ML20147D748
| ML20147D748 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 12/14/1978 |
| From: | Flynn J CINCINNATI GAS & ELECTRIC CO. |
| To: | Ballard R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7812200148 | |
| Download: ML20147D748 (28) | |
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TIIE CINCINNATI GAS & ELECTRIC COMPANY
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December 14, 1978 United States Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Site Safety and Environmental Analysis Washington, D.C.
20555
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Attention:
Mr. Ronald L. Ballard, Chief Environmental Projects Branch 1 RE:
WM. H.
ZIMMER NUCLEAR POWER STATION - UNIT 1 ENVIRONMENTAL TECHNICAL SPECIFICATIONS Gentlemen:
Enclosed is the current draft of the ZPS-1 non-radiological Environmental Technical Specifications (ETS) for your review and-approval.
Upon finalization of these ETS, we intend to submit them as an amendment to Appendix B of the ZPS-1 Environmental Report (Operating License Stage).
The Environmental Program Procedures Document which 4
will contain the technical details of the environmental monitoring i
programs is under preparation and not included in this submittal.
j We anticipate completing this document and forwarding it for your approval in February, 1979.
Very truly yours, l
THE CINCINNATI GAS & ELECTRIC COMPANY
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By
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JAME D. FLYNN, Manager Lidensing and Environmental Affairs GCP:rt Enclosure cc: ;R. Cleveland p
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1 WM. II. ZIMMER NUCLEAR POWER STATION - UNIT 1 ENVIRONMENTAL TECHNICAL SPECIFICATIONS Section Page 1.0.
Definitions.................................
1 2.0 Limiting Conditions for Opera tion...........
5 3.0 Environmental Monitoring....................
6 3.1 Nonradiological Monitoring..................
6 3.1.1 Abiotic.....................................
6 3.1.1.a Aquatic.....................................
6 3.1.1. a (1) B.4 1de.....................................
6 3.1.1. a ( 2 ) Che.nical Release Inventory..................
6 a
3.1.1.a(3) Water Quality Analysis......................
7 3.1.1.b Erosion.....................................
9 3.1.2 Biotic......................................
9 3.1.2.a General Ecological Survey...................
9 3.1.2.a(1) Aquatic.....................................
9 3.1.2.a(2) Avifauna....................................
10 3.1.2.a(3) Vegetation..................................
11 4.0 Special Studies and Requirements............
11 4.1 Sound Level Survey..........................
11 4.2 Transmission Line Right-o f-Way..............
12 4.2.1 Erosion Control Inspection..................
12 4.2.2 Herbicide Applications......................
13 5.0 Administrative Controls.....................
14 5.1 Responsibility..............................
14 5.2 Organization................................
14 5.2.1 Management Organization....................
14 5.2.2 Station Organization........................
14 5.3 Review and Audit............................
14 5.3.1 Station Review Board........................
14 5.3.2 Environmental Review Board..................
14 5.4 State and Federal Permits and Certificates..
16 5.5 Procedures..................................
17 5.5.1 Environmental Program Description...........
17 5.5.2 Quality Assurance of Program Results........
18 5.5.3 Compliance with Procedures..................
18
- 5. 5. 4 -
Changes in Procedures, Station Design or Operation.................................
18 5.5.5 Consistency with Initially Approv2d Programs.................................
19 5.6-Station Reporting Requirements..............
19 5.6.1 Routine Reports.............................
19 5.6.2 Non-ro uti no Rep o r t s.........................
20 5.6.2.a Prompt Report...............................
20 5.6.2.b Th i r ty Day Re po r t...........................
20 5.6.2.c Content of Non-routine Report...............
20
- 5. 7-Changes in Environmental Technical Specifications and Permits................
21
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o --.-. u- = =.c Section Page 5.7.1 Change in Environmental Technical Specifications..........................
21 5.7.2 Changes in Permits and certifications......
21 5.8 Records Retention..........................
21 5.8.1 Lifetime Retention.........................
21 5.8.2 NPDES Record Retention.
22 5.8.3 Pive Year Retention........................
22 ANNEX
- 1.
NPDES Permit 2.
Section 401 Water Quality Certification 3.
Environmental Program Procedures Document t
- Annexed documents are separate and, as such, do not comprise a part of these ETS.
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'l.0 Definitions Abundance An estimate.of the number of individuals in the plant or animal community.
Bases
.The technical, enviconmental and operational considerations used in developiag the environmental monitoring requirement or action.
Chlorine ZPS-1 uses chlorine as a disinfectant to kill bacteria and as a i
biocide to control algal growth in the cooling water systems.
Chlorine and water react according to ti^ equation:
Cl2+HO HOCl + F 2
s The hypochlorous acid (HOCl) ionizes or dissociates further HOCl x H+ + OCl j
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.into; hydrogen (H+) ions and hypochlorite (OCl~) ions.
These ions accomplish the disinfection, the amount of disinfection being.
diret'1y dependent upon pH value of the water.
The following is a desc..'ption.of the different types of chlorine that will be expected to' occur:
a.. Free available chlorine:. Hypochlorous acid (HOC 1), hypochlorite ion (OCl-), or a mixture of both; chlorine added as C12 quickly hydrolizes in water to form ':001.
b.
Combined available chlorine:
Compounds formed from the reaction of free chlorine with ammonia, phenols, ammonia-containing compounds or any nther compounds in which some of the oxidizing power of chlorinc is retained.
c.
Total' residual chlorine:
The sum of the free and combined chlorine.
d.
If chloraminos have been formed, a sample analysis will indicate a combined available residual.
If additional chlorine is added, the chloramines are oxidized and an analysis will then indicate free available chlorine residual, consisting of HOC 1, OCl, and C12 Both types of residual may be present at the same time.
Community; An assemblage. of plant and/or animal population living in a specific geographic location 4..d interacting with one another.
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. Density The number of individuals of a species or other taxonomic group per unit area.
Discharges Plant Discharge - Release or emission of liquids, gases, or a.
solids from the plant to the environs.
b.
Discharge Rate - Quantity per unit time of a specific plant discharge.
Distribution The geographic space over which a species or other taxonomic group of plants er animals occurs.
Diversity The number of dif ferent kinds of organisms in a defined area.
Environment All the external conditions that influence a plant or animal organism'c mode or way of living.
Environmental Surveillance The operational monitoring program.
Environs The area surrounding a given location.
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Emportant Species
'es, whether plant or animal, is important (1) if it has
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ciel or recreational value, (2) if it is threatened
_adangered, or (3) if it afftcts the well-being of some important
.aies within criteria (1) and (2) above, or (4) if it is critical the structure and function of the ecological system.
A
':aatened or endangered" species is any species officially gnated as such by Public Law 93-205, 87 Stat. 884.
Mixing Zone The area adjacent to a point of discharge within which general water quality standards do not have to be met.
Such an area may however, have specific water quality requirements applicable within it.
Water Quality Standards or Ohio (OAC 3 7-35-1-01 thru 3 7-35-1-13) regulate the size and locatic of mixing zones, s
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. Monitoring Requirement The program for monitoring which includes the sampling activities, schedules, and analyses of samples using the methods necessary
'to -detect contaminants at the levels specified in the NPDES permit.
Normal Operation Operation of the station at greater than 2% of rated thermal power in other than a safety or power emergency situation.
NPDES National Pollutant Discharge Elimination System, a program established by the USEPA pursuant to the Federal Water Pollution Control Act.
0 Amndmnts of 1972 and the Clean Water Act Amendnunts of 1977.
OEPA Ohio Envirortmental Protection Agency, an agency of the government of the State of Ohio.
ORSANCO Ohio River Valley Water Sanitation Commission, an interstate agency, consisting of the signatory states'of Illinois, Indiana, Kentucky,.
New York, Ohio, Pennsylvania, Virginia and West Virginia, with such authority to regulate water quality as defined in the Ohio River Valley Sanitation Compact.
Reportable Environmental Occurrence An environmenta'l event related to the'Wm.
H.
Zimmer Nuclear Power Station, Unit l'(ZPS-1) that causes a significant environmental impact, that changes the environmental impact from station operation, or that could be of public interest concerning environmental impact from station' operation.
Such events would include significant bird impaction. events on the cooling tower, and chemical, radioactive, and thermal releases from ZPS-1 that exceed the limitations imposed a
by applicable permits and/or regulatory authorities.
Reporting Requirement A numerical level of a measured environmental parameter which requires that (1) remedial action be taken; and (2) titat a report for each occurrence be prepared as specified in these Environmental Technical Specifications.
Site On-site-includes any area within the property owned by The Cincinnati Gas & Electric Company (CG&E), " Columbus and Southern Ohio Electric Company (C &SOE) and The Dayton Power and Light Company (DP&L) specifically described in.ZPS-ER Section 2.1.2 and Figure 2.1-5.
Off-site includes all other areas,
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Surveillance Requirements Tests, measurements or inspections performed to assure that the programs designed to determine the environmental impact of plant operation are carried'out in accordance with technical specification requirements.
Unit The Wm. II. Zimmer Nuclear Power Station, Unit 1 (ZPS-1).
USEPA United States Environmental Protection Agency, an agency of the United States Government.
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. i 2.0 Limiting Conditions for Operation d
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, 3.0 Environmental Monitoring 3.1 Nonradiological Monitoring 3.1.1 Abiotic 3.1.1.a Aquatic 3.1.1.a.
(1)
Biocide Environmental Monitoring Requirement Environmental monitoring requirements for biocide discharges from ZPS-1 have been issued with the permit to discharge industrial wastes in accordance with the requirements of Section 402 of PL 92-500 (NPDES Permit).
This monitoring program shall commence with issuance of an operating license for ZPS-1 and continue in accordance with the requirem'nts e
of the NPDES Permit.
Termination or modification of this monitoring requirement is obtained per Section 5.7.2.
This Environmental Monitoring Requirement shall be applicable during normal station operation.
Action The results of the monitoring conducted under this program shall be summarized, analyzed, interpreted, and reported in accordance with Section 5.6.1.
For each measurement required by the NPDES Permit, the date, concentration, and method of analysis shall be recorded.
A non-routine report as specified in Section 5.6.2 shall be made for any measurement of total residual chlorine in excess of the i
effluent limitations prescribed by the hPDES Permit.
Bases Section 5.3.2.1 of the FES-OL states that the proposed discharge of residual chlorine in both the cooling water and service water will be~in compliance with NiC and EPA criteria and at these levels is not expected to cause any adverse effects.
The State of Ohio has reviewed the proposed application and discharge of chlorine with respect to the Ohio Water Quality Standards and the FWPCA Steam Electric Generating Point Source Category Effluent Guidelines and Standards.
The State has determined that these standards and effluent limitations will be met by the proposed discharge and has issued.an NPDES Permit.
The procedures prepared by the licensee are cor.sistent with the requirements of the permit.
3.1.3.a.
(2)
Chemical Release Inventory 4
Entjronmental Monitoring Requirement chemical discharges include all dissolved and particulate materials released to the receiving water by the plant at concentrations above ambient.
Environmental monitoring requirements for chemical discharges from ZPS-1 have been issued with the NPDES Permit..
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.....2.
..This monitoring program shall commence with the issuance of an operating license for Unit 1 and shall continue in accordance with the requirements of the NPDES Permit.
Termination or modifi-cation of this monitoring requirement is obtained as per Section 5.7.2.
Action The results of the monitoring conducted under this program shall be summarized, analyzed, interpreted, and reported in accordance' with Section 5.6.1.
If the discharge of a chemical is greater than that addressed in the NPDES Permit, a non-routine report shall be submitted in accordance with Section 5.6.2.
Bases Documentation of the chemical releases from the station will enable the NRC to determine whether the facility is being operated, with respect to. chemical use and discharge, in the manner evaluated in the Final Environmental' Statement.
This program also is required by the NRC for evaluation of unusual occurrences revealed by other programs conducted under these ETS.
3.1.1.a.
(3)
Water Quality Analysis Environmental Monitoring Requirement Water samples that provide information on the physical and chemical characteristics of the Ohio River and Little Indian Creek shall be l
collected in the vicinity of the Zimmer Nuclear Power Station in accordance with Procedures prepared by the licensee as per Section 5.5.
j The following physical and chemical characteristics of the Ohio River and Little Indian Creek shall be measured and recorded:
a.
. Physical Parameters Parameter Temperature pil Conductivity Turbidity Dissolved oxygen (and percent saturation)
Total Dissolved Solids Total Suspended Solids In addition, the sediment character shall be determined using previously prepared maps and sampling for verification at appro--
priate stations.'. Water velocity and depth shall also be measured and recorded.
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. b.
Chemical Parameters Parameter Total Alkalinity Chlorides Chlorine Chloramines Sodium-Sulfate Total Phosphorus I
Ortho Phosphate Ammonia Nitrogen Ultrate Nitrogen Silica, soluble Total Organic' Carbon Chemical oxygen Demand Biochemical oxygen Demand (5-day)
Copper Zinc Mercury Lead Cadmium The collection of sartples shall coincide with biological sampling at the same locatien.
This monitoring program shall commence at initial attainment of nornal operation of Unit 1 and shall continue until termination of the monitoring program specified in Section 3.1.2.a (1) of these ETS.
a Action The results of the monitoring conducted under this program shall be summarized, analyzed, interpreted, and reported in accordance with Section 5.6.1.
Data shall lxa recorded as to sample date, location and depth, concentration measured and method of analysis used.
Bases Section 2.3. of the FES-OL presents a review of the existing and historical water quality of the Ohio River in the vicinity of the 4
plant which indicates a history of marginal water quality with respect to the needs of aquatic biota.
The description of the proposed plant discharges and their assessed impacts given in FFS-OL Sections 3.2.3 and 5.2.1 indicate that localized alterations to the water quality of the receiving waters will occur.
Impacts on aquatic biota may result in these areas.
Examination of the receiving water quality, at the' times and locations used for the aquatic biological investigations during station operation, will yield data required for the evaluation of station induced trends and unusual occurrences that may be suggested by the biological observations.
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3.1.1.b.
Erosion Environmental Monitoring Requirement Soil erosion shall be monitored in the vicinity of the plant, particularly on the sloped banks.near the Ohio River and Little Indian Creek in accordance with Procedures prepared by the licensco as per Section 5.5.
This inspection program shall commence at coinpletion of construction and shall continue until approval for the termination or modification of this monitoring requirement is obtained from NRC as per Section 5.7.1.
Action j
Reports of results of the erosion and sedimentation studies shall be included in routine progress reports as specified in Section S.6.1.
Results reported shall contain information encompassing but not limited to inspec tion date, location and size of any identified erosion problems areas, type of stabilization program and'date of effective stabilization.
Bases Tne intent of the program is to prevent significant soil erosion in the vicinity of the plant or;its facilities into the Ohio River and Little Indian Creek.
3.1.2 Biotic 3.1.2.a.
General Ecological Survey 3.1.2.a.
(1)
Aquatic Environmental Monitoring Requirement The General Ecological Survey shall obtain data from various biotic and abiotic parameters to evaluate the present status and any changes that may occur in the ecosystem as a result of plant operation.
Periphyton, zooplankton, phytoplankton, benthic invertebrates, fish eggs and larvae and fish shall be surveyed.
Physical and chemical parameters of water quality (see Sec tion 3.1.1. a ( 3 ) ) shall also be measured in conjunction with biological surveys.
All samples shall be collected and all analyses shall be performed in accordance with the procedures prepared by the licensee per Section 5.5.
The sampling and analytical procedures shall be such that data obtained may be validly compared with that from the program required in Section 3.1.1.a (3).
i This confirmatory monitoring program shall commence on March 1 following initial attainment of normal operation and continue for one year.
The program shall be terminated at that time provided that'the data support hypotheses of no significant adverse effects.
, Action l,
' Description of the program, results, and interpretative analyses of environmental impacts shall be reported per the routine report schedule of Section 5.6.1.-
The kinds and number of parameters that i
shall be monitored are identical with.the scope of preoperational ecological monitoring program.
This shall allow direct quantitative and statistical comparisons to be made between preoperational and operational monitoring deta.
Bases Monitoring will emphasize those members of the aquatic community that are either sensitive indicators of biotic stability, or, due to annual or seasonal population fluctuations, require additional examination to document species composition and abundance changes during plant. operation.
Physical and chemical parameters taken in conjunction with biotic samples will aid in establishing a water quality base which can then be related to changes in biotic popu-lation characteristics.
Due to seasonal fluctuations, sampling 4
programs are carried out on a scheduled year-round basis with emphasis on spring, summer and fall.
The program will be flexible so that any needed changes-can be made.
The general ecological survey is an extension of the preoperational monitoring program, but with a slightly modified sampling schedule.
The operational program schedule is similar to that used during both the pre-i construction phase (baseline) ' monitoring and the preoperational monitoring and will allow appropriate statistical analyses of j
' results.
3.1.2.a (2)
Avifauna Environmental Monitoring Requirement Surveys of resident and migrant bird species of the area shall 1
i be conducted by designated plant personnel in the vicinity of the natural draft cooling tower in accordance with the Procedures prepared by the licensee per Section 5.5.
This monitored program commenced with the completion of the cooling f
tower structure and shall continue until data from two migratory seasons after commencement of full power operation have been collected.
The program shall be terminated at this time provided that the Applicant's evaulation of the data support hypotheses of no significant adverse effects.
Action Records'of avifauna san.pling shall include the numbers and species of birds collected by location with respect to the cooling tower, and the temporal variation in the numbers of birds collected.
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Episodes involving 100 or more rmatalities in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, shall'he reported in.accordance with Section 5.6.1.
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l Bases The intent of this program is to establish a survey that will 4
' document any accident catastrophic collision of migrating bird species with the cooling tower.
3.1.2.a (3)
Vegetation Environmental Monitoring Requirement The potential impact of cooling tower salt deposition on vegetation during operation shall be monitored utilizing (1) aerial and ground color infrared photography of the site and environs and (2) measure-ment of electrical conductivity of soil extracts in accordance with the Procedures prepared by the licensee as per Section 5.5.
This program shall commence at initial attainment of normal opera-tion and continue until data from two growing seasons have been collected.
The program shall be terminated at this time provided
-that the data support hypotheses of no significant adverse effects.
Action The results of the monitoring conducted under this program shall be summarized, analyzed, interpreted and reported in accordance with Section 5.6.1.
Results shall include a brief description of vegeta-tion cover type, vegetation stress, appropriate maps and photographs including photo interpretation, and soil conductivity results.-
. Bases The environmental monitoring requirement will provide necessary information to assess the effects of cooling tower salt deposition on vegetation.
4.0 Special Studies and Requirements 4.1 Sound Level Survey Requirement A sound level survey shall be conducted to quantify the operational sound levels that exist at various locations around the site.
q MNie survey shall be conducted in accordance with the Procedures prepared by the licensee in accordance with Section 5.5 during the operational phase cf the facility, when the cooling tower is in ful] operation (operational phase).
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. Data shall be collected at several locations and at varying times during the diurnal cycle at each location such that the energy equivalent sound levels for both the daytime and nighttime periods may be determined.
The sclection, calibration, and use of equipment, procedures used in conduct of each survey and the collection, analysis and reporting of data shall conform to the provisions of the applicable American National Standards Institute Standards.
The conduct of the study shall be similar to the pre-operational phase study such that the results of the two studies are directly comparable.
This special study program shall be completed within the first year of commercial plant operation.
Action The results of the study conducted under this program shall be summarized, analyzed, interpreted and reported in accordance with Section 5.6.1.
The results shall include, for each sampling location, the daytime (LO), nighttime (:LN), and day-night (LDN) equivalent sound levels.
, Bases The results of this special study will provide the operational sound level information which will consider these effects and will form the basis for an impact appraisal.
4.2 Transmission Line Right-Of-Way 4.2.1 Erosion Control Inspection Requirements Routine transmission line inspection shall include examination for evidence of erosion.
All areas within the specified corridor right-of-way showing evidences of abnormal erosion conditions _related to transmission activities shall be identified and recorded.
Upon identification of specific erosion damaged areas, procedures shall be initiated and appropriate records shall be kept indicating any corrective measure taken to mitigate damaged areas.
This special requirement shall be applicable during normal transmission line inspection and shall be conducted no less than once each year in accordance with the Procedures prepared by the licensee per Section 5.5.
This special requirement shall apply only to transmission line corricbrs associated with the station (FES-OL Section 4.4.2). This inspection program shall commence upon initiation of normal transmission line inspection procedure and continue until full redress and recovery from con-struction impacts have been achieved.
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Action A summary of the field inspection program and any procedures implemented to control abnormal erosion conditions associated with transmission line maintenance activities shall be reported In accordance with the routine report schedule for Subsection 5.6.1.
Field logs. indicating locations of erosion damage and measures taken to rectify crosion problem areas and estimation of effective.stabili-zation Lshould be.kept and be asailable for a period of two years.
Results reported shall contain information encompassing but not limited to inspection date; and estimated size of erosion problem area, type of stabilization program, date of effective stabilization, as appropriate..
'l Bases Routine corridor inspection techniques will identify erosion problem areas and coupled with appropriate erosion control steps will insure that such areas become stabilized.
4.2.2 Herbicide Applications Requirements The use of herbicides to control undesirable vegetation within the corridor rights-of-way associated with the station shall conform to the approved use of selected herbicides as registered by the Environmental Protection Agency and approved by state authorities and' applied as directed by said authorities.
Reporting requirements.
shall be made only during the period of herbicide applications for those corridor rights-of-way associated with the station.
Reporting requirements shall be in accordance with the procedures prepared by the licensee per Section 5.5 and should confirm that areas specifically designated for protection and restriction from herbicide application have not been sprayed, and that? accidents such as spills have been documented and cleaned'up to the extent practicable.
This Special Requirement shall apply only to transmission corridors associated with the. station._ This program shall commence upon initiation of any herbicidal application program and continue until approval for modification or termination of this monitoring require-ment is obtained from NRC in accordance with Subsection 5.7.1.
Action The annual report in accordance with Subsection 5.6.1 should include a statement as to whether herbicides were used.
If herbicides were used, the licensee shall report results containing information en-compassing but not limited to:
type (s) ; concentration of active material; rates of application; method and frequency of application; location; and the date of application.
Bases.
This program will provide information to the staff concerning herbicide 1 applications and document conformance with current Federal and State regulations.
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5.0 Administrative Controls 5.1 Responsibility The Station Superintendent is responsible for the safe operation of the facility.
In the absence of the Superintendent, this responsibility is delegated to the Assistant Superintendent.
In the absence of both, this responsibility is delegated to either the Technical Engineer or a qualified group supervisor.
5.2 Organization 5.2.1 Management Organization The management organization responsible for environmental protection at the Wm.
H. Zimmer Nuclear Power Station (ZPS-1) is shown in Figure 5.2-1.
i 5.2.2 Station Organization The station organization responsible for implementation of the j
Environmental Technical Specifications (ETS) is shown in Figure 5.2-2.
5.3 Review and Audit i
5.3.1 Station Review Board The Station Review Board (SRB), Figure 5.2-2, shall have the same scope of responsibility for onsite environmental matters which it 1
holds in other operational matters.
(See OL Appendix A, Technical Specifications.) The SRB shall be advisory to the Station Super-intendent.
5.3.2 Environmental Review Board a.
Function An Environmental Review Board (E RB ) shall be established to provide independent review and audit of environmental matters, described in Section 5.3.2 (G), involving ZPS-1.
See Figure 5.3-1.
b.
Composition The ERD shall be composed of personnel who collectively have the experience and competence to review environmental matters relating to these technical specifications.
The composition of the ZRB shall be as follows:
1.
The Principal Environmental Engineer from Licensing and Environmental Affairs (LEA) who shall serve as chairman of the ERD.
2.
The station Rad-Chem Engineer.
3.
Three regular members, appointed by the LEA Manager, one of whom shall be designated as Vice chairman of the ERB.
. 4.
Qualified alternate (s) and consultant (s), as required, to be appointed by ERB Chairman.
c.
Alternates Alternates shall be appointed by the Chairman of the ERB to serve in the absence of regular members.
The adequacy of the experience and competence of alternates will be considered by the Chairman before their appointment to the ERB.
No more than two regular members of the ERB will be represented by alternates at one time, d.
Consultants Qualified consultant (s) shall be retained by the LEA Manager when necessary to assist the ERB in its function.
e.
Meeting Frequency Regular meetings of the ERB shall be held at least semiannually; within 60 days after January 1 and July 1 of each year.
Special meetings may be called at the discretion of the Chairman.
f, Quorum A quorum for regularly scheduled meetings of the ERB, held under the provisions of subsection 5.3.2(E), shall consist of not less than a majority of the members and alternates, subsection 5.3.2(B)
(1-4), and shall be subject to the following constraints:
(1)
The Chairman or Vice Chairman shall be present for each meeting.
(2) No more than half of the quorum shall have line responsibility for operation of the plant.
(3) The Rad-Chem Engineer or a member of the station staff qualified to review environmental matters shall be present for regular meetings, g.
Responsibility The ERB shall be responsible for the following:
1.
Review of the proposed environmental technical specifications.
2.
Coordination of the contents of these environmental technical specifications with the safety technical specifications to avoid conflicts and maintain consistency.
3.
Review of proposed changes to the environmental technical specifications and evaluation of impact resulting from the change.
4.
Review of proposed written station procedures and changes thereto, referred to the ERB by the SRB, that have been determined by the SRB to affect the environmental impact of the station.
(These procedures shall be reviewed for unreviewed environmental questions.)
5.
Review of proposed environmental monitoring programs and procedures w:d changes thereto.
i 6.
Review of proposed changes or modifications to plant systems or equipment after a determination by the SRB that cuch changes affect the environmental impact of the station.
7.
Review of results of the environmental monitoring programs prior to their submittal for inclusion in each annual Environmental Monitoring Report.*
(See Section 5.6.1)
- Environmental monitoring in response to the NPDES Permit require-ments is not covered under the review and audit responsibilities o f the E RB, but will be under the jurisdiction of the permitting authority.
Nothing contained in these ETS shall be construed to permit or require the ERB to exercise any jurisdiction in any manner over the.senuring, operating, sampling anc monitoring or reporting requirenients of the NPDES program.
8.
Review and audit of investigations concerning reported violations of these environmental technical specification.
Where necessary, the ERB shall evaluate the occurrence and formulate recommendations to prevent recurrer.ce.
h.
Authority The ERB shall serve as an advisory board to the LEA Manager.
Actions recommended by the LEA Manager resulting from the evaluation of the ERD affecting station operation shall be sent by him, in writing, to the Manager of Electric Production.
Actions recommended by the ERB that affect contracted services
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shall be approved by the Manager, LEA.
1.
Records Copies of minutes of all meetings of the ERB, as well as ERB recommendations to the LEA Manager shall be sent by the Chairman of the ERB to the Manager of Electric Production, Station Superintendent, and members and alternates of the ERB.
A signed copy shall be maintained by the LEA Manager.
5.4 State and Federal Permits and Certificates Section 401 of PL 92-500, the Federal Water Pollution Control Act Amendment of 1972 requires any applicant for a Federal license or permit to conduct any activity which may result in any discharge into navigable waters to provide the licensing agency a certification from the State having jurisdiction that the discharge will comply with applicable provisions of Sections 301, 302, 306, and 307 of the FWPCA.
Section 401 of PL 92-500 further requires that any certifica-tion provided under this section shall set forth any effluent limita-tions and other limitations, and monitoring requirements necessary to assure that any applicant for a Federal license or permit will comply with the applicable limitations.
Certificatione provided in
. accordance with Section 401 set forth conditions on the Federal license or permit for which the certification is provided.
Accordingly,i the licensee shall comply with the requirements, with respect to Sections 2 if applicable, and 3 of these ETS, set forth in the 401 certificat[on dated July 29, 1976, issued to the licensee by the ohic Environmental Protection Agency, which requires, among other things, that the licensee comply with ef fluent limitations stipulated in the NPDES permit.
Subsequent revisions to the certifications will be accommodated in accordance with the provisions of Subsection 5.7.2.
5.5 Procedures Written procedures shall be established, implemented and maintained for the activities involved in carrying cut these ETS.
Guidance given in ANSI N18.7-1970, Section 5.0, shall be followed and should include the following, as appropriate-a.
Standard station operations.
b.
Environmental sampling and monitoring.
c.
Data recording and storage.
d.
Instrument calibration.
e.
Measurements and analyses, f.
Environmental quality assurance.
Each procedure and administrative policy in a through f above, and changes thereto, which pertain directly to station operations shall be reviewed by the SRB and approved by the Station Super-intendent prior to implementation, and shall be reviewed period-ically as provided in station administrative controls.
Procedures and changes to procedures that affect the environmental impact of the station or that are part of a contracted, environ-mental monitoring program shall be reviewed by the ERB as specified in subsections 5. 3. 2 (G) (4) and (5) prior to implementation.
5.5.1 Environmental Program Description An Environmental Program Procedures Document, Annex 3 to these ETS, shall be prepared describin-the programs that are required by Sections 3.0 and 4.0 of thes.. I: '.
Subsequent modifications to this Procedures Document she d made as required in conformance 2
with subsection 5.5.4 and 5.5.5.
Descriptions to be included in the document shall include sampling locations, sampling frequency sample replication and descriptions of sampling equipment as required.
These descriptions and the procedures described in Section 5.5, a through f, establish the basis for the monitoring programs specified in Sections 3.0 and 4.0 of tnese ETS.
r.
5.5.2 Quality Assurance of Program Results As specified in Section 5.3.2, an Environmental Review Board (ERD) is established to provide independent review and audit of environ-mental matters described in Section 5. 3.2 (G).
Included is a review of environmental monitoring programs and program results prior to their submittal for inclusion in the annual report.
QA procedures shall be established which will provide for periodic audits of ERB activities.
5.5.3 Corpliance with Procedures Station operating procedures shall include provisions to ensure that station systems and components are operated in compliance with the conditions established in these ETS.
5.5.4 Changes in Procedures, Station Design or Operation Changes in procedures, station design or operation may be made subject to conditions described below, provided such changes are approved by the' Station Superintendent or Manager of LEA as specified:
Changes in station design and inplant operations that apply to a.
these ETS may be made without prior NRC approval unless the proposed change involves a change in ETS objectives, an unreviewed environmental question of subsumtial impact, or affects the requirements of subsection 5.5.5 of these ETS.
Such changes shall be approved by the Station Superintendent prior to imple-mentation.
b.
Changes to procedures described in subsection 5.5 may be made without prior NRC approval unless the proposed change inv61ves a change in ETS objectives, an unreviewed environmental question of substantive impact, or affects the requirements of subsection 5.5.5 of these ETS.
Changes in procedures that pertain directly to station operations shall be approved by the Station Superin-tendent prior to implementation.
Changes in procedures that are included in contract services shall be approved by the Manager, LFA, prior to implementation, c.
Records shall be maintained of changes in procedures and in facility design or inplant operation made pursuant to this subsection to the extent that such changes constitute changes in the Program Procedures Document or procedures developed in accordance with subsection 5.5.
These records shall include a written evaluation that the change does not involve an unreviewed environmental question of substantive impact or constitute,a change in the objectives of these ETS, or affect the require-ments of subsection 5.5.5 of these ETS.
d.
Changes in the Program Procedures Document developed in accordance with subsection 5.5.1 which affect sampling frequency, location, equipment or replication shall be reported to the NRC within 30 days after their implementation, unless otherwise reported in accordance with subsection 5.7.2 of these ETS.
The report shall include a descriptjon and evaluation of the change.
_ 19 -
c.
Temporary changes to procedures of subsection 5. 5 that pertain directly to station operations may be made provided the intent of the original procedure is not altered; the change is approved by the Rad-Chem engineer and one other member of the station manage-ment staff; the change is documented, reviewed by the SRB and approved by the Station Superintendent within 30 days after implementation.
Temporary changes that affect the environmental impact of the station shall be reviewed by the ERD as specified in Subsection 5.5.
5.5.5 Consistency _with Initially Approved Programs Significant modifications or changes to the Program Procedures Document described in Section 5.5.1 shall consider the need to t
maintain consistency with previously used procedures so that i
direct comparisons of data are technically valid.
Such modifi-cations or changes shall be justified end supported by the ERB.
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The description and evaluation of the change, which justifies and/or supports the change, shall be submitted to the NRC in l
accordance with che provision of subsections 3.5.4 and 5.6.1 of these ETS.
5.6 litation Reporting Requirements 5.6.1
[outine Reports a.
Annual Environmental Operating Report A report on the environmental monitoring programs for the previous calendar year shall be submitted to the NRC as a Feparato document by May 1 of each year.
I The period of the first report shall begin with the date of initial criticality but shall not be less than 3 months duration.
If criticality occurs in the last quarter of the calendar year, the initial report shall include the report for the last quarter of that year, appended to the report submitted for the following period.
The report for each period includes: a). summaries, interpreta-tions, and statistical evaluation, where warrented, of the results of the nonradiological environmental surveillance activities (Section 3.0), and the spraial studies and require-monts (Section 4.0) for the report period; b) a comparison with preoperational studies, operational controls (as appropri-ate), and previous environmental surveillance reports; and c) an assessment of the observed impacts of the plant operation on the environment.
If harmful effects or evidence of irre-versible damage are detected by the monitoring, the licensee shall provide an analysis of the problem and a proposed course
_of action.
The annual report shall also include fe' Anformation concerning reportable actions specified in Sectis 5 (Administrative Controls) of these ET5.
1
~ 20 -
b.
Data Reporting Formata Results of' analysis of. reportable nonradiological environmental data collected shall-be summarized and tabulated on an annual basis.
In.the event that some results are not available by May 1, the report shall be submitted noting and explaining the missing.results.
The missing data shall be submitted as soon as possible in the supplementary report.
5.6.2 Non-routine Reports A report shall be submitted in the event that a) a report level is reached (as specified in Section 3.0,
" Environmental Surveillance"),
or b) an unusual or important event
- occurs that causes or has the.
potential to cause a significant environmental impact.
Reports shall be submitted under one of the report schedules described below.
- The significance.of an apparently unusual or important event with regard to environmental impact or the presence of an environmental impact may not be obvious or fully appreciated at the time of occurrence.
In such cases, the NRC shall be informed promptly of changes in the licensee's assessment of the significance of the event and a corrected report shall be submitted as expeditiously as possible.
5.6.2.a Prompt Report Those events specified as prompt report occurrences 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 to the NRC followed by a written report to the NRC within 30 days.
The following.are examples of events which would require a prompt report:
excessive bird impaction events on the cooling tower structure (defined as more than' 100 in any one day);
an on-site plant or animal disease outbreaks; unusual mortality.of any species protected by the Endangered Species Act of 1973; fish kills near or. downstream of the site; events which are reportable under permits issued by.other Federal, State and local agencies in a time frame less_than or equal to.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
5.6.2.b Thirty Day Report Non-routine events not requiring a prompt report as described in Subsection"5.6.2.a, shall be reported to NRC either within 30 days of their occurrence or within the time limit specified by the reporting: requirement of the corresponding certification or permit 1
issued pursuant to Sections 401 or 402 of PL 92-500, whichever time duration following the non-routine event shall result in the earlier submittal.
5'6.2.c Content of Non-routine Reports Writ' ten 30-day reports and, to the extent possible, the preliminary
' telephone, telegraph, or facsimile reports shall a) describe, analyze ~, and evaluate the occurrence, including extent and magnitude of1theLimpact,.b)1 describe the cause of the occurrence,.and c) indicate the corrective action-(including any significant changes
- . 3
21 -
made in procedures) taken to preclude repetition of the occurrence and to prevent similar occurrences involving similar components or systems.
- If harmful effects or evidence of irreversible damage are detected i
by the monitoring or special programs, the licensee shall provide an. analysis of the problem and develop a course of action to be taken to alleviate the' problem.
For example, if the ecology of the j
- river significantly changes at a future date because of major changes in water chemistry or aquatic biota, the licensee shall provide an analysis of expected impacts and a course of action to mir.imize the impacts.
5.7 Changes in Environmental Technical Specifications and Permits 5.7.1 Change in Environmental Technical Specifications Request for changes in environmental technical specifications shall be submitted to the NRC for review and authorization per 10 CPR 50.90.
The request shall' include an evaluation of the environmental impact of the proposed change and a supporting justification.
Implementation of such requested changes in ETS.shall not commence prior to incor-poration by the NRC of the new specifications in the license.
l 5.7.2 Changes in Permits and Certifications Changes or additions to required Federal, State, local, and regional
. authority' permits and certificates for the protection of the environ-ment that pertain to the requirements of these ETS shall be reported to the NRC'within: 30 days.
In the. event that the licensee. initiates 3
or becomes aware of a request for changes to any of the water quality requirements, limits or values stipulated in any certification 4
or permit issued pursuant to Section 401 or 402 of PL 92-500 which is also the subject of an ETS reporting requirement, 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.
i
~ 5.8 Records Retention 5.8.1 Lifetime Rotention Records and logs relative to the following areas shall be made and retained for the life of the plant:
a.
Records and drawings detailing plant design changes and modifi-cations made by systems and equipment.
b.
Records of all' data from environmental monitoring (surveillance j
and special surveillance and study activities) required by these Environmental Technical Specifications.
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_ 22 5.8.2 NPDES Record Retention All records, logs, investigations and other information which are collected in response to the NPDES Permit requirements shall be maintained as required in the permit.
5.8.3 Five Year Retention All other records and logs relating to these ETS shall be retained for five years.
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