ML20079P190
| ML20079P190 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 01/24/1984 |
| From: | UNION ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20079P184 | List: |
| References | |
| NUDOCS 8401310120 | |
| Download: ML20079P190 (8) | |
Text
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APPENDIX B l
TO FACILITY OPERATING LICENSE NO.
l CALLAWAY PLANT l
UNIT 1 UNION ELECTRIC COMPANY DOCKET NO. 50-483 !
4 ENVIRONMENTAL PROTECTION PLAN i
NON-RACIOLOGICAL I
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1.0 Objectives of the Envirortmsntal Protection Plan The Environmental Protection Plan (EPP) is to provide for protection of environmental quality during operation of Callaway Plant. 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, NUREG-0813 (FES-OL).
(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 operation and of actions taken to control those effects.
Environmental concerns identified in the FES-OL which relate to water quality matters are regulated by the NPDES permit irsued by the State of Missouri and are not included in the EPP.
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. 2.0' Environmsntal ProtCction Issues In the FES-OL dated Januscy, 1982, the staff considered the environmental impacts associated with the operation of Callaway Plant. Certain environmental issues were identified which required study or license conditions to resolve environmental concerns and to assure adequate protection of the environment.
2.1 Aquatic Issues The NPDES permit required under the Clean Water Act provides the mechanisms for protection of water quality and aquatic biota.
Operational monitoring of plant effluents is required by the NPDES permit issued by the State of Missouri. A fish-impingement and entrainment monitoring program, as required under Section 316 (b) of the Clean Water Act, has been reviewed and approved by the Missouri Department of Natural Resources. NRC will rely on the decisions made by the Missouri Department of Natural Resources, under the authority of the Clean Water Act.
2.2 Terrestrial Issues The specific terrestrial issue raised by the staff in the FES-OL is the need to undertake a limited-term terrestrial monitoring program by means of infrared aerial photography with accompanying ground truth aimed at monitoring the impact of cooling tower drift on the local flora. (FES-OL: Section 5.5.1.6).
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3.0 Consistency Rcquiremsnts 3.1 Plant Design and Operation
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The licensee may make changes in plant design or operation or perform tests or experiments affecting the environmcat provided such changes, tests or experiments do not involve an unreviewed ,
environmental question, and do not involve a change in the Environmental Protection Plan.* Changes in plant design, operation, performance tests or experiments which do not affect the environment are not subject to the requirements of the 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 affect the environment, the licensee shall prepare and record 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 Director, Office of Nuclear Reactor Regulation. When such activity involves a change in the Environmental Protection Plan, such activity and change to the Environmental Protection ,
Plan may be implemented only in accordance with an appropriate license amendment as set forth in Section 5.3.
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 final i environmental statement (FES) as modified by staf f's testimony to the Atomic Safety and Licensing Board, supplements to the FES, environmental impact appraicalc, or in any decicions of the Atomic Safety and Licensing Board; or (2) a significant change in effluents or power level (in accordance with 10 CRF 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.
I The hicensee shall maintain records of changes in plant design or operption and of tests and experiments carried out pursuant to this e Subsection. These records shall include a written evaljation which provide bases for the determination that the chanje, test, or experiment does not involve an unreviewed enviWonmental question nor constitute a decrease in the effehtiveness of this EPP to meet the objectives specified in Sectf.on 1.0. The licensee shall include as part of his Annual Envilonmental Operating Report (per Subsection 5.4.1) brief
- This provision does not relieve the licensee of the requirements of 10CFR50.59 3-1
. daccriptions, analyses, interpretations, and cycluations of such changes, tests and experiments.
3.2 Changes Required for Compliance with Other Environmental P.egulations I Changes in plant design or operation and performance of tests or experiments which are required to achieve compliance with other Federal, State, or local environmental regulations are not subject to the requirements of Section 3.1 h
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4.0' Environmsntal Conditions 4.1 Unusual or Important Environmental Events Any occurrence that potentially could result in significant environmental impact causally related to plant operation shall be recorded and promptly reported to the NRC by a written report per Subsection 5.4.2. The following are examples: excessive bird destruction dua to collision with plant facilities, onsite plant or animal disease outbreaks, and mortality of any species protected by the Endangered Species Act of 1973 as amended.
No routine monitoring programs are required to implement this condition.
4.2 Environmental Monitoring No routine aquatic monitoring programs beyond those that will be conducted under requirements of the NPDES permit have been identified as necessary for the Callaway Plant.
A limited-term inspection program aimed at monitoring the potential impact of cooling tower drift on the local flora will be accomplished by means of infrared aerial photographic analysis of the terrestrial vegetation surrounding the Callaway Plant.
The interpretation of the aerial photographs will be verified by ground inspection surveys (grounding truthing) to confirm areas of stress and nonstress. Ground truthing will be also used to determine, if possible, the type and cause of any vegetation stress, disturbance, or impacts identified.
The ten one-hectare terrestrial study plots will be photographed in stereo pairs using 9" x 9" format infrared film at a scale of 250' to the inch. Each of the photographs will be reproduced in both color tran0parency and color print form. The residual lands of the plant site will be photographed above about the 39 15' parallel along transects using a 1000' to the inch scale. Stereo pair photographs will be taken along each transect, again using 9" x 9" format color infrared film.
- This photography will be done using aerial overflights during the period of maximum seasonal vegetation cover during July or August. Baseline vegetation monitoring shall commence during the growing season preceeding the onset of commercial operation of the Callaway Plant. The operational monitoring schedule shall begin during the first July-August period after the Callaway Plant has been in operation for one year. The monitoring will then be repeated 1, 3 and 5 years following the initial operational monitoring period.
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r 5 .'0 ' Administrative Procedures ;
5.1 Review and Audit , i The licensee shall provide for review and audit of compliance with the Environmental Protection Plan. The audits shall be conducted independently of the individual or groups responsible for performing the specific activity. A description of the :
i' organization structure utilized to achieve the independent review !
and audit function and results of the audit activities shall be !
maintained and made available for inspection.
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5.2 Records Retention
- Records and logs relative to the environmental aspects of plant operation 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.
- i Records of modifications to plant structures, systems and components determined to potentially affect the continued
- protection of the 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.
5.3 Changes in Environmental Protection Plan [
Request for change in the Environmental Protection Plan shall include an assessment of the environmental impact of the proposed change and a supporting justification. Implementation of such changes in the EPP shall not commence prior to NRC approval of the proposed changes in the form of a license amendment incorporating the appropriate revision to the Environmental
- Protection Plan.
5.4 Plant Reporting Requirements 5.4.1 Routine Reports -
An Annual Environmental Operating Report describing
. implementation of this EPP for the previous calendar 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
- receipt of the operating license. The period of the first report j shall begin with the date of receipt of the operating license.
The report shall include summaries and analyses of the results of the environmental protection activities required by Subsection 4.2 of this Environmental Protection Plan for the report period and will include an assessment of the observed impacts of plant '
operation on the environment. If harmful effects or evidence of l trends towards irreversible damage to the environment are l observed, the licensee shall provide a detailed analysis of the j data and a proposed course of action to alleviate the problem.
The Annual Environmental Operating Report shall also include:
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(a) A list of EPP noncompliances and the corrective actions taken to remedy them.
(b) A list of all changes in station design or operation, tests, and experiments made in accordance with Subsection 3.1 which involved a potentially significant unreviewed
, environmental issue.
(c) A list of nonroutine reports submitted in accordance with Subsection 5.4.2.
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 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 an unusual or important environmental event (see 3 4.1). The report shall, to the extent practicable, (a) describe, analyze, and evaluate the event, including extent and magnitude of the impact and plant operating conditions at the time of the event, (b) describe the probable cause of the event, (c) indicate the action taken to correct the reported event, (d) indicate the corrective action taken to preclude repetition of the event and to prevent similar occurrences involving similar components or systems, and (e) indicate the agencies notified and their preliminary responses.
Events reportable under this subsection which require reports to other Federal, State or local agencies shall be reported in accordance with those reporting requirements in lieu ot the requirements of this subsection.
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