ML13304B627

Forwards Draft ETS - Environ Protection Plan (Nonradiological) for Review & Comment

ML13304B627
Person / Time
Site:	San Onofre
Issue date:	03/27/1981
From:	Scaletti D Office of Nuclear Reactor Regulation
To:	Burtman L State of CA, San Diego Region Water Quality Control Board
References
NUDOCS 8104080035
Download: ML13304B627 (15)

Text

o-4 Mr. Leonard Burtman APR0 6 1 Executive Officer fh 0 981ob California Regional Water Quality Control Board San Diego Region 6154 Mission Gorge Road Suite 205 San Diego, California 92120

SUBJECT:

DRAFT APPENDIX B NON-RADIOLOGICAL ENVIRONMENTAL PROTECTION PLAN FOR SAN ONOFRE NUCLEAR GENERATING STATION UNIT 2 Enclosed for your review and comment is a draft of the Environmental Protection Plan (EPP) for the San Onofre Nuclear Generating Station Unit 2. The EPP when final will constitute Appendix B to the San Onofre operating license upon issuance.

The EPP, as drafted, addresses our NEPA responsibilities while relying on the NPDES permit issued by your office.

If there are any questions regarding the draft EPP please contact me on (301)492-8443.

Sincerely, Dino Scaletti, Project Manager Licensing Branch #3 Division of Licensing DISTRIBUTION:

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 MAR 2 7 1981 Mr. Leonard Burtman Executive Officer California Regional Water Quality Control Board San Diego Region 6154 Mission Gorge Road Suite 205 San Diego, California 92120

SUBJECT:

DRAFT APPENDIX B NON-RADIOLOGICAL ENVIRONMENTAL PROTECTION PLAN FOR SAN ONOFRE NUCLEAR GENERATING STATION UNIT 2 Enclosed for your review and comment is a draft of the Environmental Protection Plan (EPP) for the San Onofre Nuclear Generating Station Unit 2. The EPP when final will constitute Appendix B to the San Onofre operating license upon issuance.

The EPP, as drafted, addresses our NEPA responsibilities while relying on the NPDES permit issued by your office.

If there are any questions regarding the draft EPP please contact me on (301)492-8443.

Sincerely, Dino Scaletti, Project Manager Licensing Branch #3 Division of Licensing

MAR 2 7 19891 APPENDIX B TO FACILITY LICENSE NO FOR SAN ONOFRE NUCLEAR GENERATING STATION UNIT -2 SOUTHERN CALIFORNIA EDISON COMPANY AND SAN DIEGO GAS AND ELECTRIC COMPANY DOCKET NOS. 50-361 AND 50-362 ENVIRONMENTAL PROTECTION PLAN

SAN ONOFRE NUCLEAR GENERATING STATION UNIT 2 ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL)

TABLE OF CONTENTS Section Page 1.0 Objectives of the Environmental Protection Plan.......

1-1 2.0 Environmental Protection Issues.....

2-1 2.1 Aquatic Issues....

2-1 2.2 Terrestrial Issues... *.*

2-2 3.0 Consistency Requirements.*...*.................... 3-1 3.1 Plant Design and Operation.......

3-1 3.2 Reporting Related to the NPOES Permits and State Certification.

3-2 3.3 Changes Required for Compliance with Other Environmental Regulations...........

3-3 4.0 Environmental Conditions.........

4-1 4.1 Unusual or Important Environmental Events.

4-1 4.2 Environmental Monitoring.......

4-1 5.0 Administrative Procedures.....

5.1 Review and Audit * * *. *.

5-1 5.2 Records Retention.................... *...

5-1 5.3 Changes in Environmental Protection Plan 5-2 5.4 Plant Reporting Requirements.....

1.0 Objectives of the Environmental Protection Plan The Environmental Protection Plan (EPP) is to provide for protection of environ mental values during construction and operation of the nuclear facility.

The principal objectives of the EPP are as follows:

(1)

Verify that the plant is operated in an environmentally acceptable manner, as established by the FES and other NRC environmental impact assessments.

(2) Coordinate NRC requirements and maintain consistency with other Federal, State and local requirements for environmental protection.

(3) Keep NRC informed of the environmental effects of facility construction and operation and of actions taken to control those effects.

Environmental concerns identified in the FES which relate to water quality matters are regulated by way of the licensee's NPDES permit.

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0 Environmental Protection Issues In the FES-OL dated April 1981, the staff has considered the environrmenal impacts associated with the operation of the San Onofre Nuclear Generating Station. Certain environmental issues were identified which required study or license conditions to resolve environmental concerns and to assure adequate protection of the environment.

2.1 Aquatic Issues

1. The need for aquatic monitoring programs to ensure protection of the San Onofre kelp bed (FES-OL, Sections 5.4.2.1 and 6.3.5).

2. The need for continuation of the ichthyoplankton study until such time as it is possible to state credibly that no significant impacts result from the facility (FES-OL, Section 6.3.5).

3.

The need for a plankton entrainment mortality study to comply with Section 316(b) of the Clean Water Act.

(FES-OL, Section 6.3.5).

4. The need for a program to assess the effectiveness of the fish return system (FES-OL, Section 6.3.5).

Aquatic issues are to be addressed by the effluent limitations, monitoring requirements and demonstration studies contained in the effective NPOES permit issued by the California Regional Water Quality Control Board-San Diego Region.

The NRC will rely on that agency for regulation of matters involving water

.quality and aquatic biota.

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2.2 Terrestrial Issues (1) The need to protect the bluff area located to the south of the plant for the duration of the site easement (FES-OL, Section 6.3.2).

The California Coastal Zone Conservation Commission has recognized the need for erosion control and stablization of the area in issuing a permit authorizing the construction of Unit 2 and 3.. Permanent protection of the area is provided for the duration of the plant (expiration date: May 1, 2023). Permit No.

183-73, issued February 24, 1974, deals, inter alia, with terrestrial aspects of monitoring and enforcement. Compliance will be monitored and enforced by the State Commission (or other State body). The NRC will rely on the State with regard to this matter.

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3.0 Consistency Requirements 3.1 Plant Design and Operation The licensee may make changes in station design or operation or perform tests or experiments affecting the environment provided such changes, tests or experiments do not involve an unreviewed environmental question, and do not.

involve a change in.the Environmental Protection Plan.* Changes in plant design or operation or performance of tests or experiments which do not affect the environment are not subject to the requirements of this EPP. Activities governed by Section 3.3 are not subject to the requirements of this section.

Before engaging in additional construction or operational activities which may affect the environment, the licensee shall prepare and record an environmental evaluation of such activity. When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shall provide a written evaluation of such activities and obtain prior approval from the Director, Office of Nuclear Reactor Regulation. When such activity involves a change in the Environmental Protection Plan, such activity and change to the Environmental Protection Plan may be implemented only in accordance with an appropriate license amendment as set forth in Section 5.3.

A proposed change, test or experiment shall be deemed to involve an unreviewed environmental question if it concerns (1) a matter which may result in a significant increase in any adverse environmental impact previously evaluated in the final environmental statement (FES) as modified by staff's testimony to the Atomic Safety and Licensing Board, supplements to the FES, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing

• This provision coes not relieve the licensee of the requirements of 10 CFR O50.

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Board; or (2) a significant change in effluents or power level [in accordance with 10 CFR Part 51.5(b)(2)] or (3) a matter not previously reviewed and evaluated in the documents specified in (1) of this Subsection, which mil ave a significant adverse environmental impact..

The licensee shall maintain records of changes in facility design or operation and of tests and experiments carried out pursuant to this Subsection. These records shall include a written evaluation which provide bases for the deter mination that the change, test, or experiment does not involve an unreviewed environmental question nor constitute a decrease in the effectiveness of this EPP to meet the objectives specified in Section 1.0. The licensee shall include as part of his Annual Environmental Operating Report (per Subsec tion 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.

3.2 Reporting Related to the NPOES Permits and State Certifications*

Violations of the NPOES Permit or the State certification (pursuant to Section 401 of the Clean Water Act) shall be reported to the NRC by submittal of copies of the reports required by the NPDES Permit or certification. The licensee shall also provide the NRC with copies of the results of the following studies at the same time they are submitted to the permitting agency:

i) Section 316(b) Demonstration Study ii) Chlorine Minimization Study 3-2

Changes and additions to the NPOES Permit or the State certifica isok I be reported to the NRC within 30 days following.the date the change is approved.

It a permit or certification, in part or in its entirety, is appealad stayed, the NRC shall be notified within 30.days following the date the stay is granted.

The NRC shall be notified of changes to the effective NPDES Permit proposed by the licensee by providing NRC with a copy of the proposed change at the same time it is submitted to the permitting agency. The notification of a licensee initiated change shall include a copy of the requested revision submitted to the permitting agency. The licensee shall provide the NRC a copy of the application for renewal of the NPOES.permit at the same time the application is submitted to the permitting agency.

3.3 Changes Required for Compliance with Other Environmental Regulations Changes in plant design or operation and performance of tests or experiments which are required to achieve compliance with other Federal, State, or local environmental regulations are not subject to the.requirements of Section 3.1.

'4.0 Environmental Conditions 4.1 Unusual or Important Environmental Events Any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to plant operation shall be recorded and promptly reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone, -

telegraph, or facsimile transmissions followed by a written report per Subsection 5.4.2. The following are examples:

excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or unusual occurrence of any species protected by the Endangered Species Act of 1973, fish kills, increase in nuisance organisms or conditions and unanticipated or emergency discharge of waste water or chemical substances.

No routine monitoring programs are required to implement this condition.

4.2 Environmental Monitoring None required at the present time.

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5. 0 Administrative Procedures 5.1 Review and Audit The licensee shall provide for review and audit of compliance with the Environ mental Protection Plan. The audits shall be conducted independently of the individual or groups responsible for performing the specific activity. A -

description of the organization structure utilized to achieve the independent review and audit function and results of the audit activities shall be maintained and made available for inspection.

5.2 Records Retention Records and logs relative to the environmental aspects of plant operation shall be made and retained in a manner convenient for review and inspection.

These records and logs shall be made available to NRC on request.

Records of modifications to plant structures, systems and components determined to potentially affect the continued protection of the environment shall be retained for the life of the plant. All other records, data and logs relating to this EPP shall be retained for five years or, where applicable, in accordance with the requirements of other agencies.

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5.3 Changes in Environmental Protection Plan Request for change in the Environmental Protection Plan shall include ;n assessment of the environmental impact of the proposed change and a supporting justification. Implementation of such changes in the EPP shall not commence prior to NRC approval of the proposed changes in the form of a license amend ment incorporating the appropriate revision to the Environmental Protection Plan.

5.4 Plant Reporting Requirements 5.4.1 Routine Reports An Annual Environmental Operating Report describing implementation of this EPP for the previous year shall be submitted to the NRC prior to May 1 of each year. The initial report shall be submitted prior to May 1 of the year following issuance of the operating license. The period of the first report shall begin with the date of issuance of the operating license.

The report shall include summaries and analyses of the results of.the environ mental protection activities required by Subsection 4.2 of this Environmental Protection Plan for the report period,.including a comparison with preoperational studies, operational controls (as appropriate), and previous non-radiological environmental monitoring reports, and an assessment of the observed impacts of the plant operation on the environment. If harmful effects or evidence of trends towards irreversible damage to the environment are observed, the licensee shall provide a detailed analysis of the data and a proposed course of action to alleviate the problem.

The Annual Environmental Operating Report shall also include:

(a)

A list of EPP noncompliances and the corrective actions taken to remejy them.

(b) A list of all changes in station design or operation, tests, and experiments made in accordance with Subsection 3.1 which involved a potentially significant unreviewed environmental issue.

(c) A list of nonroutine reports submitted in accordance with Subsection 5.4.2.

In the event that some results are not available by the report due date, the report shall be submitted noting and explaining the missing results.

The missing data shall be submitted as soon as possible in a supplementary report.

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5.4.2 Nonroutine Reports A written report shall be submitted to the NRC within 30 days of occurrence of nonroutine event. The report shall (a) describe, analyze, and evaluate the event, including extent and magnitude of the impact and plant operating characteristics, (b) describe the probable cause of the event,.(c) indicate the action taken to correct the reported event, (d) indicate the corrective action taken to preclude repetition of the event and to prevent similar occurrences involving similar components or systems, and (e) indicate the agencies notified and their preliminary responses.

Events reportable under this subsection which also require reports to other Federal, State or local agencies shall be reported in accordance with those reporting requirements in lieu of the requirements of this subsection. The NRC shall be provided a copy of such report at the same time it is submitted to the other agency.

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