ML20069G529

Forwards Revisions to Environ Protection Plan Per 820915 Telcon

ML20069G529
Person / Time
Site:	Atlantic Nuclear Power Plant
Issue date:	09/17/1982
From:	Haga P OFFSHORE POWER SYSTEMS (SUBS. OF WESTINGHOUSE ELECTRI
To:	Adensam E Office of Nuclear Reactor Regulation
References
E-027, E-27, NUDOCS 8209290150
Download: ML20069G529 (3)

Text

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E-027 J

Offshore Power Systems 8000 Arlington Expressway 904 -724 -7700 Box 80cO. Jacksonville, Florida 32211 Telex:5G8406 September 17, 1982 Ms. Elinor Adensam, Chief Licensing Branch No. 4 U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20852

Reference:

Docket No. STN 50-437 Manufacturing License - Environmental Protection Plan

Dear Ms. Adensam:

This will confirm a September 15, 1982 telephone conversa-tion between D. H. Walker and D. C. Aabye of my Staff and Ron Ballard of the Environmental Engineering Branch.

Attached are the changes to the subject document (as it was originally crafted by the NRC) which were agreed to by telephone. lhese changes were telecopied to Ron Ballard on September 16, 1982. It is noted that the first paragraph of Section 3.1 of the Environmental Protection Plan, as proposed by Offshore Power Systems, is consistent with paragraph D(2) of the draft license which in turn is consist-ent with the Final Environmental Statement (Part I). Both paragraphs D(2) and D(3) of the draft license are repeated in substance in the Environmental Protection Plan.

Ver ruly yo rs, P. B. Haga, anager Engineering

/lel CC: V. W. Campbell R. A. Thomas R. L. Ballard (NRC-EEB)

B. Z. Cowan, Eckerd, Seamans, Cherin and Mellott Attachment 8209290150 020917 PDR ADOCK 05000437 A PDR

T0: Ron Ballard (Ext. 24818)

Air Rights Bldg.

FROM: Walker /Aabye(OPS)

1. Change the introductory paragraph to Section 1.0 to read:

The purpose of the Environmental Protection Plan (EPP) is to provide for protection of environmental values during operation of the manu-facturing facility. The principal objectives of the EPP are as follows:

2. Change Section 1.0, sub (3) to read:

Keep NRC informed of the environmental effects of FNP design changes and manufacturing facility operation and of actions taken to control these effects.

3. Revise Section 3.1 to read as follows:

3.1 Plant Design and Manufacturing Activities Before making an FNP design change or before engaging in a Manu-facturing activity /1, either of which is determined by the licensee to involve an unreviewed environmental licensee shall provide written notification to (question, the

• ) the NRC.

An FNP design change or a manufacturing activity shall be deemed to involve an unreviewed environmental question if it concerns (1) a matter which is likely to result in a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as modified by staff's tes-timony to the Atomic Safety and Licensing Board, supplements to the FES, or in any decisions of the Atomic Safety and Licensing Board; or (2) a significant hange in effluents (in accordance with 10 CFR Part 51.5(b) (2 or (3) a matter not previously reviewed and-evaluated in t documents specified in (1) of this Subsection, which may have a significant adverse environmental impact.

The licensee shall maintain records of changes in FNP design and manufacturing activities carried out pursuant to this Subsection.

These records shall include a written evaluation which provides bases for the determination that the change does not involve an unreviewed environmental question.

Activities governed by Section 3.3 of this EPP are not subject to the requirements of this section.

4. Revise the present footnote on p. 3-1 to read:

/1 Manufacturing Activity means an operation conducted at the Manu-facturing Facility (1) for the purpose of FNP fabrication or testing or (2) for the purpose of controlling the environmental impact of FNP fabrication or testing.

This is the wording proposed by Offshore Power Systems. If prior notifi-cation is determined to be a requirement, the words " Provide written notification to" should be replaced by the words "obtain prior approval from".

5. Revise Section 3.3 to read:

Changes which would otherwise be within the scope of Subsection 3.1, but which are required to achieve compliance with ..........

6. Revise Section 4.1'(first two paragraphs) to read:

Any occurrence of a significant event that indicates or could result in significant environmental impact causally related to manufacturing activities 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 /> followed by a written report within 30 days. No routine monitoring programs are required to implement this condition.

The written report shall (a) describe, analyze, and evaluate the event, including the extent and magnitude of the impact (b) describe the manufacturing facility conditions at the time of the event, (c) describe the probable cause of the event, (d) indicate the action taken to correct the reported event, (e) indicate the corrective action taken to preclude repetition of the event and to prevent similar occurrences involving similar components or systems, and (f) indicate other agencies notified and their preliminary responses.

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