ML20028D081
| ML20028D081 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/07/1983 |
| From: | SOUTHERN CALIFORNIA EDISON CO. |
| To: | |
| Shared Package | |
| ML20028D078 | List: |
| References | |
| NUDOCS 8301170051 | |
| Download: ML20028D081 (12) | |
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DESCRIPTION OF PROPOSED CHANGE AND SAFETY ANALYSIS PROPOSED CHANGE NO. lid fu lHE TECHNICAL SPEClflCAT10NS PROVISIONAL UPERATING LICENSE UPH-13 This is a request for revision of Appendix B. Technical Specifications, and to amend the License thereby.
Reasons for Proposed Change The intent of the proposed change is to simplify environmental monitoring and surveillance and make it cost effective, without sacrificing the standards necessary to achieve protection of the environment.
Simplification and cost effectiveness are achieved by a reorganization and revision of the non-radiological sections of the ETS under a new title, Environmental Protection Plan (EPP), which would tnen replace the entire ETS.
A major objective of the revision is to eliminate the regulatory overlap between the NRC and other agencies. Under tne Federal Water Pollution Control Act (FWPCA), the U.S. Environmental Protection Agency and the State of California are charged with the responsibility to regulate waste discharges into water bodies.
Inis responsibility is fulfilled by way of the licensee's National Pollutant Discharge Elimination System (NPOES) permit. References are therefore added in the EPP to the San Onofre Unit 1 NPUES permit.
Coapliance with the NPDES permit is expected to assure adequate protection of the receiving water quality.
The radiological sections of tne ETS, which are under the NRC's regulatory authority, as well as Section b, Acainistrative Controls, will be incorporated into Appendix A of the Technical Specifications.
Tnese changes will be nandled separately.
The effect of this proposed change on the existing ETS sections is as follows:
ETS Section Action Taken Reasons for Action Taken 1.0 Deleted Definitions in Section 1.0 are essentially inapplicable to the EPP writeup.
2.1 Deleted Objective of limiting thermal stress to aquatic ecosystem is met by satisfying relevant NPOES permit requirements.
2.2 Deleted All waste water discharges into the aquatic ecosystem are regulated by the NPOES permit.
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ETS Section Action Taken Reasons for Action Taken 2.3 Deleted Radioactive discharge is covered by Sections 4.5 and 4.6 of Appendix A of the Technical Specifications.
3.2 None This Section will be revised by Proposed Change No. 83.
5.0 None This Section will be deleted as a result of NRC's approval of Proposed Change No. 83.
An Environmental Protection Plan with similar objectives and contents is already in effect at San Onofre Unit 2.
Approval of this change would enable similar environmental programs to be implemented at Units 1 and 2.
Existing Specifications The existing specifications are as constituted in Appendix B, Environmental Technical Specifications.
Proposed Specifications The proposed specifications are as provided in the Enclosure.
Safety / Environmental Analysis The proposed Environment &1 Protection Plan does not affect the plant's operational margins, nor does it alter the minimal environmental impact due to the plant's operation.
The results of over five years (1975-1981) of ETS/ NPDES environmental studies at San Onotre Unit 1 have demonstrated that the natural variations found in the easironment are greater than any possible changes induced by the operation of Unit 1.
The current NPDES Permit No. CA0001228 became effective on July 12, 1982, and expires on July 12, 1987.
By comparing the NRC's limits and surveillance requirements with those in the NPDES permit, it has been concluded that compliance with the permit is more than adequate to preserve the beneficial uses of the receiving water.
Based upon the above, it is concluded that (1) the proposed change does not involve a safety / environmental question not previously reviewed and evaluated by the NRC, and (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change.
. Cost-Benefit Analysis The Environmental Protection Plan does not add to the existing ETS/ NPDES environmental requirements and monitoring programs. Consequently, there are no additional operating costs associated with the EPP. Un the other hand, by c
reducing the present dual regulatory interface to a single, more manageable one, and the elimination of LCO's for water quality parameters and related environmental monitoring programs, substantial savings each year will be realized.
The above savings will not result in a significant reduction in benefits, as the objectives of items 1 and 2 in the preceding paragraph are net by the NPOES permit.
IAA:4877 4
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APPENDIX B J
e TO PROVISIO1AL OPERATING LICENSE NO. DPR-13 FOR
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SAN ONOFRE NUCLEAR GENERATING STATION, UNIT NO.1 50dTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY DOCKET NO. 50-206 4
d ENVIRONMENIAL PROTECTION PLAN
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SAN ONOFRE NUCLEAR GENERATING STATION UNIT 1 ENVIRONMENTAL PROTECTION PLAN (N0ti-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 2-1 2.3 Cultural nesources Issues 2-1 3.0 Consistency Requirements 3-1 3.1 Plant Design and Operation 3-1 3.2 Reporting Related to the NPOES Permit and State Certification 3-2 3.3 Changes Required for Compliance with Other Environmental Regulations 3-2 4.0 Environmental Conditions 4-1.
4.1 Reportable Environmental Events 4-1
1.0 Objectives of the Environmental Protection Plan The Environmental Protection Plan (EPP) is to provide for protection of environmental quality during operation of the nuclear facility.
The principal objectives of the EPP are as follows:
(1)
Assure that the plant is operated in an environmentally acceptable manner, as established by the Final Environmental Statement (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 environraental effects of facility opera-tion and of actions taken to control those effects.
Environmental concerns identified in the FES which relate to water qual-ity matters are regulated by way of the licensee's NPOES permit.
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2.0 Environmental Protection Issues In the FES-OL, dated October 1973, tne staff has considered the environ-mental impacts associated witn the operation of the San Onofre Nuclear Generating Station, Unit 1.
Certain environmental issues were identi-fied which required study or license conditions to resolve environmental concerns and to assure adequate protection of the environment.
2.1 Aquatic Issues In Section 6.2.1 of the FES-OL, the following outstanding aquatic issues were identified:
(1)
Some biological studies have not been completed, and available data are inadequate.
(2)
More data on the impingement of fish during normal operation are needed.
(3)
Studies on the ef fects of entrainment on pianktonic organisms snould be completed.
The Environmental Technical Specification (ETS) aquatic monitoring pro-i gram was developed to address these issues. Monitoring was initiated in 1975 and continued until 1981. During subsequent years, all aquatic issues will De addressed as part of the effluent limitations, monitoring requirements and demonstration studies pertinent to the effective NPOES permit issued by the California Regional Water Quality Control Board-San Diego Region.
Tne NRC will rely on that agency for regulation of matters involving water quality and aquatic Dicta..
2.2 ferrestrial Issues None 2.3 Cultural Resources issues None 2el
3.0 Consistency Requirements 3.1 Plant Design and Operation The licensee may make changes in plant design or operation or perform tests or experiments affecting the environment provided such changes, tests or experiments do not involve an unreviewed environmental ques-tion. 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 FES, or (2) a significant change in efflu-i ents or power level [in accordance with 10 CFR Part Sl.5(b) (2)J, or (3) a matter not previously reviewed and evaluated in the FES whica may have a significant adverse environmental impact.
Before engaging in a construction or operational activity (including a test or experiment) whicn may affect the environment, the licensee shall prepare and record an environmental evaluation of such activity.* When the evaluation indicates that such dctivity involves an unreviewed environmental question, the licensee shall provide a written evaluation of such activity and obtain prior approval from the NRC.
Changes in plant design or operation or performance of tests or experi-ments which do not affect the environment are not subject to the above requirement.
Accidental occurrences that affect the environment are covered by Sections 3.2 and 4.1, es applicable.
Activities governed by Section 3.3 are not subject to the requirements of this section.
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 pro-vides bases for the determination that the change, test, or experiment does not involve an unreviewed environmental question.
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Activities excluded fraa this definition are those in which all measurable nonradiological effects are confined to the onsite areas previously disturbed during site prep 0 ration and plant construction.
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3.2 Reporting Related to the NPOES Permit and State Certification Tne NRC shall be notified of changes to the effective NPOES permit pro-posed by the licensee by providing the NRC with a copy of the proposed change at the same time it is submitted to the permitting agency.
The licensee shall provide the NRC a copy of the application for renewal of the NPDES permit at the same time the application is subaitted to the permitting agency.
Changes and additions to the NPOES permit or the State certification shall be reported to the NRC within 30 days following the date the change is approved.
If a permit or certification, in part or in its entirety, is appealed and stayed, the NRC shall be notified within 30 days following the date the stay is granted.
Violation (s) of the NPOES permit or State certification (pursuant to Section 401 of the Clean Water Act) shall be reported to the NRC by subaittal of copies of the reports required by the NPDES permit or certification to report the violation (s).
The licensee shall also provide the NRC with a copy of the results of the following studies at the same time as the results are submitted to the permitting agency:
Section 316(b) Demonstration Study 3.3 Changes Required for Compliance with Other Environmental Regulations Changes in plant design or operation and performance of tests or experi-ments which are required to achieve compliance with other Federal, State, or local environmental regulations are not subject to tne requirements of Section 3.1.
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T 4.0 Environmental Conditions 4.1 Heportable Environmental Events Environmental events which require reporting to another Federal, State or local agency shall be reported in accordance with the requirements of that agency.
Where a written report is required, a copy of the written report shall also be submitted to the NRC. However, environmental events reportable to the NRC under this Section exclude such events as are normally covered by routine periodic reports submitted to the various agencies. Reporting related to the NPDES permit and state certification is covered by Section 3.2.
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l IAA
- 4749 4-1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of SOUTHERN
)
CALIFORNIA EDISON COMPANY
) Docket No. 50-206 and SAN DIEGO GAS & ELECTRIC
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COMPANY (San Onofre Nuclear
)
Generating Station Unit No.1)
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j AFFIDAVIT OF SERVICE l
I, IFTIKHAR A. ABBASI, hereby declare that a copy of Amendment No.109 in Docket No. 50-206 was served on the following by deposit in the United States Mail, postage prepaid, on the 13th day of January
, 1933, Henry J. McGurren, Esq.
Staff Counsel
- 0. S. Nuclear Regulatory Commission Washington, D. C.
20S45 David R. Pigott, Esq.
Samuel B. Casey, Esq.
Orrick, Herrington & Sutcliffe 600 Montgomery Street
)
San Francisco, California 94111 John V. Morowski Bechtel Power Corporation P. O. Box 60860, Terminal Annex Los Angeles, California 90060 Michael L. Mellor, Esq.
Thelen, Harrin, Johnson & Bridges Two Embarcadero Center San Francisco, California 94111 Huey Johnson Secretary for Resources State of California 1416 Ninth Street Sacramento, California 95814 Janice E. Kerr, General Counsel California Public Utilities Commission 5066 State Building San Francisco, California 94102
f J. Rengel Atomic Power Division Westinghouse Electric Corporation Box 355 Pittsburgh, Pennslyvania 15230 A. E. Gaede P. O. Box 373 San Clemente, California 96272 Freuerick E. John, Executive Director i
California Public Utilities Commisssion 5050 State Building San Francisco, California 94102 Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C.
20S55 Dated on this UM day of der /edu/
,1983 in the County of Los Angeles at Rosemead, California.
N Y
x Iftikhar A. Abbasi Engineer SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Rosemead, California Subscribed and sworn to before me i
this ' M/ day of O,v u.%
, 1983 (N
OFFICIAL SEAL 9 NOTARY PU3U AllCE S. SILVAS PRINCIPAL OFFICE IN
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LOC ANGELES COUNTY
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MyCommessaon Enpres hn. 24.1383
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Notary Public in and for the County i --
= ~'" -' E of Los Angeles, State of California
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