ML071430593

Wolf Creek, Response 64, to Master List for Audit Needs of NRC Request for Additional Information Re License Renewal Application

ML071430593
Person / Time
Site:	Wolf Creek
Issue date:	05/09/2007
From:	Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 07-0017
Download: ML071430593 (13)

Text

64. Details regarding the maintenance procedures used in the transmission line ROWs, including mechanical, chemical, and biological control methods for vegetation management.

Terrestrial Ecology.Page I of I* Clarify discussions regarding site boundaries, land ownership, and land use within Section 2.4 and Figure 2-3 of the ER (WCGS, 1980). Clarify the difference between"Site Boundary" and the "Plant Site" on the map, with respect to whether these are a land ownership distinction, a physical fencing distinction, or some other regulatory or access distinction.

Please claarify whether or not the referenced agricultural production areas are within the "Site Boundary" as shown on Figure 2-3. Identify any areas fenced to restrict human access and any areas fenced that may restrict wildlife access.* Additional data on the avian collision studies that were ceased in 1986. Section 2.4 of the ER (WCGS, 1980) states that sufficient data had been collected by 1986. Provide any documentation of regulatory involvement and concurrence in this determination of sufficiency.

• Details on the power transmission system, including information on the design of the towers, the number and configuration of the lines on the towers within each right-of-way (ROW).* Details regarding the maintenance procedures used in the transmission line ROWs, including mechanical, chemical, and biological control methods for vegetation management.

More detailed maps/aerial photos of the transmission line ROWs showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains, and the location of the Sharpe Generating Station.* Please provide information on the locations of transmission line ROWs crossings with parks, wildlife refuges, or wildlife management areas, or any major lakes (in addition to CCL), ponds, or streams? If so, please provide information on these crossings and their locations.

-Any available studies or other information about the issues raised in the letter from the U.S. Fish and Wildlife Service (November 14, 2005) regarding terrestrial threatened and endangered species.For example:-Any assessments of the transmission lines for conformity with "Suggested Practices for Raptor Protection on Power Lines" (Raptor Research Foundation 1996)? Please provide any such assessments and details of transmission line construction relevant to raptor protection.

Also provide a copy of "Suggested Practices," if available.

-- Any special ROW maintenance procedures used to reduce the potential for impacts to Mead's milkweed or animals with federal or state listing status.* Any available maps and aerial photographs of the WCGS plant site and the area within and adjoining the larger site boundary (which encompasses CCL) showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains.

-Any available information identifying natural communities and dominant species of plants and animals that utilize terrestrial habitats of the site and the transmission line ROWs, as well as semiaquatic species such as waterfowl that use Lime Sludge Pond and CCL.

Westar Energy, Inc.Transmission Line Vegetation Management Program

)I

Introduction:

'

This document describes the Westar Energy, Inc. and Kansas Gas and Electric Company ("Westar Energy") transmission line vegetation management program. This program applies to Westar Energy transmission lines of 69 KV through 345 KV and is designed to address vegetation management issues related both to newly designed transmission lines and to the management of vegetation along existing transmission line rights-of-way.

This program is designed to allow each transmission line to operate at full rated capacity under the conditions for which it was designed without any outage caused by an energized line contacting vegetation.

I) Design of New Transmission Lines: A) Development of New Line Routes -Transmission line routing decisions shall be made based in part on current and expected vegetation growth and encroachment.

Where possible, new lines should be routed to avoid heavily wooded areas. When this is impossible due to other competing design considerations, the transmission line design engineer shall consider specifying a wider than normal right-of-way. This is particularly important in areas that contain trees that are tall enough so that toppling clearance by vegetation would be impossible to maintain using a right-of-way of standard width.B) Right-of-Way and Easement Documents

-Easements obtained for new transmission lines should incorporate language that clearly provides Westar Energy with the rights required to initially clear the full width of right-of-way from the ground to the sky. The easement documents should allow Westar Energy to maintain the right-of-way free of encroaching vegetation that may interfere with the line's operation at full capacity.

Rights to selectively remove and/or prune tall trees located off the right-of-way that may present a hazard to the transmission line should also be included.

The easement documents should also provide Westar Energy with the flexibility to use all commonly approved methods of vegetation management.

DII) Ongoing Transmission Line Vegetation Management Operations:

A) Vegetation Management Program: i) Transmission Line Vegetation Management Objectives

-This program is designed to allow each transmission line to operate at its full rated capacity under the conditions for which it was designed without any outages caused by vegetation contact with an energized line.ii) Transmission Line Vegetation Management Methods: a) Cross-Country Transmission Line Rights-of-Way

-The first step in managing the vegetation on these transmission line rights-of-way is to mechanically mow and prune to clear vegetation from the floor and sides of the right-of-way.

One to two years later, herbicide should be applied to the full width of the right-of-way to control re-sprouting of the woody vegetation that was previously mowed. This step is critically important because repeated mowing of a transmission line right-of-way without the application of herbicides to control re-sprouting will result in much higher stem counts due to shattering of each stump caused by the mowing. By the same token, application of herbicides to woody vegetation that has been allowed to get more than about 5' high will require a very high volume of herbicide to provide effective control. This may not be cost effective and will result in dead vegetation standing on the right-of-way for a long time before it finally decays and falls over. Many property owners dislike the 2 appearance of standing dead vegetation and their ill feelings may make it difficult to maintain a good working relationship between Westar Energy and the property owner. A second application of herbicide may be required two to four years later to further control re-sprouting if stem counts were originally very high. When stem counts have been sufficiently reduced, herbicides can be more selectively applied at about five-year intervals to maintain the right-of-way free of woody vegetation of more than a few feet tall. Every ten to fifteen years typically, it may be necessary to mechanically prune trees located just outside of the right-of-way to prevent their canopies from encroaching into the right-of-way.

Although the time intervals referenced herein are fairly typical of what is required in Westar Energy's service territory, the exact timing can vary somewhat due to available moisture and soil conditions across the area. Scheduling will be driven by the vegetation management inspections conducted periodically on Westar Energy's transmission system. The inspection process will be discussed in more detail in another part of this vegetation management program document.b) Transmission Lines Located in Urban Areas -Due to the nature of managing vegetation located along city streets and alleys and in the landscaped yards of urban property owners, vegetation management techniques utilized to manage cross country transmission line rights-of-way cannot generally be employed.

Vegetation management techniques generally used for distribution line rights-of-way (pruning trees and selective removal of trees using crews equipped with bucket trucks and manual climbing crews)are more often used rather than mechanical clearing of the entire right-of-way and extensive use of herbicides to control re-sprouting.

Most transmission lines located along streets and alleys in urban areas are constructed using single-pole structures and relatively short span lengths. For this reason, much narrower rights-of-way are used and frequently lines are placed in public right-of-way along streets and alleys or in a public utility easement rather than located on a transmission line easement dedicated to Westar Energy. As a result, vegetation management rights are generally not as well defined. In many cases, we must be content with clearing to the ground the area within the wire zone (defined as outside phase to outside phase plus 10'on each side) and then pruning trees located outside this wire zone using natural pruning methods to limit re-growth toward the transmission line. In many cases, less clearance can be obtained so the time between pruning cycles is limited to four or five years. The time between pruning is determined by the periodic vegetation management inspections done on the Westar Energy transmission system. The inspection process will be discussed in more detail in another part of this vegetation management program document.c) Understanding Work Load -Westar Energy maintains a record of the length of each transmission line in the system. Beginning in 2003, Westar Energy tracked the cost spent to systematically clear or do hot spot pruning on each line. Data gathered by the periodic vegetation management inspections is perhaps the most important element in understanding the scope of the work needed to complete each year. Using all these types of information validated by knowledge of the system, a transmission line vegetation management work plan should be developed each summer that identifies the lines to be cleared the following year. This plan should be used to establish the transmission line vegetation management budget for the following year.B) Annual Transmission Line Vegetation Management Work Plan: i) Transmission Line Vegetation Management Inspections

-Westar Energy conducts two inspections of the complete transmission system each year that are intended primarily to assess the system's need for vegetation management.

These inspections are generally conducted in May and September of each year.These inspection results shall be documented and any inspection results that indicate conditions that could cause an imminent outage should be cleared forthwith.

These results should then be used to develop a plan for the following year's transmission line vegetation management work.3 ii) Transmission Line Vegetation Management Schedules

-Since the mid-1990's, Westar Energy has kept historical data of when each line section was mechanically cleared, when herbicide was applied and when any hot spot vegetation management work was completed.

This historical data shall be combined with the results of the transmission line vegetation management inspection conducted in May of each year. This combination of data should then be used to create an annual plan that identifies when each transmission line segment should receive a complete mechanical clearing, the systematic application of herbicide or selectively targeted hot spot mechanical clearing or herbicide application.

These schedules should be used to determine transmission line vegetation management budget requirements for the following year.iii) Transmission Line Vegetation Manaaement Funding -Creating the transmission line vegetation management schedules in early summer each year serves to identify the work to be funded in the following year's transmission line vegetation management budget The transmission line vegetation management budget should be based on the scope of the vegetation management work plan for the year and should only be modified to reflect changes in actual conditions (higher or lower than anticipated labor bids, equipment cost, herbicide cost, etc).iv) Transmission Line Vegetation Managfement Quality Assurance

-Completion of each line section included in the annual transmission line vegetation management plan shall be documented.

For each line section, a document shall be prepared and signed by the line inspector and the line clearance manager that supervised the work certifying that the work was completed in accordance with the applicable contractual specifications.

C) Transmission Line Clearance Standards for Vegetation:

i) Clearance Standards

-The clearance standards noted in the table shown in Appendix A represent the minimum acceptable clearance immediately before the next time that vegetation management work is done on a given transmission line. More clearance than these minimufi standards must be obtained when work is performed so that the minimum standards are maintained as the vegetation grows for a period of time before the next time that vegetation management work is performed.

The amount of clearance obtained from the conductor for a particular type of vegetation when the work is performed will vary depending upon vegetation species, growth habit, availability of water, etc. The clearance standards for each transmission line voltage used by Westar Energy are shown in the attached Appendix A.D) Personnel Qualifications and Training: i) Personnel Qualifications

-Westar Energy employees and employees of the contractors employed by Westar Energy to perform vegetation management work shall be qualified by education, experience and training to perform, supervise and manage the activities needed to implement the Westar Energy transmission line vegetation management program.ii) Personnel Trainina -Contractor employees shall be trained and certified in accordance with all federal, state and local regulations as required by the work being performed.

The contractor shall ensure that all contractor employees are thoroughly trained to understand the contractual requirements of the work being performed.

The contractor shall further ensure that all contractor employees are properly trained in accordance with OSHA requirements and ANSI Z133.1-2000 and ANSI A300 for the type of work being undertaken.

All training shall be properly documented and available for audit inspection if required.4 E) Communications:

i) Transmission Line Outage Prevention

-Westar Energy employees and vegetation management contractor employees shall immediately report to the Westar Energy transmission operator any vegetation conditions that present an imminent threat of a transmission line outage or a reduction in transmission line rating. The Westar Energy transmission operations group shall report these conditions as appropriate to the governing reliability authority.

5 VERIFICATION I hereby verify that the responses in the forgoing report are accurate and representative of Westar Energy, Inc.'s activity related to transmission line vegetation management activities.

Signa e Name ,-IZE /4, 4 jp-PE. V- Date Title 6 Appendix A -Westar Energy Transmission Line Vegetation Management Clearance Standards Subject 345 KV 230 KV 161 KV, 138 KV 115 KV 69 KV Range of ROW Width 150-200 feet 75-150 feet 50-150 feet 50-150 feet 50-100 feet 50-100 feet Maintained Widths vary depending Widths vary depending Widths vary depending Widths vary depending Widths vary depending Widths vary depending on site-related factors, on site-related factors, on site-related factors,, on site-related factors, on site-related factors, on site-related factors, such as right-of-way such as right-of-way such as right-of-way such as right-of-way such as right-of-way such as right-of-way agreements with agreements with agreements with agreements with agreements with agreements with property owners, property owners, property owners, property owners, property owners, property owners, multiple lines In a multiple lines In a multiple lines In a multiple lines in a multiple lines in a multiple lines in a corridor, terrain, corridor, terrain, corridor, terrain, corridor, terrain, corridor, terrain, corridor, terrain, construction type (single construction (single pole, construction type (single construction (single pole, construction (single pole, construction (single pole, pole, steel lattice tower steel lattice tower or H- pole, steel lattice tower steel lattice tower or H- steel lattice tower or H- steel lattice tower or HT or H-frame structure, for frame structure, for or H-frame structure, for frame structure, for frame structure, for frame structure, for example) and other example) and other example) and other example) and other example) and other example) and other reasons. Most 345 KV reasons, Most 230 KV reasons. Most 161 KV reasons. Most 138 KV reasons. Most 115 KV reasons. Most 69 KV rights-of-way are 150 rights-of-way are 100 rights-of-way are 100 rights-of-way are 100 rights-of-way are 100 rights-of-way are 50 feet feet wide. feet wide. feet wide. feet wide. feet wide. wide, Minimum Clearance Horizontal:

20 feet Horizontal:

15 feet Horizontal:

10 feet Horizontal:

9.5 feet Horizontal:

9 feet Horizontal:

8.25 feet Standards Vertical:

25 feet Vertical:

20 feet Vertical:

10.5 feet Vertical:

.10 feet Vertical:

9.5 feet Vertical:

8.75 feet Standards Utilized for 1). Westar Energy 1). Westar Energy 1). Westar Energy 1). Westar Energy 1). Westar Energy 1). Wester Energy Clearances transmission line transmission line transmission line transmission line transmission line transmission line vegetation management vegetation management vegetation management vegetation management vegetation management vegetation management standards.

standards, standards.

standards.

.standards, standards.

2). NESC Rule 2181. 2). NESC Rule 2181. 2). NESC Rule 2181. 2). NESC Rule 218'. 2). NESC Rule 2181. 2). NESC Rule 2181.3). ANSI Z133.1-2000 2.3). ANSIZ133.1-2000 2.3). ANSI Z133.1-2000 2.3). ANSI Z133.1-2000 2.3). ANSI Zt33.1-2000 2.3). ANSI Z133.1-2000e.

4). ANSI A300 (Part 1)- 4). ANSI A300 (Part 1)- 4). ANSI A300 (Part 1)- 4). ANSI A300 (Part 1)- 4). ANSI A300 (Part 1)- 4). ANSI A300 (Part 1)-20012. 20012. 20012. 20012. 20012. 20012.Ground inspection One Line-Twice Most Urban Lines-Twice Most Urban Lines-Twice Most Urban Lines-Twice Most Urban Lines--Twice None annually' annually annually annually annually Aerial Inspection All Others-Twice Cross-Country Lines- Cross-Country Lines- Cross-Country Lines- Cross-Country Lines-Twice annually annually 3 Twice annually Twice annually Twice annually Twice annually Appendix A -Westar Energy Transmission Line Vegetation Management Clearance Standards Subject .345 KV 230 KV 161 KV 138 KV I 115 KV I 69 KV Vegetation 1). Mow all woody 1). Mow all woody 1). Mow all woody i). Mow all woody 1). Mow all woody 1). Mow all woody Management Strategy vegetation whose truhk vegetation whose trunk vegetation whose trunk vegetation whose trunk vegetation whose trunk vegetation whose trunk is within the ROW is within the ROW is within the ROW is within the ROW is within the ROW is within the ROW corridor.

corridor.

corridor, corridor, corridor, corridor.2). Prune trees with 2). Prune trees with 2). Prune trees with 2). Prune trees with 2). Prune trees with 2). Prune trees with trunks outside the ROW trunks outside the ROW trunks outside the ROW trunks outside the ROW trunks outside the ROW trunks outside the ROW corridor at the edge of corridor at the edge of corridor at the edge of corridor at the edge of corridor at the edge of corridor at the edge of the ROW corridor to the ROW corridor to the ROW corridor to the ROW corridor to the ROW corridor to the ROW corridor to provide appropriate provide appropriate provide appropriate provide appropriate provide appropriate provide appropriate lateral clearance from lateral clearance from lateral clearance from lateral clearance from lateral clearance from lateral clearance from the phase conductors, the phase conductors, the phase conductors, the phase conductors, the phase conductors, the phase conductors.

3): Apply herbicide to 3). Apply herbicide to 3). Apply herbicide to 3). Apply herbicide to 3). Apply herbicide to 3). Apply herbicide to cut stumps to prevent cut stumps to prevent cut stumps to prevent cut stumps to prevent cut stumps to prevent, cut stumps to prevent resprouting.

Spray resprouting.

Spray resprouting.

Spray resprouting.

Spray resprouting.

Spray resprouting.

Spray herbicide on brush and herbicide on brush and herbicide on.brush and herbicide on brush and herbicide on brush and herbicide on brush and small trees on the full small trees on the full small trees on the full small trees on the full small trees on the full small trees on the full width of the ROW to width of the ROW to width of the ROW to width of the ROW to width of the ROW to width of the ROW to prevent resprouting and prevent resprouting and prevent resprouting and prevent resprouting and prevent resprouting and prevent resprouting and reduce stem counts, reduce stem counts. reduce stem counts. reduce stem counts. reduce stem counts, reduce stem counts.Alternative Vegetation Where restrictions due Where restrictions due Where restrictions due Where restrictions due Where restrictions due Where restrictions due Management Strategy to easement limitations, to easement limitations, to easement limitations, to easement limitations, to easement limitations, to easement limitations, legal prohibitions or legal prohibitions or legal prohibitions or legal prohibitions or legal prohibitions or legal prohibitions or other Impediments do other Impediments do other Impediments do other Impediments do other impediments do other impediments do not allow tree removal, not allow tree removal, not allow tree removal, not allow tree removal, not allow tree removal, not allow tree removal, we prune trees enough we prune trees enough we prune trees enough we prune trees enough we prune trees enough we prune trees enough to achieve at least 25' of to achieve at least 20' of to achieve at least 10.5' to achieve at least 10' of to achieve at least 9.5' of to achieve at least 8.75'vertical clearance or 20' vertical clearance or 15' of vertical clearance or vertical clearance of 9.5' vertical clearance or 9' of of vertical clearance or of horizontal clearance of horizontal clearance 10' of horizontal of horizontal clearance horizontal clearance by 8.25' of horizontal by the time the tree Is by the time the tree Is clearance by the time by.the time the tree Is the time the tree Is clearance by the time pruned the next time. pruned the next time. the tree Is pruned the pruned the next time. pruned the next time. the tree is pruned the next time. next time.IEEE. 1997. National Electrical Safety Code (ANSI C2). The Institute of Electrical and Electronic Engineers, Inc. New York, New York Page 63 2 , American National Standards Institute, Inc New York, New York 3 Lawrence EC to Lawrence Hill 230 KV line is ground Inspected rather than aerial Inspected.

All other 230 KV lines are aerial Inspected.

FERC Vegetation Management Practices Reporting Template:

12 a).Subject 765 kV 500 kV 345 kV 230 kV Tie-line Interconnection facilities of other voltaaes Range of ROW Width Westar Energy has no Westar Energy has no 150-200 feet 75-150 feet 50-125 feet Maintained 765 KV facilities.

500 KV facilities.

Widths vary depending Widths vary depending Widths vary depending on site-related factors, on site-related factors, on site-related factors, such as right-of-way such as right-of-way such as right-of-way agreements with. agreements with agreements with property owners, multiple property owners, multiple property owners, voltage, lines in a corridor, lines in a corridor, multiple lines in a terrain, construction type terrain, construction corridor, terrain, (single pole, steel lattice (single pole or H-frame construction (single pole tower or H-frame structure, for example) or H-frame structure, for structure, for example) and other reasons. Most example) and other and other reasons. Most 230 KV rights-of-way are reasons. Most 161KV, 345 KV rights-of-way are 100 feet wide. 138 KV and 115 KV 150 feet wide. rights-of-way are 100 feet wide.Minimum Clearance N/A N/A Horizontal:

20 feet Horizontal:

15 feet Horizontal:

See below 4 Assumptions Vertical:

25 feet Vertical:

20 feet Vertical:

See below 5 Standards Utilized for N/A N/A 1). Westar Energy 1). Westar Energy 1). Westar Energy Clearances transmission line transmission line transmission line vegetation management vegetation management vegetation management standards as attached & standards as attached & standards as attached &summarized below, summarized below, summarized below.2). NESC Rule 2181. 2). NESC Rule 2`181. 2). NESC Rule 2181.3). ANSI Z133.1-2000 2.3). ANSI Z133.1-2000 2.3). ANSI Z133.1-2000 2.4). ANSI A300 (Part 1)- 4). ANSI A300 (Part 1)- 4). ANSI A300 (Part 1)-20012. 20012. 20012.Ground inspection N/A N/A None None None Aerial Inspection N/A NIA Twice annually Twice annually Twice annually FERC Vegetation Management Practices Reporting Template:

12 a).Subject 765 kV 500 kV 345 kV 230 kV Tie-line IInterconnection facilities of other voltaucs Vegetation Management Strategy N/A N/A 1). Mow all woody.vegetation whose trunk is within the ROW corridor.2). Prune trees with trunks outside the ROW corridor at the edge of the ROW corridor to provide appropriate lateral clearance from the phase conductors.

3). Apply herbicide to cut stumps to prevent resprouting.

Spray herbicide on brush and small trees on the full width of the ROW to prevent resprouting and reduce stem counts.4). NOTE: All clearances are based on the Westar Energy transmission line vegetation management specifications attached hereto, which exceed other standards noted above.1). Mow all woody vegetation whose trunk is within the ROW corridor.2). Prune trees.with trunks outside the ROW corridor at the edge of the ROW corridor to provide appropriate lateral clearance from the phase conductors., 3). Apply herbicide to cut stumps to prevent resprouting.

Spray herbicide on brush and small trees on the full width of the ROW to prevent resprouting and reduce stem counts.4). NOTE: All clearances are based on the Westar Energy transmission line vegetation management specifications attached hereto, which exceed other standards noted above.1). Mow all woody vegetation whose trunk is within the ROW corridor.2). Prune trees with trunks outside the ROW corridor at the edge of the ROW corridor to provide appropriate lateral clearance from the phase conductors.

3). Apply herbicide to cut stumps to prevent resprouting.

Spray herbicide on brush and small trees on the full width of the ROW to prevent resprouting and reduce stem counts.4). NOTE: All clearances are based on the Westar Energy transmission line vegetation management specifications attached hereto, which exceed other standards noted above.________________________________

I FERC Vegetation Management Practices Reporting Template:

12 a).Subject 765 kV 500 kV 345 kV 230 kV Tie-line Interconnection facilities of other voltaaes Alternative Vegetation N/A N/A Where restrictions due to Where restrictions due to Where restrictions due to Management Strategy easement limitations, easement limitations, easement limitations, legal prohibitions or legal prohibitions or legal prohibitions or other impediments do other impediments do other impediments do not allow tree removal, not allow tree removal, not allow tree removal, prune trees enough to prune trees enough to prune trees enough to achieve at least 25' of achieve at least 20' of achieve either the vertical clearance or 20' vertical clearance or 15' minimum horizontal of horizontal clearance of horizontal clearance clearance shown in note by the time the tree is by the time the tree is 4, below or the minimum pruned the next time. pruned the next time. vertical clearance shown in note 5, below by the time the tree is pruned the next time.IEEE. 1997. National Electrical Safety Code (ANSI C2). The Institute of Electrical and Electronic Engineers, Inc. New York, New York Page 63 2 American National Standards Institute, Inc. New York, New York 3Lawrence EC to Lawrence Hill 230 KV line is ground inspected rather than aerial inspected.

All other 230 KV lines are aerial inspected.

4 Horizontal clearances:

161 KV--10 feel 138 KV-9.5 feet. 115 KV-9 feet.5 Vertical clearances:

161 KV--I 0.5 feet. 138 KV-1 0 feet. 115 KV-9.5 feet.-3-