CP-201200034, Comanche Peak, Units 1 and 2, Submittal of the Annual Non-Radiological Environmental Operating Report for 2011

Comanche Peak, Units 1 and 2, Submittal of the Annual Non-Radiological Environmental Operating Report for 2011

ML12128A028
Person / Time
Site:	Comanche Peak
Issue date:	04/30/2012
From:	Flores R, Madden F W Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-2012000348, TXX12062
Download: ML12128A028 (14)

Text

U Rafael Flores Luminant Power Senior Vice President P 0 Box 1002& Chief Nuclear Officer 6322 North FM 56 Lum inant rafael.flores@luminant.com Glen Rose, TX 76043 T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-2012000348 Log # TXX12062 April 30, 2012 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 2011

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 I and 2 Operating License Nos. NPF-87 and NPF-89. The report covers the period from January 1, 2011 through December 31, 2011 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 I and 2.If there are any questions regarding this report, contact Steve Dixon at (254) 897-5482 or Ashley Birdett at (254) 897-5751.Sincerely, Luminant Generation Company LLC Rafael Flores 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 U. S. Nuclear Regulatory Commission TXX-12062 Page 2 04/30/2012 Enclosure

-Annual Non-Radiological Environmental Operating Report for 2011 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 Enclosure I to TXX-12062 Comanche Peak Annual Non-Radiological Environmental Operating Report for 2011 LUMINANT POWER COMANCHE PEAK NUCLEAR- POWER PLANT UNITS 1 & 2 2011 ANNUAL ENVIRONMENTAL OPERATING REPORT (NON-RADIOLOGICAL)

FACILITY OPERATING LICENSE NOS. NPF-87 & 89 I I. INTRODUCTION This report describes implementation of the Environmental Protection Plan (EPP)for the calender year 2011 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 2011, the CPNPP Nonradiological Environmental Monitoring Program was effective in implementing and monitoring all CPNPP environmental regulatory commitments.

Program effectiveness in 2011 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 Ipotentially significant unreviewed environmental question.3. A list of nonroutine reports submitted in accordance with Subsection 5.4.2 of the EPP.2

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 2011.Based on the results of these activities, there were no observed adverse environmental impacts resulting from plant operation during 2011.1. Groundwater Pumpage As indicated in Table 2, groundwater pumpage during 2011 averaged 14.4 gals /min. (gpm) or 7,554,200 total gallons withdrawn for the year. This withdrawal rate represents a 8.4%increase from the 2010 average rate of 13.2 gpm. Groundwater withdrawal was highest in October at 17.9 gpm and lowest in January with an average monthly withdrawal rate of 10.5 gpm.Groundwater withdrawn during 2011 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 14.4 gpm for 2011 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 2011 was 23.46 gpm. Therefore, the average operational rates are 65.9% 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.3

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 2011 from a low level in July of 591.03ft.

Mean Sea Level (MSL) to a high level in December of 602.7ft. MSL. Overall, the water level in OB-3 during the reporting period (January through December) increased 0.77ft. (0.24m).The 2011 annual average groundwater levels in wells OB-3 and OB-4 were 597.86ft.MSL and 541.1ft. MSL, respectively.

A comparison of average levels for 2010 and 2011 for OB-3 is not possible due to blockage in the old OB-3 well which caused errors in previous readings.

In March, 2010, the existing OB-3 well experienced blockage and water level readings could not be taken. A new well was drilled and placed in service in July, 2010.The annual average level in well OB-4 was 541.1ft. MSL.However, the average annual water level during 2011 was 6.5ft.(1.98m) lower than the average annual water level during 2010 (Figure 2).It should be noted that OB-4 well data logger is maintained by the Texas Water Development Board (TWDB) and the trend difference between OB-3 and OB-4 is uncertain.

OB-3 well measurements are taken with a well probe, while OB-4 are taken by a data logger. The readings for OB-4 well appear suspect and the station is working with the TWDB to confirm OB-4 readings.3. Surface Water Treatment System Operation The station's Water Treatment System processed 235,998,800 total gallons (449 gpm) of surface water during 2011 for plant process use. There were two outages during 2011 that required reporting in accordance with Section 4.2.2 of the EPP. (e)Indicates June and July were a close estimate during the microfilter installation and testing. The microfilter startup and site acceptance testing was performed in August and September with additional testing in December with the installation of the break tank. December had a high flow due to the flushing and testing.4 The following is a summary list of monthly surface water usage: MONTH SURFACE WATER PROCESSED (GALS.)JANUARY 12,155,400 FEBRUARY 13,619,300 MARCH 12,699,000 APRIL 15,522,200 MAY 18,676,900 JUNE 20,000,000 (e)JULY 20,000,000 (e)AUGUST 18,418,000 SEPTEMBER 18,712,000 OCTOBER 16,392,000 NOVEMBER 18,177,000 DECEMBER 50,997,000 TOTAL 235,998,800 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 IlllE, there were no other nonroutine reports submitted under this subsection.

5.

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 2011.The following is a summary list of correspondence pertaining to DMRs and TPDES permit related documents.

Month Monitored Log Number/Date January TXE-11018 02/15/2011 February TXE-11040 03/14/2011 March TXE-10050 04/13/2011 April TXE-10057 05/09/2011 May TXE-10077 06/13/2011 June TXE-10087 07/11/2011 TXX- 10088 (Biomonitoring Report for 01/01/2011-06/30/2011).

July TXE-11101 08/15/2011 August TXE-11117 09/14/2011 September TXE-11131 10/13/2011 October TXE-11137 11/09/2011 November TXE-11142 12/05/20 11 December TXE-12005 01/09/2012 December_

_ TXE-12006 (Biomonitoring Report for 07/01/2011

-12/31/2011) 6

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 Ceriodaphnia dubia 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 was one TPDES wastewater discharge permit noncompliance in 2011. The weekly pH analysis of Outfall 004 was 3.0 from a grab sample obtained 8/16/2011.

This was non-compliant with the TPDES wastewater permit which allows 6.0 to 9.0. This condition appears to have resulted from a pH undulation of an unknown source within the basin. A sample taken immediately following the pH measurement, revealed a compliant pH. No further actions were required based on a single, one time occurrence.

This condition did not constitute a regulatory reportable event, instead was documented in the monthly Discharge Monitoring Report (DMR) as required by the TPDES Wastewater Permit.4. There was one reportable spill during 2011. An HEDP storage tank in the Station Service Water Chlorination Building, supply line to the injection pump broke and approximately 1000 gallons of product, Bulab 7016, spilled into the berm. The berm is leaking due to a failed bottom seam and approximately 10-15 gallons of HEDP spilled from the tank berm to adjacent limestone gravel.The material neutralized upon contact with the gravel. Immediate actions taken were isolation of the product line and spill prevention placed in the leak path., The spill was reported to TCEQ and a report sent to the EPA.7 TABLE 1 2011

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 292.2 601.93 297.7 550.18 February 292.7 601.43 297.7 550.18 March 293.3 600.83 299.15 548.73 April 294.2 599.93 300.62 547.26 May 294.7 599.43 300.57 547.31'June 300.7 593.43 309.7 538.18 July 303.1 591.03 314.11 533.77 August 301.75 592.38 318.2 529.68 September 300.8 593.33 318.35 529.53 October 296.45 597.68 313.73 534.15 November 293.97 600.16 308.24 539.64 December 291.43 602.7 303.34 544.54 ANNUAL GROUNDWATER LEVEL CHANGE FOR 2011: Well OB-3: 292.2 ft. -291.43 ft. = 0.77 ft. = 0.24 m (increase)

Well OB-4: 297.7 ft. -303.34 ft. = -5.64 ft. = -1.72 m (decrease)

NOTES: (1)(2)Depth to water table (ft.)Water table elevation (ft.) Mean Sea Level (MSL)8 Table 2

SUMMARY

OF GROUNDWATER PUMPAGE For 2011 PLANT WELL 1 PLANT WELL 2 NOSF WELL 1 NOSF WELL 2 REC/TRAINING TOTALS DAYS Month Total Avg. Total Avg. Total Avg. Total Avg. Total Avg. Total Avg. BETWEEN Gallons Gallons/ Gallons Gallons/ Gallons Gallons/ Gallons Gallons/ Gallons Gallons/ Gallons Gallons/ READINGS Minute Minute Minute Minute Minute Minute January 0 0.0 0 0.0 306,600 6.9 161,100.0 3.6 1,700 0.0 469,400 10.5 31 February 0 0.0 0 0.0 300,500 7.5 167,000 4.1 1,800 0.0 469,300 11.6 28 March 10,400 0.2 0 0.0 282,200 6.3 318,400 7.1 2,200 0.0 613,200 13.7 31 April 583,600 13.5 0 0.0 82,700 1.9 70,500 1.6 2,400 0.1 739,200 17.1 30 May 483,700 10.8 0 0.0 60,600 1.4 53,100 1.2 2,700 0.1 600,100 13.4 31 June 612,700 14.2 0 0.0 50,200 1.2 56,400 1.3 1,200 0.0 720,500 16.7 30 July 399,100 8.9 0 0.0 81,100 1.8 58,100 1.3 1,800 0.0 540,100 12.1 31 August 178,600 0 0 0.0 221,900 5.0 165,200 3.7 2,900 0.1 568,600 12.7 31 September 686,500 15.9 0 0.0 53,600 1.2 50,400 1.2 2,300 0.1 792,800 18.4 30 October 711,800 15.9 0 0.0 46,500 1.0 41,400 0.9 1,200 0.0 800,900 17.9 31 November 531,100 0 0 0.0 84,400 2.0 70,000 1.6 1,100 0.0 686,600 15.9 30 December 453,600 10.2 0 0.0 42,700 1.0 56,100 1.3 1,100 0.0 553,500 12.4 31 Total 387,592 7.5 0 [ 0.0 134,417 [ 3.1 105,642] 2.4 1 1,867] 0.0 7,554,200 14.4 365 9 FIGURE 1

SUMMARY

OF GROUNDWATER PUMPAGE 1976 THROUGH 2011 (GPM)qI0 qq '*Lr 011 IP 1. 2/8/90 -Unit #1 Operational.

Discontinued using treated surface water for potable use.2. 2/2/93 -Unit #2 Operational FIGURE 2 ANNUAL AVERAGE GROUNDWATER LEVEL 1980 through 2011 Mean Sea Level (MSL)665 -.645-625-605 -l OB-3OB-4 585-565-545 5 2 5 .............. ... .... i eO~~~~b el , qrd0 C ,l