Section 8.2.1.3 of the Updatc4 Safety '
Analysis Report (USAR) states that transmission lines of GSU are inspected aerially on a conthly basis. The concern is that GSU has not been performing the conthly aerial inspections. Your response should include a copy of the results of the nonthly aerial ins;xrtion activity for the past 24 nonths.
GSU RESIW SE:
The transmission line tower alluded to (structure 276) is located where 500 kV line designated 742 is in close pr%imity to the Amite River north of GSU's -I McKnight substation. For NRC safety and environmental licensing purposes, the new transmission lines constructed with River Bend Station teminate where they connected with the existing transmission system grid. As described in USAR Section - 8.2.1.1.2 and shown in Figure 8.2-3 (attached) , 500 kV line 752 (Route III) terminates at McKnight substation. This tower therefore is located on a non-RBS associated transmission line.
At- the tine of._ RBS licensing, GSU flew aerial inspections of the transmission system nonthly. The conthly flying schedule did not allow adequate tine for ,
the identification and subsequent inspection and correction of findings by field crews before the next aerial patrol was flown. Since that tire GSU has reduced the flying schedule to approximtely three tines per year. If serious problems are found, prompt corrective actions are undertaken and increased patrols may be utilized.
The current frequency is adequate for detecting and correcting the types of discrepancies for which aerial patrols are used. These include trees growing into conductors, broken insulators, most soil erosion problems, activities in
! the right-of-way, etc. During the next revision cycle, the Usta will be j revised to reflect this reduced frequency of inspection.
It is true that the Imite River has for years been migrating to the west at this location. GSU has been aware of this developnent and has been nonitoring
. by field inspection the progress of the river and its effects on this
- transmission tower since its construction in 1967, hhen the river began undercutting the forty foot deep steel sheet pile cell placed around the base of the tower in 1973 to protect the towr from the erosional effcets of the river, an energency pemit frcm the U.S. Army Corps of Engineers was sougnt 4
and received in 1990 to- repair and stabilize a anall sinkhole fomed in the
' pile cell. Regardless of the frequency of aerial patrols, the subsurface
- undercutting of the base of this tower could not have been observed by aerial inspection early enough to take corrective action. GSU believes that the
, corrective and preventive reasures taken will assure the stability of the l1 tower. In@ection after nujor flocds and counding the riverted depth annual U
, will continue for as long as the pile cell remains in the nnin river channel.
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It is possible, also, that additional neasures nuy be requirrd in the future to assure the continued reliability of this transmission tine.
Since this tcNer is not located on an RBS-associated transmission line arrl since the erosional danage to the pile cell was not observable by aerial patrol, the aerial inspection reports for the last 24 months are not included.
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;. lNCLDGURE 3 EEQUEST FOR INFORMATION:
Section 2.4.3.5.2 of the USAR states that during operation annual inspection and maintenance will be perfomx1 to tutove accumulated vegetation, silt and debris. Section 5.3.3.1 of the n:S states that the deposited sedinent in the mn-made channel of West Creek will have to be periodically renoved fran the channel bottom. Section 2.4.3.3 of the Safety Evaluation Report (SER) states that the applicant will be expected to provide for inspection and maintenance of the man-made portion of West Creek during operation. In Section 2.4.3.3 of Supplenental Safety Evaluation Report (SSER) 2, the NRC staff discusses GSU N cmmitnents to perfom an inspection and maintenance program for the fabriform-lined section of the West Creek channel, including an annual inspection of the creek. In addition, if the sediment buildup is greater than one . foot deep, the channel will be cleaned. The concern is that the sedirent in the channel will impede the flow of water through the channel and that GSU is' not mintaining the West Creek channel properly. Your response should ( include documntation concerning inspection and maintenance efforts perfonmd in accordance with the above references. GSU RESPONSE: Before plant operation tegan in 1985, the tenporary road crossing West Creek at the paint shop was removed along with the sediment and vegetation buildup in the lined section of the creek channel. These events were documented in a letter (RBG-20959, May 13,1985) frun J.E. Booker to NBC's II.R. Denton, Office of Nuclear Reactor -Regulation. Station Support Manual Procedure ESP-8-048
" West Creek Inspections", was established in December,1985 to implecent the maintenance and inspection program. Since the renoval of sedinent in 1985, the buildup, as documented by the West Creek inspections, has not yet warranted subsequent sedinent renoval (i.e. , the accumulated sedinent has not exceeded an overall depth of 1 foot) . The docunentation of West Creek inspections to date is attached.
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; structure) (Fracton of Channel Breadth) l l }
f . Transect i 3/4 1/2 i 1/4 , Average 150 5 14 i 7 i 8.7
, 300 8 13 i 13 i 11.3 450 13 15 , O I 9.3 600 10 15 i 7 i 10.7 750 11 14 5 i 10.0 900 13 17 0 i 10.0 4
1050 11 19 i 12 1 14.0 [ 1200 14 18 13 4 15.0 __350 1 22 17 11 ' 16.7 < 1500- 11 18 11 i 13.3 1650 2 17 i 16 1 11.7 N. of Culvert 1800 24 i o
- 0 i 8.0 S. of culvert 1950 9 0 '
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TRANSECT SEDIMENT DEPTH (INCHES) COMMENTS LOCATION (feet downstream l e from drop Distance from Plant Side Edge (Fraction of Channel Breadth) l structure)
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- 12. t 9.6 i i 300 1 6 i # 5.6 i ?.S i 9 i t 450 I tv i G i y i 8 i
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Io I iY !- 8 i to.b i l 1800 i / (p i /J i % ! 11 l
-1950- I t o.o i o i o X.3 - t t 2100 i o ! O I c3 o i i 2250 i O I 5 i i 2 i !
} 2400 6 7 .i O i o ! 2.3 i i 2550 i C l /r i O i 3. t.o i 1 2700 t- O t a i o i 8 i i i 1 6 i i !
i ' 1 i i i i i i i i l i i i i !
-t t i i I i i i !
l Overall Aerage: b. inches Reviewed \By / O{ \% i ()ubV Supervisor - Environmental Services Date: // -?A &L l
>. _- - - . _ . . . _ _ . - _ ._--_m. _. . . . . _ , . . - ~ . _ . . - . - .. _..__._. _ ... _ . _
e 4)}. l l l i 05UN06e&1th11/05) RIVER BEND STATION ' WEST CREEK INSPECTION LOGSHEET-- Performed By-M+ 01- C6 Date: M ~ '2 I'8 7 - TRANSECT- SEDIMENT DEPTH (INCHES) COMMENTS
' LOCATION l~ >
i
. (feet ;
downstream . i from drop Distance from Plant Side Edge structure) (Fraction of Channel Breadth). i Transect : 3/4 4 1/2 t 1/4 A/erage t 150 1 <f ,o .J i 7 300 i r i r e i i i 450 i ;a i
/0 / c. i tr i +
600- i 9 ! e ! a- 6 3 i 750 ? /c t 7 i <f 7. 7 i 900 i (o i :;L i fe 73 ! 7
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1050 i 3 i /0 i G 6. 3 I 1200 t r i
/0 -6 y i
-- I - 1350 1 -r/ I r #3 /o 7 6 1500 ~/2 i- /4 fo ea 1650 -l 't i / t.' r/ /O -
1800 'i- 21/; i- Ayn S/A- n'iA lAr 2rguT Acepts fu) 1950 I 6 i O V 51 i % fn D b o C at /ve r k 2100 i o- -i o 6 .2 i 2250 i Il e o 5. 7 1 2400 i to d- O y. 3 ! 2550 i /v i o O 3, 3 i 2700 -i ay/e ! -up 4f/t af/> ! >
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! I Overall Aterage: O inches l Reviewed By- M ew[ Date H-b'-Q S rvisor EnvironmentalServices '
l .t I-
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- osven n esota RIVER BEND STATION WEST CREEK INSPECTION LOGSHEET 4
Performed By: bn* d% / (a Date-h / C 9/U~ _ 0 i l TRANSECT COMMENTS ! SEDIMENT DEPTH (INCHES)
! LOCATION ;
l (feet i downstream ! from orop Distance from Plant Side Edge
, structure) ! (Fraction of Channel Breadtn) f l Transect 3/4 1/2 < 1/4 Aerage i 150 i fe (; 9 i
/o
300 i 12 - 5 : (, j 7, ? ! t 450 i ~q r */ t (p n q 600 i e i 7 ; ( i y i i 750 ! c. ! A i 7 i f r i 900 t 3 i r i 7 i 4, 7- 7 i 1050 < 3 c., i s i v. 7 i ' 1200 i 9 i I( i / '
- f. 7 i 1350 ; ? 'y ! / c, i (/ ! I 1500 i #2 i fo j 9 i / o, a ! i i 1650 i c'- i af i p i 7,3 i t I 1800 I C i o i IV ! 4. 7 .
IL4f (O I } .2. 5 e q i 1950 i o i J t 7 1 3 ! j
, e100 i ? ! o ! o i 2.3 i -
2250 i /c j O i o i 33 2400 1 9 I o i 3 i *f I ! i 2550 i i i i i i
! 2700 i ! I i i i i ! ! I L i4 2 7 I f I (3 i /C I \A I M d t st,/ <s, #1%d 44+ts-t I ! I i i ! i l ! I I i i i i i i ! !
! ! i i i i i
Overall Aerage: ' inches Reviewed B 4 t-L - # Date i A- \ -86 pervisor
- Environmental Services 3
DCIDSUIE 4 REQUEST FOR INPOIOMTION: Dn3rgency I1nplenenting Procedure (EIP) 2~026 was revised to reflect the new evacuation route to the Alternate Evacuation Point as a result of resolution of previously raised issues. The concern is that the FIP and other doctents concerning evacuation incorrectly reference louisiana Highway 965, Powll Station Road and Police Jury Road and this could cause scre problems during evacuation. Miitionally, there is a concern that erosion due to flcniing at the inse of the transmission line tcwr and sections of the Police Jury Road rear the alternate assembly point sign nuy hager evacuation. Your response should address efforts to resolve these issues. GSU RESIG:SE: Louisiana Highway 965 traverses south into the center of RBS property frun U.S. Highway 61. Frcxn where the ncu-abandoned Illinois Central Gulf Railroad traversed this road west of the reactor, this state highway becues a Police Jury road and continues south and then east and north, connecting back into U.S. Highway 61 east of the reactor. This Police Jury road is also referred to as Powell Station Road and Mast Feliciana Parish 7. Procedure EIP-2-026, " Evacuation" will be revised to distinguish letween Louisiana Highway 965 and West Feliciana Parish 7 (Powll Station) Ibad to avoid any confusion. In the event of an evacuation, RBS Security personnel will be used to direct evacuees to the assembly area. It should be notcd that the evacuations addressed by this procedure are only for plant personnel and that the general public does not use these evacuation routes. It should also be notcd that this assembly area is nerely an alternate to one of the two preferred assembly areas, and therefore wild not normlly tr used even in the unlikely event of an enargency requiring evacuation of plant parsonnel. Although there has been flooding and sore minor erosica in and near Grants Bayou in the vicinity of the Alternate Evactntion Point Assembly Area, neither the assembly area nor West Feliciana Parish 7 (Powell Station) Road to or from the assembly area are affected. GSU feels that the concerns expressed would not prevent the effective use of this location as an evacuation asserbly area. w-_ --__ _ _ _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ __ _ _ _- - _ - - - _ _ - - _ - - - _ - _ _ _ _ - - - - _ _ _ _ _ - - _ _ _ _ _ _ _ _ -
4
.o # , ,
; HCDSUIE 5 REQUEST IDR INIVINATION Section 5.3.3.1 of the FES states that GSU has performed erosion repair work on the River Access Road to mintain the existing road profile and prevent extension of gullies into Alligator Bayou as a result of flood waters
. overtopping the road. The FES also states that the Corps of Engineers is expected to install a revettent along the levee to stabilize the Mississippi River bank and minimize the impact of levee overtopping. The concern is that the culverts installed undar the River Access Ibad, across Alligator Payou increase erosion problems. Your response should address any recent erosion repair work perforned on the River Access Ibad and the status of the revetmnt installation.
GSU RESIDNSE The hydrolor;y of Alligator Bayou / Mississippi River floodplain in the vicinity of FBS is describc<1 in Sections 4.2.1, 4.3.2.1, and Appendix 2B of the Environnental Ibport - Operating License Stage and in Section 5.3.3.1 of the FES. These documents recognire the flew restriction posed by the River Access Road across the floodplain and ita resulting contribution to
, erosion / overtopping at the low point alcng the river bank / River Ibad. The flow restriction occurs only during certain hydrolcgical conditions end is considered not to be significant.
Overtopping of this road occurred naturally in the past, both fran high river stages and fran rainfall-induced floods. Alligator Bayou is located in a shallow depression or trough in the Mississippi River floodplain on GSU property. As the river channel migrated eastward along this reach of the river tefore tle Corp of Engineers installed a bank stabilizing revetmnt, the lip of the trough (bank) was gradually lowerud. This effectively reduced the storage capacity of the floodplain. Ioss of storage capacity and flow restrictions encountered frcn fallen trees / forest litter and beaver dams mre directly affect the frequency and duration of River Road overtopping than the effect of the culverts. The Corps of Engineers installed its tank stabilizing revetm nt along this stretch of the river in 1988. GSU had discussed with the Corps the possibility of filling in the gully at thu low point prior to the installation of the revetront. This would have provided for the revetment being continuous from GSU's intake embaynent to beyond GSU's northern property boundary. However, the Corps stated that it was thelr policy to wrap the revetrent into the muth of such drainages, and constructed the revotm nt in just such a manner.
'Ihe erosional gully has been greatly stabilized by the Corp's placcrunt of riprap within the gully and by the construction of its revetnent. GSU occasionally makes minor erosion repaira af ter severe bank overtopping events to prevent extension of the erosion gully and to naintain the River Road passable at this low point. If the Piver Road is inpassable on GSU property because of inundation, crosional darage, or other reasons, local landowners are allowed access to their property via our River Access Road.
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