View source for CNRO-2004-00004, Revised Proposed License Amendment Requests Regarding Proposed Revision to Appendix B, Environmental Protection Plan (Non-Radiological) of the Facility Operating Licenses

{{Adams
| number = ML040370788
| issue date = 01/30/2004
| title = Revised Proposed License Amendment Requests Regarding Proposed Revision to Appendix B, Environmental Protection Plan (Non-Radiological) of the Facility Operating Licenses
| author name = Burford F
| 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-2004-00004
| document type = License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 50
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Entergy Operations, Inc.
-- Enterg                                                                             1340 Echelon Parkway Jackson, Mississippi 39213-8298 Tel 601-368-5755 F. G. Burford Acting Director Nuclear Safety & Licensing CNRO-2004-00004 January 30, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

==SUBJECT:==
Revised License Amendment Requests Proposed Revision to Appendix B, Environmental Protection Plan (Non-Radiological) of the Facility Operating Licenses 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:==
: 1. License Amendment Requests Proposed Deletion of Appendix B, Environmental Protection Plan (Non-Radiological) from the Facility Operating License Dated November 6,2002 (Accession No. ML023180512)
: 2.      Revised License Amendment Requests Proposed Deletion of Appendix B, Environmental Protection Plan (Non-Radiological) from the Facility Operating License Dated November 18, 2003 (Accession No. ML033290617)

==Dear Sir or Madam:==

By the referenced letters, Entergy Operations, Inc. (Entergy) proposed a change to revise 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.
1D

CNRO-2004-00004 Page 2 of 2 Based on discussions with the NRC staff, Entergy agreed to retain certain elements of the EPPs.
Reference 2 provided Entergy's recommended changes. The NRC staff subsequently requested further clarifications. The attached marked-up pages of the EPPs contain those clarifications.
There is no change to the intent and the scope of the original no significant hazards consideration included in Reference 1. These mark-ups supersede the mark-ups in the previous submittals in their entirety.
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 January 30, 2004.
Sincerely, FGBIW6B/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. W. A. Eaton (ECH)                          Louisiana Department of Environmental Quality Mr. P. D. Hinnenkamp (RBS)                     Office of Environmental Compliance Mr. D. E. Levanway (Wise Carter)               Attn. Prosanta Chowdhury Mr. B. S. Mallett, Administrator, Region IV    Surveillance Division Mr. J. E. Venable (W-3)                        P. 0. Box 4312 Mr. G. A. Williams (GGNS)                      Baton Rouge, LA 70821-4312 Mr. N. Kalyanam, Project Manager (W-3)         Louisiana Department of Environmental Quality Mr. B. K. Vaidya, Project Manager (GGNS)       Office of Radiological Emergency Plan Mr. M. K. Webb, Project Manager (RBS)             and Response Surveillance Division Mr. P. J. Alter, RBS Sr. Resident Inspector    P. 0. Box 4312 Mr. M. C. Hay, W-3 Sr. Resident Inspector      Baton Rouge, LA 70884-4312 Mr. T. L. Hoeg, GGNS Sr. Resident Inspector American Nuclear Insurers Mr. Brian W. Amy, MD, MHA, MPH                 Attn: Library Mississippi Department of Health               Town Center Suite 300S P. 0. Box 1700                                 29 1h S. Main Street Jackson, MS 39215-1700                          West Hartford, CT 06107-2445

Attachment 1 CNRO-2004-00004 Proposed Facility Operating License Changes (mark-up)
Grand Gulf Nuclear Station, Unit 1

II APPENDIX E TO FACILITY LICENSE MO. tNPF-29 GRAND GULF NUCLEAR STATION UHIT I ENTERGY OPERATIONS, INC.                      I DOCKET NO. 50-416 ENVIRONMENTAL PROTECTION PLAN OCTCOER 1984 Amendment No. 65

GRAND GULF NUCLEAR STATION I
                                        '   UNIT 1 S
ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL)
TABLE OF COhiENTS Section                                                            Page 1.0 Objectives of the Environmental Protection Plan.               1-1 2.0    Environental Protection Issues .                             2-1 2.1 Aquatic Issues.        . .      .    ...                        2-1 2.2 Terrestrial Issues . . . . . . . . . . . .                      2-1 3.0 Consistency Requirements.                       . . . . . . . 3-1 3.1    Plant Design and Operation .                  . . . . . .  . 3-1  '
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 Environnental Honitoring .       ..                             4-1 5.0 Administrative Procedures.
5.1 Review and Audit                                                5-1 5.2   Records Retention.                 .                          5-1 5.3   Changes in Environmental Protection Plan 5.4   Plant Reporting Requirements.                                 5-2

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

2.0    ENVIRONM4ENTAL PROTECTION ISSUES In the FE$-OL dated September 1981, the staff considered the environmental impacts associated with the operation of the Grind 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 FAuatic Iss     e~a rSqfp&#xa2;4it~>
zo fiNo   aquatic issues wore idntified in the FES-OL. Effluent limitations and monitoring requirements are contained In the effective NPOES permit issuedb
__          _ _ _ _            __ __tu xl.          The NRC will rely on c 9en eGS   wgencrv for regulation of these matters as they involve water quality and aquatic 0.
Z.z     Terrestrial Issues (1) Potential erosion along transmission line corridors during and lmnedlately following their construction.
(2) Potential impact of cooling tower drift on vegetation surrounding the sites. In the FES the staff recommended 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 Operatton The licensee say make 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.* Changes in plant design or operation and perforsance of tests or experimtnts 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.
Befort 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, Oftice of Nuclear Reactor Regulation. When such activity involves a change in the Environmental Protection Plan, such activity and change to the Environmental Protection Plan say 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 unrevieied.
environmental question if it concerns (1) a matter which way result in a sig-nificant increase in any adverse environmental impact previously evaluated in the final environmental statement (FES) as modified by staft's testimony to the Atomic Satety and Licensing Board, supplements to the FES. environmental impact appraisals. or in any decisions of the Atomic Safety and Lictnsing This provision does not relieve the licensee of the requirements of 10 CFR 50.59.
  "Activities 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 gieviously reviewed and. evaluated in the documents specified
  *1n (1)of this Subsection, which may have a significant adverse environmental fact.
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 involve an unreviewed environmental question nor constitute a decrease In the effectiveness of this EPP to meet.the objective spcte nSct0                       e1cansee shall include as part ot the r     nv~rnotn1 Gerkt ng Report tper Subsection S 4.l) brief descriptionsl l Anw
       \    anlyse 1nerpotxions, and evaluattons of such changes, tests and experimen 3.2     Reporting Related to the NPDES Permits and State Certification Ytolt10ns 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 peroit or certifl-cation.
Changes and     additions to the NPDES permit or the State certification shall be reported to    the HRC within 30 days following the date the change is approved.
Ia a permit     or certification, In part or In its entirety, is appealed and stayed, the     NRC shall be notitfed within 30 days following the date the stay is granted.
The KRC 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 tire 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 HRC with a copy of its applicat10n for renewal of the HPOES permit at the same time the applicationJ Xt ls     bntte     O h eritga 3-2

Insert A The NRC shall be provided with a copy of the current NPDES permit or State Clean Water Act, Section 401 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 wtth Other Environmental Regulations Changes in pfint design or operation and performance of tests or experiments other Federal, State, or local environmental (regu at ons are not subject to requirements of Section 3.1.
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4.0     ENVIRONMENTAL CONDITIONS 4.1    Unusual or Important Environmental Events                 pe rI'OflS        erTer Any occurrence of an unusual or important event that indicates or could result 1n                  environnental impact causally'relat siiicfanant        to station operation recorded and promptly reported to the NR      fwthin 24 hours 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 aylations from required monitoring programs will not be a violation of liciense requirenents if samples are accidentally spilled or contaminated, or if samples are unattailnable due to hazardous conditions, seasonal unavailability, or malfunction of equipment.
: 2. Erosion  Control Inspection f
antenance        and monitoring of the transrission line coroo         lhts-of-way Wil a 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 R~ectric 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-PAb     e    &Zfc'j~oni C cTrroI =J          .t7i       I       awer Df;frmonItur'fl
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by the aerial surveys, and walking patrols will be directed to the proble areas to evaluate the extent of the problem to be corrected, The Erosion Control Inspection Program shall begin upon conencement 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 measures 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 Progras Seven sampling sites were utilized to measure cooling tower drift-depositio0n.
At least two of the sampling sites had duplicate stpling devices. Six of the seven sites were located in areas where maximum salt deposition was predicted.
These artes were extrapolated from the Bechtel Salt 0eposition Yodel developed for the GGKS Final Environmental Report. The seventh saupling site was a control site located *outh 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 tan specific constituents. The details of the sampling procedure and chemical 4u~~~~~~_eL, ~N.                       f,9

an& ys s war* submitted to the NRC's Environmental Enginearing Branch for rwevew (and approval prior to plant operation above 5X power. An evaluation of the        )
results of the Cooling Towr Drift Program indlcated that the operation of the GGNS cooling tower produced no statistically Significant effect upon thu salt deposition rite for those chemical specite evaluated. The cooling tower drift program was therefore terminated.
4-3            Amendment o   96

5.0   ADHINISTRATIVE PROCEDURES 5.1   Review and Audit The licensee shall provide for review and audit of compliance with the Environmental Protection Plan. The audits fhall 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.
S.2   Records Retention Record shall be made and retained in a manner convenient for review and inspection.
These records g      iishall 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 enviroTment shall be retaiUad                            . All other reco       rds         relating to this EPP shall be retained for five years or, where applicable, in accordance with the-requirements of other agencies.
5.3   Changes in Environmental Protection Plan Requests for changes in the Environmental Protection Plan shall include an assessment of the environmental impact of the proposed change and a supporting Justification. Imptementation 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.
   - ntil The       d-re 0 f t e re rlt             ft '    cF t-he    Lacense 5-1

5.4   Station Re orting Requirements
 .5.4.21 lns~ontetelOpeat~g AnAnna1                Reortdesr~bng tmplementatIon of th s EPP
)for the previous yer shall be submitted to the NRC prior to Kay I of each year. The initil1 report shall be submitted prior to Nay I of the year follow-l Ing issuance of the operating license. The period of the first report shall begin with the data of issuance of the operating license fto 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, including a comparison with preoperational studies, operational controls (as appropriate), end 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.
tb)   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 or 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. rhe missing data shall be submitted as soon as possible in a supplementary report.
5-2

a  ~e ven-T de~s c-r iecl1 itl      Seeb n 54A.Z   Nonroutine Reports-                /o7rf.Sp* Of_
      .A written report shall be submitted to the NRC within 30 days of occurrence o The report shall (a) describe, analyze, and evaluate the event, including extent and magnitude Of these 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 tevnt and to prevent similar occurrences involving similar components or systems, and (a) indicate the agencies notift ed 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 each report at the ame time it is submitted to the other agency.

Attachment 2 CNRO-2004-00004 Proposed Facility Operating License Changes (mark-up)
River Bend Station

APPENDIX B TO FACILITY OPERATING LICENSE NO. NPF.47 RIVER BEND STATION UNIT 1 ENTERGY OPERATIONS, INC.
DOCKET NO. 50.458
                                           .. ::ECE~lIV.ED..
AUG 01 .1995
                                           . :. .sp
                                                 . DC -.    ..
ENVIRONMENTAL PROTECTION PLAN (NONRADIOLOGICAL)
Amendment No. Xo, 79

RIVER BEND STATION UNIT I ENVIRONMENTAL PROTECTION PLAN (NONRADI OLOGI CAL)
TABLE OF CONTENTS Section                                                                                                                                                    pace 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   Plant Design and Operation .........;ifer                                      b                                                                          3-1 3.2   Reporting Related to the NPDES Pe                                    ai5ndSra e 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          33eration and of actions taken to control those effects.
Environmental concerns identified in the FES-OL-wh           I    to water quality matters are regulated by way of the licensee's NPDES per           it-   iE 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                                              r no 8-     f No specific aquatic issues were identified by the NRC staff in the FES-OL. L 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 4.2pFES-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 expeimehts' 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 NPI)ES Permit and State Certification ae censee shall notify the NRC of proposed revisions to the effective NPD          erm proposed revision is a significant change of waste stream flowv rate, concentration, or point of&#xa2; discharge. This shall be done by providing NRC with a copy of the proposed revision at thel 3-2

Insert B The NRC shall be provided with a copy of the current NPDES or LPDES permit or State Clean Water Act, Section 401 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.

ttme it is submitted to the permitting agency. The licensee shall provide the NRC a copy of te B application for renewal of the NPDES Permnit 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 lcertification, in part or in its entirety, is appealed and stayed, the NRC shall be notified within 3.3          Changes Required for Compliance with Other Environmental Regulations Changes in plant design or operation and performance of tests or experimentst ther Federal, State, and local environmental regulations areno      _se         7eoq       =         .
fA/
Wevey              ffany             e nvironnrr)HeM                           c.v V(-change apre                 A 01 C -It l1urelk'            u    der    o7rd4er         elred'ep o Stale }       o r /     ca   I   en    i.,        nh bets                 5e74 lai 7  Hi     f1e         <0 Thos e        iMon pe-js                                rt              1rcsb hexcefre           o-.4 T           s 3-3

I f van eveFJI relso.-I'e "JIe-r /n C,=, 5o0.72 f7l s Sd"p/a'eTe         , nir'edTetr repot an ker rA's S Screo-c                                   ,s nI-j t ref";e2. fn~        evr,
                               ,e       Tji 6 Me,/Ok, -ul vr sfte;4 eeeo, pe                              I 4.1           Unusual or Important Environmental Events Any occu                n         r important event that indicates or could result in significant environmental impact causally related to plant operation shall be recorded and reported to the within 24 hours followed by a written report per Subsection 5.4.2.
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.          _   nvironmgeltl Monitoring     A I'      ^S~bSecrli~fo^10                  a                 .
Me.          verIleet -id jr7 D /      rA,^
The certifications and permits required under the Clean Water Act provide mechanisms            r 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                                         >
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

  /   escriton of the program, results and interpretative analsis of environmental impacts tj Results reported shall contain information encompassing but not limited to the following:             l 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 RI, 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, L-5 , Leq) for a weighted decibel levels. Additionally one-third octave band analysis will be performed at each location on each visit.
                                       >               ~~~4-3/

t  esult of these surveys will be evaluated and included in the annual environmental monitoring 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.
                                \~~~~-

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 RetenUon 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 retalnedeit All other recordsrrelating                to this EPP shall be retained for five years or, where applicable, In accordance with the requirements of other a enc 4 e0        7e            K     r    s 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       ~~~Pe~0e n~~~~ ~ nua nvrnetl             IgRpr        eciigIpeentation of this EPP for the prvious 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 nalysis of the data and a proposed course of mitigating action.
5-2

ennual Environmental Operating Report shall also inclue: d~
(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 shalt be submitted noting and explaining the missing results. The missing results shall be submitted as t\soon as possible In a supplementary report.
(Afl~~Je~esd es -ri hel 7
5.4.2        Nonroutine Reports                      ;r,                     5c      iOl A written report shall be submitted to the NRC within 30 days of occurrence o tie         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.
5-4

Attachment 3 CNRO-2004-00004 Proposed Facility Operating License Changes (mark-up)
Waterford Steam Electric Station, Unit 3

APPENDIX 8 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     i    e 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. . . . . . . . . .           *-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 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.;  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:
Effluent limitations and monitoring requirements are contained in the NPDES    fOrafDA
           .The NRC will rely on       oreulat AOn of matters involving 'the protection of water quality and aquatic blota.       h 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.
2-1

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 plant design or operation or performance of tests or experiments which do not affect the.envtronment are not subject to the requirements of this EPP. Activities governed by Section 3.3-are not subject to the requirements uof this Section.
Before engaging in construction or operation artlyjties 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.
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 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 inn Section I       h,0.nseshl include as part of its Annual Environmental Operating Report (per Subsecto 5,4.1) brief descriptions, analyses, interpretations, and-evaluations o such changes, tests and experiments.
3.2    R orting Related to the NPDES Permit and State Certification Vilton     ofth    NPDES.Permit or the State certification (purun 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 to. the penmitting agency.
3-2

Insert A The NRC shall be provided with a copy of the current NPDES or LPDES permit or State Clean Water Act, Section 401 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 o 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 is granted.
The NRC shall be notified of changes to the effective NPDES Permit proposed by the licensee by providing HRC 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 appicaiionh for renewal of the NPDES Permit at sme te    imethe application is submitted 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
             =Mul                               other Federal, State, and local environmental regulations are not subject to the requirements of Section 31.1 y~ho7%ayre e J'tAe,        re:    4y
    /Ho&e-'eJ        ifanyrnjironhmnep>i(r                 ,'t cct<
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   *tAose J^,70             are     s    j ec no rAe re                   7s-
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    . ~~<rS a ri e Llen17 ;f f spoof r1%eA L      htWnei- ./0C fr- 50,7Rj teen         dlzn*
immed,4'Te reforr. u-n4erlls Stbsecr7s is nor re &,"r-ed, t.oiet
* . lathe 4:0ovl<- Re vw t-rive     retoirtpeor .5j-bfe-rane, 5, , A          is 5To-t
           ~ nyiromenta    Conditions 4.1   Unusual or Important Environmental Events Any occurance of an unusual or Important event that indicates or could result in significant environmental impact causall     related to plant operation shall be recorded and reported to the NR     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 ipecies prifected 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 impilement 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

        .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.
4-2

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                          P nv 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 retainedy              .             All other reco       rds41        relating to this EPP shall be retained for five years or, where applicable, in accordance with the requirements of other agencies.
UW t, 7P1th e  cIa Fe v go rhe rams         m07,7or    thA e a,     e 5.3   Changes in Environmental Protection Plan Reouest for a change in the Environmental Protection plan shall include an assessment of the environmental impact of the proposed change and a supporting 5-3

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-nent incorporating the appropriate revision to the Environmental Protection Plan.
5.4 Plant Reporting Requirements 5.4.1      D        oe-U D 4e  et-reJ AAnnual Environmental Operating Report descri bing implementation of th s E
.for   the previous year shall be submitted to the NRC prior to May I of each year. The initial report shall be submitted prior to Hay of the year following issuance of the operating license. The period o1rthe first report shall begin with the date nf 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 conparison with any related preoperational studies, operational controls (as appropriate), and previous non-radiclogica1 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 a 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 t remedy them.
(b) A list of all changes in station design or operation, tests, experiments made in accordance with Subsection 3.1 which involved a potentially signf11cant 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 possible in a supplementary /
5.4.2 Nonroutine Reports' A written report shall be submitted to the NRC 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 reportable -under this subsection which also require reports to other Federal, State or local agencies shall be reported in accordance with those reporting requirementslin 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.
                          .    .~~~~~~~~~~~~~~~~~~~~~a 5-4}}