ML20100G243
| ML20100G243 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/30/1984 |
| From: | KANSAS GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20100G233 | List: |
| References | |
| NUDOCS 8412070219 | |
| Download: ML20100G243 (16) | |
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WO[E CREEK GENERATING STATION UNIT NO. 1 ENVIRONMENTAL Pf0rECTION PIAN (NCN-RADIOIDGICAL)
November, 1984 TABLE OF CONTENTS Section Pg 1.0 Objectives of the Environmental Protection 1-1 Plan 2.0 Environmental Protection Issues 2-1 2.1 Aquatic Issues 2-1 2.2 Terrestrial Issues 2-3 3.0 Consistency Requirements 3-1 3.1 Plant Design and Operation 3-1 3.2 Reportirg Related to the NPDES Permit 3-2 3.3 Changes Required for Compliance with other _3-3 Environmental Regulations 4.0 Environmental conditions 4-1 4.1 Unusual or Important Environmental Events 4-1 4.2 Ehvironmental Manitoring and Manajement 4-1 4.2.1 Fog Monitoring 4-1 4.2.2 Waterfowl Impaction 4-2 4.2.3 Land Management 4-2 i
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- p TABIE OF COirDirS (continued)
Section M 5.0 Acninistrative Procedures 5-1 5.1 Review and Audit 5-1 5.2 Retention of Program Doctmentation 5-1 5.3 Changes to the Environmental Protection Plan 5-1 5.4 Plant Reporting Requirements 5-2 5.4.1 Ibutine Reports 5-2 5.4.2 Nonroutine Reports 5-3 O
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4 1.0 Objectives of the Err /ironmental Protection Plan
'Ihe Environmental Protection Plan (EPP) provides for protection of nonradiological values during operation of Wolf Creek Generatirg Station. 'Ihe principle objectives of the EPP are as follows:
(a) Verify that the facility is operated in an environmentally acceptable manner, as established by the Final Environmental Statement-Operating License Stager NUREG-0878 (FES-OLS) , and other NRC environmental impact assessments.
(b) Coordinate NRC requirements, assure they are suitably ful-filled and maintain consistency with other Federal, State and local requirements for environmental protection.
(c) Keep NRC informed of the environmental effects of facility operation and of actions taken to cx>ntrol those effects.
Environmental concerns identified in the FES-OIS which relate to water quality matters are regulated by the NPDES permit issued by the State of Kansas.
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2.0 Envirorynental Protection Issues In the FES-OIS dated June,1982, the staff considered the environ-mental impacts associt.ted with the operation of Wolf Creek Generating Station (WCGS) . Certain environmental issues were identified which required monitorirg, study, or license conditions to resolve environ-mental concerns and to assure adequate protection of the environment.
2.1 Aguritic Issues (a)- ihe impacts of Wolf Creek Generating Station operation on the aquatic environment of the John Redmon$ Reservoir - Neosho River systen will be negligible durig p2riods of normal and above-normal hydrologic corxlitions in the upstrean water-shed. However, should a severe and prolonged drotght occur, the withdrawl of cooling-lake makeup water fran the Redmond Dam tailwaters area would contribute to a marked drawdown of water in the reservoir and to reduced streauflow in the river, thus severly depleting available aquatic habitat and adversely affecting resident biota. (FES Section 5.5.2.1) .
1 (b) Some of the operational effects on aquatic organisms in the cooling-lake will be locally severe. For example, periodically high concentrations of total residual chlorine in the vicinity of the cooliry water discharge outlet is expected to cause appreciable mortality among aquatic organisms, especially during pericds when tenperatures in the area are insufficient to cause fish and other motile species to avoid the area. (FES Section 5.5.2.2).
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(c) Cold sho:k effects on fish due to reactor shutdowns could cause significant mortality to aquatic species in the cooling lake. (FES Section 5.5.2.2) .
(d) Impingement and/or entainment impacts on aquatic biota are expected to be significant since the approach velocity of water flow to the facility are relatively high. (FES Section 5.5.2.2) .
(e) Discharge from the cooling lake to elf Creek is expected to influence the camposition of aquatic conmunities inmediately i downstream frcm the discharge outlet, but aquatic biota of the of the Wolf Creek-Neosho River confluence will not be adversely affected by the discharge. (FES Section 5.5.2.3) .
'Ihe NRC will rely on the State of Kansas for determination of the need for monitoring or permit limitations related to these and other aquatic issues.
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2.2 Terrestrial Issues (a) Wat the composition and structure of vegetation in the 453 ha (1120 acre) exclusion zone will be selectively con-trolled to be compatible with the function and security of station facilities.
(FES-OLS: Section 5.5.1.1; Station Site)
(b) Wat the vegetation within a buffer zone surrounding the cooling lake will be retained in or allowed to develop toward a natural state, i.e. naturally occurring biotic communities.
(FES-OLS: Section 5.5.1.1; Station Site)
(c) Wat herbicides used for the maintenance of transmission line corridors will be limited to herbicides approved by the U.S. EPA ad the State of Kansas at the time of such use.
(FES-OLS: Section 5.5.1.2; Energy-Transmission System)
(d) nat in the event a serious disease problem involving waterfowl attributable to station operation occurs, the actions specified in the reference will be initiated follow-ing technical evaluation if deemed necessary.
( FES-OLS: Section 5.5.1.1; Station Site) 1 (e) te need for a wildlife monitoring program which inc1Mes a general survey program for waterfowl collision events be acconplished.
(FES-OLS: Section 5.5.1.2; Energy-Trannmission System) 2-3 l
(f) The need for a fog monitoring program to doctrnent any potential increase in fogging due to the operation of the cooling lake heat dissipation system.
(FES-OLS: Section 5.4.1; Fog ard Ice) 2-4
3.0 Consistency fuguirements 3.1 Plant LMsi:n and Cmration The licensee may make chames in station design or operation or perform tests or experiments affectiry the environment provided such activities do not involve an unreviewed environmental question and do not involve a charge in the EPP*. Changes in station design or operation or per-formance of tests or expriments 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 Sect. ion.
Before ema11m in additional construction or operational activities which may significantly affect the enviornment, the licensee shall prepare and record an environnental evaluation of such activity.
Activities are excitr3ed fran this requirement if all measurable nonrMiolcgical environmental effects are confined to tht. on-site areas previously disturbed durim site preparation and plant construction. When the evaluation iMicates that such activity involves an unreviewed environmental question, the licensee shall provide a written evaluation of such activity and obtain prior tmC approval. When such activity involves a change in the EPP, su d activity and chag e to the EPP may be implemented only in accordance with an appropriate license anendment as set forth in Section 5.3 of this EPP.
- Tnis provision does not relieve the licensee of the requirenents of 10 CFR 50.59.
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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 envi-ronmental impact previously evaluated in the FES-OL, environmental impact appraisals, or in any decisions of the Atanic Safety and Licensity Board; or (2) a significant change in effluents or power level or (3) a matter, not previously reviewed and evaluated in the docunents specified in (1) of this Subsection,which may have a significant adverse environmental impact.
%e licensee shall maintain records of changes in facility design or operation and of tests and experiments carried out pursuant to this Subsection. @ese records shall include 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 this EPP to meet the objectives specified in Section 1.0. The licensee shall include as part of the Annual Environnental Ooerating Report (per Subsection 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.
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.
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'Ihe' licensee shall notify the NRC o'f changes to the effective' NPDES Pemit proposed by the licensee by providing NRC with a copy of the proposed change at the same time it is;subnitted to the permittirq 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 subnitted to the permittirs agency.
3.3 Changes Required for Compliance with Other Environmental Regulations Changes in plant design or operaticit and performance of tests or experiments which are required to achieve ccmpliance with other Federal, State, or local environmental regulat ons are not subject to the requirements of Section 3.1.
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4.0 Environmental Conditions 4.1 Unusual or Important Environmental Events Any 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 pecmptly reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed by a written report per Subsection 5.4.2.
'Ihe following are exanples: excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or unusual occurrence of any species protectC by the Endangered Species Act of 1973, fish kills, increase in nuisance organisms or conditions, and unanticipated or emergency discharge of waste water or chemical substances.
No routine monitoring programs are required to implement this condition.
4.2 Environmental Montoring and Management Environmental monitoring and management activities shall be undertaken as outlined in Section 2 and as described in the following.
4.2.1 Fog lenitoring A fog monitorirg program shall be accanplished to document the frequency of occurrence of natural fog and future cooling lake operation induced fog through the first year of commercial opera-tion of NCGS. A visianeter and continuous recorder shall be utilized in a conservative location throughout the progran.
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4.2.2 Waterfowl Impaction A general. survey program shall be accomplished to docunent sig-nificant waterfowl collision events and determine if mitigation is warranted.
4.2.3 Land Management '
here shall be a land management program instituted at NCGS to pro /ide for revegetation, maintenance, and restoration of-the NCGS site. % is program shall attempt to achieve a balance between production and conservation values on site property through the implementation of conservation and wildlife management techniques.
%ere shall be no reporting requirements associated with this condition.
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5.0 Alministrative Procedures 5.1 Review and Audit The licensee shall provide for review and audit of compliance with the EPP. 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 Retention of Program Doctrnentation Program documentation relative to the environmental aspects of plant operation shall be made and retained in a manner convenient for review and inspection. Program doctrnentation shall be made available to NRC on request.
Doctruentation of rodifications to plant structures, systems, and conponents determined to potentially affect the continued pro-tection of the environment shall be retained for the life of the plant. All other information, data, and finalized reports relating the 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 EPP shall include an assessment of the environmental impact of the prop 3 sed change and a supporting j ustification. Implementation of such changes in the EPP shall 5-1
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rut commence prior to NRC approval of the proposed changes in the form of a license amendment incorporating the appropriate revision to the EPP.
5.4 Plant Reporting Requirements 5.4.1 lbutine Reports An Annual Environmental Operating Report describing implementation of this EPP for the previous year shall be submitted to the NRC prior to May 1 of each year. W e initial report shall be subnitted prior to May 1 of the year following issuance of .the operating license. We period of the first report shall begin with the date of issuance of the operating license.
We report shall include sumaries and analyses of the results of the err /ironmental protection activities required by Subsection 4.2 of this EPP for the report period, including a comparison with related preoperational studies, operational ' controls (as appropriate) ,
previous non-radiological environmental monitoring reports, and an assessment of the observed impacts of plant operation on the environment. If harmful effects or evidence of trends towards irreversible danage to the environment are observed, the licensee shall provide a detailed analysis of the data and a proposed course of action to alleviate the problem.
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The Annual Environmental Operating Report shall also incltde:
(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 subnitted noting and explaining the missing results. 'Ibe missing results shall be subnitted as soon as possible in a supplementary report.
5.4.2 Nonroutine Reports A written report shall be subnitted to the NRC within.30 days of occurrence of nonroutine, unusual or important environmental event. 'Ihe report shall (a) describe, analyze, and evaluate the event, includirq extent arri magnitude of the impact and plant operating conditions, (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 precltde repetition of the event and to prevent similar occurrences involving 5-3 t , y,..- -- .--. . - -. _ -
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5 a similar components or systems, and (e) indicate the agencies notified and their preliminary responses.
Events reportable under this subsection which also require reports to other Federal, State, or local agencies shall be reported in accordance with those reporting requirements in lieu of the requirements of this Subsection. 'Ihe NRC shall be provided a copy of such report at the same time it is s6aitted to the other Mency.
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