Text

Submittal of 2009 Annual Environmental Operating Report
	ML101380295
Person / Time
Site:	Cook
Issue date:	04/30/2010
From:	Weber L; Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	AEP-NRC-2010-37
	Download: ML101380295 (164)
	v • d • e

INDIANA MICHIGAN Indiana Michigan Power One Cook Place POWERE Bridgman, MI 49106 A unit of American Electric Power IndianaMichiganPower.com April 30, 2010 AEP-NRC-2010-37 DPR-58/74 Appendix B 5.41 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 ANNUAL ENVIRONMENTAL OPERATING REPORT Enclosed is the Donald C. Cook Nuclear Plant Annual Environmental Operating Report. This report covers the period from January 1, 2009, through December 31, 2009, and was prepared in accordance with the requirements of Environmental Technical Specification 5.4.1.

This letter contains no new or modified regulatory commitments. Should you have any questions, please contact Mr. James M. Petro, Jr., Regulatory Affairs Manager, at (269) 466-2489.

Sincerely, Lawrence J. Weber Site Vice President RSP/jen

Enclosure:

Donald C. Cook Nuclear Plant Annual Environmental Operating Report c: T. A. Beltz, NRC Washington, DC J. T. King, MPSC, w/o enclosure S. M. Krawec, AEP Ft. Wayne, w/o enclosure MDNRE - WHMD/RPS NRC Resident Inspector M. A. Satorius, NRC Region III K. Yale, MDNRE

ENCLOSURE TO AEP-NRC-2010-37 ANNUAL ENVIRONMENTAL OPERATING REPORT

U, CL Anhual Environmental Operating. Report January 1 2009, through December 31, 2009 Indiana Michigan Power Company 13 Bridgman, Michigan Docket Nos. 50-315 & 50-316 0

0 0

TABLE OF CONTENTS Page

1. Introduction 1 II. Changes to Environmental Technical Specifications 1 III. Non-Radiological Environmental Operating Report 1 A. Non-Routine Reports 1 B. Environmental Protection Plan 1 C. Plant Design and Operation 1 D. Environmental Monitoring - Herbicide Application 2 E. Mollusc Biofouling Monitoring Program 2 F. NPDES Applications 2 G. Special Reports 3 IV. List of Appendices Appendix Title I. Non-Routine Reports - 2009 II. Herbicide Application Report - 2009 Ill. Mollusc Biofouling Monitoring Program Report - 2009 IV. NPDES Applications - 2009 V. Special Reports - 2009 i __

I. INTRODUCTION Technical Specifications Appendix B, Part II, Section 5.4.1, requires that an Annual Environmental Operating Report be produced and include summaries and analyses of the results of the environmental protection activities required by Section 4.2 of the Environmental Protection Plan for the report period. The Annual Environmental Operating Report shall include a comparison with preoperational studies, operational controls (as appropriate), previous non-radiological environmental monitoring reports, and an assessment of the observed impacts of the plant operation on the environment.

This report serves to fulfill these requirements and represents the Annual Environmental Operating Report for Units 1 and 2 of the Donald C. Cook Nuclear Plant (CNP) for the operating period from January 1, 2009, through December 31, 2009.

The following table summarizes the pertinent data concerning CNP's operation during the period from January 1, 2009, through December 31, 2009.

Parameter Unit I Unit 2 Gross Electrical Generation (megawatt 273,792 8,317,992 hours0.0115 days 0.276 hours 0.00164 weeks 3.77456e-4 months )

Unit Service Factor (%) 3.30 84.9 Unit Capacity Factor - Maximum 2.92 85.5 Dependable Capacity Net (%)

CHANGES TO THE ENVIRONMENTAL TECHNICAL SPECIFICATIONS There were no changes to Environmental Technical Specifications in 2009.

Ill. NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT A. Non-Routine Reports A summary of the 2009 non-routine events is located in Appendix I of this Report. No long-term, adverse environmental effects were noted.

B. Environmental Protection Plan There were no instances of noncompliance with the Environmental Protection Plan in 2009.

C. Plant Design and Operation During 2009, there were no changes in station design, operations, tests, opr experimehts that involved a potentially significant unreviewed environmental issue. There were no environmental evaluations performed during the reporting period.

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D. Environmental Monitoring - Herbicide Application Technical Specification Appendix B, Part II Section 4.2, requires the use of herbicides to conform to the approved use of selected herbicides as registered by the EPA and approved by State authorities. There were no preoperational herbicide studies to which comparisons could be made. Herbicide applications are managed by plant procedure PMP-2160-HER-001, Guidelines for the Application of Approved Herbicides.

A summary of the 2009 herbicide application is contained in Appendix II of this report. Based on observations, there were no negative impacts or evidence of trends toward irreversible change to the environment as a result of the herbicide applications. Based on our review of application records and field observations, the applications conformed to Environmental Protection Agency and State requirements for the approved use of herbicide.

E. Mollusc Biofouling Monitoring Program Macrofouling monitoring and control activities during 2009 are discussed in Appendix III of this report.

F. NPDES Applications Groundwater MI DEQ issued a draft for comment on CNP's Groundwater Discharge Permit GW1810102 on October 16, 2009. The Plant responded with comments in a letter on October 28, 2009. The new Groundwater Permit was issued by the MI DEQ on December 15, 2009 (received at the plant on January 15, 2010) to take effect on January 1, 2010. The New Groundwater Permit was submitted to the NRC on January 29, 2010 via AEP-NRC-2010-10.

Surface Water On September 30, 2009, the Michigan Department of Environmental Quality issued renewed National Pollutant Discharge Elimination System (NPDES) permit number M10005827 to Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2. The permit took effect on January 1, 2010 and supersedes the NPDES permit number M10005827, which had an expiration date of October 1, 2008. The new NPDES permit was submitted to the NRC on October 29, 2009 via AEP-NRC-2009-77.

Copies of the above documents are included in Appendix IV of this report.

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G. Special Reports On June 26, 2009, a report was sent to the Michigan Department of Environmental Quality (MI DEQ) in follow-up to questions posed by the state toxicologist at a meeting with company and vendor representatives on November 20, 2008. The Plant had previously evaluated the product, Mexel, in a pilot study "Mexel Efficiency Study, D. C. Cook Nuclear Plant, Bridgman, Michigan, February 2008" (2008 Annual Environmental Operating Report) and found it effective in the control of zebra mussels. The plant was requesting permission to use the product in a full-scale application at the plant. The questions posed by the state toxicologist were on Mexel demand and degradation within the plant and the mixing zone. The questions were answered in a report sent to the MI DEQ titled "Explanation of the Need for and Rationale for a Mixing Zone Defined as the edge of the 1 ft/s Isopleth". The report concluded that when the product is applied at 4 mg/I for 40 minutes per day, it would be effective in controlling zebra mussels and the discharge would not be harmful to aquatic life assuming a 4:1 mixing zone at the 1 ft/sec velocity isopleth in the discharge plume. On August 3, 2009 the Plant received approval to apply Mexel at 4 mg/I for 40 minutes per day on a full scale basis.

A copy of this approval letter is included with this report.

Copies of the June 26, 2009 and August 3, 2009 reports are included in Appendix V of this report.

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APPENDIX I NON-ROUTINE REPORTS 2009

2009 Non-Routine Reports April 20, 2009 - Notice was made to the MI DEQ retracting a previous notice made to the MI DEQ on May 20, 2008 regarding exceeding the maximum daily concentration of 100 mg/I for total suspended solids for Outfall 00H, Turbine Room Sump Emergency Overflow. A review of the data and Part II, Section A, of CNP's NPDES permit determined that the daily concentration of total suspended solids was 95.3 mg/I and did not exceed 100 mg/I as originally reported in our written notification dated May 20, 2008.

August 3, 2009 - Notice was made to the MI DEQ that on July 29, 2009, at 1230 hours0.0142 days 0.342 hours 0.00203 weeks 4.68015e-4 months , a plume was observed from Outfall 001A. The plume was approximately 300' x 300' in size in Lake Michigan. The turbidity diminished over time and disappeared by 1430 hours0.0166 days 0.397 hours 0.00236 weeks 5.44115e-4 months the same day.

The plume was the result of starting the Unit 1 circulating water (CW) system. The system had not been operated since April 2009. Sand had accumulated in the tunnels due to natural lake action, and when the Unit 1 CW pump was placed in service, the sand was discharged to Lake Michigan.

Due to the nature of the CW system, there is very little that can be done to reduce this type of turbidity. The event lasted for approximately two hours, and there was minimal environmental impact from the plume.

November 2, 2009 - Notice was made to the MI DEQ that for the weeks ending October 10 and October 24, 2009, Cook Nuclear Plant (CNP) failed to obtain a Reverse Osmosis System Reject (Outfall OOG) weekly sample for Total Suspended Solids during a discharge period, defined as Sunday through Saturday in CNP's NPDES permit.

Approximately 0.186 million gallons of reject water was discharged between Sunday October 4 and Monday October 5, 2009, prior to the system being shut down for maintenance early on Monday October 5, 2009. Although Monday is the normally scheduled sample day, the system had been taken out of service prior to obtaining a sample for that discharge period.

Approximately 0.231 million gallons of reject water was discharged between Friday October 23 and Saturday October 24, during startup of the system following maintenance. Reverse Osmosis System Reject flow Total Suspended Solids was <4.0 parts per million from samples taken on Sunday, October 25, 2009, which was not the normally scheduled sample day. CNP's procedure defines the discharge period as Monday through Sunday; therefore, it was considered that the Sunday sample would satisfy the requirements for the week of October 19, 2009. The delay in sampling does not pose a threat to the environment, public health, or safety. CNP has identified a procedure revision which will provide reasonable assurance this sample requirement will be met in the future. This event was entered into CNP's corrective action system.

December 1, 2009 - A letter was sent to provide documentation of a phone conversation between the plant Environmental Manager and the MI DEQ District Supervisor regarding Outfall 001A turbidity. On July 29, 2009, at 1230 hours0.0142 days 0.342 hours 0.00203 weeks 4.68015e-4 months , a plume was observed from Outfall 001A. The MI DEQ was notified of this condition in a letter dated August 3, 2009 (see above). The source of the plume was from starting up the Unit 1 Circulating Water System. The plant is working on strategies to prevent recurrence. Upon discussion it was concluded that accumulated sand and silt is not considered "unnatural turbidity" and that a courtesy notification to the MI DEQ office prior to equipment startup would suffice. This type of discharge would not require written notification of the narrative standard from the Plant's NPDES permit, and no further actions would be required.

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APPENDIX II HERBICIDE APPLICATION REPORT 2009

INDIANA MICHIGAN A unit of American Electric Power Date April15,2010 Subject 2009 Herbicide Spray Report - Cook Nuclear Plant From Richard Hedgepeth To Jon Hamer, Environmental Manager The following herbicides were applied per manufacturers' direction by certified Michigan licensed applicators on Cook Nuclear Plant property during 2009:

Via Contractor Via AEP Personnel Landmark/Dupont Round-Up Pro/Monsanto Karmex/Dupont(Griffin) Speed Zone/PBI Gordon Razor/Riverdal Treflan 500/Knox Krovar T/Dupont Tordon 101/Dow Tordon K/Dow Garlon 3A/Dow Escort XP/Dupont Spret/Helena Invade 90/Townsend Trail Lite/Townsend Mistrol/Townsend Townsend Tree Service:

Townsend Tree service; a Michigan licensed herbicide applicator on contract to AEP Energy Delivery and Customer Relations performed the applications (Lance C Sherrick).

On July 22 and 23, 2009 a mixture of Karmex, Landmark, Krovar T, Razor, Invade 90, Trail Lite and Mistrol were used for total plant control in the 69 KV, the 345 KV and the 765 KV switch yards. A total of 168 lbs of Karmex, 42 oz. of Landmark, 42 lbs. of Krovar T, 31.5 qt. of Razor, 672 oz. of Invade 90, 168 oz. of Trail Lite and 168 oz.

Mistrol were used for the application and spread over about 21 acres in accordance with the manufacturers' labels. All drainage ditches, storm sewers and any other bodies of water were identified within the application areas. These areas were checked for water and the spray pattern was decreased in these areas.

Product Name Quantity Quantity Quantity Used Used/Acre Allowed/Acre Karmex 168 lbs 8.0 lbs 5-8 lbs Landmark 42 oz 2.0 oz 4.5 oz Krovar T 42 lbs 2.0 lbs 5-7 lbs Razor 31.5 qt 1.5 qt 2-10 qt Invade 90 672 oz 32 oz 64 oz Trail Lite 168 oz 8.0 oz 8.0 oz Mistrol 168 oz 8.0 oz 12 oz American Tree:

American Tree; a Michigan licensed herbicide applicator on contract to the Cook Plant Engineering Systems and Electrical Department performed the applications (David Jones).

On August 31 and September 1, of 2009, a mixture of Tordon 101, Garlon 3A, Escort XP, Spret and Tordon K, were used for total plant control in the following locations:

The Owner Controlled Area (OCA) east of the 345 KV yard, along the 345 KV power lines to Thorton Rd.

Under the 345 KV lines east of the 345 switch yard near the Kelly Buildings.

A total of 14 qt. of Tordon 101, 14 qt. Garlon 3A, 7 oz. of Escort XP, 14 qt. of Spret and 4 qt. of Tordon K were used for the application and spread over 30 acres in accordance with the manufacturers' labels. All drainage ditches, storm sewers or any other bodies of water were identified within the application area. These areas were checked for water and the spray pattern was decreased in these areas.

Equipment failure greatly reduced the scope of this application project and limited application to only 30 acres.

Product Name Quantity Quantity Quantity P Used Used/Acre Allowed/Acre Tordon 101 14 qt 0.5 qt 2 qt Garlon 3A 14 qt 0.5 qt 2 qt Escort XP 7 oz 0.2 oz 1 oz Spret 14 qt 0.5 qt 2 qt Tordon K 4 qt 0.1 - qt 1 qt

Maintenance Building and Grounds:

Round-Up Pro, Speed Zone and Treflan 500 was mixed with water in a sprayer and applied to Owner Controlled Areas by licensed applicators from the Maintenance Building and Grounds crew (Todd Brooks).

During the growing season of 2009, 19-19-19 Fertilizer was applied to all grass and lawn areas 13.9 acres) on plant property by Facilities/Maintenance.

Weeds were sprayed in all gravel areas East and South of the Protected Area (no Refueling Water Storage Tank Yards), inside the Protected Area on gravel areas around lawn and fence, North Access, Sidewalks, roadways and 1/22 microwave zone, on the railroad tracks & gravel areas fromNorth Access to Training Center, the Railroad tracks

& gravel areas from the Training Center to Red Arrow Highway, and the gravel area along the Technical Support Operations Center parking lots (length of building x 10' wide) and road way. A total of 6.0 oz of Round-Up Pro were used for spraying in 2009.

According to the product label, spraying should contain a maximum of 2 % solution and' a total permitted concentration of I oz per 15,000 sq. ft. A total of 6 gallons of solution was used to treat about 2 acres (total of 6 gallons of 1 % mixed solution used).

On May 1 1 th and 12th of 2009, Speed Zone was applied to all the grass/lawn areas of the Protected and Owner Controlled areas of the Plant. According to the product label, spraying should contain a 1 % solution and a total permitted concentration of 1 gallon per 1,000 sq. ft. A total of 220 gallons of solution was used to treat 6.0 acres (total of 2201-gallons of 1 % mixed solution used).

On May 1 3 th 2009, Treflan500 was applied to all flower beds,. under mulch, North, East and South of the Training Center, East North and West of the visitor center and East and West of the Red Arrow Highway main entrance. According to .the product label, the Treflan 500 granules were applied at a rate of 1.8 lbs. per 1000 sq. ft. A total of 80 lbs of product was used to treat approximately 1.5 acres.

The following table details the application rates used for weed control in the grass and garden beds compared to the allowable application rates.

Product Name Quantity Concentration Used Concentration Used Allowed 1.0 % solution - 6.0 oz of solution for 10.6 qt/acre per 6 gallons used. year 1 gal. per 1000 Speed Zone 2.5 gal 1.0% solution- 2.5 gallons of solution sq. ft., 6'acres for 220 gallons used. treated, 262,360 sq. ft.

1.8 lbs. 1000 sq.

Treflan 500 80 lbs. Granules applied at a rate of 1.8 lbs. ft., 1.5 acres per 1000 sq. ft. treated, 65, 340 1 sq. ft.

Mortality Inspection:

The 2009 herbicide survey was performed per PMP-2160-HER-00 1 on October 26, 29, 30 and November 2, 2009. There was no evidence of spillage, overspray or excessive application; no adverse environmental effects were noted during the inspection.

Herbicides were applied in accordance with manufacturer's label instructions and Federal and State requirements by Michigan-licensed applicators. Preparation and application descriptions were documented on PMP-2160-HER-001 Data Sheet 1, Herbicide Request.

Herbicides applied by Townsend Tree Service were Riverdale Razor, DuPont Karmex DF, Landmark II MP, Krovar I DF, Alenza 90, Invade 90, Mist-Trol 336 and Trail Lite 264. American Tree Company applied Dow Turdon 101, Turdon K, Garlon 3A, DuPont Escort XP and Spret. Additionally, Roundup Pro, Treflan 500, and Speed Zone broadleaf herbicide were applied by Sun Technical Services' licensed applicator.

Townsend Tree Service treated the 69 kV, 345 kV and 765 kV SwitchYards; also the loop feed enclosure east of the "blowdown" parking lot.

American Tree Company treated areas under the 345 kV lines eastward from the 345 kV SwitchYard to Thornton Road until equipment failure ended the job.

Sun Technical Services treated the following areas: stone-covered sections and lawns of the Protected Area, flower beds, parking lot perimeters, the Visitor Center and the main plant entrance area by Red Arrow Highway.

The overall effectiveness of the application was good. There is some vegetation growing on the north side of the 69 kV Yard. Also, grasses in the AB EDG fuel oil unloading area, U2 RWST Yard and the stone areas between the U2 Main Transformers.

Summary:

In summary, based upon our review of the application records, manufacturer specifications, material safety data sheets (MSDSs) and observations of the treated areas, the herbicides were applied according to the manufacturer's labeled. instructions and according to Federal and State requirements. All personnel performing herbicide applications were licensed by the State of Michigan. A detailed map and application records are filed in accordance with PMP-2160-HER-00 1, Guidelines for the Application of Approved Herbicides. No signs of over spray or spillage were observed. No adverse environmental effects occurred.

APPENDIX III MOLLUSC BIOFOULING MONITORING PROGRAM REPORT 2009

Mollusc Biofouling Monitoring Program 2009 Performed at Donald C. Cook Nuclear Plant Performed and Submitted By Cook Plant Environmental

Prepared for:

American Electric Power Donald C. Cook Nuclear Plant One Cook Place Bridgman, Michigan MOLLUSC BIOFOULING MONITORING PROGRAM 2009 April 2010 Cook Nuclear Plant Environmental Section

Table of Contents Page #

List of Tables and Figures i Executive Summary 1 Chapter 1 - Introduction 3 1.1 Past History 3 1.2 Objectives 4 Chapter 2 - Methods 5 2.1 Whole-Water Sampling 5 2.2 Artificial Substrates 7 2.2.1 Intake Forebay 7 2.2.2 Service Water Systems 8 2.2.3 Artificial Substrate Cumulative Sample 8 Analysis Chapter 3 - Results and Discussion 10 3.1 Whole-Water Sampling 10 3.2 Artificial Substrate Sampling, Biocide Treatment, and 14 Mechanical Cleaning 3.2.1 Circulating Water System Artificial Substrate 14 Sampling 3.2.2 Service Water Systems and Miscellaneous 15 Sealing and Cooling Water System Artificial Substrate Sampling 3.2.3 Biocide Treatment 21 3.2.4 Mechanical Cleaning 21 Chapter 4 Summary and Recommendations 23 4.1 Summary 23 4.2 Recommendations 25 References 27 Appendix Table 1 SWS Chlorination Values for 2009 Zebra 28 Mussel Monitoring Program

List of Tables and Figures Table # Title Page #

2-1 Sampling Schedule for Zebra Mussel Monitoring at 6 the D.C. Cook Nuclear Plant in 2009 3-1 Whole-Water Sampling Program Zebra Mussel 11 Veligers Per Cubic Meter, Veliger Size Range, and Mean Veliger Size (um) 3-2 Density, Average Size, and Size Range of Settled 19 Zebra Mussel Postveligers Collected on Cumulative Artificial Substrates Placed in the Forebay, in the Service Water Systems and the Miscellaneous Sealing and Cooling Water System in the D. C. Cook Nuclear Plant in 2009 Figure #

3-1 2009 D.C. Cook Plant-Whole-Water Zebra Mussel 12 Veliger Density and Water Column Temperature in Intake Forebay 3-2 2009 D.C. Cook Plant - Zebra Mussel Postveliger 20 Cumulative Settlement in the Service Water Systems 3-3 Screenhouse Intake Forebay 22 i

Executive Summary Biofouling studies have been conducted at the Donald C. Cook Nuclear Plant since 1983.

In 1991, monitoring of zebra mussels in the circulating water, essential service water (ESW), nonessential service water (NESW), and miscellaneous sealing and cooling water (MSCW) systems was added to the program. The objectives of this monitoring program are to detect the presence and determine the density of zebra mussel veligers in the Circulating Water System and postveliger settlement and growth rate in the forebay and service water systems, and to determine the effectiveness of oxidizing and non-oxidizing biocides in the plant systems by comparing densities and sizes of settled zebra mussels when applicable.

Veligers were present in the forebay from 23 April through 3 December 2009. Peak densities occurred on 25 June, 2 July, and 9 July 2009, with 9 July 2009, being the largest peak (733,500 veligers/m 3) during the 2009 sampling season. Historical data supports that zebra mussel density is independent of the volume of water entering the plant, as the concentration of veligers in the water remains the same regardless of the flow rate through the plant. Historical data collected for the past eighteen years suggests that the zebra mussel population is highly variable and future populations of zebra mussels prove difficult to accurately predict.

Cumulative settlement was monitored in the forebay by using a six-inch PVC pipe as an artificial substrate. As in 2008, the time period of collection was made to more accurately coincide with the annual fall intake crib cleaning to estimate the size and density of mussels the divers might encounter at the time of cleaning. The PVC pipe was deployed on 4 December 2008 and was retrieved on 12 November 2009. The settlement density and average size of postveligers for the 12-month period was I

703,701 individuals/m 2 and 2,120 pm (2.1 mm). As a comparison, the substrate sample collected during the 2008 sampling had a density of 272,026 individuals/m 2 and an average size of 2,526 pm (2.5 mm). Higher numbers of individuals encountered during the 2009 sampling could possibly be attributed to much higher than average veliger numbers during early July 2009.

Service Water Systems and Miscellaneous Sealing and Cooling Water The return sides (after systems' use) of the ESW and NESW systems and the MSCW system were monitored in the 2009 Mollusc Biofouling Monitoring Program. The results indicate that the chlorination system was effective in preventing growth and prolonged settlement of postveligers in the service water systems. The results showed despite ESW pump chlorine sparger design deficiencies, or when the system was taken out of service for short periods of time for system maintenance, or when system total residual chlorine (TRC) levels fell below their target band of 0.02-0.6 ppm, settlement control was quickly re-established.

Biocide Treatment There were no biocide treatments in 2009.

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Chapter 1 Introduction 1.1 Past History American Electric Power Company (AEP) has been conducting zebra mussel monitoring studies at the Donald C. Cook Nuclear Plant since 1991. The purpose of these studies is to monitor zebra mussel veliger and postveliger settlement densities in the Circulating Water, Essential Service Water (ESW), Nonessential Service Water (NESW), and Miscellaneous Sealing and Cooling Water (MSCW) systems to help determine the effectiveness of the zebra mussel control program.

Numerous private consulting firms had been involved in the past (1991-2004) to aid in the performance and analysis of the program. However, in 2004 the program was made the responsibility of the Donald C. Cook Plant's Environmental staff who conducted the monitoring programs designed to detect the timing of spawning and settling of zebra mussels at the Cook Nuclear Plant. The program also determines densities for: 1) whole water samples for planktonic veligers; and 2) artificial substrates set within the ESW, NESW, and MSCW systems for cumulative postveliger settlement.

In the Circulating Water System, a section of PVC piping is utilized as an artificial substrate to determine the cumulative settlement in the intake forebay.

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1.2 Objectives Specific objectives for the 2009 Mollusc Biofouling Monitoring Program were as follows:

- Conduct whole-water sampling of the Circulating Water System weekly (July-September), bimonthly (May, June, October & November), and monthly (April and December) to determine the presence and density of larval zebra mussels.

- Deploy artificial substrates (microscope slides in test tube racks) in the service water systems to determine cumulative settlement of postveligers. Collect samples monthly from May through December.

- Deploy a PVC piping section, also as an artificial substrate, in the intake forebay to determine cumulative settlement for approximately one year.

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Chapter 2 Methods 2.1 Whole-Water Sampling Whole-water sampling of the Circulating Water System was conducted from 23 April to 3 December 2009 (Table 2-1). Samples were collected from mid-depth in the intake forebay by pumping lake water through an in-line flowmeter into a plankton net. The sampling location was consistent with that of previous studies. Two replicates (2,000 liters each) were collected during each sampling date.

A Myers Model 2JF-51-8 pump or equivalent was connected to an in-line flowmeter assembly (Signet Model #P58640) and pumped water into a plankton net for approximately one hour. To minimize organism abrasion, measured flow was directed into a No. 20 plankton net that was suspended in a partially filled 55-gallon plastic barrel.

Samples were transferred to a one-liter plastic container by rinsing the plankton net with filtered Circulating Water System water. Filtered water was added to the container to ensure that a full liter was analyzed. The samples were stored under refrigeration and transferred to PhycoTech, Inc. within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of sampling for analysis.

Samples were mixed thoroughly then transferred to a calibrated 1ml Sedgewick-Rafter cell for counting. An Olympus BX51 research-grade compound microscope with Nemarski optics (10-100x) equipped with cross-polarizing filters was used to visually identify and enumerate individual viable veligers.

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TABLE 2-1 SAMPLING SCHEDULE FOR ZEBRA MUSSEL MONITORING AT THE D.C. COOK NUCLEAR PLANT IN 2009 Date Whole Water Artificial Substrates April 23 X 30 (1)

May 7 X 21 X X June 4 X 25 X X July 2 X 9 X 16 X X 23 X 30 X August 5 X 13 X X 19 X 27 X September 3 X 10 X X 17 X 24 X October 8 X X 22 X November 5 X X 12 (2) 19 X December 3 X X (3)

(1). Deploy slide racks.

(2). Retrieve PVC pipe section. Read & clean.

(3). Re-deploy PVC pipe section.

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Ten aliquots were counted and the average was extrapolated to determine the number of individuals per cubic meter. The density was calculated as follows:

3 Density (#/m3)=(average #*DF)/0.001 L*1 L/2000L*1 0OOL/m DF- Dilution Factor This process was repeated for a second replicate and the mean of the two values was calculated to yield a final density value. Size measurements were recorded for up to 50 organisms from each sample. Veliger size was measured using an ocular micrometer that was calibrated to a stage micrometer.

2.2 Artificial Substrates To determine zebra mussel settlement in the Circulating Water, a section of PVC pipe was deployed in the intake forebay, upstream of the trash racks. Bio-box side-stream samplers were installed on the return sides of both service water systems (ESW and NESW) and on the Miscellaneous Sealing and Cooling Water System (MSCW) to determine settlement in these systems. The side-stream samplers consisted of modified test-tube racks designed to hold microscope slides and placed in bio-boxes for cumulative sampling.

2.2.1 Intake Forebay On 12 November 2009 the PVC pipe, utilized as an artificial substrate, was retrieved from the forebay. The pipe, which had been installed on 4 December 2008, 7

measured 6 inches in length and had an inside diameter of 3.5 inches. The pipe had been cut in half lengthwise, rejoined using hose clamps, attached to a rope weighted by a stainless steel pipe section, and suspended at mid-depth in the intake forebay. The PVC sampler was analyzed for densities and shell sizes by analyzing scrapings from two separate one-inch square sections of the PVC sampler. The PVC sampler was

.designed to provide information on zebra mussel accumulated infestation and sizes occurring over a 1-year period.

2.2.2 Service Water Systems Side-stream bio-boxes were placed on the return side of the service water systems (1 ESW, 2 ESW, NESW) and the Miscellaneous Sealing and Cooling (MSCW) Water System. Each bio-box contained two modified test tube racks containing a total of 80 microscope slides. The racks held the slides above the bio-box base that allowed silt and sediment to fall out before they could affect the slide settlement. The bio-boxes were covered with a plant-approved fireproof fabric to limit light exposure. Plant personnel inspected the bio-boxes to ensure that flow was constant and unimpeded.

Adjustments were made when necessary. Ten slides from each location were collected monthly and were analyzed for postveliger density and shell size.

2.2.3 Artificial Substrate Cumulative Sample Analysis An Olympus BX51 research-grade compound microscope with Nemarski optics (10-100x) equipped with cross-polarizing filters was used to visually identify and enumerate individual viable veligers.

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Slide preparation consisted of scraping clean one side of the, slide allowing for direct placement on the microscope stage. The remaining postveligers could then be directly counted from the other side of the slide. When the 25mm x 75mm slide surfaces became heavily infested, the following sub-sampling technique was used:

Growth on slides was divided into either 2 or 4 equal subsections (depending on density of growth) and then a subsection was counted and the findings were extrapolated to give a number for the whole slide. Counts were then proportionally extrapolated to one square meter.

Settlement rates were calculated by taking the average number of mussels from the ten slides and multip!ying this value by 533.33 to obtain the density of zebra mussels per square meter. (One postveliger/microscope slide equals 533.33 post veligers per square meter.) [(1,000,000 mm 2 /25mm x 75mm = 1875mm 2, surface area of slide)]

Greatest Axial Linear Dimension (GALD) shell measurements were taken for up to 50 random individuals to obtain maximum, minimum and mean sizes. Dimensions were measured using an ocular micrometer calibrated to a stage micrometer at 100x.

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Chapter 3 Results and Discussion The zebra mussel monitoring system provided representative numbers for whole-water veliger and artificial substrate postveliger settlement densities. The whole-water sampling for free-swimming'veligers coupled with monitoring postveliger settlement on artificial substrates provided sample results that could be compared with previous years' data.

Appendix Table 1 shows the chlorination values for the ESW and NESW systems. A 0.02-0.6 ppm total residual chlorine (TRC) was the target band for the control of zebra mussel settlement. Chlorination levels were relatively consistent, with the exception of U-1 ESW [C12] East throughout August, late September and the majority of November 2009. Inconsistencies were also observed in U-2 ESW [C12] West in mid-August, late September and throughout November 2009 (Appendix Table 1). The MSCW system, which was cross-connected to the NESW system, was chlorinated on all of the dates that the NESW system was chlorinated. Ramifications of sub-target chlorine levels will be discussed further.

3.1 Whole-Water Sampling Sampling of planktonic veligers in the circulating water system was initiated 23 April 2009 and was completed on 3 December 2009. Results are presented in Table 3-1 and in Figure 3-1. Veligers were present in all samples throughout the monitoring season.

Heaviest spawning activity occurred in early to mid-July (733,500 ind./m 3) followed by the period from late-June to early-July (51,750 ind./M 3 and 36,900 ind./m 3 ). The overall 10

peak number of individual veligers occurred on 9 July (733,500 ind./M 3). This coincided with the highest numbers of the 2009 season which ran from 25 June through to 23 July and was closer to the timing of other peak events in recent history. The total number of individuals recorded was more than double that of 2008 (335,000 ind./M 3), and nearly double that of recent historical highs recorded in 2003 and 2005 of 450,000 ind./m 3 and 455,000 ind./m 3, respectively.

TABLE 3-1 Whole-Water Sampling Program Zebra Mussel Veligers Per Cubic Meter, Veliger Size Range, and Mean Veliger Size (um)

Density Size Range Mean Size Date (No./m 3) (urn) (urn) 4/23/09 125 100 173 5/07/09 800 110-170 148 5/21/09 1225 110-160 132 6/04/09 10075 110-280 138 6/25/09 51750 130-280 158 7/02/09 36900 130-300 150 7/09/09 733500 140-350 209 7/16/09 20350 140-350 218 7/23/09 23850 130-310 192 7/30/09 8400 140-320 192 8/05/09 4700 130-310 160 8/13/09 6700 130-400 177 8/19/09 1800 150-320 220 8/27/09 36500 120-300 167 9/03/09 24800 130-240 172 9/10/09 22600 140-250 175 9/17/09 18200 140-320 195 9/24/09 900 170-250 210 10/08/09 26000 130-300 150 10/22/09 3600 120-350 170 11/05/09 4300 120-250 164 11/19/09 200 120-240 180 12/03/09 2450 140-380 248 I1

Fig 3-1 2009 D.C. -Cook Plant- Whole-Water Zebra Mussel Veliger Density- and Water Column Temperaturein: Intake Forebay

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C .0 ) 0) 0: 0D 0 - -- (N t0 n *- ,(0 r- 0 .0. 0. 0 0 O 00 0 0, 0 0) 0 CD - - -(.

Sample Date 12

Whole water veliger densities declined dramatically following their peak on 9 July 2009.

Water temperatures remained constant, gradually rising, with no abrupt changes throughout the year with a season high of 74.9 degrees on 19 August 2009. Temperatures declined predictably at this point to a recorded season low of 45.3 degrees on 3 December 2009. Veligers were present in the whole water samples through the December sampling further reinforcing the need for chlorination in service water systems throughout the end of the year.

Historical whole-water densities have shown a rising trend in the numbers of veligers documented in the November/ December sampling events. Records during 1993 through 1995 for November and December showed a trend with sampling events reaching less than 1,000 ind. /m 3 , however, data from 2007-2009 shows at least one 3

November/December sampling event with veliger numbers exceeding 1,000 ind. /m individuals per event. Veliger numbers as a whole have increased in the period from 2007

- 2009. Although many parameters may be responsible for this trend, a noticeable factor in recent history is that lake temperatures are remaining warmer into the fall season than in the past, therefore allowing for spawning to occur late into the fall. Another potential contributing factor is an increase in the overall numbers of zebra mussels occurring in Lake Michigan, and potential changes in food supply as productivity and planktivorous fish populations fluctuate. Because of the late fall spawning in recent years, chlorination needs to continue into the late fall months to prevent mussel settlement and growth in plant service water systems. Let it be noted that higher peak numbers could potentially be partially attributed to the introduction of Quagga mussels into Lake Michigan. Quagga mussel veligers are indistinguishable from those of zebra mussels and a combination of the two may be responsible for elevated numbers of veligers especially during periods of lower water temperatures.

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The 2003 report concluded that yearly results in peak abundances make it difficult to predict when the peak abundance will occur each season other than estimating some time between July and October. Elevated levels in late June 2009 (51,750 ind. /m 3 ) have justified extending the peak season to include the month of June where high levels of veligers could possibly be encountered.

In summary, zebra mussel veligers were present in the water column on all sampling dates from 23 April through 3 December. Spawning commenced in early May and continued through the end of the sampling program. Peak veliger densities occurred at a maximum level of 733,500 ind./M 3 on 9 July 2009 with the second highest recorded level occurring on 25 June 2009 (51,750 ind. /M 3).

3.2 Artificial Substrate Sampling, Biocide Treatment, and Mechanical Cleaning 3.2.1 Circulating Water System Artificial Substrate Sampling Cumulative settlement was monitored in the intake forebay using a six-inch PVC pipe with a 3.5 inch inside diameter. The PVC pipe was set in the forebay on 4 December 2008 and retrieved on 12 November 2009 to determine the average density and size range for 12 months. The density on the substrate was 703,701 ind./m 2 . Individuals ranged from 120 pm-1 0,100 pm (0.12 mm -10.1 mm) and the mean size of fifty randomly selected individuals was 2,100 pm (2.1 mm). As in 2008, the time period of collection was designed to coincide with the annual fall intake crib cleaning to estimate the size and density of mussels the divers might encounter at the time of cleaning. For comparison, the sample substrate that was pulled in 2008 had a density of 272,026 individuals/m 2 and an average 14

size of 2,526 pm (2.5 mm). An explanation for this difference could be attributed to a large peak veliger density (733,500 ind./m 3 ) occurring in early July of 2009 that was more than twice the peak veliger density occurring in the fall of 2008. Smaller shell size and their ability to stack once a base layer of mussels is in place, could also account for increased numbers over 2008 results.

3.2.2 Service Water Systems and Miscellaneous Sealing and Cooling Water System Artificial Substrate Sampling The return sides (after systems' use) of the ESW and NESW systems and the MSCW system were monitored in the 2009 Mollusc Biofouling Monitoring Program. Chlorine is injected beneath each ESW pump suction. The ESW trains are typically cross-tied downstream of the chlorine injection point so that both ESW trains are served. A separate chlorine injection point, which is in the suction header, serves the NESW system and subsequently the MSCW system.

The plant's Zebra Mussel Monitoring & Control Program calls for continuous chlorination at 0.02-0.6 ppm total residual chlorine (TRC) of the service water and MSCW systems from May through November to correspond with the zebra mussel spawning season.

Cumulative settlement sampling and analysis was performed on a monthly basis in 2009.

Artificial substrate slides were installed on 30 April and ten slides per month were examined and not replaced. Results are shown in Table 3-2 and Figure 3-2.

Chlorination levels remained relatively consistent throughout the season with three noticeable exceptions. Levels dropped significantly and fluctuated in both U-1 ESW [C12]

15

East and U-2 ESW [C12] West through most of August. Levels in the same two systems were low as well in late October. Chlorine levels were once again below target levels for these two systems through much of November. Peak levels of veligers did not necessarily coincide with low chlorine levels. Chlorination was suspended from 29 September to 2 October when the plant experienced a large amount of lake debris influx from stormy lake conditions. This necessitated taking the Unit 1 circulating water pumps off line so that the debris could be removed from the traveling screens. The pumps were secured, so that chlorine residuals could remain in compliance with the Plant's discharge permit. This interruption in chlorination most likely caused the large spike seen on the U-2 ESW slides on 8 October when counts rose to 9,546 postveligers/m 2.

As mentioned in the 2008 report, the variability in ESW TRC was attributable to inadequacies in the liquid sodium hypochlorite injection design. The chlorine feed diffusers beneath the ESW pump bells were originally designed to feed gaseous chlorine. The permanent liquid sodium hypochlorite feed system installed in 2005 was tied into these original gaseous chlorine diffusers. It is believed that varying currents in the Plant's intake forebay affect the delivery of liquid sodium hypochlorite from the diffusers located below the ESW pump bells. This is most apparent when hypochiorite delivery is aligned to the west ESW pumps that are closer to the flow patterns in the intake forebay. The plant is in the process of raising the ESW pump bell heights to minimize sediment entrainment, and also plumbing the hypochlorite feed lines directly into the pump bells.

An explanation for low chlorine levels in the Unit 1 East ESW Pump header could be due to a missing end-plug in the chlorine sparger that runs beneath the Unit 1 East ESW Pump bell. This was discovered in a diving inspection of the Unit 1 ESW pump bay during the Unit 1 C22 Refueling Outage. This finding was documented in AR 2010-0656. This was 16

resolved during the 2010 Unit 1 C23 Refueling Outage when on 15 March 2010 the divers inserted an expandable plug in the end of the chlorine sparger per Temporary Modification 1- TM-10-13-RO.

The Unit 1 West ESW Pump bell height was raised with new chlorine plumbing installed on 3 August 2009 on Engineering Change EC-49340. The Unit 2 West ESW Pump bell height was raised with new chlorine plumbing installed on 27 January 2010 (EC-49339).

The Unit 1 East (EC-49341) and Unit 2 East (EC-48566) ESW Pump bells remain to be modified. These engineering changes should greatly improve chlorine delivery to the ESW system.

In summary, data indicated that peak levels were noted on 16 July 2009 for all locations.

Chlorine levels were within target levels, however, these high numbers were following the peak whole water levels, (733,500) on 9 July 2009. It is likely that the unusually high numbers of veligers present in the whole water system raised the numbers of veligers that settled out in subsequent weeks. It should be noted that the August sampling event had far fewer numbers than those immediately following the season high peak on 9 July 2009.

Low chlorine levels may have been responsible for elevated levels of veligers during the 13 August sampling in ESW-1. Chlorine levels had been below target ranges leading up to this sampling with numbers only elevated in ESW- 1 and the remaining sampling locations greatly reduced from the previous sampling event. Chlorination has proven effective in the historical data as well as in the 2008 sampling event. It appears that insufficient chlorine may have been present to combat the sheer numbers present during the 9 July 2009 peak, and high numbers in the subsequent weeks may be due to carry-over from the high number of veligers present at that time., As stated earlier, chlorine appears to have a direct correlation on the number of individuals observed in the water systems. When operating 17

properly the chlorination of system water appears to be an effective mechanism for the control of the zebra mussel veliger.

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Table 3-2 Density, Average Size, and Size Range of Settled Zebra Mussel Postveligers Collected on Cumulative Artificial Substrates Placed in the Forebay, in the Service Water Systems and Miscellaneous Sealing and Cooling Water System in the D.C. Cook Nuclear Plant in 2009.

Cumulative Samples Forebay NESW MSCW I ESW 2 ESW Avg. Avg. Avg. Avg. Avg.

Density Size Range Density Size Range Density Size Range Density Size Range Density Size Range Date (no/m2) (urn) (urn) (no/m2) (urn) (urn) (no/m2) (urn) (urn) (no/m2) (urn) (urn) (no/m2) (urn) (urn) 5/21/2009 906 132 120-160 853 133 120-160 746 130 110-150 320 130 130-150 6/25/2009 1547 151 100-261 1440 152 100-225 1,120 150 110-232 2,133 126 100-25!0 7/16/2009 3,626 220 140-350 3,946 215 140-310 5,706 249 140-430 3,626 260 140-420 8/13/2009 0 0 0 320 278 150-400 2,560 254 130-900 587 222 120-310 9/10/2009 373 195 150-240 320 194 140-260 1,013 192 140-300 587 163 140-200 280-10/8/2009 1,120 427 130-1210 0 0 0 0 0 0 9,546 523 1600 11/5/2009 266 748 480-1200 53 400 400 160 213 190-240 53 240 240 120-11/12/2009 703,701 2100 10100 - - - - - - - - - - - -

12/3/2009 - - - 0 0 0 0 0 0 0 0 0 0 0 0 19

Fig 3-2 2009 D.C. Cook Plant- Zebra Mussel Postveliger Cumulative Settlement in the Service Water Systems 10.00

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---"-2 NESW ns e" 7.00 --

-4 _ .

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3.2.3 Biocide Treatment There were no biocide treatments in 2009.

3.2.4 Mechanical Cleaning During the Unit 2 C18 (March-April) refueling outage, divers were employed to mechanically clean sand, zebra mussels, and debris from the walls and floors of the Unit 2 Circulating Water Intake Forebay and Unit 2 Condenser Inlet Tunnel. The Unit 2 Condenser Inlet Tunnel was cleaned in its entirety. The Unit 2 Intake Forebay was cleaned on the east (pump) side of the traveling screens (Figure 3-3). This included areas of the Unit 2 Circulating Water Pump and Unit 2 ESW Pump bays. The west side (lakeside) of traveling screen bays 2-2 and 2-3 and 2-4 and 2-5 were cleaned in their entirety to the trash racks. The trash racks in front of traveling screen bays 2-1 thru 2-7 were cleaned. The area further west of the trash racks extending to the west wall of the intake forebay was not cleaned as well as the west sides of traveling screen bays 1-7 and 2-1, and 2-6 and 2-7 to the trash racks.

In the Fall of 2009, the divers cleaned the intake crib velocity caps, ice guards, and trash racks of zebra mussels to remove the food source that attracts wild ducks to the intake cribs.

21

Figure 3-3 Screenhouse Intake Forebay Note: Lined out areas were cleaned during the U2C18 Refueling Outage.

Chapter 4 Summary and Recommendations 4.1 Summary The 2009 Mollusc Biofouling Monitoring Program was initiated on 23 April and continued through to 3 December 2009. Heaviest spawning activity started in late June and continued through mid-July. The most pronounced spawning peak occurred on 9 July 2009 with numbers peaking at 733,500 ind./m 3. Whole water veliger densities declined to levels, less than thirty times that (20,350 ind./M 3 ) on the subsequent sampling date of 16 July 2009. Levels dropped off significantly throughout the month of August. A slight secondary 3

peak occurred in late August and early September with levels ranging from 30,200 ind./M to 14,250 ind./M 3 spanning a 3-week time period. Veligers were observed through the end of the year 3 December 2009 sampling. The whole water densities show that there are substantial numbers of veligers in the forebay, from early May and through into December, indicating the need for effective and closely monitored chlorination in the service water systems throughout the reproductive season. Based on historical data, veligers have been present in system water from the April sampling through the end of December and it is still difficult to predict when peak abundance levels will occur each season. The 2003 report concluded that yearly results in peak abundances make it difficult to predict when the peak abundance will occur each season other than estimating sometime between July and October, however, with the significant numbers of veligers present in early June 2009, the peak season should be extended to include the entire month of June and possibly the very end of May. Therefore it is recommended that the current chlorination and monitoring program remain in place. Continued whole-water monitoring during the veliger spawning season will detect when these peak abundances occur.

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The intake forebay PVC sampler, collected on 12 November 2009, zebra mussel density was 703,701 ind./m 2 . Individuals ranged from 120pm-10,1001pm (0.120 mm - 10.10 mm) and the mean size of fifty randomly selected individuals was 2,100pm (2.1 mm). As in 2008, the time period of collection was designed to coincide with the annual fall intake crib cleaning to estimate the size and density of mussels the divers might encounter at the time of cleaning. For comparison, the sample substrate that was pulled in 2008 had a density of 272,026 individuals/m 2 and an average size of 2,526pm (2.5 mm).

The data indicates that the chlorination system, when operating correctly, was effective in preventing growth and prolonged settlement of postveligers in the service water systems.

The excessive number of whole water veligers documented on 9 July 2009, may have created a carry-over situation where such numbers could not be sufficiently controlled with the given levels of chlorine and subsequently may have resulted in higher numbers than otherwise collected on the 16 July cumulative artificial substrate slides. The effects of continuous chlorination eventually took their toll as witnessed by the gradual monthly decline in numbers of postveligers on the slides into December 2009.

Reports of visual heat exchanger inspections performed during the Unit 2 C18 Refueling Outage revealed no live mussel colonies growing within the heat exchangers.

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4.2 Recommendations Based on observations made during the course of this program and on previous historical data, it is recommended that:

- Whole-Water sampling should continue to be initiated in April to determine the presence of veligers in the water column, as currently implemented. The whole-water sampling frequency in 2005 was reduced from weekly to twice monthly in the months of June, October, and November to lessen the sampling burden and better target sampling based on previous years' spawning data. This sampling frequency reduction proved to be effective from 2005 through I

2009 as the major spawning peaks were still able to be captured, but with less sampling and analysis effort. This reduced sampling schedule should be continued as currently implemented.

- Studies of cumulative postveliger settlement should continue to be conducted from May through December, as currently implemented.

- Continuous chlorination maintained in the 0.02 -0.6 ppm target band should continue to run throughout the spawning season, as currently implemented.

Zebra mussel sampling and analysis in 2009 confirmed the efficacy of this target band.

- Chlorination system outages should be kept to a minimum and the chlorination system continued to be checked on a frequent basis to assure that target levels are being maintained.

- Chlorine levels should be checked in the system water to verify chlorine levels.

- Maintain daily bio-box flow checks to ensure bio-box conditions are representative of system conditions.

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- Chlorination data from all water systems (ESW, NESW, and MSCW) and temperature data should continue to be made available to allow meaningful interpretation of results.

26

References Lawler, Matusky, & Skelly Engineers LLP. 1995. Mollusc biofouling monitoring during 1994, Donald C. Cook Nuclear Plant: Final Report.

Great Lakes Environmental Center. 1996. A Zebra Mussel (Dreissena)

Monitoring Survey for the Donald C. Cook Plant April-December 1995: Final Report Lawler, Matusky,& Skelly Engineers LLP. 1997. Mollusc biofouling monitoring during 1996, Donald C. Cook Nuclear Plant: Final Report.

Lawler, Matusky,& Skelly Engineers LLP. 1998. Mollusc biofouling monitoring during 1997, Donald C. Cook Nuclear Plant: Final Report.

Lawler, Matusky, & Skelly Engineers LLP. 1999. Mollusc biofouling monitoring during 1998, Donald C. Cook Nuclear Plant: Final Report.

Grand Analysis. 1999. Zebra Mussel Monitoring Project for 1999.