ML20247D533

App B to License NPF-85,Environ Protection Plan (Nonradiological)

ML20247D533
Person / Time
Site:	Limerick
Issue date:	08/25/1989
From:	NRC
To:
Shared Package
ML20246G199	List: ML20246G202 ML20246G207 ML20247D533 ML20247D545
References
NUDOCS 8909150004
Download: ML20247D533 (15)

Text

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APPENDIX B TO FACILITY OPERATING LICENSE NO. NPF-85 LIMERICK GENERATING STATION UNITS 1 AND 2 l PHILADELPHIA ELECTRIC COMPANY DOCKET NOS. 50-352 AND 50-353 ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL)

August 25, 1989 I

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LIMERICK GENERATING STATION

.r UNITS 1.AND 2 0

ENVIRONMENTAL' PROTECTION PLANL

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(NON-RADIOLOGICAL)

TABLE OF CONTENTS  ;

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Section Page

.1. 0 OBJECTIVES OF-THE ENVIRONMENTAL PROTECTION PLAN . . . . . 1-1 2.0 ENVIRONitENTAL PROTECTION ISSUES'. . . . . . . . . . . . . 2-1 2.1 Aqu a t i c I s su es . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.2 Terrestria l Is sues. . . . . . . . . . . . . . . . . . . . 2-2

2.3 No i s e . I s s u e s . . . . . . . . . . . . . . . . . . .. . . . . . 2 3.0 CONSISTENCY REQUIREMENTS. . . . . . . .-. . . . . . . . . .

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.3.1 Plant Design and Operation. . . . . . . . . . . . . . . . 3-1 3.2 Reporting Related to the NPDES Permit and State Certifications. . . . . . . . . . . . . . . . . . . . . 3-2 3.3. Changes Recuired for Compliance with Other Environmental Regulations . . . . . . . . . . . . . . . 3-2 4.0 ENVIRONMENTAL C0hDITIONS. . . . . . . . . . . . . . . . . 4-1

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4.1. Unusual or Important Environmental Events . . . . . . . . 4-1 4.2 Environmental Monitoring. . . . . . . . . . . . . . . . . 4-1 5.0 ADM!iCSTRATIVE FRCCEDURES . . . . . . . . . . . . . . . 5-1 5.1 Review and Audit. . . . . . . . . . . . . . . , . . . . . 5-1 5.2 Records Re tention . . . . . . . . . . . . . . . . . . . . 5-1 5.3 Changes in Environmental Protection Plan. . . . . . . . . 5-1 5.4 Plant' Reporting Requirements. . . . . . . . . . . . . . . 5-2

1.0 OBJECTIVE 5 0F THE ENVIRONMENTAL PROTECTION PLAN The Environmental Protection Plan (EPP) is to provide for protection of f

non-radiological environmental values during operation of the nuclear facility.

The principal objectives of the EPP are as follows:

(1) Verify that the facility is operated in an environmentally acceptable manner, as established by the Final Environmental Statement-Operating i I

License Stage (FES-OL) and other NRC environmental impact assessments. j i

I (2) Coordinate NRC requirements and maintain consistency with other Federal, j State and local requirements for environmental protection. I (3) Keep NRC informed of the environmental effects of facility construction and operation and of actions taken to control those effects.

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

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• y h' + ~2.0 ENVIRONMENTAL PROTECTION ISSilES Ir.theFES-OLldatedApril,1984,thestaffconsideredtheenvironmental impacts associated with.the operation of the two. unit Limerick Generating Station. Certain environmental issues were identified which' required study or license conditions to resolve environmental concerns and to assure adequate' protection of the environment. )

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f 2.1 Aquatic Issues

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(1) During operation, the station blowdown temperature will exceed the maximum' )

permissible. temperatures set by the applicable water cuality standards.

However,. ths' affected area'of the Schuylkill River is expected to be smaller than the maximum area permitted by the Delaware River Basin i Commission. (FES Section 5.3.2.2) i (2) The water quality of the station discharge, after initial mixing with the Schuylkill River, is' predicted to, at times, exceed the applicable quality criteria for some constituents, based on source water maximum constituent concentrations. These exceedances are expected for constituents'whose maximum river concentrations also exceed the applicable criteria.

(FES Section 5.3.2.3)

(3) Chlorination of station cooling waters for condenser and cooling tower biofouling control may result in some adverse impacts to Schuylkill River biota in the vicinity of the station discharge. -(FES Section 5.3.2.3)

(4) Operation of the Point Pleasant Diversion will alter the hydrology,

, aquatic habitats, and water quality of the headwater section of the East Branch of Perkiomen Creek but the diversion waters are expected to provide beneficial dilution of waste loads entering the stream in its middle and lower reaches. (FES Sections 5.3.2.3 and 5.2.2)

(5) The supplemental cooling water withdrawal from Perkiomen Creek using state-of-the-art technology will result in localized effects from entrainment of fish larvae. (FES Section 5.5.2) 1 2-1 l

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2.2.- Terrestrial Issues '

No specific terrestrial issues were identified by the NRC-staff in the FES-OL. u 2.3 Noise Issues.

e.: .1 (1). Tones from the Point Pleasant pumphouse transformers are predicted to be audible and may cause annoyance at'a nearby residence. Noise monitoring _

and,. if necessary, mitigative measures to make the tones inaudible have been mandated by the ASLB.

(FES Sections 5.12.1 and 5.14.4.1)-

(2) Noise from transformers and pumps-in the Bradshaw Reservoir pumphouse may be audible at nearby residences. The licensee has. committed to ambient-and operational noise level monitoring and implementation of. identified mitigative measures, if necessary, to reduce noise levels below those likely to cause annoyance and complaints. (FES Sections 5.12.2 and 5.14.4.2)

(3) Offsite noise levels in the vicinity of the Limerick site during station  ;

operation are not expected to be high enough above ambient levels to annoy nearby residents. But because of uncertainties in the assessment, a confirmatory noise monitoring program and implementation of mitigative measures, if necessary, will be undertaken. (FES Sections 5.12.3 and 5.14.4.3) '

NRC requirements with regard to noise issues are specified in Section 4.3 of this EPP.

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'3.0 CONSISTENCY REQU!REMENTS 4

3.1 Pla'nt' Design and Operation The licensee may make changes in' station design or operation or perform tests -

or experiments affecting the environment provided such activities do not involve an unreviewed environmental question and do not involve a change.in the.EPP.* -Changes in station design or operation or performance of tests or

' experiments which-do not. affect the environment are not subject to the requirements of this EPP. Activities governed by Section 3.3 are not subject to the requirements of this Section.

Before engaging 1'n additional construction or operational activities which may significantly affect the. environment, the licensee shall prepare and record an environmental evaluation of such activity. Activities are excluded from this requirement if all measurable non-radiological environmental effects are confinec to the on-site areas previous?y disturbed during site preparation and plant construction. When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shall provide a written evaluation of such activity ard.obtain prior NRC approval. When such activity involves a change in the EPP, such activity and change to the EPP may be l implemented only in accordance with an appropr.iate license amendment as set forth in Section 5.3 of this EPP.

A proposed change, test or experimant shall be deemed to involve an unreviewed environmental question if it concerns. (1) a matter which may result in a significant increase'in hny adverse environ: rental impact previously evaluated in the FES-OL, environmental impact appreisals, or in any decisions of the l Atomic Safety and Licensing Board; or (2) a significant change in effluents or j

• This provision coes not relieve the licensee of the requirements of 10 CFR j 50.59 l 3-1 '

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c power level; or-(3) a matter not previously reviewed and evaluated in the-3 ' documents specified inl(1) of this Subsection, which may have.a significant:

adverse environmental impact.

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q The ifcensee shall maintain records of changes in. facility design or operation and of, tests'and experiments carried out pursuant to this' Subsection. These-records shall include written evaluations which provide bases for the 1 determination that;the change, test, or experiment does not involve an '

.unreviewed environmental. question or constitute a decrease in the-effectiveness of the EPP to meet the. objectives specified in Section.1.0. The licensee shall' j include as part of the Annual Environmental Operating Report (per Subsection I l

5.4.1) brief' descriptions, analyses, interpretations. and evaluations of such j changes, tests and experiments.

'3.2 Report'ino.Related to the NPDES Permit and State Certification Changes to, or renewals of, the NPDES Permit or the State certification shall be reported to the NRC within 30 days following the date the change or renewal is approved. If a permit or certification, in part or in its entirety, is appealed and stayed, the NRC shall be notified within 30 days following the date the stay is granted.

The licensee shall notify the NRC of changes to the effective NPDES Permit .

proposed by the licensee by providing the NRC with a copy of the proposed change at the same time it is submitted to the permitting agency. The licensee shall provide the NRC a copy of the application for renewal of the NPDES Permit at the same time the application is submitted to the permitting agency.

3.3 Changes Recuired for Compliance with Other Environtrental Regulations Changes in plant design or operation and performance of tests or experiments which are required to achieve compliance with other Federal, State and local

environmental regulations are not subject to the requirements of Section 3.1.

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'4.0 ENVIRONMENTAL. CONDITIONS

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4.1 ~ Unusual or important Environmental Events-

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Any occurrence' of an unusual or important event that indicates or could result 1

u. in significant environmental impact causally related to plant operation sha.ll be recorded and reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed by a written report per Subsection 5.4.2; The following are examples: excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or- .

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unusual occurrence of any species protected by'the Endangered Species Act of

-1973,. fish kills,, increase in nuisance organisms.or conditions, and unanticipated or emergency discharge of waste water or chemical substances.

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No routine monitoring programs are required to implement this condition.

4.2 Environmental Monitoring

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4 '. 2 .1 The certifications and permits required under the Clean Water Act provide j mechanisms for-protecting water cuality and, indirectly, aquatic biota. The-

' f1RC will rely on the decisions made by the Commonwealth of Pennsylvania, under ,

the authority of the Clean Water Act, for any requirements for aquatic monitoring. '

4.2.2 Terrestrial Monitoring i

No, terrestrial monitoring is required.

4.2.3 t'aintenance of Transmission Line Corridors {

t The use of herbicides within the Limerick Generating Station transmission  !

line corridors (Limerick to Cromby, Cromby to Plymouth Meeting, Cromby to North Wales, and Limerick to Whitpain) shall conform to the approved use of selected herbicides as registered by the Environmental Protection Agency and approved by Commonwealth authorities and applied as directed on the pesticide label.

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, .7 3 : y Records-shall'be maintained in the licensee's Electric Transmission and Distribution Department concerning herbicide use. Such records'shall include the following information: commercial and che:nical names of. materials used; concentration of active material in formulations for field use;' diluting substances other than water; rates of application; method of application;

. location; and the date of application. Such records shall be maintained for a period of 5 years from the date they are prepared and shall be made readily available to the NRC.upon request. There shall be no routine reporting requirement associated with this condition.

4.2.4 Noise Monitoring

'4.2.4.1 General Requirements for Sound Level Surveys Surveys shall be conducted to quantify the ambient (i.e., background) and the operational sound levels that exists at various locations in the vicinity of the LGS site and supplemental cooling water system facilities, as specified below. The ambient sound level surveys shall be conducted during the time period when significant station or supplemental cooling water system outdoor construction activity has ended, and with no operation of the cooling system  ;

or other significant noise sources (e.g., transformers) so that measured sound levels are not affected by such activities. The operational sound level '

suryeys shall be conducted as soon as practicable within the first year of the operational phase of the various station associated facilities, when transformers are energized or when the cooling-towers are operating with their design water flow rates, as appropriate for the facility under study. For the LGS site, one survey shall be conducted for one unit normal operation and a second survey for two unit normal operation. The conduct of the surveys for both phases shall be such that the results are comparable.

For each of the surveys, except as otherwise specified below or in LBP-83-11, sound level data shall be collected at several sites, the exact number and

' location te be selected by the licensee after consideration of (1) existing ersite and nearby offsite noise sources and barriers; (2) noise sensitive land uses in the site vicinity (e.g., residences, schools, churches, cemeteries, hospitals, parks); ano (3) previously conducted noise surveys in the site vicinity.

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The' selection, calibration and use of-equipment, conduct of the surveys, and 7.. the ' analysis and reporting of data shall conform to the provisions of the .

t' applicable _ American National Standards Institute Standards, The results of the surveys conducted under this program shall be summarized,

. interpreted and reported in accordance with Section 5.4.1 of this EPP.

2 The final report of this program.shall present a brief assessment by the licensee of the environmental impact and supplemental cooling water system operation on the varicus offsite acoustic environments, and shall describe the mitigative measures, if any, that have been, or.are to be taken to reduce the impact of plant or supplemental cooling water system noise levels on the offsite environments. 'This report shall also contain a list of noise-related complaints or inquiries received by Philadelphia Electric Company concerning the Limerick Generating Station or its supplemental cooling water system subsequent to issuance cf the operating license along with a description of the action taken by Philadelphia Electric Company to resolve these complaints or inquiries.

This program shall terminate upon completion of the collection of.the specified sound level data for each phase and submission of an acceptable final report.

4.2.4.2 Point Pleasant Purphouse

, An ASLB ruling (LBP-83-11; Parch 8,1983) requires that the licensee conduct a .,

one-time field study after the transformers are placed in operation at Point Pleasant. The noise from operation of the transformers shall be reduced to a level so that the transformer core tones will be inaudible (i.e., not above the masking level, as defined telow) at the site boundary.

The licensee shall determina, b6 sed on onsite measurements, the delta L(ex)

(i.e., the noise level in excess of the masking level) for each tore. The marking level is defined as "N" d3 above the ambient spectrum levei, where "N" is defined as follows:

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.18.2 480 The steps to be carried out are: .

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'(1)- Measures the' broadband (nontonal) ambient' nighttime (midnight'to 4 a.m.)-

!i levels in all octave bands of frequency when the tra isformers' are not

. energized (step.A in the ASLB ruling). From these, tone-masking sound levels.(thresholds of audibility) at each tone. frequency shall be -

calculated.

(2) Measure the' level of the tones-that exist when the transformers are energize'd (step B) in.the'one-third-octave bands that contain them.for comparison with the' calculated masking levels from step A to determine audibility. Transformer tones should.not be greater than the masking level for specific one-third-octave bands,.

If, for any reason, it is not practicable to de-energize the transformers at any time during the prescribed measurement time period-(midnight to 4 a.m.),

alternative measurements shall be made. .In'that event, only one measurement of the entire spectrum need be made, but it must be done entirely in one-third-octave bands. Any measured octave band sound level that includes a tone or tones cannot be used to determine the true background ambient sound level for that octave band. In such cases, the background ambient level in any one-third-octave band containing a tone shall be approximated by interpolating between those adjacent one-third-octave band levels that do not contain any tones.

If audible tones, defined as any delta L(ex) value greater than 0, are found at the site boundary, mitigative measures, such as a three-sided barrier or a 4-4

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full enclosure around the transformers, shall be implemented (and their

' performance' verified by noise measurement) so' that tones are not greater than

~ the masking level as previously-determined.

4.2.4.3 Bradshaw . Reservoir The noise measurements proposed for the Point Pleasant site shall be made at the'Bradshaw pumphouse site boundary while energized, on the line between the transformers a'nd residences B, D, and F, to determine if the tones would be audible at those points (see Figure 5.6 LGS Final Environmental Statement, NUREG-0974, p. 5-140). Measures to render these tones inaudible to thcee points shall.then be applied, as necessary, and their performance verified.

The measurement program recommended for.Bradshaw to test for audible tones from the transformers shall also be extended to include audible tones in the 1000-liz octave band at the southeast site boundary in the direction of -

residence B.

4.2.4.4 Limerick Site

- i., The operational measurement program to be applied to the Point Pleasant area shall be applied to the area immediately beyond the northern boundary of the Limerick site as well. If audible tones are found to be present at the northern site boundary af ter Unit I transformers are energizad, mitigative measures shall be taken end their performance verificd, as required for the Bradshaw Reservoir, to cause those tones to be inaudible..

Fer the LGS site only, data shall be collected from each sampling site during the time of yaar when foliage of deciduous trees is present and also during the time of year when such foliage is largely absent. Data collected from "

each sampling ' location shall encompass both the daytime and nighttime periods.

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D . 5.0.1 ADMINISTRATIV

E. PROCEDURE

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5.1' Review and Audit-t L

The licensee shall; provide for review and audit of compliance with the EPP.

The' audits shall be. conducted independently of the .fodividual or groups responsible for performing the specific activity.. A description'of the-organizational' structure utilized to achieve the independent review and audit function and results of the audit activities shall be maintained and made {

available'for. inspection.

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5.2 Records Retention Records and logs relative to the environmental aspects of station operation shall be made and' retained in a manner convenient for review ana inspection.

'These records and logs shall be made available to NRC on request.

Records of modifications to station structures, systems and components determined to potentially affect the continued protection of the environment shall be retained _for the life of the station. .All other records, data and logs relating to this.EPP shall be retained for five years or, where applicable, in accordance with the requireme,nts of other agencies.

5.3 Changes in Environmental Protection Plan Request for changes in the EPP shall include an assessment of the environmental impact of the proposed change and a supporting justification. Implementation of such changes in the EPP shall not commence prior to NRC approval of'the proposed changes in the form of a license amendment incorporating the appropriate revision to the EPP.

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r 5.4 Plant Reporting Requirements 5.4.1 Routine Reports An Annual: Environmental Operating Report describing implementation of this EPP for the previous year shall be submitted to the NRC prior to May 1 of each year. The initial report shall be submitted prior to May 1 of the year following issuance of the operating license.

The report shall include summaries and analyses of the results of the environ-mental protection activities as required by Subsection 4.2 of this EPP for the report period, including a comparison with related preoperational studies, operational controls (as appropriate), and previous non-radiological environmental monitoring reports, and an assessment of the observed impacts of the plant operation on the environment. If harmful effects or evidence of

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trends towards i* reversible damage to the environment are observed, the licensee shall provide a detailed analysis of the data and a proposed course of mitigating action.

The Annual Environmental Operating Report shall also include:

(1) A list of EPP noncompliance and the corrective actions taken to remedy them.

(2) A list of all changes in station design or operation, tests, and experiments made in accordance with Subsection 3.1 whien involved a potentially significant unreviewed environmental question.

. (3) A list of nonroutine reports submitted in accordance with Subsection 5.4.2.

In the event that some results are not available by the report due date, the report shall be submitted noting and explaining the missing results. The missing results shall be submitted as soon as possible in a supplementary report.

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+ 5.4.2. Nonroutine. Reports 4

A written report shall be submitted to the NRC within 30 days of occurrence of a nonroutine event. The report shall (a) describe, analyze, and evaluate the event, including extent and magnitude of the impact and plant operating characteristics,-(b) describe the probable cause of the event, (c) . indicate the action taken to correct the reported event, (d) indicate the corrective action taken to preclude repetition of the event and to prevent similar occurrences involving similar components or systems, and (e) indicate the agencies notified-and their preliminary responses.

Events reportable under this subsection which also require' reports to other Federal, State or local agencies shall be reported in accordance with.those reporting requirements in lieu of the requirements of this subsection. The NRC shall be provided i copy of such report at the same time it is submitted to the other. agency.

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