United States          Regions          May 1979
          Environmental Protection      1201 Elm Street
          Agency            Dallas. TX 75270
          Enforcement	
&EPA   Environmental            Final
          Impact Statement

          Fayette Power
          Project

          Fayette County,
          Texas

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             FINAL
 ENVIRONMENTAL IMPACT STATEMENT
              FOR
     FAYETTE POWER PROJECT
     FAYETTE COUNTY, TEXAS
ENVIRONMENTAL PROTECTION AGENCY
            REGION 6
         DALLAS, TEXAS
            MAY 1979
                         APPROVED 3Y
                         ADLENE HARRISON
                         REGIONAL ADMINISTRATOR

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                                                                   FINAL 1
                            EXECUTIVE SUMMARY
                     ENVIRONMENTAL IMPACT STATEMENT
     The following Executive Summary for the Environmental Impact Statement,
Fayette Power Project, should replace that which appeared in the Draft
Environmental Impact Statement.

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                                                                   FINAL 2
                            EXECUTIVE SUMMARY
                     ENVIRONMENTAL IMPACT STATEMENT
                     New Source NPDES Permit for the
                          Fayette Power Project
                     iA>wer Colorado River Authority
( )  Draft Environmental Impact Statement
(X)  Final Environmental Impact Statement
                  U. S. Environmental Protection Agency
                                Region 6
                              Dallas, Texas

1.   Name of Action:        (X)  Administrative        ( ) Legislative

2.   Summary Description of Administrative Action

     The United States Environmental Protection Agency (USEPA) is proposing
to issue a New Source National Pollutant Discharge Elimination System (NPDES)
permit for wastewater discharge from the Fayette Power Project into Cedar
Creek and the Colorado River.  The applicant, the Lower Colorado River
Authority (LCRA), has initiated construction on a coal-fired steam electric
station on a site located seven miles east of La Grange in Fayette County,
Texas.  Pursuant to the National Environmental Policy Act of 1969 (Public
Law 91-190 or NEPA), USEPA has prepared this Final Environmental Impact
Statement (FEIS) to evaluate the potential impacts of the proposed action on
the human environment.

     NEPA requires  that all Federal agencies prepare detailed environmental
impact statements on major actions significantly affecting the quality of
the human environment.  Furthermore, Section 511(c)(l) of the Federal Water
Pollution Control Act  (FWPCA) as amended (P.L. 92-500 as amended by P.L. 95-
217) mandates that  the requirements of NEPA apply to the issuance of a permit
under Section 402 of FWPCA for the discharge of any pollutant by a New Source
as defined in Section  306 of FWPCA.  USEPA has determined that the issuance
of a New Source NPDES  permit to the applicant would represent a major Federal

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                                                                   FINAL 3
action significantly affecting the quality of the human environment.  Based
on this finding, a detailed environmental impact statement on the proposed
action has been prepared.

     As directed by Section 102(2) (c) of NEPA, this statement describes:
(1) the environmental impact of the proposed action; (2) any adverse en-
vironmental effects which cannot be avoided should the proposal be imple-
mented; (3) alternatives to the proposed action; (4) the relationship between
local short-term use of man's environment and the maintenance and enhance-
ment of long-term productivity; and (5) irreversible and irretrievable
commitments of resources which would be involved in the proposed action
should it be implemented.

     By public notice dated 24 February 1979, USEPA declared its intent to
issue a proposed NPDES permit to the applicant.  Interested parties had
thirty (30) days from the publication of the public notice to comment on the
proposed permit.  All comments received within the thirty (30) day period
are considered in the formulation of the final determination regarding
issuance of the permit.  The permit becomes issued and effective thirty (30)
days after the date of determination.

     Where the final determination remains substantially unchanged from
that published in the public notice, a copy of such final determination
will be forwarded to all persons who submitted written comments on the pro-
posed permit.  If the permit is substantially changed, a public notice of
such determination shall be given.

3.  Summary Description of Proposed Action and Associated Impacts

     The Lower Colorado River Authority and the City of Austin are con-
structing the Fayette Power Project in response to the increasing demand
for electric power.  This need is based on projected loads for the service
area and the needed reserve margins of the individual utilities and on the
lack of other available sources of power.  Based on this projected need,
LCRA has initiated construction on the project at their own risk prior to
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                                                                   FINAL 4
USEPA"s issuance of the NPDES permit.  This will allow Unit 1 to be operational
by June 1979 and Unit 2 to be operational by June 1980.  Currently, Unit 1
is approximately 96% completed while Unit 2 is 32% completed.  The project
consists of two '00 MWe fossil-fueled steam electric generating units along
with associated coal nandling and storage areas, ash storage area, switch-
yard, cooling pond, flue gas stacks, maintenance and administrative build-
ings, and 121 miles of new or widened transmission corridor.  The water
needs for the power plant will be met through the use of both surface water
from the Colorado River and the 2,400 acre Cedar Creek cooling pond.  The
cooling pond will require a maximum monthly average of 50 cfs from the
Colorado River, representing 17.0% of the 7-day low flow.

     During the construction phase of development, surface water impacts
have resulted from sediments produced during clearing, excavation, and fill
operations.  This runoff from the construction area has been controlled and
treated prior to discharge, thereby resulting in minimal impacts.  Other
sediment producing activities have been localized and of short duration.
The primary construction impact on water resources has been the impoundment
of Cedar Creek which has changed the upstream portion of the Creek from a
running to a standing water system with the associated changes on the aquatic
environment.  Some pre-project species will not reproduce in the cooling
pond.  However, it is expected that new and other existing species will re-
proouce and that the reservoir will have significant recreational value.

     The formation of the cooling pond has changed that portion of Cedar
Creek from a groundwater discharge to a recharge area.  Although power plant
operations will result in increased temperature and dissolved solids levels
in the cooling pond, Cedar Creek, and the Colorado River, these increases
should not significantly alter the water quality of these water bodies or
the groundwater resources.

     No major impacts have or are expected to occur on the geologic condi-
tions of the project area.  Some minor changes in natural drainage patterns
and topography have occurred which are irreversible, but the formation of
the cooling pond has provided a locally unique water resource which provides
                                     iii

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                                                                   FINAL 5
aesthetic relief in comparison to the typical land forms of the area.

     The project area has experienced some localized, intermittent fugitive
dust emissions during the construction phase of this project, but the pri-
mary impacts to the c-lr quality of the region are expected from the operation
of the facility.  Increases in the ambient levels of sulfur dioxide, particu-
late matter, carbon monoxide, hydrocarbons, oxidants, and nitrogen oxides
will occur during plant operation, but will be well below the ambient
standards established for the protection of health and welfare.  The cooling
pond also will tend to lengthen the occurrences of fog in the project area,
but is not expected to result in increased ice formation.

     The sound quality of the project area was minimally increased during
project construction, but this increase had no significant impacts on the
nearest residences or the point of closest public approach (cooling pond
intake).  During operation the plant is anticipated to raise ambient noise
levels by 0-8 dB.  However, these increases should not significantly impact
nearby residences.

     Although prior to construction 97% of the site supported some type of
vegetation, most of which has been eliminated along with the animal species
it supported, no rare or endangered species were affected by site develop-
ment.  Although terrestrial biological productivity has been reduced, aquatic
biological productivity has been increased through the formation of a
nutrient-rich cooling pond.  Construction activities in transmission line
corridors also have destroyed some vegetation, but planned revegetation
measures for the corridors will ultimately increase habitat diversity in
the project area.

     Three historic structures were removed intact from the project site
prior to construction.  The Biegel-December House was moved to the Winedale
Inn Historical Complex, the Legler Log House was disassembled and put in
storage at the Winedale Inn Historical Complex, and the Gentner-Kroll-
Polasek Farmstead was sold to private individuals and removed from the
project site.  The architectural details of those structures moved to the

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Winedale Inn Historical Complex were recorded and complete sets of measured
drawings and photographs were prepared.  The archaeologic investigations
were documented in two reports prepared by the Texas Archaeological Survey
Six of the arci.Teological sites were fully investigated and recorded.  A
total of twenty-five ether archaeological and historic sites were also
identified on the site.  Since none met the criteria for nomination for
national registration for historical places, the Texas Historic Preservation
Officer made no nomination.  Historic and archaeological information from
the twenty-five sites was gathered and has been preserved, although no arti-
facts were removed and presumably will be lost due to the construction
activities.

     The conversion of 3,000 acres of agricultural land to an industrial
land use has resulted in a reduction in agricultural productivity.  Most
of this land was used as pastureland.  Approximately 700 acres of prime
farmland exist on the site, but only a small portion was culti-
vated.  This prime farmland may be irretrievably lost since pre-project
soil conditions are unlikely to be duplicated.

     Other impacts on the socioeconomic characteristics of the project area
are expected to be minimal, but primarily beneficial.  Employment, disposable
incomes, and retail sales have and will continue to increase.  Property and
school tax losses will be offset by increased sales tax revenues resulting
from the sale of electric power.  Some minor adverse impacts on community
facilities and services, particularly housing, schools, and traffic, have
occurred during the construction phase.  However, as the construction labor
force decreases and is replaced by a smaller operating staff, these impacts
will be reduced.

A.  Alternatives Considered

     Five alternatives that do not require the creation of new electric
generating capacity were considered by the applicant.  These are:  (1) no
action; (2) purchase or exchange of power; (3) reactivation or upgrading of
existing units; (4) conversion of peaking units; and (5) voluntary consumer

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                                                                   FINAL 7
conservation.  None of these non-structural alternatives was considered a
viable alternative for meeting the demand for electricity.  The alternatives
that were considered by the applicant requiring the creation of new electric
generating capacity included the use of six different power sources:  (1)
natural gas; (2) nuc^ar power; (3) oil; (4) geothermal energy; (5) solar
energy; and (6) solid fossil fuels.  The selection of solid fossil fuels
considered Texas lignite and several alternative coal supplies.  Other
alternatives considered in the project planning were six alternative sites
and six alternative cooling systems.  The final selection of a coal-fired
steam electric generating plant at the Cedar Creek site using a cooling
pond was based on economic, environmental, timing, and sizing considerations
which favored this alternative.

     The alternatives available to USEPA are the issuance of the New Source
NPDES permit for the facility as proposed and/or conditioned, or the denial
of the permit.  Based on the findings of the Draft EIS and the comments
received during the review period, USEPA has decided to condition the permit
(the proposed New Source NPDES permit is attached).  The condition requires
that an on the ground cultural.resource survey of the transmission line
routes shall be undertaken by a qualified archaeologist prior to any line
construction by LCRA.  LCRA shall provide the results of the survey includ-
ing any recommendations as to National Register eligibility to the Texas
State Historic Preservation Officer (SHPO) and EPA.  EPA in coordination
with the Texas SHPO shall follow the procedures of the Advisory Council on
Historic Preservation (36 CFR Part 800) to determine the effect of trans-
mission line construction on cultural properties.  Line construction shall
not commence until a determination is made and appropriate mitigation
procedures  (if necessary) are agreed to by all parties (EPA, Texas SHPO,
Advisory Council on Historic Preservation, and LCRA).  Further, if during
construction, cultural resources are identified, work shall be halted and
the Texas SHPO and EPA shall be notified.  The procedures described above
shall then be followed.
                                    vi

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                                                                   FINAL 8
5.  Federal, State, and Local Agencies and Other Sources from Which Comments
    on the Draft EIS Were Requested
     Copies of the Draft EIS were made available to the following:
Federal Offices

Department of Interior
Corps of Engineers
Advisory Council on Historic Preservation
Department of Commerce
Department of Agriculture
Soil Conservation Service
Federal Highway Administration
Department of Health, Education and Welfare
Department of Housing and Urban Development
Department of Energy
Water Resources Council
Federal Energy Regulatory Commission
Department of Transportation
Honorable John Tower, U. S. Senate
Honorable Lloyd Bentsen, U. S. Senate
Honorable J. J. Pickle, U. S. House of Representatives

State Offices

Texas Budget and  Planning Office  (A-95-Clearinghouse - distributes
    statements to  all  state agencies)
Texas Historical  Commission
Governor's Office
Texas Parks and Wildlife Department
Texas Department  of Agriculture
Texas Department  of Water Resources
Texas Department  of Health
Texas Air Control Board

Other Interested  Parties

City of La Grange
National Audubon  Society
Sportsmen's Club  of Texas
Natural Resources Defense Council
Texas Environmental Coalition
Nature Conservancy
Izaak Walton League of America
Environmental Defense Fund
National Wildlife Federation
Texas Organization for Endangered  Species
League of Women Voters
American Lung Association of Central Texas
Sierra Club of Texas
Citizen's Environmental Coalition
Texas Public Interest Research Group


                                     vii

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                                                                    FINAL 9
                              TABLE OF CONTENTS

                                                                    Page
EXECUTIVE SUMMARY 	   1
TABLE OF CONTENTS	   9
1.0  INTRODUCTION	10
2.0  NEED FOR THE PROJECT	13
3.0  ALTERNATIVES	14
4.0  DESCRIPTION OF THE PROJECT	22
5.0  IMPACTS OF THE PROJECT ON THE ENVIRONMENT	26
6.0  COORDINATION	31
7.0  RESPONSE TO PUBLIC COMMENTS RECEIVED ON DRAFT EIS  	  33
BIBLIOGRAPHY	56
APPENDIX A NPDES PERMIT 	  62
APPENDIX B BIOLOGY SUPPORTING DATA  	  77

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                                                                  FINAL 10
                            1.0  INTRODUCTION

     The following Section 1,0 should replace the previous Introduction of
the Draft Environmental Impact Statement.

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                                                                  FINAL il
                           1.0  INTRODUCTION

     The U.S. Environmental Protection Agency (USEPA) is proposing to issue
a New Source National Pollutant Discharge Elimination System (NPDES) permit
to the Lower Colorat^ River Authority for a fossil-fueled steam electric
generating plant known as the Fayette Power Project.  The Lower Colorado
River Authority (LCRA) and the City of Austin (COA) are constructing the
Fayette Power Project in response to the increasing demand for electric
power.  The two utilities each have a 50% interest in the project, but LCRA
made application to USEPA for a discharge permit and is referred to as the
applicant throughout the text.  The project consists of two 600 MWe fossil-
fueled steam electric generating units, both of which are partially con-
structed, located approximately seven miles east of La Grange, Texas.  Three
transmission lines, representing 121 miles of new or widened corridor, will
extend from the plant to substations near Fayetteville, Austrop, and Lytton
Springs.

     USEPA has determined the proposed plant to be a new source in accor-
dance with the Federal Water Pollution Control Act (FWPCA) as amended in
1977 (P.L. 92-500, as amended by P.L. 95-217).  Cooling water discharge from
the condensers will go into the cooling pond, then Cedar Creek, and even-
tually into the Colorado River.  The continuous pond discharge into Cedar
Creek as required by the Texas Water Rights Commission is 0.5 cfs.  On
14 October 1976 LCRA applied to USEPA for an NPDES permit for the discharge
from the cooling pond at the plant.  The issuance of this permit has been
determined to be a significant Federal action by USEPA.

     In accordance with the requirements of P.L. 91-190, the National En-
vironmental Policy Act of 1969 (NEPA), major Federal actions which signifi-
cantly affect the quality of the human environment must be accompanied by
a detailed statement of the environmental impacts of the proposed action.
Accordingly, USEPA issued a Notice of Intent (NOI) to prepare an Environ-
mental Impact Statement (EIS) on 27 July 1978.  This Final EIS, along with
the Draft EIS which was distributed for comment on 29 January  1979, fulfills
USEPA's responsibilities under NEPA and the Federal Water Pollution Control

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                                                                  FINAL 12
Act.  A substantial portion of the information in this document was taken
from the Environmental Assessment of the Fayette Power Project, Volumes 1,
2, and 3, which was required as part of LCRA's NPDES permit application.

     Due to the limit?d number of changes and modifications required by
comments received on the Draft EIS, the Final EIS for the Fayette Power
Project contains only those pages that have required modifications or
additions plus the comment letters received during the public comment period
and USEPA's responses to these comments.  The reader is referred to the Draft
EIS for a full analysis of the environmental issues associated with this
project.

     It should be noted that all page changes, except for responses to and
letters from the various agencies on the Draft EIS (Section 7.0), have been
paginated as in the Draft EIS.  Any additional required pages have been
followed by a letter designation (la, Ib, Ic).  Each text change or addition
is indicated with a line in the left hand margin.  Page numbers for the
Final EIS are indicated in the upper right hand corner.
                                     la

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                                                                  FINAL 13
                       2.0  NEED FOR THE PROJECT

     This section remains unchanged from the Draft Environmental Impact
Statement.

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                                                                  FINAL 14
                            3.0  ALTERNATIVES

     The following list presents the page changes in this section of the
Draft Environmental Impact Statement:

          Page 14
               17
               19
               19a
               21
               24
               24a

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                                                                  FINAL 15
from the issuance of the permit are summarized in Section 3.4.2 and dis-
cussed in detail in Section 5.0.

3.2.2  Denial cf the Permit

     USEPA can deny LCRA's application for a New Source NPDES permit if the
agency determines that the proposed discharge will violate effluent limita-
tions or if violations of the Texas water quality standards are anticipated.
Furthermore, USEPA could deny the permit if environmental considerations
such as endangered species, historic and/or archaeologic sites, wetlands,
floodplains, etc., are significantly impacted and measures for mitigating
these impacts are unacceptable.  Should the permit application be denied by
USEPA, LCRA could abandon the project, locate and evaluate another site,
redesign the project to operate without a discharge, or modify the project
so that the discharge would meet the water quality standards.

     Based on the current extent of construction and the economic loss to
LCRA which would result from abandoning the project or evaluating another
site, it is likely that LCRA would attempt to redesign their facilities to
meet the effluent limitations.

3.3  ALTERNATIVES AVAILABLE TO OTHER PERMITTING AGENCIES

     All other permits required for project construction and initial opera-
tion from State or Federal agencies already have been approved and received.
The U.S. Army Corps of Engineers has issued the construction permit required
for the pumping station on the Colorado River (Section 10, River and Harbor
Act of 1899) and the required Section 404 (FWPCA, as amended) permit for the
Cedar Creek Dam is covered under a Nationwide Permit since the flow in Cedar
Creek is less than 5 cfs.  The Texas Department of Water Resources has
approved the Water Quality Waste Control Order which is the State equivalent
of the NPDES permit.  The only remaining permit to be obtained is the operat-
ing permit from the Texas Air Control Board which must be applied for within
60 days after the first day of operation.  Section 6.0 summarizes all other
permits approved and received for the project.
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     3.4.1.4  Sound Quality Impacts

     Construction activities on site resulted in no increase in noise levels
at the nearest residence to the project site.  The construction noise level
at the cooling pond ir.take (the point of closest public approach) was 4 dB
above ambient levels which is barely noticeable and has had no impact on
daily activities at this location.  Noise impacts from transmission line
construction have thus far been minimal due to the short-term nature of the
activity.

     3.4.1.5  Biologic Impacts

     The primary biologic impact which has occurred during plant construction
is the loss of terrestrial biological productivity.  The project includes
approximately 3,000 acres of which nearly 97% supported some kind of vegeta-
tion.  The various construction activities have eliminated much of this
vegetation along with the animal communities it supported.  However, because
no critical habitats of any endangered or threatened plant or animal species
were found on the project site,, the removal of the commonly occurring vegeta-
tion types will not have any significant impact on wildlife species or habitat
diversity.  The formation of .the cooling pond has increased the aquatic pro-
ductivity of the area and has created a more unique aquatic habitat for the
area.  The cooling pond, due to its nutrient-rich water, has greater biological
productivity than most natural lakes.

     3.4.1.6  Archaeologic and Historic Impacts

     The Texas Antiquities Code was followed and utilized to protect and
preserve the historic and archaeological resources identified on the Fayette
Power Project site.  A total of 31 archaeological and  18 historic sites were
identified in the project area.  Six of these archaeological sites were
further  evaluated and tested and the results of these  surveys were fully
documented.  Three historic structures were removed from the site intact and
relocated to other sites prior to construction.  The Biegel-December House and
the  Legler Log House were moved to the Winedale Inn Historic Complex.  The
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                                                                  FINAL 17
by LCRA and resulted in no significant adverse impacts on the environment
or local residents.

     3.A.1.8  Transmission Line Impacts

     The construction of the transmission lines which has been completed
thus far has had minimal impacts on hydrology, biology, and geology.
Natural drainage patterns have been altered and short-term increases in
erosion have occurred.  Clearing activities have disturbed some faunal habi-
tats and some loss of plant and animal life is likely.  However, revegetation
measures have been applied to completed areas, and the resultant growth will
increase habitat diversity.  Construction noise has had minimal effects due
to its short-term nature, and the aesthetic impacts have been minimized by
using existing corridors wherever possible.  A full archaeological survey
will be completed when the final off-site transmission line routes are selected
and the results of this survey will be reported to USEPA and the Texas State
Historic Preservation Officer before construction is initiated.

      3.4.1.9  Other  NEPA  Impacts

      In accordance with  the  requirements  of NEPA,  the  EIS  must  address  the
 effect of  the project  on  short-term  and  long-term  productivity  and- the .
 irreversible and  irretrievable  commitments of resources.   During  the con-
 struction  phase of  the Fayette  Power Project,  the  following  impacts  on  pro-
 ductivity  and resources  have occurred:

      •  Approximately 3,000  acres  of land have been  removed  from  long-
         term  productivity.   If  the project were not  completed,  it is
        unlikely  that pre-project  topographic and  soil conditions could
        be duplicated.  However,  since this  land was primarily used as
        unimproved pasture,  no  significant loss in agricultural pro-
         ductivity has occurred.
      •   Removal  of the 3,000 acre  project site and 4,500 acres for
         future  expansion from the  tax rolls  has resulted in  a long-
         term  impact  on property and school  taxes.  However,  the tax
         losses  are insignificant  compared to  total taxes collected.
      •   The impoundment of Cedar Creek has affected  the vegetation and
         wildlife in the portion of the Creek lying upstream  of the dam.
         While there has been a  long-term loss of terrestrial biological

                                      19

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                                                          FINAL 18

productivity in the area, it has been replaced by increased
aquatic biological productivity.  In addition, the overall loss
of terrestrial productivity is negligible since similar habitats
and species are abundant elsewhere in the region.
                              19a

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                                                                  FINAL 19
chlorides range from 53.6 to 99.0 mg/1, and pH ranges from 8.0 to 8.52.  How-
ever, power plant operations may alter water quantity and quality, particu-
larly in Cedar Creek and the cooling pond.  An average monthly withdrawal
from the Colorado River of 36 cfs for makeup water will not affect the flow
or productivity of chc River, and the 0.5 cfs continuous discharge from the
pond should maintain a more consistent flow in Cedar Creek.  Releases from
the pond for blowdown could contribute dissolved metals such as iron, lead,
manganese, and aluminum to the Creek during pond stratification periods.
However, proper monitoring and operation of the variable intake depth dis-
charge system should prevent significant discharges of dissolved metals.
Other water quality standards including those for temperature and chlorine
also are expected to be met.

     Groundwater resources are not anticipated to be adversely affected by
plant operation.  The total dissolved solids (IDS) and chlorine levels of
the cooling pond during worst case operating conditions will not exceed
the 900 mg/1 and 1,100 mg/1 permit limits for IDS or the 0.2 mg/1 and
0.5 mg/1 permit limits for chlorine.  Since these anticipated operating
levels of IDS and chlorine are.lower than current groundwater levels of these
pollutants, cooling pond seepage into the groundwater table should not re-
duce groundwater quality.  Groundwater withdrawal from induced development
is expected to be minimal, resulting in no adverse impact on groundwater
quantity.  No impacts from the 100-year flood are anticipated.

     3.4.2.3  Air Quality Impacts

     The ambient concentrations of emissions from the Fayette Power Project
are anticipated to be well within the National Ambient Air Quality Standards
for sulfur dioxide, nitrogen dioxide, carbon monoxide, and particulate matter
(See Table 27).  Hydrocarbon and oxidant levels also should be in accordance
with the appropriate standards.  Atmospheric emissions from fugitive dust
will be confined to the project site through air pollution control measures
such as wet sprays and a bag filter collection system.  The evaporation of
water and the dissipation of heat from the cooling pond will increase fog
formation in the project are, but will not cause increased ice formation.
                                     21

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                                                                  FINAL 20
     3.4.2.7  Socioeconomic Impacts

     The 2,400 acre cooling pond will be developed by LCRA into a regional
recreational a^ea for fishing, boating, and other passive recreational
activities.  Neither the plant development and operation nor the recrea-
tional development is expected to induce any secondary growth impacts other
than the limited development of housing which occurred during the construc-
tion phase.  During plant operation, increased sales tax revenues of ap-
proximately $5.7 million annually will be realized by Fayette County and
the City of Austin.

     As construction work is completed, the construction labor force will
be replaced by an operational staff of 230 employees.  These operating
employees are anticipated to permanently relocate within the 30 mile pro-
ject area and increase the project area population by an estimated 730
people.  This increased population is not expected to adversely impact
housing, schools, or other services in the project area since a larger con-
struction phase population increase has already been accommodated without
significant impacts.  Approximately 327 secondary job opportunities are
projected to result from plant operation.  The total increase in disposable
income resulting from these 557 new jobs is projected to be over $152 million
over the 30 year operating life of the project.

     Increased highway and rail traffic from project operation are antici-
pated, but will not create any significant traffic problems.

     3.4.2.8  Transmission Line Impacts

     Non-structural uses will be permitted in the transmission line cor-
ridors, and revegetation measures will be applied to those areas not used
for agricultural activities.  As a result, the corridor will not remove
appreciable amounts of land from productive use.  Right-of-way maintenance
may have some short-term impacts on plants, but the corridors generally
are expected to increase faunal and habitat diversity.  A full-scale
archaeological survey of the  final off-site transmission'line corridors will be
                                     24

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                                                                  FINAL 21
completed and the results reported to USEPA and the Texas State Historic
Preservation Officer before construction is commenced.  Further, if any
potential archaeological resources are found during construction activities,
work will be halted until these resources are evaluated for their historical
significance.
                                    24a

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                                                                  FINAL 22
                     4.0  DESCRIPTION OF THE PROJECT

     The following list presents the page changes in this section of the
Draft Environmenral Impact Statement:

          Page 49
               49a
               51

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                                                                  FINAL 23
     4.5.6.5  Biological Impacts

     The construction of the cooling pond has substituted a large standing
water impoundment for grassland, forest, and intermittent stream habitats
and their associated potentials for biological productivity and species diver-
sity.  Approximately 97% of the project site supported some type of vegetation
prior to construction, most of which has been eliminated along with the animal
communities it supported.  However, no threatened or endangered species were
found on the plant site, and as a result the removal of existing vegetation
types has not significantly affected habitat or species diversity.

     Existing and future terrestrial biological productivity has been replaced
by increased aquatic biological productivity in the cooling pond.  Upon im-
poundment, major physical, chemical, and biological changes occurred as the
aquatic habitat in Cedar Creek changed from a running water (lotic) to a
standing water (lentic) environment and as existing standing water bodies
(ponds) were flooded.  Leaching of inundated soils and vegetation has pro-
duced nutrient-rich water almost immediately after filling.  As a result of
this, biological productivity in the newly impounded pond is greater than in
most natural lakes.

     Specific procedures and policies have been implemented for erosion con-
trol measures during and after construction at the plant site and along
transmission corridors.  Clearing and grubbing activities have been performed
only where necessary and within well-defined boundaries.  Disturbed areas
have been topsoiled and seeded in accordance with the Texas Highway Depart-
ment Standard Specifications for Construction of Highways, Streets, and
Bridges.  Topsoil has been placed and seeded on all surfaces of embankments,
fills, and excavations exposed to the elements except embankment and excava-
tion slopes which are below water surface or where riprap slope protection
lining is specified.

     Creek and wash crossings have been backfilled as required to prevent
soil and bank erosion, and banks returned to their original configuration.
Appropriate drainage systems, intercept, and berm ditches have been
                                     49

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                                                                  FINAL 24
provided to assist in controlling erosion.   Drainage system openings have
been surrounded by riprap.

     4.5.6.6  A-chaeologic and Historic Impacts

     Of the 18 historic and 31 archaeological sites identified on or near the
Fayette Power Project site, six archaeologic and three historic sites were inves-
tigated and reported on by the Texas Archaeological Survey.  Construction
activities necessitated the removal of three historic sites from the project
site.  These sites (Beigel-December House,  Legler Log Cabin, and Gentner-
Kroll-Polasek Farmstead) were relocated intact to several other locations
in Texas.  The actions completed by LCRA in coordination with the State have
obtained as much information as feasibly possible and have adequately
mitigated any adverse impacts.  However, historic evidence on some of the
less important sites was presumably lost during construction.
                                     49a

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                                                                  FINAL 25
pletion of construction activities.  This will minimize long-term effects
and ultimately will increase habitat diversity.  Off-site transmission line
construction has not yet been initiated.

4.6  POWER PLANT OPERATION

4.6.1  Personnel Requirements

     Operational staffing for the plant has begun during 1978 and primarily
consists of supervisory personnel.  Upon completion of both units, it is
estimated that 230 operating personnel will be on-site by 1980.  The staff
breakdown is indicated in Table 9.  Based on the current residence patterns
of on-site operating personnel, it is anticipated that nearly all operating
personnel will reside within the 30 mile project area.
            Table 9.  Plant operation staffing requirements,
                 Fayette Power Project, Units 1 and 2.
          General Category    ..             Personnel Required
          Supervisors                               38
          Operators                                 40
          Coal Handlers        '                     28
          Clerical                                  17
          Mechanical Maintenance                    49
          Electrical Maintenance                    22
          Instrument Maintenance                     9
          General Maintenance                       19
          Lab Technicians                            8
               Total                               230
SOURCE:  Lower Colorado River Authority.  1978.  Environmental assessment of
         the Fayette Power Project.  Volume 2.  Austin TX.  p. C-54.
                                     51

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                                                                  FINAL 26
             5.0  IMPACTS OF THE PROJECT ON THE ENVIRONMENT

     The following list presents the page changes in this section of the
Draft Environmental Impact Statement:

          Page  81
                83
               118

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                                                                  FINAL 27
the operation of boiler units 1 and 2 of the Fayette Power Project (Table 27).
Concentration estimates were made for 12 distances of up to 30 miles in each
of 16 compass directions from the source, and the locations and values of
the highest concentrations were determined.  The dispersion estimates were
conservative (tendir^ to overestimate impacts) due to the use of emission
rates based on fuels having maximum sulfur and ash content and minimum heat-
ing value (actual fuels will be cleaner and have a higher average heating
value);  the assumption of constant plant operation at maximum continuous
rating;  and certain inherently conservative aspects of the CRSTER model.

     To  evaluate the potentially significant short-term atmospheric dis-
persion condition called inversion breakup fumigation (which is not con-
sidered  by CRSTER), separate manual calculations were performed according to
techniques recommended by Turner (1970) and the USEPA (1974a).  The results
showed that inversion breakup fumigation impacts would be significantly less
than maximum short-term levels estimated by CRSTER; therefore, this would not
be a critical plume dispersion condition for the Fayette Project (Table 27).

     Compliance with NAAQS was assessed by adding the maximum estimated air
quality effects of boiler units 1 and 2 to the estimated baseline air quality
levels prior to plant construction.  (Baseline air quality was estimated from
available on-site monitoring data.)  Projected SO-, TSP, N02, and CO levels
will meet NAAQS, and HC and oxidant levels also are expected to be within
the appropriate standards (Table 27).  As a result, no significant adverse
impacts on air quality should result from plant operations.

     Atmospheric emissions of fugitive dust will result from coal storage,
handling, and processing operations.  Although these types of fugitive
emissions are not easily quantified, effects on air quality are projected
to be negligible due to the proposed emission control system.  Fugitive dust
emissions during coal handling and processing operations will be minimized
through the use of wet sprays, a bag filter collection system, and a tele-
scoping chute on the coal stackout boom.  The coal storage piles will be
compacted and wetted as required to prevent fugitive dust emissions and
spontaneous combustion.  All emissions related to coal handling, processing,
                                     81

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                                                                  FINAL 28
and storage areas will be controlled as described to alleviate any possible
associated health hazards.  Several air pollution control measures will be
used to prevent dust from becoming airborne.  Dust from grading, excavating,
and vehicular traffic will be reduced by the use of water sprays or other
wetting agents, and permanent roads and parking lots will be maintained and
resurfaced as needed to reduce dust.  A wet ash handling system will minimize
potential dust emissions from fly ash handling.  As a result, fugitive dust
emissions from the project are expected to be minimal, confined primarily to
the project site.

     The evaporation of water and the dissipation of heat from the 2,400 acre
cooling pond will affect local meteorology, primarily by increasing fog or
ice formation.  A computer model was used to evaluate the potential cooling
pond effects based on climatological data from the National Weather Service
Station in Austin for the period from 1955 through 1964 (1957 was selected
as the year of maximum impacts), and expected cooling pond temperature and
heat input data.
     Based on modeling results, the pond may increase the hours of fog as
much as 305 hours per year over the estimated natural frequency of 725 hours
per year, and the greatest hourly increases would occur in April, May, and
June (Table 28).

       Table 28.  Estimate of monthly distribution of natural and
            increased hours of fog at the Fayette Power Project.
             Natural Occurrence Without Pond
Occurrence With Pond

Month
January
February
March
April
May
June
July
August
September
October
November
December
Year

Hours
124
60
75
67
29
20
0
0
41
87
168
54
725

Percent of Period
17
9
10
9
4
3
0
0
6
12
23
7
8
Increase
in Hours
31
23
27
41
46
48
0
0
20
25
34
8
305
Percent of
Period Increase
4
3
4
6
6
7
0
0
4
3
5
1
4
SOURCE:  Lower Colorado River Authority, 1978.  Environmental assessment
         of the Fayette Power Project.  Volume 2.  Austin TX.  p. A-91.
                                     83

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                                                                  FINAL 29
Based on existing information concerning the routes and the vegetational
characteristics of the surrounding areas, it is unlikely that significant or
unusual vegetation will be impacted by corridor construction.  The opening
of woodlands cleared for the transmission corridors will be beneficial for
many species, particularly the important game animals such as deer, rabbit,
bobwhite, and mourning doves.  Revegetacion measures in the corridors should
not only minimize erosion, but also increase habitat diversity and nesting
sites in the project area for existing and new species.  Adverse impacts to
aquatic biota will be avoided since erosion and stream bank disturbance will
be minimized through appropriate revegetation measures.

     The construction schedule for the transmission lines allows adequate
lead time for scheduling construction activities to avoid crop harvesting.
The tower structures will remove approximately six acres from farming and
may marginally interfere with farming activities, but the lines will not
remove land from productive use.  However, only non-structural uses will be
permitted in the right-of-way.  The undesirable aesthetic effect of the
lines will be minimized where possible by using existing corridors.  Right-
of-way maintenance will be performed with brush killer and by shredding,
creating some short-term negative impacts on broadleaved plants.

     Prior to the initiation of off-site transmission corridor construction,
a full-scale cultural resource survey of the selected routes will be completed
and the results reported to USEPA and the Texas State Historic Preservation
Officer (SHPO).  EPA in coordination with the Texas SHPO will follow the pro-
cedures of the Advisory Council on Historic Preservation (36 CFR Part 800)
to determine the effect (if any) of transmission line construction on cultural
resources.  Construction will not commence until this determination is made
and the appropriate mitigation measures (if necessary) are agreed to by all
parties.  Further, if any cultural resources are identified during construc-
tion, work shall be halted and the Texas SHPO and USEPA notified.  These
conditions have been agreed to by LCRA and have been made part of the proposed
New Source NPDES permit.
                                      118

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                                                                  FINAL 30
                             6.0  COORDINATION

     The following list presents page changes in this section of the Draft
Environmental lupact Statement:

          Page 119
               120

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                                                                  FINAL 31
                             6.0  COORDINATION

6.1  PUBLIC PARTICIPATION

     The Notice of Indent which was distributed to State and local agencies
and other interested parties on 27 July 1978 resulted in letters from the
Federal Energy Regulatory Commission, the Advisory Council on Historic
Preservation, the Texas Antiquities Committee, and the Soil Conservation
Service.  Copies of these letters are included at the end of this section.

     The DEIS has been available for public review and comment for 45 days.
All local, State, and Federal agencies, private citizens, and interested
environmental groups have had an opportunity during this review period to
provide comments to USEPA.  The nature and extent of the comments received
by USEPA did not warrant a formal public hearing.  All comments have been
reviewed by USEPA and those comments of a pertinent and substantial nature
have been incorporated into the Final EIS along with appropriate and defini-
tive responses.

6.2  LCRA PROJECT COORDINATION

     Numerous public and private meetings were held by LCRA during the
planning and initial construction phases of the Fayette Power Project.  These
meetings addressed the need for power, the choice of fuel, the site selection
process, the power plant facilities, and the pollution abatement measures to
be used.  In addition, public hearings on the relocation of State Highway 159
and the control of air pollution at the project have been held.  All relevant
suggestions and objections raised at these meetings have been made and ad-
dressed in LCRA's Environmental Assessment and are incorporated in the DEIS.

6.3  PERMITS AND APPROVALS

     In addition to the New Source NPDES permit, the Fayette Power Project
has been subject to a number of other Federal and State permit and approval
                                    119

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                                                                  FINAL 32
actions.  To date, most of these actions have taken place and are briefly

summarized below.


6.3.1  Other Federal Requirements


     Environmental Protection Agency

     •  Approved application and designated Cedar Creek impoundment
        as a "cooling pond."

     •  Approved design intake water velocities at pumping plant
        and at cooling water intakes for Units 1 and 2.

     •  Issued Prevention of Significant Air Quality Deterioration
        approval for Unit 2.

     Federal Aviation Administration

     •  Approved chimney heights and lighting facilities for Units
        1 and 2.

     Federal Energy Administration

     •  Issued Construction Order for Units 1 and 2.

     US Army Corps of Engineers

     •  Issued Section 10 permit to construct a river intake pumping
        station.  (Note:  In process of obtaining above Section 10
        pumping plant permit, approvals of project had to be obtained
        from U.S. Fish and Wildlife Service and National Marine
        Fisheries Services, both Federal agencies.)

     •  Waived Section 404 Permit requirement for Cedar Creek Dam.


6.3.2  Other State Requirements


     Texas Air Control Board

     •  Issued construction permit for Unit 1 and Unit 2 boiler,
        precipitator, and chimney.

     •  Issued permit for dust suppression control on coal handling
        for Units 1 and 2.

     •  Operating permit to be applied for within 60 days after first
        day of operation.
                                     120

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                                                                  FINAL 33
          7.0  RESPONSE TO PUBLIC COMMENTS RECEIVED ON DRAFT EIS

     This section has been added to the Environmental Impact Statement in
order to respo/.'l to the comments received during the public review period.
Included are the comment letters from the interested agencies, groups, and
individuals and USEPA's responses to these comments.  The questions and
comments contained in these letters have been answered either in the response
following the letters and/or in the text changes preceding this section.

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             FEDEHAL ENERGY RtouLATORv COMMISSION

                          REGIONAL OFFICC

                         819 Taylor Street
                      Fort Worth. Texas  7610?
                          January 31, 1979
                                                   In reply refer to:
                                                        OF.PR-FW
Mrs. Adlene Harrison
Regional Administrator
U. 5. environmental Protection Agency
Region 6
1201 tlra Street
Dallas, Texas   75270

0L'ar Mrs. Harrison:

     We have received your memorandum of January 29 transaitting
a copy of the DEIS for the Fayette Power Project to this  office
for review and comment.   We will  not have any coaments  on this
document for reasons explained in the following paragraph.

     Up until October 1,  1977, this office operated as  a  regional
arm of the Federal Power  Commission and would have  conmented on
the power supply and reliability  aspects of the Fayette Project.
However, the FPC was abolished on that date and certain functions.
including responsibilities for electric power supply and  reliability,
were transferred to the DOE.   I note that the OOF. did receive a.
copy of the draft statement.

                                      Sincerely yours.
                                                  . «AV
                                     lenard  B.  Young
                                     Regional  Engineer
tee ponce  to  Consents Fron Federal Energy Regulatory Cooml sii Ion


     No reiponse  !• required by USKPA.

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O • OCPAHTMCNT Or I
                                    February  7.  1979
                                                       M Hn* Mft» to
                                                       IIC-TX

Drjft E1S for Fayette Power Froject


Mra. Adlene Hjrrlaon
Regional Administrator
United State Environmental Protect loo Agency
l.'Ol Ela Street
Dallas. Teiac  75270

Dear Mrs. Harrison:

tie have read the above Draft EIS  and  have no coosneots to offer.

                                                                s ''•*
                                      Sincerely yours.        / \


                                                           '-.'  .:J»~°
                                                                                    Hepponse to Coanenta Kro« I). S. Oepartnent  of Transportation - fed e^a I
                                                                                    Highway Ail»lnI s t rat Ion
                                                                                         No response la required  by  USEPA.
                                                                                                                                                         O)
                                                                                                                                                         Oi

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®
                United States Department  of the Interior
                           NATIONAL PARK SERVICt.
                               $raiTH»CST KECION
                                  P.O.  So. 72«
                             S.«i> Fe. N<« Mencu 117501

                               FEB9    1979
    Mr. Clinton B. Spotta, Regional
      EIS Coordinator
    U.S. Envlroraaantal Protection Agency
      Region 6
    L2O1 Elm street
    First International Building
    Dallas. Texas 75270

    Dear Mr. Spotta:

    'J* have reviewed tha draft environmental iatiact statement on the
    proposed Issuance of a new source  NPOB3 pa rait for vaatewater
    discharge froaj the Fayatta Power Project In Fayette County, Texas,
    and otter the following comments:

~ I Tha exact number of cultural resources to be affected by the
(V I project should be specified.  Also,  mention should be made
, . I concerning the effect on cultural  resources of the 121 adlos
^£/ | of trensailssloa lines.
Contract specifications  should  Include a sentence to the effect
that If any arcbeological  resourcea are encountered during
coca true t Ion, operations will cease at the discovery site and    *•
a professional archeologist will be consulted aa to the significance
of the material.

                                    Sincerely yours.
                                         Associate Regional Director,
                                           Planning and Cultural Resources,
                                           Southwest Region
                                                                                                    Reapooae to Cooaaenta tram U.S. Department of the Interior -
                                                                                                    National Park Service
I.  A total of V> cultural resources (three historic and thirty-one archae-

    ological sites) could be potentially effected '/ construction activities

    at the Payette Pover Project alte.  The threr hlatorlc areaa (Blegel-

    December House, Legler Log Cabin, anj the Polasek-Kroll-Centner Farm-

    stead) on the project alte were evaluated b; the text* Archaeological

    Survey and subsequently relocated Intact to other areaa In the State.

    Six of the archaeological sites on. the project site vere fully Investi-

    gated and reported on.  Aa ajuch Information aa could feaalbly be obtained

    waa collected froai the Fayetta Power Project alte end adequate alligation

    of adverae effects on hlatorlcal aod cultural resources was provided by

    thla reiearch (ly phone. Dr. David Dibble, Director, Texas Archaeological

    Survey, 26 October 1978).


2.  LCRA Is In the process of conducting a cultural resourcea survey of the

    proposed transmission Una routes.  Upon completion of the survey. LCKA

    will file a report with the Texas State Historic Preservation Officer and

    USEPA.  Construction will not be Initiated until these two agencies. In

    accordance with the procedure! of the Advlaory Council on Historic Preser-

    vation, detemlne the effect of transmission line construction on cultural.

    reuourcev and any required altlgatlve meabures.  These requirements hdve

    been agreed to by LCRA and Included AS a part of the proposed New Source

    NPDES permit.


3.  LCRA personnel will perform all transmission line construction activities.

    During construction, LCRA haa agreed to halt confltructJun work If any

    cultural resources of potential historic significance are found.  These

    resources will be fully evaluated and any appropriate mltlgatlvu

    •eaaurea completed In accord with the requirements of USEPA and the

    Te>as SHPO before construction Is continued.  This requirement has been

    agreed to by LCRA and Included as a part of the proposed New Source WOKS

    pvrult.
                                                                                                                                                                                    t-J
                                                                                                                                                                                    CTi

-------
WILLIAM P CLEMENTS JR.
      jOvtR
                      OFFICE Of  THE GOVERNOR
                            March 8. 1979   rffrS

                                     /-"••£•••...
                                     /.       •
                                     te •
                                                             ".:.7  -
Mr. Clinton B. Spotts
Regional EIS Coordinator. EPA, Region 6
1201 El« Street
First International Building
Dallas. Texaa 75270

Dear Hi. Spotta:

The draft environmental Impact staceawnt on tba propoaed Fayette Power
Project la Fayette County, Taxaa ha a bean reviewed by the Budget and
Planning Office end by Interested and affected State agencies.

The coananta of the reviewing agendas are enclosed, to aaatat your
planning effort.  If this Office can be of further aealatanca, pldsae
contact us.

                                   Sincerely.
                                             Tom B. Rhodea, Director
                                             Budget and Planning Office
          Enclosures
                                                                                                                  >espon»c to Coaaeota Team the Oft Ica of  the  Governor


                                                                                                                       Ho response la required by USEPA.
              EXECUTIVE OFFICE SUt-OING
                                         411 Wf IT I1TM SIHtCT
                                                               AUSTIN. T«AI IIIOI
                                                                                                                                                                                 CO
                                                                                                                                                                                 —I

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          TEXAS DEPARTMENT OF AGRICULTURE
       REAIMN V. BROWN. COMMISSIONER / P. O. BOX I2&47 / AUSTIN. TEXAS 78711
                           AN tQUAl, OPPORTUNITY EMi'LOYEH 31/F
                             COMMENTS


Ua have reviewed the environmental  Impact  statement:  Fayette Power Project,
fayetto Count'/. Texas (EIS-9-002-007) .   The  statement «ppear> to txi coaprehensiva
ind w«ll prepared.

Oir concerns include the irrevocable  cosssitaMnc Q£  )*OOO acre* ot farmland - 700
Acre* of which is classified as prlM agricultural  land - while comparatively
insignificant in this instance  it addle  to  the burgeoning total acreage being
CtxncDitad to non-agricultural purpoeea nationally.   Other concern! relate to the
proposed najor Increase  in coal-fired boilers on  a  statewide and nationwide
ba&u which r.ot only involve potentially large acreages of agricultural land
for plant sites and  coal and lignite  mines,  but where concentrations are 'freat
in J livited area, air and water pollution and the  potential threat of acid-rain
which in lightly buffered soils are all  starters which daaerve the sost careful
attention.

Plans c-ir ihe Payeete project ippear  to  include adequate safeguarJs.
                                                           •-V
    Pirsoo Conducting Raviaw (Slgnatur*)
             Texas Department of Agriculture
                                                        Oat.  2-9-7-:
Raaponaa to Cotment» from the Tcicaa De .artaent  of  Agriculture


    CoMcnta have been noted.  No responie  !• required  by  UStPA.
                                                                                                                                                                     OJ
                                                                                                                                                                     00

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         TEXAS AIR CONTROL  BOARD
CHARLCS I. JAYNES
Vki Churaw
IU.LSTrwA«r.P C.
t*M«ti»f Dvecluc
MM JHOAl CHEEK KOUIEVAHO
   AUSTIN. TEXAS  U7SI
      SII/4II-S7II



    $&
    k&33
                                                     HSllI AH N. AILAH
                                                JOE C. lllOGEFARIIf«. t C.
                                                      rlfOHAITUAN
                                                    0. lACHHUA*. • 0
                                                     KIINZE.rV.).. P I.
                                                      f RANK H. IE-Alt
                                                      UIAMO
    March  7,  1979
Mr. Ward C.  Goes sling. Jr.    ^J0^>
Natural Resources Section
Budget and Planning Office
Office of the  Governor
411 West 13th  Street
Austin, Texas   78701

Subject:  Draft  Environmental Impact Statement:
          Fayette Power Project, Fayette  County, Texaa
          EIS  9-002-007

Dear Mr. Goesslingi

I Please have  two  minor corrections made: one is on page 14,
second to last sentence, replace 30 with  60;  anu the other
ii on page 123,  last sentence, replace  30 with 60.
Although it  is indicated en page 46 thftt  on-site open
burning of refuse and construction waste  had  occurred, the
Lower Colorado River Authority (LCRA! , when quosticneo, •
denied  its occurrence but adaltted a need to  burn to
dispose of the waste that would otherwise overta:; the
capacity of  the  small available landfills.  A perr.it to
burn ha:> been  forwarded by LCRA and is presently under
study by the Tsxas Air Control 3oard Compliance  personnel.

Me have no other objections to thi.s document.  The air
contaminant  scissions associated with  the project de-
scribed will have an insignificant ivpact on  anhient air
quality.  When the status of the requested burn permit
has been settled and the disposal of the  construction
waste satisfactorily decided, then the proposed activities
will be consistent with the Texas Air  Pollution Control
Implementation Plan.
                                                                                       Response to Coaaents  from Texas Air Contr
                                                                                                                        ntrol Board
                                                                                           1.  The changes requested by the TACB have been made ia Sections 3.0

                                                                                               and 6.0 relative to Its requirement  thet en operating peralt Bust

                                                                                               be applied for within 60 days after  the fltsc day of operation.
                                                                                           2.   Coosient  has been noted.   No response In rcqulr
                                                                                                                                    quired by USEPA.
                                                                                                                                                        L-J
                                                                                                                                                        IO

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                                                                  -r
Mr.  '.lard C.  ^oessling.  Jr.  -2-
                                           March  7,  1979
Thank you (or the opportunity  to  review this elocunenc.
If we can be of further  assistance, please contact me.
      a.  Mallis,  Deputy  Director
Standards and Regulations  Program

cc:  Mr.  Suqena Fulton,  Regional Supervisor, Waco

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                     rCXAS DEPARTMENT OF WATKH
                                  I 7UO N. CiMgrcu Avenu
«1 »'ATKH DEveiOPMENT BOABP          / ./ J_ J<-                    Tf XA» • VflH CIIMMISSMIN


 .1,1	 I  i:*,,                            --•—•                        |-><: „  r.4,,,,11
             Lev                      Mirtry Dam
                                    l*..uu*. IWdtt
                                  February 22. 1979


                                                     RECEIVE!;
 Mr. Tom 8. Rhodes. Director
 Governor's aidjet and Plaining office                ...[J  |   1979
 Executive Office Building
 ill .te£t  13th Street
 Austin, Texas  787O1

 Dear Kr. anories:

 Re:  U.5.  awircriMsital  Protection  Agency—Draft Environnentai  Lrpact  State—
      .ne.it—Fjyette Power  Project,  Fayette Canty. Texas.   January 1979.

 In  response  to your February  5 .Honor antium,  the  Texas Ceperonent of  -later Re-
 acurces  iTDHR)  lias  reviewed  the subject  Draft Envirorirent^l  Inpact  Statanent
 •EISK   prepared by  the  U.S.  Envrromental Protection *v>jcy t!.^fPAI  in con-
 rfcjct:on '.«ith  U:eir  current processing  of sn 3pc>lication from tr*e Lower C^lurado
 liver  AijtHjrity ILCRA)  for 3  itew Source National  Pollutant Discharge rlLT.nu-
 ticn Systctn  i^POtS)  permit for tlie  future discharge of condenser coolmj >ater
 r:c™ uie pt^er  block of  the  Fayette Power Project (FPPI  to  the  ooolirq porxJ on
 ~c:ar  Crt=h.  and uita the Colorado River.   ULFfi  has determined  that  the FPP
 i.-j.->tit;jt2s a ne.-i pollutant  source  as  defined in the Federal Vater  Control .Act,
 arnerxieil  in   1977  (P.L.  92-SOO).  and  as  further  dit^nried  by  P.L.   95-217.
 Sf«c>f:cally,   t)a   etflu««it   frun  the  FPP  is  subject  to USEPA flew  Source
 PerfoniBrce  St^rxiird   (40  CFR  .432)  chlcrine  luiutations  ror  the   conrisrse.-
 di ictunje 1:0  tt.o  rrx>l UV| pcrJ.  y^l  Ij t.'w Sljt^ of r^r.u± r.:it».i- ,i«nr. .>ui .'-•/
 jLji.ijuta  :or u.-j _colii'ij ponu oisctkirge to CeOar Creek, wtucti  is >]ovemeo  ay
 .later  'jaialitv 5C-»vJards  specified for  Colorado River  Basin  jtrsam ^«j^ait Mo.
 Uu2.    (ioe  Secticn  i.2.J.  page   6O.  Draft  SIS.;    In addition.  USEFt luis
 ^Jetenroj^ed  that the  issuance  of  the fTOCS *.4ast<.-.eter  r'ischaroe peniut  for ^he
 FPP constitutes a significant Federal  action requiring the preparation of  an
 tIS,  as  specified  ;n  the  National  awironmental  Policy  Act   of  1969  ;p._.
 O'-I-JOI. and  as required by  Sections Sll(c)(l>. iOZ.  *i'4 TO6  of  P.L.  92-i.XJ  as
         i>y P.L.  95-217.
 n>«  rotts  the  following basic  data on  the  score and  status of  the FFP.  ^,
 or'icr to  pi'esent o:r «*risumfj  review ccnraents on  this iraicr ^ner>jy  Ki^oject in a
 vTiirrent ;.erspective:
                                                              . it: i: •'  lid'1

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                                                                                       t
i-lr. Ton B.  rthodes.  Director
Kebnury  22.  )3'/9
Page T./o
     1.  The  KPP is*being constructed and will be jointly cxwd  by tne LCTA
         and  (he Cicy of Austin, Texas.  The LCRA Is the NPCES permit
         applicant.

     2.  Initially,  the project will consist of two 60O Mtfe coal-tired
         steam electric generating units.  It is planned to expand the FPP
         generating  capacity bo 3.OOO Mte.

     3.  n«  project is under construction, at an advanced stage,  at an
         jpprGx.uTute J.UOO-acre site located approximately seven rules east
         of the City cf La Grange, Fayette Coxnty, Texas.

     i.  ileneratinc;  lint No.  1 is approximately 75% comnlece and is scneduled
         for  operational iee in 1979; unit No. 2 is approximately  11% com-
         plete and scheduled for operational use in 108O.

     i.  nie  construction and filling of the 2,cno-aore cooling  pond,  formed
         by a to-flii le-lcng earthen dam on the Cedar Creek *as completed in
         July 1978.   This reservoir has an average depth of 3O feet,  ard a
         itcrflge capacity of  72.OGO acre-feet at the authorized  surface of
         390  feet above irean sea le\-el. to be iraintained by aiidoriz^d di-
         versicn of  approximately 26.COO acre-feet f«r year of makcuo .tit.er
         from the Colorado River.

     •i.  Hie  future  expansion of the FPP to a capacity of 3.oO«) l*)e will be
         throiicn Ihe 'Jevelopraent of a second cooling pond on Baylor Crvek,
         west of the Cedar Creek site.   LCHA hjs accguired the jjliticrul
         ~,5d> acres cf land required for tlie expansion.

     ".  Tlie  estimated cost of the project (excluding the cost of  trans-
         mission lines, switchyard, did coal cersi is V-S^.OOO.OOO.

     t.  Ail  other permits reouired for project construction from  State or
         F-jleral >>guf.ciss already nave been approved anj received,   iiee
         oectic-n 3.3. page H. and Section 6.3, page-j 11Q-121 for  status
         of all retired permits.)

rtvw offers U'.a foUcwing staif review oaiments, fion tlie stjr*^x>int of TT*R's
.cja.it.Di-/ St.ite-wide respo»sibilitics relative to the pl.wnir.], dtvel-v«nc
nk.iijnement., and regulation of water resources, watsr ojnlitv, wastewatir.
i:-.l i.-.tistnal  solid wastes:

     i.  ICWR believes that tlie ajbject Draft EIS,  and the basic jource
         •Jocuient used in tf-e preparation thereof (i.e., UCRA. Ii73. Snvirc.-y-
         .rental  Assesgnpnt of the Fayette Po«?r Proiect. Vuls. I,  2, «nrj I—
         -.jricti .433 part of LCIW3 fPCCS permit application,  as indicat«,-d on
         p^<.»; 1,  Or-:ft EIS) confirm TOUR'S basic t'lnciliqs reoardiiq tJve f-.-.isi-
         jn:ty of U'-e proposeii project, as reflected in TTWR's  issi
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Mr. Tom B. .Thudes. Director
February 22. 1979
Page Three
         a.  i;onstruction permit  for Cedar Creek and Baylor Creek dans anri
             reservoirs to provide  an ultimate ceo I u 13 capacity for 3,000
             MWe, or four generating nuts for the  FVP.  (See  Section 6.3.2.
             page 121).

         b.  Permit tor appropriation of State water from Cedar Creek and
             Baylor Creek, aivl the  authorized diversion of 26.0OO icr-i-feet
             |.er year of lakeip water from the Colorado (liver (page 68.  Draft
             EIS) for the FPP.

         c.  Vtoter Quality Waste Control Order and  Industrial Solid Waste
             Disposal Site (77-acre. clay-lined ash disposal  and recycle pond
             with ro discharge).  (See Section 1.3.  page K.  Section O.I.2.
             pages 35-37; jrd page  121. Draft EIS.)

         a.  Certification that oonstniction of Colorddo River r>unping Plant
             /ds.  and power plant block
             cor two generating units. (Page 121, Draft EIS.)

         Sect ion 3.4.2.9, sixth paragraph, aa«je 25.
         Attfcnticn is invited to  the following statonert relative to the pro-
         bdole. post-operational water quality impacts of the FPP:

           "Ihe water qua 1 if/ of Cedar Creek, the ooollng pond,  ind the Colo-
           rt shoulij be
         carefully qualified to state that in order to assure ratioral
         sanplirig aiJ nuxitoring cf the Interrelated water todies are
         essmtial. and that these  actions should be considered as intrinsic
         parts of aie full, systematic e'/aluatlon and  dsv.;lcf«nti.t of Vt.i rPP
         to  its ultimata 3.OOO I He  cauacity.

TU-IR <*]precic»to
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                     Texas Department of Health
     nd T. Mo«c, M 0.
«i:lip w Millat. M.O.
Depuly Comnmiicnw
                                    Atnun. Tep_uri^ent_pj_ HeaJ^tli

                                                                                                                     The anticipated magnitude of coal dust generation  Is  expected

                                                                                                                     to be negligible.   The  applicant hab propoeed  the  use of  duat

                                                                                                                     elusions control  syrens and procedures that  when loplemented

                                                                                                                     will allow a negligible  Impact on the air quality.  Section S.J

                                                                                                                     of this Final Environmental  Impact Statement has been modifier!
                                                                                                                     to dddrecs lhid comment.

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CD
     Mr.  Goessltng
     Hag* Two
     Hatch I.  1979
Records of thij Department Indicate chat sanitation problems previously hav«
be«Q reported ind Investigated *t th« Payette Pow*r Project construction site.
The provision of Insufficient toilet facilities and bap roper maintenance of
tnese facilities were found to be creating Insanitary conditions and possible
oollutlon problems.

Except tor the health conditions noted above, no adverts public or en v Iron -
acntal health aspects of the Power Project were noted In our review of che
subject Statement.

Uu appreciate the opportunity to review and cooeent on the Draft Environmental
Impact Statement for the Fayette Power Project.
     S Incerely.
     C.  R.
     Deputy Cdnnissianer for Environaenc«l
       jnd  Consumer  HejlLh Protection
     DUI/ds
           Bureau oi  Scata Health  Planning
             and Resource  Development,  TDH
           Public Health Region 6,  TWI
           Occupational  Health and
             BjnUtlon Control Dlvlaion,  TDH
           ^^neral Sanitation Divlaion, TCM
           Occupational Safety Dlvlaion,  TDH
2.  The unaanltary condition* noted at  the  constructl  n >lta have

    b.en corrected by the PrlM contractor.  Brown I  toot.  Inc.   A

    package waatew.ter treatMnt plant  and adequate  convenlencea
    have been Inatalled for con«tructlon workers.
                                                                                                                                                                                 •Ti
                                                                                                                                                                                 Ol

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                                                                    1
                     IfMlllfll If  IDC till   _
                         tilllicl CIMI tr utinllil
                          f t.lti lilt
                       IIIXIIM. Iflll !•»»>   U,
                                                '' .'I  "U '1C

                                                  28 FLB (979
Ms. Adlene  Harrison
Regional Administrator (6A)
Environmental  Protection Agency
1201 Elm Street
Dallas, Texas   75270
Dear Ms. Harrison:
This is  In  response to your letter dated 29 January 1979,
which provided  a  copy of the "Environmental Impact Statement,
Fayette  Power Project, Fayette County,  Texas," for our review
and coinini;nts.

All necessary Department of the Array  permits have been Issued.
I'arjgr.ipli 3.1,  line 3 on page 14 should be revised to state
that fill material  placed in Cedar Creek is covered under a
Nationwide  permit since the flow rate  is less than 5 cfs.

The opportunity to  review the environmental statement is
apprec ialed.

                             Sincerely  yours.
                             JON C. VANDKN  BOSCH
                             Colonel, Corps of Engineers
                             District Engineer
»e«pon«e to Consent» from the Pepartaent of the Aray - Corp« of
Engineers
          lu» b«eo noted and Che requested eodlfIcationa have been Incor-
porated la Section 3.}.

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                     DEPARTMENT Of £.'. 5
                                                                  2  19??
AJlene Harrison
Regional  Administrator
environmental  Protection  Agency
Region VI
I?OI  tin  Street
Dallas. Texas   /S270

Dear  Ms.  Harrison:

The Draft Environmental Impact Statement for the Fayette Power Project,
Fayctle County.  Texas  has been reviewed.  Since the project Is substantially
complete, we hive no comments.
                              .     Sincerely,/  I



                               ^  G. Dan Rauibo
                                   RegionJI Representative
L
         Bob  Stern. Acting Director, Division of NEPA Affairs
                                             Heaponiie to CuMMnta ttom the Dep
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 United Sl*le>
I Department of
 Agriculture
                 Sol
                 Cumervjlion
                 Service
                                P. 0. Box 648
                                Temple. TX   .
                                76501    -  '
                                                   Harch-5.
Mrs. Adlene Harrison
Regional Administrator (6A)
Environmental Protection Agency
1201 Elm Street
Dallas. TX  75270

Dear Mrs. Harrison:

We have read the draft environmental isipact statement for the proposed
construction of the Fayette Power Project in Fayette County. Texas and
feel that the statement adequately reflects the Impacts this project
will have on the soil, water, and plant resources.

Although the statement discusses the revegetation of disturbed areas
resulting from construction of transmission lines, there Is no reference
made to vegetating the disturbed areas resulting front plant construction.
We strongly recommend that all disturbed areas be vegetated as soon as
practical in order to keep soil erosion and sedimentation at a minimum.

We appreciate the opportunity of reviewing this statement.

Sincerely.

lieorge C. Harks
State Conservationist
                                                                                             teipons*  to Cot-ent« Fro« th« U.S. Dep»rt»ent  of  Agriculture. - Soil
                                                                                             Conservation Service

                                                                                                   1.   The requested consideration (or the revegecstlon of disturbed

                                                                                                       aress resulting Iron plant construction  Is  noted.   Section 4.5.6.5

                                                                                                       of this Final Environmental Ixpact Statement  for the Fayette Pouer

                                                                                                       Project Included the appropriate aodlfIcatlonu.
                                                                                                                                                                        r-
                                                                                                                                                                        -f^
                                                                                                                                                                        cr>

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HlexPIRG
 Texas Public Inurol Hsiaarch Gtoup
                                  la. 23) • U.C.
                                               Uiwwuly ol Huuiion
  (7131 749 JIM

HOKUM. T». 77004
®
                              March 6. 1979
U.  S.  Environmental Protection Agency
Region 6
1201  Elm Street
Dallas,  Texas

Re: Comment on Draft Environmental  Impact Statement: Fayette Power
    Project, Fayette County  Texas.

      TEXPIRC, a  student  funded consumer and environmental  organiza-
tion,  part of the nationwide PIRG group,  would  comment on  the
statement as below.  We  appreciate  this opportunity extended
us  by  EPA.

       We are concerned about the Increase of radio-active
matter In the air.   We are particularly concerned  of the
radio-active emissions which are reaching Live  Oak and Duval
Counties in which there  are  significant mining  and milling
of  uranium.

       Therefore,  we request  that the  applicant  provide data
for the  three different  coal  types  to be  burned In the two
units  which describes:the estimated ground level concentrations of
radio-active elements;
    226
 Ra      Emission  rate for (a)  Maximum 24  hour period,  (b)  Annual
 average.

Th       Em I s.i Ion  rate for (a)  Maximum 24  hour period,  (b)  Annual
average.

     Evidently Thorium and Radon would  be the chief emissions
from coals, as from the  FEIS of the North Valroy, Nevada, Coal
Fired  Plant, pg.  3-16.

     Again, thank you for this opportunity,  and we  look forward
to hearing from you In    this regard either personally  or through
the Final  Statement.

                           Sincerely,
                             C/)ohn F.   Doherty
                               Acting Director
                             Response to Comments 'rom Tatas  Public Interest Research Croup


                                 1.  There is increasing swsreness of Che presence of uranium and thorium

                             "daughter*** to fly ssh aod in airborne particular:*, in the atack plume of

                             coal-flrad power plaota.  However, theae are presently unregulated pollutant*

                             under Section 122 of the Clean Air Ace as amandi J In 1977.


                                 The data requested for the  three types of coal to be burned la preaented

                             In Table 1. I; la known that coala contain varying concentrations of

                             uraniuai and thorlua) and their radioactive daughters. There haa been Hatted

                             radiological surveillance conducted around foaall fuel power planta; however,

                             it haa been generally accepted that the utilization of fossil fuels for power

                             generation does not present a significant radiological health concern.  As

                             coal ia burned to produce steam, portlona of theae trace elements are re-

                             tained In bottoai aah, captured In the baghouse. or released to the acokovphere

                             aa gases or perticulate fly ash.  While it la recognized that minute quanti-

                             ties of theaa trace elements will be deposited ia the surrounding envlronoent

                             during the operational life of the power plant. Federal or State atandards

                             to Malt such missions have not been established.  With the projected

                             electrostatic precipltator efficiency of 99.&t and low trace element con-

                             centration of the coal at the Fayette Power Project, the Impact of the pro-

                             jected emissions should be negligible.


                                 USEPA is currently researching radioactive emissions and has many fosttil

                             fuel plants under atudy as specified In Section 122 of the Clean Air Act aa

                             amended In 1977.  The USEPA adalnlacrator will review all relevanc information

                             and determine whether or not emissions of rsdlosctive pollutants.Into die air

                             will cauae or contribute to air  pollution which may reasonably be anticipate.I

                             to endanger public health.

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                                  Table I.

       AtBoipherlc Radioactivity Predicted for Fayette  Power  Project


                              Unit I      	Unit 2
                          t. Decker Coal  Coal Crk. Coal  (lack Thunder Coal
   Cone, in Dry Coal
     ThortuD (ppa),
     Uraniim (ppa)         0.99             2.4              0.77
Thortun leilon
       and Bail Bun lipact data preaented In the DEIS according to the
       Indicated content* of thorlim (Th) and uranim (U) bautd on core
       •aaple data (cleaned coal aa fired would be lover In Th and (I).  Con-
       versions to ptcocurlea (pCI) are 0.109 and 0.333 per Blcrogran (UK)
       for Th and U, respectively (see Wang. Yen (ed.). HondhooK of RjJlo-
       actlve Huclldea.  67th ed., Ch.11 lea I  Rubber Co.).

                                                                           cn
                                                                           CJ

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                                                                        t
               FEDERAL ENERGY REGULATORY COMMISSION
                       WASHINGTON. D. C. jo«i«


                          March 9.  1979
Mr. Clinton B. Spotts
Regional EIS Coordinator
Environmental Protection Agency,  Region 6
1201 Elm Street
First International Building
Dallas.  Texas  75270

Dear Mr. Spotts:

     I an replying to your request of  January 29.  1979 to the
Federal Energy Regulatory Coonisalon for cements  on the Draft
Environmental Impact Statement for the Fayette Power Project,
Texas.  This Draft EIS has been reviewed by appropriate FERC
staff components upon whose evaluation this response is based.

     The staff concentrates its review of other agencies'
environmental impact statements basically on chose areas of
the electric power, natural gas,  and oil pipeline  Industries
for which the Copulas Ion has jurisdiction by law,  or where staff
has special expertise in evaluating environmental  impacts
involved with the proposed action.  It does not appear that
there would be any significant Impacts In these areas of concern-
nor serious conflicts with this agency's responsibilities should
this action be undertaken.

     Thank you for the opportunity to  review this  statement.

                                   Sincerely,
>a«pooa« to Co«»aot» Trom the Federal Enargy iegulatory Co«alB«toii



    Ho reipooaa 1> r«qulc«d by USEPA.
                                  I jacx. n.  Helnemann
                                  I/'Advisor  on Environmental Quality

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              United Stales Department of the Interfcjr *Ei*0.'i£/} '
                        UKFICEOKTIIESECHETAKV       ^   '"    • V W)lff- ,
                             SlllITIIWESTHElilOS             ^9j\    ,_**•
(1)
                             HOST O»>H:E BOX .*!*•
                                    NEW MEXICO  .i7nrl
                               March II.  1979
Hr.  Clinlon B. Spoils
Regional EIS Coordinator
Environmental Protection Agency. Region 6
1201 (Ira Street
First International Building
Dallas, Texas 75270

Dear Sir:

This responds to the January 29. 1979 notice by Adlene  Harrison,
Regional Administrator. Environmental Protection Agency,  sent  to
Mr.  Bruce Blanchard. Director,  Office of Environmental  Project
Review, requesting our comments on the draft environmental  state-
ment on the proposed issuance of a new source National  Pollution
Discharge Elimination System permit for wastcwater  discharge  from
the Fayetle Power Project in Fayette County. Texas.

It is our view that while the draft statement adequately  describes
the power plant development and expected impacts,  the preparation of
an environmental statement after the majority of the project  has
been completed, negates the purpose and intent of  the National En-
vironmental Policy Act.  Section 1500.2 of  CEQ Guidelines indicates
that statements should be completed prior to construction so  that
impacts can be assessed and less damaging alternatives  identified.

This draft statement conflicts  with the requirement for early pre-
paration of statements which are meaningful  in the  decision-making
process.  For example:

     I.   Critical environmental features cannot  be  preserved when
         construction has taken place before »uch  features  are
         identified.

     2.   The Incorporation of measures to minimise  environmental
         impacts such as inclusion of natural areas and tree
         preservation cannot be accomplished if  existing  vegeta-
         tion is destroyed.
                                                                                                           »e»pon»e to Co»ent.  fro. U.S.  Dep.rtmril of the Interior
                                                                                                           Office of the Secretary                    ""   	
                                                                                                                1.   ComentJ  liave been noted.  Mo reiponae It require
                                                                                                                                                               quired by USKPA.

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(D
     3.  Alternatives cannot be properly considered, particularly
         the "no build" alternative when construction is underway
         and impact* to the environment have already taken place.

Our review and comment of an environmental statement for a project
welt under construction j$ rather Meaningless.  We urge that you
adop*t a procedure to assure environmental analysis and review of a
development priur to any disturbance of the area.

For your use, we do offer the following comments concerning infor-
mation that shoo Id be in the statement for the Fayet te Power Project.

On page l8. Ihe  statement, "...construction activities did not adver-
sely affect the major historic and archeologteal structures and sites
in the project area, although potential historic research on less
important sties was presumably lost during construction." is In con-
flict with Srction 106 of the National Historic Preservation Act.
Pursuant to Section 106. all sites of potential archeological  or his-
torical value must be adequately surveyed and examined for their Nat-
ional Register eligibility prior to any development.  Also, the Keeper
of the National Register of Historic Places was not given the oppor-
tunity to provide Otterainations of Eligibility on the properties
identified in the  cultural survey.

Section 106 a I r.o states that Federal agencies must "afford the
Advisory Council on Historic Preservation, established under Title
II of this Act, a reasonable opportunity to comment with regard to
vuch undertaking."  Although the Advisory Council was notified of
CPA's intent to prepare an environmental statement, they were not
afforded an opportunity to comment on the undertaking in accordance
with the procedures in 36 CFR 800 ("Procedures for the Protection
of Historic and Cultural Properties" established by the Advisory
Council).  Mitigation measures should not have been undertaken until
the procedures in 36 CFA 800 had been completed.  We find no evidence
of consultation with the Stale Historic Preservation Officer (SHPO)
In any cultural resource matters.   The final statement should include
the SMPO's findings or comments.

flic depth to water table below the ash disposal pond should be given.
and the anticipated seepage from the pond and related monitoring needs
should be addressed.  Since the project will maintain a O.$~cfs dis-
charge from the cooling pond (p.  70), the effects of changes in stream-
flow on ground-water levels downstream should be assessed.   The dis-
cussion should include impacts of changes in temperature (e.g.. on
putobility anJ flow rates).
                                                                                                           2,   Prior (o Che completion of EPA's NEPA procedure*. LCRA elected to
                                                                                                           uce  construction at their own riufc.  The cultural resource investiga-
                                                                                                      tion* and subsequent excavation of six prehistoric and three historic
                                                                                                      sites, which vcre conducted by the Texas Archaeological Survey, war* per-

                                                                                                      formed under tha Texas Antiquities God* rather tti«n under federal procedures.
                                                                                                      However,  the Texas Scats Historic Preservation Officer stated In his letter
                                                                                                      daced April 3. 1979 (copy Included In chla section)          that a review
                                                                                                      of  tha project utilizing the "Procedures for the P» .cectlon of Historic and
                                                                                                      Cultural  Properties" (36 CFR. Part BOO. as amende,!) revealed thst project
                                                                                                      impact on sites posulbly Meting National legist r eligibility were Mitigated.
                                                                                                      EPA did not become aware of the significance of the cultural resources
                                                                                                      until the Environment*! Assessment was submitted on February 27. 1978.  At
                                                                                                      that  elm:, the cooling pond was being filled and actions had already been
                                                                                                      taken to  Mitigate impacts of the project on cultural resources at the ait
                                                                                                      As  *  result, compliance with Section 106 of the National Historic Preservation
                                                                                                      Act was not poeaible.
                                                                                                          3.  In accordance with Texas Water Conlssion Permit No. 0210S, Part III.
                                                                                                     Issued on October 19, 1978. to LCRA, relative to seepage Che Commission

                                                                                                     requested that :
                                                                                                              "The ash disposal pond shall be canstiucted/excavated In such
                                                                                                               a Manner that * minimum of three (3) feet of clay-rich
                                                                                                               (liquid limit 30, plasticity Indei 15) soil Material
                                                                                                               exhibiting permeability of 1 x 10~7 en/sec or its equivalent
                                                                                                               (In no case less than eighteen (IB) Inches in thickness)
                                                                                                               directly underlies the bane uf the excavation.  Natural In-
                                                                                                               place soils Meeting chase criteria may be utilized as liners.
                                                                                                               If any soils not meeting the above are encountered within
                                                                                                               the disposal facility, this Material shall be excavated
                                                                                                               and/or covered with a sufficient thickness of conpscted
                                                                                                               clay-rich soil material to provide a liner equivalent to
                                                                                                               three (3) feet of soil having a permeability ot  1 x 10~7
                                                                                                               cm/sec.   The permittee has submit ted data which confirms
                                                                                                               Chat the coal/lignite storage runoff retention pond and
                                                                                                               other wustevater ponds comply with the pond lining
                                                                                                               requirements .
                                                                                                               Subsequent to use of the ash disposal facility, construction
                                                                                                               of the recoMpacted clay-rich soil  liner or "blanket" pro-
                                                                                                               posed for installation to ch« north central pond area shall
                                                                                                               be certified by a professional engineer with current
                                                                                                               registration «s specified in the Tends Engineering Act.
                                                                                                               Certification shall Include actual "blanket" thickness and
                                                                                                               coefiIcient of permeabllIty.  Result u of ail engineering
                                                                                                               test data, such as compaction density testtT, permeability
                                                                                                               tests, or the logs of additional soil borings employed to
                                                                                                               confJ rm blanket thickness, shsl 1 accoapuny the rertltl-
                                                                                                               catlon." (TWC 1978)
                                                                                                                                                                              cn
                                                                                                                                                                              to

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                                                                                1-
®
(D
The statement should reference other ongoing studies in the vicinity
of the project.   In addition to the Bureau of Reclamation's apprai-
sal level study. "Colorado Coastal Plains Project. Texas." the Corps
of Engineers has a project called "Mouth of Colorado River, Texas1'
which is an authorized project scheduled for construction In l$80.
The Corps' project has been coordinated with region VI  of the Environ-
ment* I Protection Agency.  The Bureau of Reclamation study is in the
preliminary planning stages in which the present yield of the Lower
Colorado River  is being  identified along with the future yield with
and without additional water supply development, and the expected
future water requirements of the Colorado River Basin below Austin.
Texas.  That study includes the Fayette Power Project in the yield
determinations;  thus, no effects on the Colorado Plains Project are
ant icipated.
Page 21  - It appears that the anticipated chlorine levels of the
cool iny pond doe_& exceed per mi t I irai ts for chlor ine .
               S3 6  to  99.0 mg/l
                                                 Permit   Iimi ts
                                             0.2 to 0.5 rng/1
     The opportunity  to  review  the draft  statement  for  the Fayette Power
     Project  is apprec iaied.
                                     S incere ly ,

                                   >Y
                                    /Raymond P. Churan
                                     Region*I Cnv ironmentaI Officer
      4.  In It a order Issuing Permit  No.  021< '».  the Texas Water Commission
 found that ths affluent  discharge of  the  quality aa required by the permit
 "will not unreasonably Impair ths quality nor adversely affect  uses of  the
 area ground or surface water."  (TWC  1978)

      Texas Hater Rights Permit No.  1175 requires LCRA to release 0.5 cfa on
 a continuous basis.   Once  the cooling pood systesj reaches equilibrium
 there will bs an average dlschsrge of 10  cfs to  Cedar Creek.  Because the
 total dissolved solids (TSD)  psr.lt limitations  of 900 mg/1  sod 1100 mg/1
 are less than TSD concentrations fro» existing groundwater sources In the
 area, the dlschsrge  fro* the  pood Is  expected to have no effect on the
 potability or quantity of  groundwater.  No effects on the groundwater are
 anticipated due to the increase In itrees) tesiperatur .  The  time of flow
 from the pond dlschsrge to Cedar Creek to the Crate's mixing point with the
 Colorado River la not significant in  comparison  v

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THIUSTT
ttecimv* iiiieirrtHi
          Hi. Adlene Harrison
          Regional Adolnistrator  (6A)
          United States Environmental
            Protection Agency
          Region 6
          1201 Elm Street
          Dallas. Texas    75270

          Re:  E.I.S.: Fayette Powar Project,  Fayette
               County, Texas.  Proposed  issuanco of  new
               source NPOES Permit  for wastewater dis-
               charge. Lower Colorado River  Authority

          Dear Ms. Harrison:

          Thanl you for the opportunity  to examine this environmental  impact
          statement to assess the effects of the Fayette Power  Project  on
          cultural (prehistoric, historic, and architectural) resources in
          the area.  Harly consultations with  the Environnental  Stuff of the
          Lower Colorado River Authority revealed that  this  project would not
          be federally funded, assisted or permitted.   Accordingly, cultural
          resource investigations were perfomed under  State antiquities law
          and an antiquities permit.  Review of this case utiliiing the Procedure!
          (36 C.F.R., Part 800, as  amended)  reveals  that sites  which night have
          been determined eligible  for inclusion within the  National Register
          have been considered and  in various  fashions,  the  impact of the project
          on these resources mitigated.

          If I nay be of further service, please advise.

          Sincerely,

          Tniett Lat liner
          Stale Historic Preservation Officer

          By
            •^J	— — »   -V
          Alton K. Briggs
          Director
          Cultural Resource Management

          ACS/1 ft
                           JtitU .JVOfJir-u /v
ieapunse to Comments From the Texaa Historical Commission


     Ttie commenca  have  been  noted.   No response la required by USEPA.
                                                                                                                                                                                     Ol
                                                                                                                                                                                     Ol

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                                                                    FINAL 56
                               BIBLIOGRAPHY

     The following list presents the page changes in this section of the
Draft Environmental Impact Statement:

          Page 128
               129
               129a
               131
               131a

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                                                                    FINAL 57
                               BIBUOCRAi'HY
Adare, Joe.  1978.  Water analysis, Fayette Power Project, August 1977 -
     August 1978.  Memo, Joe Adare, LCRA, to Otto Kohler, LCRA, 6 September
     1978, 12 p.

B&R (Brown & Root, Inc.)-  1975.  Manpower projections and labor rates
     transmitted to TERA by Carol L. Copeland, 24 November 1975.

BPC (Bechtel Power Corporation).  1975.  Letter, BPC, to Lower Colorado
     River Authority, 14 September 1975.

BPC.  1974a.  Site selection study, oil/coal/lignite power plant.  45 p.

BPC.  1974b.  Fayette Power Project cooling reservoir thermal performance
     summary report.

Babcock, John E.  1975a.  Letter, John E. Babcock, LCRA, to David N. Peters,
     USEPA - Region VI, 28 August 1975, 3 p.

Babcock, John E.  1975b.  Letter, John Babcock, LCRA, to Dave Peters, USEPA -
     Region VI, 23 September 1975, 3 p.

Babcock, John E.  1978a.  Letter, John E. Babcock, LCRA, to Jerry Hitzemann,
     19 October 1978, 4 p.

Babcock, John E.  1978b.  Letter, John E. Babcock, LCRA, to Jerry Hitzemann,
     7 November 1978, 2 p.

Babcock, John E.  1978c.  Letter, John E. Babcock, LCRA, to Jerry Hitzemann,
     26 December 1978, 2 p.

Babcock, John E.  1979.  Letter, John E. Babcock, LCRA,  to Jerry Hitzemann,
     4 April 1979, 3 p.

Bishop, K. Don.  1979.  Letter, K. Don Bishop, Decker Coal Company, to
     Elof Sodenberg, LCRA, 20 March 1979.

Blair, W. F.  1950.  The biotic provinces of Texas.  Texas J. Sci. 2:93-117.

Carter, E. S. and C. S. Ragsdale  (Carter and Ragsdale).   1976.  Biegel settle-
     ment:  Historic sites research, Fayette Power Project, Fayette County,
     Texas.  Research Report No.  59, Texas Archaeological Survey, University
     of Texas at Austin.

Conant, R. 1975.  A field guide to reptiles and amphibians of eastern and
     central North America.  Houghton Mifflin, Boston MA.

Conference of Radiation Control Program Directors, Inc.   1978.  Natural
     radioactivity contamination  problems.  U.S. Environmental Protection
     Agency, Office of Radiation  Programs.  Washington,  D.C.
                                      128

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                                                                     FINAL 58
Davis, W. B. 1966.  The mammals of Texas.  TPWD Bull.  41.

Dibble, David.  1978.  By telephone, Dr. David Dibble, Texas Archaeological
     Survey, Austin, Texas, to Elizabeth Righter, 26 October 1978.

Elliott, Robert b.  1975.  Letter, Robert B.  Elliott, USEPA - Region VI,
     to John E. Babcodv, LCRA, 1 p.

FEA (Federal Energy Administration).  1974.  Project independence report.
     435 p.

Godfrey, C. L., G. McKee, and H. Oaks.  1973.  General soil map of Texas.
     Texas Agriculture Extension Service, College Station, TX, 1 p.

Gould, F. W.  1975.  Texas plants:  A checklist and ecological summary.
     MP-585/Revised.  Texas Agricultural Experiment Station, College Station,
     TX.

Harrison, Adlene.  1978.  Public notice of EPA intent to prepare an EIS on
     the Fayette Power Project, 27 July 1978.  3 p.

Hays, John R., Jr.  1978.  Memo, John R. Hays, Jr., Railroad Commission of
     Texas, Gas Utilities Division, to File, 3 October 1978.  2 p.

Holzworth, G. C.  1972.  Mixing heights, wind speeds, and potential for
     urban air pollution throughout the contiguous United States.  Prepared
     for USEPA, Office of Air Programs, Research Triangle Park, NC, 118 p.

Holzworth, G. C.  1974.  Meteorological episodes of slowest dilution in the
     contiguous United States.  U.S. Environmental Protection Agency, EPA-
     650/4-74-002.

Jackson, M. F. and D. W. Skelton.  1975.  Fayette Power Project, An interim
     report on the assessment of its impact on the cultural resources.
     Texas Archaeological Survey, University of Texas at Austin.

Jaspers.  1978.  By telephone, Ms. Jaspers, Winedale Inn Historical Complex,
     Winedale, Texas, to Elizabeth Righter, 2 November 1978.

Jensen, A. M.  1975.  Letter, A. M. Jensen, Bechtel Power Corp., Houston, to
     USEPA - Region VI, 1 p. and 2 maps.

Jones, J. K., Jr., D. C. Carter, and H. H. Genoways.  1973.  Checklist of
     North American mammals north of Mexico.  Occasional Paper No. 12.
     The Museum, Texas Tech. Univ., 14 p.

Korshover, J.  1976.  Climatology of stagnating anticyclones east of the
     Rocky Mountains, 1936-1975.  NOAA Technical Memorandum ERL ARI-55,
     U.S. Department of Commerce.

LCRA  (Lower Colorado River Authority).  1973a.  Environmental assessment of
     the Fayette Power Project, Volumes 1, 2, and 3.
                                     129

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                                                                       FINAL 59
  LCRA.  1978b.  Annual report 1978.  32 p.

  NSS  (National Soils Services, Inc.). 1975.  Foundation investigation of
       Fayette Power Project.

I  Narcavage, G. A.  1977.  Letter, G. A. Narcavage, Atlantic Richfield Company,
1       to Elof H. SoderbPrg, LCRA, 20 May 1977.

  OIS  (Office of Information Services).  1975.  Population projections for
       Texas counties from "POPPROJ" program.  Office of the Governor, Division
       of Planning Coordination.

  Oak  Ridge National Laboratory.  1977.  Environmental, health, and control
       aspects of coal conversion:  An information overview.  Volume 1.
       Prepared for Energy Research and Development Administration.

  Oberholser, H. C., E. B. Kincaid, and L. A. Fuertes.  The bird life of Texas.
       University of Texas Press, Austin, TX.
                                       129a

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                                                                    FINAL 60
Tilton, J. E.  1961.  Ichthyological  survey of  the Colorado  River of Texas.
     Master's thesis, Department of Biology, University of Texas, Austin TX.

Turner, D. B. 1970.  Workbook of atmospheric dispersion estimates.  US Depart-
     ment of Health, Education and Welfare, National Air Pollution Control
     Administration.

Tynan, Harold.  1978.  By telephone,  Harold Tynan, ERCOT, San Antonio, Texas,
     to Sheryl Alberga, 12 November 1978.

US Bureau of Census.  1970.  1970 census of population, Texas.

US Corps of Engineers, Galveston District.   1977.   Mouth of  Colorado  River,
     Texas final environmental statement.  Department of the Army, Galveston,
     Texas, 103 p.

US.Department of Commerce.  1973.  Climatological summary, climatography of
     the United States, No. 20-41, Sealy, Texas and Brenhara, Texas.

US Department of Energy.  1977.  1977 inventory of power plants in the United
     States.  Office of Utility Program Operations, Washington, D.C.

US Department of Housing and Urban Development.  1978.  Flood hazard boundary
     map, Fayette County, Texas.  Federal Insurance Administration, 14 sheets.

US Department of the Interior.  1978a.  Endangered species technical bulletin,
     Volume 3.

U.S. Department of the Interior.  1978b.  Final environmental statement on the
     Sierra Pacific Company proposed 500 MW coal-fired generating station,
     North Valmy, Nevada. Bureau of Land Management, Reno, Nevada.

US Department of Labor.  1974.  Occupational noise exposure standards, 29 CFR
     Part 1910.

US Environmental Protection Agency.  1973a.  Compilation of air pollutant
     emission factors, 2nd ed.  Washington DC.

US Environmental Protection Agency.  1973b.  Effects of sulfur oxides in the
     atmosphere on vegetation, revised chapter 5 for air quality criteria
     for sulfur oxides.  EPA R8-73-030.  Research Triangle Park NC.

US Environmental Protection Agency.  1973c.  Proposed water quality criteria.
     Washington, D.C.

US Environmental Protection Agency.  1974a.  Guidelines for air quality
     maintenance planning and analysis, Volume 10:  reviewing new stationary
     sources.  Washington, D.C.

US Environmental Protection Agency.  1974b.  Information on levels of environ-
     mental noise requisite to protect public health and welfare with an
     adequate margin of  safety, EPA 550/9-74-004.
                                    131

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                                                                     FINAL 61
US Environmental Protection Agency.  1975.  Background document for portable
     air compressors, EPA 550/9-76-004.

US Environmental Protection Agency.  1978.  Manual for evaluating secondary
     impacts of wastewater treatment facilities, EPA 600/5-78-003.

U.S. Nuclear Regulator:' Commission.  1977.  The environmental effects of
     using coal for generating electricity.  Washington, D.C.

Wilson, Robert L.  1978.  Letter, Robert L. Wilson, TERA Corp. to John
     Babcock, LCRA, Austin TX, 13 October 1978, 4 p.
                                     131a

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                                                                  FINAL 62
                                 APPENDIX A
                                NPDES PERMIT

      The New Source NPDES Permit as proposed by USEPA remains the same as
in the Draft EIS ~ith the exception of page A-14.  A Section III.L.  has been
added as a condition to the permit regarding cultural resources along the
proposed transmission line routes.  The entire permit as presently proposed
                                                                   \
is attached.
                                    A-l

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                                                                         FINAL 63
                                                             Permit No  TX0073121
                                                             Application No. TXC073121
                   AUTHORIZATION TO DISCHARGE UNDER THE
            NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM


   In compliance with the provisions of the Federal Water Pollution Control Act, as amended,
(33 U.S.C. 1251 et. seq; the "Act"),

                           Lower Colorado River Authority
                           P. 0. Box  220
                           Austin, Texas  78767
is authorized to discharge from a facility located at
to receiving waters named
                           Fayette  Power Project
                           La Grange,  Fayette County,  Texas
                           Cedar Creek,  thence into  the
                           Colorado  River Basin
in accordance with effluent limitations, monitoring requirement* and other conditions set forth
in Part* I, II, and III hereof.

   This permit shall become effective on

   This permit aid the authorization to discharge shall expire at midnight,
Signed this 21st day of  February 1979
  Howard G. Bergman
  Director
  Enforcement Division (6AE)
Perm 33:<5-.< '',0-731

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A- 1 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

     During the period beginning  effective date    and lasting through  expiration  date
     the permittee is authorized to discharge from outfall(s) serial number(s)   001 reservoir blowdown.
     Such discharges shaM be limited and monitored by the permittee as sjx.-cified below:

     Kffluent Characteristic                       Discharge Limitations
                                                       Monitoring Requirements
                                   kg/day (Ibs/day)            Other Units (Speci'v)
                                                                                      Measurement      Sample
                               Daily Avg      Daily Max     Daily Avg      Daily Max     Frequency        Type
      Flovr-m3/Day(MGD)
      Temperature,  degrees
N/A
N/A
N/A           (*)           (*)        Continuous      Record
N/A      *oC(0F)***   35.0°C(95°F)** Continuous      Record
      *    Report
      **   Instantaneous Maximum
      ***  See  Part III, Paragraph C.
     The pH shall not be less than "• 0   standard units nor greater than  9.0   standard units and shall be monitored
      I/week by  grab sample.

     There shall be no discharge of floating solids or visible foam in other than trace amounts.
                                                                                         3)
                                                                                                                     ro
     Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):       —i
      At Outfall  001  where  Cedar Creek  reservoir  discharges  from a  9  foot diameter conduit  to Cedar Creek.g-
                                                                                                                   o
                                                                                                                   CO
                                                                                                                   -'•
                                                                                                                   ro
                                                                                               J>

                                                                                               CT!

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A-  2 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
      During the period beginning   effective date   and lasting through expiration date
      the permittee is authorized to discharge from outfaJI(s) serial number(s) 101 ,  recirculatlnq codling water.
     Such discharges shall be limited and monitored by the permittee as specified below:
      Effluent Giamcteristic
      ROB—m3/Dcy (MGD)
      Temperature, degrees
      Free  Available
        Chlorine**
               Dbchara Limitations
                                         Monitoring Requirements
                                   kg/day (Iba/day)
                             Olncr Units (Specify)
fairy Avg
N/A
N/A
Daily Max
N/A
N/A
Daily Avg
(*)
C(*F)
Daily Max
(*)
C(*F)
Measurement
Frequency
I/day
I/day
Sample
Type
Calculated
In Situ
N/A
N/A
0.2  mg/1      0.5  mg/i  I/week***
Grab
        *   Report
       **   See Part  III
      ***   Samples shall  be representative of  periods of chlorination.
      The pH shall not be less than  N/A  standard units nor greater than  N/A  standard units and shall be monitored  N/A.


      There shell be no discharge of floating solkls or visible foam in other than trace amounts.

      Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
      At Outfall 101  where ree1rcu1atincf00^n9 water discharges from  the canal  into
      Cedar Creek Reservoir.
                                                                     •w -o
                                                                     O  ft*

                                                                     3  "

                                                                     .j, OJ
                                                                     o
                                                                                   X
                                                                                   o
                                                                                   o
                                                                                         -O
                                                                                         >
                                                                                         31
                                                                                                                              01
                                                                                                                              cri

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A   3    EFf'LUENT LIMITATIONS AND MONITORING REQUIREMENTS
        Durini', the period beginning effective date     and lasting through  expiration  date
        the permittee is aiithori/cd to discharge from outfall's) serial nii:r.bcr(s) Q02 low-volume wastewater. **
        Such discharges shall be limited and monitored by the permittee as specified below:

        Effluent Oir.Mctpristic                       Discharge Limitations
                                         Monitoring Requirements
                                      kg/day (Ibs/drw)            OUv-r Unite (Specify)
                                                                                         Measurement     Sample
                                  Daily Avg      Daily Max      Daily Avg      Daily Max      Frequency       Type
        Flow-m3/Day (MGD)        N/A
        Total  Suspended  Solids   N/A
        Oil  and Grease            N/A
N/A
N/A
N/A
(*)           N/A          I/day
30 mg/1       100  mg/1    I/week
15 mg/1        20  mg/1    I/week
Estimate
Grab
Grab
        *    Report
        **   See Part  III  ,  Paragraph  F.
        The pH shall not be less than  6.0   standard units nor greater than 9. Q
        I/week  by grab sample.
                        standard units and shall be monitored
        There shall be no discharge of floating solids or visible foam in other than trace amounts.

        Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
        At Outfall  002 where low volume  wastewater is discharged from  the low volume waste  treatment
        facility prior to mixing with any other waste stream.
                                                                    V.
                                                                    o
                                                                    X
                                                                    o
                                                                    o
                                                                                CTl
                                                                                CTl

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EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

I Hiring the period banning effective date    and lasting through expiration date
llvr |xrmi»tco is aulhori/.f-d to discharge from oulfall(s) serial nurnbcr(s)  003 area  runoff water.**

Stit:h rlisr|\;ir(.'t.r. shall ho limited am! monitored by the permittee as specified below:

Effluent Oiainctcrislic                       Dischr.rjje Limitations                      Monitoring Requirements
          	                 kg/day (Ibs/day)"OlhtTr Units (Specify)
                                                                                Measurement     SDm))le
                          Daily AVR      Daily M.ix      Daily Av;;      Daily Max      Frequent y       'J'ypi1

Flov—m^/Day (MGD)        N/A           N/A          (*)            N/A       I/occurrence*** Estimate
Total  Suspended Solids   N/A           N/A          10 "'9/1        50  mg/1   1/occurrcnce*** Grab
*     Report
**    See Part III  , Paragraph G.
***   Samples shall  be taken once during  each occurrence or once  every 24 hours if duration of  occurrence
      is  greater  than  24 hours.
The p!I shall not be less than  6.0   standard units nor greater than   9.0 standard units and shall be monitored
I/occurrence*** by  grab sample.

There shall be no discharge of floating solids or visible foam in other than trnce amounts.

Samples Liken in compliance with the monitoring requirements specified above shall be taken at the following lornt.ion(s):
At Outfall 003 where area  runoff water is discharged  from the coal storage runoff retention
pond  prior to mixing with  any  other woste stream and  prior to entry  to Cedar  Creek.

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                                                                           FINAL 68
                                                                   PARTI
                                                                       6   of     14
                                                                   PermiiNo. TX0073121
B. SCHEDULE OF COMPLIANCE
    1.  The  permittee  shall achieve compliance  with  the effluent limitations specified for
       discharges in accordance with the foilow-ing schedule:
                                                              i
        None
    2.  No later than 14  calendar days following a date identified in the above schedule of
       compliance, the permittee  shall  sub.-nit either a report of proznrx or, in the case of
       specific actions being required by identified dates, a written notice of compliance or
       noncompliance. In the hltsr case, the notice shall include the cause of noncompliance,
       any  remedial  actions  taken,  and  the  probability  of meeting  the  next  scheduled
       requirement.

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                                                                             FINAL  69


                                                                   PART I

                                                                        7         14
                                                                   Rape  '   "!
                                                                   Pcrm-.N,, TX0073121
C.  MC;.STORING AND REPORTING

    1.  F.epnsenta.' -i-e Stripling

       Samples and msasuremonts tnl'.rn as required herein shaJl be- representative of the volume
       and nature of th-2 monitored disch?j£s. '

    2.  ncporting

       Monitoring rtsulti  obtoinad durir? the previous  ]p   months shall  he summarized for
       CECh month and imported on a Discharge  ''.fynitonng  Report Form  (EPA No. 3320-1),
       postmarked no later than the 2Sth day of  the month following the completed reporting
       psri'jd. The  first report is  due on  June  23,  1930       . Duplicate signed copies of
       these,  and a!!  other  reports required h?zcin,  shall  be  submit led  to the  Regional
       Administrator and the State at the following addresses:

       Mr. Hov;ard  G.  Peroir.an, Director             Mr. Harvey D.  Davis
       Enforcement  Division                          Executive Director
       Environmental  Protection Agency  .  ..       Texas Department  of  Water Resources
       First  International  Building                 P.  0. Box  13087
       1201 Elm Street                                Capitol  Station
       Dallas,  Texas   75270                          Austin,  Texas  78711

    3.  Definitions

       a.  The "daily aversce." discharge means the total discharge by weight during a calendar
          month  divir-ed  by  th2 number  of days in the  rnur.th  1hat the production or
          ccmmercirJ i':>.cility '^as or-siatinc. Where lo:s than daiiv samplint; is required by this
          permit, the diily avers--;" discharge shall bo dote;mined by .he summation of all  the
          mu^-jred diJiy  dischaj.-'.'s by weight  divided  l:y the number of  days  during  the
          calendar mon:h wh?r> the mc-asurements were made.

       b.  The "daily rrajtimurr." discharce  meaj;;; the  total dicrhurge by  weight during ar,y
          calendar day.

    4.  Test Procedures

       Test  procedures  for  the analyus  of  pollutants shall conform to regulations published
       pursuant to Section 304(s;) of  the Act, under which such procedures may be required.

    5.  Recording of Kf.-uUs

       For each merj--.!'t:rr.ent or sa~.pl? t<"!:en purr.uar.t to the rcquire-r.ients of this permit,  the
       permittee «h.r\l' rt  .-oio li-.e follo'.^nc :nformc.t.ion:

       a.  The exact }:i.".c?, dsto. artel  ti'v.e of sampling;

       b.  The dates the- analyses WC-.T i-prforrned:

       c.  The personfs) who p'.Tforrr.id tile ?.nalyr-:'s;

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                                                                               FINAL  70
                                                                 PART I
                                                                 Pja-   8  '"
                                                                 Pcrmn No  TX0073121
   d.  The analytical tecnniques or methods used; and

   e.  The results -.' all required analyses.

6. Additional Monitoring by Permittee

   If  the  permittee monitors  any  pollutant at  the  location^  designated  herein  more
   frequently than  required by this permit, using approved analytical methods as specified
   above, the results of such monitoring shall  be included in the calculation and reporting of
   the values required  in the Discharge Monitoring Report Form (EPA No. 3320-1). Such
   increased frequency  shall also be indicated.

7. Records Retention

   All records and information resulting from  th.?  monitoring activities required  by this
   permit  including aJl records of analyses performed and caJibraiion and maintenance of
   instrumentation  and recordings  from continuous monitoring instrumentation shall be
   retained for a  minimum of three  (3) yc^rs,  or  longer  if  requested by the Regional
   Administrator or the State water pollution  control  agency.

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                                                                        PAP.TI!
                                                                                  FINAL 71
                                                                        Permit No.  TX0073"l2"i
A.  V
    1.  C .-.-.. 5V'
        Ail ciiichBrcea autnrmed he.tin .-hall be consistent ••••ilh the terras and conditions of this
        permit. The uischi1-;::- c: any pc.!j'.':-'.t ic!?ntifi°d in this p?imit more frequently than or
        at a level in  excess o; that author, /.ed shall  constitute  a violation of the permit. Any
        anticipated facility expansions, production i-icrPuses. or proct:j modifications \vhich will
        result  in  now,  different, or  incroased  dischcjres  of  pollutants  must he reported  by
        submission of a nc-.v NPDES application or, if such changes will not violate the effluent
        limitations specified in  this permit, by  not.ice  to the  permit issuing authority of such
        chan(-;pi.  Followinc  surh r.orice, tho permit may be modified to specify and limit any
        pollutants not previously limited.

    2.   .iVoncomp.'r'aice Notification

        If, for any r?--.m. IMC permittee does  not comply vith or will be  unable to comply with
        any  rlsiiy  rm:c;rr.un  effluent  limitation specified in  this  perr/.it, the permittee  sh:*ll
        pro\ndo  tho  Hrpor.J Adininistrrtor  and  the Sftp with the followng information,  in
        writinf.!. within five (5) dcys of b?comn£ av/are of such  condition:

        a.  A description of the discharge and cause of ncnccr.ipliance; and

        b.  The  period of r.v.ii-ornpliance, including exact dates end times; or, if not corrected,
           tho anticipatc-d  tir.-.o the  noncompiiance is e/;;?cted! to continue, and steps b?irig
           taken to reduce, '.-liininaie and prevent recurrence of the noncomplying discharge.

    3.   Facilities Operation

        The permittee shrJl  at all times ir.r.intain in ?ooc! v.-orkinr; order and operite as  efficiently
        as po.'siMe all treat nr.'nt or control  ;'r.cilitir-3 or «y:::-:r:c installed or used by the permittee
        to achieve cnmpliAr.c? with the terns and ror.citiro.s of this permit.

    4.   Adi:t>r*c Impact

        The permittee shaJ1  tx'.':p  aJi  rc£rn.i"bi2 su-p? to rnin'-^.iro ^ny at!vc?se impact to navisnible
        waters  i!':u!t.irij:  fie.1.  noncom-:.;'. •-;-.- c  v.-ith  ar.y ci..lv.-:-nt iir/.itstions specif'od  in this
        permit, including suwii acceierM.:-o cr ^ddivion^i monitoring as necessary to determine the
        nature and impact of '.he r.oncojrpiying dir
Any  diver;; :r n f'^
term? and cc-ci:' :•.-
loss  of  life or ro.
would da;r.;-uO ar.y
[••roh-.h: i !:•::«  of   I
Admin:. ;.Mtor and
                            .-•: h;-r\-,<,s of 'ai-'iliti^s nee-- :.;:rv to mnjr.tain  cornpli?.r!ce  v,-ith the
                            •;:' iu.s pfi'niit ,-. prr-!-.;:;U'id. o/.:.: : {;) v,-h£ie unavoidable to prevent
                            - r.'oprrry di-n:::-:-?, or ,'i:> '.\irrt! -3x?::;ive .storm crxnr/je or runot'f
                                      -vf •'.">• f-'i rc'mr-'li.-.r'.v  \-itii th? pfflac-nt limitations ^nd
                                     .  T •    ;i1-:-'.iit:' ••'  s;:r.'.'.  p?^>^7::;y  notif;'  t!>e  RvTiopaJ
                                      ur:i:;;: c-i  eicli fuch  •^.voriipn cr bypr>ss.

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                                                                              FINAL  72
                                                                    PART 11
                                                                    Past  10  of      .14
                                                                    F,mit No. TXOC73121
   6.  Removed Substances
       Solids, sludges, fiiU.r backlash, or other pollutants removed in the course of treatment or
       control of wcstevraten shall be cbposed of in a manner such as to prevent any pollutant
       from such rr.atcrialo from enu-hng navigable waters.

   7.  Power Failures

       In order to  maintain comphcr.ee with  the effluent limitations and prohibitions of this
       permit, the permittee thail cither:

       a.  In  accordance with the Schedule  of Compliance  contained in Part  I, provide an
          alternative power source sufficient to operate the waatevvater control facilities;

       or, if such alternative power source is not in existence, and no date for its implementation
       appears in Part I,

       b. Halt,  reduce  or  other.vise  control production  and/or  all  discharges upon the
          reduction, loss, or failure of  the  primary  source of power to the waste-water control
          facilities.
B.  RESPONSIBILITIES

    1.  Right of Entry

       The  permittee  shall allow the head  of the State  watr.-r pollution .control  agency,  the
       Regional Administrator, and /or their authorized representatives, upon the presentation of
       credentials:

       a. To  enter upon the permittee's premiros where an  effluent source is located or in
          which any  records are required to  be kept  under the terms and conditions  of this
          permit; and
       b.  At rcasonpb'.e times to h.-.ve acce^ to end copy any records required to be kept under
           ths terms and conditions 01' this ufrr.iit: to inspect any monitoring equipment or
           monitoring method requ.'tt-d in this permit; nnd to sample any discharge of pollutants.

    2.  Transfer of Ownership or Control

       In the event of r.ny chan<>r pollution cor.rrol r^cncy.

    3.  Availability  o/' /C^-piprt*

       Except for dr.r.3  r>i?mincd to be confidential ur.dpr Section 308 of the Act, all reports
       prepared in p.ccorjancc with  the terms of this permit shall  be  available for public

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                                                                              FINAL 73
                                                                 PART II


                                                                 Page  11  of   14
                                                                 Pennlt.Vo.  TX007312T
    inspection at the G^iic^s ;A l!.2 I';^.t wsiir rxOiutlon  conu-ol c-r-n<:y ^Q tne Regional
    Adinir.istrjtt.r. AJ r?ruired U? u-:e Act, feifluent dr.ta shall not be considered confidential.
    Knowingly ciaiw,-^ f.ny i_iss sui^^cr.t on any such rjpcrt may result in the imposition of
    criminal penalties aa provided for in Section 303 oi i'r.s Act.

4.  Permit Modification

    After notice and opportunity for a hearing, this permit may be modified, suspended, or
    revoked in \7hole or in part during its term  for cause including, but not limited to,  the
    following:

    a.  Violation of any terms or conditions of this permit;

    b.  Obtaining this permit by misrepresentation or failure to disclose fully all relevant
       facts; or

    c.  A change in any condition that requires either a temporary or permanent reduction or
       elimination of the authorized discharge.

5.  Toxic Pollutantt

    Notwithstanding Part II, B-4 above, if a  toxic effluent standard or prohibition (including
    any  schedule of compliance specified  in  such effluent standard  cr  prohibition) is
    ostablbhtxl un-23? £?cticn 307(a) of the Act  for a toxic pollutant which  is present in  the
    dbcharje end such standard or  prohibition is more ctiinf^nt than any limitation for such
    pollutant in this penr.it, this permit 'hail be  revised  or modified in accordance with  the
    toxic effluent standard or prohibition  and the permittee so notified.

6.  Civil and Criminal Liebility

    Except  as  provided  in permit  conditions on  "Bypicsing" (Part II, A-5) and "Power
    Failures" (Pert II, A-7), nothing in this permit shall be construea to relieve the permittee
    from civil or crimind ponaliies for noncompliance.

7.  Oil and Hazardous Subttance Lisbiliiy

    Nothing in this permit shrill be construed  to preclude  the institution of any legal action or
    relieve  the  permittee  u'r>in any  responsibilities, liabilities,  or  penalties to which  the
    permittee is or may be subject under Section 311 of the Act.

8.  State Laws

    Nothing ir this permit «'i"il be construed  to preclude  the ir.iJiution of any lejial action or
    relieve the permittoe from any responsibilities, liabilities, or penalties established pursuant
    to any appiicabie St^'c? i?.w or rrraiU-.ticn i;ncior autlicnty proser/cd by Section 510 of  the
    Act.

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                                                                        FINAL 74
                                                              PART II
                                                              Page 12   of  14.
                                                              Permit No.  TX0073121
     9.  Property Rights
        The issuance of thb permit doss not convey any propsrty ri^hta in either real or personal
        property, or any exclusive privileges, nor does it authorize any injury to private property
        or any invasion of personal rights, ncr any infringement of Federal, State or local laws or
        regulations.

     10. Severabitity

        The provisions of this permit are se/era'ole, and if any provision of this permit, or the
        application of any provieicn  of thir permit to  any circumstance, is held invalid, the
        application of such provision  to other circumstances, and the remainder of this permit,
        shall not be affected thereby.
                                     PART III


  OTHER REQUIREMENTS

A-   There shall be no  discharge of pclychlorinated biphenyl transformer
     fluid.

B-   The  "daily average"  concentration means  the  arithmetic average  (weighted
     by flow value) of  all  the daily determinations of concentration  made during
     a calendar month.  Daily determinations  of concentration made using a
     composite sar.-ple shall  be the concentration  of the composite sample.
     When grab samples  are  used, the daily  determination of concentration shall
     be the  arithmetic  average (weighted by flow  value) of all the samples
     collected during that  ca'iendar day.
                                                        *
C-   The  "daily maximum"  concentration means  the  daily determination  of
     concentration for  any  calendar dcy.

^"   Daily average temperature is defined as  the  flow weighted average
     temperature (F.-;AT) end  shall be computed  and recorded on a daily basis.
     FWAT shall be computed  at equal tir.e intervals nor greater than  two hours.
     The  method of calculating FWAT is as follows:

      FWAT   -  SUMf'ATION (INSTANTANEOUS FLO'.-.'  X  INSTANTANEOUS TEMPERATURE)
                             SlKiATION u-NSTAfiTANEOUS
     The term "ash transport water" shall mean  water used in the  transport
   •  of either fly ash  or  ootto.n ash.

     There shall b? r.o  discharge of "ash transport water".

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                                                                     FINAL 75
                                                              Page 13 of 14
                                                              Perm-it No. TX0073121
Ctlvr Requirements (Continued)

E.  The term "metal cleaning wastes" shall  mean any cleaning compounds,  rinse
    waters, or other waterborne residues derived from cleaning and metal process
    equipment including, but not limited to, boiler tube cleaning, boiler fire-
    side cleaning and air preheater cleaning.

    There shall be no discharge of "metal cleaning wastes".

    "Metal cleaning wastes", water treatment wastes, demineralizer wastes,  and
    boiler lowdown shall be routed into.the closed cycle ash handling system.

F.  The term "low-volume waste sources" means, wastewaters from,  but not limited
    to:  wet scrubber air pollution control systems, ion exchange water  treatment
    system, water treatment, evaporator blowdown, loboratory and  sampling streams,
    floor drainage, cooling tower basin cleaning wastes and  blowdown from recir-
    culating house service water systems.

G.  The term "area runoff" means discharges resulting from material  storage  runoff
    and construction runoff.

    The term "material  storage runoff" means the rainfall  runoff  from or through
    any coal, ash or other material storage pile.

    The term "construction runoff" means the rainfall runoff from any construc-
    tion activity and any earth surface disturbed by such activity from  the
    inception of construction until construction is complete and  any disturbed
    earth is returned to a vegetative or other cover commensurate with the
    intended land use.

    Any untreated overflow from facilities  designed, constructed  and operated
    to treat the volume of "material  storage runoff" and "construction runoff"
    which is associated with a 10.year, 24  hour rainfall event shall  not be  subject
    to the limitations  specified in Part 1, area runoff, of  this  oermit.

    The term "10 year,  24 hour rainfall event" shall mean a  rainfall  event with
    a probable recurrence interval  of once  in ten years as defined by the
    National Weather Service in Technical Paper No. 40, "Rainfall  Frequency
    Atlas of the United States,"; May 1961,  and subsequent amendments, or equiva-
    lent regional or state rainfall probability information  developed therefrom.

H.  The applicant's makeup water intake structure, located on the Colorado River,
    meets the requirements of Section 316(b) of the Clean Water Act and  is hereby
    approved.

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Other Requirements (Continued)                                    Permit No.  TX0072"21

I.  The permit shall  be modified, or alternatively, revoked and reissued, to
    comply with any applicable effluent standard or limitation issued or approved
    under sections 301 (b)(2)(C), and (D), 304(b)(2), and 307(a)(2) of the Clean
    Water Act, if the effluent standard or limitation so issued or approved:

         (1)  Contains  different conditions or is otherwise more stringent
              than any effluent limitation in the permit; or

         (2)  Controls  any pollutant not limited in the permit.

    The permit as modified or reissued under this paragraph shall  also contain
    any other requirements of the Act then applicable.

J.  The term "free available chlorine" shall mean the value obtained using the
    amperometric titration method for free available chlorine described in
    "Standard Methods for the Examination of Water and Wastewater", page 112
    (13th edition).

    Neither free available chlorine nor total residual chlorine may be discharged
    from any unit for more than two hours in any one day and not more than one
    unit in any plant may discharge free available or total residual chlorine at
    any one time unless 1) the permittee can demonstrate to the permitting Agency
    that the units in e particular location cannot operate at or below the limi-
    tations specified in this permit, or 2) such discharge is part of an approved
    chlorine minimization program.

K.  The permittee shall submit, for EPA approval, a study plan to demonstrate the
    minimum level of chlorination required to prevent biofouling of the condenser
    tubes.  This study shall consider seasonal temperature differences, variations
    in chlorine concentrations and time of chlorination, and predicted water  qual-
    ity changes.  It shall be designed to be conducted for at least one calendar
    year following operation of each unit at greater than 5% of rated thermal power.
    The study plan shall be submitted within 90 days of the effective date of this
    permit.  Results of the study shall be submitted within 18 months of the  operation
    at greater than 5>-  of rated thermal power.  Chlorine concentrations determined
    by this study may be used for modification of chlorine limitations.

L.  National Environmental  Policy Act (NEPA) Condition:   An  on-the-ground  cultural
    resource survey of  the transnission line routes  shall  be undertaken by a quali-
    fied archaeologist  prior to any line construction  by LCRA.   LCRA  shall provide
    the results of the  survey including any recommendations  as  to  National Register
    eligibility to the  Texas State Historic Preservation Officer and  EPA.  EPA in
    coordination with the Texas State Historic Preservation  Officer  shall  follow
    the procedures of the Advisory Council  on Historic Preservation  (36 CFR Part
    800) to determine the effect of transmission  lire  construction on cultural
    properties.  Line construction shall  not cor.nence  until  a detemi nation is race
    and appropriate mitigntion procedures (if necessary) are agreed  to  by  all
    parties (EPA, Texas State Historic Preservation  Officer,  Advisory Council
    on Historic Preservation and LCRA).

    If cultural resources are identified during construction, work shall be halted
    and the Texas State Historic Preservation Officer  and EPA shall  be  notified.
    The procedures described above shall  then be  followed.

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                                                                    FINAL 77
                                 APPENDIX B
                           BIOLOGY SUPPORTING DATA

      This sections remains unchanged from the Draft Environmental Impact
Statement.

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