ML20115C444
| ML20115C444 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/08/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20115C441 | List: |
| References | |
| NUDOCS 9607120009 | |
| Download: ML20115C444 (4) | |
Text
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UNITED STATES l
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON. D.C. 20666 4 001 1
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SAFETY EVALUATION BY THE OFflCE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.149 TO FACILITY OPERATING LICENSE NPF-35 l
AND AMENDMENT NO.143 TO FACILITY OPERATING LICENSE NPF-52 DUKE POWER COMPANY. ET AL.
CATAWBA NUCLEAR STATION. UNITS 1 AND 2 l
DOCKET NOS. 50-413 AND 50-414
1.0 INTRODUCTION
By letter dated November 2, 1994, Duke Power Company (the licensee) requested
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amendments to the operating licenses for Catawba Nuclear Station, Units 1 and 2.
The proposed amendments would delete the content of Appendix B,
" Environmental Protection Plan (Nonradiological)," (EPP) Technical Specifications and modify License Condition 2.C.(2) so as to delete that l
portion which refers to the EPP.
Radiological environmental monitoring, which is not affected by the proposed amendments, will continue to be required as j
specified in Section 6.8.4.g of Appendix A, " Technical Specifications," of the operating licenses, l
2.0 EVALUATION The EPP was originally issued with the Catawba Nuclear Station Operating License Nos. NPF-35 and NPF-52, and contains, among other items, requirements to conduct for a limited time period certain aquatic and terrestrial environmental monitoring studies. These studies have now been completed.
Other requirements currently contained in the EPP also exist in other documents. The following discussion delineates the basis for eliminating each
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section of the EPP:
Section 1.0, " Objectives of the Environmental Protection Plan," conveys no requirement. Deletion of this section has no impact on plant operation or environmental monitoring, and is therefore acceptable.
Section 2.0, " Environmental Protection Issues," is descriptive in nature and conveys no requirement. Deletion of this section has no impact on plant operation or environmental monitoring, and is therefore acceptable.
Section 2.1, " Aquatic Issues," only refers to the National Pollution Discharge Elimination System (NPDES) permit issued by the South Carolina Department of Health and Environmental Control.
The section states that "the NRC will rely on this agency for regulation of matters involving water quality and aquatic biota." The deletion of this section does not have any impact on plant safety or environmental concern, and is 960712o009 960708 DR ADOCK 0500 3
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. therefore acceptable.
Section 2.2, " Terrestrial Issues" and Section 2.3, " Atmospheric Issues,"
convey no requirements but references Section 4.2 of the EPP. Deletion of these sections has no impact on plant safety or environmental concern, and is therefore acceptable.
Section 3.1, " Plant Design and Operation," provides general guidelines to the licensee to maintain records of changes in the plant design or operation and of tests and experiments carried out at Catawba Nuclear Station which might affect the environment.
The. licensee proposes to delete this section since this requirement is duplicated in the NPDES permit as well as in licensee's Nuclear Station Modification Manus 1 and in Nuclear System Directive 301. The staff concurs with the licensee's proposal and finds deletion of this section acceptable.
Section 3.2, " Reporting Related to the NPDES Permit and State Certification," requires the licensee to report to the NRC and the permitting agency any violations of the NPDES permit or the State certification of the results of the special studies conducted in accordance with the Clean Water Act, and any proposed changes to the effective NPDES permit. The licensee proposes to submit the copies of the application for renewal of the NPDES permit to the NRC within 30 days of submission to the permitting agency as opposed to the same time of submission to the permitting agency.
In addition, the licensee also requests deletion of water quality limits and monitoring programs from the EPP as these aquatic requirements are now under the jurisdiction of the Environmental Protection Agency (EPA) as established by the Federal Water Pollution Control Act Amendments of 1972.
The staff concurs in i
the deletion of the aquatic requirements and will rely on the NPDES l
permit system which is administered by the EPA for regulation and protection of the aquatic environment.
l Section 3.3, "Changas Required for Compliance With Other Environmental Regulations" is descriptive in nature and conveys no requirement.
i Deletion of this section has no impact on plant safety or environmental concern, and is therefore acceptable.
Section 4.1, " Unusual or Important Environmental Events," requires that "any occurrence of an unusual or important event that indicates or could I
result in significant environmental impact causally related to plant I
operation shall be recorded and 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 Section 5.4.2."
The licensee states l
that this requirement is duplicated in the licensee's Nuclear System Directive 202, "10 CFR 50.72 Reports," and the licensee's Catawba Nuclear Station Procedure RP/0/B/5000/13 (NRC notification requirements).
The written report requirement is not duplicated in the aforementioned procedures but the licensee committed to incorporate it in the Corporate Environmental Manual. The deletion of Section 4.1 is therefore administrative and would result in no change in reporting requirements.
The staff finds the proposed change acceptable.
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. l Section 4.2, " Environmental Monitoring," requires environmental monitoring studies.
These portions can be summarized as:
(1) aerial remote sensing, (2) sound level surveys, and (3) fog raonitoring.
Item (1) was required to be done three times after Unit 2 had been in operation; all aerial sensing was completed with the final report i
submitted on April 25, 1994.
Item (2) was to " terminate upon completion of the collection of the specifted sound level data for each phase and submission of.an acceptable final report;" such was done with the final report submitted on April 28, 1989.
Item (3) was to be continued until Unit 2 had been operated for one year; such monitoring was completed with the final report submitted on April 29, 1988. The staff agrees that Section 4.2 can be eliminated on the basis of completion of all requirements.
Section 5.1, "P.eview and Audit," requires the licensee to provide for review and audit of compliance with the EPP. The deletion of the i
requirements above renders this specification moot.
Its deletion is therefore acceptable.
Section 5.2, " Records Retention," requires records and logs relative to the environmental aspects of station operation be made and retained in a manner convenient for review and inspection, and available to the NRC on i
request.
Further, records of modifications to station structures, systems and components determined to potentially affect the continued protection of the environment shall be retained for the life of the station.
Such requirements already exist in Section 6.10, " Record Retention" of the Technical Specifications. The deletion of this section does not eliminate record retention requirements, has no impact on plant safety and environmental concerns.
This deletion is acceptable.
Section 5.3, " Changes in Environmental Protection Plan," specifies that changes to the EPP shall not commence prior to NRC approval of the proposed changes in the form of a license amendment. The deletion of the requirements above renders this specification moot.
Its deletion is therefore acceptable.
Section 5.4.1, " Routine Reports," specifies _ that an Annual Environmental Operating Report, summarizing analyses and results of the environmental protection activities required by Section 4.2 of the EPP, be submitted.
Since all Section 4.2 requirements have been completed as stated above, any future annual report will not contain any new information in that regard.
Section 5.4.1 also specifies that the annual report include EPP noncompliances, changes made as specified in Section 3.1 of the EPP, and occurrences already reported as specified in the NPDES permit.
The annual report specified by Section 5.4.1 contains no new environmental information not previously submitted by other reports.
Therefore, the deletion of Section 5.4.1 does not have an impact on plant safety or environmental concerns, and is acceptable.
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. Section 5.4.2, "Nonroutine Reports," requires a written report be submitted to the NRC within 30 days of occurrence of a nonroutine event.
The discussion in Section 4.1 above states that the licensee committed to include this requirement in the Corporate Environmental Manual.
The deletion of Section 5.4.2 is therefore administrative and would result in no change in reporting requirements. The staff finds the proposed change acceptable.
In the preceding, the staff finds the deletion of each section of the EPP acceptable. Therefore, deletion of the EPP in its entirely is acceptable.
Similarly, the deletion of the phrases in License Condition 2.C.(2) which refers to the EPP is also acceptable.
There is no safety or environmental impact caused by the action of the proposed amendments.
The amendments are administrative in nature and ars intended to relieve the licensee of the burden of certain environmentai reporting requirements as discussed above, though it does not eliminate the requirement for a long-term, terrestrial and aquatic environmental monitoring program.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the South Carolina State Official was notified of the proposed issuance of the amendment. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendments change recordkeeping, reporting, or administrative procedures 1
or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment j
need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and i
security or to the health and safety of the public.
Principal Contributors:
Raj K. Anand Peter S. Tam Date:
July 8, 1996
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