ML20091H260
| ML20091H260 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/31/1984 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20091H258 | List: |
| References | |
| NUDOCS 8406050111 | |
| Download: ML20091H260 (23) | |
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1 DRAFT APPENDIX B TO FACILITY OPERATING LICENSE HO.
LIMERICK GENERATING STATION, UNITS 1 AND 2 PHILADELPHIA ELECTRIC COMPANY DOCKET N05. 50-352 AND 50-353 d
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-1 ENVIRONMENTAL PROTECTION PLAN i' (HON-RADIOLOGICAL) it f
May 1984 1 :
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D_ w-.., A.r TABLE OF CONTENTS Page 1.0 Objectives of the Environmental Protection Plan 1-1 2.0 Environmental Protection Issues 2-1 2.1 Aquatic Issues 2-1 2.2 Terrestrial Issues 2-2 2.3 Noise Issues 2-2 3.0 Consistency Requirements 3-1 3.1 Plant Design and Operation 3-1 3.2 Reporting Related to the NPDES Permits and State Certifications 3-3 3.3 Changes Required f or Compilance with Other Environmental Regulations 3-4
, 4.0 Environmental Conditions 4-1 4.1 Unusual or Important Environmental Events 4-1 4.2 Environmental Monitoring 4-2 4.2.1 Aquatic Monitoring 4-2 4.2.2 Terrestrial Monitoring 4-2 4.2.3 Maintenance of Transmission Line Corridors 4-2 4.2.4 Noise Monitoring 4-4 5.0 Administrative Procedures 5-1 5.1 Review and Audit 5-1 5.2 Records Retention 5-1 5.3 Changes in Environmental Protection Plan 5-2 5.4 Plant Reporting Requirements 5-2 5.4.1 Routine Reports 5-2 5.4.2 Non-routine Reports 5-4 0
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l.0 Objectives of the Environmental Protection Plan This Environmental Protection Plan (EPP) is to provide for protection of the environment during operation of Limerick Generating Station Units I and 2 (LGS). The principal objectives of the EPP are as follows:
(1) Verify that the station is operated in an environmentally acceptable manner, as established by the Nuclear Regulatory
, Commission (NRC) in the Final Environmental Statement (FES) for LGS.
(2) Coordinate NRC requirements and maintain consistency with other Federal, State and local requirements for environmental protection.
i Environmental concerns identified in the FES which relate to water a
quality matters are regulated by way of Philadelphia Electric's (licensee's) National Pollutant Discharge Elimination System (HPDES) i permit.
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l 2.0 Environmental Protection Issues l In the FES, the NRC considered the environmental impacts associated with the operation of LGS. Certain environmental issues were
' identified which required study or license conditions to resolve cnvironmental concerns and to assure adequate protection of the environment.
2.1 Aquatic Issues Specific aquatic issues raised by the NRC in the FES were:
(l) The need f or aquatic monitoring programs to confirm that thermal mixing occurs as predicted, t hat chlorine releases are controlled within those discharge concentrations evaluated, and that ef fects on aquat ic blotc and water quality of the Delaware and Schuylkill Rivers and the East Branch and mainstem of the Perklomen Creeks due to plant l
operat ion are no greater than predicted.
(2) The need for special studies to document levels of intake entrainment (Delaware, Perklomon, Schuylkill) and impingement (Schuylkill only).
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Sce subsection 4.2-1 for aquatic monitoring requirements.
2.2 Terrestrial Issues The only unresolved terrestrial issues raised by the NRC in the FES was maintenance of transmission lines.
NRC conditions with regard to terrestrial issues are specified in Subsections 4.2.2 and 4.2.3 of the EPP.
1 2.3 Holse Issues (1) Point Pleasant Pumphouse The NRC staf f evaluated the impacts of noise on nearby 4
residents f rom four sources associated with the Point Pleasant pumphouse. Only noise radiated from the two 7.5-MVA l
transformers was judged to be audible at nearby residences.
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(2) 5.adshaw Reservoir Pumping Station The staf f evaluated impacts of noise f rom both the pumphouse and the two transf ormers associated with the Bradshaw Reservoir pumping station. Noise from pumphouse intake ventilation louvers was judged audible at nearby residences utilizing the present design. However the vent ilators can be modified using attenuators which will ensure inaudibility of these noises at the residences in question.
(3) Limerick Site The staf f evaluated noise impacts at Li:nerick from operation of the two cooling towers and ten transf ormers and judged t hat monitoring and mit igat ive act ion, if necessary, should be undertaken.
Noise monitoring programs are discussed in 4.2.4.
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3.0 Consistency Requirements 3.1 Plant Design and Operation The licensee may make changes in station design or operation or p:rform tests or experiments affecting the environment provided such changes, tests or experiments do not involve an unreviewed environmental question, and do not involve a change in t he Environmental Protection Plan. Changes in plant design or operation er performance of tests or experiments which do not affect the cnvironment 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 construction or operational activities which may offect the environment, the licensee shall prepare and record an cnvironmental evaluation of such activity. (Activities are excluded f rom this requirement if all measureable non-radiological effects are confined to the on-site areas previously disturbed during site preparation and construction.) When the evaluation indicates that cuch activity involves an unreviewed environmental question, the licensee shall provide a written evaluation of such activities and cbtain prior approval from the Director, Office of Huclear Reactor 3-1
R:gulation. 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 cppropriate license amendment as set f orth in Section 5.3.
A proposed change, test, or experiment shall be deemed to invcivo an unreviewed environmental question if it concerns (1) a matter which say result in a significant increase in any adverse environmental impact previously evaluated in the FES, supplements to the FES, or in or (2) cny decisions of the Atomic Safety and Licensing Board CASLB);
e matter not previously reviewed and evaluated in the documents cpecified in (1) of this Subsection, which may have a significant cdverse environmental impact.
The licensee shall maintain records of change in facility design or aporation and of tests and experiments carried out pursuant to this Subsection. These records shall include a written evaluation which test, or provides bases f or the determination that the change, experiment does not involve an unreviewed environmental question nor const itute a decrease in the ef fectiveness of this EPP to meet the objectives specified in Section 1.0. The licensee shall include as part of his Annual Environmental Operation Report (per Subsection 3-2
i 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.
3.2 Reporting Related to the HPDES Permits and State Certifications Violations of the HPDES Permit or the State certification (pursuant to Section 401 of the Clean Water Act) shall be reported to the HRC Region I Of fice in King of Prussia, PA by submittal of copies of the reports required by the NPDES Permit or State 401 certification. The licensee shall also provide the HRC Region I Of fice with copies of the 316(b) documentat ion at the same t ime it is submitted to the permitting agency.
Changes and additions to the NPDES Permit or the State certification chall be reported to the NRC Region I Of fice within 45 days following the date the change is approved by the State. If a permit or certification, in part or in its entirety, is appealed and stayed, t he NRC shall be not ified within 45 days f ollowing the date the stay is granted. (If the 45th day falls on a weekend or a holiday, the report chall be made no lat er t han t he f irst working day f ollowing.)
The HRC shall be not ified of changes to the ef f ect ive HPDES Permit proposed by the licensee by providing HRC Region I Office with a copy 3-3 e v -+- , , . ~ ;.- , ,. - , - - , ~ - s -
of the proposed change when it is submitted to the permitting agency.
The notification of a licensee-initiated change shall include a copy of the requested revision submitted to the permitting agency. The 1icensee shal1 provide the NRC a copy of the application f or renewal of the NPDES Permit at the same time ihe application is submiited to the permitting agency.
3.3 ' Changes Required f or Compliance with Other Environmental Regulations Changes in plant design or operat ion and perf ormance 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.
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l 4.0 Environmental Conditions 1 1
4.1 Unusual or Important Environmental Events I
/.ny observed occurrence of an unusual or important event that Indicates or could result in significant environmental impact causally related to plant operation shall be recorded and reported to the NRC
- Region I Of fice within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter becoming aware of the i
occurrence. This report should be made by telephone, t elegraph, or facsimile transmission followed by a written report per Subsection L 5.4.2. (If a significant environmental event occurs over weekends or
- - holidays the report shall be supplied within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the first working day f ollowing the weekend or holiday.) The following are examples: excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or unusual occurrence of any species f protected by the Endangered Species Act of 1973, unusual' fish kills, j and' increase in nuisance organisms or conditions.
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t p No routine monitoring programs are required to implement this o
. condition.
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4.2 -Environmental Monitoring 4.2.1 Aquatic Monitoring The certifications and permits required under the Clean Water Act indirectly, provide mechanisms for protecting water quality and, aquatic biota. The HRC will rely on the decisions made by the Commonwealth of Pennsylvania, under the authority of the Clean Water Act, for any requirements for monitoring.
4.2.2 Terrestrial Monitoring Ho terrestrial monitoring is requrred.
4.2.3 Maintenance of Transmission Line Corridors The use of herbicides within the Limerick Generating Station transmission line corridors (Limerick to Cromby, Cromby to Plymouth shall Meeting, Cromby to North Wales, and Limerick to Whitpain) conf orm to the approved use of selected herbicides as registered by
- the Environmental Protection Agency and approved by State authorities and applied as directed on the pesticide label.
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Records shall be maintained by the Licensee's Electric Transmission cnd Distribution Department concerning herbicide use. Such records chall include the following information: commercial and chemical in names of materials used; concentration of active material f ormulations for field use; diluting substances other than water; rates of application; method of application; location; and the date of cpplication. Such records shall be maintained for a period of 5 years f rom the date they are prepared and shall be made readily available to the NRC upon request . There shall be no routine reporting requirement associated with this condition.
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4.2.4 Hoise Monitoring 4.2.4.1 Point Pleasant Pumphouse A recent ASLB ruling (ASLB, 1983) requires that the licensee conduct a ene-t ime field study af ter the transf ormers are placed in operation at Point Pleasant. If audible tones are f ound at the site boundary, the licensee will implement noise reduction measures (e.g., installation of barriers around the transf ormers). The noise shall be reduced to a level so that the transf ormer core tones will be inaudible at the site boundary as defined below. Based on onsite measurements, the delta L(ex) f or each tone will be determined. If those values are greater t han 5 dB, mit igat ive measures will have to be undertaken.
The measurement program required in the ASLB ruling involves
! determining, for each transf ormer tone, the number of dB (if any) l cbove the threshold of audibility defined by the masking level for
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that tone. The masking level is defined as 16 dB above t he ambient spectrum level. The steps to be carried out are:
l (1) Measure the broadband (nontonal) ambient nighttime (midnight to 4 a.m.) levels in all octave bands of f requency when the transformers are not energized (step A in the ASLB ruling).
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From t hese, tone-masking sound levels (thresholds of audibility) at each tone f requency will be calculated.
J (2) Measure the level of the tones that exist when the transformers _are energized (step B) in the one-third octave bands that contain them f or comparison with the calculated masking levels from step A to determine audibility.
Transf ormer tones may be 5 dB above the masking level f or specific one-third octave bands.
If, for any reason, it is not pract icable to de-energize .the transf ormers at any time during the prescribed measurement time period (midnight to 4 a.m.), alternative measurements will be required. In that event, only one measurement of the ent ire spectrum need be made, but it must be done entirely in one-third-octave bands. Any measured octave band sound level that includes a tone or tones cannot be used to determine the true background ambient sound level for that octave band. In such cases, the background ambient level in any one-t hird-octave band containir.g a tone will be approximated by interpolating between those adjacent one-third-octave band levels that do not contain any tones.
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If audible tones are found at the site boundary, mitigative measures will be undertaken. The mit igat ive measures might involve the use of a t hree-sided berrier or a f ull enclosure.
4.2.4.2 Bradshaw Reservoir The operat ional measurement program to be applied to the Point
, Pleasant Pumping Station is appropriate for the Bradshaw environment 3
as well. In addition, to characterize the potent ial f er complaint s that are likely to occur if the transf ormer tones exceed the masking levels at the tonal f requencies by greater than 5 dB, the noise h1 measurements proposed f or the Point Pleasant site should be made at the Bradshaw pumphouse site boundary while energized, on the line '
- j. between the transf ormers and residences B, D, and F, to determine if 2=
2 the tones would be audible at those points (see Figure 5.6, LGS Final I Environmental Statement, p. 5-140). ' Measures to render these tones D
inaudible at these points will then be applied as necessary.
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H The measurement program recommended f or Bradshaw to test f or audible f
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) tones f rom the transfo mers should also be extended to include audible tones in the 1000-Hz octave band at the southeast site boundary in the direction of residence B.
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4.2.4.3 Limerick Site i
i I The operational measurement program to be applied to Pt. Pleasant area i
L is appropriate f or the area immediately beyond the northern boundary of the Limerick site as well. If audible tones are found to be I
.present at - the northern site boundary af ter Unit I transformers are energized mitigative measures will be taken, as required for the Bradshaw Reservoir, to cause those tones to be inaudible.
4.2.4.4 General Conditions for Hoise Monitoring The selection, calibration and use of equipment, conduct of the noise surveys, and the analysis and reporting of data shall conf orm to the provisions of the applicable American Hattonal Standards Institute l standards.
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$- The results of the surveys conducted under this program shall be j summarized, interpreted and reported in accordance with Section 5.4.1 7
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!. The final report of this program shall present a brief assessment by h
h the licensee of the environmental impact of plant operat ion on the of f site acoustic environment, and shall describe the proposed l 4-7 1
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t mitigative measures, if any, to be taken to reduce the impact of plant noise levels on the of f-site environment. This report shall also contain a list of all valid, written noise-related complaints or inquiries received by Philadelphia Electric Company concerning the Limerick Generat ing Stat ion during the first year of operation subsequent to issuance of the operating license for Unit I and Unit 2.
The report shall include a descript ion of the act ion taken by PEco to resolve t hese complaint s or inquiries. A valid complaint is defined as one received from a local resident who objects to the noise level in or adjacent to his residence.
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5.0 Administrative Procedures 5.1 Review and Audit 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 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.
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 the NRC on request.
Records of modifications to plant structures, systems and components determined to potentially af f ect the continued protection of the environment shall be retained for the lif e of the plant. All other records, data and logs relat ing to this EPP shall be retained f or five 5-1 i
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years f rom the date t hey are prepared 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 year shall be submitted to the NRC Of fices of Inspection and Enforcement and Region 1 prior to June 1 of each year. The initial report shall be submitted prior to June 1 of the year following issuance of the full power operating license for Unit
- 1. The period of the first report shall begin with the date of 5-2
Issuance of the f ull power operat ing license for the first operat ional unit.
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! 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 f or the report period, including a I
' comparison with preoperational studies such as those reported in the l: -
1 Environmental Report-Operating License, operational controls (as appropriate), and previous nonradiological environmental monitoring reports, and an assessment of the observed impacts of the plant i
operation on the environment. If harmful affects or evidence of 1
trends towards irreversible damage to the environment are observed.
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.[ the licensee shall provide a detailed analysis of the data and a proposed course of action to alleviate the problem.
The Annual Environmental Operating Report shall also include t
j (a) A list of EPP noncompliances and the corrective actions taken t
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(b) A list of all changes in station design or operation, tests, J
, and experiments made in accordance with Subsect ion 3.1 which
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involved a potentially significant unreviewed environmental issue.
(c) A list of noncoutine reports submitted in accordance with Subsection 5.4.2.
1 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 Unusual or Important Event Reports A written report shall be submitted to the NRC Region 1 Of fice within 22 working days of occurrence of an unusual or important event. The report shall (a) describe, analyze, and evaluat e t he event , including extent and magnitude of the impact and plant operation I c haract er i st i cs , (b) describe the probable cause of the event, (c) l Indicate the action taken 'o correct the reported event, ( d') indicate the corrective action taken to preclude repetition of the event and to i
f prevent similar occurrences involving similar components or systems, l
and (e) indicate the agencies notified and t heir preliminary responses.
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Events reportable under this subsection which also require reports to other Federal, State or local agencies shall be reported in accordance with those report ing requirement s in lieu of the requirements of this subsection. The NRC Region 1 Office shall be provided a copy of such report at the same time it is submitted to the other agency.
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