CPSES-200700859, Submittal of the Annual Non-Radiological Environmental Operating Report for 2006

Submittal of the Annual Non-Radiological Environmental Operating Report for 2006

ML071240200
Person / Time
Site:	Comanche Peak
Issue date:	04/27/2007
From:	Blevins M, Madden F TXU Generation Co, LP, TXU Power
To:	Document Control Desk, NRC/NRR/ADRO
References
CPSES-200700859, TXX-07085
Download: ML071240200 (12)

Text

STXU

'4AC Power TXU Power Mike Blevins Comanche Peak Steam Senior Vice President &

Electric Station Chief Nuclear Officer P. 0. Box 1002 (E01)

Glen Rose, TX 76043 Tel: 254 897 5209 Fax: 254 897 6652 mike.blevins@txu.com CPSES-200700859 Log # TXX-07085 April 27, 2007 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 2006 Gentlemen:

Attached is one (1) copy of the Annual Non-Radiological Environmental Operating Report for the CPSES Non-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, 2006 through December 31, 2006 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.

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

• Comanche Peak

• Diablo Canyon

• Palo Verde

• South Texas Project o Wolf Creek

TXX-07085 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 Mike Blevins By:

/FredW. Madden' Director, Oversight and Regulatory Affairs NSH

Attachment:

Annual Non-Radiological Environmental Operating Report for 2006 c - B. S. Mallett, Region IV M. C. Thadani, NRR Resident Inspectors, CPSES 0

TXU GENERATION COMPANY LP (TXU POWER)

COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 & 2 2006 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 2006 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 2006, the CPSES Nonradiological Environmental Monitoring Program was effective in implementing and monitoring all CPSES environmental regulatory commitments.

Program effectiveness in 2006 was substantiated by TXU Corporate environmental audits and compliance evaluations of the CPSES environmental program.

II. SCOPE Section 5.4.1 of the EPP requires that CPSES submitto 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.

II1. 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 2006. Based on the results of these activities, there were no observed adverse environmental impacts resulting from plant operation during 2006.

1. Groundwater Pumpage As indicated in Table 1, groundwater pumpage during 2006 averaged 17.3 gals./min. (gpm) or 9,092,700 total gallons withdrawn for the year. This withdrawal rate represents a 4.4% decrease from the 2005 average rate of 18.1 gpm. Groundwater withdrawal was highest in March at 23.5 gpm and lowest in November and December with an average monthly withdrawal rate of 13.2 gpm.

Groundwater withdrawn during 2006 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 17.3 gpm for 2006 represents 13.6%

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 10.9 % 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 2006 was 26.2 gpm. Therefore, the average operational rates are 62% 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 2006 from a high level in May of 519.0 ft. Mean Sea Level (MSL) to a low level in August of 512.8 ft. MSL. Overall, the water level in OB-3 during the reporting period (January through December) decreased 2.6 ft. (0.8m).

The 2006 annual average groundwater levels in wells OB-3 and OB-4 were 516.1 ft. MSL and 541.2 ft. MSL, respectively. 'These average levels demonstrated a decrease of 7.0 ft. (2.1 m) for OB-3 and a decrease of 10.8 ft.(3.3m) for OB-4 from the respective average 2005 levels (Figure 2).

As illustrated by Figure 2, the overall general decline in groundwater levels appears to have increased significantly during 2006 as compared to previous annual averages. It is recommended that this decline is unrelated to the operation of the CPSES, since actual groundwater pumpage at CPSES was 4.4% less in 2006 as compared to 2005 (see section III.A. 1).

Although groundwater pumpage increased slightly when comparing 2005 to 2004, overall annual groundwater pumpage generally declined throughout the previous decade (Figure 1). A predominate influencing factor is likely the significant increase in gas well drilling activities occurring in the region surrounding CPSES. These gas well drilling activities require large amounts

of water for fracturing and much of this water is being supplied by groundwater sources from the Trinity Aquifer.

The use of groundwater for these activities and the potential impact to groundwater levels is gaining considerable attention, both locally and at the state level. Since rainfall during 2006 was significantly greater than in 2005

( 30.5 in. vs. 16.4 in., respectively), it is unlikely that precipitation was a contributor to the decline in groundwater levels.

3. Surface Water Treatment System Operation The station's Water Treatment System processed 223,450,900 total gallons (431 gpm) of surface water during 2006 for plant process use. There were no outages during 2006 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 MONTH _

II SURFACE WATER PROCESSED (GALS.)

JANUARY 16,832,600 FEBRUARY 18,147,500 MARCH 20,357,700 APRIL 15,952,500 MAY 20,497,900 JUNE 18,894,500 JULY 19,624,000 AUGUST 19,554,300 SEPTEMBER 18,679,600 OCTOBER 18,477,900 NOVEMBER 16,904,642 DECEMBER 19,527,758 TOTAL 223,450,900 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 III.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 2006. The following is a summary list of correspondence pertaining to DMRs and TPDES permit related documents.

MONTH LOG NUMBER/DATE MONITORED JANUARY TXX-06033 - 02/20/06 FEBRUARY TXX-06055- 03/20/06 MARCH TXX-06073 - 04/20/06 APRIL TXX-06083- 05/19/06 MAY TXX-06083 - 06/21/06 JUNE TXE-06127- 07/20/06 TXX-06131 Biomonitoring Report for 1/1/2006-6/30/2006 JULY TXE-06140 - 08/17/06 AUGUST TXE-06160- 09/20/2006 SEPTEMBER TXE-06177- 10/20/2006 OCTOBER TXE-06188- 11/16/2006 NOVEMBER TXE-06199- 12/19/2006 DECEMBER TXE-07009 1/17/2007 TXE-07010 1/17/2006 Biomonitoring Report for 7/1/2006-12/31/2006

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 were invalid due to insufficient survival and neonate production in the control (intake) water. These invalidations are believed to be a result of elevated Total Dissolved Solids in Squaw Creek Reservoir. The company has been collecting data which supports this view and will be submitting a request for an alternate invertebrate species for use in testing when the reservoir is at these higher TDS concentrations in the second quarter of 2007.

3. There were no TPDES wastewater discharge permit noncompliances in 2006.

4. There were also no reportable spills during 2006.

TABLE 1

SUMMARY

OF GROUNDWATER PUMPAGE For 2006 PLANT WELL1 PLANT WELL 2 NOSFWELL 1 NOSF WE2 RECiTRAINING g TOTALS NO. ODAYS IBETWEEN MONTH Total Avg. Total Gals. Avg Total Avg. Total Gals. Avg. Total Gals. Avg. Total Gals. Avg. READINGS Gals. Gal. Gal Gals. Gal. Gal. Gal. Gal.

Per Min. Per Mi Per Min. Per Per Min. Per Min.

Pd Min.

January 0 0.0 747,900 16.8 31,200 0.7 54,100 1.2 2,400 0.0 835,600 18.7 31 February 360,800 8.9 264,500 6.6 62,700 1.6 69,700 1.7 2,100 0.0 759,800 18.8 28 March 20,200 0.5 931,500 20.9 46,600 1.0 50,000 1.1 2,400 0.3 1,050,700 23.5 31 April 0 0.0 816,200 18.9 43,900 1.0 42,600 1.0 1,700 0.1 904,400 20.9 30 May 56,400 1.3 506,900 11.4 69,200 1.6 52,900 1.2 2,900 0.1 688,300 15.4 31 June 196,400 4.5 476,700 11.0 43,900 1.0 44,600 1.0 1,000 0.1 762,600 17.7 30 July 0 0.0 544,400 12.2 75,100 1.7 76,100 1.7 1,900 <0.1 697,500 15.6 31 August 0 0.0 490,600 11.0 106,700 2.4 80,300 1.8 1,400 0.1 679,000 15.2 31 September 0 0.0 346,100 8.0 148,000 3.4 132,100 3.1 2,300 <0.1 628,500 14.5 30 October 0 0.0 672,000 15.1 132,200 3.0 123,200 2.8 2,600 <0.1 930,000 20.8 31 November 129,400 3.0 190,900 4.4 128,600 3.0 118,200 2.7 1,700 <0.1 568,800 13.2 30 December 498,200 11.2 0 0.0 41,200 0.9 47,000 1.1 1,100 <0.1 587,500 13.2 31 TOTAL IF 1,261,400 2.4 5,987,700 11.3 1 929,300 [ 1.8 890,800 1.7 23,500 0.1 9,092,700 17.3 IF 36I5

TABLE 2 2006

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 276.5 517.3 306.6 541.3 February 276.7 517.1 305.6 542.3 March 275.6 518.2 303.1 544.8 April 274.3 518.8 307.0 540.1 May 274.1 519.0 297.5 549.6 June 275.7 518.2 299.2 548.7 July 277.8 516.1 305.0 542.9 August 281.0 512.8 311.7 536.2 September 280.5 513.3 313.7 534.1 October 280.5 513.3 312.2 535.7 November 279.4 514.4 310.0 537.9 December 279.1 514.7 307.2 540.7 ANNUAL GROUNDWATER LEVEL CHANGE FOR 2005:

Well OB-3: 276.5 ft. - 279.1 ft = (-)2.6ft. = (-)0.8 m (decrease)

Well OB-4: 306.6 ft. - 307.2 ft = (-) 0.6 ft. = (-)0.2 m (decrease)

NOTES:

(1) Depth to water table (ft.)

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

Attachment to TXX-06082 Page 9 of 10 FIGURE 1

SUMMARY

OF GROUNDWATER PUMPAGE 1975 THROUGH 2006 (GPM)

Annual Groundwater Pumpage 200 180 160 140 120 100 a-80 60 40 20 0 -V A")

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

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

Attachment to TXX-06082 Page 10 of 10 FIGURE 2 ANNUAL AVERAGE GROUNDWATER LEVEL 1980 through 2006 Mean Sea Level (MSL) 620,*-..

600-580 +

560-OB-3 540-08-4 520-500 4.

480-460 4. .

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