ML13317A042
| ML13317A042 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/06/1980 |
| From: | Dietch R Southern California Edison Co |
| To: | |
| Shared Package | |
| ML13308A662 | List: |
| References | |
| NUDOCS 8010210337 | |
| Download: ML13317A042 (6) | |
Text
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDISON
)
COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY )
for a Class 104(b) License to Acquire,
) DOCKET NO. 50-206 Possess, and Use a Utilization Facility as
)
Part of Unit No. 1 of the San Onofre Nuclear ) Amendment No. 93 Generating Station
)
SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS
& ELECTRIC COMPANY, pursuant to 10 CFR 50.90, hereby submit Amendment No. 93.
This amendment consists of Proposed Change No. 94 to the Technical Specifications incorporated in Provisional Operating License No. DPR-13 as Appendix B. Proposed Change No. 94 is a request to revise the Technical Specifications at San Onofre Unit 1 by deleting the limiting conditions for operation (LCO's) and related environmental monitoring programs, by adding a reference to the National Pollution Discharge Elimination System (NPDES) permit and by revising the Administrative Controls accordingly.
In the event of conflict, the information in this Amendment No. 93 supersedes the information previously submitted.
In our opinion, the proposed change does not result in a condition which significantly alters the impact of San Onofre Unit 1 on the environment, and there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change.
Pursuant to 10 CFR 170.22, Proposed Change No. 94, submitted as Amendment No. 93, is determined to be a Class III change.
The basis for this determination is that the Change involves a single environmental issue and is deemed not to involve a significant hazards consideration.
Accordingly, the fee of $4,000.00 corresponding to this determination is remitted herewith as required by 10 CFR 170.22.
REGM L~ WaffHlE COP"
-2 Subscribed on this W day of 61-21611, 1980.
Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By Robert Dietch Vice President Subscribed and sworn to before me this day of
/
AGNES CRABTREE NOmW Pueuc* CAUFOSHA Not ry blic in and for the County of LO"AGLE OU" Los Ang les, State of California MY mCnD P.adia 27198 My Commission expires o7 day of
, /fd:2.
Charles R. Kocher James A. Beoletto At orneys for Sout rn Ca *fornia Edison o any By ames A. 14eo'etto
S
-3 Subscribed on this 1st day of October
,1980.
Respectfully submitted, SAN DIEGO GAS & ELECTRIC COMPANY By Vice President Power Supply Subscribed and sworn to before me this 1st day of October, 1980 My Commission expires the 11th day of October, 1983.
Notary Public in andfor the County of San Diego, State of California ANNE R. SCHMIDT NOTARY PUBUC-CALIFORNIA Principal Office In SanDlegoCounty David R. Pigott My Commission Exp. OTct.
11, 1983 Samuel B. Casey Chickering & Gregory Attorneys for San Diego Gas & lectric Co pany By
__/_
D. R. Pigott
Description of Proposed Change and Environmental Analysis Proposed Change No. 94 to the Technical Specifications Provisional Operating License DPR-13 This is a request to amend the Environmental Technical Specifications (ETS) of Appendix B of the San Onofre Unit 1 operating license.
This proposed change would revise totally the ETS by deleting the limiting conditions for operation (LCO's) and related environmental monitoring programs, by adding a reference to the National Pollution Discharge Elimination System (NPDES) permit and by revising the Administrative Controls accordingly.
This request supercedes deletion requests currently pending for certain subsections within sections 3.1 and 4.0 (Attachment 2).
Reason for Proposed Change Water quality limits and environmental surveillance requirements are presently imposed on the San Onofre Nuclear Generating Station by two agencies:
(1) the U.S.
Nuclear Regulatory Commission and (2) the State of California Regional Water Quality Control Board -
San Diego Region (CRWQCB).
This request for deletion of limiting conditions for operation (LCO's) for certain water quality parameters and related environmental monitoring programs contained in the Appendix B, Environmental Technical Specification is based upon the fact that the U. S. Environmental Protection Agency and the State of California have been charged with the responsibility to regulate pollutant discharges into water bodies under the authority of the Federal Water Pollution Control Act (FWPCA).
Section 511 of the FWPCA provides that nothing under the National Environmental Policy Act shall be deemed to authorize any Federal Agency to review any effluent limitation or other requirement established pursuant to the FWPCA, or to impose, as a condition of any license or permit, any effluent limitation other than any such limitation established pursuant to FWPCA. Therefore, the present Appendix B Technical Specifications represent unnecessary duplicative efforts among regulatory agencies. The intent of this proposed change, to eliminate regulatory overlap, is fully consistent with Section 101 (f) of FWPCA, where it is stated that:
"It is the national policy that to the maximum extent possible the procedures utilized for implementing this Act shall encourage the drastic minimization of paperwork and interagency decision procedures, and make the best use of available manpower and funds, so as to prevent needless duplication and unnecessary delays at all levels of government."
Routine and non-routine reports are a requirement of the NPDES permit.
In the event the discharger (Applicants) is unable to comply with any of the conditions of the NPDES permit, the CRWQCB is immediately notified by tele phone.
This is followed by written confirmation within two weeks of the telephone notification.
-2 Proposed changes to the Administrative Controls to delete duplicative reporting requirements are consistent with the deletion of the LCO's and environmental monitoring programs and subsequent sole reliance upon the NPDES Permit for protection of the environment.
Existing Specifications The existing environmental technical specifications are as constituted in the Appendix B Environmental Technical Specification for San Onofre Unit 1.
Proposed Specifications (See Attachment 1)
Environmental Analysis Preoperational environmental surveillance studies for San Onofre Nuclear Generating Station (SONGS),
Unit 1 began in 1963.
Operational studies to assess the effects of the operation of SONGS, Unit 1 upon the marine environ ment have been conducted since 1968. During this period, annual environmental monitoring reports have been submitted to the CRWQCB (1968-1980) and the Commission (1975-1980).
NPDES Permit No.
CAO001228 issued in 1976 by Order No.
76-11 of the California Regional Water Quality Control Board (CRWQCB)-San Diego Region sets forth environmental monitoring program requirements. SONGS, Unit I has operated in compliance with the requirements of the ETS and NPDES Permit including those requirements under Section 316(a) and 316(b) of the FWPCA.
NPDES Permit No.
CA0001228 became effective on June 8, 1976 and expires on June 8, 1981. A copy of the permit is provided as Attachment 3. A comparison has been made of limits and surveillance requirements imposed upon the opera tions of San Onofre, Unit 1 by the NRC, Appendix B, Environmental Technical Specification and the NPDES Permit.
From this comparison, it is concludea that effluent limitations and surveillance requirements specified in the NPDES Permit are either identical to the NRC ETS requirements or, where differences exist, are more than adequate to assure protection of the beneficial uses of the receiving water.
Five years of ETS/NPDES environmental studies have now been completed at SONGS
- 1. They demonstrate that natural variation of biological and physical elements in the San Onofre area are greater than any possible changes induced by the operation of Unit 1. Any measurable changes are confined to a relati vely small area adjacent to the offshore structures.
The current focus of concern is toward the nearly completed Units 2 and 3.
Studies have been in progress which augment the ETS program in gathering preoperational baseline data by which to measure any significant operational effects of Units 2 and 3 upon the marine environment and to examine the effects of construction.
-3 The proposed change is warranted considering (1) the absence of any significant adverse environmental impacts due to operation of SONGS, Unit 1 and (2) the jurisdictional authority of the U.S.E.P.A.
and the State of California as set forth in the FWPCA.
Cost Benefit Analysis Amending the Unit 1 ETS to delete the LCO's and related environmental monitoring programs will not result in any significant loss of environmental data since the same data is collected to meet the same objectives for the NPDES permit.
By reducing the present complex dual regulatory interface process to a single, more expedient one, it is estimated that a savings of $360,000 in the first year will be realized. Commensurate savings are expected in following years.