ML19341B559

Proposed ETS (Nonradiological) for Facilities.Related Info Encl

ML19341B559
Person / Time
Site:	LaSalle
Issue date:	01/23/1981
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML19341B558	List: ML19341B557 ML19341B559 ML19341B560
References
NUDOCS 8102020519
Download: ML19341B559 (28)

Text

O LaSalle County Nuclear Generating Station Units 1 and 2 Environmental Tecnnical Specification (Nonradiological)

Table of Contents Page Se ction 1-1 1.0 Definitions.

Limiting Conditions for Operation . . . . . . . 2-1 2.0 Environmental Monitoring . . ' . . . . . . . . . . 3-1 3.0 3-1 3.1 Vegetative Integrity on Cooling Pond Dike . . .

4-1 4.0 Special Studies and Requirements . . . . . . . .

. . . . . . . . . . . . 4-1 4.1 Ex ceptional Occurrences 4-3 4.2 Special Studies . . . . . . . . . . . . . . . .

. . . . . . . . . . . . 5-1 5.0 Administrative Controls 5-1 5.1 Responsibility . . . . . . . . . . . . . . . . .

5-1 5.2 Review and Audit . . . . . . . . . . . . . . . .

Station Reporting Requirenents . . . . . . . . . 5-2 5.3 5.4 Changes in Environmental Te cnnical 5-5 Spe cifications anc Permits . . . . . . . . . . .

5-6 5.5 Re coro Retention .

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1-1 1.C nefinitions Clean Water Sci: Federal water Pollution Control Act (FWPCA) as amenceo.

NPDES Permit: NPDES permit is the National Pollutant Discharge

' Elimination System No. IL 0048151, issued by the U.S.

certified by the Illinois Environmental Protection Agency and Environmental Protection Agency to the Commonwealth Edison Company. This permit authorizes the Commonwealth Edison Company to_ discharge controlled wastewater from the LaSalle County ,

Nuclear Power Plant, Units'1 and 2, into the waters of the n

Illinois River.

Plant: Plant refers to LaSalle County Units 1 and 2.

I Site: On-site includes any area within the LaSalle County Nuclear Generating Station property owned by the Commonwealth Edison Company. Of f-site includes all other areas.

Station: Sr.ation refers to LaSalle County Units 1 a.1d 2.

Unit: Unit refers only to Units 1 or 2 of.LaSalle County as oefined of its usage.

2 - l' 2.0 Limitino Conditions for Ooeration Kone required.*

• In consideration of the provisions of the Clean Water Act (33 USC.

1251, et sec.) and in the interest c,f avoicing cuplication of effort 7 tne conoitions and monitocing requirements related to water quality and aquatic biota art .specified in the National IL Pollutant Discharge Elimination' System (NPOES) Permit No.

0048151 issued by U.S. Environmental Protection Agency. and-certified by the Illinois Environmental Protec' ion Agency to the Commonwealth Edison Company (CECO.) for the LaSalle County Nuclear Generating Station Units 1 and 2. This' permit authorizes the Commonwealth Edison Company to discharge controlleo wastewater f rom the LaSalle County Nuclear Power' Plant, Units 1 and 2, into the waters of the Illinois River.

The Nuclear Regulatory Commission will- be relying on the NPDES permit limitations for protection. of the aquatic environment f rom nonradiological ef fluents.

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3-1 3.0 Environmental Monitoring 3.1 Vegetative Integritv on Coolino Pono Dike Recoirements The monitoring program consists of a visual inspection of the vegetative integrity on tt,e outer face of the peripheral cooling pond dike f ace at the beginning of the spring planting season (May) and at the beginning of the fall planting season (August). If a f ailure of the -vegetative cover is oiscovered by inspe ctio n , the af fected area shall be reseedeo during the succeeoing planting season.

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Basis A stable vegetative cover inhibits erosion of the dike during intense rainstorms.

Action s

Tne results of these inspe'ctions and any required reseeding actions taken will be included in'the annual Environmental Operating Report in accordance -with Se ction 5. 3.1.

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4-1 4.0 Soecial Studies and Recuirements 4.1 Ex ceotional O ccurrences 4.1.1 , Unusual or Icoortant Environmental Events Recuirements The licensee will record any discovered occurrences of unusual or important events. Unusual or important events are those that potentially could cause or indicate significant environmental impact causally relat,ed with station operation. The following are exaoples: excessive bird impaction events; on-site plant or animal disease outbreaks; unusual mortality of any species protected by the Endangered Species Act of 1973; fish kills within 1 mile downstream of the Illinois River Intake structure; and, unanticipated or emergency discharges of wastewater or chemical substances. .

Tne special requirement shall commence witn the date of issuance of the operating license and continue for .the life of the plant, unless enanged in accordance with Subsection 5.4.1.

A ct ion Should an unusual or important event be discovered, the

t licensee nill make a prompt report to the NRC in accorcance i

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4-2 with the provisions of Subsections 5.3.2.1 or Subsection 5.3.2.3.

4.1.2 Ex ceedino Limits of Other Relevant Permits Recuirements The licensee will notify the NRC of ' occurrences in whicn the limits specified in relevant permits and certificates for the protection of the environment issued by other Federal, State and local agencies are exceeded and which are reportable to the agency which issued the permit. This requirement shall commence with the date of issuance of the operating license and continue for the life of the station, unless changed in accordance with Subsecton 5. A 1.

.t A ction l

l The licensee will make a report to the NRC in accordance with-the provisions of Subsections 5.3.l' or 5.3.2.3 in the event of a reportable occurrence in which a limit specified in a relevant permit or certificate issued by another Federal, State or local agency is exceeded.

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-s, 4.2 Soecial Stuoles 4.2.1 Monitoring Program to Measure Local Foo and Ice Caused bv Coolino Pono Reouirementq (a) Training Company personnel will be trained to observe and report steam fogging and rime ice conditions near the periphery of the cooling pond under the auspices of a Certified Consulting Meteorologist.

(b) Loci of Observations In connection with the training phase above, lo cations will be established from and at which observations will-be made. These observation locations will be chosen to include appropriate sightings of the. roadways near the periphery of the cooling pond,- nearby residences and' other sensitive locations, if any. Specific roadways to be observed near the cooling pond are County . Highway 6, State Route 170, .the gravel road north of the cooling ponc and County Highway-30.

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4-4 4.2.1 Monitoring Program tv Measure Local Foo anc Ice Causeo by Coolinn Pond ( continued)

( c) Sightings Senenmarks Appropriate landmarks will be identified within sight of eacn observation location to f acilitate the estimation of the extent of (distance covered by) fogging and rime icing and the density of (visibility impairment caused j

by) fogging. The distances between the landmarks and tneir associated observation locations will be measureo and re corded.

(d) Fog From eacn observation location, visual observations will be made and recorded by trained personnel twice each day, before and after-the day shift, ex cept weekends and holicays, indicating the presence, location and extent of fog and the estimated local visibility '(range) .

These observations will notJbe made on days these roads are impassaole due to snow or flood.

(e) Ice From each observation location, visual observations will be made anc recorded oy trained personnel twice each day, 4

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1 4-5 4.2.1 Monitoring Program to Measure Local Fog and Ice Causeo by Coolina Pond (Continued) before and after the day shift, ex cept weekends and holidays, from October 1 through March 31, indicating the presence, location, extent and thickness of rime i ce . These observations will not be made on days these roads are impassable due to snow or flood.

(f) Supporting Observations i

' The observations record shall include time, ambient air temperature (dry bulb and dew point), wind direction and l speed, electrical load on plant and condensing water temperatures (intake to and discharge from the plant).

(g) Environmental Impact of Rime Icing i

l As soon as possible after the end of the observation season, but no later than May 1, the' data on the occurrence of rime icing will be correlated 1to determine the locations where environmental impact surveys will be concu cted . Such surveys will include observation of i

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vegetation by a terrestrial' biologist or cotanist curing tne spring growing season.

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4-6 4.2.1 Monitoring Program to Measure Local Fog and Ice Caused by Cooling Pono (Continued)

Action The monitoring under requirements d), e) ano f) shall commence as soon as practical af ter January 1, 1980, so as to obtain as much of one year's preoperational data as possible. Observations made curing one-unit and two-unit s

operation will be in accordance with the schedule expressed in paragraph six of Subsection 6.2.1 of the LSCS Final The monitoring data will be Environmental Statement (FES).

summarized and submitted to the NRC quarterly until at least 12 months of cata collection has accrued with reasonable complete two-unit operation. These data shall be summarized, analyzed, interpreted and compared with the preoperational l

l monitoring data in the annual reports in accordance with l

• Subsection 5.3.1 of the LSCS Environmental Technical Spe cifications (ETS) .

I Basis The purpose of this monitoring program is to determine (1) l the f requency and density of cooling pond-induced fog on local r. cads; and-(2) the extent of rime ice formation in the-vicinity of the pond. The results of this program will

' determine whether there is a need for action to mitigate fog or icing ef fects.

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A-7 4.2.2 Cooling Pond Caliform Monitorino Prooram Requirements

'Wat'er samples from the cooling pond will be collected and analyzed for fecal and total califorms and for fe cal s t rep to co cci .

This program shall commence af ter the lake is filled to its anticipated operating level and regular pumping of water

- through the plant system begins. It shall terminate one year af ter the second unit is placed into commercial service.

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The results of this monitoring program shall be summarized, l

l analyzed and-reported within 120 days following its l

' completion.

l Basis The results of the coliform monitoring program will be used i

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to assist in the determination rF what re creational use can be made of the cooling pond.

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a-8 4.2.3 Quantitative Monitoring Program of Veceta*.ive Integrity on Cooling 's ni k,e Recuirements Tne outer f ace of the peripheral cooling pond dike shall be inspected semiannually using quantitative methods to estimate vegetative cover. This program shal'1 be pursued until the Vegatation is estaDlished and shall continue for at least the three-year period commencinc with the Spring, 1978 growing season.

Basis The purpose of this quantitative monitoring is to estimate vegetative cover. Successful establisnment of vegetative Cover ch the outer f ace of the peripheral dike will reduce the runoff rate and inhibit erosion of the dike.

5-1 5.0 Acministrative Controls 5.1 Resconsibility I I

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The station superintendent has responsiollity for operating the plant in compliance with these te chnical spe cifications. j 1

1 I 5.2 Review and Audit I

5.2.1 Review The Environmental Affairs Department is responsible for incependent review of procedures for meeting enviranmental-technical spe cifications.

the The above mentioned review shall be conducted m1 following:

I a) Proposed changes to the Environmental Technical i

Specifications and evaluated impact of the change.

b) All routine reports prior to their submittal.to NRC

! (described in Subse ction 5.3.1) .

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c) All reports of noncompliance with Environmental Technical-Specifications, associated corrective . actions and measures taken to prevent. recurrence.

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5 -2' 5.2.2 Audit The Quality Assurance Department shall conduct an annual audit of the environmental monitoring program.

5.3 Station Recortino Reouirements 5.3.1 Routine Reoorts Annual Environmental 00eratino Recort A report of the environmental monitoring program for the previous year shall be submitted to-the NRC separate from other NRC reporting requirements on or about May 1 of each year af ter the issuance of the operating license and shall contain at least one year's operating data.* The report i

shall include summaries, analyses, interpretations and statistical evaluation of the results of the environmental monitoring required for the report period,. including comparison with preoperational studies, operating controls

• The first report to be submitted may be deferred one year if at least one year's data does not exist at the time this specification would require initial submittal.

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5-3' (as appropriate), previous nonraciological environmental monitoring reports and an assessment of the observec impacts of tne station operation on the environment. If harmful ef fects or evioence of irreversible damage are suggesteo by the monitoring programs, ne licensee shall provide a more

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cetaileo analysis of tne cata and a proposeo course of action to alleviate the problem.

For those programs concerned with water quality or protection 4

of aquatic Dicta, whicn are regulated under the Clean Water A ct , this requirement shall ce satisfied by.sumitting to the NRC copies of the reports to the Illinois Environmental Protection Agency or U.S. Environmental Protection Agency that are requireo by the NPOES permit or any other agency that deals with aquatic concerns.

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In the event that some results are not available by the-l l

report due date, the report shall ce submitted noting and explaining the missing results. The missing data shall be l suomitteo as soon as possible in a' supplementary report.

The Annual Report shall also include a summary of:-

i a) All ETS- noncompliances and the corrective . actions taken to remecy- them.

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5-4 b) Changes made to relevant environmental Federal and State permits and certifications.

c) Changes in station design which could involve a significant environmental impact or change the findings of the FES.

d) All nonroutine reports submitted per ETS Section 4.1.5.3.1 f

e) Changes in approved ETS.

5.3.2 Nonroutine Recorts A report shall be submitted in the event that an " Unusual or Important Environmental Event," as specified in Subse ction 4.1.1 be dis covered. The schedule and content I

for these nonroutine reports are described below:

5.3.2.1 Promat Reoort .

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Those avents specified as requiring prompt reporting shall-l l- be reported 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 l

l facsimile transmission to the NRC.

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5-5' 5.3.2.2 Content of Nonroutine Reports To the extent possible, the telephone, telegraph or facsimile reports shall (1) describe, analyze and evaluate the occurrence, including extent and magnitude of the impact; (2) cescribe the cause of the occurrence; (3) indicate the action taken to c]rrect the reported occurrence; and (4) indicate the correct i ve action taken (including any significan'. changes made in procedures) to preclude repetition of the occurrence and to prevent similar occurrences involving. similar components. or systems.

5.3.2.3 Exceptions for Matters Regulated Under the Clean Water Act l For matters regulated under the Clean Water Act, the report r

schedules and content requirements described in Subsections 5.3.2.1 and 5.3.2.2 shall be satisfied by submitting to he l

NRC copies of reports as required by the NPOES permit (or and in other regulations pursuant.to the Clean Water'Act) a ccordance with the s chedule and conten t requirements imposed thereby.

5-6 5.4 Changes in Environmental Technical Specifications and Permits 5.4.1 Chances in Environmental Tecnnical Soecifications Requests for changes in environmental technical specifications shall be submitted to the NRC for review and authorization per 10 CFR 50.90. The request snall include an evaluation of the environmental impact of the proposed change and a supporting justification. Implementation of such requested changes in the ETS shall not commence prior to incorporation by the NRC of the new specifications into the license.

5.4.2 Chances in Permits and Certifications Changes and additions to required Federal (other than NRC), State, regional and local authority permits and certificates for protection of the environment that pertain to the requirements of these ETS will be reported to the NRC. In the event that the licensee initiates or

5-7 Decomes aware of a request for changes to any of the water quality requirements, limits or values stipulated in any certification or permit issued pursuant to the Clean Water A ct which is also the suoject of an ETS reporting requirement, NRC will be informed.

If a permit or certification for the protection of the environment, in part or its entirety, is appealed and stayed, NRC will be informed. If, as the result of the appeal process, the permit or certification requirements are changed, the change will be dealt with as described in the previcus paragrapn of this subsection.

5.5 Records Retention Records anc logs relative' to the envi.'nmental ~ aspects of station operation will be made and reta'ned in a manner convenient for review and inspection, in accordance with:

These records and logs l

Subsections 5.5.1, 5.5.2 and 5.5.3.

l i shall be made available to NRC onLrequest.

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5.5.1 The following records will be retained for the life of the station:

I i a) Records of changes - to these Environmental . Te cnnical Spe cifications including, if applicaule, recoros of NRC.

approval of sucn changes.

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5-8 b) Records of modifications to station structures, systems and components determined to potentially af fect the continedd protection of the environment.

c) Records of changes to relevent environmental permits and certification _ required by Federal (other than NRC),

State, regional and local authorities for the protection of the environment. .

d) Routine reports submitted to the NRC.

5.5.2 Records of the following will be retained for a minimum of I six years:

l a) Review and audit activities.

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b) Events, and the reports thereon, which are - the subjects of nonroutine reports to the NRC.

5.5.3 Records associated with requirements of Federal (other than NRC), State,-regional and local authorities' permits and certificates for the protection of' the environment will bE retained for the period established by the respective pe rmit or ce rtificate.

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- A?rACINE.T2 LaSalle County Station Cooling Lake Monitorine Progra= with Respect to Fathetens The NRC commented on Edison's proposed pathogen monitoring program in a letter to 3. Lee of Edison, dated December 13,1976. In an enclosure to that letter (Ite= 6), it was recom= ended that all samples collected in the cool-ing lake prcper (excluding the intake and discharge canals) be taken f rom a point not nearer than 50 feet to any shoreline, weather conditions permitting. This was suggested to avoid sample bias due to naturally present soil microorganisms.

As the program was reviewed in preparation for its implementation, it was observed that 1) only one sampling statiou in the lake would need to be located 50 feet offshore, 2) this location is at the end of a long artificial b riprapped dike, and 3) the location is not near any soil that could cause con-taminated samples.

We propose that the requirement to sample a mininum of 50 feet off-shore for the lake sample, to prevent contamination from soil bacteria, be dropped because 1) there is no soil near the sam 711ng location, 2) the cost of the program is increased because two people, rather than one, are needed to T take the sa=ples f or safety reasons, and 3) safety risks of sampling frem a small boat under changing weather conditions.

The NRC staff also required that the sampling frequency consist of j

a minimum of five samples per calendar month, with a minimum sampling interval

( of three days (Item 7) .

We propose that a minimum of one sample per week be taken, erith a minimum sampling interval of three days. The proposed sa=pling frequency would t result in 52 sa=ples versus 60 samples which would result from the required pro-gram.

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_2-The proposed pregram would greatly reduce the scheduling problems and the weekend work involved with these weeks where two sa=pling trips are re-quired. Weekend work is required due to the ttne it takes to culture the sanple (48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) bef ore it can be analyzed.

The pathogen menitoring program began on November 12, 1930. We were required to start the program when pumping of water through plant systems began.

Ecwever, we were uncertain as to exactly what pu= ping through plant syste=s re-The study was started because occasionally so=e pumping does occur in fers to.

connection with preoperational tests. Until fuel is loaded the heat rejected to the cooling pondvill not be significiant.

Since the monitoring progras began the co==ercial ser;;ce date for Unit One has been delayed until 1982.

We feel that sampling for pathogens would be core appropriate when heat is being added to the cooling lake in significant quantities on a regular basis.

Since that will not occur until af ter fuel load, we request that we be allowed to terminate the program now and reinstitute it. The program would begin One, within 30 days after completion of fuel load in Unit i

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ATTACHMENT 3 Summary Report of Armstrong Run  :

Revegetation Monitoring l

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Summarv Report of Armstrong Run Issue in C. Reed's letter to V. A. Moore, dated May 25, 1978, Commonwealth Edison Cc=pany ce==itted to five actions relating to the Armstrong Run issue. of the The action items are also contained in Section 6.3.4 Terrestrial Ecology FES for the LaSalle County Station (NUREC-0486, dated November,1978) unich is Attachment 1.

The status of each commitment is as follcws:

1. The third year of the monitoring program has been com-pleted. A copy of the report for the third year, " Dike Revegetatien Monitoring at the LaSalle County Station, 4

August, 1930", is enclosed (see Attachment 2). This re-port indicates that the cover during May, 1980 was (de- 95 percent and the mean for August was 92.46 percent crease due to partial def oliation of crown vetch and

' sweet clover). This is an excellent cover "and capable of doing the job f or which it was planned" (page 10 of the report). No further action is required on this item and it should therefore be dropped.

2. We have implemented a monitoring program of twice annual visual inspections to determine the vegetative integrity of the dike.

3. Any f ailure noted in Number 2 has been and will continue to be acted upon in a etnely manner.

4. The Armstrong Run banks have been reshaped. Reseeding has been completed this summer. No further action is therefore required on this item and it should therefore be dropped.

5. It is apparent that this action item may not be possible to complete. We negotiated with the two owners of the f arm (through their attorney) that is adjacent to our Station property and through which the run flows. An agreement was struck, Attachment 3, whereby portions of the run would be reshaped and reseeded and CECO would reimburse the landowners for these expenses in return for release of any damage claims _and twice yearly access to the run area in order to perform the required reveg-etation inspections. The reshaping of the run was com-pleted in late summer 1979, and The the reseeding was com-landowners , however, pleted in the summer of 1980.

have refused to sign the agreement on the basis that they have lost "as much as three acres" of f armable land and incurred legal fees in bringing the matter to the atten-tion of the NRC and in negotiating the unsigned agreement

(see Attach =ent 4). '*e

- are presently at an impasse be-cause the bef ere and af ter photographs that we have in-dicate that more land is now f arnable than before the reshaping of the banks because the elimination of spoil banks and other areas along the run that were not f a rm-able more than co=pensate f or the land lost where the ditch slope was altered. Attached is a chronological

- list of activities associated with the Armstrong Run situation (Attachment 5). '.*ithout the assurances of a signed agreement, such as the one attached which was to doing negotiated in good f aith, CECO cannot commit the revegetation inspection along the run because.we lack the right of access. According to Table 4.1 of the LaSalle County Station FES (Attachment 6), the estimated peak discharge frem the run at the site boun-dary is significantly less with the dike covered with vegetation than the preconstruction levels which shculd eliminate the run erosion issue. Since the dike vegeta-tien has been successfully established, the erosion of dike caterial should be negligible, and therefore the t

issue of silt depositien in the run from the dike should also be eliminated. The reshaping of the run banks was also done in such a manner that the erosion from adjacent f armland would also be reduced. This action item should therefore be dropped.

The only action items that should be carried forward are Items 2 and 3 which would require e.vice annual visual inspection of the integrity of the dike vegetation and reseeding, if necessary.

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Attachment 1

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6.3.s Terrestrial f :1 - -_v of ve;etatien en the cooling lake dike is necessary te prevent erosion Successf s1 estat11s* +-t f-o af fecting far-land adja:ent to the statien. there'cee.

and ra:': rs :ff of ;ee:1;itaticeinstitute tne follo-irg -emitering pre; ear ard tske the necessary a

the a;;11: ant is res. ired t: in the follcwing requirements, reference to the dite caree:tive inc1 wats the ;eatnete* cit:r suraca acti:n as iacitated (note:nding the esterior of the dike as well as the dike itself):

1. The a:elicaat sna11 routinely (at least se-iannostly) renitor the initial vegetation on tne entire cike cy qwantitative metneds (such as these descritec inThis small te ADC. G) to esti.Jte cave'.

but nct f:r less tr.an three yenes co rencing mitn the spring 1978 gro.ing season.

2. The a: licant sna11 merit

• the enti*e dike by visual irsoection for ve;etative sete;*ity at tne te;'netn; of the f all ;14nting season ( Auggst) and .

at tne be; inn w; ec the s:*; :la ting season (may). This re:. ire ent shall continwe for the life of tne stati:n.

3. If a failu*e of t*e ve;etative ccver of the dike is detected, the af fe:ted area srall be revege* ate: in a tirely renner (i.e.. at the beginning of tne neat plar. ting seasse, spring or f all) 4 Since the tanks cf Ar-strong Run will continue to erode until the esisting ecosion in the Run is re: aired, the applicant sna11 regrade where necessary and revegetate those porticas of Ar-staen; Run where bank ercsion now a;oears. The grading shall be timed to match the neat clattin; sessen (May 1979) so that irrnediate reseeding of the sloped sides is pessible. The reseedin; shall use suitable sod-forming grass species and include the use of netting, mulch, and a soil binder.

5. The revegetation in An=stron; Run shall be acnitored routinely (at least semi-annually) to easure its su: cess, and repair =crk taken prometlyu if any failure of reseeding is dete:ted. The remitcring of the revegetation in Aavestrong a n should continue until the vegetation en bott the dike and the Run is successfully estselished and do:umented by Corren-ealth Edisca Cormany. Swecessful establishrent of the ve;etation will be detertined througn NEC staf f review of the Corrtnwealih Edison Company documentation.

• Execrpted from LaSalle County Station FLS (Nt' REG-0186), November, 1976.

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