CP-200800655, Submittal of the Annual Non-Radiological Environmental Operating Report for 2007

Submittal of the Annual Non-Radiological Environmental Operating Report for 2007

ML081340349
Person / Time
Site:	Comanche Peak
Issue date:	05/06/2008
From:	Flores R Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-200800655, TXX-08075
Download: ML081340349 (12)

Text

U Rafael Site Vice Flores President rafael.flores@luminant.com Luminant P 0 Box 1002Power 6322 North FM 56 Luminant Glen Rose, TX 76043 T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-200800655 Log # TXX-08075 May 6,2008 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445/446 SUBMITTAL OF THE ANNUAL NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FOR 2007

Dear Sir or Madam:

Luminant Generation Company LLC (Luminant Power) hereby submits for Comanche Peak Steam Electric Station, herein referred to as Comanche Peak Nuclear Power Plant (CPNPP), the enclosed copy of the Annual Non-Radiological Environmental Operating Report for the CPSES Radiological Environmental Monitoring Program. This report is submitted pursuant to Appendix B of the CPSES Unit 1 and 2 Operating License Nos. NPF-87 and NPF-89. The report covers the period from January 1, 2007 through December 31, 2007 and summarizes the results of measurements and analysis of data obtained from samples collected during this interval.

If there are any questions regarding this report, contact Neil Harris at (254) 897-5449 or Bruce Turner at (254) 897-8901.

This communication contains no new licensing basis commitments regarding CPNPP Units 1 and 2.

Sincerely, Luminant Generation Company LLC R~af1ael Flores Site Vice President

U. S. Nuclear ReguLatory Commission TXX-08075 Page 2 05/06/2008 Enclosure - Annual Non-Radiological Environmental Operating Report for 2007 c- E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak

TXU GENERATION COMPANY LP (TXU POWER)

COMANCHE PEAK NUCLEAR POWER PLANT UNITS 1 & 2 2007 ANNUAL ENVIRONMENTAL OPERATING REPORT (NON-RADIOLOGICAL)

FACILITY OPERATING LICENSE NOS. NPF-87 & 89 I

INTRODUCTION This report describes implementation of the Environmental Protection Plan (EPP) for the calender year 2007 as required by Appendix B to Facility Operating License Nos. NPF-87

& 89 for Comanche Peak Nuclear Power Plant (CPNPP) for Units 1 & 2.

During 2007, the CPNPP Nonradiological Environmental Monitoring Program was effective in implementing and monitoring all CPNPP environmental regulatory commitments.

Program effectiveness in 2007 was substantiated by Luminant Corporate environmental audits and compliance evaluations of the CPNPP environmental program.

SCOPE Section 5.4.1 of the EPP requires that CPNPP submit to the NRC an Annual Environmental Operating report that shall address the following environmental protection activities:

A. Summaries and analyses of the results of the environmental protection activities required by Section 4.2 of the EPP, 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 plant operation on the environment. If harmful effects or evidence of trends toward irreversible damage to the environment are observed, a detailed analysis of the data and a proposed course of mitigating action is required.

Section 4.2 of the EPP pertains to results from:

1. Groundwater levels and station water use monitoring.

2. Water treatment facility outages impact assessment and reporting.

B. The report shall also include:

1. A list of EPP noncompliances and the associated corrective actions.

2. A list of all changes in station design and operation, tests, and experiments made in accordance with Subsection 3.1 of the EPP which involved a potentially significant unreviewed environmental question.

3. A list of nonroutine reports submitted in accordance with Subsection 5.4.2 of the EPP.

4. A summary list of Texas Pollutant Discharge Elimination System (TPDES) permit related reports relative to matters identified in Subsection 2.1 of the EPP which were submitted to the Texas Commission on Environmental Quality (TCEQ) during the report period. Subsection 2.1 of the EPP pertains to aquatic matters that are addressed by the effluent limitations, and the monitoring requirements contained in the TCEQ TPDES station wastewater discharge permit.

III. RESULTS OF ACTIVITIES A. As required by Subsection 4.2 of the EPP, the following are summaries and analyses of the environmental protection activities during 2007. Based on the results 2

of these activities, there were no observed adverse environmental impacts resulting from plant operation during 2007.

Groundwater Pumpage As indicated in Table 1, groundwater pumpage during 2007 averaged 15.8 gals./min. (gpm) or 8,279,900 total gallons withdrawn for the year. This withdrawal rate represents a 8.8% decrease from the 2006 average rate of 17.3 gpm. Groundwater withdrawal was highest in February at 25.1 gpm and lowest in June and December with an average monthly withdrawal rate of 12.4 gpm.

Groundwater withdrawn during 2007 was used primarily for potable and sanitary purposes with only a very small amount used as make-up to the plant fire protection system. No groundwater was used to supplement the station's Surface Water Treatment System.

The average annual pumpage rate of 15.8 gpm for 2007 represents 12.4%

of the predicted operational pumpage (127 gpm) identified in Section 3.3 of the Station's Environmental Report - Operational License Stage. This rate also represents approximately 10.0 % of the actual average withdrawal rate (158 gpm) reported in the Station's Final Environmental Statement -

Operating License Stage (Section 5.3.1.2) for the period 1975 to May 1979.

The combined annual rate for all recorded pre-operational groundwater pumpage averaged 68.8 gpm, while the average operational pum page for the period 1990 through 2007 was 24.7 gpm. Therefore, the average operational rates are 64.1% less than the groundwater pumpage during the preoperational period. Figure 1 illustrates the annual fluctuation of groundwater withdrawal over the entire pre-operational and operational period.

2. Groundwater Levels As indicated in Table 2, the groundwater level in the on-site observation well OB-3 (intersection of Highway 56 and the Plant Access Road) fluctuated during 2007 from a high level in July of 521.93 ft. Mean Sea Level (MSL) to a low level in January of 516.63 ft. MSL. Overall, the water level in OB-3 during the reporting period (January through December) decreased 3.1 ft.

(0.94m).

The 2007 annual average groundwater levels in wells OB-3 and OB-4 were 519.56ft. MSL and 550.23ft. MSL, respectively. These average levels demonstrated a increase of 3.5 ft. (1.07m) for OB-3 and a increase of 6.66 ft.(2.74m) for OB-4 from the respective average 2006 levels (Figure 2).

As illustrated by Table 2, ground water levels increased during the reporting period. This increase coincided with increase rainfall of 37.7 inches during 2007 as compared to 28.9 inches in 2006.

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3. Surface Water Treatment System Operation The station's Water Treatment System processed 221,263,300 total gallons (421 gpm) of surface water during 2007 for plant process use. There were no outages during 2007 that required reporting in accordance with Section 4.2.2 of the EPP.

The following is a summary list of monthly surface water usage:

MONTH

_ I?*'SURF ACE 'WATER PROCESSED (GALS.)

JANUARY 18,841,800 FEBRUARY 17,646,600 MARCH 16,079,700 APRIL 20,095,700 MAY 19,327,185 JUNE 17,978,255 JULY 16,617,260 AUGUST 17,512,400 SEPTEMBER 18,117,900 OCTOBER 19,429,000 NOVEMBER 19,092,000 DECEMBER 20,525,500 TOTAL 221,263,300 B. EPP Noncompliance and Corrective Actions - Subsection 5.4.1(1)

There were no noncompliances with the requirements of the EPP during the reporting period.

C. Changes In Station Design or Operation, Tests, and Experiments Made In Accordance With Subsection 3.1 Which Involved A Potentially Significant Unreviewed Environmental Question.

There were no changes in station design, operation, tests or experiments conducted during the reporting period that are reportable under this subsection.

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D. Nonroutine Reports Submitted In Accordance With Subsection 5.4.2 Otherthan those nonroutine reports identified in section Ill.E, therewere no other nonroutine reports submitted under this subsection.

E. Texas Pollutant Discharge Elimination System (TPDES) Permit-Related Reports Relative To Matters Identified In Subsections 2.1 and 5.4.1

1. Routine monthly Discharge Monitoring Reports (DMR) for all wastewater outfalls were submitted to the Texas Commission on Environmental Quality (TCEQ) for each month during 2007. The following is a summary list of correspondence pertaining to DMRs and TPDES permit related documents.

MONTH LGNMBRDT MONITORED6LONUBRAT JANUARY TXE-07041-02/20/07

,FEBRUARY TXE-07062-03/20/07 MARCH 6 TXE-07077-04-20-07 APRIL TXE-07093-05/22/07 MAY TXE-07104-06/20/07 JUNE TXE-07116-07/19/07 JULY TXE-07125-08/16/07 TXE-07119-07/19/08 AUGUST TXE-07135-09/20/07 SEPTEMBER TXE-07144-10/19/07 OCTOBER TXE-07166-11/15/07 NOVEMBER 6 TXE-07185-12/19/07 DECEMBER. TXE-08099-01/16/08 TXE-08010-01/16/08

2. Routine biomonitoring was conducted semi-annually in accordance with the TPDES Permit. The tests using the fathead minnow (Pimephales promelas) were passed in accordance with all criteria. The Ceriodaphnia dubia tests continued to be invalid due to insufficient survival and neonate production in the control (intake) water. On 2 May 2008, the Company submitted a request to the Texas Commission on Environmental Quality (TCEQ).

for an alternate invertebrate species, Daphnia magna, for use in testing when the reservoir Total Dissolved Solids (TDS) concentrations are elevated. Successful testing was performed with this species with TCEQ approval during the 4th Quarter. This alternative test species is expected to be included as an option for testing at elevated TDS concentrations in the forthcoming TPDES Permit renewal.

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3. There were no TPDES wastewater discharge permit noncompliances in 2007.

4. There were also no reportable spills during 2007.

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TABLE 1

SUMMARY

OF GROUNDWATER PUMPAGE For 2007

' RE/TRINIG . OTAS "NO. OF PLANT WELL 1 PLANT WELL2

___ __ __ j NOSF WELL1-NOSF WELL 2

__ _ .1_

RETRAIN

_ -___j TOTALSNOA

~DAYS, . , . ..BETW EEN Total Avg. vg. Total Avg. Total Gals. Avg., Total Gals. Avg. Total Gals. Avg.. READINGS MONTH Gals. _

J_ _ Gal. , Gal. _ Gals.

_ Gal. _ _ _ _ Gal. _ _ _ _ _ Gal.

Per Mi. PerMi. . Per Mi Per Per Min. Pe Min.

January 396,200 8.9 339,600 7.6 57,900 1.3 64,400 1.4 2,200 0.0 860,300 19.3 31 February 623,500 15.5 256,500 6.4 65,000 1.6 65,000 1.6 1,300 0.0 1,011,300 25.1 28 March. 650,000 14.6 239,200 5.4 58,900 1.3 61,000 1.4 1,200 0.3 1,010,300 22.6 31 April 440,000 10.2 348,900 8.1 39,000 0.9 32,100 0.7 1,200 0.1 861,200 19.9 30 May 499,900 11.2 0 0.0 52,200 1.2 56,500 1.3 1,500 0.1 610,100 13.7 31 June 181,600 4.2 245,100 5.7 52,600 1.2 55,700 1.3 1,500 0.1 536,500 12.4 30 July 71,400 1.6 593,800 13.3 39,500 0.9 48,800 1.1 1,400 <0.1 754,900 16.9 31 August 324,600 7.3 0 0.0 101,300 2.3 59,400 1.3 1,800 0.1 487,100 10.9 31 September 62,100 1.4 308,800 7.1 40,800 0.9 38,400 0.9 1,700 <0.1 451,800 10.5 30 October 345,500 7.7 155,600 3.5 40,700 0.9 40,200- 0.9 1,200 <0.1 583,200 13.1 31 November 395,200 9.1 78,900 1.8 42,700 1.0 40,400 0.9 1,700 <0.1 558,900 12.9 30 December 14,800 0.3 461,300 10.3 41,200 0.9 35,200 0.8 1,800 <0.1 554,300 12.4 31 TOTA - 4,0,0 7][3,:027,700 j 5.8 6=31,800 j 1.2 597,100 j 1.1 18,500 0.1 8,279,900. 15.8 IF 365 7

I 'y TABLE 2 2007

SUMMARY

OF GROUNDWATER LEVELS IN OBSERVATION WELLS WELL-.OB-*3.MH* WELL -4)

MONTH (G-3)(G4

[DEPTH-(1) MSL (2) DEPTH (1) MSL(2)

January 277.2 516.63 302.01 545.87 February 276.8 .517.03 300.97 546.91 March 276.1 517.73 299.94 547.94 April,'. 274.82 519.01 298.13 549.75 May 273.7 520.13 296.3 551.58.

June.%. 272.45 521.38 294.98 552.90 July , 271.9 521.93 294.11 553.77

,August,, 272.55 521.28 296.32 551.56 September 274.2 519.63 297.57 550.31 October 273.75 520.08 298.54 549.34 November 273.67 520.16 297.56 550.32 December 274.10 519.73 295.35 552.53 ANNUAL GROUNDWATER LEVEL CHANGE FOR 2005:

Well OB-3: 277.2 ft. - 274.1 ft = 3.1ft. = 0.94 m (increase)

Well OB-4: 302.01 ft. - 295.35 ft = 6.66 ft. = 2.03 m (increase)

NOTES:

(1) Depth to water table (ft.)

(2) Water table elevation (ft.) Mean Sea Level (MSL) 8

Attachment to TXX-OSO7S Page 8of 9 FIGURE 1

SUMMARY

OF GROUNDWATER PUMPAGE 1975 THROUGH 2007 (GPM)

Annual Groundwater Pumpage 200 180 160 140 -4n 120 100 0.

80 60 40 20 0

Oh

• 1 Oh Nv 4' ~ ~' ~ 4410

1. 2/8/90 - Unit #1 Operational. Discontinued using treated surface water for potable use.

2. 2/2/93 - Unit #2 Operational

Attachment to TXX- O0*>15 Page 9 of 9 FIGURE 2 ANNUAL AVERAGE GROUNDWATER LEVEL 1980 through 2007 (MSL)

Mean Sea Level Mean Sea Level (MSL) 620 f

Ann 580 560 OB-3 540 OB-4 520 500 480 I 46C"a . . I . .

q;o rell41 41