ML19321A154

Forwards Revised Draft Environ Protection Plan (Nonradiological).Also Requests That NRC Not Incorporate Document as Part of OL for Facility

ML19321A154
Person / Time
Site:	Mcguire, McGuire
Issue date:	07/17/1980
From:	Parker W DUKE POWER CO.
To:	Harold Denton, Youngblood B Office of Nuclear Reactor Regulation
References
NUDOCS 8007220536
Download: ML19321A154 (8)

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. . . . -o DUKE POWER COhiPANY Powen Buu.ntxo 402 SocTn Cuuacu SrazzT, CruatoTTE, N. C. asc42 wim w o. m ca.sa. July 17, 1980 Vier PattotNT TgttP=.omc; Asta 704

$ttaes P400ucttO4 373-4083 Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. B. J. Youngblood, Chief Licensing Projects Branch No. 1

Reference:

McGuire Nuclear Station Docket Nos. 50-369, -370

Subject:

McGuire Nuclear Station Units 1 and 2 Environmental Protection Plan (Non-Radiological)

Dear Mr. Denton:

On June 13, 1980, Duke Power Company received a draft of the McGuire Nuclear Station Units 1 and 2 Environmental Protection Plan (Non-Radiological). This document was informally transmitted by your staff for comment. We have reviewed the subject document, as requested, and our comments have been incorporated into the attached revision to the Environmental Protection Plan (Non-Radiological).

It la our opinion, however, that the December 27, 1978 decision in the matter of tne Yellow Creek Nuclear Plant (ALAB-515), held that the issues addressed by ttis draft plan and the reporting requirements imposed are outside the scope of NRC responsibility, and in fact, are the responsibility of the Environ-mental Protection Agency (EPA). Further, it is submitted that the protection of non-radiological environmental values during operation of McGuire Nuclear Station are addressed by the National Pollutant Discharge Elimination System (NPDES) permit issued by the State of North Carolina Division of Environmental Management (NCDEM). It is, therefore, requested that the NRC not incorporate this document as a part of the Operating License for McGuire Nuclear Station.

Very truly yours, w& &h ,

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William O. Parker, Jr.

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LJB:scs Attachment

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WILLIAM B. MCGUIRE NUCLEAR STATION

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UNITS 1 AND 2 DUKE POWER COMPANY DOCKET NOS. 50-369 AND 50-370 ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL)

JULY, 1980

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1.0 -0BJECTIVES OF THE ENVIRONMENTAL PROTECTION PLAN

• The EPP assures that protection of environmental values is provided during operation of McGuire Nuclear Station. The principal objectives of the EPP are as follows:

(1) Assure!that environmental impacts do not exceed those identified and found acceptable in the FES-OL, supplements to the FES-OL, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board.

(2) Assure that Federal, State and local agencies are advised of environmental protection issues.

(3) Keep NRC informed of the environmental effects of facility operation and of actions taken to control those effects.

Modifications or revisions in the EPP may be requested by the licensee in accor-dance with Subsection 4.4. The NRC may also require modifications or revisions of this EPP because of changes in station operation, en"ironmental conditions, or environmental protection concerns associated with station operation.

2.0 CONSISTENCY EVALUATION 2.1 NRC ENVIRONMENTAL IMPACT ASSESSMENT

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2.1.1 ENVIRONMENTAL PROTECTION ISSUES Environmental protection issues are listed below. Environmental issues to assure adequate protection of the environment from the operation of the William B. McGuire Nuclear Station Units 1 and 2 are addressed by the NPDES permit for McGuire. This permit is the responsibility of the State of North Carolina Civision of Environmental Management. The NRC has provided the Division of Environmental Management with the FESOL discussion of other issues; however, any further requirements related to these issues are the responsibility of the State. The NRC will not consider the 13 issues itemized below or any other water quality related issues to be compliance monitoring items. ,

1. Maintenance of condenser discharge temperature within NPDES permit limitations

2. Limitation of the drawdown of Lake Norman to 15 ft

3. Monitoring of water quality, including temperature

4. Monitoring of phytoplankton

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5. Monitoring of zooplankton

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6. Monitoring of benthic organisms *

7. Monitoring of the fish community

8. Monitoring of gas bubble disease in fishes

9. Monitoring of fish disease

10. Monitoring of temperature continuously and synoptically, and modeling of Lake Norman mathematically

11. Evaluation of the possible synergistic effects of oil treatment with addition of heat on the benthic community

12. Monitoring of chemical releases from the Conventional Wastewater Treat-ment System and Radwaste Holding Tanks

13. Monitoring the inventory of chemicals kept onsite 2.1.2 STATION DESIGN AND OPERATION The licensee may make changes in station design or operation or perform tests or experiments affecting the environment provided such changes, terts or experiments are approved by the Station Manager or the Manager of "4 clear Production, do not involve an unreviewed environmental question, and do not involve a change in the Environmental Protection Plan. Before engaging in additional construction, operational, testing, or experimental activities which may affect the environment, the licensee shall prepare and record an enviromnental evaluation of such activity. When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shall provide a written evaluation of such activities and obtain prior approval from the Director, Office of Nuclear Reactor Regulation. When such activity involves a change in the Environmental Protection Plan, such activity and change to the Environmental Protection Plan may be implemented only in accordance with an appropriate license amendment as set forth in Section 4.4.

A proposed change, test or experiment shall be deemed to involve an unreviewed environmental question if it concerns (1) a matter which may result in a signi-ficant increase in any adverse environmental impact previously evaluated in the final environmental statement (FES-OL) as modified by staff's testimony to the Atomic Safety and Licensing Boa'd, supplements to the FES-OL, environmental

~ impact appraisals, or in any decish as of the Atomic Safety and Licensing Board; or (2) a significant increase in effluents or power level (in accordance with 10CFR Part 51.5(b)(2)) or (3) a matter not previously reviewed and evaluated in the documents specified in (1) of this Subsection, which may have a significant adverse environmental impact.

The licensee shall maintain records of changes in facility design or operation and of tests and experiments carried out pursuant to this subsection. These records shall be retained onsite pursuant to Section 4.3.

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2.2 RELEVANT FEDERAL, STATE, AND LOCAL PERMITS AND CERTIFICATES 2.2.1 PROTECTION OF THE AQUATIC ENVIRONMENT Conditions and monitoring requirements for protection of the aquatic environment are specified (pursuant to Section 402 of the Clean Water Act) in the National Pollutant Discharge Elimination System (NPDES) Permit No. NC 0024392 issued by the State of North Carolina Division of Environmental Management (NCDEM), to Duke Power Company (DPC) for the McGuire Nuclear Station, Mecklenburg County, and in the certification issued by the State of North Carolina on July 22, 1976, under Section 401 of the Clean Water Act.

Nonconformance with those portions of the NPDES Permit or the State certifi-cation (pursuant to Section 401 of the Clean Water Act) which pertain to the environmental protection issues listed in Subsection 2.1.1 shall be reported to the NRC. The licensee shall submit to the NRC a copy of the reports to the NCDEM required by the NPDES permit in accordance with the schedules and content requirements imposed thereby.

2.2.2 EXCEEDING LIMITS OF OTHER RELEVANT PERMITS Occurrences of exceeding the limits specified in permits and certificates issued by other Federal, State and local agencies which pertain to the envi-ronmental protection issues listed in Subsection 2.1.1 shall be reported to the NRC in accordance with the schedules, content, and requirements specified by the agency which issued the permit.

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2.2.3 CHANGES IN PERMITS AND CERTIFICATIONS Changer and additions to Federal (other than NRC), State, regional, and local authority permits and certificates for the protection of the environment shall be reported to the NRC within 30 days following the date the change is approved.

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

If, as a result of the appeal procesa, permit requirements are changed, the change shall be reported within 30 days of the date the change is approved.

The NRC shall be notified of changes to the NPDES Permit proposed by the licen-see which pertain to issues listed in Subsection 2.1.1 by providing NRC with a copy of the proposed change at the same time it is submitted to the permit-ting agency. The notification of a licensee-initiated change shall include a copy of the justification for the requested revision submitted to the permit-ting agency.

3.0 SPECIAL CONDITIONS 3.1 UNUSUAL OR IMPORTANT ENVIRONMENTAL EVENTS Any occurrence of an unusual or important event that indicates or could result in significant environmental impact casually related to station operation shall be recorded and promptly 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 /> by telephone, telegraph,.or facsimile transmissions followed by a written report within 30 days, as specified in Subsection 4.5.2. The following are examples: excessive bird impaction events; onsite plant or animal disease outbreaks; mortality or

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unusual occurrence of any species protected by the Endangered Species Act of 1973; fish kills; increase in nuisance organisms or conditions; and unantici-pated or emergency discharge or waste water or chemical substances.

'4.0 -ADMINISTRATIVE PROCEDURES 4.1 - RESPONSIBILITY The Vice President, Steam Production, is responsible for compliance with this Environmental Protection Plan.

4.2 REVIEW AND AUDIT 4.2.1 REVIEW The following environmental matters shall be reviewed in accordance with pro-cedures prepared by the licensee.

A. Proposed changes to the Environmental Protection Plan shall be prepared by a qualified individual. Each such change shall be reviewed by a sec-ond individual who may be from the same organization as the individual who prepared the change. The review shall include an evaluation of the impact of the proposed changes.

B. Proposed changes to station operation procedures which alter the envi-ronmental effects of station operation shall be prepared by a qualified individual. Each such change shall be reviewed by a second individual who may be from the same organization as the individual who prepared the change. The review shall include an evaluation of the impact of the proposed changes.

C. Proposed changes or modifications to station equipment or systems which alter the environmental effects of station operation shall be prepared by a qualified individual. Each such change shall be reviewed by a sec-ond individual who may be from the same organization as the individual who prepared the change. The review shall include an evaluation of the impact of the proposed changes.

D. All routine reports, prior to their submittal to the NRC, shall be review-ed by a qualified individual.

E. All non-routine reports, prior to submittal to the NRC, shall be reviewed by a qualified individual.

4.2.2 AUDITS An audit of compliance with the Environmental Protection Plan shall be conduc-ted annually. The audit shall be conducted independently of the individual or group responsible for performing this specific activity. The results shall be forwarded to the Vice President, Steam Production, to the Senior Vice President, Production and Transmission, and to the management pop" ions respon-sible for the areas audited within 30 days after completion of the audit. '

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4.3 RECORDS RETENTION Records relative to the environmental aspects of station operation shall be

-made and retained at the site in a manner convenient for review and inspection as listed below. These records shall be made available to the NRC upon request.

A. The following records shall be retained for the life of the station:

(a) Records of changes to the Environmental Protection Plan including records of NRC approval of such changes.

(b) Records of modifications to station structures, systems and com-ponents determined to effect the continued protection of the envi-ronment.

(c) Records of changes to permits and certification required by Federal (other than NRC), State, regional, and local authorities for the protection of the environment.

(d) Routine reports submitted to the NRC.

B. Records of the following shall be retained for a minimum of six years:

(a) Revie*. and audit activities.

(b) Events, and the reports thereon, which are the suoject of a non-f ,

routine report to the NRC.

C. Reports required by the NPDES and other~ permits shall be retained in accordance with the requirements of those permits. ,

4.4 CHANGES IN ENVIRCNMENTAL PROTECTION PLAN Requests for a change in the Environmental Protection Plan may be submitted to the NRC at any time. The request shall include an assessment of the environmental impact of the proposed change and a supporting justification.

Implementation of such changes in the EPP shall not commence prior to NRC approval of the proposed changes in the form of a license amendment incorpor-ating the appropriate revision to the Environmental Protection Plan.

4.5 STATION REPORTING REQUIREMENTS 4.5.1 ROUTINE REPORTS Reports required by the NPDES and other permits shall be submitted to the NRC in accordance with the schedules and content requirements imposed thereby.

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4.5.2 NON-ROUTINE REPORTS A report shall be submitted in the event that an " Unusual or Important Environ- 1 mental Event," as specified in Subsection 3.1, occurs, or if another relevant i permit is exceeded or changed as specified in Subsection 2.2. .

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Non-routine. reports, to the extent practicable and applicable, shall (a) de-scribe, analyze, and evaluate the event, including extent and magnitude of the impact and plant operating characteristics, (b) describe the probable cause of the event, (c) indicate the action taken to preclude repetition of the event and to prevent similar occurrences involving similar components or systems, and (d) indicate the agencies notified and their prelimicary responses.

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