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{{#Wiki_filter:Entergy Nuclear South 1340 Echelon Parkway E            tegyJackson,                                      gwllil601 Tel MS 39213 368 5670
                                                                                    @entergy corn George A. Williams Vice President Operations Support CNRO-2002/00005 November 6, 2002 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
 
==SUBJECT:==
Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 LDC number (2002-053)
River Bend Station, Unit 1 Docket No. 50-458 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License Amendment Requests Proposed Deletion of Appendix B, Environmental Protection Plan (Non-Radiological) from the Facility Operating License
 
==Dear Sir or Madam:==
 
Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests the following amendments 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 proposed amendments will delete the content of the Appendix B, Environmental Protection Plan (Non-Radiological) (EPP) for each unit. In addition, the appropriate sections of each FOL referring to the EPP will be modified to delete reference to the EPPs. This amendment request is administrative in nature and is intended to relieve Entergy of the burden of certain environmental reports and delete obsolete program information.
All environmental conditions imposed by these appendixes have been completed. All other requirements for non-radiological monitoring are governed by other Federal, State, or local permits and regulations. There is no impact on the continued safety or in protection of the environment for the GGNS, RBS, and Waterford 3 units by deleting Appendix B of the FOLs.
The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards consideration. The bases for these determinations are included in attachment 1.
A
 
CNRO-2002/00005 Page 2 of 3 The proposed change includes no new commitments. This amendment request is similar to that granted to Duke Power for its McGuire Nuclear Station Units 1 & 2 (TAC Nos. M90860 and M90861) and Catawba Nuclear Station Units 1 & 2 (Amendment Nos. 149 and 143) in 1996.
Entergy requests approval of the proposed amendment within one year of this application.
Once approved, the amendment shall be implemented within 60 days. Although this request is neither exigent nor emergency, your prompt review is requested.
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 6, 2002.
Sincerely, GAW/WBB/bal attachments:
: 1. Analysis of Proposed Facility Operating License Change
: 2. Proposed Facility Operating License Changes (mark-up) - Grand Gulf Nuclear Station, Unit 1
: 3. Proposed Facility Operating License Changes (mark-up) - River Bend Station
: 4. Proposed Facility Operating License Changes (mark-up) - Waterford Steam Electric Station, Unit 3 cc:            (See Next Page)
 
CNRO-2002/00005 Page 3 of 3 cc:        Mr. C. G. Anderson (ANO)
Mr. J. L. Blount,(ECH)
Mr. W.R. Campbell (ECH)
Mr. W. A. Eaton (GGNS)
Mr. P. D. Hinnenkamp (RBS)
Mr. E.W. Merschoff Mr. N. S. Reynolds Mr. L. Jager Smith (Wise, Carter)
Mr. G. J. Taylor (ECH)
Mr. J. E. Venable (W-3)
Mr. G. A. Williams (ECH)
Mr. M. K. Webb, Project Manager (RBS)  W-3 NRC Resident Inspectors Office Office of Nuclear Reactor Regulation    W-MSB4-266 U. S. Nuclear Regulatory Commission Mail Stop OWFN/7D1                      Louisiana DEQ/Surveillance Division Washington, DC 20555                    P. O. Box 82215 Baton Rouge, LA 70884-2445 Mr. N. Kalyanam, Project Manager (W-3)
Office of Nuclear Reactor Regulation    American Nuclear Insurers U. S. Nuclear Regulatory Commission    ATTN: Library Mail Stop OWFN/7D1                      Town Center Suite 300S Washington, DC 20555                    WestSouth 29th      MainCT Hartford,  Street 06107-2445 Mr. D. H. Jaffe, Project Manager (GGNS)
Office of Nuclear Reactor Regulation    Mr. Prosanta Chowdhury U. S. Nuclear Regulatory Commission    Program Manager-Surveillance Division Mail Stop OWFN/7D1                      Louisiana Dept. of Environmental Quality Washington, DC 20555                    Office of Radiological EP and Response P. O. Box 82215 RBS NRC Senior Resident Inspector      Baton Rouge, LA 70884-221 P. O. Box 1050 St. Francisville, LA 70775
 
Attachment I CNRO-2002100005 Analysis of Proposed Facility Operating License Change to CNRO-2002/005 Page 1 of 14
 
==1.0    DESCRIPTION==
 
This letter is a request to amend Facility Operating Licenses (FOLs) NPF-29 for Grand Gulf Nuclear Station, Unit 1 (GGNS), NPF-47 for River Bend Station, Unit 1 (RBS), and NPF-38 for Waterford Steam Electric Station, Unit 3 (Waterford 3).
The proposed changes will revise the FOLs to delete the content of the Appendix B, Environmental Protection Plan (Non-Radiological) (EPP) for each unit. In addition, the appropriate sections of each FOL referring to the EPP will be modified to delete that reference.
This amendment request is administrative in nature because all environmental conditions imposed have been completed or are covered by Federal, State, or local permits and regulations. This change will relieve Entergy Operations inc. (Entergy) of the burden of certain environmental reports and delete obsolete program information.
 
==2.0      PROPOSED CHANGE==
 
These proposed amendments delete Appendix B, Environmental Protection Plan (Non-Radiological) and references to Appendix B from the FOLs and Technical Specifications for GGNS, RBS, and Waterford 3. Details of the proposed changes to the FOLs are provided separately for each of the facilities as follows:
GGNS Delete the references to Appendix B on Page 2, Section 1 H Page 4, Section 2 C(2)
Page 17, List of Attachments Delete the Appendix B, Environmental Protection Plan, in its entirety (13 pages)
RBS Delete the phrase "subject to the conditions for protection of the environment set forth herein" Page 2, Section 1 H Delete references to Appendix B on Page 3, Section 2 C(2)
Page 7, Section 2 E Page 7, List of Attachments Delete Appendix B, Environmental Protection Plan, in its entirety to CNRO-2002/005 Page 2 of 14 Waterford3 Delete references to Appendix B on Page 2, Section 1 H Page 4, Section 2 C 2 Page 8, Section 2 F Page 9, List of Attachments Delete Appendix B, Environmental Protection Plan, in its entirety In summary, these proposed amendments delete Appendix B, Environmental Protection Plan (Non-Radiological) and references to Appendix B from the Facility Operating Licenses for GGNS, RBS, and Waterford 3.
 
==3.0    BACKGROUND==
 
The EPP was established during initial plant operations to monitor terrestrial issues such as potential erosion along transmission lines, cooling tower drift, impact on vegetation, noise, and cultural resources issues. The regulatory basis for the establishment of the EPP was 10 CFR 50.36b. This section requires that any obligations in the environmental area identified by the Nuclear Regulatory Commission (NRC) during their evaluation in the NRC record of decision be included in an attachment to the license. The attachment is incorporated in, and made a part of the license. The conditions are derived from information contained in the environmental report and the supplement to the environmental report submitted as required by 10 CFR 51.50 and 51.53. The attachment is only required when conditions are identified in the record. In this case, these monitoring programs have been completed and the results have demonstrated that the environmental impacts are negligible. Although these monitoring programs have since been discontinued, the sites are still required to submit an annual report to the NRC.
The licensees are bound by other Federal (i.e., the Environmental Protection Agency (EPA)),
State, and local agencies to comply with environmental protection regulations. The NRC relies on these agencies to regulate licensees in environmental matters. No environmental protection requirements established by other agencies are being reduced by removal of Appendix B from the FOLs.
 
==4.0    TECHNICAL ANALYSIS==
 
The analyses for the proposed changes are addressed separately for each licensed plant.
Justification for the deletion of each applicable section is provided below.
GGNS Section 1.0 - Objectives of the Environmental Protection Plan This section contains the objectives of the EPP which is to provide for protection of environmental values during construction and operation of the nuclear facility. These objectives to CNRO-2002/005 Page 3 of 14 are met through the National Pollutant Discharge Elimination System (NPDES) Permit, and other Federal, State and local requirements for environmental protection.
Section 2.0 - Environmental Protection Issues This section contains the environmental protection issues.        Each issue will be discussed separately.
Section 2.1 - Aquatic Issues This section of the EPP does not impose any requirements or identify any aquatic issues at GGNS.      The NRC relies on the State regulatory agency (Mississippi Department of Environmental Quality) to regulate water quality matters. The EPA has oversight of State programs. This is accomplished through compliance with the limitations and conditions imposed by the GGNS NPDES permit.
Section 2.2 - Terrestrial Issues The EPP imposes monitoring requirements on two terrestrial issues. These issues are: 1) potential erosion along transmission line corridors following their construction and 2) potential impact of cooling tower drift on vegetation surrounding the site.
The transmission line survey program was completed and discontinued in 1988 as reported in Section 2.1 of each GGNS Annual Environmental Operating Report submitted to the NRC.
The cooling tower drift program has also been discontinued.      The final sentence of Section 4.2.2 of the EPP states that the program was discontinued.
Section 3.0 - Consistency Requirements This section consists of Sections 3.1, 3.2, and 3.3 as discussed below.
Section 3.1 - Plant Design and Operation The EPP allows changes to be made in plant design or operation or performance of tests or experiments affecting the environment provided that they do not involve an unreviewed environmental question or a change to the EPP. Activities are excluded from this requirement if all measurable nonradiological effects are confined to on-site areas previously disturbed during site preparation and plant construction. This requirement is duplicated in the Entergy 10 CFR 50.59 Review Program procedure. This procedure requires an environmental screening. Full Environmental Evaluations are performed for those changes that do not meet the screening criteria. These changes are evaluated against all environmental requirements.
This section also requires that the licensee maintain a record of changes in plant design or operation and of tests and experiments carried out pursuant to this section. This requirement is also duplicated in the Entergy 10 CFR 50.59 Review Program procedure.
to CNRO-2002/005 Page 4 of 14 Section 3.2 - Reportingq Related to the NPDES Permits and State Certification This section requires that violations, changes and additions of/to the NPDES permit or the State Certification shall be reported to the NRC. The NRC relies on the State regulatory agency to regulate these matters. All reporting to the NRC will be done in accordance with 10 CFR 50.72 "Immediate notification requirements for operating nuclear power reactors." Information related to environmental permits will be available on site for NRC review.
Section 3.3 - Changes Required for Compliance with Other Environmental Regulations This section exempts those changes required to achieve compliance with other Federal, State, or local environmental regulations from the requirements of Section 3.1. An exemption from this section will no longer be necessary after implementation of this change.
Section 4.0 - Environmental Conditions This section consists of Section 4.1 and 4.2 discussed below.
Section 4.1 - Unusual or Important Environmental Events This section requires that any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to station operation shall be recorded and reported to the NRC within 24 hours followed by a written report within 30 days.
GGNS is already required to notify the NRC in accordance with 10 CFR 50.72. Follow-up written reports are submitted to state agencies based on State regulatory requirements. The written reports are initiated through the GGNS environmental reporting procedure. Therefore, sending an additional copy of the written report to the NRC is an unnecessary reporting burden.
Entergy will, of course, provide any of this information at the request of the NRC staff.
Section 4.2 - Environmental Monitoring For GGNS, environmental monitoring in the areas of Erosion Control and in Cooling Tower Drift were required. As discussed above, there are no longer any active monitoring requirements for these issues. The Erosion Control Inspection was included in semi-annual surveys until stabilization of soil and vegetation (i.e., ground cover establishment) was achieved. This has been achieved, and is no longer reported in the annual report to the NRC. The Cooling Tower Drift Program measured cooling tower drift deposition. The last sentence of Section 4.2.2 states that the program was terminated.
Section 5.0 -- Administrative Procedures This section consists of Sections 5.1, 5.2, and 5.3 discussed below.
to CNRO-2002/005 Page 5 of 14 Section 5.1 - Review and Audit This section requires review and audit of compliance with the EPP. There are no longer any active EPP monitoring programs to audit. Therefore, reviews and audits of the EPP are no longer necessary.
Section 5.2 - Records Retention This section requires retention of records relative to the environmental aspects of plant operation and modifications determined to potentially affect the continued protection of the environment. Evaluation records involving unreviewed environmental questions (environmental evaluations) are required to be documented by corporate environmental administrative procedures.
Section 5.3 - Chanqes in the Environmental Protection Plan This section requires NRC approval prior to implementing changes in the EPP.            With the deletion of the other sections of the EPP, this section would no longer apply.
Section 5.4 - Station Reportinc Requirements This section consists of Sections 5.4.1 and 5.4.2 discussed below.
Section 5.4.1 - Routine Reports This section requires an annual environmental operating report be submitted to the NRC prior to May 1 of each year. The report includes summaries/analyses of the activities required by Section 4.2, a list of EPP noncompliances and the corrective actions taken to remedy them, a list of all changes in the station design or operation, tests and experiments made in accordance with Section 3.1 involving potentially significant unreviewed environmental issues, and a list of nonroutine reports submitted in accordance with Section 5.4.2. The programs that had been required by Section 4.2 have been discontinued. Environmental noncompliances are reported as required by 10 CFR 50.72 and, along with the associated corrective actions, are included in the Entergy Corrective Action Program. Design changes are included in the Entergy 10 CFR 50.59 Review Program and are reported to the staff under the guidelines of 10 CFR 50.59.
Deletion of the EPP would negate the need to transmit an annual environmental operating report to the NRC with this information.
As the pertinent information of the report is submitted to the NRC under separate programs, this section may be deleted.
Section 5.4.2 - Nonroutine Reports A written report to the NRC is required within 30 days of occurrence of nonroutine events. The NRC shall be provided with a copy of reports to other Federal, State, or local agencies. The NRC is already notified verbally of unusual or important environmental events per the requirements of 10 CFR 50.72. Nonroutine reports, including those involving unusual or important environmental events, are submitted to the appropriate regulatory agency per to CNRO-2002/005 Page 6 of 14 applicable requirements. Since the reports are already required by other agencies and the NRC is verbally notified, sending an additional copy of a written report to the NRC is an unnecessary reporting burden.
RBS Section 1.0 - Obiective of the Environmental Protection Plan This section contains the objectives of the EPP which is to provide for protection of environmental values during construction and operation of the nuclear facility. These objectives are met through the NPDES Permit, and other Federal, State, and local requirements for environmental protection.
Section 2.0 - Environmental Protection Issues This section consists of Sections 2.1, 2.2, and 2.3 discussed below.
Section 2.1 - Aquatic Issues This section of the EPP does not impose any requirements or identify any aquatic issues at RBS. The NRC relies on the State regulatory agency (Louisiana Department of Environmental Quality) to regulate water quality matters. The EPA has oversight of State programs. This is accomplished through compliance with the limitations and conditions imposed by the RBS Louisiana Pollutant Discharge Elimination System (LPDES) permit.
Section 2.2 - Terrestrial Issues The EPP imposes monitoring requirements on potential impact of cooling tower drift on vegetation surrounding the site. This monitoring program was required during the first three years of operation. No adverse impacts were noted during this monitoring period and the program was discontinued. There are no longer any active monitoring requirements associated with this section.
Section 2.3 - Noise Issues The EPP imposes monitoring requirements on operational noise levels in the site vicinity. This requirement was met during the first year of operation. No adverse impacts were noted during this monitoring period and the program was discontinued. There are no longer any active monitoring requirements associated with this section.
Section 3.0 - Consistency Requirements This section consists of Sections 3.1, 3.2, and 3.3 discussed below Section 3.1 - Plant Design and Operation The EPP allows changes to be made in plant design or operation or performance of tests or experiments affecting the environment provided that they do not involve an unreviewed to CNRO-2002/005 Page 7 of 14 environmental question or a change to the EPP. Activities are excluded from this requirement if all measurable nonradiological effects are confined to on-site areas previously disturbed during site preparation and plant construction. This requirement is duplicated in the Entergy 10 CFR 50.59 Review Program procedure. This procedure requires an environmental screening. Full Environmental Evaluations are performed for those changes that do not meet the screening criteria. These changes are evaluated against all environmental requirements.
This section also requires that the licensee maintain record of changes in plant design or operation and of tests and experiments carried out pursuant to this section. This requirement is also duplicated in the Entergy 10 CFR 50.59 Review Program procedure.
Section 3.2 - Reportingq Related to the NPDES Permits and State Certification This section requires that violations, changes and additions of/to the NPDES permit or the State Certification shall be reported to the NRC. The NRC relies on the State regulatory agency to regulate these matters. All reporting to the NRC will be done in accordance with 10 CFR 50.72.
Information related to environmental permits will be available on site for NRC review.
Section 3.3 - Changes Required for Compliance with Other Environmental Regulations This section exempts those changes required to achieve compliance with other Federal, State, or local environmental regulations from the requirements of Section 3.1. An exemption from this section will no longer be necessary after implementation of this change.
Section 4.0 - Environmental Conditions This section consists of Sections 4.1 and 4.2 discussed below.
Section 4.1 - Unusual or Important Environmental Events This section requires that any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to station operation shall be recorded and reported to the NRC within 24 hours followed by a written report within 30 days.
RBS is required to notify the NRC in accordance with 10 CFR 50.72. In addition, the site is already required by State and Federal Agencies to report such incidences. Therefore, sending an additional copy of the written report to the NRC is an unnecessary reporting burden.
Entergy will, of course, provide any of this information at the request of the NRC staff.
Section 4.2 - Environmental Monitoring This section consists of Sections 4.2.1 Aquatic Monitoring, 4.2.2 Terrestrial Monitoring and 4.2.3 Noise Monitoring discussed below.
For RBS, no Aquatic Monitoring was deemed necessary because the NRC relies on the EPA and the State of Louisiana for aquatic monitoring requirements. Environmental monitoring in the areas of Terrestrial Monitoring and Noise Monitoring were required. As discussed above, both areas no longer contain any active monitoring requirements. Section 4.2 may be deleted in its entirety.
to CNRO-2002/005 Page 8 of 14 Section 5.0 - Administrative Procedures This section consists of Sections 5.1, 5.2, 5.3, and 5.4 discussed below.
Section 5.1 - Review and Audit This section requires review and audit of compliance with the EPP. There are no longer any active EPP monitoring programs to audit. Therefore, reviews and audits of the EPP are no longer necessary.
Section 5.2 - Records Retention This section requires retention of records relative to the environmental aspects of plant operation and modifications determined to potentially affect the continued protection of the environment. Evaluation records involving unreviewed environmental questions (environmental evaluations) are required to be documented by corporate environmental administrative procedures.
Section 5.3 - Changes in the Environmental Protection Plan This section requires NRC approval prior to implementing changes in the EPP.          With the deletion of the other sections of the EPP, this section no longer applies.
Section 5.4 - Plant Reporting Requirements This section consists of Sections 5.4.1 and 5.4.2 discussed below.
Section 5.4.1 - Routine Reports. This section requires an annual environmental operating report be submitted to the NRC within 90 days following each anniversary of issuance of the operating license. The report includes summaries/analyses of the activities required by Section 4.2, a list of EPP noncompliances and the corrective actions taken to remedy them, a list of all changes in the station design or operation, tests, and experiments made in accordance with Section 3.1 involving potentially significant unreviewed environmental issues, and a list of nonroutine reports submitted in accordance with Section 5.4.2. Section 4.2 has been discontinued. Environmental noncompliances are reported as required by 10 CFR 50.72 and, along with the associated corrective actions, are included in the Entergy Corrective Action Program. Design changes are included in the Entergy 10 CFR 50.59 review program and are reported to the staff under the guidelines of 10 CFR 50.59. Deletion of the EPP would negate the need to transmit an annual report to the NRC with this information.
Section 5.4.2 - Nonroutine Reports A written report to the NRC is required within 30 days of occurrence of nonroutine events. The NRC shall be provided with a copy of reports to other Federal, State, or local agencies. The NRC is already notified verbally of unusual or important environmental events as required by 10 CFR 50.72. Nonroutine reports, including those involving unusual or important environmental events, are submitted to the appropriate regulatory agency per applicable requirements. Since to CNRO-2002/005 Page 9 of 14 the reports are already required by other agencies and the NRC is verbally notified, sending an additional copy of a written report to the NRC is an unnecessary reporting burden.
Waterford 3 Section 1.0 - Obiectives of the Environmental Protection Plan This section contains 'the objectives of the EPP which is to provide for protection of environmental values during construction and operation of the nuclear facility. These objectives are met through the NPDES Permit, and other Federal, State and local requirements for environmental protection. This section may be deleted based on meeting these objectives through these other means.
Section 2.0 - Environmental Protection Issues This section contains the environmental protection issues.        Each issue will be discussed separately.
Section 2.1 - Aquatic Resources Issues This section of the EPP does not impose any requirements or identify any aquatic issues at Waterford 3. The NRC relies on the State regulatory agency (Louisiana Department of Environmental Quality) to regulate water quality matters. The EPA has oversight of State programs. This is accomplished through compliance with the limitations and conditions imposed by the Waterford 3 LPDES permit.
Section 2.2 - Terrestrial Resources Issues No terrestrial issues were identified for Waterford 3. Therefore, there were no monitoring requirements past or present associated with terrestrial issues.
Section 2.3 - Cultural Resources Issues The EPP requires the protection of two archaeological sites though the development of a Cultural Resources Protection Plan. This plan has been developed and is now in place. The plan is the binding document to which Waterford 3 will adhere. This requirement is fully satisfied with no further action required.
Section 3.0 - Consistency Requirements This section consists of Sections 3.1, 3.2 and 3.3 discussed below.
Section 3.1 - Plant Desiqn and Operation The EPP allows changes to be made in plant design or operation or performance of tests or experiments affecting the environment provided that they do not involve an unreviewed environmental question or a change to the EPP. Activities are excluded from this requirement if all measurable nonradiological effects are confined to on-site areas previously disturbed during to CNRO-2002/005 Page 10 of 14 site preparation and plant construction. This requirement is duplicated in the Entergy 10 CFR 50.59 review program.          This procedure requires an environmental screening.            Full Environmental Evaluations are performed for those changes        that do  not meet the screening criteria. These changes are evaluated against all environmental requirements.
This section also requires that the licensee maintain record of changes in plant design or operation and of tests and experiments carried out pursuant to this section. This requirement is duplicated in the Entergy 10 CFR 50.59 review progdrai Section 3.2 - Reporting Related to the NPDES Permits and State Certification This section requires that changes and additions of/to the NPDES permit or the State Certification shall be reported to the NRC. The NRC relies on the State regulatory agency to regulate these matters. All reporting to the NRC will be done in accordance with 10 CFR 50.72.
Information related to environmental permits will be available on site for NRC review.
Section 3.3 - Changes Required for Compliance with Other Environmental Requlations This section exempts those changes required to achieve compliance with other Federal, State or local environmental regulations from the requirements of Section 3.1. An exemption from this section will no longer be necessary after implementation of this change.
Section 4.0 - Environmental Conditions This section consists of Sections 4.1 and 4.2 discussed below.
Section 4.1  -  Unusual or Important Environmental Events This section requires that any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to station operation shall be recorded and reported to the NRC within 24 hours followed by a written report within 30 days.
There is already a requirement to notify the NRC verbally as required by 10 CFR 50.72. Follow up written reports are submitted based on State regulatory requirements. Therefore, sending an additional copy of the written report to the NRC is an unnecessary reporting burden.
Entergy will provide any of this information when requested by the NRC staff.
Section 4.2 - Environmental Monitoring For Waterford 3, no Aquatic or Terrestrial Monitoring was deemed necessary. The NRC relies on the EPA and the State of Louisiana for aquatic monitoring requirements. Operations and maintenance activities are controlled through a Cultural Resources Protection Plan to negate any possible adverse effects to Waterford 3 cultural resources. This plan is the binding document to which the licensee will adhere. The Advisory Council on Historic Preservation (ACHP) concurrence of the plan was received by the NRC on October 18. 1983.
Section 5.0 - Administrative Procedures This section consists of Sections 5.1, 5.2, 5.3 and 5.4 discussed below.
 
Attachment I to CNRO-20021005 Page 11 of 14 Section 5.1 - Review and Audit This section requires review and audit of compliance with the EPP. There are no active monitoring EPP programs to audit. Therefore, reviews and audits of the EPP are no longer necessary.
Section 5.2 - Records Retention This section requires retention of records relative to the environmental aspects of plant operation and modifications determined to potentially affect the continued protection of the environment. Evaluation records involving unreviewed environmental questions (environmental evaluations) are required to be documented by corporate environmental administrative procedures.
Section 5.3 - Chanqies in the Environmental Protection Plan This section requires NRC approval prior to implementing changes in the EPP.            With the deletion of the other sections of the EPP, this section no longer applies.
Section 5.4 - Plant Reporting Requirements This section consists of Sections 5.4.1 and 5.4.2 discussed below.
Section 5.4.1 - Routine Reports This section requires an annual environmental operating report be submitted to the NRC within 90 days following each anniversary of issuance of the operating license. The report includes summaries/analyses of the activities required by Section 4.2, a list of EPP noncompliances and the corrective actions taken to remedy them, a list of all changes in the station design or operation, tests, and experiments made in accordance with Section 3.1 involving potentially significant unreviewed environmental issues, and a list of nonroutine reports submitted in accordance with Section 5.4.2.          Section 4.2 has been discontinued.          Environmental noncompliances are reported as required      by  10  CFR  50.72 and,  along with the associated corrective actions, are included in the Entergy Corrective Action  Program. Design  changes are included in the Entergy 10 CFR 50.59 review program and are reported to the staff      under the guidelines of 10 CFR 50.59. Deletion of the EPP would negate the need to transmit an annual report to the NRC with this information.
Section 5.4.2 - Nonroutine Reports A written report to the NRC is required within 30 days of occurrence of nonroutine events. The NRC shall be provided with a copy of reports to other Federal, State, or local agencies. The NRC is already notified verbally of unusual or important environmental events per the requirements of 10 CFR 50.72. Nonroutine reports, including those involving unusual or important environmental events, are submitted to the appropriate regulatory agency per applicable requirements. Since the reports are already required by other agencies and the to CNRO-2002/005 Page 12 of 14 NRC is verbally notified, sending an additional copy of a written report to the NRC is an unnecessary reporting burden.
 
==5.0    REGULATORY ANALYSIS==
 
5.1    Applicable Regulatory Reguirements/Criteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. Entergy has determined that the proposed changes do not require any exemptions or relief from any regulatory requirements, other than the FOLs, and do not affect conformance with any General Design Criteria (GDC) differently than described in the Updated Final Safety Analysis Report (UFSAR). The EPP was established during initial plant operations to monitor terrestrial issues such as potential erosion along transmission lines, cooling tower drift impact on vegetation, noise, and cultural resources issues. The regulatory basis for the establishment of the EPP was 10 CFR 50.36b. This section requires that any obligations in the environmental area identified by the NRC during their evaluation in the NRC record of decision be included in an attachment to the license. The attachment is incorporated in, and made a part of the license. The conditions are derived from information contained in the environmental report and the supplement to the environmental report submitted as required by 10 CFR 51.50 and 51.53. The attachment is only required when conditions are identified in the record. In this case, these monitoring programs have been completed and the results have demonstrated that the environmental impacts are negligible.
The licensees are bound by other Federal (i.e., the EPA), State, and local agencies to comply with environmental protection regulations. The NRC relies on these agencies to regulate the licensee in environmental matters. None of the environmental protection requirements established by other agencies are being reduced by removal of Appendix B from the FOLs.
The EPPs can therefore be deleted from the FOLs.
5.2      No Significant Hazards Consideration The proposed amendments will delete the content of the Appendix B, Environmental Protection Plan (Non-Radiological) from the Facility Operating License (FOL) for each unit. In addition, the appropriate sections of each FOL referring to the Environmental Protection Plan (EPP) will be modified to remove that reference. This amendment request is administrative in nature and is intended to relieve Entergy Operations, inc. (Entergy) of the burden of certain environmental reports.
Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
: 1.      Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
to CNRO-2002/005 Page 13 of 14 The EPPs are concerned with monitoring the effect that plant operations have on the environment for the purpose of protecting the environment and has no affect on any accident postulated in the Updated Final Safety Analysis Report (UFSAR). Accident probabilities or consequences are not affected in any way by the environmental monitoring and reporting required by the EPPs. The deletion of Appendix B of the FOL will not impact the design or operation of any plant system or component. The NRC relies on other Federal, State, and local agencies for environmental protection regulation. No environmental protection requirements established by these other agencies are being reduced by this license amendment. The programs and reporting requirements of the EPPs do not affect initiation or mitigation of any accidents previously analyzed.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2.      Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
This license amendment is administrative in nature. Environmental monitoring and reporting has no affect on accident initiation. The deletion of the EPPs will not produce any changes to the design or operation of the plant. There will be no effect on the types and amounts of any effluent that will be released.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
: 3.        Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
This change is administrative in nature. The change in annual reporting requirements has no impact on margin of safety. Environmental Evaluations will still be performed, where necessary, on changes to plant design or operations to assess the effect on environmental protection.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, Entergy concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
5.3      Environmental Considerations The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be to CNRO-2002/005 Page 14 of 14 released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
6.0    PRECEDENCE This amendment request is similar to that granted to Duke Power for its McGuire Nuclear Station Units 1 & 2 (TAC Nos. M90860 and M90861) and Catawba Nuclear Station Units 1 & 2 (Amendment Nos. 149 and 143) in 1996.
 
Attachment 2 CNRO-2002/00005 Markup of Current Facility Operating License Grand Gulf Nuclear Station
 
E. Entergy Operations, Inc. (EOI), is technically qualified to engage in the activities authorized by this operating license in accordance with the Commission's regulations set forth in 10 CFR Chapter 1; F. The licensees have satisfied the applicable provisions of 10 CFR Part 140, *Financial Protection Requirements and Indemnity Agreements," of the Commission's regulations; G. The issuance of this license will not be inimical to the common defense and security or to the health and safety of the public; H. After weighing the environmental, economic, technical, and other benefits of the facility against environmental and other costs and considering available alternatives, thissuance of Facility O eatiýn      cans No. NPF-29 pla *t~ahpd t Ane*"
Ap~tpAJ9                      s 1-in ac-co-rdance with 10 C ~Par-t 51 of the Commission's egulations and all applicable requirements have been satisfied; and I. The receipt, possession, and use of source, by-product and special nuclear material as authorized by this license will be in accordance with the Commission's regulations in 10 CFR Parts 30, 40, and 70.
: 2. Based on the foregoing findings regarding this facility and pursuant to Commission Order CLI-84-19, dated October 25, 19B4, License NPF-13, as amended, is superseded by this Facility Operating License NPF-29 which is hereby issued to Entergy Operations, Inc., Entergy Mississippi, Inc.,    I System Energy Resources, Inc., and South Mississippi Electric Power Association to read as follows:
  'A. This license applies to the Grand Gulf Nuclear Station (GGNS),
Unit 1, a boiling water nuclear reactor and associated equipment (the facility), owned by System Energy Resources, Inc., and South Mississippi Electric Power Association and operated by Entergy Operations, Inc. The facility is located in Claiborne County, Mississippi, and is described in the licensees' "Final Safety Analysis Report,' as supplemented and amended, and in the licensees' Environmental Report, as supplemented and amended.
D. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses:
(1)    Entergy Operations, Inc. (EOI) pursuant to Section'103 of the Act and 10 CFR Part 50, to possess, use, and operate the facility at the designated location in Claiborne County, Mississippi, in accordance with the procedures and limitations set forth in this license; (2)    System Energy Resources, Inc., and South Mississippi Electric Power Association to possess, but not operate, the facility at the designated location in Claiborne County, Mississippi, in accordance with the procedures and limitations set forth in this license; Amendment No. 6;,125
 
(b)    SERI is required to notify the NRC in writing prior to any change in (i) the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized financial transactions, (ii)            the GGNS Unit 2 operating agreement, (iii)            the existing property insurance coverage for GGNS Unit 1 that would materially alter        the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19," 1988 attached to Amendment No. 54.
In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.
C. The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)  Maximum Power Level Entergy Operations, Inc. is authorized to operate the facility  at reactor core power levels not in excess of 3898 megawatts thermal (100 percent power) in accordance with the conditions specified herein.
(2)  Technical Specifications The Technical Specifications contained in Appendix A as revised thrugh  ýA:mendmnt No. 156 are ereby incorporated into this license.        Entergy Operations, Inc. shall operate the facility              in accordance with the Technical Specifications 4          Amendment 1-4-8.,  a-5-,    156
 
F,    EOI shall report any violations of the requirements contained in Section 2, Items C.(1), C.(4) through C.(38) of this license within-twenty-four (24) hours. Initial notification shall be made in accordance with the provisions of 10 CFR 50.72 with written follow-up in accordance vith the procedures described in 10 CFR 50.73(b),    (c), and We).
G. The licensees shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, an amended, to cover public :iability claims.
H,  This license is effective as of the date of issuance and shall "exepire at midnight on November 1, 2024.
rOP THE NUCLEAR REGULATORY CObMISSION ORICINAL SIGNED BY:
Harold R. Denton, Director Office of Nuclear Reactor Regulation Attachments:
: 1. Attachments I and 2
: 2. Appendix A - Technical Specifications (NUREG-0934). ,
: 5.                - Eni7ý Bp~n            l  0"z j,_'*QeJ
: 4. Appendix C - Ant*itrust  ConditionsI Date of Imsuance: November 1, 19A4 Amendment No. &6, 137          1
 
APP!1NDIX TO FACILITY L1ICENSE NO. MPF-29 11 41D GULFJNULElAR STATION ENTERGY OPýRATIONS, INC.
DOCKET NO. 50-416 ENVIRONMENTAL PROTECTION PLAN OCTOCE    1984 Amendment~tNo. 65
 
GRAND GULFNNUCLEAR STATION
                                                    "*NIT 1 ENVIRONMENTAL PROTECTION PLAN (NON-RADI ILOGICAL)
TABLE OF \CONlTENTS Section                                                                                              Page 1.0  Objectives of the Envlronmental Pro ection Plan ........                                        1 2.0  Environmental Protection Issues.                  . . .. ............                    ... 2-1 2.1  Aquatic Is&ues . ..    ..      ....            ..      .. . . . . . . . . . .                  2-1 2.2  Terrestrial Issues ...............                                                  .  . . . 21 3.0  Consistency Requirements .......                          . .........                          3-1 3.1  Plant Design and Operation .....                                                                3-...............
3.2  Reporting Related to the NPDES Permits and State Certification . . . . . . . . . . . .                      . . . . . . . . . . .                3-2 3.3  Changes Required for Compliance with pther Environmental Regulation .....        ........................                                                3-3 4.0  Environmental Conditions      ......                          ...            ....          . 4-1 4.1  Unusual or Important Environmental Evints. ....                              ...........        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
                                                                        \2
 
'. 1.0  OBJECTIVES OFrTHE ENVIRONHENTAL PROTECTION PLAN The Environmental Prolection Plan (EPP) is to provide for protettion of environmental values daring construction and operation of the nuclear facility.
The principal objectives\of the EPP are as follows:
(1)  Verify that the Plant\I  operated in an enviraonentally acceptable mannar, as established by the tES and other NRC environmental impact assessments.
(2)  Coordinate NRC requirement and maintain consistency with other Federal, State and local requirements\for environmental protection, (3)  Keep NRC informed of the envir nmental effects of facility construction and operation and of action tak    to control those effects.
                                              \FES which relate to water quality tatters are regulated by way of the        \(PDES permit.
I 1-1                          .nt No. 27  1
 
2.0    ENVIRONMENTAL PRTECTION ISSUFS In the FES-OL dated Sep\amber 1981, the staff considered the environmental impacts associated with ihe operation of the Grand Gulf Nuclear Station, Certain environmental iss aes were Identified which re*uired study or license conditions to resolve env$tronmenta1 concerns and to assure adequate protection of the environment.
2.1    AQUatic Issuet No aquatic issues were ident fied in the FES-OL. EffluInt limitations And monitoring requirements are c ntained In the effective NPOES permit issued by the Mississippi Departenl    of atural Resources. The NRC will rely on this agency for regulation of these atters as they Involve water quality and aquatic biota, 2.2    Terrestrial Issues (1)    Potential erosion along trans Ission line-corridors during and  immediately following their construction.
(2)    Potential Impact of cooling towe drift on vegetation surrounding the sites. In the FES the staff reco    nded an aerial remote sensing program.
The applicant opted to do a mort d tailed surveillance program.
NRC requirem4nts with regard to the terrost ial issues are specified in Subsection 4.2 of this EPP.
(L) 2-1            Aiendment No. 96
 
  " 3.0 CORSISTEI  Y REQUIREMfNTS 3.1  Plant Ctesin and Operation The licensee may 4ake changes in plant design or operation or perform tests or experiments affect ng the environment provided such changes, tests or experi ments do not invol    an unreviewed environmental question, and do not involye a change in the Env ohmental Protection Plan.4 Changes In plant design or
* operation and perfo rnce of tests or experiments which do not affect the environment are not s bject to the requirements of this EPP. Activities governed by Section 3. are not subject to the requirements of this section.
* Before engaging in additional construction or operational activities which may affect the environment,    e licensee shall prepare and record an environmental evaluation of such activi .*      When the evaluation indicates that such activity involves an unreviewad envi onmental question, the licensee shall provide a
written evaluation of such    tivities and obtain prior approval from the Director, Office of Nuclear      actor Regulation. When such activity involves a change in the Environnental P otection Plan, such activity and change to the Environmental Protection Plan ay be implemented only in accordance with an appropriate license amendment a set forth in Section 5.3.
A proposed change, test or experi ent shall be deemed to involve an unreviewed environmental question if it conce ns (1) a matter which may result in a sig nificant increase in any adverse environmental impact previously evaluated in the final environmental statement (F\S) 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 A\
This provision does not relieve the lice see of the requirements of 10 CFR 50.59, "Activities are excluded from this requirem t if all measurable environmental effects are confined to on-site areas previo sly disturbed during site pre paration and plant construction.                      2 3-1          Q
 
Board; or (2) a significant change in effluents or power. level; or (3) a matter not iievioushy reviewed and- evaluated in the documents specified
      .in (1) Of this Subsac ion, which may have a significant adverse
        *environtenta) impact.
The licensee shall ma)t..an 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 ex eriment does not InVolve an unreviewed environmental question nor constitute    decrease In the effectiveness of this EPP to meet -he
* objectives specified In ýection 1.0. The licensee shall include as part of the
* Annual Environmental Ope ating Report (per Subsection 5.4.1) brief descriptions.
analyses, interpretations and evaluations of such changes, tests and experiments.
3.2    Reporting Related to    NPDES Permits and Statt Certification Violations of the NPDE5 palt or the State certification (pursuant to Section 401 of the Clean Wat r Act, respectively) shall be reported to the NRC by submittal of copies of th reports required by the NPOES permit or certifi cation.
Changes and additions to the N1 ES permit or the State certification shall be reported to the NRC within 30 d ys following the date the change Is approved.
  "-  If a permft or certification, In\ part or in Its entirmty, is appealed and "stayed, the HRC shall be notifie within 30 days following the date the stay is granted.
The NRC Shall be notified of change proposed by the licensee to the effective NPMES permit by providing NRC with            oft\copy the proposed change at the Same time it is submitted to the permittink agency. The notification of a licensee Initiated change shall Include a copy *1 the requested revision submitted to the Permitting agency. The licensee shf11_ provide the NRC with a copy of its application for renewal of the HPOES per It at the same time the application is submitted to the permitting agency.
3-2
 
3.3  ChanQes Required for Compliance with Other Environmental Regulations Changes in plant design or operation and performance of tests or experiments "required to achieve compliance ith other Federal, State, or local environmental regulations are not subject to  quirements of Section 3.1.
3-3
 
i
* 4.0  ERVIRO        CONDITIONS 4.1  Unusual or I  ortant Environmental Events Any occurrence of a  unusual or important event that indicates or could result in significant envi onmental impact causally'related to station operation shall be recorded an promptly reported to the NRC vithin 24 hours by telephone, telegraph or facsimil transmissions followed by a written report per Sub section 5.4.2. The Ilowing are examples: excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or unusual occurrence of any species protected    the Endangered Species Act of 1973, fish kills, increase in nuisance or anisms or conditions and unanticipated or emergency discharge oi waste wate or chemical substances.
No routine monitoring pro rams are required to implement this condition.
4.2  Environmental Monitor\nq Deviations from required mo itoring programs will not be a violation of license requirements if saumples are accidentally spilled or contaminated, or if samples are unattainable ýue to hazardous conditions, seasonal unavailability, or malfunction of equipment.
t 4.2.1  Erosion Control Inspect on SMaintenance and monitoring of th\ transmission line corridor rights-of-way will be conducted as a part of the normal transmission line inspections from the GGNS to the Franklin in EHV Switch\ng Station, to the Baxter Wilson Steam ELectric Station Switchyard, and to the Port Gibson Substation. These inspections, conducted by aerial surv ys and walking patrols at periodic intervals, include monitoring for eros on or vehicular damage caused by right of-way encroachment by hunters and logge. Problem areas will be identified 4-1
 
by the aerial s\rveys, and walking patrols will be directed to the problem areas to evaluate the extent of the problem to be corrected, The Erosion Cont ol Inspection Program shall begin upon conmencement of normal transmission line inspection procedures. Semi-annual surveys shall continue until stabilizatin of soil and vegetation (i.e., ground cover establishment) is achieved.
A summary of the fi Id Inspection program and any procedures Implemented to control abnormal er sion conditions associated with transmission line maintenance actlviti s shall be reported in the Annual Environmntal Operation Report in accordance ith Subsection 5.4.1. Field logs indicating locations of erosion damage and me surs taken to rectify erosion problem areas and estimation of the time to achieve effective stabilization will be maintained and available for inspectio for a period of five years. Results reported shall contain Information enc passing but not limited to inspection date, estimated size of erosion problem a @a, probable cause of erosion, type of stabilization program, and date of effe tive stabilization, as appropriate.
4.2.2 Cool    Tower ina      Drift P 7a Seven sampling sites were Oti\izo to measure cooling tower
"                                                              drift-deposition.
At least two of the sampling s tes had duplicate sapling devices. Six of the seven sites were located in are s where maximm salt deposition was predicted.
These areas were extrapolated fr    the Bechtel Salt Deposition Model developed for the GGIS Final Environmental eport. The seventh sampling site was a control site located south of Ra    nd, Mississippi. An eighth offsit. control site was added in 1985 in Port Gibs on,Mississippi.
Fallout samples were collected on a q arterly basis and analyzed for ton specific constituents. The details o, the sampling proceddre and chemical
(---*
4-2            Amendment No. #J, 96
 
analysis were submitted to the NIC's Environmental Engfleerlfn  Branch for review and approval prior to plant operation above 5% power. An evaluation of the results of the Cooling Tower Or1't Program Indicated that the operation of the GGNS cooling tower produced no s$tltistically significant effect upon the salt deposition rate for those chemical species evaluated. lhe cooling tower drift program was therefore terminated, V
4,-3          - Amendment No. 96
 
53.0  ADHINIST ATIVE PROCEDURES 5.1  Review an  Audit The licensee sh 11 provide for review and audit of compliance with the Envirocnental Pr tection Plan. The audits fhall be conducted Independently of the individual o groups responsible for performing the specific activity. A description of th organization structure utilized to achieve the independent review and audit f nction and results of the audit activities shall be maintained and made available for inspection.
5.2    Records Retenti Records and logs ralat've to the environmental aspects of plant operation shall be made and rota ned in a manner convenient for review and inspection.
These records and logs hall be made available to NRC on request.
Records of modifications to plant structures, systems and components determined to potentially affect th continued protection of the environment shall be retained for the life of he plant. All other records, data and logs relating to this EPP shall be reta ned for five years or, where applicable, in accordance with the requirements of ther agencies.
5.3    Changes in Environme txl Protection Plan Requests for changes in th Environmental Pvotectlon Plan shall include an assessment of the environmw tel impact of the proposed change and a supporting justification. Implementati n of such changes in the EPP shall not commence prior to NRC approval of the roposed changes In the form of a licensee amendment incorporating the a ropriate revision to the Environmental Protection Plan.
5-1
 
5.4  Station Re~artino Reoulrements
.'5.4.1    Routin  Reports An Annual Envi onmental Operating Report describing Implementation of this EPP for the previo s year shall be submitted to the NRC prior to May 1 of each year. The init Ial report shall be submitted prior to Hay I of the year follow Ing issuance of the operating license. The period of the first report shall begin with the d to of issuance of the operating license for the first operational unit.
The report shall nelude summaries and analyses of the results of the invlrotaental prot ction activities required by Subsection 4.2 of this Environ mental Protection ]an for the report period, including a comparison wlth preoperational stud is, operational controls (ms appropriate),
and previous non-radiological en tronmental monitoring reports, and an assessment of the observed impacts of he station operation on the invironment.
If havmful effects or evidence f trends towards irreversible damage to the environment are observed, the lic nsee shill provide a detailed analysis of the data and a proposed course of ac ion to alleviate the problem.                            I/
the Annual Environment I Operating Report shall also Include:
(a) A list of EPP nonc apliances and the corrective actions taken to remedy them.
Wb)  A list of all chan s In station design or operation, tests, and experiments made in accordance with Subsection 3.1 which involved potentially signifi ant unreviewed environmental issue.
(c) A list of nonroutine reports submitted in accordance with Subsection 5,4.2.
In the event that some res Its are not available by the report due date, the report shall be Submitted oting and explaining the missing results.
The missing data shall be submi ted as soon as possible in a supplementary report.
5-2
 
5.4.2  Honroutine Reports
.*A written repo t shall be submitted to the NRC within 30 days of occurrence of a nonroutine e  nt. The report shall (a) describe, analyze, and evaluate the event, includin  extent and magnitude of these Impact and plant operating characteristics  (b) describe the probable cause of the event, (c) indicate the action take  to correct the reported event, (d) indicate the corrective action taken to  reclude repetition of the qvent and to prevent similar occurrences invo ving similar components or systems,  and (a) indicate the agencies notifie 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 requirem nts in lieu of the requirements of this subsection. The HRC shall be provid d with a copy of each report at the same time it is submitted to the oth r agency.
 
Attachment 3 CNRO-2002/00005 Markup of Current Facility Operating License River Bend Station
 
F.      Entergy Gulf States, Inc. and EOI have satisfied the applicable provisions of 10 CFR Part 140, Financial Protection Requirements and Indemnity Agreements,' of the Commission's regulations; G.      The Issuance of this license will not be inimical to the common detense and security or to the health and safety of the public; H.      After weighing the environmental, economic, lechnical, and other benefits of the facility against environmental and other costs and considering availabl altomabAse Issuance of Faolt 0                  ratin UcenseNo. NPF-47,
* J.... ... ... ..  .      . vi 'on Use 6VJ              is In e c rla ne wt .
CFR
                  .0 Part 51 of the Commission's regulatons and all applicable requirements have been satisfied; and
: 1.      The receipt, possession, and use of source, byproduct and special nuclear material as authorized by this license will be In accordance with the Commission's*
regulations in 10 CFR Parts 30, 40 and 70.
: 2. Based on the foregoing findings and approval by the Nuclear Regulatory Commission at a meeting on November 15, 1985, the Ucense for Fuel Loading and Low Power Testing.
License No. NPF-40, Issued on August 29, 1985, Is superseded by Facility Operating License NPF-47 hereby Issued to EOI and Entergy Gulf Slates, Inc. (the licensees), to read as follows:
A.      This license applies to the River Bend Station, Unit 1, a boiling water nuclear reactor and associated equlprihent, owned by Enlergy Gulf States, Inc. and operated by EOI. The facility is located approximately 2 miles east of the Mississippi River in West Feliciana Parish, Louisiana, approximately 2.7 miles southeast of St. Francisville, Louisiana and approximately 18 miles northwest of the city limits of Baton Rouge, Louisiana, and is described in the "Final Safety Analysis Report, as supplemented and amended, and in the Environmental Report-Operating License Stage, as supplemented and amended.
B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses:
(1)        Entergy Gulf States, Inc. to possess the facility at the designated location in West Feliciana Pariah, Louisiana, In accordance with the procedures and limitations set forth in this license; (2)        E01, pursuant to Section 103 of the Act and 10 CFR Part 50, to possess, use and operate the facility at the above designated location in accordance with the procedures and limitations set forth in this license; Amendment No. 9.9.8.
101
 
                                              .3-(3)      EOI, pursuant to the Act and 10 CFR Part 70, to receive, possess and to use at any time special nuclear material as reactor fuel, in accordance with the hmitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended, (4)      E0I, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required:
(5)        E0I, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restnction to chemical or physical form. for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6)        EOI, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C.      This license shall be deemed to contain and Is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect: and is subjec-to the additional conditions specified or incorporated below:
(1)        Maximum Power Level EOI is authorized to operate the facility at reactor core power levels not in excess of 3039 megawatts thermal (100% rated power) in accordance with the conditions specified herein. The items identified in Attachment 1 to this license shall be completed as specified. Attachment 1 Is hereby incorporated into this license.
(2)      Technical Specifications The Technical Specifications contained in A pendix          as revised through Amend ent No. 704 are hereby incorporated In the license. EOI shall peratethe ai4 in accordance with the Technical Specifications
                                                                                        ')
Amendment No. 4 Q.    ! 14
 
D. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to the provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "River Bend Station Security Plan," with revisions submitted through May 25, 1995; "River Bend Station Guard Training and Qualification Plan," with revisions submitted through December 3, 1993; and "River Bend station Contingency Plan," with revisions submitted through August 17, 1990.
Changes made in accordance with 10'CFR 73.55 shall be implemented in accordance with the schedule set forth therein.
E. Except as otherwise provided in the Technical Specifications(ox rm'        t      rt-,                EOI shall report any violationlg-of the requirements contained in Section 2.C of this license in the following manner: initial        notification shall be made within 24 hours to the NRC Operations Center via the Emergency Notification System with written followup within thirty days in accordance with the procedures described in 10 CFR 50.73(b),
(c) and (e).
F. The licensee shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Enezgy Act of 1954, as amended, to cover public liability        claims.
G. This license is effective as of the date of issuance and shall expire at midnight on August 29, 2025.
FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By Harold R. Denton, Director Office of Nuclear Reactor Regulation
 
==Enclosures:==
: 1. AtLachments 1-5
: 2. Appendix A - Technical Specifications (NUREG-_17
: 3. Appendix B -            .. tTTUEýL.---Plan tm-,-tJJ
: 4. Appendix C - Antitrust Conditions Date of Issuance: November 20,      1985 Revised: December 16,  1993 Amendment No. .0,  979,as, 119
 
APPENDIX B TO FACILITY OP \RATING LICENSE NO. NPF-47 R1I~ R BEND STATION NIT 1 ENTERGY OP RATIONS, INC.
DOCKET *.O 50-458 RECEIVED..
:AuC . 01 1995.:
S* * -.  . : ' .
ENVIRONMENTAL PROTECT      N PLAN (NONRADIOLOGICAL)
Amendment No. Z, 79
 
                                  "          RIVE'R>END STATION
                                                            \UNIT I
ENVIRONMENTAI\ PROTECTION PLAN (NONRADI'LOGICAL)
Section.O                              TABLE OF CO\TENTS aq 1.0  Objectives of the Environmental Protecti n Plan .............................                                        .
2.0    Environmental Protection Issues .............. ....                                                                  ........ 2-1 2.1  Aquatic Issues                                                                                                                  2-1 2.2  Terrestrial Issues .......................................                                                                      2-1 2.3  N oise Issues ...............................................  .........................................................        2-1 30    Consistency Requirements.................                                                                                      3-1 3 1  Plant D esign and O peration ................................................................................                  3-1 32    Reporting Related to the NPDES Permit an State Certifications ........................ 3-2
. 3.3  Changes Required for Compliance with Othe Environmental Regulations .......... 3-3 4.0  Environm ental 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  R eview and A udit .....................................                . . .... .................................... 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    e Environmental Protection Plan The Environmental Protect\on 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 op rated in an environmentally acceptable manner, as established by the Final En ronmental Statement - Operating Licensing Stage (FES OL) and other NRC environm Mal impact assessments,
    * (2)    Coordinate NRC requirements a          maintain consistency with other Federal, State and local requirements for environment I protection.
(3)    Keep NRC informed of the environmen I effects of facility construction and operation and of actions taken to control those effe ts.
Environmental concerns identified in the FES-OL whi h relate to water quality matters are regulated by way of the licensee's NPDES permit.
      ...                    .*-1-1
 
20          Environmental P lection Issues In the FES-O1L dated Januar' 1985, the staff considered the environmental impacts associated with the operation of the RivJ r Bend Station Unit 1. Certain environmental issues were identified which required stu    or license conditions to resolve environmental concerns and to assure adequate protection o the environment.
2.1        Aquatic Issues No specific aquatic issues we    identified by the NRC staff in the FES-OL.
2.2        Terrestrial Issues Detection of possible changes i or damage to local flora caused by drift deposition due to the operation of the River Bend Stat on Cooling Towers. (FES-OL Section 5.14.1) 23          Noise Issues Adverse community reaction is exp cted 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 i Section 4.2.3. (FES-OL Section 5.A4) 2-1
 
3.0    Consistenc Requirehients 3.1      Plant Design and Operation The licensee may ma e changes in station design or operation or perform tests or experiments affecting the environ    nt provided such activities do not involve an unreviewed environmental question and do not in olve a change in the EPP*. Changes in station design or operation or performance of tests o experiments which do not affect the environment are not subject to the requirements of this EP . Activities governed by Section 3.3 are not subject to the requirements of this Sec ion.
Before engaging in additi\ nal construction or operational activities which may significantly affect the environment, th licensee shall prepare and record an environmental evaluation of such activity. Activities ar excluded from this requirement if all measurable nonradiological environmental effects are      nfined to the on-site areas previously disturbed during site preparation and plant const uction. When the evaluation indicates that such activity involves an unreviewed environment I question, the licensee shall provide a written evaluation of such activity and obtain prior NRC pproval. When such activity involves a change in the EPP, such activity and change to th EPP may be implemented only in accordance with an appropriate license amendmen as set forth in Section 5.3 of this EPP, This provision does not relie(,'e the licensee of the requirements of 10 CFR 50.59.
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A proposed change, te2t or 6xperiment shall be deemed to involve an uhreviewed environmental question f it concerns: (1) a matter which may result in a significant increase in any adverse environmen al impact previously evaluated in the FES-OL, environmental impact appraisals, or in any de i ions of the Atomic Safety and Licensing Board; or (2) a significant change in effluents or pov r 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 r cords of changes in facility design or operation and of tests and
* experiments' carried out purs    nt to this Subsection. These records shall include written evaluations which provide bas    for the determination that the change, test, or experiment does not involve an unreviewed environmental question or constitute a decrease in the effectiveness of this EPP to mee the objectives specified in Section 1.0. The licensee ihall include as part of the Annual Envi onmental Operating Report (per Subsection 5.4.1) brief
"*  descriptions, analyses, interpreatib ns, and evaluations of such changes, tests and
  *' experiments.
3.2          Reporting Related to th    NPDES Permit and State Certification The licensee shall notify the NRC of pr posed revisions to the effective NPDES Permit if the "proposedrevision is a significant chang of waste stream flow rate, concentration, or point of discharge. This shall be done by providrin NRC with a copy of the proposed revision at the same 3-2
 
time it is submitted to the permiti g agency. The licensee shall provide the NRC a copy of the application for renewal of the NP ES Permit at the same time the application is submitted to the permitting agency.
Changes to, or renewals of, the NPý ES Permits or the State certification shall be reported to the NRC within 30 days following tht date the change or renewal is approved. If a permit or certification, in part or in its entirety, appealed and stayed, the NRC shall be notified within 30 days following the date the stay is ranted.
3.3          Changes Required for Corn liance with Other Environmental Regulations Changes in plant design or operation an performance of tests or experiments which are required to achieve compliance with othe \Federal, State, and local environmental regulations are not subject to the requirements of Sect] n 3A.1 3-3
 
"4.0          Environmental Conditions 4.1          Unusua~or Important Environmental Events Any occurrence of an nusual or important event that indicates or could result in significant environmental impact ausally related to plant operation shall be recorded and reported to the NRC 'Within24 hours fol owed by a written report per Subsection 5.4.2. The following are examples: excessive bir impaction events, onsite plant or animal disease outbreaks, mortality or unusual occurrence of ny species protected by the Endangered Species Act of 1973, fish kills, increase in nuisance rganisms or conditions, and unanticipated or emergency discharge of waste water or chemical ubstances.
No routine monitoring progra s are required to implement this condition.
4.2          Environmental Monit ring 4.2.1        Aquatic Monitoring The certifications and permits require under the Clean Water Act provide mechanisms for protecting water quality and, indirectly, a uatic biota. The NRC will rely on the decisions made by the U.S. Environmental Protection Agen and the State of Louisiana underthe authority of the Clean Water Act for any requirements for uatic monitoring.
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4.2.2        Terrellrial Monitoring Vegetative commu ities of the site and vicinity within 1 Kilometer of the cooling towers in all directions shall be a rially 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 Septe    ber or early October. Monitoring shall include a program of low altitude color Infrared p otography. The scale for full coverage shall be adequate to enable identification of vegetativ damage over relatively small areas of terrain, Some circumstances may warrant inspection of photographs discerning individual trees. Such scale should be rti  ns a b adequate to resolve impact d features. Photographs              duin flnptaken during plant operation shall be t
compared with pre-operation I photographs (baseline) to ascertain changes in vegetation.
Photographic interpretations siall be verified by ground inspection surveys to confirm areas of stress and non-stress. This pr gram shall require aerial photographic monitoring to begin 2 years preceding initiation of coo Iing tower operation and during the following first and third years. If adverse effects are obs~erved, the NRC will require the applicant to repeat the study in additional years and to performrexaminations of vegetation, both on and off site, to Sdetermine the extent of the damage. Such studies are necessary to determine the need for any corrective action to mitigate the\mpacts.
A report shall be submitted as part ofthe\;                          each aerial photographic monitoring period. The report shall contaii 4-2
 
I.
description of the ýrogtam, results and interpretative analysis of environmental impacts.
Results reported shall contain information encompassing but not limited to the following:
sampling date, tim, of day, film types, and one (1) set of resultant color transparencies encompassing an a a within approximately a one Kilometer (1 Kin) radius of the Station's normal cooling tower 4.2.3        Noise Monit ring A noise monitoring progr 'm shall be conducted in the site vicinity during the first full year following the onset of com ercial operation of River Bend Station.
The purpose of the
. program is to characterize t e Station's operational noise levels, to compare these levels with ambient levels recorded duri g 1972 and 1980 surveys, and to evaluate the community impact, ifany, of cooling towerfan blade tonal noise and incremental broadband noise.
The monitoring program will inclu e measurements of sound levels at the nearest residence in each of six 45" (forty-five degree) 'rectional sectors from the Northwest through the South (i.e., residences RI, R4, and R7 sho n on Figure 5.22 FES-OL, and throe additional residences in the compass sectors Ea        Southeast, and South. At each location daytime and nighttime (midnight to 4:00 a m ) measur ments will be made once in Wrnter and Summer to S *obtain statistical indicators (Lo0 L, L5 Leq) fo a weighted decibel levels. Additionally one-third octave band analysis will be performed at ea h location on each visit.
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Results of these surveys will be evalu fed and included in the ahnual environmental monitoring report. If noise Impacts are identified during the Summer or Winter surveys a discussion of proposed mitigative melsures will be included In the monitoring report.
                                          \C 4-4
 
5.0          Admini trative Procedures 5.1          Review and Audit The licensee shall pr vide for review and audit of compliance with the EPP, The audits shall be conducted indepe dently of the individual or groups responsible for performing the specific activity. A descriptio of the organization structure utilized to achieve the independent review and audit function and esults of the audit activities shall be maintained and made available for inspection.
5.2          Records Reaen ion "Records and logs relative to th environmental aspects of station operation shall be made and retained in a manner convenientxfor review and inspection. These records and logs shall be made available to NRC on reque t.
Records of modifications to station tructures, systems and components determined to potentially affect the continued prote ion of the environment shall be retained for the life of the station. All other records, data and log relating to this EPP shall be retained for five years or, where applicable, in accordance with the equirements of other agencies.
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o 3Changes    Envirnmental Protection Plan Reqluests 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 l*(ior to NRC approval of the proposed changes in the form of a license amendment incorpo.ting the appropriate revision to the EPP.
5.4          Plant. Reporting ReJuirements 5.4.1        Routine Reports An Annual Environmental Operating Report describing implementation of this EPP for the previous year shall be submitted wit in 90 days following each anniversary of 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\lyses 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, operatio al controls (as appropriate),
and previous nonradiological environmental monitoring rep        s, and an assessment of the observed impacts of the plant operation on the environment. If ha      ful effects or evidence of trends toward irreversible damage to the environment are obser~ad, the licensee 1                shall provide a detailed analysis of the data and a proposed course of mitigý,ing action.
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The Annual Environmental Operating Report shall also include:
(1)    A list of EPP nonco pliances 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 Subs ction 3.1 which involved a potentially significant unreviewed environmental questio\
(3)    A list of nonroutine repots submitted in accordance with Subsection 5.4.2.
In the event that some results ar\ not available by the report due date, the report shall be submitted noting and explaining t le missing results, The missing results shall be submitted as
* soon as possible in a supplement ry 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, ýnalyze, and evaluate the event, including extent and magnitude of the impact, and plant ope ating characteristics, (b) describe the probable cause
;  of the event, (c) indicate the action taken o correct the reported event, (d) indicate the corrective 5-3
 
action taken to preclude repetition of the event and to pr6ven' similar occurrences involving similar components or systems, ar*d (e) indicate the agencies notified and their preliminary respcnses.
Events reportable under this subs ction 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, T e NRC shall be provided with a copy of such report at the same time it is submitted to the othe\ agency.
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Attachment 4 CNRO-2002/00005 Markup of Current Facility Operating License Waterford Steam Electric Station - Unit No. 3
 
E.    ' Entergy Operations, Inc. (EOI) is technically qualified to engage in the activities authorized by this operating license In accordance with the Commission's regulations set forth in 10 CFR Chapter I; F.      Entergy Louisiana, Inc. has satisfied the applicable provisions of 10 CFR Part 140, "Financial Protection Requirements and Indemnity Agreements", of the Commission's regulations; G.      The issuance of this license will not be inimical to the common defense and security or to the health and safety of the public; H.      After weighing the environmental, economic, technical, and other benefits of the facility against environmental and other costs, and after considering available alternatives, the issuance of the Facility Operating License No. NPF-38. 2>.jt I. the  -    ,nditkr" !a, protection of the enoAronment set forth in thI En'i.ronmmnt*l P.....tie. Plan a..he. e. Appendix B--- is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied; and
: 1.      The receipt, possession, and use of source, byproduct, and special nuclear material as authorized by this license will be in accordance with the Commission's regulations in 10 CFR Part 30, 40 and 70, except that an exemption to the provisions of 10 CFR 70.24 is granted as described in Supplement No. 8 to the Safety Evaluation Report. This exemption is authorized under 10 CFR 70.24(d) and will not endanger life or property or the common defense and security and is otherwise In the public Interest.
: 2. Pursuant to approval by the Nuclear Regulatory Commission at a meeting on March 15, 1985, the license for fuel loading and low power testing, License No, NPF-26, issued on December 18, 1984, is superseded by Facility Operating License No. NPF-38 hereby issued to Entergy Louisiana, inc. and Entergy Operations, Inc. to read as follows:
A.      This license applies to the Waterford Steam Electric Station, Unit 3, a pressurized water reactor and associated equipment (the facility), owned by Entergy Louisiana, Inc. The facility is located on the Entergy Louisiana, Inc. site in St. Charles Parish, Louisiana and Is described in the Entergy Louisiana, Inc. Final Safety Analysis Report as amended, and the Environmental Report as amended, AMENDMENT NO, 134
 
or indirectly any control over (i) the facility, (ii) power or energy produced by the facility, or (iii) the licensee of the facility.
Further, any rights acquired under this authorization may be exercised compliance with and subject to the requirements and                    only in restrictions of this operating license, the Atomic Energy Act of 1954.
as amended, and the NRC's regulations. For purposes of this condition, limitations of 10 CFR 50.81, as now in effect and as                      the they may be subsequently amended, are fully applicable to the equity and any successors in interest to the equity investors,                investors as long as the license for the facility remains in effect.
(b)        Entergy Louisiana, Inc. (or its designee) to notify the prior to any change in (i) the terms or conditions of NRC in writing any agreements executed as part of the above authorized lease transactions, (iH)any facility operating agreement involving    financial a licensee that is in effect now or will be In effect in the future, property insurance coverages for the facility, that          or  (iii)  the  existing alter the representations and conditions, set forth would materially in the staff's Safety Evaluation enclosed to the NRC letter dated September addition, Entergy Louisiana, Inc. or its designee is                  18, 1989. In required to notify the NRC of any action by equity investors or successors Entergy Louisiana, Inc. that may have an effect on                      in interest to the operation of the facility.
C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter applicable provisions of the Act and to the rules, regulationsI and is subject to all Commission now or hereafter in effect; and is subject                    and orders of the to the additional conditions specified or incorporated below:
: 1.        MaximumPower Level EOI is authorized to operate the facility at reactor core power levels not in excess of 3441 megawatts thermal (100% power) in accordance with the conditions specified herein.
: 2.        TechnicalSpecificatlonsl                        4 M-En-.r ~n,,entiin            Pt-,
The Technical Specifications contained In Appe.ndix A, as r._evised through
_..r...mp orent No. 18                                    endix A a                    t are hereby incorporated ;n the license. EDI shall operate faciliy in accordance with the Technical Specifications                                    the and the Environmental Protection Plan.
AMENDMENT NO. 1.4,16S,        10,"        7,      183
 
                      "d. Prior to completion of Phase          of the Waterford 3 startup test program, the licensee shall complete corrective actions related to the 23 NRC issues as identified in the LP&L-responses.
: 17.        Basemat The licensee shall comply with its commitments
                    'basemat cracking surveillance                          to perform a program and additional            .
confirmatory analyses of basemat structural described in its letter of February 25, 1985.      strength  as significant change to this program shall              Any be reviewed and approved by the NRC staff prior to Its implementation.
D.      The facility requires an exemption from certain requirements~of Appendices E and J to 10 CFR Part 50. These described in the Office of Nuclear Reactor            exemptions are Evaluation Report, Supplement No. 10 (Section      Regulation's Safety No. 8 (Section 6.2.6), respectively. These              6.1.2) and Supplement authorized by law and will not                      exemptions  are common defense and security and endanger        life or property or the are otherwise in the public interest. These exemptions are, therefore, to 10 CFR 50.12. With the granting of these hereby granted pursuant facility will operate, to the extent authorized      exemptions, the conformity with the application,                          herein, in as amended, the provisions      of the "Act, and the rules and regulations of the Commission.
E. EOI shall fully implement and maintain in effect all provisions of the Comrission-approved physical security, qualification, and safeguards contingency guard training and made pursuant to provisions of the Miscellaneous  plans including amendments Search Requirements revisions to 10 CFR 73.55              Amendments and 27822) and to the authority of 10 CFR 50.90            (51 FR 27817 and and The plans, which contain Safeguards Information 10 CFR 50.54(p).
CFR 73.21, are entitled: "Waterford Physical              protected under 10 revisions submitted through August 9, 1995;              Security Plan," with Training and Qualification Plan," with revisions      "Waterford Security October 30, 1992; and "Waterford Safeguards                submitted through revisions submitted through September zo,              Contingency  Plan," with 1995. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein.
F. E                                              h
              *etas ýothrwlse provided in the Technical Specificaiions SE*O. shall report any violations jFo--f
_t,,h e6iirements containl-ed in Section following manner. Initial notification2.Cshall      of this license in the hours to the NRC Operations Center via the                be made within 24 System with written follow-up within 30 days          Emergency  Notification procedures described in 10 CFR 50.73(b),                in  accordance  with the (c) and (e).
G. Entergy Louisiana, Inc. shall have and maintain financial protection of such type and in such amounts as the Commission accordance with Section 170 of the Atomic                      shall require in Energy Act of 1954, as amended, to cover public liability claims.
AMENDMENT NO. 134
 
                                                -9 H. This license is effective as the date of issuance and shall expire at midnight on December 18, 2024.
FOR THE NUCLEAR REGULATORY COMMISSION original signed by H.R. Denton                  I Harold R. Denton, Director Office of Nuclear Reactor Regulation Enclos ures:
1,      (DELETED)
: 2. Attachment 2
: 3. Appendix A (Technica 8pecif ation .            EG..N.1l7),.
: 4. Appendix B                  1PiZ-Jer&
: 5. Appendix C (AntitrustConditions Date of Issuance: March 16, 1985                                                                I AMENDMENT NO. 171
 
APP NDIX B TO FACILITY OPERAT NG LICENSE NO. NPF-38 WATERFORD STEAM ELECT IC STATION - UNIT NO. 3 ENTERGY LOU SIANA, INC.                          I DOCKET N  . 50-382 ENVIRONMENTAL P OTECTION PLAN (NONRADIO OGICAL)
MARCH 1 85 AMENDMENIf NO. 134
 
WATERFORD STEAM ELE ITRIC STATION - UNIT -NO. 3 ENVIR .ONMENTýjL PROTECTION PLAN (NON-RA IOLOGICAL)
TABLE            F CONTENTS Section                                                                                                                  Page 1.0  Objectives of the Environmental Pr'otection Plan. .....                                                            1-1 2.0  Environmental Protection Issues.                          .    .*.                          .
                                                                                  .                                        2-1 2.1  Aquatic Resources Issues,        ......                      *      *      .    ..                            2-1 SA 2.2  Terrestrial Resources Issues. . . .....                                          . . ....                          2-1 6      9 2.3  Cultural Resources Issues . ...                                                  . . ..                        . 2-1
* 6 3.0  Consistency Requirements .                      .                              S. . ...                        . 3-1 3.1  Plant Design and Operation . . . .                                              . . . ..                        . 3-1 3.2  Reporting Related to the NPDS Perm t and State Certification ,*                    ..        . .              6      0    *        #      6      4
* 3-Z 3.3. Changes Required for Compliance w th other Environmental Regulations .            .    ..
* 3-3 4.0  Environmental Conditions .              .    .    .  ....
* 4-I
* 6        6    6        9      6      .
4.1  "Unusual or Important Environmenta                  Events,
* 4-1 6      9              6      6      6 4.2 .Environmental Monitoring ...                    .
* 4-1
* 6      6              9      9      6 5.0 Administrative Procedures . .                        ..
* 5-1.
                                                                    *      &      6    6        6      6    *
" 5.1. Review and  Audit......
                                                                                                                        . 5-1 5.2  Records Retention... ...............                                                                            , 5-1 5.3  Changes in Environmental Protecti n Plan.                          S      I    *P      *
* 6
* 5-1 5.4  Plant Reporting Requirements .........
* 5-2 6
* 6    1      .*      .
 
1.0  Objectives of the E vironmental Protection Olan The Environmental Protec t on Plan (EPP)  is to provide for protection of environmental values durin  construction .and operation of the nuclear facility. The principal o ectives of the EPP are'as follows; (1) Verify that the plant    s operated in a environmentally acceptable manner, as established  y the FES-OL and other NRC environmental impact assessments.
(2)  Coordinate NRC requireme ts and maintain conslstencywith other Federal.
State, and local requir    nts for environmental protection.
(3)  Keep NRC informed of the  nvironmental effects of facility construction
    -and operation and of actlo s taken to control those effects.
Environmental concerns Identifie  in the FES-OL which relate to water quality matters and regulated by way of    e licensee's NPDES permit.
 
2.0  Environmenta    Protection Issues In the FES-OL date    September 1981, the staff considered the environmental impacts associated    ith the operation of Waterford Steam Electric Station Unit No. 3. The envi onmental resources which were evaluated, and the corresponding NRC sta f decisions regarding the protection of each resource are as follows!      \
2.1  Aquatic Resources I s.ues J
Effluent limitations and      nitoring requirements are contained in the NPDES Permit (No. LA 0007174) is ued by the U.S. Environmental Protection Agency, Region VI. The NRC will rely on EPA for regulatf&n of matters involving The protection of water quality and aquatic biota.
2.2  Terrestrial Resources I sues No terrestrial resources issu      were raised by the staff in the. FES-OL..
2.3  Cultural Resources Issues There are two archaeological sit s on the licensee's property which have been determined to be eligible for the National'Register of Historic Places.
Protection for these two sites wil      be provided through a Cultural Resources Protection Plan. NRC requirements    ith regard to the cultural resources issue are specified in Subsection 4.2.1 of his EPP.
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3.0  Consisten y Requirements 3.1  Plant Desig  and Operation The licensee may m ke changes in station design or operation or perform tests or experiments aff ting the environment, provided such activities do not involve an unreview d environmental question and d6 not involve a change in the EPP. Changes in plant design or operation or performance of tests or experiments which do ot affect the..environment are not subject to the requirements of this PP. Activities governed by Section 3.3-are not subject to the requirements o    this Section.
Before engaging In con truction or operation attiyitles which may significantly affect the environment, the licensee shall prepare and record an environmental evaluation of such acti ity. Activities are excluded from this requirement if all measurable nonra lological effects are confined to .the on'-site areas previously disturbed dur ng site preparation and plant constructinn.
When the evaluation indicates that such activity involves an unreviewed environ mental question, the lice see shall provide a written evaluation of such activity and obtain prior RC approval. When such activity involves a change
-  in the EPP, such activity      nd change to' the EPP may be implemented only in accordance with an appropr ate license amendment as set forth in Section 5.3 of this EPP.
A prnoosed change,    test or e periment shall be deemed to involve an unreviewed environmental question if it oncerns: (1) a matter which may result in a
  'ionificant s            increase in any aduere environmental impact previously evaluated 3-1
* in the FES_      environmental impact appraisals, or. in any decisions of the Atomic Safety and Licensing Board, or (2)a ýignificant change in effluents or power level    in accordance with 10 CFR Part S1.5(b)(2)] or (3) a matter, not previously r    iewed and evaluated in the documents specified in (1) of this Subsection, i w ch may have a significant adverse environmental impact.
The licensee shall mnintain records of' changes in facility design or operation and of tests and expe Iments carried out pursuant to this Subsection. These records thall include w itten evaluations which provide bases for the deter rmination that the change  'test, or e'x'p'eriment 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. The licensee shall include as part of its Annu 1 Environmental Operating Report (per Subsection 5.4.1) brief descriptions, a    lyses, interpretations, and evaluations of such changes, tests and exper    etts.
3.2 Reporting Related to the N DES Permit and State Certification Violations'of the NPDES.Pemit oi the State certification (pursuant to Section 401 of the Clean Water Act      shall be reported to the'NRC by providing copies of the reports req ired by the NPDES Permit or State Certification. The licensee shall a so 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 hey are submitted to.the permitting agency.
3-2
 
Changes to, or renewal    of, the NPDES Permit or the State certification shall be reported to the NRC within 30 days following the date the change or renewal is approved. If    permit or certification, in part or in its entirety, is appealed and s ayed, the NRC shall be notified within 30 days following the date the stay i    granted.
The N*RC shall be notified of ch nges to the effective NPDES Vermit proposed by the licensee by providing NRC    ith a copy of the proposed change at the same time it is submitted to the p      ittlng agency. The licensee shall provide the NRC a copy of ihe applict'iih for renewal of tFte NPDES Permit at the same time the application is s bitted to the permitting agency.
*- 3.3  Changes Required for Compliance wit    Other Environmental Regulations Changes in plant design or operation and pe formance of tests or experimehts which are required to achieve compliance wit    other Federal, State, and local environmental regulations'are not subject to t      requirements of Section 3.1.
3-3
 
4;0  Environ ental Conditions 4.1  Unusual o Important Environmental Events Any accurance o an unusual or important event that indicates or could result in significant e vironmental impact causally related to plant operation shall' be recorded and r ported to the NRC within 24 hours, followed by a written report per Subsect on 5.4.2. The following are examples:  excessive bird
* impaction events, o site plant or animal disease outbreaks, mortality or unusual occurrence o  any"ipecies pr6te6ted by the Endangered Species Act of 1973, fish kills, inc ease in nuisance organisms or conditions, and
* unanticipated or emerg ncy discharge of waste water or chemical substances.
* No routine monitoring-p ograms are required to imp~lemnent this condition.
4.2  Environmental Monit  ing 4.2.1  Cultural Resources  rotection Plan The licensee, the NRC and th  State Historic Preservation Officer (SHPO)  concur that the appropriate action' t be taken to negate any possible adverse effects to the Waterford 3 cultural re ources by the operation and maintenance activities of the licensee will    ý through a Cultural Resources Protection Plan that provides documentation of a    no adverse effect" determination.
This-Cultural Resources Protection P an was transmitted to the NRC and the SHPO by a letter from L. V. Maurin to G. W. nighton, dated April 15, 1983 for 4-1
 
-  final review and c  currence, after which the NRC submittod the plan to the
  "*Advisory Council on Historic Preservation (ACHP) for comment on September 28, 1983. ACHP conc rrence was received by the NRC,, on October 18, 1983 without change.
The Cultural Resource  Protection Plan, as referenced above, is the binding document to which the  icensee-will adhere and this Section of the EPP is considered fully satisfi d with no further action required.
4-2
 
5:0 Adminst ative Procedures 5.1  Review  Lnd Audit The licensee    hall provide for review and audlt of compliance with the Environmental    rotection Plan. The audits shall be conducted independently of.
* the individual or groups responsible for performing the specific activity.
A
* description of    he organizational structure utilized to achieve the independent review and audi    function and results of~the audit activities shall be maintained and n de available for inspection.
5.2  Records Reten ion Records and logs re ative to the environmental aspects of station operation shall be made and r tained in a manner covenlent for review and inspection.
These records and lo s shill be made available to the NRC on request.
  . Records of modfficatl ns to plant structures,      systems and components determined "to potentially affect    he continued protection of the environment shall be
  -    retained for the life    f the plant. All other records,  data and logs relating to this EPP shall be re ained for five years or, where applicable; in accordance with the requ rements of other agencies.
5.3  Changes                  il Protection Plan Recuest for a change in the 'nvironmental      Protection plan shall include an assessment of the environmer ta    iT2act of the proposed change and a supporting 5-1
 
justification.  ]mplementation nf such changes in 'the EPP shall not commence prior to NRC a )royal of the proposed changes in the form of a license amend ment incorpora Ing the appropriate revision to the Environmental Protection Plan.
"    "  5.4    Plant Repo  ing Requirements 5.4.1    Routine Re orts An Annual Environ    ntal Operating Report describing implefientation of this EPP for the previous ye r shall be submitted to the NRC prior to May 1 of each year. The initial      port shall be submitted prior to May of the year fol lowina issuance of the oper ting license. The period or-the first report shall 'begin with the date of iss ance of the operating license.
The report shall incl de summaries and analyses of -the results of the environ mental protection acti ities required by Subsection 4.2 of this Environmental Protection Plan for the report period, including a comparison with any related predperational studies, operational controls (as appropriate),
and previous
.- '  non-radiological environ ental monitoring reports, and an assessment of the observed impacts of the p ant operation' on the environment.
If  harmful effects or evidence of trends towa d irreversible damage to the environmental are observed, the licensee sha I provide a detailed analysis of the-data and a proposed course of mitigati    actions.
5-2
 
The Annual En ironmental Operating Report shall also include:
.          (a)  A list of EPP noncompliances and the corrective actions taken to remedy th (b)  A list of a 1 changes In station design or operation,.tests, experiments made in acco dance with Subsection 3.1 which involved a potentially significant u reviewed environmental questioný.
(c)  A list of nonro tine reports submitted in accordance with Subsection 5.4.2.      \          .      ...
In the event that some  esults are not available by the report due date, the report shall be submitt    noting and, explaining the missing results. The missing results shall be    ubmitted as soon as posaible in'a supplementary' report.
5.4.2. Nonroutine Reports A written report shall be su    itted to the NRC within 30 days of occurrence of any event described in Sectio    4.1 of this Plan. The reports shall (a)
  -      describe, analyze, and evaluat    the event, including extent and magnitude of "the impact and plant operating    haracteristics, (b) describe the probable
* "cause          of the event, (c) indicate the action taken to correct the reported event, (d) indicate the correctiv    action taken to preclude repetition of the event and to prevent similar occurr nces involving similar components or' systems, and (e)  indicate the agencies notified and their preliminary S responses,.
5-3
 
' Events ýeportable -under t is subsection which also require reports to other Federal,  State or local a encies shall be reported in accordance with those reporting requirements in lieu of the requirements of this subsection. The NRC shall be provided a co y of such report at the. same time it is submitted to the other agency.
Si/
o*/
1.
5-4
                                                          /}}

Latest revision as of 06:50, 26 March 2020

License Amendment Requests Proposed Deletion of Appendix B, Environmental Protection Plan from Facility Operating License
ML023180512
Person / Time
Site: Grand Gulf, River Bend, Waterford  Entergy icon.png
Issue date: 11/06/2002
From: Gerald Williams
Entergy Nuclear South
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CNRO-2002/00005
Download: ML023180512 (72)
v • d • e


Text

Entergy Nuclear South 1340 Echelon Parkway E tegyJackson, gwllil601 Tel MS 39213 368 5670

@entergy corn George A. Williams Vice President Operations Support CNRO-2002/00005 November 6, 2002 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 LDC number (2002-053)

River Bend Station, Unit 1 Docket No. 50-458 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License Amendment Requests Proposed Deletion of Appendix B, Environmental Protection Plan (Non-Radiological) from the Facility Operating License

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests the following amendments 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 proposed amendments will delete the content of the Appendix B, Environmental Protection Plan (Non-Radiological) (EPP) for each unit. In addition, the appropriate sections of each FOL referring to the EPP will be modified to delete reference to the EPPs. This amendment request is administrative in nature and is intended to relieve Entergy of the burden of certain environmental reports and delete obsolete program information.

All environmental conditions imposed by these appendixes have been completed. All other requirements for non-radiological monitoring are governed by other Federal, State, or local permits and regulations. There is no impact on the continued safety or in protection of the environment for the GGNS, RBS, and Waterford 3 units by deleting Appendix B of the FOLs.

The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards consideration. The bases for these determinations are included in attachment 1.

A

CNRO-2002/00005 Page 2 of 3 The proposed change includes no new commitments. This amendment request is similar to that granted to Duke Power for its McGuire Nuclear Station Units 1 & 2 (TAC Nos. M90860 and M90861) and Catawba Nuclear Station Units 1 & 2 (Amendment Nos. 149 and 143) in 1996.

Entergy requests approval of the proposed amendment within one year of this application.

Once approved, the amendment shall be implemented within 60 days. Although this request is neither exigent nor emergency, your prompt review is requested.

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 6, 2002.

Sincerely, GAW/WBB/bal attachments:

1. Analysis of Proposed Facility Operating License Change
2. Proposed Facility Operating License Changes (mark-up) - Grand Gulf Nuclear Station, Unit 1
3. Proposed Facility Operating License Changes (mark-up) - River Bend Station
4. Proposed Facility Operating License Changes (mark-up) - Waterford Steam Electric Station, Unit 3 cc: (See Next Page)

CNRO-2002/00005 Page 3 of 3 cc: Mr. C. G. Anderson (ANO)

Mr. J. L. Blount,(ECH)

Mr. W.R. Campbell (ECH)

Mr. W. A. Eaton (GGNS)

Mr. P. D. Hinnenkamp (RBS)

Mr. E.W. Merschoff Mr. N. S. Reynolds Mr. L. Jager Smith (Wise, Carter)

Mr. G. J. Taylor (ECH)

Mr. J. E. Venable (W-3)

Mr. G. A. Williams (ECH)

Mr. M. K. Webb, Project Manager (RBS) W-3 NRC Resident Inspectors Office Office of Nuclear Reactor Regulation W-MSB4-266 U. S. Nuclear Regulatory Commission Mail Stop OWFN/7D1 Louisiana DEQ/Surveillance Division Washington, DC 20555 P. O. Box 82215 Baton Rouge, LA 70884-2445 Mr. N. Kalyanam, Project Manager (W-3)

Office of Nuclear Reactor Regulation American Nuclear Insurers U. S. Nuclear Regulatory Commission ATTN: Library Mail Stop OWFN/7D1 Town Center Suite 300S Washington, DC 20555 WestSouth 29th MainCT Hartford, Street 06107-2445 Mr. D. H. Jaffe, Project Manager (GGNS)

Office of Nuclear Reactor Regulation Mr. Prosanta Chowdhury U. S. Nuclear Regulatory Commission Program Manager-Surveillance Division Mail Stop OWFN/7D1 Louisiana Dept. of Environmental Quality Washington, DC 20555 Office of Radiological EP and Response P. O. Box 82215 RBS NRC Senior Resident Inspector Baton Rouge, LA 70884-221 P. O. Box 1050 St. Francisville, LA 70775

Attachment I CNRO-2002100005 Analysis of Proposed Facility Operating License Change to CNRO-2002/005 Page 1 of 14

1.0 DESCRIPTION

This letter is a request to amend Facility Operating Licenses (FOLs) NPF-29 for Grand Gulf Nuclear Station, Unit 1 (GGNS), NPF-47 for River Bend Station, Unit 1 (RBS), and NPF-38 for Waterford Steam Electric Station, Unit 3 (Waterford 3).

The proposed changes will revise the FOLs to delete the content of the Appendix B, Environmental Protection Plan (Non-Radiological) (EPP) for each unit. In addition, the appropriate sections of each FOL referring to the EPP will be modified to delete that reference.

This amendment request is administrative in nature because all environmental conditions imposed have been completed or are covered by Federal, State, or local permits and regulations. This change will relieve Entergy Operations inc. (Entergy) of the burden of certain environmental reports and delete obsolete program information.

2.0 PROPOSED CHANGE

These proposed amendments delete Appendix B, Environmental Protection Plan (Non-Radiological) and references to Appendix B from the FOLs and Technical Specifications for GGNS, RBS, and Waterford 3. Details of the proposed changes to the FOLs are provided separately for each of the facilities as follows:

GGNS Delete the references to Appendix B on Page 2, Section 1 H Page 4, Section 2 C(2)

Page 17, List of Attachments Delete the Appendix B, Environmental Protection Plan, in its entirety (13 pages)

RBS Delete the phrase "subject to the conditions for protection of the environment set forth herein" Page 2, Section 1 H Delete references to Appendix B on Page 3, Section 2 C(2)

Page 7, Section 2 E Page 7, List of Attachments Delete Appendix B, Environmental Protection Plan, in its entirety to CNRO-2002/005 Page 2 of 14 Waterford3 Delete references to Appendix B on Page 2, Section 1 H Page 4, Section 2 C 2 Page 8, Section 2 F Page 9, List of Attachments Delete Appendix B, Environmental Protection Plan, in its entirety In summary, these proposed amendments delete Appendix B, Environmental Protection Plan (Non-Radiological) and references to Appendix B from the Facility Operating Licenses for GGNS, RBS, and Waterford 3.

3.0 BACKGROUND

The EPP was established during initial plant operations to monitor terrestrial issues such as potential erosion along transmission lines, cooling tower drift, impact on vegetation, noise, and cultural resources issues. The regulatory basis for the establishment of the EPP was 10 CFR 50.36b. This section requires that any obligations in the environmental area identified by the Nuclear Regulatory Commission (NRC) during their evaluation in the NRC record of decision be included in an attachment to the license. The attachment is incorporated in, and made a part of the license. The conditions are derived from information contained in the environmental report and the supplement to the environmental report submitted as required by 10 CFR 51.50 and 51.53. The attachment is only required when conditions are identified in the record. In this case, these monitoring programs have been completed and the results have demonstrated that the environmental impacts are negligible. Although these monitoring programs have since been discontinued, the sites are still required to submit an annual report to the NRC.

The licensees are bound by other Federal (i.e., the Environmental Protection Agency (EPA)),

State, and local agencies to comply with environmental protection regulations. The NRC relies on these agencies to regulate licensees in environmental matters. No environmental protection requirements established by other agencies are being reduced by removal of Appendix B from the FOLs.

4.0 TECHNICAL ANALYSIS

The analyses for the proposed changes are addressed separately for each licensed plant.

Justification for the deletion of each applicable section is provided below.

GGNS Section 1.0 - Objectives of the Environmental Protection Plan This section contains the objectives of the EPP which is to provide for protection of environmental values during construction and operation of the nuclear facility. These objectives to CNRO-2002/005 Page 3 of 14 are met through the National Pollutant Discharge Elimination System (NPDES) Permit, and other Federal, State and local requirements for environmental protection.

Section 2.0 - Environmental Protection Issues This section contains the environmental protection issues. Each issue will be discussed separately.

Section 2.1 - Aquatic Issues This section of the EPP does not impose any requirements or identify any aquatic issues at GGNS. The NRC relies on the State regulatory agency (Mississippi Department of Environmental Quality) to regulate water quality matters. The EPA has oversight of State programs. This is accomplished through compliance with the limitations and conditions imposed by the GGNS NPDES permit.

Section 2.2 - Terrestrial Issues The EPP imposes monitoring requirements on two terrestrial issues. These issues are: 1) potential erosion along transmission line corridors following their construction and 2) potential impact of cooling tower drift on vegetation surrounding the site.

The transmission line survey program was completed and discontinued in 1988 as reported in Section 2.1 of each GGNS Annual Environmental Operating Report submitted to the NRC.

The cooling tower drift program has also been discontinued. The final sentence of Section 4.2.2 of the EPP states that the program was discontinued.

Section 3.0 - Consistency Requirements This section consists of Sections 3.1, 3.2, and 3.3 as discussed below.

Section 3.1 - Plant Design and Operation The EPP allows changes to be made in plant design or operation or performance of tests or experiments affecting the environment provided that they do not involve an unreviewed environmental question or a change to the EPP. Activities are excluded from this requirement if all measurable nonradiological effects are confined to on-site areas previously disturbed during site preparation and plant construction. This requirement is duplicated in the Entergy 10 CFR 50.59 Review Program procedure. This procedure requires an environmental screening. Full Environmental Evaluations are performed for those changes that do not meet the screening criteria. These changes are evaluated against all environmental requirements.

This section also requires that the licensee maintain a record of changes in plant design or operation and of tests and experiments carried out pursuant to this section. This requirement is also duplicated in the Entergy 10 CFR 50.59 Review Program procedure.

to CNRO-2002/005 Page 4 of 14 Section 3.2 - Reportingq Related to the NPDES Permits and State Certification This section requires that violations, changes and additions of/to the NPDES permit or the State Certification shall be reported to the NRC. The NRC relies on the State regulatory agency to regulate these matters. All reporting to the NRC will be done in accordance with 10 CFR 50.72 "Immediate notification requirements for operating nuclear power reactors." Information related to environmental permits will be available on site for NRC review.

Section 3.3 - Changes Required for Compliance with Other Environmental Regulations This section exempts those changes required to achieve compliance with other Federal, State, or local environmental regulations from the requirements of Section 3.1. An exemption from this section will no longer be necessary after implementation of this change.

Section 4.0 - Environmental Conditions This section consists of Section 4.1 and 4.2 discussed below.

Section 4.1 - Unusual or Important Environmental Events This section requires that any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to station operation shall be recorded and reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed by a written report within 30 days.

GGNS is already required to notify the NRC in accordance with 10 CFR 50.72. Follow-up written reports are submitted to state agencies based on State regulatory requirements. The written reports are initiated through the GGNS environmental reporting procedure. Therefore, sending an additional copy of the written report to the NRC is an unnecessary reporting burden.

Entergy will, of course, provide any of this information at the request of the NRC staff.

Section 4.2 - Environmental Monitoring For GGNS, environmental monitoring in the areas of Erosion Control and in Cooling Tower Drift were required. As discussed above, there are no longer any active monitoring requirements for these issues. The Erosion Control Inspection was included in semi-annual surveys until stabilization of soil and vegetation (i.e., ground cover establishment) was achieved. This has been achieved, and is no longer reported in the annual report to the NRC. The Cooling Tower Drift Program measured cooling tower drift deposition. The last sentence of Section 4.2.2 states that the program was terminated.

Section 5.0 -- Administrative Procedures This section consists of Sections 5.1, 5.2, and 5.3 discussed below.

to CNRO-2002/005 Page 5 of 14 Section 5.1 - Review and Audit This section requires review and audit of compliance with the EPP. There are no longer any active EPP monitoring programs to audit. Therefore, reviews and audits of the EPP are no longer necessary.

Section 5.2 - Records Retention This section requires retention of records relative to the environmental aspects of plant operation and modifications determined to potentially affect the continued protection of the environment. Evaluation records involving unreviewed environmental questions (environmental evaluations) are required to be documented by corporate environmental administrative procedures.

Section 5.3 - Chanqes in the Environmental Protection Plan This section requires NRC approval prior to implementing changes in the EPP. With the deletion of the other sections of the EPP, this section would no longer apply.

Section 5.4 - Station Reportinc Requirements This section consists of Sections 5.4.1 and 5.4.2 discussed below.

Section 5.4.1 - Routine Reports This section requires an annual environmental operating report be submitted to the NRC prior to May 1 of each year. The report includes summaries/analyses of the activities required by Section 4.2, a list of EPP noncompliances and the corrective actions taken to remedy them, a list of all changes in the station design or operation, tests and experiments made in accordance with Section 3.1 involving potentially significant unreviewed environmental issues, and a list of nonroutine reports submitted in accordance with Section 5.4.2. The programs that had been required by Section 4.2 have been discontinued. Environmental noncompliances are reported as required by 10 CFR 50.72 and, along with the associated corrective actions, are included in the Entergy Corrective Action Program. Design changes are included in the Entergy 10 CFR 50.59 Review Program and are reported to the staff under the guidelines of 10 CFR 50.59.

Deletion of the EPP would negate the need to transmit an annual environmental operating report to the NRC with this information.

As the pertinent information of the report is submitted to the NRC under separate programs, this section may be deleted.

Section 5.4.2 - Nonroutine Reports A written report to the NRC is required within 30 days of occurrence of nonroutine events. The NRC shall be provided with a copy of reports to other Federal, State, or local agencies. The NRC is already notified verbally of unusual or important environmental events per the requirements of 10 CFR 50.72. Nonroutine reports, including those involving unusual or important environmental events, are submitted to the appropriate regulatory agency per to CNRO-2002/005 Page 6 of 14 applicable requirements. Since the reports are already required by other agencies and the NRC is verbally notified, sending an additional copy of a written report to the NRC is an unnecessary reporting burden.

RBS Section 1.0 - Obiective of the Environmental Protection Plan This section contains the objectives of the EPP which is to provide for protection of environmental values during construction and operation of the nuclear facility. These objectives are met through the NPDES Permit, and other Federal, State, and local requirements for environmental protection.

Section 2.0 - Environmental Protection Issues This section consists of Sections 2.1, 2.2, and 2.3 discussed below.

Section 2.1 - Aquatic Issues This section of the EPP does not impose any requirements or identify any aquatic issues at RBS. The NRC relies on the State regulatory agency (Louisiana Department of Environmental Quality) to regulate water quality matters. The EPA has oversight of State programs. This is accomplished through compliance with the limitations and conditions imposed by the RBS Louisiana Pollutant Discharge Elimination System (LPDES) permit.

Section 2.2 - Terrestrial Issues The EPP imposes monitoring requirements on potential impact of cooling tower drift on vegetation surrounding the site. This monitoring program was required during the first three years of operation. No adverse impacts were noted during this monitoring period and the program was discontinued. There are no longer any active monitoring requirements associated with this section.

Section 2.3 - Noise Issues The EPP imposes monitoring requirements on operational noise levels in the site vicinity. This requirement was met during the first year of operation. No adverse impacts were noted during this monitoring period and the program was discontinued. There are no longer any active monitoring requirements associated with this section.

Section 3.0 - Consistency Requirements This section consists of Sections 3.1, 3.2, and 3.3 discussed below Section 3.1 - Plant Design and Operation The EPP allows changes to be made in plant design or operation or performance of tests or experiments affecting the environment provided that they do not involve an unreviewed to CNRO-2002/005 Page 7 of 14 environmental question or a change to the EPP. Activities are excluded from this requirement if all measurable nonradiological effects are confined to on-site areas previously disturbed during site preparation and plant construction. This requirement is duplicated in the Entergy 10 CFR 50.59 Review Program procedure. This procedure requires an environmental screening. Full Environmental Evaluations are performed for those changes that do not meet the screening criteria. These changes are evaluated against all environmental requirements.

This section also requires that the licensee maintain record of changes in plant design or operation and of tests and experiments carried out pursuant to this section. This requirement is also duplicated in the Entergy 10 CFR 50.59 Review Program procedure.

Section 3.2 - Reportingq Related to the NPDES Permits and State Certification This section requires that violations, changes and additions of/to the NPDES permit or the State Certification shall be reported to the NRC. The NRC relies on the State regulatory agency to regulate these matters. All reporting to the NRC will be done in accordance with 10 CFR 50.72.

Information related to environmental permits will be available on site for NRC review.

Section 3.3 - Changes Required for Compliance with Other Environmental Regulations This section exempts those changes required to achieve compliance with other Federal, State, or local environmental regulations from the requirements of Section 3.1. An exemption from this section will no longer be necessary after implementation of this change.

Section 4.0 - Environmental Conditions This section consists of Sections 4.1 and 4.2 discussed below.

Section 4.1 - Unusual or Important Environmental Events This section requires that any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to station operation shall be recorded and reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed by a written report within 30 days.

RBS is required to notify the NRC in accordance with 10 CFR 50.72. In addition, the site is already required by State and Federal Agencies to report such incidences. Therefore, sending an additional copy of the written report to the NRC is an unnecessary reporting burden.

Entergy will, of course, provide any of this information at the request of the NRC staff.

Section 4.2 - Environmental Monitoring This section consists of Sections 4.2.1 Aquatic Monitoring, 4.2.2 Terrestrial Monitoring and 4.2.3 Noise Monitoring discussed below.

For RBS, no Aquatic Monitoring was deemed necessary because the NRC relies on the EPA and the State of Louisiana for aquatic monitoring requirements. Environmental monitoring in the areas of Terrestrial Monitoring and Noise Monitoring were required. As discussed above, both areas no longer contain any active monitoring requirements. Section 4.2 may be deleted in its entirety.

to CNRO-2002/005 Page 8 of 14 Section 5.0 - Administrative Procedures This section consists of Sections 5.1, 5.2, 5.3, and 5.4 discussed below.

Section 5.1 - Review and Audit This section requires review and audit of compliance with the EPP. There are no longer any active EPP monitoring programs to audit. Therefore, reviews and audits of the EPP are no longer necessary.

Section 5.2 - Records Retention This section requires retention of records relative to the environmental aspects of plant operation and modifications determined to potentially affect the continued protection of the environment. Evaluation records involving unreviewed environmental questions (environmental evaluations) are required to be documented by corporate environmental administrative procedures.

Section 5.3 - Changes in the Environmental Protection Plan This section requires NRC approval prior to implementing changes in the EPP. With the deletion of the other sections of the EPP, this section no longer applies.

Section 5.4 - Plant Reporting Requirements This section consists of Sections 5.4.1 and 5.4.2 discussed below.

Section 5.4.1 - Routine Reports. This section requires an annual environmental operating report be submitted to the NRC within 90 days following each anniversary of issuance of the operating license. The report includes summaries/analyses of the activities required by Section 4.2, a list of EPP noncompliances and the corrective actions taken to remedy them, a list of all changes in the station design or operation, tests, and experiments made in accordance with Section 3.1 involving potentially significant unreviewed environmental issues, and a list of nonroutine reports submitted in accordance with Section 5.4.2. Section 4.2 has been discontinued. Environmental noncompliances are reported as required by 10 CFR 50.72 and, along with the associated corrective actions, are included in the Entergy Corrective Action Program. Design changes are included in the Entergy 10 CFR 50.59 review program and are reported to the staff under the guidelines of 10 CFR 50.59. Deletion of the EPP would negate the need to transmit an annual report to the NRC with this information.

Section 5.4.2 - Nonroutine Reports A written report to the NRC is required within 30 days of occurrence of nonroutine events. The NRC shall be provided with a copy of reports to other Federal, State, or local agencies. The NRC is already notified verbally of unusual or important environmental events as required by 10 CFR 50.72. Nonroutine reports, including those involving unusual or important environmental events, are submitted to the appropriate regulatory agency per applicable requirements. Since to CNRO-2002/005 Page 9 of 14 the reports are already required by other agencies and the NRC is verbally notified, sending an additional copy of a written report to the NRC is an unnecessary reporting burden.

Waterford 3 Section 1.0 - Obiectives of the Environmental Protection Plan This section contains 'the objectives of the EPP which is to provide for protection of environmental values during construction and operation of the nuclear facility. These objectives are met through the NPDES Permit, and other Federal, State and local requirements for environmental protection. This section may be deleted based on meeting these objectives through these other means.

Section 2.0 - Environmental Protection Issues This section contains the environmental protection issues. Each issue will be discussed separately.

Section 2.1 - Aquatic Resources Issues This section of the EPP does not impose any requirements or identify any aquatic issues at Waterford 3. The NRC relies on the State regulatory agency (Louisiana Department of Environmental Quality) to regulate water quality matters. The EPA has oversight of State programs. This is accomplished through compliance with the limitations and conditions imposed by the Waterford 3 LPDES permit.

Section 2.2 - Terrestrial Resources Issues No terrestrial issues were identified for Waterford 3. Therefore, there were no monitoring requirements past or present associated with terrestrial issues.

Section 2.3 - Cultural Resources Issues The EPP requires the protection of two archaeological sites though the development of a Cultural Resources Protection Plan. This plan has been developed and is now in place. The plan is the binding document to which Waterford 3 will adhere. This requirement is fully satisfied with no further action required.

Section 3.0 - Consistency Requirements This section consists of Sections 3.1, 3.2 and 3.3 discussed below.

Section 3.1 - Plant Desiqn and Operation The EPP allows changes to be made in plant design or operation or performance of tests or experiments affecting the environment provided that they do not involve an unreviewed environmental question or a change to the EPP. Activities are excluded from this requirement if all measurable nonradiological effects are confined to on-site areas previously disturbed during to CNRO-2002/005 Page 10 of 14 site preparation and plant construction. This requirement is duplicated in the Entergy 10 CFR 50.59 review program. This procedure requires an environmental screening. Full Environmental Evaluations are performed for those changes that do not meet the screening criteria. These changes are evaluated against all environmental requirements.

This section also requires that the licensee maintain record of changes in plant design or operation and of tests and experiments carried out pursuant to this section. This requirement is duplicated in the Entergy 10 CFR 50.59 review progdrai Section 3.2 - Reporting Related to the NPDES Permits and State Certification This section requires that changes and additions of/to the NPDES permit or the State Certification shall be reported to the NRC. The NRC relies on the State regulatory agency to regulate these matters. All reporting to the NRC will be done in accordance with 10 CFR 50.72.

Information related to environmental permits will be available on site for NRC review.

Section 3.3 - Changes Required for Compliance with Other Environmental Requlations This section exempts those changes required to achieve compliance with other Federal, State or local environmental regulations from the requirements of Section 3.1. An exemption from this section will no longer be necessary after implementation of this change.

Section 4.0 - Environmental Conditions This section consists of Sections 4.1 and 4.2 discussed below.

Section 4.1 - Unusual or Important Environmental Events This section requires that any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to station operation shall be recorded and reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed by a written report within 30 days.

There is already a requirement to notify the NRC verbally as required by 10 CFR 50.72. Follow up written reports are submitted based on State regulatory requirements. Therefore, sending an additional copy of the written report to the NRC is an unnecessary reporting burden.

Entergy will provide any of this information when requested by the NRC staff.

Section 4.2 - Environmental Monitoring For Waterford 3, no Aquatic or Terrestrial Monitoring was deemed necessary. The NRC relies on the EPA and the State of Louisiana for aquatic monitoring requirements. Operations and maintenance activities are controlled through a Cultural Resources Protection Plan to negate any possible adverse effects to Waterford 3 cultural resources. This plan is the binding document to which the licensee will adhere. The Advisory Council on Historic Preservation (ACHP) concurrence of the plan was received by the NRC on October 18. 1983.

Section 5.0 - Administrative Procedures This section consists of Sections 5.1, 5.2, 5.3 and 5.4 discussed below.

Attachment I to CNRO-20021005 Page 11 of 14 Section 5.1 - Review and Audit This section requires review and audit of compliance with the EPP. There are no active monitoring EPP programs to audit. Therefore, reviews and audits of the EPP are no longer necessary.

Section 5.2 - Records Retention This section requires retention of records relative to the environmental aspects of plant operation and modifications determined to potentially affect the continued protection of the environment. Evaluation records involving unreviewed environmental questions (environmental evaluations) are required to be documented by corporate environmental administrative procedures.

Section 5.3 - Chanqies in the Environmental Protection Plan This section requires NRC approval prior to implementing changes in the EPP. With the deletion of the other sections of the EPP, this section no longer applies.

Section 5.4 - Plant Reporting Requirements This section consists of Sections 5.4.1 and 5.4.2 discussed below.

Section 5.4.1 - Routine Reports This section requires an annual environmental operating report be submitted to the NRC within 90 days following each anniversary of issuance of the operating license. The report includes summaries/analyses of the activities required by Section 4.2, a list of EPP noncompliances and the corrective actions taken to remedy them, a list of all changes in the station design or operation, tests, and experiments made in accordance with Section 3.1 involving potentially significant unreviewed environmental issues, and a list of nonroutine reports submitted in accordance with Section 5.4.2. Section 4.2 has been discontinued. Environmental noncompliances are reported as required by 10 CFR 50.72 and, along with the associated corrective actions, are included in the Entergy Corrective Action Program. Design changes are included in the Entergy 10 CFR 50.59 review program and are reported to the staff under the guidelines of 10 CFR 50.59. Deletion of the EPP would negate the need to transmit an annual report to the NRC with this information.

Section 5.4.2 - Nonroutine Reports A written report to the NRC is required within 30 days of occurrence of nonroutine events. The NRC shall be provided with a copy of reports to other Federal, State, or local agencies. The NRC is already notified verbally of unusual or important environmental events per the requirements of 10 CFR 50.72. Nonroutine reports, including those involving unusual or important environmental events, are submitted to the appropriate regulatory agency per applicable requirements. Since the reports are already required by other agencies and the to CNRO-2002/005 Page 12 of 14 NRC is verbally notified, sending an additional copy of a written report to the NRC is an unnecessary reporting burden.

5.0 REGULATORY ANALYSIS

5.1 Applicable Regulatory Reguirements/Criteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. Entergy has determined that the proposed changes do not require any exemptions or relief from any regulatory requirements, other than the FOLs, and do not affect conformance with any General Design Criteria (GDC) differently than described in the Updated Final Safety Analysis Report (UFSAR). The EPP was established during initial plant operations to monitor terrestrial issues such as potential erosion along transmission lines, cooling tower drift impact on vegetation, noise, and cultural resources issues. The regulatory basis for the establishment of the EPP was 10 CFR 50.36b. This section requires that any obligations in the environmental area identified by the NRC during their evaluation in the NRC record of decision be included in an attachment to the license. The attachment is incorporated in, and made a part of the license. The conditions are derived from information contained in the environmental report and the supplement to the environmental report submitted as required by 10 CFR 51.50 and 51.53. The attachment is only required when conditions are identified in the record. In this case, these monitoring programs have been completed and the results have demonstrated that the environmental impacts are negligible.

The licensees are bound by other Federal (i.e., the EPA), State, and local agencies to comply with environmental protection regulations. The NRC relies on these agencies to regulate the licensee in environmental matters. None of the environmental protection requirements established by other agencies are being reduced by removal of Appendix B from the FOLs.

The EPPs can therefore be deleted from the FOLs.

5.2 No Significant Hazards Consideration The proposed amendments will delete the content of the Appendix B, Environmental Protection Plan (Non-Radiological) from the Facility Operating License (FOL) for each unit. In addition, the appropriate sections of each FOL referring to the Environmental Protection Plan (EPP) will be modified to remove that reference. This amendment request is administrative in nature and is intended to relieve Entergy Operations, inc. (Entergy) of the burden of certain environmental reports.

Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

to CNRO-2002/005 Page 13 of 14 The EPPs are concerned with monitoring the effect that plant operations have on the environment for the purpose of protecting the environment and has no affect on any accident postulated in the Updated Final Safety Analysis Report (UFSAR). Accident probabilities or consequences are not affected in any way by the environmental monitoring and reporting required by the EPPs. The deletion of Appendix B of the FOL will not impact the design or operation of any plant system or component. The NRC relies on other Federal, State, and local agencies for environmental protection regulation. No environmental protection requirements established by these other agencies are being reduced by this license amendment. The programs and reporting requirements of the EPPs do not affect initiation or mitigation of any accidents previously analyzed.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

This license amendment is administrative in nature. Environmental monitoring and reporting has no affect on accident initiation. The deletion of the EPPs will not produce any changes to the design or operation of the plant. There will be no effect on the types and amounts of any effluent that will be released.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

This change is administrative in nature. The change in annual reporting requirements has no impact on margin of safety. Environmental Evaluations will still be performed, where necessary, on changes to plant design or operations to assess the effect on environmental protection.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Entergy concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.3 Environmental Considerations The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be to CNRO-2002/005 Page 14 of 14 released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 PRECEDENCE This amendment request is similar to that granted to Duke Power for its McGuire Nuclear Station Units 1 & 2 (TAC Nos. M90860 and M90861) and Catawba Nuclear Station Units 1 & 2 (Amendment Nos. 149 and 143) in 1996.

Attachment 2 CNRO-2002/00005 Markup of Current Facility Operating License Grand Gulf Nuclear Station

E. Entergy Operations, Inc. (EOI), is technically qualified to engage in the activities authorized by this operating license in accordance with the Commission's regulations set forth in 10 CFR Chapter 1; F. The licensees have satisfied the applicable provisions of 10 CFR Part 140, *Financial Protection Requirements and Indemnity Agreements," of the Commission's regulations; G. The issuance of this license will not be inimical to the common defense and security or to the health and safety of the public; H. After weighing the environmental, economic, technical, and other benefits of the facility against environmental and other costs and considering available alternatives, thissuance of Facility O eatiýn cans No. NPF-29 pla *t~ahpd t Ane*"

Ap~tpAJ9 s 1-in ac-co-rdance with 10 C ~Par-t 51 of the Commission's egulations and all applicable requirements have been satisfied; and I. The receipt, possession, and use of source, by-product and special nuclear material as authorized by this license will be in accordance with the Commission's regulations in 10 CFR Parts 30, 40, and 70.

2. Based on the foregoing findings regarding this facility and pursuant to Commission Order CLI-84-19, dated October 25, 19B4, License NPF-13, as amended, is superseded by this Facility Operating License NPF-29 which is hereby issued to Entergy Operations, Inc., Entergy Mississippi, Inc., I System Energy Resources, Inc., and South Mississippi Electric Power Association to read as follows:

'A. This license applies to the Grand Gulf Nuclear Station (GGNS),

Unit 1, a boiling water nuclear reactor and associated equipment (the facility), owned by System Energy Resources, Inc., and South Mississippi Electric Power Association and operated by Entergy Operations, Inc. The facility is located in Claiborne County, Mississippi, and is described in the licensees' "Final Safety Analysis Report,' as supplemented and amended, and in the licensees' Environmental Report, as supplemented and amended.

D. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses:

(1) Entergy Operations, Inc. (EOI) pursuant to Section'103 of the Act and 10 CFR Part 50, to possess, use, and operate the facility at the designated location in Claiborne County, Mississippi, in accordance with the procedures and limitations set forth in this license; (2) System Energy Resources, Inc., and South Mississippi Electric Power Association to possess, but not operate, the facility at the designated location in Claiborne County, Mississippi, in accordance with the procedures and limitations set forth in this license; Amendment No. 6;,125

(b) SERI is required to notify the NRC in writing prior to any change in (i) the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized financial transactions, (ii) the GGNS Unit 2 operating agreement, (iii) the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19," 1988 attached to Amendment No. 54.

In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.

C. The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level Entergy Operations, Inc. is authorized to operate the facility at reactor core power levels not in excess of 3898 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised thrugh ýA:mendmnt No. 156 are ereby incorporated into this license. Entergy Operations, Inc. shall operate the facility in accordance with the Technical Specifications 4 Amendment 1-4-8., a-5-, 156

F, EOI shall report any violations of the requirements contained in Section 2, Items C.(1), C.(4) through C.(38) of this license within-twenty-four (24) hours. Initial notification shall be made in accordance with the provisions of 10 CFR 50.72 with written follow-up in accordance vith the procedures described in 10 CFR 50.73(b), (c), and We).

G. The licensees shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, an amended, to cover public :iability claims.

H, This license is effective as of the date of issuance and shall "exepire at midnight on November 1, 2024.

rOP THE NUCLEAR REGULATORY CObMISSION ORICINAL SIGNED BY:

Harold R. Denton, Director Office of Nuclear Reactor Regulation Attachments:

1. Attachments I and 2
2. Appendix A - Technical Specifications (NUREG-0934). ,
5. - Eni7ý Bp~n l 0"z j,_'*QeJ
4. Appendix C - Ant*itrust ConditionsI Date of Imsuance: November 1, 19A4 Amendment No. &6, 137 1

APP!1NDIX TO FACILITY L1ICENSE NO. MPF-29 11 41D GULFJNULElAR STATION ENTERGY OPýRATIONS, INC.

DOCKET NO. 50-416 ENVIRONMENTAL PROTECTION PLAN OCTOCE 1984 Amendment~tNo. 65

GRAND GULFNNUCLEAR STATION

"*NIT 1 ENVIRONMENTAL PROTECTION PLAN (NON-RADI ILOGICAL)

TABLE OF \CONlTENTS Section Page 1.0 Objectives of the Envlronmental Pro ection Plan ........ 1 2.0 Environmental Protection Issues. . . .. ............ ... 2-1 2.1 Aquatic Is&ues . .. .. .... .. .. . . . . . . . . . . 2-1 2.2 Terrestrial Issues ............... . . . . 21 3.0 Consistency Requirements ....... . ......... 3-1 3.1 Plant Design and Operation ..... 3-...............

3.2 Reporting Related to the NPDES Permits and State Certification . . . . . . . . . . . . . . . . . . . . . . . 3-2 3.3 Changes Required for Compliance with pther Environmental Regulation ..... ........................ 3-3 4.0 Environmental Conditions ...... ... .... . 4-1 4.1 Unusual or Important Environmental Evints. .... ........... 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

\2

'. 1.0 OBJECTIVES OFrTHE ENVIRONHENTAL PROTECTION PLAN The Environmental Prolection Plan (EPP) is to provide for protettion of environmental values daring construction and operation of the nuclear facility.

The principal objectives\of the EPP are as follows:

(1) Verify that the Plant\I operated in an enviraonentally acceptable mannar, as established by the tES and other NRC environmental impact assessments.

(2) Coordinate NRC requirement and maintain consistency with other Federal, State and local requirements\for environmental protection, (3) Keep NRC informed of the envir nmental effects of facility construction and operation and of action tak to control those effects.

\FES which relate to water quality tatters are regulated by way of the \(PDES permit.

I 1-1 .nt No. 27 1

2.0 ENVIRONMENTAL PRTECTION ISSUFS In the FES-OL dated Sep\amber 1981, the staff considered the environmental impacts associated with ihe operation of the Grand Gulf Nuclear Station, Certain environmental iss aes were Identified which re*uired study or license conditions to resolve env$tronmenta1 concerns and to assure adequate protection of the environment.

2.1 AQUatic Issuet No aquatic issues were ident fied in the FES-OL. EffluInt limitations And monitoring requirements are c ntained In the effective NPOES permit issued by the Mississippi Departenl of atural Resources. The NRC will rely on this agency for regulation of these atters as they Involve water quality and aquatic biota, 2.2 Terrestrial Issues (1) Potential erosion along trans Ission line-corridors during and immediately following their construction.

(2) Potential Impact of cooling towe drift on vegetation surrounding the sites. In the FES the staff reco nded an aerial remote sensing program.

The applicant opted to do a mort d tailed surveillance program.

NRC requirem4nts with regard to the terrost ial issues are specified in Subsection 4.2 of this EPP.

(L) 2-1 Aiendment No. 96

" 3.0 CORSISTEI Y REQUIREMfNTS 3.1 Plant Ctesin and Operation The licensee may 4ake changes in plant design or operation or perform tests or experiments affect ng the environment provided such changes, tests or experi ments do not invol an unreviewed environmental question, and do not involye a change in the Env ohmental Protection Plan.4 Changes In plant design or

  • operation and perfo rnce of tests or experiments which do not affect the environment are not s bject to the requirements of this EPP. Activities governed by Section 3. are not subject to the requirements of this section.
  • Before engaging in additional construction or operational activities which may affect the environment, e licensee shall prepare and record an environmental evaluation of such activi .* When the evaluation indicates that such activity involves an unreviewad envi onmental question, the licensee shall provide a

written evaluation of such tivities and obtain prior approval from the Director, Office of Nuclear actor Regulation. When such activity involves a change in the Environnental P otection Plan, such activity and change to the Environmental Protection Plan ay be implemented only in accordance with an appropriate license amendment a set forth in Section 5.3.

A proposed change, test or experi ent shall be deemed to involve an unreviewed environmental question if it conce ns (1) a matter which may result in a sig nificant increase in any adverse environmental impact previously evaluated in the final environmental statement (F\S) 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 A\

This provision does not relieve the lice see of the requirements of 10 CFR 50.59, "Activities are excluded from this requirem t if all measurable environmental effects are confined to on-site areas previo sly disturbed during site pre paration and plant construction. 2 3-1 Q

Board; or (2) a significant change in effluents or power. level; or (3) a matter not iievioushy reviewed and- evaluated in the documents specified

.in (1) Of this Subsac ion, which may have a significant adverse

  • environtenta) impact.

The licensee shall ma)t..an 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 ex eriment does not InVolve an unreviewed environmental question nor constitute decrease In the effectiveness of this EPP to meet -he

  • objectives specified In ýection 1.0. The licensee shall include as part of the
  • Annual Environmental Ope ating Report (per Subsection 5.4.1) brief descriptions.

analyses, interpretations and evaluations of such changes, tests and experiments.

3.2 Reporting Related to NPDES Permits and Statt Certification Violations of the NPDE5 palt or the State certification (pursuant to Section 401 of the Clean Wat r Act, respectively) shall be reported to the NRC by submittal of copies of th reports required by the NPOES permit or certifi cation.

Changes and additions to the N1 ES permit or the State certification shall be reported to the NRC within 30 d ys following the date the change Is approved.

"- If a permft or certification, In\ part or in Its entirmty, is appealed and "stayed, the HRC shall be notifie within 30 days following the date the stay is granted.

The NRC Shall be notified of change proposed by the licensee to the effective NPMES permit by providing NRC with oft\copy the proposed change at the Same time it is submitted to the permittink agency. The notification of a licensee Initiated change shall Include a copy *1 the requested revision submitted to the Permitting agency. The licensee shf11_ provide the NRC with a copy of its application for renewal of the HPOES per It at the same time the application is submitted to the permitting agency.

3-2

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

3-3

i

  • 4.0 ERVIRO CONDITIONS 4.1 Unusual or I ortant Environmental Events Any occurrence of a unusual or important event that indicates or could result in significant envi onmental impact causally'related to station operation shall be recorded an promptly reported to the NRC vithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone, telegraph or facsimil transmissions followed by a written report per Sub section 5.4.2. The Ilowing are examples: excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or unusual occurrence of any species protected the Endangered Species Act of 1973, fish kills, increase in nuisance or anisms or conditions and unanticipated or emergency discharge oi waste wate or chemical substances.

No routine monitoring pro rams are required to implement this condition.

4.2 Environmental Monitor\nq Deviations from required mo itoring programs will not be a violation of license requirements if saumples are accidentally spilled or contaminated, or if samples are unattainable ýue to hazardous conditions, seasonal unavailability, or malfunction of equipment.

t 4.2.1 Erosion Control Inspect on SMaintenance and monitoring of th\ transmission line corridor rights-of-way will be conducted as a part of the normal transmission line inspections from the GGNS to the Franklin in EHV Switch\ng Station, to the Baxter Wilson Steam ELectric Station Switchyard, and to the Port Gibson Substation. These inspections, conducted by aerial surv ys and walking patrols at periodic intervals, include monitoring for eros on or vehicular damage caused by right of-way encroachment by hunters and logge. Problem areas will be identified 4-1

by the aerial s\rveys, and walking patrols will be directed to the problem areas to evaluate the extent of the problem to be corrected, The Erosion Cont ol Inspection Program shall begin upon conmencement of normal transmission line inspection procedures. Semi-annual surveys shall continue until stabilizatin of soil and vegetation (i.e., ground cover establishment) is achieved.

A summary of the fi Id Inspection program and any procedures Implemented to control abnormal er sion conditions associated with transmission line maintenance actlviti s shall be reported in the Annual Environmntal Operation Report in accordance ith Subsection 5.4.1. Field logs indicating locations of erosion damage and me surs taken to rectify erosion problem areas and estimation of the time to achieve effective stabilization will be maintained and available for inspectio for a period of five years. Results reported shall contain Information enc passing but not limited to inspection date, estimated size of erosion problem a @a, probable cause of erosion, type of stabilization program, and date of effe tive stabilization, as appropriate.

4.2.2 Cool Tower ina Drift P 7a Seven sampling sites were Oti\izo to measure cooling tower

" drift-deposition.

At least two of the sampling s tes had duplicate sapling devices. Six of the seven sites were located in are s where maximm salt deposition was predicted.

These areas were extrapolated fr the Bechtel Salt Deposition Model developed for the GGIS Final Environmental eport. The seventh sampling site was a control site located south of Ra nd, Mississippi. An eighth offsit. control site was added in 1985 in Port Gibs on,Mississippi.

Fallout samples were collected on a q arterly basis and analyzed for ton specific constituents. The details o, the sampling proceddre and chemical

(---*

4-2 Amendment No. #J, 96

analysis were submitted to the NIC's Environmental Engfleerlfn Branch for review and approval prior to plant operation above 5% power. An evaluation of the results of the Cooling Tower Or1't Program Indicated that the operation of the GGNS cooling tower produced no s$tltistically significant effect upon the salt deposition rate for those chemical species evaluated. lhe cooling tower drift program was therefore terminated, V

4,-3 - Amendment No. 96

53.0 ADHINIST ATIVE PROCEDURES 5.1 Review an Audit The licensee sh 11 provide for review and audit of compliance with the Envirocnental Pr tection Plan. The audits fhall be conducted Independently of the individual o groups responsible for performing the specific activity. A description of th organization structure utilized to achieve the independent review and audit f nction and results of the audit activities shall be maintained and made available for inspection.

5.2 Records Retenti Records and logs ralat've to the environmental aspects of plant operation shall be made and rota ned in a manner convenient for review and inspection.

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

Records of modifications to plant structures, systems and components determined to potentially affect th continued protection of the environment shall be retained for the life of he plant. All other records, data and logs relating to this EPP shall be reta ned for five years or, where applicable, in accordance with the requirements of ther agencies.

5.3 Changes in Environme txl Protection Plan Requests for changes in th Environmental Pvotectlon Plan shall include an assessment of the environmw tel impact of the proposed change and a supporting justification. Implementati n of such changes in the EPP shall not commence prior to NRC approval of the roposed changes In the form of a licensee amendment incorporating the a ropriate revision to the Environmental Protection Plan.

5-1

5.4 Station Re~artino Reoulrements

.'5.4.1 Routin Reports An Annual Envi onmental Operating Report describing Implementation of this EPP for the previo s year shall be submitted to the NRC prior to May 1 of each year. The init Ial report shall be submitted prior to Hay I of the year follow Ing issuance of the operating license. The period of the first report shall begin with the d to of issuance of the operating license for the first operational unit.

The report shall nelude summaries and analyses of the results of the invlrotaental prot ction activities required by Subsection 4.2 of this Environ mental Protection ]an for the report period, including a comparison wlth preoperational stud is, operational controls (ms appropriate),

and previous non-radiological en tronmental monitoring reports, and an assessment of the observed impacts of he station operation on the invironment.

If havmful effects or evidence f trends towards irreversible damage to the environment are observed, the lic nsee shill provide a detailed analysis of the data and a proposed course of ac ion to alleviate the problem. I/

the Annual Environment I Operating Report shall also Include:

(a) A list of EPP nonc apliances and the corrective actions taken to remedy them.

Wb) A list of all chan s In station design or operation, tests, and experiments made in accordance with Subsection 3.1 which involved potentially signifi ant unreviewed environmental issue.

(c) A list of nonroutine reports submitted in accordance with Subsection 5,4.2.

In the event that some res Its are not available by the report due date, the report shall be Submitted oting and explaining the missing results.

The missing data shall be submi ted as soon as possible in a supplementary report.

5-2

5.4.2 Honroutine Reports

.*A written repo t shall be submitted to the NRC within 30 days of occurrence of a nonroutine e nt. The report shall (a) describe, analyze, and evaluate the event, includin extent and magnitude of these Impact and plant operating characteristics (b) describe the probable cause of the event, (c) indicate the action take to correct the reported event, (d) indicate the corrective action taken to reclude repetition of the qvent and to prevent similar occurrences invo ving similar components or systems, and (a) indicate the agencies notifie 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 requirem nts in lieu of the requirements of this subsection. The HRC shall be provid d with a copy of each report at the same time it is submitted to the oth r agency.

Attachment 3 CNRO-2002/00005 Markup of Current Facility Operating License River Bend Station

F. Entergy Gulf States, Inc. and EOI have satisfied the applicable provisions of 10 CFR Part 140, Financial Protection Requirements and Indemnity Agreements,' of the Commission's regulations; G. The Issuance of this license will not be inimical to the common detense and security or to the health and safety of the public; H. After weighing the environmental, economic, lechnical, and other benefits of the facility against environmental and other costs and considering availabl altomabAse Issuance of Faolt 0 ratin UcenseNo. NPF-47,

  • J.... ... ... .. . . vi 'on Use 6VJ is In e c rla ne wt .

CFR

.0 Part 51 of the Commission's regulatons and all applicable requirements have been satisfied; and

1. The receipt, possession, and use of source, byproduct and special nuclear material as authorized by this license will be In accordance with the Commission's*

regulations in 10 CFR Parts 30, 40 and 70.

2. Based on the foregoing findings and approval by the Nuclear Regulatory Commission at a meeting on November 15, 1985, the Ucense for Fuel Loading and Low Power Testing.

License No. NPF-40, Issued on August 29, 1985, Is superseded by Facility Operating License NPF-47 hereby Issued to EOI and Entergy Gulf Slates, Inc. (the licensees), to read as follows:

A. This license applies to the River Bend Station, Unit 1, a boiling water nuclear reactor and associated equlprihent, owned by Enlergy Gulf States, Inc. and operated by EOI. The facility is located approximately 2 miles east of the Mississippi River in West Feliciana Parish, Louisiana, approximately 2.7 miles southeast of St. Francisville, Louisiana and approximately 18 miles northwest of the city limits of Baton Rouge, Louisiana, and is described in the "Final Safety Analysis Report, as supplemented and amended, and in the Environmental Report-Operating License Stage, as supplemented and amended.

B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses:

(1) Entergy Gulf States, Inc. to possess the facility at the designated location in West Feliciana Pariah, Louisiana, In accordance with the procedures and limitations set forth in this license; (2) E01, pursuant to Section 103 of the Act and 10 CFR Part 50, to possess, use and operate the facility at the above designated location in accordance with the procedures and limitations set forth in this license; Amendment No. 9.9.8.

101

.3-(3) EOI, pursuant to the Act and 10 CFR Part 70, to receive, possess and to use at any time special nuclear material as reactor fuel, in accordance with the hmitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended, (4) E0I, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required:

(5) E0I, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restnction to chemical or physical form. for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) EOI, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and Is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect: and is subjec-to the additional conditions specified or incorporated below:

(1) Maximum Power Level EOI is authorized to operate the facility at reactor core power levels not in excess of 3039 megawatts thermal (100% rated power) in accordance with the conditions specified herein. The items identified in Attachment 1 to this license shall be completed as specified. Attachment 1 Is hereby incorporated into this license.

(2) Technical Specifications The Technical Specifications contained in A pendix as revised through Amend ent No. 704 are hereby incorporated In the license. EOI shall peratethe ai4 in accordance with the Technical Specifications

')

Amendment No. 4 Q.  ! 14

D. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to the provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "River Bend Station Security Plan," with revisions submitted through May 25, 1995; "River Bend Station Guard Training and Qualification Plan," with revisions submitted through December 3, 1993; and "River Bend station Contingency Plan," with revisions submitted through August 17, 1990.

Changes made in accordance with 10'CFR 73.55 shall be implemented in accordance with the schedule set forth therein.

E. Except as otherwise provided in the Technical Specifications(ox rm' t rt-, EOI shall report any violationlg-of the requirements contained in Section 2.C of this license in the following manner: initial notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC Operations Center via the Emergency Notification System with written followup within thirty days in accordance with the procedures described in 10 CFR 50.73(b),

(c) and (e).

F. The licensee shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Enezgy Act of 1954, as amended, to cover public liability claims.

G. This license is effective as of the date of issuance and shall expire at midnight on August 29, 2025.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosures:

1. AtLachments 1-5
2. Appendix A - Technical Specifications (NUREG-_17
3. Appendix B - .. tTTUEýL.---Plan tm-,-tJJ
4. Appendix C - Antitrust Conditions Date of Issuance: November 20, 1985 Revised: December 16, 1993 Amendment No. .0, 979,as, 119

APPENDIX B TO FACILITY OP \RATING LICENSE NO. NPF-47 R1I~ R BEND STATION NIT 1 ENTERGY OP RATIONS, INC.

DOCKET *.O 50-458 RECEIVED..

AuC . 01 1995.:

S* * -. . : ' .

ENVIRONMENTAL PROTECT N PLAN (NONRADIOLOGICAL)

Amendment No. Z, 79

" RIVE'R>END STATION

\UNIT I

ENVIRONMENTAI\ PROTECTION PLAN (NONRADI'LOGICAL)

Section.O TABLE OF CO\TENTS aq 1.0 Objectives of the Environmental Protecti n Plan ............................. .

2.0 Environmental Protection Issues .............. .... ........ 2-1 2.1 Aquatic Issues 2-1 2.2 Terrestrial Issues ....................................... 2-1 2.3 N oise Issues ............................................... ......................................................... 2-1 30 Consistency Requirements................. 3-1 3 1 Plant D esign and O peration ................................................................................ 3-1 32 Reporting Related to the NPDES Permit an State Certifications ........................ 3-2

. 3.3 Changes Required for Compliance with Othe Environmental Regulations .......... 3-3 4.0 Environm ental 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 R eview and A udit ..................................... . . .... .................................... 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 e Environmental Protection Plan The Environmental Protect\on 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 op rated in an environmentally acceptable manner, as established by the Final En ronmental Statement - Operating Licensing Stage (FES OL) and other NRC environm Mal impact assessments,

  • (2) Coordinate NRC requirements a maintain consistency with other Federal, State and local requirements for environment I protection.

(3) Keep NRC informed of the environmen I effects of facility construction and operation and of actions taken to control those effe ts.

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

... .*-1-1

20 Environmental P lection Issues In the FES-O1L dated Januar' 1985, the staff considered the environmental impacts associated with the operation of the RivJ r Bend Station Unit 1. Certain environmental issues were identified which required stu or license conditions to resolve environmental concerns and to assure adequate protection o the environment.

2.1 Aquatic Issues No specific aquatic issues we identified by the NRC staff in the FES-OL.

2.2 Terrestrial Issues Detection of possible changes i or damage to local flora caused by drift deposition due to the operation of the River Bend Stat on Cooling Towers. (FES-OL Section 5.14.1) 23 Noise Issues Adverse community reaction is exp cted 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 i Section 4.2.3. (FES-OL Section 5.A4) 2-1

3.0 Consistenc Requirehients 3.1 Plant Design and Operation The licensee may ma e changes in station design or operation or perform tests or experiments affecting the environ nt provided such activities do not involve an unreviewed environmental question and do not in olve a change in the EPP*. Changes in station design or operation or performance of tests o experiments which do not affect the environment are not subject to the requirements of this EP . Activities governed by Section 3.3 are not subject to the requirements of this Sec ion.

Before engaging in additi\ nal construction or operational activities which may significantly affect the environment, th licensee shall prepare and record an environmental evaluation of such activity. Activities ar excluded from this requirement if all measurable nonradiological environmental effects are nfined to the on-site areas previously disturbed during site preparation and plant const uction. When the evaluation indicates that such activity involves an unreviewed environment I question, the licensee shall provide a written evaluation of such activity and obtain prior NRC pproval. When such activity involves a change in the EPP, such activity and change to th EPP may be implemented only in accordance with an appropriate license amendmen as set forth in Section 5.3 of this EPP, This provision does not relie(,'e the licensee of the requirements of 10 CFR 50.59.

3-1

A proposed change, te2t or 6xperiment shall be deemed to involve an uhreviewed environmental question f it concerns: (1) a matter which may result in a significant increase in any adverse environmen al impact previously evaluated in the FES-OL, environmental impact appraisals, or in any de i ions of the Atomic Safety and Licensing Board; or (2) a significant change in effluents or pov r 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 r cords of changes in facility design or operation and of tests and

  • experiments' carried out purs nt to this Subsection. These records shall include written evaluations which provide bas for the determination that the change, test, or experiment does not involve an unreviewed environmental question or constitute a decrease in the effectiveness of this EPP to mee the objectives specified in Section 1.0. The licensee ihall include as part of the Annual Envi onmental Operating Report (per Subsection 5.4.1) brief

"* descriptions, analyses, interpreatib ns, and evaluations of such changes, tests and

  • ' experiments.

3.2 Reporting Related to th NPDES Permit and State Certification The licensee shall notify the NRC of pr posed revisions to the effective NPDES Permit if the "proposedrevision is a significant chang of waste stream flow rate, concentration, or point of discharge. This shall be done by providrin NRC with a copy of the proposed revision at the same 3-2

time it is submitted to the permiti g agency. The licensee shall provide the NRC a copy of the application for renewal of the NP ES Permit at the same time the application is submitted to the permitting agency.

Changes to, or renewals of, the NPý ES Permits or the State certification shall be reported to the NRC within 30 days following tht date the change or renewal is approved. If a permit or certification, in part or in its entirety, appealed and stayed, the NRC shall be notified within 30 days following the date the stay is ranted.

3.3 Changes Required for Corn liance with Other Environmental Regulations Changes in plant design or operation an performance of tests or experiments which are required to achieve compliance with othe \Federal, State, and local environmental regulations are not subject to the requirements of Sect] n 3A.1 3-3

"4.0 Environmental Conditions 4.1 Unusua~or Important Environmental Events Any occurrence of an nusual or important event that indicates or could result in significant environmental impact ausally related to plant operation shall be recorded and reported to the NRC 'Within24 hours fol owed by a written report per Subsection 5.4.2. The following are examples: excessive bir impaction events, onsite plant or animal disease outbreaks, mortality or unusual occurrence of ny species protected by the Endangered Species Act of 1973, fish kills, increase in nuisance rganisms or conditions, and unanticipated or emergency discharge of waste water or chemical ubstances.

No routine monitoring progra s are required to implement this condition.

4.2 Environmental Monit ring 4.2.1 Aquatic Monitoring The certifications and permits require under the Clean Water Act provide mechanisms for protecting water quality and, indirectly, a uatic biota. The NRC will rely on the decisions made by the U.S. Environmental Protection Agen and the State of Louisiana underthe authority of the Clean Water Act for any requirements for uatic monitoring.

4-1

4.2.2 Terrellrial Monitoring Vegetative commu ities of the site and vicinity within 1 Kilometer of the cooling towers in all directions shall be a rially 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 Septe ber or early October. Monitoring shall include a program of low altitude color Infrared p otography. The scale for full coverage shall be adequate to enable identification of vegetativ damage over relatively small areas of terrain, Some circumstances may warrant inspection of photographs discerning individual trees. Such scale should be rti ns a b adequate to resolve impact d features. Photographs duin flnptaken during plant operation shall be t

compared with pre-operation I photographs (baseline) to ascertain changes in vegetation.

Photographic interpretations siall be verified by ground inspection surveys to confirm areas of stress and non-stress. This pr gram shall require aerial photographic monitoring to begin 2 years preceding initiation of coo Iing tower operation and during the following first and third years. If adverse effects are obs~erved, the NRC will require the applicant to repeat the study in additional years and to performrexaminations of vegetation, both on and off site, to Sdetermine the extent of the damage. Such studies are necessary to determine the need for any corrective action to mitigate the\mpacts.

A report shall be submitted as part ofthe\; each aerial photographic monitoring period. The report shall contaii 4-2

I.

description of the ýrogtam, results and interpretative analysis of environmental impacts.

Results reported shall contain information encompassing but not limited to the following:

sampling date, tim, of day, film types, and one (1) set of resultant color transparencies encompassing an a a within approximately a one Kilometer (1 Kin) radius of the Station's normal cooling tower 4.2.3 Noise Monit ring A noise monitoring progr 'm shall be conducted in the site vicinity during the first full year following the onset of com ercial operation of River Bend Station.

The purpose of the

. program is to characterize t e Station's operational noise levels, to compare these levels with ambient levels recorded duri g 1972 and 1980 surveys, and to evaluate the community impact, ifany, of cooling towerfan blade tonal noise and incremental broadband noise.

The monitoring program will inclu e measurements of sound levels at the nearest residence in each of six 45" (forty-five degree) 'rectional sectors from the Northwest through the South (i.e., residences RI, R4, and R7 sho n on Figure 5.22 FES-OL, and throe additional residences in the compass sectors Ea Southeast, and South. At each location daytime and nighttime (midnight to 4:00 a m ) measur ments will be made once in Wrnter and Summer to S *obtain statistical indicators (Lo0 L, L5 Leq) fo a weighted decibel levels. Additionally one-third octave band analysis will be performed at ea h location on each visit.

4-3

Results of these surveys will be evalu fed and included in the ahnual environmental monitoring report. If noise Impacts are identified during the Summer or Winter surveys a discussion of proposed mitigative melsures will be included In the monitoring report.

\C 4-4

5.0 Admini trative Procedures 5.1 Review and Audit The licensee shall pr vide for review and audit of compliance with the EPP, The audits shall be conducted indepe dently of the individual or groups responsible for performing the specific activity. A descriptio of the organization structure utilized to achieve the independent review and audit function and esults of the audit activities shall be maintained and made available for inspection.

5.2 Records Reaen ion "Records and logs relative to th environmental aspects of station operation shall be made and retained in a manner convenientxfor review and inspection. These records and logs shall be made available to NRC on reque t.

Records of modifications to station tructures, systems and components determined to potentially affect the continued prote ion of the environment shall be retained for the life of the station. All other records, data and log relating to this EPP shall be retained for five years or, where applicable, in accordance with the equirements of other agencies.

5-1 i i i i i i iI

o 3Changes Envirnmental Protection Plan Reqluests 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 l*(ior to NRC approval of the proposed changes in the form of a license amendment incorpo.ting the appropriate revision to the EPP.

5.4 Plant. Reporting ReJuirements 5.4.1 Routine Reports An Annual Environmental Operating Report describing implementation of this EPP for the previous year shall be submitted wit in 90 days following each anniversary of 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\lyses 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, operatio al controls (as appropriate),

and previous nonradiological environmental monitoring rep s, and an assessment of the observed impacts of the plant operation on the environment. If ha ful effects or evidence of trends toward irreversible damage to the environment are obser~ad, the licensee 1 shall provide a detailed analysis of the data and a proposed course of mitigý,ing action.

5-2

The Annual Environmental Operating Report shall also include:

(1) A list of EPP nonco pliances 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 Subs ction 3.1 which involved a potentially significant unreviewed environmental questio\

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

In the event that some results ar\ not available by the report due date, the report shall be submitted noting and explaining t le missing results, The missing results shall be submitted as

  • soon as possible in a supplement ry 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, ýnalyze, and evaluate the event, including extent and magnitude of the impact, and plant ope ating characteristics, (b) describe the probable cause

of the event, (c) indicate the action taken o correct the reported event, (d) indicate the corrective 5-3

action taken to preclude repetition of the event and to pr6ven' similar occurrences involving similar components or systems, ar*d (e) indicate the agencies notified and their preliminary respcnses.

Events reportable under this subs ction 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, T e NRC shall be provided with a copy of such report at the same time it is submitted to the othe\ agency.

I 5-4

Attachment 4 CNRO-2002/00005 Markup of Current Facility Operating License Waterford Steam Electric Station - Unit No. 3

E. ' Entergy Operations, Inc. (EOI) is technically qualified to engage in the activities authorized by this operating license In accordance with the Commission's regulations set forth in 10 CFR Chapter I; F. Entergy Louisiana, Inc. has satisfied the applicable provisions of 10 CFR Part 140, "Financial Protection Requirements and Indemnity Agreements", of the Commission's regulations; G. The issuance of this license will not be inimical to the common defense and security or to the health and safety of the public; H. After weighing the environmental, economic, technical, and other benefits of the facility against environmental and other costs, and after considering available alternatives, the issuance of the Facility Operating License No. NPF-38. 2>.jt I. the - ,nditkr" !a, protection of the enoAronment set forth in thI En'i.ronmmnt*l P.....tie. Plan a..he. e. Appendix B--- is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied; and

1. The receipt, possession, and use of source, byproduct, and special nuclear material as authorized by this license will be in accordance with the Commission's regulations in 10 CFR Part 30, 40 and 70, except that an exemption to the provisions of 10 CFR 70.24 is granted as described in Supplement No. 8 to the Safety Evaluation Report. This exemption is authorized under 10 CFR 70.24(d) and will not endanger life or property or the common defense and security and is otherwise In the public Interest.
2. Pursuant to approval by the Nuclear Regulatory Commission at a meeting on March 15, 1985, the license for fuel loading and low power testing, License No, NPF-26, issued on December 18, 1984, is superseded by Facility Operating License No. NPF-38 hereby issued to Entergy Louisiana, inc. and Entergy Operations, Inc. to read as follows:

A. This license applies to the Waterford Steam Electric Station, Unit 3, a pressurized water reactor and associated equipment (the facility), owned by Entergy Louisiana, Inc. The facility is located on the Entergy Louisiana, Inc. site in St. Charles Parish, Louisiana and Is described in the Entergy Louisiana, Inc. Final Safety Analysis Report as amended, and the Environmental Report as amended, AMENDMENT NO, 134

or indirectly any control over (i) the facility, (ii) power or energy produced by the facility, or (iii) the licensee of the facility.

Further, any rights acquired under this authorization may be exercised compliance with and subject to the requirements and only in restrictions of this operating license, the Atomic Energy Act of 1954.

as amended, and the NRC's regulations. For purposes of this condition, limitations of 10 CFR 50.81, as now in effect and as the they may be subsequently amended, are fully applicable to the equity and any successors in interest to the equity investors, investors as long as the license for the facility remains in effect.

(b) Entergy Louisiana, Inc. (or its designee) to notify the prior to any change in (i) the terms or conditions of NRC in writing any agreements executed as part of the above authorized lease transactions, (iH)any facility operating agreement involving financial a licensee that is in effect now or will be In effect in the future, property insurance coverages for the facility, that or (iii) the existing alter the representations and conditions, set forth would materially in the staff's Safety Evaluation enclosed to the NRC letter dated September addition, Entergy Louisiana, Inc. or its designee is 18, 1989. In required to notify the NRC of any action by equity investors or successors Entergy Louisiana, Inc. that may have an effect on in interest to the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter applicable provisions of the Act and to the rules, regulationsI and is subject to all Commission now or hereafter in effect; and is subject and orders of the to the additional conditions specified or incorporated below:

1. MaximumPower Level EOI is authorized to operate the facility at reactor core power levels not in excess of 3441 megawatts thermal (100% power) in accordance with the conditions specified herein.
2. TechnicalSpecificatlonsl 4 M-En-.r ~n,,entiin Pt-,

The Technical Specifications contained In Appe.ndix A, as r._evised through

_..r...mp orent No. 18 endix A a t are hereby incorporated ;n the license. EDI shall operate faciliy in accordance with the Technical Specifications the and the Environmental Protection Plan.

AMENDMENT NO. 1.4,16S, 10," 7, 183

"d. Prior to completion of Phase of the Waterford 3 startup test program, the licensee shall complete corrective actions related to the 23 NRC issues as identified in the LP&L-responses.

17. Basemat The licensee shall comply with its commitments

'basemat cracking surveillance to perform a program and additional .

confirmatory analyses of basemat structural described in its letter of February 25, 1985. strength as significant change to this program shall Any be reviewed and approved by the NRC staff prior to Its implementation.

D. The facility requires an exemption from certain requirements~of Appendices E and J to 10 CFR Part 50. These described in the Office of Nuclear Reactor exemptions are Evaluation Report, Supplement No. 10 (Section Regulation's Safety No. 8 (Section 6.2.6), respectively. These 6.1.2) and Supplement authorized by law and will not exemptions are common defense and security and endanger life or property or the are otherwise in the public interest. These exemptions are, therefore, to 10 CFR 50.12. With the granting of these hereby granted pursuant facility will operate, to the extent authorized exemptions, the conformity with the application, herein, in as amended, the provisions of the "Act, and the rules and regulations of the Commission.

E. EOI shall fully implement and maintain in effect all provisions of the Comrission-approved physical security, qualification, and safeguards contingency guard training and made pursuant to provisions of the Miscellaneous plans including amendments Search Requirements revisions to 10 CFR 73.55 Amendments and 27822) and to the authority of 10 CFR 50.90 (51 FR 27817 and and The plans, which contain Safeguards Information 10 CFR 50.54(p).

CFR 73.21, are entitled: "Waterford Physical protected under 10 revisions submitted through August 9, 1995; Security Plan," with Training and Qualification Plan," with revisions "Waterford Security October 30, 1992; and "Waterford Safeguards submitted through revisions submitted through September zo, Contingency Plan," with 1995. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein.

F. E h

  • etas ýothrwlse provided in the Technical Specificaiions SE*O. shall report any violations jFo--f

_t,,h e6iirements containl-ed in Section following manner. Initial notification2.Cshall of this license in the hours to the NRC Operations Center via the be made within 24 System with written follow-up within 30 days Emergency Notification procedures described in 10 CFR 50.73(b), in accordance with the (c) and (e).

G. Entergy Louisiana, Inc. shall have and maintain financial protection of such type and in such amounts as the Commission accordance with Section 170 of the Atomic shall require in Energy Act of 1954, as amended, to cover public liability claims.

AMENDMENT NO. 134

-9 H. This license is effective as the date of issuance and shall expire at midnight on December 18, 2024.

FOR THE NUCLEAR REGULATORY COMMISSION original signed by H.R. Denton I Harold R. Denton, Director Office of Nuclear Reactor Regulation Enclos ures:

1, (DELETED)

2. Attachment 2
3. Appendix A (Technica 8pecif ation . EG..N.1l7),.
4. Appendix B 1PiZ-Jer&
5. Appendix C (AntitrustConditions Date of Issuance: March 16, 1985 I AMENDMENT NO. 171

APP NDIX B TO FACILITY OPERAT NG LICENSE NO. NPF-38 WATERFORD STEAM ELECT IC STATION - UNIT NO. 3 ENTERGY LOU SIANA, INC. I DOCKET N . 50-382 ENVIRONMENTAL P OTECTION PLAN (NONRADIO OGICAL)

MARCH 1 85 AMENDMENIf NO. 134

WATERFORD STEAM ELE ITRIC STATION - UNIT -NO. 3 ENVIR .ONMENTýjL PROTECTION PLAN (NON-RA IOLOGICAL)

TABLE F CONTENTS Section Page 1.0 Objectives of the Environmental Pr'otection Plan. ..... 1-1 2.0 Environmental Protection Issues. . .*. .

. 2-1 2.1 Aquatic Resources Issues, ...... * * . .. 2-1 SA 2.2 Terrestrial Resources Issues. . . ..... . . .... 2-1 6 9 2.3 Cultural Resources Issues . ... . . .. . 2-1

  • 6 3.0 Consistency Requirements . . S. . ... . 3-1 3.1 Plant Design and Operation . . . . . . . .. . 3-1 3.2 Reporting Related to the NPDS Perm t and State Certification ,* .. . . 6 0 * # 6 4
  • 3-Z 3.3. Changes Required for Compliance w th other Environmental Regulations . . ..
  • 3-3 4.0 Environmental Conditions . . . . ....
  • 4-I
  • 6 6 6 9 6 .

4.1 "Unusual or Important Environmenta Events,

  • 4-1 6 9 6 6 6 4.2 .Environmental Monitoring ... .
  • 4-1
  • 6 6 9 9 6 5.0 Administrative Procedures . . ..
  • 5-1.
  • & 6 6 6 6 *

" 5.1. Review and Audit......

. 5-1 5.2 Records Retention... ............... , 5-1 5.3 Changes in Environmental Protecti n Plan. S I *P *

  • 6
  • 5-1 5.4 Plant Reporting Requirements .........
  • 5-2 6
  • 6 1 .* .

1.0 Objectives of the E vironmental Protection Olan The Environmental Protec t on Plan (EPP) is to provide for protection of environmental values durin construction .and operation of the nuclear facility. The principal o ectives of the EPP are'as follows; (1) Verify that the plant s operated in a environmentally acceptable manner, as established y the FES-OL and other NRC environmental impact assessments.

(2) Coordinate NRC requireme ts and maintain conslstencywith other Federal.

State, and local requir nts for environmental protection.

(3) Keep NRC informed of the nvironmental effects of facility construction

-and operation and of actlo s taken to control those effects.

Environmental concerns Identifie in the FES-OL which relate to water quality matters and regulated by way of e licensee's NPDES permit.

2.0 Environmenta Protection Issues In the FES-OL date September 1981, the staff considered the environmental impacts associated ith the operation of Waterford Steam Electric Station Unit No. 3. The envi onmental resources which were evaluated, and the corresponding NRC sta f decisions regarding the protection of each resource are as follows! \

2.1 Aquatic Resources I s.ues J

Effluent limitations and nitoring requirements are contained in the NPDES Permit (No. LA 0007174) is ued by the U.S. Environmental Protection Agency, Region VI. The NRC will rely on EPA for regulatf&n of matters involving The protection of water quality and aquatic biota.

2.2 Terrestrial Resources I sues No terrestrial resources issu were raised by the staff in the. FES-OL..

2.3 Cultural Resources Issues There are two archaeological sit s on the licensee's property which have been determined to be eligible for the National'Register of Historic Places.

Protection for these two sites wil be provided through a Cultural Resources Protection Plan. NRC requirements ith regard to the cultural resources issue are specified in Subsection 4.2.1 of his EPP.

2-1

3.0 Consisten y Requirements 3.1 Plant Desig and Operation The licensee may m ke changes in station design or operation or perform tests or experiments aff ting the environment, provided such activities do not involve an unreview d environmental question and d6 not involve a change in the EPP. Changes in plant design or operation or performance of tests or experiments which do ot affect the..environment are not subject to the requirements of this PP. Activities governed by Section 3.3-are not subject to the requirements o this Section.

Before engaging In con truction or operation attiyitles which may significantly affect the environment, the licensee shall prepare and record an environmental evaluation of such acti ity. Activities are excluded from this requirement if all measurable nonra lological effects are confined to .the on'-site areas previously disturbed dur ng site preparation and plant constructinn.

When the evaluation indicates that such activity involves an unreviewed environ mental question, the lice see shall provide a written evaluation of such activity and obtain prior RC approval. When such activity involves a change

- in the EPP, such activity nd change to' the EPP may be implemented only in accordance with an appropr ate license amendment as set forth in Section 5.3 of this EPP.

A prnoosed change, test or e periment shall be deemed to involve an unreviewed environmental question if it oncerns: (1) a matter which may result in a

'ionificant s increase in any aduere environmental impact previously evaluated 3-1

  • in the FES_ environmental impact appraisals, or. in any decisions of the Atomic Safety and Licensing Board, or (2)a ýignificant change in effluents or power level in accordance with 10 CFR Part S1.5(b)(2)] or (3) a matter, not previously r iewed and evaluated in the documents specified in (1) of this Subsection, i w ch may have a significant adverse environmental impact.

The licensee shall mnintain records of' changes in facility design or operation and of tests and expe Iments carried out pursuant to this Subsection. These records thall include w itten evaluations which provide bases for the deter rmination that the change 'test, or e'x'p'eriment 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. The licensee shall include as part of its Annu 1 Environmental Operating Report (per Subsection 5.4.1) brief descriptions, a lyses, interpretations, and evaluations of such changes, tests and exper etts.

3.2 Reporting Related to the N DES Permit and State Certification Violations'of the NPDES.Pemit oi the State certification (pursuant to Section 401 of the Clean Water Act shall be reported to the'NRC by providing copies of the reports req ired by the NPDES Permit or State Certification. The licensee shall a so 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 hey are submitted to.the permitting agency.

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Changes to, or renewal of, the NPDES Permit or the State certification shall be reported to the NRC within 30 days following the date the change or renewal is approved. If permit or certification, in part or in its entirety, is appealed and s ayed, the NRC shall be notified within 30 days following the date the stay i granted.

The N*RC shall be notified of ch nges to the effective NPDES Vermit proposed by the licensee by providing NRC ith a copy of the proposed change at the same time it is submitted to the p ittlng agency. The licensee shall provide the NRC a copy of ihe applict'iih for renewal of tFte NPDES Permit at the same time the application is s bitted to the permitting agency.

  • - 3.3 Changes Required for Compliance wit Other Environmental Regulations Changes in plant design or operation and pe formance of tests or experimehts which are required to achieve compliance wit other Federal, State, and local environmental regulations'are not subject to t requirements of Section 3.1.

3-3

4;0 Environ ental Conditions 4.1 Unusual o Important Environmental Events Any accurance o an unusual or important event that indicates or could result in significant e vironmental impact causally related to plant operation shall' be recorded and r ported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, followed by a written report per Subsect on 5.4.2. The following are examples: excessive bird

  • impaction events, o site plant or animal disease outbreaks, mortality or unusual occurrence o any"ipecies pr6te6ted by the Endangered Species Act of 1973, fish kills, inc ease in nuisance organisms or conditions, and
  • unanticipated or emerg ncy discharge of waste water or chemical substances.
  • No routine monitoring-p ograms are required to imp~lemnent this condition.

4.2 Environmental Monit ing 4.2.1 Cultural Resources rotection Plan The licensee, the NRC and th State Historic Preservation Officer (SHPO) concur that the appropriate action' t be taken to negate any possible adverse effects to the Waterford 3 cultural re ources by the operation and maintenance activities of the licensee will ý through a Cultural Resources Protection Plan that provides documentation of a no adverse effect" determination.

This-Cultural Resources Protection P an was transmitted to the NRC and the SHPO by a letter from L. V. Maurin to G. W. nighton, dated April 15, 1983 for 4-1

- final review and c currence, after which the NRC submittod the plan to the

"*Advisory Council on Historic Preservation (ACHP) for comment on September 28, 1983. ACHP conc rrence was received by the NRC,, on October 18, 1983 without change.

The Cultural Resource Protection Plan, as referenced above, is the binding document to which the icensee-will adhere and this Section of the EPP is considered fully satisfi d with no further action required.

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5:0 Adminst ative Procedures 5.1 Review Lnd Audit The licensee hall provide for review and audlt of compliance with the Environmental rotection Plan. The audits shall be conducted independently of.

  • the individual or groups responsible for performing the specific activity.

A

  • description of he organizational structure utilized to achieve the independent review and audi function and results of~the audit activities shall be maintained and n de available for inspection.

5.2 Records Reten ion Records and logs re ative to the environmental aspects of station operation shall be made and r tained in a manner covenlent for review and inspection.

These records and lo s shill be made available to the NRC on request.

. Records of modfficatl ns to plant structures, systems and components determined "to potentially affect he continued protection of the environment shall be

- retained for the life f the plant. All other records, data and logs relating to this EPP shall be re ained for five years or, where applicable; in accordance with the requ rements of other agencies.

5.3 Changes il Protection Plan Recuest for a change in the 'nvironmental Protection plan shall include an assessment of the environmer ta iT2act of the proposed change and a supporting 5-1

justification. ]mplementation nf such changes in 'the EPP shall not commence prior to NRC a )royal of the proposed changes in the form of a license amend ment incorpora Ing the appropriate revision to the Environmental Protection Plan.

" " 5.4 Plant Repo ing Requirements 5.4.1 Routine Re orts An Annual Environ ntal Operating Report describing implefientation of this EPP for the previous ye r shall be submitted to the NRC prior to May 1 of each year. The initial port shall be submitted prior to May of the year fol lowina issuance of the oper ting license. The period or-the first report shall 'begin with the date of iss ance of the operating license.

The report shall incl de summaries and analyses of -the results of the environ mental protection acti ities required by Subsection 4.2 of this Environmental Protection Plan for the report period, including a comparison with any related predperational studies, operational controls (as appropriate),

and previous

.- ' non-radiological environ ental monitoring reports, and an assessment of the observed impacts of the p ant operation' on the environment.

If harmful effects or evidence of trends towa d irreversible damage to the environmental are observed, the licensee sha I provide a detailed analysis of the-data and a proposed course of mitigati actions.

5-2

The Annual En ironmental Operating Report shall also include:

. (a) A list of EPP noncompliances and the corrective actions taken to remedy th (b) A list of a 1 changes In station design or operation,.tests, experiments made in acco dance with Subsection 3.1 which involved a potentially significant u reviewed environmental questioný.

(c) A list of nonro tine reports submitted in accordance with Subsection 5.4.2. \ . ...

In the event that some esults are not available by the report due date, the report shall be submitt noting and, explaining the missing results. The missing results shall be ubmitted as soon as posaible in'a supplementary' report.

5.4.2. Nonroutine Reports A written report shall be su itted to the NRC within 30 days of occurrence of any event described in Sectio 4.1 of this Plan. The reports shall (a)

- describe, analyze, and evaluat the event, including extent and magnitude of "the impact and plant operating haracteristics, (b) describe the probable

  • "cause of the event, (c) indicate the action taken to correct the reported event, (d) indicate the correctiv action taken to preclude repetition of the event and to prevent similar occurr nces involving similar components or' systems, and (e) indicate the agencies notified and their preliminary S responses,.

5-3

' Events ýeportable -under t is subsection which also require reports to other Federal, State or local a encies shall be reported in accordance with those reporting requirements in lieu of the requirements of this subsection. The NRC shall be provided a co y of such report at the. same time it is submitted to the other agency.

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