п х п с ж
T h e W e s t e r n A r e a P o v e r A d m i n i s t r a t i o n ( W e s t e r n ) h a s e s t a b l i s h e d a f o r m a l e n v i r o n m e n t a l p r o t e c t i o n , a u d i t i n g , m o n i t o r i n g , a n d p l a n n i n g p r o g r a m t h a t h a s b e e n i n e f f e c t s i n c e 1 9 7 8 . T h e s i g n i f i c a n t e n v i r o n m e n t a l p r o j e c t s a n d i s s u e s W e s t e r n w a s i n v o l v e d w i t h i n 1 9 9 4 a r e d i s c u s s e d i n t h i s a n n u a l s i t e e n v i r o n m e n t a l r e p o r t . I t i s w r i t t e n t o s h o w t h e n a t u r e a n d e f f e c t i v e n e s s o f t h e e n v i r o n m e n t a l p r o t e c t i o n p r o g r a m .
T h e D e p a r t m e n t o f E n e r g y O r d e r 5 4 0 0 . 1 , C h a p t e r I I . 4 , r e q u i r e s t h e p r e p a r a t i o n o f a n a n n u a l s i t e e n v i r o n m e n t a l r e p o r t . B e c a u s e W e s t e r n h a s f a c i l i t i e s l o c a t e d i n 1 5 s t a t e s , t h i s r e p o r t a d d r e s s e s t h e e n v i r o n m e n t a l a c t i v i t i e s i n a l l t h e f a c i l i t i e s a s o n e " s i t e . "
t a b lt o r c a n s a re
P a g *
L I S T O F T A B L E S ... i v L I S T O F F I G U R E S ... i v
1 . 0 I N T R O D U C T I O N ...1
2 . 0 SU M M A R Y ... 3
3 . 0 C O M PLIA N CE S E L F - A S S E S S M E N T ...4
3 . 1 C O M PLIA N C E S T A T U S ...4
3 . 1 . 1 R C R A ...4
3 . 1 . 2 T S C A ...5
3 . 1 . 3 C E R C L A ...5
3 . 1 . 4 F I F R A ...6
3 . 1 . 5 C A A ...7
3 . 1 . 6 S D W A ...8
3 . 1 . 7 C W A ...9
3 . 1 . 8 H M T A ...1 0 3 . 1 . 9 N H Ï A ...1 0 3 . 2 CURRENT I S S U E S ...1 0 3 . 3 SUMMARY O F P E R M I T S ...1 2 3 . 4 C O M PLIA N C E SUMMARY ( JANUARY-M ARCH 1 9 9 4 ) ... 1 6 4 . 0 ENVIRONM ENTAL PROGRAM IN FO R M A TIO N ... 1 9 4 . 1 ENVIRONM ENTAL P R O T E C T IO N PROGRAMS ... 1 9 4 . 1 . 1 E n v i r o n m e n t a l P r o t e c t i o n I m p l e m e n t a t i o n P l a n ...1 9 4 . 1 . 2 E n v i r o n m e n t a l A u d i t i n g P r o g r a m ... 1 9 4 . 1 . 3 L o n g R a n g e E n v i r o n m e n t a l P l a n ... 2 0 4 . 1 . 4 E n v i r o n m e n t a l P r o t e c t i o n C o m p l i a n c e I n f o r m a t i o n ... 2 1 4 . 1 . 5 W a s t e M i n i m i z a t i o n ... 2 1 4 . 2 S T A T E AND LOCAL ENVIRONM ENTAL R EQ U IR EM EN T S . . . 2 2 4 . 3 ENVIRONM ENTAL PL A N N IN G AND R E S E A R C H ... 2 2
PREFACE ... i
4.3.1 Research... 26
i i
5 . 0 ENVIRONM ENTAL M O N ITO R IN G IN FO R M A TIO N ... 2 6 5 . 1 GROUNDWATER M O N I T O R I N G ... 2 6
5 . 1 . 1 M i l e s C i t y C o n v e r t e r S t a t i o n ... 2 6 5 . 2 HAZARDOUS M A T ER IA L S P I L L IN FO R M A TIO N ... 2 7 6 . 0 GROUNDWATER P R O T E C T IO N PROGRAM . ... 2 7 7 . 0 Q U A LIT Y A S S U R A N C E ...2 8 R E F E R E N C E S ...2 8 A P P E N D IX A ... A - 1 A P P E N D IX В ...B - l A P P E N D IX С ...C - l A P P E N D IX D ...D - l A P P E N D IX E ...E - l
T A B U O F С О И ТИИТ В - C o n t in u e d
Page
i i i
L I S T O F ra B L B S
P a g * TA B LE 1 L I S T O F HAZARDOUS M A T ER IA L S P I L L S
D U RIN G CALENDAS YEAR 1 9 9 4 ... 1 4 TA B LE 2 L I S T O F ENVIRONM ENTAL P E R M IT S O B TA IN ED
OR ONGOING D U R IN G CALENDAR YEAR 1 9 9 4 ... 1 5
TA B LE 3 ENVIRONMENTAL A S S E S SM E N T S AND ENVIRONM ENTAL
IM PA C T STATEM ENTS FO R CALENDAR YEAR 1 9 9 4 . . . . 2 3
TA B LE 4 ENVIRONMENTAL PL A N N IN G P R O JE C T S ONGOING
OR COMPLETED I N CALENDAR YEAR 1 9 9 4 ... 2 5
L IS T OF FIGOTU58
F i g u r e 1 M ap o f W e s t e r n A r e a P o w e r A d m i n i s t r a t i o n ... 2
iv
1 .0 INTRODUCTION
The Western Area Potier Administration (Western) was established on
Cecember 21, 1977, pursuant to Section 302 o f Public Law 95-91, the Department o f Energy Organization Act dated August 1, 1977. Western i s responsible for the Federal e le c tr ic power marketing and transm ission functions in 15 central and western sta te s encompassing a 1.3 million-square-mile geographic area
(Figure 1).
In 1994, Western provided power to more than 600 wholesale power customers co n sistin g o f cooperatives, m u n icip alities, public u tilit y d i s t r i c t s , investor-owned u t i l i t i e s , federal and sta te agencies, irrig atio n d i s t r i c t s , and p roject use customers. The wholesale power customers, in turn, provide service to m illion s o f r e t a il consumers in the S tate s o f C aliforn ia, Nevada, Montana, Arizona, Utah, New Mexico, Texas, North Dakota, South Dakota, Iowa, Colorado, Wyoming, Minnesota, Nebraska, and Kansas.
Western i s responsible fo r the operation and maintenance o f nearly 17,000 m iles of transm ission lin e s , 271 su bstation s, and various appurtenant power f a c i l i t i e s in the s ta t e s lis t e d above. Western also is responsible for planning, construction, and operation and maintenance o f additional federal transm ission f a c i l i t i e s that may be authorized in the future. E le ctric power marketed by Western i s generated by the Bureau o f Reclamation (BuRec), the U.S. Army Corps o f Engineers (Corps), and the U.S. Section o. the International Boundary and Water Com ission (IBWC). There i s a combined to tal of 55 hydroelectric power generating p lan ts in the service area.
A dditionally, Western markets the United State s entitlement from the Navajo c o al-fire d plant near Page, Arizona. The maximum operating c ap ab ility that Western currently markets more than 10,000 megawatts (MW). In 1994, Western sold over 36 -b illio n kilow att (kV) hours o f e le c tr ic ity that generated more than $787 m illion in revenues.
Western’ s organization c o n sists of the Headquarters O ffice located in Solden, Colorado, and fiv e Area O ffices located in B illin g s, Montana; Phoenix,
Arizona; Loveland, Colorado; Sacramento, C alifo rn ia; and S a lt Lake C ity, Utah.
A dditionally, there are fiv e D istric t O ffices and six power dispatching cen ters. Figure 1 i s the Western marketing area. Through i t s power marketing and transm ission program, Western secures revenues to meet the annual co sts of operation and maintenance o f transmission f a c i l i t i e s , purchased power, wheeling, and other expenses. Western is required to repay within allowable time periods a ll the power investment plus in te re st as well as the portion of the Government’ s irrig a tio n and other non-power investments beyond the water users repayment c ap ab ility .
x
D U TY LO C A T IO N S
OPERATIONSOFFICEMany sta te and federal environmental protection laws and regulations are applicable to Western. Western f a c i l i t i e s are within the ju risd ic tio n of six Environmental Protection Agency (EPA) regions and 15 s t a t e s . To help assure conformance with al'i regulatory requirements, Western developed Environmental Protection Implementation Plans (EPIP) in accordance with DOE Order 5400.1, for Headquarters and each o f the fiv e Area O ffices. The EPIPs estab lish environmental protection programs th at define Western’ s environmental conpliance program, the overall environmental protection and pollution prevention goals and o b je ctiv es. A dditionally, Western Headquarters compiled the Lono Ranoe Environmental Plan, also required by DOE Order 5400.1, to provide general guidance fo r compliance with environmental laws and regulations as they pertain to environmental protection compliance issu e s.
Western i s taking action to prevent, control, and abate environmental pollution a t f a c i l i t i e s under i t s control.
One of the major regulatory impacts upon Western continues to be the Toxic Substances Control Act (TSCA) th at regulates the use o f polychlorinated biphenyls (PCB). Western’ s policy i s to elim inate PCBs from i t s system wherever economically and operation ally p ossib le to lessen the impact o f PCB regulation s. Western has undertaken e ffo r ts to minimize procurement expense and maximize contracting e fficien cy by coordinating PCB removal a c tiv itie s throughout Western’ s power marketing system.
E lectric and magnetic fie ld (EHF) e ffe c ts of altern atin g current (AC) and d ire ct current (DC) power transm ission remain a concern in the decision-making process under the National Environmental Policy Act (NEPA). Increased public awareness has also added impetus fo r additional research in the area o f ENF e ffe c ts . Western continues to monitor the research e ffo r ts underway in these areas and i s a p articip an t in a study coordinated by Bonneville Power Administration that exposes sheep to high voltage AC fie ld s .
Throughout 1994, Western’ s environmental planning process continued toward increasingly early public and agency involvement in proposed p ro je cts. This emphasis on early scoping o f environmental issu e s, which follows the amended DOE Guidelines fo r Compliance with NEPA, i s to iden tify sig n ific a n t impacts.
Western determines the appropriate level o f environmental documentation by i t s policy o f pre-scoping and increasing the level o f public and agency
p articip atio n in p roject development.
In July 1994, Western was delegated the authority to approve i t s own environmental assessments (EA) as p art o f i t s NEPA program. This authority has shortened the environmental process and provided fo r p roject decisions to be made c lo se r to the project le v e l. A dditionally, the Area O ffices were provided an opportunity to seek the authority to approve th e ir own categroical exclusions.
Large sc a le p ro je cts and p ro je cts with a high potential fo r sig n ific a n t environmental impacts are analyzed within the framework o f EAs and impact statem ents. Host Western p ro je cts re su lt in minimal environmental impacts with appropriate planning and m itigation .
2 .0 SUMMRY
3
Ноге comprehensive o ffic ia l particip ation by the Advisory Council on H istoric Preservation e a r lie r in the planning process has streamlined Western’ s cultural resource compliance a c t iv itie s . Monitoring o f p roject implementation through public and agency feedback has inproved planning methods.
3.0 COMPLIANCE SELF-ASSESSMENT 3.1 COMPLIANCE STATUS
Western operates in coapliance with environmental and other requirements establish ed by fed eral, sta te , and local statu te s and regu lation s, Executive Orders, Department o f Energy Orders, and agreements with fe d e ral, s t a t e , and local regulatory agencies. The following paragraphs summarize Western’ s compliance sta tu s with the major environmental sta tu te s.
3 .1 .1 Resource Conservation and Recovery Act (RCRA)
Since 1984, many regulations have been proposed or fin a liz e d as a re su lt o f the Hazardous and Solid Waste Amendments o f 1984 (HSWA).
HSWA-based regulations impact Western most sig n ific a n tly by c la ssify in g some f a c i l i t i e s as small quantity generators o f hazardous waste. HSWA also impacts Western by prohibiting the la n d fillin g of liq u id s, dioxin-containing w astes, and certain so lv en ts.
The S tate of C alifornia requires that disposal o f 'extremely hazardous wastes” be permitted on a case-by-case b a s is . The sta te considers PCBs at a concentration of greater than 5,000 ppm as an
"extremely hazardous w aste*.
3 .1 .1 .1 Underground Storage Tanks (UST)
C aliforn ia requires the annual renewal o f permits to operate underground storage tanks. Through the monitoring and updating o f permits, Western continued to comply with C aliforn ia underground storage tank regulations during 1994.
Western removed underground storage tanks at the following f a c i l i t i e s : Sherman H ills substation, Wyoming and Mead Substation, Nevada. Closure of a ll tanks was in accordance with sta te regulations.
A leaking underground storage tank was discovered in 1985 at the Huron O&M Center in South Dakota. At the d irection o f the State o f South Dakota, monitoring w ells were in sta lle d to determine i f o f f - s i t e migration was taking p lace . In December 1990, the sta te required Western to place an additional monitoring well on -site fo r further v e rific a tio n regarding o ff- s ite m igration. The in sta lla tio n was accomplished in 1991, and the monitoring data fo r the p ast year i s found in Table 5. Remediation o f the contaminated so il took place in la te 1993. Approximately 700 cubic yards of so il were removed from the s it e and approximately 6,000 gallons o f gasoline contaminated water was pumped from the
excavation s i t e . The groundwater monitoring well was removed in accordance with st a te requirements. It was determined by the sta te that Western has successfully remediated th is s i t e . The S ta te o f South Dakota found in la te 1993 that Western’ s monitoring r e su lts , to date have been sa tisfa c to r y and suspended further monitoring requirements.
3 .1 .2 Toxic Substances Control Act (TSCA1
Western continued the renoval and proper disposal of PCBs from f a c i l i t i e s during 1994. An agency-wide PCB transportation and d isposal contract ensures co n sisten t and proper handling of PCB waste m aterial. The contractor tran spo rts and disposes o f the PCBs and prepares a ll necessary paperwork, including c e r tific a te s o f destruction or d isp o sa l. Western reduced the risk of future PCB re le a se s by removing and disposing o f more than 252,793 kg of PCB-contaminated o il and equipment.
3 .1 .3 Comprehensive Environmental Response. Compensation, and L ia b ility Act /CERCLAI
Congress passed the Superfund Amendments and Reauthorization Act (SARA) o f 1986, which revised and expanded CERCLA. Many revision s apply to Western.
Western does not have any s i t e s currently lis te d on the National P rio rity L is t (P^L), but the Agency has taken a proactive ro le by implementing a F a c ility Evaluation Program. The purpose of th is program i s to evaluate a ll Western f a c i l i t i e s for sources of and suspected re le a se s of o i l , hazardous substances, p ollu tan ts, or contaminants into the environment. Western has also proactively conducted Preliminary Assessments and S ite Investigations (PA/SI) a t s i t e s which could have the p oten tial for contamination. The Montrose Power Operations Center, located 1n Montrose, Colorado, n o tified EPA o f hazardous waste storage a c tiv itie s in the early 1980’ s as did the Watertown Substation 1n Watertown, South Dakota, and Casper Maintenance Yard in Casper, Wyoming. None of these s i t e s are RCRA hazardous waste Treatment, Storage or Disposal F a c ili t ie s , but because they have f a c i l i t i e s fo r storage o f PCB w astes, the s i t e s were lis t e d on the docket. Preliminary Assessments and screening S ite In vestigation fin al reports have been completed and submitted to EPA.
Update No. 6 o f the Federal Agency Hazardous Waste Compliance Docket lis t e d two Western f a c i l i t i e s which Western disputed:
Pierre Hydroelectric Plant and Parker Dam. EPA corrected the lis t in g o f the Pierre Hydroelectric Plant, to re fle c t ownership by the Corps. Parker Dam i s pending furth er review by EPA and no n o tific a tio n s were received in 1994. Update No. 7 lis te d three f a c i l i t i e s as S ite Evaluation Accomplished (SEA): Montrose Power Operations, Hinton, and Casper Maintenance Yard. In 1994, Western was n o tified by EPA that no further remedial action was planed a t the Watertown, South Dakota f a c i li t y . Closure o f the the RCRA p art В f a c i l i t y in Hinton, Iowa, was approved by the EPA
in 1994 a fte r the pentachlorophenol contaminated so il was incinerated.
In 1987, Western acquired a 1.45 acre parcel o f land e a st o f the Bering Substation in Gering, Nebraska, with the intent o f using the area for expansion o f the existin g su bstation . An inactive foundry and Machine shop i s located on the p arcel. After
acquiring the property, Western suspected that i t was contaminated with heavy metals and solvents associated with a c t iv itie s
conducted a t the s i t e by the p rio r owners. Western conducted a s i t e v i s i t and reconnaissance o f the f a c i li t y in March o f 1990.
Based on the re su lts o f the reconnaissance, Western deternined th at a more d etailed environmental in vestigation was necessary.
Western conducted a Preliminary Assessment in early 1991. This f a c i li t y was lis t e d on the Federal Agency Hazardous Waste Compliance docket Update No. 5 which was published in December 1991. The fin al S ite Investigation report was submitted to EPA Region 7 in early 1992. The additional sampling that EPA required indicated le s s contamination than had been previously expected.
3 .1 .4 Federal In secticide. Funoicide. and Rodenticide Act (FIFRA1 Western i s required to comply with the use, storage, and disposal regulations contained in FIFRA and individual sta te p esticid e management programs. P esticides are used by Western to control vegetation, rodents, and for wood preservation.
During 1993 and 1994, Western Implemented Integrated Pest Management (IPM) methods. Western developed a program which addresses the control o f vegetation at f a c i l i t i e s and along transmission lin e rights-of-way (ROW). This program combines mechanical, b io lo g ic a l, and chemical methods in a way that minimizes economic, health, and environmental r is k s . Herbicide r isk assessments w ill be conducted to serve as a screening process fo r the development o f a Western-approved herbicide use l i s t . Herbicides can then be selected from th is approved l i s t fo r use by Western and/or contract ap p licato rs. Western i s also evaluating herbicides for th e ir potential fo r groundwater and surface water contamination. By settin g lim its on known physical and chemical ch a ra c te ristic s o f herbicides which Influence leaching potential m itigation measures w ill be outlined which are known to reduce the likelihood o f herbicide contamination r isk s to human health and the environment. In addition, a program i s being developed to monitor herbicide residues in so il and water to determine the concentrations or persistence o f these chemicals in the environment. Sp e cific application and management guidance has been id en tified and incorporated into the vegetation management program.
P esticide guidance i s being developed fo r miscellaneous p esticid e uses such as the disposal o f chemically treated wood poles and crossarms and the control of rodent/bird damages at Western f a c i l i t i e s . An Interagency agreement has been establish ed between the Deparment o f Agriculture, Animal Damage Control, and Western
б
fo r the control o f pest-caused damages to e le c tr ic transm ission f a c i l i t i e s .
In compliance with the Federal Noxious Heed Act o f 1974, as amended by Section 15, Management o f Undesirable Plants on Federal Lands, 1990, and S ta te / County noxious weed management
le g is la tio n , Western has written d ra ft policy guidance fo r the management o f noxious weeds id e n tified by State and County weed management laws on Western fee-owned and nonfee-owned (easements, ROW, perm its, e tc .) land. Western has entered into interagency agreements and county cooperative agreements fo r assitan ce with control o f noxious weeds.
The annual selection o f contractor services fo r control o f vegetative growth within substations and maintenance yards has been updated to include the submittal o f the co n tracto rs’
technical q u a lific a tio n s along with cost information. The contractor i s selected based upon technical merit as well as cost proposal. In addition, the scope o f the statement-of-work for annual chemical control of vegetation has been expanded to Include the control o f State and County targeted noxious weed species on Western fee-owned land.
3 .1 .5 Clean Air Act (CAA)
Several potential sources o f a ir emissions e x is t at Western f a c i l i t i e s that are regulated under the CAA: dust during construction a c t iv it ie s ; fria b le asbestos during building
renovation or demolition; and v o la tile organic compounds emissions from gaso lin e dispensing f a c i l i t i e s and cold solvent clean ers.
In arid regions, Western requires th at a ll disturbed areas and roads be watered during construction a c t iv itie s to reduce p artic u la te (dust) a ir pollution.
Asbestos regulations under the National Emission Standards for Hazardous Air Pollutants a ffe c t Western when any work i s planned to modify or demolish existin g bu ildin gs. Surveys to iden tify and quantify asbestos in Western f a c i l i t i e s were in itia te d in 1988.
The r e su lts o f these surveys indicated the presence o f asbestos in some older buildings.
Some sta te s also regulate the removal and disposal o f fria b le asb e sto s. Western personnel n otify a ll appropriate regulatory agencies when planning renovation and demolition p ro je c ts, and assure proper disposal of asbestos wastes.
A R efrigerant Working Group composed of individuals from various p arts o f Western has been formed to develop str a te g ie s to comply with Sections 608 and 609 of the CAA. A consensus o f the group was to inventory a ll equipment containing ozone-depleting
re frig e ra n ts to comply with regulations and plan fo r the phase out o f ozone-depleting substances. Technician c e r tific a tio n i s mandatory e ffe c tiv e November 14, 1994, fo r a ll individuals who service a ir conditioning and re frig e ratio n equipment. This
in c lu d e s aotor vehicle a ir co n d itio n e rs (HVAC) and NVAC-like ap p lian ces under Section 609 o f th e CAA. F a c ilit ie s Mill have to ac q u ire approved equipment and tra in in g for tech n ician s, or c o n tra c t for such services th a t have EPA approval, to conform to the refrigeran t recycling r u le . F a c ilit ie s will a ls o have to implement procedures to ensure th a t leaks are rep aired and records are kept in accordance to the re g u la tio n s. The equipment used for se rv ic in g also needs to be ab le to coaply with the applicable requirements.
3 .1 .6 Safe Drinking Water Act (SDWA)
3.1.6.1 Underground In je c tio n Control fUIO
As required by UIC r e g u la tio n s , Western has completed an inventory of wells a t a l l i t s f a c i li t i e s . All w ells found to date, at the f a c i l i t i e s , are considered C la ss V injection w ells.
These consist ao stly o f f l o o r drains within soee battery rooas and vehicle Maintenance buildings which are connected to dry wells. Soae a i r co ap resso rs used on power circu it breakers send sa a ll q u a n t it ie s of blow-by o il Into dry w ells. The Area O ffic e s a re working with EPA regions an¿
states to obtain p e ra isslo n to permanently abandon the battery and oil rooa in je c tio n wells as needed and to close the wells accepting the blow by froaair b la s t breakers.
Additionally, soae s e p t ic sy s te a s used to d isp o se of sanitary waste q u alify a s In jection w ells. Western 1s eliminating the use o f in je c tio n wells a t th e ir new fa c ilitie s and has plugged th e drains fr o * washbays and aaintenance f a c i l i t i e s le a d in g to dry w ells o r septic systeas at a nuaber o f f a c i l i t i e s .
3 .1 .7 Clean Water Act (CWA)
3.1.7.1 Sp ill Prev en tion . Control, and Counteraeasure Plans (SPCC)
The discharges fro a the f a c i l i t i e s Western owns and operates are generally not re g u la te d under the CWA and other water pollution control laws and sta tu te s. Host o f Western’ s fa c ilit ie s do not gen erate efflu en t ex'.ept fo r stonatater runoff. New storaw ater disch arge regulation s have impacted soae of Western’ s f a c i l i t i e s .
In 1990, Western id e n tifie d unpermitted point source discharges at soae o f i t s la rg e r f a c i l i t i e s where floor drains were found to connect to storm sewer drainage systems. Host o f the d isc h a rg e s are to dry ditch es along public roadways next to th e f a c i l i t i e s . These were corrected in 1991 and 1992 a s part of the F a c ility Evaluation Program. The purpose of th is program 1s to evaluate all Western f a c i l i t i e s for sources o f and suspected
re le a se s o f o i l , hazardous su b stan ces, p ollu tan ts, or contaminants into the environment.
Western f a c i l i t i e s using or sto r in g o il must a s s e s s the p oten tial fo r sp ille d o i ls to reach navigable Maters or th e ir t r ib u ta r ie s . I f the p o te n tial e x is ts , Western develops and implements S p ill Prevention, Control, and Countermeasure plan s, including appropriate p rovision s for diversion and secondary containment.
SPCC plans are reviewed every th re e years and amended, i f necessary. All new and amended p lan s are re c e r tifie d by a re g istere d professional engineer. About 25 f a c i l i t y SPCC plans were reviewed, amended, o r re c e rtifie d in 1994. Water pollu tion control regulations found in 40 CFR (112 also provide guidelines for construction o f stru ctu res to prevent sp ille d o il froa reaching n avigable waters. Western follows these guidelines when designing new f a c i li t i e s or
refurbish in g existin g su b statio n s.
The S a lt Lake City Area developed a standard s p i ll containment k it that i s stored a t f a c i li t i e s regulated under 40 CFR 112. Western i s considering using th ese k its Western-wide. Western i s a lso studying the use o f a lte rn a tiv e secondary containment measures, such as
aboveground storage tanks with reinforced concrete secondary s h e lls and Improved oil/w ater se p arato rs.
The N iles City Converter S ta tio n , located in Montana, is a back-to-back, altern atin g-curren t to direct-curren t converter f a c i li t y . This f a c i l i t y has been granted a water p ollu tion control permit fro a th e State of Montana. This f a c i l i t y i s required to conduct a quarterly groundwater monitoring program for the o n - s ite coolant system
evaporation pond. The B illin g s Area Office has applied for a permit to hook up to the M iles City sewer system.
Construction on the project s t a r te d in la te 1994.
3 .1 .8 Hazardous Material s Transporta tio n Act (HHTA1
Much o f the hazardous and toxic m a te r ia ls transported fo r Western is shipped v ia contracted commercial h au lers. However, trained and q u a lifie d Western employees o c casio n ally transport to x ic m aterials from one f a c i li t y to another.
Hazardous waste transportation requirements for the C alifo rn ia Department o f Health Services are more extensive than those of the U.S. Department o f Transportation (DOT). Therefore, the
Sacramento Area Office and Phoenix Area O ffice must have a C aliforn ia waste hauler’ s permit fo r the transportation o f PCB wastes. In 1994, the p em lts fo r v e h ic le inspections and
insurance were renewed by both Area o f f i c e s . The annual report on qu an tities shipped was provided to the State as required by their waste h au ler’ s permit.
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Western environmental s t a f f developed a training program in 1993 which addresses the requirements of HN-126F fo r the sa fe tran sportation o f hazardous M aterials. DOT regulates Western’ s transportation o f hazardous w astes, PCB wastes, and other hazardous M aterials. DOT a lso regulates personnel tran spo rt, g aso lin e and other fu e ls fo r use In construction equipment, large b a tte rie s fo r use a t su bstation s, battery acid , с Depressed g ase s, e sp e c ia lly nitrogen, su lfu r hexafluoride and acetylene, and bulk q u a n titie s o f non-hazardous e le c tric a l o i l .
3 .1 .9 National H istoric Preservation Act (NHPA1
During 1994, Western in itia te d or continued previous cu ltu ral resource compliance e ffo r ts fo r 26 p rojects in 8 s t a t e s . The p ro je cts included the construction o f su bstations, microwave c o w n ic a tio n f a c i l i t i e s , construction a t pumping p lan ts, repeater f a c i l i t i e s , e le c tr ic a l transmission lin e s, access road
maintenance, access road construction, s i t e monitoring, s i t e te s tin g , and warehouse construction. In accordance with Section 106 o f the NHPA, as amended, Western so lic ite d the contents o f the S tate H istoric Preservation O ffic er(s) in 8 sta te s regarding these p ro je c ts. This allowed Western to evaluate cultural resources within the proposed project areas and identify potential e ffe c ts o f the p ro je cts on sig n ifican t cultural resources. Plans to m itigate potential project e ffe c t s included avoiding, monitoring, te s tin g , and excavation.
3.2 CURRENT ISSUES
The DOE O ffice o f Audit conducted a Line Program Environmental Management Audit In December 1991. A total o f 19 findings were id e n tified by the audit team. Seven of the 19 findings were compliance fin din gs, in th at the audit tean f e l t that Western was not in compliance with DOE Orders. The remaining 12 were 'B est Management P ractice*
fin din gs. Western received the fin a l audit report Nay 22, 1992, and submitted a fin a l remedial action plan July 30. Department approval was received August 28, 1992. Listed below i s a tab le o f the a c tiv ity on the remedial action items for the f i r s t quarter calendar year 1994
(January through March 1994).
FINDINGS
REMEDIAL ACTION ITEM DATE
COMPLETED OS/BMPF-2 Identify Personnel needing environmental
language in th e ir job descriptio n s.
Prepare le t t e r to rewrite jo b descriptio n s.
Review e x istin g jo b d escriptio n s.
Review e x istin g performance standards.
Apply e x istin g job descrip tio n s.
Apply ex istin g performance standards.
Develop environmental job descriptions as needed.
Develop environmental performance standards as needed.
In progress In prograss DOE lead In progress DOE revising In progress DOE lead Drafted CA/BMPF-l Implement a documented periodic Western-wide
environmental Self-Assessment Program to provide Senior Management with Information on the sta tu s o f Western's environmental perfonrance.
Drafted
SR/BHPF-l Perform an aly sis o f current and projected sta ffin g needs fo r Headquarters Division o f Environmental A ffa irs.
Not done
SR/BHPF-2 Provide environmental awareness training to
a ll Une personnel and key managers. Not done EP/CF-1 Develop Meteorological Monitoring Plan
Develop Groundwater Monitoring Plan
Develop program fo r evaluating and permitting surface water discharges
(Stormwater Pollution Prevention Guidance Manual)
Begin Implementation o f Western-wide Waste Minimization and Pollution Prevention Program Develop Western-wide Environmental Monitoring Implement the Western-wide Groundwater Plan Protection Management Program.
In progress A pril, 1994 Drafted
(Feb. 1994) In progress In progress Drafted EP/CF-2 Develop guidance fo r well closu res.
F in alize Hazardous Waste Management Plans.
Implement Hazardous Waste Management Plans.
Develop P esticid e Management Program.
Develop Underground Storage Tank Program.
Develop Underground Injection Control Program.
Develop a comprehensive SPCC Program.
Drafted P a rtia lly
complete In progress In progress In progress In progress Drafted EP/CF-3 Develop guidance to ensure remedial responses
comply with regulatory requirements.
Incorporate remedial action response training into Training Program.
March 1994 In progress 11
EP/BMPF—1 Develop procedure to ensure M itigation action
plans are follow ed.' In progress
IC/BKPF-1 Develop ’ lesson s learned* proqram. In progress
SR/8HPF-2 Modify IDP and DTIS systems. In progress
SR/BHPF-3 Develop Environmental Training Prog гая.
Iden tify personnel needed environmental train in g.
Determine training needs.
Coordinate training needs with other functional areas.
Develop generic SON for train in g.
Incorporate environmental train in g into IDP and DTIS systems.
Develop recordkeeping procedures.
Procure train in g.
P a rtia lly complete In progress P a rtia lly
complete P a rtia lly complete In progress Not done Not done Not done PE/CF-] Incorporate self-assessm ent missing elements.
Incorporate self-assessm ent into train in g. In progress In proqress PE/CF-2 Rewrite
ПАРА
5482.1 (replaced by ИАРА 5482.2A)Supplement aud it/app raisal plan s, as needed.
Incorporate Into training program.
Implement a ll phases of audit and appraisal program.
March 1994 Drafted Not done Not done PE/CF-3 E stablish program to c o lle c t data to track and
trend.
Establish program to track and trend.
Provide training in tracking and trending.
P a rtia lly complete P a rtia lly complete Not done PE-BHPF-1 Provide environmental train in g to maintenance
personnel. In progress
RM/BMPF-1 Review and define existin g r isk management.
Develop procedures to ensure id e n tificatio n of regulatory issu es pertinent to risk
management.
F ir s t Phase completed
Several separate hazardous/toxic material s p ill incidents were reported.
These s p i ll s were cleaned up as required by TSCA, RCRA, or the CWA, and the s p i l l s resu lted in In sign ifican t environmental damage. The location s and m aterials sp ille d are lis t e d below:
TABLE 1
LIST OF HAZARDOUS MATERIAL SPILLS DURING CALENDAR YEAR 1994
Reportable quantity (RQ) i s the quantity of hazardous/toxic substance fo r which reporting o f a s p ill or discharge i s required. Under the National Contingency Plan a ll s p i ll s involving 1 pound or more by weight o f PCBs (>RQ) must currently be reported to the National Response Center. N otification should be in the sh ortest p o ssib le time a fte r discovery, but in no case la te r than 24 hours a fte r discovery. S p ills o f le s s than 1 pound of PCBs by weight (<RQ) must be cleaned up in accordance with TSCA requirements, but n o tificatio n o f EPA i s not required.
3.3 SUMMARY OF PERMITS
Western i s required to obtain permits fo r underground storage tanks, PCB transportation and storage, hazardous waste storage, gasolin e dispensing and underground injection w ells.
TABLE 2
LIST OF ENVIRONMENTAL PERN ITS OBTAINED OR 0И601Н6 DURING CALENDAR YEAR 1994
NAME ISSUING AGENCY STATUS EXPIRATION
DATE 404 Permit
Nationwide U.S. Army Corps Onqoinq None
Hazardous Waste
Hauler R egistration State o f CA Renewed 10/31/94
Variance Application S tate o f CA Obtained 10/31/94
F erait to Operate Underground Storage
Tanks Shasta County Ongoing Annually
Sacramento County Ongoing Annually Hazardous M aterials Permit
Hazardous M aterials
Business Plans Shasta County Ongoing Annually
Sacramento County Ongoing Annually
Tehama County Onqoinq Annually
Alameda County Kern County Calaveras County San Joaquin Santa Clara County Colusa County Merced County Contra Costa County Water Quality
Miles City Converter State o f Montana Ongoing 5/31/94 V irginia Smith Converter
Station
State o f Nebraska Ongoing Annually
RCRA Part В Permit Permit fo r Hinton Hazardous Waste Storage F a c ility
U.S. EPA Closed N/A
Gasoline Dispensing
F a c ility Permit (CA) Air Pollution
Control D istrict Ongoing 9/94
National Environmental Policy Act (NEPA). Hestem has several
categorical exclusions (CX), environmental assessn en ts (EA) and EISs in various stages o f the NEPA process. The most notable are described here.
B illin g s Area O ffice: CXs processed were: Fargo building purchase;
Midland Substation; Devaul Substation; Bonesteel Substation; Rapid City Substation; Winner Substation; Hawksnest Microwave; Rainbow/Havre Reroute; Huron Substation; Westfield and Forbes Communications S ite Upgrade; Page Communication S ite Disposal Review; W illiston Stage 6 Upgrade; and the Sioux City Stage 11 Upgrade.
Loveland Area O ffice: The following CXs were processed: Sidney Substation; Granby Substation; Brush Maintenance Building; and Lovell Substation Stage 08. The following EAs were processed: Estes-Marys Lake Transmission Line Project and Gering-Stegall Transmission Line P roject. An EIS was processed fo r the F latiron -E rie Transmission Line Project.
Phoenix Area O ffice: The following CXs were processed: Pole Replacement Project for the Arizona Department o f Transportation;
S ilv e rc ro ft Wash Pole Replacement fo r the City of Tucson; ED? Substation Upgrade; and Oracle-Tucson Transmission Line.
Sacramento Area O ffice: The following CXs were processed: Los Vaqueros Tap; Fiddyment Substation City o f R o sev ille; Stampede Rate Adjustment;
Tracy-Ygnacio 69-kV Transmission Line Relocation Viera Ranch II Grant of Easement; Powerex Enabling Agreement; Shasta Dam PowerPlant Rewind; and Tracy-Ygnacio 69-kV Rehabilitation and License Agreement.
S a lt Lake City Area O ffice: The fin al EIS fo r Glen Canyon Dam was distribu ted to the public in March 1995 with the Record o f Decision expected by March or April 1996, following a General Accounting O ffice aud it. Various environmental groups have taken exception to Inclusion in the fin al EIS of a new maximum allowable re le a se o f 25,000 c f s (up from 20,000 c fs 1n the d ra ft EIS) and a maximum allowable upramp ra te of 4,000 c f s / hour (up from 2,500 cfs/hour in the d r a ft EIS) arguing that the sc ie n tific support fo r such changes i s in su ffic ie n t. The changes were made following extensive consultation with s c ie n tis ts and the public, Including the environmental organization s. The changes would benefit the hydropower resource without any apparent environmental consequence. The Navajo Transmission Project EIS stu dies o f a potential corridor across the Hualapai Indian Reservation have been completed and the re su lts are being incorporated into the alte rn ativ e s being
evaluated. The cooperating agencies met March 9, 1995, in F la g s ta ff, AZ, and received an overall update on the sta tu s o f the d r a ft EIS. The current schedule fo recasts a d raft EIS by the f a l l o f 1995. For the S a lt Lake City Area Integrated Projects E le ctric Power Marketing EIS, Western has provided the d raft of the fin al EIS to cooperating agencies (BuRec; Fish and W ildlife Service; National Park Service, Utah,
Colorado, New Mexico, Arizona, and Wyoming). The National Park Service has asked for a 60-day cornent period. Western agreed; th erefore, comments will be taken until la te A pril. Western i s completing a CX on 3.4. COMPLIANCE SUMMARY (JANUARY THROUGH MARCH 1995)
15
the proposal to sake permanent the t e s t flows at Collbran fo r the Upper and Lower Holina PowerPlants Reoperation Proposal. These t e s t flows were Intended to determine the f e a s ib i l it y of changing flows froa a
"base-load" to a 'peaking* operation. BuRec and FWS have agreed to th is proposed change provided that the en tire operation be subject to an endangered sp ecies review a t a la te r date.
Resource Conservation and Recovery Act (RCRA).
B illin g s Area O ffice: The Huron D is tric t O ffice received a le t t e r from EPA Region VII sta tin g they accepted Western’ s closure plan fo r the hazardous waste f a c i li t y a t Hinton, Iowa. The 1994 hazardous waste reports have been submitted to the S ta te . , The Bismarck D istric t O ffice environmental s t a f f sampled the used o il a t the Bismarck warehouse. The analyses Indicate the used o il i s o ff-sp e c ific a tio n used o i l . The B illin g s Area O ffice submitted a Hazardous Waste License Application to the Minnesota Pollution Control Agency fo r the storage of used motor o i l .
Loveland Area O ffic e: Liqu ified Petroleum Gas (LPG) Tank Plot Plans were submitted and approved fo r Grouse Mountain and Blue Ridge Microwave s i t e s . These s i t e s have buried LPG tanks which were required by the Forest Service. Western contracted fo r the consolidation o f flanmable liq u id wastes a t Loveland and Brush. The s it e s were sampled fo r a waste p ro file p rio r to incineration a t Ensco. The hazardous wastes and asbestos waste i s scheduled fo r disposal in mid-April.
Phoenix Area O ffice: The Phoenix Area O ffice submitted hazardous waste generation f a c i l i t y annual reports to the Arizona Department of Environmental Q uality. These reports documented a c t iv itie s during 1994 fo r the 21 Phoenix area s i t e s in Arizona: Bouse Substation, Buckeye Substation, Casa Grande Substation, Cochise Substation, Coolidge Substation, Davis Dam Substation, ED-2 Substation, ED-4 Substation, ED-5 Substation, Gila Substation, Liberty Substation, Maricopa Substation, Mesa Substation, Nogales Substation, Oracle su bstation, Phoenix OSM Complex, Phoenix Substation, Pinnacle Peak Substation, Prescott Substation, Tucson Substation, and Wellton Substation. The warehouse sent fifte e n b a tte rie s to Exide Corporation fo r recycling. Laidlaw Environmental Service o f C aliforn ia transported two drums o f hazardous waste (waste naphtha and waste paint related m aterials) along with one drum o f non-RCRA waste (gear o il) from the Operations and Maintenance Como’ ex to the treatm ent, storage and disposal f a c i li t y fo r Laidlaw in Phoenix.
Sacraircnto Area O ffice - Four drums o f so il contaminated with mineral o il was removed and disposed from the Tracy Substation. Four non-PCB o il cap acito rs were sent fo r metal recycling from the Elverta Maintenance f a c i l i t y . Removal and disposal o f approximately 40 cubic yards o f asbestos-containing pipe from the Tracy 04 reconstruction p roject took p lace in early A pril. Approximately 2,250 gallons of mineral o il with l e s s than 1 ppm PCB were removed from a breaker at Keswick Substation.
S a lt Lake City Area O ffice: Ensco transported and disposed o f hazardous and non-hazardous waste previously located at the Montrose Power
Operations Center. The waste con sistin g o f fiv e drums o f hazardous and three drums o f non-hazardous waste was picked up in mid-January.
Comprehensive Environmental Response, Compensation, and L ia b ility Act.
B illin g s Area O ffice: The Bismarck D istric t O ffice s t a f f conducted environmental inspections at the following f a c i l i t i e s : Fargo, Grand Forks, Lakota, Devils Lake, Carrington, 0amestown, and Bismarck. These were jo in t inspections with area safe ty and Headquarters secu rity s t a f f s . An environmental audit was conducted of the Devils Lake t r a i le r lo t s fo r property management in mid-March. The Huron D istric t O ffice submitted Tier II reports in February to the appropriate State agencies, f i r e departments and local emergency planning c o m ltte e s fo r the follow ing: 32 substations in South Dakota, 4 su bstations in Iowa, 1 su bstation in Minnesota, and 1 substation in Nebraska. The Fort Peck D is tric t O ffice completed Tier I ! reports for 9 su b statio n s. The Bismarck D istric t O ffice completed Tier II reports fo r the follow ing:
21 su bstation s in North Dakota, 1 substation in Minnesota, and 1 Minnesota Hazardous Waste Chemical Report as required per SARA T itle III Section 311 and 312. All reports contained s i t e plans and o i l - f i l le d equipment l i s t s . North Dakota and Minnesota require reporting of 10,000 pounds o f transformer o il in addition to extremely hazardous substances.
Loveland Area O ffice: The removal a c tiv ity was completed a t the Sishc Foundry in Gering, Nebraska, the end o f February. The Groundwater In vestigation Plan was approved by EPA and the State o f Nebraska, and well in s ta lla tio n i s scheduled fo r mid-April. Western received
n o tific a tio n from EPA that no further action i s required under CERCLA at the Fort Morgan Substation.
Phoenix Area O ffice: Tier II report forms were submitted fo r Phoenix Operations and Maintenance Complex, Liberty Substation and Pinnacle Peak Substation to the Arizona Emergency Response Coamtisslon, Maricopa County Emergency Planning CoM ittee and the Phoenix Fire Department. The Operations and Maintenance Complex reported for unleaded gaso lin e, d ie sel fuel and su lfu ric acid . Liberty and Pinnacle Peak Substations reported fo r su lfu ric acid.
S a lt Lake City Area O ffice: The environmental s t a f f Id en tified several substation and microwave f a c i l i t i e s with su ffic ie n t q u an titie s of b a tte rie s th at exceed reporting thresholds for su lfu ric acid . Annual T ier II reports fo r Sections 311 and 312 were generated and forwarded to the appropriate State Emergency Response Com issions (SERC), Local Emergency Response Committees (LEPC), and Designated Emergency Response A uthorities (DERA). In addition, the J e t A fuel at Montrose was reported.
Toxic Substances Control Act.
Nothing to report.
Safe Drinking Water Act.
Nothing to report.
The Western Quality Assurance Program Plan has been formatted fo r Inclusion in Western’ s two-volume Environmental Manual being written for d istrib u tio n to a ll s t a f f involved in environmental work. Preliminary implementation i s underway In the Area O ffices within Western. Quality assurance requirements are written into a ll statements o f work fo r contracted f ie ld and laboratory support at Western s i t e s .
4.0 ENVIRONMENTAL PROGRAM INFORMATION 4.1 ENVIRONMENTAL PROTECTION PROGRAMS
4.1.1 Environmental Protection Implementation Plan In accordance with DOE Order 5400.1, Western developed an Environmental Protection Implementation Plan fo r Headquarters and each o f the fiv e Area O ffic es. The plans esta b lish a written program th at defines Western’ s environmental compliance, p rotection , and pollution prevention goals and o b je c tiv e s. The plans also delineate the re sp o n s ib ilitie s and a u th o ritie s o f the Heads o f Field Organizations. Each Area O ffice i s responsible fo r overseeing development o f the program and ensuring i t s implementation. Western’ s D ivision of Environment i s responsible fo r overseeing development and Implementation o f the Environmental Protection Implementation Plan fo r Western’ s Headquarters O ffice.
4 .1 .2 Environmental Auditing Program
Western establish ed an environmental auditing program in 1980.
The major purposes o f the auditing program are as follow s:
• discover noncompliance with applicable lo c a l, s t a t e , and Federal regulations;
• reduce environmental r is k s ;
• allow fo r communication with f a c i li t y personnel;
• improve overall environmental performance;
• provide assistan ce and d iscu ss compliance alte rn a tiv e s for problem areas;
• accelerate development o f good environmental management p ractic e s;
• provide for worker safety when working with hazardous m aterials; and
• provide management with a tool fo r evaluating the p rio rity of compliance issu es.
The Western environmental auditing program includes auditing of Western f a c i l i t i e s . The purpose o f these aud its i s to advise
DOE 5 4 0 0 .1 .
18
f a c i li t y and Area management of the a p p lic a b ility o f current regulations regarding th eir p articu lar operation s. The aud its are also conducted to review records, point out areas o f non-
compliance, and iden tify practices that are a t variance with industry environmental standards. The audit re su lts are used to provide compliance assistan ce to the f a c i l i t i e s .
In 1994, 40 f a c i l i t i e s were audited by Headquarters D ivision of Environment s t a f f . These functional a p p raisals were undertaken in accordance with DOE Order 5482.IB and included su b station s, maintenance f a c i l i t i e s , and storage yards. The aud its were performed as p art o f Western’ s Combined F ield Review Program. In 1992 Western in itia te d a Combined Field Review Team incorporating environmental, sa fe ty , and maintenance s t a f f members. This provides a m ulti-disciplin ary view of jo in tly related issu es to supplement the formal audit program.
Formal audit reports are prepared for each functional appraisal to d iscu ss the problems found and call attention to potential problems noted by the auditors. The reports include recommended actions the f a c i li t y may adopt to improve compliance with the applicable regulation s. The audited f a c i l i t i e s are required by DOE Order 5482.IB and Western Order 5482.1 to formally respond to the audit within 30 days a fte r receiving the report, and to correct the id en tified problems.
4 .1 .3 Long Range Environmental Plan
In 1988, the Department of Energy committed to the preparation o f a long range plan to address the Department’ s environmental, sa fe ty , and health concerns. Western began the preparation o f i t s long range environmental plan in 1988 in accordance with DOE Order 5400.1. An updated d raft of the plan was prepared in November
of
1990 andrevised
again in 1994. The primary purpose of the plan i s to present environmental protection requirements, go als, and necessary resources so that long range budgets and other coanitments can be made. The information presented in the plan w ill also aid the Area o ffic e s and f a c i l i t i e s in understanding, and complying with the Federal environmental protection regulation s. Some sp e c ific issu e s addressed in the plan are provided below.• assessin g environmental compliance
• implementing programs and achieving compliance
• emergency planning
• environmental training equipment
• recordkeeping and waste tracking
• enforcement actions
• a ir qu ality control
• water q u ality control
• managing and disposal of hazardous wastes
• transporting of hazardous wastes
• managing and disposal of p esticid es
• managing so lid wastes
• managing polychlorinated biphenyls 19
• managing underground storage tanks
• compliance with community right-to-know
• - assessment and management o f past d isp osal p ractices 4 .1 .4 Environmental Protection Compliance Information
In 1994, Western continued to provide f ie ld s t a f f with information on environmental protection compliance. Information and summaries of sp e c ific regu lation s, sta tu te s, and compliance issu es are covered in non-legal terms, to enhance understanding and re ad ab ility . A dvisories developed during 1994, as shown below, supplement the more formal notices (sent in the form o f handbooks and memoranda) that are used to inform Area and D istric t Managers and th e ir environmental s t a f f o f regulatory requirements.
• Final Quality Assurance Program Plan
• WAPA 5400.1A and 2A which assign r e sp o n s ib ilitie s and delegate authority fo r ensuring environmental compliance.
• NPDES Stormwater Discharge Rules Updates
• Underground Storage Tank Requirements
• SARA T itle II I Right-to-Know Guidance
• Revised Preliminary Assessment/Site Investigation Guidance Document
• Groundwater Protection Guidance
• C lass V Underground Injection Well Information and Guidance
• Oil Pollution Act o f 1990 Update and Guidance
• DOE Guidance Sheets fo r RCRA/CERCLA
• Land Disposal R estriction s Regulation Changes
• Clean Air Act Updates and Guidance
• Risk Management Guidance
• EPA SAFER and SACM Guidance
• Stomwater Management Guidance
4 .1 .5 Waste Minimization
Minimization o f hazardous waste production i s continuing at Western. F ir s t , hazardous waste minimization i s accomplished by
the reduced use of hazardous M aterials, that i s , sm aller anounts o f hazardous m aterials, such as solven ts, are being used. Second, m aterials that are non-toxic or th at have reduced to x ic ity are being su b stitu ted , whenever p o ssib le, for more hazardous
m aterials. Western is specifying a product that i s not lis t e d as hazardous be su bstituted , where p o ssib le, fo r tre atin g wood transm ission lin e stru ctu res. Third, employees are being informed as to the d e sira b ility of using altern ate, l e s s regulated
so lv en ts, degreasers, corrosion in h ibitors, and other substances.
4.2 STATE AND LOCAL ENVIRONMENTAL REQUIREMENTS
Western operates in 15 western and mid-western s ta te s . S ta te , county, and lo cal governments apply environmental and sitin g controls and re str ic tio n s to Federal agencies as well as to private industry.
Executive Order 12088 requires Federal agencies to comply and coordinate with EPA and sta te and local environmental regulators in many
situ a tio n s.
Most o f the sta te s in Western’ s service area regulate the generation, tran spo rtation , treatment, storage, and disposal o f hazardous and toxic m aterials. Community right-to-know le g isla tio n and hazardous waste clean-up laws, enacted by numerous s ta te s , are increasing control over or tracking hazardous and toxic m aterials. Congress has included provisions in most o f i t s Federal environmental acts fo r s t a te s to become authorized to implement and manage the requirements of Federal a c ts. Examples o f th is include RCRA authorization, community rig h t-to - know, p e stic id e application , and underground storage tank re gu lation s.
Western cooperates with sta te and local environmental re gu lators and works toward compliance with applicable laws, sta tu te s, re gu latio n s, and ordinances. Environmental audits of Western f a c i l i t i e s address
app licable sta te requirements 1n addition to those imposed by the Federal government.
4.3 ENVIRONMENTAL PLANNING ACTIVITIES AND RESEARCH
Table 3 l i s t s the EAs and EISs completed in calendar year 1994. One EA was completed in calendar year 1994.
Western’ s l i s t o f standard m itigation measures (Appendix C) accompanies a ll transm ission lin e construction contracts. This l i s t has been developed over the years to ensure compliance with the NEPA, the Council on Environmental Quality (CEQ) gu id elin es, the NHPA, and the Fish and W ildlife Coordination Act, among others. These measures are based on Western’ s experience with impacts associated with transm ission lin e construction, operation, and maintenance.
21
ENVIRONMENTAL ASSESSMENTS MD ENVIRONMENTAL INPACT STATEMENTS
FOR CALENDAR YEAR 1994
TABLE 3
PROJECT NAME CLEARANCE DATE
Salt Lake C ity Integrated
Projects Power Marketing EIS 06/95
F latiron -E rie Transmission Line
EIS 02/95
Energy Planning and Management Program (EPAMP) EIS
03/95 Central V alley Project 2004 Power
Marketing EIS
11/96 Adelanto-Lugo Transmission Line
Project EIS 06/96
Navajo Transmission Project EIS 10/96 Emery-Grand Junction Transmission
Line P roject EIS no date
Sacramento Energy Service Center
EA 04/94
Provo River Market1nq EA 11/94
Big George-Carter Mountain Transmission Line EA
03/94 Tracy D irect Connect Transmission
Line EA
09/94 Weld-Windsor Transmission Line EA
no
date Gering-Stegal Transmission LineProject EA
05/95
In 1994, Western continued i t s policy o f i n i t ia t i n g contacts with resource Management and permitting agen cies 1n the early sta g e s o f p ro jects. This provides an e ffe ctiv e and e f f i c i e n t means o f assuring the consideration of sensitive environmental parameters.
Western construction ac tiv itie s operated under two M itigation Action Plans during CY94. Accomplishments under th e Plan for the Mead-Phoenix Transmission Line Project are reported in Attachment D and those fo r the Sacramento Operations Center are reported in Attachment E. Other m itigation a c t iv itie s undertaken during CY94 are liste d below.
• Surveys were undertaken for the American burying beetle and the p r a ir ie fringed orchid in South Dakota; black-footed f e r r e ts in Wyoming; b ird s of prey 1n Wyoming, C olorado , Nebraska, Utah, and Arizona; and various endangered or th reaten ed plants in Arizona and New Mexico.
• Aviation Marker b a lls were in sta lle d a t riv e r crossin gs in Montana, Nebraska, and C aliforn ia.
• Purchased 1200 acres of waterfowl h a b ita t In C alifornia and developed Waterfowl Management Plan.
• Monitored reconstructed vernal pools (wetlands) in C alifo rn ia to determine su ccess rate. Requirements were to replace 2.92 acres.
Western i s cu rren tly showing 3.27 a c re s as successful h ab itat.
Western had approximately 37 environmental planning p ro je cts eith er started or underway during CY94. Most o f these p ro jects, lis t e d in Table 4, are CXs, EISs or EAs for high v o ltage transmission lin e s , power Marketing ra te adjustm ents, and/or communications systems.
23
ENVIRONMENTAL PLANNING PROJECTS ONGOING OR COMPLETED IN CALENDAR YEAR 1994
TABLE 4
PLANNING PROJECTS CLEARANCE
CATEGORICAL EXCLUSIONS
LAO Mood-Pole Replaçaient CX 03/94
Frenchman Creek Substation CX 04/94
Fort Morgan North Tapiine CX 04/94
Holyoke and Nray Substations CX 04/94
01 inda Substation Maintenance Building CX 03/94
Fiber Optics Communication System CX no date
Fiddyment Substation CX 04/95
S a lt Lake City Integrated Projects Rate Adjustment CX 10/94
Flaming Gorge Switchyard and Substation CX 10/94
Brush Field O ffice Maintenance Building CX 12/94
Provo River Project Rate Adjustment CX 12/94
McConnico Substation Development CX 12/94
Basic Substation Easement Outqrant CX 11/94
Casper-Glendo South Access Road Erosion Control and Revegetation
12/94 Saguaro-Tuscon and Tuscon-Apache Pole Replacement CX 02/95
Lovell Substation Stage Ú8 CX 01/95
ED 2 Substation Upgrade CX 02/95
Transmission Line Aerial Ball In sta lla tio n CX 01/95
Western-wide Routine Maintenance CX 01/95
Kayenta-Shiprock Staged Fault Test CX 03/95
4 .3 .1 Research
Western p articip ated in several programs dealing with environmental planning. Among these i s the Colorado River Endangered Fish Species Recovery Program. For th is program Western provides program review o f the ecological stu d ies o f such endangered fis h as the Colorado River Squawfish and the Humpback Chub. Western also has personnel serving on the Jo in t High Voltage Direct Current Agricultural Study Oversight Committee, Western Systems Coordinating Council
Environmental Committee, the Mid-Continent Area Power Pool Environmental Coonlttee, American Public Power A ssociation
Environmental Committee, and the E lectric Power Research In stitu te ’ s Environmental Research Oversight Committees.
ENVIRONMENTAL N0NIT0R1NG INFORMATION 5.1 GROUNDWATER H0NIT0R1N6
Two Western f a c i l i t i e s are required by sta te regulations to conduct quarterly groundwater monitoring. The groundwater monitoring w ells at the f a c i l i t i e s are to determine i f degradation o f groundwater is occurring.
5.1 .1 Miles City Converter Station
Miles City Converter Station i s a back-to-back, alternating-current to direct-curren t converter f a c i li t y . It i s located in Montana and has obtained a water pollution control permit from the State o f Montana. The permit i s required under the Administrative Rules o f Montana 16.20.1017. The permit, number MGWPCS-0020, allows Western to discharge coolant water to an on -site evaporation pond. The coolant water discharge contains low concentrations o f a corrosion in h ib ito r, an anti-foaming agent, and sodium hypochlorite.
Western was authorized by the State o f Montana, to operate an
evaporation pond a t the Miles City Converter Station in June o f 1984.
Operation began on Ju ly 11, 1985, and the f i r s t sampling event occurred on November 14, 1985. As required by the sta te permit, there are three w ells located a t the f a c i li t y used to monitor groundwater degradation. The w ells are sampled on a quarterly b asis and samples are sent to an o f f - s ite laboratory fo r a n aly sis. The r e s u lts of the 1994 monitoring are included in Appendix A.
The permit requires quarterly an alysis o f the groundwater monitoring w ells fo r the following parameters:
• S p e c ific conductance (umhos/cm ? 25 C)
• ethylene glycol (mg/1)
• to ta l phosphorus (mg/1)
• s t a t i c water level (tenths o f fe e t below datum)
Three alte rn a tiv e s to correct d e ficien cies o f the ex istin g cooling water system a t the Miles City Converter Station were formulated in
1992. The alte rn ativ e s were: (1) connecting to c ity sewer;
(2) replacing the cooling system with a new closed loop system;
