HL-4723, Application for Amends to Licenses DPR-57 & NPF-5,replacing Environ TS W/Environ Protection Plan (Nonradiological) & Revising OLs to Reflect Changes
| ML20077D885 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/02/1994 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20077D886 | List: |
| References | |
| HL-4723, NUDOCS 9412090227 | |
| Download: ML20077D885 (31) | |
Text
4 Georg:a Power Company
. 40 invemess Corder Parkway Post Office Box 1295 Birmingham. Alabama 35201 Telephono 205 877-7279 m
J. T. Deckham, Jr.
Vice President - Nuclear GeorgiaPower Hatch Project te swtwn ekttnc systom Docket Nos. 50-321 HL-4723 50-366 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Edwin I. Hatch Nuclear Plant Request to Revise Technical Specifications:
Appendix B Replacement of Environmental Technical Specifications With the Environmental Protection Plan (Nonradiological)
Gentlemen:
In accordance with the provisions of 10 CFR 50.90, as required by 10 CFR 50.59(c)(1),
Georgia Power Company (GPC) hereby proposes changes to the Plant Hatch Units 1 and 2 Environmental Technical Specifications, Appendix B to Operating Licenses DPR-57 and NPF-5.
The proposal involves replacing Appendix B - Environmental Technical Specificitions (ETS) with an Environmental Protection Plan (Nonradiological) and revising the Operat ng Licenses to reflect these changes. The proposed changes are administrative in nature, altering only the format and location of programmatic controls and procedural details relative to nonradiological environmental monitoring.
Enclosure I describes the proposed changes, the basis for each change, and the circumstances necessitating each change. Enclosure 2 details the bases for GPC's determination the proposed changes do not involve a significant hazards consideration. Enclosure 3 is an environmental assessment of the proposed changes. Enclosure 4 provides page change instructions for incorporating the proposed changes. The proposed Environmental Protection Plan, and the associated markups of the existing Environmental Technical Specifications pages and the i I
Operating Licenses follow Enclosure 4.
I Georgia Power Company requests the proposed amendments be issued with the same effective i date as the Improved Technical Specifications (ITS) so implementation will be concurrent with l ITS implementation. I l
e g o e, . . 3 u a t) L e l
9412090227 941202 . I PDR ADOCK 05000321 P PDR
GeorgiaPower A U.S. Nuclear Regulatory Commission' Page Two December 2, 1994
. In accordance with the requirements of 10 CFR 50.91, a copy of this letter and all applicable enclosures will be sent to the designated State official of the Environmental Protection Division '
of the Georgia Department ofNatural Resources.
Mr. J. T. Beckham,'Jr. states that'he is' duly authorized to e.secute this oath on beFalf of Georgia Power Company, and to the best of his knowledge and belief, the facts set forth .n this letter are true.
GEORGIA POWER COMPANY BY: cb N=
() J. T. Beckham, Jr. . i Sworn to andsubscribed before me this 2 "' day of ,1994.
~ h Notary Public My Commission Expires! 8/S/97 KAU/ku
Enclosures:
- 1. Basis for Change Request
- 2. 10 CFR 50.92 Evaluation
- 3. Environmental Assessment
- 4. Revision Insertion Instnactions cc: (See next page.)
HL-4723
I GeorgiaPower A U.S. Nuclear Regulatory Commission Page Three December 2, 1994 cc: Georgia Power Comrmnv Mr. H. L. Sumner, Nuclear Plant General Manager NORMS U.S. Nuclear Reerdatorv Commission. Washington. D.C.
Mr. K. Jabbour, Licensing Manager - Hatch Mr. C. Grimes, Technical Specifications Branch U.S. Nuclear Regulatorv Commission. Region 11 Mr. S. D. Ebneter, Regional Administrator ;
Mr. B. L. Holbrook, Senior Resident Inspector - Hatch State ofGeorzia Mr. J. D. Tanner, Commissioner - Department of Natural Resources l
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Enclosure 1 Edwin I. Hatch Nuclear Plant Request to Revise Technical Specifications Basis for Change Request Backeround The proposed amendments entail replacing Appendix B - Environmental Technical Specifications (ETS) with an Environmental Protection Plan (EPP) (NonradiologiceD containing the programmatic controls currently residing in the ETS, and revising the operating licenses to change the Appendix B reference from ETS to EPP. Appropriate plant procedures will serve as implementing documents. The proposed amendments clarify and streamline ETS requirements, and revise the ETS format to be consistent with the current EPP format. The proposed amendments are administrative in nature, altering the format and location of programmatic controls and procedural details relative to nonradiological environmental monitoring. The proposed changes will not reduce the level of nonradiological environmental protection at Plant Hatch.
Currently, Unit 1 and Unit 2 have separate, but identical, ETS. Therefore, the proposed EPP is a common document, identical for both units. The objective of the proposed EPP is to protect the environment at the Plant Hatch site and immediate adjacent areas by ensuring the following:
- 1. The plant is operated in an environmentally acceptable manner.
- 2. NRC requirements are reviewed to assure consistency with other Federal, State, and local environmental protection requirements.
- 3. The NRC is informed of any significant environmental effects causeo Ly facility operation and of actions taken to control these effects.
The following paragraphs present the wording in each section of the current Plant Hatch i ETS, the proposed EPP wording, and the bases for the proposed changes. Where no ETS section exists, the proposed EPP wording and the bases for the proposed changes are provided. The proposed EPP wording appears in italics for clarity.
PROPOSED CIIANGE 1 ETS SECTION 1.0 l
ETS Section 1.0, " Definitions," defines terms associated with the content of the ETS. l This section will be deleted.
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Enclosure 1 Basis for Change Request 1 Proposed EPP Section 1.0 I
The EPP does not contain a definitions section. EPP Section 1.0, which is consistent with the current EPP format, states the objectives of the proposed Plan as follows:
1.0 Objectives of the Environmental Protection Plan The Environmental Protection Plan (EPP) is to provideforprotection ofnonradiological environmental values during operation of the nuclearfacility. The principal objectives :
of the EPP are asfollows:
(1) Verify that thefacility is operated in an environmentally acceptable manner, as established by the Final Environmental Statements (FES) and other NRC environmentalimpact assessments.
(2) Coordinate NRC requirements and mamtain consistency with other Federal, State and local requirementsfor environmentalprotection.
(3) Keep NRC informed of the environmental effects offacility construction and operation and ofactions taken to control those effects. l Environmental concerns identified in the FES which relate to water quality matters are l regidated by um' of the licensee 's NPDESpermit. l i
Basis for Proposed Change 1 i
The definitions contained in ETS Section 1.0 were originally provided to assist in consistent interpretations of the technical requirements contained in the document. The majority of the technical monitoring requirements once contained in the ETS, to which l these definitions were applicable, have been removed In addition, the proposed EPP does i not include definitions since documents now exist which provide interpretation and ;
clarification of these requirements. j i
PROPOSED CIIANGE 2 ETS SECTION 2.0 i I
Section 2.0, " Limiting Conditions for Operation," was deleted from the current Plant Ilatch ETS. i HL-4723 El-2
Enclosure 1 Basis for Change Request Pronosed EPP Section 2.0 i
l The following wording for EPP Section 2.0 is proposed:
2.0 EnvironmentalProtectionIssues In the FinalEnvironmentalStatements dated October,1972 andMarch,1978, the staff
,. considered the environmentalimpacts associated with the operation ofEdwin I. Hatch Nuclear Plant (HNP) Units 1 and 2. Certain environmentalissues were identifiedwhich .
required study, or license conditions to resolve concerns and assure adequate protection of the environment.
2.1 AquaticIssues Initialpost-operationalstudies to evaluate impacts ofstation intake anddischarge effects .
are complete. No additional aquatic momtormg requirements are necessary.
1 i 2.2 TerrestrialIssues l
l Initial jx>st-operational studies to evaluate terrestrial impacts are complete. No j l
l additional terrestrial studies or monitoring requirements are necessary i
Basis for Proposed Change 2
! The Edwin I. Hatch Unit 2 Final Environmental Statement (FES) (NUREG-0417), dated l March 1978, specified certain requirements for post-operational studies and monitoring to verify the effects of two unit operation on the environment. Specifically, these requirements included:
- 1. A monitoring program to verify the impact of two unit operation on benthic organisms and impingementlentrainment effects of the intake.
- 2. A study to determine the quantity and type of corrosion products in the cooling l system discharge.
l These studies were completed in 1981 and submitted to the NRC for review. The aquatic monitoring requirements were subsequently removed from the Unit 1 ETS by License -
Amendment No. 94 and from the Unit 2 ETS by License Amendment No. 31, both dated March 11,1983.
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Enclosure 1 '!
Basis for Change Request
- 3. A monitoring program to determine the effects of salt deposition on vegetation associated with cooling tower drin. The program consisted of a 4-year extension of the Unit I study,
'4. A 4-year surveillance on the Hatch-Bonaire. transmission corridor to verify i stabilization of erosion and/or vegetation damage.
These requirements were also removed from the Unit I and Unit 2 ETS by License ,
Amendment Nos. 94 and 31. !
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- 5. A program to conduct aerial remote sensing to verify the long-term effects of cooling tower drift This requirement was removed from the Unit I and Unit 2 ETS by License Amendment Nos. I15 and 56, respectively, dated September 9,1985. -
The above referenced studies required by the Unit 2 FES actually verify the effects of two i unit operation by extending studies and monitoring requirements of the Unit 1 FES or adding additional requirements to be completed after Unit 2 became operational. As such, the results of the above programs summarize the effects of two unit operation on the ,
environment and support approval of a single two unit EPP in lieu of separate EPP documents for each unit. This language is consistent with the current EPP format.
PROPOSED CHANGFJ ETS SECTION 3.0 .
ETS Section 3.0, " Environmental Monitoring," was previously deleted from the Plant Hatch ETS.
Proposed EPP Section 3.0 3.0 Consistency Requirements ,
Basis For Proposed Change 3 i
This change is consistent with the current EPP format.
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Enclosure 1 ;
Basis for Change Request PROPOSED CHANGE 4 j
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Proposed EPP Section 3.1 )
l 3.1 Plant Design and Operation l The licensee may make changes inplant design or operation orperform tests or experirrents affecting the environment provided that such activities do not involve an unreviewed environmental question and do not involve a change in the EPP*, Changes in plant design or operation orperformance of tests or experiments which do not affect the environment are not subject to the requirements of this EPP Activities governed by Section 3.3 are not subject to the requirements of this Section.
Before engaging in additional construction or operational activities which may :
sigmficantly affect the environment, the licensee shallprepare and record an environmental evaluation ofsuch activity. Activities are excludedfrom this requirement ifall meamrable nonradiological environmental effects are confined to the on-site areas ,
previously disturbed during site preparation andplant construction. When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shallprovide written evaluation ofsuch activity and obtain prior NRC
, approval. When such activity inmives a change in the EPP, such activity and change to the EPP may be implemented only in accordance with an appropriate license amendment as setforth in Section 5.3 of this EPP.
A proposed change, test or experiment shall be deemed to invoh'e an unreviewed I environmental question ifit concerns: (1) a matter which may resr' s sigmficant increase in any adverse environmentalimpactpreviously evaluateJ ... :FES, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing i Board; or (2) a sigmficant change in effluents orpower level; or (3) a matter, not previously reviewed and evaluated in the documents specified in (1) of this Subsection, which may have a sigmficant adverse environmentalimpact.
Ihe licensee shall maintain records of changes in plant design or operation and of tests and experiments carried outpursuant to this Subsection 7hese records shallinclude written emluations which provide basesfor the determination that the change, test, or experiment does not invoh'e an unreviewed environmental question or constitute a decrease in the effectiveness of the EPP to meet the objectives specifiedin Section 1.0. i 7he licensee shall include as part of the Annual Environmental Operating Report (per l l
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Enclosure 1 Basis for Change Request Subsection 5.4.1) briefdescriptions, analyses, interpretations, and evahrations ofsuch changes, tests and experiments.
- Thisprovision does not relieve the licensee of the requirements of10 CFR 50.59.
Basis for Proposed Channe 4 This change is consistent with the current EPP format, thereby defining actions related to Plant Design and Operation. This section functionally replaces ETS Section 5.5.3,
" Changes in Procedures and Station Design or Operation" ETS Section 5.5.3 addresses procedural changes, as well as changes in plant design or operation, or tests or experiments. The requirement to review procedural changes is specifically addressed in ETS Section 5.5.3(e) and defines the procedural review process t and personnel who must approve the revisions. This requirement is not consistent with the language contained in the EPP format which does not specifically define procedure -
review and approval requirements. Procedures which implement actions associated with ,
plant design and operation, and meet the criteria for review as changes in plant design or i operation, or tests or experiments will be reviewed under EPP requirements. The matrix 1 for review and approval responsibility will be defined in appropriate plant procedures and !
documents. ;
PROPOSED CHANGE 5 Proposed EPP Section 3.2 l
3.2 Reporting Related to the NPDES Permit andState Certification :
Changes to, or renewals of the NPDES Permit or the State certification shall be reported j to the NRC within 30 daysfollowing the date the change or renewalis approved. Ifa 1 permit or cernpcation, in part or in its entirety, is appealed and stayed, the NRC shall be i' notified within 30 daysfollowing the date the stay is granted.
1he licensee shall notify the NRC of changes to the effective NPDES Permit proposed by the licensee byproviding NRC with a copy of the proposed change at the same time it is submitted to the permitting agency. The licensee shallprovide the NRC a copy of the application for renewal of the NPDES Permit at the same time the application is submitted to thepermitting agency.
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Enclosure 1 Basis for Change Request Basis for Proposed Chanec 5 This change, which functionally replaces ETS Sections 5.4 and 5.6.3.2, is consistent with the current EPP format. Conditions and monitoring requirements for the protection of water quality and aquatic biota are addressed in the NPDES Permit originally issued by EPA Region IV and implemented by the State of Georgia Department of Natural Resources - Environmental Protection Division. The proposed EPP language provides a mechanism within the EPP to ensure the NRC is informed of activities under the purview of the NPDES Permit, while recognizing the role of the EPA and the State of Georgia in matters involving implementation and enforcement of permit requirements.
PROPOSED CHANGE 6 Proposed EPP Section 3.3 3.3 Changes Requiredfor Compliance with Other EnvironmentalRegidations Changes inplant design or operation andperformance of tests or experiments which are l required to achieve compliance with other Federal, State, and local environmental l
regidations are not subject to the requirements ofSection 3.1. '
Basis for Proposed Channe 6 1
This section functionally replaces a portion of the requirements in ETS Section 4.3,
" Exceeding Limits of Other Relevant Permits," relative to reporting associated with matters not of NEP.A concern.
PROPOSED CHANGE 7 ETS SECTION 4.0 ETS Section 4.0,"Special Surveillance and Study Activities," has no text and thus, will be deleted.
Proposed EPP Section 4.0 The following wording for EPP Section 4.0 is proposed:
1.0 Environmental Conditions l 1
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Enclosure 1 Basis for Change Request :
1 Basis for Proposed Channe 7 ;
1 This change is consistent with the current EPP format. l PROPOSED CIIANGE 8 ETS SECTION 4.1 ETS Section 4.1, "Erosit n Control Inspection," contains no text and thus, will be deleted.
Proposed EPP Section 4.1 The following wording is proposed as EPP Section 4.1 which will effectively replace ETS Section 4.2, " Unusual or Important Event Requirements," of the current ETS.
4.1 Umisual or Important Environmental Events 1 Any occurrence ofan unusual or imoortant event that indicates or couldresult in significant environmentalimpact causally related toplant operation shall be recorded 1 and reported to the NRC within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />sfollowed by a written report per Subsection 5.4.2. Thefollowingare examples: excessive bird impaction events; onsiteplant or animal disease outbreaks; mortality or unusual occurrences ofany species protected by :
the Endangered Species Act of1973; fish kills or impingement events on the intake screens; increase in nuisance organisms or conditions; unanticipated or emergency i discharge ofwaste water or chemicalsubstances; and damage to vegetation restdting from cooling tower operations.
I No routine monitoringprograms are required to implement this condition. i l
Basis for Proposed Change 8 l This change, which provides a reference to the reporting requirements associated with unusual or important environmental events, is consistent with the current EPP format.
PROPOSED CIIANGE 9 I
ETS SECTION 4.2 ETS Section 4.2 " Unusual or Important Events Requirements" has been relocated to Section 4.1 of the proposed EPP. (See discussion above.)
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l Enclosure 1 Basis for Change Request ;
Proposed EPP Section 4.2 1
4.2 EnvironmentalMonitoring l 4.2.1 AquaticMonitoring Ihe ce-tifications andpermits required under the Clean Water Actprovide mechanisms forpro >tecting water quality and, indirectly, aquatic biota. The NRC willrely on the dnision made by the State ofGeorgia under the authority of the Clean Water Actfor any requirementsfor aquatic monitoring.
4.2.2 TerrestrialMonitoring Terrestrial monitoring is not required.
4.2.3 Maintenance of Transmission Line Corridors 7he use ofherbicides within the Edwin L Hatch Nuclear Plant transmission line corridors shall conform to the approved use ofselected herbicides as registered by the Environmental Protection Agency and a;> proved by the State of Georgia authorities and applied as directed on the herbicide label.
Records shall by maintained in accordance with EPA or State of Georgia requirements by the licensee's Transmission Operating and Maintenance Department concerning herbicide use. Such records shall be made readily available to the NRC upon request.
7here shall be no routine reporting requirement associated with this condition.
Hasis for Proposed Chance 9 As discussed in the narrative for proposed EPP Section 2.0, aquatic monitoring requirements were removed from the ETS by license amendments. The wording in EPP Section 4.2.1 is consistent with the current EPP format. As noted in proposed EPP Sections 2.0 and 4.2.2, there are no terrestrial monitoring requirements. The ETS do not contain requirements for transmission line maintenance; however, EPP Section 4.2.3 was added to be consistent with the Unit 2 FES and the current EPP format.
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t Enclosure 1 Basis for Chnge Request i PROPOSED CIIANGE 10 :
ETS SECTION 4.3 ETS Section 4.3, " Exceeding Limits of Other Relevant Permits," has been deleted. This requirement is satisfied in EPP Sections 3.3 and 4.1. .
Basis for Proposed Channe 10 ETS Section 4.3 provides for reporting of exceedances oflimits for other relevant permits associated with reportable events. This requirement has been merged into EPP Section -
4.1, " Unusual or Important Environmental Events", where recording and reporting of i events that could result in significant environmental impact causally related to plant ,
operation are required. !
PROPOSED CHANGE 11 !
ETS SECTIONS 5.0,5.1,5.2 These sections, which address Administrative Controls, Responsibility, and Organization, respectively, have been deleted from the proposed document. This change is consistent with the current EPP format.
Proposed EPP Section 5.0 5.0 Administrative Procedures Hasis for Proposed Change 11 This change is consistent with the current EPP format.
PROPOSED CilANGE 12 Proposed EPP Section 5.1 5.1 Review and Audit 7he licensee shallprovidefor review and audit ofcompliance with the EPP. The audits shall be conducted independently of the individual or groups responsibleforperforming the specific activity. A description of the organi:ation structure utili:ed to achieve the independent review and auditfunction and restdts of the audit activities shall be maintained and made amilablefor inspection.
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9 Enclosure 1 Basis for Change Request )
Basis for Proposed Channe 12 The proposed section functionally replaces ETS Sections 5.3, 5.3.1, and 5.3.2. ETS I Section 5.3 specifically outlined the audit function and organizational structure. The proposed EPP specifies that the structure be defined, but allows it' to be maintained in j implementing documents, such as plant procedures. The functional structure and. .
requirements defined in current ETS Sections 5.3.1 and 5.3.2 will be maintained in appropriate pirat implementing documents.
PROPOSED CifANGE 13 ;
ETS SECTION 5.3 ETS Section 5.3," Review and Audit," and associated subsections 5.3.1.1 through 5.3.1.4 l and 5.3.2 have been functionally replaced by EPP Section 5.1. See Proposed Change 12 I for the Basis ofChange discussion.
ETS SECTION 5.4 ETS Section 5.4, " State Permits and Certificates," has been functionally replaced by EPP j Section 3.2. The bases for the changes are discussed in the narrative for EPP Section 3.2.
ETS SECTION 5.5 ETS Sections 5.5, " Procedures;" 5.5.1, " Quality Assurance Results;" 5.5.2, " Compliance with Procedures;" and 5.5.4, "NRC Authority to Require Revisions," have been deleted from the proposed EPP. ETS Section 5.5.3 will be functionally replaced by EPP Section 3.1, with the exception of 5.5.3(e) which will not be replaced.
Basis for Pronosed Change 13 This change is consistent with the current EPP format which does not specify detailed organizational and procedural responsibilities. Such information shall be contained in appropriate plant implementing documents, consistent with EPP format. The functional stmeture and requirements reflected in the sections listed above will be maintained in appropriate plant implementing documents.
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i Enclosure 1 Basis for Change Request l
PROPOSED CHANGE 14 ETS SECTION 5.6 ETS Sections 5.6, " Plant Reporting Requirements;" 5.6.1, " Routine Reports;" and 5.6.2, l "Nonroutine Reports," contain the reo*cments for submittal of routine reports (Annual Environmental Surveillance Report) ...a nonrc.. m reports associated with 10 CFR 50.72 and 10 CFR 50.'.3 4qunemm "hese scctions have been deleted and functionally replaced with EPP Sea x '. 4 )
l Pronosed EPP Section 5.4 5.4 Plant ReportingRequirements
- 5. 4.1 Routine Reports An Annual Environmental Operating Report describing implementation of this EPPfor the previousyear shall be submitted to the NRCprior to May 1 of each year. The period of thefirst report shall begin with the date ofissuance of this EPP.
The report shallinclude summaries and analyses of the results of the em>ironmental protection activities required by Subsection 4.2 (ifany) of this EPPfor the reportperiod, including a comparison with relatedpreoperational studies, operational controls (as appropriate), andprevious nonradiological environmental monitoring reports, and an assessment of the observed impacts of theplant operation on the environment. Ifharmful effects or evidence of trends towardirreversible damage to the environment are observed, the licensee shallprovide a detailed analysis of the data and a proposed course ofmitigating action. j The AnnualEnvironmental Operating Report shall also include:
(1) A list ofEPP noncompliances and the corrective actions taken to remedy them. ,
(2) A list of all changes in station design or operation, tests, and experiments made in accordance with Subsection 3.1 which involved a potentially sigmficant ,
unreviewed environmental question. !
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(3) A list of nonroutine reports submitted in accordimce with Subsection 5.4.2.
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i Enclosure 1
- Basis for Change Request j in the event that some results are not available by the report due date the report shall be submitted noting and explaining the missing results. The missing restdts shall be submitted as soon aspossible in a supplementary report.
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- 5. 4.2 Nonroutine Reports ;
A written report shall be submitted to the NRC within 30 days ofoccurrence ofa nonroutine event. The report shall: (a) describe, analy:e, and evaluate the event including extent and magnitude of the impact, andplant operating characteristics; (b) describe the probable cause of the event; (c) indicate the action taken to correct the reported event; (d) indicate the corrective action taken topreclude repetition of the event and to prevent similar occurrences involving similar components or systems; and (e) indicate the agencies notifed 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 l
in lieu of the requirements of this Subsection. The ERC shall be provided with a copy of such report at the same time it is submitted to the other agency.
Basis for Proposed Change 14 The proposed EPP sections functionally replace ETS Sections 5.6,5.6.1 and 5.6.2. The :
reporting date change for the Annual Emironmental Operating Report is consistent with l the current EPP format.
PROPOSED CIIANGE 15 +
ETS SECTIONS 5.6.3, 5.6.3.1, and 5.6.3.2 ETS Section 5.6.3.1, " Changes in Environmental Technical Specifications," has been i functionally replaced by EPP Section 5.3, " Changes in Environmental Protection Plan." l ETS Section 5.6.3.2, " Changes in Permits and Certificates," has been functionally replaced l by ETS Section 3.2," Reporting Related to the NPDES Permit and State Cenificates."
Proposed EPP Section 5.3 ,
i 5.3 Changes in Environmental Protection Plan 1
Requestsfor changes in the EPP shallinclude an assessment of the environmentalimpact i of the proposed change anda supportingjustification. Implementation ofsuch changes l l
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Enclosure 1 Basis for Change Request i in the EPP shall not commence prior to NRC approval of the proposed changes in the l form ofa license amendment incorporating the appropriate revision to the EPP.
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Basis for Proposed Channe 15 j This change is consistent with the current EPP format. See Proposed Change 5 for the :
Basis for Change discussion relative to ETS Section 5.6.3.2. :
PROPOSED CIIANGE 16 ETS SECTION 5.7 ETS Section 5.7," Records Retention," has been functionally replaced by EPP Section 5.2.
Proposed EPP Section 5.2 5.2 RecordsRetention Records and logs relative to the environmental aspects ofstation operation shall be made and retained in a manner convenientfor review and inspection. These records and logs i shall by made available to NRC on request.
t Records ofmodifcations to station structures, systems and components determined to potentially affect the continuedprotection of the environment shall be retainedfor the hfe of the station. All other records, data and logs relating to this EPP shall be retained forfive years or, where applicable, in accordance with the requirements of other agencies.
Basis for Proposed Change 16 i
This change is consistent with the current EPP format.
SUMMARY
AND CONCLUSIONS l
Baseo on the above information, it is concluded that the proposed amendments to replace l the current Unit I and Unit 2 Environmental Technical Specifications with a common Environmental Protection Plan are administrative in nature and do not constitute a matter
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which has significant adverse environmental impact or will result in an unreviewed environmental question. The changes relate to matters involving recordkeeping, reporting,
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and administrative procedures or requirements. No significant change in the type or l
quantity of any efIluent release will result from these changes. i HL-4723 El-14 i
Enclosure 2 Edwin L Hatch Nuclear Plant Request to Revise Technical Specifications 10 CFR 50.92 Evaluation In 10 CFR 50.92(c), the NRC provides the following standards to be used in determining l the existence of a significant hazards consideration:
..a proposed amendment to an operating license for a facility licensed under 10 CFR 50.21(b) or 10 CFR 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment, would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a i significant reduction in the margin of safety.
Georgia Power Company has reviewed the proposed amendments and determined that their adoption will not result in a significant hazards consideration based on the following ,
discussion.
Basis for no significant hazards consideration determination k The proposed changes do not involve a significant hazards consideration for the following reasons:
- 1) 7he proposed amendments do not invoh'e a sigmficant increase in the probability or consequences of an accidentpreviously evahiated.
The proposed changes to the Environmental Technical Specifications (ETS) are administrative in nature, altering only the format and location of programmatic controls and procedural details relative to 'nonradiological environmental values.
The proposed Environmental Protection Plan (EPP) (Nonradiological) contains the programmatic controls now residing in the ETS, with appropriate plant procedures serving as impleme.nting documents. The proposed changes to the operating licenses are also administrative in nature and change the Appendix B reference from ETS to EPP. Compliance with applicable regulatory requirements will be maintained. In addition, the proposed changes do not alter the conditions or assumptions in any of the accident analyses. Therefore, these proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
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Enclosure 2 10 CFR 50.92 Evaluation
- 2) The proposedamendments do not create the possibility of a n.w or different kind of accidentfrom any accidentpreviously evaluated.
The proposed changes to the ETS do not involve any change to the configuration or method of operation of any plant equipment. These proposed changes are administrative in nature and consist of replacing the ETS with an EPP. The proposed changes to the operating licenses are also administrative in nature and change the Appendix B reference from ETS to EPP. Accordingly, no new failure modes have been identified for any plant system or component important to safety nor has any new limiting single failure been identified as a result of the proposed changes. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3) Ihe proposed amendments do not result in a sigmficant reduction in the margin of ,
safety.
The proposed changes to the ETS relate primarily to matters involving recordkeeping, reporting, and administrative procedures or requirements. No significant change in the type or quantity of any efiluent release will result from this action. These changes replace the ETS with an EPP. The proposed EPP contains the programmatic controls now residing in the ETS, with appropriate plant procedures serving as implementing documents to ensure compliance with applicable regulatory requirements. The proposed changes to the operating licenses are also administrative in nature and change the Appendix B reference from ETS to EPP.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Based on the preceding discussion, GPC has determined that the proposed changes to Appendix B - Environmental Technical Specifications do not involve a significant hazards consideration as defined by 10 CFR 50.92 (c).
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IIL-4723 E2-2 i
l Enclosure 3 Edwin 1. Hatch Nuclear Plant Request to Revise Technical Specifications:
Environmental Assessment
Background
In support of clarification and streamlining the current Edwin I. Hatch Unit I and 2 Environmental Technical Specifications (ETS), license amendments are proposed to replace the current ETS with a common Environmental Protection Plan (EPP)
(Nonradiological). In accordance with the requirements of ETS Section 5.6.3.1, Appendix B to Facility Operating Licenses DPR-57 and NPF-5, charges to the ETS must be submitted to the NRC for review and authorization in accordance vith 10 CFR 50.90.
The report must include an evaluation of the environmental impact of the proposed changes and suppo-tingjustification. Pursuant to these requirements, the following environmental assessment and justification for the proposed changes have been developed.
Descrirstion of Chanee The proposed license amendment deletes each unit's existing ETS and replaces them with a common EPP. The objective of the proposed EPP is protect the environment at the Plant Hatch site and immediate adjacent areas by ensuring the following:
- 1. The plant is operated in an environmentally acceptable manner.
- 2. NRC requirements are reviewed to assure consistency with other Federal, State, and local environmental protection requirements.
- 3. The NRC is informed of any significant environmental effects caused by facility operation and of actions taken to control these effects.
Environmental Assessment / Justification Ibr Change The current Plant Hatch ETS have been significantly amended since they were originally issued in that most of the specific nonradiological and all of the radiological monitoring requirements have been removed or relocated to other licensee controlled documents.
The proposed amend:nents relate to changes in recordkeeping, reporting, and administrative procedures or requirements. No significant change in matters associated with the amount or type of any efiluent released offsite will result from the proposed amendments.
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Environmental Assessment Conclusion The proposed amendments are administrative in nature, altering only the format and - ,
location of programmatic controls and procedural details relative to nonradiological ;
matters involving protection of the environment. The level of nonradiological ;
environmental protection at Plant Hatch will not be reduced as the result of these proposed changes. ,
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Enclosure 4 Edwin I. Ilatch Nuclear Plant Request to Revise Technical Specifications Revision Insertion instructians Unit 1 Eage Instruction All Replace Unit 2 Page Instruction All Replace iIL-4723 E4-1
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l APPENDIX B )
To FACILITY OPERATING LICENSE NOS.
DPR-57 and NPF-5 l HATCH NUCLEAR PLANT l UNITS I and 2 GEORGIA POWER COMPANY :
DOCKET NOS. 50-321 and 50-366 ENVIRONMENTAL PROTECTION PLAN (NONRADIOLOGICAL) i l
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Ilatch Nuclear Plant I
. Units 1 and 2 Environmental Protection Plan (Nonradiological)
Table of Contents j Section Page 1.0 Objectives of the Environmental Protection Plan . . . . . . .1-1 2.0 Environmental Protection Issues . . .. . . . . , . .2-1 3.0 Consistency Requirements . . . . . . . . ... . . .3-1 4.0 Environmental Conditions . . . . .... . . . 4-1 5.0 Administrative Procedures.. . . . . . . . . .5-1 l
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1.0 Objectives of the Environmental Protection Plan The Environmental Protection Plan (EPP) is to provide for protection of nonradiological environmental values during operation of the nuc.aar facility. The principal objectives of the EPP are as follows:
(1) Verify that the facility is operated in an environmentally acceptable manner, as established by the Final Environmental Statements (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 environmental effects of facility construction and operation and of actions taken to control those effects.
Environmental concerns identified in the FES which relate to water quality matters are regulated by way of the licensee's NPDES permit.
IIATCII- UNITS 1 AND 2 1-1
l 2.0 Environmental Protection Issues In the Final Environmental Statements dated October,1972 and March,1978, the staff considered the environmental impacts associated with the operation of Edwin I. Hatch Nuclear Plant OINP) Units I and 2. Certain environmentalissues were identified which required study, or license conditions to resolve concerns and assure adequate protection of the environment.
2.1 Aquatic Issues Initial post-operational studies to evaluate impacts of station intake and discharge efTects are complete. No additional aquatic monitoring requirements are necessary.
2.2 Terrestrial Issues Initial post-operational studies to evaluate terrestrialimpacts are complete. No additional terrestrial studies or monitoring requirements are necessary.
IIATCli- UNITS 1 AND 2 2-1
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 that such activities do not involve an unreviewed environmentel question and do not involve a change in the EPP* Changes in plant design er operation or performance of tests or experiments which do not affect the environment are not subject to the requirements of this EPP. Activities governed by Section 3.3 are not subje-et to the requirements of this Section.
Before engaging in additional construction or operational activities which may significantly affect the environment, the licensee shall prepare and record an environmental evaluation of such activity. Activities are excluded from this requirement if all measurable nonradiological environmental effects are confined to the on-site areas previously disturbed during site preparation and plant construction. When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shall provide written evaluation of such activity and obtain prior NRC approval. 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 Section 5.3 of this EPP.
A proposed change, test or experiment shall be deemed to involve an unreviewed environmental question ifit concerns: (1) a matter which may result in a significant increase in any adverse environmental impact previously evaluated in 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; 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.
The licensee shall maintain records of changes in plant design or operation and of tests and experiments carried out pursuant to this Subsection. These records shallinclude written evaluations which provide bases for the determination that the change, test, or experiment does not involve an unreviewed environmental question or constitute a decrease in the effectiveness of the EPP to meet the objectives specified in Section 1.0. The licensee shall include as part of the Annual Environmental Operating Report (per Subsection 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.
- This provision does not relieve the licensee of the requirements of 10 CFR 50.59.
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4 3.2 Reporting Related to the NPDES Permit and State Certification Changes to, or renewals of, the NPDES Permit or the State certification shall be reported to the NRC within 30 days following the date the change or renewal 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.
The licensee shall notify the NRC of changes to the effective NPDES Permit proposed by the licensee by providing 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 submitted to the permitting agency.
3.3 Changes Required for Compliance with Other Environmental Regulations l Changes in plant design or operation and performance of tests or experiments which are required to achieve compliance with other Federal, State, and local environmental regulations are not subject to the requirements of Section 3.1.
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