ML20117H859

Environ Protection Plan (Nonradiological), App B to Ol

ML20117H859
Person / Time
Site:	Hope Creek
Issue date:	05/01/1985
From:	Public Service Enterprise Group
To:
Shared Package
ML20117H833	List: ML20117H832 ML20117H859
References
NUDOCS 8505140429
Download: ML20117H859 (15)

Text

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APPENDIX B TO FACILITY OPERATING LICENSE NO.

HOPE CREEK GENERATING STATION l~

PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOCKET NO. 50-354 l-l' ENVIRONMENTAL PROTECTION PLAN (NONRADIOLOGICAL) 3-t h54 A PDR MP84 184 01 1-vw

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" 'l HOPE CREEK GENERATING STATION ENVIRONMENTAL PROTECTION PLAN (NONRADIOLOGICAL)

TABLE CONTENTS Section Page 1.0 Objectives of the Environmental Protection Plan........................................... 1-1 2.0 Environmental Protection Issues................ 1-1 2.1 Aquatic / Water Quality Issues................... 2-1 i

2.2 Terrestrial Issues............................. 2-1 2.3 Noise Issues................................... 2-2 l 2.4 Atmospheric / Air Quality Issues................. 2-2 3.0 Consistency Requirements....................... 3-1 1

3.1 Plant Design and Operation..................... 3-1 I 3.2 Reporting Related to the NJPDES Permit and State Certifications........................... 3-3 l

3.3 Changes Required for Compliance with Other Environmental Regulations...................... 3-4 1 4.0 Environmental Conditions....................... 4-1 4.1 Unusual or Important Environmental Events...... 4-1 l 4.2 Environmental Monitoring....................... 4-1 5.0 Administrative Procedures...................... 5-1 5.1 Review and Audit............................... 5-1 5.2 Records Retention.............................. 5-1 5.3 Changes in Environmental Protection Plan....... 5-2 1

l 5.4 Plant Reporting Requirements................... 5-2 1

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1.0 Objectives of the Environmental Protection Plan The Environmental Protection Plan (EPP) is to provide for protection of nonradiological environmental values during operation of the nuclear facility. The principal objectivos of the EPP are as follows:

(1) Verify that the facility is operated in an environmen-tally acceptable manner, as established by the Final Environmental Statement - Operating Licensing Stage (FES-OL) and other NRC environmental impact assessments.

(2) Coordinato NRC requirements and maintain consistency with other Federal, State, and local requirements for u*.vironmental protection.

(3) Koop NRC informed of the environmontal offects of facility construction and operation and of actions taken to control those offects.

Environmental concerns identified in the FES-OL which rotate to water quality matters are regulated by way of the licensoo's NJPDES permit.

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i 2.0 Environmental Protection Issues In the FES-OL dated December 1984, the staff considered the I

j environmental impacts associated with the operation of the Hope Creek Generating Station. Certain environmental issues l were identified which required study or license conditions I

to resolve environmental concerns and to assure adequate protection of the environment.

2.1 Aquatic / Water Quality Issues Specific issues raised by the staf f in the FES-OL were:

( Consumptive surface water use by Hope Creek during periods of river flow below 85 m 3/s (3,000 f t3 /s), as

! measured at Trenton, New Jersey, is to be compensated

! for under a ruling of the Delaware River Basin Commis sion . The applicant is participating in the I

I development of a supplementary reservoir for this purpose. (FES Section 4.2.3.2) 2.2 Terrestrial Issues Specific issues raised by the staff in the FES-OL were:

The primary potential ef fect of station operation on terrestrial resources derives from cooling tower ,

drift. Since issuance of the PES-CP, one unit and its associated cooling tower have been cancelled, reducing the potential impact by about one-half. In addition, more operating experience has been gained with natural l

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draft cooling towe rs at other power plants. This experience shows that significant impacts on terres trial resources will likely not occur at Hope Creek if the cooling tower functions properly and is adequately maintained. (FES Section 5.5.1.1) 2.3 Noise Issues Specific issues raised by the staff in the FES-OL were :

Area residents will not be af fected by noise resulting from station operation (FES Section 5.12); however, a potential impact to the public may be the periodic testing of the early notification system. This impact will be inf requent and insignificant. (FES Section 5.13) 2.4 Atmospheric / Air Quality Issues Specific issues raised by the staf f in the FES-OL were Operation of the anorgency diesel generators and the auxiliary boilers will not significantly degrade air quality in the vicinity of the plant . The applicant has cammitted to the New Jersey Depa rtment of Environmental Protection to operate no more than two of the three auxiliary boilers at one time. (FES Section 5.4.2) 2-2 MP84 184 01 5-vw L

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,; i YC. 3.0 Consistency Requirements

, y f- 3.1- ' Plant Design'and Operation

TheTlicensee-may make changes in station design or_ operation

'or perform tests or experiments af fecting the environment

provided such activities do not involve an unreviewed environmental question and do not involve a' change in the R 'EPP*. . Changes'in station design or operation or performance-of tests'or experiments which do not affect the environment are not subject to the requirements of this EPP. Activities governed by section 3.3 are not subject to the requirements of this Section.

Before engaging in additional construction or operational

- activities that may significantly affect the environment, the licensee shall prepare and record an environmental evaluation of such activity. Activities are excluded from this requirement if all measurable nonradiological environ-mental effects are confined.to the on-site areas previously disturbed during site preparation and plant construction.

When~the evaluation indicates that such. activity involves an-unreviewed environmental question, the licensee shall pro-vide a written evaluation of such activity and obtain prior i

• This provision does not relieve the licensee of the requirements of 10 CPR 50.59.

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-NRC approval.. 'When such activity-involves a change in the EPP,ssuchEactivity and change toLthe'EPP may be implemented only.inJaccordance:with an appropriate license amendment'as

. set forth in-Section 5.3 of this EPP.

A proposed change, test'or experiment shall' be deemed to involve an unreviewed environmental question if'it concerns:

(1) a~ matter which may result in a significant increase in

.any adverse environmental impact previously evaluated.in the FES-OL, environmental impact appraisals, or in-any decisions of..the Atomic Safety and Licensing Board; or (2)-a signifi-

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. cant change in effluents or power level; or (3) a matter, not previously. reviewed and evaluated in the documents specified in'(-1) of'this' Subsection..which may-have:a signi-ficant adverse environmental impact.

The : licensee shall maintain records of changes in facility E

design or operation and of tests and experiments carried out pursuant to this Subsection. These records shall include written evaluations which provide bases for the determina-

' tion that the change, test, or experiment 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 the Annual Environmental Operating Report t

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(per subsection 5,4.1) .brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.

3.2 Reporting Related to the NJPDES Permit and State Certification Changes to, or renewals of, the NJPDES Permits or the State Certification shall be reported to the NRC within 30 days 3 following the date the change or renewal.is approved. If a permit or certification, in part or in. its entirety, is appealed and stayed, the NRC shall be notified within 30 days following the date the stay is granted.

The licensee'shall notify the NRC of changes to the effective NJPDES Permit proposed by the licensee by provid-ing NRC with a copy of the proposed change at ~ the same time it is submitted to the permitting agency. The licensee shall provide the NRC a copy of the application for renewal of'the NJPDES Permit at the same time the application is submitted to the permitting agency.

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3.3 iChanges Required for Compliance with Other Environmental Regulations

. Changes 51'n plant design.or operation and performance of tests or experiments which are required to achieve -compli-

'ance'with other Federal, State, and local environmental

' regulations are not subject to the requirements of Section 3.1.-

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4.0 Environmental Conditions 4 .~ 1 Unusual or Important Environmental Events Any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to plant operation shall be recorded and reported to the NRC by 4 p.m. of the following business day-followed by a written report per Subsection 5.4.2. The following are examples: excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or unusual occurrence of any species protected by the Endangered Species Act of 1973, fish kills, increase in nuisance organisms or conditions, and unanticipated or emergency discharge of waste water or chemical substances.

No routine monitoring programs are required to implement this~ condition'.

4.2 Environmental Monitoring

-4.2.1 Aquatic Monitoring The certifications and permits required under the Clean Water Act provide mechanisms for protecting water quality and, indirectly, aquatic biota. Therefore, the NRC will rely on the decisions made by the State of New Jersey under the authority of the Clean Water Act, -for any requirements for aquatic monitoring that may be required during plant operation.

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4.2.2 Terrestrial Monitoring (1) To' ensure proper cooling tower operation, the staff and the New Jersey Department of Environmental Protection (NJDEP) requires that the applicant measure particulate emission during the period of initial power plant operation, report quarterly the calculated particulate emission, and to report annually the cumulative particulate emission and maintenance procedures applied to the tower.

(2) The applicant has committed to perform deposition measurements and native vegetative leaf analyses to detect any effects of cooling tower drift on vegetation.

4.2.3 Atmospheric / Air Quality Monitoring (1) The applicant has determined that the present onsite meteorological measurements system complies with the accuracy specifications presented in RG 1.23, "Onsite Meteorological Programs." The meteorological measure-ments program during plant operation will include those parameters currently measured.

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5.0' -Administrative Procedures

' 5 .1 Review and Audit The. licensee shall provide'for review and audit of compli-ance'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 Records Retention Records and -logs relative to the environmental aspects of station-operation shall-be made and retained in a manner convenient for review and inspection and in accordance with PSE&G's Nuclear Department Records Management Program.

These recordscand logs shall be made available to NRC on request.

Records of modification to station structures, systems and components determined'to potentially affect the continued protection of the environment shall be retained for the life of.the station. All other records, data and logs relating to this EEP shall be retained for five years or, where

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applicable, in accordance with the requirements of other agencies.

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5.3 Changes for Environmental Protection Plan Requests 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 prior to'NRC approval of the proposed changes in the form.of a license amendment ,

incorporating the appropriate revision 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

~ submitted to the NRC prior to May 1 of each year. The initial report shall be submitted prior to May 1 of the year following issuance of the operating license.

The 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), and previous nonradiological environmental monitoring reports, and an assessment of the' observed impacts of the plant operation on the environment. If harmful effects or evidence of trends 5-2

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toward irreversib'le damage to the environment are observed, the' licensee shall provide a detailed analysis of the data and a proposed course of mitigating action.

The Annual Environmental Operating Report shall also include:

(1)' A-list of EPP noncompliances 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 Subsection 3.1 which involved a potentially significant unreviewed environmental question.

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

In the event that some results are not available by the report due date, the report shall be submitted noting and explaining the missing results. The missing 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 occrrrence of a nonroutine event. The report shall (a) describe, analyze, and evaluate the event, including 5-3 MP84 184 01 14-vw

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extent andfmagnitude of the impact, and plant operating

-characteristics, (b) describe the probable cause of the

. event,-(c)' indicate the action taken to correct the reported event, (d) indicate the-corrective actionEtaken to preclude repetitionoof.the event and to prevent similar occurrences involving similar components or. systems,.and (e) indicate the agencies notified and their preliminary responses.

Events reportable under-this subsection which'also require reports to other Federal ~, State, or local agencies shall be 1 reported in accordance with those reporting requirements in

'lieulof the requirements of this-subsection. The NRC shall be provided with a copy of such report at the same time it

'is submitted to the other agency.

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