CP-201000645, Submittal of the Annual Non-Radiological Environmental Operating Report for 2009

Submittal of the Annual Non-Radiological Environmental Operating Report for 2009

ML101241196
Person / Time
Site:	Comanche Peak
Issue date:	04/29/2010
From:	Flores R Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201000645, TXX10066
Download: ML101241196 (13)

Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Luminant rafael.flores@luminant.com Glen Rose, TX 76043 T 254 897 5550 C'817 559 0403 F 254 897 6652 CP-201000645 Log # TXX10066 April 29, 2010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445/446 SUBMITTAL OF THE ANNUAL NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FOR 2009.

Dear Sir or Madam:

Luminant Generation Company LLC (Luminant Power) hereby submits for Comanche Peak Nuclear Power Plant (CPNPP), the enclosed copy of the Annual Non-Radiological Environmental Operating Report for the CPNPP Radiological Environmental Monitoring Program. This report is submitted pursuant to Appendix B of the CPNPP Unit 1 and 2 Operating License Nos. NPF-87 and NPF-89. The report covers the period from January 1, 2009 through December 31, 2009 and summarizes the results of measurements and analysis of data obtained from samples collected during this interval.

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

If there are any questions regarding this report, contact Steve Dixon at (254) 897-5482 or Bruce Turner at (254) 897-8901.

Sincerely, Luminant Generation Company LLC Rafael Flores By: 2f272L&

Fred W. Madden Director, Oversight & Regulatory Affairs A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway - Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre. South Texas Project

• Wolf Creek KJ(LI~

U. S. Nuclear Regutatory Commission TXX-10066 Page 2 04/29/2010 Enclosure - Annual Non-Radiological Environmental Operating Report for 2009 Attachments - Figure 1, "Summary of Groundwater Pumpage 1975 through 2009 (gpm)

Figure 2, "Annual Average Groundwater Level 1980 through 2009 c- E. E. Collins, Region IV L. K. Gibson, NRR Resident Inspectors, Comanche Peak A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway Comanche Peak - Diablo Canyon - Palo Verde

• San Onofre- South Texas Project Wolf Creek

LUMINANT POWER COMANCHE PEAK NUCLEAR POWER PLANT UNITS 1 & 2 2009 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 2009 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 2009, the CPNPP Nonradiological Environmental Monitoring Program was effective in implementing and monitoring all CPNPP environmental regulatory commitments. Program effectiveness in 2009 was substantiated by Luminant Corporate environmental audits and compliance evaluations of the CPNPP environmental program.

II. 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.

Ill. 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 2009.

Based on the results of these activities, there were no observed adverse environmental impacts resulting from plant operation during 2009.

1. Groundwater Pumpage As indicated in Table 2, groundwater pumpage during 2009 averaged 14.3 gals /min. (gpm) or 7,488,200 total gallons withdrawn for the year. This withdrawal rate represents a 7.5%

increase from the 2008 average rate of 13.3 gpm. Groundwater withdrawal was highest in October at 20.3 gpm and lowest in April with an average monthly withdrawal rate of 10.8 gpm.

Groundwater withdrawn during 2009 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 14.3 gpm for 2009 represents 11.3% 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 9.1 % 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 pumpage for the period 1990 through 2009 was 24.23 gpm.. Therefore, the average operational rates are 64.8% 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 1, the groundwater level in the on-site observation well OB-3 (intersection of Highway 56 and the Plant Access Road) fluctuated during 2009 from a low level in August of 513.43ft. Mean Sea Level (MSL) to a high level in December of 517.73ft. MSL. Overall, the water level in OB-3 during the reporting period (January through December) increased 1.4 ft.

(0.43m).

The 2009 annual average groundwater levels in wells OB-3 and OB-4 were 515.63ft.MSL and 542.97ft. MSL,respectively. These average levels demonstrated a decrease of 1.4 ft (0.43m) for OB-3 and a decrease of 1.45 ft. (0.44m) for OB-4 from the respective average 2008 levels (Figure 2).

As illustrated by Table 2, ground water levels increased during the reporting period. This increase coincided with increased rainfall of 37.26 inches during 2009 as compared to 24.18 inches in 2008.

3. Surface Water Treatment System Operation The station's Water Treatment System processed 265,317,000 total gallons (505 gpm) of surface water during 2009 for plant process use. There were no outages during 2009 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 SUFP AE

~PROCESSED (GALS,)

JANUARY 21,351,000 FEBRUARY 20,477,400 MARCH 23,027,900 APRIL 20,996,800 MAY 16,491,300 JUNE 21,021,200 JULY 23,656,500 AUGUST 21,942,200 SEPTEMBER 24,416,100 OCTOBER 25,862,200 NOVEMBER 20,719,000 DECEMBER 25,355,400 TOTAL 265,317,000 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.

D. Nonroutine Reports Submitted In Accordance With Subsection 5.4.2 Other than those nonroutine reports identified in section Ill.E, there were 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 2009.

The following is a summary list of correspondence pertaining to DMRs and TPDES permit related documents.

Month Log Number/Date Monitored January TXE-09034 02/12/2009 February TXE-09047 03/16/2009 March TXE-09063 04/13/2009 April TXE-09073 05/07/2009 May TXE-09080 06/08/2009 June TXE-09088 07/08/2009 TXX-09091 (Biomonitoring Report for 01/01/2009-06/30/2009)

July TXE-09102 08/12/2009 August TXE-09116 09/14/2009 September TXE-09132 10/15/2009 October TXE-09140 11/16/2009 November TXE-09147 12/14/2009 December TXE-10008 01/14/2010 TXE-100 11 (Biomonitoring Report for 07/01/2009-12/31/2009)

2. Current biomonitoring in reduced status in accordance with TPDES Permit. The 1/year 7-day Fathead Minnow (Pimephales promelas) Survival and Growth Test was passed. The chronic testing using an invertebrate species is required 1/6 months. The first 7-day Ceriodaphniadubia Survival and Reproduction Test was invalid due to insufficient neonate production resulting from elevated Total Dissolved Solids (TDS) in the source water, Squaw Creek Reservoir. In accordance with an agreement with TCEQ, a 4-day Daphnia magna Survival and Growth Test was conducted and passed. Due to continued elevated source water TDS in the autumn, the D. magna test was again utilized and passed during the second monitoring period. Acute 24-hour screen tests with appropriate invertebrates and the fathead minnow were also passed during each semi-annual monitoring period. The Company currently has a TPDES Permit Application pending which includes the agreed alternate invertebrate species test, the 4-day D. magna Survival/Growth test for use when the reservoir TDS is elevated.

3. There were no TPDES wastewater discharge permits or noncompliances in 2009.

4. There were-also no reportable spills during 2009.

TABLE 1 2009

SUMMARY

OF GROUNDWATER LEVELS IN OBSERVATION WELLS WELL OB-3 WELL OB-4 MONTH (G-3) (G-4)

DEPTH (1) MSL (2) DEPTH (1) MSL (2)

January 277.5 516.33 301.37 546.51 February 279.3 514.53 305.32 542.56 March 277.2 516.63 300.54 547.34 April 276.7 517.13 299.67 548.21 May 277.3 516.53 299.68 548.20 June 279.3 514.53 303.28 544.60 July 279.9 513.93 312.13 535.75 August 280.4 513.43 314.98 532.90 September 279.4 514.43 311.73 536.15 October 278.2 515.63 307.61 540.27 November 277.1 516.73 302.64 545.24 December 276.1 517.73 299.92 547.96 ANNUAL GROUNDWATER LEVEL CHANGE FOR 2009:

Well OB-3: 277.5 ft. - 276.1 ft. = 1.4 ft. = 0.43 me(increase)

Well OB-4: 301.37 ft. - 299.92 ft. = 1.45 ft. = 0.44 m (increase)

NOTES:

(1) Depth to water table (ft.)

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

Table 2

SUMMARY

OF GROUNDWATER PUMPAGE For 2009 PLANT WELL 1 PLANT WELL 2 NOSF WELL 1 NOSF WELL 2 REC/TRAINING TOTALS NO. OF DAYS Avg. Avg. Avg. Avg. Avg. Avg. BETWEEN READINGS Month Total Total Total Total Total Total Gals. Gal. Gals. Gal. Gals. Gal. Gals. Gal. Gals. Gal. Gals. Gal.

Per Per Per Per Per Per Min. Min. Min. Min. Min. Min.

January 335,500 7.5 138200 3.1 47,300 1.1 41,300.0 0.9 1,900 0.0 564,200 12.6 31 February 150,900 3.7 443,100 11.0 41,000 1.0 38,800 1.0 2,100 0.1 675,900 16.8 28 March 396,200 8.9 0 0.0 39,900 0.9 45,900 1.0 3,300 0.1 485,300 10.9 31 April 141,100 3.3 258500 6.0 32,700 0.8 33,100 0.8 2,600 0.1 468,000 10.8 30 May 358,900 8.0 63,400 1.4 23,200 0.5 37,500 0.8 2,300 0.1 485,300 10.9 31 June 429,300 9.9 0 0.0 42,100 1.0 86,300 2.0 1,100 0.0 558,800 *12.9 30 July 212,300 4.8 243,700 5.5 82,800 1.9 54,400 1.2 2,400 0.1 595,600 13.3 31 August 426,500 0 246,600 5.5 65,700 1.5 93,600 2.1 2,300 0.1 834,700 18.7 31 September 646,700 15.0 8,200 0.2 57,100 1.3 54,100 1.3 1,700 0.0 767,800 17.8 30 October 826,200 18.5 0 0.0 39,000 0.9 39,500 0.9 1,700 0.0 906,400 20.3 31 November 542,000 0 0 0.0 35,000 0.8 33,200 0.8 1,700 0.0 611,900 14.2 30 December 459,700 10.3 0 0.0 34,500 0.8 38,900 0.9 1,200 0.0 534,300 12.0 31 Total 11410,4421 7.5]1 116,808 1 2.711 45,025 1.0II 49,7171 1.11 2,0251 0.01 7,488,200 14.3 365

Attachment to TXX-10066 FIGURE 1

SUMMARY

OF GROUNDWATER PUMPAGE 1975 THROUGH 2009 (GPM)

Annual Groundwater Pumpage 200-180-160-140-120-100-0~ 80 60 40 20 n

Oh 4 Oh ~

Oh ~'

Oh '~

Oh 4' Oh (~%

Oh 8'

Oh o~'

Oh ~

Oh Oh Oh ~D P

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-10066 FIGURE 2 ANNUAL AVERAGE GROUNDWATER LEVEL 1980 through 2009 Mean Mean Sea Level (MSL) 620 600-580-560-OB-3 540-OB-4 520-500-480-46C c;l' O~O c9 oft- o~ o"~ &