ML20076F103

App B Tech Specs Re Environ Protection Plan (Nonradiological)

ML20076F103
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/20/1983
From:	PUBLIC SERVICE CO. OF COLORADO
To:
Shared Package
ML20076F091	List: ML20076F088 ML20076F099 ML20076F103
References
NUDOCS 8306010419
Download: ML20076F103 (12)

Text

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Fort St. Vrain #1 hon-Radiological Technical Specifications Amendment #

Cover Sheet - Appendix B Page 1 of 1 APPENDIX B TO OPERATING LICENSE NO. DPR-34 FORT ST. VRAIN !1UCLEAR GENERATING STATION PUBLIC SERVICE COMPANY OF COLORADO DOCKET NO. 50-267 ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL) 8306010419 830520 DR ADOCK 0500026

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Technical Specifications Amendment #

Page 1 of 9 i

1.0 OBJECTIVES OF THE ENVIRONMENTAL PROTECTION PLAN The Environmental Protection Plan (EPP) is to provide for protection of environmental values during operation and additional construction of the nuclear facility. The principle l objectives of the EPP are as follows:

a) Verify that the plant is operated in an environmentally acceptable manner, as_ established by the Final Environmental Statement (FES) and other Nuclear Regulatory Commission environmental impact assessments.

b) Coordinate Nuclear Regulatory Commission requirements and maiatain consistency with other Federal, State, and local reqLirements for environmental protection.

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.c) Keep the Nuclear Regulatory Commission informed of the

> environmental effects of facility operation and additional construction and of actions taken to control those effects.

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Environmental concerns identified in the FES which relate to water quality matters are regulated by way of the licensee's NPDES permit.

2.0 ENVIRONMENTAL PROTECTION ISSUES In the FES-OL, the staff considered the environmental impacts associated with the operation of the Fort St. Vrain Station.

Certain environmental issues were identified which required i

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study or license conditions to resolve environmental concerns

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Page 2 of 9 and to assure adequate prctection of the environment. The Appendix B Environmental Technical Specifications (ETS) issued with the licenses included discharge restrictions and monitoring programs to resolve the issues. Prior to issuance of this EPP, the requirements remaining in the ETS were:

a) Protection of the aquatic environment by limiting thermal stress to aquatic organisms.

b) Protection of aquatic life by limiting the release of chemicals from plant operation.

c) The need for aquatic monitoring programs to confirm that effects on phytoplankton, periphyton, plankton, benthos, and fish due to plant operation are no greater than anticipated.

d) The need for studies to document. levels of intake entrainment and impingement in relation to the densities of important species in the plant vicinity.

Aquatic issues are now addressed by the effluent limitations and monitoring requirements contained in the effective NPDES Permit issued by the State of Colorado. The Nuclear Regulatory Commission will rely on this agency for regulation of matters involving water quality and aquatic biota.

Fort St. Vrain #1 Non-Radiological

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Page 3 of 9 2.1 Terrestrial Issues The ETS also contained the following programs related to protection of the terrestrial environment:

a) Surveillance programs to determine vegetation composition, bird and small mammal populations, amphibian and reptile distribution, and distribution of terrestrial invertebrates.

b) Special programs were undertaken to: 1) examine vegetation tissue changes related to cooling tower drift, and 2) examine heavy metal uptake by a common resident mammal and amphibian species.

The Nuclear Regulatory Commission requirements for Issue a) and b)2) have been completed and are terminated by the appraisal prepared in conjunction with preparation of this EPP. The requirements with regard to Issue b)1) are specified in Subsection 4.2 of this EPP.

3.0 CONSISTENCY REQUIREMENTS 3.1 Plant Design and Operation The licensee may make changes in station design or operation or perform tests or experiments affecting the environment provided such changes, tests, or experiments do 1

not involve an unreviewed environmental question. Changes in plant design or operation or performance of tests or

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Page 4 of 9 experiments which do not affect the environment are not subject to this requirement.

Before engaging in construction or operational activities which may affect the environment, the licensee shall perform an environmental evaluation of such activity.*

When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shall provide a written evaluation of such activities and obtain prior approval from the Nuclear Regulatory Commission.

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 as modified by staff's testimony to the Atomic Safety and Licensing Board, supplements to the FES, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board; or 2) a significant change in effluents or 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) of this subsection, which may have a significant adverse environmental impact.

• Activities are excluded from this requirement if all measurable non-radiological effects are confined to the on-site areas previous'y disturbed during site preparation, plant construction, and previous plant operation.

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Page 5 of 9 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 provides bases for the determination that the change, test, or experiment 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.

3.2 Reporting Related to the NPDES Permit and State Certification (Pursuant to Section 401 of the Clean Water Act) a) Violations of the NPDES Permit or the State 401 Certification conditions shall be reported to the Nuclear Regulatory Commission by submittal of copies of the reports required by the NPDES Permit or State 401 Certification.

b) The licensee shall provide the Nuclear Regulatory Commission with a copy of any 316(a) or (b) studies and/or related documentation at the same time it is submitted to the permitting agency.

c) Changes and additions to the NPDES Permit or the State 401 Certification shall be reported to the Nuclear Regulatory Commission within 30 days following the date the change is approved. If a permit or

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Page 6 of 9 certification, in part or in its entirety, is appealed and stayed, the Nuclear Regulatory Commission shall be notified within 30 days following the date the stay is granted.

d) The Nuclear Regulatory Commission shall be notified of changes to the effective NPDES Permit proposed by the licensee by providing the Nuclear Regulatory Commission with a copy of the proposed change at the same time it is submitted to the permitting agency. The licensee shall provide the Nuclear Regulatory Commission with a 4

copy of the application for renewal of the NPDES Permit at the same time the application is submitted to the

permitting agency.

3.3 Changes Required for Compliance with Other Environmental Regulations Changes in plant design or operation and performance of tests or experiments which are required to achieve compliance with other Federal, State, or local l

environmental regulations are not subject to the requirements of Section 3.1.

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Page 7 of 9 4.0 ENVIRONMENTAL CONDITIONS 4.1 Significant Environmental Events Any occurrence of a significant event that indicates or could result in significant environmental impact causally related to station operation shall be recorded and promptly reported to the Nuclear Regulatory Commission 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 1) describe, analyze, and evaluate the event, including extent and magnitude of the impact and plant operating characteristics, 2) describe the probable cause of the event, 3) indicate the action taken to correct the reported event, 4) indicate the corrective action taken to preclude repetition of the event and to prevent similar occurrences involving similar components or systems, and

5) indicate the agencies notified and their preliminary responses.

Events reportable under this subsection which also require

. reports to other Federal, State, or local agencies shall be reported in accordance with those reporting requirements in lieu of the requirements of this subsection. The Nuclear Regulatory Commission shall be provided a copy of such a

Fort St. Vrain #1 Non-Radiological Technical Specifications Amendment #

Page 8 of 9 report at the same time it is submitted to the other agency.

The following are examples of significant environmental events: excessive bird impaction events; on-site plant or animal disease outbreaks; mortality or unusual occurrence of any species protected by the Endangered Species Act of 1973; unusual fish kills; and increase in nuisance organisms or conditions.

4.2 Aerial Remote Sensing Vegetation, communities of the site' and vicinity within two kilometers of the cooling towers in all directions shall be aerially photographed to detect and assess the significance of damage, or lack thereof, as related to cooling tower drift dispersions. Color infrared photography shall be utilized by low altitude aerial overflight during August or September, whichever corresponds to the height of the growing season for most agricultural crops in the area. A scale of at least 1" to 2000' will be used which will permit the identification of vegetative damage or impacted features over relatively small areas of terrain. Some circumstances may warrant inspection of photographs discerning individual trees.

Aerial photographic monitoring shall be conducted during the August / September period after the station has operated at a capacity factor of greater than 50% during the months

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Page 9 of 9 of May, June, July, and the portions of August and September prior to the phot'ographic date. Following the first monitoring period, the program shall be repeated during appropriate alternate years for two additional aerial photographic surveys. A report shall be submitted within 90 days following each aerial photographic monitoring period. The report shall contain a description of the program results and interpretative analyses of environmental impacts. Photographs shall be interpreted to ,

ascertain stress in vegetation as a function of distance from the cooling tower for each photographic period and for.

changes in the size of any impacted area from the first photographic period to later photographic periods.

Photographic interpretations shall be verified by ground inspection surveys to confirm areas of indicated stress and non-stress. Results reported shall contain information encompassing, but not limited to the following: ground inspection verification data; time of day; film types; and one set of resultant color transparencies encompasing an area within approximately a two kilometer radius of t,1e cooling tower.

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ATTACHMENT 2 SIGNIFICANT HAZARDS CONSIDERATIONS ANALYSIS u

SIGNIFICANT HAZARDS CONSIDERATIONS ANALYSIS Since the changes to Appendix B of the Fort St. Vrain Technical Specifications are proposed at the request of the Nuclear Regulatory Commission to provide better conformance with present NRC practices, it is apparent that no significant hazards considerations are involved.

Based on the above, operation of Fort St. Vrain in accordance with the proposed changes will not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

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