ML073240579
| ML073240579 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/04/2006 |
| From: | Godfrey J M Southern Nuclear Operating Co |
| To: | Buck C L Office of Nuclear Reactor Regulation, Southern Nuclear Operating Co |
| References | |
| 017-0003, E.03.34, EV-06-0009, NL-07-2097 | |
| Download: ML073240579 (17) | |
Text
Intracompany Correspondence File: E.03.34 Log: EV-06-0009 DATE: RE: FROM: TO: January 4, 2006 Groundwater Use Permit#017-0003 J.M.Godfrey, Environmental Affairs Manager C.L.Buck, Chemistry Manager Plant Vogtle In response to a request made by Environmental Affairs, Georgia Environmental Protection Division (Division) modified the Vogtle Electric Generating Plant (VEGP)Groundwater Use Permit No.017-0003.The modified permit authorizes groundwater withdrawal from nine (9)wells with a system wide total of 6.000 mgd monthly average and 5.500 mgd annual average.The semiannual reports must continue to be submitted to the Division by July 31 of the same year for production between January and June, and by January 31 of the following year for production between July and December.The modified permit includes the following updated Special Conditions applicable to the VEGP Groundwater Use Permit.*This groundwater use permit and any future modification or re-issuances of such, is conditional upon an active implementation of the relevant Division-approved Water Conservation Plan.An approved Water Conservation Plan, included as attachment 2, was submitted to the Division with the permit modification application package on October 4,2005.*A Water Conservation Progress Report must be submitted to the Division on or before the 6 th of August 2010, and every five years thereafter.
This item will be tracked using the Environmental Affairs Permits and Reports List.*In accordance with the Groundwater Use Rules, 391-3-2-.08(2), a permit holder shall analyze a raw groundwater sample for specific conductance on an annual basis.This requirement is currently part of the sampling regimen.Action should be taken to ensure procedure 30140-C entirely captures the sampling specifications contained in Permit Special Condition No.9.*This groundwater use permit and any future modifications or re-issuances of such, is conditional upon an active implementation of the appropriate provisions outlined in the Georgia Drought Management Plan.This stipulation encompasses irrigation of ornamental vegetation.
All outdoor water use must adhere to the GA Rules Chapter 391-3-30"Outdoor Water Use".
Page 2 EV-06-0009 C.L.Buck This permit will be incorporated into the Environmental Permits Manual CD, which will be transmitted by separate correspondence.
If there are any questions concerning the modified permit or the conditions contained therein, please feel free to contact Jessica Joyner at 8-992-7693.
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Mike Godfrey"/Environmental Affairs Manager JMG/JAJ:ahl Enclosure bcc: w/o Enclosures D.E.Grissette P.D.Rushton T.E.Tynan S.Sundaram T.D.Blalock w/Enclosures D.G.Goodwin F.I.Page B.R.Evans SNC Document Services-Vog'tle (return receipt)
Attachment 1 EV-06-0009 Georgia Department of Natural Resources, Environmental Protection Division Permit to Use Groundwater No.017-0003 enclosure Georgia Department of Natural Resources Environmental Protection Division, Watershed Protection Branch 4220 International Parkway, Suite 101, Atlanta, Georgia 30354 Noel Holcomb, Commissioner Carol A.Couch, PhD, Director Linda MacGregor, Branch Chief (404)675-6232 FAX: (404)675-6247 December 19,2005 Mr.Mike Godfrey Southern Nuclear Operating Company-V ogtle Electric Generating Plant P.O.Box 1295 Birmingham, Alabama 35201-1295 Dear Mr.Godfrey;This is to inform Southern Nuclear Operation Company that the Georgia Environmental Protection Division has approved your application to modify Groundwater Use Permit#017-0003.
Read your permit carefully, especially with regard to your total system groundwater production limits of: 6.000 million gallons per day (mgd)monthly average and 5.500 mgd annual average, from nine wells in the Cretaceous Sand aquifer.Also note the Standard Conditions and Special Conditions contained within the permit.The expiration date of this new permit is August 6, 2010.Please be aware of the legal necessity for the submission of Groundwater Use Reports (GWURs)on a semi-annual basis.A condition of the Groundwater Use Permit requires that GWURs be submitted to this office every SIX months.Please send each completed GWUR to: Groundwater Use Reports Watershed Protection Branch Water Withdrawal Permitting Program 4220 International Parkway, Suite 101 Atlanta, Georgia 30354-3902 Enclosed are some blank groundwater use report forms for your file.Failure to submit therequiredreport is a violation of the Groundwater Use Act, for further information see Chapter 391-3-2-.08 (1)and (2)of the Rules.Any change in the withdrawal limits or conditions under which your permit was issued will require a permit modification, see Chapter 391-3-2-.06, paragraph 6 of the Rules for specifics.
If you have any further questions, please call me at 404-362-6537, or email meatchristineVoudy@dnr.state.ga.us.
Sincerely,Geologist Environmental Affairs ENVIRONMENTAL PROTECTION DIVISION DEPARTMENT OF NATURAL RESOURCES ST ATE OF GEORGIA PERMIT TO USE GROUNDWATER PERMIT NUMBER 017-0003 DATE: December 9, 2005 PERMITTEE'S NAME Southern Nuclear Operating Company-Vogtle Electric Generating Plant PERMITTEE'S ADDRESS P.O.Box 1295, Birmingham, Alabama 35201-1295 Burke County In accordance with the Provisions of the Groundwater Use Act, (Ga.Laws 1972, p.976, et seq., as amended by Ga.Laws 1973, p.1273, et seq.)and the Rules and Regulations promulgated pursuant thereto, this Permit is issued to withdraw, obtain, or utilize a maximum system wide total of groundwater in the amount of: 6.000 million gallons per day monthly average and 5.500 million gallons per day annual average;from nine wells located near Waynesboro, Georgia-Burke County for the purpose of a consumptive use for sanitary facilities, central water supplv.
water Drocess water for operation of units 1 and 2 and of ornamental vel!etation.
This Permit is conditioned upon the permittee complying with the following:
STANDARD CONDITIONS (1)The provisions of the Groundwater Use Act, as amended, or any of the Rules and Regulations promulgated pursuant thereto;(2)The Permit shall not be transferred except with the approval of the Division;(3)The Groundwater Use Report shall be submitted SEMI-ANNUALLY to the Environmental Protection Division (EPD)in accordance with the following schedule:*Production between the months of January through June shall be submitted by July 31 of the same year;and,*Production between the months of July through December shall be submitted by January 31 of the following year.(4)The use of groundwater is limited to the quantities and purpose of the water herein specified.
SPECIAL CONDITIONS (5)This Permit is valid for ground water withdrawal from the Cretaceous Sand Aquifer.No other aquifer can be used without the approval of the Division.(6)The replacement of any permitted well must receive prior approval from the Division.And theadditionalattached conditions (7 through 10), which are hereby made a part of this Permit.In accordance with the letter dated October 4, 2005 and in conformity with the statements and supporting data entered therein or attached thereto, all of which are filed with the Environmental Protection Division of the Department of Natural Resources and are hereby made part of this Permit.This permit is effective from the date first above written and is subject to revocation on evidence of noncompliance with any of the provisions of the Groundwater Use Act, as amended, or any of the Rules and Regulations promulgated pursuant thereto;or with any representation made in the above mentioned application or the statements and supporting data entered therein or attached thereto;or with any condition of this permit.Absent prior revocation in accordance with the above language, this Permit shall expire on the 6 tb day of August 2010.DIRf'\TOR'S SIGNA TURE J....DATE: December 9, 2005 Director Environmental Protection Division Department of Natural Resources STATE OF GEORGIA DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION SPECIAL CONDITIONS PAGE 2 OF 2 PERMIT NO.DATE: 017-0003 December 9,2005 (7)This groundwater use permit and any future modifications or re-issuances of such, is conditional upon an active implementation of the relevant Division-approved Water Conservation Plan.The Division will be conducting periodic inspections and tracking the standard Water Conservation Progress Report updates to ensure that water conservation efforts are implemented.
(8)A Water Conservation Progress Report must be submitted to the Division on or before the 6th of August 2010, and every five years thereafter.
This Progress Reportshouldinclude any actions and/or improvements made to conserve water and reduce water losses (e.g., leak detection and leak repair, meter installation and calibration, and meter replacement, etc.).The Water Conservation Progress Report must also include a comparison of unaccounted for water trends as well as a comparison of gallons of water used per unit of product produced for each of the five years presented in the report.(9)In accordance with the Groundwater Use Rules, 391-3-2-.08(2), a permit holder shall analyze a raw groundwater sample for specific conductance on an annual basis.Analysis for specific conductance shall be conducted in accordance with 40 Code of Federal Regulations, Part 141.89.A raw groundwater sample shall be collected at the point where the groundwater accumulates within the underground mine and is pumped to the surface.The results shall be submitted to the Division on corporate letterhead and shall include the date sampled, a map depicting where the groundwater sample was collected, temperature of water sample at time of testing, the specific conductance result, and the units of measurement.
(10)This groundwater use permit and any future modifications or re-issuances of such, is conditional upon an active implementation of the appropriate provisions outlined in the Georgia Drought ManagementPlan,which was approved by the Department of Natural Resources Board on March 26,2003.PERMIT MODIFICATION The permittee may seek modification of any of the terms of an unexpired permit upon written request to the Director.The Georgia EPD has the authority to modify any groundwater withdrawal permit at any time.
Attachment 2 EV-06-0009 Plant Vogtle Water Conservation Plan SOUTHERN NUCLEAR OPERATING COMPANY Plant Vogtle Water Conservation Plan Version 1.0 Effective Date: Date: JO/3/0S SOUTHERN A COMPANY Plant Vogtle Water Conservation Plan CONTENTS Version 1.0 Page 2 oflO Introduction 3 System Management 3 Identification of Water Conservation Measures 4 Drought Contingency Plan 5 Implementation of Water Conservation Measures 5 Education Efforts 5 Preparation of Demand Forecast 5 Evaluation of Strategy 6 Attachment1-Table 1 8 Attachment1-Figure 1 9 Attachment1-Figure 2 9 Southern Nuclear Operating Company Plant Vogtle Water Conservation Plan WATER CONSERVATION PLAN Introduction Version 1.0 Page 3 of 10 Vogtle Electric Generating Plant (VEGP)is a two reactor steam-electric power generating facility licensed by the Nuclear Regulatory Commission (NRC).The VEGP site encompasses an approximate 3169-acre area located in the eastern sector of Burke County, Georgia, on the Savannah River.The site is located on the west bank of the Savannah River at river mile 151.1, and is approximately 26 miles southeast of Augusta and 15 miles east-northeast of Waynesboro.
VEGP is jointly owned by Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and the City of Dalton, Georgia.All activities on the site are managed by Southern Nuclear Operating Company, a subsidiary of Southern Company and sister company of Georgia Power Company.Plant V ogtle is authorized to withdraw groundwater under Georgia Environmental Protection Division Permit (EPD)No.017-0003.The permit limits groundwater withdrawal to 6.0 MGD monthly average and 5.5 MGD annual average from eight wells.Attachment1-Table 1 provides well and aquifer data for the eight wells.System Management At V ogtle Electric Generating Plant, a conscientious effort to conserve water is maintained throughout the facility.Meeting or surpassing all environmental laws and regulations is the foundation of Southern Nuclear's environmental commitment.
All operations are conducted in an environmentally sound and responsible manner.Compliance with the rules and regulations of the Nuclear Regulatory Commission and the Georgia Environmental Protection Division ensures system accountability and efficiency of the systems utilizing groundwater.
The updating of various components to improve system operability is a continuous process.Because water is an essential element of nearly all plant systems, it is constantly being monitored and analyzed throughout the plant site.Attachment1-Figure 1 provides a schematic flow diagram of systems utilizing groundwater.
Groundwater wells provide makeup process water, utilized in the nuclear service cooling water systems and make-up to the demineralized water treatment plant, as well as potable water, utility water, and the fire protection system.Wells SB and Rec provide potable water to the Simulator Building and Recreation Area respectively.
Due to the complex design and nature of operation of the facility, a formal internal metering program of water flow is not practical.
However, level control instrumentation is provided in the nuclear service cooling tower basins to control the rate of make-up to the basins and serves to preclude unnecessary overflow of the basins.The quantity of water used throughout the facility operations is determined by metering the total amount of groundwater withdrawn.
Flows in wells MU-l, MU-2A, and TW-l are monitored with an annular flow element while wells SB, CW-3, IW-4, and Rec are Southern Nuclear Operating Company Plant Vogtle Water Conservation Plan Version 1.0 Page 4 of 10 monitored with turbine-type totalizers.
NPDES Permit No.GA0026786 governs discharge of wastewater from the facility.The discharge consists primarily of non contact cooling water.Plant sanitary wastes and other process waste waters are discharged in accordance with this permit.The maximum waste water flow that would be produced in the Combined Plant Waste Streams is 59,028 GPM.A flow diagram of NPDES related systems is provided in Attachment1-Figure 2.Due to the nature of operations at Plant Vogtle, it is not entirely sensible to measure the plant's efficiency in terms of gallons of water used per unit produced.A rough calculation for groundwater use efficiency, based on 2004 water use values, resulted in an estimate of 15.0 gallons of water used per megawatt-hour of electricity generated.Additionally,Plant Vogtle does not track Unaccounted for Water (UA W)because it relates exclusively to metered water used by a customer of the water system.Plant Vogtle does not sell or transfer groundwater withdrawn in accordance with Permit0003, nor does it operate a municipal water supply system.Accordingly, UA W is not applicable to Plant V ogtle and therefore is not addressed in this Water Conservation Plan.Due to Plant Vogtle's design and locations, there are no alternate viable sources of water available for use within operations.
Identification of Water Conservation Measures Various conservation measures are implemented throughout operations at Plant V ogtle.System leakage is detected by visual inspection and abnormal meter readings, then repaired.All major plant equipment containing significant inventories of water is monitored by plant operators through the use of level alarms or other devices.Should a system alarm for water level be received, plant operators would dispatch an Operations and Maintenance team to determine the cause for the level alarm and perform repairs as necessary.
Preventative maintenance is performed as determined by system-owner engineers.
To aid in the maintenance of plant systems, detailed system and component drawings are available through an electronic database for reference use and are maintained current.Withdrawal pumps and meters are maintained in accordance with manufacturer recommendations to ensure accuracy.Plant Vogtle also conserves water through reusing and/or recycling water where practical.
The design of the nuclear service cooling water system involves recirculation of cooling water instead of once through use.Make-up water is only added to this system to compensate for evaporation, drift, and blowdown losses.Waste water that is generated by blowdown of the steam generators is reprocessed by a filtration and demineralizer system.If this water meets operational water quality standards of the plant, the water is reclaimed and reused.In addition to recycling, water use efficiency is a factor in evaluation of new technology or new equipment when replacement of old equipment iswarranted.Currently, Xeriscape landscaping is not practiced on the plant site;however, water use for irrigation is monitored and adjusted according to drought severity indicators.
Unauthorized or excessive water use is prevented through procedural guidance.When a design change is proposed for a system, a screening process is utilized to identify potential environmental impacts, among others, at which time water use would be evaluated as part of the process change.Procedures are also in place to control water usage and contain limitations and provisions for the occurrence of abnormalities.
Southern Nuclear Operating Company Plant Vogtle Water Conservation Plan Version 1.0 Page 5 of 10 Selection criteria for conservation measures and improvements include ensuring plant system modifications are as efficient or more efficient after implementation.
Other conservation efforts are evaluated as appropriate.
Due to the nature of this facility, water availability is a highly important factor in operating the plant in a safe and reliable manner.The NRC regulates the overall operations of the plant and requires the availability of adequate water resources to safely operate or shutdown the plant at all times.The NRC supports and encourages water conservation practices where possible.Currently, no other water conservation efforts or measures have been identified for further analysis.The practice of factoring water efficiency into process modifications will continue throughout the remainder of plant operation.
Drought Contingency Plan There are two major regional aquifer systems containing large quantities of water located under the V ogtle Electric Generating Plant site.The lower regimen is referred to as the Cretaceous aquifer system and the upper regimen is referred to as the Tertiary aquifer system.Based on extensive studies conducted prior to the construction and operation of VEGP, it is estimated that the two systems have a safe yield of greater than 5 billion gallons per day.The impact of a drought on this groundwater system should be minimal.SNC tracks drought severity and announcements of measures to take as relayed by EPD to industrial facilities.
Plant V ogtle takes measures to conserve groundwater as outlined by EPD Rules for Outdoor Water Use and by reducing water used for recreational purposes.Implementation of Water Conservation Measures Water conservation is a continuous effort at Plant V ogtle through process modifications, therefore no detailed timetable is provided here.Education Efforts Currently, there is not a formal education plan in place for employees since water usage is an element of design and operational practices.
Procedural guidance is in place to aid in evaluation of process modifications that could impact water usage among other environmental impacts.Southern Nuclear is a member of the American Water Works Association and Georgia Association of Water Professionals (formerly Georgia Water Pollution Control Assocatiation).
Additionally, certain employees maintain a certified Water/Wastewater Operator License.Water conservation techniques are learned through continuing education and implemented where practical.
Preparation of Demand Forecast The production of electricity is the main purpose of Vogtle Electric Generating Plant.As such the demand for groundwater to support in-plant uses is not expected to change significantly in the next 20 years nor within the operation period of the plant licenses.Plant Vogtle intends to renew the existing operating licenses, which currently will expire Southern Nuclear Operating Company Plant V ogtle Water Conservation Plan Version 1.0 Page 6 oflO in 2027 for Unit 1 and 2029 for Unit 2.License renewal will allow 20 additional years of operation.
Evaluation of Strategy This Water Conservation Plan shall be reviewed for updates and revisions concurrent with either the Water Progress Report submittal or any time a significant plant modification is performed that involves groundwater use, whichever is first.Plant management is dedicated to the operation of Vogtle Electric Generating Plant safely, reliably, and in a water-conscientious manner.Southern Nuclear Operating Company Plant Vogtle Water Conservation Plan ATTACHMENT 1 Southern Nuclear Operating Company Version 1.0 Page 7 of 10 Plant V ogtle Water Conservation Plan Attachment1-Table 1 Vogtle Groundwater Wells Permit No.017-0003 Version 1.0 Page 8 of 10 WELLID Pump Capacity Size Depth Elev.Aquifer PWSID Comments (gpm)(in)(ft)(ft)Supplied MU-l 2000 26 851 197 Cretaceous PG0330017 Provide make-up water for in-NTNC plant use (Le., Nuclear Service Cooling Water system, make-up to the water treatment plant demineralizer, and potable water source).MU-2A 1000 26 884 225 Cretaceous PG0330017 Provide make-up water for in-NTNC plant use (Le., Nuclear Service Cooling Water system, make-up to the water treatment plant demineralizer, and potable water source).TW-l 1000 28 860 219 Cretaceous N/A Contingency source for the Production Make-up Well System SW-5 20 2 200 232 Tertiary N/A Water supply for old Security Tactical Training Area IW-4 120 4 370 215 Tertiary N/A Irrigation water source for ornamental vegetation.
CW-3 220 210 Tertiary N/A Water supply for Nuclear Operations Garage.REC 150 265 168 NG0330036 Potable water supply for TNC Recreation Area.SB 50 340 115 Tertiary PG0330035 Potable water supply for the NTNC Simulator (Training)
Building.Southern Nuclear Operating Company Plant Vogtle Water Conservation Plan Attachment1-Figure 1 Version 1.0 Page 9 of 10 Wells
- .....VEGP 2-Unit Plant Liquid Radwaste Treatment Nuclear 4 Service Cooling Water System r...Evaporation/Drift Losses Circulating Water System Sanitary Waste Treatment Plant Miscellaneous Low Volume Waste River 1 Evaporation/Drift Losses.,......Slowdown Sump 14------------',...PlantDischarge To River Waste Water Retention Basin SOUTHERN NUCLEAR OPERATING COMPANY VOGTLE ELECTRIC GENERATING PLANT FLOW DIAGRAM*Path from River to Nuclear Service Cooling Water System normally closed.For emergency Jl.lrposes only.Southern Nuclear Operating Company Plant Vogtle Water Conservation Plan Version 1.0 Page 10 of 10 Attachment1-Figure 2 Vogtle Electric Generating Plant Generalized Water Balance-.U1&U2 Cooling Tower Slowdown 10,000 GPM/Unit (OSN 002&003)U1&U2 NSCW Slowdown 250 GPM/Unit (OSN 009)Low Volume.....
Deepwells Wastes Ir eire.Water Makeup 46.000 GPM Radwaste Dilution 46,000 GPM (OSN 010),IrU1&U2 VWVRB 1-----1:
Slowdown......1--------1 1,300 GPM/Unit Sump..(OSN 004&005)J Mixing Box Intake Structure Intake Screen Backwash 1.256 GPM (OSN 011) All flows are maximum.Liq.Radwaste Sys.a.----I Low Volume Waste....100 GPM/Unit (OSN 007&008), SAVANNAH RIVER Southern Nuclear Operating Company Sewage Treatment Plant Emergency Overflow 125GPM[(OSN006)SOU'HERHA.
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