ML20138A700

Revised Environ Protection Plan (Nonradiological)

ML20138A700
Person / Time
Site:	Clinton
Issue date:	11/30/1985
From:	ILLINOIS POWER CO.
To:
Shared Package
ML20138A688	List: ML20138A700 U-600356, Forwards Revised Environ Protection Plan (Nonradiological), for Review & Approval.Rev Incorporates NRC Comments Discussed W/R Samworth on 851105
References
NUDOCS 8512120087
Download: ML20138A700 (11)

Text

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I APPENDIX B TO FACILITY LICENSE NO. NPF-h CLINTON POWER STATION UNIT 1 2

j-ILLINOIS POWER COMPANY l

DOCKET NO. 50-461

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ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL)

NOVEMBER.1985-1

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CLINTON POWER STATION UNIT 1 ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL)

TABLE OF CONTENTS Section 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. . . . . . . . . . . . . . . . . . . . . . 2-1 2.3 Atmic Safety Licensing Board Ordered Unit 2 Issues . . . . . 2-2 3.0 Consistency Requirements . . . . . . . . . . . . . . . . . . . 3-1 3.1 Plant Design and Operation. . . . . . . . . . . . . . . . . . 3-1 3.2 Paporting Related to the NPDES Permits and State certification . . . . . . . . . . . . . . . . . . . . . . . . 3-2 3.3 Changes Required for Cmpliance with Other Environmental Pogulation. . . . . . . . . . . . . . . . . . . . . . . . . . 3-2 4.0 Environmental Conditions. . . . . . . . . . . . . . . . . . . 4-1 4.1 Enviromental Monitoring. . . . . . . . . . . . . . . . . . . 4-1 5.0 A &inistrative Procedures . . . . . . . . . . . . . . . . . . 5-1 5.1 Review and Audit. . . . . . . . . . . . . . . . . . . . . . . 5-1 5.2 Records Retention . . . . . . . . . . . . . . . . . . . . . . 5-1 5.3 Changes in Enviromental Protection Plan. . . . . . . . . . . 5-1 5.4 Plant Reporting Requirements. . . . . . . . . . . . . . . . . 5-2

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l 1.0 OBJECTIVES OF THE ENVIRONMENTAL PROTECTION PLAN The Environmental Protection Plan (EPP) is to provide for protection of non-radiological environmental values during operation of the nuclear facility. The principal objectives of the EPP are as follows:

(a) Verify that the Plant is operated in an environmentally acceptable manner, as established by the Final Environmental Statement-Operating License Stage * (FES-OL) and other NRC environmental impact assessment.

(b) Coordinate NRC requirements and maintain consistency with other Federal, State, and local requirements for environmental protection.

(c) Keep NRC informed of the environmental effects of facility construction and operation and of action taken to control those effects.

Environmental concerns identified in the FES-OL which relate to water quality' matters are regulated by way of Illinois Power's (the licensee s) NPDES permit.

• Final Environmental Statement related to the operation of Clinton Power Station, Unit No. 1. NUREG-0854, May 1982 (FES-OL).

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2.0 ENVIRONMENTAL PROTECTION ISSUES In the FES-OL. dated May 1982, the staff considered the environmental impacts associated with the operation of the Clinton Power Station. 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 (a) Effluent limitations and aquatic monitoring requirements are contained in the effective NPDES permit issued by the Illinois Environmental Protection Agency (IL0036919). The NRC will rely on this agency for regulation of these matters as they involve water quality and aquatic biota.

(b) One specific aquatic issue raised by the staff concerned the potential'for the establishment of encephalitic human pathogenic thermophilic amoeba in Clinton Lake after power generation begins. The NRC will rely on the licensee to conduct monitoring in accordance with the recommendations of the Illinois Department of Public Health as stated in the FES-OL.

2.2 Terrestrial Issues Steam fog from the station's cooling lake has the potential of reducing visibility over nearby roads and bridges. A fog monitoring program shall be initiated to determine the frequency  :'

and density of cooling lake-induced fog which could potentially cause highway safety hazards adjacent to the cooling lake. The NRC shall rely on the licensee to conduct a fog monitoring program in cooperation with the Illinois Department of Transportation and local highway safety officials as stated in the FES-OL.

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2.3 ' Atomic Safety Licensing Board Ordered Unit 2 Issues

- In the event of harmful effects or evidence of trends toward j irreversible damage to the environment due to the Unit 2

• excavation, the.NRC will be provided with a detailed analysis of i data and proposed course of action to_. alleviate the problem.

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3.0 CONSISTENCY REQUIREMENTS 3.1 Plant Design and Operation The licensee may make changes in plant design or operation or perform 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 the EPP.*

Changes in plant design or operation and performance of tests or experiments 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 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 if the activity has measurable environmental effects which are not confined to onsite areas previously disturbed during site preparation and plant construction. 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 Nuclear Regulatory Commission. When such activity involves a change in the EPP, such activity and change to the EPP may be implemented only in accordance with an appropriate license amendment as set forth in Section 5.3 of this EPP.

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 FES-OL as modified by staff's testimony to the Atomic Safety and Licensing Board, supplements to the FES-OL, environmental iLpact appraisals, or in any decisions of the Atomic Safety and Licensing Board; or (2) a significant change in effluents or power level or (3) a matter not previously reviewed and

• This provision does not relieve the licensee of the requirements of 10 CFR 50.59.

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which may have a signfficant adverse. environmental impact.

The licensee shall maintain recor'ds of changes in plant design or

. operation and of tests and s.xperiments carried out pursuant to this Subsection. These records shall include a written ,

evaluation.which provide bases for the determination that the .

change, test or experiment does not involve an unreviewed environmentalDquestion nor constitute a decrease in the effectiveness of this EPP to meet the objectives specified in . -

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Section 1.0. The licensee shall include as part of the Annual Environmental. Operating. Report (per Subsection 5.4.1) ' h'rief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.

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3.2- Reporting Related to the NPDES Permits and State Certification Modification to the NPDES permit or'the State certification pursuant to Section 401 of the Clean Water Act shall be reported to the NRC within 30 days following the date the modified permit N.

is reissued. If a permit or. certification, in part or in its entirety, is appealed and stayed, the NRC shall be notified q within 30 days following the date the stay is granted.

i The NRC shall be notified of modifications proposed by the <

licensee-to the effective NPDES permit by.providing NRC with a copy of the proposed modification at the same time it is submitted-to the permitting agency. The notification of a' licensee-initiated modification shall include a copy of the requested modification submitted to the permitting agency. .The

licensee shall provide the NRC with a copy of its application for reissuance of the4 NPDES permit at the same time the application is submitted to'the permitting agency.

3.3 Changes RegtrirId for Compliance with Other Environmental l Regulations ,

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Changes in plant design or operation ned performance of tests or '

, j experiments required to achieveresn' coms1.ance with notother Federal,/,

State, or. local environmental stains are subject to

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4 .' 0 ENVIRONMENTAL CONDITIONS ,

- 4.1 Environmental Monitoring Environmental monitoring programs are conducted in accordance with the guidance-and controls of agencies outside the Nuclear Regulatory Commission (NRC). The NRC has recognized these j agencies (Illinois Environmental Protection Agency, Illinois Department of Public Health, and Illinois Department of i Transportation) as the authority having jurisdiction in Section 2.0 of this EPP. Therefore, no specific environmental monitoring is required by the NRC under this EPP.

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i 5.0 ADMINISTRATIVE-PROCEDURES 5.1 Review and Audit i The licensee.shall provide for review and audit of compliance

.with the EPP. The audits shall be conducted independently of the j 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

Lof the audit activities shall be maintained and made available for inspection.

4 5.2 Records Retention

The documentation listed below shall be made and retained in a r  ; manner convenient for review and inspection by the NRC. This

documentation shall be retained as indicated below and made available to the NRC upon request.

i (a) Records of modifications to plant structures, systems, and components determined to potentially affect the continued

! protection of the environment (life of the plant).

(b) Records, procedures, data, and logs relating to this EPP (5 years).

(c)' Preoperational environmental monitoring records, procedures, data and logs (5 years).

(d) All other records and logs relative'to the environmental aspects of plant operation (5 years).

5.3 Changes in' Environmental Protection Plan

Requests for changes in the EPP 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 licensee amendment incorporating the appropriate revision _to the EPP.

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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 prior to May 1 of each year. The initial report shall be submitted prior to May 1 of the year following issuance of the operating license. The period of the first report shall begin with the date of issuance of the operating license for Unit One.

The Annual Environmental Operating Report shall include:

(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.

(d) Any results and/or assessments for the environmental monitoring programs described in Subsection 2.0 of this EPP which were submitted to the respective regulatory agencies during the annual reporting period.

If harmful effects or evidence of trends towards irreversible damage 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.

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.

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r 5.4.2 Nonroutine Reports A written report shall be submitted to the NRC within 30 days of

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occurrence of a nonroutine event. The report shall (a) describe, analyze, and evaluate the event, including extent and magnitude of these impact and plant operating characteristics, (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 also required 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. The NRC shall be provided with a copy of each report at the same time it is submitted to the other agency.

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