ML20154N129

Proposed Tech Specs,Removing Two Requirements Contained in Environ Protection Plan Re Reporting Redundant NPDES Violations to NRC & State of Il & Termination of Fog & Ice Monitoring Program

ML20154N129
Person / Time
Site:	LaSalle
Issue date:	03/10/1986
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20154N104	List: ML20154N101 ML20154N129 ML20154N144
References
NUDOCS 8603170208
Download: ML20154N129 (6)

Text

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= . s' ATTACHMENT B

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Aquatic issues identified in items 1 and 2 above are accressed by the affluant j

' limitations, monitoring requirements and the section 315(b) demonstration requirement contained in the effective NP0E5 permit issued by the Illinois j Environmental P a tectica Agency. The NRC will rely on this agency for regu-I 1ation of these satters' as they involve water quality and aquatic biota. The 4

l aquatic issue identified in itas 3 above has been addressed in correspondence between the NRC and the State of Illincts. The Stata has been acoraised of j the intan, tion of the NRC not to include this monitoring ar.d mitigation recaire-

. sent in this facility license. ' The NRC will rely on the Stata of Illinois for l the estaalishment and conduct of this program. This action has been *.akan in

'. accordance with Section 511(c)(2) of the Clean Watar Act which places 1

i responsibility for establishment and enforcement. of pregrams for the protaction of the aquatic environment with the U.S. Environmental Protaction Agency or

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hJ stata(s) grantad authority for such programs under the Act. .

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2.1 Te restrial Issues -

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(1) P,otantial increase in fogging and icing associatad with operttion of the i

! cpoling system involving the* cooling , lake (FES-CL Section 5.4.1).

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i ,,( 2) Potantial erosion effect.s along the ,dika around the cooling lak,e and tne i

l banks of Armstr.ung Run.

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l i* MRC requirements with regard to the terrestrial issues are specified in 4

a subsection 4.2 of tais EPP. .. . ., .

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,' B603170200 860310

- PDR ADOCK 05000373 l P

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[, A proposed ensnge, test or experiment shall be caemed to involve an unreviewed

' environmental question if it concarns. (1) a matter which may result in a sig-nificant increase in any adverse environmental impact previously evaluated in ,

the final environmental statament (FIS) as socified by staff's tastimeny to ths Ateele Safety and Licensing Board, sucalements to the FIS, environmental impact appraisals, or in any decisions of the At:mic Safety and Licansing Board; or (2) a significant change in effluents or pcwer level (in ac::rcanca j with 10 CFR Part 51.!(b)(2)) or (3) a mattar not previously reviewed sed i

evaluated in the documents specified in (1) of this Subsectian, wnich may have a significant, adverse environmental incact.

The licensee shall maintain records of changes in plant design er :;eratica and of tests and experiments carried cut pursuant to this Subsection. These '

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records shall include a written evaluation 'Jhich provide bases for tha deter-

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aination that the change, tast, or experiment does not involve an unreviewed ,

,, environmental question nor esnstituta a decrease in the effectiveness of this i .

EPP to meet the objectives specified in secticn 1.0. The licensee . hall

' include as part of his Annual Envir:nmental Operating Report (per Sutsection 5.4.1) j brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments. .

3.2 Reeertine Related to the NPOES Permits and State Ca?tifiestien i

tolations of I!he NPCES permit or the State certification (pursuant t:

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.Section 401 of the" Clean Water Act, respectively) shall be reportec :: tas NP.C l \

. by submittal of c:;ies of the reports required by the Nr0E0 parmit or certifip evice the NRC with c: pies of the results of cation.[be licansee 'shall

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' .* s l, .The sonitoring program consists of a visual inspection of the vegetative integrity on the outer face of the periph'ral cooling pond dike at the beg.in-ning of the spring planting season (May) and at the beginning of the fall .

j planting season (August). If a fatture of the vegetative cover is discovered by inspection, the affected area shall be reseeded during the succeeding .

plantfig season.

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N j 4.2.2 Menitorine of Fee and ten Oue to the cooM ne pend 3  :

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\ s j - The results of this monitoring program will be to determine (1) the frequency \

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j and density of cooling pond-induced fog on local roads; and (2) the extant of \

rise ice formation in the vicinit/ of the pond ar.d to' detarsine nh' ether taere \\

d -s is a need for action to mitigata fog or icing effects.

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- t Ilicennection' with the training phase described below, locations will be t i

established frem and at which observations will 'be made for oc:urrence of fog j -

a'n'd ice'. Cbsqrvation locations will be chosen to include accropriate signtings ',

1 I of the roadways near the periphei/ of the cooling pond, nearty residencas, .and i j oder 's'ensitive locations, if any. Specific readways to be.cbserved near the

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cooling pond are County Highway 5. State Route UO, the gravel road norta of i t.5e' c' soling. pond..an' d icunty Hist $vay' 30. .. .

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Tiierobs'arvatio'nsN11'be madeby c:mpany personnel trained to observin and. [

' t j rispo~r t steam fogging and rise ice esnditions near the periphery of the coo 1Ing

. s pon'd.~uncer the auspices of a Cartified Consulticq Metarcrolegfst. j

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l O nonitar4ns ih i1 c===er== == saaa == aractic=i after aanvarv t. Isao. == == =

obtain.as such of one year's preoperational data as ;ossiale. Observatifens \

sade during one-unit and two unit operation will be in ac:ordance with the j schedule excrossed in paragraph six of Sunsection 6.2.1 of the L5CNPP Final  ;

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. Environmental Statement (Fis). The annitoring data will be'.s.anarized and

. submittad to the NRC quartarly. These data shall be suinnart...t. analyzed, ,

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- intarpreted and c: scared with the proccarational monitsring :ata in the annual f l*

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envirormental reports. ,

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j As an aid to obsamations, ap;;ropriata landmarks will be identified witnin l

sight of each observation location ts facilitata the estimation of the extant

4 I of (distance envered,by) fogging and rise icing and the density of (visibility l l

impairment cause.1 by) fogging. The distances between the landmarts and their

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O associated observation locations will be sessu' red and recorded. j I

l, (a) Fog  ;

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.) Free each observation ' location, visual caservations will be sada and

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j recorded by trained personnel twice esca week, before and after the day /

shift, except weekends and holidays, indicating the presence,1ccation /.

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q and extant of fog' and the estimatad foca visibility (range). These -

observationswillnotbemadeondaysthesereadsare'impassaclecuets!

h snow or flood. -

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(b) Ice

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Erom each observation location, visual otservations will be made and .\

recorded by trained personnel twice each day, before and after the day shift, except weekends and holidays, free Cetober 1 through March 31, \

' . indicating the presence, location, extant and thickness of rise ice.

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These obsenations will not be made on days t.*.ese roads are imcassacle r

, h l l due ta snow or flood. I

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j (c) Supporting Cbservations The observations record shall include time, ancient air 'tamcerature (dry  ;

buib and de'w point), wind direction' and speed, electrical load on plant f

• i ' and condensing water tanceratures (intake' to and dischaage from the

plant).

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(d) Environmental Iscact of Rise Icing I

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} Ks"soon as possible after the end of the observation season, but no latar j

1 than May 1, the data on the oc:urrence of rise icing will be correlated

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• t lo'detamine the locations where environmental imcact surveys will be

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? donduc1!ad. Suc.i surveys wili include observation of vegetation by a terrestrial biologist or botanist during the spring growing season.

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L ATTACIMENT C t

i SIGNIFICANT HAZARDS CONSIDERATION l

Commonwealth Edison has evaluated the proposed Technical Specifica-tion Amendment and determind that it does not represent a significant hazards consideration. Based on the criteria for defining a significant hazards consideration established in 10CFR50.92, operation of LaSalle County Station  ;

Units 1 and 2 in accordance with the proposed amendment will not:

! 1) Involve a significant increase in the probablity or consequences of an accident previously evaluated or create the possibility of a new ,

or different kind of accident from any accident previously evaluated i 4 because the proposed amendment merely 1) removes redundant reporting requirements with regards to the NPDg3 permit administered by the Illinois EPA, and 2) Removes the requirement to perform fog and ice monitoring which is no longer necessary.

2) Involve a significant reduction in the margin of safety because this change does not effect any permit limit.

Based on the preceding discussion, it is concluded that the proposed l system change clearly falls within all acceptable criteria with respect to the system or component, the consequences of previously evaluated accidents  ;

will not be increased and the margin of safety will not be decreased.

i Therefore, based on the guidance provided in the Federal Register and the criteria established in 10 CFR 50.92(e), the proposed change does not constitute a significant hazards consideration.

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