ML051430137

Appendix B to Facility License No. NPF-2, Joseph M. Farley Nuclear Plant, Unit 1

ML051430137
Person / Time
Site:	Farley
Issue date:	05/01/2005
From:	- No Known Affiliation
To:	Office of Nuclear Reactor Regulation
Liu T, NRR, 415-1315
References
Download: ML051430137 (30)

Text

I APPENDIX B TO FACILITY LICENSE NO. NPF-2 JOSEPH M. FARLEY NUCLEAR PLANT UNIT I SOUTHERN NUCLEAR OPERATING COMPANY I

DOCKET NO. 50-348 ENVIRONMENTAL PROTECTION PLAN Amendment No. 90

JOSEPH M. FARLEY NUCLEAR PLANT UNIT N4O. 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 Issues . .. . . . . . . . . . . . . . . . . . . 2-2 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 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 environ-mental values during construction and operation of the nuclear facility. The principal objectives of the EPP are as follows:

(1) Verify that the plant is operated in an environmentally 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 construction and operation and of actions taken to control those effects.

Environmental concerns identified in the FES which relate to water quality matters are regulated by way of the NPDES permit.

1-1 Amendment No. 90

2.0 Environmental Protection Issues In the FES-OL dated December 1974, the staff considered the environmental impacts associated with the operation of the two-unit Farley Nuclear Plant.

Certain environmental issues were identified which required study or license conditions to resolve environmental concerns and to assure adequate protec-tion of the environment.

2.1 Aquatic Issues

1. The need for aquatic monitoring programs to confirm that thermal mixing occurs as predicted, that chlorine releases are controlled within those discharge concentrations evaluated, and that effects on aquatic biota and water quality due to plant operation are no greater than predicted.

2. The need for special studies to document levels of intake entrainment and impingement.

(FES-OL: Summary and Conclusions and Sections 6.2, 6.3, and 6.6)

Aquatic issues are addressed by the effluent limitations, monitoring require-ments and the Section 316(b) demonstration requirement contained in the effec-tive NPDES permit issued by EPA-Region IV and now implemented by the Alabama 2-1

Water Improvement Commission. The NRC will rely on these agencies for regula-tion of matters involving water quality and aquatic biota.

2.2 Terrestrial Issues

1. Potential impacts on the terrestrial environment associated with drift from the mechanical draft cooling towers. (FES-OL Section 6.5)

2. Potential increase in fogging associated with operation of the mechanical draft cooling towers. (FES-OL'Section 6.5).

3. Potential erosion and visual effects along transmission line corridors and at highway crossings, respectively. (FES-OL Sections 4.2, 5.4.4.1, 11.2).

4. The need for controlled used of herbicides on transmission rights-of-way.

(FES-OL Sections 4.2, 5.4.4.2, 11.2)

5. The need for documentation of the licensee's commitment to conduct a land management program. (FES-OL Sections 5.2 and 6.5)

NRC requirements with regard to the terrestrial issues 1, 4 and 5 above are specified in Subsection 4.2 of this EPP. Issues 2 and 3 above have been:resolved as described in the Environmental Impact Appraisal supporting Amendment No. 26 to the Farley Unit 1 Operating License, dated March 1, 1982.

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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 changes, tests or experi-ments do not involve an unreviewed environmental question, and do not involve a change in the Environmental Protection Plan.* Changes in plant design or operation or performance of tests or experiments which do not affect the environ-ment 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 significant increase in any adverse environmental impact previously evaluated in the final environmental statement (FES) as modified by staff's testimony to This provision does not relieve the licensee of the requirements of 10 CFR 50.59.

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the Atomic Safety and Licensing Board, supplements to the FES, 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 a written evaluation which provide bases for the deter-mination 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 objectives specified in Section 1.0. The licensee shall include as part of his Annual Environmental Operating Report (per Subsec-tion 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.

3.2 Reporting Related to the NPDES Permits and State Certifications Violations of the NPDES Permit or the State certification (pursuant to Section 401 of the Clean Water Act) shall be reported to the NRC by submittal of copies of the reports required by the NPDES Permit or certification. The licensee shall also provide the NRC with copies of the results of the fol-lowing studies at the same time they are submitted to the permitting agency:

i) Section 316(b) Demonstration Study ii) Chlorine Minimization Study 3-2

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 a permit or certification, in part or in its entirety, is appealed and stayed, the NRC shall be notified within 30 days following the date the stay is granted.

The NRC shall be notified of changes to the effective NPDES Permit proposed by the permit holder by providing NRC with a copy of the proposed change at the same time it is submitted to the permitting agency. The notification of an initiated change shall include a copy of the requested revision submitted to the permitting agency. The licensee shall provide the NRC a copy of the application for renewal of the NPDES permit at the same time the application is submitted to the permitting agency.

3.3 Changes Required for Compliance with Other Environmental Regulations Changes in plant design or operation and performance of tests or experiments which are required to achieve compliance with other Federal, State, or local environmental regulations are not subject to the requirements of Section 3.1.

3-3 Amendment No. 90

4.0 Environiental Conditions 4.1 Unusual or Important Environmental Events

• Any occurrence of an unusual, or important event that indicates or could result in significant environmental impact causally related to plant operation shall be recorded and reported to the' NRC in accordance with 10CFR50.72(b)(2)(vi) or by a written report per Subsection 5.4.2, as appropriate. 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 *Aerial Remote Sensing Vegetation 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 May or June.

Monitoring shall include a program of low altitude false color aerial photography (either color infrared photography or multispectral or multiband photography).

The scale for full coverage shall be adequate to 4-1 AMENDMENT NO. 57

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 in the interval between 1:1000 and 1:12,000 as appropriate to resolve impacted features.

Photographs shall be compared with baseline to ascertain changed vegetation.

Photographic interpretations shall correlate data from ground truth from ground inspection surveys with areas of stress and non-stress as seen on the photographs for purposes of verification of results and interpretation.

Ground truth surveys shall be performed during the aerial photographic monitoring for two-unit operation. This program shall require aerial photographic monitoring during the first Hay-June period after Unit 2 has been in operation for one year and the program shall be repeated once during the same period two years later. A report shall-be submitted as part of the annual report following each aerial photographic monitoring period. The report shall contain a descrip-

'ion of the program, results, and interpretative analyses of environmental.

impacts. Results reported shall contain information encompassing but not limited to the following: sampling date; time of day; film types; spectral bands; and one (1) set of resultant color transparencies encompassing an area within approximately a one kilometer (1 km) radius of the Unit 1 and 2 towers.

4.2.2 Herbicide Application The use of herbicides within the following corridor rights-of-way shall conform to the approved use of selected herbicides as registered by the Environmental 4-2

Protection Agency and approved by State authorities and applied as directed by said authorities:

i) Farley to Pickard-South 230KV ii) Farley to Webb to Pickard 230KV iii) Farley to Snowdown SOOKV Records shall be maintained concerning herbicide use. Such records shall include the following information: commercial and chemical names of materials used; concentration of active material in formulations diluted for field use; diluting substances other than water; rates of application; method and frequency of application; location; and the date of application. Such records shall be maintained for a period of 5 years and be made readily available to the NRC upon request. There shall be no routine reporting requirement associated with this condition.

4.2.3 Land Management There shall be a land management program instituted at the FNP to provide for revegetation of site areas impacted during construction as described in Section 5.2 of the FES-OL. This program requires landscaping of certain areas around the plant buildings and the revegetation and management of the remainder of the site as a wildlife refuge. There shall be no reporting requirement associated with this condition.

4-3 Amendment No. 90

5.0 Administrative Procedures 5.1 Review and Audit Review and audit of compliance with the Environmental Protection Plan shall be provided. 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 and logs relative to the environmental aspects of plant operation shall be made and retained in a manner convenient for review and inspection.

These records and logs 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 retained for the life of the plant. All other records, data and logs relating to this EPP shall be retained for five years or, where applicable, in accordance with the requirements of other agencies.

5-1 Amendment No. 90

B.3 Changes in Environmental Protection Plan Request for change in the Environmental Protection 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 license amend-ment incorporating the appropriate revision to the Environmental Protection Plan.

5.4 Plant Reporting Requirements 5.4.1 Routine Reports An Annual Environmental Operating Report describing implementation of this EPP for the previous year shall be submitted to the NRC prior to May 1 of each year. The initial report shall be submitted prior to May 1 of the year following issuance of the operating license. The 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 environ-mental protection activities required by Subsection 4.2 of this Environmental Protection Plan for the report period, including 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 plant 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.

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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 missing data shall be submitted as soon as possible in a supplementary report.

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

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

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APPENDIX B TO FACILITY LICENSE NO. NPF-8 JOSEPH M. FARLEY NUCLEAR PLANT UNIT 2 SOUTHERN NUCLEAR OPERATING COMPANY DOCKET. NO. 50-364 ENVIRONMENTAL PROTECTION PLAN Amendment Nn. 83

JOSEPH M. FARLEY NUCLEAR PLANT UNIT 2 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 Issues . . . . . . . . . . . . . . . . ... . . . 2-2 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 Regulations . . . . . . . . . . . . . . . . . . . . . . . . 3-3 4.0 Environmental Conditions . . . . . . . . . . . . . . . . . . . 4-1 4.1 Unusual or Important Environmental Events .. . . . . . . . .. 4-1 4.2 Environmental Monitoring . ... . . . . . . . . . . . . ... 4-1

.0 Administrative Procedures . . . . . . . . . . . . . . . . . . -1 5.1 Review and Audit . .. .. . . . . .. .. . .. . . .. 5-1 5.2 Records Retention . . . . . . . . . . . . . . . . . . . . . . 5-1 5.3 Changes in Environmental Protection Plan .. .. . . . .. . 5-2 i.; Plant Reporting Requirements. .. . . . .. . 5-2

1.0 Objectives of the Environmental Protection Plan The Environmental Protection Plan (EPP) is to provide for protection of environ-mental values during construction and operation of the nuclear facility. -The principal objectives of the EPP are as follows:

(1) Verify that the plant is operated in an environmentally 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 construction and operation and of actions taken to control those effects.

Environmental concerns identified in the FES which relate to.water quality matters are regulated by way of the NPDES permit.

Amendment No. 83

2.0 Environmental Protection Issues In the FES-OL dated December 1974, the staff considered the environmental impacts associated with the operation of the two-unit Farley Nuclear Plant.

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

1. The need for aquatic monitoring programs to confirm that thermal mixing occurs as predicted, that chlorine releases are controlled within those discharge concentrations evaluated, and that effects on aquatic biota and water quality due to plant operation are no greater than predicted.

2. The need for special studies to document levels of intake entrainment and impingement.

(FES-OL: Summary and Conclusions and Sections 6.2, 6.3, and 6.6)

Aquatic issues are addressed by the effluent limitations, monitoring requirements and the Section 316(b) demonstration requirement contained in the effective NPOES permit issued by EPA-Region IV and now implemented by the Alabama Water Improvement Commission. The NRC will rely on these agencies for regulation of matters involving water quality and aquatic biota.

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2.2 Terrestrial Issues

1. Potential impacts on the terrestrial environment associated with drift from the mechanical draft cooling towers. (FES-OL Section 6.5)

2. Potential increase in fogging associated with operation of the mechanical draft cooling towers. (FES-OL Section 6.5). This issue is being resolved through studies required by the Farley Unit 1 Operating License.

3. Potential erosion and visual effects along transmission line corridors and at highway crossings, respectively. (FES-OL Sections 4.2, 5.4.4.1, 11.2). This issue is being resolved through studies required by the Farley Unit 1 Operating License.

4. The need for controlled used of herbicides on transmission rights-of-way.

(FES-OL Sections 4.2, 5.4.4.2, 11.2)

5. The need for documentation of the licensee's commitment to conduct a land management program. (FES-OL Sections 5.2 and 6.5)

NRC requirements with regard to the terrestrial issues 1, 4, and S above are specified in Subsection 4.2 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 changes, tests or experiments do not irvolve an unreviewed environmental question, and do not involve a change in the Environmental Protection Plan. Changes in plant 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 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 .ina significant 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 3-1

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 a written evaluation which provide bases for the deter-mination 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 objectives specified in Section 1.0. The licensee shall include as part of his Annual Environmental Operating Report (per Subsec-tion 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.

.2 Reporting Related to the NPDES Permits and State Certifications Violations of the NPDES Permit or the State certification (pursuant to Section 401 of the Clean Water Act) shall be reported to the NRC by submittal of copies of the reports required by the NPDES Permit or certification. The licensee shall also provide the NRC with copies of the results of the following studies at the same time they are submitted to the permitting agency

i) Section 316(b) Demonstration Study ii) Chlorine Minimization Study 3-2

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 a permit or certification, in part or in its entirety, is appealed and stayed, the NRC shall be notified within 30 days following the date the stay is granted.

The NRC shall be notified of changes to the effective NPDES Permit proposed by the permit holder by providing NRC with a copy of the proposed change at the same time it is submitted to the permitting agency. The notification of an initiated change shall include a copy of the requested revision submitted to the permitting agency. The licensee shall provide the.NRC a copy of the application for renewal of the NPDES permit at the same time the application is submitted to the permitting agency.

3.3 Changes Required for Compliance with Other Environmental Regulations Changes in plant design or operation and performance of tests or experiments which are required to achieve compliance with other Federal., State, or local environmental regulations.are not subject to the requirements of Section 3.1..

.3-3 Amendment No. 83

£ 4.0 Environmental Conditions 4.1 Unusual or Important Environmental Events Any occurrence of an unusual or important event that.indicates. or could result in significant environmental impact causally related to plant operation shall be recorded and reported to the NRC in accordance with 10CFR50.72(b)(2)(vi) or by a written report per Subsection 5.4.2, as appropriate. 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 Aerial Remote Sensing Vegetation 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 May or June.

Monitoring shall include a program of low altitude false color aerial photography (either color infrared photography or multispectral or multiband photography).

The scale for full coverage shall be adequate to-4-1 AMENDMENT NO. 49

enable identification of vegetative damage over relatively small areas of terrain. Some circumstances may warrant inspection of photographs discerning individual trees. Such scale should bein the interval between 1:1000 and 1:12,000 as appropriate to resolve impacted features.

Photographs shall be compared with baseline to ascertain changed vegetation.

Photographic interpretations shall correlate data from ground truth from ground inspection surveys with areas of stress and non-stress as seen on the photographs for purposes of verification of results and interpretation.

Ground truth surveys shall be performed during the aerial photographic monitoring for two-unit operation. This program shall require aerial photographic monitoring during the first May-June period after Unit 2 has been in operation for one year and the program shall be repeated once during the same period two years later. A report shall be submitted as part of the annual report following each aerial photographic monitoring period. The report shall contain a descrip-tion of the program, results, and Interpretative analyses of environmental impacts. Results reported shall contain information encompassing but not limited to the following: sampling date; time of day; film types; spectral bands; and one (1) set of resultant color transparencies encompassing an area within approximately a one kilometer (I km) radius of the Unit 1 and 2 towers.

4.2.2 Herbicide Application The use of herbicides within the following corridor rights-of-way shall conform to the approved use of selected herbicides as registered by the Environmental 4-2

Protection Agency and approved by State authorities and applied as directed by said authorities:

9 Farley to Pickard-South 230KV ii) Farley to Webb to Pickard 230KV iii) Farley to Snowdown 500KV Records shall be maintained concerning herbicide use. Such records shall include the j following information: commercial. and chemical names of materials used; concentration of active material in formulations diluted for field use; diluting substances other than water; rates of application; method and frequency of application; location; and the-date of application. Such records shall be maintained for a period .of 5 years and be made readily available to the NRC upon request. There shall be no routine reporting requirement associated with this condition.

4.2.3 Land Management There shall be a land management program instituted at the FNP to provide for

.revegetation of site areas impacted during construction as described in Section 5.2 of the FES-OL. This program requires landscaping of certain areas around the plant buildings and the revegetation and management of the remainder of the site as a wildlife refuge. There shall be no reporting requirement associated with this condition.

4-3 Amendment No. 83

5.0 Administrative Procedures 5.1 Review and Audit Review and audit of compliance with the Environmental Protection Plan shall be provided. 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 and logs relative to the environmental aspects of plant operation shall be made and retained in a manner convenient for review and inspection...

These records and logs .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 retained for the life of the plant. All other records, data and logs-relating to this EPP.shall be retained for five years or, where applicable, in accordance with the requirements of other agencies..

5-1 Amendment No. 83

5.3 Changes in Environmental Protection Plan Request for change in the Environmental Protection 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 license amend-ment incorporating the appropriate revision to the Environmental Protection Plan.

5.4 Plant Reporting Requirements 5.4.1 Routine Reports An Annual Environmental Operating Report describing implementation of this EPP for the previous year shall be submitted to the NRC prior to May i of each year. The initial report shall be submitted prior to May 1 of the year Following issuance of the 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 environ-mental protection activities required by Subsection 4.2 of this Environmental Protection Plan for the report period,. including a comparison with preoperational studies, operational controls (as appropriate), and previous non-radiological environmental monitori4ng reports, and an assessment of the observed impacts of the plant 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.

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 in station design or operation, tests, and experiments made in accordance with Subsection 3.1 which involved a potentially significant unreviewed environmental issue.

Cc) 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 data 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 nonroutine event. The report shall (a) describe, analyze, and evaluate the event, including extent and magnitude of the impact and plant operating characteristics, Cb) 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 Ce) 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 a copy of such report at the same time it is submitted to the other agency.

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