View source for TXX-8879, Revises Util 881007 Comments on Draft Environ Protection Plan.Requests That Item 2 Under Section 2.1 Re Aquatic Issues Be Deleted.Section 4.2.1 Re Groundwater Levels & Station Water Use Monitoring Be Revised to Read as Stated

{{Adams
| number = ML20206L714
| issue date = 11/23/1988
| title = Revises Util 881007 Comments on Draft Environ Protection Plan.Requests That Item 2 Under Section 2.1 Re Aquatic Issues Be Deleted.Section 4.2.1 Re Groundwater Levels & Station Water Use Monitoring Be Revised to Read as Stated
| author name = Counsil W
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000445, 05000446
| license number = 
| contact person = 
| document report number = TXX-88797, NUDOCS 8811300172
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 1
}}

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7              tog # TXX-88797                    !
                                                                                                'l       f-            File # 10110                       l
                                                                                               =          =                    916 nlELECTRIC November 23, 1988
                                             . WMem G. counell                                                                                            ,
    !                                          Emuttve nce tresdent                                                                                       {
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U. S. Nuclear Regulatory Commission                                                                         {
Attn: Document Control Oesk                                                                                  t Washington, D. C. 20555                                                                                      !
SLMJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)                                                       l l                                                                    DOCKET N05. 50-445 AND 50-446                                                        i REVISED CO M ENTS ON DRAFT ENVIRONMENTAL PROTECTION PLAN                             l I
REF.:                  TV Electric Letter TXX-88702 from W. G. Counsil to                                   ;
NRC dated October 7, 1988                                                            i Gentlemen                                                                                                    f The referenced letter addressed TV Electric's comments on the Draft                                         !
  ,                                           Environmental Protection Plan (EPP). This letter revises TV Electric's                                      !
  !                                          comments on the draft plan.                                                                                  ,
;                                             Section 2.1 Aquatic Issues. Our comment remains unchanged.                              This section        !
states that a study of the effects of the circulating water chlorination                                    i system on aquatic biota during operation is required. The current NPDES
  ,                                          permit does not require a chlorine minimization study. We therefore request that item (2) under Section 2.1, Aquatic Issues, be deleted.                                                p i
i                                            Section 4.2.1 Groundwater Levels and Station Water Use Monitoring in the                                     :
second paragraph states that "A monthly record of the total gallons pumped                                   l from each of t1e two onsite production wells . . . ."                             TV Electic requests       ;
this sentence be changed to read "A monthly record of the total number of gallons pumped from the onsite production wells shall be maintained with an                                  I average monthly pumpage rate in gpm." Identifying the number of production i                                            wells is not an essential element of the requirement but can requir, I
unnecessary revisions to the EPP if additional production wells are placed in service or retired.
j                                                                                                                      Very truly yours s                 !
8811300172 881123                                                                             p
:                                        PDR     ADOCK 05000445 A                               PNU                                           W. G. Counsil l
I                                            R00/m15 l                                            Attachment i
j                                            c - Mr. R. D. Martin, Region IV                                                                        Cod   f j                                                          Resident inspectors, CPSES (3)                                                              i t
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TO FACILITY OPERATING LICENSE N0. NPF-28                                                                                     -
TEXA3bTILITIESGENERATINGCOMPANY CCMANCHE PEAX STEM ELECTRIC STATION UNITS 1 & 2
,                                                                                                                                                                   00CXET NOS. 50-445 AND 50 446                                                ,
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(tiONRA0!OLO3! CAL) i 1
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944GL7-G444                                                                                                                         l#ff i

CCP#1CHE PEAK STEAli ELECTRIC ~ STATION.
UNITS 1 A!;D 2 ENVIRONMENTAL PROTECTION PLAN (NONRA0!dLCGICAL)
T/?_E OF C0!iTENTS Section             -
Page      !
1.0 Objectives of the Envi'ronmental Protection Plan. . . . . . .           11 2.0 Environmental Protection Issues. . . . . . . . . . . . . . .             21 2.1 Aquatic'!ssues . . . . . . . . . . . . . . . . . . . . . . .             21 2.2 Terrestrial Issues . . . . . . . . . . . . . . . .'. . . . .             21    .
3.0 Consistency Requirements . . . . . . . . . . . . . . . . . .             31 3.1 Plant Des ign and Opera tion . . . . . . . . . . . . . . . . .                      t 31         '
3.2 7eporting Related to the NPDES Permit and                                           !
State Certifica tion. . . . . . . . . . . . . . . . . . . . .          32 3.3 Changes Required for Compliance with Other Environ..sntal Regulations. . . . . . . . . . . . . . . . . .          33 4.0 Environmental Conditions . . . . . . . . . . . . . . . . . .             41 4.1 Unusual or Important Environmental Events. . . . . . . . . .             41 4.2   Environeantal Monitoring . . . . ,. . . . . . . . . . . . . .          41 5.0 /dainistrative Procedures. . . . . . . . . . . . . . . . . .             51 5.1 P ni eu a r d A ud i t . . . . . . . . . . . . . . . . . . . . . . 5.'  .
5.2 Records Retention. . . . . . . . . . . . . . . . . . . . . .             51 5.3 C ,*9ges in Environ."ental PFoteC* ion Plan . . . . . . . . . .          !.'.
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1.0        Objectives of the Environmental Protection Plan The Environmental Protection Plan (EPP) is to provide for protection of nonra:lological envirene ntal values during operation of the nuclear fa cil i ty., The princip: '
                                              .bfectives of the EPP are as follows:
              .'(1) Verify that the facility is operated in an environmentally acceptabl6 manner, as established by the Final E' nvironmental Statement - Operating License Stage (FES-OL) and other NRC environmental impact assessments.
(2) Coordinate NRC requirements and maintain consistency with other Federal, State and local requirements for environmental protectiert.
             'l4       l' esp NRC informed of the environmenal effects of facility c:nstr cti:n and operation and of actions taken to control those effect..
Environmental concerns identified in the FES-OL which relate to water quality catters are regulated by way of the licensee's NPDES permit, 0
11

2.0      Environmental Protection Issues In the FES-OL, dated September 1981, the staff considered the environmental               '
impacts associated with the operation of the two unit Cceanche Peak Steam
         .         ElecticStation(CPS!S). Certain environeental issues were identified which required study or license conditions to resolve environrental concerns and to assure adequate protaction of the environeant.
i 2.1      Aquatic Issues (1)   Effects of the intake structure on aquatic biota during operation '                  !
(FES-OLSection5.5.2).-
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f(2)      Effects of the circulating water chlorination system en aquatic biota                '
!             C during operation (FES-OL Sections 4.2.4.1 and 5.3.4.1).
Aquatic matters are addressed by the effluent limitations, eenitoring require-eents and the Section 316(b) demonstration requirement containeo in the effective I:
POES pemit issued by the U.S. Environmental
* Protection Agency (Region y!),
The NRC will rely on this agency for regulation of aiatters involving water l               quality and aquatic biota.
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2.2        Terrestrial Issues t
The terrestrial issue raised by the staff in the FES-OL was:
                                                             ;3.GT         ,
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         ..                                                                                                                   t (1) Potential impacts resulting from the use of groun6 cater by the station during operation (FES-OL Section 5.3.1.2).
NRC requirements with   .
regard to the terrestrial issue are s;ecified in     ,
Subseition 4.2 of this EPP.
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3.0       Consistency Requirements 5,                 3.1       Plant Design and 0;eration The licensee may make changes in station design or operation or perform tests orederimentsaffectingtheenvironmentprovidedsuchactivitiesdonot involve an unreviewed environmental cuestion and do not involve a change in the EFF'. Changes in station design or operation or performance of tests or experietnts which do not affect the environment are not subject to the      .
requirements of this EPP. Activities governed by Section 3.3 are not subject to the requirements of this Section.
Before engaging in additional construc?. ion or operational activities which may si;.ificantly affect the environment, t<:4 Ifeensee shall prepare and record an environ 5 ental evaluation of such activity. Activities are excluded feca this requirement if all r.easurable nonradielegical environmental effects are i
c::.f t .sd to the ensite a*eas princwil.r distwried during site pre:aratien anc plant construction. When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shall provide a written         .
.                  evaluation of such activity and chtain prior MC approval.       When suen activity involves a change in the EPP, such activity and change to the EPP may be implacented only in accordance with an appropriate license atenceent as set i
forth in Section 5.3 of this EPP.
                   = inis     rovision dces not relieve the licensee of the requirements of l                       10 CFP. 50.59.
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proposed change, test or experiment shall be deteed to involve an unreviewed envirer.cantal question if it cencerns:                (1) a matter which may result in a
             ' significant increase in any adverse environe. ental impact previously evaluated in the FES-OL, environmental impact appraisals, or in any decisions of the Atemii Safety and Licensing Board; or (2) a significant change in effluents or rewer level (in accordance with 10 CFR Part 51.5(b)(2)] or (1) a matter, not ;reviously reviewed and evaluated in the docueents specified in (1) of this Subsection, which may have a significant adverse environmental impact, The licensee shall maintain records of changes in facility design or operation and of tests and experiments carried out pursuant to this Subsection. These records shall include written evaluations which provide, bases for the detemina-tien that the change, test, or experieent does not involve an unreviewed                     '
{(              environmental question or constitute a decrease in the effectiveness of this EPp to rett the objectives specified in Section 1.0. The licensee shall include as : art of the Annual Environrental Operating Report (;er .%bsection 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.                                                                      -
3.2             Reporting Related to the NPOES Pemit and State Certification Changes to, or renewals of, the NPDES Permit er the 5tste certif t:stien shan be re;orted to the NRC within 30 days follcwing the cate the chan;e or renevai
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:.y, ac:ealed and stayed, the NRC shall be notified within 20 cays follcwing : e c: *      '.*,e  stay is granted.
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The licensee shall notify the NRC of changes to the effective NPOES Pemit prop: sed by the licensee by providing NRC with a copy of the proposed change at the same time it is submitted to the permitt.ing agency.        The licensee shall provide the NRC a copy of the application for renewal of the NPDES Pemit at the s'ame time the application is submitted to the pemitting agency.
3.3 Changes Required for Compliance with Other Environ. ental Regulations Charges in plant' design or operation and performance of tests or experiments which are required to achieve compliance with other Federal          State, and local environmental regulations are not subject to the requirements of Section 3.1.
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i 4.0      Environcental Conditions
\                 4.1       Unusual or important Enviroceental Events Any occurrence of an unusual or important event that indicates or ceuld result in sijnificant environmental impact causally related to plant operation shall be recorded and reported to the NRC within 24 hours followed by a written reco per Subsection 5.4.2.      The follcwing are exacples:     excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or unusual oc'eurrence of any species protected by the Endangered Species Act of 1973, fish kills, increase in nuisance organisms or conditions, and unanticipated or emergenc discharge of waste water or chemical substances.
No routine monitoring programs are required to implement this cenditien.

===4.2 Enviren===
ental Monitoring c.2.1 Greur.d: cater Levels and itatic . ',later Use renitoring Groundwater levels in,the onsite observation wells identified as C3-3 and C3 4 in the FES Ot. Figure 4-3 shall be monitored and recceded centhly wnen the g pumpage rate by CPSES is less thui or equal to 30 gallons per minute (gpm) anc weekly when the CPSES average monthly rate exceeds 30 g;m for '.he previcus month.             v Water le'els    shall be read and recorded en accroxicately the same d of the month when monitoring m.cnthly and on the saca day of the week w
               *eeMy fan aid in interges*imo the rafvlts tv -i-d-4.*S;            **.a d elu u o   v e-water use ;atterns of the aquifer by others en the cbservec water levels),
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             ' A mcnthly record of the total'nunber of gallons pumped from mh-M-the n t A
or. site pecduction wells shall be maintained te;;the with an average e:nthly pumpage rate in gpm.                                   .
Amonkhlyrecordshewingtherateandtotalamountofsurfacewaterprocessed by the onsite water treat ent facility shall be maintained by the licensee on a nonthly basis. This record shall include the process rate in gallons per minute and the total amount in gallons.                                                                ,
The licensee shall include the results of this monitoring program as part of the Annual 0perating Report (see Subsection 5.4.1).
4.2.2       Water Treat..ent Facility Outages Impact Assessment and Re:orting The f:llcwing outages of the onsite water treat ent facility shall be re:or ed ts :.e ritC:
(1)     Routine or unplanned outages that exceed 30 consecutive days.                             -
(2) Any outage of at least 24 hours duration, beginning with the third such outage in a calendar year, if such outages are acco. panied by an increase in the monthly average gr:unc'. cater ;urpage to a rate exceecing 20 gpm. When it is detemined that ei:her reutine or unplanned outages 4.. ....yn......3            . y . c .- q . . . . p.  ,. . .. 3,. 3 . ,s ., ., g ....
'I Will be greater than 30 g;m when averaged over the cutage peried, the licteter will orecare Cnd submit a POE rt to the f RC within !! hys
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.o af ter a detemination of the extended outage is made. This report shall include a discussion of the reason for the extended outage, the expected duration of the outage, an estimate of the date or the time required to return the ensite water treatment facility back to operation, a determinatien c.f the potential' for lowering the groundwater levels in offsite wells, an assessment of the impact of the projected groundwater level decline, and a proposed course of action to Mtigate any adverse effects.
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5.0       Administrative Procedures 5.1       Review and Audit The licensee shall provide for review and audit of ceroliance with the EPP
* The audits shall be conducted independently of the individual or groups respnnsible for performing the specific activity. A description cf the orgsnf ratten structure utilized to achieve the independent review and audit function and results of the audit activities shall be maintained and made            EPP
.available for inspection.
.5.2        Records Retention                                                           :
Records and log; *alative to the environmental aspects of station :;eration                .
'shall be made and retained in a manner convenient for review and inscection.
.These records and logs shall be made available to NRC cn request.                       cr 5
Records of modifications to station structures, systees and c:cperents               -
ifetermined to potentially affect the continued protvetien of the environcent       .
l thall be retained for the life of the station. All other records, data and legs       5 relating to this EPP shall be retained for five years or, where aeplicable, in        II iccordance with the requirements of other agencies.
0.3         Changes in Environeental Protecticn Plan
  'ecuests fer changes in the EPP shall include an assesscent of the envir: . ental lt::ct or the ere:esed charge and a su:peating justificaticn.      L :!e :m:3:3cn E')
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of such changes in the EPP shall not cemence prior to NRC approval of the
                    ;re;osed changes in the form of a license amendment incor; orating the
             ' apprepriate revision to the EPP.                   .
5.4       Plant Reporting Requirements 5.4.1      Routine Reports An Annual Environmental Operating Report describing implementatien of this EPP for the previous' year shall be submitted to the NRC prior to May 1 of each year.
The initial report shall be submitted prior to May 1 of the year fo11 ewing issuance of the operating license.
The period of the first report shall begin with the date of issuance of the operating license.
The report shall include sumaries and analyses of the results of t.*e environmental protection activitias required by Subsection 4.2 of : 31s EPP fer e.e report period, including a ecmparison with related cree:eraticnal studies, operational controls (as appropriate), and previous non-radiolegical environ-eental monitoring reports, and an assessment of the cbserved impacts of the           -
plant operation on the environment.
If hamful effects or evidence of trends tcward irreversible damage to the environment are observed, the licensee shall provide a detailed analysis of the data and a proposed ccurse of -iti;ating action.
5-2 l(                                                                 -
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The Annual Environmental Operating' Report shall also include:
(1)
A list of EPP noncompliances and the carrective actions taken to remedy them.
(2) A Itst of all changes in station design or operation, tests, and experiments made in accordance with Subsectt:n 3.1 which involved a potentially significant unreviewed environmental question.            .
(3) A Ifst of nonroutine reports submitted in accordance with Subsection 5.4.2.
(4) A sumary list of NPDES permit related reports sent to the U.S. Enviren mental Protection Agency Region VI during the report period which relate to catters identified tr, Subsection 2.1.
In the event that some results are not available by the recort due date, the report shall be submitted noting and explaining the missing results.        The       ,
nissing results shall be submitted as seen as ;ossible in a su;;1e entary report.
5.4.2       Nonroutine Reports A written report shall be submitted to the NRC within 23 days of :::;rrene, ef a nonreutine event.       The reecrt shall (a) describe, aral":e. ;-d r"!lua t e t' .
event, including extent and magnitude of the impact, and pl:nt e;arating b(                                                  i-3     .
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characteristics, (b) describe' the ,1robable cause of the event, (c) indicate the action taken to correct the eperted event, (d) indicate the corrective action taken to preclude repetition of the e, vent and to prevent similar occurrences involving similar cempenents or systems, and (e) indicate the agene ns notified and their preliminary responses.
Events reportable under this subsection which also require reports to other Federal, State er local agencies shall be reported in accordance with thos-reporting requirements in lieu of the requirements of this subsection. 'The NRC shall be provided a copy of such report at the same time it is submitted to the cther agency.
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