ML12223A220
| ML12223A220 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 01/01/2008 |
| From: | Watts Bar Special Projects Branch |
| To: | |
| Poole J C | |
| References | |
| Download: ML12223A220 (14) | |
Text
Appendix D Final Supplemental Environmental Impact Statement A-125
APPENDIX D - SENSITIVE AREA REVIEW PROCESS
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Appendix D Final Supplemental Environmental Impact Statement A-127 Sensitive Area Review (SAR) Process
This attachment briefly summarizes the environmental compliance review process TVA uses for maintenance and modifications of transmission lines and presents the results of this process, by subject matter area.
Overview of Environmental Compliance Process for Transmission Line Maintenance and Modifications The TVA Transmission and Power Supply - Transmission Operations and Maintenance (TPS-TOM) organization routinely conducts ma intenance activities on transmission lines in the TVA system (TVA Power Service Area). These activities include, but are not restricted to, right-of-way reclearing (remo val of vegetation), pole replacements, installation of lightning arrest ors and counterpoise, and upgrading of existing equipment. Regular maintenance activities are conducted on a cycle of 3-5 years.
Prior to these activities, the transmission line area (including the right-of-way) is reviewed by technical specialists in the TVA Regional Natural Heritage Project, and TVA Cultural Resources group, to identify any resource issues that may occur along that transmission line. These reviews are c onducted on a recurring basis that coincides with the maintenance cycle, to ensure that the most current information is provided to the organizations conducting maintenance on these transmission lines.
The TVA Regional Natural Heritage Projec t maintains a database of some 30,000+
occurrence records for protected plants, ani mals, caves, heronries, eagle nests, and natural areas for the entire TVA Power Serv ice Area, including all 201 counties. All records that are present, or are potentially present, in transmission line right-of-ways are taken into consideration when conducting t hese transmission line reviews. Wetland information is maintained by TVA Resource Services and includes NWI wetland maps
for the entire TVA Power Service Area. So il survey maps are also used to identify potential wetland areas. The TVA Cultural Resources group maintains records of known archaeological sites, and routinely gat hers information from the seven-state TVA Power Service Area.
Also included in this document is the explanation of Sensitive Area Review (SAR) Class Definitions and associated table of mapping polygon colors, and the restrictions indicated by those designations.
(Managed Areas) - Managed Areas, Ecologically Significant Sites, and National Rivers Inventory for Maintenance Activiti es in TVA Transmission Line Rights-of-Way Managed Areas (MA) are lands held in public ownership that are managed to protect and maintain certain ecological features. Ecologically Significant Sites (ESS) are tracts Single Nuclear Unit at the Bellefonte Site A- Final Supplemental Environmental Impact Statement A-128 of privately owned land that are identified by resource biologists as containing significant environmental resources. National River Inventory (NRI) streams are free-flowing river segments that ar e recognized by the National Park Service as possessing remarkable natural or cultural values. T he TVA Natural Heritage Project maintains a database of all such lands and streams o ccurring within the seven state TVA power service area.
Sensitive area reviews for MA's, ESS's, and NRI streams are completed by utilizing computerized mapping graphics software known as ArcMap. If a MA, ESS, and/or NRI stream is located within the 0.5-mile buffer of the subject transmission line, a polygon is drawn that represents the area's boundaries within the buffer. A description of the area that includes contact informati on, restrictions, and the subj ect transmission line name is listed in the corresponding attribute table.
Right-of-way (ROW) maintenance and/or cleari ng and pole replacement activities are the two areas that are reviewed for the presence of sensitive resources in SARs. If all or any portion of a MA, ESS, and/or NRI stream lies within the buffer of the subject transmission line, a polygon is drawn depicting the boundary of such areas. Restrictions on proposed activities (Class 0, 1 2, or 3 below) are determined by the type and location of the MA, ESS, and/or NRI streams as well as consultation with the area manager or resource specialist. The class and contact rest rictions, definitions, and polygon color for both activities are listed in the included table.
After determining the particular class restriction associated with the area, special
instructions or comments are added to indica te the importance of the restriction and why it was assigned. For ex ample, when a portion of a national forest is within the 0.5-mile buffer or crossed by the subject transmission line, a Class 3 restriction is assigned and a comment is added indicating the area manager must be cont acted and herbicide use is restricted.
Under Categorical Exclusions, transmission line projects such as lightning mitigation, counterpoise activities, conveyances, line relocations for state highway department work, and providing delivery points and switc hes for substations are reviewed for potential impacts to MA's, ESS's, and NRI stream
- s. A three mile radi us of the project site(s) is reviewed for MA's, ESS's, and NRI streams that might be affected by the proposed activity.
(Botany) - State and Federal listed plant restrictions for Mainte nance Activities in TVA Transmission Line Rights-of-Way Botanical assessments are completed for Sensitive Area Reviews (SARs) in order to identify state and federally list ed plants that occur within a five mile radius of the transmission line. Identifying the occurrences gives us the ability to identify habitats within a proposed project area th at are sensitive and potentially require restrictions from activities. To identify rare plant and sensitive habitat locations we utilize the TVA Natural Heritage database, aerial photogr aphs and USGS topographical maps.
Appendix D Final Supplemental Environmental Impact Statement A-129 Transmission line SAR activities include ri ght-of-way (ROW) maintenance/reclearing and pole replacements. The review process for the two activities is different since they potentially impact vegetation in different ways. ROW maintenance consists of vegetation clearing with herbicides unless otherwise specified. Herbicides kill all vegetation that is sprayed. Mechanical clearing has less of an impact since many plants can tolerate being cut. Pole replac ements potentially impact vegetation when vehicles and equipment drive on and in the vicinity of the ROW and the soil and the vegetation are disturbed. If there are sensitive plants in the vicinity we recommend different access routes to be taken and we notify individuals of sensitive areas to avoid.
Restrictions are determined by our knowledge of the habitat requirem ents for rare plants and rare plant communities that occur within t he vicinity of the ROW. Once a sensitive area is located a polygon designating the known or likely extent of that occurrence is drawn on an ArcMap electroni c topographic map, and appropriate class restrictions are applied (see table of Class Definitions and Associated Polygon Colors of Sensitive Areas).
(Terrestrial Animals) - Stat e and Federal Protected Terrest rial Animal restrictions for Sensitive Area Reviews (SARs) conducted in support of Maintenance Activities in TVA Transmission Line Rights-of-Way The TVA Regional Natural Heritage Program keeps track of state and federal protected species reported from the seven-state region.
The terrestrial animal portion of the data base includes all listed birds (breedi ng and large wintering aggregations), mammals, reptiles, and amphibians. In addition to specific species of animals, the terrestrial portion of the database also includes records of heronries and caves as they often are used by multiple species.
Each SAR project is reviewed for the presence of protected terrestrial animals. A 1-mile radius of the project site(s) is typica lly reviewed for each proposed activity along transmission lines. Once an occurrence is located a polygon designating the known or likely extent of that occurrence is drawn on an ArcMap electronic topographic map (see included maps), and appropriate class restrict ions are applied (see included table of Class Definitions and Associated Polygon Co lors of Sensitive Areas). Special comments or instructions accompany each entry as appropriate. For instance, if a cave is located along a powerline corridor schedule for vegetative maintenance, a 200-foot buffer is indicated around the opening of the cave and a "Hand Clearing Only" restriction is applied within the buffer. If the cave is used by a summer or hibernating colony of bats, appropriate time restrictions, as designa ted in specific recovery plans for each species, are also applied.
Single Nuclear Unit at the Bellefonte Site A- Final Supplemental Environmental Impact Statement A-130(Aquatic Animals) - State and Federal Prot ected Aquatic Animal restrictions for Maintenance Activities in TVA Transmission Line Rights-of-Way The TVA Regional Natural Heritage Program k eeps track of state and federal protected species reported from the seven-state region. Aquatic animal occurrence records are maintained and updated by TVA Heri tage staff on a regular basis.
Each SAR project is reviewed for the known or likely occurrence of protected aquatic
animals in streams in or adjac ent to the transmission line ri ght-of-way. A 10 mile buffer around the transmission line being reviewed is examined to determine the likely occurrence of protected aquatic animals. On ce an occurrence is located, appropriate class restrictions are applied and the appropriate colored polygon is drawn around the
resource area on an ArcMap electronic t opographic map (see included maps and table of Class Definitions and Associated Polygon Colors of Sensitive Areas). All transmission line maintenance activities are currently conducted using Best Management Practices as outlined in Muncy (1999). Special comments or instructions (including designation of specific Streamside Management Zones) accompany each entry as appropriate.
(Wetlands) - Wetlands Review for Mainte nance Activities in TVA Transmission Line Rights-of-Way
Prior to the performance of any maintenance activities in TVA transmission line ROWs, office-level reviews are conducted by Natura l Heritage wetland biologists. This review includes review of the National Wetland Inv entory (NWI) map, county soil surveys, and TVA photos of transmission line structures. Potential wetland areas, not indicated on the NWI map, are identified based on interpretation of topographic features, water bodies, soils information, TVA photos and proxim ity to NWI features. All NWI wetlands or potential wetland areas are superimposed as layers on an ArcMap electronic topographic map (see included maps). Thes e ArcMap images are s ent to the client accompanied by the Wetlands ROW and Pole Replacement Guidelines and an Excel spread sheet which lists areas that have been included with the NW I data as areas of potential wetlands and what guidelines are to be used.
The NWI wetlands are indicated (in dark blue outline) on the ArcMap drawings for both the ROW and a 1-mile diameter buffer area around the ROW. Pot ential wetland areas are identified (in dark pi nk outline) in the ROW, but are not identified in the buffer area, parts of which may be used for ROW access.
If the access route follows an existing road that does not require any repair or upgrading, no further wetland reviews are needed. Repair and upgrading includes, but is not limited to grading, fill addition, new
or upgraded stream crossings, and vegetation removal. If a new or upgraded access route is necessary, environmental reviews of those particular access areas are conducted as required by the National Environmental Policy Act (NEPA).
The National Wetland Inventory (NWI) dat a was compiled using high-altitude aerial photography, some of which is no w over 15 years old, with very limited field verification.
Appendix D Final Supplemental Environmental Impact Statement A-131 Because of this, some of t he NWI data may be inaccurate.
The limitations of the NWI data are considered in the performance of ROW maintenance and pole replacement to avoid accidental wetland impacts. Since there could be wetlands present for which no map evidence or other data currently exists, maintenance crews remain alert to such things as water on the surface of the ground, soil saturation, the type of vegetation growing in an area, and evidence of present, seasonal or temporary flooding.
In the absence of a ground survey by a wetlands specialist to determine wetland
presence and location for ROW reclearing or pole replacements, Best Management Practices, as described in Muncy (1999), and TPS Environmental Quality Specifications for ROW Construction and Maintenance ar e implemented to avoid and minimize potential impacts (see attached Wetlands Gui delines for ROW and Pole Replacement). These techniques would be implemented in all locations where NWI wetlands and
potential wetland areas are indi cated on the project maps s ubmitted by the TVA Natural Heritage staff.
Site-specific recommendations for ROW reclearing include the following:
Depending on site conditions, Level B tree-cutting guidelines, or methods CM-2, CM-3, CM-4, or CM-5 may be used for tree clearing (Muncy 1999). These methods specify techniques for tree clearing and removal that are selected based on wetland hydrology and condition in order to avoid and
minimize wetland impacts. According to method CM-6 (Muncy 1999), if the wetland is a scrub-shrub, emergent, or grazed wetland, ther e should be no equipment entry, and minimal intrusion by all mechanized equipment. For aerial or ground herbicide applicati on, use is restricted to those herbicides that are EPA-approved for use in aquatic areas. If possible, mechanical clearing should be conducted when the ground is dry or minimally saturated. Ruts should be minimized to avoid altered hydrologic patterns, soil compaction, and disruptions in vegetation regeneration.
Specific recommendations for pole replac ement activities include the following:
Entry of vehicles or heavy equipment in wetlands should be avoided when possible. If entry is unavoidable, appropriate measures such as mats and low-ground pressure equipment should be used. Impacts to vegetation should be avoided or minimized.
In addition, certain activities that may o ccur during pole replacem ent in wetlands are regulated under Sections 404 and 401 of the Clean Water Act. U.S. Army Corps of Single Nuclear Unit at the Bellefonte Site A- Final Supplemental Environmental Impact Statement A-132 Engineers (USACE) Nationwide General Permit (NWP) #12 author izes certain activities related to utility line construction and contains conditions to ensure that impacts to wetlands are minimal. Section 401 gives states the authority to certify whether activities permitted under Section 404 are in accordance with state water quality standards (Strand, 1997). A qualified TVA or TVA contract wetlands specialist would be required to delineate the wetland(s) and provide the wetland determination data forms which are required for inclusion in the permit application. TVA also follows Executive Order 11990 which requires all federal agencies to minimi ze the destruction, loss, or degradation of wetlands, and to preserve and enhance the natural and beneficial values of wetlands, in carrying out the agency's responsibilities.
Potential impacts to wetlands resulting from right-of-way maintenance activities include vegetation damage, soil compaction and eros ion, sedimentation, and hydrologic alterations. These impacts are avoided or minimized during TVA maintenance operations by following the recommendations of the guidelines presented above and implementing all relevant Best Management Pr actices. In addition, the appropriate
permits are obtained if required for the specific activity.
(Cultural) - Cultural Resource Reviews Related to Operations and Maintenance Activities in TVA Transmission Line Rights-of-Way Regulatory Background The National Historic Preservation Act of 1979 (NHPA) made hist oric preservation a statutory and regulatory res ponsibility of federal government agencies and established procedures to be followed for hi storic preservation. Generally speaking, any TVA action involving construction and/or ground disturbi ng activity is subject to NHPA. The concepts "historic property" and "undertaking" ar e critical underpinnings of the Act. The NHPA defines historic property as "any prehistoric or hi storic district, site, building, structure, or object included in, or eligible for inclusion in, the National Register of Historic Places." The Secretary of the Interior is the Keeper of the Nationa l Register of Historic Places ("the National Register"), whic h is maintained by the National Park Service. Much of the regulatory language of the Act describes the processes by which districts, sites, buildings, or structures are assessed for listing in the National Register.
An undertaking is "a project, activity, or program funded in whole or in part under the direst or indirect jurisdic tion of a Federal Agency."
Section 106 of the NHPA requires TVA to 1) cons ider the effect of its actions on historic properties and 2) allow the Advisory Council on Historic Preservation an opportunity to comment on the action. Section 106 involves four steps: 1) initiate the process; 2) identify historic properties; 3) assess adverse effects; and 4) resolve adverse effects.
One of the main responsibilities of TVA Cultural Resources is to carry out these four steps. The process involves documentar y research and field reconnaissance for identifying cultural resources (such as artifacts, sites, or historic structures); determining whether any identified cu ltural resources are eligible for listing on the National Register, and therefore should be considered "historic properties"; assessing whether a proposed Appendix D Final Supplemental Environmental Impact Statement A-133 undertaking will cause adverse affects to any historic properties; and recommending ways to resolve adverse effects, namely av oidance or mitigation. This process is carried out in consultation with the State Historic Preservation Officer of the state in which the undertaking takes place and with any other interested consulting parties including federally recognized Indian tribes.
The construction, maintenance, and operation of TVA transmission lines all constitute
undertakings and as such are subject to the NHPA and its implement ing regulations at 36CFR800. Examples of maintenance activi ties associated with transmission lines are spraying herbicides and replacing individual pol es. Such activities are reviewed by TVA Cultural Resources staff on a case-by-case basis using the Sensitive Area Review (SAR) procedure. The purpose of an SAR Cultural Resources review is to identify
whether the undertaking has any potential for adverse effects on cultural resources such as historic structures or buried prehi storic sites. If the undertaking does have potential for adverse effects, then procedures for avoidance or mitigation of the effects are put into place.
How TVA Cultural Resources Conducts SA Rs for Transmission Operations and Maintenance Projects
TVA Cultural Resources staf f examine topographic maps of the project site for (a) previously recorded archaeological sites in the vicinity of the trans mission line corridor; and (b) conditions that suggest high potential for archaeological sites including low slope (< 10%), proximity to major water sources, and lack of modern disturbance.
ArcView GIS is used to identify areas with potential for cultural resources. The decision to do a field review is based on such information along with any information the staff can glean from videos of the tr ansmission line corridors and from still photographs of the project site.
Field reviews are conducted by Cultural Resources staff or by consulting archaeologists, who look for signs of intact , buried prehistoric deposits using surface survey and sub-surface probes (when appropriate). The project is cleared if no artifacts or features identified and if the project site appears to ha ve a low potential for cultural resources. If intact buried deposits contai ning cultural resources are discovered, an attempt is made to discern whet her the site may be potentially eligible for the National Register. A formal assessment of eligibility would not be undertaken during a field review, however. If the site may be eligible, then a Phase I investigation is called for. A Phase I might also be called for there is a high potential for intact buried deposits, even if no artifacts or features were identified dur ing field review. The purposes of a Phase I investigation are to delimit the boundaries of a site, gather addi tional information relating to the site's eligibility (such as integrity), and assess possible effects to the site from the undertaking.
Avoidance is generally feasible for transmissi on line maintenance projects when cultural resources are present. ArcView GIS is used to generate a map showing polygons Single Nuclear Unit at the Bellefonte Site A- Final Supplemental Environmental Impact Statement A-134 around those cultural resources, representing sensitive areas.
Areas that are sensitive from the standpoint of cultural resources are coded Level 2, which indicates restrictions on methods of clearing (no mechanized equipm ent). These maps are provided to TPS prior to any maintenance activities on the line, so that crew supervisors will be aware of the necessary restrictions. Restrictions are typically called for when a previously recorded cemetery, prehistoric mound, or ear thwork occurs within 0.25 miles of the transmission line.
Appendix D Final Supplemental Environmental Impact Statement A-135 Class Definitions and Associated Pol ygon Colors of Sens itive Areas for RIGHT-OF-WAY RECLEARING Sensitive Area Reviews Terrestrial Plants (A), Terrestrial Animals (D), and Aquatic Animals (E)
Class Restriction if Sensitive area in ROW Restriction for Sensitive Areas Potentially Affected when Accessing ROW Polygon Color 1 No broadcast spraying. Use one of the three following alternatives: 1) Hand or mechanical clearing, 2) Request field surveys by TVA Heritage staff to determine if suitable habitat for these species exists in the subject area, 3)
Selective spraying of herbicides to shrubs or
tree saplings less than 12 feet in height.
Not Applicable Yellow 2 Hand-clearing only. Vehicles and equipment restricted from area unless confined to existing access road. Special circumstance. Must contact Heritage Botanist prior to entering or conducting maintenance in subject area.
Vehicles and equipment restricted from area unless confined to existing access road. Red 0 Special circumstance.
Terrestrial Animals - Indiana Bat Summer Roosting Habitat - Trees can only be cut between November 15 and March 31. If cutting is necessary outside of this time restriction, a bat mist-net survey is necessary.
Green Wetlands* (C)
-
Wetlands obtained from National Wetland Inventory data. Refer to "Wetlands ROW and Pole Replacement Guidelines" for restrictions.
Blue Outline 1 Potential wetlands identified by Natural Heritage wetland biologists based on interpretation of topographic features, water bodies, soil surveys and proximity to NWI
features. Refer to "Wetlands ROW and Pole Replacement Guidelines" for restrictions.
Pink Outline Single Nuclear Unit at the Bellefonte Site A- Final Supplemental Environmental Impact Statement A-136 Natural Areas (B)
Class Call** Definition Color 1 No Same as Class 1 definition above.
Yellow 2 No Same as Class 2 definition above.
Red 1 Yes Same as Class 1 definition above, and must contact area manager prior to entering or conducting maintenance in subject area
Yellow hatching 2
Yes Same as Class 2 definition above, and must contact area manager prior to entering or conducting maintenance in subject area.
Red hatching 3 Yes Must contact area manager prior to entering or conducting maintenance in subject area.
Neon Green 0
Special circumstance.
Green Archaeology (F)
Class Restriction if Sensitive area in ROW Restriction for Sensitive Areas Potentially Affected when Accessing ROW Color 1 Mechanical clearing must be conducted when the ground is dry and firm. If bulldozer is used, blade must be kept above ground surface to avoid ground disturbance. Material from clearing (timber, brush, and large debris) must be removed from sensitive area.
Vehicles and equipment must be confined to existing access road.
Yellow 2 No mechanical clearing. Hand-clearing only (chainsaws may be used but not heavy equipment). Debris from clearing must be hand-carried out of sensitive area.
All vehicles must be low-pressured tire equipment and must be confined to existing access road.
Red
- Refer to Wetlands Statement included in this package.
- The "Call" column on the accompanying datasheets is used by Natural Area specialists only. A blank in the column indicates no call is necessary.
Appendix D Final Supplemental Environmental Impact Statement A-137 Class Definitions and Associated Polygon Colors of Sensitive Areas for POLE REPLACEMENT Sensitive Area Reviews All Resources Areas (Plants, Natural Areas, Wetlands, Terrestrial Animals, and Aquatic Animals)
Class Restriction Color 1 Botany: Sensitive Botanical resources are known from the area. Details of proposed activities should be submitted to TVA Heritage staff to determine if the proposed activities require restrictions.
Natural Areas: Refer to table accompanying project for restrictions.
Wetlands: Potential wetlands identified by Natural Heritage wetland biologists based on interpretation of topographic features, water bodies, soil surveys and proximity to NWI features. Refer to "Wetlands ROW and Pole Replacement Guidelines" for restrictions. Terrestrial Animals: Refer to table accompanying project for restrictions.
Aquatic Animals: Refer to table accompanying project for restrictions.
Pink Wetlands -
Wetlands obtained from National Wetland Inventory data. Re fer to "Wetlands ROW and Pole Replacement Guidelines" for restrictions.
Blue Outline Archaeology Color Class Restriction
1 Presence of significant below-ground cultural resources is highly likely. Work must be scheduled when ground is dry and firm. Only vehicles with low-pressured tires may be used within sensitive area. If structure is a pole, new poles must be placed in existing holes; if structure is a tower, existing footings must be used for new tower. If guy wires are used, existing guy wire anchors must be used for new structure. If any of these conditions can not be met, then details of proposed activities (nature of work, date work is to take place) must be submitted to TVA Cultural Resources staff so that a field review can be scheduled.
Yellow 2
Presence of significant cultural resources is known. Work schedule must be submitted to TVA Cultural Resources staff so that a field review can be scheduled.
Red Single Nuclear Unit at the Bellefonte Site A- Final Supplemental Environmental Impact Statement A-138
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