View source for CNRO-2003-00059, Revised License Amendment Requests Regarding Proposed Deletion of Appendix B, Environmental Protection Plan (Non-Radiological) from the Facility Operating License

{{Adams
| number = ML033290617
| issue date = 11/18/2003
| title = Revised License Amendment Requests Regarding Proposed Deletion of Appendix B, Environmental Protection Plan (Non-Radiological) from the Facility Operating License
| author name = Krupa M
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000382, 05000416, 05000458
| license number = NPF-029, NPF-038, NPF-047
| contact person = 
| case reference number = CNRO-2003-00059
| document type = Environmental Protection Plan, Letter type:CNRO, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 51
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Entergy Operations, Inc.
1340 Echelon Parkway Entergy                                                           Jackson, MS 39213-8298 Tel 601 368 5758 Michael A. Krupa Director Nuclear Salety &Licensing CNRO-2003-00059 November 18, 2003 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

==SUBJECT:==
Revised License Amendment Requests Proposed Deletion of Appendix B, Environmental Protection Plan (Non-Radiological) from the Facility Operating License Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 NPF-29 River Bend Station, Unit 1 Docket No. 50-458 NPF-47 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 NPF-38

==REFERENCES:==
License Amendment Requests Proposed Deletion of Appendix B, Environmental Protection Plan (Non-Radiological) from the Facility Operating License Dated November 6, 2002

==Dear Sir or Madam:==

By the referenced letter, Entergy Operations, Inc. (Entergy) proposed a change to delete the content of the Appendix B, Environmental Protection Plan (Non-Radiological) (EPP) for Grand Gulf Nuclear Station, Unit 1 (GGNS), River Bend Station (RBS), and Waterford Steam Electric Station, Unit 3 (Waterford 3) Facility Operating Licenses (FOLs). The amendment requests were considered to be administrative in nature and were intended to delete obsolete program information and relieve Entergy of the burden of preparing and submitting certain environmental reports.
Based on discussions with the NRC staff, Entergy agreed that certain elements of the EPPs would remain. The attached marked-up pages of the EPPs contain the requirements that will remain in place. Some minor changes were made to update terminology, standardize the EPPs, or to slightly modify or clarify certain reporting requirements without changing the intent. The attached mark-ups supercede the originals in their entirety. The scope of the original no significant hazards consideration, included in the referenced letter, bounds all changes made by these revisions.
Hir I

CNRO-2002-00059 Page 2 of 3 The proposed change includes no new commitments.
If you have any questions or require additional information, please contact Bill Brice at 601-433-5076.
I declare under penalty of perjury that the foregoing is true and correct. Executed on November 5, 2003.
Sincerely, MAKAWBB/bal Attachments:
: 1. Proposed Facility Operating License Changes (mark-up) - Grand Gulf Nuclear Station, Unit 1
: 2. Proposed Facility Operating License Changes (mark-up) - River Bend Station
: 3. Proposed Facility Operating License Changes (mark-up) - Waterford Steam Electric Station, Unit 3 cc:             Mr. Bruce S. Mallett Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission Attn: Mr. Bhalchandra Vaidya, NRR/DLPM ATTN: ADDRESSEE ONLY Mail Stop OWFN/7-D1 Washington, DC 20555-0001 Mr. Brian W. Amy, MD, MHA, MPH Mississippi Department of Health P. 0. Box 1700 Jackson, MS 39215-1700 Mr. T. L. Hoeg, GGNS Senior Resident Mr. D. E. Levanway (Wise Carter)
Mr. H. L. Thomas NRC Senior Resident Inspector P. 0. Box 1050 St. Francisville, LA70775

CNRO-2002-00059 Page 3 of 3 cc (cont'd) U. S. Nuclear Regulatory Commission Attn: Mr. Mike Webb MS 0-7D1 Washington, DC 20555-0001 Louisiana Department of Environmental Quality Office of Environmental Compliance Attn. Prosanta Chowdhury Surveillance Division P. O. Box 4312 Baton Rouge, LA 70821-4312 NRC Senior Resident Inspector Waterford NPS P.O. Box 822 Killona, LA 70066-0751 U.S. Nuclear Regulatory Commission Attn: Mr. Nageswaran Kalyanam MS 0-7D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway Attn: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn Attn: N.S. Reynolds 1400 L Street, NW Washington, DC 20005-3502 Louisiana Department of Environmental Quality Office of Radiological Emergency Plan and Response Surveillance Division P. O. Box 4312 Baton Rouge, LA 70884-4312 American Nuclear Insurers Attn: Library Town Center Suite 300S 2 9 th S. Main Street West Hartford, CT 06107-2445

Attachment I CNRO-2003-00059 Proposed Facility Operating License Changes (mark-up)
Grand Gulf Nuclear Station, Unit 1

APPENDIX B TO FACILITY LICENSE NO. PF-29 GRAND GULF NUCLEAR STATION UNIT I ENTERGY OPERATIONS,  INC.                     [
DOCKET NO. 50-416 ENVIRONMENTAL PROTECTION PLAN OCTCEER 1984 Amendment No. 65

GRAND GULF NUCLEAR STATION UNIT 1 ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL)
TABLE OF CONTENTS Section                                                            Page 1.0 Objectives of the Environmental Protection Plan.    . . .  . . 1-1 2.0  Environmental Protection Issues. . . . . . . . . .            2-1 2.1 Aquatic Issues . . . . . . . . . . . . . . . . . .             2-1 2.2 Terrestrial   ssues ................                           2-1 3.0 Consistency Requirements . . . . . . . . . . . . .             3-1 3.1  Plant Design and Operation . . . . . . . . . . . .            3-I 3.2 Reporting Related to the NPDES Permits and State Certification. . . . . . . . . . . . . . . . . . .. . .       3-2 3.3 Changes Required for Compliance with Other Environmental Regulation . . . . . . . . . . . . . . . . . . . . . .  . . . 3-3 4.0 Environmental Conditions . . . . . . . . . . . . .             4-1 4.1 Unusual or Important Environmental Events. . . . .             4-1 4.2 Environmental Monitoring . . . . . . . . . . . . .             4-1 5.0 Administrative Procedures. . . . . . . . . . . . .             5-1 5.1 Review and Audit . . . . . . . . . . . . .                     5-1 5.2 Records Retention. . . . . . . . . . . . .                      5-1 5.3 Changes in Environmental Protection Plan                       5-1 5.4 Plant Reporting Requirements . . . . . . .                     5-2

*1.0   OBJECTIVES OF THE ENVIRONMENTAL PROTECTION PLAN The Environmental Protection Plan (EPP) is to provide for protection of environmental values during                  operation of the nuclear facility.
The principal objectives of the EPP are as follows:
(1) Verify that the Plant is operated in an nvironmentally acceptable manner, as established by the FES and other NRC environmental impact assessments.
(2) Coordinate NRC requirements and maintain consistency with other Federal, State and local requirements for environmental protection.
(3) Keep NRC informed of the environmental effects of facility i   operation and of action taken to control those effects.
Environmental concerns identified in the FES which relate to water quality matters are regulated by way of the GGNS NPDES permit.
1-1                  Amendment No. 27    l

2.0    ENVIRONMENTAL PROTECTION ISSUES In the FES-OL dated September 1981, the staff considered the environmental impacts associated with the operation of the Grand Gulf Nuclear Station.
Certain environmental issues were identified which required study or license conditions to resolve environmental concerns and to assure adequate protection of the environment.
2.1    Aaic     IsF               dr      or   tet  /O-e ff  o aqu tic ssues were dentified n the FES-OE. Effluent lmitations nd monitoring requirements are contained in the effective NPDES permit issued by the                         __                         NRC__will
__     _.The rely on (dteIncees   agenc for regulation of these matters as they involve water quality and aquatic bit.
2.2    Terrestrial Issues (1) Potential erosion along transmission line corridors during and immediately following their construction.
(2) Potential impact of cooling tower drift on vegetation surrounding the sites. In the FES the staff recomiended an aerial remote sensing program.
The applicant opted to do a more detailed surveillance program.
NRC requirements with regard to the terrestrial issues are specified in Subsection 4.2 of this EPP.
2-1             Amendment No. 96

3.0   CONSISTENCY REQUIREMENTS 3.1   Plant Design and Operation The licensee may   ake changes in plant design or operation or perform tests or experiments affecting the environment provided such changes, tests or experi-ments do not involve an unreviewed environmental question, and do not involye a change in the Environmental Protection Plan.0   Changes in plant design or operation and performance of tests or experiments which do not affect the environment are not subject to the requirements of this EPP. Activities governed by Section 3.3 are not subject to the requirements of this section.
Before engaging in additional construction or operational activities which may affect the environment, the licensee shall prepare and record an environmental evaluation of such activity.
* When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shall provide a written evaluation of such activities and obtain prior approval from the Director, Office of Nuclear Reactor Regulation. When such activity involves a change in the Environmental Protection Plan, such activity and change to the Environmental Protection Plan may be implemented only in accordance with an appropriate license amendment as set forth in Section 5.3.
A proposed change, test or experiment shall be deemed to involve an unreviewed environmental question if it concerns (1) a matter which may result in a sig-nificant increase in any adverse environmental impact previously evaluated in the final environmental statement (FES) as modified by staff's testimony to the Atomic Safety and Licensing Board, supplements to the FES, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing This provision does not relieve the licensee of the requirements of 10 CFR 50.59.
tActivities are excluded from this requirement if all measurable environmental effects are confined to on-site areas previously disturbed during site pre-paration and plant construction.
3-1

Board; or (2) a significant change in effluents or power level; or (3) a matter not iteviously reviewed and evaluated in the documents specified
  *in(1)of this Subsection, which may have a significant adverse environmental impact.
The licensee shall maintain records of changes in plant design or operation and of tests and experiments carried out pursuant to this Subsection. These records shall Include a written evaluation which provide bases for the determination that the change, test, or experiment does not nvolve an unreviewed environmental question nor constitute a decrease in the effectiveness of this EPP to eet.the objectives specified in Slicensee                  shall nclude as part of t Annual Environmental Operating eport (per Subsection 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiment s.
3.2   Reporting Related to the NPDES Permits and State Certification Violations of the NPDES permit or the State certification (pursuant to Section 401 of the Clean Water Act, respectively) shall be reported to the NRC by submittal of copies of the reports required by the NPDES permit or certifi-cation.
Changes and  additions to the NPDES permit or the State certification shall be reported to  the NRC within 30 days following the date the change is approved.
If    permit or certification, n 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 NRC shall be notified of changes proposed by the licensee to the effective NPDES permit by providing NRC with a copy of the proposed change at the same time it is submitted to the permitting agency. The notification of a licensee-initiated change shall Include a copy of the requested revision submitted to the permitting agency. The licensee shall provide the NRC with a copy of its application for renewal of the PDES permit at the same time the application is submitted to the permitting agency.
... m a e5 3-2

Insert A The NRC shall be provided with a copy of the current NPDES permit or State certification within 30 days of approval. Changes to the NPDES permit or State certification shall be reported to the NRC within 30 days of the date the change is approved.

3.3  Changes Required for Compliance with Other Environmental Regulations Changes in pant design or operation and performance of tests or experiments other Federal, State, or local environmental regulat ons are not subject to requirements of Section 31.
6- at ffieda Zee        fed             jaD t tE e r reds Z lereS Orret D I ,
3-3

JXw on et'eT            is         brrepaJr7-Ie under O CR -                     rAen X t p #.re emped are reporT adder A1c u>E                          "         7-nosy-ec7or rel qurkdO. hoots e. et t e ,6o//o0-4                   '      Jt'rpen       ep'OCT Pe-r S Ser'-P            s-M. a hi sT.ill re fcAi rem 4.0   ENVIRONMENTAL CONDITIONS 4.1   Unusual or Important Environmental Events            PeCrlrV     7S    efler Any occurrence of an unusual or important event that Indicates or could result in significant environmental impact causally'relat      to station operation berecorded and promptly reported to the      within iR    24 hours      r followed by a written report per Sub-section 5.4.2. The following are examples: excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or 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.
No routine monitoring programs are required to implement this condition.
4.2   Environmental Monitoring Deviations from required monitoring programs will not be a violation of license requirements if samples are accidentally spilled or contaminated, or if samples are unattainable due to hazardous conditions, seasonal unavailability, or malfunction of equipment.
4.2.1   Erosion Control Inspection Maintenance and monitoring of the transmission line cordrrghts-of-way wl be conducted as a part of the normal transmission line inspections from the GGNS to the Franklin in EHV Switching Station, to the Baxter Wilson Steam Electric Station Switchyard, and to the Port Gibson Substation. These inspections, conducted by aerial surveys and walking patrols at periodic intervals, include monitoring for erosion or vehicular damage caused by right-f-way encroachment by hunters and loggers. Problem areas will       eni  d 1rh e~o;,05o moro                                    razzD m adCol     f monitrIng 1)1 f'f05ro4$ s                 6J.
7eJ    Xn Sobs ec'n 9, kqve h ee-J ff/eeS4 ,icbz o
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                                                            'ndrik         tne     Krhese And~~~~                    1 d

by the aerial surveys, and walking patrols will be directed to the problem areas to evaluate the extent of the problem to be corrected, The Erosion Control Inspection Program shall begin upon commencement of normal transmission line inspection procedures. Semi-annual surveys shall continue until stabilization of soil and vegetation (i.e., ground cover establishment) is achieved.
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 the Annual Environmental Operation Report in accordance with Subsection 5.4.1. Field logs indicating locations of erosion damage and masures taken to rectify erosion problem areas and estimation of the time to achieve effective stabilization will be maintained and available for inspection for a period of five years. Results reported shall contain information encompassing but not limited to inspection date, estimated size of erosion problem area, probable cause of erosion, type of stabilization program, and date of effective stabilization, as appropriate.
4.2.2 Cooling Tower Drift Program Seven sampling sites were utilized to measure cooling tower drift-deposition.
At least two of the sampling sites had duplicate sampling devices. Six of the seven sites were located in areas where aximum salt deposition was predicted.
These areas wer, extrapolated from the Bechtel Salt Deposition Model developed for the GNS Final Environmental Rport. The seventh sampling site was a control site located south of Raymond, Mississippi. An eighth offsite control site was added in 1985 in Port Gibson, Mississippi.
Fallout samples were collected on a quarterly basis and analyzed for ten specific constituents. The details of the sampling procedure and chemical 4-2             Amendment No.  ,  96

an& ys s were submitted to the NRC's Environmental Engineering Branch for reviewa
( and approval prior to plant operation above SX power. An valuation of the        )
results of the Cooling Tower Drift Program ndicated that the operation of the GGNS cooling tower produced no statistically significant effect upon the salt deposition rate for those chemical species evaluated. The cooling tower drift program was therefore terminated.
4-3            Amendment No. 96

5.0  ADMINISTRATIVE PROCEDURES 5.1  Review and Audit The licensee shall provide for review and audit of compliance with the Environmental Protection Plan. The audits     hall be conducted independently of the individual or groups responsible for performing the specific activity. A description of the organization structure utilized to achieve the independent review and audit function and results of the audit activities shall be maintained and made available for inspection.
5.2  Records Retention C43soc,4r0CI 7-.W                ilh,5 t         E Record                                        ena shall be made and retained in a manner convenient for review and inspection.
These records            shall be made available to NRC on request.
Records of modifications to plant structures, systems and components determined to potentially affect the continued protection of the environment shall be retain       _of               _     .All     other rec ords                relating o this EPP shall be retained for five years or, where applicable, in accordance with the requirements of other agencies.
5.3  Changes     n Environmental Protection Plan Requests for changes in the Environmental Potection Plan shall include an assessment of the environmental impact of the proposed change and a supporting justification. Implementation of such changes in the EPP shall not commence prior to NRC approval of the proposed changes in the form of a licensee amendment incorporating the appropriate revision to the Environmental Protection Plan.
wwa,'t The      cre Oz the re rr",n                   od oF:t-h       )    et 5-1

5.4   Station Reporting Requirements 5.4.1               w* De An Annual Environmental Operating Report describing implementation of ts      P    \
for the previous year shall be submitted to the   RC prior to Kay    of each year. The initial report shall be submitted prior to  ay    of the year follow-l ing issuance of the operating license. Theperiod of the first report shall begin with the date of issuance of the operating license for the first operational unit.
The report shall include summaries and analyses of the results of the environmental protection activities required by Subsection 4.2 of this Environ-mental Protection Plan for the report period,   ncluding a comparison with preoperational studies, operational controls (as appropriate), and previous non-radiological environmental monitoring reports, and an assessment of the observed impacts of the station operation on the environment. If harmful effects or evidence of trends towards irreversible damage to the environment are observed, the licensee shall provide a detailed analysis of the data and a proposed course of action to alleviate the problem.
The Annual Environmental Operating Report shall also include:
(a) A list of EPP noncompliances and the corrective actions taken to remedy them.
(b) A list of all changes in station design or operation, tests, and experiments made in accordance with Subsection 3.1 which involved a potentially significant unreviewed environmental issue.
(c) A list of nonroutine reports submitted in accordance with Subsection 5.4.2.
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 kissing data shall be submitted as soon as possible in a supplementary report.
5-2

5.4.2  Nonroutine Reports
.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 these  mpact and plant operating characteristics, (b) describe the probable cause of the event, (c) indicate the action taken to correct the reported event, (d) ndicate the corrective action taken to preclude repetition of the qvent 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 MRC shall be provided with a copy of each report at the same time it is submitted to the other agency.
r- 3

Attachment 2 CNRO-2003100059 Proposed Facility Operating License Changes (mark-up)
River Bend Station

APPENDIX B TO FACILITY OPERATING LICENSE NO. NPF-47 RIVER BEND STATION UNIT ENTERGY OPERATIONS, INC.
DOCKET NO. 50-458
                                              .... :RECEIVED:: :::::::
::G::.0      :: ::::19       - :::.-:::
ENVIRONMENTAL PROTECTION PLAN (NONRADIOLOGICAL)
Amendment No. :O, 79

RIVER BEND STATION UNIT 1 ENVIRONMENTAL PROTECTION PLAN (NONRADIOLOGICAL)
TABLE OF CONTENTS Section                                                                                                                                             Page 1.0 Objectives of the Environmental Protection Plan .                                             ................................................. 1-1 2.0 Environmental Protection Issues ...........................................................                                                       2-1 2.1 Aquatic Issues ..........................................................                         .                                               2-1 2.2  Terrestrial Issues ..........................................................                                                                    2-1 2.3   Noise Issues ..........................................................                       .                                                 2-1 3.0   Consistency Requirements                                                  ....................................                                  3-1 3.1   Plant3.1 Design Plantand Design  and Operation Operation........0S,    .....                            3..............................................- 3-1 3.2   Reporting Related to the NPDES e                                         an Pe Certifications ........................ 3-2 3.3   Changes Required for Compliance with Other Environmental Regulations .......... 3-3 4.0   Environmental Conditions                                                 .....................................                                  4-1 4.1 Unusual or Important Environmental Events .........................................................                                               4-1 4.2 Environmental Monitoring                                                   .....................................                                  4-1 5.0 Administrative Procedures                                           ......................................................... 5-1 5.1   Review and Audit..................................................................................................5-1 5.2   Records Retention .........................................................                                                                     5-1 5.3   Changes in Environmental Protection Plan                                            .....................................                       5-2 5.4   Plant Reporting Requirements ..........................................................                                                         5-2

1.0      Objectives of the Environmental Protection Plan The Environmental Protection Plan (EPP) is to provide for protection of nonradiological 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 Licensing Stage (FES-OL) and other NRC environmental impact assessments.
(2)    Coordinate NRC requirements and maintain consistency with other Federal, State and local requirements for environmental protection.
(3)    Keep NRC informed of the environmental effects of facility          toperation and of actions taken to control those effects.
Environmental concerns identified in the FES-0          h.l~e to water quality matters are or~ADEJ regulated by way of the licensee's NPDES'perTiI~-
1-1

2.0         Environmental Protection Issues In the FES-OL dated January 1985, the staff considered the environmental impacts associated with the operation of the River Bend Station Unit 1. Certain environmental issues were identified which required study or license conditions to resolve environmental concerns and to assure adequate protection of the environment.
2.1         Aquatic Issues                                            T7n5     r No specific aquatic issues were identified by the NRC staff in the FES-OL.
2.2         Terrestrial Issues Detection of possible changes in or damage to local flora caused by drift deposition due to the operation of the River Bend Station Cooling Towers. (FES-OL Section 5.14.1) 2.3         Noise Issues Adverse community reaction is expected from noise of operation of the plant (FES-OL, Section 5.12). A monitoring program to identify the extent of impacts and the mitigative actions necessary, if any, is specified in Section 4.bOFES-OL Section 5.14) 2-1

Insert A Effluent limitations and monitoring requirements are contained in the effective NPDES or LPDES permit issued by the Federal or State permitting authority. The NRC will rely on these agencies for regulation of these matters as they involve water quality and aquatic biota.

3.0      Consistency Requirements 3.1      Plant 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 in 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 nonradiological environmental effects are confined to the on-site areas previously disturbed during site preparation and plant construction. When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shall provide a written evaluation of such activity and obtain prior NRC approval. When such activity involves a change in the EPP, such activity and change to the EPP may be implemented only in accordance with an appropriate license amendment as set forth in Section 5.3 of this EPP.
* This provision does not relieve the licensee of the requirements of 10 CFR 50.59.
3-1

A proposed change, test or experiment shall be deemed to involve an unreviewed environmental question if it concerns: (1)a matter which may result in a significant increase in any adverse environmental impact previously evaluated in the FES-OL, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board; or (2) a significant change in effluents or power level; or (3) a matter, not previously reviewed and evaluated in the documents specified in (1)of this Subsection, which may have a significant adverse environmental impact.
The licensee shall maintain records of changes in facility design or operation and of tests and experimehts' carried out pursuant to this Subsection. These records shall include written evaluations which provide bases for the determination that the change, test, or experiment does not involve an unreviewed environmental question or constitute a decrease effectiveness of this EPP to meet the objectives specified in Section 1.0.The licensee shall include as part of the Annual Environmental Operating Report (per Subsection 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and 3.2           Reporting Related to the NPDES Permit and State Certification Te censee shall notify the NRC of proposed revisions to the effective NPDES Permi           f Jproposed    revision is a significant change of waste stream flow rate, concentration, or poin of discharge. This shall be done by providing NRC with a copy of the proposed revision at the same 3-2

Insert B The NRC shall be provided with a copy of the current NPDES or LPDES permit or State certification within 30 days of approval. Changes to the NPDES or LPDES permit or State certification shall be reported to the NRC within 30 days of the date the change is approved.

ime iis submitted to the permitting agency. The licensee shall provide the NRC a copy o the a application for renewal of the NPIDES Permit at the same time the application is submitted to the permitting agency.
Changes to, or renewals of, the NPDES Permits 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 notifiedwti Eday folowng he ate the stay is granted.
3.3           Changes Required for Compliance with Other Environmental Regulations Changes in plant design or operation and performance of tests or experim ents ther=Federal, State, and local environmental regulations areno subec tthreurmnsoScin3 07ttaare      oise        r repv Wed<              o r rz~&#xa2;~Xs 3-3

_Lf a             event is reportable nder I6f1? AP, 7, rAeC
   } dL~tliC~;              i'ruediate rporrunderthis 5oC                              er6"i         nr rteqai'red He wetb -i-e- *F/-4                                        Defnrp                   rPr
   .0
              \    Sub 5         elf Environmental Conditions res       ~~u;rec      -
4.1            Unusual or Important Environmental Events
            }er-                     7 Any occurrence of an unusual or important event that indicates or could result in significant nvironmental impact causally related to plant operation shall be recorded and reporte NRC       ithin 24 hours 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 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.
No routine monitoring programs are required to implement this condition.
4.2            Environmental Mo
        /he T>erresrcIO      1-'rOrK?2-nJ NoLde                        fr J P r&deg;7            ijerTi'ev
      '7 S*s      s ecT',/oi aS a                 . 3 h/Le beerbal      co,9'ie eth J           I) o trTte)
                        -re~rc/
Lo       e 0telsTec,
  /Te ceriiaon an             ermit required under the Clean Water Act provide mechanisms fr(
protecting water quality and, indirectly, aquatic biota. The NRC will rely on the decisions made {
by the U.S. Environmental Protection Agency and the State of Louisiana under the authority of the Clean Water Act for any requirements for aquatic monitoring.
4-1

/4.2.2        Terrestrial Monitoring                                           7 Vegetative communities of the site and vicinity within 1 Kilometer of the cooling towers in all directions shall be aerially photographed to detect and assess the significance of damage, or lack thereof, as related to cooling tower drift dispersions. Photography shall be done by aerial overflight during September or early October. Monitoring shall include a program of low altitude color Infrared photography. The scale for full coverage shall be adequate to enable identification of vegetative damage over relatively small areas of terrain. Some circumstances may warrant inspection of photographs discerning individual trees. Such scale should be adequate to resolve impacted features. Photographs taken during plant operation shall be compared with pre-operational photographs (baseline) to ascertain changes in vegetation.
Photographic interpretations shall be verified by ground inspection surveys to confirm areas of stress and non-stress. This program shall require aerial photographic monitoring to begin 2 years preceding initiation of cooling tower operation and during the following first and third years. If adverse effects are observed, the NRC will require the applicant to repeat the study in additional years and to perform examinations of vegetation, both on and off site, to determine the extent of the damage. Such studies are necessary to determine the need for any corrective action to mitigate the impacts.
A report shall be submitted as part of the annual report following each aerial photographic monitoring period. The report shall contain a 4-2

  /   escription of the program, results and interpretative analysis of environmental impacts.         \
is Results reported shall contain information encompassing but not limited to the following:
sampling date, time of day, film types, and one (1) set of resultant color transparencies encompassing an area within approximately a one Kilometer (1 Km) radius of the Station's normal cooling towers.
4.2.3        Noise Monitoring A noise monitoring program shall be conducted in the site vicinity during the first full year following the onset of commercial operation of River Bend Station. The purpose of the program is to characterize the Station's operational noise levels, to compare these levels with ambient levels recorded during 1972 and 1980 surveys, and to evaluate the community impact, if any, of cooling tower fan blade tonal noise and incremental broadband noise.
The monitoring program will include measurements of sound levels at the nearest residence in each of six 45- (forty-five degree) directional sectors from the Northwest through the South (i.e., residences R1, R4, and R7 shown on Figure 5.22 FES-OL, and three additional residences in the compass sectors East, Southeast, and South. At each location daytime and nighttime (midnight to 4:00 a.m.) measurements will be made once in Winter and Summer to obtain statistical indicators (L90, Lso, Leq) for a weighted decibel levels. Additionally one-third octave band analysis will be performed at each location on each visit.
4-3

esult of these surveys will be evaluated and included in the annual environmental lmonitoring report. If noise Impacts are identified during the Summer or Winter surveys a discussion of proposed mitigative measures will be included In the monitoring report.
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5.0           Administrative Procedures 5.1           Review and Audit The licensee shall provide for review and audit of compliance with the EPP. The audits shall be conducted independently of the individual or groups responsible for performing the specific activity. A description of the organization structure utilized to achieve the independent review and audit function and results of the audit activities shall be maintained and made available for inspection.
5.2            Records Retention Records                                                                          shall be made and retained in a manner convenient for review and inspection. These records;;                 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 All other recordsrrelating                 to this EPP shall be retained for five years or, where applicable, in accordance with the requirements of other agenci 5-1

5.3          Changes in Environmental Protection Plan Requests for changes In the EPP shall include an assessment of the environmental impact of the proposed change and a supporting justification. Implementation of such changes in the EPP shall not commence prior to NRC approval of the proposed changes in the form of a license amendment incorporating the appropriate revision to the EPP.
5.4          Plant. Reporting Requirements 5.4.1                          ~re@-   -
nnnaEvrnena                       eot    eciigiplementation of this EPP           r   el pevious year shall be submitted within 90 days following each anniversary of issuance of the  l operating license. The period of the first report shall begin with the date of issuance of the operating license.
The report shall include summaries and analyses of the results of the environmental protection activities 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 nonradiological environmental monitoring reports, and an assessment of the observed impacts of the plant operation on the environment. If harmful effects or evidence of trends toward irreversible damage to the environment are observed, the licensee shall provide a detailed analysis of the data and a proposed course of mitigating action.
5-2

l Te Annual Environmental Operating Report shalllalsoonclude:
(1)     A list of EPP noncompliances 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 which 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.
5.4.2       Nonroutine Reports 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 5-3

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 with a copy of such report at the same time it is submitted to the other agency.
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Attachment 3 CNRO-2003100059 Proposed Facility Operating License Changes (mark-up)
Waterford Steam Electric Station, Unit 3

APPENDIX B TO FACILITY OPERATING LICENSE NO. NPF-38 WATERFORD STEAM ELECTRIC STATION - UNIT NO. 3 ENTERGY LOUISIANA, INC.                           I DOCKET NO. 50-382 ENVIRONMENTAL PROTECTION PLAN (NONRADIOLOGICAL)
MARCH 1985 AMENDMENT NO. 134

WATERFORD STEAM ELECTRIC STATION - UNIT NO. 3 ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL)
TABLE OF CONTENTS Section                                                                 Page 1.0  Objectives of the Environmental Protection Plan . .      . .      1-1
.2.0 Environmental Protection Issues....      . . . . . . . . . .       2-1 2.1  Aquatic Resources Issues. . . . . . . . . . . . . . . . .         2-1 2.2  Terrestrial Resources Issues. . . . . . . . . . . . . . . . 2-1 2.3  Cultural Resources Issues . . . . . . . . . . . . . .             2-1 3.0  Consistency Requirements. . . . . . . . . ..    .  . . .     .. 3-1 3.1  Plant Design and Operation.  . .  .                             . 3-1 3.2 Reporting Related to the        Fe State Certification    . . . . . . . . . . . . . . . . .        . 3-2 3.3. Changes Required for Compliance with other Environmental Regulations . . . . . . . . . . . . . . . . . 3-3 4.0 Environmental Conditions. . . . . . . . . . . . . . .            . 4-1 4.1  Unusual or Important Environmental Events. . . . . . . . .        4-1 4.2 -Environmental Monitoring. . . . . . . . . . . . . . . . . . 4-1 5.0  Administrative Procedures   . . . . . . . . ..  . . . . .       . 5-1 5.1  Review and Audit... . . . . . . . . . . . . . . . . .           . 5-1 5.2  Records Retention .   . . .  . . . . . . . . . . . . . . . . 5-1 5.3  Changes in Environmental Protection Plan. . . . . . . . . . 5-1 5.4  Plant Reporting Requirements. . . . . . . . . . . . . . . . 5-2

1.0 Objectives of the Environmental Protection Plan The Environmental Protection Plan (EPP) is to provide for protection of environmental values during                 toperation of the nuclear facility. The principal objectives of the EPP are as follows:
(1) Verify that the plant is operated in a environmentally acceptable manner, as established by the FES-OL and other NRC environmental impact assessments.
(2) Coordinate NRC requirements and maintain consistency with- other Federal, State, and local requirements for environmental protection.
(3) Keep NRC informed of the environmental effects of facility
    ~               and of actions taken to control those effects.
Environmental concerns identified in the FES-OL which relate to water quality matters and regulated by way of the licensee's NPDES permit.

2;0  Environmental Protection Issues In the FES-OL dated September 1981, the staff considered the environmental impacts associated with the operation of Waterford Steam Electric Station Unit No. 3. The environmental resources which were evaluated, and the corresponding NRC staff decisions regarding the protection of each resource are as follows:
2.1  Auatic Resources Issues pere, 'I-   ssu.e-o by trhe_ FegtertrJc'r Srle preoqt#fth1'lj 4rA o;
* Effluent limitations and monitoring requirements are contained in the NPDES   ort D0
              .The NRC wl   rely on      orr   ultain of matters involving the protection of water quality and aquatic biota.
2.2 Terrestrial Resources Issues No terrestrial resources issues were raised by the staff in the FES-OL..
2.3 Cultural Resources Issues There are two archaeological sites on the licensee's property which have been determined to be eligible for the National Register of Historic Places.
Protection for these two sites will be provided through a Cultural Resources Protection Plan. NRC requirements with regard to the cultural resources issue are specified in Subsection 4.2.1 of this EPP.
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3.0   Consistency Requirements 3.1   Plant 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 d not involve a change in the EPP. Changes in plant design or operation or performance of tests or experiments which do not affect the..env.ironment are not subject to the requirements of this EPP. Activities governed by Section 3.3-are not subject to the requirements of this Section.
Before engaging in construction or operation 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 nonradiological effects are confined to the on-site areas
* previously disturbed during site preparation and plant construction.       When the evaluation indicates that such activity involves an unreviewed environ-mental question, the licensee shall provide a written evaluation of such.
* activity and obtain prior NRC approval.       When such activity involves a change in the EPP, such activity and change to the EPP may be implemented only in accordance with an appropriate license amendment as set forth in Section 5.3 of this EPP.                                                                       V A proposed change, test or experiment shall be deemed to involve an ureviewed environmental question if  it  concerns:     (1) a matter which may result in a significant increase in any adverse environmental impact previously evaluated 3-1

in the FES-OL, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board; or (2) a significant change in effluents or power level [in accordance with 10 CFR Part 51.5(b)(2)] or (3) a matter, not previously reviewed and evaluated in the documents specified in (1) of this Subsection, which may have a significant adverse environmental impact.
The licensee 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 deter-mination that the change, test, or experiment does not involve an unreviewed environmental question or constitute a decrease in the effectiveness of this EPP to meet the objectives specified in Section 1.0.       licensee sa include as part of its Annual Environmental Operating Report (per Subsection 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.
3.2  Reporting Related to the NPDES Permit and State Certification
* brl~
Violations of the NPDES Permit or the State certification (pursuant t Section 401 of the Clean Water Act) shall be reported to the NRC by providing copies of the reports required by the NPDES Permit or State Certification. The licensee shall also provide the NRC with copies of the results of studies, other than routine monitoring, conducted in accordance with the NPDES Permit at the same time they are submitted tothe permitting 3-2

Insert A The NRC shall be provided with a copy of the current NPDES or LPDES permit or State certification within 30 days of approval. Changes to the NPDES or LPDES permit or State certification shall be reported to the NRC within 30 days of the date the change is approved.

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 NRG shall be notified within 30 days following the date the stay s granted.
The NRC shall be notified of changes to the effective NPDES Permit proposed by the licensee by providing   RC 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 applicationi for renewal of the  PDES Permit at the same time the application is subitted to the permitting agency.
3.3   Changes Required for Compliance with Other Environmental Regulations_
Changes in plant design or operation and performance of tests or experiments other Federal, State, and local environmental regulations are not subject to the requirements of Section 3.1.
                         \ rr  e                     ;qc/aT60 3-3

.P
* an e va-r' s r e orra J-EAn del IC                 < so 7 t-he1         d jnmetuoe7e ree r-r. nder tA/s Sv- secT'n is nor retusred. t.foseter
'the      Iecli4/-    p wr*-en retorper          Sd*se. r,       5,4s         SJg/
re "I        dr nvionrentl Cnditions 4.1   Unusual or Important Environmental Events Any occurance of an unusual or important event that indicates or could result in significant environmental impact cau         related to plant operation shall be recorded and reported to the NRC      thin 24 hours, 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 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.
No routine monitoring programs are required to implement this condition.
4.2   Environmental Monitoring 4.2.1   Cultural Resources Protection Plan The licensee, the NRC and the State Historic Preservation Officer (SHPO) concur that the appropriate action to be taken to negate any possible adverse effects to the Waterford 3 cultural resources by the operation and maintenance activities of the licensee will be through a Cultural Resources Protection Plan that provides documentation of a "no adverse effect' determination.
This-Cultural Resources Protection Plan was transmitted to the NRC and the SHPO by a letter from L. V. Maurin to G. W. Knighton, dated April 15, 1983 for 4-1

final review and concurrence, after which the NRC submitted the plan to the Advisory Council on Historic Preservation (ACHP) for comment on September 28, 1983. ACHP concurrence was received by the NRC, on October 18, 1983 without change.
The Cultural Resources Protection Plan, as referenced above, is the binding document to which the licensee-will adhere and this Section of the EPP is considered fully satisfied with no further action required.
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5;0 Adminstrative Procedures 5.1  Review and Audit The licensee shall provide for.review and audit of compliance with the Environmental Protection Plan. The audits shall be conducted independently of.
the individual 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.
5.2  Records Retention Record                        t ee shall be made and retained in a manner covenient for.review and inspection.
These records         shall be made available to the NRC on request.
Records of modifications to plant structures, systems and components determined to potentially affect the continued protection of the environment shall be retained                  .            All other records               relating to this EPP shall be retained for five years or, where applicable, in accordance with the requirements of other agencies.
(u nt!  7P e date <O'         h e rr           7Opi n gAo7.z    thA         eus 5.3  Changes in Environmental Protection Plan Reauest for a change in the Environmental Protection plan shall include an assessment of the environmental impact of the proposed change and a supporting 5-1

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 amend-ment incorporating the appropriate revision to the Environmental Protection Plan.
5.4   Plant Reporting Requirements 5.4.1                         e-re An  nnual Environmental  perating Report descri bing implementation o tis EPPe for the previous year shall be submitted to the NRC prior to May     of each year. The initial report shall be submitted prior to May of the year following issuance of the operating license. The period orfthe first report shall begin with the date of issuance of the operating license.
The report shall include summaries and analyses of-the results of the environ-mental protection activities required by Subsection 4.2 of this Environmental Protection Plan for the report period, including a comparison with any 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 trends toward irreversible damage to the environmental are observed, the licensee shall provide a detailed analysis of the-data and proposed course of mitigating actions.
5-2

The Annual Environmental Operating Report shall also include:
(a) A list of EPP noncompliances and the corrective actions taken to remedy them.
(b) A list of all changes n station design or operation, tests, experiments made in accordance with Subsection 3.1 which involved a potentially significant unreviewed environmental question.
(c) 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 posible n a supplementary/
5.4.2 Nonroutine Reports' A written report shall be submitted to the RC within 30 days of occurrence of any event described in Section 4.1 of this Plan. The reports 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.
5-3

Events  eportable -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 a copy of such report at the same time it is submitted to the other agency.
5-4}}