ML20153E974

Errata to Environ Protection Plan (Nonradiological)

ML20153E974
Person / Time
Site:	South Texas
Issue date:	03/31/1988
From:	NRC
To:
Shared Package
ML20153E970	List: ML20153E966 ML20153E974
References
NUDOCS 8805100191
Download: ML20153E974 (13)

Text

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.I APPENDIX'8 --

TO FACILITY OPERATING LICENSE N0. NPF-7E.

SOUTH TEXAS PROJECT s'

UNITS 1 AND 2 HOUSTON LIGHTING & POWER COMPANY, ET AL, DOCKET NOS. 50-498 AND 50-499 l

ENVIPONMENTAL PROTECTION PLAN (NONPADIOLOGICAL)

MARCH 1988 8805100191 880505 PDR

. P ADOCK 05000498 ppy J$ Die,

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SOUTH TEXAS PROJECT DNITS 1 AND 2 ENVIRONNENTAL PROTECTION PLAN (NONRA010 LOGICAL)

TABLE OF CONTENTS Section Page

1. 0 Objectives of the Environmental Protection Plan... . . . .. . . . .1-1 2.0 Environmental Protection Issues............................ 2-1 3.0 Cons i s te ncy Requi rement s. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 3.1 Plant Design and Operation.,............................... 3-1 3.2 Reporting Related to the NPDES Permit and State Certification............................................ 3-2 3.3. Changes Required for Compliance with Other Environmental Regulations.............................................. 3-3 y,

L%_, 4.0 Envi ronmental Condi tions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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 Review and Audit........................................... 5-1 5.2 Recorcs Retention.......................................... 5-1 1

5.3 Changes in Envi ronmental Protection Plan. . . . . . . . . . . . . . . . . . . 5-2 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 cf the nuclear facility.

The principal objectives of the EPP are as follows:

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

(2) Coordinate NRC requirements and maintain consistency with other Federal, State and local requirements for environmental protection.

n (3) Keep NRC informed of the environmental ef fects of facility construction and operation and of actions taken to control these effects.

Envi onmental concerns identified in the FES-OL which relate tc water quality matters are regulated by way of the licensse's NPOES Hrmit.

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2.0 Environmental Protection Issues i

In the FES-OL dated August 1986 (NUREG-1171), the staff considered the environmental impacts associated with the operation of the South Texas Project

, Unit Nos. I and 2. No aquatic / water quality, terrestrial, or noise issues were identified, I

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3.0 Consistency Requirements 1

3.1 Plant Design and Operation )

The licensee may make changes in plant design or operation or perform tests or j l

experiments affecting the environment provided such activities do not involve l an untsviewed environmental question and do not involve a change in the EPP*. l Changes in plant design or operation or performance of tests or experimer.ts j

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 require-ments of this Section.

'N Before engaging in additional construction or operational activities which may

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significantly af fect the environment, the licensee sha;l prepare and record an environmental evaluation of such activity. Activities are excluded from this requirement if all measurable nonradiological envirereental effects are confined to the on-site areas previously disturDed during site preparction and i plant construction. When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shall provide a written .

evaluation of such activity and obtain prior NRC approval. When such activity l involves a change in the EPP, such activity and change to the EPP may be ieplemented only in accordance with an appropriate license aundment as set forth in Section 5.3 of this EPP,

' "This p ovision does not relieve the licensee of the requirements of 10 CFR 50.59, 3-1

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 significant  ;

change in effluents or power level; or (3) a matter, not previously reviewed l

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and evaluated in the documents specified in (1) of the Subsection, which may have a significant adverse environmental impact.

The licensee shall maintain records of changes in plant 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 deter-mination 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 (per Subsection 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.

3.2 Reporting Related to the NPDES Parsit and State Certification Changes to, or renewals 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 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.

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The licensee shall notify the NRC of changes to the effective NPOES Permit proposed by the licensee by providing MRC with a copy of the proposed change at the same time it is submitted to the permitting agency. The licensee shall

-ovide the NRC a copy of the application for renewal of the NPDES Permit at 19e same time the application is submitted to the permitting agency.

3.3 Changes Required for Compliance with Other Environmental Regulations C5anges in plant design or operation and performance of tests or experiments wditch are required to achieve compliance with other Federal, State, and local environmental regulations are not subject to the requirements of Section 3.1.

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. l 4.0 Environmental Conditions 4.1 Unusual or Important Environmental Events

< Any occurrence of an unusual or important event that indi:stes or could result I

in significant environmental impact causally related to plant 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 I

report per Subsection 5.4.2. The following are examples: onsite plant or animal disease outbreaks; mortality or unusual occurrence of any species pro-tected 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 4.2 Environmental Monitoring l

4.2.1 Aquatic Monitoring I

The certifications and permits required under the Clean Vater Act provide sechanis's The m for protecting water quality and, indirectly, aquatic biota.

NRC will rely on the decisions made by the U.1 Environmental Protection Agency and the state of Texas under the authority of the Clean Water Act for any requirements for aquatic monitoring.

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. 4.2.2 Terrestrial Monitoring No terrestrial monitoring is required.

4. 2. 3 Noise Monitoring No noise monitoring is required.

4. 2. 4 Fog Monitoring The licensee shall provide to the NRC the results of the fog monitoring j program as described in Section 6.2.4.2 of Amendment 10 to the Environmental Report dated June 16, 1987. The report shall be provided within a reasonable l

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"' time af ter completion and documentation of the results of the program.

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5.0 Administrative Procedures 5.1. Review and Audit T e licensee shall provide for the 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 rade 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.

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

Records of modifications 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 EPP shall be retained for five years or, where appli-cable, in accordance with the requirements of others agencies.

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1 5.3 Changes in Environmental Protection Plan Requests for changes in the EPP shall include an assessment of the environ-Imple-mental impact of the proposed change and a supporting justification.

mentation 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 b for the previous year shall be submitted to the NRC prior to May 1 of each year. The period of the first report shall begin with the date of issuance of the Operating License for Unit 1, and the initial report shall be submitted l prior to May 1 of the year following issuance of the Operating License for Unit 1.

The report shall include summaries and analyses of the results of the environ-mental protection activities required by Subsection 4.2 (if any) 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 1 l

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

T e Annual Environmental Operating Report shall also include:

(1) A list of EPP noncompliances and the correcuve 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.

P (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 The report shall be submitted noting and explaining the missing resuitt.

missing results shall be submitted as soon as possible in a supplementary l

report.

5.4.2 Nonroutine Reports A written report shall be submitted to the NRC within 30 days of occurrence of a nontoutine event. The report shall: (a) describe, analyze, and evaluate 5-3  !

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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 correct the reported event; (d) indicate the corrective action taken to preclude repetition of the event and to prevent similar occur-rences 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 reported in accordance with those reporting requirements in lieu of the requirements of this subsection. The NRC shall be provided with a copy of such report at the same time it is sub-mitted to the other agency.

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