ML20064J418

Revises Status of Commitment Re NPDES Permit for FCS

ML20064J418
Person / Time
Site:	Fort Calhoun
Issue date:	03/09/1994
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LIC-94-0060, LIC-94-60, NUDOCS 9403210206
Download: ML20064J418 (2)

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Omaha Public Power District 444 South 16th Street Mall Omaha, Nebraska 68102-2247 402/636-2000 March 9, 1994 LIC-94-0060 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station Pl-137 Washington, DC 20555

References:

1. Docket No. 50-285

2. Letter from NRC (R. A. Clark) to OPPD (W. C. Jones) dated March 11, 1983

3. Letter from 0 PPD (W. C. Jones) to NRC (R. A. Clark) dated April 15, 1983 (LIC-83-086)

Ge .lemen:

SUBJECT:

Notification to NRC of NPDES Permit Violations and Changes The purpose of this letter is to revise the status of a commitment concerning the National Pollutant Station (FCS). ThisDischarge commitment Elimination dates from System (NPDES)in 1983 of water quality-permit for the deletion related requirements of the Appendix B Environmental Technical Specifications for FCS. The NRC requested the following commitment in the Reference 2 transmittal letter for Amendment 69 to the FCS Facility Operating License:

We concur in the deletion of the aquatic requirements and will rely on the HPDES permit system which is administered by EPA for regulation and protection of the aquatic environment. However, the NRC staff still wishes to remain informed about any changes in your NPDES permit and any violations cf this permit. Accordingly, as discussed with your staff, you have agreed to provide NRC with a copy of any changes to the NPDES discharge permit and any permit vfolat f ans requiring notification to the permitting agency at the time this information is reported to or received from the permitting agency.

This information is to be submitted to the appropriate Regional Administrator with a copy to the Director, Office of Nuclear Reactor Regulation.

Please confirm this commitment in writing within 30 days of receipt of this letter.

Omaha Public Power District (OPPD) confirmed the commitment in Reference 3:

...the District has initiated procedure changes to ensure that a copy of all liPDES permit violations and changes will ne provided to the Director, U. S.

Huclear Regulatory Commission, Region IV, with a copy to the Director, Office cf Nuclear Reactor Regulation.

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U. $. Nuclear Regulatory Commission LIC-94-0060 Page 2 l OPPD has been reviewing and updating the status of various licensing basis commitments as part of develop ng our Ongoing Commitment Program. As a result of this review, OPPD has determ ned that the intent of the Reference 3 commitment is currently met by compliance with other NRC requirements.

On August 29, 1983, the NRC issued the final rule for 10 CFR 50.72, Immediate Notification Requirements of Significant Events at Operating Nuclear Power Reactors. Included was 10 CFR 50.72(b)(2)(vi), which requires the notification of the NRC within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of:

Any event or situation, related to the health and safety of the pubitc or onsite personnel, or protection of the environment, for which a news release is p~ianned or notification to other government agencies has been or will be made.

FCS Standing Orders R-8, Reporting Hazardous Material and NPDES Violations, and R-11, Notification of Significant Events, contain provisions for compliance with this regulation.

The Reference 3 commitment pre-dated the similar guidance in 10 CFR 50.72 for notification to NRC of significant environmental events, such as those involvin a violation of the NPDES permit. OPPD's compliance with 10 CFR 50.72(b) )(vi ensures that the NRC is notified of NPDES permit violations or noncomp ances reported to the State of Nebraska. Documentation of permit changes or violations is available for review by NRC inspectors when requested.

Based on the information provided above, OPPD concludes that the Reference '3 commitment does not appear to be cost-effective for either the NRC or OPPD, and that it therefore should be rescinded. Unless the NRC disagrees, this commitment will be removed from OPPD's database of active licensing basis commitments effective March 11, 1994.

Please contact me if you have any questions.

Sincerely,

/4. 5 W. G. Gates Vice President WGG/tcm c: LeBoeuf, Lamb, Greene & MacRae L. J. Callan, NRC Regional Administrator, Region IV .

R. P. Mullikin, NRC Senior Resident Inspector ,

S. D. Bloom, NRC Project Manager '

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