ML20151U592

Proposed Tech Specs,Consisting of Tech Spec Change Request 139,deleting Definitions Sections & Environ Monitoring Requirements

ML20151U592
Person / Time
Site:	Oyster Creek
Issue date:	02/03/1986
From:	GENERAL PUBLIC UTILITIES CORP.
To:
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ML20151U588	List: ML20151U584 ML20151U592
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NUDOCS 8602110061
Download: ML20151U592 (23)

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OYSTER CREEK NUCLEAR GENERATING STATION PROVISIONAL OPERATING LICENSE NO. DPR-16 DOCKET NO. 50-219 TECHNICAL SPECIFICATION CHANGE REQUEST NO. 139 The applicant hereby requests the Commission to change Appendix B to the above-captioned license as follows:

1.

Sections Affected Sections 1, 2, 3, and 4 2.

Extent of Changes This change request encompasses the deletion of the definitions section and various portions of Appendix B, Environmental Technical Specifications. This change also renumbers the specifications to reflect the outlined changes.

3.

Discussion The following indicates each change request followed by a justification if applicable. Also, unless otherwise specified, any reference to section numbers refers to the current version of the Technical Specification. A list of section number changes, and a revised Technical Specification are included.

A.

Change Revision of " Table of Contents" to reflect renumbering and repagination of each section consistent with this Technical Specification Change Request. Also, deletion of references.

B..

Change Deletion of " List of Tables" and " List of Figures" on pages 11 and 111 respectively.

C.

Change Deletion of all definitions.

Justification The proposed deletion of various environmental monitoring requirements obviates the need for the Definitions section of Appendix B.

Accordingly, the licensee requests that this section be deleted.

D.

Change Delete introductory paragraph under section 2.1 "Nonradiological Monitoring".

E.

Change Delete Table 2-1 and Figures 2-1 and 2-2 on pages 2-2, 2-3, 2-4 respectively.

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F.

Change Delete section 2.1.lA " Impingement of Organisms" in its entirety.

Justification The licensee presently has Section 316 (a) & (b) (Clean Water Act)

Demonstrations pending before the NJ Department of Environmental Protection (NJDEP). The oojective of the demonstrations is to assess the impingement, entrainnsent and thermal effects associated with station operation. The US Environmental Protection Agency (USEPA) has oversight review on the development and assesses the results of this Demonstration. Although the initial Section 316 Demonstration was submitted to these agencies previously, additional studies are presently being conducted to supplement the already extensive data base regarding the water quality effects of station operation. These additional studies were conducted through 1985. An additional study (one year) may be conducted if requested by USEPA and NJDEP.

The NJDEP has agreed that the data developed for the Section 316 Demonstratfor will be used to establish water quality standards for Oyster Creet and the portion of Barnegat Bay effected by station operation. The licensee is confident that the NJDEP will find, based upon review of the Section 316 Demonstration, that operation of the station assures the protNtion and propagation of a balanced, indigenous population of shellfish, fish, and wildlife in and on Oyster Creek and Barnegat Bay.

In addition to the above-referenced demonstrations and their accompanying studies, the New Jersey Pollutant Discharge Elimination System (NJPDES) permit issued by NJDEP in accordance with the New Jersey Water Pollution Control Act imposes waste water treatment requirements on the station's non-radiological waste water discharges. Such requirements implement applicable state and federal effluent limitation requirements. The NJPDES permit also includes extensive monitoring requirements. As a result, and in our view, compliance with the Section 316 Demonstration study requirements and NJPDES permit monitoring requirements renders the Environmental Monitoring provision of the subject technical specification unnecessary.

Accordingly, the licensee requests that it be deleted.

G.

Change In section 2.1.18 " Fish Kill Monitoring Program", the third paragraph under " Reporting Requirements" should be changed from "The results of this program snall be submitted in l

February of each year covering the preceding 12 months of sampling and four months of data analysis."

to read "The results of this program shall be included with the Annual Environmental Operating Report submitted in accordance with l

section 3.5.1."

(Note: new designation)

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' Justificatien For c nsistency of rep:rting, the results of this monitoring should.

be included in the Annual Environmental Operating Report. Should a station induced fishkill of greater than 100 organisms occur as a result of a winter shutdown, an unusual or important environmental event would be declared requiring the submission of a Non-Routine Environmental Operating Report within 30 days which would provide an analysis of the data collected.

H.

Change In section 2.1.1B " Fish Kill Monitoring Program", the third paragraph under the " Basis" should be changed from

" Mortality information associat'ed with a winter shutdown, when combined with the results of the impingement monitoring, will provide the empirical-bases on which to judge the impact of OCNGS operations on Barnegat Bay, Oyster Creek, Forked River."

to read " Mortality information associated with a winter shutdown will provide the empirical bases on which to judge the impact of these fish kills on Barnegat Bay, Oyster Creek, and Forked River."

Justification In order to maintain consistency with other changes requested in this Technical Specification Change Request, references to impingement should be deleted and the revised paragraph inserted.

I.

Change Delete section 3.1 "Woodborer Monitoring Program" in its entirety.

Justification The licensee believes that the extensive data base developed and presented in the 42 quarterly reports and 10 annual reports submitted to the Commission through December,1985 have addressed this issue fully. Although the licensee may choose to continue with its studies, the requirement for such studies should not be imposed by the technical specifications. As a result, it should be deleted.

J.

Change In section 3.2 " Unusual or Important Environmental Events" the second paragraph should be deleted.

K.

Change In section 4.1. " Responsibility", second paragraph and in section 4.3 " Review and Audit", first paragraph change reference to GPUNC Manager, Environmental Controls to GPUNC " Industrial Safety &

Environmental Controls Director".

L.

Change In Figure 4-1 correct block specifying Vice President & Director Radiological Controls to Vice President & Director Radiological and Environmental Controls. Also in figure 4-1 change from Manager Environmental Controls to Industrial Safety & Environmental Controls Director and delete block for Plant Operations Review Committee.

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Change Delete reference to section 4.4.3 in item F section 4.3 " Review and Audit".

Justification Administrative in that it maintains consistency with request to delete section 4.4.3 in change request P.

N.

Change Delete. item H in section 4.3 " Review and Audit".

Justification Administrative in that it maintains consistency with request to delte section 4.4.2 in change request P.

O.

Change In section.4.4 " Procedures" section 4.4.1 should be changed from

" Detailed written procedures, including applicable check lists and instructions, will be prepared and adhered-to for all activities involved in carrying out OCETS.

Procedures shall. include sampling, data recording and storage, instrument calibration, measurements, analyses and actions to be taken when limits are approached or exceeded. Testing frequency of any alanes will be included.

These frequencies, if not specified in the OCETS, will be determined frc:n experience with similar instruments in similar environments and from manufacturers' technical manual s. "

to read, " Detailed written ' procedures, including applicable check lists and instructions, will be prepared and adhered to for all activities involved in carrying out OCETS."

Justification The licensee believes that the portion of this section that is requested to be deleted relates to Woodborer Monitoring.

Impingement of Organisms, and previous Technical Specifications Limiting Conditions for Operation. Since the LCOs have been deleted from Appendix B and the Licensee is requesting that the j

other pertinent sections also to be deleted, to maintain l

consistency the licensee requests that the above specified change be incorporated.

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Change l

Delete sections 4.4.2 and 4.4.3 Justification Section 4.4.2 - GPUN maintains an Environmental Control Plan which sets forth the policies and objectives for conservation and protection of the environment. To this end, it is GPUN's policy not only to comply with all applicable environmental regulations, i

but to conduct its business in such a way as to result in as little environmental impact as is reasonably achievable.

Therefore, the licensee believes that it is no longer necessary for this section l

to remain in Appendix B Technical Specifications.

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Section 4.4.3 - Administrative in that deletion of this section y

will maintain consistency with other changes in this Technical Specification Change Request. Additionally, since Appendix B does not contain LCOs, the licensee feels that this section is no longer necessary.

Q.

Change In section 4.5.1.A " Annual Environmental Operating Report" under the summary of items to be included in the report; change item one from referencing "0CETS non-compliances" to "NE0Rs".

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. Change The following provides a listing of section number changes as they pertain directly to the attached revised Technical Specifications.

Section Changed (Present Designation)

Changed to (New Designation)

Section 2.0 Section 1.0 i'

Reference to Section 4.4 pg. 2-12 Section 3.4 pg.1-1 Reference to Section 4.5.2 pg. 2-12 Section 3.5.2 pg.1-2 Section 3.0 Section 2.0 Reference to Section 4.5.2 pg. 3-12 Section 3.5.2 pg. 2-1 Section 4.0 Section 3.0 j

Reference to Section 2.1 pg. 4-1 Section 1.1 pg. 3-1 Reference to Section 3.0 pg. 4-1 Section 2.0 pg. 3-1 i

Reference to Section 4.3 pg. 4-1 Section 3.3 pg. 3-1 i

Reference to Figure 4-1 pg. 4-2 Figure 3-1 pg. 3 Figure 4-1 pg. 4-3 Figure 3-1 pg. 3-3 i

Reference to Section 4.1 pg. 4-4 Section 3.1 pg. 3-4 Reference to Section 4.4.1 pg. 4-4 Section 3.4.1 pg. 3-4.

Reference to Section 2 pg. 4-6 Section 1 pg. 3-6 Reference to Section 3 pg. 4-6 Section 2 pg. 3-6 Reference to Section 3.2 pg. 4-7 Section 2.1 pg. 3-7 Reference to Section 4.4 pg. 4-8 Section 3.4 pg. 3-7 l

Reference to Section 4.5.3 pg. 4-10 Section 3.5.3 pg. 3-9 The requested deletions are consistent with previous decisions of the Atomic Safety and Licensing Appeal Board. They are also similar to other technical specification changes approved by the NRC staff. Furthermore, these requested changes will eliminate the duplication of effort by the NRC with respect to environmental requirements for whNh other regulatory agencies have Clean Water Act responsibilities.

Such deletions also will be consistent with federal policy to eliminate i

i unnecessary paperwork and simplify regulation.

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g, OYSTER CREEK NUCLEAR GENERATING STATION PROVISIONAL OPERATING LICENSE NO. DPR-16 DOCKET NO. 50-219 TECHNICAL SPECIFICATION CHANGE REQUEST NO.~l39 Pursuant to 10CFR 50.91, an analysis concerning significant hazards considerations is provided below:

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Sections Affected Sections 1, 2, 3, and 4 2.

Extent of Changes This change request encompasses the deletion of the Definitions section and various portions of Appendix B, Environmental Technical Specifications. This change also renumbers the specifications to reflect the outlined changes.

3.. Discussion The existin'g Appendix B of the Provisional Operating License No. OPR-16 consists of four sections covering Definitions, Environmental Monitoring, Special Monitoring and Study Activities, and Administrative Controls. As part of this change the applicant requests to delete the Definitions section. This proposal is based upon the deletion of various environmental monitoring requirements obviating the need for the Definitions section.

In regard to the deletion of various environmental monitoring requirements, the following provides further justification for the deletion of these areas:

A.

Environmental Monitoring (biotic-aquatic impacts)

The licensee presently has'Section 316 (a) & (b) (Clean Water Act) l Demonstrations pending before the NJ Department of Environmental Protection (WDEP). The objective of the demonstrations is to assess the impingement, entrainment and thermal effects associated i

with station operation. The US Environmental Protection Agency (USEPA) has oversight review on the development and assesses the results of this Demonstration. Although the initial Section 316 i

Demonstration was submitted to these agencies previously, additional studies are presently being conducted to supplement the already f

extensive data base regarding the water quality effects of station i

operation. These additional studies were conducted through 1985.

An additional study (one year) may be conducted if requested by USEPA and WDEP.

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'The WDEP has afreed that the data developed for th2 Secticn 316

~ Demonstration w ll be ussd to establish water quality standtrds for Oyster Creek and the portion of Barnegat Bay effected by station operation. The licensee is confident that the WDEP will find, based upon review of the Section 316 Demonstration, that operation of the station assures the protection and progagation of a balanced, indigenous population of shellfish, fish, and wildlife in and on Oyster Creek and Barnegat Bay.

In addition to the above-referenced demonstrations and their accompanying studies, the New Jersey Pollutant Discharge Elimination System (WPDES) permit issued by WDEP in accordance with the New Jersey Water Pollution Control Act imposes waste water treatment requirements on the station's non-radiological waste water discharges. Such requirements.

implement applicable state and federal effluent limitation requirements. The WPDES permit also includes extensive monitoring requirements.. As a result, and in our view, compliance with the Section 316 Demonstration study requirements and WPDES pemit monitoring requirements renders the Environmental Monitoring provision of the subject technical specification unnecessary.

Accordingly, the licensee requests that it be deleted.

B.

Special Monitoring and Study Activities-Woodborer Monitoring Program The licensee believes that the extensive data base developed and presented in the 42 quarterly reports and 10 annual reports submitted to the Comission through December,1985 have addressed this issue fully. Although the licensee may choose to continue with its studies, the requirement for such studies should not ce imposed by the technical specifications. As a result, it should be deleted.

The proposed changes to the Administrative Controls section are requested in order to maintain consistency with changes to the other sections of the Technical Specifications and to remove unnecessary requirements as a result of the aforementioned changes.

The requested changes and deletions are consistent with previous decisions of the Atomic Safety and Licensing Appeal Board.

They are also similar to other technical specification changes approved by the NRC staff. Furthermore, the.ie requested changes will eliminate the duplication of effort by the NRC with respect to Environmental requirements for which other regulatory agencies have Clean Water Act 3

responsibilities.

Such deletions also will be consistent with Federal l

policy to eliminate unnecessary paperwork and simplify regulation.

4.

We have determined that this Technical Specification Change Request involves no significant hazards in that operation of the Oyster Creek Nuclear Generating Station in accordance with this change request would not:

1)

Involve a significant increase in the probability or consequence of an accident previously evaluated; or 2)

Create the possibility of a new or different kind of accident from any accident previously evaluated; or 3)

Involve a significant reduction in a margin of safety.

I NUREG-0488 APPENDIX B TO FULL-TERM OPERATING LICENSE ENVIRONMENTAL TECHNICAL SPECIFICATIONS FOR OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219 OCEAN COUNTY, NEW JERSEY JERSEY CENTRAL POWER & LIGHT COMPANY GPU NUCLEAR CORPORATION November 1978*

• Issued to the ASLB on this date; issued by License Amendment No. 37, June 6,1979.

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TABLE OF CONTENTS INTRODUCTION..................................................

11 1.0 EtlVIRONMENTAL MONITORING 1 -1 1.1 NON-RADIOLOGICAL MONITORING.........................

1 -1 1.1.1 Biotic - Aquatic.............................

1 -1 A. Fish Kill Monitoring Program 1 -1 2.0 SPECIAL MONITORING AND STUDY ACTIVITIES 2-1 2.1 UNUSUAL OR IMPORTANT ENVIRONMENTAL EVENTS............

2-1 3.0 ADMINISTRATIVE CONTROLS..................................

3-1 3.1 RESPONSIBILITY......................................

3-1 3.2 ORGANIZATION........................................

3-1 3.3 REVIEW AND AUDIT....................................

3-2 3.4 PROCEDURES..........................................

3-5 3.5 PLANT REPORTING REQUIREMENTS........................

3-5 3.5.1 Routi ne Reports..............................

3-5 3.5.2 Non-Routine Reports..........................

3-7 3.5.3 Changes......................................

3-7 3.6 RECORDS RETENTION 3-9 i

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INTRODUCTION The bases, which provide technical support for the OCETS, are included for informational purposes in order to clarify the intent of the specification.

These bases are not part of the OCETS nor do they constitute limitations or requirements on the licensee.

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1.0 ENVIRONMENTAL MONITORING 3

1.1 Nonradiological Monitoring

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1.1.1 Biotic - Aquatic t

A. Fish Kill Monitoring Program Objective The objective of this program is to determine the species composition, abundance and distribution of station-induced fish kills due to winter shutdowns.

Specifications After each Station shutdown, when the intake water temperature f

is below 8.5'c (47.3'F), visual inspections for fish shall l

l be made along the shores of the discharge canal and-the lower i-1 reaches of Oyster Creek within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the initiation of the shutdown in accordance with the procedures prepared by the i

licensee per Section 3.4.

A continuous temperature record shall be maintained through the 24-hour period after reaching cold shutdown.

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Reporting Requirements t

For planned shutdowns with the temperature of the intake 0

0 water below 8.5 C (47.3 F) the NRC Region I office will be notified at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance of such shutdown.

This notification shall not be given for unplanned, automatic, or manual station trips.

If the shutdown results in greater than 100 fish killed and/or stressed, this event shall be reported to the NRC in accordance with Section 3.5.2.

The results of this program shall be included with the Annual Environmental Operating Report submitted in accordance with section 3.5.1.

Bases The Final Environmental Statement for the Oyster Creek Nuclear Generating Station documents cold shock fish kills associated with rapid temperature decreases caused by plant shutdown during the winter.

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Station shutdowns during winter months are, on occasion, unavoidable. Due to the physical configuration of the station and the discharge canal, some mortality to organisms may be experienced during winter shutdowns.

Mortality information associated with a winter shutdown will provide the empirical bases on which to judge the impact of these fishkills on Barnegat Bays Oyster Creek, and Forked River.

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2.0 SPECIAL MONITORING AND STUDY ACTIVITIES 2.1 Unusual or Important Environmental Events Environmental Monitoring Requirement Unusual or important events are those that cause potentially significant environmental impact or that could be-of public interest concerning environmental impact from station operation. The following are examples: on-site plant or animal disease outbreaks; unusual mortality of any species protected by the Endangered Species Act of 1973; fish kills in.the vicinity of the site; unusually high impingement mortality episodes.

Action Should an unusual or important event occur, the licensee shall make a non-routine prompt report to the NRC in accordance with the provisions of Subsection 3.5.2.

Bases Prompt reporting to the NRC of unusual or important events as described above is necessary for responsible and orderly regulation of the nation's system of nuclear power reactors. The information provided may be useful or necessary to others concerned with the same environmental resources.

Prompt knowledge and action may serve to all.eviate the magnitude of the environmental impact.

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3.0 ADMINISTRATIVE CONTROLS This section describes administrative and management controls established by the Applicant to provide continuing protection to the_ environment and to implement the environmental technical specifications.

3.1 Responsibility Corporate responsibility for implementation of the Oyster Creek Environmental Technical Specifications and for assuring that plant operations are controlled in such a manner as to provide continuing protection of the environment has been assigned by the Office of the President to the Vice President and Director Oyster Creek.

The responsibility for conducting the studies as set forth in Section 1.1 (Non-Radiological Monitoring) and all of Section 2.0 (Special Monitoring

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and Study Activities) rests with the GPUNC Industrial Safety &

Environmental Controls Director.

Administrative measures are defined in Section 3.3 which provide that the individual or group responsible for auditing or otherwise verifying that an activity has been correctly performed is independent of the individual or group responsible for performing the activity.

3.2 Organization The organization of the personnel responsible for implementation, audit, and review of the OCETS is shown in Figure 3-1.

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3.3 Review and Audit Independent-audit and review functions for environmental matters are the responsibility of the GPUNC Industrial Safety & Environraental Controls Director. This department reports directly to the Vice President and Director Radiological & Environmental Controls and is independent of line

. responsibility 'or the operation of the plant.

The independent reviews and audits of the OCETS will be carried out by personnel from the Environmental Centrols Department or by other personnel from GPUNC, GPUSC, outside contractors and consultants at the request of the Environmental Controls Department.

When individuals in the Environmental Controls Department of GPUNC perfonn any function relating to the OCETS other than independent audit and review, the Vice President and Director of Oyster Creek will ensure that an independent review and audit of that work is performed by another individual in the Environmental Controls Department or some other who is not directly responsible for the specific activity being reviewed and audited.

The audits and reviews will be performed as required or requested but in no case less than yearly. The results of all reviews and audits will-be

, documented in report directly to the Vice President and Director Oyster Creek.

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Office of the President General Office Review Board Vice President Vice President

& Director S Director Oyster Creek R S EC 1mmmmmmmmmmm Industrial Safety ISRG

& Environmental Coordinator Controls

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Plant Operations Director am Figure 3 -1 Direct Responsibility Organization for the

--- Advisory Capacity Implementation of the Environmental Technical Specifications 3-3

e Independent audits and reviews will encompass:

A.

Coordination of the OCETS with the safety technical specifications to avoid conflicts and maintain consistency.

B.

Compliance of station activities and operations with the OCETS.

C.

Adequacy of the programs and station procedures which are involved in ensuring the plant is operated in accordance with the OCETS.

D.

The proper functioning in accordance with the responsibilities listed in Section 3.1 of the OCETS.

E.

Proposed changes to the OCETS and the evaluation of the impacts resulting from the changes.

F.

Proposed written procedures, as described in Section 3.4.1 and proposed changes thereto which affect the environmental impact of the plant.

G.

Proposed changes or mcdifications to plant systems or equipment and a determination of the environmental impact resulting from the changes.

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H.

Adequacy of investigations of violations of the OCETS and adequacy of and implementation of the recommendations to prevent recurrence of the violations.

3.4 Procedures 3.4.1 Detailed written procedures, including applicable check lists and instructions, will tue prepared and adhered to for all activities involved in carrying out OCETS.

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3.5 Plant Reporting Requirements 3.5.1 Routine Reports

d. Annual Environmental Operating Report A report on the non-radiological environmental surveillance programs for the previous 12 months of operation shall be submitted to the Office of Inspection and Enforcement (with copy to the Director of Nuclear Reactor Regulation) as a separate document within 90 days after January 1 of each year (except as otherwise specified in the -0CETS).

In the event that some results are not available within the 90-day period, the report will be submitted noting and explaining the reasons for the missing data. The missing data shall be subnitted as soon as possible in a supplementary report.

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The rep:rt shall include smnmaries, analysts, interpretations and statistical evaluation of the results of the environmental monitoring required by the non-radiological environmental monitoring activities (Section 1), and the special monitoring study activities (Section 2) for the report period, including a comparison with preoperational studies, operating controls (as appropriate) and previous environmental monitoring reports, and an assessment of the station operation on ti.e environment.

If harmful effects or evidence of irreversible damage are suggested by the monitoring or special programs, the licensee shall provide a more detailed analysis of the data and a proposed course of action to alleviate the problem.

The Annual Report shall also include a swanary of:

1)

All NE0Rs and the corrective action taken to remedy them.

2)

Changes made to state and federal permits and certificates which pertain to the requirements of OCETS.

3)

Cha1ges in station design which could involve an environmental impact.

4)

Changes in ETS.

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A 3.5.2 Nan-Routine Environmental Operating Reports A prompt report shall be submitted in the event that an Unusual or Important Environmental Event occurs (as specified in Section 2.1).

Such an occurrence will 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, telegrapn, or facsimile transmission to the Office of Inspection and Enforcement and within 30 days by a written report to the Director of the Office of Inspection and Enforcement (with copy to the Director of Nuclear Reactor Regulation).

The written report and, to the extent possible, the prelimin,ary telephone, telegraph, or facsimile report shall (a) describe, analyze, and evaluate the occurrence, including the extent and magnitude of the impact, (b) describe the cause of the occurrence, and (c) indi_cate the corrective action, if necessary, taken (including any signficant changes made in the procedures) to preclude repetition of the occurrence should the occurrence be station related.

3.5.3 Change in Environmental Technical Specifications l

A.

A report shall be made to the NRC prior to implementation of l

l a change in plant design, in plant operation, or in l

l procedures described in Section 3.4, only if the change would t

have a significant adverse effect on the environment or i

involves an environmental matter or question not previously reviewed and evaluated by the NRC. The report shall include a description and evaluation of the changes and a supporting benefit-cost analysis.

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B.

Request for changes in environmental technical specifications shall be submitted to the Director of Nuclear Reactor Regulation.for review and authorization.

The Request shall include an evaluation of the environmental impact of the,

proposed change and a supporting benefit-cost analysis.

C.

Changes or additions to required Federal, and State permits and certificates for the protection of the environment that pertain to the requirements of OCETS shall be reported to the NRC within 30 days.

In the event that the licensee initiates or becomes aware of a request for changes to any of the water quality requirements, limits or values stipulated in any certification or permit issued purusant to Section 401 or 402 of the Federal Water Pollution Control Act (PL 92-500) which is ~also the subject of an OCETS reporting requirement, NRC shall be notified concurrently with the authorizing agency.

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The notification to the NRC shall include an evaluation of the environmental impact of the revised requirment, limit or value being sought.

If, during NRC's review of the proposed change, it is determined that a potentially severe environmental impact could result from the change, the NRC will consult with the authorizing agency to determine the appropriate action to be taken.

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3.6 Records Retention 3.6.1 Eighty (80%) percent data recovery annually for each environmental monitoring requirement is considered satisfactory for the purposes of the DCETS. The variability and uncertainty of environmental conditions demand allowance for some missed data in order to preclude an excessive reporting burden. This provision for missed data does not permit deliberate omission of sample collection or analyses but rather is meant to cover data missad due to circumstances beyond the control of the licensee, its representative or subscontractor.

Records of the reasons for all missed data shall be retained with the data reports.

3.6.2 Records and logs relative to the following areas will be retained for the life of the plant.

A.

Records and drawings detailing plant design changes made to systems and equipment as described in Section 3.5.3.

B.

Records of all environmental surveillance data.

3.6.3 All other records and logs relating to the environmental technical specifications will be retained for five years following logging or recording.

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