ML20094Q237
| ML20094Q237 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/31/1984 |
| From: | KANSAS GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20094Q232 | List: |
| References | |
| NUDOCS 8408200123 | |
| Download: ML20094Q237 (15) | |
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WOLF CREEK GENERATING STATION
-UNIT NO. 1 ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL)
July, 1984 TABLE OF CONTENTS Section a P,ajte 1.0 - Objectives of the Environmental Protection 1-1 Plan 2.0 Environmental Protection Issues 2-1 2.1 Water Quality Issues -
2-1 2.2 Aquatic Issues 2-2 23 Terrestrial Issues 2-2 3.0 Consistency Requirements 3-1 31 Plant Design and Operation 3-1 3.2 Reporting Related to the NPDES Permit 3-3 33 Changes Required for Compliance with Other 3-3 Environmental Regulations 4.0 Environmental Conditions 4-1 4.1 Unusual or Important Environmental Events 4-1 4.2 Environmental Monitoring and Management 4-1 4.2.1 Fog Monitoring 4-1 4.2.2 Waterfowl Impaction 4-2 4.2.3 Land Management 4-2 h0C 0 A i
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-TABLE OF CONTENTS (continued)
. .Section g 5.0 - ' Adrainistrative Procedures - 5-1 ,
5.1 Review and Audit 5-1 5.2- Retention of Program Doctruentation 5-1 53 Changes to 'the Environmental Protection Plan 5-1 5.4 Plan Reporting Requirements 5-2 5.4.1 Routine Reports 5-2 5.4.2 Nonroutine Reports 5-3 11
1.0 Objectives of the Environmental Protection Plan The Environmental Protection Plan (EPP) provides for protection of nonradiological values during operation of Wolf Creek Generating Station. The principle objectives of the EPP are as follows:
(a) Verify that the facility is operated in an environmentally acceptable manner, as established by the Final Environmental Statement-Operating License Stage; NUREG-0878 (FES-OLS), and other NRC environmental impact assessments.
(b) Coordinate NRC requirements, assure they are suitably ful-filled and maintain consistency with other Federal State and local requirements for environmental protection.
(c) Keep NRC informed of the environmental effects of facility operation and of actions taken to control those effects.
Environmental concerns identified in the FES-OLS which relate to water quality matters are regulated by the NPDES permit issued by the State of Kansas.
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(I 2.0 Environmental Protection Issues In the FES-OLS dated June,1982, the staff considered the environ-mental impacts associated with the operation of W olf Creek Generating Station (WCGS) . Certain environmental issues were identified which required monitoring, study, or license conditions to resolve environ-mental concerns and to assure adequate protection of the environment.
2.1 Water Quality Issues (a) That chlorine dosing is controlled within those frequencies and discharge concentrations predicted and evaluated by the staff, provided however , that the WCGS National Pollutant Discharge Elimination System (NPDES) permit will represent the final determination of acceptable chlorine usage at WCGS.
Actual chlorine usage may be greater than evaluated by the staff if so authorized by the NPDES permitting authority.
( FES-OLS: Section 4.2.6.1; Scaling and Biocide Treatment Wastes)
( b) That discharges from Wolf Creek Cooling Lake (WCCL) be regulated such that chemical constituents of the discharge in the Neosho River after complete mixing do not violate the operational WCGS NPDES permit or applicable portions of Kansas Water Quality Criteria.
( FES-OLS: Section 5.3.2.1; Neosho River)
(c) Additional water quality issues shall conform to the effec-tive NPDES permit implemented by the Kansas Department of Health and Environment.
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L 2.2 ' Aquatic Issues The need for aquatic monit(ring programs to confirm .that effects on aquatic. biota due to plant operations are no greater than predicted .
(FES-OLS: Section 5.1) 2.3 Terrestrial Issues (a) That the composition and structure of vegetation in the 453 ha (1120 acre) exclusion zone will be selectively ~ con-trolled to be canpatible with the function and security of station facilities.
( FES-OLS: Section 5.5.1.1; Station Site)
(b) That the vegetation within a buffer zone surrounding the cooling lake will be retained in or allowed to develop boward a natural state, i.e. naturally occurring biotic communities .
! ( FES-OLS: Section 5.5.1.1; Station Site) i i
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- (c) : 'That_ herbicides usedJ for the maintenance of transmission line corridors will be limited to herbicides approved by the U.S. EPA and the State of' Kansas at the time of such use.
( FES-OLS: Section 5.5.1.2; ~ Energy-Transmission System)'
L(d)! That in the event a serious disease problem involving waterfdwl attributable to' station operation occurs, 'the actions specified in the'_ reference will be initiated fbliow-ing technical evaluation if deemed necessary.
(FES-OLS: ' Section- 5.5.1.1; . Station Site)
(e);' The need for a wildlife monitoring program which includes a general survey program fbr waterfbwl collision events be accanplished.
( FES-OLS: Section 5.5.1.2; Energy-Transmission System)
( f) The need for a fog monitoring program to document any potential increase in fbgging due to the operation of the cooling lake heat dissipation system.
( FES-OLS: Section 5.4.1; Fog and Ice) 2-3
30 Concistincy - Requirements 31 Plant Design and Operation 1
Changes in station design, operation, performance testing.
experimental analysis,-etc. that do not bnpact the environment are exempt from the EPP requirements, and may be initiated according to procedure or operator judgement.' ~ Changes in these parameters that do impact the environment are not exempt and are subject to EPP control as follows.
Prior to engaging in activities which have the potential to significantly bnpact the environment, the licensee shall prepare and record an environmental evaluation of such activity. Activities are excluded from this requirement if all measurable nonradiological environmental effects are confined to the on-site areas previously disturbed during- site preparation and plant construction. If this evaluation indicates nominal environmental impact, which is considered within the general envelope of the WCGS Environmental Report-Operating License Stage (ER-OLS), FES-OLS, and Final Safety Analysis Report (FSAR), the evaluation will be retained on file and the activity or changes shall cunmence. If the evaluation indicates that such an 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 EPP, such activity and change to the EPP may be implemented only. in accordance with an appropriate license amendment as set forth in Section 5.3
- This provision does not relieve the licensee of the requirements of 10 CFR 50.59.
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TJ A proposed change, test,'or experiment shall be deemed to involve
- an unreviewed. environmental- question if it concerns (1) a matter
'which may result in a significant increase in any adverse envi-ronmental impact previously evaluated in the FES-OLS as modified by staff's testimony to the Atomic Safety and Licensing Board, supplements to the FES-OLS, environmental bnpact appraisals, or decisions of the Atomic Safety and Licensing Board; or (2) a significant change in effluents or power level (in accordance' with 10 CFR Part 51.5(b)(2)); or (3) a matter not previously reviewed and evaluated in the documents specified in (1) of this Subsection which may have a significant adverse environmental impact.
The licensee shall maintain documentation of changes in facility design or operation and of tests and experiments carried out pursuant to this Subsection. This documentation shall include a written evaluation which provide bases for the ' determination that the change, test, or experiment does not involve an unreviewed environmental question nor constitute a decrease in the effectiveness of this EPP to meet the objectives specified in Section 1.0. The licensee shall include as part of the Annual Environmental Operating Report (per Subsection 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests, and experiments.
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3 2 Reporting Related to the NPDES Permit Changes and additions to the NPDES Permit shall be reported to the NRC within 30 days following the date the change is approved.
'If a permit, in part or in its entirety, is appealed and stayed,
.the NRC shall be notified within 30 days fbilowing the date the stay is granted.
The NRC shall be notified of changes to the effective NPDES Per-mit proposed by the licensee by providing NRC with a copy of the proposed change at the same time it is submitted to the per-mitting agency. The licensee shall provide the NRC a copy of the application for renewal of the NPDES permit at the same time the application is subnitted to the permitting agency.
33 Changes Required fcr Compliance with Other Environmental Regulations Changes in plant design or operation and performance of tests or experiments which are required to achieve compliance with other Federal State, or local environmen*al regulations are not sub-ject to the requirements of Section 3.1.
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l 41U ' . Environmental Conditions 4.1_ Unusual.or Loportant- Environmental Events Any occurrence of an unusual' or important event that indicates or could result in significant environmental impact causally related to plant operation shall be recorded and 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 />' followed by a - written report per Subsection 5.4.2.
The fellowing are examples: excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or unusual occurrence of any species protected by the Endangered Species Act of 1973, fish kills, increase in nuisance organisms or conditions, and unanticipated or emergency discharge of waste water or chemical
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substances.
No routine monitoring programs are required to implement this condition.
4.2 Environmental Montoring and Management Environmental monitoring and management activities shall be undertaken as outlined in Section 2 and as described in the following .
4.2.1 Fog Monitoring A fog monitoring program shall be accomplished to document the frequency of occurrence of natural fog and future cooling lake operation induced fcg through the first year of commercial opera-tion of WCGS. A visiometer and continuous recorder shall be utilized in a conservative location throughout the program.
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4.2.2 Waterfowl Impaction
' A general survey program shall be accomplished to document sig-nificant waterfbwl collision events and determine if mitigation
'is warranted.
4.2.3 Land Management There_ shall be a land management program instituted at WCGS to provide for revegetation, maintenance, and ~ restoration of the WCGS site. This program shall attempt to achieve a balance between production and conservation values on site property through the implementation of-conservation and wildlife management techniques.
There shall be no reporting requirements associated with this condition.
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e 5.0 Administrative Procedures 5.1 Review and Audit The licensee shall provide fbr review and audit of compliance with the EPP. The audits shall be conducted independently of the individual or groups responsible for performing the specific activity.
A description of the organization structure utilized to achieve the independent review and audit function and results of the audit activities shall be maintained and made available for inspection.
5.2 Retention of Program Documentation Program documentation relative to the environmental aspects of plant operation shall be made and retained in a manner convenient for review and inspection. Program docunentation shall be made available to NRC on request.
Documentation of modifications to plant structures, systems, and couponents determined to potentially affect the continued pro-tection of the environment shall be retained fbr the life of the plant. All other information, data, and finalized reports relating the this EPP shall be retained fbr five years or , where applicable, in accordance with the requirements of other agencies.
53 Changes in Environmental Protection Plan Request for change in the EPP shall include an assessment of the environmental impact of the proposed change and a supporting justification. Lnplementation of such changes in the EPP shall 5-1
not commence prior to NRC approval of the proposed changes in the form of a license amendment incorporating the appropriate revision g to the EPP.
5 4 -Plant Reporting Requirements 5.4.1 ' Routine Reports An Annual Environmental Operating Report describing implementation of this EPP for the previous year shall be subnitked to the NRC prior to May 1 of each year. The initial report shall be submitted prior to May 1 of the year following issuance of the operating license. The period of the first report shall begin with the date of issuance of1the operating license.
.x The report shall include summaries and analyses of the results of the environmental protection activities required by Subsection 4.2 of this EPP for the report period, including a comparison with related preoperational studies, operational controls (as appropriate),
previous non-radiological environmental monitoring reports, and an assessment of the observed impacts of plant operation on the environment. IC h?rmful effects or evidence of trends towards irreversible damage to the environnent are obcerved, the licensee shall provide a detailed analysis of the data and a proposed course of action to alleviate the problem.
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= The Annual Environmental Operating Report shall also include:
(a) A list of EPP noncompliances and the corrective actions Etaken to remedy them.
(b) A list of all changes in station design or operation, tests, and experiments made in accordance with Subsection 31 which involved a potentially significant unreviewed environmental issue.
(c) A list of nonroutine reports submitted in accordance with Subsection 5.4.2.
In the event that some results are not available by the report due date, the report shall be subnitted noting and explaining the missing results. The missing results shall be submitted as soon as possible in a supplementary report.
5.4.2 Nonroutine Reports A written report shall be submitted to the NRC within 30 days of occurrence of nonroutine, unusual or important environmental l
event. The report shall (a) describe, analyze, and evaluate the I event, including extent and magnitude of the impact and plant l l
operating conditions, (b) describe the probable cause of
~ the event, (c) indicate the action taken to correct the reported event (d) indicate the corrective action taken to preclude repetition of the event and to prevent similar occurrences involving 5-3
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[ ', similar' components or systems, and (e) indicate the agencies l -- v. '
) s pt 1 ', . notified and their preliminary responses.
. Events reportable-under this Subsection which also require reports
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, - to other Federal, State', or local agencies shall be reported in a t'i;.*'
accordance with those reportint; requirements in lieu of the requirements of this Subsection. The NRC shall be provided a
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