ML20085L127

ETS for Facilities

ML20085L127
Person / Time
Site:	Hatch
Issue date:	10/17/1983
From:	GEORGIA POWER CO.
To:
Shared Package
ML20085L090	List: ML20085L088 ML20085L122 ML20085L127
References
NUDOCS 8310210279
Download: ML20085L127 (21)

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ENVIRONMENTAL TECHNICAL SPECIFICATIONS i

i EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 r

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TABLE OF CONTENTS Section Page 1.0 Definitions 1

2.0 (Section Deleted) 3 3.0 Environmental Monitoring 3

3.1 Nonradiological Monitoring 3

3.1.1 Abiotic 3.1.2 Biotic 4.0 Special Survei] lance and Study Activities 5

4.1 Erosion Control Inspection 5

4.2 Unusual or Important Events Requirements 5

4.3 Exceeding Limits of Other Relevant Permits 5

5.0 Administrative Controls 7

5.1 Responsibility 5.1.1 General Manager 7

5.1.2 Manager-Environmental Affairs 7

5.1.3 General Manager-Quality Assurance 7

and Radiological Health and Safety 5.2 Organization 7

5.3 Review and Audit 8

5.3.1 Independent Review 8

5.3.2 Audit Responsibility 9

f 5.4 State and Federal Permits and Certificates 9

l 5.5 Procedures 9

5.5.1 Environmental Programs Description 10 Document 5.5.2 Quality Assurance of Program 10 j

Results l

5.5.3 Compliance with Procedures 11 l

5.5.4 Changes in Procedures, EPDD, 11 l

and Station Design or Operation 5.5.5 Consistency with Initially 12 j (~)

Approved Programs

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5.5.6 NRC Authority to Require Revisions 13 I

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TABLE OF CONTENTS (CONTINUED) i Section Page 5.6 Plant Reporting Requirements 13 i

5.6.1 - Routine Reports 13 5.6.2 Nonroutine Reports 14 5.6.3 Changes in Environmental Technical 15 Specifications and Permits 5.7 Records Retention 16 5.7.1 Life-of-Plant Records 16 5.7.2 Five-Year Records 16 5.7.3 Records Storage 16 4

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LIST OF TABLES Table Number Title 2.1-1 Radioactive Liquid Waste Sampling and Analysis 2.1-2 Radioactive Gaseous Waste Samplir.g and Analysis 2.1-3 BWR-Liquid Waste System - Location of Process and Ef'luent Monitors and Samplers Requiced by Environmental l

Technical Specifications 2.1-4 BWR-Gaseous Waste System - Location of Process and Effluent Monitors and Samplers Required by Environmental 3

Technical Specifications 2.1-5 Average Energy Per Disintegration i

3.2-1 Radiological Environmental Monitoring i

Program 3.2-2 Detection Capabilities for Environmental Sample Analysis 3.2-3 Reporting Levels for Nonroutine Operating Reports I

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LIST OF FIGURES i

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j 3.2-1 f.ccation of Radiological Environmental i

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. Organization Structure Related.to i.

-Environmental Activities.

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2 1.0 Definitions Aerial Remote Sensing - The measurement or acquisition from aircraft or spacecraft of information on some property of an object or phenomenon by a recording device that is not in physical or intimate contact with the object or phenomenon under study.

The technique employs such devices as the camera, radio frequency receivers, and radar system.

Annually - Once per calendar year at intervals of 12 calendar months, 1 30 days.

Bi-Weekly - Once every 2 weeks, 1 4 days.

Ground Truth or Ground Data Surveys - Supporting data collected on the ground and information derived therefrom, as an aid to the interpretation of a remotely recorded survey, such as aerial imagery.

To the extent possible, this should be performed concurrently with the airborne surveys.

Infrared, Photographic - Pertaining to or designating that portion of the electromagnetic spectrum with wavelengths just beyond the red end of the visible spectrum; generally defined as being from 0.7 to about 1.0 pm or the useful

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limits of film sensitivities.

Monthly - Once during each calendar month at 30-day intervals,16 days.

Normal Operation - Operation of either unit at the station

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at greater than 5 percent of rated ther aal power in other than a safety or power emergency situation.

NPDES Permit - The National Pollutant Discharge Elimination System Permit No. GA 0004120 (or its subsequent revisions) issued by the State of Georgia, Department of Natural Resources, Environmental Protection Division to Georgia Power Company.

This permit authorizes Georgia Power Company to discharge controlled waste water from HNP into the waters of the Altamaha River.

Quarterly - Once during each successive 3-month period of the calendar year, counting from January 1, at 13-week intervals, t l4 days.

Scale - The ratio of a distance on a photograph or map to its corresponding distance on the ground.

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Semi-Annually - Once during each successive 6-month period of the calendar year, counting from January 1, at 6-month intervals, 121 days.

Spectral Band - A width, generally expressed in wavelength or frequency, of a particular portion of the electromagnetic spectrum.

A given sensor, e.g.,. radiometer detector or camera film, is designated to measure or to be sensitive to energy received from that part of the spectrum.

Station and Unit - Station refers to HNP-Units 1 and 2.

Unit refers only to HNP 1 or HNP 2, as defined by its usage.

Only the individual unit's instrument is applicable to specifications applied to that unit.

Unusual or Important Event - An event that causes potentially significant environmental impact or that could be of public interest concerning environmental impact from plant operation.

Weekly - Once during each calendar week at 7-day intervals,12 days.

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3.0 Environmental Monitorinq The objective of the environmental monitoring program is to determine the effect of plant operation on the environment.

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3.1 Nonradiological Monitoring I

j 3.1.1 Abiotic 3.1.2 Biotic i

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2 3.1.2.2 Terrestrial 3.1.2.2.1 Aerial Remote Sensing-Environmental Monitoring Requirement Plant communities of the site shall be aerially photographed to detect and assess the significance of damage, or lack thereof, related to deposition of cooling tower drift.

This monitoring program shall be conducted as specified in the program description developed by the licensee in accordance with section 5.6.1.

The. program shall commence at the time of initial commercial operation of Unit 2 and shall continue for at least 2 years, after which the licensee may request modification or termination of this monitoring requirement in accordance with section 5.6.3.

Action Results of the monitoring conducted under this program shall be summarized, analyzed, interpreted, and reported in accordance with section 5.6.1.

The licensee shall record the following information for each

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flight:

date and time of photographs, film type, spectral band, and scale of the photographs.

Bases Impacts that cause stress to vegetation may occur as a result of cooling tower drift deposition.

Reconnaisance and aerial photographic inspection of plant communities in the drift field are the methods recommended for detecting possible adverse effects of drift deposition on vegetation.

As discussed in the Edwin I. Hatch Nuclear Plant, Unit No. 2, FES-OL, no effects on vegetation have been observed to result from operation of the Unit 1 cooling towers.

However, a continuation of the current Unit 1 monitoring program will serve to verify the FES-OL conclusion that it is unlikely that drift effects on vegetation will be observed for Unit 2.

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F 4.0 Special Surveillance and Study Activities 4.1 Erosion Control Inspection i

4 4.2 Unusual or Important Events Requirements Requirements-The licensee shall be alert to the occurrence of unusual or important events.

Unusual or important events are those that cause potentially significant environmental impact or could be of public interest concerning environmental impact from plant operation.

The following are examples:

unusual or important bird impaction events on cooling tower structures or meteorological towers, onsite plant or animal disease outbreaks, unusual mortality of any species protected by the Endangered Species Act of 1973, fish kills near the HNP site, and significant violations of relevant permits and certifications.

Action Should an unusual or important event occur, the licensee shall make a prompt report to the NRC in accordance with section 5.6.2.

Bases Prompt reporting to the NRC of unusual or important events, as described, is necessary for responsible and orderly regulation of the nation's system of nuclear power reactors.

The information thus provided may be useful or necessary to others r

concerned with the same environmental resources.

Prompt knowledge and action may serve to alleviate the magnitude of l

environmental impact or to place it into a perspective broader than that available to the licensee.

The NRC also has an obligation to be responsive to inquiries from the public and the news media concerning potentially significant environmental events at nuclear power stations.

4.3 Exceeding Limits of Other Relevant Permits Requirements The licensee shall notify the NRC of occurrences exceeding the limits specified in relevant permits and certificates issued by other Federal, State, and local agencies that are reportable to the agency that issued the permit.

This requirement shall apply l

only to topics of NEPA concern within the NRC area of responsibility as identified in the Environmental Technical

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Specifications (ETS).

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1 N-This requirement shall commence with the date of issuance of the operating license for Unit 2 and continue until approval for modification or termination is obtained from the NRC in accordance with section 5.6.3.

Action The licensee shall make a report to the NRC in accordance with section 5.6.2 in the event of a reportable occurrence of exceeding a limit specified in a relevant permit or certificate issued by another Federal, State, or local agency.

Bases The NRC is required under NEPA to maintain an awareness of environmental impacts causally related to the construction and operation of facilities licensed under its authority.

Further, some of the ETS requirements are couched in terms of compliance with relevant permits, e.g.,

the NPDES permit, issued by other licensing authorities.

The reports of exceeding limits of relevant permits also alert the NRC staff.to environmental problems that may require mitigative action.

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This section describes administrative and management controls astablished to. implement the Environmental Technical Specifications (ETS).

Measures specified in this section include assignments of responsibility, review and audit functions, procedures, and reporting requirements.

Corporate responsibility for implementing the ETS and for assuring that the station is operated in such a way as to

. provide protection for the environment rests with the Executive 4

-Vice President-Power Supply.

Responsibilities for compliance with the ETS and for the environmental monitoring program required by the ETS are given below.

i Independent audit shall be provided, as discussed in section 5.3.2, by the General Manager-Quality Assurance and Radiological Health and Safety.

5.1 Responsibility 5.1.1 The General Manager-Plant Hatch is responsible for the

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environmental monotoring programs.

The General Manager-Plant Hatch is also responsible for implementing the special surveillance activities described in section 4.

5.1.2 The Manager-Environmental Affairs is responsible for the environmental monitoring programs specified in sections 3 and 4.

The Manager-Environmental Affairs is responsible for coordinating these programs with appropriate groups.

5.1.3 The General Manager-Quality Assurance and Radiological 1

Health and Safety is responsible for assuring that the periodic audits of plant operations and the environmental monitoring activities to ensure conformance with the ETS are conducted.

5.2 Organization l

A chart showing company organization relative to environmental matters is presented in figure 5.2-1.

Changes affecting company organization ~ depicted in figure 5.2-1 will not require NRC approval prior to implementation, but such changes shall be i

reported to NRC.

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-5.3 Review and Audit l

5.3.1

-Independent Review 4

5.3.1.1 The Manager-Environmental Affairs shall review the e

following:

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The conduct of the environmental monitoring programs, on a routine basis, to ensure that the specifications in I

sections 3 and 4 are being implemented.

b.

Proposed changes to plant systems or equipment, provided such changes are identified by the Plant Review Board (PRB) as having a potential adverse environmental 1

impact.

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Procedures for implementing the responsibilities specified in section 5.1.2 and proposed changes thereto.

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Proposed changes to the Environmental Technical j.

Specifications (ETS).

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Proposed changes to the Environmental Programs i

Description Document.

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-5.3.1.2 The Safety Review Board (SRB) shall review the following:

a.

Proposed changes to the ETS.

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Violations of ETS to determine whether adequate corrective action is being taken to prevent recurrence.

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Procedures or changes thereto (which could affect the monitoring of station operation) that may be considered by the Manager-Environmental Affairs or the PRB to be appropriate for SRB review.

5.3.1.3 The PRB shall review the following:

a.

Procedures for implementing the responsibilities specified in section 5.1.1 and proposed changes theretc.

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Proposed changes to the ETS.

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5.3.2 Audit Responsibility 5.3.2.1 The General Manager-Quality Assurance and Radiological Health and: Safety is responsible for an audit, conducted annually, of the activities of the General Manager-Plant Hatch ano the Manager-Environmental Affairs, related to compliance with the ETS.

5.3.2.2 Audits of facility activities shall be performed annually under the cognizance of the SRB to ensure conformance of facility operation to provisions of the ETS.

5.4 State and Federal Permit and Certificates Section 401 of PL 92-500, the Federal Water Pollution Control i

Act Amendments of 1972 (FWPCA), requires any. applicant for a l

Federal license or parmit to conduct any activity that may result in any discharge into provisions of Sections 3rl, 302, 306, and 307 of the FWPCA.

Section 401 of PL 92-500 further requires that any certification provided under this section shall set any effluent limitations and other limitations and monitoring requirements necessary to assure that any applicant s

for a Federal license or permit will comply with the applicable limitations.

Certifications provided in accordance with Section

- O-401 set forth conditons on the Federal licence or permit for which the certification is provided.

Accordingly, the licensee shall comply with the requirements set forth in the currently applicable 401 certification and amendments thereto issued to the licensee by the Georgia Environmental Protection Division.

In accordance with the provisions of the Georgia Water Quality l

j Control Act, the FWPCA and the rules and regulations promulgated l

pursuant to each of these acts, the Georgia Environmental Protection Division, under authority delegated by the U.S. EPA, issued NPDES permit No. GA 0004120 to the licensee.

The NPDES permit authorizes the licensee to discharge from HNP Units 1 and 2 to the Altamaha River in accordance with effluent limitations, monitoring requirements, and other conditions stipulated in the l

permit, effective August 1, 1983, through December 5, 1987.

Subsequent revisions to the certifications will be accommodated i

in accordance witn the provisions of section 5.6.3.

i 5.5 Procedures Detailed written procedures, including applicable checklists and instructions, shall be prepared and followed for all activities involved in implementing the ETS.

All procedures shall be maintained in a manner convenient for review and inspection.

Procedures that are the responsibility of the General Manager-Plant Hatch shall be kept at the plant.

Procedures that

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are the responsibility of the Manager-Environmental Affairs shall be kept at the Georgia Power Company General Office.

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f 5.5.1 Environmental Programs Description Document Based on these procedures, the licensee shall prepare and follow an Environmental Programs Description document (EPDD) describing the monitoring programs that are required by section 3.1.

This document shall include descriptions of sampling equipment locations, frequencies and number of replications, sample analyses, data recording and storage, and instrument calibrations where appropriate.

These program descriptions shall be approved by the NRC, and subsequent modifications to these programs shall be made by the licensee in accordance with sections 5.5.4 and 5.5.5.

5.5.2 Quality Assurance of Program Results Procedures shall be established to assure the quality of ETS program results, including analytical measurements.

These procedures shall document the program in policy directives; designate responsible organizations or individuals; describe purchased services; e.g.,

contractual laboratory or other contract services; and provide for audits or results and procedures by licensee personnel.

In addition, these quality assurance procedures shall provide for systems to identify and correct deficiencies in technical monitoring programs or related administrative activities, to investigate anomalous or suspect

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results, and to review and evaluate program results.

v 5.5.3 Compliance with Procedures In addition to the procedures specified in section 5.5, the station operating procedures shall include provisions to ensure that each unit and all its systems and components are operated in compliance with the conditions established in the Environmental Technical Specifications (ETS).

5.5.4 Changes in Procedures, EPDD, and Station Design or Operation Changes in the procedures, EPDD, and station design or operation may be made in accordance with section 5.3 and subject to conditions described below:

a.

The licensee may make changes in the station design and operation; make changes in the EPDD developed in accordance with section 5.5.1; and conduct tests and experiments not described in the EPDD without prior NRC approval, unless the proposed change, test, or experiment involves either a change in the objectives of the ETS, an unreviewed environmental question of substantial impact, or affects the requirements of section 5.5.5.

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A proposed change, test, or experiment shall be deemed to involve an unreviewed environmental question if it concerns:

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A matter which may result in a significant increase in any adverse environmental impact previously evaluated in the final environmental statement, as modified by staff's testimony at the hearing,

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supplements thereto, environmental impact appraisals, or in initial or final adjudicatory decisions.

2.

A significant change in effluents or power level.

3.

A matter not previously reviewed and evaluated in the documents specified in a.

above which may have a significant adverse environmental impact.

c.

The licensee shall maintain records of changes to the EPDD and to facility design or operation made pursuant to this section.

The licensee also shall maintain records of tests and experiments carried out pursuant to paragraph a.

of this section.

These records shall include a written evaluation that provides the bases for the determination that the change, test, or experiment does not involve an unreviewed environmental question of substantive impact, or does not constitute a change in the objectives of the ETS, or does not affect the requirements of section 5.5.5.

The licensee shall furnish to the NRC, annually or at such shorter intervals as may be specified in the license, a report containing descriptions, analyses, interpretations, and evaluations of such changes, tests, and experiments.

d.

Changes in the EPDD that affect sampling frequency, location, gear, or replication shall be reported to the NRC within 30 days after their implementation, unless otherwise reported in accordance with section 5.6.3.

Changes that affect sampling technique or data recording and storage shall be reported to the NRC at the end of the year.

These reports shall provide a description of the changes made, the reasons for making the changes, and an evaluation of the environmental impact of these changes.

e.

Proposed changes or modifications to plant systems or equipment shall be reviewed in accordance with section 5.3.

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Proposed changes to procedures for implementing the responsibilities specified in section 5.1.1 shall be O

reviewed and approved by the Plant Review Board (PRB).

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Temporary changes to the procedures that do not change the intent of the original procedure may be made with ENP-RETS-ll

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the concurrence of two individuals holding senior reactor operator licenses.

Such changes shall be documented and subsequently reviewed by the PRB and approved by the General Manager-Plant Hatch on a timely basis.

g.

Proposed changes to procedures for implementing the responsibilities specified in section 5.1.2 shall be reviewed by the staff of Environmental Affairs.

Such proposed changes shall subsequently be reviewed and approved by the Manager-Environmental Affairs.

When deemed appropriate by the Manager-Environmental Affairs, such proposed changes also shall be reviewed by the Safety Review Board prior to implementation.

5.5.5 Consistency with Initially Approved Programs Any modifications or changes to the initially approved EPDD developed in accordance with section 5.5.1 shall be governed by the need to maintain consistency so that direct comparisons of current and previous data are technically valid.

Such modifications or changes shall be justified and supported by adequate comparative sampling programs or studies that demonstrate the comparability of results or provide a basis for making adjustments that would permit direct comparisons.

A-These demonstrations of comparability shall ce submitted to the NRC in accordance with sections 5.5.4 and 5.6.1.

5.5.6 NRC Authority to Require Revisions The NRC may require modifications or revisions of the EPDD developed in accordance with section 5.5.1 or may require modification or revision of changes made.by the licensee in accordance with section 5.5.4, as a result of NRC reviews of the results of these programs, if such modifications or revisions are judged necessary to maintain consistency with the initially approved program descriptions or with the intent of the ETS.

The NRC also may require modifications or revisions of the EPDD because of changes in plant operation or changes in environmental conditions or concerns associated with plant operation.

5.6 Plant Reporting Requirements 5.6.1 Routine Reports Annual Environmental Surveillance Report A report on the environmental surveillance program for the

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previous calendar year shall be submitted to the NRC within 90

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days after January 1 of each year.

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w summaries, analyses, and interpretations or statistical evaluations, where appropriate, of the results of the environmental monitoring activities for the report period.

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The Annual Environmental Surveillance Report also will include the following:

a.

Comparison with preoperational studies, with operational controls (as appropriate), and with previous environmental monitoring reports b.

An assessment of the observed impacts of plant operation on the environment c.

A summary of:

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All instances of Environmental Technical Specifications (ETS) noncompliance and corrective actions taken to remedy them 2.

Changes to Federal and State permits and certificates made in accordance with section 5.6.3 3.

Changes to the Environmental Programs Description Document k-4.

Changes in station design or operation that could involve an environmental impact or change in the findings of the final environmental statement 5.

Changes in the ETS 6.

Copies of all reports regarding station discharges made in accordance with NPDES Permit No. GA 0004120 (and subsequent revisions); these shall include reports made in accordance with Parts 1B and III of the NPDES permit.

If harmful effects or evidence of irreversible damage are detected by monitoring, the licensee shall provide a further analysis of the problem and a proposed course of action to alleviate the problem.

Results of* analysis of all nonradiological environmental data collected shall be summarized and tabulated on an annual basis.

In the event that some results are not available within 90 days after January 1, the report shall be submitted, noting and explaining the missing results.

The missing data shall be submitted as soon thereafter as possible in a supplementary report.

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5.6.2 Nonroutine Reports A report shall be submitted to the NRC in the event that an unusual or important event occurs, as specified in section 4.2.

Reports shall be submitted under one of the report schedules described below:

a.

Prompt Report - Those events requiring prompt reports shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone, telegraph, or facsimile transmission and followed within 10 days by a written report.

b.

Thirty-Day Report - Nonroutine events not requiring a prompt report, as described in section 5.6.2, shall be reported to NRC either:

1.

Within 30 days of their occurrence 2.

Within the time limit designated in the appropriate specification 3.

Within the time limit specified by the reporting requirement of the corresponding certification or permit issued pursuant to Section 401 or 402 of PL 92-500.

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The report submitted to NRC in accordance with item 3 above will consist of a copy of the report made to the Georgia Department of Natural Resources, Environmental Protection Division.

Written reports and, to the extent possible, preliminary telephone, telegraph, or facsimile reports shall describe, analyze, and evaluate the occurrence, including extent and magnitude of the impact; describe the cause of the occurrence; and indicate corrective action (including any significant changes made in procedures) taken to preclude recurrence and to prevent similar occurrences involving similar components or systems.

5.6.3 Changes in Environmental Technical Specifications and Permits 5.6.3.1 Changes in Environmental Technical Specifications Requests for changes in ETS shall be submitted to the NRC for review and authorization in accordance with 10 CFR 50.90.

The request shall incude an evaluation of the environmental impact of the proposed change and a supporting justification.

Implementatien of such requested changes in ETS shall not commence prior to incorporation by the NRC of the new specifications in the license.

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O(.j' Proposed changes to the ETS shall be reviewed and approved by the Manager-Environmental Affairs, the Plant Review Board, and the Safety Review Board.

Prior to approval, the possible impact of the prorosed changes will be evaluated.

5.6.3.2 Changes in Permits and Certificates Changes or additions to required Federal, State, local, and regional authority permits and certificates for the protection of the environment that pertain to the requirements of the ETS shAll be reported to the NRC within 30 days.

In the event that the licensee initiates or becomes aware of a request for changes to any water quality requirements, limits, or values stipulated in any certificate or permit issued pursuant to Section 401 or 402 of PL 92-500, which are also the subject of an ETS reporting requirement, the NRC shall be notified concurrently with the authorizing agency.

The notification to the NRC shall include an evaluation of the environmental impact of the revised requirement, limit, or value being sought.

If, during the NRC's review of the proposed change, it is determined that a potentially severe environmental impact could result from the change, the NRC will consult with the authorizing agency to determine the appropriate action to be taken.

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L 5.7 Records Retention 5.7.1 Records and logs relative to the following areas shall be made and retained for the life of the plant in a manner convenient for review and inspection.

These logs shall be made available to the NRC on request.

a.

Records and drawings detailing plant design changes and modifications made to cystems and equipment as described in section 5.5.4.

b.

Records of all data from environmeal monitoring and surveillance programs required by the ETS.

5.7.2 All other records and logs relating to the ETS shall be retained, in a manner convenient for review and inspection, for 5 years following logging or recording.

5.7.3 These records shall be stored at the plant or at the Georgia Power Company General Office, as appropriate, under the control of the responsible organization.

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VICE PRESIDENT

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SAFETY REVIEW GENERAL MANAGER QUALITY ASSURANCE AND RADIOLOGICAL BOARD (SRBI HEALTH & SAFETY l

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SENIOR SENIOR VICE PRESIDENT 4

VICE PRESIDENT ENGR CONSTRUCTION POWER GENERATION

& PROJECT MANAGER 4

I VICE PRESIDENT VICE PRESIDENT POWER 4

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& GENERAL MANAGER SUPPLY ENGINEERING NUCLEAR GENERATION AND SERVICES (b) d k

NUCLEA GE ATION (a)

CHIEF ENGINEER (b) l GENERAL MANAGER MANAGER PLANT HATCH ENVIRONMENTAL AFFAIRS 9559 2TD17)

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PLANT REVIEW

b. CURRENTLY FILLED BY SAME INDIVIDUAL BOARD (PRB)

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l FIGURE 5.2-1 ORGANIZATIONAL STRUCTURE RELATED

".'O ENVIRONMENTAL ACTIVITIES i

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