ML053620247

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License Amendments 176 and 162 Regarding Revision of the Appendix B, Environmental Protection Plan (Non-Radiological)
ML053620247
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 03/08/2006
From: Sands S P
Plant Licensing Branch III-2
To: Crane C M
Exelon Generation Co
Sands S P, NRR/DLPM/415-3154
Shared Package
ML060690432 List:
References
TAC MC5463, TAC MC5464
Download: ML053620247 (18)


Text

March 8, 2006Mr. Christopher M. Crane, President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2, ISSUANCE OF AMENDMENTSRE: REVISION OF THE APPENDIX B, ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL) (TAC NOS. MC5463 AND MC5464)

Dear Mr. Crane:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed AmendmentNo. 176 to Facility Operating License No. NPF-11 and Amendment No. 162 to FacilityOperating License No. NPF-18 for the LaSalle County Station, Units 1 and 2, respectively, inresponse to your application dated December 17, 2004. The amendments revise Appendix B, Environmental Protection Plan (non-radiological), of the LaSalle County Station OperatingLicenses.A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's biweekly Federal Register notice. Sincerely,/RA/Stephen P. Sands, Project ManagerPlant Licensing Branch III-2Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-373 and 50-374

Enclosures:

1. Amendment No. 176 to NPF-112. Amendment No. 162 to NPF-18
3. Safety Evaluationcc w/encls: See next page LaSalle County Station Units 1 and 2 cc:

Site Vice President - LaSalle County StationExelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757LaSalle County Station Plant ManagerExelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757Regulatory Assurance Manager - LaSalleExelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757U.S. Nuclear Regulatory CommissionLaSalle Resident Inspectors Office 2605 North 21st Road Marseilles, IL 61341-9756Phillip P. Steptoe, EsquireSidley and Austin One First National Plaza Chicago, IL 60603Assistant Attorney General100 W. Randolph St. Suite 12 Chicago, IL 60601ChairmanLaSalle County Board 707 Etna Road Ottawa, IL 61350Attorney General500 S. Second Street Springfield, IL 62701ChairmanIllinois Commerce Commission 527 E. Capitol Avenue, Leland Building Springfield, IL 62706Robert Cushing, Chief, Public Utilities DivisionIllinois Attorney General's Office 100 W. Randolph Street Chicago, IL 60601Regional AdministratorU.S. NRC, Region III 801 Warrenville RoadLisle, IL 60532-4351Illinois Emergency Management Agency Division of Disaster Assistance &

Preparedness 110 East Adams Street Springfield, IL 62701-1109Document Control Desk - LicensingExelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555Senior Vice President of OperationsExelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 LaSalle County Station Units 1 and 2- 2 -Director - Licensing and Regulatory AffairsExelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555Assistant General CounselExelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348Manager Licensing - Dresden, Quad Cities and ClintonExelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 March 8, 2006Mr. Christopher M. Crane, President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2, ISSUANCE OF AMENDMENTSRE: REVISION OF THE APPENDIX B, ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL) (TAC NOS. MC5463 AND MC5464)

Dear Mr. Crane:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed AmendmentNo. 176 to Facility Operating License No. NPF-11 and Amendment No162 to Facility OperatingLicense No. NPF-18 for the LaSalle County Station, Units 1 and 2, respectively, in response to your application dated December 17, 2004. The amendments revise Appendix B, Environmental Protection Plan (non-radiological), of the LaSalle County Station OperatingLicenses.A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's biweekly Federal Register notice. Sincerely,/RA/Stephen P. Sands, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-373 and 50-374

Enclosures:

1. Amendment No. 176 to NPF-112. Amendment No. 162 to NPF-18
3. Safety Evaluationcc w/encls: See next page DISTRIBUTION
PUBLICRidsOgcRp LPLIII-2 R/FRidsAcrsAcnwMailCenterRidssNrrDorlLplfGHill (4)

RidsNrrPMSSandsRidsNrrDirsItsb RidsNrrLADClarkeRidsNrrDirRebaCGuerreroADAMS Accession Number: ML053620247(Ltr.) Package ML060690432 Tech.spec.pagesML060690127 OFFICENRR/LPLIII-2/PMNRR/LPLIII-2/LADRL/REBA/BCOGCNRR/LPLIII-2/BC (A)NAMESSands:mwPCoates(DClarke for)AKuglerDFruchter (NLO)MLandauDATE / / / / / / 01 / 13 / 2006 / /OFFICIAL RECORD COPY EXELON GENERATION COMPANY, LLCDOCKET NO. 50-373LASALLE COUNTY STATION, UNIT 1AMENDMENT TO FACILITY OPERATING LICENSEAmendment No. 176License No. NPF-111.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment filed by the Exelon Generation Company, LLC (thelicensee), dated December 17, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of the Act,and the regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by this amendmentcan be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission'sregulations set forth in 10 CFR Chapter I;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Environmental Protection Planas indicated in the enclosure to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-11 is hereby amended to read as follows: (2)Technical Specifications and Environmental Protection PlanThe Technical Specifications contained in Appendix A and the EnvironmentalProtection Plan contained in Appendix B, as revised through Amendment No. 176 are hereby incorporated into this license. The licensee shall operate the facility inaccordance with the Technical Specifications and the Environmental Protection Plan.3.This license amendment is effective as of the date of its issuance and shall beimplemented within 60 days of the date of issuance.FOR THE NUCLEAR REGULATORY COMMISSION/RA/Mindy S. Landau, Acting ChiefPlant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Environmental Protection Plan Date of Issuance: March 8, 2006 EXELON GENERATION COMPANY, LLCDOCKET NO. 50-374LASALLE COUNTY STATION, UNIT 2AMENDMENT TO FACILITY OPERATING LICENSEAmendment No. 162License No. NPF-181.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment filed by the Exelon Generation Company, LLC(the licensee), dated December 17, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with theCommission's regulations set forth in 10 CFR Chapter I;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Environmental Protection Planas indicated in the enclosure to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-18 is hereby amended to read as follows: (2)Technical Specifications and Environmental Protection PlanThe Technical Specifications contained in Appendix A and the EnvironmentalProtection Plan contained in Appendix B, as revised through Amendment No. 162 are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications and the EnvironmentalProtection Plan.3.This license amendment is effective as of the date of its issuance and shall beimplemented within 60 days of the date of issuance.FOR THE NUCLEAR REGULATORY COMMISSION/RA/Mindy S. Landau, Acting ChiefPlant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Environmental Protection Plan Date of Issuance: March 8, 2006 ATTACHMENT TO LICENSE AMENDMENT NOS. 176 AND 162FACILITY OPERATING LICENSE NOS. NPF-11 AND NPF-18DOCKET NOS. 50-373 AND 50-374Replace the following pages of the Appendix B Environmental Protection Plan with the enclosedpages. The revised pages are identified by an amendment number and contain marginal lines indicating the area of change.Remove Pages Insert Pages1-11-12-22-2 3-23-2 3-33-3 4-14-1 4-2---

4-3---

4-4---

5-15-1 5-25-2 5-3---

5-4---

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 176 TO FACILITY OPERATING LICENSE NO. NPF-11AND AMENDMENT NO. 162 TO FACILITY OPERATING LICENSE NO. NPF-18EXELON GENERATION COMPANY, LLCLASALLE COUNTY STATION, UNITS 1 AND 2DOCKET NOS. 50-373 AND 50-37

41.0INTRODUCTION

By application dated December 17, 2004, Exelon Generation Company, LLC (EGC) andAmerGen Company, LLC (AmerGen), the licensees, requested changes to Appendix B, Environmental Protection Plan (EPP), for Braidwood Station, Units 1 and 2; Byron Station,Units 1 and 2; Clinton Power Station, Unit 1; LaSalle County Station, Units 1 and 2; LimerickGenerating Station, Units 1 and 2; Oyster Creek Nuclear Generating Station; Peach BottomAtomic Power Station, Units 2 and 3; and Quad Cities Nuclear Power Station, Units 1 and 2. This amendment addresses the licensee's proposed changes for LaSalle County Station, Units 1 and 2. Other amendments were issued to address the proposed changes for the otheroperating units.The proposed changes revise the EPP for LaSalle County Station by clarifying a number ofitems without changing the purpose, by removing the requirement for an annual report, by updating terminology, by deleting obsolete program information, and by standardizing wording in the EPP.

2.0REGULATORY EVALUATION

The EPP was established during initial plant operation to monitor environmental issues such aspotential erosion along the transmission lines and the cooling tower drift impact on vegetationand noise, as well as cultural resources issues. The regulatory basis for the establishment of the EPP is Section 50.36b of Title 10 of the Code of Federal Regulations (10 CFR),?Environmental conditions." This section provides that a license may include conditions toprotect the environment. The regulation states that the conditions will identify the

?obligationsof the licensee in the environmental area, including, as appropriate, requirements for reporting and keeping records of environmental data, and any conditions and monitoring requirement for the protection of the nonaquatic environment" and that the conditions will be derived from thelicensee's environmental report and NRC's evaluation in the record of decision. However, inthe March 12, 1984, statements of consideration for the final rule that created Section 50.36b,the Commission stated that NRC

?may also include additional environmental conditions asappropriate."

3.0TECHNICAL EVALUATION

Section 1.0Objective of the Environmental Protection PlanRequested ActionA change is proposed to remove references to facility construction from Section 1.0. Thissection contains the objectives of the EPP which is to provide for protection of the environmental values during construction and operation of the nuclear facility. Construction iscomplete at LaSalle County Station and therefore the reference to construction is deleted.NRC Staff AnalysisThe facility construction references were included to cover the impacts related to the latterstages of the construction of the plants. The associated activities were completed many years ago. Therefore, the NRC staff concludes that removal of these references is acceptable. Theremaining text ensures that impacts related to current and future activities at the plants are considered under the EPPs. This administrative change is acceptable.Section 2.1Aquatic IssuesRequested ActionThis section of the EPP references the Illinois Environmental Protection Agency as the issuer ofthe National Pollutant Discharge Elimination System (NPDES) Permit. The proposed change

will standardize the issuer of the NPDES Permit to be the Federal or State permitting authority. The use of a more generic reference to the permitting authority will prevent future changes inthe structure of the state governments from creating new inconsistencies.NRC Staff AnalysisThe proposed change is administrative in nature and corrects existing problems in the EPPs. The use of a more generic reference to the permitting authority will prevent future changes inthe structure of the state governments from creating new inconsistencies. The NRC staff concludes that this change is acceptable.Section 2.2Terrestrial IssuesRequested ActionThe proposed change in Section 2.2 is to clarify that the State Dam Permit addresses, and willregulate, the potential erosion effects around the cooling pond and the banks of ArmstrongRun. This terrestrial issue was raised by the NRC in the Final Environmental Statement for the LaSalle County Station Operating License (FES-OL). The Dam Permit currently issued by the Illinois Department of Natural Resources addresses all regulatory requirements of the EPP.

The NRC will rely on this State agency for regulation of these requirements.NRC Staff Analysis The NRC will rely on the current permitting state agency to address the regulatoryrequirements. Therefore, the NRC staff concludes that this change is acceptable.Section 3.1Plant Design and OperationRequested ActionThe proposed change in Section 3.1, ?Plant Design and Operation", is to delete the reference tothe Annual Environmental Operating Report. With the deletion of the Annual EnvironmentalOperating Report, a reference within this section is not required.NRC Staff AnalysisThe NRC staff's analysis and conclusion regarding the need for the annual report is discussedin the evaluation for Subsection 5.4.1. Without the annual report, the NRC staff will not receivesummaries of the evaluations of changes by the licensees. However, these evaluations will beavailable for staff review at the plant. In addition, Section 3.1 will still require the licensees toobtain NRC staff approval for any changes that involve an unreviewed environmental question. Based on this, the staff concludes that the removal of the requirement for annual reporting of the licensees evaluations for unreviewed environmental questions is acceptable.Section 3.2Reporting Related to the NPDES Permit and State CertificationRequested ActionThe proposed changes in Section 3.2 are to revise the reporting requirements related toapproval or changes to the NPDES Permit or State certification.Currently, this section requires that changes and additions to the NPDES Permit or the StateCertification shall be reported to the NRC. This section also requires that a proposed revisionbe sent to the NRC at the same time as it is submitted to the permitting agency. The NRCrelies on the State regulatory agency to regulate these matters. Changes to the NPDES Permitor State Certification will continue to be provided to the NRC within 30 days of approval.Proposed changes will no longer be provided to the NRC. Information related to environmentalpermits will continue to be available onsite for NRC review.An administrative change is incorporated to delete a portion of the first paragraph in this sectionthat had been inadvertently duplicated.NRC Staff AnalysisThe EPPs require the licensees to provide the NRC staff with copies of proposed revisions to,or renewals of, the NPDES permits. However, the NRC staff does not have a role indetermining the NPDES limits for the plants. This responsibility lies with the appropriateNPDES permitting authority. Therefore, requiring the licensees to submit proposed NPDES permit changes is of little value to the NRC staff. The paragr aph that will remain in the EPP willstill require the licensees to provide the NRC staff with copies of the approved revised permits. This requirement will allow the NRC staff to remain cognizant of those environmental impacts of plant operations related to the permits. In addition, the EPP will continue to require thelicensees to evaluate plant changes for unreviewed environmental questions. This requirement ensures that significant changes to the environmental impacts of plant operation will receive anNRC staff review that is independent of the NPDES review by the permitting authority. Whilethe NRC staff will have no role in setting the limits in the NPDES permit, the staff will consider other impacts (e.g., to threatened and endangered aquatic species) that may not be included in the NPDES review. Based on this information, the staff concludes that the proposed changes are acceptable.Section 3.3Changes Required for Compliance with Other Environmental RegulationsRequested ActionA change is proposed to replace the phrase

?required to achieve compliance with" with thephrase ?that are either regulated or mandated by." This section exempts those changes thatare regulated or mandated by other Federal, State, and local environmental regulations fromthe requirements of Section 3.1. An additional sentence has been added to state, ?However, ifany environmental impacts of a change are not evaluated under other Federal, State or local environmental regulations, then those impacts are subject to the requirements of Section 3.1." This is an administrative change to improve clarity and understanding and does not change the objective of the original statement.NRC Staff AnalysisThe current Section 3.3 applies the exemption from Section 3.1 only to those changes, tests, orexperiments that are required to achieve compliance with the regulations of various agencies.

The revision expands this exemption to include environmental impacts that are evaluated by these various agencies. This change has the effect of focusing Section 3.1 on those environmental impacts that will not otherwise receive a review by a cognizant Federal, State, orlocal agency. Impacts that are the subject of the expansion of the exemption will still beevaluated, but by the appropriate cognizant agency. Therefore, the NRC staff concludes thatthis change is acceptable.Section 4.1Unusual or Important Environmental EventsRequested ActionA change is proposed that if an event is reportable under 10 CFR 50.72, ?Immediate notificationrequirements for operating nuclear power reactors," then a duplicate immediate report in accordance with the station's EPP is not required. Requirements are provided in the EPP toreport Unusual or Important Environmental Events to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Unusual andImportant Environmental Events are defined as any occurrence of an event that indicates orcould result in significant environmental impact causally related to plant operation. Such eventsshall 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 /> and followed by a written report. Similarly, 10 CFR 50.72(b)(2)(xi) states that the licensee shall notify the NRC as s oon aspractical and in all cases, within four hours of the occurrence of

?any event or situation, relatedto the health and safety of the public or onsite personnel, or protection of the environment, for which a news release is planned or notification to other government agencies has been or willbe made." The proposed change will relieve the administrative burden of making duplicatereports to the NRC for the same event. Follow-up written reports will still be required to besubmitted in accordance with the EPP.The change to delete references to telephone, telegraph or facsimile brings the text of theEPPs into conformance with the present methods of reporting events to the NRC.NRC Staff AnalysisThe change is a clarification to avoid potential duplicate reporting requirements. At the time theEPPs were developed, there was no environmental reporting requirement in 10 CFR 50.72.

Therefore, there was no issue of duplicate reporting. In the EPPs, specific methods of transmittal (e.g., By telephone, telegraph, or facsimile transmissions) are included. The proposed changes would delete these details. This change is administrative in nature, bringingthe text of the EPPs into conformance with the present methods used to make immediate reports regarding events to the NRC. Based on this information, the NRC staff finds theproposed change acceptable.Section 4.2Environmental MonitoringRequested ActionThe proposed change will standardize the agencies outside the NRC that provide jurisdictionover the Environmental Monitoring programs to be the Federal or State permitting authority.Environmental monitoring programs are conducted in accordance with the guidance andcontrols of agencies outside of the NRC. The NRC has recognized the Federal or Stateagencies as the authorities having jurisdiction in Section 2.0 of the EPP. Therefore, there is nospecific NRC-required Environmental Monitoring in the EPP.NRC Staff AnalysisThe NRC staff concludes that the proposed change is administrative in nature and isacceptable.Section 4.2.1Vegetative Integrity on Cooling Pond DikeRequested ActionA change is proposed to delete the entire Vegetative Integrity on Cooling Pond Dike, section inits entirety from the EPP.The terrestrial issue raised by the NRC in the FES-OL was potential erosion effects al ong the dike around the cooling lake and the banks of Armstrong Run. The vegetative integrity anderosion were assessed by visual inspection on the outer face of the peripheral cooling lake dike at the beginning of the spring and fall planting seasons.A four-year quantitative dike re-vegetation study was completed and submitted to the NRC in1981. Since then, the Annual Environmental Operating Reports submitted by LaSalle CountyStation for the years 1982 to present indicated no significant discrepancies with vegetativeintegrity or erosion of the cooling lake dikes and peripheral ditches discharging into Armstrong Run. Subsequent to the issuance of the Unit 1 and 2 Operating Licenses, the LaSalle CountyStation cooling lake dikes and peripheral ditches came under the purview of a State issued Dam Permit. Conditions specified in the permit along with the Illinois Department of NaturalResources (IDNR) guidelines provide detailed erosion controls, vegetation maintenance andinspection requirements that capture the requirements detailed in the current EPP. TheAnnual Dam Inspection Report is submitted to the State regulating authority and is available tothe NRC for inspection and review.Based on the studies and inspections performed, plus current permitting and regulations by aspecific State agency, it is proposed that Section 4.2.1 be deleted in its entirety.NRC Staff AnalysisBased on the studies and inspections performed by the licensee, in addition to the oversight bythe current permitting state agency, the NRC staff concludes that this change is acceptable.Section 5.2Records RetentionRequested ActionA revision is proposed to revise the requirement of log retention and retention timeframe fromfor the life of the plant to until the date of termination of the operating license.This section requires retention of records relative to the environmental aspects of plantoperation and modifications determined to potentially affect the continued protection of theenvironment. An administrative requirement to maintain logs is deleted. The requirement to maintain all records is maintained. There are no dedicated environmental logs maintained on site. Logs relative to the environment are required to be documented by specific State permits (i.e., NPDES Permit) and EGC environmental administrative procedures. Such entries are maintained as part of station operating logs. The reference to environmental logs has been deleted for clarity but the purpose of the original statement is maintained.The proposed change in the retention timeframe to the termination of the operating licensemakes the requirement consistent with similar requirements in other regulations (i.e., 10 CFR50.59, Changes, tests, and experiments). This change has been proposed to provide clarity but does not change the objective of the requirement. NRC Staff AnalysisThe proposed change regarding the types of records retained simplifies the EPPs by requiringthe retention of records associated with the EPPs. The existing reference to data and logs refers to information that would have been collected under the now-completed monitoring programs. The change to the stated retention period makes the requirement consistent withother similar requirements in the NRC regulations (e.g., 10 CFR 50.59). The NRC staffconcludes that these changes are acceptable.Section 5.4.1Routine ReportsRequested ActionA change is proposed to delete the entire section relating to Routine Reports.

This section requires an annual environmental operating report be submitted to the NRC byMay 1 of each year. The report includes summaries and analyses of the results of the monitoring requirements of 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 questions, and a list of nonroutine reports submitted in accordance with Subsection 5.4.2.As previously discussed in the evaluation of Section 4.2, Environmental Monitoring, withspecific environmental monitoring under the conditions and regulations of the Dam Permit, it is proposed that Section 4.2.1, Vegetative Integrity on Cooling Pond Dike, be deleted.Environmental noncompliances are reported as required by 10 CFR 50.72, Immediate notification requirements for operating nuclear power reactors, and corrective actions will beincluded in the Exelon Corrective Action Program. Design changes are addressed by the EGC implementing procedures associated with 10 CFR 50.59 and Section 3.1 of this EPP. If an environmental evaluation indicates that an activity involves an unreviewed environmental question, or involves a change to the EPP, prior NRC approval must be obtained prior toimplementation.With the deletion of Section 4.2.1, and the remaining requirements addressed in 10 CFR 50.72,the EGC 10 CFR 50.59 Review Program and Environmental Evaluation Program, it is proposed that Section 5.4.1 be deleted in its entirety.NRC Staff AnalysisMonitoring programs are either completed, or are monitored by the cognizant State agency. Based on the existing requirements in NRC regulations, the NRC staff concludes that theannual report is not necessary and this requirement can be deleted. Section 5.4.2Non-Routine ReportsRequested ActionA change is proposed to Section 5.4.2 to revise a non-routine event to be an unusual orimportant environmental event.Currently, this section requires written reports to be sent to the NRC within 30 days ofoccurrence of a nonroutine event. An administrative change is being made to clarify the objective of the section to refer to an unusual or important environmental event as described in Section 4.1 of Appendix B. This change is also for consistency with all other EGC and AmerGen stations.NRC Staff AnalysisThe NRC staff has reviewed the EPPs and concludes that the intent of Subsection 5.4.2 was torequire a written report for the events described in Subsection 4.1. Therefore, the NRC staffconcludes that the proposed change is acceptable.

4.0STATE CONSULTATION

In accordance with the Commission's regulations, the Illinois State official was notified of theproposed issuance of the amendments. The State official had no comments.

5.0ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to record keeping, reporting, oradministrative procedures or requirements with respect to the EPPs. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR51.22(c)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.The Commission has previously issued a proposed finding that the amendments involve nosignificant hazards consideration and there has been no public comment on such finding (70 FR 19115).

6.0CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) thereis reasonable assurance that the health and safety of the public will not be endangered byoperation in the proposed manner, (2) such activities will be conducted in compliance with theCommission's regulations, and (3) the issuance of the amendments will not be inimical to thecommon defense and security or to the health and safety of the public.Principal Contributors: A. Kugler C. Guerrero Date: March 8, 2006