ML20072R146
| ML20072R146 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/28/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 21627, NUDOCS 8304050467 | |
| Download: ML20072R146 (18) | |
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Consumers 4
POW 8r t
James W Cook
- C0m98nY viu nasue,,a - noiusa zi ~+s and Construction General offices
- 1945 West Pernell Road, Jackson, MI 49201 e (517) 788 0453 March 28, 1983 Ilarold R Denton, Director Office of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND ENERGY CENTER PROJECT MIDLAND DOCKET NOS 50-329, 50-330 ENVIRONMENTAL PROTECTION PLAN FILE 0505.5 SERIAL 21627 Enclosed herewith are six copies of the second draft proposed Environmental Protection Plan (EPP) for the Midland Plant Units 1 and 2 Operating License, Appendix B.
The Company submitted the first draft EPP to NRC on November 15, 1982 (Serial 19738). NRC and the Company met on November 22, 1982 and NRC responded with written comments on December 1, 1982. The enclosed second draft incorporates the NRC comments and Company resolutions.
JWC/RFG/fms CC RJCook, Midland Resident Inspector Rllernan, US NRC Ge I
le i
oc0383-1698a131 8304050467 830328 PDR ADOCK 05000329 A
CONSUMERS POWER COMPA?"(_
Midland Units 1 and.'-
Docket No 50-329, 50-330 Letter Serial 21627 Dated March 28, 1983 Consumers Power Company submits the second draft proposed Environmental Protection Plan for the Midland Plant Units 1 and 2 Operating License, Appendix B.
The second draft Environmental Protection Plan reflects NRC comments on the draf t submitted on November 15, 1982.
CONSUMERS POWER COMPANY W Cook, Vice President '
Prof ets, Engineering and Construction Sworn and subscribed before me this 28 day of March, 1983 Al -2f%2^I U4W/t-La -
s Notary Public
/
Jackson County, Michigan My Commission Expires September 8. 1984 oc0383-1698a131
CP Co Draft 03/28/83 APPENDIX B TO FACILITY LICENSE NO.
MIDLAND PLANT (MIDLAND ENERGY CENTER PROJECT)
UNITS 1 AND 2 CONSUMERS POWER COMPANY DOCKET NOS. 50-329 AND 50-330 ENVIRONMENTAL PROTECTION PLAN 4
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MIDLAND PLANT (MIDLAND ENERGY CENTER PROJECT)
UNITS 1 AND 2 ENVIRONMENTAL PROTECTION PALN TABLE OF CONTENTS Section Page No 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 Teirestrial Issues.
2-2 3.0 CONSI"TENCY REQUIREMENTS 3-1 3.1 Plant Design and Operation.
3-1 3.2 Reporting Related to the NPDES Permit 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.
4-2 5.0 ADMINISTRATIVE PROCEDURES....................
5-1 5.1 Review and Audit.
5-1 5.2 Records Retention 5-1 5.3 Changes in Environmental Protection Plan.
5-1 5.4 Plant Reporting Requirements.
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1.0 OBJECTIVES OF THE ENVIRONMENTAL PROTECTION PLAN 2
The Environmental Protection Plan (EPP) provides for protection of 1
I environmental values during operation and modification 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 Final Environmental Statement -
Operating Licensing (FES-OL) and other Nuclear Regulatory Commission (NRC) environmental impact assessments.
2.
Coordinate NRC requirements and maintain consistency with other Federal, State and local requirements for environmental protection.
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3.
Keep NRC informed of the environmental effects of facility operation and modification and of action taken to control those effects.
t Environmental concerns identified in the FES-OL which relate to water quality matters are regulated by the Licensee's National Pollutant Discharge Elimination System (NPDES) Permit.
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2.0 ENVIRONMENTAL PROTECTION ISSUES In the FES-OL dated July 1982, the NRC Staff considered the environmental i
impacts associated with the operation of the two-unit Midland Plant.
1 Certain environmental issues were identified which reqciired study or license conditions to resolve environmental concerns and to assure adequate protection of the environment.
2.1 Aquatic issues i
1 Specific aquatic issues discussed by the Staff in the FES-OL and which require monitoring were:
1.
Plant wastewater discharges will be monitored as required by the i
NPDES Permit (FES-OL Section 5.3.2.1).
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A measurement of impingement and entrainment losses will be made f
after Plant startup as required by the NPDES Permit (FES-OL Section 5.5.2.1).
I 3.
The impact of plant operation on the aquatic ecosystem will be f
determined by an ecological monitoring program as required by the NPDES Permit (FES-OL Section 5.5.2.2).
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Aquatic issues identified above are addressed by effluent limitations and monitoring requirements contained in the effective NPDES Permit issued by j
the Michigan Water Resources Commission. The NRC will rely on this agency for regulation of these matters as they involve water quality and aquatic biota.
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2.2 Terrestrial Issues Specific terrestrial issues discussed by the Staff in the FES-OL were:
1.
Potential fogging and icing and associated impacts from operation of the cooling pond (FES-OL Sections 5.4.1 and 5.5.1.4).
2.
Potential impacts on birds as a result of collisions with transmis-sion lines and as a result of cooling pond operation (FES-OL Section 5.5.1).
NRC monitoring requirements with regard to these terrestrial issues are specified in EPP Section 4.2.
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4 3.0 CONSISTENCY REQUIREMENTS 3.1 Plant Design and Operation A proposed change in Plant design or operation or performance of a test or experiment shall be deemed to involve an unreviewed environmental issue if it concerns (1) a matter which may result in a significant increase in any adverse environmental impact previously evaluated in the FES-OL as modified by Staff's testimony to the Atomic Safety and Licensing Board, Supplements to the FES-OL, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board; or (2) a sigriificant change in effluents or authorized 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) above, which may have a significant adverse environmental impact.
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 issue, and do not involve a change in the EPP.
Changes in Plant design or operation and performance of tests or experiments which do not affect the environment are not subject to the requirements of this EPP. Activities governed by EPP Section 3.3 are not subject to the requirements of this Section.
Before engaging in additional Plant modification or operational activi-ties which may affect the environment, the Licensee shall prepare and record an environmental evaluation of such activity. Activities are miO882-1193c131 3-1 1
excluded from this requirement if all measurable environmental effects of such activities are confined to onsite areas previously disturbed during site preparation and Plant construction. When the evaluation indicates that such activity involves an unreviewed environmental issue, 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 EPP, such activity and change to the EPP may be implemented only in accordance with an appropriate license amendment as set forth in EPP Section 5.3.
The Licensee shall maintain records of changes in Plant design or operation and of tests and experiments carried out pursuant to this Section. These records shall include a written evaluation which provide bases for the determination that the change, test, or experiment does not involve an unrevieved environmental issue nor constitute a decrease in the effectiveness of this EPP to meet the objectives specified in EPP Section 1.0.
The Licensee shall include as part of the Annual Environmental Operating Report (EPP Section 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.
3.2 Reporting Related to the NPDES Permit Violations of the NPDES Permit (pursuant to Section 402* of the Clean Water Act) shall be reported to the NRC by providing copies of the
- As stated in a letter from the Michigan Department of Natural Resources (Tanner) to the NRC (Regan) dated May 17, 1979, issuance of the NPDES Permit also constitutes the State's certification for this facility pursuant to Section 401(a)(1) of the Clean Water Act.
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reports submitted in accordance with the NPDES permit. The Licensee shall also provide the NRC with copies of the results of the studies described in EPP Section 2.1 as conducted in accordance with the NPDES Permit when they are submitted to the permitting agency.
Changes to or renewals of the NPDES Permit shall be reported to the NRC within 30 days following the date the Licensee is notified in writing of the approved change or renewal.
If the Permit, 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.
The NRC shall be notified of changes proposed by the Licensee to the effective NPDES Permit by providing NRC with a copy of the proposed change when 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 with a copy of its application for renewal of the NPDES Permit when the application is submitted to the permitting agency.
3.3 Changes Required for Compliance With Other Environmental Regulations Changes in Plant design or operation or performance of tests or i
l experiments required to achieve compliance with other Federal, State, or local environmental regulations are not subject to requirements of EPP Section 3.1.
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4.0 ENVIRONMENTAL CONDITIONS 4.1 Unusual or Important Environmental Events Amy observation of an unusual or important event that indicates or could result in significant environmental impact casually related to Plant operation shall be recorded and 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 per EPP Section 5.4.2.
The following are possible 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, excessive losses to agricultural crops from avifauna, excessive fish kills in the river, 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.
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4.2 Environmental Monitoring 4.2.1 Fog and Ice Due to the Cooling Pond The objectives of this monitoring program are to document the occur-rence of fog and icing conditions at strategic locatione in the Plant vicinity and to determine if there are offsite changes in fog and icing occurrences due to Plant operations.
The first year of the monitoring program will be initiated on October 1 following commercial operation of Unit 2.
The second year of the monitoring program will be initiated on October 1 following commercial operation of Unit 1 (two years total).
The operational program employs the same procedures used in the pre-operational program but with added instrumentation. Visiometer determined visibility as well as air temperature and relative humidity will be recorded at four locations about the cooling pond all year long. The water temperature of the pond will be measured at several points. Appropriate wet and dry bulb temperatures will be measured at poin';s of interest.
Trained onsite observers will conduct fog observations during the daylight hours of the fog season (October through March).
In addition to fog data, these observations will include ice on roadways or on vertical surfaces, snow and clouds formed by the pond, and other pertinent meteorological conditions that cannot be recorded by instruments. The onsite observers also will determine whether detected fog is pond produced, naturally occurring, or is due to other causes.
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The observers' daily schedule will vary to account for the changing length of daylight and prevailing meteorological conditions.
In general, the period covered will be from sunrise to sunset, seven days a week.
Results of this program shall be presented in the Annual Environmental Operating Report (EPP Section 5.4.1).
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1 4.2.2 Vegetation Effects Due to Icing The objective of this survey is to determine if icing damage affecting trees and shrubs in the vicinity of the Plant is attributable to the vapor plume from the cooling pond.
This program will be initiated and coordinated with the fog and ice i
monitoring program of EPP Section 4.2.1.
Color infrared aerial photographs taken in June 1981 documented ex-i 1
isting preoperational cover and vegetation damage syndromes within 3 km i
of the cooling pond. Ground-truth work in 1982 confirmed the 1981 photographic baseline and updated the preoperational vegetation damage 1
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syndromes in the vicinity of the Plant. Comparison of this baseline I
information with visual and photographic documentation of icing i
conditions and vegetation damage during operational icing events will provide the basis for assessing the effect of icing attributable to Plant operation.
Results of this program shall be presented in the Annual Environmental Operating Report (EPP Section 5.4.1).
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4.2.3 Effect of Cooling Pond on Avifauna The objective of this survey is to assess the impact of Plant operation on resident and migratory waterbird populations using the cooling pond.
i The monitoring program will be in effect during the second, third, and fourth years of full scale operation (both Units 1 and 2). Biennial sampling will monitor the anticipated gradual buildup of a resident and/or overwintering waterbird population; monitoring immediately following operation of one or both units may not provide sufficient in-formation to assess the long term impacts of the Plant and its facilities.
Monitoring is planned for the Plant site, transmission structures in the immediate vicinity, and the cooling pond /Dow tertiary treatment pond complex. Monitoring will include population estimates by total or bounded counts, observations of waterbird activity, and observations of mortality and morbidity. Approximately 40 monitoring periods will be logged per year (about 6 in summer, 6-8 in winter, and 24-26 during spring and fall migration). During spring and fall migration, intervals between monitoring of 7-10 days will be used. These short intervals correspond to periods of peak use. Six to eight winter counts should be sufficient to monitor stable winter populations and detect changes. During the period of low summer use, monitoring will be conducted less frequently.
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5.0 ADMINISTRATIVE PROCEDURES i
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5.1 Review and Audit l
3 The Licensee shall provide for review and audit of compliance with this EPP. The audits shall be conducted independently of the individual or groups responsible for performing the specific activity. A description of the organizational structure to achieve the independent review and audit function and the results of the audit activities sh:ll be maintained and made available for inspection.
5.2 Records Retention Records and logs relative to the environmental aspects of Plant opera-tion 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.
l Records of modifications to Plant structures, systems and components i
i determined to potentially affect the continued protection of the l
l 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.
l 5.3 Cnanges in Environmental Protection Plan Requests for changes in this EPP shall include an assessment of the environmental impact of the proposed change and a supporting l
justification.
Implementation of such changes in the EPP shall not l
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commence prior to NRC approval of the proposed changes in the form of a license amend:: lent incorporating the appropriate revision to this EPP.
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 for Unit 2.
The report shall include summaries and analyses of the results of the environmental protection activities required by EPP Section 4.2 for the report period, including a comparison with preoperational studies, operational controls (as appropriate), and previous environmental monitoring reports. The report also shall include 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 condition.
The Annual Environmental Operating Report shall also include:
a.
A list of EPP noncompliances and the corrective actions taken to remedy them.
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b.
A list of all changes in Plant design or operation, tests, and experiments made in accordance with EPP Section 3.1 which involved an unreviewed environmental issue.
c.
A list of nonroutine reports submitted in accordance with EPP Section 5.4.2.
In the event that some results are not available by the report due date, the report shall be submitted noting the missing results and explaining the omission. The missing data shall be submitted as soon as possible in a supplementary report.
5.4.2 Nonroutine Reports A written report shall be submitted to the NRC within 30 days of occurrence of unusual or important environmental events (EPP Section 4.1).
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) i l
indicate the action taken to correct the event, (d) indicate the l
l corrective action taken to preclude repetition of the event and to t
I prevent similar occurrences involving similar components or systems, and (e) indicate the agencies notified and their preliminary responses.
j Events reportable under this Section which also require reports to I
other Federal, State, or local agencies shall be reported in accordance with those reporting requirements in lieu of the requirements of this Section. The NRC shall be provided with a copy of such report when it is submitted to the other agency.
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