CPSES-200201771, Environmental Protection Plan Annual Environmental Operating Report for 2001

Environmental Protection Plan Annual Environmental Operating Report for 2001

ML021330055
Person / Time
Site:	Comanche Peak
Issue date:	04/29/2002
From:	Terry C TXU Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CPSES-200201771, TXX-02084
Download: ML021330055 (12)

Text

TXU TXU Energy C.Lance Terry Comanche Peak Steam Senior Vice President &

Electric Station Principal Nuclear Officer P.O. Box 1002 (E01)

Glen Rose, TX 76043 Tel: 254 897 8920 Fax: 254 897 6652 lance.terry@txu.com CPSES-200201771 Log # TXX-02084 RP-52 April 29, 2002 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 ENVIRONMENTAL PROTECTION PLAN ANNUAL ENVIRONMENTAL OPERATING REPORT FOR 2001 Gentlemen:

Pursuant to Section 5.4.1 of the Environmental Protection Plan (Appendix B to CPSES Unit 1 and Unit 2 Facility Operating License Nos. NPF-87 and NPF-89, respectively), attached is the CPSES Annual Environmental Operating Report for year 2001.

If you have any questions, please contact Mr. Bruce Turner at (254) 897-8901.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak - Diablo Canyon - Palo Verde ° South Texas Project - Wolf Creek

A TXU CPSES-200201771 TXX-02084 Page 2 of 2 This communication contains no new licensing basis commitments regarding CPSES Units 1 and 2.

Sincerely, TXU Generation Company LP By: TXU Generation Management Company LLC Its General Partner C. L. Terry Senior Vice President & Principal Nuclear Officer 6, Q , 4ý By: 6ý ý RogcVD. Walker Regulatory Affairs Manager CLW/clw Attachment c- E. W. Merschoff, Region IV w/attch.

W. D. Johnson, Region IV (clo)

D. H. Jaffe, NRR (clo)

Resident Inspectors, CPSES w/attch.

TXU ELECTRIC COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 & 2 2001 ANNUAL ENVIRONMENTAL OPERATING REPORT (NON-RADIOLOGICAL)

FACILITY OPERATING LICENSE NOS. NPF-87 & 89

Attachment to TXX-02084 Page 2 of 10 I. INTRODUCTION This report describes implementation of the Environmental Protection Plan (EPP) for the calender year 2001 as required by Appendix B to Facility Operating License Nos. NPF-87

& 89 for Comanche Peak Steam Electric Station (CPSES) for Units 1 & 2.

During 2001, the CPSES Nonradiological Environmental Monitoring Program was effective in implementing and monitoring all of CPSES's environmental regulatory commitments.

Program effectiveness was substantiated by environmental audits conducted in 2001 by in-house compliance visits by TXU Environmental, Health, and Safety and compliance evaluations conducted by the CPSES Nuclear Overview Department. Also, the Texas Natural Resource Conservation Commission (TNRCC) performed a regulatory inspection of CPSES's wastewater management program. One finding was identified pertaining to algae growth on the sewage treatment system clarifier. This finding is being appealed.

I1. SCOPE Section 5.4.1 of the EPP requires that CPSES 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 National Pollutant Discharge Elimination System (NPDES) permit related reports relative to matters identified in Subsection 2.1 of the EPP which were submitted to the EPA Region VI 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 EPA NPDES station wastewater discharge permit.

Attachment to TXX-02084 Page 3 of 10 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 2001. Based on the results of these activities, there were no observed adverse environmental impacts resulting from plant operation during 2001.

1. Groundwater Pumpage As indicated in Table 1, groundwater pumpage during 2001 averaged 19.7 gals./min. (gpm) or 10,353,900 total gallons withdrawn for the year. This withdrawal rate represents a 15% decrease from the 2000 average rate of 23.1 gpm. Groundwater withdrawal was highest in January at 26.7 gpm and lowest in October with an average withdrawal rate of 12.0 gpm.

Groundwater withdrawn during 2001 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 19.7 gpm for 2001 represents 15.5%

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 12.5% of the actual average withdrawal rate (158 gpm) reported in the Station's Final Environmental Statement Operating License Stage (Section 5.3.1.2) of the period 1975 to May 1979.

The combined annual rate for all recorded preoperational groundwater pumpage averaged 68.8 gpm, while the average operational pumpage for the period 1990 through 2001 was 32.3 gpm. Therefore, the average operational rates are 53% less than the groundwater pumpage during the preoperational period. Figure 1 illustrates the annual fluctuation of groundwater withdrawal over the entire preoperational 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 2001 from a high level in April of 529.2 ft. Mean Sea Level (MSL) to a low level in August of 521.0 ft. MSL. Overall, the water level in OB-3 during the reporting period (January through December) decreased 0.7 ft.

(0.2m).

The 2001 annual average groundwater levels in well OB-3 and OB-4 were 525.4 ft. MSL and 556.8 ft. MSL, respectively. These average levels demonstrated an increase of 0.8 ft. (0.2m) for OB-3 and a decrease of 1.5 ft. (0.5m) for OB-4 from the respective average 2000 levels (Figure 2).

Attachment to TXX-02084 Page 4 of 10

3. Surface Water Treatment System Operation The station's Water Treatment System processed 193,632,700 total gallons (368.4 gpm) of surface water during 2001 for plant process use. There were no outages during 2001 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 SURFACE WATER PROCESSED (GALS.)

JANUARY 18,747,700 FEBRUARY 14,977,000 MARCH 16,311,400 APRIL 18,042,400 MAY 18,314,900 JUNE 15,232,300 JULY 16,588,900 AUGUST 16,414,600 SEPTEMBER 15,052,400 OCTOBER 15,325,100 NOVEMBER 14,845,700 DECEMBER 13,780,300 TOTAL 193,632,700 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 There were no nonroutine reports submitted under this subsection.

Attachment to TXX-02084 Page 5 of 10 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 Natural Resource Conservation Commission (TNRCC) for each month during 2001.

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

MONTH LOG NUMBER/DATE MONITORED JANUARY TXX-01 034 23-01 FEBRUARY TXX-02021 05-02 / "Bio-Monitoring Submission" TXX-01047 23-01 MARCH TXX-01069 25-01 APRIL TXX-01088 25-01 MAY TXX-01 106 25-01 JUNE TXX-01 122 25-01 TXX-0 1121 20-01 I "Bio-Monitoring Submission" JULY TXX-01138 24-01 TXX-01121 25-01 I "Bio-Monitoring Submission" AUGUST TXX-01 158 25-01 SEPTEMBER TXX-01 175 25-01 OCTOBER TXX-01 185 21-01 NOVEMBER TXX-01207 21-01 DECEMBER TXX-02012 25-02

2. There was 1 TPDES wastewater discharge permit noncompliances in 2001.

This noncompliance pertains to the exceedance of the fecal coliform limit

3. There were three (3) on-site spills during 2001 that required reporting in accordance with the TNRCC's 24-hour notification requirements.

a. March 24, 2001 - This spill resulted when a fork lift accidently hit and ruptured a 2" Fire Protection lines. Fire Protection water was discharged to Squaw Creek Reservoir (SCR). There were no impacts to SCR. The spill was reported to the TNRCC (see TXX-01 059, dated March 29,2001). SmartForms SMF-000594 and 565 were written to monitor spill.

b. June 14, 2001 - This spill resulted when high winds caused sight glass to detach from bulk storage acid tank and allowed a portion of the tank contents (Thrugard 404) to discharge to Circulating Water Intake (CWI) deck. Approximately twenty (20) gallons reached the

Attachment to TXX-02084 Page 6 of 10 SCR shoreline. However, there were no impacts to SCR aquatic life.

Spill reported to TNRCC (TXX-01 111, dated June 25, 2001).

c. November 24, 2001 - This spill resulted when a pipe cap ruptured causing a discharge of Fire Protection water. There were no impacts to SCR's aquatic life. The spill was verbally reported to the TNRCC and no written report was required.

Attachment to TXX-02084 Page 7 of 10 TABLE 1

SUMMARY

OF GROUNDWATER PUMPAGE For 2001 P LANT PLANT WELL 2 NOSF WELL II NOSF WELL 2 TOTALS NO. OF MONTH iF Total Gals. Avg a. Total Gl.

Av.I v

Fg.

Ga II Total Gals. Avg. G Total Gals.

" Avg. Gal Ttal as.IAg a Avg G, DAYS E EEN BG.

Per Mi. Per Min. Per Min. Per Min. Per Mn. READINGS January 1,110,300 24.9 0 0.0 38,000 0.9 44,400 1.0 1,192,700 26.7 31 February 6,900 0.2 1,052,000 26.1 41,600 1.0 36,100 0.9 1,136,600 28.2 28 March 0 0.0 1,010,700 22.6 47,900 1.1 48,600 1.1 1,107,200 24.8 31 April 169,000 3.9 865,700 20.0 6,800 0.2 58,900 1.4 1,100,400 25.5 30 May 685,100 15.3 0 0.0 0 0.0 126,600 2.8 811,700 18.2 31 June 551,900 12.8 0 0.0 0 0.0 134,100 3.1 686,000 15.9 30 July 34,000 0.8 650,700 14.6 0 0.0 159,700 3.6 844,400 18.9 31 August 476,700 10.7 147,600 3.3 0 0.0 156,300 3.5 780,600 17.5 31 September 301,600 7.0 296,600 6.9 0 0.0 88,600 2.1 686,800 15.9 30 October 423,900 9.5 0 0.0 0 0.0 113,000 2.5 536,900 12.0 31 November 758,100 17.5 0 0.0 0 0.0 85,700 2.0 843,800 19.5 30 December 555,100 12.4 0 0.0 0 0.0 71,700 1.6 626,800 14.0 31 F oT 134,300,J 2.1 loI 19.7 TOA 365 96I-,033078FI 502601 TOTAL 5,072,600 9.6 4,023,300 7.8 0.3 1,123,700 10,353,900

Attachment to TXX-02084 Page 8 of 10 TABLE 2 2001

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 269.2 524.6 291.0 556.9 February 267.9 525.9 286.4 561.5 March 265.3 528.5 283.2 564.7 April 264.6 529.2 281.6 566.3 May 264.7 529.1 282.4 565.5 June 266.4 527.4 286.5 561.4 July 268.2 525.6 290.1 557.8 August 272.8 521.0 298.5 549.4 September 271.2 522.6 299.3 548.6 October 270.9 522.9 297.3 550.6 November 270.3 523.5 295.7 552.2 December 269.9 523.9 290.9 556.9 ANNUAL GROUNDWATER LEVEL CHANGE FOR 2001:

Well OB-3: 269.2 ft. - 269.9 ft = (-)0.7 ft. = (-)0.2m (Decrease)

Well OB-4: 291.0 ft. - 290.9 ft = (-)0.1 ft. = (-)0.03m (Decrease)

NOTES:

(1) Depth to water table (ft.)

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

Attachment to TXX-02084 Page 9 of 10 FIGURE 1

SUMMARY

OF GROUNDWATER PUMPAGE 1975 THROUGH 2001 (GPM)

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