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| {{#Wiki_filter:Waterford Steam Electric Station, Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment A WF3 Clean Water Act Documentation | | {{#Wiki_filter:}} |
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| Attachment A WF3 Clean Water Act Documentation
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| * Section 401 (Water Quality) Certification. June 21, 1972.
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| * Louisiana Pollutant Discharge Elimination System (LPDES) Permit No. LA0007374. September 7, 2010.
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| * Scott Guilliams, Louisiana Department of E:nvironmental Quality, to Kelli M. Dowell, Entergy Services, Inc. January 30, 2015.
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| A-1
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| 0-1 STATE OF LOUISIANA APPENDIX IJ STREAM CONTROL COMMISSION P. O. ORAWCR FC UNIVERSITY STATION
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| 'ilATON ROUGE, LOUISIANA 70803 June 21, 1972 L:>uisiana Power and Light Company 14 2 Delaronde Street New Orleans, Louisiana 70114 Attention: Mr. Donald L. Aswell, Production Manager Gentlemen:
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| This is to officially inform you that the discharge permit applications for Units 1, 2, and 3, Taft, Louisiana, to discharge condenser cooling water to the 1vfississippi River and demineralizer waste to the Forty Arpent Canal were approved by the Louisiana Stream Control Commission at its meeting on May 31 , 19 7 2. .n..ny change in eit.her the quality or qunntity of the discharges will require submission of new proposals.
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| The Commission, in approving the discharges, is of the opinion that water quality standards of the State of Louisiana ~.-.;ill not be violated. Therefore, in accordance with provisions of Louisiana Revised Statutes of 1950, Title 56, Section 1439(5) - Act 628 of the 1970 Louisiana Legislature -
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| this is your letter of certification from the commission that the installations.
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| comply with Section 21 (b) of the Federal Water Quality Improvement Act of 1970.
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| Enclosed is copy oi a public notice to be run by you 1 one (1) time, in the official state journal, the BATON ROUGE STATE TIMES, at your expense.
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| Very truly yours,
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| *c;?~Q4.~
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| Robe.rt A. Lafleur /
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| Executive Secretary fbr Enclosure A-2
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| PERMIT NUMBER LA0007374 AI No.: 35260 OFFICE OF ENVIRONMENTAL SERVICES Water Discharge Permit Pursuant to the Clean Water Act, as amended (33 U.S.C.1251 et~.), and the Louisiana Environmental Quality Act, as amended (La. R. S. 30:2001 et~.), rules and regulations effective or promulgated under the authority ofsaid Acts, and in reliance on statements and representations heretofore made in the application, a Louisiana Pollutant Discharge Elimination System permit is issued authorizing Entergy Operations, Inc.
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| Wat~rford 3 Steam Electric Station 17265 River Road Killona; Louisiana 70057
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| . Type Facility: steam electric generating station Location: 17265 River Road, Killona St. Charles Parish Receiving Waters: Outfall 00 I - Mississippi River (07030 I)
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| Outfalls 004 and 005 - 40 Arpent Canal thence to Lac Des Allemands (020202) to discharge in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, and Ill attached hereto.
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| * This permit shall become effective on d dtM< ?DI0 This permit and the authorization to discharge shall expire five (5) years from the effective date of the permit.
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| wcr<~10 Cheryl Sonnier Nolan
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| .Assistant Secretary GALVEZ BUILDING* 602 N. FlfTHSTREET* P.O. BOX 4313 *BATON ROUGE. U 70811-4313 * (215) Z/9-3181 A-3
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| PART I Page 2 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 001, the continuous discharge of once through non-contact cooling water combined with previously monitored intermittent discharges including but not limited to: steam generator blowdown, cooling tower blowdown, metal cleaning wastewaters, low volume wastewater, and stormwater from Outfalls 101, 201, 301, 401, 501, 601, 701, 801, 901, and 1001 (estimated flow is 994 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Reguirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency Type Flow-MGD (*1) 50050 Report Report Continuous Recorder Ternperature(°F) 00011 Report(*2) 118(*3) Continuous Recorder Heat 00015 (*4) Continuous Recorder Total Residual Chlorine 50060 211 1/week(*5) Grab WHOLE EFFLUENT (ACUTE) (Percent%, UNLESS STATED)
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| TOXICITY TESTING STORET Monthly Avg 48-Hour Measurement Sample Code Minimum Minimum Frequency(*5) Type NOEC, Pass/Fail [0/1], TEM6C Report Report 1/quarter 24-hr. Composite Lethality, Static Renewal, 48-Hour Acute, Pirnephales promelas NOEC, Value [%], TOM6C --- Report Report 1/quarter 24-hr. Composite Lethality, Static Renewal, 48-Hour Acute, Pimephales promelas NOEC, Value[%], TQM6C --- Report Report 1/quarter 24-hr. Composite Coefficient of Variation, Static Renewal, 48-Hour Acute, Pimephales promelas NOEC, Pass/Fail [0/1], TEM3D Report Report 1/quarter 24-hr. Composite Lethality, Static Renewal, 48-Hour Acute, Daphnia pulex NOEC, Value [%], TOM3D --- Report Report 1/quarter 24-hr. Composite Lethality, Static Renewal, 48-Hour Acute, Daphnia pulex NOEC, Value[%], TQM3D --- Report Report 1/quarter 24-hr. Composite Coefficient of Variation, Static Renewal, 48-Hour Acute, Daphnia pulex A-4
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| PART!
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| Page 3 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locatlon(s):
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| Outfall 001, at the point of discharge from the circulating water system discharge structure prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) Discharge flow is to be determined from calibrated pumping curves or calculated using appropriate heat balance methodology.
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| (*2) See Part II, Q.
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| (*3) Instantaneous maximum.
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| (*4) Daily maximum limitation of 9.5 X 103 MBTU/hour.
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| (*5) Sample shall be representative of any periodic episodes of chlorination, biocide usage, or other potentially toxic substance discharged on an intermittent basis.
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| A-5
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| PART I Page 4 of 15 Permit No. U\0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 101, the intermittent discharge from the liquid waste management system. The liquid waste management system receives low volume wastewater from the following sources, including but not limited to: the turbine and reactor building equipment and floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423 (estimated flow is 0.0129 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Reauirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(*!) Type Flow-MGD 50050 Report 1/batch Totalized TSS 00530 100 1/month Grab Oil & Grease 03582 20 1/month Grab pH Minimum/Maximum Values 00400 6.0 (*2) 9.0 (*2) 1/batch Grab (Standard Units) (Min) (Max)
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| Samples taken In compliance with the monitoring requirements specified above shall. be taken at the following location(s):
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| Outfall 101, at the point of discharge from the liquid waste management system prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-6
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| PART I Page 5 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 201, the intermittent discharge from the boron management system. The boron management system receives low volume wastewater from the following sources, inducting but not limited to: the turbine and reactor building equipment and floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423 (estimated flow is 0.0128 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring R~uirements other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Dally Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(* 1) Type Flow-MGD 50050 Report 1/batch Totalized TSS 00530 100 1/month Grab Oil & Grease 03582 20 1/month Grab pH Minimum/Maximum Values 00400 6.0 (*2) 9.0 (*2) !/batch Grab (Standard Units) (Min) (Max)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 201, at the point of discharge from the boron management system prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-7
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| PART I Page 6of15 Permit No. LA0007374 AI No. 35260 EFFLUENT UMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 301, the intermittent discharge of filter flush water from the primary water treatment system. The primary water treatment system filters rlverwater for various plant uses. The filters of this system are flushed periodically with untreated river water to remove solids trapped in the filter beds (estimated flow is 0.0001 MGO).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Requirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(*!) Type Flow-MGD 50050 Report Weekly Totalized Clarifying Agents (*2)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 301, at the point of discharge from the primary water treatment system prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) The quantity and types of clarifying agents (coagulants) used in the primary water treatment system during the sampling month shall be recorded. Records of the quantity and type of darifying agents used shall be retained for three (3) years following Part III.C.3. No DMR reporting shall be required.
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| A-8
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| PART!
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| Page 7 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 401, the intermittent discharge of steam generator blowdown and other low volume wastewaters as defined in 40 CFR 423 (estimated flow is 0.042 MGD).
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| Such discharges shall be limited and monitored by the perrnittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Requirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(*!) Type Flow-MGD(*2) 50050 Report Daily Totallzed TSS 00530 100 1/week Grab Oil &Grease 03582 20 1/week Grab pH Minimum/Maximum Values 00400 6.0 (*3) 9.0 (*3) 1/week Grab (Standard Units) (Min) (Max)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 401, at the point of discharge from the secondary steam plant system prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) When low volume wastewaters are discharged, the flow must be estimated.
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| (*3) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-9
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| PART I Page 8of15 Permit No. LA0007374 Al No. 35260 EFFLUENT LIMITATIONS AND MONITORJNG REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 501, the intermittent discharge from Auxiliary Component Cooling Water Basin A. Low volume wastewaters indude, but are not limited to: auxiliary component cooling water, component cooling water, Mississippi River water used for now testing, and stormwater (estimated now is 0.26 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effiuent Characteristic Discharge Limitations Monitoring Reauirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(* 1) Type Flow-MGD 50050 Report 1/week Estimate TOC 00680 50 1/week Grab TSS (*2) 00530 100 l/week Grab Oil &Grease 03582 20 1/week Grab pH Minimum/Maximum Values 00400 6.0 (*3) 9.0 (*3) l/week Grab (Standard Units) (Min) (Max)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 501, at the point of discharge from Auxiliary Component Cooling Water Basin A prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) During circulating water flow testing, sampling for TSS is not required (when Mississippi River water is used for the now test).
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| (*3) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-10
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| PART I Page 9 of 15 Permit No. L.A0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 601, the intermittent discharge from Auxiliary Component Cooling Water Basin B. Low volume wastewaters include, but are not limited to: auxiliary component cooling water, component cooling water, secondary plant water system wastewater, Mississippi River water used for flow testing, and stormwater (estimated flow is 0.26 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Requirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(* 1) Type Flow-MGD 50050 Report l/week Estimate TDC 00680 50 1/week Grab TSS (*2) 00530 100 1/week Grab Oil & Grease 03582 20 1/week Grab pH Minimum/Maximum Values 00400 6.0 (*3) 9.0 (*3) 1/week Grab (Standard Units) (Min) (Max)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 601, at the point of discharge from the Auxiliary Component Cooling Water Basin B prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) During circulating water flow testing, sampling for TSS is not required (when Mississippi River water is used for the flow test).
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| (*3) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-11
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| PART I Page 10of15 Permit No. lA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 701, the intermittent discharge of cooling tower blowdown and low volume wastewaters from the Cooling Tower Sump# 1. Low volume wastewaters include, but are not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. (NOTE: Optional discharge to plant drainage ditches thence to Outfall 004 may occur during periods when the circulating water system is unavailable.) (estimated flow is 0.0185 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Reguirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(*!) Type Flow-MGD 50050 Report 1/month Estimate TOC 00680 so 1/quarter Grab TSS 00530 100 1/month Grab Oil & Grease 03582 20 1/month Grab FAC (*2) 50064 0.5 1/month Grab Total Chromium (*2) 01034 0.2 1/year Grab Total Zinc (*2) 01092 1.0 1/month Grab pH Minimum/Maximum Values 00400 6.0 (*3) 9.0 (*3) 1/month Grab (Standard Units) (Min) (Max)
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| '*
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| '-"
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 701, at the point of discharge from the Dry Cooling Tower Sump #1 prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) Sample shall be representative of periods during cooling tower blowdown discharge.
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| (*3) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-12
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| PART I Page 11of15 Permit No. LA0007374 Al No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 801, the intermittent discharge of cooling tower blowdown and low volume wastewaters from Dry Cooling Tower Sump #2. Low volume wastewater sources as defined in 40 CFR 423 include, but are not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. (NOTE: Optional discharge to plant drainage ditches thence to Outfall 004 may occur during periods when the circulating water system is unavailable.) (estimated flow is 0.068 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Requirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency (* 1) Type Flow-MGD 50050 Report 1/month Estimate TOC 00680 50 !/quarter Grab TSS 00530 100 1/month Grab Oil & Grease 03582 20 1/month Grab FAC (*2) 50064 0.5 1/month Grab Total Chromium(*2) 01034 0.2 1/year Grab Total Zinc (*2) 01092 1.0 !/month Grab pH Minimum/Maximum Values 00400 6.0 (*3) 9.0 (*3) 1/month Grab (Standard Units) (Min) (Max)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 801, at the point of discharge from the Dry Cooling Tower Sump #2 prior to mixing with other waters.
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| FOOlNOTE(S):
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| (*1) When discharging.
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| (*2) Sample shall be representative of periods during cooling tower blowdown discharge.
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| (*3) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-13
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| PART I Page 12 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 901, the mobile intermittent discharge of metal cleaning wastewaters (both chemical and non-chemical) from various plant equipment components including, but not limited to: the steam generator, cooling water heat exchangers, and piping (estimated flow is 0.0201 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Requirements other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency (*1) Type Flow-MGD 50050 Report !/week Estimate TSS 00530 100 1/week Grab Oil & Grease 03582 20 1/week Grab Total Copper 01042 1.0 1/week Grab Total Iron 01045 1.0 !/week Grab pH Minimum/Maximum Values 00400 6.0 (*2) 9.0 (*2) 1/week Grab (Standard Units) (Min) (Max)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 901, at the point of discharge from the mobile cleaning process unit(s) prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-14
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| PART I Page 13 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 1001, the intermittent discharge from the yard oil separator system. Wastewater includes auxiliary boiler blowdown, stormwater, and low volume wastewaters from various sources, including plant floor drains and discharge from the industrial waste system as defined in 40 CFR 423. Low volume wastewater sources include, but are not limited to: secondary water system drains, system leakage, auxiliary boiler sumps, turbine building equipment and floor drains, turbine building floor wash downs, and laboratory drains. (NOTE: Optional discharge to Final Outfall 004 may occur during maintenance periods and during rain events that compromise the capacity of the discharge pumps.)
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| (estimated flow is 0.0553 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Requirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Dally Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency (*1) Type Flow-MGD 50050 Report 1/month Estimate TSS 00530 100 1/month Grab Oil & Grease 03582 20 I/month Grab pH Minimum/Maximum Values 00400 6.0 (*2) 9.0 (*2) 1/month Grab (Standard Units) (Min) (Max)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 1001, at the point of discharge from the yard oil separator system prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-15
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| PART I Page 14 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the perrnittee Is authorized to discharge from:
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| Outfall 004, the intermittent discharge from the plant drainage ditch system consisting of storrnwater, potable water from the fire water system, maintenance wastewaters including, but not limited to hydrostatic test water, air conditioning condensate, low volume wastewaters including, but not limited to reverse osmosis reject water and demineralized water. The plant drainage ditch system receives discharges during maintenance from the Dry Cooling Tower Sump #1 (Internal Outfall 701), Dry Cooling Tower Sump #2 (Internal Outfall 801), and treated discharge from the yard oil separator system, including, but not limited to: plant floor drains and discharge from the industrial waste system (Internal Outfall 1001).(estimated flow is 10.3 MGD).
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| Such discharges shall be limited and monitored by the pennittee as specified below:
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| Effluent Characteristic Discharne limitations Monitoring Reguirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
| |
| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency (* 1) Type Flow-MGD 50050 Report 1/3 months Estimate TOC 00680 50 1/3 months Grab TS5 (*2) 00530 100 1/3 months Grab Oil & Grease 03582 15 1/3 months Grab pH Minimum/Maximum Values 00400 6.0 (*3) 9.0 (*3) 1/3 months Grab (Standard Units) (Min) (Max)
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| C, There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 004, at the point of discharge from the stormwater drainage ditch south of the plant laydown area and prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) Samples shall be representative of periods during discharge of low volume wastewaters as defined in 40 CFR 423 (excludes Mississippi River water that accumulates in the condenser water boxes).
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| ("'3) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-16
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| PART I Page 15 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
| |
| Outfall 005, the intermittent discharge of treated sanitary wastewater and a de minimisdischarge from the HVAC unit from the Entergy Energy Education Center (estimated flow is 0.061 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Requirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
| |
| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency (*1) Type Flow-MGD 50050 Report 1/6 months Estimate BOD5 00310 30 45 1/6 months Grab TSS 00530 30 45 1/6 months Grab Fecal Coliform colonies/100 ml 74055 200 400 1/6 months Grab pH Minimum/Maximum Values 00400 6.0 (*2) 9.0 (*2) 1/6 months Grab (Standard Units) (Min) (Max)
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| There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
| |
| Outfall 005, at the point of discharge from the sewage treatment plant prior to mixing with other waters.
| |
| FOOTNOTE(S):
| |
| (*1) When discharging.
| |
| (*2) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-17
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| Page l of 24 Permit No. LA0007374 AI No. 35260 PART II OTHER REQUIREMENTS In addition to the standard conditions required in all permits and listed in Part III, the Office has established the following additional requirements in accordance with the Louisiana Water Quality Regulations.
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| A. This permit does not in any way authorize the permittee to discharge a pollutant not listed or quantified in the application or limited or monitored for in the permit.
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| B. Authorization to discharge pursuant to the conditions of this permit does not relieve the permittee of any liability for damages to state waters or private property. For discharges to private land, this permit does not relieve the permittee from obtaining proper approval from the landowner for appropriate easements and rights of way.
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| C. For definitions of monitoring and sampling terminology see STANDARD CONDITIONS FOR LPDES PERMITS, Section F.
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| D. 24-HOUR ORAL REPORTING: DAILY MAXIMUM LIMITATION VIOLATIONS Under the provisions .of Part III.D.6.e. (3) of this permit, violations of daily maximum limitations for the following pollutants shall be reported orally to the Office of Environmental Compliance within 24 hours from the time the permittee became aware of the violation followed by a written report in five days.
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| Pollutant(s): Total Copper, Total Chromium, Total Zinc E. COMPOSITE SP.MPLING (24-HOUR)
| |
| Unless otherwise specified in this permit, the term "24-hour composite sample" means a sample consisting of a minimum of four ( 4) *aliquots of effluent collected at regular .intervals over a normal 24-hour operating day and combined in proportion to flow or a sample continuously collected in proportion to flow over a normal 24-hour operating period.
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| F. 40 CFR PART 136 (See LAC 33:IX.4901) ANA..LYTICAL REQUIREMENTS Unless otherwise specified in this permit, monitoring shall be conducted according to analytical, apparatus and materials, sample collection, preservation, handling, etc., procedures listed at 40 CFR Part 136, and in particular, Appendices A, B, and C {See LAC 33:IX.4901).
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| G. FLOW MEASUREMENT "ESTIMATE" SAMPLE TYPE If the flow measurement sample type in Part I is Specified as "estimate",
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| flow measurements shall not be subject to the accuracy provisions established at Part III.C.6 of this permit. The daily flow value may be estimated using best engineering judgement.
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| A-18
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| | |
| Part II Page 2 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
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| H. MINIMUM 00.l\.NTIFICATION LEVEL (MOL)
| |
| If any individual analytical test result is less than the minimum quantifi-cation level listed below, a value cf zero (0) may be used for that individual result for the Discharge Monitoring Report (DMR) calculations and reporting requirements.
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| NON CONVENTIONAL MOL (µg/L)
| |
| Phenolics, Total Recoverable (4~.AP) 5 Chlorine (Total Residual) 100 3-Chlorophenol 10 4-Chlorophenol 10 2,3-Dichlorqphenol 10 2,5-Dichlorophenol 10 2,6-Dichlorophenol 10 3,4-Dichlorophenol 10 2,4-D 10 2,4,5-TP (Silvex) 4 METALS AND CYANIDE MOL (µa/L)
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| Antimony (Total) 60 Arsenic ' ' (Total) 10 Beryllium (Total) 5 Cadmium (Total) 1 Chromium (Total) 10 Chromium (3+) 10 Chromium (6+) 10 Copper (Total) 10 Lead (Total) 5 Mercury (Total) 0.2 Molybdenum (Total) 30 Nickel (Total) Freshwater 40 Nickel (Total) Marine 5 Seleniu.'Tl (Total) 5 Silver (Total) 2 Thallium (Total) 10 Zinc (Total) 20 Cyanide* (Total) 20 DIOXIN MOL (ug/Ll 2,3,7,8-TCDD 0.00001 VOLATILE COMPOUNDS MOL (ug/T.)
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| Acrolein 50 Acrylonitrile 50 Benzene 10 Bromof orm 10 Carbon Tetrachloride 10 Chlorobenzene 10 Chlorodibromomethane 10 Chloroethane 50 2-Chloroethylvinylether 10 Chloroform 10 A-19
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| Part II Page 3 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
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| Dichlorobromomethane 10 1,1-Dichloroethane 10 1,2-Dichloroethane 10 1,1-Dichloroethylene 10 1,2-Dichloropropane 10 1,3-Dichloropropylene 10 Ethylbenzene 10 Methyl Bromide [Brornomethane] 50 Methyl Chloride [Chloromethane] 50 Methylene Chloride 20 1,1,2,2-Tetrachloroethane 10 Tetrachloroethylene 10 Toluene 10 1,2-trans-Dichloroethylene 10 1,1,1-Trichloroethane 10 1,1,2-Trichloroethane 10 Trichloroethylene 10 Vinyl Chloride 10 ACID COMPOUNDS MOL (µg/Ll 2-Chlorophenol 10 2,4-Dichlorophenol 10 2,4-Dimethylphenol 10 4,6-Dinitro-o-Cresol [2-Methyl-4,6-Dinitrophenol] 50 2,4-Dinitrophenol 50 2-Nitrophenol 20 4-Nitrophenol 50 p-Chloro-m-Cresol [4-Chloro-3-Methylphenol] 10 Pentachlorophenol 50.
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| Phenol 10 2,4,6-Trichlorophenol 10 BnSE/NEUTRJ\L COMPOUNDS MOL {µg/Ll Acenaphthene 10 Acenaphthylene 10 Anthracene 10 Benzidine 50 Benzo(a}anthracene 10 Benzo(a)pyrene 10 3,4-Benzofluoranthene 10 Benzo(ghi)perylene 20 Benzo(k)fluoranthene 10 Bis(2-chloroethoxy) Methane 10 Bis(2-chloroethyl) Ether 10 Bis(2-chloroisopropyl) Ether 10 Bis(2-ethylhexyl) Phthalate 10 4-Bromophenyl Phenyl Ether 10 Butylbenzyl Phthalate 10 2-Chloronapthalene 10 4-Chlorophenyl Phenyl Ether 10 Chrysene 10 Dibenzo(a,h}anthracene 20 1,2-Dichlorobenzene 10 A-20
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| | |
| Part II Page 4 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS {continued) 1,3-Dichlorobenzene 10 1,4-Dichlorobenzene 10 3,3'-Dichlorobenzidine 50 Diethyl Phthalate 10 Dimethyl Phthalate 10 Di-n-Butyl Phthalate 10 2,4-Dinitrotoluene 10 2,6-Dinitrotoluene 10 Di-n-octyl Phthalate 10 1,2-Diphenylhydrazine 20 Fluoranthene 10 Fluorene 10 Hexachlorobenzene 10 Hexachlorobutadiene 10 Hexachlorocyclopentadiene 10 Hexachloroethane 20 Indeno(l,2,3-cd)pyrene [2,3-o-Phenylene Pyrene] 20 Isophorone 10 Naphthalene 10 Nitrobenzene 10 n-Nitrosodimethylamine 50 n-Nitrosodi-n-Propylamine 20 n-Nitrosodiphenylamine 20 Phenanthrene 10 Pyrene 10 1,2,4-Trichlorobenzene 10 PESTICIDES MQL !b!gt'.Ll Aldrin 0.05 Alpha-BHC 0.05 Beta-BHC 0.05 Gamrna-BHC [Lindane) 0.05 Delta-BHC 0.05 Chlordane 0.2 4,4'-DDT 0.1 4,4'-DDE [p,p-DDX) 0.1 4,4'-DDD [p,p-TDE) 0.1 Dieldrin 0.1 Alpha-Endosulfan 0.1 Beta-Endosulfan 0.1 Endosulfan Sulfate 0.1 Endrin 0.1 Endrin Aldehyde 0.1 Heptachlor 0.05 Heptachlor Epoxide i BHC-He:rnchlorocyclohexane) 0.05 PCB-1242 1. 0 PCB-1254 1. 0 PCB-1221 1. 0 PCB-1232 1. 0 PCB-1248 1. 0 PCB-1260 1. 0 PCB-1016 1. 0 Toxaphene 5.0 A-21
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| Part II Page 5 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
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| The,permittee may develop an effluent specific method detection limit (MDLi in accordance with Appendix B to 40 CFR Part 136 (See LAC 33:IX.4901). For any pollutant for which the permittee d~termines an effluent specific MDL, the, permittee shall send to this Office a report containing QA/QC documentation, analytical results, and calculations necessary to demonstrat~
| |
| that the effluent specific MDL was correctly calculated. An effluent specific minimum quantification level (MQL) shall be determined in accordance with the following calculation:
| |
| MQL = 3.3 x MDL Upon written approval by this Office, the effluent specific MQL may be utilized by the permittee for all future Discharge Monitoring Report (DMR) calculations and reporting requirements.
| |
| I. The permittee shall achieve compliance with the effluent limitations and monitoring requirements specified for discharges in accordance with the following schedule:
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| Effective date of the permit J. PROHIBITION OF PCB DISCHARGES There shall be no discharge of polychlorinated biphenyls (PCB' s) . The minimum quantification level for PCB' s is 1. 0 µg/L. If any individual analytical test result for _PCB's is less than the minimum quantification level, then a value of zero(O) shall be used for the Discharge Monitoring Report (DMR) calculations and reporting requirements.
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| K. PROHIBITION OF 126 PRIORITY POLLUTANTS There shall be no discharge of any 126 priority pollutants ( 40 CFR 423 Appendix A) associated with the chemicals added for cooling tower maintenance, except total chromium and total zinc. The minimum quantification levels for the 126 priority pollutants are found in.Part II, Paragraph I.
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| L. CHEMICll.L METAL CLEANING WASTE The term chemical metal cleaning waste means any wastewater resu~Ling from cleaning of any metal process equipment with chemical compounds, including, but not limited to, boiler tube cleaning.
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| M. METAL CLEANING WASTE The term metal cleaning waste means any wastewater resulting from cleaning (with or without chemical cleaning compounds) any metal process equipment including, but not limited to, boiler tube cleaning, boiler fireside cleaning, and air preheater cleaning.
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| A-22
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| Part II Page 6 of 24 Permit No. LA0007374
| |
| .IU No. 35260 OTHER REQUIREMENTS (continued)
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| N. LOW VOLUME WASTE SOURCES The term "low volume waste sources" means, taken collectively as if from one source, wastewater from all sources except those for which specific limitations are otherwise established. Low volume waste sources include, but are not limited to: wastewaters from wet scrubber air pollution control systems, ion exchange water treatment systems, water treatment evaporator blowdown, laboratory and sampling streams, boiler blowdown, floor drains, cooling tower basin cleaning wastes, and recirculating house service water systems. Sanitary and air conditioning wastewaters are not included.
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| : 0. TOTAL RESIDUAL CHLORINE The term "total residual chlorine" (or total residual oxidants for intake water with bromides) means the value obtained using the amperometric method for total residual chlorine described in 40 CFR Part 136.
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| Total residual chlorine may not be discharged from any unit for more than two hours per day.
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| Simultaneous multi-unit chlorination is permitted.
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| P. FREE AVAILABLE CHLORINE The term "free available chlorine" shall mean the value obtained using the amperometric titration method for free available chlorine described in the latest edition of Standard Methods for the Examination of Water and Wastewater.
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| Free available chlorine may not be discharged from any unit for more than two hours in any one day and not more than one unit in any plant may discharge free available chlorine at any one time.
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| Q. TEt1PERATORE Daily temperature discharge is defined as the flow-weighted average (FWAT) and, on a daily basis, shall be monitored and recorded in accordance with Part I of this permit. FW.11.T shall be calculated at equal time intervals not greater than two hours. The method of calculating FWAT is as follows:
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| FW.Z:\T = SUMMATION (INSTANTANEOUS FLOW X INSTll.NTANEOUS TEMPERATURE)
| |
| SUMMATION (INSTANTANEOUS FLOW)
| |
| "Daily average temperature" (also known as average monthly or maximum 30 day value) shall be the arithmetic average of all FWATs calculated during the calendar month.
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| "Daily maximum temperature" (also known as the maximum daily value) shall be the highest FWAT calculated during the calendar month.
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| A-23
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| Part II Page 7 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
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| R. HEAT Discharge of heat shall be continuously calculated and recorded as:
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| [Instantaneous AT (circulating water temperature rise through the plant in
| |
| °F)] X [Instantaneous flow rate in MGD] X [3.48Xl0 5 ]
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| OR AS
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| [Heat. transferred to the turbine generator cycle (BTU/hour)] [Gross electrical output (BTU/hour)].
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| S. NON-RADIOACTIVE WASTEWATERS Certain low volume and chemical wastewaters from this facility with no detectable radioactivity, as defined by the Nuclear Regulatory Commission plant effluent. release limits may be cominingled and treated with similar wastewaters from Waterford 1 & 2 and controlled under terms of LPDES Permit Number LA0007439.
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| T. WATER TREATMENT CLARIFIER SLUDGE WASTES Water treatment clarifier sludge wastes may be returned.to the stream without
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| *treatment if not previously combined with any other untreated waste source, including demineralizer and softener wastes, U. ZEBRA MUSSEL TREATMENT The terms and conditions of the zebra mussel treatment program submitted by Entergy Operations, Inc., Waterford 3 and approved by this Office on June 23, 1998, shall be enforceable as if part of this permit.
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| According to section 3.d., "Samples and Composites", of the biomonitoring requirements paragraph of this permit, the permit.tee must collect composite samples that "are representative of any periodic episodes of chlorination, biocide usage, or other potentially toxic substance discharged on an intermittent casis". Anytime the treatment method involves an increase in the concentration of a treatment chemical, a change in type of treatment chemical used, or if any event occurs that creates the potential for an effluent with a higher toxic nature, additional biomonitoring according to the terms and conditions of the biomonitoring seclion of Part II of this permit shall be required.
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| The perrnittee must not~fy this Office if changes occur in the zebra mussel control plan and obtain approval prior to initiating the new treatment. If chlorine is applied to control zebra mussels, the permittee must comply with a daily maximum Total Residual Chlorine (TRC) concentration limit of 0.2 mg/L. Monitoring shall be performed at a frequency o.f l/day, by grab sample, during periods of chlorine application.
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| A-24
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| Parl II Page 8 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS {continued)
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| V. PERMIT REOPENER CLAUSE This permit may be modified, or alteynatively, revoked and reissued, to comply with any applicable effluent standard or limitations issued or approved under sections 301 (b) (2) (C) and {D); 304 {b) (2); and 307 {a) (2) of the Clean Water Act, or more stringent discharge limitations and/or additional restrictions in the future to maintain the water quality integrity and the designated uses of the receiving water bodies based upon additional water quality studies and/or TMDL's, if the effluent standard, limitations, water quality studies or TMDL's so issued o:r approved:
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| : 1. Contains different conditions or is otherwise mo:re stringent than any effluent limitation in the permit; or
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| : 2. Controls any pollutant not limited in the permit; or
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| : 3. Require reassessment due to change in 303(d) status of waterbody; or
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| : 4. Incorporates the results of any to-::al maximum daily load allocation, which may be approved for the receiving water body.
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| The Louisiana Department of Environmental Quality (LDEQ) reserves the right to modify or revoke and reissue this permit based upon any changes to established TMDL' s for this dis cha r.ge, or to accommodate for pollutant trading provisions in approved TMDL watersheds as necessary to achieve compliance with water quality standards. Therefore, prior to upgrading or expanding this facility, the permi ttee should contact the Department to determine the status of the work being done to establish future effluent limitations and additional permit conditions.
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| W. STORMWATER DISCHARGES
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| : 1. This section applies to all stormwater discharges from the facility, eilher through permitted outfalls or through outfalls which are not listed in the permit or as sheet flow. The purpose of the pollution prevention plan is to identify potential sources of pollution that would reasonably be expected to affect the quality of stormwater and identify the practices that will be used to prevent or reduce the pollutants in stormwater discharges.
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| : 2. Any runoff leaving the developed areas of the facility, other than the permitted outfall (s), exce.eding 50 mg/L TOC, 15 mg/L Oil and Grease, or having a pH less than 6.0 or greater than 9.0 standard units shall be a violation of this permit. Any discharge in excess of these limitations, which is attributable to offsite contamination shall not be considered a violation of this permit. A visual inspection of the facility shall be conducted and a report made annually as described in Paragraph 4 below.
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| : 3. For first time permit issuance, the permittee shall prepare, implement, and maintain a Storm Water Pollution Prevention Plan (SWP3) within six (6) months of the effective date of the final permit. For renewal.
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| permit issuance, the perrnittee shall review and update, if necessary, A-25
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| | |
| Part II Page 9 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued) a *Storm Water Pollution Prevention Plan (SWP3) within six (6) months of the effective date of the final permit. The terms and conditions of the SWP3 shall be an enforceable Part of the permit. If the permittee maintains other plans that contain duplicative information, those plans could be incorporated by reference into the SWP3. Examples of these type plans include, but are ndt limited to: Spill Prevention Control and Countermeasure Plan (SPCC), Best Management Plan (BMP), Response Plans, etc*. EPA document 832-R-92-006 (Storm Water Management for Industrial Activities) may be used as a guidance and may be obtained by writing to the Water Resource Center (RC-4100T), U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue NW., Washington D.C. 20460 or by calling (202) 566-1729 or via the Wetl~nds Helpline (800) 832-7828.
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| : 4. The following conditions are applicable to all facilities and shall be included i~ the SWP3 for the facility.
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| : a. The permittee shall conduct an annual inspection of the facility site to identify areas contributing to the storm water discharge from developed areas of the facility and evaluate whether measures to reduce pollutant loadings identified in the SWP3 are adequate and have been properly implemented in accordance with the terms of the permit or whether additional control measures are needed.
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| : b. The perrnittee shall develop a site map which includes all areas I
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| \
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| \.,
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| where stormwater may contact potential pollutants or subs-tances which can cause pollution. Any location where reportable quantities leaks or spills have previously occurred are to be documented in the SWP3. The SWP3 shall contain a description of the potential*
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| pollutant sources, including,, the type and q1:1antity of material present and what action has been taken to assure stormwater precipitation will not directly° contact the substances and result in contaminated runoff.
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| : c. Where experience indicates a reasonable potential for equipment failure (e.g. a tank ov~rflow or leakage), natural condition of (e.g~ precipitation), or other circumstances which result in signi.ficant amounts of pollutants reaching surface waters, the SWP3 should include a prediction of the direction, rate of flow and total quantity of pollutants which could be discharged from the facility as a result of each condition or circumstance.
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| : d. The permittee shall maintain for a period of three years a record summarizing the results of the inspection and a certification that the facility is in compliance with the SWP3, ari.d identifying any incidents of noncompliance. The su.rnmary report should contain, at a minimum, the date and time of inspection, name of inspector(s),
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| conditions found, nnd changes to be made t*o the SWP3.
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| : e. The summary report and the following certification shall be signed in accordance with LAC 33: IX. 2503. The summary report is to be attached to the SWP3 and provided to the Department upon request.
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| A-26
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| Part II Page 10 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQOIREMENTS (continued}
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| "I certify under penalty of law that this docu.Tflent and all attachn1ents were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."
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| Signatory requirements for the certification may be found in Part III, Section D.10 of this permit.
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| : f. The permittee shall make available to the Department, upon request, a copy of the SWP3 and any supporting documentation.
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| : 5. The following shall be included in the SWP3, if applicable.
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| : a. The permittee shall utilize all reasonable methods to minimize any adverse impact on the drainage system including but not limited lo:
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| : i. maintaining adequate roads and driveway surfaces; ii. removing debris and .accumulated solids from the drainage system; and iii. cleaning up immediately any spill by sweeping, absorbent pads, or other appropriate methods.
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| : b. All spilled product and other spilled wastes shall be immediately cleaned up and disposed of according to all applicable regulations, Spill Prevention and Control (SPC) plans or Spill Prevention Control and Countermeasures (SPCC) plans. Use of detergents, emulsifiers, or dispersants to clean up spilled product is prohibited except where necessary to comply with State or Federal safety regulations (i.e., requirement for non-slippery w0 rk surface) except where the cleanup practice does not =esult in a discharge and does not leave residues exposed to future storm events. In all such cases, initial cleanup shall be done by physical removal and chemical usage shall be minimized.
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| : c. All equipment, parts, dumpsters, trash bins, petroleum products, chemical solvents, detergents, or other materials exposed to stormwater shall be maintained in a manner which prevents contamination of stormwater by pollutants.
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| : d. All waste fuel, lubricants, coolants, solvents, or other fluids used in the repair or maintenance of vehicles or equipment shall be recycled or contained for proper disposal. Spills of these materials are to be cleaned up by dry means whenever possible.
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| : e. If applicable, all storage tank installations (with a capacity greater than 660 gallons for an individual container, or 1,320 gallons for two or more containers in aggregate within a common A-27
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| Part II Page 11 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued) storage area) shall be constructed so that a secondary means of containment is provided for the entire contents of the largest tank plus sufficient freeboard to allow for precipitation. Diked areas should be sufficiently impervious Lo contain spills.
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| : f. All diked areas surrounding storage tanks or stormwater collection basins shall be free of residual oil or other contaminants so as to prevent the accidental discharge of these materials in the event of f1-ooding, dike failure, or improper draining of the diked area. All drains from diked areas shall be equipped with valves which shall be kept in the closed condition except during periods of supervised discharge.
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| : g. All check valves, tanks, drains, or other potential sources of pollutant releases shall be inspected and maintained on a regular basis to assure their proper operation and to prevent the discharge of pollutants.
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| : h. The permittee shall assure compliance with all applicable regulations promulgated under the Louisiana Solid Waste and Resource Recovery Law and the Hazardous Waste Management Law (L. R. S. 30: 2151, etc.). Management practices required under above regulations shall be referenced in the SWP3.
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| : i. The permi ttee shall amend the SWP3 whenever there is a change in the facility or change in the operation of the facility which materially increases the potential for the ancillary activities to result in a discharge of significant amounts of pollutanls.
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| : j. If the. SWP3 proves to be ineffective in achieving the general objectives of preventing the release of significant amounts of pollutants to water of the state, then the specific objectives and requirements of the SWP3 shall be subject to modification Lo incorporate revised SWP3 requirements.
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| : 6. Facility Specific SWP3 Conditions:
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| None X. DISCHARGE MONITORING REPORTS Monitoring results must be reported on a Discharge Monitoring Report (DMR) form (EPA No. 3320-1 or an approved substitute). All monitoring reports must be retained for a period of at least three (3) years from the date of the sample measurement. The permittee shall make available to this Department, upon request, copies of all monitoring data required by this permit.
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| If there is no discharge during the reporting period, place an "X" in the NO DISCHARGE box located in the upper right corner of the Discharge Monitoring Report for that outfall.
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| Monitoring results for each reporting period shall be surnmari zed on a Discharge Monitoring Report (DMR) Form (one DMR form per monitoring period A-28
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| Part II Page 12 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued) per outfall) and submitted to the Office of Environmental Compliance either
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| ~and delivered, postmarked, or electronically submitted no later than the 15th day of the month following each reporting period.
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| : 1. For parameter(s) with monitoring frequencies of 1/month or more frequent (i.e. continuous, 1/batch, 1/discharge event, 1/day, 3/week, 2/week, 1/week, 2/rnonth, etc.), DMRs shall be submitted in accordance with the following schedule:
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| Submit DMR postmarked by the 15th day of the following month.
| |
| : 2. For parameter(s) that require a monitoring frequency of 1/2 months, DMRs shall be submitted in accordance with the following schedule:
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| Monitoring Period DMR Postmark Date January 1 - February 28(29) March 15th March 1 - April 30 May 15th May 1 - June 30 July 15th July 1 - August 31 September 15th September 1 - October 31 November 15th November 1 -December 31 January 15th
| |
| : 3. For pararneter(s) that require a monitor.ing frequency of quarterly, DMRs shall be submitted in accordance with the following schedule:
| |
| Monitoring Period DMR Postmark Date January, February, March April 15th April, May, June July 15th July, August, September October 15th October, November, December January 15th
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| : 4. For parameter(s) that require a semiannual monitoring frequency, DMRs shall be submitted in accordance with the following schedule:
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| Monitoring Period DMR Postmark Date January - June July 15th July - December January 15th
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| : 5. For parameter(s) that require an annual monitoring frequency, D~Rs shall be submitted in accordance with the following schedule:
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| Monitoring Period DMR Postmark Date January-December January 15th If not electronically submitting, duplicate copies of DMR' s (one set of originals and one set of copies) signed and certified as required by LAC 33:IX.2503, and all other reports (one set of originals) required by this permit shall be submitted to the Permit Compliance Unit at the following address:
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| A-29
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| Part II Page 13 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS {continued)
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| Department of Environmental Quality Off.ice of Environmental Compliance Permit Compliance Unit Post Off.ice Box 4312 Baton Rouge, Louisiana 7082i-4312 Y. 316(b) PHASE II RULE REQUIREMENTS
| |
| : 1. On July 6, 2004, EPA promulgated Phase II regulations in accordance with section 316 (b) of the Clean Water Act (CWA). In February 2005, LDEQ promulgated Phase II regulations found at LAC* 33:IX.Chapter 47.Subchapter B .. On January 25, 2007, the Second U.S._Circuit Court of Appeal.s remanded several provisions of the Phase II rule. On March 20, 2007, EPA issued a memo saying, "the rule should be considered suspended"~ On July 9, 2007, EPA published a Federal Register notice suspending all.parts of the Phase II regulations except 40 CFR 125.90(b)
| |
| [LAC 33:IX.4731.B]. In October 2007, LDEQ suspended LAC 33:IX.Chapter 47, Subchapter B, with the exception of LAC 33:IX.4731.~.
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| * According to EPA, 316(b) Phase II regulations are under complete reconsideration at this time. LAC 33:IX.4731.B *provides for regulating cooling water intake structures for existing faGilities on a case-by-*
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| case basis using best professional judgment.
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| EPA' s repromulgat*ion of the Phase II Rule may require procedures or timelines different from those included in this permit. If necessary for compliance with the Phase II Rule, this permit may be reopened.
| |
| In order to reduce the adverse environmental impact, if any, caused by the cooling water intake structure (CWIS), the permittee *shall comply with effective regulations promulgated in accordance with section 316(b) of the CWA for cooling water intake structures. The permittee shall at all times operate and maintain the existing CWIS as described in the
| |
| . assessment document received on July 10, 2008, entitled Impingement Mortality and Entrainment Characterization Study (IMECSJ. The permittee has submitted information to DEQ characterizing the fish/shellfish in the vicinity of the CWIS, assessing impingement mortality and entrainment ( IM&E), and assessing the cooling water system. DEQ may request an update of this information, or additional information, if necessary, to comply with the repromulgated Phase II Rule.
| |
| : 2. The following special definitions apply to this subpart:
| |
| : a. Baseline conditions means the impingement mortality and entrainment that would occur at your site assuming that (1) the cooling water system has been designed as a once-through system, (2) the opening of the CWIS is located at, and the face of the standard 3/8-ineh mesh traveling screen is oriented parallel to, the shoreline near the surface of the source water body.
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| A-30
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| Part II Page 14 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
| |
| : b. Closed-cycle recirculating system means a system designed, using minimized makeup and blow down flows, to withdraw water from a natural or other water source to support contact and/or non-contact cooling uses within a facility. The water is usually sent to a cooling canal or channel, lake, pond, or tower to allow waste heat to be dissipated to the atmosphere and then is returned to the system. (Some facilities divert the waste heat to other process operations.) New source water (make-up water) is added to the system to replenish losses that have occurred due to blow down, drift, and evaporation
| |
| : c. Cooling water means water used for contact or non-contact cooling, including water used for equipment cooling, evaporative cooling tower makeup, and dilution of effluent heat content. The intended use of the cooling water is to absorb waste heat rejected from the process or processes used, or from auxiliary operations. on the facility's premises.
| |
| : d. Cooling water intake ~tructure means the total physical structure and any associated constructed waterways used to withdraw cooling water from waters of the U.S. The coqling water" intake structure extends from the point at which water is withdrawn from the surface water source up to, and including, the intake pumps.
| |
| : e. Intake flow means the value of the total volume of water withdrawn from a source water body over a specific time pe.riod.
| |
| : f. Intake velocity means the'value of the ~verage speed at which intake water passes through the open area of the intake screen (or other device) against which organisms might be impinged or through which they might be entrained.
| |
| : g. Entrainment means the incorporation of all life stages of fish and shellfish with intake water flow enterit1g and passing through a cooling water intake structure and into a cooling water system.
| |
| : h. Hydraulic zone of influence means that portion of the source ~ater body hydraulically affected by the cooling water intake structure withdrawal of water.
| |
| : i. Impingement means the entrapment of all life stages of fish and shellfish on the outer part of an intake structure or against a screening device during periods of intake water withdrawal.
| |
| : j. Maximiz~ means to increase to the greatest amount, extent, or degree reasonably possible.
| |
| : k. Minimize means to reduce to the smallest amount, extent, or degree reasonably possible.
| |
| A-31
| |
| | |
| Part II Page 15 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
| |
| I Z. 48 HR ACU'rE BIOMONITORING REQUIREMENTS: FRESHWATER It is unlawful and a violation of this permit for a permitt.ee or the designated agent to manipulate test samples in any manner, to delay shipment, or to terminate a i:oxicity test. Once initiated, all toxicity tests must be completed unless specific authority has been granted by the Louisiana Department of Environmental Quality.
| |
| : 1. SCOPE AND METHODOLOGY
| |
| : a. The permit tee shall test the effluent for toxicity in accordance with the provisions in this section.
| |
| A PPL I C11.BLE TO OUT FALL ( S) : 001 CRI TICP..L DILUTION: 31%
| |
| EFFLUENT DILUTION SERIES: 13%, 18%, 24%, 31%, and 42%
| |
| COMPOSITE SAMPLE TYPE: Defined at PART I TEST SPECIES/METHODS: 40 CFR Part 136 {See LAC 33:IX.4901)
| |
| Daphnia pulex acute static renewal. 48-hour definitive toxicity test using EPA 821-R-02-012, or the latest update thereof. A minimum of five (5) replicates with ten (10) organisms per replicate must be used in the control and in each effluent dilution of this test.
| |
| Pimephales promelas (Fathead minnow) acute static renewal 48-hour definitive toxicity test using EPA 821-R-02-012, or the latest update thereof. A minimum of five (5) replicates with ten (10) organisms per replicate must be used in the control and in each effluent dilution of this test.
| |
| : b. The NOEC (No Observed. Effect Concentration) is defined as the greatest effluent dilution at and below which lethality that is statistically different from the control (0% effluent) at the 95%
| |
| confidence level does not occur.
| |
| : c. This permit may be reopened to require whole effluent toxicity limits, chemical speciric effluent limits, additional testing, and/or other appropriate actions to address toxicity.
| |
| : d. Test failure is defined as a demonstration of statistically significant sub-lethal or lethal effects to a test species at or below the efflu.ent critical dilution.
| |
| : 2. PERSISTENT LETHALITY The requirements of this subsection apply only when a toxicity test demonstrates significant lethal effects at or below the critical A-32
| |
| | |
| Part I I Page 16 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued) dilution. Significant lethal effects are herein defined as a statistically significant difference at the 95% confidence level between the survival of the appropriate test organism in a specified effluent dilution and the control (0% effluent).
| |
| If any valid test demonstrates significant lethal effects to a test species at or below the critical dilution, the frequency of testing for that species is automatically increased to once per quarter for the term of the permit.
| |
| : a. The pennittee shall conduct a total of three (3) additional tests for any species that demonstrates statistically significant lethal toxic effects at the critical dilution or lower effluent dilutions.
| |
| The additional tests shall be conducted monthly during the next three consecutive months in which a discharge occurs to determine if
| |
| * toxic.ity is persistent or occurs on a periodic basis. The purpose of this testing is to determine whether toxicity is present at a level and frequency that will provide toxic sample results to use in performing a Toxicity Reduction Evaluation (TRE). If no additional test failures occur during the retest monitoring period, the testing frequency will be once per quarter for the term of the permit or until another test failure occurs. The permittee may substitute one of the additional tests in lieu of one routine toxicity test. A full report shall be prepared for each test required by this section in accordance with procedures outlined in Item 4 of this section and submitted with the period discharge monitoring report (DMR) to the permitting authority for review.
| |
| : b. If any of the valid additional tests demonstrates significant lethal effects at or below the critical dilution, the permittee shall initiate Toxicity Reduction Evaluation (TRE) requirements as specified in Ite~ 6 of this section. The permittee shall notify the Department of Environmental Quality, Office of Environmental Compliance - Permit Compliance Unit in writing within 5 days of the failure in any retest, and the TRE initiation date will be the test completion date of the first failed retest. A TRE may also be required due to a demonstration of intermittent lethal effects at or below the critical dilution, or for failure to perform the required retests.
| |
| : c. The provisions of Item 2.a are suspended upon submittal of the TRE Action Plan.
| |
| : 3. REQUIRED TOXICITY TESTING CONDITIONS
| |
| : a. Test Acceptance The permittee shall repeat a test, including the control and all effluent dilutions, if the procedures and quality assurance requirements defined in the test methods or in this permit are not satisfied, including the following additional criteria:
| |
| A-33
| |
| | |
| .Part II Page 17 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
| |
| : i. Each toxicity test control (0% effluent) must have a survival equal to or greater than 90%.
| |
| ii. The percent coefficient of variation between replicates shall be 40% or less in the control (0% effluent) for: Daphnia pulex survival test; and Fathead minnow survival test.
| |
| iii. The percent coefficient of variation between replicates shall be 40% or less in the critical dilution, unless significant lethal effects are exhibited for: Daphnia pulex survival test; and Fathead minnow survival test.
| |
| Test failure may not be construed or reported as invalid due to a coefficient of variation value of greater than 40%. A repeat test shall be conducted within the required reporting period of any test determined to be invalid.
| |
| : b. Statistical Interpretation For the Daohnia pulex survival test and the Fathead minnow survival test, the statistical analyses used to determine if there is a statistically significant difference *between the control and the critical dilution shall be in accordance with the methods for determining the No Observed Effect Concentration (NOEC) as described in EPA 821-R-02-012, or the most recent update thereof.
| |
| If the conditions of Test Acceptability are met in Item 3.a above and the percent survival of the test organism.is equal to or greater than 90% in the critical dilution concentration and all lower dilution concentrations, the test shall be considered to be a passing test regardless of the NOEC, and the permittee shall report a NOEC of not less than the critical dilution for the DMR reporting requirements found in Item 4 below.
| |
| : c. Dilution Water
| |
| : i. Dilution water used in the toxicity tests will be receiving water collected as close to the point of discharge as possible but unaffected by the discharge. The permittee shall substitute synthetic dilution water of similar pH, hardness and alkalinity to the closest downstream perennial water for; (A) toxicity tests conducted on effluent discharges to receiving water classified as intermittent streams; and (B) toxicity tests conducted on effluent discharges where no receiving water is available due to zero flow conditions.
| |
| ii. If the receiving water is unsatisfactory as a result of instream toxicity (fails to fulfill the test acceptance criteria of Item 3.a), the permittee may substitute synthetic A-34
| |
| | |
| Part II Page 18 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued) dilution water for the receiving water in all subsequent tests provided the unacceptable receiving water test met the following stipulations:
| |
| (A} a synthetic dilution water control which fulfills the test acceptance requirements of Item 3.a was run cohcurr,ently with the receiving water control; (BJ the test indicating receiving water toxicity has been carried out to completion (i.e., 48 hours);
| |
| (C) the permittee includes all test results indicating receiving water toxicity with the full report and information required by Item 4 below; and (D) the synthetic ~ilution water shall have a pH, hardness and alkalinity similar to that of the receiving water or closest downstream perennial water not adversely affected by 'the discharge, provided the magnitude of these parameters will not cause toxicity in the synthetic dilution water.
| |
| : d. Samples and-Composites
| |
| : i. The permittee shall collect two 24-hour flow-weighted composite samples from the outfall (s) listed at Item 1. a above. A 24-hour composite sample consists of a minimum of 4 effluent portions collected at equal time intervals representative of a 24-hour operating day and combined proportional to flow or a sample continuously collected proportional to flow over a 24-hbur operating day .
| |
| .ii. The permi ttee sha 11 collect a second 24-hour composite sample for use during the 24~hour renewal of each dilution concentration for both tests. The permittee must tollect the 24-hour composite samples so that the maximum holding time for ahy effluent sample shall not exceed 36 hours. The permittee must have initiated the toxicity test within 36 hours after the collection of th.e last portion of the first 24-hour composite sample. Samples shall be chilled to 0-6 degrees Centigrade during collection, shipping and/or storage.
| |
| iii. The permit tee must collect the 24-hou.r cornposi te samples such that the effluent samples are representative of any periodic e~isode of chlorination, biocide usage or other potentially toxic substance discharged on an intermittent basis.
| |
| iv; If the flow from the outfall(s) being tested ceases during the collection of effluent samples, the requirements for the minimum number of effluent samples, the minimum number of effluent portions and the sample holding time are waived during that sampling period. However, the permittee must collect an effluent composite sample volume during the period of discharge A-35
| |
| | |
| Part II Page 19 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued) that is sufficient to complete the required toxicity tests with daily renewal of effluent. When pcssibl.e, the effluent samples used for the toxicity tests shall be collected on separate days. The effluent composite sample collection duration and the static renewal protocol associated with the abbreviated sample collection must be documented in the full report required in Item 4. of this section.
| |
| : v. MULTIPLE OUTFALLS: If the provisions of this section are applicable to multiple outfalls, the perrnittee shall combine the composite effluent samples in proportion to the average flow from the outfalls listed in Item l.a above for the day the sample was collected. The permittee shall perform the toxicity test on the flow-weighted composite of the outfall samples.
| |
| 4* REPORTING
| |
| : a. A valid test must be completed and test results must be submitted for each species during each Monitoring Period. The permittee shall prepare a full report of the results of all tests conducted pursuant to ~his Part in accordance with the Report Preparation Section of EPA 821-R-02-012, for every valid or invalid toxicity test initiated, whether carried to completion or not. The permittee shall retain each full report pursuant to the provisions of Part III.C.3 of this permit. For any test which fails, is considered invalid or which is terminated early for any reason, the full report must be submitted for agency review. The permittee shall submit the first full report to the following address:
| |
| Department of Environmental Quality Office of Environmental Compliance Enforcement Division P.O. Box 4312 Baton Rouge, Louisiana 70821-4312 Attn: Permit Compliance Unit In addition, if enforcement authority has been retained by EPA, a copy of the report must also be submitted to the following address:
| |
| U.S. Environmental Protection Agency, Region 6 Water Enforcement Branch, 6 EN-WC 1445 Ross Ave.
| |
| Dallas, Texas 75202
| |
| : b. The permittee shall submit the results of each valid toxicity test on the DMR for that Moni taring Period in accordance with Part III.D.4 of this permit. Submit retest information clearly marked as such on the DMR for the Monito:::-ing Period in which the retest occurred. Only results of valid tests are to be reported on the DMR. The permittee shall submit the Table 1 Surnmary Sheet with each valid test.
| |
| A-36
| |
| | |
| Part II Page 20 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
| |
| : i. Pimeohales oromelas (Fathead minnow)
| |
| (A) If the No Observed Effect Concentration (NOEC) for survival is less than the critical dilution, enter a "l"; otherwise, enter a "0" for Parameter No. TEM6C.
| |
| (B) Report the NOEC value for survival, Parameter No. TOM6C.
| |
| (C) Report the highest (critical dilution or control)
| |
| Coefficient of Variation, Parameter No. TQM6C.
| |
| ii. Daphnia pulex (A) If the NOEC for survival is less than the critical dilution, enter a "1"; otherwise, enter a "0" for Parameter No. TEM3D.
| |
| (B) Report the NOEC value for survival, Parameter No. TOM3D.
| |
| {C) Report .the highest (critical dilution or control)
| |
| Coefficient of Variationr' Parameter No. TQM3D.
| |
| iii. The permittee shall report the following results for all VALID toxicity retests on the DMR for that Monitoring Period.
| |
| {A) Retest #1 (STORET 22415): If the first monthly retest foll'owing failure of a routine test for either test species results in an NOEC for survival less than the critical dilution, report a "l"; otherwise, report a "0".
| |
| (B) Retest #2 (STORET 22416): If the second monthly retest following failure of a routine test for either test species results in an NOEC for survival less than the critical dilution, report a "l"; otherwise, report a "0".
| |
| (C) Retest #3 (STORET 51443): If the third monthly retest following failure of a routine test for either test species results in an NOEC for survival less than the critical dilution, report a "1"; otherwise, report a "0".
| |
| If, for any reason, a retest cannot be performed during the Monitoring Period in which the triggering routine test failure is experienced, the permittee shall report it on the following Monitoring Period's DMR, and the comments section of the DMRs shall be annotated to that effect. If retesting is not
| |
| ::-equired during a given Monitoring Period, the permittee shall leave these DMR fields blank.
| |
| A-37
| |
| | |
| Part II Page 21 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQOIREMENTS (continued)
| |
| The permittee shall submit the toxicity testing information contained in Table 1 of this permit with the '.:lMR subsequent to each and every toxicity test Monitoring Period. The DMR and the su.rnmary tables should be sent to the address indicated in 4.a.
| |
| : 5. MONI'rORING FREQUENCY REDUCTION
| |
| : a. Upon successfully passing the first four quarters of WET testing after permit isSuance/reissuance and in the absence of subsequent lethal toxicity for one or both test species at or below the critical dilution, the permittee may apply for a testing frequency reduction. Tf granted, the monitoring frequency for that test species may be reduced to not less than once per year for the less sensitive species (usually the Fathead minnow) and not less than once per six months for the more sensitive test species (usually the Daphnia pulex) . Monitoring frequency reduction shall not apply to monitoring frequencies of once per year.
| |
| : b. CERTIFICATION - The permittee must certify in writing that no test failures have occurred and that all tests meet all test acceptability criteria *in Item 3.a. above. In addition, the permittee must provide a list with each test performed including test initiation date, Species,' NOEC' s fo_r lethal and sub-lethal effects and the maximum coefficient of variation for the controls.
| |
| Upon review and acceptance of this information the agency will issue a letter of confirmation of the monitoring frequency reduction. A copy of the letter will be forwarded to the agency's Permit Compliance Unit to update the permit reporting requirements.
| |
| : c. This monitoring frequency reduction applies only until the expiration date of this permit, at which time the Monitoring Frequency/Monitoring. Period for both test species reverts to once per quarter until the permit is re-issued.
| |
| : d. SORVIVAL FAILURES - If any test fails the survival endpoint at any time during the term of this permit, three monthly retests are required and the monitoring frequency for the affected test species shall be increased to once per quarter until the permit is reissued.
| |
| Monthly retesting is not required if the permittee is performing a TRE.
| |
| : 6. TOXICITY REDUCTION EVALUATION (TRE)
| |
| : a. Within ninety (90) days of confirming lethality in the retests, the permittee shall submit a Toxicity Reduction Evaluation (TRE) Action Plan and Schedule for conducting a TRE. The TRE Action Plan shall specify the approach and methodology to be used in performing the TRE. A Toxicity Reduction Evaluation is an investigation intended to determine those actions necessary to achieve compliance with water quality-based effluent requirements/and or chemical-specific limits by reducing an effluent's toxicity to an acceptable level.
| |
| A TRE is defined as a step-wise process which _combines toxicity A-38
| |
| | |
| Part II Page 22 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS {continued) testing and analyses of the physical and chemical characteristics of a toxic effluent to identify the constituents causing effluent toxicity and/or treatment methods which will reduce the effluent toxicity. The TRE Action Plan shall lead to the successful elimination of effluent toxicity at the critical dilution and include the following:
| |
| : i. Specific Activities. The plan shall detail the specific approach the permittee intends to utilize in conducting the TRE. The approach may include toxicity characterizations, identifications and confirmation activities, source evaluation, treatability studies, or alternative approaches. When the permittee conducts Toxicity Characterization Procedures the permittee shall perform multiple characterizations and follow the procedures specified in the document "Methods for Aquatic Toxicity Identification Evaluations: Phase I Toxicity Characterization Procedures" {EPA-600/6-91/003) or alternate procedures. When the permittee conducts Toxicity Identification Evaluations and Confirmations, the permittee shall perform multiple identifications and follow the methods specified in the documents "Methods for Aquatic Toxicity Identification Evaluations, Phase II Toxicity Identification Procedures for Samples Exhibiting Acute and Chronic Toxicity"
| |
| {EPA/600/R-92/080) and "Methods for Aquatic Toxicity Identification Evaluations, Phase III Toxicity Confirmation Procedures for Samples Exhibiting Acute and Chronic Toxicity" (EPA/600/R-92/081), as appropriate.
| |
| The documents referenced above may be obtained through the National Technical Information Service (NTIS) by phone at (703) 487-4650, or by writing:
| |
| U.S. Department of Commerce National Technical Information Service 5285 Port Royal Road Springfield, Va. 22161 ii. Sampling Plan (e.g., locations, methods, holding times, chain of custody, preservation, etc.). The effluent sample volume collected for all tests shall be adequate to perform the toxicity test, toxicity characterization, identification and confirmation procedures, and conduct chemical specific analyses when a probable toxicant has been identified; Where the permittee has identified or suspects specific pollutant(s) and/or source{s) of effluent toxicity, the permittee shall conduct, concurrent with toxicity testing, chemical specific analyses for the identified and/or suspected pollutant {s) andior source (s) of effluent toxicity. Where lethality was demonstrated within 24 hours of test initiation, each composite sample shall be analyzed independently.
| |
| Otherwise the permittee may substitute a composite sample, A-39
| |
| | |
| Part II Page 23 of 24 Permit No. LA0007374 AI No. 35260 OTHE~ REQUIREMENTS (continued) comprised of equal portions of the individual composite samples, for the chemical specific analysis; iii. Quality Assurance Plan (e.g., QA/QC implementation, corrective actions, etc.); and iv. Project Organization (e.g., project staff, project manager, consulting services, etc.).
| |
| : b. The permittee shall initiate the TRE Action Plan within thirty (30) days of plan and schedule submittal. The permittee shall assume all risks for failure to achieve the required toxicity reduction.
| |
| : c. The permittee shall submit a quarterly TRE Activities Report, with the Discharge Monitoring Report in the months of January, April, July and October, containing information on toxicity reduction evaluation activities including:
| |
| : i. any data and/or substantiating documentation which identify the pollutant(s) and/or source(s) of effluent toxicity; ii. any studies/evaluations and results on the treatability of the facility's effluent toxicity; and iii. any data which identify effluent toxicity control mechanisms that will reduce effluent toxicity to the level necessary to achieve compliance with permit biomonitoring requirements and/or chemical-specific limits.
| |
| The TRE Activities Report shall be submitted to the following addresses:
| |
| Department of Environmental Quality Office of Environmental Compliance Enforcement Division P.O. Box 4312 Baton Rouge, Louisiana 70821-4312 Attn: Permit Compliance Unit U.S. Environmental Protection Agency, Region 6 Water Enforcement Branch, 6 EN-WC 1445 Ross Avenue Dallas, Texas 75202
| |
| : d. The permittee shall submit a Final Report on Toxicity Reduction Evaluation Activities no later than twenty-eight (28) months from confirming lethality in the retests, which provides information pertaining to the specific control mechanism selected that will, when implemented, result in the permittee achieving compliance with permit biomonitoring requirements and/or chemical-specific limits.
| |
| The report will also provide a specific corrective action schedule for implementing the selected control mechanism.
| |
| A-40
| |
| | |
| Part II Page 24 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
| |
| A copy of the Final Report on Toxicity Reduction Evaluation Activities shall also be submitted to the above addresses.
| |
| : e. Quarterly testing during the TRE is a minimum monitoring requirement. LDEQ recommends that permittees required to perform a TR~ not rely on quarterly testing alone to ensure success in the TRE, and that additional screening tests be performed to capture toxic samples for identification of toxicants. At the end of the TRE, LDEQ will consider all information submitted and establish appropriate controls to prevent future toxic discharges, including WET and/or chemical-specific Limits per state regulations at LAC 33:IX.2707.D.l.e.
| |
| A-41
| |
| | |
| TABLE l
| |
| | |
| ==SUMMARY==
| |
| SHEET Daphnia pulex ACUTE SURVIVAL TEST RESULTS PERMITTEE: Entergy Ooerations, Inc.
| |
| FACILITY SITE: Waterford 3 Steam Electric Station LPDES'PERMIT NUMBER: LA0007374, 35260 OUTFALL IDENTIFICATION:_~O~O~l_ _ _ _ _ _ _ _ _ __
| |
| OUTFALL SAMPLE IS FROM _ _ __ SINGLE - - - - MULTIPLE DISCHARGES BIOMONITORING LABORATORY:
| |
| DILUTION WATER USED: RECEIVING WATER LAB WATER CRITICAL DILUTION 31% DATE TEST INITIATED_ _ _ _ _ __
| |
| : l. LOW-FLOW LETHALITY:
| |
| Is the mean survival at 48 hours significantly less ip=0.05) than the control survival for the low flow or critical dilution?
| |
| _ _ _ _ yes no
| |
| ----
| |
| DILUTION SERIES RESULTS-DAPHNIA TIME OF REP 0% 13% 18% 24% 31% 42%
| |
| READING A
| |
| 24-HOUR B c
| |
| D E
| |
| A 48-HOUR B c
| |
| D E
| |
| MEAN
| |
| : 2. Are the test results to be considered valid? _ _ yes no I f _X__ no (test invalid), what are the reasons for invalidity?
| |
| : 3. Is this a retest of a previous invalid test? yes no Is this a retest of a previous test failure? yes _ _ no
| |
| : 4. Enter percent effluent corresponding to each NOEC (No Observed Effect Concentration) for Daphnia pulex:
| |
| NOEC % effluent LC~48 % effluent A-42
| |
| | |
| TABLE 1
| |
| | |
| ==SUMMARY==
| |
| SHEET Pimephales promelas ACUTE SURVIVAL TEST RESULTS PERMITTEE: Entergy Ooerations, Inc.
| |
| FACILITY SITE: Waterford 3 Steam E1ectric Station LPDES PERMIT NUMBER: LA0007374, 35260 OUTFALL IDENTIFICATION:_~O~O~l----------~
| |
| OUTFALL SAMPLE IS FROM _ _ __ SINGLE MULTIPLE DISCHARGES BIOMONITORING LABORATORY:
| |
| --------------------~
| |
| DILUTION WATER USED: RECEIVING WP..TER - - -LAB WATER CRITICAL DILUTION _llL DATE TEST INITIATED
| |
| : 1. LOW-FLOW LETHALITY:
| |
| Is the mean survival at 48 hours significantly less (p=0.05) than the control survival for the low flow or critical dilution?
| |
| _ _ _ _ yes no DILUTION SERIES RESULTS-PIMEPHALES TIME OF REP 0% 13% 18% 24% 31% 42%
| |
| READING A
| |
| 24-HOUR B c
| |
| D E
| |
| A 48-HOUR B c
| |
| D E
| |
| MEAN
| |
| : 2. Are the test results to be considered valid? _ _ yes no If __X_no (test .invalid), what are the reasons for invalidity?
| |
| : 3. Is this a retest of a previous invalid test? yes _ _ no Is this a retest of a previous test failure? yes no
| |
| : 4. Enter percent effluent corresponding to each NOEC (No Observed Effect Concentration) for Pimeohales:
| |
| NOEC % effluent
| |
| % effluent A-43
| |
| | |
| REVISED 06-23-10 Page 1 of 18 PARTlll STANDARD CONDITIONS FOR LPDES PERMITS SECTION A GENERAL CONDITIONS
| |
| : 1. Introduction In accordance with the provisions of LAC 33:1X.2701, et seq., this permit incorporates either expressly or by reference ALL conditions and requirements applicable to the Louisiana Pollutant Discharge Elimination System Permits (LPDES) set forth in the Louisiana Environmental Quality Act (LEQA). as amended, as well as ALL applicable regulations.
| |
| : 2. Duty to Comply The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of the Clean Water Act (CWA) and the Louisiana Environmental Quality Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application.
| |
| : 3. Penalties for Violation of Permit Conditions
| |
| : a. La. R. S. 30:2025 provides for civil penalties for violations of these regulations and the Louisiana Environmental Quality Act. La. R. S. 30:2076.2 provides for criminal penalties for violation of any provisions of the LPDES or any order or any permit condition or limitation issued under or implementing any provisions of the LPDES program. (See Section E. Penalties for Violation of Permit Conditions for additional details).
| |
| : b. Any person may be assessed an administrative penalty by the State Administrative Authority under La.
| |
| R. S. 30:2025 for violating a permit condition or limitation implementing any of the requirements of the LPDES program in a permit issued under the regulations or the Louisiana Environmental Quality Act.
| |
| : 4. Toxic Pollutants
| |
| : a. Other effluent limitations and standards under Sections 301, 302, 303, 307, 318, and 405 of the Clean Water Act. If any applicable toxic effluent standard or prohibition (including any schedule of compliance specified in such effluent standard or prohibition) is promulgated under Section 307(a) of the Clean Water Act for a toxic pollutant and that standard or prohibition is more stringent than any limitation on the pollutant in this permit, the state administrative authority shall institute proceedings under these regulations to inodify or revoke and reissue the permit to conform to the toxic effluent standard or prohibition.
| |
| : b. The permittee shall comply with effluent standards or prohibitions established under Section 307(a) of the Clean Water Act for toxic pollutants and with standards for sewage sludge use or disposal established under Section 405(d) of the Clean Water Act within the time provided in the regulations that establish these standards or prohibitions, or standards for sewage sludge use or disposal, even if the permit has not yet been modified to incorporate the requirement.
| |
| : 5. Duty to Reapply
| |
| : a. Individual Permits. If the permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the permittee must apply for and obtain a new permit. The new application shall be submitted at least 180 days before the expiration date of the existing permit, unless permission for a later date has been granted by the state administrative authority. (The state administrative authority shall not grant permission for applications to be submitted later than the expiration date of the existing permit.) Continuation of expiring permits shall be governed by regulations promulgated at LAC 33:1X.2321 and any subsequent amendments.
| |
| form_7027 _r07 6-23-10 A-44
| |
| | |
| REVISED 06-23-10 Page 2 of 18
| |
| : b. General Permits. General permits expire five years after the effective date. The 180-day reapplication period as defined above is not applicable to general permit authorizations. Reissued general permits may provide automatic coverage for permittees authorized under the previous version of the permit, and no new application is required. Requirements for obtaining authorization under the reissued general permit will be outlined in Part I of the new permit. Permittees authorized to discharge under an expiring general permit should follow the requirements for obtaining coverage under the new general permit to maintain discharge authorization.
| |
| : 6. Permit Action This permit may be modified, revoked and reissued, or terminated for cause in accordance with LAC 33:1X.2903, 2905, 2907, 3105 and 6509. The causes may include, but are not limited to, the following:
| |
| : a. Noncompliance by the permittee with any condition of the permit;
| |
| : b. The permittee's failure in the application or during the permit issuance process to disclose fully all relevant facts, or the permittee's misrepresentation of any relevant facts at any time; or
| |
| : c. A determination that the permitted activity endangers human health or the environment and can only be regulated to acceptable levels by permit modification or termination;
| |
| : d. A change in any condition that requires either a temporary or a permanent reduction or elimination of any discharge;
| |
| : e. Failure to pay applicable fees under the provisions of LAC 33: IX. Chapter 13;
| |
| : f. Change of ownership or operational control.
| |
| The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes or anticipated noncompliance does not stay any permit condition.
| |
| : 7. Property Rights This permit does not convey any property rights of any sort, or any exclusive privilege.
| |
| : 8. Dutv to Provide Information The permittee shall furnish to the state administrative authority, within a reasonable time, any information which the state administrative authority may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. The permittee shall also furnish to the state administrative authority, upon request, copies of records required to be kept by this permit.
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| : 9. Criminal and Civil Liability Except as provided in permit conditions on "Bypassing" and "Upsets", nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance. Any false or materially misleading representation or concealment of information required to be reported by the provisions of the permit, the Act, or applicable regulations, which avoids or effectively defeats the regulatory purpose of the Permit may subject the Permittee to criminal enforcement pursuant to La. R.S. 30:2025.
| |
| : 10. Oil and Hazardous Substance Liability Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject under Section 311 of the Clean Water Act.
| |
| : 11. State Laws Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties established pursuant to any applicable State law or regulation under authority preserved by Section 51 O of the Clean Water Act.
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| form_7027_r07 6-23-10 A-45
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| | |
| REVISED 06-23-10 Page 3 of 18
| |
| : 12. Severability If any provision of these rules and regulations, or the application thereof, is held to be invalid, the remaining provisions of these rules and regulations shall not be affected, so long as they can be given effect without the invalid provision. To this end, the provisions of these rules and regulations are declared to be severable.
| |
| : 13. Dilution A permittee shall not achieve any effluent concentration by dilution unless specifically authorized in the permit. A permittee shall not increase the use of process water or cooling water or otherwise attempt to dilute a discharge as a partial or complete substitute for adequate treatment to achieve permit limitations or water quality.
| |
| : 14. Facilities Requiring Approval from Other State Agencies In accordance with La. R.S.40.4(A)(6) the plans and specifications of all sanitary sewerage treatment systems, both public and private, must be approved by the Department of Health and Hospitals state health officer or his designee. It is unlawful for any person, firm, or corporation, both municipal and private to operate a sanitary sewage treatment facility without proper authorization from the state health officer.
| |
| In accordance with La. R.S.40.1149, it is unlawful for any person, firm or corporation, both municipal and private, operating a sewerage system to operate that system unless the competency of the operator is duly certified by the Department of Health and Hospitals state health officer. Furthermore, it is unlawful for any person to perform the duties of an operator without being duly certified.
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| In accordance with La. R.S.48.385, it is unlawful for any industrial wastes, sewage, septic tanks effluent, or any noxious or harmful matter, solid, liquid or gaseous to be discharged into the side or cross ditches or placed upon the rights-of-ways of state highways without the prior written consent of the Department of Transportation and Development chief engineer or his duly authorized representative and of the secretary of the Department of Health and Hospitals.
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| SECTION B. PROPER OPERATION AND MAINTENANCE
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| : 1. Need to Halt or Reduce not a Defense It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.
| |
| : 2. Duty to Mitigate The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment. The permittee shall also take all reasonable steps to minimize or correct any adverse impact on the environment resulting from noncompliance with the permit, including such accelerated or additional monitoring as necessary to determine the nature and impact of the noncomplying discharge.
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| : 3. Proper Operation and Maintenance
| |
| : a. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit.
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| : b. The permittee shall provide an adequate operating staff which is duly qualified to carry out operation, maintenance and other functions necessary to ensure compliance with the conditions of this permit.
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| form_7027 _r07 6-23-10 A-46
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| | |
| REVISED 06-23-10 Page 4of18
| |
| : 4. Bypass of Treatment Facilities
| |
| : a. Bvpass. The intentional diversion of waste streams from any portion of a treatment facility.
| |
| : b. Bypass not exceeding limitations. The permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the provisions of Section B.4.c. and 4.d of these standard conditions.
| |
| : c. Notice (1) Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit prior notice to the Office of Environmental Services, Water Permits Division, if possible at least ten days before the date of the bypass.
| |
| (2) Unanticipated bypass. The permittee shall submit notice of an unanticipated bypass as required in LAC 33:1X.2701.L.6 (24-hour notice) and Section D.6.e. of these standard conditions.
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| : d. Prohibition of bypass (1) Bypass is prohibited, and the state administrative authority may take enforcement action against a permittee for bypass, unless:
| |
| (a) Bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; (b) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal periods of equipment downtime. This condition is not satisfied if adequate back-up equipment should have been installed in the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal periods of equipment downtime or preventive maintenance; and, (c) The permittee submitted notices as required by Section B.4.c of these standard conditions.
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| (2) The state administrative authority may approve an anticipated bypass after considering its adverse effects, if the state administrative authority determines that it will meet the three conditions listed in Section B.4.d(1) of these standard conditions.
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| : 5. Upset Conditions
| |
| : a. Upset An exceptional incident in which there is unintentional and temporary noncompliance with technology-based permit effluent limitations because of factors beyond the reasonable control of the permittee. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation.
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| : b. Effect of an upset. An upset constitutes an affirmative defense to an action brought for noncompliance witli such technology-based permit effluent limitations if the requirements of Section B.5.c. are met. No determination made during administrative review of claims that noncompliance was caused by an upset, and before an action for noncompliance, is final administrative action subject to judicial review.
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| : c. Conditions necessary for a demonstration of upset. A permittee who wishes to establish the affirmative defense of upset shall demonstrate, through property signed, contemporaneous operating logs, or other relevant evidence that (1) An upset occurred and that the permittee can identify the cause(s) of the upset; (2) The permitted facility was at the time being properly operated; and (3) The permittee submitted notice of the upset as required by LAC 33:1X.2701.L.6.b.ii. and Section 0.6.e.(2) of these standard conditions; and form_7027_r07 6-23-10 A-47
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| | |
| REVISED 06-23-10 Page 5of18 (4) The permittee complied with any remedial measures required by Section 8.2 of these standard conditions.
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| : d. Burden of proof. In any enforcement proceeding, the permittee seeking to establish the occurrence of an upset has the burden of proof.
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| : 6. Removed Substances Solids, sewage sludges, filter backwash, or other pollutants removed in the course of treatment or wastewater control shall be properly disposed of in a manner such as to prevent any pollutant from such materials from entering waters of the state and in accordance with environmental regulations.
| |
| : 7. Percent Removal For publicly owned treatment works, the 30-day average percent removal for Biochemical Oxygen Demand and Total Suspended Solids shall not be less than 85 percent in accordance with LAC 33:1X.5905.A.3. and B.3. Publicly owned treatment works utilizing waste stabilization ponds/oxidation ponds are not subject to the 85 percent removal rate for Total Suspended Solids.
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| SECTION C. MONITORING AND RECORDS
| |
| : 1. Inspection and Entry The permittee shall allow the state administrative authority or an authorized representative (including an authorized contractor acting as a representative.of the Administrator), upon the presentation of credentials and other documents as may be required by the law to:
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| : a. Enter upon the permittee's premises where a regulated facility or activity is located. or conducted, or where records must be kept under the conditions of this permit.
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| Enter upon the permittee's premises where a discharge source is or might be located or in which monitoring equipment or records required by a permit are kept for inspection or sampling purposes.
| |
| Most inspections will be unannounced and should be allowed to begin immediately, but in no case shall begin more than thirty (30) minutes after the time the inspector presents his/her credentials and announces the purpose(s) of the inspection. Delay in excess of thirty (30) minutes shall constitute a violation of this permit. However, additional time can be granted if the inspector or the Administrative Authority determines that the circumstances warrant such action; and
| |
| : b. Have access to and copy, at reasonable times, any records that the department or its authorized representative determines are necessary for the enforcement of this permit. For records maintained in either a central or private office that is open only during normal office hours and is closed at the time of inspection, the records' shall be made available as soon as the office is open, but in no case later than the close of business the next working day;
| |
| : c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment),
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| practices, or operations regulated or required under this permit; and
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| : d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise authorized by the Clean Water Act or the Louisiana Environmental Quality Act, any substances or parameters at any location.
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| : e. Sample Collection (1) When the inspector announces that samples will be collected, the permittee will be given an additional thirty (30) minutes to prepare containers in order to collect duplicates. If the permittee cannot obtain and prepare sample containers within this time, he is considered to have waived his right to collect duplicate samples and the sampling will proceed immediately. Further delay on the part of the permittee in allowing initiation of the sampling will constitute a violation of this permit.
| |
| (2) At the discretion of the administrative authority, sample collection shall proceed immediately (without the additional 30 minutes described in Section C.1.a. above) and the inspector shall supply the permittee with a duplicate sample.
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| form_7027_r07 6-23-10 A-48
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| REVISED 06-23-10 Page 6of18
| |
| : f. It shall be the responsibility of the permittee to ensure that a facility representative familiar with provisions of its wastewater discharge permit, including any other conditions or limitations, be available either by phone or in person at the facility during all hours of operation. The absence of such personnel on-site who are familiar with the permit shall not be grounds for delaying the initiation of an inspection except in situations as described in Section C.1.b. of these standard conditions. The permittee shall be responsible for providing witnesses/escorts during inspections. Inspectors shall abide by all company safety rules and shall be equipped with standard safety equipment (hard hat, safety shoes, safety glasses) normally required by industrial facilities.
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| : g. Upon written request copies of field notes, drawings, etc., taken by department personnel during an inspection shall be provided to the permittee after the final inspection report has been completed.
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| : 2. Representative Sampling Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity. All samples shall be taken at the outfall location(s) indicated in the permit. The state administrative authority shall be notified prior to any changes in the outfall location(s). Any changes in the outfall location(s) may be subject to modification, revocation and reissuance in accordance with LAC 33:1X.2903.
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| : 3. Retention of Records Except for records of monitoring information required by this permit related to the perrnittee's sewage sludge use and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR 503), the permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, for a period of at least 3 years from the date of the sample, measurement, report, or application. This period may be extended by request of the state administrative authority at any time.
| |
| : 4. Record Contents Records of monitoring information shall include:
| |
| : a. The date, exact place, and time of sampling or measurements;
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| : b. The individual(s) who performed the sampling or measurements;
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| : c. The date(s) analyses were performed;
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| : d. The time(s) analyses were begun;
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| : e. The individual(s) who performed the analyses;
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| : f. The analytical techniques or methods used;
| |
| : g. The results of such analyses; and
| |
| : h. The results of all quality control procedures.
| |
| : 5. Monitoring Procedures
| |
| : a. Monitoring results must be conducted according to test procedures approved under 40 CFR Part 136 or, in the case of sludge use or disposal, approved under 40 CFR Part 136 unless otherwise specified in 40 CFR Part 503, unless other test procedures have been specified in this permit.
| |
| : b. The permittee shall calibrate and perform maintenance procedures on all monitoring and analytical instruments at intervals frequent enough to insure accuracy of measurements and shall maintain appropriate records of such activities.
| |
| : c. The permittee or designated laboratory shall have an adequate analytical quality assurance/quality control program to produce defensible data of known precision and accuracy. All quality control measures shall be assessed and evaluated on an on-going basis and quality control acceptance criteria shall be used to determine the validity of the data. All method specific quality control as prescribed in the method shall be followed. If quality control requirements are not included in the method, the permittee or designated laboratory shall follow the quality control requirements as prescribed in the Approved Edition (40 CFR Part 136) Standard Methods for the Examination of Water and Wastes, form_7027_r07 6-23-10 A-49
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| | |
| REVISED 06-23-10 Page 7of18 Sections 1020A and 10208. General sampling protocol shall follow guidelines established in the "Handbook for Sampling and Sample Preservation of Water and Wastewater, 1982 "U.S. Environmental Protection Agency. This publication is available from the National Technical Information Service (NTIS),
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| Springfield, VA 22161, Phone number (800) 553-6847. Order by NTIS publication number PB 124503.
| |
| : 6. Flow Measurements Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The devices shall be installed, calibrated, and maintained to insure that the accuracy of the measurements is consistent with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a maximum deviation of less than 10% from true discharge rates throughout the range of expected discharge volumes. Guidance in selection, installation, calibration and operation of acceptable flow measurement devices can be obtained from the following references:
| |
| : a. "A Guide to Methods and Standards for the Measurement of Water Flow, 1975," U.S. Department of Commerce, National Bureau of Standards. This publication is available from the National Technical Information Service (NTIS), Springfield, VA 22161, Phone number (800) 553-6847. Order by NTIS publication number COM-75-10683.
| |
| : b. "Flow Measurement in Open Channels and Closed Conduits, Volumes 1 and 2," U.S. Department of Commerce, National Bureau of Standards. This publication is available from the National Technical Service (NTIS), Springfield, VA, 22161, Phone number (800) 553-6847. Order by NTIS publication number PB-273 535.
| |
| : c. "NPDES Compliance Flow Measurement Manual," U.S. Environmental Protection Agency, Office of Water Enforcement. This publication is available from the National Technical Information Service (NTIS), Springfield, VA-22161, Phone number (800) 553-6847. Order by NTIS publication number PB-82-131178.
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| : 7. Prohibition for Tampering: Penalties
| |
| : a. La. R.S. 30:2025 provides for punishment of any person who fe1lsifies, tampers with, or knowingly renders inaccurate any monitoring device or method required to be maintained under this permit.
| |
| : b. La. R.S. 30:2076.2 provides for penalties for any person who knowingly makes any false statement, representation, or certification in any record or other document submitted or required to be maintained under this permit, including monitoring reports or reports of compliance or non-compliance.
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| : 8. Additional Monitoring by the Permittee If the Permittee monitors any pollutant more frequently than required by the permit using test procedures approved under 40 CFR Part 136 (See LAC 33:1X.4901) or, in the case of sludge use and disposal, approved under 40 CFR Part 136 (See LAC 33:1X.4901) unless otherwise specified in 40 CFR Part 503, or as specified in the permit, the results of this monitoring shall be included in the calculation and reporting of the data submitted in the DMR or sludge reporting form specified by the state administrative authority.
| |
| : 9. Averaging of Measurements Calculations for all limitations which require averaging of measurements shall utilize an arithmetic mean unless otherwise specified by the state administrative authority in the permit.
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| 1O. Laboratory Accreditation
| |
| : a. LAC 33:1.Subpart 3, Chapters 45-59 provide requirements for an accreditation program specifically applicable to commercial laboratories, wherever located, that provide chemical analyses, analytical results, or other test data to the department, by contract or by agreement, and the data is:
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| (1) Submitted on behalf of any facility, as defined in La. R.S.30:2004; (2) Required as part of any permit application; (3) Required by order of the department; (4) Required to be included on any monitoring reports submitted to the department; forrn_7027 _r07 6-23-10 A-50
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| | |
| REVISED 06-23-10 Page 8 of 18 (5) Required to be submitted by contractor (6) Otherwise required by department regulations.
| |
| : b. The department laboratory accreditation program, Louisiana Environmental Laboratory Accreditation Program (LELAP) is designed to ensure the accuracy, precision, and reliability of the data generated, as well as the use of department-approved methodologies in generation of that data. Laboratory data generated by commercial environmental laboratories that are not (LELAP) accredited will not be accepted by the department. Retesting of analysis will be required by an accredited commercial laboratory.
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| Where retesting of effluent is not possible (i.e. data reported on DMRs for prior month's sampling), the data generated will be considered invalid and in violation of the LPDES permit.
| |
| : c. Regulations on the Louisiana Environmental Laboratory Accreditation Program and a list of labs that have applied for accreditation are available on the department website located under DIVISIONS 7 PERMIT SUPPORT SERVICES 7 LABORATORY ACCREDITATION at the following link:
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| http://www.deq.louisiana.gov Questions concerning the program may be directed to (225) 219-9800.
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| SECTION D. REPORTING REQUIREMENTS
| |
| ,,;' 1. Facility Changes The permittee shall give notice to the state administrative authority as soon as possible of any planned physical alterations or additions to the permitted facility. Notice is required only when:
| |
| : a. The alteration or addition to a permitted facility may meet one of the criteria for determining whether a facility is a new source in 40 CFR 122.29(b); or
| |
| : b. The alteration or addition could significantly change the nature or increase the quantity of pollutants discharged. This notification applies to pollutants which are subject neither to effluent limitations in the permit, nor to notification requirements under LAC 33: IX.2703.A.1.
| |
| : c. For Municipal Permits. Any new introduction of pollutants into the POTW from an indirect discharger which would be subject to Section 301, or 306 of the CWA if it were directly discharging those pollutants; and any substantial change in the volume or character of pollutants being introduced into that POTW by a source introducing pollutants into the POTW at the time of issuance of the permit. In no case are any new connections, increased flows, or significant changes in influent quality permitted that will cause violation of the effluent limitations specified herein.
| |
| : 2. Anticipated Noncompliance The permittee shall give advance notice to the state administrative authority of any planned changes in the permitted facility or activity which may result in noncompliance with permit requirements.
| |
| : 3. Transfers This permit is not transferable to any person except after notice to the state administrative authority. The state administrative authority may require modification or revocation and reissuance of the permit to change the name of the permittee and incorporate such other requirements as may be necessary under the Clean Water Act or the Louisiana Environmental Quality Act. (See LAC 33:1X.2901; in some cases, modification or revocation and reissuance is mandatory.)
| |
| A permit may be transferred by the permittee to a new owner or operator only if: (1 )the permit has been modified or revoked and reissued (under LAC 33:1X.2903.A.2.b) by the permittee and new owner submitting a Name/Ownership/Operator Change Form (NOC-1 Form) and approved by LDEQ (LAC 33:1.Chapter 19);
| |
| or (2) a minor modification made (under LAC 33:1X.2905) to identify the new permittee and incorporate such form_7027 _r07 6-23-10 A-51
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| | |
| REVISED 06-23-10 Page 9of18 other requirements as may be necessary under the Clean Water Act and the Louisiana Environmental Quality Act.
| |
| The NOC-1 form can be found at the following link:
| |
| http://www. deg. louisiana.gov/portal/Portals/O/assistance/NOC-1 %20FORM%20Jan%2025, %202006.pdf
| |
| : 4. Monitoring Reports Monitoring results shall be reported at the intervals and in the form specified in Part I or Part II of this permit.
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| The permittee shall submit properly completed Discharge Monitoring Reports (DMRs) on the form specified in the permit. Preprinted DMRs are provided to majors/92-500s and other designated facilities. Please contact the Permit Compliance Unit concerning preprints. Self-generated DMRs must be pre-approved by the Permit Compliance Unit prior to submittal. Self-generated DMRs are approved on an individual basis. Requests for approval of self-generated DMRs should be submitted to:
| |
| Supervisor, Permit Compliance Unit Office of Environmental Compliance Post Office Box 4312 Baton Rouge, LA 70821-4312 Copies of blank DMR templates, plus instructions for completing them, and EPA's LPDES Reporting Handbook are available at the department website located at:
| |
| http://www.deg.louisiana.gov/portal/Default.aspx?tabid=2276
| |
| : 5. Compliance Schedules Reports of compliance or noncompliance with, or any progress reports on, interim and final requirements contained in any compliance schedule of this permit shall be submitted no later than 14 days following each schedule date.
| |
| : 6. Requirements for Notification
| |
| : a. Emergency Notification As required by LAC 33.1.3915, in the event of an unauthorized discharge that does cause an emergency condition, the discharger shall notify the hotline (DPS 24-hour Louisiana Emergency Hazardous Materials Hotline) by telephone at (225) 925-6595 (collect calls accepted 24 hours a day) immediately (a reasonable period of time after taking prompt measures to determine the nature, quantity, and potential off-site impact of a release, considering the exigency of the circumstances), but in no case later than one hour after learning of the discharge. (An emergency condition is any condition which could reasonably be expected to endanger the health and safety of the public, cause significant adverse impact to the land, water, or air environment, or cause severe damage to property.) Notification required by this section will be made regardless of the amount of discharge. Prompt Notification Procedures are listed in Section D.6.c. of these standard conditions.
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| A written report shall be provided within seven calendar days after the notification. The report shall contain the information listed in Section D.6.d. of these standard conditions and any additional information in LAC 33:1.3925.B.
| |
| : b. Prompt Notification As required by LAC 33:1.3917, in the event of an unauthorized discharge that exceeds a reportable quantity specified in LAC 33:1.Subchapter E, but does not cause an emergency condition, the discharger shall promptly notify the department within 24 hours after learning of the discharge. Notification should be made to the Office of Environmental Compliance, Surveillance Division Single Point of Contact (SPOC) in accordance with LAC 33:1.3923.
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| form_7027 _r07 6-23-10 A-52
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| | |
| REVISED 06-23-10 Page 10of18 In accordance with LAC 33:1.3923, prompt notification shall be provided within a time frame not to exceed 24 hours and shall be given to the Office of Environmental Compliance, Surveillance Division (SPOC) as follows:
| |
| (1) by the Online Incident Reporting screens found at http://www.deq.louisiana.gov/portal/tabid/66/Default.aspx ;or (2) by e-mail utilizing the Incident Report Form and instructions found at http://www.deq.louisiana.gov/portal/tabid/66/Default.aspx;or (3) by telephone at (225) 219-3640 during office hours, or (225) 342-1234 after hours and on weekends and holidays.
| |
| : c. Content of Prompt Notifications. The following guidelines will be utilized as appropriate, based on the conditions and circumstances surrounding any unauthorized discharge, to provide relevant information regarding the nature of the discharge:
| |
| ( 1) the name of the person making the notification and the telephone number where any return calls from response agencies can be placed; (2) the name and location of the facility or site where the unauthorized discharge is imminent or has occurred, using common landmarks. In the event of an incident involving transport, include the name and address of the transporter and generator; (3) the date and time the incident began and ended, or the estimated time of continuation if the discharge is continuing; (4) the extent of any injuries and identification of any known personnel hazards that response agencies may face; (5) the common or scientific chemical name, the U.S. Department of Transportation hazard classification, and the best estimate of amounts of any and all discharged pollutants; (6) a brief description of the incident sufficient to allow response agencies to formulate their level and extent of response activity.
| |
| : d. Written Notification Procedures. Written reports for any unauthorized discharge that requires notification under Section D.6.a. or 6.b., or shall be submitted by the discharger to the Office of Environmental Compliance, Surveillance Division SPOC in accordance with LAC 33:1.3925 within seven calendar days after the notification required by D.6.a_ or 6.b., unless otherwise provided for in a valid permit or other department regulation. Written notification reports shall include, but not be limited to, the following information:
| |
| (1) the name, address, telephone number, Agency Interest (Al) number (number assigned by the department) if applicable, and any other applicable identification numbers of the person, company, or other party who is filing the written report, and specific identification that the report is the written follow-up report required by this section; (2) the time and date of prompt notification, the state official contacted when reporting, the name of person making that notification, and identification of the site or facility, vessel, transport vehicle, or storage area from which the unauthorized discharge occurred; (3) date(s), time(s), and duration of the unauthorized discharge and, if not corrected, the anticipated time it is expected to continue; (4) details of the circumstances (unauthorized discharge description and root cause) and events leading to any unauthorized discharge, including incidents of loss of sources of radiation, and if the release point is subject to a permit:
| |
| (a) the current permitted limit for the pollutant(s) released;and (b) the permitted release point/outfall ID.
| |
| {5) the common or scientific chemical name of each specific pollutant that was released as the result of an unauthorized discharge, including the CAS number and U.S. Department of Transportation hazard classification, and the best estimate of amounts of any and all released pollutants (total amount of each compound expressed in pounds, including calculations);
| |
| (6) a statement of the actual or probable fate or disposition of the pollutant or source of radiation and what off-site impact resulted; form_7027 _r07 6-23-10 A-53
| |
| | |
| REVISED 06-23-10 Page 11 of 18 (7) remedial actions taken, or to be taken, to stop unauthorized discharges or to recover pollutants or sources of radiation.
| |
| (8) Written notification reports shall be submitted to the Office of Environmental Compliance, Surveillance Division SPOC by mail or fax. The transmittal envelope and report or fax cover page and report should be clearly marked "UNAUTHORIZED DISCHARGE NOTIFICATION REPORT."
| |
| Written reports (LAC 33:1.3925) should be mailed to:
| |
| Louisiana Department of Environmental Quality Post Office Box 4312 Baton Rouge, LA 70821-4312 ATIENTION: EMERGENCY AND RADIOLOGICAL SERVICES DIVISION- SPOC "UNAUTHORIZED DISCHARGE NOTIFICATION REPORT" The Written Notification Report may also be faxed to the Louisiana Department of Environmental Quality, Office of Environmental Compliance, Emergency and Radiological Services Division at:
| |
| (225)-219-4044.
| |
| Please see LAC 33:1.3925.B for additional written notification procedures.
| |
| : e. Twenty-four Hour Reporting. The permittee shall report any noncompliance which may endanger human health or the environment. Any information shall be provided orally within 24 hours from the time the permittee becomes aware of the circumstances. A written submission shall also be provided within five days of the time the permittee becomes aware of the circumstances. The written submission shall contain a description of the noncompliance and its cause; the period of noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent recurrence of the noncompliance. The following shall be included as information which must be reported within 24hours:
| |
| (1) Any unanticipated bypass which exceeds any effluent limitation in the permit (see LAC 33:1X.2701.M.3.b.);
| |
| (2) Any upset which exceeds any effluent limitation in the permit; (3) Violation of a maximum daily discharge limitation for any of the pollutants listed by the state administrative authority in Part II of the permit to be reported within 24 hours (LAC 33:1X.2707.G.).
| |
| : 7. Other Noncompliance The permittee shall report all instances of noncompliance not reported under Section 0.4., 5., and 6., at the time monitoring reports are submitted. The reports shall contain the information listed in Section 0.6.e.
| |
| : 8. Other Information Where the permittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted incorrect information in a permit application or in any report to the state administrative authority, it shall promptly submit such facts or information.
| |
| : 9. Discharges of Toxic Substances In addition to the reporting requirements under Section D.1-8, all existing manufacturing, commercial, mining, and silvicultural dischargers must notify the Office of Environmental Services, Water Permits Division as soon as they know or have reason to believe:
| |
| : a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of any toxic pollutant:
| |
| : i. listed at LAC 33:1X.7107, Tables II and Ill (excluding Total Phenols) which is not limited in the permit, if that discharge will exceed the highest of the following notification levels:
| |
| (1) One hundred micrograms per liter (100 µg/L);
| |
| (2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micro-grams per liter (500 µg/L) for 2,4 -dinitro-phenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/L) for antimony; form_7027_r07 6-23-10 A-54
| |
| | |
| REVISED 06-23-10 Page 12 of 18 (3) Five (5) times the maximum concentration value reported for that pollutant in the permit application in accordance with LAC33:1X.2501.G.7; or (4) The level established by the state administrative authority in accordance with LAC 33:1X.2707.F; or ii. which exceeds the reportable quantity levels for pollutants at LAC 33:1. Subchapter E.
| |
| : b. That any activity has occurred or will occur which would result in any discharge, on a non-routine or infrequent basis, of a toxic pollutant:
| |
| : i. listed at LAC 33:1X.7107, Tables II and Ill (excluding Total Phenols) which is not limited in the permit, if that discharge will exceed the highest of the following "notification levels":
| |
| (1) Five hundred micrograms per liter (500 µg/L):
| |
| (2) One milligram per liter (1 mg/L) for antimony; (3) Ten (10) times the maximum concentration value reported for that pollutant in the permit application in accordance with LAC 33:1X.2501.G.7; or (4) The level established by the state administrative authority in accordance with LAC 33:1X.2707.F; or ii. which exceeds the reportable quantity levels for pollutants at LAC 33:1. Subchapter E.
| |
| : 10. Signatory Requirements All applications, reports, or information submitted to the state administrative authority shall be signed and certified.
| |
| : a. All permit applications shall be signed as follows:
| |
| (1) For a corporation - by a responsible corporate officer. For the purpose of this section, a responsible corporate officer means:
| |
| (a) A president, secretary, treasurer, or vice-president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision making functions for the corporation; or, (b) The manager of one or more manufacturing, production, or operating facilities, provided: the manager is authorized to make management decisions that govern the operation of the regulated facility, including having the explicit or implicit duty of making major capital investment recommendations and initiating and directing other comprehensive measures to ensure long term environmental compliance with environmental laws and regulations; the manager can ensure that the necessary systems are established or actions taken to gather complete and accurate information for permit application requirements; and the authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures.
| |
| NOTE: DEQ does not require specific assignments or delegations of authority to responsible corporate officers identified in Section D.10.a(1)(a). The age,ncy will presume that these responsible corporate officers have the requisite authority to sign permit applications unless the corporation has notified the state administrative authority to the contrary. Corporate procedures governing authority to sign permit applications may provide for assignment or delegation to applicable corporate positions under Section 0.1 O.a(1 )(b) rather than to specific individuals.
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| (2) For a partnership or sole proprietorship - by a general partner or the proprietor, respectively; or (3) For a municipality, state, federal, or other public agency - by either a principal executive officer or ranking elected official. For purposes of this section, a principal executive officer of a federal agency includes:
| |
| (a) The chief executive officer of the agency, or (b) A senior executive officer having responsibility for the overall operations of a principal geographic unit of the agency (e.g., Regional Administrators of EPA).
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| form_7027 _r07 6-23-10 A-55
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| | |
| REVISED 06-23-10 Page 13 of 18
| |
| : b. All reports required by permits and other information requested by the state administrative authority shall be signed by a person described in Section D.10.a., or by a duly authorized representative of that person. A person is a duly authorized representative only if:
| |
| (1) The authorization is made in writing by a person described in Section 0.1 O.a. of these standard conditions; (2) The authorization specifies either an individual or a position having responsibility for the overall operation of the regulated facility or activity such as the position of plant manager, operator of a well or a well field, superintendent, position of equivalent responsibility, or an individual or position having overall responsibility for environmental matters for the company, (a duly authorized representative may thus be either a named individual or an individual occupying a named position; and, (3) The written authorization is submitted to the state administrative authority.
| |
| : c. Changes to authorization. If an authorization under Section D.10.b. is no longer accurate because a different individual or position has responsibility for the overall operation of the facility, a new authorization satisfying the requirements of Section D.10.b. must be submitted to the state administrative authority prior to or together with any reports, information, or applications to be signed by an authorized representative.
| |
| : d. Certification. Any person signing a document under Section D.10. a. or b. above, shall make the following certification:
| |
| "I certify under penalty of law that this document and ail attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those *persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."
| |
| : 11. Availability of Reports All recorded information (completed permit application forms, fact sheets, draft permits, or any public document) not classified as confidential information under La. R.S. 30:2030(A) and 30:2074(0) and designated as such in accordance with these regulations (LAC 33:1X.2323 and LAC 33:1X.6503) shall be made available to the public for inspection and copying during normal working hours in accordance with the Public Records Act, La. R.S. 44:1 et seq.
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| Claims of confidentiality for the following will be denied:
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| : a. The name and address of any permit applicant or permittee;
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| : b. Permit applications, permits, and effluent data.
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| : c. Information required by LPDES application forms provided by the state administrative authority under LAC 33:1X.2501 may not be claimed confidential. This includes information submitted on the forms themselves and any attachments used to supply information required by the forms.
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| SECTION E. PENALTIES FOR VIOLATIONS OF PERMIT CONDITION
| |
| : 1. Criminal
| |
| : a. Negligent Violations The Louisiana Revised Statutes La. R. S. 30:2076.2 provides that any person who negligently violates any provision of the LPDES, or any order issued by the secretary under the LPDES, or any permit condition or limitation implementing any such provision in a permit issued under the LPDES by the secretary, or any requirement imposed in a pretreatment program approved under the LPDES is subject to a fine of not less than $2,500 nor more than $25,000 per day of violation, or by imprisonment for not more than 1 year, or both. If a conviction of a person is for a violation committed after a first conviction of such person, he shall be subject to a fine of not more than $50,000 per day of violation, or imprisonment of not more than two years, or both.
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| form_7027_r07 6-23-10 A-56
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| REVISED 06-23-10 Page 14of18
| |
| : b. Knowing Violations The Louisiana Revised Statutes La. R. S. 30:2076.2 provides that any person who knowingly violates any provision of the LPDES, or any permit condition or limitation implementing any such provisions in a permit issued under the LPDES, or any requirement imposed in a pretreatment program approved under the LPDES is subject to a fine of not less than $5,000 nor more than $50,000 per day of violation, or imprisonment for not more than 3 years, or both. If a conviction of a person is for a violation committed after a first conviction of such person, he shall be subject to a fine of not more than $100,000 per day of violation, or imprisonment of not more than six years, or both.
| |
| : c. Knowing Endangerment The Louisiana Revised Statutes La. R. S. 30:2076.2 provides that any person who knowingly violates any provision of the LPDES, or any order issued by the secretary under the LPDES, or any permit condition or limitation implementing any of such provisions in a permit issued under the LPDES by the secretary, and who knows at that time that he thereby places another person in imminent danger of death or serious bodily injury, shall, upon conviction, be subject to a fine of not more than $250,000, or by imprisonment for not more than 15 years, or both. A person which is an organization shall, upon conviction of violating this Paragraph, be subject to a fine of not more than one million dollars. If a conviction of a person is for a violation committed after a first conviction of such person under this Paragraph, the maximum punishment shall be doubled with respect to both fine and imprisonment.
| |
| : d. False Statements The Louisiana Revised Statutes La. R. S. 30:2076.2 provides that any person who knowingly makes any false material statement, representation, or certification in any application, record, report, plan, or other document filed or required to be maintained under the LPDES or who knowingly falsifies, tampers with, or renders inaccurate, any monitoring device or method required to be maintained under the LPDES, shall, upon conviction, be subject to a fine of not more than $10,000, or imprisonment for not more than 2 years, or both. If a conviction of a person is for a violation committed after a first conviction of such person under this Subsection, he shall be subject to a fine of not more than $20,000 per day of violation, or imprisonment of not more than 4 years, or both.
| |
| : 2. Civil Penalties The Louisiana Revised Statutes La. R. S. 30:2025 provides that any person found to be in violation of any requirement of this Subtitle may be liable for a civil penalty, to be assessed by the secretary, an assistant secretary, or the court, of not more than the cost to the state of any response action made necessary by such violation which is not voluntarily paid by the violator, and a penalty of not more than $32,500 for each day of violation. However, when any such violation is done intentionally, willfully, or knowingly, or results in a discharge or disposal which causes irreparable or severe damage to the environment or if the substance discharged is one which endangers human life or health, such person may be liable for an additional penalty of not more than one million dollars.
| |
| (PLEASE NOTE: These penalties are listed in their entirety in Subtitle II of Title 30 of the Louisiana Revised Statutes.)
| |
| SECTION F. DEFINITIONS All definitions contained in Section 502 of the Clean Water Act shall apply to this permit and are incorporated herein by reference. Additional definitions of words or phrases used in this permit are as follows:
| |
| : 1. Clean Water Act (CWA) means the Clean Water Act (formerly referred to as the Federal Water Pollution Control Act or the Federal Water Pollution Control Act Amendments of 1972) Pub.L.92-500, as amended by Pub.L. 95-217, Pub.L. 95-576, Pub.L. 96-483 and Pub.L. 97-117, 33 U.S.C. 1251 et. seq.).
| |
| : 2. Accreditation means the formal recognition by the department of a laboratory's competence wherein specific tests or types of tests can be accurately and successfully performed in compliance with all minimum requirements set forth in the regulations regarding laboratory accreditation.
| |
| form_7027 _r07 6-23-10 A-57
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| | |
| REVISED 06-23-10 Page 15of18
| |
| : 3. Administrator means the Administrator of the U.S. Environmental Protection Agency, or an authorized representative.
| |
| : 4. Applicable Standards and Limitations means all state, interstate and federal standards and limitations to which a discharge is subject under the Clean Water Act, including, effluent limitations, water quality standards of performance, toxic effluent standards or prohibitions, best management practices, and pretreatment standards under Sections 301, 302, 303, 304, 306, 307, 308 and 403.
| |
| : 5. Applicable water quality standards means all water quality standards to which a discharge is subject under the Clean Water Act.
| |
| : 6. Commercial Laboratory means any laboratory, wherever located, that performs analyses or tests for third parties for a fee or other compensation and provides chemical analyses, analytical results, or other test data to the department. The term commercial laboratory does not include laboratories accredited by the Louisiana Department of Health and Hospitals in accordance with La. R.S.49:1001 et seq.
| |
| : 7. Daily Discharge means the discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the calendar day for purposes of sampling. For pollutants with limitations expressed in temis of mass, the daily discharge is calculated as the total mass of the pollutant discharged over the sampling day. For pollutants with limitations expressed in other units of measurement, the daily discharge is calculated as the average measurement of the pollutant over the sampling day. Daily discharge determination of concentration made using a composite sample shall be the concentration of the composite sample.
| |
| : 8. Daily Maximum discharge limitation means the highest allowable "daily discharge".
| |
| : 9. Director means the U.S. Environmental Protection Agency Regional Administrator, or the state administrative authority, or an authorized representative.
| |
| : 10. Domestic septage means either liquid or solid material removed from a septic tank, cesspool, portable toilet, Type Ill marine sanitation device, or similar treatment works that receives only domestic sewage. Domestic septage does not include liquid or solid material removed from a septic tank, cesspool, or similar treatment works that receives either commercial wastewater or industrial wastewater and does not include grease removed from grease trap at a restaurant.
| |
| : 11. Domestic sewage means waste and wastewater from humans, or household operations that is discharged to or otherwise enters a treatment works.
| |
| : 12. Environmental Protection Agency or (EPA) means the U.S. Environmental Protection Agency.
| |
| : 13. Grab sample means an individual sample collected over a period of time not exceeding 15 minutes, unless more time is needed to collect an adequate sample, and is representative of the discharge.
| |
| : 14. Industrial user means a nondomestic discharger, as identified in 40 CFR 403, introducing pollutants to a publicly owned treatment works.
| |
| : 15. LEQA means the Louisiana Environmental Quality Act.
| |
| : 16. Louisiana Pollutant Discharge Elimination System (LPDES) means those portions of the Louisiana Environmental Quality Act and the Louisiana Water Control Law and all regulations promulgated under their authority which are deemed equivalent to the National Pollutant Discharge Elimination System (NPOES) under the Clean Water Act in accordance with Section 402 of the Clean Water Act and all applicable federal regulations.
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| forrn_7027_r07 6-23-10 A-58
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| | |
| REVISED 06-23-10 Page 16of18
| |
| : 17. Monthly Average, other than for fecal coliform bacteria, discharge limitations are calculated as the sum of all "daily discharge(s)" measured during a calendar month divided by the number of "daily discharge(s)"
| |
| measured during that month. When the permit establishes monthly average concentration effluent limitations or conditions, and flow is measured as continuous record or with a totalizer, the monthly average concentration means the arithmetic average (weighted by flow) of all "daily discharge(s)" of concentration determined during the calendar month where C = daily discharge concentration, F = daily flow and n =
| |
| number of daily samples; monthly average discharge =
| |
| C1F1 + C2F2 + ... + CnFn F1 + F2 + ... + Fn When the permit establishes monthly average concentration effluent limitations or conditions, and the flow is not measured as a continuous record, then the monthly average concentration means the arithmetic average of all "daily discharge(s)" of concentration determined during the calendar month.
| |
| The monthly average for fecal coliform bacteria is the geometric mean of the values for all effluent samples collected during a calendar month.
| |
| : 18. National Pollutant Discharge Elimination System (NPDES) means the national program for issuing, modifying, revoking and reissuing, terminating, monitoring and enforcing permits, and imposing and enforcing pretreatment requirements, under Sections 307, 318, 402, and 405 of the Clean Water Act.
| |
| : 19. Severe property damage means substantial physical damage to property, damage to the treatment facilities that causes them to become inoperable, or substantial and permanent loss of natural resources that can reasonably be expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused by delays in production.
| |
| : 20. Sewage sludge means any solid, semi-solid, or liquid residue removed during the treatment of municipal wastewater or domestic sewage. Sewage sludge includes, but is not limited to, solids removed during primary, secondary, or advanced wastewater treatment, scum, domestic septage, portable toilet pumpings, Type Ill marine sanitation device pumpings (33 CFR Part 159), and sewage sludge products. Sewage sludge does not include grit or screenings, or ash generated during the incineration of sewage sludge.
| |
| : 21. Stormwater Runoff-aqueous surface runoff including any soluble or suspended material mobilized by naturally occurring precipitation events.
| |
| : 22. Surface Water: all lakes, bays, rivers, streams, springs, ponds, impounding reservoirs, wetlands, swamps, marshes, water sources, drainage systems and other surface water, natural or artificial, public or private within the state or under its jurisdiction that are not part of a treatment system allowed by state law, regulation, or permit.
| |
| : 23. Treatment works means any devices and systems used in the storage, treatment, recycling and reclamation of municipal sewage and industrial wastes of a liquid nature to implement Section 201 of the Clean Water Act, or necessary to recycle or reuse water at the most economical cost over the estimated life of the works, including intercepting sewers, sewage collection systems, pumping, power and other equipment, and their appurtenances. extension, improvement, remodeling, additions, and alterations thereof. (See Part 212 of the Clean Water Act)
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| : 24. For fecal coliform bacteria, a sample consists of one effluent grab portion collected during a 24-hour period at peak loads.
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| : 25. The term MGD shall mean million gallons per day.
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| : 26. The term GPD shall mean gallons per day.
| |
| : 27. The term mg/L shall mean milligrams per liter or parts per million (ppm).
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| form_7027 _r07 6-23-10 A-59
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| | |
| REVISED 06-23-10 Page 17of18
| |
| : 28. The term SPC shall mean Spill Prevention and Control. Plan covering the release of pollutants as defined by the Louisiana Administrative Code (LAC 33:1X.Chapter 9).
| |
| : 29. The term SPCC shall mean Spill Prevention Control and Countermeasures Plan .. Plan covering the release of pollutants as defined in 40 CFR Part 112.
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| : 30. The term .b!.9lk shall mean micrograms per liter or parts per billion (ppb).
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| : 31. The term ng/L shall mean nanograms per liter or parts per trillion (ppt).
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| : 32. Visible Sheen: a silvery or metallic sheen, gloss, or increased reflectivity: visual color; or iridescence on the water surface.
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| : 33. Wastewater-liquid waste resulting from commercial, municipal, private, or industrial processes. Wastewater includes, but is not limited to, cooling and condensing waters, sanitary sewage, industrial waste, and contaminated rainwater runoff.
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| * 34. Waters of the State: for the purposes of the Louisiana Pollutant Discharge Elimination system, all surface waters within the state of Louisiana and, on the coastline of Louisiana and the Gulf of Mexico, all surface waters extending there from three miles into the Gulf of Mexico. For purposes of the Louisiana Pollutant Discharge Elimination System, this includes all surface waters which are subject to the ebb and flow of the tide, lakes, rivers, streams, (including intermittent streams), mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, natural ponds, impoundments of waters within the state of Louisiana otherwise defined as "waters of the United States" in 40 CFR 122.2, and tributaries of all such waters.
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| "Waters of the state" does not include waste treatment systems, including treatment ponds or lagoons designed to meet the requirements of the Clean Water Act, 33 U.S.C. 1251 et seq.
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| : 35. Weekly average, other than for fecal coliform bacteria, is the highest allowable arithmetic mean of the daily discharges over a calendar week, calculated as the sum of all "daily discharge(s)" measured during a calendar week divided by the number of "daily discharge(s)" measured during that week. When the permit establishes weekly average concentration effluent limitations or conditions, and flow is measured as continuous record or with a totalizer, the weekly average concentration means the arithmetic average (weighted by flow) of all "daily discharge(s)" of concentration determined during the calendar week where C
| |
| = daily discharge concentration, F = daily flow and n = number of daily samples; weekly average discharge C,F, + C2F2 + ... + C0 Fn
| |
| =
| |
| F,+Fz+ ... +Fn When the permit establishes weekly average concentration effluent limitations or conditions, and the flow is not measured as a continuous record, then the weekly average concentration means the arithmetic average of all "daily discharge(s)" of concentration determined during the calendar week.
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| The weekly average for fecal coliform bacteria is the geometric mean of the values for all effluent samples collected during a calendar week.
| |
| : 36. Sanitary Wastewater Term(s):
| |
| : a. 3-hour composite sample consists of three effluent portions collected no closer together than one hour (with the first portion collected no earlier than 10:00 a.m.) over the 3-hour period and composited according to flow, or*a sample continuously collected in proportion to flow over the 3-hour period.
| |
| : b. 6-hour composite sample consists of six effluent portions collected no closer together than one hour (with the first portion collected no earlier than 10:00 a.m.) over the 6-hour period and composited according to flow, or a sample continuously collected in proportion to flow over the 6-hour period.
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| form_7027 _r07 6-23-10 A-60
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| | |
| REVISED 06-23-10 Page 18of18 c.12-hour composite sample consists of 12 effluent portions collected no closer together than one hour over the 12-hour period and composited according to flow, or a sample continuously collected in proportion to flow over the 12-hour period. The daily sampling intervals shall include the highest flow periods.
| |
| : d. 24-hour composite sample consists of a minimum of 12 effluent portions collected at equal time intervals over the 24-hour period and combined proportional to flow or a sample continuously collected in proportion to flow over the 24-hour period.
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| form_7027_r07 6-23-10 A-61
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| | |
| LPDES PERMIT NO. LA0007374, AI No. 35260 LPDES FACT SHEET and RATIONALE ADDENDUM FOR THE DRAFT LOUISIANA POLLUTANT DISCHARGE ELIMINATION SYSTEM (LPDES} PERMIT TO DISCHA..~GE TO WATERS OF LOUISIANA
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| : 1. Company/Facility Name: Entergy Operations, Inc.
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| Waterford 3 Steam Electric Station 17265 River Road Killona, Louisiana 70057
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| : 2. Issuing Office: Louisiana Department of Environmental Quality (LDEQ)
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| Office of Environmental Services Post Office Box 4313 Baton Rouge, Louisiana 70821-4313
| |
| : 3. Prepared By: Michelle Bickham Industrial Permits Section Water Permits Division Phone #: 225-219-3082 Date Prepared: August 24, 2010
| |
| : 4. Permit Action/Status:
| |
| A. Reason For Permit Action:
| |
| A meeting was held on August 10, 2010, to discuss the 316(b) requirements in the permit. This addendum addresses only those changes made to the 316(b} language in the fact sheet. All other information stated in the original fact sheet remains the same.
| |
| B. LPDES permit - (LA0007374}
| |
| LPDES permit effective date: February 1, 2005 LPDES permit expiration date: January 31, 2010 LPDES permit modification date: January 10, 2008 C. LPDES Draft issued - June 28, 2010. The public notice was published in the Office of Environmental Services Public Notice Mailing List on July 12, 2010, and the ST. CHARLES HERALD-GUIDE of Boutte on July 15, 2010. The comment period ended on August 16, 2010. A request for a meeting was received on August 2, 2010. The meeting was held on August 10, 2010, with Entergy Operations, Inc. and the Water Permits Division. The permit language was changed to reflect the following: ( 1) the requirement to submit information on the assessment of the cooling water system has been removed as this information was submitted on July 10, 2008, as part of the Impingement Mortality and Entrainment Characterization Study; and replaced with a requirement stating that Office may request an update of this information or additional information of the cooling water system if necessary; and (2) the statement that the A-62
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| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 2 repromulgated regulation will supersede any requirements contained in the permit has been removed and replaced with the provision that if EPA repromulgates the Phase II Rule, this permit may be reopened to comply with the repromulgated rule. The fact sheet language from the draft permit has been changed to the following:
| |
| 316(b) PHASE II RULE REQUIREMENTS July 6, 2004, EPA promulgated 'Phase II' regulations in accordance with section 316(b) of the Clean Water Act (CWA). February 2005, LDEQ promulgated 'Phase II' regulations found at LAC 33:IX.Chapter 47.Subchapter B.
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| January 25, 2007, the Second U.S. Circuit Court of Appeals remanded several provisions of the Phase II rule.
| |
| March 20, 2007, EPA issued a memo saying, "the rule should be considered suspended" .
| |
| July 9, 2007, Federal Register notice suspending all parts of the Phase II regulations except 40 CFR 125.90(b) [LAC 33:IX.4731.B].
| |
| October 2007, LDEQ suspended LAC 33: IX. Chapter 47. Subchapter B, with the exception of LAC 33:IX.4731.B.
| |
| According to EPA, 316 (b) 'Phase II' regulations are under complete reconsideration at this time. LAC 33:IX.4731.B provides for regulating the cooling water intake structure (CWIS) for existing facilities on a case-by-case basis using best professional judgment.
| |
| This facility was issued a number of previous NPDES and/or LPDES permits and has been withdrawing once-through, non-contact cooling water without any identified problems. Based on information evaluated, there have been no past or current impacts identified associated with the withdrawal of the applicable cooling water. The facility is located in the main channel of the Mississippi River at River Mile 129.5 on the west descending bank.
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| The intake structure extends out 162 feet from the bank and is equipped with a skimmer wall as to prevent debris and surface swimming organisms from entering the CWIS. The offshore location of the CWIS minimizes fish and shellfish from entering the system as the conditions of the Mississippi River (i.e., high velocity, increased debris, shifting river bed, lack of habitat/vegetation, and reduction of food source) at the location of the intake structure are not easily tolerated. LDEQ has made the determination that this CWIS represents the best technology available.
| |
| A permit modification, effective January lO, 2008, required Entergy Operations, Inc. to characterize the fish/shellfish in the vicinity of the CWIS, assess impingement mortality and entrainment (IM&E), and assess the cooling water system. The assessment results were received by LDEQ on July 10, 2008 (EDMS document 37109798).
| |
| The permittee shall comply with effective regulations promulgated in accordance with section 316 (b) of the CWA for cooling water intake A-63
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 3 structures. Based on any additional evaluation of the assessment results received by LDEQ on July 10, 2008, any new information required to be submitted to LDEQ, or a revision to the regulations, the permit may be reopened to incorporate limitations and/or requirements for the CWIS.
| |
| ADDITIONAL INFORMATION As stated in Section 9 of the original Fact Sheet, the flow requirement for Outfall 001 was changed from a daily maximum limitation of 1518 MGD to a reporting requirement only in the draft permit. This is consistent with similar outfalls for similar permits. Because flow is not a pollutant as defined by LAC33:IX.2313, anti-backsliding regulations at LAC33:IX.2707.L do not apply.
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| A-64
| |
| | |
| LPDES PERMIT NO. LA0007374, AI No. 35260 LPDES FACT SHEET and RATIONALE FOR THE DRAFT LOUISIANA POLLUTANT DISCHARGE ELIMINATION SYSTEM (LPDES) PERMIT TO DISCHARGE TO WATERS OF LOUISIANA
| |
| : 1. Company/Facility Name: Entergy Operations, Inc.
| |
| Waterford 3 Stearn Electric Station 17265 River Road Killona, Louisiana 70057
| |
| : 2. Issuing Office: Louisiana Department of Environmental Quality (LDEQ)
| |
| Office of Environmental Services Post Office Box 4313 Baton Rouge, Louisiana 70821-4313
| |
| : 3. Prepared By: Michelle Bickham Industrial Permits Section Water Permits Division Phone #: 225-219-3082 Date Prepared: April 14, 2010
| |
| : 4. Permit Action/Status:
| |
| A. Reason For Permit Action:
| |
| Proposed reissuance of an expired Louisiana Pollutant Discharge Elimination System (LPDES) permit for a 5-year term following regulations promulgated at LAC 33:IX.2711/40 CFR 122.46.
| |
| LAC 33:IX Citations: Unless otherwise stated, citations to LAC 33:IX refer to promulgated regulations listed at Louisiana Administrative Code, Title 33, Part IX.
| |
| B. LPDES permit - LPDES permit effective date: February 1, 2005 LPDES permit expiration date: January 31, 2010 LPDES permit modification date: January 10, 2008 C. Application received on July 30, 2009
| |
| : 5. Facility Information:
| |
| A. Location - 17265 River Road, Killona, St. Charles Parish B. Applicant Activity According to the application, Entergy Operations, Inc., Waterford 3 Steam Electric Station is a steam electric generating station that has a maximum electrical generating capacity of 1,104 megawatts (MWe}. The primary fuel source for the unit is enriched Uranium 235.
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| A-65
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 2
| |
| : c. Technology Basis - LAC33:IX.4903 Guideline Reference Steam Electric Power Generating 40 CFR 423 Point Source Category Other sources of technoloqv based limits:
| |
| LDEQ Stormwater Guidance, letter dated 6/17/87, from J. Dale Givens (LDEQ) to Myron Knudson (EPA Region 6)
| |
| LDEQ Sanitary General Permits LDEQ Multi-Sector General Permit for Storm Water Discharges LAROSOOOO Best Professional Judgement D. Fee Rate -
| |
| : l. Fee Rating Facility Type: major
| |
| : 2. Complexity Type: V
| |
| : 3. Wastewater Type: I
| |
| : 4. SIC code: 4911 E. Continuous Facility Effluent Flow (30-Day Average) - 1005 MGD
| |
| : 6. Receiving Waters:
| |
| Mississippi River
| |
| : 1. TSS {15%), mg/L: 32
| |
| : 2. Average Hardness, mg/L CaC0 3 : 153.4
| |
| : 3. Critical Flow, cfs: 141,955
| |
| : 4. Mixing Zone Fraction: 0.333
| |
| : 5. Harmonic Mean Flow, cfs: 366,758
| |
| : 6. River Basin: Mississippi River, Segment No. 070301
| |
| : 7. Designated Uses:
| |
| The designated uses are primary contact recreation, secondary contact recreation, fish and wildlife propagation, and drinking water supply.
| |
| Information based on the following: LAC 33:IX Chapter 11;/Recommendation(s) from the Engineering Section. Hardness and 15% TSS data comes from monitoring station #0319 on the Mississippi River east of Plaquemine at the Plaquemine ferry landing, midstream.
| |
| {email from Ronnie Bean dated 4/28/10) 40 Ament Canal
| |
| : 1. River Basin: Barataria Basin, Segment No. 020202
| |
| : 2. Designated Uses:
| |
| The designated uses are primary contact recreation, secondary contact recreation, and fish and wildlife propagation.
| |
| A-66
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric. Station LA0007374, AI No. 35260 Page 3
| |
| : 7. Outfall Information:
| |
| Outfall 001 A. Type of wastewater - the continuous discharge of once through non-contact cooling water combined with previously monitored intermittent discharges including but not limited to: steam generator blowdown, cooling tower blowdown, metal cleaning wastewaters, low volume wastewater, and stormwater from Outfalls 101, 201, 301, 401, 501, 601, 701, 801, 901, and 1001 B. Location - at the point of discharge from the circulating water system discharge structure prior to entering the Mississippi River (Latitude 29°59'49", Longitude 90°28'01"). (NOTE: During high river stages when the structure is inaccessible, representative effluent samples are collected at an alternate location between the main condenser and the discharge structure.)
| |
| : c. Treatment - intake screening, chlorination (when required), LDEQ approved mussel treatment (when required), and addition of dispersant/polymer (when required)
| |
| D. Flow - 994 MGD (average)
| |
| E. Receiving waters - Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 Outfall 101 A. Type of wastewater - the intermittent discharge from the liquid waste management system. The liquid waste management system receives low volume wastewater from the following sources, including but not limited to: the turbine and reactor building equipment and' floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423.
| |
| B. Location at the point of discharge from the liquid waste management system prior to combining with the waters of Outfall 001 (Latitude 29°59'40", Longitude 90°28'16")
| |
| : c. Treatment filtering/screening, cationic and anionic polymer injection, ion exchange, neuralization/pH adjustmnet (when required) , and distillation (when required)
| |
| D. Flow - 0.0129 MGD (average)
| |
| E. Receiving waters - through Outfall 001 thence to the Mississippi River A-67
| |
| | |
| Fact Sheet and Rationale for Entergy Operatior..s, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 4 F. Basin and segment - Mississippi River Basin, Segment 070301 Outfall 201 A. Type of wastewater the intermittent discharge from the boron management system. The boron management system receives low volume wastewater from the following sources, including but not limited to:
| |
| the turbine and reactor building equipment and floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423 B. Location - at the point of discharge from the boron management system prior to combining with the waters of Outfall 001 (Latitude 29°59'40", Longitude 90°28'16")
| |
| C. Treatment filtering/screening, ion exchange, neutralization/pH adjustment (when required), distillation (when required)
| |
| D. Flow - 0.0128 MGD (average)
| |
| E. Receiving waters - through Outfall 001 thence to the Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 Outfall 301 A. Type of wastewater - the internd ttent discharge of filter flush water from the primary water treatment system. The primary water treatment system filters riverwater for various plant uses. The filters of this system are flushed periodically with untreated river water to remove solids trapped in the filter beds.
| |
| B. Location at the point of discharge from the primary water treatment system prior to combining with the waters of Outfall 001 (Latitude 29°59'41", Longitude 90°28'20")
| |
| C. Treatment - filter/screening, separation, polymer injection (when required)
| |
| D. Flow - O. 0001 MGD (average)
| |
| E. Receiving waters - through Outfall 001 thence to the Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 A-68
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 5 Outfall 401 A. Type of wastewater - the intermittent discharge of steam generator blowdown and other low volume wastewaters as defined in 40 CFR 423 B. Location - at the point of discharge from the secondary stream plant system prior to combining with the waters of Outfall 001 (Latitude 29°59'41", Longitude 90°28'15")
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| C. Treatment - filtration, ion exchange, neutralization/pH adjustment (when required)
| |
| D. Flow - 0.042 MGD (average)
| |
| E. Receiving waters - through Outfall 001 thence to the Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 Outfall 501 A. Type of wastewater the intermittent discharge from Auxiliary Component Cooling Water Basin A. Low volume wastewaters include, but are not limited to: auxiliary component cooling water, component cooling water, Mississippi River water used for flow testing, and stormwater.
| |
| B. Location at the point of discharge from Auxiliary Component Cooling water Basin A prior to combining with the waters of Outfall 001 (Latitude 29° 59 I 44 II Longitude 90 °28 I 13 n)
| |
| I C. Treatment sedimentation, neutralization/pH adjustment (when required), side stream ionization (when required), and filtration (when required)
| |
| D. Flow - 0.26 MGD (average)
| |
| E. Receiving waters - through Outfall 001 thence to the Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 Outfall 601 l>.. Type of wastewater the intermittent discharge from Auxiliary Component Cooling Water Basin B. Low volume wastewaters include, but are not limited to: auxiliary component cooling water, component A-69
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 6 cooling water, secondary plant water system wastewater, Mississippi River water used for flow testing, and stormwater.
| |
| B. Location at the point of discharge from Auxiliary Component Cooling Water Basin B prior to combining with the waters of Outfall 001 (Latitude 29°59'44", Longitude 90°28'13")
| |
| : c. Treatment sedimentation, neµtralization/pH adjustment (when required), side stream ionization (when required), and filtration (when required)
| |
| D. Flow - 0.26 MGD (average)
| |
| E. Receiving waters - through Outfall 001 thence to the Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 Outfall 701 A. Type of wastewater - the intermittent discharge of cooling tower blowdown and low volume wastewaters from Dry Cooling Tower Sump #1.
| |
| Low volume wastewaters include, but are not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater.
| |
| (NOTE: Optional discharge to plant drainage ditches thence to Outfall 004 may occur during periods when the circulating water system is unavailable.)
| |
| B. Location - at the point of discharge from the Dry Cooling Tower Sump
| |
| #1 prior to combining with the waters of Outfall 001 (or Outfall 004) (Latitude 29°59'44", Longitude 90°28'13")
| |
| : c. Treatment sedimentation, neutralization/pH adjustment (when required), side stream ionization (when required) , filtration (when required)
| |
| D. Flow - 0.0185 MGD (average)
| |
| E. Receiving waters - through Outfall 001 thence to the Mississippi River OR through Outfall 004 thence to 40 Arpent Canal F. Basin and segment Mississippi River Basin, Segment 070301 OR Barataria Basin, Segment 020202 A-70
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 7 Outfall 801 A. Type of wastewater - the intermittent discharge of cooling tower blowdown and low volume wastewaters from Dry Cooling Tower Sump #2.
| |
| Low volume wastewater sources as defined in 40 CFR 423 include, but are not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. (NOTE: Optional discharge to plant drainage ditches thence to Outfall 004 may occur during periods when the circulating water system is unavailable.}
| |
| B. Location - at the point of discharge from the Dry Cooling Tower Sump
| |
| #2 prior to combining with the waters of Outfall 001 (or Outfall 004) (Latitude 29°59'44", Longitude 90°28'13")
| |
| : c. Treatment sedimentation, neutralization/pH adjustment (when required), side stream ionization (when required) , filtration (when required)
| |
| D. Flow - 0.068 MGD (average)
| |
| E. Receiving waters - through Outfall 001 thence to the Mississippi River OR through Outfall 004 thence to 40 Arpent Canal F. Basin and segment Mississippi River Basin, Segment 070301 OR Barataria Basin, Segment 020202 Outfall 901 A. Type of wastewater - the mobile intermittent discharge of metal cleaning wastewaters (both chemical and non-chemical} from various plant equipment components including, but not limited to: the steam generator, cooling water heat exchangers, and piping B. Location - at the point of discharge from the mobile cleaning process unit(s} prior to combining with the waters of Outfall 001 C. Treatment - chemical precipitation, neutralization, sedimentation, pre-aeration (when required) , flocculation (when required} , ion exchange (when required)
| |
| D. Flow - 0.0201 MGD (average}
| |
| E. Receiving waters - through Outfall 001 thence to the Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 A-71
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 8 Outfall 1001 A. Type of wastewater - the intermittent discharge from the yard oil separator system. Wastewater includes auxiliary boiler blowdown, stormwater, and low volume wastewaters from various sources, including plant floor drains and discharge from the industrial waste system as defined in 40 CFR 423. Low volume wastewater sources include, but are not limited to: secondary water system drains, system leakage, auxiliary boiler sumps, turbine building equipment and floor drains, turbine building floor wash downs, and laboratory drains. (NOTE: Optional discharge to Outfall 004 may occur during maintenance periods and during rain events that compromise the capacity of the discharge pumps.)
| |
| B. Location - at the point of discharge from the yard oil separator system prior to combining with the waters of Outfall 001 (or Outfall 004)* (Latitude 29°59'38", Longitude 90°28'17")
| |
| C. Treatment - sedimentation, flotation, oil/water separation, polymer injection (when required), neutralization/pH adjustment, (when required), flocculation (when required), filtration (when required)
| |
| D. Flow - 0.0553 MGD (average)
| |
| E. Receiving waters - through Outfall 001 thence to the Mississippi River OR through Outfall 004 thence to 40 Arpent Canal F. Basin and segment - Mississippi River Basin, Segment 070301 OR Barataria Basin, Segment 020202 Outfall 004 f... Type of wastewater - the intermittent discharge from the plant drainage ditch system consisting of stormwater, potable water from the fire water system, maintenance wastewaters including, but not limited to: hydrostatic test water, air conditioning condensate, low volume wastewaters including, but not limited to: reverse osmosis reject water and demineralized water. The plant drainage ditch system receives discharges during maintenance from the Dry Cooling Tower Sump #1 (Internal Outfall 701), Dry Cooling Tower Sump #2 (Internal Outfall 801) , and treated discharge from the yard oil separator system, including, but not limited to: plant floor drains and discharge from the industrial waste system (Internal Outfall 1001) -
| |
| B. Location - at the point of discharge from the stormwater drainage ditch south of the plant laydown area and prior to combining with A-72
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 9 the waters of the 40 Arpent Canal (Latitude 29°59'19", Longitude 90°28'24")
| |
| : c. Treatment - none D. Flow - 10.3 MGD (average)
| |
| E. Receiving waters - 40 Arpent Canal thence to Lac Des Allernands F. Basin and segment - Barataria Basin, Segment 020202 Outfall 005 A. Type of wastewater - the intermittent discharge of treated sanitary wastewater and a de minimis discharge from the HVAC unit from the Entergy Energy Education Center B. Location - at the point of discharge from the sewage treatment plant prior to combining with the waters of the 40 Arpent Canal (Latitude 29°58'53", Longitude 90°28'35")
| |
| C. Treatment - sewage treatment plant with chlorination D. Flow - 0.061 MGD (average)
| |
| E. Receiving waters - 40 Arpent Canal thence to Lac Des Allemands F. Basin and segment - Barataria Basin, Segment 020202
| |
| : 8. Previous Effluent Limitations Outfall 001 - the continuous discharge of once through non-contact cooling water, and previously monitored intermittent discharges including but not limited to:
| |
| steam generator blowdown, cooling tower blowdown, metal cleaning wastewaters, low volume wastewaters, and stormwater Parameter LPDES Monthly Daily Average Maximum Flow - mgd Report 1518 Continuous Continuous Recorder Recorder Temperature Report 118° F Continuous Continuous Recorder Recorder A-73
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 10 Heat (BTU) --- 9.5 x 10 3 J'1BTU/hour Continuous Recorder Total Residual - -- 211 lbs/day Chlorine* 1/week Grab
| |
| *Samples shall be representative of any periodic episodes of chlornation, biocide usage, or other potentially toxic substance discharged on an intermittent basis.
| |
| WHOLE EFFLUENT PERCENT %, UNLESS STATED MONITORING TOXICITY TESTING REQUIREMENTS (ACUTE)
| |
| MONTHLY 48-HOUR MEASUREMENT SAMPLE AVERAGE MINIMUM FREQUENCY TYPE MINIMUM NOEC, Pass/Fail [0/1], Report Report 1/quarter 24-hr.
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| Lethality, Static Composite Renewal, 48-Hour Acute, Pimephales promelas NOEC, Value [%], Report Report 1/quarter 24-hr.
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| Lethality, Static Composite Renewal, 48-Hour Acute, Pimephales promelas NOEC, Value [%] , Report Report 1/quarter . 24-hr.
| |
| Coefficient of Composite Variation, Static Renewal, 48-Hour Acute, Pimephales promelas NOEC, Pass/Fail [O, 1), Report Report 1/quarter 24-hr.
| |
| Lethality , Static Composite Renewal, 48-Hour Acute, Dap.'111ia pulex NOEC, Value [%], Report Report l/quarter 24-hr.
| |
| Lethality, Static Composite Renewal, 48-Hour Acute, Daphnia pulex A-74
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| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 11 NOEC, Value [%] ' Report Report l/quarter 24-hr.
| |
| Coefficient of Composite Variation, Static Renewal, 48-Hour Acute, Daphnia pulex There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| Outfall 001, at the point of discharge from the circulating water system discharge structure Outfall 101 - the intermittent discharge from the liquid waste management system to Final Outfall 001 via the turbine condenser cooling system. The liquid waste management system receives low volume wastewater from the following sources, including but not limited to: the turbine and reactor building equipment and floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423 Parameter LPDES Monthly Daily Average Maximum Flow - mgd --- Report l/batch Totalized TSS --- 100 mg/L l/month Grab Oil & Grease 20 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u.
| |
| l/batch l/batch Grab Grab There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| A-75
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LJl.0007374, AI No. 35260 Page 12 Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| Outfall 101, at the point cf discharge from the liquid waste management system Outfall 201 - the intermittent discharge from the boron management system to Final Outfall 001 via the turbir:e condenser cooling system. The boron management system receives low volume wastewater from the following sources, including but not limited to: the turbine and reactor building equipment and *floor drains, primary plant water makeup, laborator1 drains, and other low volume wastewater sources as defined in 40 CFR 423 Parameter LP DES Monthly Daily Average Maximum Flow - mgd -- - Report l/batch Totalized TSS --- 100 mg/L l/month Grab Oil & Grease 20 mg/L 1/month Grab pH 6.0 s.u. 9.0 s.u.
| |
| 1/batch l/batch Grab Grab There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| outfall 201, at the point of discharge from the boron management system Outfall 301 - the intermittent discharge of filter flush water from the primary water treatment system A-76
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 13 Parameter LPDES Monthly Daily Average Maximwn Flow - mgd -- - Report Weekly Totalized Clarifying Agents The quantity and types of all clarifying agents (coagulants) used in the primary water treatment system during the sampling month shall be recorded.
| |
| There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| Outfall 301, at the point of discharge from the primary water treatment system Outfall 401 - the intermittent discharge of steam generator blowdown and other low volume wast.ewaters as defined in 40 CFR 423 Parameter LPDES Monthly Daily Average Maximwn Flow - mgd -- - Report Daily Totalized*
| |
| TSS --- 100 mg/L
| |
| .l/week Grab Oil & Grease -- - 20 mg/L l/week Grab pH 6.0 s.u. 9.0 s.u.
| |
| l/week l/week.
| |
| Grab Grab
| |
| *When low volume wastewaters are discharged, the flow must be estimated.
| |
| There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| A-77
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 14 Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| Outfall 401, at the point of discharge from the secondary steam plant system Outfall 501 - the intermittent discharge from Auxiliary Component Cooling Water Basin A. Low volume wastewater include, but not limited to: auxiliary component cooling water, component cooling water, Mississippi River water used for flow testing, and stormwater Parameter LPDES Monthly Daily Average Maximum Flow - mgd --- Report l/week Estimate TOC --- 50 mg/L l/week Grab TSS* - -- 100 mg/L l/week Grab Oil & Grease --- 20 mg/L l/week Grab pH 6.0 s.u. 9.0 s.u.
| |
| l/week l/week Grab Grab
| |
| *During circulating water flow testing, sampling for TSS is not required (when Mississippi River water is used for the flow test) .
| |
| There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| Outfall 501, at the point of discharge from Auxiliary Component Cooling Water Basin A A-78
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 15 Outfall 601 - the intermittent discharge from Auxiliary Component Cooling Water Basin B. Low volume wastewaters include, but are not limited to: auxiliary component cooling water, component cooling water, secondary plant water system wastewater, Mississippi River water used for flow testing, and stormwater Parameter LPDES Monthly Daily Average Maximum Flow - mgd -- - Report l/week Estimate TOC -- - so mg/L 1/week Grab TSS* -- - 100 mg/L l/week Grab Oil & Grease --- 20 mg/L l/week Grab pH 6.0 s.u. 9.0 s.u.
| |
| l/week l/week Grab Grab
| |
| *During circulating water flow testing, sampling for TSS is not required (when Mississippi River water is used for the flow test).
| |
| There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| Outfall 601, at the point of discharge from Auxiliary Component Cooling Water Basin B Outfall 701 - the intermittent discharge of cooling tower blowdown and low volume wastewaters from Dry Cooling Tower Sump #1. Low volume wastewater as defined in 40 CFR 423 include, but are not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. Optional discharge to Final Outfall 004 via the A-79
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 16 plant drainage ditches may occur during periods when the circulating water system is unavailable Parameter LPDES Monthly Daily Average Maximum Flow - mgd -- - Report l/month Estimate TOC --- 50 mg/L l/quarter Grab TSS --- 100 mg/L l/month Grab Oil & Grease --- 20 mg/L l/month Grab FAC* -- - 0.5 mg/L l/month Grab Total Chromium* -- - 0.2 mg/L l/year Grab Total zinc* -- - 1.0 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u.
| |
| l/month l/month Grab Grab
| |
| * Sample shall be representative of periods during cooling tower blowdown discharge.
| |
| There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| Outfall 701, at the point of discharge from Dry Cooling Tower Sump #1 A-80
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 17 Outfall 801 - the intermittent discharge of cooling tower blowdown and low volume wastewaters from Dry Cooling Tower Sump #2. Low volume wastewater sources as defined in 40 CFR 423 include, but not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. Optional discharge to Final Outfall 004 via the plant drainage ditches may occur during periods when the circulating water system is unavailable Parameter LPDES Monthly Daily Average Maximum Flow - mgd --- Report l/month Estimate TOC -- - 50 mg/L l/quarter Grab TSS --- 100 mg/L l/month Grab Oil & Grease --- 20 mg/L l/month Grab FAC* - -- 0.5 mg/L l/month Grab Total Chromium* --- 0.2 mg/L l/year Grab Total Zinc* --- 1- 0 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u.
| |
| l/month l/month Grab Grab
| |
| * Sample shall be representative of periods during cooling tower blowdown discharge.
| |
| A-81
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 18 There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| Outfall 801, at the point of discharge from Dry Cooling Tower Sump #2 Outfall 901 - the mobile intermittent discharge of metal cleaning wastewaters (both chemical and non-chemical) from various plant equipment components including, but not limited to: the steam generator, cooling water heat exchangers, and piping Parameter LPDES Monthly Daily Average Maximum Flow - mgd -- - Report l/week Estimate TSS -- - 100 mg/L l/week Grab Oil & Grease -- - 20 mg/L l/week Grab Total Copper - -- l . 0 mg/L l/week Grab Total Iron --- l . 0 mg/L l/week Grab pH 6.0 s.u. 9.0 s.u.
| |
| l/week l/week Grab Grab There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| A-82
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 19 Outfall 901, at the point of discharge from the mobile cleaning process unit(s)
| |
| Outfall 1001 - the intermittent discharge from the yard oil separator system.
| |
| Wastewater includes auxiliary boiler blowdown, stormwater, and low volume wastewaters from various sources, including plant floor drains and discharge from the industriil.l waste system as defined in 40 CFR 423. Low volume wastewater sources include, but are not limited to: secondary water system drains, system
| |
| 'leakage, auxiliary boiler sumps, turbine building equipment and floor drains, turbine building floor wash downs, and laboratory drains. Optional discharge to Final Outfall 004 may occur during maintenance periods and rain events that compromise the capacity of the discharge pumps.
| |
| Parameter LP DES Monthly Daily Average Maximum Flow - mgd -- - Report l/month Estimate TSS -- - 100 mg/L l/month Grab Oil & Grease 20 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u.
| |
| l/month l/month Grab Grab There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| Outfall 1001, at the point of discharge from the yard oil separator system Outfall 004 - the intermittent discharge from the plant drainage ditch system consisting of stormwater, potable water from the fire water system, maintenance wastewaters including, but not limited to: hydrostatic test water, air conditioning condensate, low volume wastewaters including, but not limited to:
| |
| reverse osmosis reject water and demineralized water. The plant drainage ditch system receives treated carwash wastewater (Internal Outfall 204), and during A-83
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 20 maintenance activities discharges from Dry Cooling Tower Sump #1 (Internal Outfall 701), Dry Cooling Tower Sump #2 (Internal Outfall 801), and treated discharge from the yard oil separator system, including, but not limited to:
| |
| plant floor drains and discharge from the industrial waste system (Internal Outfall 1001).
| |
| Parameter LPDES Monthly Daily Average Maximum Flow - mgd --- Report 1/3 months Estimate TOC --- 50 mg/L 1/3 months Grab TSS* --- 100 mg/L 1/3 months Grab Oil & Grease 15 mg/L 1/3 months Grab pH 6.0 s.u. 9.0 s.u.
| |
| 1/3 months 1/3 months Grab Grab
| |
| *Samples shall be representative of periods during discharge of low volume wastewaters as defined in 40 CFR 423 (excludes Mississippi River water that accumulates in the condenser water boxes.)
| |
| There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| Outfall 004, at the point of discharge from the stormwater drainage ditch south of the plant laydown area A-84
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 21 Outfall 204 - the intermittent internal discharge of treated carwash wastewater Parameter LPDES Monthly Daily Average Maximum Flow - rngd -- - Report 1/3 months Estimate COD 200 rng/L 300 rng/L 1/3 months 1/3 months Grab Grab TSS --- 45 mg/L 1/3 months Grab Oil & Grease 15 mg/L 1/3 months Grab pH 6.0 s.u. 9.0 s.u.
| |
| 1/3 months 1/3 months Grab Grab Soaps & Detergents* Report -- -
| |
| 1/3 months Grab
| |
| *The quantity and types of all Soaps and/or Detergents used during the sampling month shall be recorded.
| |
| There shall be no discharge of floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| Outfall 204, at the point of discharge from the carwash treatment system A-85
| |
| | |
| Fact sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 22 Outfall 005 - the intermittent discharge of treated sanitary wastewater and a de minimis discharge from the HVAC unit from the Entergy Energy Education Center Parameter LP DES Monthly Weekly Average Average Flow - mgd - -- Report 1/6 months Estimate BOD5 -- - 45 mg/L 1/6 months Grab TSS --- 45 mg/L 1/6 months Grab Oil & Grease - -- 400 mg/L 1/6 months Grab pH 6.0 s.u. 9.0 s.u.
| |
| 1/6 months 1/6 months Grab Grab There shall be no discharge of* floating solids or visible foam in other than trace amounts.
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
| |
| Outfall 005, at the point of discharge from the sewage treatment plant
| |
| : 9. Summary of Proposed Changes From the Current LPDES permit:
| |
| The outfall descriptions have been updated based on an email from Rodney LeBlanc dated March 2, 2010.
| |
| The flow limitation for Outfall 001 has been removed.
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| Outfall 204 (car washwater) has been removed from the permit and the outfall description for Outfall 004 has been modified to reflect this change.
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| A-86
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 23 The limits for outfall 005 have been updated in accordance with the reissuance of the Class I Sanitary Discharge General Permit, and the limitations have been changed from weekly average to daily maximum.
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| : 10. Proposed Permit Limits:
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| The specific effluent limitations and/or conditions will be found in the draft permit. Development and calculation of permit limits are detailed in the Permit Limit Rationale section below.
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| : 11. Permit Limit Rationale:
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| The following section sets forth the principal facts and the significant factual, legal, methodological, and policy questions considered in preparing the draft permit. Also set forth are any calculations or other explanations of the derivation of specific effluent limitations and conditions, including a citation to the applicable effluent limitation guideline or performance standard provisions as required under LAC 33:IX.2707 and reasons why they are applicable or an explanation of how the alternate effluent limitations were developed.
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| A. TECHNOLOGY-BASED VERSUS WATER QUALITY STANDARDS-BASED EFFLUENT LIMITATIONS AND CONDITIONS Following regulations promulgated at LAC 33:IX.2707.L.2.b, the draft permit limits are based on either technology-based effluent limits pursuant to LAC 33:IX.2707.A or on State water quality standards and requirements pursuant to LAC 33:IX.2707.D, whichever are more stringent.
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| B. TECHNOLOGY-BASED EFFLUENT LIMITATIONS AND CONDITIONS Regulations promulgated at LAC 33: IX. 2707 .A require technology-based effluent limitations to be placed in LPDES permits based on effluent limitations guidelines where applicable, on BPJ (best professional judgement) in the absence of guidelines, or on a combination of the two. The following is a rationale for types of wastewaters. See outfall information descriptions for associated outfall(s) in Section 7. Regulations also require permits to establish monitoring requirements to yield data representative of the monitored activity
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| [LAC 33:IX.2715] and to assure compliance with permit limitations
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| [LAC 3 3 : IX . 2 7 0 7 . I . ] .
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| Manufacturing Operation Guideline Steam Electric Power Generating Point 40 CFR 423 Source Category Regulations require permits establish monitoring requirements to yield data representative of the monitored activity [LAC33:IX.2715]
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| and to assure compliance with permit limitations [LAC33:IX.2707.I].
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| A-87
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 24 C. WATER QUALITY-BASED EFFLUENT LIMITATIONS Technology-based effluent limitations and/or specific analytical results from the permittee's application were screened against state water quality numerical standard based limits by following guidance procedures established in the Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards LDEQ, October 7, 2009. Calculations, results, and documentation are given in Appendix B.
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| The following pollutants received water quality based effluent limits:
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| .* .P6LLUTANT ( S)
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| None D. MONITORING FREQUENCIES Regulations require permits to establish monitoring requirements to yield data representative of the monitored activity (LAC33:IX.2715) and to assure compliance with permit limitations (LAC33: IX. 2707. I).
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| Specific monitoring frequencies per outfall are listed in Section E.
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| E. OUTFALL SPECIFIC RATIONALE outfall 001
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| : 1. General Comments This outfall is the continuous discharge of once through non-contact cooling water combined with previously monitored intermittent discharges including but not limited to: steam generator blowdown, cooling tower blowdown, metal cleaning wastewaters, low volume wastewater, and stormwater from Outfalls 101, 201, 301, 401, 501, 601, 701, 801, 901, and 1001.
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| A-88
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 25
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow-mgd Report Report Continuous Recorder Temperature Report 118°F Continuous Recorder Heat - -- 9.5 x 10 3 Continuous Recorder MBTU/hour Total Residual --- 211 lbs/day 1/week Grab Chlorine Flow - The current LPDES permit established a reporting requirement for monthly average. This requirement is being retained. The daily maximum limitation of 1518 in the current permit is being changed to a reporting requirement as per current guidance. Both requirements will have a measurement frequency of continuous and a sample type of recorder. These requirements are consistent with LAC33:IX.2707.I.1.b.
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| Temperature - The current LPDES permit established a reporting requirement for monthly average and daily maximum limitation of 118° F. These limitations are being retained with a moni taring frequency of continuous. Temperature is measured by a recorder with analysis required immediately.
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| Heat - The current LPDES permit established a daily maximum limitation of 9.5 x 10 3 MBTU/hour. This limitation is being retained with a monitoring frequency of continuous and a sample type of recorder.
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| Total Residual Chlorine - The current LPDES permit established a daily maximum limitation of 211 lbs/day. This limitation is being retained with the same moni taring frequency of once per week by grab sample during periods of chlorination.
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| TOXICITY TESTS FREQUENCY Acute static renewal 48-hour once per quarter definitive toxicity test using fathead minnow (Pimephales promelas)
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| Acute static renewal 48-hour Once per quarter definitive toxicity test using water flea (Daphnia pulex)
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| A-89
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 26 Toxicity tests shall be performed in accordance with protocols described in the latest revision of the "Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms." The stipulated test species are appropriate to measure the toxicity of the effluent consistent with the requirements of the State water quality standards. The biomonitoring frequency has been established to reflect the likelihood of ambient toxicity and to provide data representative of the toxic potential of the facility* s discharge in accordance with regulations promulgated at LAC 33:IX.2715.
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| Results of all dilutions as well as the associated chemical monitoring of pH, temperature, hardness, dissolved oxygen, conductivity, and salinity shall be documented in a full report according to the test method publication mentioned in the previous paragraph. The permittee shall submit a copy of the first full report to the Office of Environmental Compliance. However, the full report and subsequent reports are to be retained for three ( 3) years following the provisions of Part III.C.3 of this permit. The permit requires the submission of certain toxicity testing information as an attachment to the Discharge Monitoring Report.
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| This permit may be reopened to require effluent limits, additional testing, and/or other appropriate actions to address toxicity if biomonitoring data shows actual or potential ambient toxicity to be the result of the permit tee's discharge to the receiving stream or water body. Modification or revocation of the permit is subject to the provisions of LAC 33: IX. 3105. Accelerated or intensified toxicity testing may be required in accordance with Section 308 of the Clean Water Act.
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| Dilution Series - The permit requires five (5) dilutions in addition to the control ( 0% effluent) to be used in the toxicity te"sts. These additional effluent concentrations shall be 13%, 18% 1 24%, 31%, and 42%. The biomonitoring critical dilution is defined as 31% effluent.
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| Internal Outfalls In accordance with LAC33:IX.3305, the following is an explanation for the establishment of Internal Outfalls 101, 201, 301, 401, 501, 601, 701, 801, 901, and 1001. Certain permit effluent limitations at the point of discharge are impractical because at the final discharge point, the wastewater is diluted as to make monitoring impracticable. Therefore, in accordance with LAC33:IX.2709, the internal outfalls described below will remain in the permit.
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| Outfall 101
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| : 1. General Comments This outfall is the intermittent discharge from the liquid waste management system. The boron management system receives low volume wastewater from the following sources, including but not limited to: the A-90
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 27 turbine and reactor building equipment and floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423.
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow-mgd --- Report l/batch Totalized TSS --- 100 mg/L l/month Grab Oil and Grease --- 20 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u. l/batch Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per batch and a sample type of totalized. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with a monitoring frequency of once per month by grab sample.
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| Oil and Grease - The current LPDES permit established a daily maximum limitation of 20 mg/L in accordance with 40 CFR 423.12(b) (3). This limitation is being retained with monitoring frequency of once per month by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. o standard units and maximum discharge limit of 9. o standard units for pH in accordance with 40 CFR 423.12{b) (1). These limitations are being retained with a monitoring frequency of once per batch by grab sample.
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| Outfall 201
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| : 1. General Comments This outfall is the intermittent discharge from the boron management system. The boron management system receives low volume wastewater from the following sources, including but not limited to: the turbine and reactor building equipment and floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423.
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| A-91
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 28
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maxirnwn Measurement Sample Frequency Type Flow-mgd --- Report 1/batch Totalized TSS --- 100 mg/L 1/month Grab Oil and Grease --- 20 mg/L 1/month Grab pH 6.0 s.u. 9.0 s.u. 1/batch Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per batch and a sample type of totalized. This requirement is consistent with LAC33:IX.2707.I.1.b.
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| Total suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with a monitoring frequency of once per month by grab sample.
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| Oil & Grease - The current LPDES permit established a daily maximum limitation of 20 mg/L in accordance with 40 CFR 423 .12 (b) (3). This limitation is being retained with a monitoring frequency of once per month by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard units and maximum discharge limit of 9. O standard units for pH in accordance with 40 CFR 423.12(b) (1). These limitations are being retained with a monitoring frequency of once per batch by grab sample.
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| Outfall 301
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| : 1. General Comments This outfall is the intermittent discharge of filter flush water from the primary water treatment system. The primary water treatment system filters riverwater for various plant uses. The filters of this system are flushed periodically with untreated river water to remove solids trapped in the filter beds.
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| A-92
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Stearn Electric Station LA0007374, AI No. 35260 Page 29
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow-rngd -- - Report Weekly Totalized NOTE: The quantity and types of all clarifying agents (coagulants) used in the primary water treatment system during the sampling month shall be recorded.
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| Records of the quantity and type of clarifying agents used shall be retained for three (3) years following Part III.C.3 of the LPDES permit. No DMR reporting shall be required.
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| Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of weekly and a sample type of totalized. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| Outfall 401
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| : 1. General Comments This outfall is the intermittent discharge of steam generator blowdown and other low volume wastewaters as defined in 40 CFR 423.
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow-mgd -- - Report Daily Totalized TSS -- - 100 mg/L l/week Grab Oil and Grease --- 20 rng/L l/week Grab pH 6.0 s.u. 9.0 s. u. l/week Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a daily measurement frequency and a sample type of totalized. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| A-93
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 30 Total Suspended Solids - The current LPDES permit established a daily maximum limitation of* 100 mg/L in accordance with 40 CFR 423 .12 (bl (3) . This limitation is being retained with a monitoring frequency of once per week by grab sample.
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| Oil & Grease - The current LPDES permit established a daily maximum limitation of 20 mg/Lin accordance withi 40 CFR 423.12(b)(3). This limitation is being retained with a monitoring frequency bf once per week by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard units and maximum discharge limit of 9. 0 standard units for pH in accordance with 40 CFR 423(b} (1). These limitations are being retained with a monitoring frequency of once per week by grab sample.
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| outfall 501
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| : 1. General Comments This outfall is the intermittent discharge from Auxiliary Component Cooling Water Basin A. Low volume wastewaters include, but are not limited to: auxiliary component cooling water, component cooling water, Mississippi River water used for flow testing, and stormwater.
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow-mgd - -- Report 1/week Estimate TOC --- 50 mg/L 1/week Grab TSS --- 100 mg/L 1/week Grab Oil and Grease --- 20 mg/L 1/week Grab pH 6.0 s.u. 9.0 s.u. 1/week Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per week and a sample type of estimate. These requirements are consistent with LAC33:IX.2707.I.1.b.
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| Total Organic Carbon - The current LPDES permit established a daily maximum limitation of 50 mg/L. The limitation is based on BPJ in accordance with this A-94
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 31 Office's guidance on stormwater, letter dated 6/17 /87, from J. Dale Givens (LDEQ) to Myron Knudson (EPA Region 6)and the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAROSOOOO, effective on May 1, 2006. This limitation is being retained with a monitoring frequency of once per week by grab sample.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with a monitoring frequency of once per week by grab sample.
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| Oil & Grease - The current LPDES permit established a daily maximum limitation of 20 mg/L in accordance with 40 CFR 423.12{b) (3). This limitation is being retained with a monitoring frequency of once per week by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard units and maximum discharge limit of 9. O standard units for pH in accordance with 40 CFR 423.12(b) (1). These limitations are being retained with a monitoring frequency of once per week by grab sample.
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| Outfall 601
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| : 1. General Comments This outfall is the intermittent discharge from Auxiliary Component Cooling Water Basin B. Low volume wastewaters include, but are not limited to: auxiliary component cooling water, component cooling water, secondary plant water system wastewater, Mississippi River water used for flow testing, and stormwater.
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow-mgd -- - Report 1/week Estimate TOC - -- 50 mg/L 1/week Grab TSS - -- 100 mg/L 1/week Grab Oil and Grease - -- 20 mg/L 1/week Grab pH 6.0 s.u. 9.0 s.u. 1/week Grab A-95
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 32 Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per week and a sample type of estimate. This requirement is consistent with LAC33:IX.27Q7.I.1.b.
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| Total Organic Carbon - The current LPDES permit established a daily maximum limitation of so mg/L. The limitation is based on BPJ in accordance with this Office's guidance on stormwat;er, letter dated 6/17/87, from J. Dale Givens (LDEQl.
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| to Myron Knudson (EPA Region 6) and the LPDE.s Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAROSOOOO, effective on May 1, 2006. This limitation is being retained with a monitoring frequency of once per week by grab sample.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with a monitoring frequency of once per week by grab sample .
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| . Oil & Grease - The current LPDES permit established a daily maximum limitation of 20 mg/L in accordance with 40 CFR 423.12(b) (3). This limitation is being retained with a monitoring frequency of once per week by grab sample.
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| pH - The current LPDES pe:rmi t established a minimum discharge limit of 6. o standard units and maximum discharge limit of 9~0 standard units for pH in accordance with 40 CFR 423.12 (b) (1). These limitations are being retained with a monitoring frequency of once per week by grab sample.
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| Outfall 701
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| : 1. General Comments This outfall is the intermittent discharge of cooling tower blowdown and low volume . wastewaters from Dry Cooling Tower. Sump #1. Low volume wastewaters includ~, but are not limited to: wet cooling tower leakage, aillciliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. (NOTE: Optional discharge to plant drainage ditches thence to outfall 004 may occur during periods when the circulating water system is unavailable.)
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| A-96
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| Fact sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 33
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow -- - Report l/month Estimate TOC --- 50 mg/L l/quarter Grab TSS -- - 100 mg/L l/month Grab Oil and Grease --- 20 mg/L l/month Grab Free Available -- - 0.5 mg/L l/month Grab Chlorine Total Chromium -- - 0.2 mg/L l/year Grab Total Zinc - -- 1. 0 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u. l/month Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per month and a sample type of estimate. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| Total Organic Carbon - The current LPDES permit established a daily maximum limitation of 50 mg/L. The limitation is based on BPJ in accordance with this Office's guidance on stormwater, letter dated 6/17/87, from J. Dale Givens (LDEQ) to Myron Knudson (EPA Region 6}and the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAR050000, effective on May 1, 2006. This limitation is being retained with the same monitoring frequency of once per quarter by grab sample.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| Oil and Grease - The current LPDES permit established a daily maximum limitation of 20 mg/L in accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| Free Available Chlorine - The current LPDES permit established a daily maximum limitation of 0.5 mg/Lin accordance with 40 CFR 423.13(d) (1). This limitation is being retained with the same monitoring frequency of once per mpnth by grab sample.
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| A-97
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 34 Total Chromium - The current LPDES permit established a daily maximum of 0.2 mg/L in accordance with 40 CFR 423.13(d) (1). This limitation is being retained with the same monitoring frequency of once per year by grab sample.
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| Total Zinc - The current LPDES permit established a daily maximum of 1.0 mg/Lin accordance with 40 CFR 423.13(d) (1). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| pH - The current LPDES permit established a miniml!lm discharge limit of 6. O standard units and a maximum discharge limit of 9.0 standard units for pH. These limits are based on 40 CFR 423.12(b) (1). These limitations are being retained with the same monitoring frequency of once per month by grab sample.
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| Outfall 801
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| : 1. General Comments This outfall is the intermittent discharge of cooling tower blowdown and low volume wastewaters from Dry Cooling Tower Sump #2. Low volume wastewater sources as defined in 40 CFR 423 include, but are not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. (NOTE: Optional discharge to plant drainage ditches thence to Outfall 004 may occur during periods when the circulating water system is unavailable.)
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow --- Report l/month Estimate TOC --- 50 mg/L 1/quarter Grab TSS -- - 100 mg/L 1/month Grab Oil and Grease - -- 20 mg/L l/rnonth Grab Free Available -- - 0.5 mg/L 1/month Grab Chlorine Total Chromium -- - 0.2 mg/L l/year Grab Total Zinc --- 1. 0 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u. l/month Grab A-98
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 35 Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per month and a sample type of estimate. This requirement is consistent with LAC33:IX.2707.I.1.b.
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| Total Organic Carbon - The current LPDES permit established a daily maximum limitation of 50 mg/L. The limitation is based on BPJ in accordance with this Office's guidance on stormwater, letter dated 6/17/87, from J. Dale Givens (LDEQ}
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| to Myron Knudson (EPA Region 6}and the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAROSOOOO, effective on May 1, 2006. This limitation is being retained with the same monitoring frequency of once per quarter by grab sample.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| Oil and Grease - The current LPDES permit established a daily maximum limitation of 20 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| Free Available Chlorine - The current,LPDES permit established a daily maximum limitation of 0.5 mg/Lin accordance with 40 CFR 423.13(d) (1). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| Total Chromium - The current LPDES permit established a monthly average of 0.2 mg/Land a daily maximum of 0.2 mg/Lin accordance with 40 CFR 423.13(d) (1).
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| This limitation is being retained with the same monitoring frequency of once per year by grab sample.
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| Total Zinc - The current LPDES permit established a daily maximum of 1.0 mg/Lin accordance with 40 CFR 423.13(d} (1). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard units and a maximum discharge limit of 9.0 standard units for pH. These limits are based on 40 CFR 423.12(b) (1). These limitations are being retained with the same monitoring frequency of once per month by grab sample.
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| A-99
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 36 Outfall 901
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| : 1. General Comments This outfall is the intermittent discharge of metal cleaning wastewaters (both chemical and non-chemical) from various plant equipment components including, but not limited to: the steam generator, cooling water heat exchangers, and piping.
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow - -- Report l/week Estimate TSS - -- 100 mg/L l/week Grab Oil and Grease - -- 20 mg/L l/week Grab Total Copper --- 1. 0 mg/L l/week Grab Total Iron - -- 1. 0 mg/L l/week Grab pH 6.0 s.u. 9.0 s.u. l/week Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per week and a sample type of estimate. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per week by grab sample.
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| Oil and Grease - The current LPDES permit established a daily maximum limitation of 20 mg/L in accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per week by grab sample.
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| Total Copper- The current LPDES permit established a daily maximum limitation of
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| : 1. 0 mg/L in accordance with 40 CFR 423 .13 (b) (5). This limitation is being retained with the same monitoring frequency of once per week by grab sample.
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| A-100
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Stearn Electric Station LA0007374, AI No. 35260 Page 37 Total Iron - The current LPDES permit established a daily maximum of 1.0 rng/L in accordance with 40 CFR 423.13(b) (5). This limitation is being retained with the same monitoring frequency of once per week by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard units and a maximum discharge limit of 9.0 standard units for pH. These limits are based on 40 CFR 423.12{b) (1). These limitations are being retained with the same monitoring frequency of once per week by grab sample.
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| Outfall 1001
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| : 1. General Comments This outfall is the intermittent discharge from the yard oil separator system. Wastewater includes auxiliary boiler blowdown, stormwater, and low volume wastewaters from various sources, including plant floor drains and discharge from the industrial waste system as defined in 40 CFR 423.
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| Low volume wastewater sources include, but are not limited to: secondary water system drains, system leakage, auxiliary boiler sumps, turbine building equipment and floor drains, turbine building floor wash downs, and laboratory drains. (NOTE: Optional discharge to Final Outfall 004 may occur during maintenance periods and during rain events that compromise the capacity of the discharge pumps.)
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow -- - Report l/month Estimate TSS -- - 100 rng/L l/month Grab Oil and Grease - -- 20 rng/L l/rnonth Grab pH 6.0 s.u. 9.0 s.u. l/month Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per month and a sample type of estimate. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 rng/L in accordance with 40 CFR 423.12(b) (3). This limitation A-101
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 38 is being retained with the same monitoring frequency of once per month by grab sample.
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| Oil and Grease - The current LPDES permit established a daily maximum limitation of 20 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard uni ts and a maximum discharge limit of 9. O standard uni ts for pH. These limits are based on 40 CFR 423.12(b).(l). These limitations are being retained with the same monitoring frequency of once per month by grab sample.
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| Outfall 004
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| : 1. General Comments This outfall is the intermittent discharge from the plant drainage ditch system consisting of stormwater, potable water from the fire water system, maintenance wastewaters including, but not limited to: hydrostatic test water, air conditioning condensate, low volume wastewaters including, but not limited to: reverse osmosis reject water and demineralized water. The plant drainage ditch system receives discharges during maintenance from the Dry Cooling Tower Sump #1 (Internal Outfall 701), Dry Cooling Tower Sump #2 (Internal Outfall 801), and treated discharge from the yard oil separator system, including, but not limited to: plant floor drains and discharge from the industrial waste system (Internal Outfall 1001)
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow --- Report 1/3 months Estimate TOC --- 50 mg/L 1/3 months Grab TSS --- 100 mg/L 1/3 months Grab Oil and Grease --- 15 mg/L 1/3 months Grab pH 6.0 s.u. 9.0 s.u. 1/3 months Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per three months and a sample type of estimate. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| A-102
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 39 Total Organic Carbon - The current LPDES permit established a daily maximum limitation of 50 mg/L. The limitation is based on BPJ in accordance with this Office's guidance on stormwater, letter dated 6/17 /87, from J. Dale Givens (LDEQ) to Myron Knudson (EPA Region 6)and the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, L.1'R050000, effective on May 1, 2006. This limitation is being retained with the same monitoring frequency of once per three months by grab sample.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/L. The limitation is based on BPJ in accordance with this Office's guidance on stormwater, letter dated 6/17 /87, from J. Dale Givens (LDEQ) to Myron Knudson (EPA Region 6Jand the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAR050000, effective on May 1, 2006. This limitation .is being retained with the same monitoring frequency of once per three months by grab sample.
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| Oil and Grease - The current LPDES permit established a daily maximum limitation of 15 mg/L. The limitation is based on BPJ in accordance with this Office's guidance on stormwater, letter dated 6/17 /87, from J. Dale Givens (LDEQ) to Myron Knudson (EPA Region 6)and the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAROSOOOO, effective on May 1, 2006. This limitation is being retained with the same monitoring frequency of once per three months by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard units and a maximum discharge limit of 9.0 standard units for pH. The limitation is based on BPJ in accordance with this Office's guidance on stormwater, letter dated 6/17/87, from J. Dale Givens (LDEQJ to Myron Knudson (EPA Region 6) and the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAROSOOOO, effective on May 1, 2006. These limitations are being retained with the same monitoring frequency of once per three months by grab sample.
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| Outfall 005
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| : 1. General Comments This outfall is the intermittent discharge of treated sanitary wastewater and a de minimis discharge from the HVAC unit from the Entergy Energy Education Center.
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| A-103
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 40
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow - -- Report 1/6 months Estimate BOD 5 30 mg/L 45 mg/L 1/6 months Grab TSS 30 mg/L 45 mg/L 1/6 months Grab Fecal Coliform 200 col/100 mL 400 col/100 mL 1/6 months Grab pH 6.0 s.u. 9.0 s.u. 1/6 months Grab Flow - The current LPDES permit established a reporting requirement for weekly average flow. This requirement is being retained with a measurement frequency of once per six months and a sample type of estimate. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| Biological Oxygen Demand - The current LPDES permit established a weekly average limitation of 45 mg/L. This limitation is changed to a daily maximum limitation.
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| The same monitoring frequency of once per six months by grab sample is being retained. In addition, a monthly average limitation of 30 mg/L with a monitoring frequency of once per six months by grab sample is being proposed. These limitations are based on the Class I. Sanitary General Discharge Permit, LAG530000.
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| Total Suspended Solids - The current LPDES permit established a weekly average limitation of 45 mg/L. This limitation is changed to a daily maximum limitation.
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| The s.ame moni taring frequency of once per six months by grab sample is being retained. In addition, a monthly average limitation of 30 mg/L with a monitoring frequency of once per six months by grab sample is being proposed. These limitations are based on the Class I Sanitary General Discharge Permit, LAG530000.
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| Fecal Coliform - The current LPDES permit established a daily weekly average limitation of 400 colonies per 100 mL. This limitation is changed to a daily maximum limitation. The same monitoring frequency of once per six months by grab sample is being retained. In addition, a monthly average limitation of 200 colonies per mL with a monitoring frequency of once per six months by grab sample is being proposed. These limitations are based on the Class I Sanitary General Discharge Permit, LAG530000.
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| A-104
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| Fact sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 41 pH - The current LPDES permit established a minimum discharge limit of 6.0 standard units and a maximum discharge limit of 9.0 standard units for pH. These limitations are based on the Class I Sanitary General Discharge Pennit, LAGSJOOOO. These limitations are being retained with the same monitoring frequency of once per three months by grab sample.
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| Part II Specific Conditions PROHIBITION OF PCB DISCHARGES There shall be no discharge of polychlorinated biphenyls (PCB's). The minimum quantification level for PCB's is 1.0 µg/L. If any individual analytical test result for PCB's is less than the minimum quantification level, then a value of zero(O) shall be used for the Discharge Monitoring Report (DMR) calculations and reporting requirements.
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| PROHIBITION OF 126 PRIORITY POLLUTANTS There shall be no discharge of any 126 priority pollutants (40 CFR 423 Appendix A) associated with the chemicals added for cooling tower maintenance, except total chromium and total zinc. The minimum quantification levels for the 126 priority pollutants are found in Part II, Paragraph I.
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| CHEMICAL METAL CLEANING WASTE The term chemical metal cleaning waste means any wastewater resulting from cleaning of any metal process equipment with chemical compounds, including, but not limited to, boiler tube cleaning.
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| METAL CLEANING WASTE The term metal cleaning waste means any wastewater resulting from cleaning (with or without chemical cleaning compounds) any metal process equipment including, but not limited to, boiler tube cleaning, boiler fireside cleaning, and air preheater cleaning.
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| LOW VOLUME WASTE SOURCES The term "low volume waste sources" means, taken collectively as if from one source, wastewater from all sources except those for which specific limitations are otherwise established. Low volume waste sources include, but are not limited to: wastewaters from wet scrubber air pollution control systems, ion exchange water treatment systems, water treatment evaporator blowdovm, laboratory and sampling streams, boiler blowdown, floor drains, cooling tower basin cleaning wastes, and recirculating house service water systems. Sanitary and air conditioning wastewaters are not included.
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| A-105
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| Fact sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 42 TOTAL RESIDUAL CHLORINE The term "total residual chlorine" (or total residual oxidants for intake water with bromides) means the value obtained using the amperometric method for total residual chlorine described in 40 CFR Part 136.
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| Total residual chlorine may not be discharged from any unit for more than two hours per day.
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| Simultaneous multi-unit chlorination is permitted.
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| FREE AVAILABLE CHLORINE The term "free available chlorine" shall mean the value obtained using the amperometric titration method for free available chlorine described in the latest edition of Standard Methods for the Examination of Water and Wastewater.
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| Free available chlorine may not be discharged from any unit for more than two hours in any one day and not more than one unit in any plant may discharge free available chlorine at any one time.
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| TEMPERATURE Daily temperature discharge is defined as the flow-weighted average (FWAT) and, on a daily basis, shall be monitored and recorded in*accordance with Part I of this permit. FWAT shall be calculated at equal time intervals not greater than two hours. The method of calculating FWAT is as follqws:
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| FWAT = SUMMATION (INSTANTANEOUS FLOW X INSTANTANEOUS TEMPERATURE)
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| SUMMATION (INSTANTANEOUS FLOW)
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| "Daily average temperature" (also known as average monthly or maximum 30 day value) shall be the arithmetic average of all FWATs calculated during the calendar month.
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| "Daily maximum temperature" (also known as the maximum daily value) shall be the highest FWAT calculated during* the calendar month.
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| Discharge of heat shall be continuously calculated and recorded as:
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| [Instantaneous T (circulating water temperature rise through the plant in F)] X [Instantaneous flow rate in MGD] X [3.48Xl05]
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| OR AS
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| [Heat transferred to the turbine generator cycle (BTU/hour)] [Gross electrical output (BTU/hour)].
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| A-106
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 43 NON-RADIOACTIVE WASTEWATERS Certain low volume and chemical wastewaters from this facility with no detectable radioactivity, as defined by the Nuclear Regulatory Commission plant effluent release limits may be commingled and treated with similar wastewaters from Waterford 1 & 2 and controlled under terms of LPDES Permit Number LA0007439.
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| WATER TREATMENT CLARIFIER SLUDGE WASTES Water treatment clarifier sludge wastes may be returned to the stream without treatment if not previously combined with any other untreated waste source, including demineralizer and softener wastes.
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| ZEBRA MUSSEL TREATMENT The terins and conditions of the zebra mussel treatment program submitted by Entergy Operations, Inc., Waterford 3 and approved by this Office on June 23; 1998, shall be enforceable as if part of this permit.
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| According to section 3. d. , "Samples and Composites", of the biomoni toring requirements paragraph of this permit, the perrnittee must collect composite samples that "are representative of any periodic episodes of chlorination, biocide usage, or other potentially toxic substance discharged on an intermittent basis". Anytime the treatment method involves an increase in the concentration of a treatment chemical, a change in type of treatment chemical used, or if any event occurs that creates the potential for an effluent with a higher toxic nature, additional biomonitoring according to the terms and conditions of the biomonitoring section of Part II of this permit shall be required.
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| The permittee must notify this Office if changes occur in the zebra mussel control plan and obtain approval prior to initiating the new treatment. If chlorine is applied to control zebra mussels, the permittee must comply wit_h a daily maximum Total Residual Chlorine (TRC) concentration limit of 0.2 mg/L.
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| Monitoring shall be performed at a frequency of l/day, by grab sample, during periods of chlorine application.
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| PERMIT REOPENER CLAUSE This permit may be modified, or alternatively, revoked and reissued, to comply with any applicable effluent standard or limitations issued or approved under sections 30l(b) (2) and (D); 304(b) (2); and 307(a) (2) of the Clean Water Act, or more stringent discharge limitations and/or additional restrictions in the future to maintain the water quality integrity and the designated uses of the receiving water bodies based upon additional water quality studies and/or TMDL's, if the effluent standard, limitations, water quality studies or TMDL's so issued or approved:
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| : 1. Contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or A-107
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 44
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| : 2. Controls any pollutant not limited in the permit; or
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| : 3. Require reassessment due to change in 303 (d} status of waterbody; or
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| : 4. Incorporates the results of any total maximum daily load allocation, which may be approved for the receiving water body.
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| The Louisiana Department of Environmental Quality (LDEQ) reserves the right to modify or revoke and reissue this permit based upon any changes to established TMDL' s for this discharge, or to accommodate for pollutant trading provisions in approved TMDL watersheds as necessary to achieve compliance with water quality standards. Therefore, prior to upgrading or expanding this facility, the permittee should contact the Department to determine the status of the work being done to establish future effluent limitations and additional permit conditions.
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| 316(b} PHASE II RULE REQUIREMENTS July 6, 2004, EPA promulgated 'Phase II' regulations in accordance with section 316(b) of the Clean Water Act (CWA).
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| January 25, 2007, the Second U.S. Circuit Court of Appeals remanded several provisions of the Phase II rule.
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| March 20, 2007, EPA issued a memo saying, "the rule should be considered suspended" .
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| July 9, 2007, Federal Register notice suspending all parts of the Phase II regulations except 40 CFR 125.90(b) [LAC 33:IX.4731.B]
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| According to EPA, 316 (b) 'Phase II' regulations are under complete reconsideration at this time. LAC 33:IX.4731.B provides for regulating the cooling water intake structure (CWIS) for existing facilities on a case-by-case basis using best professional judgment.
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| This facility was issued a number of previous NPDES and/or LPDES permits and has been withdrawing once-through, non-contact cooling water without any identified problems. QLDEQ has no information which either identifies or verifies any past or current adverse environmental impacts associated with the withdrawal of the applicable cooling water. The facility is located in the main channel of the Mississippi River at River Mile 129.5 on the west descending bank. The intake structure extends out 162 feet from the bank and is equipped with a skimmer wall as to prevent debris and surface swimming organisms from entering the CWIS. The offshore location of the CWIS minimizes fish and shellfish from entering the system as the conditions of the Mississippi River (i.e., high velocity, increased debris, shifting river bed, lack of habitat/vegetation, and reduction of food source) at the location of the intake structure are not easily tolerated. LDEQ has made the determination that this CWIS represents the best technology available. This determination is based on current information available and will be re-evaluated either upon promulgation of revised 316{b) Phase II regulations or upon evaluation of the environmental impacts of their CWIS as described below.
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| The revised 316(b) Phase II regulation will supersede any requirements contained in the applicable permit.
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| A-108
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 45 A permit modification, effective January 10, 2008, required Entergy Operations, Inc. to characterize the fish/shellfish in the vicinity of the CWIS and assess impingement mortality and entrainment (IM&E) . The assessment results were received by LDEQ on July 10, 2008 (EDMS document 37109798). In this permit, LDEQ will require an assessment of the cooling water system as described in the following paragraphs:
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| The permittee shall comply with effective regulations promulgated in accordance with section 316 (b) of the CWA for cooling water intake structures. The permi ttee shall submit the cooling water system assessment results to LDEQ no later than four (4) years from the effective date of this permit. Based on the information submitted to LDEQ, the permit may be reopened to incorporate limitations and/or requirements for the CWIS.
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| The assessment of the cooling water system must include the following:
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| An assessment of the cooling water system which includes a discussion or description of how structural or operational actions currently in place reduce adverse environmental impacts caused by your CWIS, and a discussion of additional structural or operational actions, if any, that have been reviewed or evaluated as possible measures to further reduce environmental impacts caused by your CWIS.
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| STORMWATER POLLUTION PREVENTION PLAN (SWPPP3) REQUIREMENT In accordance with LAC 33:IX.2707.I.3 and 4, a Part II condition is proposed for applicability to all stormwater discharges from the facility, either through permitted outfalls or through outfalls which are not listed in the permit or as sheetflow. For first time permit issuance, the Part II condition requires a Storm Water Pollution Prevention Plan (SWP3) within six (6) months of the effective date of the final permit. For renewal permit issuance, the Part II condition requires that the Storm Water Pollution Prevention Plan (SWP3) be reviewed and updated, if necessary, within six (6) months of the effective date of the final permit. If the permittee maintains other plans that contain duplicative information, those plans could be incorporated by reference to the SWP3. Examples of these type plans include, but are not limited to: Spill Prevention Control and Countermeasures Plan (SPCC), Best Management Plan (BMP),
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| Response Plans, etc. The conditions will be found in the draft permit.
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| Including Best Management Practice (BMP) controls in the form of a SWP3 is consistent with other LPDES and EPA permits regulating similar discharges of stormwater associated with industrial activity, as defined in LAC 33:IX.2522.B.14
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| [40 CFR 122.26(b) (14)].
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| : 12. Compliance History/DMR Review:
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| A. Inspections: There was an inspection at the facility on November 25, 2008. All areas evaluated were found to be satisfactory. (EDMS A-109
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 46 Doc No. 39933315)
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| B. Enforcement Actions (COs, NOVs, Warning Letters, etc.): N/A EPA has does not have Enforcement Authority of this facility.
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| : c. DMRs: A DMR review was retrieved from ICIS. No excursions were found for the last 3 years. All DMR's were submitted in accordance with the existing permit.
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| D. Company Compliance History: AI1 email was sent to Office of Environmental Compliance on May 19, 2010, for a list of open enforcement actions for this facility. To date, there has been no response.
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| E. Permit Actions Taken: N/A Please be aware that the Department has the authority to reduce monitoring frequencies when a permittee demonstrates two or more consecutive years of permit compliance. Monitoring frequencies established in LPDES permits are based on a number of factors, including but not limited to, the size of the discharge, the type of wastewater being discharged, the specific operations at the facility, past compliance history, similar facilities and best professional judgment of the reviewer. We encourage and invite each permittee to institute positive measures to ensure continued compliance with the LPDES permit, thereby qualifying for reduced monitoring frequencies upon permit reissuance. As a reminder, the Department will also consider an increase in monitoring frequency upon permi_t reissuance when the permittee demonstrates continued non-compliance.
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| : 13. Wate~ Quality Consideratons:
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| . Subsegment 070301 is not listed on LDEQ' s Final 2006 303 (d) List as impaired, and to date no TMDL's have been established.
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| Subsegment 020202 is listed on LDEQ's Final 2006 303(d) List as impaired for dissolved oxygen. To date no TMDLs have been completed for this waterbody. A reopener clause will be established in the permit to allow for the requirement of more stringent effluent limitations and requirements as imposed by a TMDL. Until completion of TMDLs for the Barataria Basin, those suspected causes for impairment which are not directly attributed to the steam electric generating station point source category have been eliminated in the .formulation of effluent limitations and other requirements of this permit. Additionally, suspected causes of impairment which could be attributed to pollutants which were not determined to be discharged at a level which would cause, have the reasonable potential to cause or contribute to an excursion above any A-110
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 47 present state water quality standard were also eliminated.
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| Based on the evaluation of the discharges from this facility, it was determined that the facility has the potential to discharge pollutants which may contribute to the dissolved oxygen impairment of the receiving waterbody. However, compliance with the limitations established in the permit should not result in the discharge of pollutant concentrations which would cause or contribute to the further impairment of water quality standards.
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| : 14. Endangered Species:
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| The receiving waterbody, Subsegment 070301 of the Mississippi River Basin, has been identified by the U.S. Fish and Wildlife Service (FWS) as habitat for the Pallid Sturgeon, which is listed as threatened and/or endangered species. This draft permit has been submitted to the FWS for review in accordance with a letter dated January 5, 2010, from Rieck (FWS) to Nolan (LDEQ) . As set forth in the Memorandum of Understanding between the LDEQ and the FWS, and after consultation with FWS, LDEQ has determined that the issuance of the LPDES permit is not likely to have an adverse effect upon the Pallid Sturgeon. The effluent limi_tations established in the permit ensure protection of aquatic life and maintenance of the receiving water as aquatic habitat. Therefore, the issuance of the LPDES permit is not likely to have an adverse effect on any endangered or candidate species or the critical habitat.
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| The receiving waterbody, Subsegment 020202 of the Barataria Basin is not listed in Section II. 2 of the Implementation Strategy as requiring consultation with the U.S. Fish and Wildlife Service (FWS). This strategy was submitted with a letter dated January 5, 2010 from Rieck (FWS) to Nolan (LDEQJ . Therefore, in accordance with the Memorandum of Understanding between the LDEQ and the FWS, no further informal (Section 7, Endangered Species Act) consultation is required. The effluent limitations established in the permit ensure protection of aquatic life and maintenance of the receiving water as aquatic habitat. Therefore, the issuance of the LPDES permit is not likely to have an adverse effect on any endangered* or candidate species or the critical habitat.
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| A-111
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 48
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| : 15. Historic Sites:
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| The discharge is from an existing facility location, which does not include an expansion on undisturbed soils. Therefore, there should be no potential effect to sites or properties on or eligible for listing on the National Register of Historic Places, and in accordance with the "Memorandum of Understanding for the Protection of Historic Properties in Louisiana Regarding LPDES Permits" no consultation with the Louisiana State Historic Preservation Officer is required.
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| : 16. Tentative Determination:
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| On the basis of preliminary staff review, the Department of Environmental Quality has made a tentative determination to reissue a permit for the discharge described in the application.
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| : 17. Public Notices:
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| Upon publication of the public notice, a public comment period shall begin on the date of publicatio"n and last for at least 30 days thereafter.
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| During this period, any interested persons may submit written comments on the draft permit and may request a public hearing to clarify issues involved in the permit decision at this Office's address on the first page of the fact. A request for a public hearing shall be in writing and shall state the nature of the issues proposed to be raised in the hearing.
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| Public notice published in:
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| Local newspaper of general circulation Office of Environmental Services Public Notice Mailing List A-112
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| FRESHWATER ACUTE BlOMONJTORJNG FREQUENCY RECOMMENDATION AND RA TI ON ALE FOR ADDITIONAL REQUIREMENTS Pennit Number: LA0007374 Facility Name: Entergy Operations, Inc./Waterford 3 Steam Electric Station Previous Critical Biomonitoring Dilution: 46% (10:1 ACR)
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| Proposed Critical Biomonitoring Dilution: 31 % (10:1 ACR)
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| Outfall Discharge Flow: 994 MGD Receiving stream 7QJO: 141,955 cfs Date of Review: 01/15110 Name of Reviewer: Laura Thompson Recommended Frequency by Species:
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| Pimeplwles promelas (Fathead minnow): Oncc/Quarter 1 1
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| Daplmia pulex (water flea): Once/Quarter Recommended Dilution Series: 13%, 18%, 24%, 31%, and 42%
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| Number of Tests Perfonned during previous 5 years by Species:
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| Pimepha/es promelas (Fathead minnow): 11 Daplmia pulex (water flea): 11 Ceriodaplmia dubia (water flea): NI A - Testing of species was not required Number of Failed Tests during previous 5 years by Species:
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| Pimephales promelas (Fathead minnow): No failures on file during the past 5 years Daplmia pulex (water flea): No failures on file during the past 5 years Ceriodaplmia dubia (water flea): NIA - Testing of species was not required Failed Test Dates during previous 5 years by Species:
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| Pimephales promelas (Fathead minnow): No failures on file during the past 5 years Daplmia pulex (water flea): No failures on file during the past 5 years Ceriodaplwia dubia (water flea): NI A - Testing of species was not required Previous TRE Activities: NIA- No previous TRE Activities 1
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| If there are no lethal effects demonstrated after the first year of quarterly testing, the pennittee may certify fulfillment of the WET testing requirements in writing to the permitting authority. If granted, the biomonitoring frequency for the test species may be reduced to not Jess than once per year for the less sensitive species (usually Pimephales promelas) and not less than twice per year for the more sensitive species (usually Daphnia pulex).
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| Upon expiration of the permit, the biomonitoring frequency for both species shall revert to once per quarter until the permit is re-issued.
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| Page I of2 A-114
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| FRESHWATER ACUTE Additional Requirements (including WET Limits) Rationale I Comments Concerning Pennitting:
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| Entergy Operations, Inc./\Vaterford 3 Steam Electric Station owns and operates a steam electric generating facility in Killona, St. Charles Parish, Louisiana. LPDES Permit LA0007374, effec1iyc February 1, 2003, contained acute freshwater biomonitoring as an effluent characteristic of Outfall 001 for Pimep!tales prome/as and Daplwia pule.x. The effluent series consisted of 19 1!-'o, 26%, 34%, 46%, and 61 % concentrations, with 46% being defined as the critical biomonitoring dilution. Testing was to be performed quarterly for both Pimep!ta/es promelas and Dap/mia pule..'C. Data on file indicate that the permittee has complied with the biomonitoring requirements contained in LA0007374 with no toxicity failures in the last five years.
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| It is recommended that freshwater acute biomonitoring be an effluent characteristic of Outfall 001 (continuous discharge of 994 mgd of once through non-contact cooling water, and previously monitored intermittent discharges including but not limited to steam generator blowdown, cooling tower blowdown, metal cleaning wastewater, low volume wastewater, and stormwater) in LA0007374. The effluent biomonitoring dilution series shall be 13%, 18%, 24%, 31 %, and 42% concentrations, with the 31 % effluent concentration being defined as the critical biomonitoring dilution (the 10: 1 Acute-to-Chronic ratio has been implemented). In accordance with the Environmental Protection Agency (Region 6) WET testing frequency acceleration(s), the biomonitoring frequency shall be once per quarter for Daplmia pulex and Pimephales prome/as. If there are no significant lethal effects demonstrated at or below the critical biomonitoring dilution during the first four quarters of testing, the permittee may certify fulfillment of the WET testing requirements to the permitting authority and WET testing may be reduced to not less than once per six months for the more sensitive species (usually Daplmia pulex) and not less than once per year for the less sensitive species (usually Pimephales promelas) for the remainder of the term of the permit. Upon expiration of the permit, the biomonitoring frequency for both test species shaJI revert to once per quarter until the permit is re-issued.
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| This recommendation is in accordance with the LDEQ/OES Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards, Water Quality Management Plan Volume 3. Version 6 (April 16, 2008), and the Best Professional Judgment (BPJ) of the reviewer.
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| Page 2 of2 A-115
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| Appendix B Water Quality Calculations &
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| Explanations A-116
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| wqsmodn.wk4 Date: 04/U Appendix E-1 Page l Developer: Bruce Fielding Soft~are: Lotus 4.0 LA0001314, AI352GG Revision date: OB/07/08 Water Ouality Screen for Entergy Operations, !nc.iWaterford J Input variables:
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| ~eceiving Water Characteristics: Dilution: Toxicity Di.lucion series:
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| ZID Fs = 0.0333JJ Siomoni toring dlh.:ticn; O.Jl .. 796 Receiving Water Name= Mississippi River Dilution Series Factor: 0.75 Critical flew (Qr) cfsc 1-11955 MZ Fs = 0.333333 Harm. mean/avg tidal cfs= 366748 critical Qr {MGDJ= 9174~.52 Percent. Effluent Drinking Water-1 HHNPCR=2 Harm. Mean (MGD)* Dilution No. 41.973%
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| MW=l, BW=-2, O=n ZID Dilution
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| * Dilution No. .31.4799\
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| Rec. Water Hardnessc 153.' MZ Dilution = 0.0314B Dilution No. 23 609S%
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| Rec. Water TSS= 32 HHnc Dilution= 0.010718 Dilution No. 4 17.7074%
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| Fisch/Specific=!,Stream~o HHc Dilution"" 0.004176 Dilution No. 13.2EOSt:
| |
| Diffuser Ratio= ZIO Upstream = 3.076644 MZ Upstream = 30.76644 Partition coet fic::i.ents; Dissolved- - >Total Effluent Characteristics: MZhhnc Upstream= 92. 29931 Permi ttee= Entergy Operations, lnc./Waterford J* METALS FW Penni t Number= LA0007374, AI35260 Tot.al Arsenic .223578 Facility flow (Qef),MGD= 994 MZhhc Upstream= 238.46 Total Cadmium 3 .545'121 ZID Hardness- Chromium I I! 5.282524 Outtall Number = 001 MZ Hardness= Chromium VI Eff. data, 2=lbs/day ZID TSS= Total Copper 3.56079 MQL, 2=lbs/day MZ TSS= Total Lead 6.6 Effluent Hardness~ N/A Multipliers: Total Mercury 2.785159 Effluent TSS= N/A WLAa LTAa 0.32 Total Nickel J..1?4756 WQBL ind. O*y, l*n WLAc LTAc 0.53 Total Zinc 4.535534 Acute/Chr. ratio O=n, i~y LTA a,c--::.WQBL avg l.31 Aquatic,acute onlyl=y,O=n LTA a 1 c-->WQBL max 3 .11 Aquatic Life, Dissolved LTA h -*> WQBL max 2.38 Metal Criteria, ug/L Page Numbering/Labeling WOBL-limit/report 2.13 METALS ACUTE CHRONIC Appendix Appendix B-1 WLA Fraction Arsenic 339. 8 150 Page Numbers l=y, O=n WQBL Fraction Cadmium S0.5572 1.414322 Input Page U l=y, O=n Chromium III 779.0334 252.?104 Conversions: Chromium VI 15.712 10.582 li"ischer/Site specific inputs: ug/L-->lbs/day Qef B.28996 Copper 27. 5752 17. 70626 Pipe~l.Canal=2,Specific=3 ug/L-->lbs/day Qeo Lead 102 .5669 3. 996886 Pipe width, feet ug/L-->lbs(day Qr 1183.905 Mercury l. ?31 0.012 ZlD plume dist., feet lbs/day-->Ug/L Qeo 0.120628 Nickel 2032.7/5 ~25.756 MZ plume dj st., feet lbs/day-->ug/L Qef 0.120628 Zinc 164.4582 150.1753 HHnc plume dist., feet diss--~tot l~yo~n HHc plume dist.. feet Site Specific Multiplier Values:
| |
| cfs~->MGD 0.6463 r:v
| |
| * Pischer/site specific dilutions: N =
| |
| *i luticn = Receiving Stream: WLAa F/speci!ic MZ Dilution = Default Hardness= 25 WI.Ac LTP.c F'/specific HHnc D:ilution~ Default TSSt: 10 LTA a,C-->WQBL avg F/specif ic HHc Dilution= 99 Crit., l=y, O=n LTA a,C-->WQBL max LTA h - - > WQBL max A-117
| |
| | |
| Appendix B-1 Page Entergy operations, Inc./Waterford J LA0007J74, A135260
| |
| { *2> ( *)) ( "'4 l I *S) ('6) (. 7) I* 8 l {" 9; ! *10) I* 11 l Toxic Cu Ef!luent E!"fluent. MQL Effluent 9Sth Numer.ical C:--ite:-ia HH Parameters Inst ream /Tech iTech l=NO 95\ estimate Acute Chronic HHDW Can:inogen cone. {Avg) (Max) 0:95 Non-Tech F1< PW Indicator ug/L lbs/day lbs/day ug/L lbsiCay ug/L ug/L ug/L "C" NONCONVENTICN;...L Total Phenols t*H..A?) 700 350 3 -Chl()rophcnol 10 0.1 4 **Chlorophencl 10 3 83 192 0.1 2,)-Dichlorophenol 10 0.04 2,5-Dichlcrophenol 10 0.5 2,6-Dichlcrophenol 10 0.2 3,4-Dichlorophenol 10 0. J 2,4-Dichlorophenocy-acetic acid (2,4-D) 100 2-(2,4,5-Trichlorophen-oxy} propicnic acid (2,4.5-TP, Silvex) 10 METALS AND CYANIDE Tot.al Arsenic 10 755.5719 JJ].5367 111.1789 Total Cadmium 179.036 5.013602 35.49121 Chromium II! 10 4115.263 133'1. 9'19 264.1262 Chromium VI 10 15. 712 10.582 so c Total Copper 10 98.18922 63.04811 3560 .78 Total Lead 676.9417 26.37945 33 0 Total Mercury 0.2 4.829466 0.033422 5.570319 Total Nickel 40 6453.566 716 7203 Total zinc 20 745.906 6 81 .1252 22677.67 Total Cyanide 20 45.9 s .4 663.8 DIOXIN 2,3j7,8 TCDD; dioxin l.OE-05 7. lE-07 c VOLATILE COMPOUNDS Benzene 10 224 9 1125 l. 1 c Bromoform 10 293 0 14 65 .9 c Bromodichlorcmethane 10 0. 2 c Carbon Tetrachloride 10 213(1 1365 0. 22 c Chlcroform 10 2890 14 *1 s 5. 3 c Dibromochlcrornethane 10 ]9 c l,2-Dichloroethane 10 llSOO 5900 . 36 c 1,1-DichJ.oroethylene 10 1160 580 05 c
| |
| ~.3-Dichlo~opropylene :o 606 }03 s. 86 Ethylbenzene 10 3200 1600 23 9-0 Methyl Chlcn. de 50 55000 27500 Methylene Chloride 20 19]00 !:-650 4. 4 c 1,1,2,2-Tetrachlorc-ethane 10 932 .; 66 Q. 16 c A-118
| |
| | |
| Appendix B-1 Page 3 Entergy Operat.ions, lnc. /Waterford J LA0007374, A!JS~60
| |
| {* 12) ~
| |
| * 13) 1* H) I* 15) 1"16) (* 17) c- 18) I* 20) (*21) { *22) ( "23)
| |
| TOXic WLAa HLA.c Wl..Ah LT A.a :..TAc L'IAh Limiting WQBL WQBL Ueed Paramete:-s ;..cute Chror.ic HHDW Acute C:hrcni.c HHDW A,C,HH Avg Max J.!ax WQEL?
| |
| 001 001 001 ug/!.. ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L lbs/day lbs/day NONCONVENTION!1L Total Phenols (4AAF) 2653,6506 llllS.253 466.4965£. 9l3.H82 58;;2.6741 466,4%$6 466,49656 466,49656 1110.2616 J967.2l7B 520L0261 no 3-Chloropheno1 ~.329S:312 :3.3299312 9.3295312 9.3299312 22.205236 77.344757 184.0905:!' r.o 4-Chlorophenol 1561.3546 6059.156 9.3-2'19312 499 633.;6 3232.5527 9.3299312 S.3299312 9.3299:?12 22.205236 77 ..144757 184.0SOS2 no 2,3-Dichlorophenol 3.7319725 3.7319725 l.7319725 3.7319125 8.8820945 30.937903 73,612208 no 2,5-Dichlorophenol 46,64%56 46.649656 46.64965G 46.6H65E 111.02618 366.72378 920.40261 no 2, 6-Dichlorophenol 19.f5~862 JS,659862 18.655862 H.659862 44.410473 154.68951 368.16104 no 3,4-Dichlorophenol :27.S89i94 27,999794 27.989794 27.989794 66,615709 232,03427 552.24156 no 2,4-Djchlorophenocy-3Cetic acid (2,4-D) 9329.S312 9329.9312 9329.9312 9329.9312 22205,236 77344.157 184080.52 no 2-(2,4,5-Trichlorophen-oxy) propiohic acid (2,4,5-TP, Silvex) --- 932.99312 --- 932,99312 932.99312 932.99312 2220,5236 7734.4757 18408,052 no METALS AND CYANIDE Tot.al Arsenic 3080,1974 10595.274 10372.916 985,66315 5615.4951 10372.916 965.66315 1291.2187 3065.4124 10704.152 25412.Hn no Total Cadmium 731.48697 159,45481 3311.3057 234,07583 84.51108 331L3057 84.51108 110.70951 262.82946 917.77745 2178.8457 no Chromium Ill 16776.46 42406.563 24642.791 5368.4671 22475.478 24642.791 5368,46717032.691916695.933 58300.7H 138408.61 *no Chromium VI 64.052227 336.15244 11973 20,496712 118.16079 11973 20.496712 26.850693 63,744776 222.59117 528.44164 no Total copper 400,28246 2002.8137 332218.36 128.09039 l06L49l3 332218.36 128.09039167.79841 398.3611 1391.0421 3302.3976 no Total Lead 2759.6501 E37. 961 30788, 773 883 .08802 444. 12993 30788. 773 444 .12993 581.81021 1381. 2441 4823, 1834 11450. 458 no Total Mercury 19.688014 l.C6l69::iJ 519.70691 &.3001645 0.5626994 519.70691 0.5626984 0.73713-49 l.749992 6,1108189 14.S.07364 no Total Nickel 26308,891 22;67,651 8418,8452 12066,855 8418.8452 11028.687 26182.n08 91427.375 217052,78 no Total Zinc 3040.7928 21636.923 2115811 973.05371 11467,569 2ll58ll 973.053711274.7004 3026.197 10567,215 25087.052 no Total Cyanide 187,11795 171.53876 6193:1.084 59,877743 90.915544 61932.084 59.877743 78.439844 186.21978 650,26317 1543.7545 no DIOXW 2,3,7,8 TCDO; dioxin 0.0!:>017 0.00017 0,00017 0.00017 0.0004046 0.0014094 0.0033544 no VOLATILE COMPOUNDS Benzene 9168.3718 35737.242 263.40599 2933.879 18940,738 263.40599 263,40599 23.40599 626.90626 2183.6251 5i97.0278 no Bromo!orm 11944.566 46537.831 933.89397 3822.2612 24665.05 933.89397 933.89397 933,89397 2222.6676 7741.9437 18425,826 no Bromodichloromethane 47.891998 --- 47,891998 47.891998 47,891998 113.58296 397.02275 944.91415 no Carbon Tetrachloride 11129.237 43361.187 52,681198 3561.356 22981.429 52.681198 52.681198 52.681:98 125.38125 436.72503 1039,4056 no Chloroform 11781.5 .;5,02.502 1269.lJ:B 3770.0801 .24328.326' 1269.139 !269.138 1269.138 3020.5483 10S21.1C3 25040.225 no Dihromochloromethane 93,389397 93.389397 93.389397 93,389397 222,26676 774.19437 1842,5826 1,2-Dichloroethane 46104,396 18712l.9E S6.205597 15393.407 99333.GS 8G.20SS9'7 86.20559'7 86.205597 205.16932 114.64095 11C(LS455 no l,l-Dichlorcethylene ll .973 151'.?i.2.SO:t S1'f.5,0029 11.~13 11. 91 J 11.913 28.495739 99.255666 ;)3.22054 no 1, 3-Di chloropropylene 2ot70.~16l ~62S.2305 9l~.<J3122 790.54276 5101.37.2.2 9'19.93122 790.542?6 1035.611 2158.598 9585.1739 203-Bl.596 no Ethylbem:ene l.3045 26 SOS26.3 222595.36 4174 "iiE-32 2653'2.939 222ses.J6 .;174_.;932 5468.573 12982.643 4.5334.251 l0162S.S9 no Methyl Chloride 224215,41 813517 03 71149.93 .;62995.63 717.;S.SJ ~J99I.OS'8 223139.17 779182.44 184901-i 9 no Methylene Chloride 78679,224 .306S46 12 105:!.62.; 2511"'!'.352 162 .. 69 . .;.; 1953.624 1053.E24 1053.62.; 2501.'625 8734.SOOS 20788 lll no l,!,2,2*Tetrachloro-ethane j799 .. 32 i.;~o~.16 :?S.3l35!:9 1215.Sl82 7815.6717 3S.31JS99 Je.313599 38.313599 91.186365 311 6192 755.93132 no A-119
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| | |
| ;\p~endJ x B-1 Fage 4 E..!tergy Operatior.s, Inc. /Watel.*ford LA.0007374, AI3526C*
| |
| (
| |
| * l} [*2) ( .. 3f ("'i) { ~ s) i "6) ( *7) c*el 1 *9) (* 10) (*Jl)
| |
| TO:XlC Cu Effluent Effluent. V.OL Effluent 95th Numerical crite1*ia HH
| |
| ?a:rameters Inst ream /Tech /Tech l=NO 95% estimate Acute chronic HHm..: Carci:iogen Cone. \Avg) (Max) 0~9s \ Ncn*Tech FW FW !ndicator ug/L lbs/day lbs/day ug/L lbs/day ug/L ug/L ug/!.. "C" IJOLi..TlLE COMPOUNDS' {cont 'di 7etrachlorcethylene 10 1290 e.; s 0.65 c Tolut:ne 10 1270 635 6100 1, 1.1-Trichlo::'."oethane 10 5260 2640 200 1,1,2-Trichloroethane 10 1800 SOD 0.56 c Trichloroethylene 10 3900 1950 2.8 c Vinyl Chloride 10 1. 9 c ACID COMPOffiJDS 2 - Chl orophenol 10 258 129 0. J 2,4-Dichloroph~nol 10 202 101 0.3 B/\SE NEUTRAL COMPOUNDS Benzi dine so 250 125 0.00008 c Hexachlorobenzene 10 0.00025 c Hexachlorabutadiene 10 5.1 1.02 0.09 c PESTICIDES Aldrin 0.05 3. 0. 00004 c Hexachlorocyclchexane (gamma BHC, Lindane) 0.05 5.3 0.21 0.11 c Chlordane 0 .2 2.4 0.0043 0.00019 c 4, 1 1
| |
| -DDT 0.1 1.1 0.001 0.00019 c 4, 4 '-ODE 0.1 52.5 10.5 0.00019 c 4, 4 '-DDD 0 .1 0.03 0.006 c. 00027 c Dieldrin 0 .1 0. 23 74 0.0557 0.00005 c Endosultan 0 .1 0.22 0.056 Q _47 Endrin 0 .1 0.0864 0.0375 0.26 Heptachlor 0.05 0.52 0.0038 0.00007 c
| |
| : 0. 014 Toxaphene 0.73 0.0002 0.00024 c Othe~ Parameters.
| |
| Fecal Col. lcol/100ml)
| |
| Chlorine 19 Ammonia Chlorides Sulfates TDS A-120
| |
| | |
| Appendix B-l Page Entergy Ope rat ions, Inc. /wa terf ord 3 LA000/374, AD5260
| |
| (* 1} t *12) t*13) (* 14) (*lS) {
| |
| * 16 J (*.17) 1*10 J {
| |
| * 191 ( *20; (. 21) ( *22) i. 2J}
| |
| Toxic WLJ..a WLA.c WLJ..h LTAa LTAc LTl\h Limiting '1QBL WQSL WQBl, WQBL Need Pararr.eters Acute Chronic HHDW Acute Chrcnic HHD>; A,C.HH Avg Max Avg Mal\ WQE'L?
| |
| 001 OOl OCl 001 ug/L ug/L ug/L ug/L ug/L ug/L ug/!.. ug/L ug/L lbs/day lbs/day Tetrachloroethyl~ne 5258.8704 2018~.352 155.649 1GB2.8385 10859.357 155.649 lSS.619 lS~.6.;s :no 4':461 1290.3239 30?0.971 no Toiuene 5177.3376 20171.ESS 5691:?5.Sl 1656,1.;S 10690.995 56.9125.81 1656.74e 2170.3399 5152.466~ !1992.03142713.506 no 1,1,l-Trichloroethane 21524.679 83863.395 18659.86~ 6681.891~ 44447,599 18659.862 6867.8973 9023.1454 21421.361 '14801.515 l7?5B2.22 no l,l,2-Trichloroethane 7337.9587 28599.794 134.0976 2J.;S.l46S 15152.SSl 13*4.0976 134.0976 134.0976 319.15228 1111.6637 2645.7596 nc Tr ich loroethylenc 15899.911 61944.553 670.48798 5001.6514 32830.613 670.rn798 610.48198 670.48799 1595.7614 5559.3185 1322s.ns no Vinyl Chloride: --- 45-t.97399 --- 454.97399 454.9*399 454.97399 1082.B381 3771.7161 8916.6844 no ACJ D COMPOUNDS 2-Chlorophencl 1051.7741 4091.0104 9,3299312 336.56771 211i.0113 9.3299312 9.3n9312 9.3299312 22.205236 77.344757 194.08052 nc 2,4-Dichlorcphenol 823.48204 3208.4102 27.989794 263.51425 1700.4574 27.969794 27.989794 27.989794 66.615709 232.03'27 552.24156 no BASE NEUTRAL CD~POUNDS Benzi dine 1019 1609 3970.8047 0.0191568 326.1315 2104.5265 0.0191568 0.0191568 0.0191568 0.0455932 0.1588091 0.3779657 no Hexachloroben2ene 0. 059865 0.059865 0.059865 0.059865 O.H2'787 0.4962784 l.1811427 no Hexachlorabutadiene 20.790883 32.401766 21.551399 6,,6530826 17.172936 21.551399 6.6530026 8.7155392 20.691087 72.251463 171.52828 no PESTICIDES Aldrin 12 .229931 --- 0.0095784 3.913578 --- 0.0095784 0.0095784 0.0095784 0.0227966 0.0794046 0.1889028 no Hexachlorocyclohexane (gamma BHC, Lindane) 21.606212 6.6709519 26.340599 6.9139878 3.5356045 26.340599 3.5356045 4.6316419 10.99573 38.396126 91.154162 no Chlo:rdane 9.783945 0.1365957 0.0454974 3.1308624 0.0723957 0.0454974 0.0454974 0.0454974 0.1082838 0.3771716 0:8976684 no
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| : 4. 4 -DDT I 4.4943081 0.0317664 0.0454974 1.4349786 0.0168362 0.0454974 O.til68362 0.0220554 0.0523606 0.1828387 0.1340674 no 4,4'-0DE 214.0238 333.54759 0.0454974 69.487615 176.78022 0.0454974 0.0454974 .0454974 0.1082838 0.3771716 0.6976694 no 4 ,4 '-DOD 0.1222993 0.1905986 0.0646542 0.0391358 0.1010173 0.0646542 0.0391358 0.0512679 0.1217123 O.U50086 l.0089859 no Dieldrin 0.9677952 1.7693906 0.011973 0.3096945 0.93'1777 O.Oll973 0.011913 0.011973 0.0284957 0.0992557 0.2362285 no Endosul fan 0.8968616 l.7799205 43.850677 0.2869957 0.9428279 43.850677 0.2869957 0.3'759644 0.0925567 3.1167298 7.3992592 no Endrin 0.352222 1.1912114 24.257821 0.112711 0.631JS'79 24.257821 0.112711 0.1476515 0.3505311 l.2240248 2.9058909 no Heptachlor 2 1199547 o.;201125 0.0167622 o.6783535 0.0639?76 0.0167622 0.0161622 o.0167622 o.039894 o.138958 o.33072 no Toxaphene
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| * 2.9759<99 0.0063533 0,0574104 0.952304 0.0033612 0.0574704 0.0033672 0.0044111 0.0104721 0.0365677 0.0668135 no OtheI Parameters:
| |
| Fecal Col. fcol/l OOml J no Chlod r.e I; .456231 J49 43081 21. 785994 105.19933 24.7S5994 32.46.9652 77.081~41 269.17212 639.02693 no Am@onia no Chlorides no Sul fates no TDS no nc no A-121
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| | |
| APPENDIX B-2 LA0007374, AI No. 35260 Documentation and Explanation of Water Quality Screen and Associated Lotus Spreadsheet Each reference column is marked by a set of parentheses enclosing a number and asterisk, for example (*l) or (~19). These columns represent inputs, existing data sets, calculation points, and results for determining Water Quality Based Limits for an effluent of concern. The following represents a sununary of information used in calculating the water quality screen:
| |
| Receiving Water Characteristics:
| |
| Receiving Water: Mississippi River Critical Flow, Qrc (cfs): 141,955 Harmonic Mean Flow, Qrh (cfs): 366,758 Segment No.: 070301 Receiving Stream Hardness (mg/L): 153.4 Receiving Stream TSS (mg/L): 32 MZ Stream Factor, Fs: 1 Plume distance, Pf: N/A Effluent Characteristics:
| |
| 9ompany: Entergy Operations, Inc.
| |
| Outfall 001 flow, Qe (MGD): 994 Effluent Hardne~s: N/A Effluent TSS: N/A Pipe/canal width, Pw: N/A Permit Number: LA0007374 Variable Definition:
| |
| Qrc, critical flow of receiving stream, cfs Qrh, harmonic mean flow of the receiving stream, cfs Pf= Allowable plume distance in feet, specified in LAC 33:IX.1115.D Pw = Pipe width or canal width in feet Qe, total facility flow , MGb Fs, stream factor from LAC.33.IX Chapter 11 (1 for harmonic mean flow)
| |
| Cu, ambient concentration, ug/L Cr, numerical criteria from LAC.33.IX.1113, Table 1 WLA, wasteload allocation LTA, long term average calculations WQBL, effluent water quality based .limit ZID, Zone of Initial Dilution in % effluent MZ, Mixing Zone in % effluent Formulas used in aquatic life water quality screen (dilution type WLAJ:
| |
| Streams:
| |
| Dilution Factor e (Qrc x 0.6463 x Fs + Qe)
| |
| A-122
| |
| | |
| f\.ppendix B-2 LA0007374, Al No. 35260 Page 2 WL.Z\ a,c,h Cr - (Fs x Qrc x 0.6463 x Cul Di2.ution factor Qe Static wa~er bodies (in the absence of a site specific dilution):
| |
| Discharge from a pipe: Discharge from a canal:
| |
| Critical Critical Dilution (2. 8) Pw r: 11 ; Dilution {2 . 3 8 l ( Pw 112 )
| |
| Pf (Pf) in
| |
| \"1LA (Cr-Cu) Pf WL.Z\ (Cr-Cu) Pf 112 (2.8) Pw n 1 n 2.38 Pw 112 Formulas used in human health water quality screen, human health non-carcinogens (dilution type WLA):
| |
| Streams:
| |
| Dilution Factor e (Qrc x 0.6463 + Qe)
| |
| WLA a,c,h Cr - (Qrc x 0.6463 x Cu)
| |
| Dilution Factor Qe Formulas used in human health water quality screen, human health carcinogens (dilution type WLA) :
| |
| Dilution Factor = e (Qrh x 0.6463 + Qe)
| |
| WLA a,c,h Cr - (Qrh x 0.6463 x Cu)
| |
| Dilution Factor Qe Static water bodies in the absence of a site specific dilution (human health carcinogens and human health non-carcinogens):
| |
| Discharge from a pipe: Discharge from ~ canal:
| |
| Critical Critical Dilution (2.8) Pw n 112 Dilution (2.381 (Pw 112 )
| |
| (Pf) 112 l?f (Cr-Cu) Pf* WLA (Cr-Cul Pfl/ 2 *
| |
| ( 2 . 8 ) Pw n 112 2. 38 Pw; 12
| |
| ~ Pf is set equal to the mixing zone distance specified in LAC 33:IX.1115 for the static *..iater body type, i.e., lake, estuary, Gulf of Mexico, etc.
| |
| A-123
| |
| | |
| Appendix B-2 LA0007374, AI No. 35260
| |
| ?age 3 If a site specific dilution is used, WLA are calculated by subtracting Cu from Cr and dividing by the site specific dilution for human health and aquatic life criteria.
| |
| \'JLA = (Cr-Cu) site specific dilution Long Term Average Calculations:
| |
| LTAa WLAa X 0.32 LTJl.c WLAc X 0.53 LTAh WLAh WQBL Calculations:
| |
| Select most limiting LTA to calculate daily max and monthly avg WQBL If aquatic life LTA is more limiting~
| |
| Daily Maximum= Min(LTAa, LTAc) X 3.11 Monthly Average = Min(LTAc, LTAc) X 1.31 If human health LTA is more limiting:
| |
| Daily Maximum = LTAh X 2.38 Monthly Average = LTAh Mass Balance Formulas:
| |
| mass (lbs/day): (ug/L) X 1/1000 X (flow, MGD) X 8.34 =lbs/day concentration(ug/L): lbs/day = ug/L (flow, MGC) X 8.34 X 1/1000 The following is an explanation of the references in the spreadsheet.
| |
| (*l) Parameter being screened.
| |
| (*2) Instrearn concentration for the parameter being screened in ug/L. In the absence of accurate supporting data, the instream concentration is assumed to be zero (0) .
| |
| (*3) Monthly average effluent or technology value*in concentration units of ug/L or mass units of lbs/d~y. Units determined on a case-by-case basis as appropriate-to the particular situation.
| |
| (*4) Daily maximum technology value in concentration units 9f ug/L or mass units of lbs/day. Units determined on a case-by-case basis as appropriate to the particular situation.
| |
| (*5) Minimum analytical Quantification Level.s (MQLs). Established. in a letter dated January 27, i994 from Wren Stenger of EPA Region 6 to Kil ren *Vidrine of LDEQ and fr.om the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards". The applicant must test for the parameter at a level at least as sensitive as the specified MQL. If this is not done, the MQL becomes the application value for screening purposes if the pollutant is suspected to be present A-124
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| | |
| Appendix B-2 LA0007374, AI No. 35260 Page 4 on-site and/or in the waste stream. Units are in ug/1 or lbs/day depending or. the units of the effluent data.
| |
| (*6} States whether effluent data is based on 95th percentile estimation. A "l" indicates that a 95th percentile approximation is being used, a "0" indicates that no 95th percentile approximation is being used.
| |
| (*7) 95th percentile approximation multiplier (2.13). The constant, 2.13, was established in memorandum cf understanding dated October 8, 1991 from Jack Ferguson of Region 6 to Jesse Chang of LDEQ and included in the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards". This value is screened against effluent Water Quality Based Limits established in columns (*18) - (*21). Units are in ug/l or lbs/day depending on the units of the measured effluent data.
| |
| (*8) LAC 33.IX.1113.C.6, Table 1, Numerical Criteria for Specific Toxic Substances, freshwater ( FW) or marine water (MW) (whichever is applicable) aquatic life protection, acute criteria. Units are specified. Some metals are hardness dependent. The hardness of the receiving stream shall generally be used, however a flow weighted hardness may be determined in site-specific situations. Dissolved metals are converted to Total metals using partition coefficients in ac~ordance with the "Permitting Guidance Document for *Implementing Louisiana Surface Water Quality Standards". Similar: to hardness, the TSS of the receiving stream shall generally be used, however, a flow weighted TSS may be determined in site-specific situations.
| |
| Hardness Dependent Criteria:
| |
| Metal Formula Cadmium e(l.1280(1n(hardness)] - 1.6774)
| |
| Chromium III e(0.8190(ln(hardness)J + 3. 6880)
| |
| Copper e(0.9422(ln(hardness)] - J. 3884)
| |
| Lead e(l.2730(ln(hardness)) - 1. 4600)
| |
| Nickel e(0.8460(ln(hardness)] + 3.3612)
| |
| Zinc e !O. 8473 (ln !hardness I J + 0.8604)
| |
| Dissolved to Total Metal Multipliers for Freshwater Streams (TSS dependent) :
| |
| Metal Multiolier Jl.rsenic 1 + 0. 4 8 x TSS-o. 73 x TSS Cadmium 1 + 4. 00 x TSS-l. 13 x TSS Chromium III 1 + 3.36 x TSS-0.93 x TSS Copper 1 + 1. 04 x TSs- 0
| |
| * 74 x TSS Lead 1 + 2.80 x TSS-c.eo x TSS Mercury 1 + 2.90 x TSS-1. 14 x TSS Nickel 1 + 0. 4 9 x rss-o.s1 x TSS Zinc 1 + 1. 25 x TSS-0.10 x TSS Dissolved to Total Metal Multipliers for Marine Environinents (TSS dependent) :
| |
| Metal Multiplier A-125
| |
| | |
| l\ppendix B-2 LA0007374, AI No. 35260 Page 5 Copper 1 + (104.86 x TSS-0.72 x TSS) x 10-E Lead 1 + (106.06 x TSS-0.80 x TSS) x 10-6 Zinc 1 + (105.36 x TSS-0.52 x TSS) x 10- 6 If a metal does not have multiplier listed above, then the dissolved to total metal multiplier shall be 1.
| |
| (*9) LAC 33.IX.1113.C.6, Table 1, Numerical Criteria for Specific Toxic Substances, freshwater ( FW) or marine water (MW) (whichever is applicable) aquatic life protection, chronic criteria. Units are specified. Some metals are hardness dependent. The hardness of the receiving stream shall generally be used, however a flow weighted hardness may be determined in site-specific situations. Dissolved metals are converted to Total metals using partition coefficients in accordance with the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards". Similar to hardness, the TSS of the receiving stream shall generally be used, however, a flow weighted TSS may be determined in site-specific situations.
| |
| Hardness dependent criteria:
| |
| Metal Formula e(0.7852[ln(hardness)] - 3.4900)
| |
| Cadmium e(0.8473[ln(hardness)] + 0.7614)
| |
| Chromium III Copper e(0.8545[ln(hardness)] - 1.3860) e(l.2730[ln(hardness) J 4.7050)
| |
| Lead e(0.8460[ln(hardness)] + 1.1645)
| |
| Nickel e(0.8473[ln{hardness)] + 0.1614)
| |
| Zinc Dissolved to total metal multiplier formulas are the same as (~8), acute numerical criteria for aquatic l~fe.protection.
| |
| (*10) LAC 33.IX.1113.C.6, Table 1, Numerical Criteria for Specific Toxic Substances, human health protection, drinking water supply (HHDW), non-drinking water supply criteria (HHNDW), or human health non-primarry contact recreation (HHNPCR) (whichever is applicable). A DEQ and EPA approved Use Attainability Analysis is required before HHNPCR is used, e.g., Monte Sano Bayou. Units are specified.
| |
| (*11) C if screened and carcinogenic. If a parameter is being screened and is carcinogenic a "C" will appear in this column.
| |
| (*12) Wasteload Allocation for acute aquatic criteria (WLAa) Dilution type WLAa is calculated in accordance with the "Permitting Guidance* Document for Implement.ing Louisiana Surface Water Quality Standards". Negative values indicate that the receiving water is not meeting the acute aquatic nume~ical criteria for that parameter. Units are in ug/L.
| |
| Dilution WLAa formulas for streams:
| |
| WLAa = (Cr/Dilution Factor) - IFs x Ore x 0.6463 x Cul Qe Dilution WLAa formulas for, static water bodies:
| |
| WLAa = (Cr-Cul/Dilution Factor)
| |
| Cr represents aquatic acute numerical criteria from column (*.BJ.
| |
| If Cu data is unavailable or inadequate, assume Cu=O.
| |
| A-126
| |
| | |
| J\ppendix B-2 LA0007374, AI No. 35260 Page 6 If water quality standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then a blank shall appear in this column.
| |
| (*13) Wasteload .Z\llocation for chronic aquatic criteria (WLAc). Dilution tvoe WLAc is calculated in accordance with the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards". Negative values indicate that the receiving water is not meeting the chronic aquatic numerical criteria for that parameter. Units are in ug/L.
| |
| Dilution WLAc formula:
| |
| WLAc = (Cr/Dilution Factor) - (Fs x Qrc x 0.6463 x Cu)
| |
| Qe Dilution WLAc formulas for static water bodies:
| |
| WLAc = (Cr-Cul/Dilution Factor)
| |
| Cr represents aquatic chronic numerical criteria from column (*9).
| |
| If Cu data is* unavailable or inadequate, assume Cu=O.
| |
| If water quality standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then a -blank shall appear in this column.
| |
| (*14) Wasteload Allocation for human health criteria (WLAh). Dilution type WLAh is calculated in accordance with the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards". Negative values indicate that the receiving water is not meeting the human health numerical criteria for that parameter. Units are in ug/L. Dilution WLAh tormula:
| |
| WLAh = (Cr/Dilution Factor) - (Fs x Qrc,Qrh x 0.6463 x_ Cul Qe Dilution WLAh formulas for static water bodies:
| |
| WLAh = (Cr-Cul/Dilution Factor)
| |
| Cr represents human health numerical criteria from column (*10).
| |
| If Cu data is unavailable or inadequate, assume Cu=O.
| |
| If water quality standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then a blank shall appear in this column.
| |
| (*15) Long Term Average for aquatic numerical criteria (LTAa). WLAa numbers are multiplied by a multiplier specified in the "Permitting Guidance Doc~~ent for Implementing Louisiana Surface Water Quality Standards" which is 0.32. WLAa X 0.32 = LTAa.
| |
| If water quality standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then a blank shall appear in this column.
| |
| (*16) Long Term Average for chronic numerical criteria (LTAc). WLAc numbers are multiplied by a multiplier specified in the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards" which is 0.53. WLAc X 0.53 = LTAc.
| |
| If water quality standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then a blank shall appear in this column.
| |
| (
| |
| * 1 7) Long Term Average for human heal th nu.rnerical criteria (LTAh) . WLAh numbers are multiplied by a multiplier specified in the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards" which is 1. WLAc X l = LTAh.
| |
| If water quality standards are being app.lied at end-of-pipe, such as in the case of certain TMDLs, then a blank shall appear in this column.
| |
| (*18) Limiting Acute, Chronic or Human Health LTA's. The most limiting LTA is placed in this column. Units are consistent with the vJLA calculation.
| |
| A-127
| |
| | |
| Appendix B-2 LA0007374, AI No. 35260 Page 7 If standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then the type of limit, Aquatic or Hurnan Health (HH), is indicated.
| |
| (*19) End of pipe Water Quality Based Limit (WQBL) monthly average in terms of concentration, ug/L. If aquatic life criteria was the most limiting LTA then the limiting LTA is multiplied by 1.31. to determine the average WQBL (LTA!imiting aquatic X 1. 31 = WQBLmonthly average). If human health criteria was the most limiting criteria then LTAh = WQBL:uonthly average* If water quality standards are being applied at end-of-pipe, iuch as in the case of certain TMDLs, then either the human health criteria or the chronic aquatic life criteria shall appear in this column depending on which is more limiting.
| |
| (*20) End of pipe Water Quality Based Limit (WQBL) daily maximum in terms of concentration, ug/L. If aquatic life criteria was the most limiting LTA then the lim.i ting LTA is multiplied by 3. 11 to determine the daily maximum WQBL (LTAlimiting aquatic X 3.11 = WQBLaaily maxl. If human health criteria was the most limiting criteria then LTAh is multiplied by 2.38 to determine the daily maximum WQBL (LTA!imiting aquatic X 2. 38 = WQBLcaily maxl.
| |
| If water quality standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then either the human health criteria or the acute aquatic life criteria shall appear in this column depending on which is more limiting.
| |
| -(*21) End of pipe Water Quality Based Limit (WQBL) monthly average in terms of mass, lbs/day. The mass limit is determined by using the mass balance equations above. Monthly average WQBL, ug/l/1000 X facility flow, MGD X 8.34 =monthly average WQBL, lbs/day.
| |
| (*22) End of pipe Water Quality Based Limit (WQBL) monthly average in terms of mass, lbs/day. Mass limit is determined by using the mass balance equations above. Daily maximum lvQBL, ug/l/1000 X facility flow, MGD X 8.34 =daily maximum WQBL, lbs/day.
| |
| (*23) Indicates whether the screened effluent value(s) need water quality b.ased limits for the parameter of concern. A "yes" indicates that a water quality based limit is needed in the permit; a "no" indicates the reverse.
| |
| A-128
| |
| | |
| Invoice No. January 21, 2010 Page 1 LOUISIANA WATER POLLUTION CONTROL FEE SYSTEM RATING WORKSHEET PERMIT NO. LA0007374 AI NO. 35260 11.ctivity No.: PER20090001 1.a. Company Name Entergy Operations, Inc.
| |
| 1.b. Facility Name Waterford 3 Steam Electric Station 2 . Local Mailing Add res s_-=1:...7:..:2,,__6=5-=-R==i'-"v:..:e:;r=--:..:Rc.::o-=a~d=--------------------
| |
| Kil lona Louisiana 70057
| |
| : 3. Billing Address (If different) ________________________
| |
| 4.a. Facility Location 17265 River Road Killona 4.b. Parish St. Charles
| |
| : 5. Facility Type steam electric generating station
| |
| : 6. Products Produced._______________________________
| |
| 6.a. Raw materials stored or used _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
| |
| 6.b. By-products produced__________________________
| |
| : 7. Primary SIC Code 4911 7. a. Other SIC Codes _ _ _ _ _ _ _ _ _ _ __
| |
| : 8. Fae. Manager _ _ _ _ _ _ _ _ _ _ _ _ _ __ 8.a. Telephone _ _ _ _ _ _ _ _ __
| |
| : 9. Owner _________________ ~
| |
| 9.a. Telephone _ _ _ _ _ _ _ _ __
| |
| : 10. Env. Contact Rodney LeBlanc 10.a. Telephone (504)464-3267
| |
| : 11. State Permit No. _ _ _ _ _ _ _ __ 12. NPDES Permit No. LA0007374 11.a. Date Issued ____________ 12.a. Effective Date February 1, 2005 11.b. New_ _ _ _~Modified_ _ _ _ _ _~
| |
| 12.b. Expiration Date January 31, 2010
| |
| : 13. Number and Identification of Outfalls Outfall 001 - once through non-contact cooling water, intermittent discharge including utilities and maintenance wastewaters and stormwater; Outfall 004 intermittent discharges of stormwater runoff and maintenance wastewaters; Outfall 005 -
| |
| treated sanitary wastewater 14 . Number of Inject ion Well s_-=N~A'-=------------------------
| |
| : 15. Water Source(s) ________________________________
| |
| : 16. Receiving Water(s) Outfall 001 - Mississippi River; Outfalls 004 and 005 -
| |
| 40 Arpent Canal
| |
| : 17. River Basin Mississippi, Barataria 18 . Bas in Segment No. _0_7~0~3~0~1~~0~2~0~2_0~2~----------------------
| |
| TOTJ.l.L RATING POINTS ASSIGNED I 305
| |
| --~m=l=b=---__ Initials of Rater A-129
| |
| | |
| Invoice No. _ _ _ _ _ _ _~ ANNUAL FEE RATING WORKSHEET - INDUSTRIAL Page 2 PERMIT NO. LA0007374, AI No. 35260,PER20090001
| |
| : 1. FACILITY COMPLEXITY DESIGNATION Primary SIC 4911 Other SIC Complexity Designation = I (QPoints)
| |
| II (10 points)
| |
| III (20 points)
| |
| IV (30 points)
| |
| .I V (40 points)
| |
| VI (50 points)
| |
| COMPLEXITY DESIGNATION POINTS 40
| |
| : 2. FLOW VOLUME AND TYPE A. Wastewater Tyoe I Is total Daily Average Discharge greater than 400 mgd?
| |
| .I Yes, then points = 200
| |
| _ _ _ _ _ _ No, then Points 0.5 X Total Daily Average Discharge (mgd)
| |
| Poir.ts = 0.5 X Total points = --=2~0~0---~
| |
| B. Wastewater Type II Points 10 X Total Daily Average Discharge (mgd)
| |
| Points = 10 X Total points = -~--~-
| |
| C. Wastewater Type III Points 2 X Total Daily Average Discharge (mgd)
| |
| Points = 2 X Total points = -----=-0_ __
| |
| FLOW VOLUME AND TYPE POINTS 200
| |
| : 3. POLLUTANTS A. BOD or - - - -
| |
| Daily Average Load
| |
| ,/ :s: 50 lb/day (0 points)
| |
| - - - - - - > 50 - 500 (5 points)
| |
| - - - - - - > 500 - 1000 (-10 points)
| |
| - - - - - > 1000 - 3000 (20 points)
| |
| - - - - - - > 3000 - 5000 (30 points)
| |
| - - - - - - > 5000 lb/day (calculate)
| |
| Points 0.008 X Daily Average Load* (lbs)
| |
| Points 0.008 x 0 0 COD o r - - - -
| |
| Daily Average Load
| |
| .I :s: 100 lb/day ( 0 points)
| |
| > 100 - 500 ( 5 points)
| |
| > 500 - 1000 ( 10 points)
| |
| > 1000 - 5000 (20 points)
| |
| > 5000 - 10000 (30 points)
| |
| > 10000 lb/day (calculate)
| |
| Points 0.004 X Daily Average Load (lbs)
| |
| Points 0. 004 x 0 *- 0 BOD OR COD DEMAND POINTS 0 (whichever is greater)
| |
| A-130
| |
| | |
| Invoice No.~~--~---- ANNUAL FEE RATING WORKSHEET - INDUSTRIAL Page 3 PERMIT NO ... LA0007374, AI No. 35260, PER20090001 B. TSS Daily Average Load =
| |
| ./ :> 100 lb/day ( 0 points)
| |
| > 100 - 500 ( 5 points)
| |
| > 500 - 1000 (10 points)
| |
| > 1000 - 5000 (20 points)
| |
| > 5000 - 10000 (30 points)
| |
| > 10000 lb/day (calculate)
| |
| Points 0.004 X Daily Average Load (~bs)
| |
| Points 0. 004 x 0 0 TSS POINTS 0
| |
| : c. TOXICS Total Annual Discharge to Water =
| |
| Points 0.01 X Annual discharge {lbs)
| |
| Points 0. 01 x 0 0 TOXIC POINTS 0 TOTAL POLLUTANT POINTS 0
| |
| : 4. TEMPERATURE (HEAT LOAD}
| |
| Heat Load =Average Summer flow (mgd) X *T X 0.00834 where 0 T =Permit Limit (Max. Temp.) -70° Heat Load = 1125 (rngd) X 48 X 0. 00834 ___4~5~0~_Billion BTU Heat Load = 0 s 4 billion BTU ( 0 points)
| |
| > 4-20 billion BTU { 5 points)
| |
| > 20-100 billion BTU (10 points)
| |
| > 100-200 billion BTU (15 points)
| |
| ./ > 200 billion BTU (20 points)
| |
| HEAT LOAD POINTS _ _ _---'2~0=----
| |
| : 5. POTENTIAL PUBLIC HEALTH IMPACTS Is the receiving water to which the wastewater is discharged or a water body to which it is a tributary used as a drinking water supply source within 50 miles downstream?
| |
| ----..,.--~--No (0 points)
| |
| ~--~./ _ _~__ Yes, then . . . Complexity Designation
| |
| _ _ _ _ _ _ I, II ( 0 points)
| |
| _ _ _ _ _ _ III ( 5 points)
| |
| _ _ _ _ _ _ IV (10 points)
| |
| ./ V (20 points}
| |
| _ _ _ _ _ _VI (30 points)
| |
| POTENTIAL PUBLIC HEALTH IMPACT POINTS 20
| |
| : 6. MAJOR/MINOR FACILITY DESIGNATION Has your facility been designated a Major Facility by the administrative authority?
| |
| ---~--'./'--___ Yes, then Points 25
| |
| ------~--No, then were effluent limitations assigned to the discharge based on water quality factors in the receiving stream?
| |
| ~~--~./ _ _ _ _ No, then Points 0
| |
| ---~--~--Yes, then Points = 5 TOTAL MAJOR/MINOR POINTS~---=2=5---~
| |
| TOTAL RATING POINTS ASSIGNED_ _ _ _ _ _-=3-=-0=5_ _ _ _ _ __
| |
| A-131
| |
| | |
| BOBBY }INDAL PEGGY M. HATCH GOVER.l\/OR SECRETARY
| |
| ~tate of JLouistana DEPARTMENT OF ENVIRONMENTAL QUALITY ENVIRONMENTAL SERVICES Ms. Kelli M. Dowell AI No.: 35260 Entergy Services, Inc.
| |
| January 30, 2015 Activity No.: PER20140002 Post Office Box 1640 Jackson, Mississippi 39201 RE: Entergy Operations, Inc. - Waterford Steam Electric Station Unit 3 Water Quality Certification .
| |
| | |
| ==Dear Ms. Dowell:==
| |
| | |
| The Louisiana Department of Environmental Quality, Water Permits Division (LDEQ), has received the request from Entergy Operations, Inc. (Entergy) regarding the water quality certification (WQC) issued to Entergy's Waterford Steam Electric Station Unit 3 (WF3) and its upcoming operating license renewal with the United States Nuclear Regulatory Commission (NRC).
| |
| LDEQ has reviewed the request and confinns:
| |
| (i) LDEQ requires no new or additional water quality certification pursuant to Section 401 of the Federal Clean Water Act, 33 U.S.C. Section 1341, for WF3 in support of its license renewal application.
| |
| (ii) LDEQ deems the WQC issued by the State of Louisiana Stream Control Commission on June 21, 1972, valid for Waterford Units I, 2, and 3 to be a certification obtained pursuant to paragraph (I) of 33 U.S.C. Section 1341(a) with respect to the construction of WF3; and (iii) LDEQ deems the currently issued Louisiana Pollution Discharge Elimination System (LPDES) permit LA0007374 issued on October 1, 2010, to be a certification obtained pursuant to paragraph (I) of 33 U.S.C. Section l 34l(a) with respect to the operation ofWF3.
| |
| Should you have any questions concerning any part of this certification, please contact Elizabeth Johnson at (225) 219-3225, or by email at elizabeth.johnson@la.gov. To ensure all correspondence regarding this certification is properly filed into the Department's Electronic Document Management System, please reference Agency Interest (Al) number 35260 on all future correspondence to this Department.
| |
| Si , erely,?/;jf // /
| |
| W;i~
| |
| cott Guil
| |
| * ms Administrator Water Permits Division c: 10-W Corps of Engineers - New Orleans District A-132 Post Office Box4313 o Baton Rouge, Louisiana 70821-4313 *Phone 225-219-3181eFax225-219-3309
| |
| ********* ..J .... .. :_: ___ - - * -
| |
| | |
| Waterford Steam Electric Station , Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment B Threatened and Endangered Species Consultation
| |
| | |
| Attachment B Threatened and Endangered Species Consultation
| |
| * Rick Buckley, Entergy Services, Inc. , to David Bernhart, NOAA Fisheries Service-Southeast Regional Office.
| |
| May 28, 2015.
| |
| * Rick Buckley, Entergy Services, Inc., to Brad Rieck, U.S.
| |
| Fish and Wildlife Service-Louisiana Field Office. May 28, 2015.
| |
| * Rick Buckley, Entergy Services, Inc., to Carolyn Michon ,
| |
| Louisiana Natural Heritage Program-Department of Wildlife and Fisheries. May 28, 2015.
| |
| * Amity Bass, Natural Heritage Program-Louisiana Department of Wildlife and Fisheries, to Rick Buckley, Entergy Services, LLC . June 18, 2015.
| |
| * Kelly Shotts, NOAA Southeast Regional Office-National Marine Fisheries Service, to Rick Buckley, Entergy Services, Inc. June 24, 2015.
| |
| * Deborah Fuller, U.S. Fish and Wildlife Service-Louisiana Field Office, to Rick Buckley, Entergy Services, Inc. June 26, 2015.
| |
| B-1
| |
| | |
| ..
| |
| *~Entergy Entergy Services, inc 1340 Echelo n Par11way Jackson, Mississippi 39213 May 28 , 2015 Mr. David Bernhart Assistant Regional Administrator NOAA Fisheries Service Southeast Regional Office Protected Resources Division 263 13th Avenue South Saint Petersburg , Florida 33701
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3
| |
| * License Renewal Application CEO 2015-00051
| |
| | |
| ==Dear Mr. Bernhart,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish, Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application, Entergy will then have the option to continue operating WF3 for an additional 20 years until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application .
| |
| The NRC requires that the license renewal application for WF3 include an
| |
| * environmental report that assesses the potential environmental impacts from operation during the license renewal term . One of these potential environmental impacts would be B-2
| |
| | |
| the effect of license renewal on designated essential fish habitat (EFH) or protected marine mammals within the immediate environs of the WF3 site (Figure 1). Accordingly, the NRC requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51 .53). Later, during its review of the license renewal environmental report pursuant to the National Environmental Policy Act, the NRC may request information from your office to ensure compliance with the Magnuson-Stevens Fishery ConseNation and Management Act, and the Marine Mammal Protection Act.
| |
| Entergy is contacting you now in order to obtain input regarding issues that may need to be addressed in the WF3 license renewal environmental report, and to assist in identifying any information your staff believes would be helpful to expedite NRC's review.
| |
| During Entergy's review, it was determined that no designated EFH exists tor the Federally-listed threatened gulf sturgeon , Acipenser oxyrinchus desotoi, which may pass the WF3 site during the spawning season. Although the West Indian manatee, Trichechus manatus, is known to inhabit Lakes Pontchartrain and Maurepas and associated coastal waters and streams during summer months, the last known sighting of this species in the Mississippi River was 1975. We do not believe that suitable habitat exists at the ELL site tor manatees either.
| |
| However, even with designated EFH for the gulf sturgeon or the presence of the West Indian manatee in the immediate environs of WF3 (Figure 1), Entergy does not expect WF3 operations during the license renewal term to adversely affect either species since there are no plans to alter current operations during the 20-year license renewal period, and the fact that license renewal will not involve any offsite activities. Although administrative procedural controls are in place to comply with applicable state and federal laws to preseNe biological resources when facility changes do occur, no changes are planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to designated EFH for the gulf sturgeon or protection of the West Indian manatee within the immediate environs of WF3, or alternatively, confirming our conclusion that there is no designated EFH tor the gulf sturgeon within the immediate environs and that the likelihood of the West Indian manatee being adversely affected as a result of continued operations of WF3 for an additional 20 years would be minimal. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application .
| |
| B-3
| |
| | |
| If you have any questions, please contact me at (601) 368-5823 or through my email address, rbuckle @entergy.com.
| |
| Rick Buckley, CHMM , REM Sr. Project Manager, Environmental B-4
| |
| | |
| Figure 1 Location of Entergy Property, 6-Mile Radius Map Legend Cl Airpo11 - i' rope11y Bo undary
| |
| £1 H1,1liport - 1nt*<t sUl:e
| |
| -- ..
| |
| : l. _ "
| |
| Surfaco >Naier -
| |
| 6-M ire R~diu~ -- -
| |
| - U S Ro:.ite Sl ate Route
| |
| :: _*_" _. _; Census ?:~ce L=-J Parosn Local Ro<1ds
| |
| -.- .- ~a~ road
| |
| -------c::========:: =: i 0
| |
| Miles B-5
| |
| | |
| Entergy Services, Inc
| |
| .*===-
| |
| .Et 134 0 Echelon Parl<way n ergy Jackson, Mississippi 3921 3 May 28 , 2015 Mr. Brad Rieck Deputy Field Supervisor U.S. Fish and W ildlife Service Louisiana Field Office 646 Cajundome Blvd., Suite 400 Lafayette , LA 70506
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Application
| |
| * CEO 2015-00052
| |
| | |
| ==Dear Mr. Rieck,==
| |
| | |
| In 2016, Entergy Louisiana , LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish , Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application, Entergy will then have the option to continue operating WF3 for an additional 20 years until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application.
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses potential environmental impacts from plant
| |
| * operations during the license renewal term . One of these potential environmental impacts would be the effect of license renewal on Federally-listed threatened, 8-6
| |
| | |
| endangered or candidate species and designated critical habitat located on the WF3 property and its immediate environs (Figure 1). Accordingly, the NRC requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51 .53) . Later, during its review of the license renewal environmental report pursuant to the National Environmental Policy Act, the NRC may request information from your office to ensure compliance with Section 7 of the Endangered Species Act.
| |
| Entergy is contacting you now in order to obtain input regarding issues that may need to be addressed in the WF3 license renewal environmental report, and to assist in identifying any information your staff believes would be helpful to expedite NRC's review.
| |
| WF3 is located on approximately 3,560 acres of Entergy Louisiana, LLC (ELL) owned property that consists primarily of wetlands, agriculture, and developed areas. The WF3 plant area itself covers 40.1 acres and is zoned as an industrial area by St. Charles Parish . The land in the vicinity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the ELL property. The length of these transmission lines is approximately 0.6 miles, and there is limited right-of-way since the lines cross the WF3 industrial area where vegetation is sparse.
| |
| Based on review of information available, Entergy has included in Table 1 threatened, endangered and candidate species identified as being Federally-listed in St. Charles and St. John the Baptist parishes, of which portions of are included within a 6-mile radius of WF3 (Figure 1). As shown in Table 1, no suitable habitat for these species was identified on the ELL property during a pedestrian survey conducted on October 29, 2014, or was any species observed during the survey. Entergy does not anticipate that the one Federally-listed species identified only in St. John the Baptist Parish (Alabama heelsplitter mussel , Lasmigona alabamensis) would be affected by the renewal of the WF3 operating license since the Mississippi River does not provide suitable habitat for this species. In addition during Entergy's review, no designated critical habitat was identified for the species listed in Table 1 within the immediate environs (6-mile radius) of WF3.
| |
| However, Entergy does not expect that WF3's operations during the license renewal term would result in adverse effects to threatened, endangered or candidate species and designated critical habitats even if present since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to B-7
| |
| | |
| comply with applicable state and federal laws to preserve biological resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| Atter your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to threatened, endangered or candidate species and designated critical habitat on the property where WF3 is located, or the immediate environs, or alternatively, confirming our conclusion that these species and habitats will not be adversely affected as a result of renewing the WF3 operating license for an additional 20 years. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application.
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address, rbuckle@enterqy.com.
| |
| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental B-8
| |
| | |
| Table 1 Federal-Listed Species, St. Charles and St. John the Baptist Parishes Common Name Scientific Name Applicable Federal Habitat Present Species Present Parish Status on ELL Property on ELL Property Mammals West Indian Manatee Trichechus manatus SC/SJB E No No Birds Sprague's Pipit Anthus spragueii SC/SJB c No No Fish Atlantic Sturgeon Acipenser oxyrinchus desotoi SC/SJB T No No Pallid Sturgeon Scaphirhynchus a/bus SC/SJB E No No Mollusks Alabama Heelsplitter Mussel Lasmigona alabamensis SJB T No No SC = St. Charles Parish SJB = St. John the Baptist Parish T = Threatened E= Endangered C= Candidate Species
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| | |
| Figure 1 Location of Entergy Property, 6-Mile Radius Map Legend a A!rpori - Propeny Boundary
| |
| *-¢-*
| |
| £1 Helipcrt - 'nto'lrscate
| |
| ~
| |
| --,
| |
| L Sorf;:ice Waler
| |
| _.I 6 Mile Radius - -
| |
| U.S Rvt1t'!
| |
| Stal'll Rou! o
| |
| ;:* - ~ * ] Cen~us- Place :.().:a! Reads *******-========::::::iMiles 0 2 4
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| [.=:J Pivisll _..__,._ Railmad B-10
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| | |
| *
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| ~Entergy Entergy Services, Inc 1340 Echelon Par1<way Jackson , Mississippi 39213 May 28, 2015 Ms. Carolyn Michon Assistant Data Manager Louisiana Natural Heritage Program Department of Wildlife and Fisheries Post Office Box 98000 Baton Rouge, LA 70898-9000
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| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Application CEO 2015-00053
| |
| | |
| ==Dear Ms. Michon,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish, Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application, Entergy will then have the option to continue operating WF3 for an additional 20 years until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application .
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses the potential environmental impacts from operation during the license renewal term. One of these potential environmental impacts for consideration would be the effect of license renewal on state-listed species and B-11
| |
| | |
| designated critical habitat located on the WF3 property and its immediate environs (Figure 1). Accordingly, the NRG requires that the environmental report for each license renewal application assess such a potential effect ( 10 CFR 51 .53).
| |
| Entergy is contacting you now in order to obtain input regarding issues that may need to be addressed in the WF3 license renewal environmental report, and to assist in identifying any information your staff believes would be helpful to expedite NRC's review.
| |
| WF3 is located on approximately 3,560 acres of Entergy Louisiana, LLC (ELL) owned property that consists primarily of wetlands , agriculture, and developed areas. The WF3 plant area itself covers 40.1 acres and is zoned as an industrial area by St. Charles Parish. The land in the vicinity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRG considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the ELL property. The length of these transmission lines is approximately 0.6 miles, and there is limited right-of-way since the lines cross the WF3 industrial area where vegetation is sparse.
| |
| Based on review of information available, Entergy has included in Table 1 species identified as being state-listed in St. Charles and St. John the Baptist parishes, of which portions of are included within a 6-mile radius of WF3 (Figure 1). Although suitable habitat does exist on the ELL property for two species as shown in Table 1 (western antler fern, Ceratopteris pteridoides, and square-stemmed monkey flower, Mimulus ringens) based on a pedestrian suNey conducted on October 29, 2014, these species were not obseNed during the suNey. Entergy does not anticipate that the three state-listed species identified only in St. John the Baptist Parish (osprey (Pandion haliaetus) ,
| |
| alligator snapping turtle (Macrochelys temminckit) , and rooted spike rush (Eleocharis radicans) ) would be affected by the renewal of the WF3 operating license since license renewal will not involve any offsite activities. In addition during Entergy's review, no designated critical habitat was identified for the species listed in Table 1 on the ELL property or within the immediate environs (6-mile radius) of WF3.
| |
| However, Entergy does not expect WF3's operations during the license renewal term would result in adverse effects to state-listed species or designated critical habitats even if present since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to comply with applicable state and federal laws to preseNe biological resources when facility expansion or land B-1 2
| |
| | |
| disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to state-listed species or designated critical habitat on the property where WF3 is located, or the immediate environs (6-mile radius) , or alternatively, confirming our conclusion these species and habitats will not be adversely affected as a result of renewing the WF3 operating license for an additional 20 years. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application .
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address, rbuckle@entergy.com.
| |
| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental B-13
| |
| | |
| Table 1 State-Listed Species, St. Charles and St. John the Baptist Parishes Common Name Scientific Name Applicable State Habitat Present Species Present Parish Status on ELL Property on ELL Property Mammals West Indian Manatee Trichechus manatus SC/SJB SNA No No Birds Bald Eagle Ha/iaeetus leucocephalus SC/SJB S2N, S3B No No Osprey Pandion haliaetus SJB S2B ,S3N No Fish Pallid Sturgeon Scaphirhynchus a/bus SC/SJB S1 No No Paddlefish Polyodon spathu/a SC/SJB S3 No No Ree.tiles Alligator Snapping Turtle Macroche/ys temminckii SJB S3 No Plants Swamp Milkweed Asclepias incarnata SC/SJB S2 No No Golden Canna Canna f/accida SC S4? No No Floating Antler Fern Ceratopteris pteridoides SC/SJB S2 Yes No Marshland Flatsedge Cyperus distinctus SC S1 No No Western Umbrella Sedge Fuirena simplex var. aristulata SC S1 Yes No Correll's False Dragon-Head Phvsosteqia carrel/ii SC S1 No No Square-Stemmed Monkey Flower Mimu/us ringens SC S2 Yes No Rooted Spike Rush Eleocharis radicans SJB S1 ? No No SC= St. Charles Parish SJB = St. John the Baptist Parish S1 = critically imperiled in Louisiana because of extreme rarity (5 or fewer known extant populations) or because of some factor(s) making it especially vulnerable to extirpation S2 = imperiled in Louisiana because of rarity (6 to 20 known extant population s) or because of some factor(s) making it very vulnerable to extirpation 83 = rare and local throughout the state or found locally (even abundantly at some of its locations) in a restricted region of the state, or because of other factors making it vulnerable to extirpation (21 to 100 known extant populations)
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| S4 = apparently secure in Louisiana with many occurrences ( 100 to 1000 known extant populations)
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| B-14
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| Figure 1 Location of Entergy Property, 6-Mlle Radius Map
| |
| ..
| |
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| |
| £1 He~pot1
| |
| __ , Surface W.1 1 - - lJ S Route l.. _ 1 6-1*.He RalJiw - - Stale Ruule
| |
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| |
| * I Ru .tds ............im::==::::::::::::==:::=:::JM H 0 1
| |
| [.=._l P.msh --.- Ra11<oad "
| |
| B-15
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| | |
| B OOBY .J 1N DAL R O BE: R T .j BA "'HAM GOVERNO R SECR ETARY DEPARTMENT O F WIL DLI FE AN O Fl S HERIES J t MM Y L. ANTHO N "'
| |
| OFFIC E OF WIL D LIFE A SS IS":"ANT 5£CR E T A R'r Date June 18. 20 15 Name Ri ck Buckley Company Entergy Servi ces, LLC Street Address 1340 Echelon Parkway City, State, Zip Jae ks on. Mississippi 39213 Proj ect Entergy Louisiana, LLC Waterford 3 Steam Electric Station un it 3 Proj ect JD 12020 15 In voice Number 1506 180 1 Personnel of the Coasta l & ongame Resources Division have reviewed the preliminary data for the captioned project.
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| Our records indicat e that the proposed project may potenti ally impact a Bald Eagle (Haliaeetus leucocephalus) nesting site located within the project site . T his species is protected under the Bald and Golden Eagle Protecti on Act ( 16 U.S.C. 668 -
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| 668c) and the Mi gratory Bird Treaty Act (16 U.S.C. 703-7 12) and is protected by the state of Louisiana. All b~ld eagle nests (active, inactive or seemingly abandoned) should be protected. and no large trees should be removed . Please refer to the Bald Eagle Management Guidelines for more infom1ation regarding buffer zones and other info1mation on avoiding impac ts to bald eagles: http ://www.fws.gov/southcasties/baldeagle/.
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| After careful review of our database, no other impacts to rare, threatened, or endangered species or critical habitats are anticipated for the proposed project. No state or fede ral parks, wildlife refuges, scenic streams, or wildlife management areas are knmvn at the specified site within Louisiana's boundaries.
| |
| The Louisiana Na tural Heritage Program (LNHP) has compiled data on rare, endangered, or otherwise significa nt plant and animal species, plant communities, and other natural features throughout the state of Louisiana . Heritage reports summarize the existing information known at the time of the request regarding the location in question. The quantity and quality of data collected by the Lr-..'HP are dependent on the research and observations of many individuals . In most cases, this information is not the result of comprehensive or si te-specific field surveys; many natural areas in Louisiana have not been surveyed. This report docs not address the occurrence of wetl ands at the site in question. Heritage reports should not be considered fu13l statements on the biological elements or areas being considered, nor should they be substituted fo r on-site surveys required for environmental assessments . LNHP requires that this office be acknowledged in all reports as the so urce of all data provided here . If at any time Heritage tracked species are encountered within the project area. please contact the L HP Data Manager at 225-765 -2643 . lf you ha ve any questions, or need additiona l infom1ation, plea se call 22 5-765 -235 7 .
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| Sin~er~
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| ~b:t~-*
| |
| Amity'I3ass, ~ordinator
| |
| ~atura l Heri tage Program B-16
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| ?.O . eox 9BCX:>O
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| * Et.AWN ROUGE. LCLHS IAMA 10898-9000
| |
| * PHO NC <Z2.5) 765*2BOO AN t:OUAL OF'POITTU" fTY E.t*1f"_Q)'ER
| |
| | |
| BUCKLEY, RICKY N From: Kelly Shotts - NOAA Fed eral <kelly.shotts@noaa.gov>
| |
| Sent: Wednesday, June 24, 2015 2:32 PM To: BUCKLEY, RICKY N
| |
| | |
| ==Subject:==
| |
| Re: Waterford 3 Steam Electric Station Unit 3 - Gulf sturgeon EXTERNAL SENDER. DO NOT click links if sender is unknown. DO NOT provide your user ID or password.
| |
| Hi Rick, Thank you for speaking with me earlier today. As we discussed, under the Magnuson-Stevens Fishery Conservation and Management Act, EFH is designated for federally managed fishery species (e.g. , shrimp, reef fish, and red drum). There is no Essential Fish Habitat (EFH) designated for Gulf sturgeon. More information on EFH can be found at the following website:
| |
| http://sero .nmfs. noaa. gov/habitat conservation/efh/index.html Gulf sturgeon is not a fishery species, rather it is listed as threatened under the Endangered Species Act. Critical habitat for Gulf sturgeon has been designated in the Gulf of Mexico, including in Lake Pontchartrain (Unit 8). Gulf sturgeon information and maps of Gulf sturgeon critical habitat can be found at tl following websites:
| |
| Species Information http://www. nmfs.noaa. gov/pr/ species/fish/ gulfsturgeon.htm Critical Habitat Maps and GIS files http://sero.nmfs.noaa.gov/maps gis data/protected resources/critical habitat/index.html Based on the shortest distance between the project location you provided in your letter and the closest area designated as Gulf sturgeon critical habitat, your project appears to be at least 19 miles away from critical habitat. However, please confirm this yourself using the information provided above.
| |
| If you have any other questions, please feel free to contact me.
| |
| Kelly On Wed, Jun 24, 2015 at 9:37 AM, Kelly Shotts - NOAA Federal <kelly.shotts@noaa.gov> wrote:
| |
| Hi Rick, 1
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| B- 17
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| | |
| I just left you a voicemail pertaining to your May 28, 2015, letter regarding the subject project. Please give me a call at your earliest convenience to discuss issues related to Gulf sturgeon and their habitat. My direct line is 727-551 -5603 .
| |
| thanks for coordinating with us!
| |
| Kelly Kelly Shotts Section 7 Coordinator Protected Resources Division NOAA Southeast Regional Office National Marine Fisheries Service 263 13th Ave S St. Petersburg. FL 33701 Ph: 727-824-5312 Fax: 727-824-5309 kelly. shotts@noaa.gov Kelly Shotts
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| ';ection 7 Coordinator
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| >rotected Resources Division NOAA Southeast Regional Office National Marine Fisheries Service 263 13th Ave S St. Petersburg, FL 33701 Ph: 727-824-5312 Fax: 727-824-5309 kelly.shotts@noaa.gov 2
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| B- 18
| |
| | |
| -
| |
| Entergy Services, Inc 1340 Echelon Parkway Jackson, Mississippi 39213 May 28, 2015
| |
| .. j r * ~ r:
| |
| Mr. Brad Rieck Deputy Field Supervisor - 's.
| |
| U.S. Fish and Wildlife Service i 1 i\"""i vf ~1.b ,"'\""**
| |
| Louisiana Field Office 646 Cajundome Blvd., Suite 400 Lafayette, LA 70506
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 Licens~ Renewal Application CEO 2015-00052
| |
| | |
| ==Dear Mr. Rieck,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish, Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application , Entergy will then have the option to continue operating WF3 for an additional 20 years until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application.
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses potential environmental impacts from plant operations during the license renewal term. One of these potential environmental impacts would be the effect of license renewal on Federally-listed threatened, B-19
| |
| | |
| endangered or candidate species and designated critical habitat located on the WF3 property and its immediate environs (Figure 1). Accordingly, the NRG requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51 .53). Later, during its review of the license renewal environmental report pursuant to the National Environmental Policy Act, the NRG may request information from your office to ensure compliance with Section 7 of the Endangered Species Act.
| |
| Entergy is contacting you now in order to obtain input regarding issues that may need to be addressed in the WF3 license renewal environmental report, and to assist in identifying any information your staff believes would be helpful to expedite NRC's review.
| |
| WF3 is located on approximately 3,560 acres of Entergy Louisiana, LLC (ELL) owned property that consists primarily of wetlands, agriculture, and developed areas. The WF3 plant area itself covers 40.1 acres and is zoned as an industrial area by St. Charles Parish. The land in the vicinity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the ELL property. The length of these transmission lines is approximately 0.6 miles, and there is limited right-of-way since the lines cross the WF3 industrial area where vegetation is sparse.
| |
| Based on review of information available, Entergy has included in Table 1 threatened, endangered and candidate species identified as being Federally-listed in St. Charles and St. John the Baptist parishes, of which portions of are included within a 6-mile radius of WF3 (Figure 1). As shown in Table 1, no suitable habitat for these species was identified on the ELL property during a pedestrian survey conducted on October 29, 2014, or was any species observed during the survey. Entergy does not anticipate that the one Federally-listed species identified only in St. John the Baptist Parish (Alabama heelsplitter mussel, LaSfJ1igona alabamensis) would be affected by the renewal of the WF3 operating license since the Mississippi River does not provide suitable habitat for this species. In addition during Entergy's review, no designated critical habitat was identified for the species listed in Table 1 within the immediate environs (6-mile radius) of WF3.
| |
| However, Entergy does not expect that WF3's operations during the license renewal term would result in adverse effects to threatened, endangered or candidate species and designated critical habitats even if present since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to B-20
| |
| | |
| comply with applicable state and federal laws to preserve biological resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to threatened, endangered or candidate species and designated critical habitat on the property where WF3 is located, or the immediate environs, or alternatively, confirming our conclusion that these species and habitats will not be adversely affected as a result of renewing the WF3 operating license for. an additional 20 years. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application.
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address, rbuckle@entergy.com.
| |
| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental B-21
| |
| | |
| Thif' project hJ.s bee n reviewed 'or effer.ts to Federal trust resources una ~ r our jur,s*j 1ciion ancl "*Jr sr 'y ;; otect r d by the t=nd a;1gerad Species Act of 1!F 3 (Acl) . The, ~ :* *:.t as p;oposad,
| |
| ~ ~u .ave
| |
| * o tho... e "Dr ,e<>
| |
| ( ) Is not litr !y 10 ad ' E :;~l*l .**:,.-; th~.::. e *~*~mrc r.:s.
| |
| Thh:; :ini:ing fu i fi l'~; , L ia qu i. & *1~ c;~~~s unr:.:r M:;1*J n 7(ej (2) of the Act.
| |
| -t- ~.,_,,....,,.~
| |
| .\ <. . *: S1:;; <> f';i:c:
| |
| Li:*uisia"** F1 P1 '" "Jifio:;9 U. :. Fish arv:i W1it",f9 Sa:-vice B-22
| |
| | |
| Waterford Steam Electric Station, Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment C Cultural Resources Consultation
| |
| | |
| Attachment C Cultural Resources Consultation
| |
| * Rick Buckley, Entergy Services, Inc., to Phil Boggan, Office of Historic Preservation-Division of Historic Preservation. June 1, 2015.
| |
| * Rick Buckley, Entergy Services, Inc., to Kimberly Walden, Tribal Historic Preservation Officer-Chitimacha Tribe of Louisiana. June 1, 2015.
| |
| * Rick Buckley, Entergy Services, Inc., to Dr. Linda Langley, Tribal Historic Preservation Officer-Coushatta Tribe of Louisiana. June 1, 2015.
| |
| * Rick Buckley, Entergy Services, Inc., to Alina Shively, Deputy Tribal Historic Preservation Officer-Jena Band of Choctaw Indians. June 1, 2015.
| |
| * Rick Buckley, Entergy Services, Inc., to Earl J. Barbry, Jr, Tribal Historic Preservation Officer-Tunica-Biloxi Tribe of Louisiana. June 1, 2015.
| |
| * Jill Crawford, Section 106 Coordinator-Coushatta Tribe of Louisiana, to Rick Buckley, Entergy Service, Inc. June 5, 2015.
| |
| * Pam Breaux, State Historic Preservation Officer, to Rick Buckley, Entergy Services, Inc. June 8, 2015.
| |
| * Alina Shively, Deputy Tribal Historic Preservation Officer-Jena Band of Choctaw Indians, to Rick Buckley, Entergy Services, Inc. July 15, 2015.
| |
| * Phil Boggan, Deputy State Historic Preservation Officer (stamp of receipt/review/acceptance), to Rick Buckley, Entergy Services, Inc. July 15, 2015.
| |
| C-1
| |
| | |
| *
| |
| -=~*Entergy Entergy Services, Inc 1340 Echelon Parkway Jackson, Mississippi 39213 June 1, 2015 Mr. Phil Boggan Office of Historic Preservation Division of Historic Preservation Post Office Box 4424 7 Baton Rouge, LA 70804
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Application CEO 2015-00054
| |
| | |
| ==Dear Mr. Boggan,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy'') plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish, Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application, Entergy will then have the option to continue operating WF3 until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application.
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses the potential environmental impacts from operation during the license renewal term. One of these potential environmental impacts would be the effect of license renewal on archaeological resources located on the WF3 site, its immediate environs (6-mile radius) as shown in Figure 1, and transmission line corridors constructed for purposes of connecting the plant to the regional transmission grid.
| |
| C-2
| |
| | |
| Accordingly, the NRC requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51.53). Later, during its review of the license renewal environmental report pursuant to the National Environmental Policy Act, the NRC may request information from your office to ensure compliance with Section 106 of the National Historic Preservation Act of 1966, as amended (16 USC 470), and Federal Advisory Council on Historic Preservation regulations (36 CFR 800).
| |
| WF3 is located on approximately 3,560 acres of Entergy owned land (Figure 1) that consists primarily of wetlands, agriculture, and developed areas. The WF3 plant area itself covers 40.1 acres and is zoned as an industrial area by St. Charles Parish, with the exception of the property south of LA-3127. The land in the vicinity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the property.
| |
| Although not required, Entergy voluntarily contracted with Coastal Environments, Inc. to conduct a Phase 1A literature review and archaeological sensitivity assessment of the Entergy property in August and September 2014 to supplement WF3's existing administrative controls to ensure that potential resources are properly managed during the license renewal period. This assessment, which is included in Attachment 1, determined that no cultural resources would be impacted as a result of renewal of the WF3 operating license.
| |
| Table 1 lists archaeological resources within a 6-mile radius of WF3 while Table 2 lists National Register of Historic Places (NRHP) properties within this same radius that were identified by Entergy during our view. For the one partially eligible/unknown property in Table 1 that is located on the ELL property (16SC41 ), WF3 has a site-specific cultural resource protection plan that is incorporated by reference in the Environmental Protection Plan to the operating license to protect those areas on the property determined to be eligible for the NRH P, specifically the Waterford Plantation ( 16SC41 ).
| |
| This requirement ensures that cultural resource remains are not damaged and are protected from unauthorized removal, and ensures that in the event that ground disturbance is required in these areas, remains will be appropriately protected for their cultural resource information value.
| |
| However, Entergy does not expect WF3 operations during the license renewal term to adversely affect any historic or archaeological resources since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to comply with applicable state and federal laws to preserve C-3
| |
| | |
| cultural resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to historic or archaeological resources on the property where WF3 is located, or the immediate environs, or alternatively, confirming our conclusion that the operation of WF3 during the license renewal term would have no effect on known historical or archaeological properties. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application.
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address at rbuckle@entergy.com.
| |
| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental C-4
| |
| | |
| Table 1 Archaeological Sites within a 6-Mile Radius of WF3 Site Number Parish Quadrangle NRHP Status 16SC10 St. Charles Laplace Unknown 16SC19 St. Charles Hahn ville Unknown 16SC21 St. Charles Hahn ville Unknown 16SC22 St. Charles Hahnville Unknown 16SC24 St. Charles Hahnville Unknown 16SC31 St. Charles Laplace Partially lneligible/Unknown\ai 16SC39 St. Charles Hahn ville Unknown 16SC41 1u 1 St. Charles Hahn ville Partially Eligible/Unknown\CJ 16SC47 St. Charles Hahnville Unknown 16SC50 St. Charles Laplace Listed 16SC51 St. Charles Laplace Listed 16SC52 St. Charles Laplace Ineligible 16SC53 St. Charles Laplace Ineligible 16SC54 St. Charles Laplace Ineligible 16SC55 St. Charles Hahn ville Ineligible 16SC56 St. Charles Hahnville Unknown 16SC57 St. Charles Hahn ville Unknown 16SC58 St. Charles Hahnville Unknown 16SC59 St. Charles Hahnville Unknown 16SC65 St. Charles Hahnville Ineligible 16SC71 St. Charles Hahn ville Unknown 16SC72 St. Charles Hahn ville Partially lneligible/Unknown 13' 16SC79 St. Charles Laplace Ineligible 16SC80 St. Charles Laplace Eligible 16SC85 St. Charles Laplace Ineligible 16SC86 St. Charles Hahn ville Unknown 16SC88 St. Charles Laplace Unknown 16SJB6 St. John the Baptist Reserve Unknown 16SJB8 St. John the Baptist Reserve Unknown 16SJB10 St. John the Baptist Reserve Unknown 16SJB12 St. John the Baptist Reserve Unknown 16SJB22 St. John the Baptist Reserve Unknown 16SJB24 St. John the Baptist Laplace Unknown 16SJB25 St. John the Baptist Laplace Unknown 16SJB27 St. John the Baptist Reserve Unknown 16SJB67 St. John the Baptist Laplace Unknown
| |
| : a. Only a portion of the site is determined not eligible for inclusion on the NRHP; the eligibility of the rest of the site is unknown.
| |
| : b. Located on WF3 property.
| |
| : c. Only a portion of the site is determined eligible for inclusion on the NRHP; the eligibility of the rest of the site is unknown.
| |
| C-5
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| | |
| Table 2 NRHP-Listed Properties within a 6-Mile Radius of WF3 Parish Resource Name Quadrangle NRHP Distance from Listed WF3(al St. Charles Dorvin House, Mollere House, Rosedon Hahn ville 1990 3.1 mi
| |
| -*
| |
| St. Charles Homeplace Plantation House, Keller Homestead Hahnville 1970 4.1 mi St. Charles Kenner and Kugler Cemeteries Archaeological District Laplace 1987 2.0 mi(O)
| |
| (16SC50 and 16SC51)
| |
| St. Charles Ormond Plantation House Hahnville 1990 5.8 mi St . John the Baptist Haydel-Jones House Reserve 2010 6.0m i St. John the Baptist Montegut Plantation House Laplace 1988 4.4 mi St. John the Baptist Sorapuru House Reserve/Laplace 1999 3.9mi
| |
| : a. Distances are approximate and based on the WF3 reactor center point and NRHP location data.
| |
| : b. The NRHP lists Kenner and Kugler Cemeteries as "address restricted. " The distance given was created using GIS to compare the two cemetery locations and background landmarks depicted in the February 8, 2012, USACE Bonnet Carre Public Meeting - Long Term Management Report to a USGS topographic map. An approximate equidistant point was placed between the two locations to estimate distance.
| |
| C-6
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| | |
| Figure 1 Location of Entergy Property, 6-Mile Radius
| |
| \ . \
| |
| \ :-"
| |
| . .
| |
| ~:-
| |
| :* ;....
| |
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| |
| * Jo hn the Baptist 7,
| |
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| |
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| |
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| |
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| |
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| |
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| |
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| I Legend .
| |
| =
| |
| ea Alrpc.11 Heilport
| |
| -
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| F>rope"'J Souodary lnterslatfl
| |
| <>-*
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| -- Stirl Ct! W.iler -
| |
| l.. _ ..1 6* h~ Radius -
| |
| U S Route Slaw 01Jta
| |
| *~ : :.* J Ccm.us Pia~ LOCill Ro3ds 0
| |
| ................-===============~4 ~ tlc-.
| |
| L__j P.-11 --+- ~dfO.'.ld C-7
| |
| | |
| Attachment 1 Phase 1 A Literature Review and Archaeological Sensitivity Assessment of the Waterford Steam Electric Station Unit 3 The attachment noted here that was sent to the Louisiana Historic Preservation Office is not enclosed because it contains sensitive information .
| |
| C-8
| |
| | |
| *
| |
| *~Entergy Entergy Services, Inc 1340 Echelon Pari<way Jackson, Mississippi 39213 June 1, 2015 Ms. Kimberly Walden Tribal Historic Preservation Officer Chitimacha Tribe of Louisiana Post Office Box 661 Charenton, LA 70523
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Application CEO 2015-00055
| |
| | |
| ==Dear Ms. Walden ,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish , Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge , Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application, Entergy will then have the option to continue operating WF3 until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application.
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses the potential environmental impacts from operation during the license renewal term. One of these potential environmental impacts would be the effect of license renewal on archaeological resources located on the WF3 site, its immediate environs (6-mile radius) as shown in Figure 1, and transmission line corridors constructed for purposes of connecting the plant to the regional transmission grid.
| |
| C-9
| |
| | |
| Accordingly, the NRC requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51 .53). Later, during its review of the license renewal environmental report pursuant to the National Environmental Policy Act, the NRC may request information from your office to ensure compliance with Section 106 of the National Historic Preservation Act of 1966, as amended ( 16 USC 470) , and Federal Advisory Council on Historic Preservation regulations (36 CFR 800).
| |
| WF3 is located on approximately 3,560 acres of Entergy owned land (Figure 1) that consists primarily of wetlands, agriculture , and developed areas. The WF3 plant area itself covers 40.1 acres and is zoned as an industrial area by St. Charles Parish, with the exception of the property south of LA-3127. The land in the vicinity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the Entergy property.
| |
| Entergy does not expect WF3 operations during the license renewal term to adversely affect any historic or archaeological resources since there are no plans to alter current operations during the 20-year license renewal period , and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to comply with applicable state and federal laws to preserve cultural resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to historic or archaeological resources on the property where WF3 is located, or the immediate environs, or alternatively, confirming our conclusion that the operation of WF3 during the license renewal term would have no effect on known historical or archaeological properties. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application.
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address at rbuckle @entergy.com.
| |
| Rick Buckley, CHMM , REM Sr. Project Manager, Environmental C-10
| |
| | |
| Figure 1 Location of Entergy Property, 6-Mile Radius Map Legend
| |
| .
| |
| Cl Alrpmt - Pro r e1ty Bounda'Y *<>-*
| |
| !I He4po rl - lnt,...fs *atl*
| |
| __ ,
| |
| l.. _ 1 6-Mil" Rad-us *- - Stato Ro.i re
| |
| :: ~ ~ _-] Cert~u11 Place L1>*, al Rr>ads L._J Pani;h - .- - ~ailr\l<ld C-11
| |
| | |
| *
| |
| *~Entergy Entergy Services, Inc 1340 Echelon Parkway Jackson, Mississippi 3921 3 June 1, 2015 Dr. Linda Langley Tribal Historic Preservation Officer Coushatta Tribe of Louisiana Post Office Box 10 Elton , LA 70532
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Application CEO 2015-00056
| |
| | |
| ==Dear Dr. Langley,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish , Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge , Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application , Entergy will then have the option to continue operating WF3 until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application .
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses the potential environmental impacts from operation during the license renewal term. One of these potential environmental impacts would be the effect of license renewal on archaeological resources located on the WF3 site , its immediate environs (6-mile radius) as shown in Figure 1, and transmission line corridors constructed for purposes of connecting the plant to the regional transmission grid.
| |
| C-12
| |
| | |
| Accordingly, the NRC requ ires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51 .53). Later, during its review of the license renewal environmental report pu rsuant to the National Environmental Policy Act, the NRC may request information from your office to ensure compliance with Section 106 of the National Historic Preservation Act of 1966, as amended (16 USC 470) , and Federal Advisory Council on Historic Preservation regulations (36 CFR 800) .
| |
| WF3 is located on approximately 3,560 acres of Entergy owned land (Figure 1) that consists primarily of wetlands, agriculture , and developed areas. The WF3 plant area itself covers 40 .1 acres and is zoned as an industrial area by St. Charles Parish , with the exception of the property south of LA-3127. The land in the vicinity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the Entergy property.
| |
| Entergy does not expect WF3 operations during the license renewal term to adversely affect any historic or archaeological resources since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to comply with applicable state and federal laws to preserve cultural resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to historic or archaeological resources on the property where WF3 is located, or the immediate environs , or alternatively, confirming our conclusion that the operation of WF3 during the license renewal term would have no effect on known historical or archaeological properties. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application.
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address at rbuckle @entergy.com.
| |
| Rick Buckley, CHMM , REM Sr. Project Manager, Environmental C-13
| |
| | |
| Figure 1 Location of Entergy Property, 6-Mile Radius Map St . Ch a rl4":S
| |
| /
| |
| *.. .. **
| |
| l 11r n c\ ' llf1m111nd.*
| |
| Legend a A.iroort - Pro pe rty 9 .ivnr.!a l')I
| |
| £1 He~rx>rt - lnl er s131~
| |
| Snrf;oe*:" 'Na le r **~-US Route
| |
| -- .
| |
| \.. - ' 6-Mile R" OllJS . - State Root.i
| |
| :* .. _ *: ~ flsus Pl:!ce
| |
| ........ .
| |
| ,--- 4
| |
| ~ -------ic::=======>Mdt1s 0 2 4 L _J Pans11 ~- Ra1lroa .J C-14
| |
| | |
| *
| |
| *~Entergy Entergy Serv ices, Inc 1340 Echelon Parkway Jackson, Mississippi 39213 June 1, 2015 Ms. Alina Shively Deputy Tribal Historic Preservation Officer Jena Band of Choctaw Indians Post Office Box 14 Jena, LA 71342
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Appl ication CEO 2015-00057
| |
| | |
| ==Dear Ms. Shively,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3) , which is located in St. Charles Parish , Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application , Entergy will then have the option to continue operating WF3 until 2044 . In conjunction with this effort, Entergy is gathering information relative to th is license renewal project to assist with the preparation of the application .
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses the potential environmental impacts from operation during the license renewal term. One of these potential environmental impacts would be the effect of license renewal on archaeological resources located on the WF3 site, its immediate environs (6-mile radius) as shown in Figure 1, and transmission line corridors constructed for purposes of connecting the plant to the regional transmission grid.
| |
| C- 15
| |
| | |
| Accordingly, the NRC requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51 .53) . Later, during its review of the license renewal environmental report pursuant to the National Environmental Pol icy Act, the NRC may request information from your office to ensure compliance with Section 106 of the National Historic Preservation Act of 1966, as amended ( 16 USC 470), and Federal Advisory Council on Historic Preservation regulations (36 CFR 800).
| |
| WF3 is located on approximately 3,560 acres of Entergy owned land (Figure 1) that consists primarily of wetlands, agriculture , and developed areas. The WF3 plant area itself covers 40.1 acres and is zoned as an industrial area by St. Charles Parish , with the exception of the property south of LA-3127. The land in the vicinity of the WF3 site is mostly wetlands . Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the Entergy property.
| |
| Entergy does not expect WF3 operations during the license renewal term to adversely affect any historic or archaeological resources since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site . Although administrative procedural controls are in place to comply with applicable state and federal laws to preserve cultural resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to historic or archaeological resources on the property where WF3 is located, or the immediate environs, or alternatively, confirming our conclusion that the operation of WF3 during the license renewal term would have no effect on known historical or archaeological properties. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application.
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address at rbuckle @entergy.com .
| |
| ~~
| |
| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental C-16
| |
| | |
| Figure 1 Location of Entergy Property, 6-M ile Radius Map J,f/4*' Prm1d,.1nrui n St. Childes Legend '
| |
| E:I Airpon *-<?*
| |
| iJ Hefipo r*t - .rtc rs:are
| |
| --*
| |
| L_
| |
| *-- --~ ~]
| |
| Sui fa ce Wdler *- - - U S Roule 1 6- M ile R3~1us -- -
| |
| Crmilus Place Slat'!! ~ ou tt:
| |
| \.01;a1 Ro<<ds --------========:::i M~es 0 2 4 C_J P;in:;h R:1111o;io C-17
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| | |
| *
| |
| ~Entergy Entergy Services, Inc 1340 Echelon Parkway Jackson. Mississippi 3921 3 June 1, 2015 Mr. Earl J . Barbry, Jr Tribal Historic Preservation Officer Tunica-Biloxi Tribe of Louisiana Post Office Box 1589 Marksville, LA 71351
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Application CEO 2015-00058
| |
| | |
| ==Dear Mr. Barbry,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3) , which is located in St. Charles Parish, Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application , Entergy will then have the option to continue operating WF3 until 2044 . In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application.
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses the potential environmental impacts from operation during the license renewal term. One of these potential environmental impacts would be the effect of license renewal on archaeological resources located on the WF3 site , its immediate environs (6-mile radius) as shown in Figure 1, and transmission line corridors constructed for purposes of connecting the plant to the regional transmission grid.
| |
| C-18
| |
| | |
| Accordingly, the NRC requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51.53). Later, during its review of the license renewal environmental report pursuant to the National Environmental Policy Act, the NRC may request information from your office to ensure compliance with Section 106 of the National Historic PreseNation Act of 1966, as amended (16 USC 470), and Federal Advisory Council on Historic PreseNation regulations (36 CFR 800).
| |
| WF3 is located on approximately 3,560 acres of Entergy owned land (Figure 1) that consists primarily of wetlands , agriculture , and developed areas. The WF3 plant area itself covers 40 .1 acres and is zoned as an industrial area by St. Charles Parish, with the exception of the property south of LA-3127. The land in the vicin ity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the Entergy property.
| |
| Entergy does not expect WF3 operations during the license renewal term to adversely affect any historic or archaeological resources since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to comply with applicable state and federal laws to preseNe cultural resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to historic or archaeological resources on the property where WF3 is located, or the immediate environs, or alternatively, confirming our conclusion that the operation of WF3 during the license renewal term would have no effect on known historical or archaeological properties. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application .
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address at rbuckle @entergy.com .
| |
| Rick Buckley, CHMM , REM Sr. Project Manager, Environmental C-19
| |
| | |
| Figure 1 Location of Entergy Property, &-Mlle Radius Map
| |
| ,
| |
| /
| |
| I r.k .: f'orrtch.,nrll.in Leg&nd 1:1 Arrpon - Pro perty 5 oundary
| |
| --<>-*
| |
| £1 Heliport - tnl*irs! ate
| |
| -_, Surfeca Watur l.-, 6-Mi\c; R.Jdius
| |
| _s Route Slate ROLie
| |
| ;: ~:: J Ct!nsu s Pldce 1- - -1 L __J P~rr.;n
| |
| - Louil Roads
| |
| -----+-- R1111toad
| |
| --------===:::::==:=:::i" 0 2 Mlk?~
| |
| C-20
| |
| | |
| COUSHATTA TRIBE . . .
| |
| OF LOUISIANA H E RITAGE D E PARTMENT Junes. 2015 Rick Buckley Entergy Service, !nc 134-0 Echelon Park.way Jackson Miss issippi 39213 Subj ect; Waterford 3 Steam Electric Station Unit 3, License Renewal Applkation Dear Mr. Buckley The Coushatta Tribe of Louisiana Heritage Department has reviewed the above reforence p roposed undertaking, and we are in concurrence with your .findings of "no historica l properties afft.-<:ted''.
| |
| At this time, l know of no know11 sacred or ceremonial sites in the immed iate area, and do not require further Sec-tion 106 consultation on this proj~t. However, if any cultl!ra1 resources sueh as, bone, pottery, stone tools, etc ,
| |
| are fu und s11bseqmmtly, we may elect to discuss addrtional mitigation steps, including on-siie monitoring. In die event that ardiacvlogical prnpertks or human remains are di &cover~ , please stop work and cotrmcr us Immediate-ly, consiste-nt with Section fX of the Nationwide Programmatk .>\greem<:-nt and applica ble laws.
| |
| Sincere!y, Jil l Crawford.
| |
| S~tion 106 Coordinator KOWASSAAT ON NATHIHILKAS-LET US SPEAK KOASATl 3 37-584- 1 560 337~584- 1 616 (FAX) PO Box 10 E:LTON , LA 70532 C-21
| |
| | |
| C HAR LES R. D AVI S JAY D ARDENNE
| |
| :§tat .e of i!rnui.s iana DEPUTY S ECRETARY LIEUTENANT GOVERNOR OFF I CE OF THE L I EUTEN A NT GOVE R N O R P AM BRE AU X DEPA RT M ENT OF CU L T U RE , RECRE A T IO N & TOU RI S M AS S I S TA NT S ECRETARY OFF I CE O F C U L T UR A L DE V ELOP M E N T 8 June 20 15 Rick Buckley Sr. Project Manager Entergy Services. lnc .
| |
| 1340 Echelon Parkway Jackson, MS 39213 Re : Draft Report La Divisio n of Archaeology Report No. 22-4955 Phase 1A Literarure Re1*iew and Archaeological Sensiti1*i1y Assessmem of the fVare1.ford Steam Electric Station Unit 3, Kil!ona. St. Charles Parish, Louisiana
| |
| | |
| ==Dear Mr. Buckley:==
| |
| | |
| We acknowledge receipt of your letter dated l June 2015 and one copy of the above referenced rep ort.
| |
| We have comple ted our review o f this report and have no comments to offer.
| |
| The above-referenced report provides a thorough and sufficient evaluation of the known and potential cultural resources on the Waterford 3 property. As noted in the repon and attached to it, the fac ility has an existing Cu ltural Resources Protection Plan with our office and we believe this plan will be appropriate in the future. We concur that the operation of Waterford 3 during the license renewal tem1 will have no effect on known historic properties.
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| We look forward to receiving two bound copies of the final report a long with a pdf of the report. ff you have any questio ns, please contact Chip McGimsey in the Division of Archaeology by email at cmcgimsev@crt. la.gov or by phone at 225-219-45 98.
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| Sincerely,
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| /)
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| ~1!!)
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| Pam Breaux State Historic Preservation Officer PB: cnn C-22 P.O. eox 44247
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| * S A.T O N ROUGE , LOU I SIANA 70804 * <1247. PHONE ( 225} 3..:12 - 820 0 .. F A X ( 225 ) 219*9772. WWW . CRT . STATE . LA . US AN EQUAL 0 PPOR1"U NrTY EM PL.OYER
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| BUCKLEY, RICKY N From: Alina Shively <ashively@jenachoctaw.org >
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| Sent: Wednesday, July 15, 2015 11:32 AM To: BUCKLEY, RICKY N
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| | |
| ==Subject:==
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| RE: Waterford 3 Steam Station Unit 3, License Renewal; CEO 2015 -00057
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| ==Dear Sir:==
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| After researching the site files, it seems this location is on top of a prehistoric site that is considered ineligible. Several artifacts were found at the site, per the state' s documentation and record ; however, we hereby offer the determination of No Adverse Effect. Should any inadvertent discoveries of cultural resources occur, please contact our office immediately. Thank you .
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| Sincerely, Alina J. Shively Jena Band of Choctaw Indians Deputy Tribal Historic Preservation Officer P.O. Box 14 Jena, LA 71342 (318) 992-1205 ashively@jenachoctaw.org From: BUCKLEY, RICKY N [mailto :RBUCKLE@entergy.com ]
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| Sent: Tuesday, July 14, 2015 4 :39 PM To: Alina Shively <ashively@jenachoctaw.org>
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| | |
| ==Subject:==
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| RE: Waterford 3 Steam Station Unit 3, License Renewal; CEO 2015-00057 Alina ,
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| The coordinates for Waterford 3 are "latitude 30 degrees , 45 minutes, 26 seconds north; longitude 91 degrees , 19 minutes, 54 seconds west.
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| The conversion to decimal degrees is 30 .757222 and -91 . 331666 . The site will fall in the correct location when you run it in google earth .
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| Please let me know if this satisfies your requests or if you need additional information.
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| : Thanks, 1
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| C-23
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| Rick Buckley, CHMM, REM Sr. Project Manager S::ntergy Nuclear Jost Office Box 31995 Jackson, MS 39286-1995 601-368-5823 (Office) 601-927-5132 (Cellular) 601-368-5812 (Fax) rbuckle@entergy.com This e-mail and any attachments thereto are intended only for the use by the addressee(s) named herein and contain proprietary and confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, or copying of this e-mail and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify me by telephone and permanently delete the original and any copy of any e-mail and any printout thereof.
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| From: Alina Shively [mailto :ashively@jenachoctaw.org]
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| Sent: Tuesday, July 14, 2015 3:25 PM To: BUCKLEY, RICKY N
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| ;ubject: Waterford 3 Steam Station Unit 3, License Renewal; CEO 2015-00057 EXTERNAL SENDER. DO NOT click links if sender is unknown. DO NOT provide your user ID or password.
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| | |
| ==Dear Sir:==
| |
| | |
| Regarding the above-mentioned project, the Jena Band of Choctaw Ind ians' requests GPS coordinates, so that we may check the stat e site files . We request t his information in order to properly comment.
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| Sincerely, Alina J. Shively Jena Band of Choctaw Indians Deputy Tribal Historic Preservation Officer P.O. Box 14 Jena, LA 71342
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| {318) 992-1205 ashive ly@ jen achoctaw.org 2
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| C-24
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| | |
| *
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| ~*Entergy Entergy Services, Inc 1340 Echelon Pa ri<way Jackson. Mississippi 39213 Ms. Pam Breaux Office of Historic PreseNation Division of Historic PreseNation Post Office Box 4424 7 Baton Rouge , LA 70804
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| | |
| ==SUBJECT:==
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| La Division of Archaeology Report No. 22-4955 Phase IA Literature Review and Archaeological Sensitivity Assessment of the Waterford Steam Electric Station Unit 3, Ki/Iona, St. Charles Parish, Louisiana
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| | |
| ==Dear Ms. Breaux,==
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| | |
| As requested in June 8, 2015 letter, enclosed are two bound copies of the final Phase IA Literature Review and Archaeological Sensitivity Assessment of the Waterford Steam Electric Station Unit 3 report along with a pdf copy of the report.
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| If you have any questions, please contact me at (601) 368-5823 or through my email address at rbuckle @entergy.com .
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| j T he l'i nal iZ:; lrt h:t$ bt*c n reviewed JaJ n.ccq.JLCO.
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| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental 1...1 -t. r-: ~
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| :: .:. i \
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| . *, I I !* ~ ,. ....
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| C-25
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| Waterford Steam Electric Station, Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment D Severe Accident Mitigation Alternatives Analysis
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment D Severe Accident Mitigation Alternatives Analysis Attachment D contains the following sections:
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| D.1 - Evaluation of Probabilistic Risk Analysis Model D.2 - Evaluation of WF3 SAMA Candidates
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| ',
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| '
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| Page D-1
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table of Contents D.1 Evaluation of Probabilistic Safety Analysis Model ...................................................... 8 D.1.1 PSA Model- Level 1 Analysis ............................................................................. 8 D.1.2 PSA Model - Level 2 Analysis ...........................................................................26 D.1.2.1 Containment Performance Analysis ................................................................... 26 D.1.2.2 Radionuclide Analysis ....................................................................................... 51 D.1.3 External Events and Internal Flooding ............................................................... 61 D.1.3.1 Seismic Analysis ................................................................................................ 61 D.1.3.2 Fire Analysis ...................................................................................................... 62 D.1.3.3 Other External Hazards ..................................................................................... 63 D.1.3.4 Internal Flooding ................................................................................................ 63 D.1.4 PSA Model Revisions and Peer Review Summary ............................................ 64 D.1.4.1 Major Differences Between the 2000 (R2) PSA Model and the IPE Model. ........ 64 D.1.4.2 Major Differences Between the 2003 (R3) PSA Model and the 2002 (R2) PSA Model. ............................. :.................................................................................. 64 D.1.4.3 Major Differences Between the 2009 R4C1 (R4) PSA Model and the 2003 WSES-3 PSA (R3) PSA model .......................................................................... 65 D.1.4.4 Major Differences Between the 2015 (R5) PSA Model and the 2009 (R4) PSA Model. ................................................................................................................65 D.1.4.5 PSA Model Peer Review .................................................................................... 66 D.1.5 The WinMACCS Model-Level 3 Analysis ......................................................... 68 D.1.5.1 Introduction ........................................................................................................68 D.1.5.2 Input ..................................................................................................................68 D.1.5.3 Results .............................................................................................................. 74 D.1.6 References********'*********************************************************************************************** 77 D.2 Evaluation of WF3 SAMA Candidates ......................................................................... 81 D.2.1 SAMA List Compilation ...................................................................................... 81 D.2.2 Qualitative Screening of SAMA Candidates (Phase 1) ........................................ 82 D.2.3 Final Screening and Cost Benefit Evaluation of SAMA Candidates (Phase 11) ... 82 D.2.4 Sensitivity Analyses ........................................................................................... 93 D.2.5 References ........................................................................................................ 94 Page D-2
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage List of Tables D.1-1 WF3 Model CDF Results by Major Initiators ................................................................. 9 D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF) .. 12 D.1-3 Containment Event Tree Tops .................................................................................... 27 D.1-4 Correlation of Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Large Early Release Frequency ...........................................................................................43 D.1-5 Correlation of Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Level 2 Release Frequency ....................................................................................................48 D.1-6 Release Timing Classification ..................................................................................... 53 D.1-7 WF3 Release Categories ............................................................................................ 53 D.1-8 WF3 Release Categories ............................................................................................ 54 D.1-9 Summary of Containment Event Tree Quantification .................................................. 57 D.1-10 WF3 Release Category Source Terms ....................................................................... 59 D.1-11 Estimated WF3 Core Inventory (Becquerels) .............................................................. 73 D.1-12 Base Case Mean PDR and OECR Values for Postulated Internal Events ................... 75 D.1-13 Summary of Offsite Consequence Results for Sensitivity Cases ................................ 76 D.2-1 Phase I SAMAs Related to IPE and IPEEE Insights ................................................... 95 D.2-2. Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation ...... 100 D.2-3 Sensitivity Analysis Results ...................................................................................... 121
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| \
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| Page D-3
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage List of Acronyms Acronym Definition ABWR Advanced Boiling Water Reactor AC Alternating Current ACCW Auxiliary Component Cooling Water ADV Atmospheric Dump Valve AFW Auxiliary Feedwater AM SAC A lWS Mitigating System Actuation Circuit AOV Air-Operated Valve ASME American Society of Mechanical Engineers AlWS Anticipated Transient Without Scram BWR Boiling Water Reactor CCF Common Cause Failure ccw Component Cooling Water CDF Core Damage Frequency CET Containment Event Tree CFC Containment Fan Coolers CHR Containment Heat Removal COE Cost of Enhancement cs Containment Spray CSP Condensate Storage Pool css Containment Spray System CST Condensate Storage Tank DC Direct Current OCH Direct Containment Heating DG Diesel Generator DWST Demineralized Water Storage Tank ECCS Emergency Core Cooling System EOG Emergency Diesel Generator EFW Emergency Feedwater EOOS Equipment Out of Service EOP Emergency Operating Procedure EPRI Electrical Power Research Institute EPU Extended Power Uprate EPZ Emergency Planning Zone ERFBS Electric Raceway Fire Barrier System ESF Engineered Safety Features ES FAS Engineered Safety Features Actuation System ETE Evacuation Time Estimates FIVE Fire Induced Vulnerability Evaluation FP Fission Product FPS Fire Protection System FW Feedwater FWCS Feedwater Control System HEAF High Energy Arcing Fault HPCI High Pressure Coolant Injection HPSI High Pressure Safety Injection HVAC Heating Ventilation and Air Conditioning Page D-4
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Acronym Definition IA Instrument Air ILRT Integrated Leak Rate Test IPE Individual Plant Examination IPEEE Individual Plant Examination of External Events ISLOCA Interfacing Systems Loss of Coolant Accident L1 Level 1 L2 Level2 LAR License Amendment Request LERF Large Early Release Frequency LOCA Loss of Coolant Accident LOOP or Loss of Off-site Power LOSP LPSI Low Pressure Safety Injection MAAP Modular Accident Analysis Program MACCS2 Melear Accident Consequences Code System 2 MCCI Molten Cerium-Concrete Interaction MCR Main Control Room MDAFW Motor-Driven Auxiliary Feedwater MOV Motor-Operated Valve MSIV Main Steam Isolation Valve MSL Mean Sea Level MSLB Main Steam Line Break MSSV Main Steam Safety Valve NPSH Net Positive Suction Head NRC Nuclear Regulatory Commission OECR Off-site Economic Cost Risk OSP Off-site Power PDR Population Dose Risk PDS Plant Damage State PORV Pressure-Operated Relief Valve PRA Probabilistic Risk Assessment PSA Probabilistic Safety Assessment PWR Pressurized Water Reactor RAS Recirculation Actuation System RCIC Reactor Core Isolation Cooling RCP Reactor Coolant Pump RCS Reactor Coolant System RHR Residual Heat Removal RPS Reactor Protection System RPV Reactor Pressure Vessel RRW Risk Reduction Worth RWSP Refueling Water Storage Pool RWST Refueling Water Storage Tank SAMA Severe Accident Mitigation Alternative SAM DA Severe Accident Mitigation Design Alternative SAMG Severe Accident Management Guideline SBO Station Blackout scv Steel Containment Vessel soc Shutdown Cooling Page D-5
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Acronym Definition SER Safety Evaluation Report SG Steam Generator SGTR Steam Generator Tube Rupture SI Safety Injection SIS Safety Injection System SMA Seismic Margin Assessment SPDS Safety Parameter Display System SQUG Seismic Qualification Utility Group SRV Safety Relief Valve SSC Systems, Structures, and Components SSEL Safe Shutdown Equipment List SUPS Static Uninterruptible Power Supply SW Service Water TDAFP Turbine-Driven Auxiliary Feedwater Pump TDEFW Turbine-Drive Emergency Feedwater UHS Ultimate Heat Sink VB Vessel Breach WCT Wet Cooling Tower WF3 Waterford Steam Electric Station Unit 3 Windows Melcer Accident Consequences Code WinMACCS System
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| )
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| Page D-6
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment D.1 Evaluation of Probabilistic Safety Analysis Model Page D-7
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1 EVALUATION OF PROBABILISTIC SAFETY ANALYSIS MODEL The severe accident risk was estimated using the Probabilistic Safety Analysis (PSA) model and a Level 3 model developed using the most recent version (version 3.10.0) of the Windows Melear Accident Consequences Code System (WinMACCS code). The CAFTA code was used to develop the Waterford 3 (WF3) PSA Level 1 and Level 2 models. This section provides descriptions of the WF3 PSA levels 1, 2, and 3 analyses, Core Damage Frequency (CDF) uncertainty, Individual Plant Examination of External Events (IPEEE) and NFPA 805 analyses, and PSA model peer review.
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| D.1.1 PSA Model - Level 1 Analysis The SAMA analysis was performed using the most recent WF3 internal events risk models (Level 1 and Level 2). The Level 1 model is documented in PSA-WF3-01-QU [D.1-1] and the Level 2 model is documented in PSA-WF3-01-L2-01 [D.1-2]. The WF3 model adopts the small event tree
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| /large fault tree approach and uses the CAFTA code for quantifying risk.
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| The PSA model has had four major revisions since the IPE due to the following:
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| Modeling changes - The PSA model. was updated with the latest information Power Uprate- Several different analyses were conducted to reflect the Extended Power Update (EPU) plant.
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| Modeling Updates - The PSA model was refined to incorporate the latest state of knowledge and recommendations from internal and industry peer reviews.
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| The internal events PRA model contains the major initiators leading to core damage with baseline CDFs listed in Table D.1-1.
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| The WF3 Level 1 Model was reviewed to identify those potential risk contributors that made a significant contribution to CDF. GDF-based Risk Reduction Worth (RRW) rankings were reviewed down to 1.005. Events below this point would influence the CDF by less than 0.5% and are judged to be highly unlikely contributors for the identification of cost-beneficial enhancements. These basic events; including component failures, operator actions, and initiating events, were reviewed to determine if additional SAMA actions may need to be considered.
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| Table D.1-2 provides a correlation between the Level 1 RRW risk significant events (component failures, operator actions, and initiating events) down to 1.005 identified from the WF3 PSA model and the SAMAs evaluated in Section D.2.
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| Page D-8
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-1 WF3 Model CDF Results by Major Initiators Initiating Event Group Total IE Group Probability %CDF LARGE LOCA 4.87E-09 0.05%
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| AOV Sl-405A DISK RUPTURE WHILE 2.22E-10 0.00%
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| INDICATING CLOSED (YEAR)
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| AOV Sl-4058 DISK RUPTURE WHILE 2.22E-10 0.00%
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| INDICATING CLOSED (YEAR)
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| SI CHECK VALVE 335A RUPTURE 1.59E-11 0.00%
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| (PER YEAR)
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| SI CHECK VALVE 3368 RUPTURE 1.59E-11 0.00%
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| (PER YEAR)
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| SI CHECK VALVE 336A RUPTURE 1.59E-11 0.00%
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| (PER YEAR)
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| SI CHECK VALVE 3368 RUPTURE 1.59E-11 0.00%
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| (PER YEAR)
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| CCF OF 2 FWIVs FAIL TO REMAIN 3.39E-09 0.03%
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| OPEN INADVERTENT OPEN RELIEF VALVE 4.80E-07 4.58%
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| Medium LOCA 3.75E-08 0.36%
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| SI MOV 401A RUPTURES (PER YEAR) 2.22E-10 0.00%
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| SI MOV 4018 RUPTURES (PER YEAR) 2.22E-10 0.00%
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| Steam Generator Tube Rupture 1.03E-07 0.98%
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| RCP SEAL LOCA 9.31 E-08 0.89%
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| Small LOCA 9.49E-07 9.04%
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| Reactor Trip (General Transient) 1.18E-07 1.13%
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| Loss of Condenser Heat Sink 2.51 E-08 0.24%
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| Turbine Trip (General Transient) 1.95E-07 1.86%
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| Page D-9
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Initiating Event Group Total IE Group Probability %CDF Loss of Main Feedwater 9.86E-08 0.94%
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| Loss of Offsite Power 4.42E-06 42.14%
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| Steam Line Break I Leak Inside 4.05E-10 0.00%
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| Containment Steam Line Break Outside Containment 3.57E-08 0.34%
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| or Inadvertent Closure of MSIVs Feedwater Line Break I Leak 5.63E-08 0.54%
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| Loss of Condensate System 6.30E-08 0.60%
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| Loss of CCW System 4.97E-08 0.47%
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| CCW Loss to RCPs Only Initiator 6.30E-09 0.06%
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| Loss Of 6.9KV Bus A 3.45E-09 0.03%
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| Loss Of 6.9KV Bus B 4.18E-09 0.04%
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| LOSS OF 4.16KV BUS 3A3-S 8.79E-07 8.38%
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| LOSS OF 4.16KV BUS 3B3-S 2.53E-06 24.13%
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| LOSS OF 480V BUS 3A31-S 2.75E-08 0.26%
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| LOSS OF 480V BUS 3B31-S 2.86E-08 0.27%
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| LOSS OF 480 V BUS 3AB31-S 7.87E-08 0.75%
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| LOSS OF 480V MCC 3AB311-S 1.44E-09 0.01%
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| Loss of DC Bus A IE 6.94E-08 0.66%
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| Loss of DC Bus B IE 8.17E-08 0.78%
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| Loss of DC Bus AB IE 3.08E-10 0.00%
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| Page D-10
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Initiating Event Group Total IE Group Probability %CDF Loss Of PDP 3014-AB IE 3.02E-10 0.00%
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| Loss of DC Bus TGB IE 6.18E-11 0.00%
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| Loss of Instrument Air System 1.16E-08 0.11%
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| Loss of Turbine Cooling Water System 1.78E-09 0.02%
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| Reactor Vessel Rupture Initiator 3.20E-08 0.30%
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| Total CDF 1.05E-05 100.0%
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| Total ATWS 1 == 1.45E-07 1.38%
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| Total SB0 1 == 3.61 E-06 34.37%
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| Note 1: SBO and A TWS may occur following multiple initiators, thus their contributions to GDF are listed separately.
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| Page D-11
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| Waterford Steam Electric Station unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
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| Event Name I Probability I RRW l Event Description I Disposition I
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| #RX 1.00E+OO 1.0087 RX Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| #SBO 1.00E+OO 11.5237 SBO Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| #SU 1.00E+OO 1.0287 SU Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| #SX 1.00E+OO 11.1318 SX Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| #TB 1.00E+OO 1.49 TB Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| #TK 1.00E+OO 1.014 ATWS Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| #TQX 1.00E+OO 1.1767 TQX Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| This term represents an inadvertent open relief valve, which has similar INADVERTENT OPEN RELIEF VALVE consequences as a small LOCA. Phase II SAMAs 13 and 18 for reducing
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| %10RV 1.83E-03 1.048 <INITIATOR> the frequency of core melt from a small LOCA were evaluated.
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| This term represents a steam generator tube rupture (SGTR). Phase II SAMA 57 for eliminating a release pathway to the environment following a SGTR; SAMAs 58, 59, 60, and 61 for reducing the consequences of a
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| %R 2.07E-03 1.0099 Steam Generator Tube Rupture SGTR; and SAMA 56 for reducing the frequency of SGTRs were evaluated.
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| This term represents a Reactor Coolant Pump (RCP) seal LOCA. Phase II SAMAs 57, 59, 25, 26 and 27 for reducing the likelihood of an RCP seal
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| %RCP 3.67E-04 1.009 RCP SEAL LOCA <INITIATOR> LOCA were evaluated.
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| This term represents a small LOCA. Phase II SAMAs 13 and 18 for
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| %S 3.50E-03 1.0995 Small LOCA reducing the frequency of core melt from a small LOCA were evaluated.
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| This term represents a general transient reactor trip. Phase II SAMA 20 for elimination of ECCS dependency on component cooling system; SAMAs 22, 23, 24, and 25 for increased availability of cooling water; and SAMAs 14, 15, and 17 for improved core injection capability were
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| %Tl 2.12E-01 1.0114 Reactor Trip (General Transient) evaluated.
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| Page D-12
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 I Correlation Event Name I Probability I of~evel 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
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| RRW I Event Description I Disposition I This term represents a general transient turbine trip. Phase II SAMA 20 for elimination of ECCS dependency on component cooling system; SAMAs 22, 23, 24, and 25 for increased availability of cooling water; SAMAs 14, 15, and 17 for improved core injection capability were
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| %T3 2.17E-01 1.0189 Turbine Trip (General Transient) evaluated.
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| This term represents a loss of Main Feedwater. Phase II SAMAs 31, 32, and 33 for increased feedwater availability; and SAMA 34 for improved
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| %T4 7.96E-02 1.0095 Loss of Main Feedwater feedwater supply were evaluated.
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| This term represents a loss of offsite power (LOOP). Phase II SAMAs 13 and 24 for improving offsite power reliability; SAMAs 5 and 7 for increased availability of on-site AC power; and SAMAs 8, 9, and 11 for
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| %TS 2.62E-02 1.7282 Loss of Offsite Power increasing diesel generator availability were evaluated.
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| This term represents a feedwater line break or leak. Phase II SAMAs 32 and 33 for increased feedwater availability; and SAMA 34 for improved
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| %T7 1.83E-03 1.0054 Feedwater Line Break I Leak feedwater supply were evaluated.
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| This term represents a loss of the condensate system. Phase II SAMA 32 to create ability for emergency connection of existing or new water
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| %T8 2.52E-02 1.006 Loss of Condensate System sources to feedwater and condensate systems was evaluated.
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| This term represents a loss of 4.16kV power to bus 3A3-S. Phase II SAMAS 5 and 7 for increased availability of on-site AC power and SAMAs 8, 9, and
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| %TAC3 2.18E-03 1.0914 LOSS OF 4.16KV BUS 3A3-S 11 for increased diesel generator availability were evaluated.
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| This term represents a loss of 4.16kV power to bus 3B3-S. Phase II SAMAs 5 and 7 for increased availability of on-site AC power and SAMAs 8, 9, and
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| %TAC4 2.18E-03 1.318 LOSS OF 4.16KV BUS 3B3-S 11 for increased diesel generator availability were evaluated.
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| This term represents a loss of a 480 VAC bus 3AB31-S. Phase II SAMA 13 to install an independent active or passive high pressure injection system;
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| %TAC7 5.22E-04 1.0076 LOSS OF 480 V BUS 3AB31-S and phase II SAMAs 35 and 36 to enhance HVAC were evaluated.
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| Pc: , -13
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
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| Event Name I Probability j RRW I Event Description I Disposition l This term represents a loss of DC bus A. Phase 11 SAMAs 1, 2 and 3 for
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| %TDC1 1.84E-04 1.0067 Loss of DC Bus A IE improving DC power availability were evaluated.
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| This term represents a loss of DC bus B. Phase II SAMAs 1, 2 and 3 for
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| %TDC2 1.84E-04 1.0078 Loss of DC Bus B IE improving DC power availability were evaluated.
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| Battery life extended and battery This term is a flag for successful battery load shedding. No SAMAs need AABATT3ABD 1.00E+OO 11.8819 drain occurs to be aligned.
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| AACSPEMPTY 1.00E+OO 1.0119 CSP is Empty Flag This term is a flag. No SAMAs need to be aligned.
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| Logic flag that indicates Loss of all SG Feed Water (LOSP recovery AALOSPEVTB 1.00E+OO 1.4935 Flag) This term is a flag. No SAMAs need to be aligned.
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| Logic flag that indicates that DG/TEDG to 3A3-S has failed (LOSP AA FAIL3AS 1.00E+OO 1.7326 recovery Flag This term is a flag. No SAMAs need to be aligned.
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| Logic flag that indicates that DG/TEDG to 3B3-S has failed (LOSP AA FAIL3BS 1.00E+OO 1.775 recovery Flag This term is a flag. No SAMAs need to be aligned.
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| AB ELECTRIC POWER IS ALIGNED A TO AB 5.00E-01 11.0137 TOA TRAIN This term is a flag. No SAMAs need to be aligned.
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| AB ELECTRIC POWER IS ALIGNED IB_TO_AB 15.00E-01 11.0381 TO B TRAIN This term is a flag. No SAMAs need to be aligned.
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| CCWABSTBY 3.30E-01 1.0717 CC Pump AB in standby This term is a flag. No SAMAs need to be aligned.
| |
| CCWASTBY 3.30E-01 11.0715 CC Pump A in standby This term is a flag. No SAMAs need to be aligned.
| |
| This term represents a failure of bus load shedding to extend battery Operators fail to shed battery depletion time. Phase II SAMAs 1, 2 and 3 for improving DC power DHFBAT LSP 1.00E+OO 1.2475 loads for A or B or AB battery availability were evaluated.
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| Page D-14
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 I I Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
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| Probability I Event Name RRW I Event Description l Disposition I This term represents a loss of 4.16kV power to bus 3A3-S. Phase II SAMAs 5 and 7 for increased availability of on-site AC power and SAMAs 8, 9, and EB1003A3SF 3.34E-05 1.0087 BUS 3A3-S FAULT 11 for increased diesel generator availability were evaluated.
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| This term represents a loss of 4.16kV power to bus 3B3-S. Phase II SAMAs 5 and 7 for increased availability of on-site AC power and SAMAs 8, 9, and EB1003B3SF 3.34E-05 1.0201 BUS 3B3-S FAULT 11 for increased diesel generator availability were evaluated.
| |
| This term represents a failure of breaker 0002A1 which fails bus 3A2.
| |
| Phase 11 SAMAs 5 and 7 for increased availability of on-site AC power and AC BREAKER 0002A1 FAILS TO SAMAs 8 and 9 for increasing diesel generator availability were ECB0002A1D 2.39E-03 1.0201 OPERATE evaluated.
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| This term represents a failure of breaker 0002A4 which fails bus 3A2.
| |
| Phase II SAMAs 5 and 7 for increased availability of on-site AC power and AC BREAKER 0002A4 FAILS TO SAMAs 8 and 9 for increasing diesel generator availability were ECB0002A4D 2.39E-03 1.0201 OPERATE evaluated.
| |
| This term represents a failure of breaker 0002B1 which fails bus 3B2.
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| Phase II SAMAs 5 and 7 for increased availability of on-site AC power and AC BREAKER 0002B1 FAILS TO SAMAs 8 and 9 for increasing diesel generator availability were ECB0002B1D 2.39E-03 1.0232 OPERATE evaluated.
| |
| This term represents a failure of breaker 0002B4 which fails bus 3B2.
| |
| Phase II SAMAs 5 and 7 for increased availability of on-site AC power and AC BREAKER 0002B4 FAILS TO SAMAs 8 and 9 for increasing diesel generator availability were ECB0002B4D 2.39E-03 1.0232 OPERATE evaluated.
| |
| This term represents a breaker failure that leads to DG 3A-S failing to A312 ASSOCIATED CIRCUITS FAIL start. Phase II SAMAs 5, 6, 7, and 10 for increased availability of AC power ECB312A8MD 2.39E-03 1.0278 TO STRIP ON DEMAND were evaluated.
| |
| This term represents a breaker failure that leads to DG 3B-S failing to B312 ASSOCIATED CIRCUITS FAIL start. Phase II SAMAs 5, 6, 7, and 10 for increased availability of AC power ECB312B8MD 2.39E-03 1.0261 TO STRIP ON DEMAND were evaluated.
| |
| Pc -15
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
| |
| ,Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (13ased on CDF)
| |
| Event Name I Probability I RRW I Event Description ! Disposition I This term represents a breaker failure that leads to DG 3A-S failing to A313 ASSOCIATED CIRCUITS FAIL start. Phase II SAMAs 5, 6, 7, and 10 for increased availability of AC power ECB313A8MD 2.39E-03 1.0278 TO STRIP ON DEMAND were evaluated.
| |
| This term represents a breaker failure that leads to DG 3B-S failing to B313 ASSOCIATED CIRCUITS FAIL start. Phase II SAMAs 5, 6, 7, and 10 for increased availability of AC power ECB313B8MD 2.39E-03 1.0261 TO STRIP ON DEMAND were evaluated.
| |
| This term represents a breaker failure that leads to DG 3A-S failing to A314 ASSOCIATED CIRCUITS FAIL start. Phase II SAMAs 5, 6, 7, and 10 for increased availability of AC power ECB314A2MD 2.39E-03 1.0278 TO STRIP ON DEMAND were evaluated.
| |
| This term represents a breaker failure that leads to DG 3B-S failing to B314 ASSOCIATED CIRCUITS FAIL start. Phase II SAMAs 5, 6, 7, and 10 for increased availability of AC power ECB314B2MD 2.39E-03 1.0261 TO STRIP ON DEMAND were evaluated.
| |
| This term represents a loss of startup transformers. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for increased CCF 2 OF 2 SUT FAIL TO PROVIDE availability of on-site AC power; and SAMAs 8, 9, and 11 for increasing ECCOOOSUTF 1.60E-04 1.0177 OUTPUT diesel generator availability were evaluated.
| |
| This term represents the diesel generators failing to run. Phase II SAMAs CCF DIESEL GENERATORS FAIL TO 5, 6, 7, 10, 11, and 13 for increased availability of AC power were ECCDGNORUN 7.20E-05 1.0108 RUN evaluated.
| |
| CCF DIESEL GENERATORS FAIL TO This term represents the diesel generators failing to start. Phase II SAMAs ECCDGSTART 1.92E-05 11.0059 START 5, 6, 7, 10, and 13 for increased availability of AC power were evaluated.
| |
| This term represents a loss of Diesel Fuel Oil, which leads to loss of DGs A CCF Diesel Fuel Oil Transfer Pumps and B. Phase II SAMAs 5, 6, 7, 10, and 11 for increased availability of AC ECCFOXFRA 1.41E-04 1.0454 Fail to Start power were evaluated.
| |
| DIESEL GENERATOR 3A-S FAILS TO This term represents a failure of DG 3A-S to start. Phase II SAMAs 5, 6, 7, EDGODG3ASAE 1.56E-03 11.0178 START 10, and 13 for increased availability of AC power were evaluated.
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| Page D-16
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
| |
| Event Name I Probability I RRW I Event Description I Disposition I DIESEL GENERATOR 3A-S FAILS TO This term represents a failure of DG 3A-S to run after the first hour of RUN AFTER FIRST HOUR OF operation. Phase II SAMAs 5, 6, 7, 10, 11, and 13 for increased availability EDGODG3ASFE 5.48E-03 1.0381 OPERATION of AC power were evaluated.
| |
| DIESEL GENERATOR 3B-S FAILS TO This term represents a failure of DG 3B-S to start. Phase II SAMAs 5, 6, 7, IEDGODG3BSAE li.56E-03 11.0167 START 10, and 13 for increased availability of AC power were evaluated.
| |
| DIESEL GENERATOR 3B-S FAILS TO This term represents a failure of DG 3B-S to run after the first hour of RUN AFTER FIRST HOUR OF operation. Phase II SAMAs 5, 6, 7, 10, 11, and 13 for increased availability EDGODG3BSFE 5.48E-03 1.0371 OPERATION of AC power were evaluated.
| |
| This term represents a failure of a human action to energize bus AB3-S from bus opposite initial supply. Phase II SAMAs 6, 7, and 10 for increased availability of on-site and offsite power and SAMAs 8, 9, and 11 for increased diesel generator availability were evaluated. In addition, the Failure to energize bus 3AB3-S failure of this human action causes a loss of battery power due to a loss from bus opposite initial of AC power in which phase II SAMAs 1 and 2 for improving DC power EHFALNAB_P 1.00E+OO jl.0481 supply--recovery flag availability were evaluated.
| |
| This term represents a failure ofthe exhaust fan for DG 3A-S. Phase II MOTOR-DRIVEN FAN EXFANA SAMAs 5, 6, 7, 10, and 13 for increased availability of AC power were EMFEXFANAA 8.42E-04 1.0094 FAILS TO START evaluated.
| |
| MOTOR-DRIVEN FAN EXFANA . This term represents a failure of the exhaust fan for DG 3A-S. Phase II FAILS TO RUN AFTER FIRST HOUR SAMAS 5, 6, 7, 10, 11, and 13 for increased availability of AC power were EMFEXFANAF 1.04E-03 1.0068 OF OPERATION evaluated.
| |
| MOTOR-DRIVEN FAN EXFANA This term represents a failure of the exhaust fan for DG 3A-S. Phase II FAILS TO RUN DURING FIRST HOUR SAMAs 5, 6, 7, 10, and 13 for increased availability of AC power were EMFEXFANAL 1.07E-03 1.0121 OF OPERATION evaluated.
| |
| This term represents a failure of the exhaust fan for DG 3B-S. Phase II MOTOR-DRIVEN FAN EXFANB SAMAs 5, 6, 7, 10, and 13 for increased availability of AC power were EMFEXFANBA 8.42E-04 1.0089 FAILS TO START evaluated.
| |
| Pc: -17
| |
| | |
| Waterford Steam Electric Station unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
| |
| Event Name! Probability I RRW I Event Description I Disposition I MOTOR-DRIVEN FAN EXFANB This term represents a failure of the exhaust fan for DG 3B-S. Phase II FAILS TO RUN AFTER FIRST HOUR SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC power were EMFEXFANBF 1.04E-03 1.0066 OF OPERATION evaluated.
| |
| MOTOR-DRIVEN FAN EXFANB This term represents a failure of the exhaust fan for DG 3B-S. Phase II FAILS TO RUN DURING FIRST HOUR SAMAs 5, 6, 7, 10, and 13 for increased availability of AC power were EMFEXFANBL 1.07E-03 1.0113 OF OPERATION evaluated.
| |
| This term represents a loss of Diesel Fuel Oil, which leads to loss of DG Fuel Oil Transfer Pump 3A-S.Phase II SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC EMPOILTRAA 5.68E-03 1.0695 EDG-MPMP-OOOlA Fails to Start power were evaluated.
| |
| This term represents a loss of Diesel Fuel Oil, which leads to loss of DG Fuel Oil Transfer Pump 3B-S. Phase II SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC EMPOILTRBA 5.68E-03 1.0651 EDG-MPMP-OOOlB Fails to Start power were evaluated.
| |
| DIESEL GENERATOR 3A-S IN TEST This term represents the unavailability of DG 3A-S. Phase II SAMAs 5, 6, 7, ETMOODG3AS 4.00E-03 1.0352 OR MAINTENANCE 10, and 13 for increased availability of AC power were evaluated.
| |
| DIESEL GENERATOR 3B-S IN TEST This term represents the unavailability of DG 3B-S. Phase II SAMAs 5, 6, 7, IETMOODG3BS 16.09E-03 11.0568 OR MAINTENENCE 10, and 13 for increased availability of AC power were evaluated.
| |
| This term represents a loss of a startup transformer 3A. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for STARTUP TRANSFORMER 3A IN increased availability of on-site AC power; and SAMAs 8, 9, and 11 for ETM SUT-3A 1.75E-03 1.0142 TEST OR MAINTENANCE increasing diesel generator availability were evaluated.
| |
| This term represents a loss of a startup transformer 3B. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for STARTUP TRANSFORMER 3B IN increased availability of on-site AC power; and SAMAs 8, 9, and 11 for ETM SUT-3B 1.75E-03 1.0165 TEST OR MAINTENANCE increasing diesel generator availability were evaluated.
| |
| This term represents a failure to isolate HPSI pump recirculation lines CCF of Sl-120A and 121A to Close after initiation of sump recirc. Phase II SAMAs 29 and 30 for greater HCCISOMNAC 1.llE-05 1.0062 After RAS RWSP inventory were evaluated.
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| Page D-18
| |
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1..:2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
| |
| Event Name I Probability I RRW I Event Description I Disposition -1 This term represents a failure to isolate HPSI pump recirculation lines CCF of Sl-120B and 121B to Close after initiation of sump recirc. Phase II SAMAs 29 and 30 for greater HCCISOMNBC 1.llE-05 1.0062 After RAS RWSP inventory were evaluated.
| |
| This term represents HPSI pumps failing to run. Phase II SAMAs 13 and 17 for decreasing HPSI pump CCF were evaluated and Phase II SAMA 12 for increasing the availability of charging which is a backup to HPSI was HCCPMPSBCF 1.46E-05 1.0084 CCF FOR HPSI PUMPS FAIL TO RUN evaluated.
| |
| This term represents a failure of HPSI pump recirculation. Phase II SAMAs HCCSI0602N 1.04E-05 1.0058 CCF Sl-602 FAIL TO OPEN ON RAS 29 and 30 for greater RWSP inventory were evaluated.
| |
| This term represents a failure of a human action to align the standby HPSI pump to replace the failed pump. Phase II SAMAs 13 and 17 for Failure to align standby HPSI pump enhancing the HPSI system by adding or enhancing the HPSI pumps were to replace failed pump--recovery evaluated and Phase II SAMA 27 for increasing the availability of charging HHFALNAB P 1.00E+OO 1.0158 flag which is a backup to HPSI was evaluated.
| |
| Failure to isolate HPSI pump This term represents a failure of a human action to isolate HPSI pump recirculation lines after initiation recirculation lines after initiation of sump recirculation. Phase II SAMAs HHFISOMINP 1.00E+OO 1.0183 of sump recirc 29 and 30 for greater RWSP inventory were evaluated.
| |
| MOV-602A FAILS TO OPEN ON This term results in a failure of HPSI train A recirc mode. Phase II SAMAs HMVSl602AN 9.63E-04 1.0059 DEMAND 29 and 30 for greater RWSP inventory were evaluated.
| |
| MOV-602B FAILS TO OPEN ON This term results in a failure of HPSI train B recirc mode. Phase II SAMAs HMVSl602BN 9.63E-04 1.0053 DEMAND 29 and 30 for greater RWSP inventory were evaluated.
| |
| HPSI AB IS ALIGNED AS STANDBY HPIABISSTBY 3.30E-01 li.0051 PUMP This term is an alignment flag. No SAMAs need to be aligned.
| |
| HPSI A is the Standby pump for H PIAISASTBY 3.30E-01 1.0067 Train A (I PE) This term is an alignment flag. No SAMAs need to be aligned.
| |
| HPSI Bis the standby pump for HPIBISBSTBY 3.30E-01 1.0067 Train B (IPE) This term is an alignment flag. No SAMAs need to be aligned.
| |
| P; -19
| |
| | |
| Waterford Steam Electric Station unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 .Risk Significant Terms to Evaluated SAMAs (Based on CDF)
| |
| Event Name I Probability J RRW I Event Description j Disposition I I
| |
| This term represents adverse MTC during an ATWS event. Phase II SAMAs 63, 64, 65, and 66 for improved reliability during an ATWS were KMTCO 4.00E-01 1.0137 ADVERSE MTC (-1.145 MTC) evaluated.
| |
| This term represents a mechanical failure of the reactor to trip. Phase II FAILURE OF REACTOR TRIP SAMAs 63, 64, 65, and 66 for improved reliability during an ATWS were KRTMECH 8.40E-07 1.014 (MECHANICAL) evaluated.
| |
| This term is a loss of offsite power (LOOP) after a plant trip. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for increased availability of on-site AC power; and SAMAs 8, 9, and 11 for LOSP-EPRI 1.00E-03 1.0105 Conditional LOSP after a plant trip increasing diesel generator availability were evaluated.
| |
| This term represents a failure of a human action to trip the RCPs following a loss of seal cooling leading to a Reactor Coolant Pump (RCP)
| |
| Failure to trip RCPs following loss seal LOCA. Phase II SAMAs 23, 24, 25, 26, and 27 for reducing the OHFRCPTRIP 1.00E+OO 1.177 of seal cooling likelihood of an RCP seal LOCA were evaluated.
| |
| CCF 4 of 4 EFW AOVs 223A, 2238, This term represents a failure of EFW due to CCF valve failures. Phase II QCC442234N 3.74E-06 1.0139 224A,2248 SAMAs 32, 33 and 34 for increased feedwater availability were evaluated.
| |
| CCF 4 of 4 EFW AOVs 228A, 2288, This term represents a failure of EFW due to CCF valve failures. Phase II QCC442289N 3.74E-06 1.0139 229A,2298 SAMAs 32, 33 and 34 for increased feedwater availability were evaluated.
| |
| This term represents a failure of EFW Motor driven pumps. Phase II SAMAs 32, 33, and 34 for increased feedwater availability were QCCPMDPSSF 8.66E-05 1.0153 CCF EFW MDP FAIL TO RUN evaluated.
| |
| This term represents a failure of all EFW pumps. Phase II SAMAs 32, 33, QCCPUMPSSF 1.33E-05 1.0518 CCF ALL EFW PUMPS FAIL TO RUN and 34 for increased feedwater availability were evaluated.
| |
| This term represents failure of a human action to supply makeup to the CSP during EFW operation. This term is essentially a flag for the HFE and no combination or H FE with the associated probability are contained in Failure to supply makeup to CSP the RRW tables. Phase II SAMA 32 is also evaluated for making the QHFCSPEMPP 1.00E+OO 1.0052 during EFW operation transfer ofthe condensate storage pool to the DWST automatic.
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| Page D-20
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (.Based on CDF)
| |
| Event Name l Probability I RRW I Event Description J Disposition I This term represents failure of a human action to align EFW suction to WCT after CSP depletion. This term is essentially a flag for the HFE and no combination or HFE with the associated probability are contained in the Failure to align EFW suction to RRW tables. Phase II SAMA 32 is also evaluated for making the transfer of QHFCSPWCTP 1.00E+OO 1.0085 WCT after CSP depletion the condensate storage pool to the DWST automatic.
| |
| MOTOR-DRIVEN PUMP EFW PMP This term represents a failure to start of EFW pump A. Phase II SAMAs 32, QMPEFPMPAAQ 5.75E-04 1.0068 A FAILS TO START 33, and 34 for increased feedwater availability were evaluated.
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| MOTOR-DRIVEN PUMP EFW PMP A FAILS TO RUN AFTER FIRST HOUR This term represents a failure to run of EFW pump A. Phase II SAMAs 32, QMPEFPMPAF 2.83E-03 1.0354 OF OPERATION 33, and 34 for increased feedwater availability were evaluated.
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| MOTOR-DRIVEN PUMP EFW PMP This term represents a failure to start of EFW pump B. Phase II SAMAs 32, QMPEFPMPBAQ 5.75E-04 1.0068 B FAILS TO START 33, and 34 for increased feed water availability were evaluated.
| |
| EFW MDP A TRAIN UNAVAILABLE This term represents unavailability of EFW pump A. Phase II SAMAs 32, QTMEFWPPAM 6.27E-04 11.0067 (MAINTENANCE) 33, and 34 for increased feedwater availability were evaluated.
| |
| EFW MDP B TRAIN UNAVAILABLE This term represents unavailability of EFW pump B. Phase II SAMAs 32, QTMEFWPPBM 6.27E-04 1.007 (MAINTENANCE) 33, and 34 for increased feedwater availability were evaluated.
| |
| TURBINE-DRIVEN PUMP 3PMPAB This term represents a failure of the turbine-driven EFW pump. Phase II FAILS TO RUN AFTER FIRST HOUR SAMAs 32, 33, and 34 for increased feedwater availability were QTP3PMPABF 3.06E-02 1.0974 OF OPERATION evaluated.
| |
| This term represents the transfer closed of a manual valve that results in failure of the DWSTto CSP flow path. Phase II SAMA 32 is evaluated for MANUAL VALVE CMU142 making the transfer of the condensate storage pool to the DWST QXVCMU142K S.53E-04 1.0052 TRANSFERS CLOSED automatic.
| |
| This leads to a loss of Component Cooling Water (CCW) to DG 3A-S. Phase AIR-OPERATED VALVE CC413A II SAMAs 8 and 9 for backup sources of diesel generator cooling were SAVCC413AN 9.51E-04 1.0107 FAILS TO OPEN evaluated.
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| Pc:* *-21
| |
| | |
| Waterford Steam Electric Station unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
| |
| Event Name I Probability I RRW I, Event Description. I Disposition I This leads to a loss of Component Cooling Water (CCW} to DG 3B-S. Phase AIR-OPERATED VALVE CC-413B II SAMAs 8 and 9 for backup sources of diesel generator cooling were SAVCC413BN 9.51E-04 1.01 FAILS TO OPEN evaluated.
| |
| CCF of ACCW Pump Discharge Isolation MOVs ACC-110A/B Fail To This represents CCF of the ACCW pump discharge isolation valves. Phase SCCPMPISON 1.85E-05 1.0104 Open II SAMAs 22 and 23 to decrease the importance of ACCW were evaluated.
| |
| This term represents failure of a human action to align CCW train AB to replace lost train A or B. Phase II SAMAs 8, 9, 20, 23, and 27 to decrease Failure to align CCW train AB to the importance of and enhance the availability and reliability of the CCW SHFABCCWRP 1.00E+OO 1.1549 replace lost train A or B system to provide cooling water were evaluated.
| |
| This term represents unavailability of CCW train B. Phase 11 SAMAs 8, 9, 20, 23, and 27 to decrease the importance of and enhance the availability CCW TRAIN B UNAVAILABLE DUE and reliability of the CCW system to provide cooling water were STMCCTRNBF 1.17E-03 1.015 TO TEST/MAINTENANCE evaluated.
| |
| This term represents a failure of the exhaust fans for both DGs. Phase II CCF EDG EXHAUST FANS FAIL TO SAMAs 5, 6, 7, 10, and 13 for increased availability of AC power were UCCEDGFANA 8.42E-05 1.0266 START evaluated.
| |
| This term represents a failure of the exhaust fans for both DGs. Phase II CCF EDG EXHAUST FAN FAILS TO SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC power were UCCEDGFANF 1.07E-04 1.0161 RUN evaluated.
| |
| This term represents a failure of room cooling for DG 3A-S. Phase II INLET DAMPER HVR-501A FAILS TO SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC power were UMCHV501AN 5.80E-04 1.0064 OPEN evaluated.
| |
| This term represents a failure of room cooling for DG 3B-S. Phase II INLET DAMPER HVR-5018 FAILS TO SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC power were UMCHV501BN 5.80E-04 1.006 OPEN evaluated.
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| Page D-22
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF}
| |
| Event Name I Probability I RRW I Event Description I Disposition I This term represents a failure of the exhaust fan for DG 3A-S. Phase II EDG EXHAUST FAN UNAVAILABLE SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC power were UTMFANA3AS 2.00E-03 1.0193 DUE TO TEST OR MAINTENANCE evaluated.
| |
| This term represents a failure of the exhaust fan for DG 3B-S. Phase II EDG EXHAUST FAN B IN TEST OR SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC power were UTMFANB3BS 2.00E-03 1.0192 MAINTENANCE evaluated.
| |
| CCFACCW BASIN STRAINERS This represents CCF of the ACCW basin strainers. Phase II SAMAs 22, 23, XCCWCTSTRP 3.60E-05 1.0204 PLUGGED 24, 25 and 26 to decrease the importance of ACCW were evaluated.
| |
| MOTOR DRIVEN PUMP ACCW-lA This represents a failure of MDP ACCW-lA. Phase II SAMAs 19, 21, 22, 23, XMP3ACCWAAX l.54E-03 1.0071 FAILS TO START 24, 25 and 26 to decrease the importance of ACCW were evaluated.
| |
| MOTOR DRIVEN PUMP ACCW-lB This represents a failure of MDP ACCW-18. Phase II SAMAs 19, 21, 22, 23, XMP3ACCWBAX 1.54E-03 1.0062 FAILS TO START 24, 25 and 26 to decrease the importance of ACCW were evaluated.
| |
| This term represents a failure of a human action to perform bus load Failure to shed loads on the A or B shedding. Phase II SAMAs 1, 2, and 3 for improving DC power availability ZDHFBAT LSP 8.40E-02 1.0398 battery were evaluated.
| |
| This term represents a failure of a human action to align CCW train AB to Failure to align CCW train AB to replace lost train A or Band failure to trip RCPs after loss of seal cooling.
| |
| replace lost train A or Band failure Phase II SAMAs 8, 9, 20, 23, and 27 to decrease the importance of and to trip RCPs after loss of seal enhance the availability and reliability of the CCW system to provide cooling (SH FABCCWRP
| |
| * cooling water were evaluated. Phase II SAMAs 24, 25, and 26 for reducing ZHF-C2-011 8.20E-04 1.1294 OHFRCPTRIP) the likelihood of an RCP seal LOCA were evaluated.
| |
| PC -23
| |
| | |
| Waterford Steam Electric Station unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1~2 I . Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs .(Based on CDF)
| |
| Event Name] Probability I RRW I Event Description I Disposition 1 This term represents a failure of a human action to trip RCPs or swap AB bus supply. Phase II SAMAs 23, 24, 25, 26, and 27 for reducing the likelihood of an RCP seal LOCA were evaluated. Phase II SAMAs 6, 7, and 10 for increased availability of on-site and offsite power and SAMAs 8, 9, and 11 for increased diesel generator availability were evaluated. In Failure to trip RCPs or swap AB bus addition, the failure of this human action causes a loss of battery power supply {OHFRCPTRIP
| |
| * due to a loss of AC power in which phase II SAMAs 1 and2 for improving ZHF-C2-052 1.20E-04 1.0128 EHFALNAB_P) DC power availability were evaluated.
| |
| This term represents a failure of a human action to align CCW train AB to replace lost train A or Band failure to trip RCPs after loss of seal cooling and failure to energize bus 3AB3-S from bus opposite initial supply. Phase II SAMAs 8, 9, 20, 23, and 27 to decrease the importance of and enhance the availability and reliability of the CCW system to provide cooling water Failure to align CCW train AB to were evaluated. Phase II SAMAs 24, 25, and 26 for reducing the likelihood replace lost train A or Band failure of an RCP seal LOCA were evaluated. Phase II SAMAs 6, 7, and 10 for to trip RCPs after loss of seal increased availability of on-site and offsite power and SAMAs 8, 9, and 11 cooling and failure to energize bus for increased diesel generator availability were evaluated. In addition, the 3AB3-S from bus opposite initial failure of this human action causes a loss of battery power due to a loss supply {SHFABCCWRP
| |
| * of AC power in which phase II SAMAs 1 and 2 for improving DC power ZHF-C3-020 1.20E-04 1.0168 OHFRCPTRIP
| |
| * EHFALNAB_P) availability were evaluated.
| |
| Failure to isolate HPSI pump This term represents a failure of a human action to isolate HPSI pump recirculation lines after initiation recirculation lines after initiation of sump recirculation. Phase II SAMAs ZHFISOMINP 3.20E-05 1.0181 of sump recirc 29 and 30 for greater RWSP inventory were evaluated.
| |
| This term represents a failure of a human action to trip the RCPs following a loss of seal cooling leading to a Reactor Coolant Pump {RCP)
| |
| Failure to trip RCPs following loss seal LOCA. Phase II SAMAs 23, 24, 25, 26, and 27 for reducing the ZHFRCPTRIP 2.20E-03 1.0057 of seal cooling likelihood of an RCP seal LOCA were evaluated.
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| Page D-24
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2
| |
| '
| |
| Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based' on CDF)
| |
| Event Name I Probability I RRW .I Event Description I Disposition I This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for LOOP Recovery with Batt Depl and increased availability of on-site AC power; and SAMAs 8 and 9 for ZLOOP_BO 9.52E-02 1.2877 0 Run Fail increasing diesel generator availability were evaluated.
| |
| I This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for LOOP Recovery with Batt Depl and increased availability of on-site AC power; and SAMAs 8 and 9 for ZLOOP _BONL 1.59E-01 1.0323 0 Run Fail (No Load Shed) increasing diesel generator availability were evaluated.
| |
| This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for LOOP Recovery with Batt Depl and increased availability of on-site AC power; and SAMAs 8, 9, and 11 for ZLOOP Bl 4.34E-02 1.0674 1 Run Fail increasing diesel generator availability were evaluated.
| |
| ' This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for LOOP Recovery with Batt Depl and increased availability of on-site AC power; and SAMAs 8, 9, and 11 for ZLOOP_BlNL 5.77E-02 1.0069 1 Run Fail (No Load Shed) increasing diesel generator availability were evaluated.
| |
| I This term represents a failure to recover offsite power when lost. Phase II I SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for LOOP Recovery without Batt Depl increased availability of on-site AC power; and SAMAs 8, 9, and 11 for ZLOOP Dl 1.07E-01 1.0092 and 1 Run Fail increasing diesel generator availability were evaluated.
| |
| Pc -25
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage CDF Uncertainty The uncertainty associated with core damage frequency was estimated and documented in the WF3 PSA Uncertainty and Sensitivity Analysis Report [D.1-3].
| |
| The ratio of the 95th percentile GDF to the mean is approximately 1.99. An uncertainty factor of 1.99 was applied to determine the internal and external benefit with uncertainty as described in Section 4.15.1.4.4.
| |
| D.1.2 PSA Model - Level 2 Analysis D.1.2.1 Containment Performance Analysis The WF3 Level 2 PSA model used for the SAMA analysis is the most recent internal events risk model.
| |
| The WF3 Level 2 model includes two types of considerations: 1) a deterministic analysis of the physical processes for a spectrum of severe accident progressions, and 2) a probabilistic analysis component in which the likelihood of the various outcomes are assessed. The deterministic analysis examines the response of the containment to the physical processes during a severe accident. This response is performed by
| |
| * utilization of the MAAP 4.0.6 code [D.1-2] to simulate severe accidents that have been identified as dominant contributors to core damage in the Level 1 analysis, and
| |
| * reference calculation of several hydrodynamic and heat transfer phenomena that occur during the progression of severe accidents. Examples include debris cool-ability, pressure spikes due to ex-vessel steam explosions, direct containment heating, high pressure melt ejection, molten debris filling the pedestal area and flowing over the drywell floor, containment bypass, deflagration and detonation of hydrogen, and thrust forces at reactor vessel failure.
| |
| The development of the CET was based on the plant-specific information and conditions associated with the Level 1 event tree end states that result in a plant core damage state. Using the information from the Level 1 core damage states including the accident sequence, equipment availability, and Containment Heat Removal (CHR) systems, the Level 1 core damage states were used to define the initial states for the Level 2. The progression of these Level 2 initial states through the CETs ends in a radionuclide release end state (CET end state). The WF3 Level 2 containment event trees model the postulated course of core melt progression events. This CET tool integrates the sequence-based accident scenario with the plant mitigation features (active and passive}, operator actions, phenomenological effects, and containment capability to calculate the fission product (FP) distribution .
| |
| . Four CETs have been developed to address the core melt progression and radioactive releases associated with the Level 2 plant response [D.1-2].
| |
| The event tree headings are based on previously developed CETs [D.1-4] and results obtained from the deterministic MAAP calculations for each of the Level 2 accident sequences. A summary of the CET tops are included in table D.1-3.
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| Page D-26
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage The Large Early Release Frequency (LERF) is an indicator of containment performance from the Level 2 results because the magnitude and timing of these releases provide the greatest potential for early health effects to the public. The frequency calculated is approximately 1.88E-06/ry.
| |
| LERF represents a fraction (-18%) of all release end states. Table D.1-4 provides a correlation between the Level 2 LERF RRW risk significant events (severe accident phenomenon, initiating events, component failures and operator actions) and Table D.1-5 provides the correlation between all level 2 release states RRW risk significant events down to 1.005 identified from the WF3 PRA Level 2 model and the SAMAs evaluated in Section D.2.
| |
| Table D.1-3 CONTAINMENT EVENT TREE TOPS CETTop Description of CET Top CFC Containment Fans ON cs Containment Sprays ON CB Containment Bypass Cl Containment Isolation 1-SGTR Induced SGTR Occurs DP Depressurization Successful REC RPV Water Level Sufficient EXC Successful Ex-Vessel Cooling CFE No Early Containment Failure CAV Wet Cavity VB Vessel Intact- No Breach BMT Basemat Melt Through CFL No Late Containment Failure Because deterministic MAAP calculations were performed for each of the Level 1 core damage sequences, no binning of the accident sequences was performed to group plant damage states with similar accident sequence characteristi.cs, mitigating systems, and containment responses.
| |
| The sequence-specific Level 2 responses were evaluated directly from the MAAP results. To provide a more accurate determination of the Level 2 sequence response, different configurations of Containment Heat Removal (CHR) system performance was applied to each Level 2 sequence and evaluated independently.
| |
| CHR systems are key to.integrity and performance of the containment structure during the Level 2 accidents analysis. As a result, four CHR configurations were developed to represent the specific combination of the CHR systems available during the accident progression. These configurations of the Level 2 sequences and CHR systems are represented in four separate event trees as follows:
| |
| * Tree B: Both containmen_t spray system (CSS) and containment fan coolers (CFC) are available and operate (CHR-B)
| |
| * Tree D: CFC is available and operates; CSS are not available or fail to operate (CHR-D)
| |
| * Tree F: CSS is available and operates; CFC are not available or fail to operate (CHR-F)
| |
| * Tree H: Neither CSS nor CFC is available or successfully operates (CHR-H)
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| Page D-27
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage The sections below describe top events used in the development of the CET.
| |
| D.1.2.1.1 CFC - Containment Fans ON The CFC CET Top considers the operation of the containment fans for the removal of heat from the containment atmosphere and the reduction of containment pressure. The configuration of the containment heat removal systems has been integrated with the Level 1 core damage sequences as part of the generation of the Level 2 accident sequence. This integration is consistent with the previous WF3 Level 2 analysis [D.1-4].
| |
| Level 2 accident sequences with the CHR configuration of B or D are considered to have successful operation of the containment fans, whereas CHR configurations of F and H are not considered to be successful due to failure of the containment fans to operate. Success of the CFC top is considered as the successful start and long-term operation of 2 of 4 containment cooling fans [D.1-5, D.1-6].
| |
| For SBO sequences, the loss of power results in the failure of the containment cooling fans to start. As a result, no operation of the containment fans is considered for SBO sequences.
| |
| D.1.2.1.2 CS - Containment Sprays ON The CS CET Top considers the operation of the CSS for the removal of heat from the containment atmosphere, the reduction of containment pressures, limiting hydrogen concentrations, and the removal of radioactive components. Like the CFC CET Top, the CS CET Top is integrated with the Level 1 core damage sequences as part of the generation and evaluation of the Level 2 accident sequences and is consistent with the previous WF3 Level 2 analysis [D.1-4].
| |
| Level 2 accident sequences with the CHR configuration of 8 or F are considered to have successful operation of the containment sprays, whereas CHR configurations of D and H are not considered to be successful due to failure of the containment sprays to operate. Success of the CS top is considered as the succei;;sful start and operation of 1 of 2 containment spray trains
| |
| [D.1-5, D.1-6]. The Level 2 does not consider refilling of the RWSP or alternate water sources, and as a result, the operation of the containment spray following depletion of the RWSP is not considered. In addition, the operation of containment spray in recirculation mode is not considered in the Level 2 because the Level 1 sequences with successful recirculation do not
| |
| ,. progress to core damage.
| |
| For SBO sequences, the initial loss of power results in the failure of the containment spray system. For SBO sequences where the batteries are credited for short-term, no credit is assumed
| |
| . for the operation of the containment spray system.
| |
| D.1.2.1.3 CB - <;;ontainment Bypass The CB CET Top considers a unique set of Level 2 accident sequences where an early pathway opens as a result of a pipe break outside of containment that would allow for the unmitigated release of fission products (FP) to the environment. Because a bypass sequence results in a containment release at a time point coincident with the initiation of the accident, the FP releases from the bypass sequence are characterized as unmitigated. The shortened residence time of the FP in containment are released without the benefit of radioactive decay time, scrubbing effects, or gravitational settling.
| |
| Accident sequences with the potential to bypass a traditional containment failure include SGTR
| |
| . Page D-28
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage and ISLOCA. In addition to the early containment release pathway, mitigation actions engaged during an ISLOCA and SGTR sequence result in the release of RWSP water outside of containment. This depletion of water available for cooling of the core or cerium, or scrubbing of FP releases, contributes to the potential for severe consequences associated with these containment bypass sequences.
| |
| As a result of the early unmitigated release pathway, all containment bypass sequences are characterized as high-early release scenarios.
| |
| The CB CET Top is successful when no containment bypasses occur.
| |
| D.1.2.1.4 Cl - Containment Isolation The Cl CET Top considers containment isolation failures in excess of 2.25 inches [D.1-6, D.1-7]
| |
| which is consistent with the definition associated with the LERF analysis. Release scenarios associated with the Cl top include all non-bypass core damage sequences accompanied by a containment isolation failure. Two types of containment isolation failures have been considered, including (1) pre-existing containment flaw failure and (2) isolation failures of the valves, piping, and systems associated with the Containment Isolation System.
| |
| Containment failure due to pre-existing errors, cracks or tears represent a potential direct release pathway for FP release outside of containment. Based on an evaluation of pre-existing flaws conducted as part of the LERF analysis, the WF3 leakage liner tear is found to be less than the LERF sizing of 2.25-inches. As a result, the pre-existing flaw isolation failure was not considered for the LERF in that they represent a small isolation failure. For the purpose of the Level 2, the pre-existing flaw containment isolation failure is conservatively retained and considered as a potential Cl faiiure. Although the liner leakage tear size does not meet the minimum release sizes, this containment isolation failure will be considered in the Level 2 based on the uncertainty associated with the significance of liner cracks and tears in the steel containment vessel (SCV).
| |
| Failure of containment valves, piping, and systems to properly isolate represents another potential containment isolation pathway for FP releases. These failures occur as a result of the failure to isolate containment given actuation of a CIAS signal (pressurizer pressure decreases to 1684 psia or containment pressure increases above 17.1 psia). Penetrations and valves with flow diameters of 2.25-inches and above are considered as potential containment isolation pathways.
| |
| These Cl pathways and their failure modes have been developed as part of the Level 1 and LERF analyses [D.1-8, D.1-6].
| |
| Like the containment bypass sequences, a containment isolation failure has the potential to release radionuclides early in the accident progression. As a result of the early unmitigated release pathway, all containment isolation sequences are characterized as high-early release scenarios. A containment isolation failure is considered for all L2 accident sequences.
| |
| The CET Top Cl is successful when no containment isolation failures occur.
| |
| D.1.2.1.5 1-SGTR -INDUCED STEAM GENERATOR TUBE RUPTURE Induced Steam Generator Tube Rupture (1-SGTR) represents a containment bypass similar to a SGTR sequence. The 1-SGTR CET Top represents a failure of a SG tube as a result of severe accident conditions, either pressure-induced or temperature-induced tube failures. These (
| |
| induced tube failures are similar in nature with other SGTR accident sequences in that they result Page D-29
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage in a containment bypass release scenario. However, these 1-SGTR failures differ from the SGTR sequence in that the tube failures have the potential to occur later in the sequence and may occur in cornbination with other severe accident sequences.
| |
| The 1-SGTR GET Top considers only sequences with potential for induced SG tube failures.
| |
| 1-SGTR can be caused by temperature-induced mechanisms or pressure-induced mechanisms.
| |
| Temperature-induced SGTR (Tl-SGTR) failures result from long-term exposure to high temperatures that result in creep rupture of the tube wall with elevated pressure differential across the primary to secondary system sides. Pressure-induced SGTR (Pl-SGTR) failures result from a high pressure differential between the primary to secondary system sides.
| |
| Based on the L2 MAAP deterministic calculations, potential induced-SGTR failures were identified for sequences with the potential for long-term, high temperature exposure of the tubes and thinning of the tube walls, for sequences with high primary-secondary differential pressures, and for sequences with loss of heat removal.
| |
| Characteristics used to identify potential Pl-SGTR accident sequences included the following
| |
| [D.1-9, D.1-1 O]:
| |
| * Primary-secondary heat removal failures
| |
| * High pressure differential between primary and secondary side (-2500 psid)
| |
| * Timing of rupture likely to occur early, well before core damage Characteristics used to identify potential Tl-SGTR accident sequences included the following
| |
| [D.1-9, D.1-10]:
| |
| * Primary-secondary heat removal failures
| |
| * Accident sequences with loss of feedwater and/or SG dryout
| |
| * Likely to occur after core damage
| |
| * High SG tube surface temperatures
| |
| * Occur in sequences where creep-related failures of RCS piping and other pressure boundary failures are also likely to occur.
| |
| Once potential 1-SGTR scenarios were identified, the timing of the failure was estimated and compared to the timing of other sequence events such as containment failure and creep rupture.
| |
| For sequences where conditions characterizing either Pl-SGTR or Tl-SGTR occurred at or near the timing of a hot leg creep rupture or before containment failure, a potential 1-SGTR was identified. For conditions of 1-SGTR occurring later in the sequence, no probability of an 1-SGTR was assumed to occur. Because no actual tube ruptures occurred based on the MAAP calculations, a probability of occurrence (Pl_SGTR, Pl_SGTR_SBO and Tl_SGTR) was developed to account for the uncertainty in the. understanding of the phenomena and the application of the analyses [D.1-2].
| |
| The GET Top 1-SGTR represents success when no induced SGTR failure occurs. The failure branch, 1-SGTR, represents an early 1-SGTR that occurs and results in the release of FP. 1-SGTR are included in the Level 2 model under the gates named Tl-SGTR, Pl-NSGTR and Pl-SGTR_SBO.
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| Page D-30
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.2.1.6 DP Depressurization The CET Top DP represents the successful depressurization of the RCS to a pressure below the high pressure melt ejection (HPME) minimum of approximately 200 psig [D.1-11 ]. Successful depressurization allows for the operation of SI systems to initiate and aid in lowering the pressure in the RPV to below a pressure where HPME is not expected to occur (approximately 200 psig) prior to a vessel breach.
| |
| Several depressurization mechanisms are available and can be implemented in response to a Level 2 severe accident sequence including:
| |
| * Phenomena based on initiating events (IE)
| |
| * Creep rupture failure of the RCS
| |
| * Sequence-based depressurization IE Phenomena Certain initiating events result in the depressurization of the RCS to levels below the HPME minimum pressure of 200 psig. For WF3, initiating events that lead to depressurization include large, medium, and small break LOCA.
| |
| * DPL - The DPL gate represents a LOCA break scenario in combination with the other features of the accident progression that lead to successful depressurization of the RPV.
| |
| The #DP_LOCA flag has value of 1.0 and represents the inadvertent depressurization associated with a LOCA break.
| |
| * xDPL - The gate, xDPL, is included to address the potential for unsuccessful depressurization of the RPV as a result of the LOCA. The #NO_DP_LOCA flag has value of 1.0 and represents accident conditions in which a LOCA break is unsuccessful in providing depressurization in a timely manner.
| |
| Creep Rupture Another method by which RCS pressure may be reduced prior to RPV failure is by a thermally induced failure of an RCS hot leg. During core melt progression, heat is transferred throughout the RCS piping causing increased gas temperatures in the pipes. When surface temperatures in the piping reach temperatures consistent with failure properties of the metal, a pipe failure due to a thinning of the pipe wall can create an opening in the RCS pipe that acts to depressurize the RCS. RCS piping susceptible to creep failures include the hot legs and pressurizer surge lines.
| |
| The occurrence of a hot leg creep, as indicated by the Level 2 MAAP calculations, facilitates a mechanism by which the RCS begins to depressurize. Due to the small size of the creep rupture openings, a creep rupture alone is not always sufficient to reduce pressure levels to below 200 psig. However, the contribution of the hot leg ru.pture phenomena is accounted for in the progression of the accident sequence. The following gates are included for phenomena related to the occurrence of hot leg creep ruptures.
| |
| * #HLCREEP - The #HLCREEP gate represents the creep failure of a hot leg with the accompanied unintentional depressurization of the RCS prior to containment failure. This flag has a value of 1.0 and is represented by the flag event #HLCREEP.
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| Page D-31
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
| |
| * #NO_HLCREEP-The #NO_HLCREEP gate represents an intact hot leg with no creep damage failure and without any unintentional depressurization. This flag has a value of 1.0 and is represented by the flag event #NO~HLCREEP.
| |
| Sequence-Based Depressurization During the progression of Level 2 accident sequences, operating systems are available and operated to reduce the RCS pressure. Because success of these operating systems is required to the specific sequences, the success and failure of these systems to perform their depressurization functions and to achieve sufficient depressurization to below 200 psig is considered. These sequence-based depressurization operations include:
| |
| * PT01 - This gate models RCS pressure control via the pressurizer to adequately control RCS pressure using SRVs. The function is part of the sequence-specific success criteria and is applied to TRANS sequences that support depressurization of the RPV. The function for successful RCS pressure control is applied to sequences TB, TQX, TQB, and TQU [D.1-5] as part of the sequence definition.
| |
| * @PRAlWS - This gate models the failure of the PRVs to provide depressurization as required forthe AlWS sequence [D.1-12]. The function is part of the sequence-specific success criteria applied to A lWS sequences that aid in the depressurization of the RPV.
| |
| The function for successful operation of the PRVs is applied to sequences TKC, TKX, and TKW [D.1-12] as part of the sequence definition.
| |
| * SBORCPLOCA - This gate represents a leakage failure through the RCP seals. This is a sequence-based event that supports inadvertent depressurization due to RCP seal rupture for SBORCP accident sequences. For the Level 2 analyses, this function is included as part the SBORCP sequence definition under the gate SBORCP The Level 2 MAAP calculations evaluate the successful depressurization of the RPV. The CET Top DP success branch represents RPV depressurization to below the HPME minimum of 200 psig. Similarly, the failure branch represents the failure to adequately reduce RPV pressures.
| |
| However, Level 2 sequences may include the success operation of systems or other measures that provide depressurization, but these are ineffective in lowering the RPV below 200 psig.
| |
| D.1.2.1.7 REC - Reactor Pressure Vessel Reflood and Refill The REC CET Top represents successful SI injection to refill and maintain the RPV water level to ensure core cooling and to prevent vessel breach. Re-flooding of the RPV and maintaining a water level in the RPV serves to re-establish core cooling and to end the core melt progression and subsequent hydrogen generation (zirconium oxide and water reaction). A side effect of re-flooding of the core is the generation of significant amounts of steam that re-pressurize the RPV and re-start the zirconium-water reaction.
| |
| Successful RPV injection and core reflood is dependent upon the operation of the HPI or LPI systems to provide a source of water to provide in vessel cooling of the core, to retain the cerium in vessel, and maintain vessel integrity. For A lWS sequences, the successful injection of borated water into the RCS by the charging pumps is also considered as a potential injection source to refill the RPV. No other active systems or recovery actions are credited to supplement water levels in the RPV.
| |
| Results from the deterministic MAAP calculations were used to evaluate the success of the REC Page D-32
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage top. Successful core reflood is defined as restoration of the RPV water level to greater than 22 ft.
| |
| at the end of injection. This water level represents the elevation of the top of the active fuel within
| |
| =
| |
| the RPV (MAAP Parameter ZCRU 21.926 ft.).
| |
| Reflooding of the RPV to water levels less than 22.0 ft. is considered unsuccessful in the CET Trees despite the successful operation of injection systems. The in-vessel arrest of core melt in accidents that progress rapidly to core melt and/or lead to early core relocation may not be accomplished by SI injection. The timing of the RPV reflood must take place such that appreciable core relocation to the plenum is arrested [D.1-2].
| |
| The following tops are used to model the success and failure of the REC CET top.
| |
| * REC1
| |
| * REC2 For Level 2 accident sequences where no injection sources are credited, a successful REC Top is not considered in the event tree, and the sequence progresses to the next CET top on the down branch. Likewise, no consideration of RPV reflood and recovery is considered in the Level 2 model for these sequences.
| |
| REC1 The REC1 top models HPSI injection as a source of water for re-flooding the RPV. The use of this gate is specific to the success criteria associated with Level 2 accident sequences. Failures in the HPSI syste-m are modeled by the gate H1000 and would lead to a failure of vessel reflood and recovery. As a result, any failures of the system operations and components in the H1000 gate would subsequently result in the failure of the REC1 top. For Level 2 sequences where the HPSI system is credited for RPV re-flood, the REC1 gate is included under the sequence-specific accident sequences.
| |
| REC2 The REC2 top models emergency boration as an injection source for re-flooding of the RPV. The use of this gate is specific to the success criteria associated with Level 2 accident sequences and is used only for ATWS sequences. Failures in the emergency boration system would lead to a failure of vessel re-flood and recovery. For Level 2 accident sequences where emergency boration is credited for RPV re-flood, the REC2 gate is included under the sequence-specific accident sequences.
| |
| D.1.2.1.8 EXC - Ex-Vessel Cooling The EXC CET Top represents the contribution of outside factors to aid in the cooling of the RPV and subsequently the core and corium within the vessel. The contribution of these external cooling factors associated with the EXC CET Top is considered for sequences where internal cooling of the core and restoration of RPV water levels have been unsuccessful (REC). EXC is considered for sequences where RPV injection sources are not considered during the progression of the accident, as well as sequences where active injection sources have been unsuccessful in providing full reflood of the RPV.
| |
| Deterministic MAAP calculations are used to assess the success of the ex-vessel cooling on mitigating in vessel core melt and preventing rupture of the RPV. Successful ex-vessel cooling is defined as a water level in the reactor cavity sufficient to cover the lower head of the RPV. A dry reactor cavity allows for unmitigated heating of the corium to occur in the RPV due to a lack of Page D-33
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage cooling to the RPV. The presence of water in the cavity insulates the RPV and prevents the direct contact of the RPV with these hot gases. A minimum cavity water of 15.5' is defined as successful ex-vessel cooling. This elevation of water column in the cavity corresponds to the elevation of the
| |
| =
| |
| bottom of active fuei (MAAP Parameter ZCRL 9.428 ft.) above the bottom of the RPV (MAAP Parameter ZNVP =6.0 ft.). Maintenance of this water level in the RPV ensures that the lower head is submerged [D.1-2].
| |
| Successful EXC has been shown to occur in large LOCA sequences and in accident sequences with operating containment sprays for containment heat removal. Under these conditions, a large amount of water is being deposited into containment either through the break in the RCS piping or the containment spray headers. This water is conveyed through the floor drain system and ends up in the Containment Sump. With a minimum water level of 3.0 feet in the containment sump, leakage through the gaskets and under the marine access door provides a continuous source of water to fill the Reactor Cavity. Without the contribution from the operating containment sprays, water levels in the reactor cavity are insufficient to submerge the lower RPV head.
| |
| D.1.2.1.9 BURN - Hydrogen Burns in Containment Compartments Hydrogen combustion burns can cause large, rapid increases in pressure and high spikes in temperature that result in a combination of mechanical and thermal load with potential impact to containment integrity. The BURN CET Top assesses the containment compartment conditions that lead to the occurrence of hydrogen burns. With the presence of sufficient concentrations of hydrogen and at elevated temperature, localized burn and global burns have the potential to occur and result in challenges to containment. The success branch of the CET top xBURN represents conditions in the containment compartments that are insufficient to support and propagate hydrogen burns. Similarly, the down failure branch to CET BURN represents conditions conducive to facilitating hydrogen burns that challenge contail')ment and can lead to containment failure.
| |
| Burns that occur in the upper, annular, or upper RPV dome portions of the WF3 containment are considered to lead to containment failures due to the proximity of these containment compartments to the SCV. Burns that occur in other portions of the containment are not considered as events that will challenge containment or result in failure of containment.
| |
| During the progression of severe accident scenarios, several mechanisms have the potential to produce concentrations of hydrogen both in-vessel and ex-vessel. Some of these mechanisms that produce hydrogen include:
| |
| * Zircaloy oxidation
| |
| * Molten cerium-concrete interaction (MCCI)
| |
| * Steam Reactions with boron carbide, uranium, or steel
| |
| * Cerium debris Interactions Because hydrogen is a burnable gas in the presence of air, the WF3 large dry containment supports hydrogen burn scenarios.
| |
| In-Vessel When the reactor core uncovers, zirconium oxidation of the fuel cladding may occur when the cladding comes in contact with steam. Hydrogen is generated during this reaction and is produced at the onset of core damage. As core degradation continues, hydrogen continues to be Page D-34
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage generated as more cladding becomes exposed and the core begins to relocate. If reflooding and quenching of the relocated debris in the RPV occurs, the ziracloy oxidation increases, which in turn increases steam generation due to the cooling effect that also results in increased hydrogen generation. During severe accidents, the hydrogen generated and contained in the RPV can escape through openings in the RCS piping, RCP seal leaks, and lifting of safety and relief valves.
| |
| If large quantities of hydrogen are generated, hydrogen burns after in-vessel recovery could result in an early release of radionuclides that escaped the fuel during the initial heatup.
| |
| Ex-Vessel If the core degradation and relocation progress and a vessel rupture occurs, the cerium debris is ejected from the RPV and into cavity compartments contributing to hydrogen concentrations occurring outside of the vessel. At the point of vessel breach, the hydrogen contained in the vessel is released to the cavity and can migrate through containment. Also, as a result of the vessel breach, the cerium debris is ejected and deposited onto the concrete floor of the cavity.
| |
| This MCCI interaction between the concrete and the ejected core materials will lead to additional hydrogen generation as a result of concrete ablation. If quantities of water are present in the cavity, the rapid cooling of the ejected cerium debris in the water pool can result in large quantities of steam to be produced.
| |
| The concentration of steam present is an important factor in the potential occurrence of a hydrogen burn. The flammability limits of the two-component mixture (hydrogen:air) differ from the flammability limits of a three-component mixture (hydrogen:air:steam). The changes in flammability limits leads to steam inerting attributed to a' change in the dominant heat transfer pathway by combination of both convective and radiative mechanisms. In environments with moderate quantities of steam present, hydrogen burns can be precluded due the presence of the steam concentrations. Steam concentrations above which denotation can occur in the three-component mixture have been reported from 55% up to 75% for a steam mass fraction.
| |
| Deterministic MAAP calculations are used to assess the likelihood and occurrence of hydrogen burns in containment. Factors evaluated to assess hydrogen bums include the following:
| |
| * Concentration of hydrogen present in the containment atmosphere
| |
| * Steam concentration
| |
| * Operating containment heat removal systems - ignition source
| |
| * Ability for a Hydrogen burn to cause a containment failure Hydrogen Concentration Hydrogen gas has the potential to ignite in normal air concentrations at concentrations as low as 4% LEL (lower explosive limit) and up to concentrations of about 75% UEL (upper explosive limit).
| |
| These limits are based on the two-component mixture (hydrogen:air). These explosive limits are affected by the presence of steam concentrations as discussed below.
| |
| Steam Concentration Steam inerting due the presence of moderate to high mole concentrations of steam (a range in excess of 55% to 75%) have been shown to prevent hydrogen bums. The Level 2 MAAP calculations used the higher steam fraction of 75%. When steam concentrations exceed this concentration, no hydrogen burns are allowed. This represents an upper limit, which would conservatively allow for the likelihood of more hydrogen burns to occur.
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| Page D-35
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Containment Spray Systems The operation of the containment spray systems affect the localized and global distribution of hydrogen concentrations within the containment environment. The containment spray system
| |
| * introduces water droplets from the spray header located in the upper portion of containment. As the water droplets fall, steam condensation occurs on the surface of the droplet lowering the steam within containment and thereby the containment pressure. However, the reduction in the concentration of steam corresponds to an increase in hydrogen concentrations within Containment.
| |
| Burn Causes Containment Failure Hydrogen bums provide challenges to the integrity of containment, including both the thermal and pressure loads and spikes from the propagation of dynamic pressure pulses. This phenomena is not modeled specifically in the MAAP code used for the deterministic Level 2 MAAP calculations.
| |
| However, for the CET BURN tops, hydrogen burns occurring in the upper, annular, or upper RPV dome portions of the WF3 containment were considered to have the potential to lead to a containment failure given the presence of an ignition source. If AC power is available in the containment, which is required for the operation of the containment heat removal systems, many potential sources of ignition will be present and an ignition source is almost assured.
| |
| D.1.2.1.10 CFE - Containment Failure Early Early containment failures are failures that occur concurrent with or shortly after the RPV has ruptured. The timing of these failures are based on time of less than 4 hours between vessel rupture and containment failure. The CFE CET Top assesses the Level 2 accident progression and containment compartment conditions that lead to the occurrence of an early containment failure. The success branch of the CET Top xCFE represents an intact early containment status.
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| Similarly, the down failure branch to the CET Top CFE represents a containment status where failure has occurred early.
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| Based on the characteristics and capacity of the WF3 containment, the following forms of early containment failure mechanisms were considered and evaluated as part of the Level 2 analysis.
| |
| * Hydrogen Burns
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| * Direct Containment Heating (OCH)
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| * Containment Penetration Isolation Failure
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| * Mechanical integrity Failures
| |
| * Steam Explosions Hydrogen Burns As discussed in D.1.2.1.9 and considered in the CET Top BURN, hydrogen burns present challenges to containment stemming from high thermal and pressure loads and the propagation of dynamic pressure pulses. As a result, hydrogen bums occurring in the upper, annular, or upper RPV dome portions of the WF3 containment are considered to have the potential to lead to a containment failure. Based on the timing of the containment burns, these containment failures may present an early containment challenge.
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| Direct Containment Heating Direct containment heating of the RPV vessel has the potential to lead to an early containment
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| "' -
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| Page D-36
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage failure. In the event of a high pressure ejection of molten cerium from the RPV breach, the potential exists for fragmented core to travel to outside of the cavity to other areas of containment. Oxidation of these fragmented cerium particles may produce significant quantities of heat and hydrogen that can challenge containment. The combination of the RPV breach and containment failure provides significant impact to health and safety due to the early timing of the release and the short residence time in containment to aid in the retention of the fission products.
| |
| Mechanical Integrity Failures Mechanical integrity failures of containment can occur in a number of ways. When a catastrophic vessel breach occurs (initiating event %V), the potential exists for the vessel or pieces of the vessel to become airborne or otherwise dislodged. The uplifting of the vessel structure and/or generation of missiles is likely to result in damage to the containment and/or cavity structure.
| |
| Steam Explosions An in-vessel steam explosion in the RPV can occur when a large amount of cerium relocates to the lower plenum where it comes in contact with water in the lower head. This encounter with water in the lower head can result in an in vessel explosive steam explosion which may lead to an induced lower head failure or may cause internal RPV structure to be thrust upwards inducing an upper head failure. Due to the energy of these failures, it is likely to result in damage to the containment and/or cavity structure.
| |
| CFE2 The CFE2 gate is used to model an early containment failure with a given vessel breach. During the vessel breach, the core melt is ejected into the cavity bottom. If the cavity conditions are such that a pool of water has collected, the rapid cooling of the ejected core materials generates large quantities of steam. The WF3 cavity design does permit the.conveyance and collection of the water within the cavity. Based on the L2 MAAP deterministic calculations, an early containment failure occurs as a result of the ejection of the core melt, which causes a rapid formation of steam that leads to containment over-pressurization. Without the operation of containment fans, the cooling and condensation of the steam is limited, and containment pressures increases. Upon reaching the ultimate containment capacity, containment fails.
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| Based on the Level 2 MAAP deterministic results, early containment failures only occur in sequences where both forms of containment heat removal fail to operate. The consideration of this CET Top is only addressed in the CET H event tree.
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| D.1.2.1.11 VB Vessel Breach The VB CET Top represents the conditions within the RPV where significant core degradation has occurred such that the integrity of the reactor pressure vessel has been challenged with a subsequent RPV breach. The fundamental process controlling RPV integrity is the heat removal and cooling of the molten cerium pool within the RPV. The success VB branch (No_VB) in the CETs occurs with sequences where RPV injection source are available and operating (REC) or when sources of water are available in sufficient quantities to support external cooling of the vessel (EXC). The failure VB branch (VB) in the CET considers the remaining sequences where core and vessel cooling mechanisms are unavailable or ineffective. These sequences have a likelihood of leading to extensive rupture of the vessel given the degree of core degradation and Page D-37
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage in-vessel geometry of the core debris.
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| For the accident sequences where in-vessel and ex-vessel cooling actions have not been successful, the core melt has progressed to the lower plenum and subsequently to the RPV bottom. At this point, the melt-vessel interface is the contact point at which the cerium melt and the RPV material interact. The RPV lower head is subjected to the internal system pressure, thermal loads from the cerium melt, and dead loads associated with the relocation of the cerium.
| |
| These factors challenge the mechanical integrity of the RPV and lead the way for creep rupture of the RPV material to occur. Creep of RPV materials occurs at temperatures above 600 °C (1100 OF).
| |
| The VB CET top considers the following vessel breach mechanisms for the WF3 Level 2:
| |
| * Catastrophic Vessel Breach
| |
| * Lower Head Failure Mechanism Catastrophic Vessel Breach Catastrophic vessel ruptures are characterized as an unrecoverable vessel failure. Scenarios such as in-vessel steam explosion or vessel failure due to internal relocation of loads are considered as catastrophic failures.
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| Lower Head Failure Mechanisms Mechanisms for lower head vessel breach include the following:
| |
| * Heat up and/or Failure of Instrument Tubes, CRD Tubes, and Drain Line
| |
| * Ejection of Instrument Tubes, CRD Tubes, and Drain Line (not applicable)
| |
| * Jet ablation of the vessel wall ,
| |
| * Attack of wall by overlaying steel
| |
| * Creep rupture Because the RPV lower head has no penetrations, the tube ejections and failures are not applicable to the WF3 vessel breach evaluation. The primary mechanism for the vessel breach failure is an extensive creep rupture. A creep rupture represents the long-term exposure of the RPV materials to temperature and pressures that result in thermal stresses that cause thinning of the material wails.
| |
| '
| |
| Deterministic MAAP calculations were used to evaluate the RPV integrity for the Level 2 sequences. The MAAP analysis considers vessel failure mechanisms and accounts for a layered lower debris bed model. Creep rupture fractions in the lower head were used to determine the status of the RPV vessel. Failure to maintain an intact VB was determined to be a lower head creep damage fraction in a single node that exceeds 0.4. Creep damage fractions in excess of 0.4 lead to failure of the RPV.
| |
| Based on the Level 2 MAAP calculations, a breach of the WF3 vessel only occurs with no containment-heat removal systems operating. As a result, the VB CET Top is only addressed in the CET H event tree.
| |
| D.1.2.1.12 CAV - Cavity Status The CAV CET Top represents the status of the reactor cavity at the time of vessel breach. A wet cavity has a sufficient quantity of water to receive the cerium ejected during the vessel breach and mitigate the transport of materials to other areas outside of containment. A dry cavity cannot fully submerge to ejected cerium debris and is thus limited in potential to capture and retain the cerium Page D-38
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage within the cavity.
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| Successful CAV requires the operation of the containment sprays. Under these conditions, spray water is deposited into containment via the containment spray headers. Some of this water is conveyed through the floor drain system and ends up in the Containment Sump. With a minimum water level in the containment sump, leakage through the gaskets and under the marine access door provides a continuous source of water to fill the Reactor ~avity. Without the contribution from the operating containment sprays, water levels in the reactor cavity are insufficient to submerge the lower RPV head.
| |
| Results from the deterministic MMP calculations were used to evaluate the success of the CET Top CAV. A wet cavity is defined as a cavity water level greaterthan 6 ft. (MMP Parameter ZNVP) at the time of vessel breach. Maintenance of this water level in the RPV will provide a wet cavity in the event of an ejection of corium debris for the purpose of capturing and mitigating the dispersion of these materials to other areas of within containment. The CET Top CAV is considered following a VB and is included on the VB failure branch of the CET H event tree.
| |
| D.1.2.1.13 BMT - Bas'emat Melt Through The BMT CET Top represents the status of the corium debris released from the RPV during VB that is ejected and received in the reactor cavity. The loads released from the RPV can fail containment due to thermal attacks of corium melt on the concrete basemat. This attack by the corium melt can lead to basemat concrete erosion and generation of hydrogen gas and steam which can pressurize containment. Because of the high energies and heat associated with the corium debris, the potential exists for the ejected material to become a long-term source of FP for release.
| |
| Factors that affect the retention and stabilization of the corium debris include the quantities of material released, the pressure of the RPV at the time of release, and the mechanisms in place to provide cooling or retention of the released corium. The amount of material released to the cavity and the cavity geometry determines the initial depth of the corium. Debris beds with depths greater than 25 cm are considered uncoolable and represent a failure to arrest ex-vessel corium melt [D.1-11]. The failure to arrest the corium debris melt in the cavity can lead to a breach of containment through the lower basemat.
| |
| An unmitigated core melt on the cavity floor can result in a failure of the basemat. The basemat concrete depth on the floor of the cavity is 12.0 feet thick. A depth of erosion greater than 12.0 feet would have the potential to fail the basemat. In addition, corium spread to the cavity tunnel has the potential to. fail the marine access door that separates the cavity tunnel from the Containment Sump. Failures to the access door could result from the degradation of the gasket seal material or deformation of the door steel plate. However, due to the uncertainty and unknowns associated with basemat melt scenarios, unquenched corium pools with increasing erosion depths are assumed to lead to containment breach based on basemat melt-through.
| |
| Debris depths following vessel breach were used to evaluate and determine the ability to cease the ex-vessel corium melt based on the deterministic MMP calculations. The success branch of the CET top BMT represents a debris depth in the cavity of less than 25 cm (0.82 ft) where cooling and stabilization of the corium debris spread is still possible. Similarly, the down failure branch to the CET Top (xBMT) represents a debris depth in the cavity of more than 25 cm. The BMT CET Top is considered following VB and is included on the VB failure branch of the CET H event tree.
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| Page D-39
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.2.1.14 CFL - Late Containment Failure Late containment failures are failures of the containment as a result of a vessel breach as well as challenges other than those associated with a breach of the RPV. The timing of these containment failures are based on times of greater than 4 hours from the time of core damage to the time of containment failure. The CET Top CFL assesses the Level 2 accident progression and containment compartment conditions that lead to the occurrence of a late containment failure.
| |
| The success branch of the CET Top (xCFL) represents an intact late containment status given no early containment failure has occurred. Similarly, the down failure branch to the CET Top CFL represents a containment status where failure has occurred late.
| |
| Based on the characteristics and capacity of the WF3 containment, the following forms of late containment failure mechanisms were considered and evaluated as part of the Level 2 analysis.
| |
| * Hydrogen Burns
| |
| * Containment Over-pressurization above the Ultimate Containment Capacity Hydrogen Burns As discussed in Section D.1.2.1.9 and considered in the CET Top BURN, hydrogen burns present challenges to containment stemming from high thermal and pressure loads and the propagation of dynamic pressure pulses. As a result, hydrogen burns occurring in the upper, annular or upper RPV dome portions of the WF3 containment are considered to have the potential to lead to a containment failure. Based on the timing of the containment burns, these containment failures may present an early or late containment challenge. Late containment challenges are considered in the CFL CET Top.
| |
| Containment Over-Pressurization During the progression of severe accident sequences, mechanisms generate quantities of steam as a result of the heating and oxidation of the core materials, the introduction of sources of cooling water, and the lifting of safety and relief valves. These quantities of steam contribute to a buildup of pressure in containment. At pressures in excess of the containment capacity, containment fails and releases FP outside of containment to the environment.
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| For Level 2 accident sequences where an early containment failure occurs, the CET Top CFL is not considered in the event tree. A successful CFL Top, xCFL, represents an intact containment.
| |
| A late containment failure is represented on the failure branch of the CET Top CFL branch. The following gates are used to model the failure of the CET Top CFL.
| |
| * CFL2
| |
| * CFL3
| |
| * CFL4
| |
| * CFLS CFL2 The CFL2 gate is used to model a late containment failure with a vessel breach. Based on the L2 MAAP deterministic calculations, vessel breaches can occur when both containment spray and containment cooling fans fail to operate. As a result, the CFL2 can only occur without the operation of containment heat removal systems fans. Under these conditions, containment pressures increase due to increasing steam concentration from both the release of hydrogen Page D-40
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage from the RPV and the ex-vessel cerium melt, as well as the pressure increases associated with long-term buildup of steam due to no containment heat removal.
| |
| CFL3 The CFL3 CET Top models a late containment failure due to over-pressurization. For these sequences, the RPV remains intact, but the containment pressure is slowly allowed to increase in containment due to the failure of containment fans to operate. Once the containment pressure in one of the containment compartments - annular, upper dome or upper RPV head - exceeds the containment capacity of 99.3 psig, a rupture in containment occurs and release of FP begins.
| |
| CFL4 The CFL4 CET Top is used to model a late containment failure due to a hydrogen burn. Based on the L2 MAAP deterministic calculations, a late containment failure due to a hydrogen burn can occur when containment cooling fans operate. Without the operation of containment fans, steam concentrations increase rapidly to levels where steam inerting inhibits hydrogen burns.
| |
| CFL5 The CFL5 CET Top is used to model containment isolation failures that have the potential to occur as a result of high temperatures (T-CIF) inside of containment. Temperatures in containment in excess of 600 °F are considered in the Level 2 analysis based on the FEA analyses performed to evaluate the ultimate containment capacity [D.1-13]. The containment over pressurization at 600 °F was determined to be 104 psi. Using this over pressurization value, a probability of occurrence corresponds to 0.601.
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| Page D-41
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| Waterford Steam Electric Stati1 t3 Applicant's Environmental Report Operating License Renewal Stage Figure D.1-1 WF3 Radionuclide Release Category Summary Other 0.03% _ _ _~
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| M/L 0.18%
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| 1.28% 0.26%
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| Page D-42
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-4 Correlation of Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Large Early Release Frequency)
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| Event Name Probability RRW Event Description Disposition EARLY CONTAINMENT FAILURE WITH VESSEL
| |
| #CFE2 1.00E+OO 5.3337 FAILURE Thi s term is a flag . No SAMAs need to be aligned .
| |
| CHR SEQUENCE MARKER B - Both Sprays and Fans are
| |
| #CHR B 1.00E+OO 1.0683 available and operate rrhis term is a flag . No SAMAs need to be aligned .
| |
| CHR_ H - Neither Sprays nor Fans are available
| |
| #CHR H 1.00E+OO 5.5758 or successfully operate This term is a flag . No SAMAs need to be aligned .
| |
| HOT LEG CREEP
| |
| #HLCREEP 1.00E+OO 5.3337 RUPTURE OCCURS !This term is a flag . No SAMAs need to be aligned .
| |
| PRESURE INDUCED STEAM GENERATOR TUBE RUPTURE - NON
| |
| #Pl -SGTR 1.00E+OO 1.0086 SBO !This term is a flag . No SAMAs need to be aligned .
| |
| PRESURE INDUCED STEAM GENERATOR
| |
| #P l-SGTR-SBO 1.00E+OO 1.1052 TUBE RUPTURE - SBO !This term is a flag. No SAMAS need to be aligne d.
| |
| THERMALLY INDUCED STEAM GENERATOR TUBE RUPTURE - NON
| |
| #Tl -SGTR 1.00E+OO 1.0073 SBO This term is a flag. No SAMAs need to be aligned.
| |
| #V 1.00E+OO 1.0173 V Sequence Marker This term is a flag. No SAMAs need to be aligned .
| |
| D-43
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| | |
| (
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| Waterford Steam Electric S1.;tmm Unit 3 Applicant's Environmental Report Operating License Renewal Stage
| |
| *. ' *' .. 'Table D.1-4. '* '
| |
| * ..
| |
| :
| |
| J!
| |
| .. LeV:~12 *Risk *significan.t Term~ to Evaluated SAMAs (Based on Correlation of
| |
| ' ,'
| |
| .. .
| |
| .:* ' ,' '
| |
| ._.
| |
| ' *
| |
| * Large** Early.Release Frequency)
| |
| ,,* <
| |
| * I 1
| |
| .Event Name
| |
| ..
| |
| **.* l *probability I ~RV)f
| |
| * j Ev~nt Descr:iption'. !
| |
| ;.
| |
| .El is position .. !I NO LOWER HEAD I, FAILURE OFRPV- NO I CREEP RUPTURE MAAP
| |
| #X_VB 1.00E+OO 5~3337 ANALYSES This term is a flag. No SAMAs need to be aligned. 1!
| |
| This term represents a loss of the CCW system. Phase II SAMAs !
| |
| 8, 9, 20, 23, and 27 to decrease the importance of and enhance
| |
| * the availability and reliability of the CCW system to provide
| |
| %T9 1.75E-05 1.0237 Loss of CCW System cooling water were evaluated. I This term represents a reactor vessel rupture initiator. Phase II Reactor Vessel Rupture SAMA 44 to create a large concrete crucible with heat removal
| |
| %V 3.20E-08 1.0173 Initiator potential to contain molten core debris was evaluated. i CHR- FAIL 1.00E+OO 1.0251 CHR Flag This term is a flag. No SAMAs need to be aligned.
| |
| I EA2 SBO 1.00E+OO 1.1348 SBO Flag This term .is a flag. No SAMAs need to be aligned. ~
| |
| EA3_SBO 1.00E+OO 1.1358 SBO Flag This term is a flag. No SAMAs need to be aligned. I EB2 SBO 1.00E+OO 1.1382 SBO Flag This term is a flag. No SAMAs need to be aligned.
| |
| EB3_SBO 1.00E+OO 9.3555 SBO Flag This term is a flag. No SAMAs need to be aligned.
| |
| Thi_s term represents a conditional LOSP given SIAS signal after a plant trip. Phase II SAMAs 6 and 10 for improving offsite Conditional LOSP given power reliability; SAMAs 5 and 7 for increased availability of SIAS signal after a plant on-site AC power; and SAMAs 8, 9, and 11 for increasing diesel !
| |
| LOSP-ECCS 1.00E-02 1.0184 trip generator availability were evaluated. I Page D-44
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
| |
| - -- .. -.
| |
| *- table D.14 _.- _
| |
| *" '
| |
| I'
| |
| .
| |
| Correlation
| |
| *,
| |
| ''
| |
| oi'-evel 2 Risk Significant Terms to Evaluated.$AMAs
| |
| .
| |
| ' . '
| |
| (Based oh large Early Release Frequency)' !
| |
| *Event Name, 1..Probability j *RRW __ I E_vent.Description I Disposition li
| |
| !This term represents a failure of a human action to initiate cooldown of the RCS following a steam generator tube rupture (SGTR). Phase II SAMA 57 for eliminating a release pathway to Failure to initiate the environment following a SGTR; SAMAs 58, 59, 60, and 61 cooldown of the RCS for reducing the consequences of a SGTR; and SAMA 56 for OHFSGTRCDP 1.00E+OO 1.0212 following a SGTR reducing the frequency of SGTRs were evaluated.
| |
| [This term represents a failure of a human action to blowdown the steam generator to prevent overfilling the affected Failure to blowdown generator. Phase II SAMA 57 for eliminating a release steam generator to pathway to the environment following a SGTR; SAMAs 58, 59, prevent overfilling 60, and 61 for reducing the consequences of a SGTR; and SAMA*
| |
| PHFSGTRBDP 1.00E+OO 1.0069 affected generator 56 for reducing the frequency of SGTRs were evaluated. I n-his term represents a pressure induced steam generator tube rupture without a SBO. Phase II SAMA 57 for eliminating a release pathway to the environment following a SGTR; SAMAs 58, 59, 60, and 61 for reducing the consequences of a SGTR; Pl-SGTR NON-SBO and SAMA 56 for reducing the frequency of SGTRs were '
| |
| Pl SGTR 4.80E-03 1.0086 FAILURE OCCURS evaluated.
| |
| This term represents a pressure induced steam generator tube rupture with a SBO. Phase II SAMA 57 for eliminating a release pathway to the environment following a SGTR; SAMAs 58, 59,
| |
| . Pl-SGTR SBO FAILURE 60, and 61 for reducing the consequences of a SGTR; and SAMA Pl_SGTR_SBO 4.41E-03 1.1052 OCCURS 56 for reducing the frequency of SGTRs were evaluated.
| |
| PROBABILITY THAT I VESSEL BREACH FAILS i P FCONTVB 9.90E-Ol 5.3337 CONTAINMENT This term is a split fraction. No SAMAs need to be aligned.
| |
| i I ' D-45
| |
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| Waterford Steam Electric Static~ Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-4 Correlation of Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Large Early Release Frequency)
| |
| Event Name I Probability I RRW I Event Description I Disposition I AB charging pump is assigned to emergency RABCVCASA 5.00E-01 1.0142 start in place of A rrhis term is a flag. No SAMAs need to be aligned.
| |
| AB Charging pump is assigned to emergency RABCVCASB 5.00E-01 1.0123 start in place of B h'"his term is a flag. No SAMAs need to be aligned.
| |
| Weighting factor for likelihood that SGTR RSGTRONSGl 5.00E-01 1.0285 happens in SGl This term is a flag. No SAMAs need to be aligned.
| |
| Weighting factor for likelihood that SGTR '
| |
| RSGTRONSG2 5.00E-01 1.0285 happens in SG2 This term is a flag. No SAMAs need to be aligned.
| |
| This term represents a thermally induced steam generator tube Tl-SGTR - INTACT rupture. Phase II SAMA 54 to modify procedures such that the CONTAINMENT OR water loop seals in the reactor cooling system (RCS} cold legs Tl_SGTR 3.19E-02 1.0073 BEFORE VB are not cleared following core damage was evaluated.
| |
| NO LOWER HEAD FAILURE OF RPV - NO CREEP RUPTURE MAAP X_VB 9.90E-01 5.3337 ANALYSES This term is a split fraction. No SAMAs need to be aligned.
| |
| This term represents a failure of a human action to blowdown i the steam generator to prevent overfilling the affected Failure to use steam generator. Phase II SAMA 57 for eliminating a release generator blowdown pathway to the environment following a SGTR; SAMAs 58, 59, to prevent overfilling 60, and 61 for reducing the consequences of a SGTR; and SAMA.
| |
| ZHFSGTRBDP 2.70E-02 1.0068 affected S/G 56 for reducing the frequency of SGTRs were evaluated. !
| |
| Page D-46
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-4 II Correlation of Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Large Early Release Frequency) II I
| |
| Event Name I Probability I RRW j Event Description I Disposition l This term represents a failure of a human action to initiate i cooldown of the RCS following a steam generator tube rupture (SGTR). Phase II SAMA 57 for eliminating a release pathway to Failure to initiate the environment following a SGTR; SAMAs 58, 59, 60, and 61 cooldown of the RCS for reducing the consequences of a SGTR; and SAMA 56 for ZHFSGTRCDP 1.80E-05 1.0202 following a SGTR reducing the frequency of SGTRs were evaluated.
| |
| This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for increased availability of on-site LOOP Recovery with AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP CSP 6.30E-02 1.0109 CSP Depletion generator availability were evaluated.
| |
| This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power LERF LOOP Recovery reliability; SAMAs 5 and 7 for increased availability of on-site with Batt Depl and 0 AC power; and SAMAs 8 and 9 for increasing diesel generator ZLOOP _LERF _RF _BO 9.15E-01 1.0541 Run Fail availability were evaluated.
| |
| This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power LERF LOOP Recovery reliability; SAMAs 5 and 7 for increased availability of on-site with Batt Depl and 1 AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP _LERF _RF _Bl 9.59E-01 1.0344 Run Fail generator availability were evaluated.
| |
| Note: Basic events that are correlated in Table D.1-2 are not listed again in Table D..1-4 if they are equivalent basic events .
| |
| . D-47
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage TableD.1".s
| |
| '
| |
| Correlation Qf ~e'(el 2. Risk Significant, Terms to Evaluated*SAMAs (Based on Lewd 2*Release Frequency}'
| |
| ... *' .
| |
| *~* ~ ~ . ' ... '
| |
| l;verit Name RRW l Event De.scripti9n J Disposition WATER LEVEL IN CAVITY BELOW BOTIQM OF RPV [> 6
| |
| #CAV 1.00E+OO 3.2723 FT] This term is a flag. No SAMAs need to be aligned.
| |
| LATE CONTAINMENT FAILURE WITH VESSEL f#CFL2 1.00E+OO 1.3031 BREACH This term is a flag. No SAMAs need to be aligned.
| |
| LATE CONTAINMENT FAILURE DUE TO LOSS OF CONTAINMENT
| |
| #CFL3 1.00E+OO 1.0227 FANS This term is a flag. No SAMAs need to be aligned.
| |
| FAILURE OF EX VESSEL SYSTEMS TO MAINTAIN ADEQUATE
| |
| #CS_UNAVAIL 1.00E+OO 3.4,449 WATER LEVELS This term is a flag. No SAMAs need to be aligned.
| |
| LOCA DEPRESSURIZATION
| |
| #DP _LOCA 1.00E+OO 1.0223 OCCURS This term is a flag. No SAMAs need to be aligned.
| |
| #TQU 1.00E+OO 1.0386 TQU Sequence Marker This term isa flag. No SAMAs need to be aligned.
| |
| RPS VESSEL HAS BEEN
| |
| #VB 1.00E+OO 3.2723 BREACHED This term is a flag. No SAMAs. need to be aligned.
| |
| CONTAINMENT FAILURE - DUE TO This term represents containment failure due to concrete CONCRETE EROSION erosion of the basemat. Phase II SAMAs 44 and 46 to reduce BMT 1.00E-02 1.0062 OF BASEMAT the probability of basemat melt-through were evaluated.
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| Page D-48
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-5 Correlation o.f Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Level 2 Release Frequency)
| |
| Event Name l Probability I RRW I Event Description I Disposition I FAILURE TO MANUALLY RECOVER This term represents a failure of a human action to manually COOLING FANS TO recover cooling fans to prevent late failure. Currently this is a GHFFANM 1.00E+OO 3.4536 PREVENT LATE FAILURE flag and no SAMAs need to be aligned.
| |
| NO BASEMAT FAILURE DUE TO CONCRETE X BMT 9.90E-01 3.2081 EROSION This term is a split fraction. No SAMAs need to be aligned.
| |
| This term represents a failure to recover offsite power when LERF LOOP lost. Phase II SAMAs 6 and 10 for improving offsite power Non-Recovery with reliability; SAMAs 5 and 7 for increased availability of on-site Batt Depl and 0 Run AC power; and SAMAs 8 and 9 for increasing diesel generator ZLOOP - LERF- NRF- BO 8.47E-02 1.4337 Fail availability were evaluated.
| |
| This term represents a failure to recover offsite power when LERF LOOP lost. Phase II SAMAs 6 and 10 for improving offsite power Non-Recovery with reliability; SAMAs 5 and 7 for increased availability of on-site Batt Depl and 0 Run AC power; and SAMAs 8 and 9 for increasing diesel generator ZLOOP_LERF_NRF _BONL 1.35E-01 1.0362 Fail {No Load Shed) availability were evaluated.
| |
| This term represents a failure to recover offsite power when LERF LOOP lost. Phase II SAMAs 6 and 10 for improving offsite power Non-Recovery with reliability; SAMAs 5 and 7 for increased availability of on-site Batt Depl and 1 Run AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP- LERF- NRF- Bl 4.06E-02 1.0984 Fail generator availability were evaluated.
| |
| This term represents a failure to recover offsite power when LERF LOOP . lost. Phase II SAMAs 6 and 10 for improving offsite power Non-Recovery with reliability; SAMAs 5 and 7 for increased availability of on-site Batt Depl and 1 Run AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP - LERF- NRF- B1NL 5.27E-02 1.0083 Fail {No Load Shed) generator availability were evaluated.
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| D-49
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| | |
| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-5
| |
| <'
| |
| Correlation of Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Level 2 Release Frequency)
| |
| Event Name I Probability I RRW I Event Description j Disposition I This term represents a failure to recover offsite power when LERF LOOP lost. Phase II SAMAs 6 and 10 for improving offsite power Non-Recovery with reliability; SAMAs 5 and 7 for increased availability of on-site Batt Depl and 2 or AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP_LERF _NRF _B2 3.18E-02 1.006 more Run Fail generator availability were evaluated.
| |
| This term represents a failure to recover offsite power when LERF LOOP lost. Phase II SAMAs 6 and 10 for improving offsite power Non-Recovery without reliability; SAMAs 5 and 7 for increased availability of on-site Batt Depl and 1 Run AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP_LERF _NRF_Dl 9.SOE-02 1.0107 Fail generator availability were evaluated.
| |
| This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for increased availability of on-site LERF LOOP Recovery AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP_LERF _RF _CSP 9.42E-01 l.0094 with CSP Depletion generator availability were evaluated.
| |
| This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power i LERF LOOP Recovery reliability; SAMAs 5 and 7 for increased availability of on-site without Batt Depl and AC power; and SAMAs 8, 9, and 11 for increasing diesel '
| |
| ZLOOP_LERF_RF _Dl 9.0SE-01 1.0058 1 Run Fail generator availability were evaluated. I Note: Basic events that are correlated m Tables 0.1-2 and 0.1-4 are not hsted agam m Table 0.1-5 1f they are equivalent basic events.
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| Page D-50
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License "Renewal Stage D.1.2.2 Radionuclide Analysis D.1.2.2.1 Introduction The goal of the radionuclide release characterization is to capture and collect accident scenarios resulting in releases from containment in a manner that best represents potential outcomes to public health consequences.
| |
| By using the end states of the CET, the progression of each accident sequence is passed through the CET to an end state. Associated with each of these end states is an accident release scenario that is characterized by the mechanism by which FPs are released outside of containment, the magnitude of FP release, and the timing of the release mechanism. The nature of the radioactive release categories is such that the spectrum of severe accidents is divided up into bins that represent a group with similar public health consequences. However, the determination of these public health consequences can be affected by a number of factors that impact the characterization of the radionuclide characterization.
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| The main characteristics of the containment end states for consideration in the development of the radionuclide release categories are shown below and are discussed in the following sections.
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| * Containment Failure Mechanism
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| * Timing of The Release
| |
| * Magnitude of the Release D.1.2.2.2 Containment Failure Mechanism The containment failure mechanism by which the FP releases occur affects the magnitude of the release and are considered in the classification of radionuclide releases. Factors for consideration regarding *the containment failure pathways include:
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| * Size of the Containment Breach
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| - Containment Failure
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| - SGTR
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| - Containment Isolation
| |
| * Location of Containment Breach The size of the containment breach is dictated by the specific accident sequence and the type of breach. The relative size of the outside opening in the RCB can determine the ability and capacity of the RCB to retain and contain FP from being released.
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| A containment failure represents a catastrophic rupture of the containment vessel based on exceeding the ultimate containment capacity.
| |
| SGTR releases bypass containment and are directly released outside of the RCB. The size of this containment breach is consistent with the break size of a single SG tube. However, no retention time exists to retain FP prior to release, and scrubbing of the releases can only occur if the tube break is below the SG water level.
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| Failure of containment isolation systems to operate are defined as 2.25-inches or greater in size.
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| Page D-51
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Cl failures also provide a direct release of FP outside of containment. However, FP must travel through containment prior to release, allowing for natural deposition and gravitational settling mechanisms to attenuate the FP releases.
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| Similarly, the location of the containment failure breach plays a role in reducing the FP released.
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| The distance the FP must travel inside of containment to the point of release can reduce the magnitude of radionuclides reduced. For containment failures, the release point was determined to be the escape hatch located in the lower portion of the annular compartment based on the finite element analysis of the WF3 containment [D.1-13].
| |
| D.1.2.2.3 Timing of Release Release timing of the accident sequences are based on a number of considerations including the timing of the containment release against the implementation of plant responses actions to control and contain the release. Of equal importance to the determination of release timings is the timing of notification to the public to ensure adequate warning for implementation of protective actions, such as evacuation.
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| The WF3 Emergency Plan identified four classes of Emergencies: Unusual Event, Alert, Site Area Emergency and General Emergency. Issuance of a General Emergency is made based on core degradation with a potential challenge to containment integrity and requires the initiation of predetermined protective actions for the public. The WF3 plant maintains a readiness level to declare an emergency within 15 minutes of indication showing exceedance of an emergency action level [D.1-14].
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| In consideration of response times, the Emergency Plan provides the conditions for deriving accident response times. A Category F accident, characterized as degraded FP barrier, requires the loss of two barriers with a potential loss of the third barrier for declaration of a WF3 General Emergency.
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| With regard to characterization of release timing, the indication timing of the second FP barrier would indicate the beginning of the emergency action timing. The timing to the failure of the third FP barrier would indicate the timing of the accident release.
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| An evacuation study was performed for WF3 to evaluate evacuation time estimates (ETE) under varied conditions. These ETEs address mobilization times and voluntary evacuations of the permanent residents and the shadow population in the Emergency Planning Zone (EPZ). The time to clear 90% of the affected population in the EPZ boundary under worst case conditions is 3 hours and 45 minutes [D.1-15]. An evacuation from WF3 would be considered to be complete within 4 hours from the start of the evacuation, which accounts for the 15 minute timing to declare the General Emergency and the worst-case ETE. This evaluation is used to characterize "early" radionuclide releases as any release initiated less than four (4) hours following the declaration of a General Emergency, which would not allow the population in the EPZ to evacuate Jn time.
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| The following timing categories were used for the Level 2 radionuclide release classification.
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| Release timings used in the Level 2 are based on the actual accident scenario timing (failure of the FP barriers) as determined by the MAAP calculations and include MAAP timing to core damage, vessel breach, containment failure, low SG water level and high containment pressure, as calculated in the MAAP calculation spreadsheets.
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| Page D-52
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-6 Release Timing Classification Time of Initial Release Classification Classification Relative to Time for General Abbreviation Category Emergency Declaration E Early Time< 4 hours I Intermediate 4 to 24 hours L Late > 24 hours D.1.2.2.4 Magnitude of Release The source term values were determined from the deterministic Level 2 sequence calculations using the MMP code. MMP results were used to classify the magnitude of the FP releases for each Level 2 accident sequence. Because sequence-specific data was obtained for every sequence, no estimation of FP releases was required for the Level 2 analysis. Each source term is characterized by a set of release fractions quantifying the releases *Of those FP of interest because of possible deleterious effects to humans and the environment. Based on a review of the MMP results, the following classification was selected to characterize the severity of the radionuclide releases based on the fraction of cesium iodide (Csl) released.
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| Table D.1-7 WF3 Release Categories Classification Classification Cs Iodide % in Abbreviation Category Release H High Csl > 10%
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| M Moderate 1-10%
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| L Low 0.1-1 %
| |
| LL Low-Low << 0.1 %
| |
| Negligible Intact 0 D.1.2.2.5 Release Category Bin Assignments The combination of the timing and magnitude of release categories results in 12 different release categories with an additional intact category as shown in Table D.1-8. The actual magnitude of the release for each Level 2 scenario was evaluated to the maximum release fraction of Csl over the duration of the run as found in the MMP results.
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| Page D-53
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-8 WF3 Release Categories Identifier Description Definition Intact Containment Intact Nominal leakage rate.
| |
| Intact H-E High - Early Release Category Csl > 10%
| |
| Release Time < 4 hours M-E Moderate - Early Release Category Csl: 1 - 10%
| |
| Release Time < 4 hours L-E Low - Early Release Category Csl:0.1-1%
| |
| Release Time < 4 hours LL-E Low Low - Early Release Category Csl << 0.1%
| |
| Release Time < 4 hours H-1 High- Intermediate Release Category Csl > 10%
| |
| Release Time: 4 - 24 hours M-1 Medium- Intermediate Release Category Csl: 1 - 10%
| |
| Release Time: 4 - 24 hours L-1 Low - Intermediate Release Category Csl: 0.1 -1%
| |
| Release Time: 4 - 24 hours LL-I Low Low- Intermediate Release Category Csl << 0.1%
| |
| Release Time: 4 - 24 hours H-L High - Late Release Category Csl > 10%
| |
| Release Time: > 24 hours M-L Medium - Late Release Category Csl: 1 - 10%
| |
| Release Tiine: > 24 hours L-L Low - Late Release Category Csl: 0.1 -1%
| |
| Release Time > 24 hours LL-L Low Low - Late Release Category Csl << 0.1%
| |
| Release Time > 24 hours 0.1.2.2.6 Mapping of Level 1 Results into the Various Release Categories The purpose of the Level 1 is to identify and capture accident sequences that have the potential to result in core damage. These sequences include the core damage states from the Level 1 PRA
| |
| [D.1-5, 0.1-16 & 0.1-12]. Success criteria used in the Level 1 look at sequences that result in core damage with a 24-hour time frame. Once core damage has occurred, the accident sequences are no longer considered for success and are labeled as "core damage".
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| Page D-54
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Guidance for performing Level 2 analyses and determination of LERF identifies core damage sequences and groups them into four containment failure plant states as shown below [D.1-6].
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| * Containment Bypass
| |
| * Containment Isolation
| |
| * Containment Failure with low RCS pressure
| |
| * Containment Failure with high RCS pressure The WF3 Level 2 considers these containment failure states as identified in the guidance. The purpose of this guidance is to ensure that accident sequences with the potential to impact off-site emergency response, public health and the corresponding protective measures have been identified and addressed. The potential exists for the identification of accident sequences that lead to core damage, but can be returned to a safe and stable state as a result of plant response measures (safeguard systems) within a period of time. These sequences would then be precluded from further Level 2 analysis due to establishing a safe and stable state and the mitigation of offsite impacts.
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| These accident sequences were evaluated deterministically using the MAAP 4.0.6 code and a 36-hour accident time period. This time period was selected to ensure that sufficient time was allotted to allow for late failures and to capture the peak steady-state FP release concentrations.
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| Accident sequences identified and evaluated as Level 2 sequences include:
| |
| * Transients
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| * Large Loss of Coolant Accidents (LOCA) - ALOCA
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| * Medium Loss of Coolant Accidents - MLOCA
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| * Small Loss of Coolant Accidents - SLOCA
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| * Steam Generator Tube Rupture Accidents - SGTR
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| * Station Blackout Accidents - SBO
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| * Anticipated Transients Without Scram -ATWS
| |
| * Interfacing System LOCA - ISLOCA Bridge trees can be used to convert the results from the Level 1 into the inputs for the Level 2 accident sequences. The Level 2 accident sequences are comprised of elements from the Level 1 core damage sequence to include both the success and failure accident-sequence pathways in combination with the containment safeguard systems. The resulting Level 2 accident sequences from the bridge tree process results in plant damage states (PDS).
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| To simplify the process and reduce the number of Level 2 accident sequences, these PDS can then be grouped based on a shared containment response. The previous WF3 Level 2 performed as part of the IPE used this binning process to combine the sequences into the following groups as shown below [D.1-11 ]:
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| I - Medium Pressure RCS at core uncovery, No HPI II - Medium Pressure RCS at core uncovery, No RAS Ill - High Pressure RCS at core uncovery, No HPI IV - Small LOCA with SG dryout, High pressure RCS at core uncover prevents HPI V - Large LOCA, no HPSI VI - Large LOCA, no RAS Page D-55
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
| |
| *, For the WF3 Level 2 analysis, no grouping into PDS was performed to group accident sequences with similar safety features and containment failure responses. A more rigorous approach was taken where each Level 2 accident sequence was assessed individually based on the accident-specific containment response.
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| The WF3 Level 2 accident sequences were named using the two or three letter identification for the CD sequences from the Level 1 core damage event trees (i.e., AX, MU, SB, TQX, TKQ, and RB) and combined with a one-letter code to represent core melt sequences (core damage with containment safeguard systems).
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| D.1.2.2.7 Process Used to Group the Source Terms With the development of the Level 2 release scenarios based on the integration of the Level 1 accident sequences, the containment safeguard configurations, and the Level 2 phenomena, these sequences were grouped under one of the 12 Release Categories identified in Table D.1-9.
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| These groupings are based on the release timing and magnitude of FP as determined by the deterministic MAAP Level 2 calculations.
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| Exceptions were made in the classification of the release scenario associated with the following:
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| * Containment Bypass Sequences
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| * Containment Isolation Sequences
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| * Reactor Vessel Rupture Events
| |
| * Interfacing System LOCA Events Containment Bypass Sequences SGTR and 1-SGTR sequences are characterized as bypass sequences due to a direct opening outside of containment at the onset of the accident sequence. These sequences were grouped with the H-E (high-early) release category based on an early release with minimal potential for mitigation of the FP releases. No consideration of FP scrubbing, retention, or deposition was considered for the bypass sequences.
| |
| Containment Isolation Sequences Containment isolation failures are defined as early failures based on open pathways through the containment at the onset of the accident sequences. These sequences were grouped with the H-E (high-early) release category based on an early release with minimal potential for mitigation of the FP releases. No consideration of FP scrubbing, retention, or deposition was considered for the containment isolation sequences.
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| Reactor Vessel Rupture Events .
| |
| Catastrophic reactor vessel rupture events pose a high likelihood of the occurrence of a containment failure concurrent with the vessel breach. As a result, these sequences were grouped with the H-E (high-early) release category based on an early release with maximum potential for the release of significant quantities of FP. No consideration of FP scrubbing, retention, or deposition was considered for the catastrophic vessel rupture sequences.
| |
| Interfacing System LOCA Events Like the SGTR sequences, the ISLOCA events are characterized as bypass sequences due to a direct opening outside of containment at the onset of the accident sequence. These sequences were grouped with the H-E (high-early) release category based on an early Page D-56
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage release with minimal potential for mitigation of the FP releases. No consideration of FP scrubbing, retention, or deposition was considered for the ISLOCA sequences.
| |
| Table D.1-9 Summary of Containment Event Tree Quantification Release Category Release Frequency (Magnitude/Timing) (Perry)
| |
| H-E 1.88E-06 H-1 4.75E-06 H-L O.OOE+OO L-E O.OOE+OO L-1 2.42E-09 L-L 5.56E-10 LL-E O.OOE+OO LL-I O.OOE+OO LL-L 3.85E-10 M-E 2.74E-08 M-1 1.34E-07 M-L 1.84E-08 lntact1 3.67E-06 CDF 1.05E-05 1
| |
| The "intact" column is calculated as (Base CDF - Total Release).
| |
| Nomenclature:
| |
| Timing (time between General Emergency Declaration and initial release):
| |
| Late (L) - Greater than 24 hours Intermediate (I) - 4.0 to 24 hours Early (E) - Less than 4.0 hours Magnitude:
| |
| Intact- Much less than 0.1% Csl release fraction Low-Low (LL) - Less than 0 .1 % Csl release fraction Low (L) - 0.1 % to 1% Csl release fraction Medium (M) - 1% to 10% Csl release fraction High (H) - Greater than 10% Csl release fraction D.1.2.2.8 Consequence Analysis Source Terms Input to the Level 3 WF3 model from the Level 2 model is a combination of radionuclide release fractions, timing of radionuclide releases, and frequencies at which the releases occur. This Page D-57
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage combination of information is used in conjunction with WF3 site characteristics in the Level 3 model to evaluate the off-site consequences of a core damage event.
| |
| Source terms were developed for the release categories identified in Table D.1-8. Table D.1-10 provides a summary of the Level 2 results that were used as Level 3 input for the WF3 SAMA analysis (the baseline analysis case).
| |
| Consequences corresponding to each of the release categories are developed in the WF3 Level 3 model, which is discussed in section D.1.5.
| |
| D.1.2.2.9 Release Magnitude Calculations The MMP computer code is used to assign both the radionuclide release magnitude and timing based on the accident progression characterization. Specifically, MMP provides the following information:
| |
| * containment pressure and temperature (time of containment failure is determined by comparing these values with the nominal containment capability);
| |
| * radionuclide release timing and magnitude for a large number of radioisotopes; and
| |
| * release fractions for twelve radionuclide species.
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| Page D-58
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
| |
| ( \
| |
| Table D.1-1 O WF3 Release Category Source Terms RDRELFRC001 - Release Fractions Warning Time (sec) RDPDELAY - Start RDPLHITE - Height RDPLUDUR-Release Freq. RDOALARM MACCS - Measured from scram of Plume release - MAAPTiming of plume release - Energy of Release Release Cat. Level 2 MAAP Run ID Duration of (per year) Time to declare GE, sec time; uses 15 minute from scram time Release Ends (sec) centerline of Escape EREL(6), W Release (sec)
| |
| GE declaration (sec) Hatch (26.5 ft)
| |
| Noble Gases I Cs Te Sr Ru La Ce Ba TPQU_BI 900.00 3224.35 Intact 3.68E-06 Plume#1 2324 88724 86400 65.38 2.07E-+-03 6.59E-03 3.20E-04 1.91E-04 1.18E-04 2.15E-07 9.28E-07 3.30E-09 7.80E-08 4.80E-07 Plume#2 88724 129600 40876 65.38 2.45E-+-03 9.99E-03 3.24E-04 1.92E-04 1.18E-04 2.15E-07 9.28E-07 3.30E-09. 7.80E-08 4.81E-07 TQX H 900.00 49288.77 H-E 1.88E-06 Plume#1 48389 50042 1653 65.38 2.45E-+-03 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 Plume#2 50042 129600 79558 8.08 4.11E-+-06 0.9998 0.2129 0.1987 0.2352 9.90E-04 1.36E-02 4.43E-05 1.02E-04 6.49E-03 SBO 900.00 8233.16 H-1 4.75E-06 Plume#1 7333 80630 73297 65.38 2.45E-+-03 5.89E-03 1.01E-04 3.89E-05 1.36E-04 1.29E-06 7.58E-05 3.44E-08 1.05E-07 8.69E-06 Plume#2 80630 129600 48970 8.08 7.57E-+-05 0.9803 0.2563 1.17E-01 1.64E-01 1.76E-03 9.04E-04 2.90E-05 1.08E-03 9.11E-04
| |
| - - - - - - - - - - - - - - - -
| |
| H-L NA1 NA
| |
| \_ -- /
| |
| SX B 900.00 32997.73 M-E 2.74E-08 Plume#1 32098 82532 50434 65.38 2.45E-+-03 3.25E-03 3.30E-04 1.88E-04 2.70E-04 3.24E-07 3.10E-06 2.01E-08 4.49E-08 2.71E-06 Plume#2 50434 129600 79166 8.08 2.09E-+-04 0.4946 0.0542 1.33E-02 7.49E-03 5.88E-06 5.86E-05 3.58E-07 7.62E-07 7.11E-05 SU_H 900.00 3270.88 M-1 1.34E-07 Plume#1 2371 43200 40829 65.38 2.45E-+-03 0.8415 5.65E-02 1.62E-02 4.64E-02 1.48E-03 2.42E-02 7.69E-05 1.42E-04 6.26E-03 Plume#2 43200 129600 86400 8.08 5.03E-+-06 0.8801 7.69E-02 2.42E-02 4.87E-02 1.57E-03 2.57E-02 8.04E-05 1.48E-04 6.61E-03 TB_F 900.00 3198.58 M-L 1.84E-08 Plume#1 2299 72608 70310 65.38 2.45E-+-03 5.85E-03 4.30E-04 2.02E-04 1.66E-04 1.81E-08 5.45E-07 1.77E-09 4.39E-09 1.92E-07 Plume#2 72608 129600 56992 8.08 4.54E-+-06 0.9996 7.85E-02 2.10E-02 1.16E-02 2.84E-08 5.75E-07 1.87E-09 4.88E-09 5.39E-06
| |
| --- --- --- --- -- --- - --- --- - --- -- --- --- --- -
| |
| L-E NA1 NA MU_H 900.00 3735.56 L-1 2.42E-09 Plume#1 2836 43200 40364 8.08 1.39E-+-07 0.8260 7.47E-03 7.42E-03 4.32E-02 1.75E-02 3.29E-02 8.76E-04 3.72E-03 4.91E-02 Plume#2 43200 129600 86400 8.08 5.05E-+-06 0.9016 7.93E-03 7.83E-03 6.59E-02 2.39E-02 3.48E-02 1.17E-03 5.06E-03 5.25E-02 TQX_B 900.00 19751.58 L-L 5.56E-10 Plume#1 18852 105252 86400 65.38 2.45E-+-03 6.08E-03 1.27E-04 8.81E-05 9.61E-05 4.00E-07 7.79E-06 2.17E-08 1.44E-07 2.29E-06 Plume#2 105252 129600 24348 8.08 2.35E-+-04 4.56E-01 2.48E-03 8.41E-04 3.53E-02 4.54E-07 8.65E-06 2.42E-08 1.61E-07 4.21E-06
| |
| - - - - - -- - -- - -- --- - - - -- -
| |
| LL-E NA1 NA
| |
| --- -- - --- -- -- --- --- -- -- --- -- --- --- --- ---
| |
| LL-I NA1 NA l) LL-L 3.85E-10 AX_D Plume#1 900.00 910.00 10 86410 86400 65.38 2.45E-+-03 6.27E-03 3.03E-04 2.10E-04 2.11E-04 2.19E-06 5.54E-06 6.24E-08 1.69E-07 7.05E-06 Page D-59
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
| |
| /~
| |
| . )
| |
| RDRELFRC001 - Release Fractions Warning Time (sec) RDPDELAY - Start RDPLHITE - Height RDPLUDUR-Release Freq. RDOALARM MACCS - Measured from scram of Plume release - MAAPTiming of plume release - Energy of Release Release Cat. Level 2 MAAP Run ID Duration of (per year) Time to declare GE, sec time; uses 15 minute from scram time Release Ends (sec) centerline of Escape EREL(6), W Release (sec)
| |
| GE declaration (sec) Hatch (26.5 ft)
| |
| Noble Gases I Cs Te Sr Ru La Ce Ba Plume#2 86410 129600 43190 8.08 3.81E-+-05 0.5375 5.06E-04 5.49E-03 3.09E-03 2.22E-06 5.65E-06 6.33E-08 1.71E-07 1.08E-05 I
| |
| These Release Categories were included as part of the level 2 model, but were not present m the level 2 results. As a result, release scenarios were not developed as part of the level 3 analysis.
| |
| )
| |
| Page D-60
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.3 External Events and Internal Flooding D.1.3.1 Seismic Analysis The WF3 PRA used for the SAMA analysis does not include external events. In the absence of such an analysis, Entergy used the WF3 IPEEE and more recent analyses to estimate the benefit of potential SAMAs using an external events benefit modifier as discussed in Section 4.15.1.4.4.
| |
| The seismic portion of the WF3 I PEEE [D.1-17] follows the guidance of NU REG-1407
| |
| [D.1-18], defined as a reduced scope plant, and EPRI NP-6041-SL [D.1-19]. This was accomplished by performing a Seismic Margins Assessment (SMA) of the Safe Shutdown Equipment List (SSEL) with plant walkdowns in accordance with the guidelines and procedures documented in Electrical Power Research Institute (EPRI) Report NP-6041-SL.
| |
| The SMA approach is a deterministic and conservative evaluation that does not calculate risk on a probabilistic basis. Therefore, its results should not be compared directly with the best-estimate internal events results.
| |
| The conclusions of the WF3 IPEEE seismic margin analysis are as follows:
| |
| : 1. Walkdowns resulted in no outliers that are operability issues at the plant.
| |
| : 2. No unique decay heat removal vulnerabilities to seismic events were found.
| |
| : 3. Seismic-induced flooding and fires do not pose major risks.
| |
| : 4. No unique seismic-induce.d containment failure mechanisms were identified.
| |
| However, there were three unresolved issues at the completion of the walkdowns. These issues are not significant to seismic risk and were made to conform to standard practice in seismic design. The issues and resolutions are [D.1-20]:
| |
| Issue Resolution Loose items in the Control The equipment identified was analyzed for potential impact Room to safety-related equipment. As good engineering practice the book cases near CP-22 and the tool cart in the EDG Room B were removed and there was no additional impact to safety related equipment following the evaluation.
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| Station air pipe not meeting CR-94-1111 contains the evaluation that the existing clearance requirements clearance for the station air pipe which is adjacent to 4KVESWGR3B will have no significant adverse impact during a seismic condition.
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| Storage of temporary Procedural guidance was updated for temporary storage in equipment UNT-007-060 to prevent potentially hazardous situations under seismic conditions.
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| Though the IPEEE did not calculate a CDF due to seismic events, an Integrated Leak Rate Test (ILRT) Interval Extension Report from August 2014 [D.1-21] conservatively estimated a value of Page D-61
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage 6.87E-07 forthe seismic CDF. For conservatism in the SAMA benefit analysis, this value will used to calculate the internal/external events benefit multiplier discussed in Section 4.15.1.4.4.
| |
| D.1.3.2 Fire Analysis The Waterford 3 (WF3) IPEEE included an internal fire analysis employing EPRl's FIVE methodology [D.1-22]. The NRC's IPEEE SER for WF3 reports a total fire CDF of 7 .OE-06/yr.
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| However, the IPEEE fire analysis has been superseded by the WF3 fire PRA created for NFPA 805, which utilizes guidance in NUREG/CR-6850 [D.1-23].
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| The WF3 fire PRA was not used in the SAMA analysis to estimate the risk reduction of individual SAMAs. Rather, the WF3 fire PRA was used in the SAMA analysis for determining the fire contribution to the external events multiplier, as well as for identifying potential SAMAs to mitigate the internal fire risk.
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| Since the WF3 fire PRA model is not fully integrated with the most recent Level 2 and 3 analyses, it wasn't used directly for the SAMA analysis. In addition, the WF3 fire PRA is based on NFPA 805 modifications that have not been implemented. However, the SAMA evaluation should be performed using the best available information on risk insights. Considering that the interim fire PRA model is a more current analysis of the fire risk at WF3 than the IPEEE fire analysis, and, therefore, is the best currently available fire risk information, use of the fire PRA model provides an acceptable basis (best available information) for identifying and evaluating SAMA candidates.
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| The total fire CDF was reported to be 1.62E-05/yr per the fire PRA model associated with the most recent LAR submittal [D.1-24]. In May 2015, an updated fire CDF of 1.80E-05/yr was calculated in PRA-W3-05-049 [D.1-25] due to changes resulting from NRC RAls. Since the CDF reported in PRA-W3-05-049 is the most recent value, this value was used in calculating the SAMA internal/external events multiplier discussed in Section 4.15.1.4.4.
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| Page D-62
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.3.3 Other External Hazards The WF3 IPEEE submittal, in addition to the internal fires and seismic events, examined a number of other external hazards:
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| * high winds and tornadoes;
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| * external flooding; and
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| * ice, hazardous chemical, transportation, and nearby facility incidents The WF3 Individual Plant Examination of External Events (IPEEE) concluded for high winds, floods, and other external events that WF3 meets the applicable NRC SRP requirements, and therefore has an acceptably low risk with respect to these hazards. As these events are not dominant contributors to external event risk and quantitative analysis of these events is not practical, they are considered negligible.
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| D.1.3.4 Internal Flooding An internal flooding analysis was performed in response to Generic Letter 88-20 (November 23, 1988) issued by the NRC. An updated analysis was performed with significant changes including how small diameter lines are handled, the assumed duration of releases, the handling of drains and turbine building floods, the charaQterization of rupture frequencies and sizes, and elimination of any screening of potential core damage scenarios by rupture frequency. These changes allowed the internal flooding analysis to satisfy the requirements in the ASME Standard and Regulatory Guide 1.200.
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| Revision 3 of the internal flooding notebook, PRA-W3-01-002 [D.1-45], calculates a total CDF contribution of 2.48E-06 from internal floods. This value was used, along with external events CDF values discussed above, to calculate the internal/external events multiplier discussed in Section 4.15.1.4.4. The multiplier was utilized because the current internal flooding model hasn't been integrated with the current internal events model or the Level 2 and 3 models.
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| Page D-63
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.4 PSA Model Revisions and Peer Review Summary The summary of the WF3 PSA models GDF and LERF is presented in the table below.
| |
| Summary of Major PSA Models PSA Model CDF (/nc-yr) LERF (/nc-yr) 1992 (IPE) (R1) 1.?0E-05 1.SOE-06 2000 (R2) 2.54E-05 5.33E-07 2003 (R3) 6.75E-06 2.42E-07 2009 (R4) 3.96E-06 4.94E-07 2015 (RS) 1.0SE-05 1.36E-07 D.1.4.1 Major Differences Between the 2000 (R2) PSA Model and the IPE Model The WF3 IPE model was created in 1992 [D.1-26]. The model was updated in 2000 and documented in Reports EC-S00-001Rev.0 [D.1-39], EC-S93-008 Rev. 1, Rev. 1C1, and Rev.
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| 1C2 [D.1-27]; with the final GDF and LERF values documented in ILRT Interval Extension Report W3F1-2001-0108 [D.1-28]. Changes to the model are summarized below.
| |
| * The main focus of Revision 2 was to remove asymmetries existing in the model for standby components (i.e. - the HPSI, CCW, eve and CHW systems) and incorporate missed support functions (i.e. - EOG dependency on DC power).
| |
| * DC control power dependencies were also added to FW-173A&B, AB bus alignment, ACC pumps, CCW AB pump, HPSI Pumps, LPSI Pumps, CS Pumps, EFW Pumps, and the AB Switchgear.
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| * Incorporated changes from a plant modification (DC-3402) which moved some loads from the AB battery to the turbine building battery.
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| * Updated EOG fail to run and start rates.
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| * Updated Loss of Offsite Power recovery analysis.
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| D.1.4.2 Major Differences Between the 2003 (R3) PSA Model and the 2002 (R2) PSA Model
| |
| * Included ISLOCA and A TWS sequences.
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| * Improved RCP seal LOCA modeling.
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| * Updated human reliability analysis.
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| * Updated generic and plant-specific failure rates.
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| * Improved Loss of Offsite Power recovery analysis.
| |
| * Improved common cause failure analysis.
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| * Updated HRA and LOSP analyses to reflect the Extended Power Uprate (EPU). The EPU changes the times available for operator actions and recovery of offsite power.
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| Page D-64
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
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| * Hot Leg Injection was added to mitigate medium and large LOCAs after the EPU which increased power that created the need for hot leg injection.
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| * Added Primary Safety Valve LOCA Initiating Event.
| |
| * Updated the Level 1 containment heat removal logic to 1 of 2 containment spray trains OR 2 of 4 containment cooling system fans.
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| Calculations EC-S00-001, Rev.1 [D.1-40], ECS93-008 [D.1-29], DRN_05-142, ORN 06-26, and PRA-W3-01-001S12 [D.1-30] summarize changes incorporated in the Revision 3 model, the overall core damage frequency results, and other additional information from the Revision 3 version of the model.
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| D.1.4.3 Major Differences Between the 2009 R4C1 (R4) PSA Model and the 2003 WSES-3 PSA (R3) PSA model The update of the Revision 4 Model is designated as the WF3 Level-1 Model R4C1 [D.1-31 ]. The following list describes the most significant changes from the WF3 PSA model R3 to PSA model 2009 R4C 1 Model.
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| * Updated initiating event data for plant operating experience with Bayesian updates using NUREG/CR-5750.
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| * Added safety injection (SI) valve rupture initiating events.
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| * Added instrument air system initiating event.
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| * Updated ATWS system interactions and failure propagations.
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| * Added initiating event %FVIVCC to the AFW system modeling.
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| * Updated the loss of offsite power (LOOP) logic to address both the consequential LOOP and the LOOP frequency for conditions such as severe weather, grid degradation, and switchyard work.
| |
| * Updated generic failure rates and component boundaries using NUREG/CR-6928.
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| * Added logic to the dry and wet cooling tower fans to allow for out of service selections as required for EOOS-related activities.
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| * Added emergency feedwater (EFW) recirculation line and component failures.
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| * Removed or replaced NOT gates in the model logic where possible.
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| * Added common cause failures for the diesel generator fuel oil transfer pumps.
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| * Added initiating event %T60C, for a line break outside of containment.
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| * Addressed most peer review and expert panel model comments.
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| D.1.4.4 Major Differences Between the 2015 (RS) PSA Model and the 2009 (R4) PSA Model Several changes were made in the Revision 5 PSA model update. The most significant changes are listed below.
| |
| * Resolved Peer Review findings.
| |
| * Updated success criteria associated with the number of dry cooling towers and wet cooling towers required to mitigate various accident sequences.
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| * Developed WF3-specific LOCA break sizes and associated frequencies.
| |
| * Converted from "flag" set alignments to conditional probability alignments.
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| * Updated generic and plant-specific failure rate data.
| |
| * Updated common cause failure (CCF) event probabilities.
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| Page D-65
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
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| * Updated initiator frequencies.
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| * Updated human failure events.
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| * HVAC dependencies were removed from the switchgear rooms and some pump rooms based on NRC comments and available room heat-up calculations associated with the room.
| |
| * A main control room (MCR) notebook and model was developed and included in the integrated model.
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| * Removed dependency to refill nitrogen accumulators by extending credited operation time from 10 hours to 24 hours.
| |
| * Revised modeling of refill of the CSP to reflect current procedural guidance.
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| * Added containment cooling system fan coil isolation valves.
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| * Revised battery depletion modeling to credit new procedural direction to strip batteries to extend battery life.
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| Details about the changes are included in calculation PSA-WF3-01-QU [D.1-32].
| |
| In addition, a full level 2 model was created which is based on the 2015 internal events model.
| |
| D.1.4.5 PSA Model Peer Review The Waterford 3 IPE [D.1-26] PRA was reviewed by an independent review team in three levels.
| |
| The first consisted of normal engineering Quality Assurance carried out by the organization performing the analysis. A qualified individual with knowledge of PRA methods and plant systems performed an independent review of all assumptions, calculations, and results for each task and system model in the Level 1 analysis (except the Internal Flood analysis).
| |
| The second level of review was performed by plant personnel not directly involved with the development of the PRA model. This consisted of individuals from Operations, Engineering, Training, and licensing groups which reviewed the system models and accident sequence description. This provided diverse expertise with plant design and operations knowledge to review the system fault trees for accuracy.
| |
| The third level of review was performed by PRA experts from ERIN Engineering. This review provided broad insights on techniques and results based on experience from other plant PRAs.
| |
| This review was conducted in two phases. During the first phase, the review team concentrated on the overall PRA methodology, accident sequence analysis, and system fault trees. The intent was to provide early feedback to the Waterford 3 staff concerning the adequacy and accuracy of the reviewed products. The second phase included Level 1 results, human failure and recovery analysis, preliminary plant damage state cutsets that combined Level 1 with containment system failures, and a preliminary CET.
| |
| An additional review was performed near the end of the project on the Level 2 analysis by experts from ABB Combustion Engineering. The intent of this review was to ensure that all important phenomena were considered and modeled correctly. Design features unique to CE plants were given particular emphasis. Detailed and specific comments on analysis methods, assumptions, and results were obtained.
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| The review teams found that the project was successfully meeting those objectives with a sound methodology and relatively minor adjustments necessary. The major comments are summarized below:
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| Page D-66
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
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| * The overall methodology reflects the current state of the art for PRAs and will meet the requirements of GL 88-20.
| |
| * Cutset results were found to be complete and reasonable with few modeling errors.
| |
| * Several conservatisms were identified in the success criteria, system modeling, and failure data used.
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| * The level of documentation was generally found to be good with more detail recommended for the accident sequence descriptions, treatment of RCP seal failures, and human recovery analysis. Some inconsistencies between the documentation and the modeling were found.
| |
| * Control of changes to the model should be improved so as to document which files were used for a particular solution.
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| * The EFW turbine driven pump can be expected to continue to operate with low quality steam or even water at the turbine inlet.
| |
| * Plant damage state category IV (high RCS pressure with late core melt) contained no cutsets due to the method of modeling. Although this is adequate for categorizing risk at the plant, it should be kept in mind during accident management guidance development that sequences such as those in category IV can in fact exist.
| |
| * Instrument air initiators should be included in the model.
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| In August 2009 the WF3 PRA was peer reviewed against the requirements of the American Society of Mechanical Engineers (ASME) PRA standard and the requirements of Regulatory Guide (RG) 1.200, Revision 1. This peer review was performed using the process defined in Nuclear Energy Institute (NEI) 05-04. The ASME PRA Standard contains a total of 327 numbered supporting requirements in nine technical elements and the configuration control element.
| |
| Thirteen of the SRs represent deleted requirements, and of the remaining 314 SRs, thirteen were determined to be not applicable to the WF3 PRA. Of the 301 remaining SRs, 244 SRs (81 % ) were rated as Capability Category II or greater and approximately 9% were Capability Category I. Only 10% of the SRs were rated as not met. In the course of this review, ninety-six new Facts and Observations (F&Os) were prepared, including two "Best Practices".
| |
| Many of the findings pertained to documentation issues. However, there were some technical Issues in various parts of the PRA. The F&Os were resolved and resulted in documentation updates, model updates, human action updates, and procedure updates.
| |
| The documentation of the Integration and Quantification Work Package, PRA-W3-01-001S02, was found to be a Best Practice because it was well-written and appropriately detailed. Also, in the Systems Analysis, the documentation of the Component Dependency tables was found to be a Best Practice because of the completeness, clarity, and ease of use of the tables.
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| Page D-67
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.5 The WinMACCS Model-Level 3 Analysis D.1.5.1 Introduction SAMA evaluation relies on Level 3 PRA results to measure the effects of potential plant modifications. A Level 3 PRA model using version 3.10.0 of the Windows Melcer Accident Consequences Code System (WinMACCS) [D.1-33] was created for WF3. A WinMACCS calculation consists of three phases: input processing and validation, phenomenological modeling, and output processing. The phenomenological .models are based mostly on empirical data. The modeling software is subdivided into three modules:
| |
| * ATMOS treats atmospheric transport and dispersion of material and its deposition from the air utilizing a Gaussian plume model with Pasquill-Gifford dispersion parameters.
| |
| * EARLY models consequences of the accident to the surrounding area during an emergency action period. The emergency action period is the duration that begins when the first plume of the release arrives and ranges between 1 and 7 days.
| |
| * CHRONC considers the intermediate long-term impact in the period subsequent to the emergency action period.
| |
| Detailed. site-specific meteorological, population, and economic data are required. Model parameters can be varied by the user via input files, thus facilitating the analysis of consequence sensitivities due to uncertainties in specific model parameters. Assumptions associated with the model parameters can be found in the input document [D.1-34].
| |
| The Level 3 report evaluates a base case and two sensitivity. cases to account for variations in data and assumptions for postulated internal events. The base case uses estimated evacuation speed and times for evacuation based on site-specific evacuation calculations and consequence analysis best practices [D.1-35, D.1-34]. A sensitivity case (TIME) is the base case with the initial time to seek shelter extended from 2 hours to 3 hours. The other sensitivity case (SPEED) is the base case with a slower evacuation speed.
| |
| The population dose risk (PDR) was estimated by summing the product of population dose (obtained via WinMACCS calculation) and frequency for each accidental release over all releases. The offsite economic cost risk (OECR) was estimated by summing the product of offsite economic cost (obtained via WinMACCS calculation) and frequency for each accidental release over all releases. The offsite economic cost includes costs that could be incurred during the emergency response phase and the long-term protective action phase.
| |
| D.1.5.2 Input The following sections describe the site-specific input parameters used to obtain the off-site dose and economic impacts for cost-benefit analyses.
| |
| D.1.5.2.1 Projected Total Population Projected permanent, transient, and total population estimates in parish and sector geography was developed. Sector geography consists offifteen concentric bands at 0-0.914 km (0.568-mi.),
| |
| 0.914-1.61 km (1-mi.), 1.61-3.22 km (2-mi.), 3.22-4.83 km (3-mi.), 4.83-6.44 km (4-mi.), 6.44-8.05 km (5-mi.), 8.05-9.66 km (6-mi.), 9.66-11.27 km (7-mi.), 11.27-12.87 km (8-mi.), 12.87-14.48 km Page D-68
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage (9-mi.) 14.48-16.09 km (10-mi.), 16.09-32.19 km (20-mi.), 32.19-48.28 km (30-mi.), 48.28-64.37 km (40-mi.), and 64.37-80.47km (50 mi.) from the center point in 22.5 degree segments centered on the 16 compass points .
| |
| 2010 Census information found the following:
| |
| * Permanent Population within 20 Miles = 371,976 persons
| |
| * 20 Mile Population Density (371,976/Area) = 296 persons/square mile
| |
| * Permanent Population within 50 Miles= 2,006,583 persons
| |
| * 50 Mile Density (2,006,583/Area) = 255 persons/square mile 2045 Total Population= 2,882,454 2010-2045 Annual Growth Rate for all Parishes within the Region = 0.92.
| |
| Additional details of the distri.bution of the population can be found in reference WF3-EP-14-00012 [D.1-34]
| |
| D.1.5.2.2 Land Fraction The percentage of land in each of the 240 spatial elements is required by WinMACCS. The National Hydrography Dataset (NHD) for the watersheds and the area within the 50-mile region was used to calculate the ratio of land to surface water coverage [D.1-36]. Swampland was included as land, rather than water, so that WinMACCS habitability and farmability decisions would be applied to the swampland, resulting in a conservative estimate of the costs for decontamination, interdiction, and condemnation. Calculated values ranged from 0.00 to 1.00. A value of 1.00 indicates the spatial element area is all land, with no significant surface water.
| |
| D.1.5.2.3 Watershed Class Watershed Index is defined by NUREG/CR-4551, Volume 2, Rev. 1 as areas drained by rivers (Class 1) or large water bodies (Class 2). Class 2 is intended only for use with a very large lake, similar in size to Lake Michigan. Thus for WF3, a .watershed index of 1 (drained by rivers) was used for all spatial elements.
| |
| D.1.5.2.4 Regional Economic Data Economic data were obtained from SECPOP 2013 [D.1-41], U.S. Census of Agriculture for 2012
| |
| [D.1-42], Global Insight [D.1-43] and Department of Labor Statistics [D.1-44].
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| Page D-69
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Region Index Each spatial element was assigned to an economic region, defined in this report as a parish.
| |
| When a spatial element was comprised of more than one parish, it was assigned to the parish that had the most area in that spatial element. Four parishes in Louisiana (Iberia, St. Helena, St. Mary, and West Baton Rouge) were not assigned due to their small representation in any one spatial element.
| |
| Regional Economic Data Economic data were obtained from SECPOP 2013 [D.1-41 ], U.S. Census of Agriculture [D.1-42]
| |
| for 2012, Global Insight [D.1-43] and Department of Labor Statistics [D.1-44].
| |
| VAL WF- Value of Farm Wealth WinMACCS input requires VALWF, an average value of farm wealth (dollars/hectare) for the 50-mile radius area. This value is calculated by first, converting each parish's VFRM to dollars per county using U.S. Census of Agriculture item approximate land area (acres, 2012) and the conversion factor of 0.4047 ha/acre. These values are then weighted by the area each of the 21 parishes has in the WF3 50-mile area. Finally, the resultant values are then summed, producing a dollar value for the region, and divided by the total number of hectares within the region. The resulting value is $9281.53/ha.
| |
| VALWNF- Value of Non-Farm Wealth WinMACCS input requires a regional average value of non-farm wealth. This value is calculated by first multiplying the VNFRM by the 2010 parish permanent population, and then weighting by the area each of the 21 parishes have in the WF3 50-mile region. These resultant values are then summed, producing a dollar value for the region, and divided by 2010 permanent population within the 50-mile region. The 2010 permanent population within the region was obtained from the U.S. Census Bureau (USCB 2010). The regional value of non-farm wealth is $448,741.03/person.
| |
| VALWNF is based upon fixed, reproducible, tangible wealth, a measure of the durable goods owned in an area. This value was modified by adding a measure of total economic activity based upon the state gross domestic product (GDP). The modified VALWNF is $512,597.99/person.
| |
| D.1.5.2.5 Agriculture Data WinMACCS requires input regarding the crop type, growing season, and average fraction of farmland devoted to each crop type. The WinMACCS model requires average values for the 50-mile radius area instead of specific values for each of the 240 spatial elements. Agriculture data were obtained from the 2012 Census of Agriculture for the 21 parishes of interest in Louisiana [D.1-37]. The acres for each crop type and land in area (acres) were downloaded for each parish and the crop data were classified into seven crop categories, as defined in NUREG/CR-4551 Evaluation of Severe Accident Risks: Quantification of Major Input Parameters.
| |
| D.1.5.2.6 Meteorological Data Meteorological data representative of the WF3 site was collected to support the Level 3 analysis.
| |
| This data included wind speed, wind direction, atmospheric stability class, accumulated precipitation, and atmospheric mixing heights. The required data were obtained from the onsite WF3 meteorological monitoring system and regional National Weather Service stations [Slidell, LA (National Weather Service Station No. 53813) and Armstrong International Airport, LA Page D-70
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage (National Weather Service Station No. 72231 )]. Data records were collected for years 2004 through 2013 [D.1-34] and converted into formatted files for use in the WinMACCS model.
| |
| Site-Specific Data The site-specific meteorological data from the refined data set was used to produce fourteen separate WinMACCS input files, one for each year from 2004 through 2009 and two for each year from 2010 through 2013. Any missing hourly data was filled in the WinMACCS input files using data from approved data substitution methods as needed. Data from years 2010 through 2013 was missing seasonal mixing height averages. As a result, both minimum and maximum mixing heights were calculated for these years and incorporated into the meteorological data Regional Mixing Height Data The NCDC daily values for morning and afternoon mixing heights were averaged for each season and year. Calculated seasonal mixing height values were rounded to the nearest hundred and divided by 100 to express values in hundreds of meters for the WinMACCS model. Because data was not available for 2010 through 2013, the minimum and maximum average seasonal values for the years 2000 through 2009 were used for these years.
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| Page D-71
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.5.2.7 Evacuation Scenario Two cohorts were used to define the WF3 evacuation scenario for the evacuation of 90% of the affected population [D.1-33]. Cohort 1 defines the evacuation of 90% of the affected population while Cohort 2 defines the remaining 10% of the population that does not evacuate. The emergency response implementation for the execution of these 2 cohorts is defined by the parameters ESPEED, DLTSHL, TIMHOT, and TIMNRM as described below.
| |
| Travel Speed of Evacuees [ESPEED]
| |
| This value is the speed at which the evacuees move through the area based on evacuation of a full 10 mile EPZ [D.1-35]. This value is 1.192 mis based on traveling the full 10 miles in 3 hours and 45 minutes. The 3 hour and 45 minute evacuation time is determined based on the longest evacuation time occurring in Regions R14 and R15 as part of the Evacuation Time Estimate evaluations
| |
| [D.1-34].
| |
| Delay to Shelter [DL TSHL]
| |
| The delay to shelter (DLTSHL) is the time it takes for residents in the EPZ to receive the alert and notification and to enter a shelter (their residence, workplace, etc.) This value reflects the time required to execute the activities prior to beginning the evacuation trip [D.1-34]. This value is 7200 seconds based on the maximum time for all employees, residents and commuters [D.1-34]. This time includes the 1 :45 minute time for trip generation based on the 901h percentile evacuation time plus 15 minutes for the remaining 101h of evacuation times to begin.
| |
| Hotspot Relocation Time [TIMHOT] & Normal Relocation Time [TIMNRM]
| |
| These times are associated with the hotspot and normal time required to relocate residents from the area based on EPA Protective Action Guides (PAGs) [D.1-35]. Times of 43,200 and 86,400 seconds were used for TIMHOT and TIMNRM, respectively, and are based on NRC guidance
| |
| [D.1-35].
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| Page D-72
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.5.2.8 Core Inventory The WF3 core inventory input to the WinMACCS model [D.1-33] is based on a core thermal power of 3735 MWt [D.1-38]. The core inventory is shown in Table D.1-11.
| |
| Table D.1-11 Estimated WF3 Core Inventory (Becquerels)*
| |
| Nuclide Inventory Nuclide Inventory Co-58 3.53E+l6 Te-131m 5.75E+l7 Co-60 2.70E+l6 Te-132 5.61E+18 Kr-85 4.92E+l6 1-131 3.94E+l8 Kr-85m 1.45E+l8 1-132 5.70E+l8 Kr-87 2.94E+l8 1-133 7.97E+l8 Kr-88 4.15E+l8 1-134 8.87E+l8 Rb-86 2.07E+l5 1-135 7.48E+l8 Sr-89 4.06E+l8 Xe-133 7.80E+18 Sr-90 3.96E+l7 Xe-135 2.29E+l8 Sr-91 5.43E+l8 Cs-134 1.11E+l8 Sr-92 5.26E+l8 Cs-136 2.92E+l7 Y-90 4.18E+l7 Cs-137 5.91E+l7 Y-91 5.09E+l8 Ba-139 6.88E+18 Y-92 5.28E+l8 Ba-140 7.03E+l8 Y-93 5.97E+l8 La-140 7.30E+l8 Zr-95 6.61E+l8 La-141 6.38E+l8 Zr-97 6.30E+l8 La-142 6.15E+l8 Nb-95 6.61E+18 Ce-141 6.19E+l8 Mo-99 7.15E+l8 Ce-143 6.34E+l8 Tc-99M 6.26E+l8 Ce-144 4.73E+l8 Ru-103 6.23E+l8 Pr-143 6.15E+l8 Ru-105 3.23E+l8 Nd-147 2.64E+l8 Ru-106 2.38E+l8 Np-239 7.08E+l9 Rh-105 2.24E+l8 Pu-238 4.01E+l5 Sb-127 3.05E+l7 Pu-239 9.04E+l4 Sb-129 l.29E+l8 Pu-240 l.14E+l5 Te-127 2.95E+l7 Pu-241 l.92E+l7 Te-127m 3.90E+l6 Am-241 l.27E+l4 Te-129 l.27E+l8 Cm-242 4.86E+l6 Te-129m l.88E+l7 Cm-244 2.84E+l5
| |
| *Based on a thermal power of 3735 MWt (100.5% of upgraded power level of 3716 MWt)
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| Page D-73
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.5.2.9 Source Terms Twelve release categories, corresponding to internal event sequences, were part of the WinMACCS input. Section D.1.2.2.7 provides details of the source terms for postulated internal events. Based on the Level 2 results, a review of the dominant accident classes and maximum release of fission products was performed to select a representative accident sequence for each release category. The representative accident sequences selected for each release category represented both the dominant accident class based on the Level 2 results and the maximum release of fission products from the MAAP analyses.
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| Based on regulatory guidance and best practices [D.1-35], two plume segments were used to represent each release category based on the MAAP results from the Level 2
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| [D.1-2]. In general, these plumes characterize the two-phases of the source term release associated with (1) the initial accident sequence from core damage up to containment failure, and (2) the accident sequence following containment failure.
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| D.1.5.3 RES ULTS The WinMACCS model was run with each of the fourteen separate WinMACCS input files, one for each year from 2004 through 2009 and two for each year from 2010 through 2013 (one with the minimum average mixing heights and one with the maximum average mixing heights). The results showed that the site-specific meteorological data from year 2010, with the minimum average mixing heights, generated the highest population dose and the highest offsite economic cost.
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| Therefore, the base case results are those obtained using the site-specific meteorological data from year 2010, with the minimum average mixing heights.
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| Risk estimates for a base case and two sensitivity cases were analyzed to account for variations in data and assumptions with WinMACCS. The base case uses estimated evacuation speed (1.192 m/s) and sheltering times (2 hours). A sensitivity case, SPEED, is the base case with a slower evacuation speed (reduced by a factor of 2 from 1.192 m/s (base) to 0.596 m/s) with the sensitivity case, TIME, being a longer sheltering time (increased from 2 hours to 3 hours). These sensitivities were evaluated to conservatively reflect and quantify the uncertainties in specific model parameters. Results from the Level 3 sensitivities are shown in Table D.1-13.
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| Table D.1-12 shows estimated base case mean risk values for each release mode. The estimated mean values of PDR and offsite OECR forWF3 are 15.9 person-rem/yr and $147,339/yr, respectively [D.1-33].
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| Page D-74
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-12 Base Case Mean PDR and OECR Values for Postulated Internal Events Characteristics of Release Results - Year 2010M Mode Population Dose Offsite Economic Release ID Frequency (per year) person-sv Cost($)
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| Intact 3.68E-06 1.39E+03 1.59E+08
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| - ~~-~*--~-----
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| H-E 1.BBE-06 2.94E+04 2.79E+10 H-1 4.75E-06 1.96E+04 1.92E+10 M-E 2.74E-08 1.01E+04 6.02E+09 M-1 1.34E-07 3.43E+04 2.04E+10 M-L 1.84E-08 1.18E+04 8.53E+09 L-1 2.42E-09 4.01E+04 1.87E+10 L-L 5.56E-10 3.55E+03 4.44E+08 LL-L 3.85E-10 6.83E+03 2.41E+09 1.59E+01 1.47E+05 Totals person- rem/yr $/yr Com.ersion Factor: 1 sv = 100 rem A sensitivity case (SPEED) was performed to assume an evacuation speed that is reduced from 1.192 m/s (base) to 0.596 m/s. This sensitivity case (SPEED) assumes a lower average evacuation speed. Results of sensitivity analyses as shown in Table D.1-13 indicate that a slower evacuation speed slightly increases the population dose offsite consequences by less than 1%
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| with no change to economic impact.
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| A sensitivity case (TIME) was conducted assuming a longer delay in the initial time to seek sheltering (parameter DLTSHL). The sheltering time of 2 hrs was used for the baseline. This time was increased to time of 3 hrs (10,800 sec) evacuation for the sensitivity run. Results of sensitivity analyses as shown in Table D.1-13 indicate that a longer period between the onset of the accident and the start of the sheltering period does not significantly impact population doses (less than 1% )
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| or the offsite costs.
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| Page D-75
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-13 Summary of Offsite Consequence Results for Sensitivity Cases Characteristics of 1 Population Dose (person-sv) Offsite Economic Cost($)
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| Release Mode Frequency Baseline Speed Time i Baseline Speed Time ID (per year) (person-sv) (person-sv) (person-sv) i ($) ($) ($)
| |
| Intact 3.68E-06 1.39E+03 1.40E+03 1.39E+03 1.59E+08 1.59E+08 1.59E+08 H-E 1.88E-06 2.94E+04 2.94E+04 2.94E+04 2.79E+10 2.79E+10 2.79E+10 H-1 4.75E-06 1.96E+04 1.96E+04 1.96E+04 1.92E+10 1.92E+10 1.92E+10 M-E 2.74E-08 1.01E+04 1.01E+04 1.01E+04 6.02E+09 6.02E+09 6.02E+09 M-1 1.34E-07 3.43E+04 4.06E+04 3.59E+04 2.04E+10 2.04E+10 2.04E+10 M-L 1.84E-08 1.18E+04 1.18E+04 1.18E+04 8.53E+09 8.53E+09 8.53E+09 L-1 2.42E-09 4.01E+04 4.85E+04 4.21E+04 1.87E+10 1.87E+10 1.87E+10 L-L 5.56E-10 3.55E+03 3.56E+03 3.55E+03 4.44E+08 4.44E+08 4.44E+08 LL-L 3.85E-10 6.83E+03 6.84E+03 6.83E+03 2.41E+09 2.41E+09 2.41E+09 Totals 1.59E+01 1.60E+01 1.59E+01 1.47E+05 1.47E+05 1.47E+05
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| % Change NA 0.57% 0.14% NA 0.00% 0.00%
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| Units person- rem/yr person-rem/yr person- rem/yr $/yr $/yr $/yr Conwrsion Factor: 1 sv= 100 rem Page D-76
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.6 References D.1-1 WF3 Calculation No: PSA-WF3-01-QU," WF3 PSA At-Power Level 1 Integration and Quantification Analysis", Rev. 3, October 2015.
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| D.1-2 PSA-WF3-01-L2-01, 'Waterford 3 Level 2 PRA", Revision 0.
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| D.1-3 PSA-WF3-01-QU-01, 'WF3 PSA Uncertainty and Sensitivity Analysis", Revision 0, July 2015.
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| D.1-4 Waterford 3 Probabilistic Risk Assessment Individual Plant Examination Submittal, August 1992.
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| D.1-5 PSA-WF3-01-SC, WF3 PSA At-Power Level 1 Success Criteria Analysis, Rev. 1.
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| D.1-6 PSA-WF3-01-LE Large Early Release Frequency (LERF) Model, Rev. 1.
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| D.1-7 RSC-CALKNX-2013-0706, Waterford LERF-Containment Isolation System Break Size MMP Sensitivity Assessment, Rev. 0.
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| D.1-8 PSA-WF3-01-SY, WF3 PSA Model System Analysis Work Package, Rev. 0.
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| D.1-9 NUREG-1570 Risk Assessment of Severe Accident-Induced Steam Generator Tube Rupture.
| |
| D.1-10 WCAP-16341-P Simplified Level 2 Modeling Guidelines, Westinghouse, Rev. 0.
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| D.1-11 Waterford 3 Probabilistic Risk Assessment Individual Plant Examination Submittal, August 1992.
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| D.1-12 PSA-WF3-01-AS-01, WF3 PSA At-Power Level 1 Anticipated Transient Without Scram Analysis, Rev.a.
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| D.1-13 PSA-WF3-01-L2-02, Finite Element Analysis for Entergy Waterford Unit 3 Containment Failure Analysis, Rev. 0.
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| D.1-14 Waterford 3 SES Emergency Plan, Revision 45.
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| D .1-15 KLD TR-502, Waterford-3 Steam Electric Station Development of Evacuation Time Estimates, Rev.1.
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| D.1-16 PSA-WF3-01-AS, WF3 PSA At-Power Level 1 Accident Sequence Analysis, Rev. 0.
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| D.1-17 WF3 IPEEE "Internal Plant Examination of External Events", Revision 0, July 1995.
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| D.1-18 NUREG-1407, "Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities," June, 1991.
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| D.1-19 EPRI NP-6041-SL, "A Methodology for Assessment of Nuclear Power Plant Seismic Margin," August, 1991.
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| Page D-77
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1-20 NRC SER "Safety Evaluation of Individual Plant Examination of External Events (IPEEE)
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| Submittal On Waterford Electric Station, Unit 3" July 27, 2000.
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| D .1-21 W3F1-2015-0021, "Waterford Steam Electric Station, Unit 3 Response to Request for Additional Information Regarding the Request to Permanently Extend the Integrated Leak Rate Test Frequency to 15 Years", May, 2015.
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| D.1-22 Fire-Induced Vulnerability Evaluation (FIVE), EPRI TR-100370 Project 3000-41, April 1992.
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| D.1-23 NUREG/CR-6850, "Fire PRA Methodology for Nuclear Power Facilities", 2005.
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| D.1-24 W3F1-2013-0048, "Supplement to NFPA 805 License Amendment Request (LAR)
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| Waterford Steam Electric Station, Unit 3", December, 2013.
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| D.1-25 WF3 Calculation No: PRA-W3-05-049, "Comparison of Waterford 3 MOR and FRE CDF and LERF", Revision 1, May, 2015.
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| D.1-26 Individual Plant Examination Submittal for the Waterford 3 Nuclear Plant, August, 1992.
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| D.1-27 EC-S93-008, "Waterford 3 Level 1 Internal Events PSA Model," Revision 1, August, 2000.
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| D.1-28 W3F1-2001-0108, "Risk Evaluation of ILRT Interval Extension", November 8, 2001.
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| D.1-29 EC-S93-008, 'Waterford 3 Level 1 Internal Events PSA Model," Revision 2, June, 2003.
| |
| D.1-30 PRA-W3-01-001S12. "Waterford 3 PRA LERF Model", Rev 0.
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| D.1-31 PRA-W3-01-001, 'Waterford Steam Electric Station Unit 3 Probabilistic Safety Assessment Level-1 Model R4C1 Summary Report", Revision 0, March, 2009.
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| D.1-32 PSA-WF3-01-QU, "WF3 PSA At-Power Level 1 Integration and Quantification Analysis",
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| Rev. 0.
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| D.1-33 W3-EP-14-00013, 'Waterford 3 Level 3 PRA," Rev. 0.
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| D.1-34 WF3-EP-14-00012, Site-Specific MACCS2 Input Data for WF3, Rev. 0.
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| D.1-35 NUREG/CR-7009, MACCS Best Practices as Applied in the State-of-the-Art Reactor Consequence Analysis (SOARCA) Project, June 2014.
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| D.1-36 USGS (U.S. Geological Survey). 2014. National Hydrography Dataset (NHD). Retrieved from ftp://nhdftp.usgs.gov/DataSets/Staged/States/FileGDB/HighResolution (accessed June 9, 2014).
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| D.1-37 USDA (U.S. Department of Agriculture). 2012. 2012 Census of Agriculture Louisiana State and Parish Data. May 2014.
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| D.1-38 WSES-FSAR-UNIT-3, Waterford 3 Steam Electric Station Unit 3 Final Safety Analysis Report, Rev. 308.
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| Page D-78
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1-39 EC-S00-001, "PSA Model Summary Report," Revision 0.
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| D.1-40 EC-S00-001, "PSA Model Summary Report," Revision 1.
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| D.1-41 SECPOP (SECPOP 4.2.0 Software). 2013. Sector Population, Land Fraction and Economic Estimation Program. Released 10/21/2013. Sandia National Laboratories, Albuquerque, NM.
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| D.1-42 USDA (U.S. Department of Agriculture). 2012. 2012 Census of Agriculture Louisiana State and Parish Data. May 2014.
| |
| D.1-43 Global Insight, 2014. U.S. Metro Economies- GMP and Employment 2013-2015. June 2014.
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| D.1-44 USDL (U.S. Department of Labor). 2015. U.S. Bureau of Labor Statistics Quarterly Census of Employment and Wages for 2013. Retrieved from
| |
| <http://www.bls.gov/data/#employment> (accessed January 27, 2015).
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| D.1-45 WF3 Calculation No: PRA-W3-01-002, "W3 Internal Flooding Analysis", Revision 3.
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| Page D-79
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment D.2 Evaluation of WF3 SAMA Candidates Page D-80
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.2 EVALUATION OF WF3 SAMA CANDIDATES This section describes the generation of the initial list of potential SAMA candidates, screening methods, and the analysis of the remaining SAMA candidates.
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| D.2.1 SAMA List Compilation Candidate SAMAs are defined as potential enhancements to the plant design, operating procedures, inspection programs, or maintenance programs that have the potential to reduce the severe accident risk of WF3. These SAMAs can be characterized as either hardware (e.g.,
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| physical modification of plant structure, systems, and components) or non-hardware enhancements (e.g., operation, maintenance programs, and procedure changes), or a combination of the two. The candidate SAMAs considered for WF3 encompass both hardware and non-hardware enhancements.
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| A list of SAMA candidates was developed by reviewing industry documents and considering other plant-specific enhancements not identified in the published industry documents. Since WF3 is a PWR, considerable attention was paid to the SAMA candidates from SAMA analyses for other PWR plants. Industry documents reviewed included the following.
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| * NEI 05 Severe Accident Mitigation Alternatives Analysis [D.2-1]
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| * Davis-Besse Nuclear Power Station SAMA Analysis [D.2-2]
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| * South Texas Project, Units 1 and 2 SAMA Analysis [D.2-3]
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| * Callaway Plant SAMA Analysis [D.2-4]
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| * Seabrook Station SAMA Analysis [D.2-5]
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| * Sequoyah Nuclear Plant, Units 1 and 2 SAMA Analysis [D.2-6]
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| In addition to SAMA candidates from review of industry documents, additional SAMA candidates were obtained from plant-specific sources, such as the WF3 Individual Plant Examination (IPE)
| |
| [D.2-7] and the WF3 Individual Plant Examination of External Events (IPEEE) [D.2-8]. In the IPE and IPEEE several enhancements related to severe accident insights were recommended and implemented. These enhancements are included in the comprehensive list of phase I SAMA candidates as 183 through 195 (Table D.2-1). The current WF3 PSA Level 1and2 models were also used to identify plant-specific modifications for inclusion in the comprehensive list of SAMA candidates. The risk significant events from the current PSA model were reviewed for similar failure modes and effects that could be addressed through a potential enhancement to the plant.
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| The correlation between SAMAs and the risk significant terms are listed in Tables D.1-2, D.1-4, and D.1-5.
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| The comprehensive list of 201 candidate SAMAs considered for implementation at WF3 is provided in onsite documentation [D.2-1 O].
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| Page D-81
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.2.2 Qualitative Screening of SAMA Candidates (Phase I)
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| The purpose of the preliminary SAMA screening was to eliminate from further consideration enhancements that were not viable for implementation at WF3. Potential SAMA candidates were screened out if they modified features not applicable to WF3, if they had already been implemented at WF3, or if they were similar in nature and could be combined with another SAMA candidate to develop a more comprehensive or plant-specific SAMA candidate. During this process, 48 of the Phase I SAMA candidates were screened out because they were not applicable to WF3, 11 of the Phase I SAMA candidates were screened out because they were similar in nature and could be combined with another SAMA candidate, and 68 of the Phase I SAMA candidates were screened out because they had already been implemented at WF3, leaving 74 SAMA candidates for further analysis. The final screening process involved identifying and eliminating those items whose implementation cost would exceed their benefit as described below. Table D.2-2 provides a description of each of the 74 Phase II SAMA candidates.
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| D.2.3 Final Screening and Cost Benefit Evaluation of SAMA Candidates (Phase II}
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| To assess the viability of each SAMA considered for a final cost-benefit evaluation, the cost of implementing that particular SAMA was estimated and compared with the estimated benefit. If the cost of implementation was greater than the attainable benefit of a particular SAMA, then the modification was not considered economically viable and was eliminated from further consideration.
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| The expected cost of enhancement to implement each SAMA (COE) was established from existing estimates of similar modifications combined with engineering judgment. Most of the cost estimates were developed from similar modifications considered in previously performed SAMA analyses. In particular, these cost-estimates were derived from the following major sources.
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| * Davis-Besse [D.2-2]
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| * South Texas project [D.2-3]
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| * Callaway [D.2-4]
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| * Seabrook Station [D.2-5]
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| * Sequoyah [D.2-6]
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| * AN0-2 [D.2-11]
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| * Indian Point [D.2-12]
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| Detailed cost estimates were often not required to make informed decisions regarding the economic viability of a potential plant enhancement when compared to attainable benefit. The implementation costs for of the SAMA candidates were clearly in excess of the attainable benefit estimated from a particular analysis case. Nonetheless, the cost of each SAMA candidate was conceptually estimated to the point where conclusions regarding the economic viability of the proposed modification could be adequately gauged.
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| Based on a review of previous submittals, SAMA evaluations, and an evaluation of expected implementation costs at WF3, the following estimated cost ranges for each type of proposed SAMA were used.
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| Page D-82
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage ESTIMATED COST Type of Change RANGE Procedural only $25K-$50K Procedural change with engineering or training required $50K-$200K Procedural change with engineering and testing/training $200K-$300K required Hardware modification $100K to >$1000K Detailed cost estimates were based on the engineering judgment of project engineers experienced in performing design changes at the facility. The detailed cost estimates considered engineering, labor, materials, and support functions such as planning, scheduling, health physics, quality assurance, security, safety, and firewatch. The estimates included a 20%-30%
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| contingency on the design and a 30%-40% contingency on the installation costs, but did not account for inflation, replacement power during extended outages necessary for SAMA implementation, or increased maintenance or operation costs following SAMA implementation.
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| The cost benefit comparison and disposition of each of the 74 Phase II SAMA candidates is presented in Table D.2-2. Three of the Phase II SAMA candidates were retained without evaluation as they are already commitments in the NFPA 805 LAR [D.2-13]
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| Bounding evaluations (or analysis cases) were performed to address specific SAMA candidates or groups of similar SAMA candidates. These analysis cases overestimated the benefit and thus were conservative calculations. For example, if the objective of the SAMA was to reduce the likelihood of a certain failure mode, then eliminating the failure mode from the PSA bounded the benefit, even though the SAMA would not be expected to be 100% effective in eliminating the failure. This calculation obviously overestimated the benefit, but if the inflated benefit indicated that the SAMA candidate was not cost beneficial, then the purpose of the analysis was satisfied.
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| A description of the analysis cases used in the evaluation follows.
| |
| Case 1: SBO Reduction This analysis case was used to evaluate the change in plant risk from providing additional DC or AC power to reduce SBO contribution. A bounding analysis was performed by eliminating the SBO contribution from the PSA model by setting events #SBO and #SBORCP to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $5,597,783. This analysis case was used to model the benefit of Phase II SAMAs 1, 2, and 7.
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| Case 2: Improve Feedwater Reliability This SAMA analysis case was used to evaluate the change in plant risk from installing a digital feed water upgrade. A bounding analysis was performed by eliminating the failure of feedwater by setting the %T4 initiator to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $35,361. This analysis case was used to model the benefit of phase II SAMA 31.
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| Case 3: Add DC System Cross-ties This analysis case was used to evaluate the change in plant risk from providi~g DC bus cross-ties. A bounding analysis was performed where the failure of DC bus 38-DC-S (gate D100) was ANDed with the failures of DC busses 3A-DC-S (gate 0200) and 3AB-OC-S (0300) below Page D-83
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage gate 0605. Similarly, below gate 0605A, gates 01 OOA, 0200A, and 0300AW were ANOed; below gate 0352, gates 01 OO_AX, D201A, and D301AW were ANDed; and below gate H0217, gates 01 OO_AD, D200_AD, and D300_AD were ANDed. Also, BEs DBD03BOCSF (DC BUS 03BDCS FAULT) and %TDC2 (Loss of DC Bus B IE) were set to zero. This resulted in an internal and external benefit (with uncertainty) of approximately $3,912,412. This analysis case was used to model the benefit of phase II SAMA 3.
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| Case 4: Increase Availability of On-Site AC Power This analysis case was used to evaluate the change in plant risk from improving the 4.16 kV bus cross-tie ability. Two bounding analyses were performed, conservatively ANDing the failure of 4.16 kV bus 3B3-S logic (E100) with the logicfor4.16 kV BUS 3A3-S (E300) and vice versa. It was determined that adding a crosstie from 4.16 kV BUS 3B3-S to 4.16 kV BUS 3A3-S would give the maximum CDF reduction, and the following changes were made in order to evaluate this SAMA case: Gate E100 was ANDed with E300, gate E100JZ was ANDed with E300JZ, gate E100-L2 was ANDed with E300-L2, gate E100X was ANDed with E300X, and gates E0003B3S_L 1 and E0003A3S_L 1 were ANDed under gates E507 A, E508A, and E51 OA. This SAMA case resulted in an internal and external benefit (with uncertainty) of approximately
| |
| $4,047,285. This analysis case was used to model the benefit of Phase II SAMA 5.
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| Case 5: Reduce Loss of Off-Site Power This SAMA analysis evaluated the change in plant risk from installing an additional buried off-site power source or burying off-site power lines. A bounding analysis was performed by changing the frequency of % TS initiator to 1. 79E-02 /rx-critical-yr by removing severe weather contribution based on PSA-WF3-01-IE-01, which resulted in an internal and external benefit (with uncertainty) of approximately $1,816, 135. This analysis case was used to model the benefit of Phase II SAMAs 6 and 10.
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| Case 6: Provide Backup EOG Cooling This analysis case was used to evaluate the change in plant risk from increasing EOG reliability by adding a backup source of diesel cooling. A bounding analysis was performed by eliminating failure of CCW cooling to the EOG gates. Gates EMMCCAVALV, S002, S002-L2, and BE SCCMDPSTRT were deleted from gates E340 and E340-L2 and gates EMMCCBVALV, S502, S502-L2, and event SCCMDPSTRT were deleted from gates E140 and E140-L2. Also, gate EMMCCAVALV was deleted from E340X and EMMCCBVALV was deleted from E140X, which resulted in an internal and external benefit (with uncertainty) of approximately $1,337,906. This analysis case was used to model the benefit of phase II SAMAs 8 and 9.
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| Case 7: Reduced Frequency of Loss of Auxiliary Component Cooling Water This analysis case was used to evaluate the change in plant risk from adding the ability to cross-tie the ACCW trains. Since Waterford 3 does not have a traditional service water system, the closest system is the ACCW system. WF3 can't currently cross-tie the ACCW pumps for cooling. A bounding analysis was performed to evaluate adding the ability to cross-tie the ACCW trains by removing ACCW gates 0519, 0527, S133, S233, S133-L2, and S233-L2 which resulted in an internal and external benefit (with uncertainty) of approximately $183,427. This analysis case was used to model the benefit of phase II SAMAs 21, 22 and 23.
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| Page D-84
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Case 8: Increased availability of feedwater Description/Evaluation This analysis case was used to evaluate the change in plant risk from increased availability of feedwater. A bounding analysis was performed by eliminating DWST failure to supply the CSP in the PSA model. Basic events QHFCSPEMPP, QPP6CD250J, QXVDW4411K, QCVCMU123N, OXVDW4414K, QXVCMU141K, QXVCMU142K, and QXVCMU141N were set to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $46,934. This analysis case was used to model the benefit of phase II SAMA 32.
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| Case 9: High Pressure Safety Injection System This analysis case evaluated the change in plant risk from plant modifications that would increase the availability of high pressure safety injection. A bounding analysis was performed by eliminating failure of HPSI in the PSA model by replacing gates H1000, H 1OOO_REC, and H2000 with a single basic event set to zero representing the new HPSI system, which resulted in an internal and external benefit (with uncertainty) of approximately $541,919. This analysis case was used to model the benefit of phase II SAMAs 13 and 17.
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| Case 10: Extend Reactor Water Storage Pool Capacity This analysis case was used to evaluate the change in plant risk from throttling RWSP demands and providing additional makeup to the RWSP to maintain RWSP inventory. Due to an increase in RWSP inventory, more time is available to swap ECCS pump suction from the RWSP to the Safety Injection Sump. A bounding analysis was performed by setting two operator actions to zero, HHFISOMINP and HHFMANRA_P, and also setting the tank rupture probability, HTK3RWSPRJ, to zero. This resulted in an internal and external benefit (with uncertainty) of
| |
| $37,457. This analysis case was used to model the benefit of phase II SAMAs 16, 29, 30, and 49.
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| Case 11: Eliminate ECCS Dependency on Component Cooling Water System This analysis case was used to evaluate the change in plant risk from replacing ECCS pump motors with air-cooled motors. A bounding analysis was performed by eliminating failure of ECCS motor cooling due to failure of CCW in the PSA model [CCWTOA, CCWTOABA, CCWTOB, CCWTOABB, L 130, and L230 were deleted], which resulted in an internal and external benefit (with uncertainty) of $361,328.This analysis case was used to model the benefit of phase II SAMA 20.
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| Case 12: Increase Availability of ACCW This analysis case was used to evaluate the change in plant risk from adding redundant power to the dry cooling tower fans, wet cooling tower fans, and ACCW pumps. A bounding analysis was performed by eliminating the DC control power gates to the ACCW pumps (gate D200A under S 135 and Gate D1 DOA under S235) and the DC power logic to the dry and wet cooling tower fans (Gates SA51 R3, SA52R3, SB51 R3, and SB52R3), which resulted in an internal and external benefit (with uncertainty) of approximately $18,655.This analysis case was used to model the benefit of phase II SAMA 19.
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| Page D-85
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Case 13: Low Pressure Safety Injection System This analysis case was used to evaluate the change in plant risk from adding an alternate Low Pressure Safety Injection system. A bounding analysis was performed by eliminating failure of the Low Pressure Safety Injection system in the PSA model [gate L 1000 was deleted], which resulted in an internal and external benefit (with uncertainty) of approximately $39. This analysis case was used to model the benefit of phase II SAMAs 14 and 15.
| |
| Case 14: Increase Component Cooling Water Availability This analysis case was used to evaluate the change in plant risk from installing an additional component cooling water pump. A bounding analysis was performed by eliminating failure of CCW pump failures and CCFs in the PSA model. Events SCCMOPNRUN, SMPCCW-ABG, SMPCCW-ABB, SHFCCWPABA, STMCCWPABF, CCWABSTBY, SMP3CCW1 BGS, STMCCWPPBF, SMP3CCW1 BBS, CCWBSTBY, SMP3CCW1AGS, STMCCWPPAF, CCWASTBY, SMP3CCW1ABS were set to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $3,532,265. This analysis case was used to model the benefit of phase II SAMA 27.
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| Case 15: Decreased Charging Pump Failure This analysis case was used to evaluate the change in plant risk from increasing availability of electrical power to the normal charging pump by adding an alternate power source. A bounding analysis was performed by eliminating the normal charging pump power gates in the PSA model.
| |
| Gates E604 and R384 under R392, and gate E604 under RABFAIL were deleted, which resulted in an internal and external benefit (with uncertainty) of approximately $96, 156. This analysis case was used to model the benefit of phase II SAMA 12.
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| Case 16: Reactor Coolant Pump Seals This analysis case was used to evaluate the change in plant risk from improving the RCP seals or cooling system. A bounding analysis was performed by eliminating RCP Seal LOCA. in the PSA model. Initiators %RCP and %T9RCP were set to zero and gate QT02 was dele~ed, which resulted in an internal and external benefit (with uncertainty) of approximately $3,969,811. This analysis case was used to model the benefit of phase II SAMAs 24, 25, and 26.
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| Case 17: Main Feedwater System Reliability This analysis case was used to evaluate the change in plant risk from installing a motor-driven feedwater pump. A bounding analysis was performed by setting loss of main feedwater to zero in the PSA model. Initiator% T4 was set to zero and gate BT02 was deleted, which resulted in an internal and external benefit (with uncertainty) of approximately $2,637,923. This analysis case was used to model the benefit of phase II SAMA 33.
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| Case 18: EOG Fuel Oil This analysis case was used to evaluate the change in plant risk from installing a large volume EOG fuel oil tank at an elevation greater than the EOG fuel oil day tanks. A bounding analysis was performed by setting the failure of the fuel oil pumps to zero in the PSA model [basic events ETKFOTNKAK, ETKFOTNKAG, ECVEG109AN, EXVEG117AK, EXVEG111AK, ETKFOSTKAJ, EXVF0105AK,ETKFOSTKAG,EHFFOXFRAA,ETKFOTNKBK,ETKFOTNKBG,ECVEG109BN, Page D-86
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage EXVEG117BK,EXVEG111BK,ETKFOSTKBJ,EXVF0105BK,ETKFOSTKBG,EHFFOXFRBA, EMPOILTRAL, EMPOILTRAA, ECCFOXFRA, ECCFOXFRF, EMPOILTRBF, EMPOILTRBL, EMPOILTRBA, and EMPOIL TRAF were set to zero] which resulted in an internal and external benefit (with uncertainty) of approximately $2, 722, 110. This analysis case was used to model the benefit of phase II SAMA 11.
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| Case 19: Intentionally Left Blank Case 20: Create a reactor coolant depressurization system This analysis case was used to evaluate the change in plant risk from creating a reactor coolant depressurization system. A bounding analysis was performed by eliminating small LOCA events by setting events #SB, #SU, and #SX to zero. This resulted in an internal and external benefit (with uncertainty) of approximately $465, 700. This analysis case was used to model the benefit of phase II SAMA 18.
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| Case 21 : Steam Generator Inventory This analysis case was used to evaluate the change in plant risk from using the fire water system as a backup for steam generator inventory. A bounding analysis was performed by reducing the frequency of the turbine-driven AFW pump and failure of local operation of AFW during SBO in the PSA model [gates 0304, 0305, 0471, 0481, 0120, 0202, and EFW were ANOed with a basic event set to 1.0E-03 (based conservatively on the failure of the entire firewater system)],
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| \ which resulted in an internal and external benefit (with uncertainty) of approximately $8,212,217.
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| This analysis case was used to model the benefit of phase II SAMA 34.
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| Case 22: Instrument Air Reliability This analysis case was used to evaluate the change in plant risk from increasing the reliability of the Instrument Air system. A bounding analysis was performed by eliminating the loss of the Instrument Air System initiating event in the PSA model [Initiator% TIA was set to zero, and gates 1110, IMM3SLWTRA, IMM3SLWTRB, MMM3SLWTRA, MMM3SLWTRB, MMM3SLWTRC were pruned and set to zero], which resulted in an internal and external benefit (with uncertainty) of approximately $4,532. This analysis case was used to model the benefit of phase II SAMA 37.
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| Case 23: Increased availability of HVAC This analysis case was used to evaluate the change in plant risk from a loss of HVAC in the battery, EOG, and main control rooms with temporary HVAC such as fans, portable coolers, or opening doors. A bounding analysis was performed by running three cases, each eliminating one system; MCR HVAC (gate W001), EOG room 3A cooling (gate U007), and EOG room 38 cooling
| |
| .(gate U008). It was determined that removing the EOG room 3A cooling gate U007 would provide the most benefit. This case resulted in an internal and external benefit (with uncertainty) of approximately $1,550,385. This analysis case was used to model the benefit of phase II SAMAs 35 and 36.
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| Page D-87
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Case 24: Debris coolability and core concrete interaction This analysis case was used to evaluate the change in plant risk from enhancing debris coolability and mitigating core concrete interaction. A bounding analysis was performed by eliminating failure of debris coolability and core concrete interaction in the PSA model [Gate CMR_3 under gate CMR, gate XCAV underneath gate Hl_2F, and basic event CAV-FSUMP underneath gate VB_FAIL were deleted and basic event BMT was set to zero], which resulted in an internal and external benefit (with uncertainty) of approximately $61, 182. This analysis case was used to model the benefit of phase II SAMAs 38, 47, 72, and 73.
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| Case 25: Decay Heat Removal Capability This analysis case was used to evaluate the change in plant risk from installing a containment vent. A bounding analysis was performed by eliminating late containment failure due to over-pressurization in the PSA model [BE Flags #CFL2, #CFL3, #CFL4, and #CFL5 were set to FALSE], which resulted in an internal and external benefit (with uncertainty) of approximately
| |
| $2,612,900. This analysis case was used to model the benefit of phase II SAMAs 41 and 42.
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| Case 26: Improve Containment Spray Capability This analysis case was used to evaluate the change in plant risk from improving the Containment Spray system. A bounding analysis was performed by reducing failure of containment spray in the PSA model. Gate Y001L1 was ANDed with an event set to 1.0E-03, and events P_CSFAILS and YHFSPRAYLP were set to 1.0E-03 based conservatively on the failure of the entire containment spray system, which resulted in an internal and external benefit (with uncertainty) of approximately $3,864,827. This analysis case was used to model the benefit of phase II SAMAs 39, 40, and 50.
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| Case 27: Reduce Hydrogen Ignition This analysis case was used to evaluate the change in plant risk from implementing means to reduce hydrogen ignition. A bounding analysis was performed by eliminating hydrogen detonation in the PSA model. Basic events H2GLOBCON, CNTH2FAILG, H2LOCCON, CNTH2FAILL, H2LCH, H2LCL, CNTFAILLCH, CNTFAILLCL, H2HCL, CNTFAILHCL, H2HCH, CNTFAILHCH, P_IGN, P_H2BURN were set to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $25,290. This analysis case was used to model the benefit of phase II SAMAs 43, 51, and 52.
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| Case 28: Increase Cooling and Containment of Molten Core Debris This analysis case was used to evaluate the change in plant risk from creating a large concrete crucible to contain molten core debris or creating a core melt reduction system. A bounding analysis was performed by eliminating containment core melt propagation in the PSA model.
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| Basic events BMT, X_BMT, and PRCOOLDBIV were set to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $6,946,981. This analysis case was used to model the benefit of phase II SAMAs 44, 45, and 46.
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| Case 29. High Pressure Core Ejection Occurrences This analysis case was used to evaluate the change in plant risk from erecting a barrierthat would \
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| provide enhanced protection of the containment walls (shell) from ejected core debris following a '
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| Page D-88
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage core melt scenario at high pressure. A bounding analysis was performed by eliminating high pressure core ejection occurrences in the PSA model [basic events HPME, and X_BMT were set to zero], which resulted in an internal and external benefit (with uncertainty) of approximately
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| $6,885,811. This analysis case was used to model the benefit of phase II SAMA 53.
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| Case 30: Reduce Probability of Containment Failure This analysis case was used to evaluate the change in plant risk from constructing a building to be connected to the primary/secondary containment and maintained at a vacuum. A bounding analysis was performed by eliminating containment failure from the PSA model [BE Flags #CFE2,
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| #CFL3, #CFL2, #CFL4 , and #CFL5 were set to FALSE], which resulted in an internal and external benefit (with uncertainty) of appro!{imately $10,535,565. This analysis case was used to model the benefit of phase II SAMA 48.
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| Case 31 : Containment Isolation This analysis case was used to evaluate the change in plant risk from adding redundant and diverse limit switches to each containment isolation valve. A bounding analysis was performed by eliminating containment isolation failure by setting #CIF to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $14,752. This analysis case was used to model the benefit of Phase II SAMA 55.
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| Case 32: Reduce Frequency of Steam Generator Tube Ruptures This SAMA analysis case was used to evaluate the change in plant risk with reducing the frequency of steam generator tube ruptures. A bounding analysis was performed by eliminating steam generator tube ruptures in the PSA model by setting events %R, #Tl-SGTR, Tl-SGTR_SBO, Tl_SGTR and Tl-SGTR_NOSBO, Pl_SGTR_SBO, #Pl-SGTR-SBO, Pl-SGTR_NOSBO, Pl_;SGTR, and #Pl-SGTR to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $694,437. This analysis case was used to model the benefit of phase II SAMAs 56, 57, 58, 59, and 60.
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| Case 33: Reduce Consequences of Steam Generator Tube Ruptures This analysis case was used to evaluate the change in plant risk from implementing mitigation strategies for reducing steam generator tube rupture consequences. A bounding analysis was performed by reassigning the SGTR CDF contribution from H-E (2.17E-7 per year) to release category L-1. The frequency of 2.17E-7 was determined by eliminating the SGTR contribution to H-E by eliminating or setting to zero gates UR01_1 and UR01_2 along with basic events
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| #Tl-SGTR, Tl-SGTR_SBO, Tl_SGTR, Tl-SGTR_NOSBO, Pl_SGTR_SBO, #Pl-SGTR-SBO, Pl-SGTR_NOSBO, Pl_SGTR, and #Pl-SGTR. This resulted in an internal and external benefit (with uncertainty) of approximately $100,807. This analysis case was used to model the benefit of phase II SAMA 61 .
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| Case 34: Reduce ATWS Frequency This analysis case was used to evaluate the change in plant risk from reducing the A TWS frequency and consequences. A bounding analysis was performed by setting the A TWS events from the PSA model [#TK, #TKQ, and #TKC] to FALSE, which resulted in an internal and external benefit (with uncertainty) of approximately $39,577. This analysis case was used to model the benefit of phase II SAMAs 63, 64, 65, and 66.
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| Page D-89
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Case 35: Intentionally Left Blank Case 36: Intentionally Left Blank Case 37: Reduce Probability of a LOCA This analysis case was used to evaluate the change in plant risk from installing a digital large break LOCA protection system. A bounding analysis was performed by setting the initiators for a Large LOCA (%A) and a medium LOCA (%M) to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $28,650. This analysis case was used to model the benefit of phase II SAMA 69.
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| Case 38: Prevent Secondary Side Depressurization This analysis case was used to evaluate the change in plant risk from installing secondary side guard pipes up to the main steam isolation valves. A bounding analysis was performed by eliminating the initiator for a steam line break outside containment or the inadvertent closure of MS IVs in the PSA model by setting events %T6 and % T60C to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $10,417. This analysis case was used to model the benefit of phase II SAMA 70.
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| Case 39: Eliminate Thermally Induced Tube Ruptures Following Core Damage This analysis case was used to evaluate modifying procedures such that the water loop seals in the reactor cooling system (RCS) cold legs are not cleared following core damage. A bounding analysis was performed by eliminating thermal induced steam generator tube rupture events by setting events #Tl-SGTR, Tl_SGTR, Tl-SGTR_SBO, and Tl-SGTR_NOSBO to zero. This resulted in an internal and external benefit (with uncertainty) of approximately $29,591. This analysis case was used to model the benefit of phase II SAMA 54.
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| Case 40: Replace CARMVAAA201-B with a fail closed AOV This analysis case was used to evaluate replacing MOV CARMVAAA201-B to remove its AC power dependency. A bounding analysis was performed by eliminating motive power dependency from gate JMMCAR201 C (Gate G024), which resulted in an internal and external benefit (with uncertainty) of approximately $0. This analysis case was used to model the benefit of phase II SAMA 62.
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| Case 41: Improve internal flooding response procedures and training This analysis case was used to evaluate the change in plant risk from improving internal flooding response procedures and training to improve the response to internal flooding events.
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| The WF3 internal flooding notebook states the following for the modified operator actions:
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| Based on a review of the operator actions impacted by internal flooding three actions in Turbine Generator Building +15 elevation and one action on Reactor Auxiliary Building +46 elevation were Page D-90
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage identified. Therefore, two additional rule recovery files, recovery_rulesTB15.txt and recovery_rulesRAB46.txt, were developed that removed the actions on these elevations.
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| Since the internal event risk analysis does not include internal flooding, this internal flooding SAMA would not mitigate internal event risk. A bounding analysis was performed by assuming the SAMA would eliminate the contribution to internal flooding CDF in the Turbine Generator Building
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| +15 elevation and Reactor Auxiliary Building +46 elevation. The total internal flooding CDF is 2.48E-06/rx-yr [D.2-9]. This analysis case was used to model the benefit of phase II SAMA 67.
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| The internal flooding CDF eliminated is as follows:
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| Event CDF RAB46-299-A 1.58E-08 RAB46-299-B 1.58E-08 RAB46-300-46E-46W-A 3.26E-09 RAB46-300-46E-46W-B 1.62E-09 TB15-250-3 1.94E-08 TB15-250-1B 1.13E-08 TB15-250-5 2.05E-09 TB15-250-2 6.47E-10 TB15-250-4 4.00E-10 TB15-250-1A 6.14E-11 TB15-250-1 3.29E-12 Total 7.03E-08 The percent reduction is 7.03E-08/2.48E-06 = 2.83%
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| The internal events model cannot be used to assess the benefit from this internal flooding SAMA.
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| However, the consequences resulting from internal flooding core damage and internal event-induced core damage would be comparable. Since we have already estimated the maximum benefit from removing all internal event risk, the maximum benefit of removing all internal flooding risk can be estimated by reducing the maximum internal event benefit by the ratio of the total internal flooding CDF to the internal event CDF. The total internal flooding benefit is calculated below.
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| Given, Maximum internal benefit is $2, 163, 103 Total internal flooding CDF = 2.48E-06/rx-yr [D.2-9]
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| Internal events CDF = 1.05E-05/rx-yr Maximum internal flooding benefit = Maximum internal benefit x Total internal flooding GDF/Internal events CDF Maximum internal flooding benefit= $2, 163, 103 x (2.48E-06/1.05E-05) = $510,904 SAMA case 41 benefit= 2.83% x (Maximum internal flooding benefit)= 0.0283 x $510,904 SAMA case 41 benefit= $14,459 Applying the uncertainty factor of 1.99,
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| *SAMA case 41 benefit with uncertainty= $14,459 x 1.99 = $28,773 Page D-91
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Case 42: Water tight doors for the largest contributor to internal flooding This analysis case was used to evaluate the change in plant risk from installing flood doors to prevent water propagation in the electric board room. The electrical equipment rooms at WF3 do not have water tight flood doors. Specifically this SAMA will evaluate water tight doors for the largest contributor to internal flooding, which is flood zone RAB21-212/2258. This analysis case was used to model the benefit of phase II SAMA 68.
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| Since the internal event risk analysis does not include internal flooding, this internal flooding SAMA would not mitigate internal event risk. A bounding analysis was performed by assuming the SAMA would eliminate the contribution to internal flooding CDF from flood zone RAB21-212/2258.
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| The total internal flooding CDF is 2.48E-06/rx-yr [D.2-9].
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| The internal flooding CDF eliminated is as follows:
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| Event CDF RAB21-212-225B-80MIN 7.19E-07 RAB21-212-225B-45MIN 3.47E-10 RAB21-212-225B-15MIN 8.40E-11 RAB21-212-225B-15-45MIN 2.76E-11 Total 7.19E-07 The percent reduction is 7 .19E-07 /2.48E-06 = 28.99%
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| The internal events model cannot be used to assess the benefit from this internal flooding SAMA.
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| However, the consequences resulting from internal flooding core damage and internal event-induced core damage would be comparable. Since we have already estimated the maximum benefit from removing all internal event risk, the maximum benefit of removing all internal flooding risk can be estimated by reducing the maximum internal event benefit by the ratio of the total internal flooding CDF to the i.nternal event CDF. The total internal flooding benefit is calculated below.
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| : Given, Maximum internal benefit is $2, 163, 103 Total internal flooding CDF = 2.48E-06/rx-yr [D.2-9]
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| Internal events CDF = 1.05E-05/rx-yr Maximum internal flooding benefit = Maximum internal benefit x Total internal flooding GDF/Internal events CDF Maximum internal flooding benefit= $2, 163, 103 x (2.48E-06/1.05E-05) = $510,904 SAMA case 42 benefit= 28.99% x (Maximum internal flooding benefit) = 0.2899 x $510,904 SAMA case 42 benefit= $148, 111 Applying the uncertainty factor of 1.99, SAMA case 42 benefit with uncertainty= $148, 111 x 1.99 = $294,741
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| /
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| I Page D-92
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Case 43: Gagging device to close a stuck open safety valve This analysis case was used to evaluate installing a gagging device to close a stuck open safety valve. A bounding analysis was performed by eliminating the failure of stuck open relief valves by setting events PRYMS 1068T, PRYMS 112BT, PRYMS 1088T, PRYMS 1138T, PRYMS 11 OST, PRYMS114BT, PRYMS106AT, PRYMS112AT, PRYMS108AT, PRYMS113AT, PRYMS110AT, PRYMS114AT, and OHFMSSGAGR to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $76. This analysis case was used to model the benefit of phase II SAMA 71.
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| D.2.4 Sensitivity Analyses Two sensitivity analyses were conducted to gauge the impact of assumptions upon the analysis.
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| The benefits estimated for each of these sensitivities are presented in Table D.2-3.
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| A description of each sensitivity case follows.
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| Sensitivity Case 1: Years Remaining Until End of Plant Life The purpose of this sensitivity case was to investigate the sensitivity of assuming a 29-year period for remaining plant life (i.e. nine years on the original plant license plus the 20-year license renewal period), rather than the 20-year license renewal period used in the base case.
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| Changing this assumption does not cause additional SAMAs to be cost-beneficial.
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| Sensitivity Case 2: Conservative Discount Rate The purpose of this sensitivity case was to investigate the sensitivity of each analysis case to the discount rate. The discount rate of 7.0% used in the base case analyses is conservative relative to corporate practices. Nonetheless, a lower discount rate of 3.0% was assumed in this case to investigate the impact on each analysis case. Changing this assumption does not cause additional SAMAs to be cost-beneficial.
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| Page D-93
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.2.5 References D.2-1 Nuclear Energy Institute (NEI), NEI 05-01, Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance Document, November 2005, Revision A.
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| D.2-2 U.S. Nuclear Regulatory Commission (USNRC), NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Davis-Besse Nuclear Power Station (NUREG-1437, Supplement 52) Final Report, April 2015.
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| D.2-3 USNRC, NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding South Texas Project, Units 1 and 2 (NUREG-1437, Supplement 48) Final Report, November 2013.
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| D.2-4 USNRC, NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Callaway Plant, Unit 1 (NUREG-1437, Supplement 51) Final Report, October 2014.
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| D.2-5 USNRC, NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Seabrook Station (NU.REG-1437, Supplement 46) Final Report, July 2015.
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| D.2-6 USNRC, NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Sequoyah Nuclear Plant, Units 1 and 2 (NUREG-1437, Supplement 53) Final Report, March 2015.
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| D.2-7 Waterford 3 Probabilistic Risk Assessment Individual Plant Examination Submittal, August 1992.
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| D.2-8 WF3 IPEEE "Internal Plant Examination of External Events", Revision 0, July 1995.
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| D.2-9 WF3 Calculation No: PRA-W3-01-002, 'W3 Internal Flooding Analysis", Revision 3.
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| D.2-10 WF3-EP-14-00014, "Cost-Benefit Analysis of Severe Accident Mitigation Alternatives,"
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| Revision 0.
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| D.2-11 NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Arkansas Nuclear One, Unit 2 (NUREG-1437, Supplement 19)
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| Final Report", April 2005.
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| D.2-12 Entergy Letter NL-14-143, "Reply to Request for Additional Information Regarding the License Renewal Application," November 20, 2014(ML14337A042).
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| D.2-13 W3F1-2011-007 4, "License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)", November 2011.
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| Page D-94
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-1 Phase I SAMAs Related to IPE and IPEEE Insights Phase I SAMA Title Result of Potential Screening SAMA Disposition Credited in SAMA ID Enhancement Results PSA Model Number 183 Cross-tie of AC power trains. Proceduralize the process to #2 - Similar See disposition on SAMA 11. No cross-tie power from train A item is to train B equipment. The addressed ability to cross-tie power under other trains can have a significant proposed impact on preventing core SAM As melt when failure of one train is due to power failures.
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| 184 Install a portable generator to A portable generator that #3 -Already The AB battery is generally utilized to Yes charge the AB battery. can be used to continue to installed power the TDEFW pump. The TDEFW supply DC power to the EFW control system is operable until the turbine driven pump AB station battery reaches its controls (and necessary minimum voltage. At this time local monitoring instrumentation) manual control of the TDEFW pump is can decrease the likelihood implemented. Due to the length of of core melt before AC time before battery depletion and power is restored. the ability to perform manual operation it's not expected that additional charging capacity would have significant importance for the AB system. Therefore, the intent of this SAMA is considered to have already been implemented at WF3 Page D-95
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-1 Phase I SAMAs Related to IPE and IPEEE Insights Phase I SAMA Title Result of Potential Screening SAMA Disposition Credited in SAMA ID Enhancement Results PSAModel Number 185 Add guidance for aligning the LPSI !The LPSI pumps can be #3 -Already Using LPSI to replace containment No pump for containment spray. aligned to serve as installed spray is proceduralized in containment spray pumps OP-902-009, Appendix 28. The and therefore may provide a containment spray system is utilized backup to this function. in response to a large LOCA, however, Guidance for this alignment the operator action has not been would decrease the included in the PRA model due to probability of containment insufficient time to perform the failure caused by steam alignment.
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| overpressurization.
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| 186 Enhance refill of condensate storage Emphasize the need to refill #3 -Already For Emergency Feedwater (EFW) the Yes pool. the condensate storage pool installed CSP inventory is not sufficient for the (CSP) with acceptable 24 mission time, so either CSP quality water (or switch to makeup or transfer of the EFW the wet cooling tower basin) suction to the wet cooling towers in training. Makeup from (WCTs) via the ACCW system is other sources can extend needed.
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| the time for the coo Id own or If CSP level drops below 25%, the ensure continued heat operators are instructed to align EFW removal. suction to ACCW per OP-902-009, Appendix 10. Operators are trained to this procedure.
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| F .)-96
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| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-1 Phase I SAMAs Related to IPE and IPEEE Insights Phase I SAMA Title Result of Potential Screening SAMA Disposition Credited in SAMA ID Enhancement Results PSA Model Number 187 Provide feedwater from the fire The fire protection system #2 - Similar See disposition on SAMA 83. No protection system to the steam has its own diesel driven item is generator pumps. During station addressed blackouts or total loss of under other feedwater, this system could proposed provide an additional source SAM As of feedwater to remove heat from the RCS.
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| 188 Provide additional guidance for Room cooling failures are #2 - Similar See SAMA 93 for implementing No chiller/HVAC failure. important to the long term item is procedures for temporary HVAC.
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| operation of the HPSI and addressed EFW pumps. Additional under other guidance to address room proposed cooling failures can provide SAMAs information to identify actions to recover cooling and minimize the effects of room heatup.
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| 189 Provide water from the fire Providing water to the Retain This SAMA is being retained to No protection system to the reactor cavity from the fire consider providing water to the containment sump. protection system may reactor cavity from the fire prevent vessel breach by protection system.
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| allowing ex-vessel cooling.
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| Page D-97
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-1 Phase I SAMAs Related to IPE and IPEEE Insights Phase I SAMA Title Result of Potential Screening SAMA Disposition Credited in SAMA ID Enhancement Results PSA Model Number 190 Enhance communication between Increasing the flow area Retain This SAMA is being retained to No sump and cavity. through the door in the consider removal of the door in the ductwork (or removal of the ductwork to allow increased flow of door completely) will allow a water from the containment sump more free flow of water into the reactor cavity.
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| from the containment sump into the reactor cavity.
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| 191 Add a portable pump in the cooling Reduce risk due to external #3 -Already The licensee added a portable pump No tower area to mitigate excess flooding in the cooling tower installed in the cooling tower area to mitigate ponding due to a PMP or probable area. excess ponding due to a postulated maximum hurricane event. probable maximum precipitation or probable maximum hurricane event.
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| rrhis pump was added to the surveillance testing program.
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| 192 Remove or restrain the lockers and Reduce seismic risk in the #3 -Already The equipment identified was No file cabinets in the control room, Control Room installed analyzed for potential impact to remove book shelves in the vicinity safety-related equipment. As good of safety-related cabinets, and engineering practice the book cases relocate or restrain other loose near CP-22 and the tool cart in the items in the vicinity of safety-related EOG Room B were removed and cabinets. there was no additional impact to safety related equipment following the evaluation.
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| ::>-98
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-1 Phase I SAMAs Related to IPE and IPEEE Insights Phase I SAMA Title Result of Potential Screening SAMA Disposition Credited in SAMA ID Enhancement Results PSA Model Number 193 Revise procedure FP-001-17, Include guidance for #3 -Already Procedural guidance for temporary No Transient Combustibles and temporary storage of temp installed storage is provided in UNT-007-060 Designated Storage Areas. equipment inside the to prevent potentially hazardous Seismic Category I buildings situations under seismic conditions.
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| to prevent hazardous seismic interactions.
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| 194 Add fire wrap to the B Chilled Water A fire on Chiller A or Chilled #3 -Already Fire wrap has been installed in fire No cables in the vicinity of the A Chiller. Water Pump A could installed area RAB-2 to the B chilled water damage cables associated cables in the vicinity of the A chiller with Chiller train B. Adding and is being maintained in the NFPA fire wrap to the B train 805 submittal for defense in depth.
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| cables would add robustness Also, one of the NFPA-805 mods is in of the plant to fire hazards RAB 2 and is to construct a radiant in this fire area. heat barrier to further separate the A and B trains of chilled water pumps.
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| This change protects each trains chiller pump (and associated nearby equipment) from a fire in the opposite train.
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| 195 Evaluate why existing clearance for Reduces seismic risk for the #3 -Already CR-94-1111 contains the evaluation No the station air pipe which is adjacent equipment in the panel. installed that the existing clearance for the to 4KVESWGR3B XPANEL does not station air pipe which is adjacent to meet the clearance requirements 4KVESWGR3B will have no significant stated on the design drawing. adverse impact during a seismic condition.
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| Page D-99
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| ~
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| Case 1. SBO Eliminated SBO
| |
| .Reduction contribution. 34.4% 42.5% 44.5% $2,812,956 $5,597,783
| |
| : 1. Provide additional WF3 plant specific DC battery capacity. cost $3,172,695 Retain
| |
| : 2. Replace lead-acid WF3 plant specific Not cost batteries with fuel cells. cost $6, 185,319 effective
| |
| : 7. Install a gas turbine Davis-Besse cost generator. estimate $2,000,000 Retain Case 2. Improve Eliminated failure of Feedwater Reliability feedwater. 0.9% 0.2% 0.2% $17,769 $35,361
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| : 31. Install a digital feed Seabrook Cost Not cost water upgrade. estimate $6, 100,000 effective I; .D-100
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Changed gates to Case 3. Add DC require multiple DC System Cross-ties bus failures. 20.8% 31.0% 31.3% $1,966,036 $3,912,412
| |
| : 3. Provide DC bus WF3 plant specific cross-ties. cost $1,449,686 Retain Case 4. Increase Changed gates to Availability of On-Site require multiple AC AC Power bus failures. 22.2% 32.0% 32.3% $2,033,811 $4,047,285
| |
| : 5. Improve 4.16-kV bus WF3 plant specific cross-tie ability. cost $1,554,988 Retain Reduce the frequency of the LOOP initiator Case 5. Reduce Loss by removing severe of Off-Site Power weather contribution. 13.5% 13.7% 14.1% $912,630 $1,816,135
| |
| : 10. Bury off-site power Seabrook Cost Not cost lines. estimate $3,000,000 effective Page D-101
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 6. Install an additional, buried off-site power Seabrook Cost Not cost source. estimate $3,000,000 effective Eliminated failure of Case 6. Provide CCW cooling to the Backup EOG Cooling EDGs. 4.4% 10.8% 11.0% $672,315 $1,337,906
| |
| : 8. Use fire water system as a backup source for Seabrook Cost Not cost diesel cooling. estimate $2,000,000 effective
| |
| : 9. Add a new backup source of diesel Seabrook Cost Not cost cooling. estimate $2,000,000 effective Case 7. Reduced Frequency of Loss of Auxiliary Component Eliminated failure of Cooling Water ACCW. 6.4% 1.3% 0.7% $92,174 $183,427
| |
| : 21. Enhance procedural Generic cost estimate guidance for use of for procedural change cross- tied component with engineering and cooling or service water testing/training Not cost pumps. required. $200,000 effective F )-102
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| | |
| Waterford Steam Electric Srauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 22. Add a service water Sequoyah cost Not cost pump. estimate $1,043,000 effective
| |
| : 23. On loss of essential raw cooling water, proceduralize shedding Generic cost estimate component cooling for procedural change water loads to extend with engineering and the component cooling testing/training Not cost water heat-up time. required. $200,000 effective Case 8. Increased Eliminated DWST availability of failure to supply the feedwater CSP. 1.2% 0.3% 0.2% $23,585 $46,934
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| : 32. Create ability for emergency connection of existing or new water sources to feedwater and condensate WF3 plant specific Not cost systems. cost $885,760 effective Case 9. High Pressure Eliminated failure of Injection System HPSI. 8.4% 4.7% 3.4% $272,321 $541,919 Page D-103
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 17. Replace two of the four electric safety injection pumps with Callaway cost Not cost diesel-powered pumps. estimate $1,500,000 effective
| |
| : 13. Install an independent active or passive high pressure Callaway cost Not cost injection system. estimate $1,500,000 effective Case 10. Extend Reactor Water Reduced failure from Storage Pool operator actions and Capacity tank rupture. 1.8% 0.2% 0.1% $18,822 $37,457
| |
| : 16. Throttle low pressure injection pumps earlier in medium or large-break LOCAs to maintain reactor water storage Seabrook Cost Not cost tank inventory. estimate $3,000,000 effective
| |
| : 29. RWST fill from firewater during containment injection-Modify 6 inch RWST flush flange to have a 2%-inch female fire hose adapter with WF3 plant specific Not cost isolation valve. cost $747,640 effective F *)-104
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 30. High-volume makeup to the refueling Sequoyah cost Not cost water storage tank. estimate $565,000 effective
| |
| : 49. Install automatic containment spray pump header throttle Not cost valves. AN0-2 cost estimate $2,500,000 effective Case 11. Eliminate ECCS Dependency on Component Cooling Eliminated failure of Water System ECCS motor cooling. 0.7% 2.8% 3.1% $181,572 $361,328
| |
| : 20. Replace ECCS pump motors with Seabrook Cost Not cost air-cooled motors. estimate $6,000,000 effective Eliminated the DC Case 12. Increase control power gates to Availability of ACCW the ACCW pumps. 0.2% 0.1% 0.1% $9,374 $18,655
| |
| : 19. Add redundant DC control power for SW Callaway cost Not cost pumps. estimate $100,000 effective Page D-105
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Eliminated failure of Case 13. Low the Low Pressure Pressure Safety Safety Injection Injection System system. 0.0% 0.0% 0.0% $20 $39
| |
| : 14. Add a diverse low pressure injection Callaway cost Not cost system. estimate $1,000,000 effective
| |
| : 15. Provide capability for alternate injection via diesel-driven fire Davis-Besse cost Not cost pump. estimate $6,500,000 effective Case 14. Increase Eliminated failure of Component Cooling CCW pump failures Water Availability and CCFs. 13.5% 28.1% 29.0% $1,775,007 $3,532,265
| |
| : 27. Install an additional component cooling Seabrook Cost Not cost water pump. estimate $6,000,000 effective Case 15. Decreased Eliminated the normal Charging Pump charging pump power Failure gates. 0.4% 0.8% 0.8% $48,319 $96,156 p )-106
| |
| | |
| i' Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 12. Install modification to power the normal charging pump from an existing spare breaker from the alternate emergency power Callaway cost Not cost system. estimate $350,000 effective Case 16. Reactor Eliminated RCP Seal Coolant Pump Seals LOCA. 16.0% 31.6% 32.4% $1,994,880 $3,969,811
| |
| : 24. Install an independent reactor coolant pump seal injection system, with Seabrook Cost Not cost dedicated diesel. estimate $6,400,000 effective
| |
| : 25. Install an independent reactor coolant pump seal injection system, without dedicated Seabrook Cost Not cost diesel. estimate $6,400,000 effective
| |
| : 26. Install improved reactor coolant pump Seabrook Cost seals. estimate $2,000,000 Retain Page D-107
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Case 17. Main Feedwater System Set loss of main Reliability feedwater to zero. 33.3% 19.5% 18.5% $1,325,589 $2,637,923
| |
| : 33. Add a motor-driven Sequoyah cost Not cost feedwater pump. estimate $10,000,000 effective Set the failure of fuel Case 18. EOG Fuel Oil oil pumps to zero. 17.1% 20.8% 21.5% $1,367,894 $2,722,110
| |
| : 11. Install a large volume EOG fuel oil tank at an elevation greater than the EOG Callaway cost fuel oil day tanks. estimate $150,000 Retain Case 20. Create a reactor coolant depressurization Eliminated small system LOCA events. 14.5% 3.8% 1.9% $234,020 $465,700
| |
| : 18. Create a reactor coolant depressurization Callaway cost Not cost system. estimate $500,000 effective
| |
| | |
| Waterford Steam Electric 8tauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Reduced the frequency of turbine-driven AFW Case 21. Steam pump failure during Generator Inventory SBO. 67.3% 61.8% 62.9% $4,126,742 $8,212,217
| |
| : 34. Use fire water system as a backup for steam generator Cost from Indian Point inventory. (IP2) $3,073,130 Retain Case 22. Instrument Eliminated the loss of Air Reliability Instrument Air. 0.1% 0.0% 0.0% $2,278 $4,532
| |
| : 37. Replace service and instrument air compressors with more reliable compressors which have self-contained air cooling by shaft driven Callaway cost Not cost fans. estimate $500,000 effective Case 23. Increased Eliminated failure of Availability of HVAC EOG room 3A cooling. 9.4% 11.9% 12.3% $779,088 $1,550,385 Page D-109
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert ,WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 35. Provide a redundant train or means of WF3 plant specific Not cost ventilation. cost $3,574,481 effective
| |
| : 36. Implement procedures for Callaway cost temporary HVAC. estimate $100,000 Retain Eliminated failure of Case 24. Debris debris coolability and coolability and core core concrete concrete interaction interaction. 0.0% 0.5% 0.5% $30,745 $61,182
| |
| : 38. Create a reactor Cost from Indian Point Not cost cavity flooding system. (IP2) $1,741,724 effective
| |
| : 47. Provide a reactor vessel exterior cooling Not cost system.* Cost f ram AN0-2 $2,500,000 effective
| |
| : 72. Provide water from the fire protection system to the WF3 plant specific Not cost containment sump. cost $715,918 effective I: D-110
| |
| | |
| Waterford Steam Electric 8tat1on Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 73. Enhance communication between sump and WF3 plant specific Not cost cavity. cost $702,551 effective Eliminated late containment failure Case 25. Decay Heat due to Removal Capability over-pressurization. 0.0% 21.5% 22.8% $1,313,015 $2,612,900
| |
| : 41. Install an unfiltered, hardened containment Seabrook cost Not cost vent. estimate $3,000,000 effective
| |
| : 42. Install a filtered containment vent to remove decay heat Option 1: Gravel Bed Filter Option 2: Multiple Seabrook cost Not cost Venturi Scrubber estimate $20,000,000 effective Case 26. Improve Containment Spray Reduced failure of Capability containment spray. 5.8% 17.2% 35.9% $1,942,124 $3,864,827
| |
| : 39. Install a passive containment spray Seabrook cost Not cost system. estimate $10,000,000 effective Page D-111
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 50. Install a redundant containment spray Seabrook cost Not cost system. estimate $10,000,000 effective
| |
| : 40. Use the fire water system as a backup source for the containment spray WF3 plant specific system. cost $2,455,808 Retain Case 27. Reduce Eliminated hydrogen Hydrogen Ignition detonation. 0.0% 0.3% 0.2% $12,709 $25,290
| |
| : 43. Provide post-accident containment inerting Callaway cost Not cost capability. estimate $100,000 effective
| |
| : 51. Install an independent power supply to the hydrogen control system using either new batteries, a non-safety grade portable generator, existing station batteries, or existing AC/DC independent power supplies, such as Callaway cost Not cost the security system estimate $100,000 effective F '.D-112
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion diesel.
| |
| : 52. Install a passive hydrogen control Seabrook cost Not cost system. estimate $100,000 effective Case 28. Increase Cooling and Eliminated Containment of containment core melt Molten Core Debris propagation. 0.0% 54.3% 61.1% $3,490,945 $6,946,981
| |
| : 44. Create a large concrete crucible with heat removal potential to contain molten core Callaway cost Not cost debris. estimate $10,000,000 effective
| |
| : 45. Create a core melt source reduction Callaway cost Not cost system. estimate $10,000,000 effective
| |
| : 46. Increase depth of the concrete base mat or use an alternate concrete material to ensure melt- through Callaway cost Not cost does not occur. estimate $10,000,000 effective Page D-113
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Case 29. High Eliminated high Pressure Core pressure core ejection Ejection Occurrences occurrences. 0.0% 53.8% 60.6% $3,460,207 $6,885,811
| |
| : 53. Erect a barrier that would provide enhanced protection of the containment walls (shell) from ejected core debris following a core melt scenario at Callaway cost Not cost high pressure. estimate $10,000,000 effective Case 30. Reduce Probability of Eliminated Containment Failure containment failure. 0.0% 84.6% 92.2% $5,294,254 $10,535,565
| |
| : 48. Construct a building to be connected to primary/secondary containment and maintained at a Seabrook cost Not cost vacuum. estimate $56,700,000 effective Eliminated Case 31. Containment containment isolation Isolation failure. 0.0% 0.1% 0.1% $7,413 $14,752
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| | |
| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 55. Add redundant and diverse limit switches to each containment Sequoyah cost Not cost isolation valve. estimate $692,000 effective Case 32. Reduce Frequency of Steam Eliminated steam Generator Tube generator tube Ruptures ruptures. 1.0% 5.6% 5.9% $348,963 $694,437
| |
| : 56. Institute a maintenance practice to perform a 100%
| |
| inspection of steam generator tubes during Callaway cost Not cost each refuelinq outaqe. estimate $3,000,000 effective
| |
| : 57. Increase the pressure capacity of the secondary side so that a steam generator tube rupture would not cause Callaway cost Not cost the relief valves to lift. estimate $10,000,000 effective
| |
| : 58. Install a redundant spray system to depressurize the primary system during a steam generator tube Callaway cost Not cost rupture estimate ' $10,000,000 effective Page D-115
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 59. Route the discharge from the main steam safety valves through a structure where a water spray would condense the steam and remove most of Callaway cost Not cost the fission products. estimate $10,000,000 effective
| |
| : 60. Install a highly reliable (closed loop) steam generator shell-side heat removal system that relies on natural circulation and Callaway cost Not cost
| |
| *-
| |
| stored water sources estimate $10,000,000 effective Case 33. Reduce Reassigned the SGTR Consequences of CDF contribution from Steam Generator H-E release category Tube Ruptures to release category L-1. 0% 0% 1.4% $50,657 $100,807
| |
| : 61. Direct steam Generic cost estimate generator flooding after for procedural change a steam generator tube with engineering and rupture, prior to core testing/training Not cost damage. required. $200,000 effective Case 34. Reduce Eliminated ATWS ATWS Frequency contribution. 1.4% 0.3% 0.2% $19,888 $39,577 F ~ D-116
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| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 63. Add an independent Seabrook cost Not cost boron injection system. estimate $500,000 effective
| |
| : 64. Add a system of relief valves to prevent equipment damage from pressure spikes Seabrook cost Not cost during an ATWS. estimate $500,000 effective
| |
| : 65. Install motor generator set trip breakers in control Sequoyah cost Not cost room. estimate $100,000 effective
| |
| : 66. Provide capability to remove power from the bus powering the Sequoyah cost Not cost control rods. estimate $100,000 effective Eliminated the initiators for a Large Case 37. Reduce LOCA and a medium Probability of a LOCA LOCA. 0.4% .0.2% 0.2% $14,397 $28,650
| |
| : 69. Install digital large break LOCA protection Seabrook cost Not cost system. estimate $500,000 effective Page D-117
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Eliminated the initiator for a steam line break Case 38. Prevent outside containment Secondary Side and for inadvertent Depressu rization closure of MSIVs. 0.3% 0.1% 0.0% $5,235 $10,417
| |
| : 70. Install secondary side guard pipes up to the main steam Seabrook cost Not cost isolation valves. estimate $500,000 effective Case 39. Eliminate Thermally Induced Eliminated thermal Tube Ruptures induced steam Following Core generator tube Damage rupture. 0.0% 0.2% 0.3% $14,870 $29,591
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| : 54. Modify procedures such that the water loop seals in the reactor cooling system (RCS) cold legs are not cleared following core South Texas cost Not cost damage. estimate $100,000 effective Eliminated motive Case 40. Replace power dependency CARMVAAA201-B from MOV with a fail closed AOV CARMVAAA201-B. 0.0% 0.0% 0.0% $0 $0
| |
| : 62. Hardware change to eliminate MOV CS-V-17 AC power Seabrook cost Not cost dependency. estimate $300,000 effective F )-118
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Eliminated the contribution to internal flooding CDF from Case 41. Improve floods in the Turbine Internal Flooding Generator Building Response + 15 elevation and Procedures and Reactor Auxiliary 1
| |
| Training Building +46 elevation. N/A N/A N/A $14,459 $28,773
| |
| : 67. Improve internal flooding response procedures and training to improve the response to internal Sequoyah cost Not cost flooding events. estimate $400,000 effective Eliminated the Case 42. Water tight contribution to internal doors for the largest flooding CDF from contributor to internal floods in flood zone 1
| |
| flooding RAB21-212/225B. N/A N/A N/A $148,111 $294,741
| |
| : 68. Install flood doors to prevent water propagation in the Sequoyah cost Not cost electric board room. estimate $4,695,000 effective Case 43. Gagging device to close a Eliminated failure stuck open safety events for of stuck valve open relief valves. 0.0% 0.0% 0.0% $38 $76 Page D-119
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 71. Manufacture a gagging device for a steam generator safety valve and developing a procedure or work order for closing a stuck-open Seabrook cost Not cost valve. estimate $30,000 effective These SAMA candidates were retained without evaluation as they are already commitments in the NFPA 805 LAR
| |
| [D.2-13] N/A N/A N/A N/A N/A N/A
| |
| : 74. In Fire Area RAB 2 construct a radiant heat barrier to further separate the A and B This modification is trains of chilled water from the Waterford 3 pumps. NFPA 805 LAR N/A N/A N/A N/A N/A N/A Retain
| |
| : 75. In Fire Area RAB 8C construct a radiant heat This modification is shield in Switchgear from the Waterford 3 Room A/B. NFPA 805 LAR N/A N/A N/A N/A N/A N/A Retain
| |
| : 76. In Fire Area RAB 6 install a 1-hour fire resistance rating This modification is ERFBS fire wrap barrier from the Waterford 3 from fire damage. NFPA 805 LAR N/A N/A N/A N/A N/A N/A Retain
| |
| \1)
| |
| These analysis cases only impact internal flooding and have been evaluated as described in Section D.2.3.
| |
| D-120
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| | |
| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate($)
| |
| Case 1. SBO Reduction $2,812,956 $3,312,210 $3,889,025
| |
| : 1. Provide additional DC battery capacity. $3,172,695
| |
| : 2. Replace lead-acid batteries with fuel cells. $6,185,319
| |
| : 7. Install a gas turbine generator. $2,000,000 Case 2. Improve Feedwater Reliability $17,769 $22,368 $23,693
| |
| : 31. Install a digital feed water upgrade. $6,100,000 Case 3. Add DC System Cross-ties $1,966,036 $2,308,511 $2,722,034
| |
| : 3. Provide DC bus cross-ties. $1,449,686 Case 4. Increase Availability of On-Site AC Power $2,033,811 $2,389,512 $2,815,012
| |
| : 5. Improve 4.16-kV bus cross-tie ability. $1,554,988 Case 5. Reduce Loss of Off-Site Power $912,630 $1,079,233 $1,258,950
| |
| : 10. Bury off-site power lines. $3,000,000
| |
| : 6. Install an additional, buried off-site power source. $3,000,000 Page D-121
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% . Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| Case 6. Provide Backup EOG Cooling $672,315 $783,999 $934,124
| |
| : 8. Use fire water system as a backup source for diesel cooling. $2,000,000
| |
| : 9. Add a new backup source of diesel cooling. $2,000,000 Case 7. Reduced Frequency of Loss of Auxiliary Component Cooling Water $92,174 $119,090 $121,050
| |
| : 21. Enhance procedural guidance for use of cross-tied component cooling or service water pumps. $200,000
| |
| : 22. Add a service water pump. $1,043,000
| |
| : 23. On loss of essential raw cooling water, Proceduralize shedding component cooling water loads to extend the component cooling water heat-up time. $200,000 Case 8. Increased availability of feedwater $23,585 $29,547 $31,533
| |
| : 32. Create ability for emergency connection of existing or new water sources to feedwater and condensate systems. $885,760 Case 9. High Pressure Injection System $272,321 $330,726 $370,403
| |
| : 17. Replace two of the four electric safety injection pumps with diesel-powered pumps. $1,500,000
| |
| : 13. Install an independent active or passive high pressure injection system. $1,500,000 Case 10. Extend Reactor Water Storage Pool Capacity $18,822 $25,402 $24,064
| |
| : 16. Throttle low pressure injection pumps earlier in medium or large-break LOCAs to maintain reactor $3,000,000
| |
| : f. D-122
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| water storage tank inventory.
| |
| : 29. RWST fill from firewater during containment injection-Modify 6 inch RWST flush flange to have a 2%-inch female fire hose adapter with isolation valve. $747,640
| |
| : 30. High-volume makeup to the refueling water storage tank. $565,000
| |
| : 49. Install automatic containment spray pump header throttle valves. $2,500,000 Case 11. Eliminate ECCS Dependency on Component Cooling Water System $181,572 $210,796 $252,845
| |
| : 20. Replace ECCS pump motors with air-cooled motors. $6,000,000 Case 12. Increase Availability of ACCW $9,374 $11,229 $12,845 Page D-123
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 19. Add redundant DC control power for SW pumps. $100,000 Case 13. Low Pressure Safety Injection System $20 $23 $28
| |
| : 14. Add a diverse low pressure injection system. $1,000,000
| |
| : 15. Provide capability for alternate injection via diesel-driven fire pump. $6,500,000 Case 14. Increase Component Cooling Water Availability $1,775,007 $2,073,694 $2,463,907
| |
| : 27. Install an additional component cooling water pump. $6,000,000 F 1
| |
| )-124
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs .. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| Case 15. Decreased Charging Pump Failure $48,319 $56,495 $67,046
| |
| : 12. Install modification to power the normal charging pump from an existing spare breaker from the alternate emergency power system. $350,000 Case 16. Reactor Coolant Pump Seals $1,994,880 $2,332,233 $2,768,106
| |
| : 24. Install an independent reactor coolant pump seal injection system, with dedicated diesel. $6,400,000
| |
| : 25. Install an independent reactor coolant pump seal injection system, without dedicated diesel. $6,400,000
| |
| : 26. Install improved reactor coolant pump seals. $2,000,000 Page D-125
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| Case 17. Main Feedwater System Reliability $1,325,589 $1,595,223 $1,811,895
| |
| : 33. Add a motor-driven feedwater pump. $10,000,000 Case 18. EOG Fuel Oil $1,367,894 $1,611,548 $1,890,640
| |
| : 11. Install a large volume EOG fuel oil tank at an elevation greater than the EOG fuel oil day tanks. $150,000 Case 20. Create a reactor coolant depressurization system $234,020 $298,942 $309,396
| |
| : 18. Create a reactor coolant depressurization system. $500,000 F .)-126
| |
| | |
| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit,
| |
| . Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| Case 21. Steam Generator Inventory $4,126,742 $4,893,060 $5,684,889
| |
| : 34. Use fire water system as a backup for steam generator inventory. $3,073, 130 Case 22. Instrument Air Reliability $2,278 $2,894 $3,021
| |
| : 37. Replace service and instrument air compressors with more reliable compressors which have self-contained air cooling by shaft driven fans. $500,000 Case 23. Increased Availability of HVAC $779,088 $917,204 $1,077,216
| |
| : 35. Provide a redundant train or means of ventilation. $3,574,481 Page D-127
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 36. Implement procedures for temporary HVAC. $100,000 Case 24. Debris coolability and core concrete interaction $30,745 $35,448 $42,962
| |
| : 38. Create a reactor cavity flooding system. $1,741,724
| |
| : 47. Provide a reactor vessel exterior cooling system. $2,500,000
| |
| : 72. Provide water from the fire protection system to the containment sump. $715,918
| |
| : 73. Enhance communication between sump and cavity. $702,551 F . )-128
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| Case 25. Decay Heat Removal Capability $1,313,015 $1,513,887 $1,834,753
| |
| : 41. Install an unfiltered, hardened containment vent. $3,000,000
| |
| : 42. Install a filtered containment vent to remove decay heat Option 1: Gravel Bed Filter Option 2: Multiple Venturi Scrubber $20,000,000 Case 26. Improve Containment Spray Capability $1,942,124 $2,250,883 $2,706,801
| |
| : 39. Install a passive containment spray system. $10,000,000
| |
| : 50. Install a redundant containment spray system. $10,000,000 Page D-129
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 40. Use the fire water system as a backup source for the containment spray system. $2,455,808 Case 27. Reduce Hydrogen Ignition $12,709 $14,649 $17,761
| |
| : 43. Provide post-accident containment inerting capability. $100,000
| |
| : 51. Install an independent power supply to the hydrogen control system using either new batteries, a non-safety grade portable generator, existing station batteries, or existing AC/DC independent power supplies, such as the security system diesel. $100,000
| |
| : 52. Install a passive hydrogen control system. $100,000 Case 28. Increase Cooling and Containment of Molten Core Debris $3,490,945 $4,025,013 $4,878,098 F* 0-130
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 44. Create a large concrete crucible with heat removal potential to contain molten core debris. $10,000,000
| |
| : 45. Create a core melt source reduction system. $10,000,000
| |
| : 46. Increase depth of the concrete base mat or use an alternate concrete material to ensure melt-through does not occur. $10,000,000 Case 29. High Pressure Core Ejection Occurrences $3,460,207 $3,989,572 $4,835,145
| |
| : 53. Erect a barrier that would provide enhanced protection of the containment walls (shell) from ejected core debris following a core melt scenario at high pressure. $10,000,000 Case 30. Reduce Probability of Containment Failure $5,294,254 $6,104,206 $7,397,963 Page D-131
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 48. Construct a building to be connected to primary/secondary containment and maintained at a vacuum. $56,700,000 Case 31. Containment Isolation $7,413 $8,544 $10,361
| |
| : 55. Add redundant and diverse limit switches to each containment isolation valve. $692,000 Case 32. Reduce Frequency of Steam Generator Tube Ruptures $348,963 $404,313 $486,439
| |
| : 56. Institute a maintenance practice to perform a 100% inspection of steam generator tubes during each refueling outage. $3,000,000
| |
| : 57. Increase the pressure capacity ofthe secondary side so that a steam generator tube rupture would not cause the relief valves to lift. $10,000,000 F . 'J-132
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate($)
| |
| '.
| |
| : 58. Install a redundant spray system to depressurize the primary system during a steam generator tube rupture $10,000,000
| |
| : 59. Route the discharge from the main steam safety valves through a structure where a water spray would condense the steam and remove most of the fission products. $10,000,000
| |
| : 60. Install a highly reliable (closed loop) steam generator shell-side heat removal system that relies on natural circulation and stored water sources $10,000,000 Case 33. Reduce Consequences of Steam Generator Tube Ruptures $50,657 $58,655 $70,635
| |
| : 61. Direct steam generator flooding after a steam generator tube rupture, prior to core damage. $200,000 Case 34. Reduce ATWS Frequency $19,888 $25,698 $26,117 Page D-133
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 63. Add an independent boron injection system. $500,000
| |
| : 64. Add a system of relief valves to prevent equipment damage from pressure spikes during anATWS. $500,000
| |
| : 65. Install motor generator set trip breakers in control room. $100,000
| |
| : 66. Provide capability to remove power from the bus powering the control rods. $100,000 Case 37. Reduce Probability of a LOCA $14,397 $17,406 $19,630
| |
| : 69. Install digital large break LOCA protection system. $500,000 F *)-134
| |
| | |
| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| Case 38. Prevent Secondary Side Depressurization $5,235 $6,722 $6,900
| |
| : 70. Install secondary side guard pipes up to the main steam isolation valves. $500,000 Case 39. Eliminate Thermally Induced Tube Ruptures Following Core Damage $14,870 $17,141 $20,780
| |
| : 54. Modify procedures such that the water loop seals in the reactor cooling system (RCS) cold legs are not cleared following core damage. $100,000 Case 40. Replace CARMVAAA201-B with a fail closed AOV $0 $0 $0
| |
| : 62. Hardware change to eliminate MOV CS-V-17 AC power dependency. $300,000 Case 41. Improve Internal Flooding Response Procedures and Training 1 N/A N/A N/A Page D-135
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 67. Improve internal flooding response procedures and training to improve the response to internal flooding events. $400,000 Case 42. Water tight doors for the largest contributor to internal flooding 1 NIA N/A N/A
| |
| : 68. Install flood doors to prevent water propagation in the electric board room. $4,695,000 Case 43. Gagging device to close a stuck open safety valve $38 $44 $53
| |
| : 71. Manufacture a gagging device for a steam generator safety valve and developing a procedure or work order for closing a stuck-open valve. $30,000 These SAMA candidates were retained without evaluation as they are already commitments in the NFPA 805 LAR [D.2-13] N/A N/A N/A N/A
| |
| : 74. In Fire Area RAB 2 construct a radiant heat barrier to further separate the A and B trains of chilled water pumps. N/A N/A N/A N/A
| |
| : 75. In Fire Area RAB BC construct a radiant heat shield in Switchgear Room A/B. N/A N/A N/A N/A P, :)-136
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| | |
| Waterford Steam Electric Stafl6n Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 76. In Fire Area RAB 6 install a 1-hour fire resistance rating ERFBS fire wrap barrier from fire damage. N/A N/A N/A N/A 111 These analysis cases only impact internal flooding and have been evaluated as shown in Section D.2.3.
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| Page D-137
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| Waterford Steam Electric Station, Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment E Coastal Zone Consistency Determination
| |
| | |
| Attachment E Coastal Zone Consistency Determination
| |
| * Rick Buckley, Entergy Services, Inc. to Jeff Harris, Louisiana Department of Natural Resources, Office of Coastal Management. April 9, 2015.
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| * Don Haydel, Louisiana Department of Natural Resources, Office of Coastal Management, to Rick Buckley, Entergy Services, Inc. April 14, 2015.
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| E-1
| |
| | |
| Entergy Services, Inc 1340 Echelon Parkway Jackson, Mississippi 39213 Date: April 9, 2015 Mr. Jeff Harris Louisiana Department of Natural Resources Office of Coastal Management Post Office Box 94396 Baton Rouge, LA 70804-9396
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| | |
| ==Subject:==
| |
| Waterford Steam Electric Station, Unit 3 Coastal Zone Consistency Determination CEO 2015-00033
| |
| | |
| ==Dear Mr. Harris,==
| |
| | |
| Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") are applying to the Nuclear Regulatory Commission (NRC) for renewal of the Waterford Steam Electric Station Unit 3 (WF3) operating license (OL) for an additional 20 years to preserve the option for Entergy to continue to operate WF3 to provide reliable base-load power throughout the extended license renewal period. For WF3 (Facility OL NPF-38), the requested renewal would extend the license expiration date from December 18, 2024, to December 18, 2044.
| |
| On June 4, 2014, Entergy submitted a Coastal Use Permit application (Attachment 1) to your agency regarding a Request for Determination that the renewal of the WF3 OLdid not require a Coastal Use Permit. In your response letter dated June 18, 2014 (Attachment 2), it was determined that "the proposed activity is exempt and a Coastal Use Permit is not required".
| |
| As previously stated above, license renewal only preserves the option for Entergy to continue to operate WF3 to provide reliable base-load power throughout the extended license renewal period. It does not authorize changes to the WF3 facility or operations.
| |
| E-2
| |
| | |
| As stated in the Coastal Use Permit application submitted by Entergy and the response letter from your agency, no plant refurbishment or other license-renewal-related construction activities have been identified as necessary to support the continued operation of WF3 beyond the end of the existing operating license term.
| |
| Therefore, Entergy is requesting a determination from your agency that the proposed activity, renewal of the WF3 OL, will be consistent with Louisiana's Coastal Resources Program.
| |
| If you have any questions or need additional information, please contact me at 601-368-5823 or by email at rbuckle@entergy.com.
| |
| I certify to the best of my knowledge that the proposed activity complies with, and will be conducted in a manner that is consistent with the Louisiana Coastal Resources Program.
| |
| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental E-3
| |
| | |
| Attachment 1 Entergy's Request for Determination E-4
| |
| | |
| Joint Permit Application Louisiana Department of Natural For Work Within the Louisiana U.S. Army Corps Of Engineers Resources Coastal Zone (COE)
| |
| Office of Coastal Management New Orleans District (OCM)
| |
| Print Application Permit Number: P20140826 Date Received: 06/04/2014 Step 1 of 15 - Applicant Information Applicant/Company WATERFORD 3 STEAM ELECTRIC Applicant Type: INDUSTRY/OTHER Name: STATION Mailing Address: 17265 RIVER ROAD KILLONA, LA 70057 Contact Information: Rick Buckley Daytime: 6013685823 Fax: 6013685812 Contact Email: rbuckle@entergy.com Step 2 of 15 - Agent Information Company Name:
| |
| Mailing Address:
| |
| Contact Information:
| |
| Daytime: Fax: Contact Email:
| |
| Step 3 of 15 - Permit Type
| |
| ~ Request for Determination D Coastal Use Permit (CUP) D Solicitation of Views (SOV)
| |
| (RFD)
| |
| Step 4 of 15 - Pre-Application Activity
| |
| : a. Have you participated in a Pre-Application or Geological Review Meeting for the proposed project?
| |
| D No ~Yes Date meeting was held:
| |
| E-5
| |
| | |
| Attendees:
| |
| (Individual or Company Rep) (OCM Representative) (COE Representative)
| |
| : b. Have you obtained an official wetland determination from the COE for the project site? .
| |
| 181 No D Yes JD Number:
| |
| : c. Is this application a mitigation plan for another CUP?
| |
| 181 No D Yes OCM Permit Number:
| |
| Step 5 of 15 - Project Information
| |
| : a. Describe the project:
| |
| Entergy Louisiana, LLC will be submitting an application to the Nuclear Regulatory Commission during the first quarter of 2016 for renewal of the Waterford 3 Steam Electric Station (WF3) license which will preserve the option to continue to operate WF3 to provide reliable base-load power for an additional 20 years beyond its existing 40 year license to meet Entergy's system generating needs. For WF3, the requested renewal would extend the license expiration date from midnight December 18, 2024, to midnight December 18, 2044.
| |
| In summary, there will be no changes related to this project with respect to operation of WF3 that wou'ld significantly change the plant's effects on the environment during the period of extended operation. In addition, no plant refurbishment or other license-renewal-related construction activities have been identified as ne.cessary to support the continued operation of WF3 beyond the end of the existing operating license term.
| |
| : b. Is this application a change to an existing permit?
| |
| 181 No D Yes OCM Permit Number:
| |
| Have you previously app/if#d for a permit or emergency authorization for all or any part of the
| |
| : c. proposed project? **
| |
| 181 No D Yes Agency Name Permit Number Decision Status Decision Date OCM COE Other Step 6 of 15 - Project Location
| |
| : a. Physical Location E-6
| |
| | |
| Street: 17265 RIVER .ROAD City: KILLONA Parish: SAINT CHARLES Zip: 70057 Water Body: MISSISSIPPI RIVER
| |
| : b. Latitude and Longitude Latitude: 29 59 42 Longitude: -90 28 16
| |
| : c. Section, Township, and Range Section#: 26 Township#: 12S Range#: 20E Section#: Township#: Range#:
| |
| : d. Lot, Tract, Parcel, or Subdivision Name Lot#: Parcel#:
| |
| Tract#: Subdivision Name:
| |
| : e. Site Direc,tion:
| |
| 1-10 East toward New Orleans. Exit 220 to 1-310 South toward Boutee/Houma. Exit #10 onto LA-3127 North toward Donaldsonville. Turn right on LA-3142 North. Turn left onto River Road. Turn left at the Entergy Waterford 3 SES Sign. Turn right, turn left and turn right into the Generation Support Building parking lot. -
| |
| END. .
| |
| Step 7 of 15 - Adjacent Landowners Step 8 of 15 - Project Specifics WATERFORD 3 STEAM ELECTRIC STATlON LICENSE RENEWAL
| |
| : a. Project Name and/or Title: PROJECT
| |
| : b. Project Type: Non-Residential
| |
| : c. Source of Funding: Private
| |
| : d. What will be done for the proposed project?
| |
| Home D Bridge/Road 0 Site/Driveway D Pipeline/Flow Line D Rip Rap/Erosion Control D Bulkhead/Backfill D Levee ConstructionD Plug/Abandon D Site Clearance Drainage Production 0 D Dredging D Barge/Structure D Subdivision Improvements D Drill Barge/Structure D Prop Washing D Vegetative Plantings D Wharf/Pier/Boathouse E-7
| |
| | |
| D Drill Site D Pilings D Remove Structures Major D Fill D Marina 0 Industrial/Commercial
| |
| !!;a Other: RENEWAL OF AN EXISTING OPERATING LICENSE FOR AN ADDITIONAL 20 YEARS.
| |
| : e. Why is the proposed project needed?
| |
| The proposed project would renew the operating license for WF3 which would preserve the option for Entergy Louisiana, LLC to continue to operate WF3 to provide reliable base-load power for an additional 20 years beyond its existing 40 year license to meet Entergy's system generating needs. ForWF3, the requested renewal would extend the license expiration date from midnight December 18, 2024, to midnight December 18, 2044.
| |
| Step 9 of 15 - Project Status
| |
| : a. Proposed project start date: Proposed project completion date:
| |
| : b. Is any of the project work in progress?
| |
| !!;a No D Yes
| |
| : c. Is any of the project work complete?
| |
| !!;a No D Yes Step 10of15 - Structures, Materials, and Methods for the Proposed Project
| |
| : a. Excavations 0 yd 3 O Acres
| |
| : b. Fill Areas O Acres
| |
| : c. Fill Materials D Concrete: D Rock: yd3 Crushed Stone or 0 Gravel: D Sand: yd3 Excavated and placed Hauled in 0 onsite: 0 topsoil/Dirt:
| |
| yd3 Excavated and hauled 0 offsite:
| |
| Other: NO FILL
| |
| !!;a MATERIALS ARE 0 yd 3 INVOLVED.
| |
| E-8
| |
| : d. What equipment will be used for the proposed project?
| |
| D Airboat D Bulldozer/Grader D Marsh Buggy Other Tracked or Wheeled D Backhoe D Dragline/Excavator 0 Vehicles Barge Mounted Bucket Self Propelled Pipe Laying 0 D Handjet 0 Dredge Barge
| |
| . D Barge Mounted Drilling Rig D Land Based Drilling Rig D Tugboat a Other: None. There is no construction activities associated with this project.
| |
| Step 11 of 15 - Project Alternatives
| |
| '.
| |
| : a. Total acres of wetlands and/or waterbottoms filled and/or excavated.
| |
| acres What alternative locations, methods, *and access routes were considered to avoid impact to wetlands
| |
| : b. and/or waterbottoms?
| |
| : c. What efforts were made to minimize impact to wetlands and/or waterbottoms?
| |
| : d. How are unavoidable impacts to v~getated wetlands to be mitigated?
| |
| Step 12 of 15 - Permit Type and Owners
| |
| : a. Are you applying for a C9astal Use Permit?
| |
| la!No D Yes
| |
| : b. Are you the sole landowner/oyster lease holder?
| |
| DNo la! Yes D The applicant is an owner of the property on which the proposed described activity is to occur.
| |
| D The applicant has made reasonable effort to determine the identity and current address of the owner(s) of the land on which the proposed described activity is to occur, which includeq, a search of the public records of the parish in which the proposed activity is to occur.
| |
| The applicant hereby attests that a copy of the application has been distributed to the following 0
| |
| landowners/oyster lease holders: .
| |
| : c. Does the project involve drilling, production, and/or storage of oil and gas?
| |
| E-9
| |
| | |
| ~ No D Yes Step 13 of 15 - Maps and Drawing Instructions CoastalZoneVicinitvMap.jpg 06/04/2014 02:18:06 PM Step 14 of 15 - Payment The fee for this permit is: $100.00 Step 15 of 15 - Payment Processed Applicant Information Applicant Name: WATERFORD 3 STEAM ELECTRIC STATION Address: 17265 RIVER ROAD City/State/Zip : KILLONA, LA 70057 Application Information Permit Type: RFD To the best of my knowledge the proposed activity described in this permit application complies with, and will be conducted in a manner that is consistent with the Louisiana Coastal Resources Program. If applicable, I also certify that the declarations in Step 12c, oil spill response, are complete and accurate.
| |
| View Comments related to this project E-10
| |
| | |
| PROJECT SITE:
| |
| Sect 26 T12S - R2 0E Lat: 29 ° 59' 42" Long: 90° 28' 16" X: 743963 Y: 3320744 NAD27 Legend
| |
| - Property Boundary
| |
| ----=====::::i Feet 0 2,000 4,000 E-11
| |
| | |
| Attachment 2 Louisiana Department of Natural Resources Determination E-12
| |
| | |
| BOBBY JINDAL STEPHEN CHUSTZ GOVERNOR SECRETARY
| |
| ~tate of JLoutstana DEPARTMENT OF NATURAL RESOURCES OFFICE OF COASTAL MANAGEMENT 06/18/2014 WATERFORD 3 STEAM ELECTRIC STATION 17265 RIVER ROAD KILLONA, LA 70057 RE: P20140826, Request for Determination WATERFORD 3 STEAM ELECTRIC STATION
| |
| | |
| == Description:==
| |
| Entergy Louisiana, LLC will be submitting an application to the Nuclear Regulatory Commission during the first quarter of 2016 for renewal of the Waterford 3 Steam Electric Station (WF3) license. There will be no changes related to this project with respect to operation of WF3 that would significantly change the plant's effects on the environment during the period of extended operation. In addition, no plant refurbishment or other license-renewal-related construction activities have been identified as necessary to support the continued operation of WF3 beyond the end of the existing operating license term.
| |
| Location: Lat. 29° 59' 42" N, Long. -90° 28' 16" W; Section 26 T12S R20E; 17265 River Road, Killona Saint Charles Parish, LA
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| | |
| ==Dear Rick Buckley:==
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| | |
| We have received a Request for Determination for the above referenced project, which has been found to be inside the Louisiana Coastal Zone. In accordance with the State and Local Coastal Resources Management Act of 1978, as amended (La. R.S. 49:214.34.a), the proposed activity is exempt and a Coastal Use Permit is not required.
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| This determination is valid for two (2) years from the date of this letter. If the proposed activity is not initiated within this 2-year period, this determination will expire and the applicant will be required to submit a new application. This determination does not eliminate the need to obtain a permit from the United States Army, Corps of Engineers (USA CE) or any other Federal, state, or local approval, that may be required by law.
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| This determination has been made on the basis of information provided by your application. If it is later established that you furnished erroneous data, you may be directed to alter or modify your plans, to remove structures you have installed, and/or to restore the work area to pre-project conditions at your own expense. If it is established that you knowingly furnished erroneous data, you could also be subject to legal action.
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| Post Office Box 44487
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| * Baton Rouge, Louisian a 70804-4487 617 North Third Street
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| * 1Orh Floor
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| * Suite 1078
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| * Bato n Rouge, Louisiana 70802 (225 ) 342-7591
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| * fax (225 ) 342-9439
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| * http://www.dnr.louisiana.gov An Equal Opportunity Employe r E-13
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| | |
| P20140826, Request for Determination WATERFORD 3 STEAM ELECTRIC STATION 06118/2014 Page 2 The drawings submitted with your referenced application are attached hereto and made a part of the record. If you have any questions regarding this authorization, please contact our office at (225) 342-7591 or (800) 267-4019.
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| Sincerely,
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| ~~
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| Keith Lovell For Karl L. Morgan, Administrator Keith Lovell/aw Attachments E-14
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| P20140826, Request for Determination WATERFORD 3 STEAM ELECTR IC STA TIO 06/18/2014 Page 3 Final Plats:
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| : 1) P20140826 Final Plats 06/04/2014 cc: Martin Mayer, COE w/plats Dave Butler, LDWF w/plats Jessica Diez, OCM w/plats Lafourche Basin Levee District, LD w/plats Kirk Kilgen, CMD/FI w/plats E-15
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| | |
| PROJECT SITE:
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| Sect 26 T12S - R20E Lat: 29° 59 ' 42" Long : 90° 28' 16" X: 743963 Y: 3320744 NAD27 Legend
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| - Property Boundary E-16
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| ****c::===F 0 2,000 eet 4,000
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| | |
| BOBBY Jr DAL TEPHE CHUSTZ GOVERNOR SECRETARY
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| ~t te of JLoui!)i n OF RESOURCE OFFICE OF COASTAL . . . ~"'" ...ciG*EMENT April 14, 2015 Rick Buckley Entergy Services Inc.
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| 1340 Echelon Parkway Jackson, MS 39213 RE: C20150075, Coastal Zone Consistency Entergy Louisiana, LLC and Entergy Operations, Inc.
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| Nuclear Regulatory Commission Federal License or Permit Renewal of the operating license for the Waterford Steam Electric Station Unit 3, throu gh December 18, 2044 St. Charles Parish, Louisiana
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| | |
| ==Dear Mr. Buckley:==
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| | |
| The above referenced project has been reviewed for consistency with the approved Louisiana Coastal Resource Program (LCRP) as required by Section 307 of the Coastal Zone Management Act of 1972, as amended . The project, as proposed in the application, is consistent with the LCRP. If you have any questions concerning thi s determination, please contact Jeff Harris of the Consistency Section at (225) 342-7949 or 1-800-267-4019.
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| Sincerely yours,
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| /S/ Don Haydel Acting Administrator lnteragency Affairs/Field Services Division DH/SK/jdh cc: Martin Mayer, NOD-COE Dave Butler, LDWF Kirk Kil gen, OCM Fl E-17 PoSt Office Box 44487
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| * Baton Rouge, Louisiana 70804-4487 617 North Third Street
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| * l 0th Floor
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| * Suite l 078
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| * Baton Rouge, Louisiana 70802 (225) 342-7591
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| * Fax (225) 342-9439
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| * http://www.dnrJouisiana.gov An Equal Opportunity Employer
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| | |
| * .\i;
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| [)f!P--003
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| Waterford Steam Electric Station, Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment A WF3 Clean Water Act Documentation
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| Attachment A WF3 Clean Water Act Documentation
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| * Section 401 (Water Quality) Certification. June 21, 1972.
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| * Louisiana Pollutant Discharge Elimination System (LPDES) Permit No. LA0007374. September 7, 2010.
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| * Scott Guilliams, Louisiana Department of E:nvironmental Quality, to Kelli M. Dowell, Entergy Services, Inc. January 30, 2015.
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| A-1
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| 0-1 STATE OF LOUISIANA APPENDIX IJ STREAM CONTROL COMMISSION P. O. ORAWCR FC UNIVERSITY STATION
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| 'ilATON ROUGE, LOUISIANA 70803 June 21, 1972 L:>uisiana Power and Light Company 14 2 Delaronde Street New Orleans, Louisiana 70114 Attention: Mr. Donald L. Aswell, Production Manager Gentlemen:
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| This is to officially inform you that the discharge permit applications for Units 1, 2, and 3, Taft, Louisiana, to discharge condenser cooling water to the 1vfississippi River and demineralizer waste to the Forty Arpent Canal were approved by the Louisiana Stream Control Commission at its meeting on May 31 , 19 7 2. .n..ny change in eit.her the quality or qunntity of the discharges will require submission of new proposals.
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| The Commission, in approving the discharges, is of the opinion that water quality standards of the State of Louisiana ~.-.;ill not be violated. Therefore, in accordance with provisions of Louisiana Revised Statutes of 1950, Title 56, Section 1439(5) - Act 628 of the 1970 Louisiana Legislature -
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| this is your letter of certification from the commission that the installations.
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| comply with Section 21 (b) of the Federal Water Quality Improvement Act of 1970.
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| Enclosed is copy oi a public notice to be run by you 1 one (1) time, in the official state journal, the BATON ROUGE STATE TIMES, at your expense.
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| Very truly yours,
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| *c;?~Q4.~
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| Robe.rt A. Lafleur /
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| Executive Secretary fbr Enclosure A-2
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| | |
| PERMIT NUMBER LA0007374 AI No.: 35260 OFFICE OF ENVIRONMENTAL SERVICES Water Discharge Permit Pursuant to the Clean Water Act, as amended (33 U.S.C.1251 et~.), and the Louisiana Environmental Quality Act, as amended (La. R. S. 30:2001 et~.), rules and regulations effective or promulgated under the authority ofsaid Acts, and in reliance on statements and representations heretofore made in the application, a Louisiana Pollutant Discharge Elimination System permit is issued authorizing Entergy Operations, Inc.
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| Wat~rford 3 Steam Electric Station 17265 River Road Killona; Louisiana 70057
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| . Type Facility: steam electric generating station Location: 17265 River Road, Killona St. Charles Parish Receiving Waters: Outfall 00 I - Mississippi River (07030 I)
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| Outfalls 004 and 005 - 40 Arpent Canal thence to Lac Des Allemands (020202) to discharge in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, and Ill attached hereto.
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| * This permit shall become effective on d dtM< ?DI0 This permit and the authorization to discharge shall expire five (5) years from the effective date of the permit.
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| wcr<~10 Cheryl Sonnier Nolan
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| .Assistant Secretary GALVEZ BUILDING* 602 N. FlfTHSTREET* P.O. BOX 4313 *BATON ROUGE. U 70811-4313 * (215) Z/9-3181 A-3
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| PART I Page 2 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 001, the continuous discharge of once through non-contact cooling water combined with previously monitored intermittent discharges including but not limited to: steam generator blowdown, cooling tower blowdown, metal cleaning wastewaters, low volume wastewater, and stormwater from Outfalls 101, 201, 301, 401, 501, 601, 701, 801, 901, and 1001 (estimated flow is 994 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Reguirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency Type Flow-MGD (*1) 50050 Report Report Continuous Recorder Ternperature(°F) 00011 Report(*2) 118(*3) Continuous Recorder Heat 00015 (*4) Continuous Recorder Total Residual Chlorine 50060 211 1/week(*5) Grab WHOLE EFFLUENT (ACUTE) (Percent%, UNLESS STATED)
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| TOXICITY TESTING STORET Monthly Avg 48-Hour Measurement Sample Code Minimum Minimum Frequency(*5) Type NOEC, Pass/Fail [0/1], TEM6C Report Report 1/quarter 24-hr. Composite Lethality, Static Renewal, 48-Hour Acute, Pirnephales promelas NOEC, Value [%], TOM6C --- Report Report 1/quarter 24-hr. Composite Lethality, Static Renewal, 48-Hour Acute, Pimephales promelas NOEC, Value[%], TQM6C --- Report Report 1/quarter 24-hr. Composite Coefficient of Variation, Static Renewal, 48-Hour Acute, Pimephales promelas NOEC, Pass/Fail [0/1], TEM3D Report Report 1/quarter 24-hr. Composite Lethality, Static Renewal, 48-Hour Acute, Daphnia pulex NOEC, Value [%], TOM3D --- Report Report 1/quarter 24-hr. Composite Lethality, Static Renewal, 48-Hour Acute, Daphnia pulex NOEC, Value[%], TQM3D --- Report Report 1/quarter 24-hr. Composite Coefficient of Variation, Static Renewal, 48-Hour Acute, Daphnia pulex A-4
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| | |
| PART!
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| Page 3 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locatlon(s):
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| Outfall 001, at the point of discharge from the circulating water system discharge structure prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) Discharge flow is to be determined from calibrated pumping curves or calculated using appropriate heat balance methodology.
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| (*2) See Part II, Q.
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| (*3) Instantaneous maximum.
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| (*4) Daily maximum limitation of 9.5 X 103 MBTU/hour.
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| (*5) Sample shall be representative of any periodic episodes of chlorination, biocide usage, or other potentially toxic substance discharged on an intermittent basis.
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| A-5
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| PART I Page 4 of 15 Permit No. U\0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 101, the intermittent discharge from the liquid waste management system. The liquid waste management system receives low volume wastewater from the following sources, including but not limited to: the turbine and reactor building equipment and floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423 (estimated flow is 0.0129 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Reauirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(*!) Type Flow-MGD 50050 Report 1/batch Totalized TSS 00530 100 1/month Grab Oil & Grease 03582 20 1/month Grab pH Minimum/Maximum Values 00400 6.0 (*2) 9.0 (*2) 1/batch Grab (Standard Units) (Min) (Max)
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| Samples taken In compliance with the monitoring requirements specified above shall. be taken at the following location(s):
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| Outfall 101, at the point of discharge from the liquid waste management system prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-6
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| PART I Page 5 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 201, the intermittent discharge from the boron management system. The boron management system receives low volume wastewater from the following sources, inducting but not limited to: the turbine and reactor building equipment and floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423 (estimated flow is 0.0128 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring R~uirements other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Dally Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(* 1) Type Flow-MGD 50050 Report 1/batch Totalized TSS 00530 100 1/month Grab Oil & Grease 03582 20 1/month Grab pH Minimum/Maximum Values 00400 6.0 (*2) 9.0 (*2) !/batch Grab (Standard Units) (Min) (Max)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 201, at the point of discharge from the boron management system prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-7
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| PART I Page 6of15 Permit No. LA0007374 AI No. 35260 EFFLUENT UMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 301, the intermittent discharge of filter flush water from the primary water treatment system. The primary water treatment system filters rlverwater for various plant uses. The filters of this system are flushed periodically with untreated river water to remove solids trapped in the filter beds (estimated flow is 0.0001 MGO).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Requirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(*!) Type Flow-MGD 50050 Report Weekly Totalized Clarifying Agents (*2)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 301, at the point of discharge from the primary water treatment system prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) The quantity and types of clarifying agents (coagulants) used in the primary water treatment system during the sampling month shall be recorded. Records of the quantity and type of darifying agents used shall be retained for three (3) years following Part III.C.3. No DMR reporting shall be required.
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| A-8
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| PART!
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| Page 7 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 401, the intermittent discharge of steam generator blowdown and other low volume wastewaters as defined in 40 CFR 423 (estimated flow is 0.042 MGD).
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| Such discharges shall be limited and monitored by the perrnittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Requirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(*!) Type Flow-MGD(*2) 50050 Report Daily Totallzed TSS 00530 100 1/week Grab Oil &Grease 03582 20 1/week Grab pH Minimum/Maximum Values 00400 6.0 (*3) 9.0 (*3) 1/week Grab (Standard Units) (Min) (Max)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 401, at the point of discharge from the secondary steam plant system prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) When low volume wastewaters are discharged, the flow must be estimated.
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| (*3) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-9
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| | |
| PART I Page 8of15 Permit No. LA0007374 Al No. 35260 EFFLUENT LIMITATIONS AND MONITORJNG REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 501, the intermittent discharge from Auxiliary Component Cooling Water Basin A. Low volume wastewaters indude, but are not limited to: auxiliary component cooling water, component cooling water, Mississippi River water used for now testing, and stormwater (estimated now is 0.26 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effiuent Characteristic Discharge Limitations Monitoring Reauirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(* 1) Type Flow-MGD 50050 Report 1/week Estimate TOC 00680 50 1/week Grab TSS (*2) 00530 100 l/week Grab Oil &Grease 03582 20 1/week Grab pH Minimum/Maximum Values 00400 6.0 (*3) 9.0 (*3) l/week Grab (Standard Units) (Min) (Max)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 501, at the point of discharge from Auxiliary Component Cooling Water Basin A prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) During circulating water flow testing, sampling for TSS is not required (when Mississippi River water is used for the now test).
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| (*3) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-10
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| | |
| PART I Page 9 of 15 Permit No. L.A0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 601, the intermittent discharge from Auxiliary Component Cooling Water Basin B. Low volume wastewaters include, but are not limited to: auxiliary component cooling water, component cooling water, secondary plant water system wastewater, Mississippi River water used for flow testing, and stormwater (estimated flow is 0.26 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Requirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
| |
| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(* 1) Type Flow-MGD 50050 Report l/week Estimate TDC 00680 50 1/week Grab TSS (*2) 00530 100 1/week Grab Oil & Grease 03582 20 1/week Grab pH Minimum/Maximum Values 00400 6.0 (*3) 9.0 (*3) 1/week Grab (Standard Units) (Min) (Max)
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 601, at the point of discharge from the Auxiliary Component Cooling Water Basin B prior to mixing with other waters.
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| FOOTNOTE(S):
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| (*1) When discharging.
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| (*2) During circulating water flow testing, sampling for TSS is not required (when Mississippi River water is used for the flow test).
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| (*3) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-11
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| | |
| PART I Page 10of15 Permit No. lA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
| |
| Outfall 701, the intermittent discharge of cooling tower blowdown and low volume wastewaters from the Cooling Tower Sump# 1. Low volume wastewaters include, but are not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. (NOTE: Optional discharge to plant drainage ditches thence to Outfall 004 may occur during periods when the circulating water system is unavailable.) (estimated flow is 0.0185 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Reguirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
| |
| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency(*!) Type Flow-MGD 50050 Report 1/month Estimate TOC 00680 so 1/quarter Grab TSS 00530 100 1/month Grab Oil & Grease 03582 20 1/month Grab FAC (*2) 50064 0.5 1/month Grab Total Chromium (*2) 01034 0.2 1/year Grab Total Zinc (*2) 01092 1.0 1/month Grab pH Minimum/Maximum Values 00400 6.0 (*3) 9.0 (*3) 1/month Grab (Standard Units) (Min) (Max)
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| '*
| |
| '-"
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
| |
| Outfall 701, at the point of discharge from the Dry Cooling Tower Sump #1 prior to mixing with other waters.
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| FOOTNOTE(S):
| |
| (*1) When discharging.
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| (*2) Sample shall be representative of periods during cooling tower blowdown discharge.
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| (*3) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-12
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| | |
| PART I Page 11of15 Permit No. LA0007374 Al No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
| |
| Outfall 801, the intermittent discharge of cooling tower blowdown and low volume wastewaters from Dry Cooling Tower Sump #2. Low volume wastewater sources as defined in 40 CFR 423 include, but are not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. (NOTE: Optional discharge to plant drainage ditches thence to Outfall 004 may occur during periods when the circulating water system is unavailable.) (estimated flow is 0.068 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
| |
| Effluent Characteristic Discharge Limitations Monitoring Requirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
| |
| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency (* 1) Type Flow-MGD 50050 Report 1/month Estimate TOC 00680 50 !/quarter Grab TSS 00530 100 1/month Grab Oil & Grease 03582 20 1/month Grab FAC (*2) 50064 0.5 1/month Grab Total Chromium(*2) 01034 0.2 1/year Grab Total Zinc (*2) 01092 1.0 !/month Grab pH Minimum/Maximum Values 00400 6.0 (*3) 9.0 (*3) 1/month Grab (Standard Units) (Min) (Max)
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
| |
| Outfall 801, at the point of discharge from the Dry Cooling Tower Sump #2 prior to mixing with other waters.
| |
| FOOlNOTE(S):
| |
| (*1) When discharging.
| |
| (*2) Sample shall be representative of periods during cooling tower blowdown discharge.
| |
| (*3) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
| |
| A-13
| |
| | |
| PART I Page 12 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
| |
| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
| |
| Outfall 901, the mobile intermittent discharge of metal cleaning wastewaters (both chemical and non-chemical) from various plant equipment components including, but not limited to: the steam generator, cooling water heat exchangers, and piping (estimated flow is 0.0201 MGD).
| |
| Such discharges shall be limited and monitored by the permittee as specified below:
| |
| Effluent Characteristic Discharge Limitations Monitoring Requirements other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
| |
| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency (*1) Type Flow-MGD 50050 Report !/week Estimate TSS 00530 100 1/week Grab Oil & Grease 03582 20 1/week Grab Total Copper 01042 1.0 1/week Grab Total Iron 01045 1.0 !/week Grab pH Minimum/Maximum Values 00400 6.0 (*2) 9.0 (*2) 1/week Grab (Standard Units) (Min) (Max)
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
| |
| Outfall 901, at the point of discharge from the mobile cleaning process unit(s) prior to mixing with other waters.
| |
| FOOTNOTE(S):
| |
| (*1) When discharging.
| |
| (*2) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
| |
| A-14
| |
| | |
| PART I Page 13 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
| |
| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
| |
| Outfall 1001, the intermittent discharge from the yard oil separator system. Wastewater includes auxiliary boiler blowdown, stormwater, and low volume wastewaters from various sources, including plant floor drains and discharge from the industrial waste system as defined in 40 CFR 423. Low volume wastewater sources include, but are not limited to: secondary water system drains, system leakage, auxiliary boiler sumps, turbine building equipment and floor drains, turbine building floor wash downs, and laboratory drains. (NOTE: Optional discharge to Final Outfall 004 may occur during maintenance periods and during rain events that compromise the capacity of the discharge pumps.)
| |
| (estimated flow is 0.0553 MGD).
| |
| Such discharges shall be limited and monitored by the permittee as specified below:
| |
| Effluent Characteristic Discharge Limitations Monitoring Requirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
| |
| STORET Monthly Dally Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency (*1) Type Flow-MGD 50050 Report 1/month Estimate TSS 00530 100 1/month Grab Oil & Grease 03582 20 I/month Grab pH Minimum/Maximum Values 00400 6.0 (*2) 9.0 (*2) 1/month Grab (Standard Units) (Min) (Max)
| |
| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
| |
| Outfall 1001, at the point of discharge from the yard oil separator system prior to mixing with other waters.
| |
| FOOTNOTE(S):
| |
| (*1) When discharging.
| |
| (*2) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-15
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| PART I Page 14 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the perrnittee Is authorized to discharge from:
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| Outfall 004, the intermittent discharge from the plant drainage ditch system consisting of storrnwater, potable water from the fire water system, maintenance wastewaters including, but not limited to hydrostatic test water, air conditioning condensate, low volume wastewaters including, but not limited to reverse osmosis reject water and demineralized water. The plant drainage ditch system receives discharges during maintenance from the Dry Cooling Tower Sump #1 (Internal Outfall 701), Dry Cooling Tower Sump #2 (Internal Outfall 801), and treated discharge from the yard oil separator system, including, but not limited to: plant floor drains and discharge from the industrial waste system (Internal Outfall 1001).(estimated flow is 10.3 MGD).
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| Such discharges shall be limited and monitored by the pennittee as specified below:
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| Effluent Characteristic Discharne limitations Monitoring Reguirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
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| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency (* 1) Type Flow-MGD 50050 Report 1/3 months Estimate TOC 00680 50 1/3 months Grab TS5 (*2) 00530 100 1/3 months Grab Oil & Grease 03582 15 1/3 months Grab pH Minimum/Maximum Values 00400 6.0 (*3) 9.0 (*3) 1/3 months Grab (Standard Units) (Min) (Max)
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| C, There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 004, at the point of discharge from the stormwater drainage ditch south of the plant laydown area and prior to mixing with other waters.
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| FOOTNOTE(S):
| |
| (*1) When discharging.
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| (*2) Samples shall be representative of periods during discharge of low volume wastewaters as defined in 40 CFR 423 (excludes Mississippi River water that accumulates in the condenser water boxes).
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| ("'3) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-16
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| PART I Page 15 of 15 Permit No. LA0007374 AI No. 35260 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
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| During the period beginning the effective date and lasting through the expiration date the permittee is authorized to discharge from:
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| Outfall 005, the intermittent discharge of treated sanitary wastewater and a de minimisdischarge from the HVAC unit from the Entergy Energy Education Center (estimated flow is 0.061 MGD).
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| Such discharges shall be limited and monitored by the permittee as specified below:
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| Effluent Characteristic Discharge Limitations Monitoring Requirements Other Units (lbs/day, UNLESS STATED) (mg/L, UNLESS STATED)
| |
| STORET Monthly Daily Monthly Daily Measurement Sample Code Average Maximum Average Maximum Frequency (*1) Type Flow-MGD 50050 Report 1/6 months Estimate BOD5 00310 30 45 1/6 months Grab TSS 00530 30 45 1/6 months Grab Fecal Coliform colonies/100 ml 74055 200 400 1/6 months Grab pH Minimum/Maximum Values 00400 6.0 (*2) 9.0 (*2) 1/6 months Grab (Standard Units) (Min) (Max)
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| There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s):
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| Outfall 005, at the point of discharge from the sewage treatment plant prior to mixing with other waters.
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| FOOTNOTE(S):
| |
| (*1) When discharging.
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| (*2) The permittee shall report on the Discharge Monitoring Reports both the minimum and maximum instantaneous pH values measured.
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| A-17
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| Page l of 24 Permit No. LA0007374 AI No. 35260 PART II OTHER REQUIREMENTS In addition to the standard conditions required in all permits and listed in Part III, the Office has established the following additional requirements in accordance with the Louisiana Water Quality Regulations.
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| A. This permit does not in any way authorize the permittee to discharge a pollutant not listed or quantified in the application or limited or monitored for in the permit.
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| B. Authorization to discharge pursuant to the conditions of this permit does not relieve the permittee of any liability for damages to state waters or private property. For discharges to private land, this permit does not relieve the permittee from obtaining proper approval from the landowner for appropriate easements and rights of way.
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| C. For definitions of monitoring and sampling terminology see STANDARD CONDITIONS FOR LPDES PERMITS, Section F.
| |
| D. 24-HOUR ORAL REPORTING: DAILY MAXIMUM LIMITATION VIOLATIONS Under the provisions .of Part III.D.6.e. (3) of this permit, violations of daily maximum limitations for the following pollutants shall be reported orally to the Office of Environmental Compliance within 24 hours from the time the permittee became aware of the violation followed by a written report in five days.
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| Pollutant(s): Total Copper, Total Chromium, Total Zinc E. COMPOSITE SP.MPLING (24-HOUR)
| |
| Unless otherwise specified in this permit, the term "24-hour composite sample" means a sample consisting of a minimum of four ( 4) *aliquots of effluent collected at regular .intervals over a normal 24-hour operating day and combined in proportion to flow or a sample continuously collected in proportion to flow over a normal 24-hour operating period.
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| F. 40 CFR PART 136 (See LAC 33:IX.4901) ANA..LYTICAL REQUIREMENTS Unless otherwise specified in this permit, monitoring shall be conducted according to analytical, apparatus and materials, sample collection, preservation, handling, etc., procedures listed at 40 CFR Part 136, and in particular, Appendices A, B, and C {See LAC 33:IX.4901).
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| G. FLOW MEASUREMENT "ESTIMATE" SAMPLE TYPE If the flow measurement sample type in Part I is Specified as "estimate",
| |
| flow measurements shall not be subject to the accuracy provisions established at Part III.C.6 of this permit. The daily flow value may be estimated using best engineering judgement.
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| A-18
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| Part II Page 2 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
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| H. MINIMUM 00.l\.NTIFICATION LEVEL (MOL)
| |
| If any individual analytical test result is less than the minimum quantifi-cation level listed below, a value cf zero (0) may be used for that individual result for the Discharge Monitoring Report (DMR) calculations and reporting requirements.
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| NON CONVENTIONAL MOL (µg/L)
| |
| Phenolics, Total Recoverable (4~.AP) 5 Chlorine (Total Residual) 100 3-Chlorophenol 10 4-Chlorophenol 10 2,3-Dichlorqphenol 10 2,5-Dichlorophenol 10 2,6-Dichlorophenol 10 3,4-Dichlorophenol 10 2,4-D 10 2,4,5-TP (Silvex) 4 METALS AND CYANIDE MOL (µa/L)
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| Antimony (Total) 60 Arsenic ' ' (Total) 10 Beryllium (Total) 5 Cadmium (Total) 1 Chromium (Total) 10 Chromium (3+) 10 Chromium (6+) 10 Copper (Total) 10 Lead (Total) 5 Mercury (Total) 0.2 Molybdenum (Total) 30 Nickel (Total) Freshwater 40 Nickel (Total) Marine 5 Seleniu.'Tl (Total) 5 Silver (Total) 2 Thallium (Total) 10 Zinc (Total) 20 Cyanide* (Total) 20 DIOXIN MOL (ug/Ll 2,3,7,8-TCDD 0.00001 VOLATILE COMPOUNDS MOL (ug/T.)
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| Acrolein 50 Acrylonitrile 50 Benzene 10 Bromof orm 10 Carbon Tetrachloride 10 Chlorobenzene 10 Chlorodibromomethane 10 Chloroethane 50 2-Chloroethylvinylether 10 Chloroform 10 A-19
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| | |
| Part II Page 3 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
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| Dichlorobromomethane 10 1,1-Dichloroethane 10 1,2-Dichloroethane 10 1,1-Dichloroethylene 10 1,2-Dichloropropane 10 1,3-Dichloropropylene 10 Ethylbenzene 10 Methyl Bromide [Brornomethane] 50 Methyl Chloride [Chloromethane] 50 Methylene Chloride 20 1,1,2,2-Tetrachloroethane 10 Tetrachloroethylene 10 Toluene 10 1,2-trans-Dichloroethylene 10 1,1,1-Trichloroethane 10 1,1,2-Trichloroethane 10 Trichloroethylene 10 Vinyl Chloride 10 ACID COMPOUNDS MOL (µg/Ll 2-Chlorophenol 10 2,4-Dichlorophenol 10 2,4-Dimethylphenol 10 4,6-Dinitro-o-Cresol [2-Methyl-4,6-Dinitrophenol] 50 2,4-Dinitrophenol 50 2-Nitrophenol 20 4-Nitrophenol 50 p-Chloro-m-Cresol [4-Chloro-3-Methylphenol] 10 Pentachlorophenol 50.
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| Phenol 10 2,4,6-Trichlorophenol 10 BnSE/NEUTRJ\L COMPOUNDS MOL {µg/Ll Acenaphthene 10 Acenaphthylene 10 Anthracene 10 Benzidine 50 Benzo(a}anthracene 10 Benzo(a)pyrene 10 3,4-Benzofluoranthene 10 Benzo(ghi)perylene 20 Benzo(k)fluoranthene 10 Bis(2-chloroethoxy) Methane 10 Bis(2-chloroethyl) Ether 10 Bis(2-chloroisopropyl) Ether 10 Bis(2-ethylhexyl) Phthalate 10 4-Bromophenyl Phenyl Ether 10 Butylbenzyl Phthalate 10 2-Chloronapthalene 10 4-Chlorophenyl Phenyl Ether 10 Chrysene 10 Dibenzo(a,h}anthracene 20 1,2-Dichlorobenzene 10 A-20
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| | |
| Part II Page 4 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS {continued) 1,3-Dichlorobenzene 10 1,4-Dichlorobenzene 10 3,3'-Dichlorobenzidine 50 Diethyl Phthalate 10 Dimethyl Phthalate 10 Di-n-Butyl Phthalate 10 2,4-Dinitrotoluene 10 2,6-Dinitrotoluene 10 Di-n-octyl Phthalate 10 1,2-Diphenylhydrazine 20 Fluoranthene 10 Fluorene 10 Hexachlorobenzene 10 Hexachlorobutadiene 10 Hexachlorocyclopentadiene 10 Hexachloroethane 20 Indeno(l,2,3-cd)pyrene [2,3-o-Phenylene Pyrene] 20 Isophorone 10 Naphthalene 10 Nitrobenzene 10 n-Nitrosodimethylamine 50 n-Nitrosodi-n-Propylamine 20 n-Nitrosodiphenylamine 20 Phenanthrene 10 Pyrene 10 1,2,4-Trichlorobenzene 10 PESTICIDES MQL !b!gt'.Ll Aldrin 0.05 Alpha-BHC 0.05 Beta-BHC 0.05 Gamrna-BHC [Lindane) 0.05 Delta-BHC 0.05 Chlordane 0.2 4,4'-DDT 0.1 4,4'-DDE [p,p-DDX) 0.1 4,4'-DDD [p,p-TDE) 0.1 Dieldrin 0.1 Alpha-Endosulfan 0.1 Beta-Endosulfan 0.1 Endosulfan Sulfate 0.1 Endrin 0.1 Endrin Aldehyde 0.1 Heptachlor 0.05 Heptachlor Epoxide i BHC-He:rnchlorocyclohexane) 0.05 PCB-1242 1. 0 PCB-1254 1. 0 PCB-1221 1. 0 PCB-1232 1. 0 PCB-1248 1. 0 PCB-1260 1. 0 PCB-1016 1. 0 Toxaphene 5.0 A-21
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| Part II Page 5 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
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| The,permittee may develop an effluent specific method detection limit (MDLi in accordance with Appendix B to 40 CFR Part 136 (See LAC 33:IX.4901). For any pollutant for which the permittee d~termines an effluent specific MDL, the, permittee shall send to this Office a report containing QA/QC documentation, analytical results, and calculations necessary to demonstrat~
| |
| that the effluent specific MDL was correctly calculated. An effluent specific minimum quantification level (MQL) shall be determined in accordance with the following calculation:
| |
| MQL = 3.3 x MDL Upon written approval by this Office, the effluent specific MQL may be utilized by the permittee for all future Discharge Monitoring Report (DMR) calculations and reporting requirements.
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| I. The permittee shall achieve compliance with the effluent limitations and monitoring requirements specified for discharges in accordance with the following schedule:
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| Effective date of the permit J. PROHIBITION OF PCB DISCHARGES There shall be no discharge of polychlorinated biphenyls (PCB' s) . The minimum quantification level for PCB' s is 1. 0 µg/L. If any individual analytical test result for _PCB's is less than the minimum quantification level, then a value of zero(O) shall be used for the Discharge Monitoring Report (DMR) calculations and reporting requirements.
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| K. PROHIBITION OF 126 PRIORITY POLLUTANTS There shall be no discharge of any 126 priority pollutants ( 40 CFR 423 Appendix A) associated with the chemicals added for cooling tower maintenance, except total chromium and total zinc. The minimum quantification levels for the 126 priority pollutants are found in.Part II, Paragraph I.
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| L. CHEMICll.L METAL CLEANING WASTE The term chemical metal cleaning waste means any wastewater resu~Ling from cleaning of any metal process equipment with chemical compounds, including, but not limited to, boiler tube cleaning.
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| M. METAL CLEANING WASTE The term metal cleaning waste means any wastewater resulting from cleaning (with or without chemical cleaning compounds) any metal process equipment including, but not limited to, boiler tube cleaning, boiler fireside cleaning, and air preheater cleaning.
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| A-22
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| Part II Page 6 of 24 Permit No. LA0007374
| |
| .IU No. 35260 OTHER REQUIREMENTS (continued)
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| N. LOW VOLUME WASTE SOURCES The term "low volume waste sources" means, taken collectively as if from one source, wastewater from all sources except those for which specific limitations are otherwise established. Low volume waste sources include, but are not limited to: wastewaters from wet scrubber air pollution control systems, ion exchange water treatment systems, water treatment evaporator blowdown, laboratory and sampling streams, boiler blowdown, floor drains, cooling tower basin cleaning wastes, and recirculating house service water systems. Sanitary and air conditioning wastewaters are not included.
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| : 0. TOTAL RESIDUAL CHLORINE The term "total residual chlorine" (or total residual oxidants for intake water with bromides) means the value obtained using the amperometric method for total residual chlorine described in 40 CFR Part 136.
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| Total residual chlorine may not be discharged from any unit for more than two hours per day.
| |
| Simultaneous multi-unit chlorination is permitted.
| |
| P. FREE AVAILABLE CHLORINE The term "free available chlorine" shall mean the value obtained using the amperometric titration method for free available chlorine described in the latest edition of Standard Methods for the Examination of Water and Wastewater.
| |
| Free available chlorine may not be discharged from any unit for more than two hours in any one day and not more than one unit in any plant may discharge free available chlorine at any one time.
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| Q. TEt1PERATORE Daily temperature discharge is defined as the flow-weighted average (FWAT) and, on a daily basis, shall be monitored and recorded in accordance with Part I of this permit. FW.11.T shall be calculated at equal time intervals not greater than two hours. The method of calculating FWAT is as follows:
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| FW.Z:\T = SUMMATION (INSTANTANEOUS FLOW X INSTll.NTANEOUS TEMPERATURE)
| |
| SUMMATION (INSTANTANEOUS FLOW)
| |
| "Daily average temperature" (also known as average monthly or maximum 30 day value) shall be the arithmetic average of all FWATs calculated during the calendar month.
| |
| "Daily maximum temperature" (also known as the maximum daily value) shall be the highest FWAT calculated during the calendar month.
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| A-23
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| | |
| Part II Page 7 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
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| R. HEAT Discharge of heat shall be continuously calculated and recorded as:
| |
| [Instantaneous AT (circulating water temperature rise through the plant in
| |
| °F)] X [Instantaneous flow rate in MGD] X [3.48Xl0 5 ]
| |
| OR AS
| |
| [Heat. transferred to the turbine generator cycle (BTU/hour)] [Gross electrical output (BTU/hour)].
| |
| S. NON-RADIOACTIVE WASTEWATERS Certain low volume and chemical wastewaters from this facility with no detectable radioactivity, as defined by the Nuclear Regulatory Commission plant effluent. release limits may be cominingled and treated with similar wastewaters from Waterford 1 & 2 and controlled under terms of LPDES Permit Number LA0007439.
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| T. WATER TREATMENT CLARIFIER SLUDGE WASTES Water treatment clarifier sludge wastes may be returned.to the stream without
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| *treatment if not previously combined with any other untreated waste source, including demineralizer and softener wastes, U. ZEBRA MUSSEL TREATMENT The terms and conditions of the zebra mussel treatment program submitted by Entergy Operations, Inc., Waterford 3 and approved by this Office on June 23, 1998, shall be enforceable as if part of this permit.
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| According to section 3.d., "Samples and Composites", of the biomonitoring requirements paragraph of this permit, the permit.tee must collect composite samples that "are representative of any periodic episodes of chlorination, biocide usage, or other potentially toxic substance discharged on an intermittent casis". Anytime the treatment method involves an increase in the concentration of a treatment chemical, a change in type of treatment chemical used, or if any event occurs that creates the potential for an effluent with a higher toxic nature, additional biomonitoring according to the terms and conditions of the biomonitoring seclion of Part II of this permit shall be required.
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| The perrnittee must not~fy this Office if changes occur in the zebra mussel control plan and obtain approval prior to initiating the new treatment. If chlorine is applied to control zebra mussels, the permittee must comply with a daily maximum Total Residual Chlorine (TRC) concentration limit of 0.2 mg/L. Monitoring shall be performed at a frequency o.f l/day, by grab sample, during periods of chlorine application.
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| A-24
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| | |
| Parl II Page 8 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS {continued)
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| V. PERMIT REOPENER CLAUSE This permit may be modified, or alteynatively, revoked and reissued, to comply with any applicable effluent standard or limitations issued or approved under sections 301 (b) (2) (C) and {D); 304 {b) (2); and 307 {a) (2) of the Clean Water Act, or more stringent discharge limitations and/or additional restrictions in the future to maintain the water quality integrity and the designated uses of the receiving water bodies based upon additional water quality studies and/or TMDL's, if the effluent standard, limitations, water quality studies or TMDL's so issued o:r approved:
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| : 1. Contains different conditions or is otherwise mo:re stringent than any effluent limitation in the permit; or
| |
| : 2. Controls any pollutant not limited in the permit; or
| |
| : 3. Require reassessment due to change in 303(d) status of waterbody; or
| |
| : 4. Incorporates the results of any to-::al maximum daily load allocation, which may be approved for the receiving water body.
| |
| The Louisiana Department of Environmental Quality (LDEQ) reserves the right to modify or revoke and reissue this permit based upon any changes to established TMDL' s for this dis cha r.ge, or to accommodate for pollutant trading provisions in approved TMDL watersheds as necessary to achieve compliance with water quality standards. Therefore, prior to upgrading or expanding this facility, the permi ttee should contact the Department to determine the status of the work being done to establish future effluent limitations and additional permit conditions.
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| W. STORMWATER DISCHARGES
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| : 1. This section applies to all stormwater discharges from the facility, eilher through permitted outfalls or through outfalls which are not listed in the permit or as sheet flow. The purpose of the pollution prevention plan is to identify potential sources of pollution that would reasonably be expected to affect the quality of stormwater and identify the practices that will be used to prevent or reduce the pollutants in stormwater discharges.
| |
| : 2. Any runoff leaving the developed areas of the facility, other than the permitted outfall (s), exce.eding 50 mg/L TOC, 15 mg/L Oil and Grease, or having a pH less than 6.0 or greater than 9.0 standard units shall be a violation of this permit. Any discharge in excess of these limitations, which is attributable to offsite contamination shall not be considered a violation of this permit. A visual inspection of the facility shall be conducted and a report made annually as described in Paragraph 4 below.
| |
| : 3. For first time permit issuance, the permittee shall prepare, implement, and maintain a Storm Water Pollution Prevention Plan (SWP3) within six (6) months of the effective date of the final permit. For renewal.
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| permit issuance, the perrnittee shall review and update, if necessary, A-25
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| | |
| Part II Page 9 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued) a *Storm Water Pollution Prevention Plan (SWP3) within six (6) months of the effective date of the final permit. The terms and conditions of the SWP3 shall be an enforceable Part of the permit. If the permittee maintains other plans that contain duplicative information, those plans could be incorporated by reference into the SWP3. Examples of these type plans include, but are ndt limited to: Spill Prevention Control and Countermeasure Plan (SPCC), Best Management Plan (BMP), Response Plans, etc*. EPA document 832-R-92-006 (Storm Water Management for Industrial Activities) may be used as a guidance and may be obtained by writing to the Water Resource Center (RC-4100T), U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue NW., Washington D.C. 20460 or by calling (202) 566-1729 or via the Wetl~nds Helpline (800) 832-7828.
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| : 4. The following conditions are applicable to all facilities and shall be included i~ the SWP3 for the facility.
| |
| : a. The permittee shall conduct an annual inspection of the facility site to identify areas contributing to the storm water discharge from developed areas of the facility and evaluate whether measures to reduce pollutant loadings identified in the SWP3 are adequate and have been properly implemented in accordance with the terms of the permit or whether additional control measures are needed.
| |
| : b. The perrnittee shall develop a site map which includes all areas I
| |
| \
| |
| \.,
| |
| where stormwater may contact potential pollutants or subs-tances which can cause pollution. Any location where reportable quantities leaks or spills have previously occurred are to be documented in the SWP3. The SWP3 shall contain a description of the potential*
| |
| pollutant sources, including,, the type and q1:1antity of material present and what action has been taken to assure stormwater precipitation will not directly° contact the substances and result in contaminated runoff.
| |
| : c. Where experience indicates a reasonable potential for equipment failure (e.g. a tank ov~rflow or leakage), natural condition of (e.g~ precipitation), or other circumstances which result in signi.ficant amounts of pollutants reaching surface waters, the SWP3 should include a prediction of the direction, rate of flow and total quantity of pollutants which could be discharged from the facility as a result of each condition or circumstance.
| |
| : d. The permittee shall maintain for a period of three years a record summarizing the results of the inspection and a certification that the facility is in compliance with the SWP3, ari.d identifying any incidents of noncompliance. The su.rnmary report should contain, at a minimum, the date and time of inspection, name of inspector(s),
| |
| conditions found, nnd changes to be made t*o the SWP3.
| |
| : e. The summary report and the following certification shall be signed in accordance with LAC 33: IX. 2503. The summary report is to be attached to the SWP3 and provided to the Department upon request.
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| A-26
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| Part II Page 10 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQOIREMENTS (continued}
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| "I certify under penalty of law that this docu.Tflent and all attachn1ents were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."
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| Signatory requirements for the certification may be found in Part III, Section D.10 of this permit.
| |
| : f. The permittee shall make available to the Department, upon request, a copy of the SWP3 and any supporting documentation.
| |
| : 5. The following shall be included in the SWP3, if applicable.
| |
| : a. The permittee shall utilize all reasonable methods to minimize any adverse impact on the drainage system including but not limited lo:
| |
| : i. maintaining adequate roads and driveway surfaces; ii. removing debris and .accumulated solids from the drainage system; and iii. cleaning up immediately any spill by sweeping, absorbent pads, or other appropriate methods.
| |
| : b. All spilled product and other spilled wastes shall be immediately cleaned up and disposed of according to all applicable regulations, Spill Prevention and Control (SPC) plans or Spill Prevention Control and Countermeasures (SPCC) plans. Use of detergents, emulsifiers, or dispersants to clean up spilled product is prohibited except where necessary to comply with State or Federal safety regulations (i.e., requirement for non-slippery w0 rk surface) except where the cleanup practice does not =esult in a discharge and does not leave residues exposed to future storm events. In all such cases, initial cleanup shall be done by physical removal and chemical usage shall be minimized.
| |
| : c. All equipment, parts, dumpsters, trash bins, petroleum products, chemical solvents, detergents, or other materials exposed to stormwater shall be maintained in a manner which prevents contamination of stormwater by pollutants.
| |
| : d. All waste fuel, lubricants, coolants, solvents, or other fluids used in the repair or maintenance of vehicles or equipment shall be recycled or contained for proper disposal. Spills of these materials are to be cleaned up by dry means whenever possible.
| |
| : e. If applicable, all storage tank installations (with a capacity greater than 660 gallons for an individual container, or 1,320 gallons for two or more containers in aggregate within a common A-27
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| Part II Page 11 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued) storage area) shall be constructed so that a secondary means of containment is provided for the entire contents of the largest tank plus sufficient freeboard to allow for precipitation. Diked areas should be sufficiently impervious Lo contain spills.
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| : f. All diked areas surrounding storage tanks or stormwater collection basins shall be free of residual oil or other contaminants so as to prevent the accidental discharge of these materials in the event of f1-ooding, dike failure, or improper draining of the diked area. All drains from diked areas shall be equipped with valves which shall be kept in the closed condition except during periods of supervised discharge.
| |
| : g. All check valves, tanks, drains, or other potential sources of pollutant releases shall be inspected and maintained on a regular basis to assure their proper operation and to prevent the discharge of pollutants.
| |
| : h. The permittee shall assure compliance with all applicable regulations promulgated under the Louisiana Solid Waste and Resource Recovery Law and the Hazardous Waste Management Law (L. R. S. 30: 2151, etc.). Management practices required under above regulations shall be referenced in the SWP3.
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| : i. The permi ttee shall amend the SWP3 whenever there is a change in the facility or change in the operation of the facility which materially increases the potential for the ancillary activities to result in a discharge of significant amounts of pollutanls.
| |
| : j. If the. SWP3 proves to be ineffective in achieving the general objectives of preventing the release of significant amounts of pollutants to water of the state, then the specific objectives and requirements of the SWP3 shall be subject to modification Lo incorporate revised SWP3 requirements.
| |
| : 6. Facility Specific SWP3 Conditions:
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| None X. DISCHARGE MONITORING REPORTS Monitoring results must be reported on a Discharge Monitoring Report (DMR) form (EPA No. 3320-1 or an approved substitute). All monitoring reports must be retained for a period of at least three (3) years from the date of the sample measurement. The permittee shall make available to this Department, upon request, copies of all monitoring data required by this permit.
| |
| If there is no discharge during the reporting period, place an "X" in the NO DISCHARGE box located in the upper right corner of the Discharge Monitoring Report for that outfall.
| |
| Monitoring results for each reporting period shall be surnmari zed on a Discharge Monitoring Report (DMR) Form (one DMR form per monitoring period A-28
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| | |
| Part II Page 12 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued) per outfall) and submitted to the Office of Environmental Compliance either
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| ~and delivered, postmarked, or electronically submitted no later than the 15th day of the month following each reporting period.
| |
| : 1. For parameter(s) with monitoring frequencies of 1/month or more frequent (i.e. continuous, 1/batch, 1/discharge event, 1/day, 3/week, 2/week, 1/week, 2/rnonth, etc.), DMRs shall be submitted in accordance with the following schedule:
| |
| Submit DMR postmarked by the 15th day of the following month.
| |
| : 2. For parameter(s) that require a monitoring frequency of 1/2 months, DMRs shall be submitted in accordance with the following schedule:
| |
| Monitoring Period DMR Postmark Date January 1 - February 28(29) March 15th March 1 - April 30 May 15th May 1 - June 30 July 15th July 1 - August 31 September 15th September 1 - October 31 November 15th November 1 -December 31 January 15th
| |
| : 3. For pararneter(s) that require a monitor.ing frequency of quarterly, DMRs shall be submitted in accordance with the following schedule:
| |
| Monitoring Period DMR Postmark Date January, February, March April 15th April, May, June July 15th July, August, September October 15th October, November, December January 15th
| |
| : 4. For parameter(s) that require a semiannual monitoring frequency, DMRs shall be submitted in accordance with the following schedule:
| |
| Monitoring Period DMR Postmark Date January - June July 15th July - December January 15th
| |
| : 5. For parameter(s) that require an annual monitoring frequency, D~Rs shall be submitted in accordance with the following schedule:
| |
| Monitoring Period DMR Postmark Date January-December January 15th If not electronically submitting, duplicate copies of DMR' s (one set of originals and one set of copies) signed and certified as required by LAC 33:IX.2503, and all other reports (one set of originals) required by this permit shall be submitted to the Permit Compliance Unit at the following address:
| |
| A-29
| |
| | |
| Part II Page 13 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS {continued)
| |
| Department of Environmental Quality Off.ice of Environmental Compliance Permit Compliance Unit Post Off.ice Box 4312 Baton Rouge, Louisiana 7082i-4312 Y. 316(b) PHASE II RULE REQUIREMENTS
| |
| : 1. On July 6, 2004, EPA promulgated Phase II regulations in accordance with section 316 (b) of the Clean Water Act (CWA). In February 2005, LDEQ promulgated Phase II regulations found at LAC* 33:IX.Chapter 47.Subchapter B .. On January 25, 2007, the Second U.S._Circuit Court of Appeal.s remanded several provisions of the Phase II rule. On March 20, 2007, EPA issued a memo saying, "the rule should be considered suspended"~ On July 9, 2007, EPA published a Federal Register notice suspending all.parts of the Phase II regulations except 40 CFR 125.90(b)
| |
| [LAC 33:IX.4731.B]. In October 2007, LDEQ suspended LAC 33:IX.Chapter 47, Subchapter B, with the exception of LAC 33:IX.4731.~.
| |
| * According to EPA, 316(b) Phase II regulations are under complete reconsideration at this time. LAC 33:IX.4731.B *provides for regulating cooling water intake structures for existing faGilities on a case-by-*
| |
| case basis using best professional judgment.
| |
| EPA' s repromulgat*ion of the Phase II Rule may require procedures or timelines different from those included in this permit. If necessary for compliance with the Phase II Rule, this permit may be reopened.
| |
| In order to reduce the adverse environmental impact, if any, caused by the cooling water intake structure (CWIS), the permittee *shall comply with effective regulations promulgated in accordance with section 316(b) of the CWA for cooling water intake structures. The permittee shall at all times operate and maintain the existing CWIS as described in the
| |
| . assessment document received on July 10, 2008, entitled Impingement Mortality and Entrainment Characterization Study (IMECSJ. The permittee has submitted information to DEQ characterizing the fish/shellfish in the vicinity of the CWIS, assessing impingement mortality and entrainment ( IM&E), and assessing the cooling water system. DEQ may request an update of this information, or additional information, if necessary, to comply with the repromulgated Phase II Rule.
| |
| : 2. The following special definitions apply to this subpart:
| |
| : a. Baseline conditions means the impingement mortality and entrainment that would occur at your site assuming that (1) the cooling water system has been designed as a once-through system, (2) the opening of the CWIS is located at, and the face of the standard 3/8-ineh mesh traveling screen is oriented parallel to, the shoreline near the surface of the source water body.
| |
| A-30
| |
| | |
| Part II Page 14 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
| |
| : b. Closed-cycle recirculating system means a system designed, using minimized makeup and blow down flows, to withdraw water from a natural or other water source to support contact and/or non-contact cooling uses within a facility. The water is usually sent to a cooling canal or channel, lake, pond, or tower to allow waste heat to be dissipated to the atmosphere and then is returned to the system. (Some facilities divert the waste heat to other process operations.) New source water (make-up water) is added to the system to replenish losses that have occurred due to blow down, drift, and evaporation
| |
| : c. Cooling water means water used for contact or non-contact cooling, including water used for equipment cooling, evaporative cooling tower makeup, and dilution of effluent heat content. The intended use of the cooling water is to absorb waste heat rejected from the process or processes used, or from auxiliary operations. on the facility's premises.
| |
| : d. Cooling water intake ~tructure means the total physical structure and any associated constructed waterways used to withdraw cooling water from waters of the U.S. The coqling water" intake structure extends from the point at which water is withdrawn from the surface water source up to, and including, the intake pumps.
| |
| : e. Intake flow means the value of the total volume of water withdrawn from a source water body over a specific time pe.riod.
| |
| : f. Intake velocity means the'value of the ~verage speed at which intake water passes through the open area of the intake screen (or other device) against which organisms might be impinged or through which they might be entrained.
| |
| : g. Entrainment means the incorporation of all life stages of fish and shellfish with intake water flow enterit1g and passing through a cooling water intake structure and into a cooling water system.
| |
| : h. Hydraulic zone of influence means that portion of the source ~ater body hydraulically affected by the cooling water intake structure withdrawal of water.
| |
| : i. Impingement means the entrapment of all life stages of fish and shellfish on the outer part of an intake structure or against a screening device during periods of intake water withdrawal.
| |
| : j. Maximiz~ means to increase to the greatest amount, extent, or degree reasonably possible.
| |
| : k. Minimize means to reduce to the smallest amount, extent, or degree reasonably possible.
| |
| A-31
| |
| | |
| Part II Page 15 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
| |
| I Z. 48 HR ACU'rE BIOMONITORING REQUIREMENTS: FRESHWATER It is unlawful and a violation of this permit for a permitt.ee or the designated agent to manipulate test samples in any manner, to delay shipment, or to terminate a i:oxicity test. Once initiated, all toxicity tests must be completed unless specific authority has been granted by the Louisiana Department of Environmental Quality.
| |
| : 1. SCOPE AND METHODOLOGY
| |
| : a. The permit tee shall test the effluent for toxicity in accordance with the provisions in this section.
| |
| A PPL I C11.BLE TO OUT FALL ( S) : 001 CRI TICP..L DILUTION: 31%
| |
| EFFLUENT DILUTION SERIES: 13%, 18%, 24%, 31%, and 42%
| |
| COMPOSITE SAMPLE TYPE: Defined at PART I TEST SPECIES/METHODS: 40 CFR Part 136 {See LAC 33:IX.4901)
| |
| Daphnia pulex acute static renewal. 48-hour definitive toxicity test using EPA 821-R-02-012, or the latest update thereof. A minimum of five (5) replicates with ten (10) organisms per replicate must be used in the control and in each effluent dilution of this test.
| |
| Pimephales promelas (Fathead minnow) acute static renewal 48-hour definitive toxicity test using EPA 821-R-02-012, or the latest update thereof. A minimum of five (5) replicates with ten (10) organisms per replicate must be used in the control and in each effluent dilution of this test.
| |
| : b. The NOEC (No Observed. Effect Concentration) is defined as the greatest effluent dilution at and below which lethality that is statistically different from the control (0% effluent) at the 95%
| |
| confidence level does not occur.
| |
| : c. This permit may be reopened to require whole effluent toxicity limits, chemical speciric effluent limits, additional testing, and/or other appropriate actions to address toxicity.
| |
| : d. Test failure is defined as a demonstration of statistically significant sub-lethal or lethal effects to a test species at or below the efflu.ent critical dilution.
| |
| : 2. PERSISTENT LETHALITY The requirements of this subsection apply only when a toxicity test demonstrates significant lethal effects at or below the critical A-32
| |
| | |
| Part I I Page 16 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued) dilution. Significant lethal effects are herein defined as a statistically significant difference at the 95% confidence level between the survival of the appropriate test organism in a specified effluent dilution and the control (0% effluent).
| |
| If any valid test demonstrates significant lethal effects to a test species at or below the critical dilution, the frequency of testing for that species is automatically increased to once per quarter for the term of the permit.
| |
| : a. The pennittee shall conduct a total of three (3) additional tests for any species that demonstrates statistically significant lethal toxic effects at the critical dilution or lower effluent dilutions.
| |
| The additional tests shall be conducted monthly during the next three consecutive months in which a discharge occurs to determine if
| |
| * toxic.ity is persistent or occurs on a periodic basis. The purpose of this testing is to determine whether toxicity is present at a level and frequency that will provide toxic sample results to use in performing a Toxicity Reduction Evaluation (TRE). If no additional test failures occur during the retest monitoring period, the testing frequency will be once per quarter for the term of the permit or until another test failure occurs. The permittee may substitute one of the additional tests in lieu of one routine toxicity test. A full report shall be prepared for each test required by this section in accordance with procedures outlined in Item 4 of this section and submitted with the period discharge monitoring report (DMR) to the permitting authority for review.
| |
| : b. If any of the valid additional tests demonstrates significant lethal effects at or below the critical dilution, the permittee shall initiate Toxicity Reduction Evaluation (TRE) requirements as specified in Ite~ 6 of this section. The permittee shall notify the Department of Environmental Quality, Office of Environmental Compliance - Permit Compliance Unit in writing within 5 days of the failure in any retest, and the TRE initiation date will be the test completion date of the first failed retest. A TRE may also be required due to a demonstration of intermittent lethal effects at or below the critical dilution, or for failure to perform the required retests.
| |
| : c. The provisions of Item 2.a are suspended upon submittal of the TRE Action Plan.
| |
| : 3. REQUIRED TOXICITY TESTING CONDITIONS
| |
| : a. Test Acceptance The permittee shall repeat a test, including the control and all effluent dilutions, if the procedures and quality assurance requirements defined in the test methods or in this permit are not satisfied, including the following additional criteria:
| |
| A-33
| |
| | |
| .Part II Page 17 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
| |
| : i. Each toxicity test control (0% effluent) must have a survival equal to or greater than 90%.
| |
| ii. The percent coefficient of variation between replicates shall be 40% or less in the control (0% effluent) for: Daphnia pulex survival test; and Fathead minnow survival test.
| |
| iii. The percent coefficient of variation between replicates shall be 40% or less in the critical dilution, unless significant lethal effects are exhibited for: Daphnia pulex survival test; and Fathead minnow survival test.
| |
| Test failure may not be construed or reported as invalid due to a coefficient of variation value of greater than 40%. A repeat test shall be conducted within the required reporting period of any test determined to be invalid.
| |
| : b. Statistical Interpretation For the Daohnia pulex survival test and the Fathead minnow survival test, the statistical analyses used to determine if there is a statistically significant difference *between the control and the critical dilution shall be in accordance with the methods for determining the No Observed Effect Concentration (NOEC) as described in EPA 821-R-02-012, or the most recent update thereof.
| |
| If the conditions of Test Acceptability are met in Item 3.a above and the percent survival of the test organism.is equal to or greater than 90% in the critical dilution concentration and all lower dilution concentrations, the test shall be considered to be a passing test regardless of the NOEC, and the permittee shall report a NOEC of not less than the critical dilution for the DMR reporting requirements found in Item 4 below.
| |
| : c. Dilution Water
| |
| : i. Dilution water used in the toxicity tests will be receiving water collected as close to the point of discharge as possible but unaffected by the discharge. The permittee shall substitute synthetic dilution water of similar pH, hardness and alkalinity to the closest downstream perennial water for; (A) toxicity tests conducted on effluent discharges to receiving water classified as intermittent streams; and (B) toxicity tests conducted on effluent discharges where no receiving water is available due to zero flow conditions.
| |
| ii. If the receiving water is unsatisfactory as a result of instream toxicity (fails to fulfill the test acceptance criteria of Item 3.a), the permittee may substitute synthetic A-34
| |
| | |
| Part II Page 18 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued) dilution water for the receiving water in all subsequent tests provided the unacceptable receiving water test met the following stipulations:
| |
| (A} a synthetic dilution water control which fulfills the test acceptance requirements of Item 3.a was run cohcurr,ently with the receiving water control; (BJ the test indicating receiving water toxicity has been carried out to completion (i.e., 48 hours);
| |
| (C) the permittee includes all test results indicating receiving water toxicity with the full report and information required by Item 4 below; and (D) the synthetic ~ilution water shall have a pH, hardness and alkalinity similar to that of the receiving water or closest downstream perennial water not adversely affected by 'the discharge, provided the magnitude of these parameters will not cause toxicity in the synthetic dilution water.
| |
| : d. Samples and-Composites
| |
| : i. The permittee shall collect two 24-hour flow-weighted composite samples from the outfall (s) listed at Item 1. a above. A 24-hour composite sample consists of a minimum of 4 effluent portions collected at equal time intervals representative of a 24-hour operating day and combined proportional to flow or a sample continuously collected proportional to flow over a 24-hbur operating day .
| |
| .ii. The permi ttee sha 11 collect a second 24-hour composite sample for use during the 24~hour renewal of each dilution concentration for both tests. The permittee must tollect the 24-hour composite samples so that the maximum holding time for ahy effluent sample shall not exceed 36 hours. The permittee must have initiated the toxicity test within 36 hours after the collection of th.e last portion of the first 24-hour composite sample. Samples shall be chilled to 0-6 degrees Centigrade during collection, shipping and/or storage.
| |
| iii. The permit tee must collect the 24-hou.r cornposi te samples such that the effluent samples are representative of any periodic e~isode of chlorination, biocide usage or other potentially toxic substance discharged on an intermittent basis.
| |
| iv; If the flow from the outfall(s) being tested ceases during the collection of effluent samples, the requirements for the minimum number of effluent samples, the minimum number of effluent portions and the sample holding time are waived during that sampling period. However, the permittee must collect an effluent composite sample volume during the period of discharge A-35
| |
| | |
| Part II Page 19 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued) that is sufficient to complete the required toxicity tests with daily renewal of effluent. When pcssibl.e, the effluent samples used for the toxicity tests shall be collected on separate days. The effluent composite sample collection duration and the static renewal protocol associated with the abbreviated sample collection must be documented in the full report required in Item 4. of this section.
| |
| : v. MULTIPLE OUTFALLS: If the provisions of this section are applicable to multiple outfalls, the perrnittee shall combine the composite effluent samples in proportion to the average flow from the outfalls listed in Item l.a above for the day the sample was collected. The permittee shall perform the toxicity test on the flow-weighted composite of the outfall samples.
| |
| 4* REPORTING
| |
| : a. A valid test must be completed and test results must be submitted for each species during each Monitoring Period. The permittee shall prepare a full report of the results of all tests conducted pursuant to ~his Part in accordance with the Report Preparation Section of EPA 821-R-02-012, for every valid or invalid toxicity test initiated, whether carried to completion or not. The permittee shall retain each full report pursuant to the provisions of Part III.C.3 of this permit. For any test which fails, is considered invalid or which is terminated early for any reason, the full report must be submitted for agency review. The permittee shall submit the first full report to the following address:
| |
| Department of Environmental Quality Office of Environmental Compliance Enforcement Division P.O. Box 4312 Baton Rouge, Louisiana 70821-4312 Attn: Permit Compliance Unit In addition, if enforcement authority has been retained by EPA, a copy of the report must also be submitted to the following address:
| |
| U.S. Environmental Protection Agency, Region 6 Water Enforcement Branch, 6 EN-WC 1445 Ross Ave.
| |
| Dallas, Texas 75202
| |
| : b. The permittee shall submit the results of each valid toxicity test on the DMR for that Moni taring Period in accordance with Part III.D.4 of this permit. Submit retest information clearly marked as such on the DMR for the Monito:::-ing Period in which the retest occurred. Only results of valid tests are to be reported on the DMR. The permittee shall submit the Table 1 Surnmary Sheet with each valid test.
| |
| A-36
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| | |
| Part II Page 20 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
| |
| : i. Pimeohales oromelas (Fathead minnow)
| |
| (A) If the No Observed Effect Concentration (NOEC) for survival is less than the critical dilution, enter a "l"; otherwise, enter a "0" for Parameter No. TEM6C.
| |
| (B) Report the NOEC value for survival, Parameter No. TOM6C.
| |
| (C) Report the highest (critical dilution or control)
| |
| Coefficient of Variation, Parameter No. TQM6C.
| |
| ii. Daphnia pulex (A) If the NOEC for survival is less than the critical dilution, enter a "1"; otherwise, enter a "0" for Parameter No. TEM3D.
| |
| (B) Report the NOEC value for survival, Parameter No. TOM3D.
| |
| {C) Report .the highest (critical dilution or control)
| |
| Coefficient of Variationr' Parameter No. TQM3D.
| |
| iii. The permittee shall report the following results for all VALID toxicity retests on the DMR for that Monitoring Period.
| |
| {A) Retest #1 (STORET 22415): If the first monthly retest foll'owing failure of a routine test for either test species results in an NOEC for survival less than the critical dilution, report a "l"; otherwise, report a "0".
| |
| (B) Retest #2 (STORET 22416): If the second monthly retest following failure of a routine test for either test species results in an NOEC for survival less than the critical dilution, report a "l"; otherwise, report a "0".
| |
| (C) Retest #3 (STORET 51443): If the third monthly retest following failure of a routine test for either test species results in an NOEC for survival less than the critical dilution, report a "1"; otherwise, report a "0".
| |
| If, for any reason, a retest cannot be performed during the Monitoring Period in which the triggering routine test failure is experienced, the permittee shall report it on the following Monitoring Period's DMR, and the comments section of the DMRs shall be annotated to that effect. If retesting is not
| |
| ::-equired during a given Monitoring Period, the permittee shall leave these DMR fields blank.
| |
| A-37
| |
| | |
| Part II Page 21 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQOIREMENTS (continued)
| |
| The permittee shall submit the toxicity testing information contained in Table 1 of this permit with the '.:lMR subsequent to each and every toxicity test Monitoring Period. The DMR and the su.rnmary tables should be sent to the address indicated in 4.a.
| |
| : 5. MONI'rORING FREQUENCY REDUCTION
| |
| : a. Upon successfully passing the first four quarters of WET testing after permit isSuance/reissuance and in the absence of subsequent lethal toxicity for one or both test species at or below the critical dilution, the permittee may apply for a testing frequency reduction. Tf granted, the monitoring frequency for that test species may be reduced to not less than once per year for the less sensitive species (usually the Fathead minnow) and not less than once per six months for the more sensitive test species (usually the Daphnia pulex) . Monitoring frequency reduction shall not apply to monitoring frequencies of once per year.
| |
| : b. CERTIFICATION - The permittee must certify in writing that no test failures have occurred and that all tests meet all test acceptability criteria *in Item 3.a. above. In addition, the permittee must provide a list with each test performed including test initiation date, Species,' NOEC' s fo_r lethal and sub-lethal effects and the maximum coefficient of variation for the controls.
| |
| Upon review and acceptance of this information the agency will issue a letter of confirmation of the monitoring frequency reduction. A copy of the letter will be forwarded to the agency's Permit Compliance Unit to update the permit reporting requirements.
| |
| : c. This monitoring frequency reduction applies only until the expiration date of this permit, at which time the Monitoring Frequency/Monitoring. Period for both test species reverts to once per quarter until the permit is re-issued.
| |
| : d. SORVIVAL FAILURES - If any test fails the survival endpoint at any time during the term of this permit, three monthly retests are required and the monitoring frequency for the affected test species shall be increased to once per quarter until the permit is reissued.
| |
| Monthly retesting is not required if the permittee is performing a TRE.
| |
| : 6. TOXICITY REDUCTION EVALUATION (TRE)
| |
| : a. Within ninety (90) days of confirming lethality in the retests, the permittee shall submit a Toxicity Reduction Evaluation (TRE) Action Plan and Schedule for conducting a TRE. The TRE Action Plan shall specify the approach and methodology to be used in performing the TRE. A Toxicity Reduction Evaluation is an investigation intended to determine those actions necessary to achieve compliance with water quality-based effluent requirements/and or chemical-specific limits by reducing an effluent's toxicity to an acceptable level.
| |
| A TRE is defined as a step-wise process which _combines toxicity A-38
| |
| | |
| Part II Page 22 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS {continued) testing and analyses of the physical and chemical characteristics of a toxic effluent to identify the constituents causing effluent toxicity and/or treatment methods which will reduce the effluent toxicity. The TRE Action Plan shall lead to the successful elimination of effluent toxicity at the critical dilution and include the following:
| |
| : i. Specific Activities. The plan shall detail the specific approach the permittee intends to utilize in conducting the TRE. The approach may include toxicity characterizations, identifications and confirmation activities, source evaluation, treatability studies, or alternative approaches. When the permittee conducts Toxicity Characterization Procedures the permittee shall perform multiple characterizations and follow the procedures specified in the document "Methods for Aquatic Toxicity Identification Evaluations: Phase I Toxicity Characterization Procedures" {EPA-600/6-91/003) or alternate procedures. When the permittee conducts Toxicity Identification Evaluations and Confirmations, the permittee shall perform multiple identifications and follow the methods specified in the documents "Methods for Aquatic Toxicity Identification Evaluations, Phase II Toxicity Identification Procedures for Samples Exhibiting Acute and Chronic Toxicity"
| |
| {EPA/600/R-92/080) and "Methods for Aquatic Toxicity Identification Evaluations, Phase III Toxicity Confirmation Procedures for Samples Exhibiting Acute and Chronic Toxicity" (EPA/600/R-92/081), as appropriate.
| |
| The documents referenced above may be obtained through the National Technical Information Service (NTIS) by phone at (703) 487-4650, or by writing:
| |
| U.S. Department of Commerce National Technical Information Service 5285 Port Royal Road Springfield, Va. 22161 ii. Sampling Plan (e.g., locations, methods, holding times, chain of custody, preservation, etc.). The effluent sample volume collected for all tests shall be adequate to perform the toxicity test, toxicity characterization, identification and confirmation procedures, and conduct chemical specific analyses when a probable toxicant has been identified; Where the permittee has identified or suspects specific pollutant(s) and/or source{s) of effluent toxicity, the permittee shall conduct, concurrent with toxicity testing, chemical specific analyses for the identified and/or suspected pollutant {s) andior source (s) of effluent toxicity. Where lethality was demonstrated within 24 hours of test initiation, each composite sample shall be analyzed independently.
| |
| Otherwise the permittee may substitute a composite sample, A-39
| |
| | |
| Part II Page 23 of 24 Permit No. LA0007374 AI No. 35260 OTHE~ REQUIREMENTS (continued) comprised of equal portions of the individual composite samples, for the chemical specific analysis; iii. Quality Assurance Plan (e.g., QA/QC implementation, corrective actions, etc.); and iv. Project Organization (e.g., project staff, project manager, consulting services, etc.).
| |
| : b. The permittee shall initiate the TRE Action Plan within thirty (30) days of plan and schedule submittal. The permittee shall assume all risks for failure to achieve the required toxicity reduction.
| |
| : c. The permittee shall submit a quarterly TRE Activities Report, with the Discharge Monitoring Report in the months of January, April, July and October, containing information on toxicity reduction evaluation activities including:
| |
| : i. any data and/or substantiating documentation which identify the pollutant(s) and/or source(s) of effluent toxicity; ii. any studies/evaluations and results on the treatability of the facility's effluent toxicity; and iii. any data which identify effluent toxicity control mechanisms that will reduce effluent toxicity to the level necessary to achieve compliance with permit biomonitoring requirements and/or chemical-specific limits.
| |
| The TRE Activities Report shall be submitted to the following addresses:
| |
| Department of Environmental Quality Office of Environmental Compliance Enforcement Division P.O. Box 4312 Baton Rouge, Louisiana 70821-4312 Attn: Permit Compliance Unit U.S. Environmental Protection Agency, Region 6 Water Enforcement Branch, 6 EN-WC 1445 Ross Avenue Dallas, Texas 75202
| |
| : d. The permittee shall submit a Final Report on Toxicity Reduction Evaluation Activities no later than twenty-eight (28) months from confirming lethality in the retests, which provides information pertaining to the specific control mechanism selected that will, when implemented, result in the permittee achieving compliance with permit biomonitoring requirements and/or chemical-specific limits.
| |
| The report will also provide a specific corrective action schedule for implementing the selected control mechanism.
| |
| A-40
| |
| | |
| Part II Page 24 of 24 Permit No. LA0007374 AI No. 35260 OTHER REQUIREMENTS (continued)
| |
| A copy of the Final Report on Toxicity Reduction Evaluation Activities shall also be submitted to the above addresses.
| |
| : e. Quarterly testing during the TRE is a minimum monitoring requirement. LDEQ recommends that permittees required to perform a TR~ not rely on quarterly testing alone to ensure success in the TRE, and that additional screening tests be performed to capture toxic samples for identification of toxicants. At the end of the TRE, LDEQ will consider all information submitted and establish appropriate controls to prevent future toxic discharges, including WET and/or chemical-specific Limits per state regulations at LAC 33:IX.2707.D.l.e.
| |
| A-41
| |
| | |
| TABLE l
| |
| | |
| ==SUMMARY==
| |
| SHEET Daphnia pulex ACUTE SURVIVAL TEST RESULTS PERMITTEE: Entergy Ooerations, Inc.
| |
| FACILITY SITE: Waterford 3 Steam Electric Station LPDES'PERMIT NUMBER: LA0007374, 35260 OUTFALL IDENTIFICATION:_~O~O~l_ _ _ _ _ _ _ _ _ __
| |
| OUTFALL SAMPLE IS FROM _ _ __ SINGLE - - - - MULTIPLE DISCHARGES BIOMONITORING LABORATORY:
| |
| DILUTION WATER USED: RECEIVING WATER LAB WATER CRITICAL DILUTION 31% DATE TEST INITIATED_ _ _ _ _ __
| |
| : l. LOW-FLOW LETHALITY:
| |
| Is the mean survival at 48 hours significantly less ip=0.05) than the control survival for the low flow or critical dilution?
| |
| _ _ _ _ yes no
| |
| ----
| |
| DILUTION SERIES RESULTS-DAPHNIA TIME OF REP 0% 13% 18% 24% 31% 42%
| |
| READING A
| |
| 24-HOUR B c
| |
| D E
| |
| A 48-HOUR B c
| |
| D E
| |
| MEAN
| |
| : 2. Are the test results to be considered valid? _ _ yes no I f _X__ no (test invalid), what are the reasons for invalidity?
| |
| : 3. Is this a retest of a previous invalid test? yes no Is this a retest of a previous test failure? yes _ _ no
| |
| : 4. Enter percent effluent corresponding to each NOEC (No Observed Effect Concentration) for Daphnia pulex:
| |
| NOEC % effluent LC~48 % effluent A-42
| |
| | |
| TABLE 1
| |
| | |
| ==SUMMARY==
| |
| SHEET Pimephales promelas ACUTE SURVIVAL TEST RESULTS PERMITTEE: Entergy Ooerations, Inc.
| |
| FACILITY SITE: Waterford 3 Steam E1ectric Station LPDES PERMIT NUMBER: LA0007374, 35260 OUTFALL IDENTIFICATION:_~O~O~l----------~
| |
| OUTFALL SAMPLE IS FROM _ _ __ SINGLE MULTIPLE DISCHARGES BIOMONITORING LABORATORY:
| |
| --------------------~
| |
| DILUTION WATER USED: RECEIVING WP..TER - - -LAB WATER CRITICAL DILUTION _llL DATE TEST INITIATED
| |
| : 1. LOW-FLOW LETHALITY:
| |
| Is the mean survival at 48 hours significantly less (p=0.05) than the control survival for the low flow or critical dilution?
| |
| _ _ _ _ yes no DILUTION SERIES RESULTS-PIMEPHALES TIME OF REP 0% 13% 18% 24% 31% 42%
| |
| READING A
| |
| 24-HOUR B c
| |
| D E
| |
| A 48-HOUR B c
| |
| D E
| |
| MEAN
| |
| : 2. Are the test results to be considered valid? _ _ yes no If __X_no (test .invalid), what are the reasons for invalidity?
| |
| : 3. Is this a retest of a previous invalid test? yes _ _ no Is this a retest of a previous test failure? yes no
| |
| : 4. Enter percent effluent corresponding to each NOEC (No Observed Effect Concentration) for Pimeohales:
| |
| NOEC % effluent
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| % effluent A-43
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| | |
| REVISED 06-23-10 Page 1 of 18 PARTlll STANDARD CONDITIONS FOR LPDES PERMITS SECTION A GENERAL CONDITIONS
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| : 1. Introduction In accordance with the provisions of LAC 33:1X.2701, et seq., this permit incorporates either expressly or by reference ALL conditions and requirements applicable to the Louisiana Pollutant Discharge Elimination System Permits (LPDES) set forth in the Louisiana Environmental Quality Act (LEQA). as amended, as well as ALL applicable regulations.
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| : 2. Duty to Comply The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of the Clean Water Act (CWA) and the Louisiana Environmental Quality Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application.
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| : 3. Penalties for Violation of Permit Conditions
| |
| : a. La. R. S. 30:2025 provides for civil penalties for violations of these regulations and the Louisiana Environmental Quality Act. La. R. S. 30:2076.2 provides for criminal penalties for violation of any provisions of the LPDES or any order or any permit condition or limitation issued under or implementing any provisions of the LPDES program. (See Section E. Penalties for Violation of Permit Conditions for additional details).
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| : b. Any person may be assessed an administrative penalty by the State Administrative Authority under La.
| |
| R. S. 30:2025 for violating a permit condition or limitation implementing any of the requirements of the LPDES program in a permit issued under the regulations or the Louisiana Environmental Quality Act.
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| : 4. Toxic Pollutants
| |
| : a. Other effluent limitations and standards under Sections 301, 302, 303, 307, 318, and 405 of the Clean Water Act. If any applicable toxic effluent standard or prohibition (including any schedule of compliance specified in such effluent standard or prohibition) is promulgated under Section 307(a) of the Clean Water Act for a toxic pollutant and that standard or prohibition is more stringent than any limitation on the pollutant in this permit, the state administrative authority shall institute proceedings under these regulations to inodify or revoke and reissue the permit to conform to the toxic effluent standard or prohibition.
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| : b. The permittee shall comply with effluent standards or prohibitions established under Section 307(a) of the Clean Water Act for toxic pollutants and with standards for sewage sludge use or disposal established under Section 405(d) of the Clean Water Act within the time provided in the regulations that establish these standards or prohibitions, or standards for sewage sludge use or disposal, even if the permit has not yet been modified to incorporate the requirement.
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| : 5. Duty to Reapply
| |
| : a. Individual Permits. If the permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the permittee must apply for and obtain a new permit. The new application shall be submitted at least 180 days before the expiration date of the existing permit, unless permission for a later date has been granted by the state administrative authority. (The state administrative authority shall not grant permission for applications to be submitted later than the expiration date of the existing permit.) Continuation of expiring permits shall be governed by regulations promulgated at LAC 33:1X.2321 and any subsequent amendments.
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| form_7027 _r07 6-23-10 A-44
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| | |
| REVISED 06-23-10 Page 2 of 18
| |
| : b. General Permits. General permits expire five years after the effective date. The 180-day reapplication period as defined above is not applicable to general permit authorizations. Reissued general permits may provide automatic coverage for permittees authorized under the previous version of the permit, and no new application is required. Requirements for obtaining authorization under the reissued general permit will be outlined in Part I of the new permit. Permittees authorized to discharge under an expiring general permit should follow the requirements for obtaining coverage under the new general permit to maintain discharge authorization.
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| : 6. Permit Action This permit may be modified, revoked and reissued, or terminated for cause in accordance with LAC 33:1X.2903, 2905, 2907, 3105 and 6509. The causes may include, but are not limited to, the following:
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| : a. Noncompliance by the permittee with any condition of the permit;
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| : b. The permittee's failure in the application or during the permit issuance process to disclose fully all relevant facts, or the permittee's misrepresentation of any relevant facts at any time; or
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| : c. A determination that the permitted activity endangers human health or the environment and can only be regulated to acceptable levels by permit modification or termination;
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| : d. A change in any condition that requires either a temporary or a permanent reduction or elimination of any discharge;
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| : e. Failure to pay applicable fees under the provisions of LAC 33: IX. Chapter 13;
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| : f. Change of ownership or operational control.
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| The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes or anticipated noncompliance does not stay any permit condition.
| |
| : 7. Property Rights This permit does not convey any property rights of any sort, or any exclusive privilege.
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| : 8. Dutv to Provide Information The permittee shall furnish to the state administrative authority, within a reasonable time, any information which the state administrative authority may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. The permittee shall also furnish to the state administrative authority, upon request, copies of records required to be kept by this permit.
| |
| : 9. Criminal and Civil Liability Except as provided in permit conditions on "Bypassing" and "Upsets", nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance. Any false or materially misleading representation or concealment of information required to be reported by the provisions of the permit, the Act, or applicable regulations, which avoids or effectively defeats the regulatory purpose of the Permit may subject the Permittee to criminal enforcement pursuant to La. R.S. 30:2025.
| |
| : 10. Oil and Hazardous Substance Liability Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject under Section 311 of the Clean Water Act.
| |
| : 11. State Laws Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties established pursuant to any applicable State law or regulation under authority preserved by Section 51 O of the Clean Water Act.
| |
| form_7027_r07 6-23-10 A-45
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| | |
| REVISED 06-23-10 Page 3 of 18
| |
| : 12. Severability If any provision of these rules and regulations, or the application thereof, is held to be invalid, the remaining provisions of these rules and regulations shall not be affected, so long as they can be given effect without the invalid provision. To this end, the provisions of these rules and regulations are declared to be severable.
| |
| : 13. Dilution A permittee shall not achieve any effluent concentration by dilution unless specifically authorized in the permit. A permittee shall not increase the use of process water or cooling water or otherwise attempt to dilute a discharge as a partial or complete substitute for adequate treatment to achieve permit limitations or water quality.
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| : 14. Facilities Requiring Approval from Other State Agencies In accordance with La. R.S.40.4(A)(6) the plans and specifications of all sanitary sewerage treatment systems, both public and private, must be approved by the Department of Health and Hospitals state health officer or his designee. It is unlawful for any person, firm, or corporation, both municipal and private to operate a sanitary sewage treatment facility without proper authorization from the state health officer.
| |
| In accordance with La. R.S.40.1149, it is unlawful for any person, firm or corporation, both municipal and private, operating a sewerage system to operate that system unless the competency of the operator is duly certified by the Department of Health and Hospitals state health officer. Furthermore, it is unlawful for any person to perform the duties of an operator without being duly certified.
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| In accordance with La. R.S.48.385, it is unlawful for any industrial wastes, sewage, septic tanks effluent, or any noxious or harmful matter, solid, liquid or gaseous to be discharged into the side or cross ditches or placed upon the rights-of-ways of state highways without the prior written consent of the Department of Transportation and Development chief engineer or his duly authorized representative and of the secretary of the Department of Health and Hospitals.
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| SECTION B. PROPER OPERATION AND MAINTENANCE
| |
| : 1. Need to Halt or Reduce not a Defense It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.
| |
| : 2. Duty to Mitigate The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment. The permittee shall also take all reasonable steps to minimize or correct any adverse impact on the environment resulting from noncompliance with the permit, including such accelerated or additional monitoring as necessary to determine the nature and impact of the noncomplying discharge.
| |
| : 3. Proper Operation and Maintenance
| |
| : a. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit.
| |
| : b. The permittee shall provide an adequate operating staff which is duly qualified to carry out operation, maintenance and other functions necessary to ensure compliance with the conditions of this permit.
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| form_7027 _r07 6-23-10 A-46
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| | |
| REVISED 06-23-10 Page 4of18
| |
| : 4. Bypass of Treatment Facilities
| |
| : a. Bvpass. The intentional diversion of waste streams from any portion of a treatment facility.
| |
| : b. Bypass not exceeding limitations. The permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the provisions of Section B.4.c. and 4.d of these standard conditions.
| |
| : c. Notice (1) Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit prior notice to the Office of Environmental Services, Water Permits Division, if possible at least ten days before the date of the bypass.
| |
| (2) Unanticipated bypass. The permittee shall submit notice of an unanticipated bypass as required in LAC 33:1X.2701.L.6 (24-hour notice) and Section D.6.e. of these standard conditions.
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| : d. Prohibition of bypass (1) Bypass is prohibited, and the state administrative authority may take enforcement action against a permittee for bypass, unless:
| |
| (a) Bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; (b) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal periods of equipment downtime. This condition is not satisfied if adequate back-up equipment should have been installed in the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal periods of equipment downtime or preventive maintenance; and, (c) The permittee submitted notices as required by Section B.4.c of these standard conditions.
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| (2) The state administrative authority may approve an anticipated bypass after considering its adverse effects, if the state administrative authority determines that it will meet the three conditions listed in Section B.4.d(1) of these standard conditions.
| |
| : 5. Upset Conditions
| |
| : a. Upset An exceptional incident in which there is unintentional and temporary noncompliance with technology-based permit effluent limitations because of factors beyond the reasonable control of the permittee. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation.
| |
| : b. Effect of an upset. An upset constitutes an affirmative defense to an action brought for noncompliance witli such technology-based permit effluent limitations if the requirements of Section B.5.c. are met. No determination made during administrative review of claims that noncompliance was caused by an upset, and before an action for noncompliance, is final administrative action subject to judicial review.
| |
| : c. Conditions necessary for a demonstration of upset. A permittee who wishes to establish the affirmative defense of upset shall demonstrate, through property signed, contemporaneous operating logs, or other relevant evidence that (1) An upset occurred and that the permittee can identify the cause(s) of the upset; (2) The permitted facility was at the time being properly operated; and (3) The permittee submitted notice of the upset as required by LAC 33:1X.2701.L.6.b.ii. and Section 0.6.e.(2) of these standard conditions; and form_7027_r07 6-23-10 A-47
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| | |
| REVISED 06-23-10 Page 5of18 (4) The permittee complied with any remedial measures required by Section 8.2 of these standard conditions.
| |
| : d. Burden of proof. In any enforcement proceeding, the permittee seeking to establish the occurrence of an upset has the burden of proof.
| |
| : 6. Removed Substances Solids, sewage sludges, filter backwash, or other pollutants removed in the course of treatment or wastewater control shall be properly disposed of in a manner such as to prevent any pollutant from such materials from entering waters of the state and in accordance with environmental regulations.
| |
| : 7. Percent Removal For publicly owned treatment works, the 30-day average percent removal for Biochemical Oxygen Demand and Total Suspended Solids shall not be less than 85 percent in accordance with LAC 33:1X.5905.A.3. and B.3. Publicly owned treatment works utilizing waste stabilization ponds/oxidation ponds are not subject to the 85 percent removal rate for Total Suspended Solids.
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| SECTION C. MONITORING AND RECORDS
| |
| : 1. Inspection and Entry The permittee shall allow the state administrative authority or an authorized representative (including an authorized contractor acting as a representative.of the Administrator), upon the presentation of credentials and other documents as may be required by the law to:
| |
| : a. Enter upon the permittee's premises where a regulated facility or activity is located. or conducted, or where records must be kept under the conditions of this permit.
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| Enter upon the permittee's premises where a discharge source is or might be located or in which monitoring equipment or records required by a permit are kept for inspection or sampling purposes.
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| Most inspections will be unannounced and should be allowed to begin immediately, but in no case shall begin more than thirty (30) minutes after the time the inspector presents his/her credentials and announces the purpose(s) of the inspection. Delay in excess of thirty (30) minutes shall constitute a violation of this permit. However, additional time can be granted if the inspector or the Administrative Authority determines that the circumstances warrant such action; and
| |
| : b. Have access to and copy, at reasonable times, any records that the department or its authorized representative determines are necessary for the enforcement of this permit. For records maintained in either a central or private office that is open only during normal office hours and is closed at the time of inspection, the records' shall be made available as soon as the office is open, but in no case later than the close of business the next working day;
| |
| : c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment),
| |
| practices, or operations regulated or required under this permit; and
| |
| : d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise authorized by the Clean Water Act or the Louisiana Environmental Quality Act, any substances or parameters at any location.
| |
| : e. Sample Collection (1) When the inspector announces that samples will be collected, the permittee will be given an additional thirty (30) minutes to prepare containers in order to collect duplicates. If the permittee cannot obtain and prepare sample containers within this time, he is considered to have waived his right to collect duplicate samples and the sampling will proceed immediately. Further delay on the part of the permittee in allowing initiation of the sampling will constitute a violation of this permit.
| |
| (2) At the discretion of the administrative authority, sample collection shall proceed immediately (without the additional 30 minutes described in Section C.1.a. above) and the inspector shall supply the permittee with a duplicate sample.
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| form_7027_r07 6-23-10 A-48
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| | |
| REVISED 06-23-10 Page 6of18
| |
| : f. It shall be the responsibility of the permittee to ensure that a facility representative familiar with provisions of its wastewater discharge permit, including any other conditions or limitations, be available either by phone or in person at the facility during all hours of operation. The absence of such personnel on-site who are familiar with the permit shall not be grounds for delaying the initiation of an inspection except in situations as described in Section C.1.b. of these standard conditions. The permittee shall be responsible for providing witnesses/escorts during inspections. Inspectors shall abide by all company safety rules and shall be equipped with standard safety equipment (hard hat, safety shoes, safety glasses) normally required by industrial facilities.
| |
| : g. Upon written request copies of field notes, drawings, etc., taken by department personnel during an inspection shall be provided to the permittee after the final inspection report has been completed.
| |
| : 2. Representative Sampling Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity. All samples shall be taken at the outfall location(s) indicated in the permit. The state administrative authority shall be notified prior to any changes in the outfall location(s). Any changes in the outfall location(s) may be subject to modification, revocation and reissuance in accordance with LAC 33:1X.2903.
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| : 3. Retention of Records Except for records of monitoring information required by this permit related to the perrnittee's sewage sludge use and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR 503), the permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, for a period of at least 3 years from the date of the sample, measurement, report, or application. This period may be extended by request of the state administrative authority at any time.
| |
| : 4. Record Contents Records of monitoring information shall include:
| |
| : a. The date, exact place, and time of sampling or measurements;
| |
| : b. The individual(s) who performed the sampling or measurements;
| |
| : c. The date(s) analyses were performed;
| |
| : d. The time(s) analyses were begun;
| |
| : e. The individual(s) who performed the analyses;
| |
| : f. The analytical techniques or methods used;
| |
| : g. The results of such analyses; and
| |
| : h. The results of all quality control procedures.
| |
| : 5. Monitoring Procedures
| |
| : a. Monitoring results must be conducted according to test procedures approved under 40 CFR Part 136 or, in the case of sludge use or disposal, approved under 40 CFR Part 136 unless otherwise specified in 40 CFR Part 503, unless other test procedures have been specified in this permit.
| |
| : b. The permittee shall calibrate and perform maintenance procedures on all monitoring and analytical instruments at intervals frequent enough to insure accuracy of measurements and shall maintain appropriate records of such activities.
| |
| : c. The permittee or designated laboratory shall have an adequate analytical quality assurance/quality control program to produce defensible data of known precision and accuracy. All quality control measures shall be assessed and evaluated on an on-going basis and quality control acceptance criteria shall be used to determine the validity of the data. All method specific quality control as prescribed in the method shall be followed. If quality control requirements are not included in the method, the permittee or designated laboratory shall follow the quality control requirements as prescribed in the Approved Edition (40 CFR Part 136) Standard Methods for the Examination of Water and Wastes, form_7027_r07 6-23-10 A-49
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| | |
| REVISED 06-23-10 Page 7of18 Sections 1020A and 10208. General sampling protocol shall follow guidelines established in the "Handbook for Sampling and Sample Preservation of Water and Wastewater, 1982 "U.S. Environmental Protection Agency. This publication is available from the National Technical Information Service (NTIS),
| |
| Springfield, VA 22161, Phone number (800) 553-6847. Order by NTIS publication number PB 124503.
| |
| : 6. Flow Measurements Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The devices shall be installed, calibrated, and maintained to insure that the accuracy of the measurements is consistent with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a maximum deviation of less than 10% from true discharge rates throughout the range of expected discharge volumes. Guidance in selection, installation, calibration and operation of acceptable flow measurement devices can be obtained from the following references:
| |
| : a. "A Guide to Methods and Standards for the Measurement of Water Flow, 1975," U.S. Department of Commerce, National Bureau of Standards. This publication is available from the National Technical Information Service (NTIS), Springfield, VA 22161, Phone number (800) 553-6847. Order by NTIS publication number COM-75-10683.
| |
| : b. "Flow Measurement in Open Channels and Closed Conduits, Volumes 1 and 2," U.S. Department of Commerce, National Bureau of Standards. This publication is available from the National Technical Service (NTIS), Springfield, VA, 22161, Phone number (800) 553-6847. Order by NTIS publication number PB-273 535.
| |
| : c. "NPDES Compliance Flow Measurement Manual," U.S. Environmental Protection Agency, Office of Water Enforcement. This publication is available from the National Technical Information Service (NTIS), Springfield, VA-22161, Phone number (800) 553-6847. Order by NTIS publication number PB-82-131178.
| |
| : 7. Prohibition for Tampering: Penalties
| |
| : a. La. R.S. 30:2025 provides for punishment of any person who fe1lsifies, tampers with, or knowingly renders inaccurate any monitoring device or method required to be maintained under this permit.
| |
| : b. La. R.S. 30:2076.2 provides for penalties for any person who knowingly makes any false statement, representation, or certification in any record or other document submitted or required to be maintained under this permit, including monitoring reports or reports of compliance or non-compliance.
| |
| : 8. Additional Monitoring by the Permittee If the Permittee monitors any pollutant more frequently than required by the permit using test procedures approved under 40 CFR Part 136 (See LAC 33:1X.4901) or, in the case of sludge use and disposal, approved under 40 CFR Part 136 (See LAC 33:1X.4901) unless otherwise specified in 40 CFR Part 503, or as specified in the permit, the results of this monitoring shall be included in the calculation and reporting of the data submitted in the DMR or sludge reporting form specified by the state administrative authority.
| |
| : 9. Averaging of Measurements Calculations for all limitations which require averaging of measurements shall utilize an arithmetic mean unless otherwise specified by the state administrative authority in the permit.
| |
| 1O. Laboratory Accreditation
| |
| : a. LAC 33:1.Subpart 3, Chapters 45-59 provide requirements for an accreditation program specifically applicable to commercial laboratories, wherever located, that provide chemical analyses, analytical results, or other test data to the department, by contract or by agreement, and the data is:
| |
| (1) Submitted on behalf of any facility, as defined in La. R.S.30:2004; (2) Required as part of any permit application; (3) Required by order of the department; (4) Required to be included on any monitoring reports submitted to the department; forrn_7027 _r07 6-23-10 A-50
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| | |
| REVISED 06-23-10 Page 8 of 18 (5) Required to be submitted by contractor (6) Otherwise required by department regulations.
| |
| : b. The department laboratory accreditation program, Louisiana Environmental Laboratory Accreditation Program (LELAP) is designed to ensure the accuracy, precision, and reliability of the data generated, as well as the use of department-approved methodologies in generation of that data. Laboratory data generated by commercial environmental laboratories that are not (LELAP) accredited will not be accepted by the department. Retesting of analysis will be required by an accredited commercial laboratory.
| |
| Where retesting of effluent is not possible (i.e. data reported on DMRs for prior month's sampling), the data generated will be considered invalid and in violation of the LPDES permit.
| |
| : c. Regulations on the Louisiana Environmental Laboratory Accreditation Program and a list of labs that have applied for accreditation are available on the department website located under DIVISIONS 7 PERMIT SUPPORT SERVICES 7 LABORATORY ACCREDITATION at the following link:
| |
| http://www.deq.louisiana.gov Questions concerning the program may be directed to (225) 219-9800.
| |
| SECTION D. REPORTING REQUIREMENTS
| |
| ,,;' 1. Facility Changes The permittee shall give notice to the state administrative authority as soon as possible of any planned physical alterations or additions to the permitted facility. Notice is required only when:
| |
| : a. The alteration or addition to a permitted facility may meet one of the criteria for determining whether a facility is a new source in 40 CFR 122.29(b); or
| |
| : b. The alteration or addition could significantly change the nature or increase the quantity of pollutants discharged. This notification applies to pollutants which are subject neither to effluent limitations in the permit, nor to notification requirements under LAC 33: IX.2703.A.1.
| |
| : c. For Municipal Permits. Any new introduction of pollutants into the POTW from an indirect discharger which would be subject to Section 301, or 306 of the CWA if it were directly discharging those pollutants; and any substantial change in the volume or character of pollutants being introduced into that POTW by a source introducing pollutants into the POTW at the time of issuance of the permit. In no case are any new connections, increased flows, or significant changes in influent quality permitted that will cause violation of the effluent limitations specified herein.
| |
| : 2. Anticipated Noncompliance The permittee shall give advance notice to the state administrative authority of any planned changes in the permitted facility or activity which may result in noncompliance with permit requirements.
| |
| : 3. Transfers This permit is not transferable to any person except after notice to the state administrative authority. The state administrative authority may require modification or revocation and reissuance of the permit to change the name of the permittee and incorporate such other requirements as may be necessary under the Clean Water Act or the Louisiana Environmental Quality Act. (See LAC 33:1X.2901; in some cases, modification or revocation and reissuance is mandatory.)
| |
| A permit may be transferred by the permittee to a new owner or operator only if: (1 )the permit has been modified or revoked and reissued (under LAC 33:1X.2903.A.2.b) by the permittee and new owner submitting a Name/Ownership/Operator Change Form (NOC-1 Form) and approved by LDEQ (LAC 33:1.Chapter 19);
| |
| or (2) a minor modification made (under LAC 33:1X.2905) to identify the new permittee and incorporate such form_7027 _r07 6-23-10 A-51
| |
| | |
| REVISED 06-23-10 Page 9of18 other requirements as may be necessary under the Clean Water Act and the Louisiana Environmental Quality Act.
| |
| The NOC-1 form can be found at the following link:
| |
| http://www. deg. louisiana.gov/portal/Portals/O/assistance/NOC-1 %20FORM%20Jan%2025, %202006.pdf
| |
| : 4. Monitoring Reports Monitoring results shall be reported at the intervals and in the form specified in Part I or Part II of this permit.
| |
| The permittee shall submit properly completed Discharge Monitoring Reports (DMRs) on the form specified in the permit. Preprinted DMRs are provided to majors/92-500s and other designated facilities. Please contact the Permit Compliance Unit concerning preprints. Self-generated DMRs must be pre-approved by the Permit Compliance Unit prior to submittal. Self-generated DMRs are approved on an individual basis. Requests for approval of self-generated DMRs should be submitted to:
| |
| Supervisor, Permit Compliance Unit Office of Environmental Compliance Post Office Box 4312 Baton Rouge, LA 70821-4312 Copies of blank DMR templates, plus instructions for completing them, and EPA's LPDES Reporting Handbook are available at the department website located at:
| |
| http://www.deg.louisiana.gov/portal/Default.aspx?tabid=2276
| |
| : 5. Compliance Schedules Reports of compliance or noncompliance with, or any progress reports on, interim and final requirements contained in any compliance schedule of this permit shall be submitted no later than 14 days following each schedule date.
| |
| : 6. Requirements for Notification
| |
| : a. Emergency Notification As required by LAC 33.1.3915, in the event of an unauthorized discharge that does cause an emergency condition, the discharger shall notify the hotline (DPS 24-hour Louisiana Emergency Hazardous Materials Hotline) by telephone at (225) 925-6595 (collect calls accepted 24 hours a day) immediately (a reasonable period of time after taking prompt measures to determine the nature, quantity, and potential off-site impact of a release, considering the exigency of the circumstances), but in no case later than one hour after learning of the discharge. (An emergency condition is any condition which could reasonably be expected to endanger the health and safety of the public, cause significant adverse impact to the land, water, or air environment, or cause severe damage to property.) Notification required by this section will be made regardless of the amount of discharge. Prompt Notification Procedures are listed in Section D.6.c. of these standard conditions.
| |
| A written report shall be provided within seven calendar days after the notification. The report shall contain the information listed in Section D.6.d. of these standard conditions and any additional information in LAC 33:1.3925.B.
| |
| : b. Prompt Notification As required by LAC 33:1.3917, in the event of an unauthorized discharge that exceeds a reportable quantity specified in LAC 33:1.Subchapter E, but does not cause an emergency condition, the discharger shall promptly notify the department within 24 hours after learning of the discharge. Notification should be made to the Office of Environmental Compliance, Surveillance Division Single Point of Contact (SPOC) in accordance with LAC 33:1.3923.
| |
| form_7027 _r07 6-23-10 A-52
| |
| | |
| REVISED 06-23-10 Page 10of18 In accordance with LAC 33:1.3923, prompt notification shall be provided within a time frame not to exceed 24 hours and shall be given to the Office of Environmental Compliance, Surveillance Division (SPOC) as follows:
| |
| (1) by the Online Incident Reporting screens found at http://www.deq.louisiana.gov/portal/tabid/66/Default.aspx ;or (2) by e-mail utilizing the Incident Report Form and instructions found at http://www.deq.louisiana.gov/portal/tabid/66/Default.aspx;or (3) by telephone at (225) 219-3640 during office hours, or (225) 342-1234 after hours and on weekends and holidays.
| |
| : c. Content of Prompt Notifications. The following guidelines will be utilized as appropriate, based on the conditions and circumstances surrounding any unauthorized discharge, to provide relevant information regarding the nature of the discharge:
| |
| ( 1) the name of the person making the notification and the telephone number where any return calls from response agencies can be placed; (2) the name and location of the facility or site where the unauthorized discharge is imminent or has occurred, using common landmarks. In the event of an incident involving transport, include the name and address of the transporter and generator; (3) the date and time the incident began and ended, or the estimated time of continuation if the discharge is continuing; (4) the extent of any injuries and identification of any known personnel hazards that response agencies may face; (5) the common or scientific chemical name, the U.S. Department of Transportation hazard classification, and the best estimate of amounts of any and all discharged pollutants; (6) a brief description of the incident sufficient to allow response agencies to formulate their level and extent of response activity.
| |
| : d. Written Notification Procedures. Written reports for any unauthorized discharge that requires notification under Section D.6.a. or 6.b., or shall be submitted by the discharger to the Office of Environmental Compliance, Surveillance Division SPOC in accordance with LAC 33:1.3925 within seven calendar days after the notification required by D.6.a_ or 6.b., unless otherwise provided for in a valid permit or other department regulation. Written notification reports shall include, but not be limited to, the following information:
| |
| (1) the name, address, telephone number, Agency Interest (Al) number (number assigned by the department) if applicable, and any other applicable identification numbers of the person, company, or other party who is filing the written report, and specific identification that the report is the written follow-up report required by this section; (2) the time and date of prompt notification, the state official contacted when reporting, the name of person making that notification, and identification of the site or facility, vessel, transport vehicle, or storage area from which the unauthorized discharge occurred; (3) date(s), time(s), and duration of the unauthorized discharge and, if not corrected, the anticipated time it is expected to continue; (4) details of the circumstances (unauthorized discharge description and root cause) and events leading to any unauthorized discharge, including incidents of loss of sources of radiation, and if the release point is subject to a permit:
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| (a) the current permitted limit for the pollutant(s) released;and (b) the permitted release point/outfall ID.
| |
| {5) the common or scientific chemical name of each specific pollutant that was released as the result of an unauthorized discharge, including the CAS number and U.S. Department of Transportation hazard classification, and the best estimate of amounts of any and all released pollutants (total amount of each compound expressed in pounds, including calculations);
| |
| (6) a statement of the actual or probable fate or disposition of the pollutant or source of radiation and what off-site impact resulted; form_7027 _r07 6-23-10 A-53
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| | |
| REVISED 06-23-10 Page 11 of 18 (7) remedial actions taken, or to be taken, to stop unauthorized discharges or to recover pollutants or sources of radiation.
| |
| (8) Written notification reports shall be submitted to the Office of Environmental Compliance, Surveillance Division SPOC by mail or fax. The transmittal envelope and report or fax cover page and report should be clearly marked "UNAUTHORIZED DISCHARGE NOTIFICATION REPORT."
| |
| Written reports (LAC 33:1.3925) should be mailed to:
| |
| Louisiana Department of Environmental Quality Post Office Box 4312 Baton Rouge, LA 70821-4312 ATIENTION: EMERGENCY AND RADIOLOGICAL SERVICES DIVISION- SPOC "UNAUTHORIZED DISCHARGE NOTIFICATION REPORT" The Written Notification Report may also be faxed to the Louisiana Department of Environmental Quality, Office of Environmental Compliance, Emergency and Radiological Services Division at:
| |
| (225)-219-4044.
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| Please see LAC 33:1.3925.B for additional written notification procedures.
| |
| : e. Twenty-four Hour Reporting. The permittee shall report any noncompliance which may endanger human health or the environment. Any information shall be provided orally within 24 hours from the time the permittee becomes aware of the circumstances. A written submission shall also be provided within five days of the time the permittee becomes aware of the circumstances. The written submission shall contain a description of the noncompliance and its cause; the period of noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent recurrence of the noncompliance. The following shall be included as information which must be reported within 24hours:
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| (1) Any unanticipated bypass which exceeds any effluent limitation in the permit (see LAC 33:1X.2701.M.3.b.);
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| (2) Any upset which exceeds any effluent limitation in the permit; (3) Violation of a maximum daily discharge limitation for any of the pollutants listed by the state administrative authority in Part II of the permit to be reported within 24 hours (LAC 33:1X.2707.G.).
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| : 7. Other Noncompliance The permittee shall report all instances of noncompliance not reported under Section 0.4., 5., and 6., at the time monitoring reports are submitted. The reports shall contain the information listed in Section 0.6.e.
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| : 8. Other Information Where the permittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted incorrect information in a permit application or in any report to the state administrative authority, it shall promptly submit such facts or information.
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| : 9. Discharges of Toxic Substances In addition to the reporting requirements under Section D.1-8, all existing manufacturing, commercial, mining, and silvicultural dischargers must notify the Office of Environmental Services, Water Permits Division as soon as they know or have reason to believe:
| |
| : a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of any toxic pollutant:
| |
| : i. listed at LAC 33:1X.7107, Tables II and Ill (excluding Total Phenols) which is not limited in the permit, if that discharge will exceed the highest of the following notification levels:
| |
| (1) One hundred micrograms per liter (100 µg/L);
| |
| (2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micro-grams per liter (500 µg/L) for 2,4 -dinitro-phenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/L) for antimony; form_7027_r07 6-23-10 A-54
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| | |
| REVISED 06-23-10 Page 12 of 18 (3) Five (5) times the maximum concentration value reported for that pollutant in the permit application in accordance with LAC33:1X.2501.G.7; or (4) The level established by the state administrative authority in accordance with LAC 33:1X.2707.F; or ii. which exceeds the reportable quantity levels for pollutants at LAC 33:1. Subchapter E.
| |
| : b. That any activity has occurred or will occur which would result in any discharge, on a non-routine or infrequent basis, of a toxic pollutant:
| |
| : i. listed at LAC 33:1X.7107, Tables II and Ill (excluding Total Phenols) which is not limited in the permit, if that discharge will exceed the highest of the following "notification levels":
| |
| (1) Five hundred micrograms per liter (500 µg/L):
| |
| (2) One milligram per liter (1 mg/L) for antimony; (3) Ten (10) times the maximum concentration value reported for that pollutant in the permit application in accordance with LAC 33:1X.2501.G.7; or (4) The level established by the state administrative authority in accordance with LAC 33:1X.2707.F; or ii. which exceeds the reportable quantity levels for pollutants at LAC 33:1. Subchapter E.
| |
| : 10. Signatory Requirements All applications, reports, or information submitted to the state administrative authority shall be signed and certified.
| |
| : a. All permit applications shall be signed as follows:
| |
| (1) For a corporation - by a responsible corporate officer. For the purpose of this section, a responsible corporate officer means:
| |
| (a) A president, secretary, treasurer, or vice-president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision making functions for the corporation; or, (b) The manager of one or more manufacturing, production, or operating facilities, provided: the manager is authorized to make management decisions that govern the operation of the regulated facility, including having the explicit or implicit duty of making major capital investment recommendations and initiating and directing other comprehensive measures to ensure long term environmental compliance with environmental laws and regulations; the manager can ensure that the necessary systems are established or actions taken to gather complete and accurate information for permit application requirements; and the authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures.
| |
| NOTE: DEQ does not require specific assignments or delegations of authority to responsible corporate officers identified in Section D.10.a(1)(a). The age,ncy will presume that these responsible corporate officers have the requisite authority to sign permit applications unless the corporation has notified the state administrative authority to the contrary. Corporate procedures governing authority to sign permit applications may provide for assignment or delegation to applicable corporate positions under Section 0.1 O.a(1 )(b) rather than to specific individuals.
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| (2) For a partnership or sole proprietorship - by a general partner or the proprietor, respectively; or (3) For a municipality, state, federal, or other public agency - by either a principal executive officer or ranking elected official. For purposes of this section, a principal executive officer of a federal agency includes:
| |
| (a) The chief executive officer of the agency, or (b) A senior executive officer having responsibility for the overall operations of a principal geographic unit of the agency (e.g., Regional Administrators of EPA).
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| form_7027 _r07 6-23-10 A-55
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| | |
| REVISED 06-23-10 Page 13 of 18
| |
| : b. All reports required by permits and other information requested by the state administrative authority shall be signed by a person described in Section D.10.a., or by a duly authorized representative of that person. A person is a duly authorized representative only if:
| |
| (1) The authorization is made in writing by a person described in Section 0.1 O.a. of these standard conditions; (2) The authorization specifies either an individual or a position having responsibility for the overall operation of the regulated facility or activity such as the position of plant manager, operator of a well or a well field, superintendent, position of equivalent responsibility, or an individual or position having overall responsibility for environmental matters for the company, (a duly authorized representative may thus be either a named individual or an individual occupying a named position; and, (3) The written authorization is submitted to the state administrative authority.
| |
| : c. Changes to authorization. If an authorization under Section D.10.b. is no longer accurate because a different individual or position has responsibility for the overall operation of the facility, a new authorization satisfying the requirements of Section D.10.b. must be submitted to the state administrative authority prior to or together with any reports, information, or applications to be signed by an authorized representative.
| |
| : d. Certification. Any person signing a document under Section D.10. a. or b. above, shall make the following certification:
| |
| "I certify under penalty of law that this document and ail attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those *persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."
| |
| : 11. Availability of Reports All recorded information (completed permit application forms, fact sheets, draft permits, or any public document) not classified as confidential information under La. R.S. 30:2030(A) and 30:2074(0) and designated as such in accordance with these regulations (LAC 33:1X.2323 and LAC 33:1X.6503) shall be made available to the public for inspection and copying during normal working hours in accordance with the Public Records Act, La. R.S. 44:1 et seq.
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| Claims of confidentiality for the following will be denied:
| |
| : a. The name and address of any permit applicant or permittee;
| |
| : b. Permit applications, permits, and effluent data.
| |
| : c. Information required by LPDES application forms provided by the state administrative authority under LAC 33:1X.2501 may not be claimed confidential. This includes information submitted on the forms themselves and any attachments used to supply information required by the forms.
| |
| SECTION E. PENALTIES FOR VIOLATIONS OF PERMIT CONDITION
| |
| : 1. Criminal
| |
| : a. Negligent Violations The Louisiana Revised Statutes La. R. S. 30:2076.2 provides that any person who negligently violates any provision of the LPDES, or any order issued by the secretary under the LPDES, or any permit condition or limitation implementing any such provision in a permit issued under the LPDES by the secretary, or any requirement imposed in a pretreatment program approved under the LPDES is subject to a fine of not less than $2,500 nor more than $25,000 per day of violation, or by imprisonment for not more than 1 year, or both. If a conviction of a person is for a violation committed after a first conviction of such person, he shall be subject to a fine of not more than $50,000 per day of violation, or imprisonment of not more than two years, or both.
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| form_7027_r07 6-23-10 A-56
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| | |
| REVISED 06-23-10 Page 14of18
| |
| : b. Knowing Violations The Louisiana Revised Statutes La. R. S. 30:2076.2 provides that any person who knowingly violates any provision of the LPDES, or any permit condition or limitation implementing any such provisions in a permit issued under the LPDES, or any requirement imposed in a pretreatment program approved under the LPDES is subject to a fine of not less than $5,000 nor more than $50,000 per day of violation, or imprisonment for not more than 3 years, or both. If a conviction of a person is for a violation committed after a first conviction of such person, he shall be subject to a fine of not more than $100,000 per day of violation, or imprisonment of not more than six years, or both.
| |
| : c. Knowing Endangerment The Louisiana Revised Statutes La. R. S. 30:2076.2 provides that any person who knowingly violates any provision of the LPDES, or any order issued by the secretary under the LPDES, or any permit condition or limitation implementing any of such provisions in a permit issued under the LPDES by the secretary, and who knows at that time that he thereby places another person in imminent danger of death or serious bodily injury, shall, upon conviction, be subject to a fine of not more than $250,000, or by imprisonment for not more than 15 years, or both. A person which is an organization shall, upon conviction of violating this Paragraph, be subject to a fine of not more than one million dollars. If a conviction of a person is for a violation committed after a first conviction of such person under this Paragraph, the maximum punishment shall be doubled with respect to both fine and imprisonment.
| |
| : d. False Statements The Louisiana Revised Statutes La. R. S. 30:2076.2 provides that any person who knowingly makes any false material statement, representation, or certification in any application, record, report, plan, or other document filed or required to be maintained under the LPDES or who knowingly falsifies, tampers with, or renders inaccurate, any monitoring device or method required to be maintained under the LPDES, shall, upon conviction, be subject to a fine of not more than $10,000, or imprisonment for not more than 2 years, or both. If a conviction of a person is for a violation committed after a first conviction of such person under this Subsection, he shall be subject to a fine of not more than $20,000 per day of violation, or imprisonment of not more than 4 years, or both.
| |
| : 2. Civil Penalties The Louisiana Revised Statutes La. R. S. 30:2025 provides that any person found to be in violation of any requirement of this Subtitle may be liable for a civil penalty, to be assessed by the secretary, an assistant secretary, or the court, of not more than the cost to the state of any response action made necessary by such violation which is not voluntarily paid by the violator, and a penalty of not more than $32,500 for each day of violation. However, when any such violation is done intentionally, willfully, or knowingly, or results in a discharge or disposal which causes irreparable or severe damage to the environment or if the substance discharged is one which endangers human life or health, such person may be liable for an additional penalty of not more than one million dollars.
| |
| (PLEASE NOTE: These penalties are listed in their entirety in Subtitle II of Title 30 of the Louisiana Revised Statutes.)
| |
| SECTION F. DEFINITIONS All definitions contained in Section 502 of the Clean Water Act shall apply to this permit and are incorporated herein by reference. Additional definitions of words or phrases used in this permit are as follows:
| |
| : 1. Clean Water Act (CWA) means the Clean Water Act (formerly referred to as the Federal Water Pollution Control Act or the Federal Water Pollution Control Act Amendments of 1972) Pub.L.92-500, as amended by Pub.L. 95-217, Pub.L. 95-576, Pub.L. 96-483 and Pub.L. 97-117, 33 U.S.C. 1251 et. seq.).
| |
| : 2. Accreditation means the formal recognition by the department of a laboratory's competence wherein specific tests or types of tests can be accurately and successfully performed in compliance with all minimum requirements set forth in the regulations regarding laboratory accreditation.
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| form_7027 _r07 6-23-10 A-57
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| | |
| REVISED 06-23-10 Page 15of18
| |
| : 3. Administrator means the Administrator of the U.S. Environmental Protection Agency, or an authorized representative.
| |
| : 4. Applicable Standards and Limitations means all state, interstate and federal standards and limitations to which a discharge is subject under the Clean Water Act, including, effluent limitations, water quality standards of performance, toxic effluent standards or prohibitions, best management practices, and pretreatment standards under Sections 301, 302, 303, 304, 306, 307, 308 and 403.
| |
| : 5. Applicable water quality standards means all water quality standards to which a discharge is subject under the Clean Water Act.
| |
| : 6. Commercial Laboratory means any laboratory, wherever located, that performs analyses or tests for third parties for a fee or other compensation and provides chemical analyses, analytical results, or other test data to the department. The term commercial laboratory does not include laboratories accredited by the Louisiana Department of Health and Hospitals in accordance with La. R.S.49:1001 et seq.
| |
| : 7. Daily Discharge means the discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the calendar day for purposes of sampling. For pollutants with limitations expressed in temis of mass, the daily discharge is calculated as the total mass of the pollutant discharged over the sampling day. For pollutants with limitations expressed in other units of measurement, the daily discharge is calculated as the average measurement of the pollutant over the sampling day. Daily discharge determination of concentration made using a composite sample shall be the concentration of the composite sample.
| |
| : 8. Daily Maximum discharge limitation means the highest allowable "daily discharge".
| |
| : 9. Director means the U.S. Environmental Protection Agency Regional Administrator, or the state administrative authority, or an authorized representative.
| |
| : 10. Domestic septage means either liquid or solid material removed from a septic tank, cesspool, portable toilet, Type Ill marine sanitation device, or similar treatment works that receives only domestic sewage. Domestic septage does not include liquid or solid material removed from a septic tank, cesspool, or similar treatment works that receives either commercial wastewater or industrial wastewater and does not include grease removed from grease trap at a restaurant.
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| : 11. Domestic sewage means waste and wastewater from humans, or household operations that is discharged to or otherwise enters a treatment works.
| |
| : 12. Environmental Protection Agency or (EPA) means the U.S. Environmental Protection Agency.
| |
| : 13. Grab sample means an individual sample collected over a period of time not exceeding 15 minutes, unless more time is needed to collect an adequate sample, and is representative of the discharge.
| |
| : 14. Industrial user means a nondomestic discharger, as identified in 40 CFR 403, introducing pollutants to a publicly owned treatment works.
| |
| : 15. LEQA means the Louisiana Environmental Quality Act.
| |
| : 16. Louisiana Pollutant Discharge Elimination System (LPDES) means those portions of the Louisiana Environmental Quality Act and the Louisiana Water Control Law and all regulations promulgated under their authority which are deemed equivalent to the National Pollutant Discharge Elimination System (NPOES) under the Clean Water Act in accordance with Section 402 of the Clean Water Act and all applicable federal regulations.
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| forrn_7027_r07 6-23-10 A-58
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| | |
| REVISED 06-23-10 Page 16of18
| |
| : 17. Monthly Average, other than for fecal coliform bacteria, discharge limitations are calculated as the sum of all "daily discharge(s)" measured during a calendar month divided by the number of "daily discharge(s)"
| |
| measured during that month. When the permit establishes monthly average concentration effluent limitations or conditions, and flow is measured as continuous record or with a totalizer, the monthly average concentration means the arithmetic average (weighted by flow) of all "daily discharge(s)" of concentration determined during the calendar month where C = daily discharge concentration, F = daily flow and n =
| |
| number of daily samples; monthly average discharge =
| |
| C1F1 + C2F2 + ... + CnFn F1 + F2 + ... + Fn When the permit establishes monthly average concentration effluent limitations or conditions, and the flow is not measured as a continuous record, then the monthly average concentration means the arithmetic average of all "daily discharge(s)" of concentration determined during the calendar month.
| |
| The monthly average for fecal coliform bacteria is the geometric mean of the values for all effluent samples collected during a calendar month.
| |
| : 18. National Pollutant Discharge Elimination System (NPDES) means the national program for issuing, modifying, revoking and reissuing, terminating, monitoring and enforcing permits, and imposing and enforcing pretreatment requirements, under Sections 307, 318, 402, and 405 of the Clean Water Act.
| |
| : 19. Severe property damage means substantial physical damage to property, damage to the treatment facilities that causes them to become inoperable, or substantial and permanent loss of natural resources that can reasonably be expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused by delays in production.
| |
| : 20. Sewage sludge means any solid, semi-solid, or liquid residue removed during the treatment of municipal wastewater or domestic sewage. Sewage sludge includes, but is not limited to, solids removed during primary, secondary, or advanced wastewater treatment, scum, domestic septage, portable toilet pumpings, Type Ill marine sanitation device pumpings (33 CFR Part 159), and sewage sludge products. Sewage sludge does not include grit or screenings, or ash generated during the incineration of sewage sludge.
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| : 21. Stormwater Runoff-aqueous surface runoff including any soluble or suspended material mobilized by naturally occurring precipitation events.
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| : 22. Surface Water: all lakes, bays, rivers, streams, springs, ponds, impounding reservoirs, wetlands, swamps, marshes, water sources, drainage systems and other surface water, natural or artificial, public or private within the state or under its jurisdiction that are not part of a treatment system allowed by state law, regulation, or permit.
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| : 23. Treatment works means any devices and systems used in the storage, treatment, recycling and reclamation of municipal sewage and industrial wastes of a liquid nature to implement Section 201 of the Clean Water Act, or necessary to recycle or reuse water at the most economical cost over the estimated life of the works, including intercepting sewers, sewage collection systems, pumping, power and other equipment, and their appurtenances. extension, improvement, remodeling, additions, and alterations thereof. (See Part 212 of the Clean Water Act)
| |
| : 24. For fecal coliform bacteria, a sample consists of one effluent grab portion collected during a 24-hour period at peak loads.
| |
| : 25. The term MGD shall mean million gallons per day.
| |
| : 26. The term GPD shall mean gallons per day.
| |
| : 27. The term mg/L shall mean milligrams per liter or parts per million (ppm).
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| form_7027 _r07 6-23-10 A-59
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| | |
| REVISED 06-23-10 Page 17of18
| |
| : 28. The term SPC shall mean Spill Prevention and Control. Plan covering the release of pollutants as defined by the Louisiana Administrative Code (LAC 33:1X.Chapter 9).
| |
| : 29. The term SPCC shall mean Spill Prevention Control and Countermeasures Plan .. Plan covering the release of pollutants as defined in 40 CFR Part 112.
| |
| : 30. The term .b!.9lk shall mean micrograms per liter or parts per billion (ppb).
| |
| : 31. The term ng/L shall mean nanograms per liter or parts per trillion (ppt).
| |
| : 32. Visible Sheen: a silvery or metallic sheen, gloss, or increased reflectivity: visual color; or iridescence on the water surface.
| |
| : 33. Wastewater-liquid waste resulting from commercial, municipal, private, or industrial processes. Wastewater includes, but is not limited to, cooling and condensing waters, sanitary sewage, industrial waste, and contaminated rainwater runoff.
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| * 34. Waters of the State: for the purposes of the Louisiana Pollutant Discharge Elimination system, all surface waters within the state of Louisiana and, on the coastline of Louisiana and the Gulf of Mexico, all surface waters extending there from three miles into the Gulf of Mexico. For purposes of the Louisiana Pollutant Discharge Elimination System, this includes all surface waters which are subject to the ebb and flow of the tide, lakes, rivers, streams, (including intermittent streams), mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, natural ponds, impoundments of waters within the state of Louisiana otherwise defined as "waters of the United States" in 40 CFR 122.2, and tributaries of all such waters.
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| "Waters of the state" does not include waste treatment systems, including treatment ponds or lagoons designed to meet the requirements of the Clean Water Act, 33 U.S.C. 1251 et seq.
| |
| : 35. Weekly average, other than for fecal coliform bacteria, is the highest allowable arithmetic mean of the daily discharges over a calendar week, calculated as the sum of all "daily discharge(s)" measured during a calendar week divided by the number of "daily discharge(s)" measured during that week. When the permit establishes weekly average concentration effluent limitations or conditions, and flow is measured as continuous record or with a totalizer, the weekly average concentration means the arithmetic average (weighted by flow) of all "daily discharge(s)" of concentration determined during the calendar week where C
| |
| = daily discharge concentration, F = daily flow and n = number of daily samples; weekly average discharge C,F, + C2F2 + ... + C0 Fn
| |
| =
| |
| F,+Fz+ ... +Fn When the permit establishes weekly average concentration effluent limitations or conditions, and the flow is not measured as a continuous record, then the weekly average concentration means the arithmetic average of all "daily discharge(s)" of concentration determined during the calendar week.
| |
| The weekly average for fecal coliform bacteria is the geometric mean of the values for all effluent samples collected during a calendar week.
| |
| : 36. Sanitary Wastewater Term(s):
| |
| : a. 3-hour composite sample consists of three effluent portions collected no closer together than one hour (with the first portion collected no earlier than 10:00 a.m.) over the 3-hour period and composited according to flow, or*a sample continuously collected in proportion to flow over the 3-hour period.
| |
| : b. 6-hour composite sample consists of six effluent portions collected no closer together than one hour (with the first portion collected no earlier than 10:00 a.m.) over the 6-hour period and composited according to flow, or a sample continuously collected in proportion to flow over the 6-hour period.
| |
| form_7027 _r07 6-23-10 A-60
| |
| | |
| REVISED 06-23-10 Page 18of18 c.12-hour composite sample consists of 12 effluent portions collected no closer together than one hour over the 12-hour period and composited according to flow, or a sample continuously collected in proportion to flow over the 12-hour period. The daily sampling intervals shall include the highest flow periods.
| |
| : d. 24-hour composite sample consists of a minimum of 12 effluent portions collected at equal time intervals over the 24-hour period and combined proportional to flow or a sample continuously collected in proportion to flow over the 24-hour period.
| |
| form_7027_r07 6-23-10 A-61
| |
| | |
| LPDES PERMIT NO. LA0007374, AI No. 35260 LPDES FACT SHEET and RATIONALE ADDENDUM FOR THE DRAFT LOUISIANA POLLUTANT DISCHARGE ELIMINATION SYSTEM (LPDES} PERMIT TO DISCHA..~GE TO WATERS OF LOUISIANA
| |
| : 1. Company/Facility Name: Entergy Operations, Inc.
| |
| Waterford 3 Steam Electric Station 17265 River Road Killona, Louisiana 70057
| |
| : 2. Issuing Office: Louisiana Department of Environmental Quality (LDEQ)
| |
| Office of Environmental Services Post Office Box 4313 Baton Rouge, Louisiana 70821-4313
| |
| : 3. Prepared By: Michelle Bickham Industrial Permits Section Water Permits Division Phone #: 225-219-3082 Date Prepared: August 24, 2010
| |
| : 4. Permit Action/Status:
| |
| A. Reason For Permit Action:
| |
| A meeting was held on August 10, 2010, to discuss the 316(b) requirements in the permit. This addendum addresses only those changes made to the 316(b} language in the fact sheet. All other information stated in the original fact sheet remains the same.
| |
| B. LPDES permit - (LA0007374}
| |
| LPDES permit effective date: February 1, 2005 LPDES permit expiration date: January 31, 2010 LPDES permit modification date: January 10, 2008 C. LPDES Draft issued - June 28, 2010. The public notice was published in the Office of Environmental Services Public Notice Mailing List on July 12, 2010, and the ST. CHARLES HERALD-GUIDE of Boutte on July 15, 2010. The comment period ended on August 16, 2010. A request for a meeting was received on August 2, 2010. The meeting was held on August 10, 2010, with Entergy Operations, Inc. and the Water Permits Division. The permit language was changed to reflect the following: ( 1) the requirement to submit information on the assessment of the cooling water system has been removed as this information was submitted on July 10, 2008, as part of the Impingement Mortality and Entrainment Characterization Study; and replaced with a requirement stating that Office may request an update of this information or additional information of the cooling water system if necessary; and (2) the statement that the A-62
| |
| | |
| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 2 repromulgated regulation will supersede any requirements contained in the permit has been removed and replaced with the provision that if EPA repromulgates the Phase II Rule, this permit may be reopened to comply with the repromulgated rule. The fact sheet language from the draft permit has been changed to the following:
| |
| 316(b) PHASE II RULE REQUIREMENTS July 6, 2004, EPA promulgated 'Phase II' regulations in accordance with section 316(b) of the Clean Water Act (CWA). February 2005, LDEQ promulgated 'Phase II' regulations found at LAC 33:IX.Chapter 47.Subchapter B.
| |
| January 25, 2007, the Second U.S. Circuit Court of Appeals remanded several provisions of the Phase II rule.
| |
| March 20, 2007, EPA issued a memo saying, "the rule should be considered suspended" .
| |
| July 9, 2007, Federal Register notice suspending all parts of the Phase II regulations except 40 CFR 125.90(b) [LAC 33:IX.4731.B].
| |
| October 2007, LDEQ suspended LAC 33: IX. Chapter 47. Subchapter B, with the exception of LAC 33:IX.4731.B.
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| According to EPA, 316 (b) 'Phase II' regulations are under complete reconsideration at this time. LAC 33:IX.4731.B provides for regulating the cooling water intake structure (CWIS) for existing facilities on a case-by-case basis using best professional judgment.
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| This facility was issued a number of previous NPDES and/or LPDES permits and has been withdrawing once-through, non-contact cooling water without any identified problems. Based on information evaluated, there have been no past or current impacts identified associated with the withdrawal of the applicable cooling water. The facility is located in the main channel of the Mississippi River at River Mile 129.5 on the west descending bank.
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| The intake structure extends out 162 feet from the bank and is equipped with a skimmer wall as to prevent debris and surface swimming organisms from entering the CWIS. The offshore location of the CWIS minimizes fish and shellfish from entering the system as the conditions of the Mississippi River (i.e., high velocity, increased debris, shifting river bed, lack of habitat/vegetation, and reduction of food source) at the location of the intake structure are not easily tolerated. LDEQ has made the determination that this CWIS represents the best technology available.
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| A permit modification, effective January lO, 2008, required Entergy Operations, Inc. to characterize the fish/shellfish in the vicinity of the CWIS, assess impingement mortality and entrainment (IM&E), and assess the cooling water system. The assessment results were received by LDEQ on July 10, 2008 (EDMS document 37109798).
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| The permittee shall comply with effective regulations promulgated in accordance with section 316 (b) of the CWA for cooling water intake A-63
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 3 structures. Based on any additional evaluation of the assessment results received by LDEQ on July 10, 2008, any new information required to be submitted to LDEQ, or a revision to the regulations, the permit may be reopened to incorporate limitations and/or requirements for the CWIS.
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| ADDITIONAL INFORMATION As stated in Section 9 of the original Fact Sheet, the flow requirement for Outfall 001 was changed from a daily maximum limitation of 1518 MGD to a reporting requirement only in the draft permit. This is consistent with similar outfalls for similar permits. Because flow is not a pollutant as defined by LAC33:IX.2313, anti-backsliding regulations at LAC33:IX.2707.L do not apply.
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| A-64
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| LPDES PERMIT NO. LA0007374, AI No. 35260 LPDES FACT SHEET and RATIONALE FOR THE DRAFT LOUISIANA POLLUTANT DISCHARGE ELIMINATION SYSTEM (LPDES) PERMIT TO DISCHARGE TO WATERS OF LOUISIANA
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| : 1. Company/Facility Name: Entergy Operations, Inc.
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| Waterford 3 Stearn Electric Station 17265 River Road Killona, Louisiana 70057
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| : 2. Issuing Office: Louisiana Department of Environmental Quality (LDEQ)
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| Office of Environmental Services Post Office Box 4313 Baton Rouge, Louisiana 70821-4313
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| : 3. Prepared By: Michelle Bickham Industrial Permits Section Water Permits Division Phone #: 225-219-3082 Date Prepared: April 14, 2010
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| : 4. Permit Action/Status:
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| A. Reason For Permit Action:
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| Proposed reissuance of an expired Louisiana Pollutant Discharge Elimination System (LPDES) permit for a 5-year term following regulations promulgated at LAC 33:IX.2711/40 CFR 122.46.
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| LAC 33:IX Citations: Unless otherwise stated, citations to LAC 33:IX refer to promulgated regulations listed at Louisiana Administrative Code, Title 33, Part IX.
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| B. LPDES permit - LPDES permit effective date: February 1, 2005 LPDES permit expiration date: January 31, 2010 LPDES permit modification date: January 10, 2008 C. Application received on July 30, 2009
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| : 5. Facility Information:
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| A. Location - 17265 River Road, Killona, St. Charles Parish B. Applicant Activity According to the application, Entergy Operations, Inc., Waterford 3 Steam Electric Station is a steam electric generating station that has a maximum electrical generating capacity of 1,104 megawatts (MWe}. The primary fuel source for the unit is enriched Uranium 235.
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| A-65
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 2
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| : c. Technology Basis - LAC33:IX.4903 Guideline Reference Steam Electric Power Generating 40 CFR 423 Point Source Category Other sources of technoloqv based limits:
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| LDEQ Stormwater Guidance, letter dated 6/17/87, from J. Dale Givens (LDEQ) to Myron Knudson (EPA Region 6)
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| LDEQ Sanitary General Permits LDEQ Multi-Sector General Permit for Storm Water Discharges LAROSOOOO Best Professional Judgement D. Fee Rate -
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| : l. Fee Rating Facility Type: major
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| : 2. Complexity Type: V
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| : 3. Wastewater Type: I
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| : 4. SIC code: 4911 E. Continuous Facility Effluent Flow (30-Day Average) - 1005 MGD
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| : 6. Receiving Waters:
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| Mississippi River
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| : 1. TSS {15%), mg/L: 32
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| : 2. Average Hardness, mg/L CaC0 3 : 153.4
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| : 3. Critical Flow, cfs: 141,955
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| : 4. Mixing Zone Fraction: 0.333
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| : 5. Harmonic Mean Flow, cfs: 366,758
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| : 6. River Basin: Mississippi River, Segment No. 070301
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| : 7. Designated Uses:
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| The designated uses are primary contact recreation, secondary contact recreation, fish and wildlife propagation, and drinking water supply.
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| Information based on the following: LAC 33:IX Chapter 11;/Recommendation(s) from the Engineering Section. Hardness and 15% TSS data comes from monitoring station #0319 on the Mississippi River east of Plaquemine at the Plaquemine ferry landing, midstream.
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| {email from Ronnie Bean dated 4/28/10) 40 Ament Canal
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| : 1. River Basin: Barataria Basin, Segment No. 020202
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| : 2. Designated Uses:
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| The designated uses are primary contact recreation, secondary contact recreation, and fish and wildlife propagation.
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| A-66
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric. Station LA0007374, AI No. 35260 Page 3
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| : 7. Outfall Information:
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| Outfall 001 A. Type of wastewater - the continuous discharge of once through non-contact cooling water combined with previously monitored intermittent discharges including but not limited to: steam generator blowdown, cooling tower blowdown, metal cleaning wastewaters, low volume wastewater, and stormwater from Outfalls 101, 201, 301, 401, 501, 601, 701, 801, 901, and 1001 B. Location - at the point of discharge from the circulating water system discharge structure prior to entering the Mississippi River (Latitude 29°59'49", Longitude 90°28'01"). (NOTE: During high river stages when the structure is inaccessible, representative effluent samples are collected at an alternate location between the main condenser and the discharge structure.)
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| : c. Treatment - intake screening, chlorination (when required), LDEQ approved mussel treatment (when required), and addition of dispersant/polymer (when required)
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| D. Flow - 994 MGD (average)
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| E. Receiving waters - Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 Outfall 101 A. Type of wastewater - the intermittent discharge from the liquid waste management system. The liquid waste management system receives low volume wastewater from the following sources, including but not limited to: the turbine and reactor building equipment and' floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423.
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| B. Location at the point of discharge from the liquid waste management system prior to combining with the waters of Outfall 001 (Latitude 29°59'40", Longitude 90°28'16")
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| : c. Treatment filtering/screening, cationic and anionic polymer injection, ion exchange, neuralization/pH adjustmnet (when required) , and distillation (when required)
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| D. Flow - 0.0129 MGD (average)
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| E. Receiving waters - through Outfall 001 thence to the Mississippi River A-67
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| Fact Sheet and Rationale for Entergy Operatior..s, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 4 F. Basin and segment - Mississippi River Basin, Segment 070301 Outfall 201 A. Type of wastewater the intermittent discharge from the boron management system. The boron management system receives low volume wastewater from the following sources, including but not limited to:
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| the turbine and reactor building equipment and floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423 B. Location - at the point of discharge from the boron management system prior to combining with the waters of Outfall 001 (Latitude 29°59'40", Longitude 90°28'16")
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| C. Treatment filtering/screening, ion exchange, neutralization/pH adjustment (when required), distillation (when required)
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| D. Flow - 0.0128 MGD (average)
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| E. Receiving waters - through Outfall 001 thence to the Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 Outfall 301 A. Type of wastewater - the internd ttent discharge of filter flush water from the primary water treatment system. The primary water treatment system filters riverwater for various plant uses. The filters of this system are flushed periodically with untreated river water to remove solids trapped in the filter beds.
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| B. Location at the point of discharge from the primary water treatment system prior to combining with the waters of Outfall 001 (Latitude 29°59'41", Longitude 90°28'20")
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| C. Treatment - filter/screening, separation, polymer injection (when required)
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| D. Flow - O. 0001 MGD (average)
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| E. Receiving waters - through Outfall 001 thence to the Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 A-68
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 5 Outfall 401 A. Type of wastewater - the intermittent discharge of steam generator blowdown and other low volume wastewaters as defined in 40 CFR 423 B. Location - at the point of discharge from the secondary stream plant system prior to combining with the waters of Outfall 001 (Latitude 29°59'41", Longitude 90°28'15")
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| C. Treatment - filtration, ion exchange, neutralization/pH adjustment (when required)
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| D. Flow - 0.042 MGD (average)
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| E. Receiving waters - through Outfall 001 thence to the Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 Outfall 501 A. Type of wastewater the intermittent discharge from Auxiliary Component Cooling Water Basin A. Low volume wastewaters include, but are not limited to: auxiliary component cooling water, component cooling water, Mississippi River water used for flow testing, and stormwater.
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| B. Location at the point of discharge from Auxiliary Component Cooling water Basin A prior to combining with the waters of Outfall 001 (Latitude 29° 59 I 44 II Longitude 90 °28 I 13 n)
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| I C. Treatment sedimentation, neutralization/pH adjustment (when required), side stream ionization (when required), and filtration (when required)
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| D. Flow - 0.26 MGD (average)
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| E. Receiving waters - through Outfall 001 thence to the Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 Outfall 601 l>.. Type of wastewater the intermittent discharge from Auxiliary Component Cooling Water Basin B. Low volume wastewaters include, but are not limited to: auxiliary component cooling water, component A-69
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 6 cooling water, secondary plant water system wastewater, Mississippi River water used for flow testing, and stormwater.
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| B. Location at the point of discharge from Auxiliary Component Cooling Water Basin B prior to combining with the waters of Outfall 001 (Latitude 29°59'44", Longitude 90°28'13")
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| : c. Treatment sedimentation, neµtralization/pH adjustment (when required), side stream ionization (when required), and filtration (when required)
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| D. Flow - 0.26 MGD (average)
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| E. Receiving waters - through Outfall 001 thence to the Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 Outfall 701 A. Type of wastewater - the intermittent discharge of cooling tower blowdown and low volume wastewaters from Dry Cooling Tower Sump #1.
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| Low volume wastewaters include, but are not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater.
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| (NOTE: Optional discharge to plant drainage ditches thence to Outfall 004 may occur during periods when the circulating water system is unavailable.)
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| B. Location - at the point of discharge from the Dry Cooling Tower Sump
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| #1 prior to combining with the waters of Outfall 001 (or Outfall 004) (Latitude 29°59'44", Longitude 90°28'13")
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| : c. Treatment sedimentation, neutralization/pH adjustment (when required), side stream ionization (when required) , filtration (when required)
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| D. Flow - 0.0185 MGD (average)
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| E. Receiving waters - through Outfall 001 thence to the Mississippi River OR through Outfall 004 thence to 40 Arpent Canal F. Basin and segment Mississippi River Basin, Segment 070301 OR Barataria Basin, Segment 020202 A-70
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 7 Outfall 801 A. Type of wastewater - the intermittent discharge of cooling tower blowdown and low volume wastewaters from Dry Cooling Tower Sump #2.
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| Low volume wastewater sources as defined in 40 CFR 423 include, but are not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. (NOTE: Optional discharge to plant drainage ditches thence to Outfall 004 may occur during periods when the circulating water system is unavailable.}
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| B. Location - at the point of discharge from the Dry Cooling Tower Sump
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| #2 prior to combining with the waters of Outfall 001 (or Outfall 004) (Latitude 29°59'44", Longitude 90°28'13")
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| : c. Treatment sedimentation, neutralization/pH adjustment (when required), side stream ionization (when required) , filtration (when required)
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| D. Flow - 0.068 MGD (average)
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| E. Receiving waters - through Outfall 001 thence to the Mississippi River OR through Outfall 004 thence to 40 Arpent Canal F. Basin and segment Mississippi River Basin, Segment 070301 OR Barataria Basin, Segment 020202 Outfall 901 A. Type of wastewater - the mobile intermittent discharge of metal cleaning wastewaters (both chemical and non-chemical} from various plant equipment components including, but not limited to: the steam generator, cooling water heat exchangers, and piping B. Location - at the point of discharge from the mobile cleaning process unit(s} prior to combining with the waters of Outfall 001 C. Treatment - chemical precipitation, neutralization, sedimentation, pre-aeration (when required) , flocculation (when required} , ion exchange (when required)
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| D. Flow - 0.0201 MGD (average}
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| E. Receiving waters - through Outfall 001 thence to the Mississippi River F. Basin and segment - Mississippi River Basin, Segment 070301 A-71
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 8 Outfall 1001 A. Type of wastewater - the intermittent discharge from the yard oil separator system. Wastewater includes auxiliary boiler blowdown, stormwater, and low volume wastewaters from various sources, including plant floor drains and discharge from the industrial waste system as defined in 40 CFR 423. Low volume wastewater sources include, but are not limited to: secondary water system drains, system leakage, auxiliary boiler sumps, turbine building equipment and floor drains, turbine building floor wash downs, and laboratory drains. (NOTE: Optional discharge to Outfall 004 may occur during maintenance periods and during rain events that compromise the capacity of the discharge pumps.)
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| B. Location - at the point of discharge from the yard oil separator system prior to combining with the waters of Outfall 001 (or Outfall 004)* (Latitude 29°59'38", Longitude 90°28'17")
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| C. Treatment - sedimentation, flotation, oil/water separation, polymer injection (when required), neutralization/pH adjustment, (when required), flocculation (when required), filtration (when required)
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| D. Flow - 0.0553 MGD (average)
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| E. Receiving waters - through Outfall 001 thence to the Mississippi River OR through Outfall 004 thence to 40 Arpent Canal F. Basin and segment - Mississippi River Basin, Segment 070301 OR Barataria Basin, Segment 020202 Outfall 004 f... Type of wastewater - the intermittent discharge from the plant drainage ditch system consisting of stormwater, potable water from the fire water system, maintenance wastewaters including, but not limited to: hydrostatic test water, air conditioning condensate, low volume wastewaters including, but not limited to: reverse osmosis reject water and demineralized water. The plant drainage ditch system receives discharges during maintenance from the Dry Cooling Tower Sump #1 (Internal Outfall 701), Dry Cooling Tower Sump #2 (Internal Outfall 801) , and treated discharge from the yard oil separator system, including, but not limited to: plant floor drains and discharge from the industrial waste system (Internal Outfall 1001) -
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| B. Location - at the point of discharge from the stormwater drainage ditch south of the plant laydown area and prior to combining with A-72
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 9 the waters of the 40 Arpent Canal (Latitude 29°59'19", Longitude 90°28'24")
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| : c. Treatment - none D. Flow - 10.3 MGD (average)
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| E. Receiving waters - 40 Arpent Canal thence to Lac Des Allernands F. Basin and segment - Barataria Basin, Segment 020202 Outfall 005 A. Type of wastewater - the intermittent discharge of treated sanitary wastewater and a de minimis discharge from the HVAC unit from the Entergy Energy Education Center B. Location - at the point of discharge from the sewage treatment plant prior to combining with the waters of the 40 Arpent Canal (Latitude 29°58'53", Longitude 90°28'35")
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| C. Treatment - sewage treatment plant with chlorination D. Flow - 0.061 MGD (average)
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| E. Receiving waters - 40 Arpent Canal thence to Lac Des Allemands F. Basin and segment - Barataria Basin, Segment 020202
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| : 8. Previous Effluent Limitations Outfall 001 - the continuous discharge of once through non-contact cooling water, and previously monitored intermittent discharges including but not limited to:
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| steam generator blowdown, cooling tower blowdown, metal cleaning wastewaters, low volume wastewaters, and stormwater Parameter LPDES Monthly Daily Average Maximum Flow - mgd Report 1518 Continuous Continuous Recorder Recorder Temperature Report 118° F Continuous Continuous Recorder Recorder A-73
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 10 Heat (BTU) --- 9.5 x 10 3 J'1BTU/hour Continuous Recorder Total Residual - -- 211 lbs/day Chlorine* 1/week Grab
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| *Samples shall be representative of any periodic episodes of chlornation, biocide usage, or other potentially toxic substance discharged on an intermittent basis.
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| WHOLE EFFLUENT PERCENT %, UNLESS STATED MONITORING TOXICITY TESTING REQUIREMENTS (ACUTE)
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| MONTHLY 48-HOUR MEASUREMENT SAMPLE AVERAGE MINIMUM FREQUENCY TYPE MINIMUM NOEC, Pass/Fail [0/1], Report Report 1/quarter 24-hr.
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| Lethality, Static Composite Renewal, 48-Hour Acute, Pimephales promelas NOEC, Value [%], Report Report 1/quarter 24-hr.
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| Lethality, Static Composite Renewal, 48-Hour Acute, Pimephales promelas NOEC, Value [%] , Report Report 1/quarter . 24-hr.
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| Coefficient of Composite Variation, Static Renewal, 48-Hour Acute, Pimephales promelas NOEC, Pass/Fail [O, 1), Report Report 1/quarter 24-hr.
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| Lethality , Static Composite Renewal, 48-Hour Acute, Dap.'111ia pulex NOEC, Value [%], Report Report l/quarter 24-hr.
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| Lethality, Static Composite Renewal, 48-Hour Acute, Daphnia pulex A-74
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 11 NOEC, Value [%] ' Report Report l/quarter 24-hr.
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| Coefficient of Composite Variation, Static Renewal, 48-Hour Acute, Daphnia pulex There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| Outfall 001, at the point of discharge from the circulating water system discharge structure Outfall 101 - the intermittent discharge from the liquid waste management system to Final Outfall 001 via the turbine condenser cooling system. The liquid waste management system receives low volume wastewater from the following sources, including but not limited to: the turbine and reactor building equipment and floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423 Parameter LPDES Monthly Daily Average Maximum Flow - mgd --- Report l/batch Totalized TSS --- 100 mg/L l/month Grab Oil & Grease 20 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u.
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| l/batch l/batch Grab Grab There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| A-75
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LJl.0007374, AI No. 35260 Page 12 Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| Outfall 101, at the point cf discharge from the liquid waste management system Outfall 201 - the intermittent discharge from the boron management system to Final Outfall 001 via the turbir:e condenser cooling system. The boron management system receives low volume wastewater from the following sources, including but not limited to: the turbine and reactor building equipment and *floor drains, primary plant water makeup, laborator1 drains, and other low volume wastewater sources as defined in 40 CFR 423 Parameter LP DES Monthly Daily Average Maximum Flow - mgd -- - Report l/batch Totalized TSS --- 100 mg/L l/month Grab Oil & Grease 20 mg/L 1/month Grab pH 6.0 s.u. 9.0 s.u.
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| 1/batch l/batch Grab Grab There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| outfall 201, at the point of discharge from the boron management system Outfall 301 - the intermittent discharge of filter flush water from the primary water treatment system A-76
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 13 Parameter LPDES Monthly Daily Average Maximwn Flow - mgd -- - Report Weekly Totalized Clarifying Agents The quantity and types of all clarifying agents (coagulants) used in the primary water treatment system during the sampling month shall be recorded.
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| There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| Outfall 301, at the point of discharge from the primary water treatment system Outfall 401 - the intermittent discharge of steam generator blowdown and other low volume wast.ewaters as defined in 40 CFR 423 Parameter LPDES Monthly Daily Average Maximwn Flow - mgd -- - Report Daily Totalized*
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| TSS --- 100 mg/L
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| .l/week Grab Oil & Grease -- - 20 mg/L l/week Grab pH 6.0 s.u. 9.0 s.u.
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| l/week l/week.
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| Grab Grab
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| *When low volume wastewaters are discharged, the flow must be estimated.
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| There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| A-77
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 14 Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| Outfall 401, at the point of discharge from the secondary steam plant system Outfall 501 - the intermittent discharge from Auxiliary Component Cooling Water Basin A. Low volume wastewater include, but not limited to: auxiliary component cooling water, component cooling water, Mississippi River water used for flow testing, and stormwater Parameter LPDES Monthly Daily Average Maximum Flow - mgd --- Report l/week Estimate TOC --- 50 mg/L l/week Grab TSS* - -- 100 mg/L l/week Grab Oil & Grease --- 20 mg/L l/week Grab pH 6.0 s.u. 9.0 s.u.
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| l/week l/week Grab Grab
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| *During circulating water flow testing, sampling for TSS is not required (when Mississippi River water is used for the flow test) .
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| There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| Outfall 501, at the point of discharge from Auxiliary Component Cooling Water Basin A A-78
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 15 Outfall 601 - the intermittent discharge from Auxiliary Component Cooling Water Basin B. Low volume wastewaters include, but are not limited to: auxiliary component cooling water, component cooling water, secondary plant water system wastewater, Mississippi River water used for flow testing, and stormwater Parameter LPDES Monthly Daily Average Maximum Flow - mgd -- - Report l/week Estimate TOC -- - so mg/L 1/week Grab TSS* -- - 100 mg/L l/week Grab Oil & Grease --- 20 mg/L l/week Grab pH 6.0 s.u. 9.0 s.u.
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| l/week l/week Grab Grab
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| *During circulating water flow testing, sampling for TSS is not required (when Mississippi River water is used for the flow test).
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| There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| Outfall 601, at the point of discharge from Auxiliary Component Cooling Water Basin B Outfall 701 - the intermittent discharge of cooling tower blowdown and low volume wastewaters from Dry Cooling Tower Sump #1. Low volume wastewater as defined in 40 CFR 423 include, but are not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. Optional discharge to Final Outfall 004 via the A-79
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 16 plant drainage ditches may occur during periods when the circulating water system is unavailable Parameter LPDES Monthly Daily Average Maximum Flow - mgd -- - Report l/month Estimate TOC --- 50 mg/L l/quarter Grab TSS --- 100 mg/L l/month Grab Oil & Grease --- 20 mg/L l/month Grab FAC* -- - 0.5 mg/L l/month Grab Total Chromium* -- - 0.2 mg/L l/year Grab Total zinc* -- - 1.0 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u.
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| l/month l/month Grab Grab
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| * Sample shall be representative of periods during cooling tower blowdown discharge.
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| There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| Outfall 701, at the point of discharge from Dry Cooling Tower Sump #1 A-80
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 17 Outfall 801 - the intermittent discharge of cooling tower blowdown and low volume wastewaters from Dry Cooling Tower Sump #2. Low volume wastewater sources as defined in 40 CFR 423 include, but not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. Optional discharge to Final Outfall 004 via the plant drainage ditches may occur during periods when the circulating water system is unavailable Parameter LPDES Monthly Daily Average Maximum Flow - mgd --- Report l/month Estimate TOC -- - 50 mg/L l/quarter Grab TSS --- 100 mg/L l/month Grab Oil & Grease --- 20 mg/L l/month Grab FAC* - -- 0.5 mg/L l/month Grab Total Chromium* --- 0.2 mg/L l/year Grab Total Zinc* --- 1- 0 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u.
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| l/month l/month Grab Grab
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| * Sample shall be representative of periods during cooling tower blowdown discharge.
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| A-81
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 18 There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| Outfall 801, at the point of discharge from Dry Cooling Tower Sump #2 Outfall 901 - the mobile intermittent discharge of metal cleaning wastewaters (both chemical and non-chemical) from various plant equipment components including, but not limited to: the steam generator, cooling water heat exchangers, and piping Parameter LPDES Monthly Daily Average Maximum Flow - mgd -- - Report l/week Estimate TSS -- - 100 mg/L l/week Grab Oil & Grease -- - 20 mg/L l/week Grab Total Copper - -- l . 0 mg/L l/week Grab Total Iron --- l . 0 mg/L l/week Grab pH 6.0 s.u. 9.0 s.u.
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| l/week l/week Grab Grab There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| A-82
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 19 Outfall 901, at the point of discharge from the mobile cleaning process unit(s)
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| Outfall 1001 - the intermittent discharge from the yard oil separator system.
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| Wastewater includes auxiliary boiler blowdown, stormwater, and low volume wastewaters from various sources, including plant floor drains and discharge from the industriil.l waste system as defined in 40 CFR 423. Low volume wastewater sources include, but are not limited to: secondary water system drains, system
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| 'leakage, auxiliary boiler sumps, turbine building equipment and floor drains, turbine building floor wash downs, and laboratory drains. Optional discharge to Final Outfall 004 may occur during maintenance periods and rain events that compromise the capacity of the discharge pumps.
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| Parameter LP DES Monthly Daily Average Maximum Flow - mgd -- - Report l/month Estimate TSS -- - 100 mg/L l/month Grab Oil & Grease 20 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u.
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| l/month l/month Grab Grab There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| Outfall 1001, at the point of discharge from the yard oil separator system Outfall 004 - the intermittent discharge from the plant drainage ditch system consisting of stormwater, potable water from the fire water system, maintenance wastewaters including, but not limited to: hydrostatic test water, air conditioning condensate, low volume wastewaters including, but not limited to:
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| reverse osmosis reject water and demineralized water. The plant drainage ditch system receives treated carwash wastewater (Internal Outfall 204), and during A-83
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 20 maintenance activities discharges from Dry Cooling Tower Sump #1 (Internal Outfall 701), Dry Cooling Tower Sump #2 (Internal Outfall 801), and treated discharge from the yard oil separator system, including, but not limited to:
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| plant floor drains and discharge from the industrial waste system (Internal Outfall 1001).
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| Parameter LPDES Monthly Daily Average Maximum Flow - mgd --- Report 1/3 months Estimate TOC --- 50 mg/L 1/3 months Grab TSS* --- 100 mg/L 1/3 months Grab Oil & Grease 15 mg/L 1/3 months Grab pH 6.0 s.u. 9.0 s.u.
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| 1/3 months 1/3 months Grab Grab
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| *Samples shall be representative of periods during discharge of low volume wastewaters as defined in 40 CFR 423 (excludes Mississippi River water that accumulates in the condenser water boxes.)
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| There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| Outfall 004, at the point of discharge from the stormwater drainage ditch south of the plant laydown area A-84
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 21 Outfall 204 - the intermittent internal discharge of treated carwash wastewater Parameter LPDES Monthly Daily Average Maximum Flow - rngd -- - Report 1/3 months Estimate COD 200 rng/L 300 rng/L 1/3 months 1/3 months Grab Grab TSS --- 45 mg/L 1/3 months Grab Oil & Grease 15 mg/L 1/3 months Grab pH 6.0 s.u. 9.0 s.u.
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| 1/3 months 1/3 months Grab Grab Soaps & Detergents* Report -- -
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| 1/3 months Grab
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| *The quantity and types of all Soaps and/or Detergents used during the sampling month shall be recorded.
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| There shall be no discharge of floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| Outfall 204, at the point of discharge from the carwash treatment system A-85
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| Fact sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 22 Outfall 005 - the intermittent discharge of treated sanitary wastewater and a de minimis discharge from the HVAC unit from the Entergy Energy Education Center Parameter LP DES Monthly Weekly Average Average Flow - mgd - -- Report 1/6 months Estimate BOD5 -- - 45 mg/L 1/6 months Grab TSS --- 45 mg/L 1/6 months Grab Oil & Grease - -- 400 mg/L 1/6 months Grab pH 6.0 s.u. 9.0 s.u.
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| 1/6 months 1/6 months Grab Grab There shall be no discharge of* floating solids or visible foam in other than trace amounts.
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| Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations:
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| Outfall 005, at the point of discharge from the sewage treatment plant
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| : 9. Summary of Proposed Changes From the Current LPDES permit:
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| The outfall descriptions have been updated based on an email from Rodney LeBlanc dated March 2, 2010.
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| The flow limitation for Outfall 001 has been removed.
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| Outfall 204 (car washwater) has been removed from the permit and the outfall description for Outfall 004 has been modified to reflect this change.
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| A-86
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 23 The limits for outfall 005 have been updated in accordance with the reissuance of the Class I Sanitary Discharge General Permit, and the limitations have been changed from weekly average to daily maximum.
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| : 10. Proposed Permit Limits:
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| The specific effluent limitations and/or conditions will be found in the draft permit. Development and calculation of permit limits are detailed in the Permit Limit Rationale section below.
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| : 11. Permit Limit Rationale:
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| The following section sets forth the principal facts and the significant factual, legal, methodological, and policy questions considered in preparing the draft permit. Also set forth are any calculations or other explanations of the derivation of specific effluent limitations and conditions, including a citation to the applicable effluent limitation guideline or performance standard provisions as required under LAC 33:IX.2707 and reasons why they are applicable or an explanation of how the alternate effluent limitations were developed.
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| A. TECHNOLOGY-BASED VERSUS WATER QUALITY STANDARDS-BASED EFFLUENT LIMITATIONS AND CONDITIONS Following regulations promulgated at LAC 33:IX.2707.L.2.b, the draft permit limits are based on either technology-based effluent limits pursuant to LAC 33:IX.2707.A or on State water quality standards and requirements pursuant to LAC 33:IX.2707.D, whichever are more stringent.
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| B. TECHNOLOGY-BASED EFFLUENT LIMITATIONS AND CONDITIONS Regulations promulgated at LAC 33: IX. 2707 .A require technology-based effluent limitations to be placed in LPDES permits based on effluent limitations guidelines where applicable, on BPJ (best professional judgement) in the absence of guidelines, or on a combination of the two. The following is a rationale for types of wastewaters. See outfall information descriptions for associated outfall(s) in Section 7. Regulations also require permits to establish monitoring requirements to yield data representative of the monitored activity
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| [LAC 33:IX.2715] and to assure compliance with permit limitations
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| [LAC 3 3 : IX . 2 7 0 7 . I . ] .
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| Manufacturing Operation Guideline Steam Electric Power Generating Point 40 CFR 423 Source Category Regulations require permits establish monitoring requirements to yield data representative of the monitored activity [LAC33:IX.2715]
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| and to assure compliance with permit limitations [LAC33:IX.2707.I].
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| A-87
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 24 C. WATER QUALITY-BASED EFFLUENT LIMITATIONS Technology-based effluent limitations and/or specific analytical results from the permittee's application were screened against state water quality numerical standard based limits by following guidance procedures established in the Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards LDEQ, October 7, 2009. Calculations, results, and documentation are given in Appendix B.
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| The following pollutants received water quality based effluent limits:
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| .* .P6LLUTANT ( S)
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| None D. MONITORING FREQUENCIES Regulations require permits to establish monitoring requirements to yield data representative of the monitored activity (LAC33:IX.2715) and to assure compliance with permit limitations (LAC33: IX. 2707. I).
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| Specific monitoring frequencies per outfall are listed in Section E.
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| E. OUTFALL SPECIFIC RATIONALE outfall 001
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| : 1. General Comments This outfall is the continuous discharge of once through non-contact cooling water combined with previously monitored intermittent discharges including but not limited to: steam generator blowdown, cooling tower blowdown, metal cleaning wastewaters, low volume wastewater, and stormwater from Outfalls 101, 201, 301, 401, 501, 601, 701, 801, 901, and 1001.
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| A-88
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 25
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow-mgd Report Report Continuous Recorder Temperature Report 118°F Continuous Recorder Heat - -- 9.5 x 10 3 Continuous Recorder MBTU/hour Total Residual --- 211 lbs/day 1/week Grab Chlorine Flow - The current LPDES permit established a reporting requirement for monthly average. This requirement is being retained. The daily maximum limitation of 1518 in the current permit is being changed to a reporting requirement as per current guidance. Both requirements will have a measurement frequency of continuous and a sample type of recorder. These requirements are consistent with LAC33:IX.2707.I.1.b.
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| Temperature - The current LPDES permit established a reporting requirement for monthly average and daily maximum limitation of 118° F. These limitations are being retained with a moni taring frequency of continuous. Temperature is measured by a recorder with analysis required immediately.
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| Heat - The current LPDES permit established a daily maximum limitation of 9.5 x 10 3 MBTU/hour. This limitation is being retained with a monitoring frequency of continuous and a sample type of recorder.
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| Total Residual Chlorine - The current LPDES permit established a daily maximum limitation of 211 lbs/day. This limitation is being retained with the same moni taring frequency of once per week by grab sample during periods of chlorination.
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| TOXICITY TESTS FREQUENCY Acute static renewal 48-hour once per quarter definitive toxicity test using fathead minnow (Pimephales promelas)
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| Acute static renewal 48-hour Once per quarter definitive toxicity test using water flea (Daphnia pulex)
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| A-89
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 26 Toxicity tests shall be performed in accordance with protocols described in the latest revision of the "Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms." The stipulated test species are appropriate to measure the toxicity of the effluent consistent with the requirements of the State water quality standards. The biomonitoring frequency has been established to reflect the likelihood of ambient toxicity and to provide data representative of the toxic potential of the facility* s discharge in accordance with regulations promulgated at LAC 33:IX.2715.
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| Results of all dilutions as well as the associated chemical monitoring of pH, temperature, hardness, dissolved oxygen, conductivity, and salinity shall be documented in a full report according to the test method publication mentioned in the previous paragraph. The permittee shall submit a copy of the first full report to the Office of Environmental Compliance. However, the full report and subsequent reports are to be retained for three ( 3) years following the provisions of Part III.C.3 of this permit. The permit requires the submission of certain toxicity testing information as an attachment to the Discharge Monitoring Report.
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| This permit may be reopened to require effluent limits, additional testing, and/or other appropriate actions to address toxicity if biomonitoring data shows actual or potential ambient toxicity to be the result of the permit tee's discharge to the receiving stream or water body. Modification or revocation of the permit is subject to the provisions of LAC 33: IX. 3105. Accelerated or intensified toxicity testing may be required in accordance with Section 308 of the Clean Water Act.
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| Dilution Series - The permit requires five (5) dilutions in addition to the control ( 0% effluent) to be used in the toxicity te"sts. These additional effluent concentrations shall be 13%, 18% 1 24%, 31%, and 42%. The biomonitoring critical dilution is defined as 31% effluent.
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| Internal Outfalls In accordance with LAC33:IX.3305, the following is an explanation for the establishment of Internal Outfalls 101, 201, 301, 401, 501, 601, 701, 801, 901, and 1001. Certain permit effluent limitations at the point of discharge are impractical because at the final discharge point, the wastewater is diluted as to make monitoring impracticable. Therefore, in accordance with LAC33:IX.2709, the internal outfalls described below will remain in the permit.
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| Outfall 101
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| : 1. General Comments This outfall is the intermittent discharge from the liquid waste management system. The boron management system receives low volume wastewater from the following sources, including but not limited to: the A-90
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 27 turbine and reactor building equipment and floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423.
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow-mgd --- Report l/batch Totalized TSS --- 100 mg/L l/month Grab Oil and Grease --- 20 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u. l/batch Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per batch and a sample type of totalized. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with a monitoring frequency of once per month by grab sample.
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| Oil and Grease - The current LPDES permit established a daily maximum limitation of 20 mg/L in accordance with 40 CFR 423.12(b) (3). This limitation is being retained with monitoring frequency of once per month by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. o standard units and maximum discharge limit of 9. o standard units for pH in accordance with 40 CFR 423.12{b) (1). These limitations are being retained with a monitoring frequency of once per batch by grab sample.
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| Outfall 201
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| : 1. General Comments This outfall is the intermittent discharge from the boron management system. The boron management system receives low volume wastewater from the following sources, including but not limited to: the turbine and reactor building equipment and floor drains, primary plant water makeup, laboratory drains, and other low volume wastewater sources as defined in 40 CFR 423.
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| A-91
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 28
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maxirnwn Measurement Sample Frequency Type Flow-mgd --- Report 1/batch Totalized TSS --- 100 mg/L 1/month Grab Oil and Grease --- 20 mg/L 1/month Grab pH 6.0 s.u. 9.0 s.u. 1/batch Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per batch and a sample type of totalized. This requirement is consistent with LAC33:IX.2707.I.1.b.
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| Total suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with a monitoring frequency of once per month by grab sample.
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| Oil & Grease - The current LPDES permit established a daily maximum limitation of 20 mg/L in accordance with 40 CFR 423 .12 (b) (3). This limitation is being retained with a monitoring frequency of once per month by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard units and maximum discharge limit of 9. O standard units for pH in accordance with 40 CFR 423.12(b) (1). These limitations are being retained with a monitoring frequency of once per batch by grab sample.
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| Outfall 301
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| : 1. General Comments This outfall is the intermittent discharge of filter flush water from the primary water treatment system. The primary water treatment system filters riverwater for various plant uses. The filters of this system are flushed periodically with untreated river water to remove solids trapped in the filter beds.
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| A-92
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Stearn Electric Station LA0007374, AI No. 35260 Page 29
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow-rngd -- - Report Weekly Totalized NOTE: The quantity and types of all clarifying agents (coagulants) used in the primary water treatment system during the sampling month shall be recorded.
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| Records of the quantity and type of clarifying agents used shall be retained for three (3) years following Part III.C.3 of the LPDES permit. No DMR reporting shall be required.
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| Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of weekly and a sample type of totalized. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| Outfall 401
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| : 1. General Comments This outfall is the intermittent discharge of steam generator blowdown and other low volume wastewaters as defined in 40 CFR 423.
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow-mgd -- - Report Daily Totalized TSS -- - 100 mg/L l/week Grab Oil and Grease --- 20 rng/L l/week Grab pH 6.0 s.u. 9.0 s. u. l/week Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a daily measurement frequency and a sample type of totalized. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| A-93
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 30 Total Suspended Solids - The current LPDES permit established a daily maximum limitation of* 100 mg/L in accordance with 40 CFR 423 .12 (bl (3) . This limitation is being retained with a monitoring frequency of once per week by grab sample.
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| Oil & Grease - The current LPDES permit established a daily maximum limitation of 20 mg/Lin accordance withi 40 CFR 423.12(b)(3). This limitation is being retained with a monitoring frequency bf once per week by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard units and maximum discharge limit of 9. 0 standard units for pH in accordance with 40 CFR 423(b} (1). These limitations are being retained with a monitoring frequency of once per week by grab sample.
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| outfall 501
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| : 1. General Comments This outfall is the intermittent discharge from Auxiliary Component Cooling Water Basin A. Low volume wastewaters include, but are not limited to: auxiliary component cooling water, component cooling water, Mississippi River water used for flow testing, and stormwater.
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow-mgd - -- Report 1/week Estimate TOC --- 50 mg/L 1/week Grab TSS --- 100 mg/L 1/week Grab Oil and Grease --- 20 mg/L 1/week Grab pH 6.0 s.u. 9.0 s.u. 1/week Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per week and a sample type of estimate. These requirements are consistent with LAC33:IX.2707.I.1.b.
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| Total Organic Carbon - The current LPDES permit established a daily maximum limitation of 50 mg/L. The limitation is based on BPJ in accordance with this A-94
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 31 Office's guidance on stormwater, letter dated 6/17 /87, from J. Dale Givens (LDEQ) to Myron Knudson (EPA Region 6)and the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAROSOOOO, effective on May 1, 2006. This limitation is being retained with a monitoring frequency of once per week by grab sample.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with a monitoring frequency of once per week by grab sample.
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| Oil & Grease - The current LPDES permit established a daily maximum limitation of 20 mg/L in accordance with 40 CFR 423.12{b) (3). This limitation is being retained with a monitoring frequency of once per week by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard units and maximum discharge limit of 9. O standard units for pH in accordance with 40 CFR 423.12(b) (1). These limitations are being retained with a monitoring frequency of once per week by grab sample.
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| Outfall 601
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| : 1. General Comments This outfall is the intermittent discharge from Auxiliary Component Cooling Water Basin B. Low volume wastewaters include, but are not limited to: auxiliary component cooling water, component cooling water, secondary plant water system wastewater, Mississippi River water used for flow testing, and stormwater.
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow-mgd -- - Report 1/week Estimate TOC - -- 50 mg/L 1/week Grab TSS - -- 100 mg/L 1/week Grab Oil and Grease - -- 20 mg/L 1/week Grab pH 6.0 s.u. 9.0 s.u. 1/week Grab A-95
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 32 Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per week and a sample type of estimate. This requirement is consistent with LAC33:IX.27Q7.I.1.b.
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| Total Organic Carbon - The current LPDES permit established a daily maximum limitation of so mg/L. The limitation is based on BPJ in accordance with this Office's guidance on stormwat;er, letter dated 6/17/87, from J. Dale Givens (LDEQl.
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| to Myron Knudson (EPA Region 6) and the LPDE.s Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAROSOOOO, effective on May 1, 2006. This limitation is being retained with a monitoring frequency of once per week by grab sample.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with a monitoring frequency of once per week by grab sample .
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| . Oil & Grease - The current LPDES permit established a daily maximum limitation of 20 mg/L in accordance with 40 CFR 423.12(b) (3). This limitation is being retained with a monitoring frequency of once per week by grab sample.
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| pH - The current LPDES pe:rmi t established a minimum discharge limit of 6. o standard units and maximum discharge limit of 9~0 standard units for pH in accordance with 40 CFR 423.12 (b) (1). These limitations are being retained with a monitoring frequency of once per week by grab sample.
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| Outfall 701
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| : 1. General Comments This outfall is the intermittent discharge of cooling tower blowdown and low volume . wastewaters from Dry Cooling Tower. Sump #1. Low volume wastewaters includ~, but are not limited to: wet cooling tower leakage, aillciliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. (NOTE: Optional discharge to plant drainage ditches thence to outfall 004 may occur during periods when the circulating water system is unavailable.)
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| A-96
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| Fact sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 33
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow -- - Report l/month Estimate TOC --- 50 mg/L l/quarter Grab TSS -- - 100 mg/L l/month Grab Oil and Grease --- 20 mg/L l/month Grab Free Available -- - 0.5 mg/L l/month Grab Chlorine Total Chromium -- - 0.2 mg/L l/year Grab Total Zinc - -- 1. 0 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u. l/month Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per month and a sample type of estimate. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| Total Organic Carbon - The current LPDES permit established a daily maximum limitation of 50 mg/L. The limitation is based on BPJ in accordance with this Office's guidance on stormwater, letter dated 6/17/87, from J. Dale Givens (LDEQ) to Myron Knudson (EPA Region 6}and the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAR050000, effective on May 1, 2006. This limitation is being retained with the same monitoring frequency of once per quarter by grab sample.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| Oil and Grease - The current LPDES permit established a daily maximum limitation of 20 mg/L in accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| Free Available Chlorine - The current LPDES permit established a daily maximum limitation of 0.5 mg/Lin accordance with 40 CFR 423.13(d) (1). This limitation is being retained with the same monitoring frequency of once per mpnth by grab sample.
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| A-97
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 34 Total Chromium - The current LPDES permit established a daily maximum of 0.2 mg/L in accordance with 40 CFR 423.13(d) (1). This limitation is being retained with the same monitoring frequency of once per year by grab sample.
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| Total Zinc - The current LPDES permit established a daily maximum of 1.0 mg/Lin accordance with 40 CFR 423.13(d) (1). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| pH - The current LPDES permit established a miniml!lm discharge limit of 6. O standard units and a maximum discharge limit of 9.0 standard units for pH. These limits are based on 40 CFR 423.12(b) (1). These limitations are being retained with the same monitoring frequency of once per month by grab sample.
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| Outfall 801
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| : 1. General Comments This outfall is the intermittent discharge of cooling tower blowdown and low volume wastewaters from Dry Cooling Tower Sump #2. Low volume wastewater sources as defined in 40 CFR 423 include, but are not limited to: wet cooling tower leakage, auxiliary component cooling water, component cooling water, secondary plant water system wastewater, and stormwater. (NOTE: Optional discharge to plant drainage ditches thence to Outfall 004 may occur during periods when the circulating water system is unavailable.)
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow --- Report l/month Estimate TOC --- 50 mg/L 1/quarter Grab TSS -- - 100 mg/L 1/month Grab Oil and Grease - -- 20 mg/L l/rnonth Grab Free Available -- - 0.5 mg/L 1/month Grab Chlorine Total Chromium -- - 0.2 mg/L l/year Grab Total Zinc --- 1. 0 mg/L l/month Grab pH 6.0 s.u. 9.0 s.u. l/month Grab A-98
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 35 Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per month and a sample type of estimate. This requirement is consistent with LAC33:IX.2707.I.1.b.
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| Total Organic Carbon - The current LPDES permit established a daily maximum limitation of 50 mg/L. The limitation is based on BPJ in accordance with this Office's guidance on stormwater, letter dated 6/17/87, from J. Dale Givens (LDEQ}
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| to Myron Knudson (EPA Region 6}and the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAROSOOOO, effective on May 1, 2006. This limitation is being retained with the same monitoring frequency of once per quarter by grab sample.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| Oil and Grease - The current LPDES permit established a daily maximum limitation of 20 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| Free Available Chlorine - The current,LPDES permit established a daily maximum limitation of 0.5 mg/Lin accordance with 40 CFR 423.13(d) (1). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| Total Chromium - The current LPDES permit established a monthly average of 0.2 mg/Land a daily maximum of 0.2 mg/Lin accordance with 40 CFR 423.13(d) (1).
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| This limitation is being retained with the same monitoring frequency of once per year by grab sample.
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| Total Zinc - The current LPDES permit established a daily maximum of 1.0 mg/Lin accordance with 40 CFR 423.13(d} (1). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard units and a maximum discharge limit of 9.0 standard units for pH. These limits are based on 40 CFR 423.12(b) (1). These limitations are being retained with the same monitoring frequency of once per month by grab sample.
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| A-99
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 36 Outfall 901
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| : 1. General Comments This outfall is the intermittent discharge of metal cleaning wastewaters (both chemical and non-chemical) from various plant equipment components including, but not limited to: the steam generator, cooling water heat exchangers, and piping.
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow - -- Report l/week Estimate TSS - -- 100 mg/L l/week Grab Oil and Grease - -- 20 mg/L l/week Grab Total Copper --- 1. 0 mg/L l/week Grab Total Iron - -- 1. 0 mg/L l/week Grab pH 6.0 s.u. 9.0 s.u. l/week Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per week and a sample type of estimate. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per week by grab sample.
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| Oil and Grease - The current LPDES permit established a daily maximum limitation of 20 mg/L in accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per week by grab sample.
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| Total Copper- The current LPDES permit established a daily maximum limitation of
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| : 1. 0 mg/L in accordance with 40 CFR 423 .13 (b) (5). This limitation is being retained with the same monitoring frequency of once per week by grab sample.
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| A-100
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Stearn Electric Station LA0007374, AI No. 35260 Page 37 Total Iron - The current LPDES permit established a daily maximum of 1.0 rng/L in accordance with 40 CFR 423.13(b) (5). This limitation is being retained with the same monitoring frequency of once per week by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard units and a maximum discharge limit of 9.0 standard units for pH. These limits are based on 40 CFR 423.12{b) (1). These limitations are being retained with the same monitoring frequency of once per week by grab sample.
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| Outfall 1001
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| : 1. General Comments This outfall is the intermittent discharge from the yard oil separator system. Wastewater includes auxiliary boiler blowdown, stormwater, and low volume wastewaters from various sources, including plant floor drains and discharge from the industrial waste system as defined in 40 CFR 423.
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| Low volume wastewater sources include, but are not limited to: secondary water system drains, system leakage, auxiliary boiler sumps, turbine building equipment and floor drains, turbine building floor wash downs, and laboratory drains. (NOTE: Optional discharge to Final Outfall 004 may occur during maintenance periods and during rain events that compromise the capacity of the discharge pumps.)
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow -- - Report l/month Estimate TSS -- - 100 rng/L l/month Grab Oil and Grease - -- 20 rng/L l/rnonth Grab pH 6.0 s.u. 9.0 s.u. l/month Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per month and a sample type of estimate. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 rng/L in accordance with 40 CFR 423.12(b) (3). This limitation A-101
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 38 is being retained with the same monitoring frequency of once per month by grab sample.
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| Oil and Grease - The current LPDES permit established a daily maximum limitation of 20 mg/Lin accordance with 40 CFR 423.12(b) (3). This limitation is being retained with the same monitoring frequency of once per month by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard uni ts and a maximum discharge limit of 9. O standard uni ts for pH. These limits are based on 40 CFR 423.12(b).(l). These limitations are being retained with the same monitoring frequency of once per month by grab sample.
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| Outfall 004
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| : 1. General Comments This outfall is the intermittent discharge from the plant drainage ditch system consisting of stormwater, potable water from the fire water system, maintenance wastewaters including, but not limited to: hydrostatic test water, air conditioning condensate, low volume wastewaters including, but not limited to: reverse osmosis reject water and demineralized water. The plant drainage ditch system receives discharges during maintenance from the Dry Cooling Tower Sump #1 (Internal Outfall 701), Dry Cooling Tower Sump #2 (Internal Outfall 801), and treated discharge from the yard oil separator system, including, but not limited to: plant floor drains and discharge from the industrial waste system (Internal Outfall 1001)
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow --- Report 1/3 months Estimate TOC --- 50 mg/L 1/3 months Grab TSS --- 100 mg/L 1/3 months Grab Oil and Grease --- 15 mg/L 1/3 months Grab pH 6.0 s.u. 9.0 s.u. 1/3 months Grab Flow - The current LPDES permit established a reporting requirement for daily maximum flow. This requirement is being retained with a measurement frequency of once per three months and a sample type of estimate. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| A-102
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 39 Total Organic Carbon - The current LPDES permit established a daily maximum limitation of 50 mg/L. The limitation is based on BPJ in accordance with this Office's guidance on stormwater, letter dated 6/17 /87, from J. Dale Givens (LDEQ) to Myron Knudson (EPA Region 6)and the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, L.1'R050000, effective on May 1, 2006. This limitation is being retained with the same monitoring frequency of once per three months by grab sample.
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| Total Suspended Solids - The current LPDES permit established a daily maximum limitation of 100 mg/L. The limitation is based on BPJ in accordance with this Office's guidance on stormwater, letter dated 6/17 /87, from J. Dale Givens (LDEQ) to Myron Knudson (EPA Region 6Jand the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAR050000, effective on May 1, 2006. This limitation .is being retained with the same monitoring frequency of once per three months by grab sample.
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| Oil and Grease - The current LPDES permit established a daily maximum limitation of 15 mg/L. The limitation is based on BPJ in accordance with this Office's guidance on stormwater, letter dated 6/17 /87, from J. Dale Givens (LDEQ) to Myron Knudson (EPA Region 6)and the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAROSOOOO, effective on May 1, 2006. This limitation is being retained with the same monitoring frequency of once per three months by grab sample.
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| pH - The current LPDES permit established a minimum discharge limit of 6. O standard units and a maximum discharge limit of 9.0 standard units for pH. The limitation is based on BPJ in accordance with this Office's guidance on stormwater, letter dated 6/17/87, from J. Dale Givens (LDEQJ to Myron Knudson (EPA Region 6) and the LPDES Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activities, LAROSOOOO, effective on May 1, 2006. These limitations are being retained with the same monitoring frequency of once per three months by grab sample.
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| Outfall 005
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| : 1. General Comments This outfall is the intermittent discharge of treated sanitary wastewater and a de minimis discharge from the HVAC unit from the Entergy Energy Education Center.
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| A-103
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 40
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| : 2. Effluent Limitation, Monitoring Frequencies, and Sample Types EFFLUENT LIMITATION MONITORING CHARACTERISTIC REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Flow - -- Report 1/6 months Estimate BOD 5 30 mg/L 45 mg/L 1/6 months Grab TSS 30 mg/L 45 mg/L 1/6 months Grab Fecal Coliform 200 col/100 mL 400 col/100 mL 1/6 months Grab pH 6.0 s.u. 9.0 s.u. 1/6 months Grab Flow - The current LPDES permit established a reporting requirement for weekly average flow. This requirement is being retained with a measurement frequency of once per six months and a sample type of estimate. This requirement is consistent with LAC33:IX.2707.I.l.b.
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| Biological Oxygen Demand - The current LPDES permit established a weekly average limitation of 45 mg/L. This limitation is changed to a daily maximum limitation.
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| The same monitoring frequency of once per six months by grab sample is being retained. In addition, a monthly average limitation of 30 mg/L with a monitoring frequency of once per six months by grab sample is being proposed. These limitations are based on the Class I. Sanitary General Discharge Permit, LAG530000.
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| Total Suspended Solids - The current LPDES permit established a weekly average limitation of 45 mg/L. This limitation is changed to a daily maximum limitation.
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| The s.ame moni taring frequency of once per six months by grab sample is being retained. In addition, a monthly average limitation of 30 mg/L with a monitoring frequency of once per six months by grab sample is being proposed. These limitations are based on the Class I Sanitary General Discharge Permit, LAG530000.
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| Fecal Coliform - The current LPDES permit established a daily weekly average limitation of 400 colonies per 100 mL. This limitation is changed to a daily maximum limitation. The same monitoring frequency of once per six months by grab sample is being retained. In addition, a monthly average limitation of 200 colonies per mL with a monitoring frequency of once per six months by grab sample is being proposed. These limitations are based on the Class I Sanitary General Discharge Permit, LAG530000.
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| A-104
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| Fact sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 41 pH - The current LPDES permit established a minimum discharge limit of 6.0 standard units and a maximum discharge limit of 9.0 standard units for pH. These limitations are based on the Class I Sanitary General Discharge Pennit, LAGSJOOOO. These limitations are being retained with the same monitoring frequency of once per three months by grab sample.
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| Part II Specific Conditions PROHIBITION OF PCB DISCHARGES There shall be no discharge of polychlorinated biphenyls (PCB's). The minimum quantification level for PCB's is 1.0 µg/L. If any individual analytical test result for PCB's is less than the minimum quantification level, then a value of zero(O) shall be used for the Discharge Monitoring Report (DMR) calculations and reporting requirements.
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| PROHIBITION OF 126 PRIORITY POLLUTANTS There shall be no discharge of any 126 priority pollutants (40 CFR 423 Appendix A) associated with the chemicals added for cooling tower maintenance, except total chromium and total zinc. The minimum quantification levels for the 126 priority pollutants are found in Part II, Paragraph I.
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| CHEMICAL METAL CLEANING WASTE The term chemical metal cleaning waste means any wastewater resulting from cleaning of any metal process equipment with chemical compounds, including, but not limited to, boiler tube cleaning.
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| METAL CLEANING WASTE The term metal cleaning waste means any wastewater resulting from cleaning (with or without chemical cleaning compounds) any metal process equipment including, but not limited to, boiler tube cleaning, boiler fireside cleaning, and air preheater cleaning.
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| LOW VOLUME WASTE SOURCES The term "low volume waste sources" means, taken collectively as if from one source, wastewater from all sources except those for which specific limitations are otherwise established. Low volume waste sources include, but are not limited to: wastewaters from wet scrubber air pollution control systems, ion exchange water treatment systems, water treatment evaporator blowdovm, laboratory and sampling streams, boiler blowdown, floor drains, cooling tower basin cleaning wastes, and recirculating house service water systems. Sanitary and air conditioning wastewaters are not included.
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| A-105
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| Fact sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 42 TOTAL RESIDUAL CHLORINE The term "total residual chlorine" (or total residual oxidants for intake water with bromides) means the value obtained using the amperometric method for total residual chlorine described in 40 CFR Part 136.
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| Total residual chlorine may not be discharged from any unit for more than two hours per day.
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| Simultaneous multi-unit chlorination is permitted.
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| FREE AVAILABLE CHLORINE The term "free available chlorine" shall mean the value obtained using the amperometric titration method for free available chlorine described in the latest edition of Standard Methods for the Examination of Water and Wastewater.
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| Free available chlorine may not be discharged from any unit for more than two hours in any one day and not more than one unit in any plant may discharge free available chlorine at any one time.
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| TEMPERATURE Daily temperature discharge is defined as the flow-weighted average (FWAT) and, on a daily basis, shall be monitored and recorded in*accordance with Part I of this permit. FWAT shall be calculated at equal time intervals not greater than two hours. The method of calculating FWAT is as follqws:
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| FWAT = SUMMATION (INSTANTANEOUS FLOW X INSTANTANEOUS TEMPERATURE)
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| SUMMATION (INSTANTANEOUS FLOW)
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| "Daily average temperature" (also known as average monthly or maximum 30 day value) shall be the arithmetic average of all FWATs calculated during the calendar month.
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| "Daily maximum temperature" (also known as the maximum daily value) shall be the highest FWAT calculated during* the calendar month.
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| Discharge of heat shall be continuously calculated and recorded as:
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| [Instantaneous T (circulating water temperature rise through the plant in F)] X [Instantaneous flow rate in MGD] X [3.48Xl05]
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| OR AS
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| [Heat transferred to the turbine generator cycle (BTU/hour)] [Gross electrical output (BTU/hour)].
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| A-106
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 43 NON-RADIOACTIVE WASTEWATERS Certain low volume and chemical wastewaters from this facility with no detectable radioactivity, as defined by the Nuclear Regulatory Commission plant effluent release limits may be commingled and treated with similar wastewaters from Waterford 1 & 2 and controlled under terms of LPDES Permit Number LA0007439.
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| WATER TREATMENT CLARIFIER SLUDGE WASTES Water treatment clarifier sludge wastes may be returned to the stream without treatment if not previously combined with any other untreated waste source, including demineralizer and softener wastes.
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| ZEBRA MUSSEL TREATMENT The terins and conditions of the zebra mussel treatment program submitted by Entergy Operations, Inc., Waterford 3 and approved by this Office on June 23; 1998, shall be enforceable as if part of this permit.
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| According to section 3. d. , "Samples and Composites", of the biomoni toring requirements paragraph of this permit, the perrnittee must collect composite samples that "are representative of any periodic episodes of chlorination, biocide usage, or other potentially toxic substance discharged on an intermittent basis". Anytime the treatment method involves an increase in the concentration of a treatment chemical, a change in type of treatment chemical used, or if any event occurs that creates the potential for an effluent with a higher toxic nature, additional biomonitoring according to the terms and conditions of the biomonitoring section of Part II of this permit shall be required.
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| The permittee must notify this Office if changes occur in the zebra mussel control plan and obtain approval prior to initiating the new treatment. If chlorine is applied to control zebra mussels, the permittee must comply wit_h a daily maximum Total Residual Chlorine (TRC) concentration limit of 0.2 mg/L.
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| Monitoring shall be performed at a frequency of l/day, by grab sample, during periods of chlorine application.
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| PERMIT REOPENER CLAUSE This permit may be modified, or alternatively, revoked and reissued, to comply with any applicable effluent standard or limitations issued or approved under sections 30l(b) (2) and (D); 304(b) (2); and 307(a) (2) of the Clean Water Act, or more stringent discharge limitations and/or additional restrictions in the future to maintain the water quality integrity and the designated uses of the receiving water bodies based upon additional water quality studies and/or TMDL's, if the effluent standard, limitations, water quality studies or TMDL's so issued or approved:
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| : 1. Contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or A-107
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 44
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| : 2. Controls any pollutant not limited in the permit; or
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| : 3. Require reassessment due to change in 303 (d} status of waterbody; or
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| : 4. Incorporates the results of any total maximum daily load allocation, which may be approved for the receiving water body.
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| The Louisiana Department of Environmental Quality (LDEQ) reserves the right to modify or revoke and reissue this permit based upon any changes to established TMDL' s for this discharge, or to accommodate for pollutant trading provisions in approved TMDL watersheds as necessary to achieve compliance with water quality standards. Therefore, prior to upgrading or expanding this facility, the permittee should contact the Department to determine the status of the work being done to establish future effluent limitations and additional permit conditions.
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| 316(b} PHASE II RULE REQUIREMENTS July 6, 2004, EPA promulgated 'Phase II' regulations in accordance with section 316(b) of the Clean Water Act (CWA).
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| January 25, 2007, the Second U.S. Circuit Court of Appeals remanded several provisions of the Phase II rule.
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| March 20, 2007, EPA issued a memo saying, "the rule should be considered suspended" .
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| July 9, 2007, Federal Register notice suspending all parts of the Phase II regulations except 40 CFR 125.90(b) [LAC 33:IX.4731.B]
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| According to EPA, 316 (b) 'Phase II' regulations are under complete reconsideration at this time. LAC 33:IX.4731.B provides for regulating the cooling water intake structure (CWIS) for existing facilities on a case-by-case basis using best professional judgment.
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| This facility was issued a number of previous NPDES and/or LPDES permits and has been withdrawing once-through, non-contact cooling water without any identified problems. QLDEQ has no information which either identifies or verifies any past or current adverse environmental impacts associated with the withdrawal of the applicable cooling water. The facility is located in the main channel of the Mississippi River at River Mile 129.5 on the west descending bank. The intake structure extends out 162 feet from the bank and is equipped with a skimmer wall as to prevent debris and surface swimming organisms from entering the CWIS. The offshore location of the CWIS minimizes fish and shellfish from entering the system as the conditions of the Mississippi River (i.e., high velocity, increased debris, shifting river bed, lack of habitat/vegetation, and reduction of food source) at the location of the intake structure are not easily tolerated. LDEQ has made the determination that this CWIS represents the best technology available. This determination is based on current information available and will be re-evaluated either upon promulgation of revised 316{b) Phase II regulations or upon evaluation of the environmental impacts of their CWIS as described below.
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| The revised 316(b) Phase II regulation will supersede any requirements contained in the applicable permit.
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| A-108
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 45 A permit modification, effective January 10, 2008, required Entergy Operations, Inc. to characterize the fish/shellfish in the vicinity of the CWIS and assess impingement mortality and entrainment (IM&E) . The assessment results were received by LDEQ on July 10, 2008 (EDMS document 37109798). In this permit, LDEQ will require an assessment of the cooling water system as described in the following paragraphs:
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| The permittee shall comply with effective regulations promulgated in accordance with section 316 (b) of the CWA for cooling water intake structures. The permi ttee shall submit the cooling water system assessment results to LDEQ no later than four (4) years from the effective date of this permit. Based on the information submitted to LDEQ, the permit may be reopened to incorporate limitations and/or requirements for the CWIS.
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| The assessment of the cooling water system must include the following:
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| An assessment of the cooling water system which includes a discussion or description of how structural or operational actions currently in place reduce adverse environmental impacts caused by your CWIS, and a discussion of additional structural or operational actions, if any, that have been reviewed or evaluated as possible measures to further reduce environmental impacts caused by your CWIS.
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| STORMWATER POLLUTION PREVENTION PLAN (SWPPP3) REQUIREMENT In accordance with LAC 33:IX.2707.I.3 and 4, a Part II condition is proposed for applicability to all stormwater discharges from the facility, either through permitted outfalls or through outfalls which are not listed in the permit or as sheetflow. For first time permit issuance, the Part II condition requires a Storm Water Pollution Prevention Plan (SWP3) within six (6) months of the effective date of the final permit. For renewal permit issuance, the Part II condition requires that the Storm Water Pollution Prevention Plan (SWP3) be reviewed and updated, if necessary, within six (6) months of the effective date of the final permit. If the permittee maintains other plans that contain duplicative information, those plans could be incorporated by reference to the SWP3. Examples of these type plans include, but are not limited to: Spill Prevention Control and Countermeasures Plan (SPCC), Best Management Plan (BMP),
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| Response Plans, etc. The conditions will be found in the draft permit.
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| Including Best Management Practice (BMP) controls in the form of a SWP3 is consistent with other LPDES and EPA permits regulating similar discharges of stormwater associated with industrial activity, as defined in LAC 33:IX.2522.B.14
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| [40 CFR 122.26(b) (14)].
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| : 12. Compliance History/DMR Review:
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| A. Inspections: There was an inspection at the facility on November 25, 2008. All areas evaluated were found to be satisfactory. (EDMS A-109
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 46 Doc No. 39933315)
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| B. Enforcement Actions (COs, NOVs, Warning Letters, etc.): N/A EPA has does not have Enforcement Authority of this facility.
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| : c. DMRs: A DMR review was retrieved from ICIS. No excursions were found for the last 3 years. All DMR's were submitted in accordance with the existing permit.
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| D. Company Compliance History: AI1 email was sent to Office of Environmental Compliance on May 19, 2010, for a list of open enforcement actions for this facility. To date, there has been no response.
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| E. Permit Actions Taken: N/A Please be aware that the Department has the authority to reduce monitoring frequencies when a permittee demonstrates two or more consecutive years of permit compliance. Monitoring frequencies established in LPDES permits are based on a number of factors, including but not limited to, the size of the discharge, the type of wastewater being discharged, the specific operations at the facility, past compliance history, similar facilities and best professional judgment of the reviewer. We encourage and invite each permittee to institute positive measures to ensure continued compliance with the LPDES permit, thereby qualifying for reduced monitoring frequencies upon permit reissuance. As a reminder, the Department will also consider an increase in monitoring frequency upon permi_t reissuance when the permittee demonstrates continued non-compliance.
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| : 13. Wate~ Quality Consideratons:
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| . Subsegment 070301 is not listed on LDEQ' s Final 2006 303 (d) List as impaired, and to date no TMDL's have been established.
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| Subsegment 020202 is listed on LDEQ's Final 2006 303(d) List as impaired for dissolved oxygen. To date no TMDLs have been completed for this waterbody. A reopener clause will be established in the permit to allow for the requirement of more stringent effluent limitations and requirements as imposed by a TMDL. Until completion of TMDLs for the Barataria Basin, those suspected causes for impairment which are not directly attributed to the steam electric generating station point source category have been eliminated in the .formulation of effluent limitations and other requirements of this permit. Additionally, suspected causes of impairment which could be attributed to pollutants which were not determined to be discharged at a level which would cause, have the reasonable potential to cause or contribute to an excursion above any A-110
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 47 present state water quality standard were also eliminated.
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| Based on the evaluation of the discharges from this facility, it was determined that the facility has the potential to discharge pollutants which may contribute to the dissolved oxygen impairment of the receiving waterbody. However, compliance with the limitations established in the permit should not result in the discharge of pollutant concentrations which would cause or contribute to the further impairment of water quality standards.
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| : 14. Endangered Species:
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| The receiving waterbody, Subsegment 070301 of the Mississippi River Basin, has been identified by the U.S. Fish and Wildlife Service (FWS) as habitat for the Pallid Sturgeon, which is listed as threatened and/or endangered species. This draft permit has been submitted to the FWS for review in accordance with a letter dated January 5, 2010, from Rieck (FWS) to Nolan (LDEQ) . As set forth in the Memorandum of Understanding between the LDEQ and the FWS, and after consultation with FWS, LDEQ has determined that the issuance of the LPDES permit is not likely to have an adverse effect upon the Pallid Sturgeon. The effluent limi_tations established in the permit ensure protection of aquatic life and maintenance of the receiving water as aquatic habitat. Therefore, the issuance of the LPDES permit is not likely to have an adverse effect on any endangered or candidate species or the critical habitat.
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| The receiving waterbody, Subsegment 020202 of the Barataria Basin is not listed in Section II. 2 of the Implementation Strategy as requiring consultation with the U.S. Fish and Wildlife Service (FWS). This strategy was submitted with a letter dated January 5, 2010 from Rieck (FWS) to Nolan (LDEQJ . Therefore, in accordance with the Memorandum of Understanding between the LDEQ and the FWS, no further informal (Section 7, Endangered Species Act) consultation is required. The effluent limitations established in the permit ensure protection of aquatic life and maintenance of the receiving water as aquatic habitat. Therefore, the issuance of the LPDES permit is not likely to have an adverse effect on any endangered* or candidate species or the critical habitat.
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| A-111
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| Fact Sheet and Rationale for Entergy Operations, Inc., Waterford 3 Steam Electric Station LA0007374, AI No. 35260 Page 48
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| : 15. Historic Sites:
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| The discharge is from an existing facility location, which does not include an expansion on undisturbed soils. Therefore, there should be no potential effect to sites or properties on or eligible for listing on the National Register of Historic Places, and in accordance with the "Memorandum of Understanding for the Protection of Historic Properties in Louisiana Regarding LPDES Permits" no consultation with the Louisiana State Historic Preservation Officer is required.
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| : 16. Tentative Determination:
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| On the basis of preliminary staff review, the Department of Environmental Quality has made a tentative determination to reissue a permit for the discharge described in the application.
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| : 17. Public Notices:
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| Upon publication of the public notice, a public comment period shall begin on the date of publicatio"n and last for at least 30 days thereafter.
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| During this period, any interested persons may submit written comments on the draft permit and may request a public hearing to clarify issues involved in the permit decision at this Office's address on the first page of the fact. A request for a public hearing shall be in writing and shall state the nature of the issues proposed to be raised in the hearing.
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| Public notice published in:
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| Local newspaper of general circulation Office of Environmental Services Public Notice Mailing List A-112
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| FRESHWATER ACUTE BlOMONJTORJNG FREQUENCY RECOMMENDATION AND RA TI ON ALE FOR ADDITIONAL REQUIREMENTS Pennit Number: LA0007374 Facility Name: Entergy Operations, Inc./Waterford 3 Steam Electric Station Previous Critical Biomonitoring Dilution: 46% (10:1 ACR)
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| Proposed Critical Biomonitoring Dilution: 31 % (10:1 ACR)
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| Outfall Discharge Flow: 994 MGD Receiving stream 7QJO: 141,955 cfs Date of Review: 01/15110 Name of Reviewer: Laura Thompson Recommended Frequency by Species:
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| Pimeplwles promelas (Fathead minnow): Oncc/Quarter 1 1
| |
| Daplmia pulex (water flea): Once/Quarter Recommended Dilution Series: 13%, 18%, 24%, 31%, and 42%
| |
| Number of Tests Perfonned during previous 5 years by Species:
| |
| Pimepha/es promelas (Fathead minnow): 11 Daplmia pulex (water flea): 11 Ceriodaplmia dubia (water flea): NI A - Testing of species was not required Number of Failed Tests during previous 5 years by Species:
| |
| Pimephales promelas (Fathead minnow): No failures on file during the past 5 years Daplmia pulex (water flea): No failures on file during the past 5 years Ceriodaplmia dubia (water flea): NIA - Testing of species was not required Failed Test Dates during previous 5 years by Species:
| |
| Pimephales promelas (Fathead minnow): No failures on file during the past 5 years Daplmia pulex (water flea): No failures on file during the past 5 years Ceriodaplwia dubia (water flea): NI A - Testing of species was not required Previous TRE Activities: NIA- No previous TRE Activities 1
| |
| If there are no lethal effects demonstrated after the first year of quarterly testing, the pennittee may certify fulfillment of the WET testing requirements in writing to the permitting authority. If granted, the biomonitoring frequency for the test species may be reduced to not Jess than once per year for the less sensitive species (usually Pimephales promelas) and not less than twice per year for the more sensitive species (usually Daphnia pulex).
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| Upon expiration of the permit, the biomonitoring frequency for both species shall revert to once per quarter until the permit is re-issued.
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| Page I of2 A-114
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| | |
| FRESHWATER ACUTE Additional Requirements (including WET Limits) Rationale I Comments Concerning Pennitting:
| |
| Entergy Operations, Inc./\Vaterford 3 Steam Electric Station owns and operates a steam electric generating facility in Killona, St. Charles Parish, Louisiana. LPDES Permit LA0007374, effec1iyc February 1, 2003, contained acute freshwater biomonitoring as an effluent characteristic of Outfall 001 for Pimep!tales prome/as and Daplwia pule.x. The effluent series consisted of 19 1!-'o, 26%, 34%, 46%, and 61 % concentrations, with 46% being defined as the critical biomonitoring dilution. Testing was to be performed quarterly for both Pimep!ta/es promelas and Dap/mia pule..'C. Data on file indicate that the permittee has complied with the biomonitoring requirements contained in LA0007374 with no toxicity failures in the last five years.
| |
| It is recommended that freshwater acute biomonitoring be an effluent characteristic of Outfall 001 (continuous discharge of 994 mgd of once through non-contact cooling water, and previously monitored intermittent discharges including but not limited to steam generator blowdown, cooling tower blowdown, metal cleaning wastewater, low volume wastewater, and stormwater) in LA0007374. The effluent biomonitoring dilution series shall be 13%, 18%, 24%, 31 %, and 42% concentrations, with the 31 % effluent concentration being defined as the critical biomonitoring dilution (the 10: 1 Acute-to-Chronic ratio has been implemented). In accordance with the Environmental Protection Agency (Region 6) WET testing frequency acceleration(s), the biomonitoring frequency shall be once per quarter for Daplmia pulex and Pimephales prome/as. If there are no significant lethal effects demonstrated at or below the critical biomonitoring dilution during the first four quarters of testing, the permittee may certify fulfillment of the WET testing requirements to the permitting authority and WET testing may be reduced to not less than once per six months for the more sensitive species (usually Daplmia pulex) and not less than once per year for the less sensitive species (usually Pimephales promelas) for the remainder of the term of the permit. Upon expiration of the permit, the biomonitoring frequency for both test species shaJI revert to once per quarter until the permit is re-issued.
| |
| This recommendation is in accordance with the LDEQ/OES Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards, Water Quality Management Plan Volume 3. Version 6 (April 16, 2008), and the Best Professional Judgment (BPJ) of the reviewer.
| |
| Page 2 of2 A-115
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| | |
| Appendix B Water Quality Calculations &
| |
| Explanations A-116
| |
| | |
| wqsmodn.wk4 Date: 04/U Appendix E-1 Page l Developer: Bruce Fielding Soft~are: Lotus 4.0 LA0001314, AI352GG Revision date: OB/07/08 Water Ouality Screen for Entergy Operations, !nc.iWaterford J Input variables:
| |
| ~eceiving Water Characteristics: Dilution: Toxicity Di.lucion series:
| |
| ZID Fs = 0.0333JJ Siomoni toring dlh.:ticn; O.Jl .. 796 Receiving Water Name= Mississippi River Dilution Series Factor: 0.75 Critical flew (Qr) cfsc 1-11955 MZ Fs = 0.333333 Harm. mean/avg tidal cfs= 366748 critical Qr {MGDJ= 9174~.52 Percent. Effluent Drinking Water-1 HHNPCR=2 Harm. Mean (MGD)* Dilution No. 41.973%
| |
| MW=l, BW=-2, O=n ZID Dilution
| |
| * Dilution No. .31.4799\
| |
| Rec. Water Hardnessc 153.' MZ Dilution = 0.0314B Dilution No. 23 609S%
| |
| Rec. Water TSS= 32 HHnc Dilution= 0.010718 Dilution No. 4 17.7074%
| |
| Fisch/Specific=!,Stream~o HHc Dilution"" 0.004176 Dilution No. 13.2EOSt:
| |
| Diffuser Ratio= ZIO Upstream = 3.076644 MZ Upstream = 30.76644 Partition coet fic::i.ents; Dissolved- - >Total Effluent Characteristics: MZhhnc Upstream= 92. 29931 Permi ttee= Entergy Operations, lnc./Waterford J* METALS FW Penni t Number= LA0007374, AI35260 Tot.al Arsenic .223578 Facility flow (Qef),MGD= 994 MZhhc Upstream= 238.46 Total Cadmium 3 .545'121 ZID Hardness- Chromium I I! 5.282524 Outtall Number = 001 MZ Hardness= Chromium VI Eff. data, 2=lbs/day ZID TSS= Total Copper 3.56079 MQL, 2=lbs/day MZ TSS= Total Lead 6.6 Effluent Hardness~ N/A Multipliers: Total Mercury 2.785159 Effluent TSS= N/A WLAa LTAa 0.32 Total Nickel J..1?4756 WQBL ind. O*y, l*n WLAc LTAc 0.53 Total Zinc 4.535534 Acute/Chr. ratio O=n, i~y LTA a,c--::.WQBL avg l.31 Aquatic,acute onlyl=y,O=n LTA a 1 c-->WQBL max 3 .11 Aquatic Life, Dissolved LTA h -*> WQBL max 2.38 Metal Criteria, ug/L Page Numbering/Labeling WOBL-limit/report 2.13 METALS ACUTE CHRONIC Appendix Appendix B-1 WLA Fraction Arsenic 339. 8 150 Page Numbers l=y, O=n WQBL Fraction Cadmium S0.5572 1.414322 Input Page U l=y, O=n Chromium III 779.0334 252.?104 Conversions: Chromium VI 15.712 10.582 li"ischer/Site specific inputs: ug/L-->lbs/day Qef B.28996 Copper 27. 5752 17. 70626 Pipe~l.Canal=2,Specific=3 ug/L-->lbs/day Qeo Lead 102 .5669 3. 996886 Pipe width, feet ug/L-->lbs(day Qr 1183.905 Mercury l. ?31 0.012 ZlD plume dist., feet lbs/day-->Ug/L Qeo 0.120628 Nickel 2032.7/5 ~25.756 MZ plume dj st., feet lbs/day-->ug/L Qef 0.120628 Zinc 164.4582 150.1753 HHnc plume dist., feet diss--~tot l~yo~n HHc plume dist.. feet Site Specific Multiplier Values:
| |
| cfs~->MGD 0.6463 r:v
| |
| * Pischer/site specific dilutions: N =
| |
| *i luticn = Receiving Stream: WLAa F/speci!ic MZ Dilution = Default Hardness= 25 WI.Ac LTP.c F'/specific HHnc D:ilution~ Default TSSt: 10 LTA a,C-->WQBL avg F/specif ic HHc Dilution= 99 Crit., l=y, O=n LTA a,C-->WQBL max LTA h - - > WQBL max A-117
| |
| | |
| Appendix B-1 Page Entergy operations, Inc./Waterford J LA0007J74, A135260
| |
| { *2> ( *)) ( "'4 l I *S) ('6) (. 7) I* 8 l {" 9; ! *10) I* 11 l Toxic Cu Ef!luent E!"fluent. MQL Effluent 9Sth Numer.ical C:--ite:-ia HH Parameters Inst ream /Tech iTech l=NO 95\ estimate Acute Chronic HHDW Can:inogen cone. {Avg) (Max) 0:95 Non-Tech F1< PW Indicator ug/L lbs/day lbs/day ug/L lbsiCay ug/L ug/L ug/L "C" NONCONVENTICN;...L Total Phenols t*H..A?) 700 350 3 -Chl()rophcnol 10 0.1 4 **Chlorophencl 10 3 83 192 0.1 2,)-Dichlorophenol 10 0.04 2,5-Dichlcrophenol 10 0.5 2,6-Dichlcrophenol 10 0.2 3,4-Dichlorophenol 10 0. J 2,4-Dichlorophenocy-acetic acid (2,4-D) 100 2-(2,4,5-Trichlorophen-oxy} propicnic acid (2,4.5-TP, Silvex) 10 METALS AND CYANIDE Tot.al Arsenic 10 755.5719 JJ].5367 111.1789 Total Cadmium 179.036 5.013602 35.49121 Chromium II! 10 4115.263 133'1. 9'19 264.1262 Chromium VI 10 15. 712 10.582 so c Total Copper 10 98.18922 63.04811 3560 .78 Total Lead 676.9417 26.37945 33 0 Total Mercury 0.2 4.829466 0.033422 5.570319 Total Nickel 40 6453.566 716 7203 Total zinc 20 745.906 6 81 .1252 22677.67 Total Cyanide 20 45.9 s .4 663.8 DIOXIN 2,3j7,8 TCDD; dioxin l.OE-05 7. lE-07 c VOLATILE COMPOUNDS Benzene 10 224 9 1125 l. 1 c Bromoform 10 293 0 14 65 .9 c Bromodichlorcmethane 10 0. 2 c Carbon Tetrachloride 10 213(1 1365 0. 22 c Chlcroform 10 2890 14 *1 s 5. 3 c Dibromochlcrornethane 10 ]9 c l,2-Dichloroethane 10 llSOO 5900 . 36 c 1,1-DichJ.oroethylene 10 1160 580 05 c
| |
| ~.3-Dichlo~opropylene :o 606 }03 s. 86 Ethylbenzene 10 3200 1600 23 9-0 Methyl Chlcn. de 50 55000 27500 Methylene Chloride 20 19]00 !:-650 4. 4 c 1,1,2,2-Tetrachlorc-ethane 10 932 .; 66 Q. 16 c A-118
| |
| | |
| Appendix B-1 Page 3 Entergy Operat.ions, lnc. /Waterford J LA0007374, A!JS~60
| |
| {* 12) ~
| |
| * 13) 1* H) I* 15) 1"16) (* 17) c- 18) I* 20) (*21) { *22) ( "23)
| |
| TOXic WLAa HLA.c Wl..Ah LT A.a :..TAc L'IAh Limiting WQBL WQBL Ueed Paramete:-s ;..cute Chror.ic HHDW Acute C:hrcni.c HHDW A,C,HH Avg Max J.!ax WQEL?
| |
| 001 001 001 ug/!.. ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L lbs/day lbs/day NONCONVENTION!1L Total Phenols (4AAF) 2653,6506 llllS.253 466.4965£. 9l3.H82 58;;2.6741 466,4%$6 466,49656 466,49656 1110.2616 J967.2l7B 520L0261 no 3-Chloropheno1 ~.329S:312 :3.3299312 9.3295312 9.3299312 22.205236 77.344757 184.0905:!' r.o 4-Chlorophenol 1561.3546 6059.156 9.3-2'19312 499 633.;6 3232.5527 9.3299312 S.3299312 9.3299:?12 22.205236 77 ..144757 184.0SOS2 no 2,3-Dichlorophenol 3.7319725 3.7319725 l.7319725 3.7319125 8.8820945 30.937903 73,612208 no 2,5-Dichlorophenol 46,64%56 46.649656 46.64965G 46.6H65E 111.02618 366.72378 920.40261 no 2, 6-Dichlorophenol 19.f5~862 JS,659862 18.655862 H.659862 44.410473 154.68951 368.16104 no 3,4-Dichlorophenol :27.S89i94 27,999794 27.989794 27.989794 66,615709 232,03427 552.24156 no 2,4-Djchlorophenocy-3Cetic acid (2,4-D) 9329.S312 9329.9312 9329.9312 9329.9312 22205,236 77344.157 184080.52 no 2-(2,4,5-Trichlorophen-oxy) propiohic acid (2,4,5-TP, Silvex) --- 932.99312 --- 932,99312 932.99312 932.99312 2220,5236 7734.4757 18408,052 no METALS AND CYANIDE Tot.al Arsenic 3080,1974 10595.274 10372.916 985,66315 5615.4951 10372.916 965.66315 1291.2187 3065.4124 10704.152 25412.Hn no Total Cadmium 731.48697 159,45481 3311.3057 234,07583 84.51108 331L3057 84.51108 110.70951 262.82946 917.77745 2178.8457 no Chromium Ill 16776.46 42406.563 24642.791 5368.4671 22475.478 24642.791 5368,46717032.691916695.933 58300.7H 138408.61 *no Chromium VI 64.052227 336.15244 11973 20,496712 118.16079 11973 20.496712 26.850693 63,744776 222.59117 528.44164 no Total copper 400,28246 2002.8137 332218.36 128.09039 l06L49l3 332218.36 128.09039167.79841 398.3611 1391.0421 3302.3976 no Total Lead 2759.6501 E37. 961 30788, 773 883 .08802 444. 12993 30788. 773 444 .12993 581.81021 1381. 2441 4823, 1834 11450. 458 no Total Mercury 19.688014 l.C6l69::iJ 519.70691 &.3001645 0.5626994 519.70691 0.5626984 0.73713-49 l.749992 6,1108189 14.S.07364 no Total Nickel 26308,891 22;67,651 8418,8452 12066,855 8418.8452 11028.687 26182.n08 91427.375 217052,78 no Total Zinc 3040.7928 21636.923 2115811 973.05371 11467,569 2ll58ll 973.053711274.7004 3026.197 10567,215 25087.052 no Total Cyanide 187,11795 171.53876 6193:1.084 59,877743 90.915544 61932.084 59.877743 78.439844 186.21978 650,26317 1543.7545 no DIOXW 2,3,7,8 TCDO; dioxin 0.0!:>017 0.00017 0,00017 0.00017 0.0004046 0.0014094 0.0033544 no VOLATILE COMPOUNDS Benzene 9168.3718 35737.242 263.40599 2933.879 18940,738 263.40599 263,40599 23.40599 626.90626 2183.6251 5i97.0278 no Bromo!orm 11944.566 46537.831 933.89397 3822.2612 24665.05 933.89397 933.89397 933,89397 2222.6676 7741.9437 18425,826 no Bromodichloromethane 47.891998 --- 47,891998 47.891998 47,891998 113.58296 397.02275 944.91415 no Carbon Tetrachloride 11129.237 43361.187 52,681198 3561.356 22981.429 52.681198 52.681198 52.681:98 125.38125 436.72503 1039,4056 no Chloroform 11781.5 .;5,02.502 1269.lJ:B 3770.0801 .24328.326' 1269.139 !269.138 1269.138 3020.5483 10S21.1C3 25040.225 no Dihromochloromethane 93,389397 93.389397 93.389397 93,389397 222,26676 774.19437 1842,5826 1,2-Dichloroethane 46104,396 18712l.9E S6.205597 15393.407 99333.GS 8G.20SS9'7 86.20559'7 86.205597 205.16932 114.64095 11C(LS455 no l,l-Dichlorcethylene ll .973 151'.?i.2.SO:t S1'f.5,0029 11.~13 11. 91 J 11.913 28.495739 99.255666 ;)3.22054 no 1, 3-Di chloropropylene 2ot70.~16l ~62S.2305 9l~.<J3122 790.54276 5101.37.2.2 9'19.93122 790.542?6 1035.611 2158.598 9585.1739 203-Bl.596 no Ethylbem:ene l.3045 26 SOS26.3 222595.36 4174 "iiE-32 2653'2.939 222ses.J6 .;174_.;932 5468.573 12982.643 4.5334.251 l0162S.S9 no Methyl Chloride 224215,41 813517 03 71149.93 .;62995.63 717.;S.SJ ~J99I.OS'8 223139.17 779182.44 184901-i 9 no Methylene Chloride 78679,224 .306S46 12 105:!.62.; 2511"'!'.352 162 .. 69 . .;.; 1953.624 1053.E24 1053.62.; 2501.'625 8734.SOOS 20788 lll no l,!,2,2*Tetrachloro-ethane j799 .. 32 i.;~o~.16 :?S.3l35!:9 1215.Sl82 7815.6717 3S.31JS99 Je.313599 38.313599 91.186365 311 6192 755.93132 no A-119
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| | |
| ;\p~endJ x B-1 Fage 4 E..!tergy Operatior.s, Inc. /Watel.*ford LA.0007374, AI3526C*
| |
| (
| |
| * l} [*2) ( .. 3f ("'i) { ~ s) i "6) ( *7) c*el 1 *9) (* 10) (*Jl)
| |
| TO:XlC Cu Effluent Effluent. V.OL Effluent 95th Numerical crite1*ia HH
| |
| ?a:rameters Inst ream /Tech /Tech l=NO 95% estimate Acute chronic HHm..: Carci:iogen Cone. \Avg) (Max) 0~9s \ Ncn*Tech FW FW !ndicator ug/L lbs/day lbs/day ug/L lbs/day ug/L ug/L ug/!.. "C" IJOLi..TlLE COMPOUNDS' {cont 'di 7etrachlorcethylene 10 1290 e.; s 0.65 c Tolut:ne 10 1270 635 6100 1, 1.1-Trichlo::'."oethane 10 5260 2640 200 1,1,2-Trichloroethane 10 1800 SOD 0.56 c Trichloroethylene 10 3900 1950 2.8 c Vinyl Chloride 10 1. 9 c ACID COMPOffiJDS 2 - Chl orophenol 10 258 129 0. J 2,4-Dichloroph~nol 10 202 101 0.3 B/\SE NEUTRAL COMPOUNDS Benzi dine so 250 125 0.00008 c Hexachlorobenzene 10 0.00025 c Hexachlorabutadiene 10 5.1 1.02 0.09 c PESTICIDES Aldrin 0.05 3. 0. 00004 c Hexachlorocyclchexane (gamma BHC, Lindane) 0.05 5.3 0.21 0.11 c Chlordane 0 .2 2.4 0.0043 0.00019 c 4, 1 1
| |
| -DDT 0.1 1.1 0.001 0.00019 c 4, 4 '-ODE 0.1 52.5 10.5 0.00019 c 4, 4 '-DDD 0 .1 0.03 0.006 c. 00027 c Dieldrin 0 .1 0. 23 74 0.0557 0.00005 c Endosultan 0 .1 0.22 0.056 Q _47 Endrin 0 .1 0.0864 0.0375 0.26 Heptachlor 0.05 0.52 0.0038 0.00007 c
| |
| : 0. 014 Toxaphene 0.73 0.0002 0.00024 c Othe~ Parameters.
| |
| Fecal Col. lcol/100ml)
| |
| Chlorine 19 Ammonia Chlorides Sulfates TDS A-120
| |
| | |
| Appendix B-l Page Entergy Ope rat ions, Inc. /wa terf ord 3 LA000/374, AD5260
| |
| (* 1} t *12) t*13) (* 14) (*lS) {
| |
| * 16 J (*.17) 1*10 J {
| |
| * 191 ( *20; (. 21) ( *22) i. 2J}
| |
| Toxic WLJ..a WLA.c WLJ..h LTAa LTAc LTl\h Limiting '1QBL WQSL WQBl, WQBL Need Pararr.eters Acute Chronic HHDW Acute Chrcnic HHD>; A,C.HH Avg Max Avg Mal\ WQE'L?
| |
| 001 OOl OCl 001 ug/L ug/L ug/L ug/L ug/L ug/L ug/!.. ug/L ug/L lbs/day lbs/day Tetrachloroethyl~ne 5258.8704 2018~.352 155.649 1GB2.8385 10859.357 155.649 lSS.619 lS~.6.;s :no 4':461 1290.3239 30?0.971 no Toiuene 5177.3376 20171.ESS 5691:?5.Sl 1656,1.;S 10690.995 56.9125.81 1656.74e 2170.3399 5152.466~ !1992.03142713.506 no 1,1,l-Trichloroethane 21524.679 83863.395 18659.86~ 6681.891~ 44447,599 18659.862 6867.8973 9023.1454 21421.361 '14801.515 l7?5B2.22 no l,l,2-Trichloroethane 7337.9587 28599.794 134.0976 2J.;S.l46S 15152.SSl 13*4.0976 134.0976 134.0976 319.15228 1111.6637 2645.7596 nc Tr ich loroethylenc 15899.911 61944.553 670.48798 5001.6514 32830.613 670.rn798 610.48198 670.48799 1595.7614 5559.3185 1322s.ns no Vinyl Chloride: --- 45-t.97399 --- 454.97399 454.9*399 454.97399 1082.B381 3771.7161 8916.6844 no ACJ D COMPOUNDS 2-Chlorophencl 1051.7741 4091.0104 9,3299312 336.56771 211i.0113 9.3299312 9.3n9312 9.3299312 22.205236 77.344757 194.08052 nc 2,4-Dichlorcphenol 823.48204 3208.4102 27.989794 263.51425 1700.4574 27.969794 27.989794 27.989794 66.615709 232.03'27 552.24156 no BASE NEUTRAL CD~POUNDS Benzi dine 1019 1609 3970.8047 0.0191568 326.1315 2104.5265 0.0191568 0.0191568 0.0191568 0.0455932 0.1588091 0.3779657 no Hexachloroben2ene 0. 059865 0.059865 0.059865 0.059865 O.H2'787 0.4962784 l.1811427 no Hexachlorabutadiene 20.790883 32.401766 21.551399 6,,6530826 17.172936 21.551399 6.6530026 8.7155392 20.691087 72.251463 171.52828 no PESTICIDES Aldrin 12 .229931 --- 0.0095784 3.913578 --- 0.0095784 0.0095784 0.0095784 0.0227966 0.0794046 0.1889028 no Hexachlorocyclohexane (gamma BHC, Lindane) 21.606212 6.6709519 26.340599 6.9139878 3.5356045 26.340599 3.5356045 4.6316419 10.99573 38.396126 91.154162 no Chlo:rdane 9.783945 0.1365957 0.0454974 3.1308624 0.0723957 0.0454974 0.0454974 0.0454974 0.1082838 0.3771716 0:8976684 no
| |
| : 4. 4 -DDT I 4.4943081 0.0317664 0.0454974 1.4349786 0.0168362 0.0454974 O.til68362 0.0220554 0.0523606 0.1828387 0.1340674 no 4,4'-0DE 214.0238 333.54759 0.0454974 69.487615 176.78022 0.0454974 0.0454974 .0454974 0.1082838 0.3771716 0.6976694 no 4 ,4 '-DOD 0.1222993 0.1905986 0.0646542 0.0391358 0.1010173 0.0646542 0.0391358 0.0512679 0.1217123 O.U50086 l.0089859 no Dieldrin 0.9677952 1.7693906 0.011973 0.3096945 0.93'1777 O.Oll973 0.011913 0.011973 0.0284957 0.0992557 0.2362285 no Endosul fan 0.8968616 l.7799205 43.850677 0.2869957 0.9428279 43.850677 0.2869957 0.3'759644 0.0925567 3.1167298 7.3992592 no Endrin 0.352222 1.1912114 24.257821 0.112711 0.631JS'79 24.257821 0.112711 0.1476515 0.3505311 l.2240248 2.9058909 no Heptachlor 2 1199547 o.;201125 0.0167622 o.6783535 0.0639?76 0.0167622 0.0161622 o.0167622 o.039894 o.138958 o.33072 no Toxaphene
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| * 2.9759<99 0.0063533 0,0574104 0.952304 0.0033612 0.0574704 0.0033672 0.0044111 0.0104721 0.0365677 0.0668135 no OtheI Parameters:
| |
| Fecal Col. fcol/l OOml J no Chlod r.e I; .456231 J49 43081 21. 785994 105.19933 24.7S5994 32.46.9652 77.081~41 269.17212 639.02693 no Am@onia no Chlorides no Sul fates no TDS no nc no A-121
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| | |
| APPENDIX B-2 LA0007374, AI No. 35260 Documentation and Explanation of Water Quality Screen and Associated Lotus Spreadsheet Each reference column is marked by a set of parentheses enclosing a number and asterisk, for example (*l) or (~19). These columns represent inputs, existing data sets, calculation points, and results for determining Water Quality Based Limits for an effluent of concern. The following represents a sununary of information used in calculating the water quality screen:
| |
| Receiving Water Characteristics:
| |
| Receiving Water: Mississippi River Critical Flow, Qrc (cfs): 141,955 Harmonic Mean Flow, Qrh (cfs): 366,758 Segment No.: 070301 Receiving Stream Hardness (mg/L): 153.4 Receiving Stream TSS (mg/L): 32 MZ Stream Factor, Fs: 1 Plume distance, Pf: N/A Effluent Characteristics:
| |
| 9ompany: Entergy Operations, Inc.
| |
| Outfall 001 flow, Qe (MGD): 994 Effluent Hardne~s: N/A Effluent TSS: N/A Pipe/canal width, Pw: N/A Permit Number: LA0007374 Variable Definition:
| |
| Qrc, critical flow of receiving stream, cfs Qrh, harmonic mean flow of the receiving stream, cfs Pf= Allowable plume distance in feet, specified in LAC 33:IX.1115.D Pw = Pipe width or canal width in feet Qe, total facility flow , MGb Fs, stream factor from LAC.33.IX Chapter 11 (1 for harmonic mean flow)
| |
| Cu, ambient concentration, ug/L Cr, numerical criteria from LAC.33.IX.1113, Table 1 WLA, wasteload allocation LTA, long term average calculations WQBL, effluent water quality based .limit ZID, Zone of Initial Dilution in % effluent MZ, Mixing Zone in % effluent Formulas used in aquatic life water quality screen (dilution type WLAJ:
| |
| Streams:
| |
| Dilution Factor e (Qrc x 0.6463 x Fs + Qe)
| |
| A-122
| |
| | |
| f\.ppendix B-2 LA0007374, Al No. 35260 Page 2 WL.Z\ a,c,h Cr - (Fs x Qrc x 0.6463 x Cul Di2.ution factor Qe Static wa~er bodies (in the absence of a site specific dilution):
| |
| Discharge from a pipe: Discharge from a canal:
| |
| Critical Critical Dilution (2. 8) Pw r: 11 ; Dilution {2 . 3 8 l ( Pw 112 )
| |
| Pf (Pf) in
| |
| \"1LA (Cr-Cu) Pf WL.Z\ (Cr-Cu) Pf 112 (2.8) Pw n 1 n 2.38 Pw 112 Formulas used in human health water quality screen, human health non-carcinogens (dilution type WLA):
| |
| Streams:
| |
| Dilution Factor e (Qrc x 0.6463 + Qe)
| |
| WLA a,c,h Cr - (Qrc x 0.6463 x Cu)
| |
| Dilution Factor Qe Formulas used in human health water quality screen, human health carcinogens (dilution type WLA) :
| |
| Dilution Factor = e (Qrh x 0.6463 + Qe)
| |
| WLA a,c,h Cr - (Qrh x 0.6463 x Cu)
| |
| Dilution Factor Qe Static water bodies in the absence of a site specific dilution (human health carcinogens and human health non-carcinogens):
| |
| Discharge from a pipe: Discharge from ~ canal:
| |
| Critical Critical Dilution (2.8) Pw n 112 Dilution (2.381 (Pw 112 )
| |
| (Pf) 112 l?f (Cr-Cu) Pf* WLA (Cr-Cul Pfl/ 2 *
| |
| ( 2 . 8 ) Pw n 112 2. 38 Pw; 12
| |
| ~ Pf is set equal to the mixing zone distance specified in LAC 33:IX.1115 for the static *..iater body type, i.e., lake, estuary, Gulf of Mexico, etc.
| |
| A-123
| |
| | |
| Appendix B-2 LA0007374, AI No. 35260
| |
| ?age 3 If a site specific dilution is used, WLA are calculated by subtracting Cu from Cr and dividing by the site specific dilution for human health and aquatic life criteria.
| |
| \'JLA = (Cr-Cu) site specific dilution Long Term Average Calculations:
| |
| LTAa WLAa X 0.32 LTJl.c WLAc X 0.53 LTAh WLAh WQBL Calculations:
| |
| Select most limiting LTA to calculate daily max and monthly avg WQBL If aquatic life LTA is more limiting~
| |
| Daily Maximum= Min(LTAa, LTAc) X 3.11 Monthly Average = Min(LTAc, LTAc) X 1.31 If human health LTA is more limiting:
| |
| Daily Maximum = LTAh X 2.38 Monthly Average = LTAh Mass Balance Formulas:
| |
| mass (lbs/day): (ug/L) X 1/1000 X (flow, MGD) X 8.34 =lbs/day concentration(ug/L): lbs/day = ug/L (flow, MGC) X 8.34 X 1/1000 The following is an explanation of the references in the spreadsheet.
| |
| (*l) Parameter being screened.
| |
| (*2) Instrearn concentration for the parameter being screened in ug/L. In the absence of accurate supporting data, the instream concentration is assumed to be zero (0) .
| |
| (*3) Monthly average effluent or technology value*in concentration units of ug/L or mass units of lbs/d~y. Units determined on a case-by-case basis as appropriate-to the particular situation.
| |
| (*4) Daily maximum technology value in concentration units 9f ug/L or mass units of lbs/day. Units determined on a case-by-case basis as appropriate to the particular situation.
| |
| (*5) Minimum analytical Quantification Level.s (MQLs). Established. in a letter dated January 27, i994 from Wren Stenger of EPA Region 6 to Kil ren *Vidrine of LDEQ and fr.om the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards". The applicant must test for the parameter at a level at least as sensitive as the specified MQL. If this is not done, the MQL becomes the application value for screening purposes if the pollutant is suspected to be present A-124
| |
| | |
| Appendix B-2 LA0007374, AI No. 35260 Page 4 on-site and/or in the waste stream. Units are in ug/1 or lbs/day depending or. the units of the effluent data.
| |
| (*6} States whether effluent data is based on 95th percentile estimation. A "l" indicates that a 95th percentile approximation is being used, a "0" indicates that no 95th percentile approximation is being used.
| |
| (*7) 95th percentile approximation multiplier (2.13). The constant, 2.13, was established in memorandum cf understanding dated October 8, 1991 from Jack Ferguson of Region 6 to Jesse Chang of LDEQ and included in the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards". This value is screened against effluent Water Quality Based Limits established in columns (*18) - (*21). Units are in ug/l or lbs/day depending on the units of the measured effluent data.
| |
| (*8) LAC 33.IX.1113.C.6, Table 1, Numerical Criteria for Specific Toxic Substances, freshwater ( FW) or marine water (MW) (whichever is applicable) aquatic life protection, acute criteria. Units are specified. Some metals are hardness dependent. The hardness of the receiving stream shall generally be used, however a flow weighted hardness may be determined in site-specific situations. Dissolved metals are converted to Total metals using partition coefficients in ac~ordance with the "Permitting Guidance Document for *Implementing Louisiana Surface Water Quality Standards". Similar: to hardness, the TSS of the receiving stream shall generally be used, however, a flow weighted TSS may be determined in site-specific situations.
| |
| Hardness Dependent Criteria:
| |
| Metal Formula Cadmium e(l.1280(1n(hardness)] - 1.6774)
| |
| Chromium III e(0.8190(ln(hardness)J + 3. 6880)
| |
| Copper e(0.9422(ln(hardness)] - J. 3884)
| |
| Lead e(l.2730(ln(hardness)) - 1. 4600)
| |
| Nickel e(0.8460(ln(hardness)] + 3.3612)
| |
| Zinc e !O. 8473 (ln !hardness I J + 0.8604)
| |
| Dissolved to Total Metal Multipliers for Freshwater Streams (TSS dependent) :
| |
| Metal Multiolier Jl.rsenic 1 + 0. 4 8 x TSS-o. 73 x TSS Cadmium 1 + 4. 00 x TSS-l. 13 x TSS Chromium III 1 + 3.36 x TSS-0.93 x TSS Copper 1 + 1. 04 x TSs- 0
| |
| * 74 x TSS Lead 1 + 2.80 x TSS-c.eo x TSS Mercury 1 + 2.90 x TSS-1. 14 x TSS Nickel 1 + 0. 4 9 x rss-o.s1 x TSS Zinc 1 + 1. 25 x TSS-0.10 x TSS Dissolved to Total Metal Multipliers for Marine Environinents (TSS dependent) :
| |
| Metal Multiplier A-125
| |
| | |
| l\ppendix B-2 LA0007374, AI No. 35260 Page 5 Copper 1 + (104.86 x TSS-0.72 x TSS) x 10-E Lead 1 + (106.06 x TSS-0.80 x TSS) x 10-6 Zinc 1 + (105.36 x TSS-0.52 x TSS) x 10- 6 If a metal does not have multiplier listed above, then the dissolved to total metal multiplier shall be 1.
| |
| (*9) LAC 33.IX.1113.C.6, Table 1, Numerical Criteria for Specific Toxic Substances, freshwater ( FW) or marine water (MW) (whichever is applicable) aquatic life protection, chronic criteria. Units are specified. Some metals are hardness dependent. The hardness of the receiving stream shall generally be used, however a flow weighted hardness may be determined in site-specific situations. Dissolved metals are converted to Total metals using partition coefficients in accordance with the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards". Similar to hardness, the TSS of the receiving stream shall generally be used, however, a flow weighted TSS may be determined in site-specific situations.
| |
| Hardness dependent criteria:
| |
| Metal Formula e(0.7852[ln(hardness)] - 3.4900)
| |
| Cadmium e(0.8473[ln(hardness)] + 0.7614)
| |
| Chromium III Copper e(0.8545[ln(hardness)] - 1.3860) e(l.2730[ln(hardness) J 4.7050)
| |
| Lead e(0.8460[ln(hardness)] + 1.1645)
| |
| Nickel e(0.8473[ln{hardness)] + 0.1614)
| |
| Zinc Dissolved to total metal multiplier formulas are the same as (~8), acute numerical criteria for aquatic l~fe.protection.
| |
| (*10) LAC 33.IX.1113.C.6, Table 1, Numerical Criteria for Specific Toxic Substances, human health protection, drinking water supply (HHDW), non-drinking water supply criteria (HHNDW), or human health non-primarry contact recreation (HHNPCR) (whichever is applicable). A DEQ and EPA approved Use Attainability Analysis is required before HHNPCR is used, e.g., Monte Sano Bayou. Units are specified.
| |
| (*11) C if screened and carcinogenic. If a parameter is being screened and is carcinogenic a "C" will appear in this column.
| |
| (*12) Wasteload Allocation for acute aquatic criteria (WLAa) Dilution type WLAa is calculated in accordance with the "Permitting Guidance* Document for Implement.ing Louisiana Surface Water Quality Standards". Negative values indicate that the receiving water is not meeting the acute aquatic nume~ical criteria for that parameter. Units are in ug/L.
| |
| Dilution WLAa formulas for streams:
| |
| WLAa = (Cr/Dilution Factor) - IFs x Ore x 0.6463 x Cul Qe Dilution WLAa formulas for, static water bodies:
| |
| WLAa = (Cr-Cul/Dilution Factor)
| |
| Cr represents aquatic acute numerical criteria from column (*.BJ.
| |
| If Cu data is unavailable or inadequate, assume Cu=O.
| |
| A-126
| |
| | |
| J\ppendix B-2 LA0007374, AI No. 35260 Page 6 If water quality standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then a blank shall appear in this column.
| |
| (*13) Wasteload .Z\llocation for chronic aquatic criteria (WLAc). Dilution tvoe WLAc is calculated in accordance with the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards". Negative values indicate that the receiving water is not meeting the chronic aquatic numerical criteria for that parameter. Units are in ug/L.
| |
| Dilution WLAc formula:
| |
| WLAc = (Cr/Dilution Factor) - (Fs x Qrc x 0.6463 x Cu)
| |
| Qe Dilution WLAc formulas for static water bodies:
| |
| WLAc = (Cr-Cul/Dilution Factor)
| |
| Cr represents aquatic chronic numerical criteria from column (*9).
| |
| If Cu data is* unavailable or inadequate, assume Cu=O.
| |
| If water quality standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then a -blank shall appear in this column.
| |
| (*14) Wasteload Allocation for human health criteria (WLAh). Dilution type WLAh is calculated in accordance with the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards". Negative values indicate that the receiving water is not meeting the human health numerical criteria for that parameter. Units are in ug/L. Dilution WLAh tormula:
| |
| WLAh = (Cr/Dilution Factor) - (Fs x Qrc,Qrh x 0.6463 x_ Cul Qe Dilution WLAh formulas for static water bodies:
| |
| WLAh = (Cr-Cul/Dilution Factor)
| |
| Cr represents human health numerical criteria from column (*10).
| |
| If Cu data is unavailable or inadequate, assume Cu=O.
| |
| If water quality standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then a blank shall appear in this column.
| |
| (*15) Long Term Average for aquatic numerical criteria (LTAa). WLAa numbers are multiplied by a multiplier specified in the "Permitting Guidance Doc~~ent for Implementing Louisiana Surface Water Quality Standards" which is 0.32. WLAa X 0.32 = LTAa.
| |
| If water quality standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then a blank shall appear in this column.
| |
| (*16) Long Term Average for chronic numerical criteria (LTAc). WLAc numbers are multiplied by a multiplier specified in the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards" which is 0.53. WLAc X 0.53 = LTAc.
| |
| If water quality standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then a blank shall appear in this column.
| |
| (
| |
| * 1 7) Long Term Average for human heal th nu.rnerical criteria (LTAh) . WLAh numbers are multiplied by a multiplier specified in the "Permitting Guidance Document for Implementing Louisiana Surface Water Quality Standards" which is 1. WLAc X l = LTAh.
| |
| If water quality standards are being app.lied at end-of-pipe, such as in the case of certain TMDLs, then a blank shall appear in this column.
| |
| (*18) Limiting Acute, Chronic or Human Health LTA's. The most limiting LTA is placed in this column. Units are consistent with the vJLA calculation.
| |
| A-127
| |
| | |
| Appendix B-2 LA0007374, AI No. 35260 Page 7 If standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then the type of limit, Aquatic or Hurnan Health (HH), is indicated.
| |
| (*19) End of pipe Water Quality Based Limit (WQBL) monthly average in terms of concentration, ug/L. If aquatic life criteria was the most limiting LTA then the limiting LTA is multiplied by 1.31. to determine the average WQBL (LTA!imiting aquatic X 1. 31 = WQBLmonthly average). If human health criteria was the most limiting criteria then LTAh = WQBL:uonthly average* If water quality standards are being applied at end-of-pipe, iuch as in the case of certain TMDLs, then either the human health criteria or the chronic aquatic life criteria shall appear in this column depending on which is more limiting.
| |
| (*20) End of pipe Water Quality Based Limit (WQBL) daily maximum in terms of concentration, ug/L. If aquatic life criteria was the most limiting LTA then the lim.i ting LTA is multiplied by 3. 11 to determine the daily maximum WQBL (LTAlimiting aquatic X 3.11 = WQBLaaily maxl. If human health criteria was the most limiting criteria then LTAh is multiplied by 2.38 to determine the daily maximum WQBL (LTA!imiting aquatic X 2. 38 = WQBLcaily maxl.
| |
| If water quality standards are being applied at end-of-pipe, such as in the case of certain TMDLs, then either the human health criteria or the acute aquatic life criteria shall appear in this column depending on which is more limiting.
| |
| -(*21) End of pipe Water Quality Based Limit (WQBL) monthly average in terms of mass, lbs/day. The mass limit is determined by using the mass balance equations above. Monthly average WQBL, ug/l/1000 X facility flow, MGD X 8.34 =monthly average WQBL, lbs/day.
| |
| (*22) End of pipe Water Quality Based Limit (WQBL) monthly average in terms of mass, lbs/day. Mass limit is determined by using the mass balance equations above. Daily maximum lvQBL, ug/l/1000 X facility flow, MGD X 8.34 =daily maximum WQBL, lbs/day.
| |
| (*23) Indicates whether the screened effluent value(s) need water quality b.ased limits for the parameter of concern. A "yes" indicates that a water quality based limit is needed in the permit; a "no" indicates the reverse.
| |
| A-128
| |
| | |
| Invoice No. January 21, 2010 Page 1 LOUISIANA WATER POLLUTION CONTROL FEE SYSTEM RATING WORKSHEET PERMIT NO. LA0007374 AI NO. 35260 11.ctivity No.: PER20090001 1.a. Company Name Entergy Operations, Inc.
| |
| 1.b. Facility Name Waterford 3 Steam Electric Station 2 . Local Mailing Add res s_-=1:...7:..:2,,__6=5-=-R==i'-"v:..:e:;r=--:..:Rc.::o-=a~d=--------------------
| |
| Kil lona Louisiana 70057
| |
| : 3. Billing Address (If different) ________________________
| |
| 4.a. Facility Location 17265 River Road Killona 4.b. Parish St. Charles
| |
| : 5. Facility Type steam electric generating station
| |
| : 6. Products Produced._______________________________
| |
| 6.a. Raw materials stored or used _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
| |
| 6.b. By-products produced__________________________
| |
| : 7. Primary SIC Code 4911 7. a. Other SIC Codes _ _ _ _ _ _ _ _ _ _ __
| |
| : 8. Fae. Manager _ _ _ _ _ _ _ _ _ _ _ _ _ __ 8.a. Telephone _ _ _ _ _ _ _ _ __
| |
| : 9. Owner _________________ ~
| |
| 9.a. Telephone _ _ _ _ _ _ _ _ __
| |
| : 10. Env. Contact Rodney LeBlanc 10.a. Telephone (504)464-3267
| |
| : 11. State Permit No. _ _ _ _ _ _ _ __ 12. NPDES Permit No. LA0007374 11.a. Date Issued ____________ 12.a. Effective Date February 1, 2005 11.b. New_ _ _ _~Modified_ _ _ _ _ _~
| |
| 12.b. Expiration Date January 31, 2010
| |
| : 13. Number and Identification of Outfalls Outfall 001 - once through non-contact cooling water, intermittent discharge including utilities and maintenance wastewaters and stormwater; Outfall 004 intermittent discharges of stormwater runoff and maintenance wastewaters; Outfall 005 -
| |
| treated sanitary wastewater 14 . Number of Inject ion Well s_-=N~A'-=------------------------
| |
| : 15. Water Source(s) ________________________________
| |
| : 16. Receiving Water(s) Outfall 001 - Mississippi River; Outfalls 004 and 005 -
| |
| 40 Arpent Canal
| |
| : 17. River Basin Mississippi, Barataria 18 . Bas in Segment No. _0_7~0~3~0~1~~0~2~0~2_0~2~----------------------
| |
| TOTJ.l.L RATING POINTS ASSIGNED I 305
| |
| --~m=l=b=---__ Initials of Rater A-129
| |
| | |
| Invoice No. _ _ _ _ _ _ _~ ANNUAL FEE RATING WORKSHEET - INDUSTRIAL Page 2 PERMIT NO. LA0007374, AI No. 35260,PER20090001
| |
| : 1. FACILITY COMPLEXITY DESIGNATION Primary SIC 4911 Other SIC Complexity Designation = I (QPoints)
| |
| II (10 points)
| |
| III (20 points)
| |
| IV (30 points)
| |
| .I V (40 points)
| |
| VI (50 points)
| |
| COMPLEXITY DESIGNATION POINTS 40
| |
| : 2. FLOW VOLUME AND TYPE A. Wastewater Tyoe I Is total Daily Average Discharge greater than 400 mgd?
| |
| .I Yes, then points = 200
| |
| _ _ _ _ _ _ No, then Points 0.5 X Total Daily Average Discharge (mgd)
| |
| Poir.ts = 0.5 X Total points = --=2~0~0---~
| |
| B. Wastewater Type II Points 10 X Total Daily Average Discharge (mgd)
| |
| Points = 10 X Total points = -~--~-
| |
| C. Wastewater Type III Points 2 X Total Daily Average Discharge (mgd)
| |
| Points = 2 X Total points = -----=-0_ __
| |
| FLOW VOLUME AND TYPE POINTS 200
| |
| : 3. POLLUTANTS A. BOD or - - - -
| |
| Daily Average Load
| |
| ,/ :s: 50 lb/day (0 points)
| |
| - - - - - - > 50 - 500 (5 points)
| |
| - - - - - - > 500 - 1000 (-10 points)
| |
| - - - - - > 1000 - 3000 (20 points)
| |
| - - - - - - > 3000 - 5000 (30 points)
| |
| - - - - - - > 5000 lb/day (calculate)
| |
| Points 0.008 X Daily Average Load* (lbs)
| |
| Points 0.008 x 0 0 COD o r - - - -
| |
| Daily Average Load
| |
| .I :s: 100 lb/day ( 0 points)
| |
| > 100 - 500 ( 5 points)
| |
| > 500 - 1000 ( 10 points)
| |
| > 1000 - 5000 (20 points)
| |
| > 5000 - 10000 (30 points)
| |
| > 10000 lb/day (calculate)
| |
| Points 0.004 X Daily Average Load (lbs)
| |
| Points 0. 004 x 0 *- 0 BOD OR COD DEMAND POINTS 0 (whichever is greater)
| |
| A-130
| |
| | |
| Invoice No.~~--~---- ANNUAL FEE RATING WORKSHEET - INDUSTRIAL Page 3 PERMIT NO ... LA0007374, AI No. 35260, PER20090001 B. TSS Daily Average Load =
| |
| ./ :> 100 lb/day ( 0 points)
| |
| > 100 - 500 ( 5 points)
| |
| > 500 - 1000 (10 points)
| |
| > 1000 - 5000 (20 points)
| |
| > 5000 - 10000 (30 points)
| |
| > 10000 lb/day (calculate)
| |
| Points 0.004 X Daily Average Load (~bs)
| |
| Points 0. 004 x 0 0 TSS POINTS 0
| |
| : c. TOXICS Total Annual Discharge to Water =
| |
| Points 0.01 X Annual discharge {lbs)
| |
| Points 0. 01 x 0 0 TOXIC POINTS 0 TOTAL POLLUTANT POINTS 0
| |
| : 4. TEMPERATURE (HEAT LOAD}
| |
| Heat Load =Average Summer flow (mgd) X *T X 0.00834 where 0 T =Permit Limit (Max. Temp.) -70° Heat Load = 1125 (rngd) X 48 X 0. 00834 ___4~5~0~_Billion BTU Heat Load = 0 s 4 billion BTU ( 0 points)
| |
| > 4-20 billion BTU { 5 points)
| |
| > 20-100 billion BTU (10 points)
| |
| > 100-200 billion BTU (15 points)
| |
| ./ > 200 billion BTU (20 points)
| |
| HEAT LOAD POINTS _ _ _---'2~0=----
| |
| : 5. POTENTIAL PUBLIC HEALTH IMPACTS Is the receiving water to which the wastewater is discharged or a water body to which it is a tributary used as a drinking water supply source within 50 miles downstream?
| |
| ----..,.--~--No (0 points)
| |
| ~--~./ _ _~__ Yes, then . . . Complexity Designation
| |
| _ _ _ _ _ _ I, II ( 0 points)
| |
| _ _ _ _ _ _ III ( 5 points)
| |
| _ _ _ _ _ _ IV (10 points)
| |
| ./ V (20 points}
| |
| _ _ _ _ _ _VI (30 points)
| |
| POTENTIAL PUBLIC HEALTH IMPACT POINTS 20
| |
| : 6. MAJOR/MINOR FACILITY DESIGNATION Has your facility been designated a Major Facility by the administrative authority?
| |
| ---~--'./'--___ Yes, then Points 25
| |
| ------~--No, then were effluent limitations assigned to the discharge based on water quality factors in the receiving stream?
| |
| ~~--~./ _ _ _ _ No, then Points 0
| |
| ---~--~--Yes, then Points = 5 TOTAL MAJOR/MINOR POINTS~---=2=5---~
| |
| TOTAL RATING POINTS ASSIGNED_ _ _ _ _ _-=3-=-0=5_ _ _ _ _ __
| |
| A-131
| |
| | |
| BOBBY }INDAL PEGGY M. HATCH GOVER.l\/OR SECRETARY
| |
| ~tate of JLouistana DEPARTMENT OF ENVIRONMENTAL QUALITY ENVIRONMENTAL SERVICES Ms. Kelli M. Dowell AI No.: 35260 Entergy Services, Inc.
| |
| January 30, 2015 Activity No.: PER20140002 Post Office Box 1640 Jackson, Mississippi 39201 RE: Entergy Operations, Inc. - Waterford Steam Electric Station Unit 3 Water Quality Certification .
| |
| | |
| ==Dear Ms. Dowell:==
| |
| | |
| The Louisiana Department of Environmental Quality, Water Permits Division (LDEQ), has received the request from Entergy Operations, Inc. (Entergy) regarding the water quality certification (WQC) issued to Entergy's Waterford Steam Electric Station Unit 3 (WF3) and its upcoming operating license renewal with the United States Nuclear Regulatory Commission (NRC).
| |
| LDEQ has reviewed the request and confinns:
| |
| (i) LDEQ requires no new or additional water quality certification pursuant to Section 401 of the Federal Clean Water Act, 33 U.S.C. Section 1341, for WF3 in support of its license renewal application.
| |
| (ii) LDEQ deems the WQC issued by the State of Louisiana Stream Control Commission on June 21, 1972, valid for Waterford Units I, 2, and 3 to be a certification obtained pursuant to paragraph (I) of 33 U.S.C. Section 1341(a) with respect to the construction of WF3; and (iii) LDEQ deems the currently issued Louisiana Pollution Discharge Elimination System (LPDES) permit LA0007374 issued on October 1, 2010, to be a certification obtained pursuant to paragraph (I) of 33 U.S.C. Section l 34l(a) with respect to the operation ofWF3.
| |
| Should you have any questions concerning any part of this certification, please contact Elizabeth Johnson at (225) 219-3225, or by email at elizabeth.johnson@la.gov. To ensure all correspondence regarding this certification is properly filed into the Department's Electronic Document Management System, please reference Agency Interest (Al) number 35260 on all future correspondence to this Department.
| |
| Si , erely,?/;jf // /
| |
| W;i~
| |
| cott Guil
| |
| * ms Administrator Water Permits Division c: 10-W Corps of Engineers - New Orleans District A-132 Post Office Box4313 o Baton Rouge, Louisiana 70821-4313 *Phone 225-219-3181eFax225-219-3309
| |
| ********* ..J .... .. :_: ___ - - * -
| |
| | |
| Waterford Steam Electric Station , Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment B Threatened and Endangered Species Consultation
| |
| | |
| Attachment B Threatened and Endangered Species Consultation
| |
| * Rick Buckley, Entergy Services, Inc. , to David Bernhart, NOAA Fisheries Service-Southeast Regional Office.
| |
| May 28, 2015.
| |
| * Rick Buckley, Entergy Services, Inc., to Brad Rieck, U.S.
| |
| Fish and Wildlife Service-Louisiana Field Office. May 28, 2015.
| |
| * Rick Buckley, Entergy Services, Inc., to Carolyn Michon ,
| |
| Louisiana Natural Heritage Program-Department of Wildlife and Fisheries. May 28, 2015.
| |
| * Amity Bass, Natural Heritage Program-Louisiana Department of Wildlife and Fisheries, to Rick Buckley, Entergy Services, LLC . June 18, 2015.
| |
| * Kelly Shotts, NOAA Southeast Regional Office-National Marine Fisheries Service, to Rick Buckley, Entergy Services, Inc. June 24, 2015.
| |
| * Deborah Fuller, U.S. Fish and Wildlife Service-Louisiana Field Office, to Rick Buckley, Entergy Services, Inc. June 26, 2015.
| |
| B-1
| |
| | |
| ..
| |
| *~Entergy Entergy Services, inc 1340 Echelo n Par11way Jackson, Mississippi 39213 May 28 , 2015 Mr. David Bernhart Assistant Regional Administrator NOAA Fisheries Service Southeast Regional Office Protected Resources Division 263 13th Avenue South Saint Petersburg , Florida 33701
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3
| |
| * License Renewal Application CEO 2015-00051
| |
| | |
| ==Dear Mr. Bernhart,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish, Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application, Entergy will then have the option to continue operating WF3 for an additional 20 years until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application .
| |
| The NRC requires that the license renewal application for WF3 include an
| |
| * environmental report that assesses the potential environmental impacts from operation during the license renewal term . One of these potential environmental impacts would be B-2
| |
| | |
| the effect of license renewal on designated essential fish habitat (EFH) or protected marine mammals within the immediate environs of the WF3 site (Figure 1). Accordingly, the NRC requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51 .53). Later, during its review of the license renewal environmental report pursuant to the National Environmental Policy Act, the NRC may request information from your office to ensure compliance with the Magnuson-Stevens Fishery ConseNation and Management Act, and the Marine Mammal Protection Act.
| |
| Entergy is contacting you now in order to obtain input regarding issues that may need to be addressed in the WF3 license renewal environmental report, and to assist in identifying any information your staff believes would be helpful to expedite NRC's review.
| |
| During Entergy's review, it was determined that no designated EFH exists tor the Federally-listed threatened gulf sturgeon , Acipenser oxyrinchus desotoi, which may pass the WF3 site during the spawning season. Although the West Indian manatee, Trichechus manatus, is known to inhabit Lakes Pontchartrain and Maurepas and associated coastal waters and streams during summer months, the last known sighting of this species in the Mississippi River was 1975. We do not believe that suitable habitat exists at the ELL site tor manatees either.
| |
| However, even with designated EFH for the gulf sturgeon or the presence of the West Indian manatee in the immediate environs of WF3 (Figure 1), Entergy does not expect WF3 operations during the license renewal term to adversely affect either species since there are no plans to alter current operations during the 20-year license renewal period, and the fact that license renewal will not involve any offsite activities. Although administrative procedural controls are in place to comply with applicable state and federal laws to preseNe biological resources when facility changes do occur, no changes are planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to designated EFH for the gulf sturgeon or protection of the West Indian manatee within the immediate environs of WF3, or alternatively, confirming our conclusion that there is no designated EFH tor the gulf sturgeon within the immediate environs and that the likelihood of the West Indian manatee being adversely affected as a result of continued operations of WF3 for an additional 20 years would be minimal. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application .
| |
| B-3
| |
| | |
| If you have any questions, please contact me at (601) 368-5823 or through my email address, rbuckle @entergy.com.
| |
| Rick Buckley, CHMM , REM Sr. Project Manager, Environmental B-4
| |
| | |
| Figure 1 Location of Entergy Property, 6-Mile Radius Map Legend Cl Airpo11 - i' rope11y Bo undary
| |
| £1 H1,1liport - 1nt*<t sUl:e
| |
| -- ..
| |
| : l. _ "
| |
| Surfaco >Naier -
| |
| 6-M ire R~diu~ -- -
| |
| - U S Ro:.ite Sl ate Route
| |
| :: _*_" _. _; Census ?:~ce L=-J Parosn Local Ro<1ds
| |
| -.- .- ~a~ road
| |
| -------c::========:: =: i 0
| |
| Miles B-5
| |
| | |
| Entergy Services, Inc
| |
| .*===-
| |
| .Et 134 0 Echelon Parl<way n ergy Jackson, Mississippi 3921 3 May 28 , 2015 Mr. Brad Rieck Deputy Field Supervisor U.S. Fish and W ildlife Service Louisiana Field Office 646 Cajundome Blvd., Suite 400 Lafayette , LA 70506
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Application
| |
| * CEO 2015-00052
| |
| | |
| ==Dear Mr. Rieck,==
| |
| | |
| In 2016, Entergy Louisiana , LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish , Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application, Entergy will then have the option to continue operating WF3 for an additional 20 years until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application.
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses potential environmental impacts from plant
| |
| * operations during the license renewal term . One of these potential environmental impacts would be the effect of license renewal on Federally-listed threatened, 8-6
| |
| | |
| endangered or candidate species and designated critical habitat located on the WF3 property and its immediate environs (Figure 1). Accordingly, the NRC requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51 .53) . Later, during its review of the license renewal environmental report pursuant to the National Environmental Policy Act, the NRC may request information from your office to ensure compliance with Section 7 of the Endangered Species Act.
| |
| Entergy is contacting you now in order to obtain input regarding issues that may need to be addressed in the WF3 license renewal environmental report, and to assist in identifying any information your staff believes would be helpful to expedite NRC's review.
| |
| WF3 is located on approximately 3,560 acres of Entergy Louisiana, LLC (ELL) owned property that consists primarily of wetlands, agriculture, and developed areas. The WF3 plant area itself covers 40.1 acres and is zoned as an industrial area by St. Charles Parish . The land in the vicinity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the ELL property. The length of these transmission lines is approximately 0.6 miles, and there is limited right-of-way since the lines cross the WF3 industrial area where vegetation is sparse.
| |
| Based on review of information available, Entergy has included in Table 1 threatened, endangered and candidate species identified as being Federally-listed in St. Charles and St. John the Baptist parishes, of which portions of are included within a 6-mile radius of WF3 (Figure 1). As shown in Table 1, no suitable habitat for these species was identified on the ELL property during a pedestrian survey conducted on October 29, 2014, or was any species observed during the survey. Entergy does not anticipate that the one Federally-listed species identified only in St. John the Baptist Parish (Alabama heelsplitter mussel , Lasmigona alabamensis) would be affected by the renewal of the WF3 operating license since the Mississippi River does not provide suitable habitat for this species. In addition during Entergy's review, no designated critical habitat was identified for the species listed in Table 1 within the immediate environs (6-mile radius) of WF3.
| |
| However, Entergy does not expect that WF3's operations during the license renewal term would result in adverse effects to threatened, endangered or candidate species and designated critical habitats even if present since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to B-7
| |
| | |
| comply with applicable state and federal laws to preserve biological resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| Atter your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to threatened, endangered or candidate species and designated critical habitat on the property where WF3 is located, or the immediate environs, or alternatively, confirming our conclusion that these species and habitats will not be adversely affected as a result of renewing the WF3 operating license for an additional 20 years. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application.
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address, rbuckle@enterqy.com.
| |
| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental B-8
| |
| | |
| Table 1 Federal-Listed Species, St. Charles and St. John the Baptist Parishes Common Name Scientific Name Applicable Federal Habitat Present Species Present Parish Status on ELL Property on ELL Property Mammals West Indian Manatee Trichechus manatus SC/SJB E No No Birds Sprague's Pipit Anthus spragueii SC/SJB c No No Fish Atlantic Sturgeon Acipenser oxyrinchus desotoi SC/SJB T No No Pallid Sturgeon Scaphirhynchus a/bus SC/SJB E No No Mollusks Alabama Heelsplitter Mussel Lasmigona alabamensis SJB T No No SC = St. Charles Parish SJB = St. John the Baptist Parish T = Threatened E= Endangered C= Candidate Species
| |
| | |
| Figure 1 Location of Entergy Property, 6-Mile Radius Map Legend a A!rpori - Propeny Boundary
| |
| *-¢-*
| |
| £1 Helipcrt - 'nto'lrscate
| |
| ~
| |
| --,
| |
| L Sorf;:ice Waler
| |
| _.I 6 Mile Radius - -
| |
| U.S Rvt1t'!
| |
| Stal'll Rou! o
| |
| ;:* - ~ * ] Cen~us- Place :.().:a! Reads *******-========::::::iMiles 0 2 4
| |
| [.=:J Pivisll _..__,._ Railmad B-10
| |
| | |
| *
| |
| ~Entergy Entergy Services, Inc 1340 Echelon Par1<way Jackson , Mississippi 39213 May 28, 2015 Ms. Carolyn Michon Assistant Data Manager Louisiana Natural Heritage Program Department of Wildlife and Fisheries Post Office Box 98000 Baton Rouge, LA 70898-9000
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Application CEO 2015-00053
| |
| | |
| ==Dear Ms. Michon,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish, Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application, Entergy will then have the option to continue operating WF3 for an additional 20 years until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application .
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses the potential environmental impacts from operation during the license renewal term. One of these potential environmental impacts for consideration would be the effect of license renewal on state-listed species and B-11
| |
| | |
| designated critical habitat located on the WF3 property and its immediate environs (Figure 1). Accordingly, the NRG requires that the environmental report for each license renewal application assess such a potential effect ( 10 CFR 51 .53).
| |
| Entergy is contacting you now in order to obtain input regarding issues that may need to be addressed in the WF3 license renewal environmental report, and to assist in identifying any information your staff believes would be helpful to expedite NRC's review.
| |
| WF3 is located on approximately 3,560 acres of Entergy Louisiana, LLC (ELL) owned property that consists primarily of wetlands , agriculture, and developed areas. The WF3 plant area itself covers 40.1 acres and is zoned as an industrial area by St. Charles Parish. The land in the vicinity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRG considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the ELL property. The length of these transmission lines is approximately 0.6 miles, and there is limited right-of-way since the lines cross the WF3 industrial area where vegetation is sparse.
| |
| Based on review of information available, Entergy has included in Table 1 species identified as being state-listed in St. Charles and St. John the Baptist parishes, of which portions of are included within a 6-mile radius of WF3 (Figure 1). Although suitable habitat does exist on the ELL property for two species as shown in Table 1 (western antler fern, Ceratopteris pteridoides, and square-stemmed monkey flower, Mimulus ringens) based on a pedestrian suNey conducted on October 29, 2014, these species were not obseNed during the suNey. Entergy does not anticipate that the three state-listed species identified only in St. John the Baptist Parish (osprey (Pandion haliaetus) ,
| |
| alligator snapping turtle (Macrochelys temminckit) , and rooted spike rush (Eleocharis radicans) ) would be affected by the renewal of the WF3 operating license since license renewal will not involve any offsite activities. In addition during Entergy's review, no designated critical habitat was identified for the species listed in Table 1 on the ELL property or within the immediate environs (6-mile radius) of WF3.
| |
| However, Entergy does not expect WF3's operations during the license renewal term would result in adverse effects to state-listed species or designated critical habitats even if present since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to comply with applicable state and federal laws to preseNe biological resources when facility expansion or land B-1 2
| |
| | |
| disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to state-listed species or designated critical habitat on the property where WF3 is located, or the immediate environs (6-mile radius) , or alternatively, confirming our conclusion these species and habitats will not be adversely affected as a result of renewing the WF3 operating license for an additional 20 years. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application .
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address, rbuckle@entergy.com.
| |
| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental B-13
| |
| | |
| Table 1 State-Listed Species, St. Charles and St. John the Baptist Parishes Common Name Scientific Name Applicable State Habitat Present Species Present Parish Status on ELL Property on ELL Property Mammals West Indian Manatee Trichechus manatus SC/SJB SNA No No Birds Bald Eagle Ha/iaeetus leucocephalus SC/SJB S2N, S3B No No Osprey Pandion haliaetus SJB S2B ,S3N No Fish Pallid Sturgeon Scaphirhynchus a/bus SC/SJB S1 No No Paddlefish Polyodon spathu/a SC/SJB S3 No No Ree.tiles Alligator Snapping Turtle Macroche/ys temminckii SJB S3 No Plants Swamp Milkweed Asclepias incarnata SC/SJB S2 No No Golden Canna Canna f/accida SC S4? No No Floating Antler Fern Ceratopteris pteridoides SC/SJB S2 Yes No Marshland Flatsedge Cyperus distinctus SC S1 No No Western Umbrella Sedge Fuirena simplex var. aristulata SC S1 Yes No Correll's False Dragon-Head Phvsosteqia carrel/ii SC S1 No No Square-Stemmed Monkey Flower Mimu/us ringens SC S2 Yes No Rooted Spike Rush Eleocharis radicans SJB S1 ? No No SC= St. Charles Parish SJB = St. John the Baptist Parish S1 = critically imperiled in Louisiana because of extreme rarity (5 or fewer known extant populations) or because of some factor(s) making it especially vulnerable to extirpation S2 = imperiled in Louisiana because of rarity (6 to 20 known extant population s) or because of some factor(s) making it very vulnerable to extirpation 83 = rare and local throughout the state or found locally (even abundantly at some of its locations) in a restricted region of the state, or because of other factors making it vulnerable to extirpation (21 to 100 known extant populations)
| |
| S4 = apparently secure in Louisiana with many occurrences ( 100 to 1000 known extant populations)
| |
| B-14
| |
| | |
| Figure 1 Location of Entergy Property, 6-Mlle Radius Map
| |
| ..
| |
| '
| |
| ' \
| |
| -.
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| |
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| |
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| |
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| |
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| |
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| |
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| |
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| |
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| |
| I l - -- ... -....... -----
| |
| --~
| |
| legend a rport
| |
| £1 He~pot1
| |
| __ , Surface W.1 1 - - lJ S Route l.. _ 1 6-1*.He RalJiw - - Stale Ruule
| |
| *.:.-* .: C4.1~SP 1: i..
| |
| * I Ru .tds ............im::==::::::::::::==:::=:::JM H 0 1
| |
| [.=._l P.msh --.- Ra11<oad "
| |
| B-15
| |
| | |
| B OOBY .J 1N DAL R O BE: R T .j BA "'HAM GOVERNO R SECR ETARY DEPARTMENT O F WIL DLI FE AN O Fl S HERIES J t MM Y L. ANTHO N "'
| |
| OFFIC E OF WIL D LIFE A SS IS":"ANT 5£CR E T A R'r Date June 18. 20 15 Name Ri ck Buckley Company Entergy Servi ces, LLC Street Address 1340 Echelon Parkway City, State, Zip Jae ks on. Mississippi 39213 Proj ect Entergy Louisiana, LLC Waterford 3 Steam Electric Station un it 3 Proj ect JD 12020 15 In voice Number 1506 180 1 Personnel of the Coasta l & ongame Resources Division have reviewed the preliminary data for the captioned project.
| |
| Our records indicat e that the proposed project may potenti ally impact a Bald Eagle (Haliaeetus leucocephalus) nesting site located within the project site . T his species is protected under the Bald and Golden Eagle Protecti on Act ( 16 U.S.C. 668 -
| |
| 668c) and the Mi gratory Bird Treaty Act (16 U.S.C. 703-7 12) and is protected by the state of Louisiana. All b~ld eagle nests (active, inactive or seemingly abandoned) should be protected. and no large trees should be removed . Please refer to the Bald Eagle Management Guidelines for more infom1ation regarding buffer zones and other info1mation on avoiding impac ts to bald eagles: http ://www.fws.gov/southcasties/baldeagle/.
| |
| After careful review of our database, no other impacts to rare, threatened, or endangered species or critical habitats are anticipated for the proposed project. No state or fede ral parks, wildlife refuges, scenic streams, or wildlife management areas are knmvn at the specified site within Louisiana's boundaries.
| |
| The Louisiana Na tural Heritage Program (LNHP) has compiled data on rare, endangered, or otherwise significa nt plant and animal species, plant communities, and other natural features throughout the state of Louisiana . Heritage reports summarize the existing information known at the time of the request regarding the location in question. The quantity and quality of data collected by the Lr-..'HP are dependent on the research and observations of many individuals . In most cases, this information is not the result of comprehensive or si te-specific field surveys; many natural areas in Louisiana have not been surveyed. This report docs not address the occurrence of wetl ands at the site in question. Heritage reports should not be considered fu13l statements on the biological elements or areas being considered, nor should they be substituted fo r on-site surveys required for environmental assessments . LNHP requires that this office be acknowledged in all reports as the so urce of all data provided here . If at any time Heritage tracked species are encountered within the project area. please contact the L HP Data Manager at 225-765 -2643 . lf you ha ve any questions, or need additiona l infom1ation, plea se call 22 5-765 -235 7 .
| |
| Sin~er~
| |
| ~b:t~-*
| |
| Amity'I3ass, ~ordinator
| |
| ~atura l Heri tage Program B-16
| |
| ?.O . eox 9BCX:>O
| |
| * Et.AWN ROUGE. LCLHS IAMA 10898-9000
| |
| * PHO NC <Z2.5) 765*2BOO AN t:OUAL OF'POITTU" fTY E.t*1f"_Q)'ER
| |
| | |
| BUCKLEY, RICKY N From: Kelly Shotts - NOAA Fed eral <kelly.shotts@noaa.gov>
| |
| Sent: Wednesday, June 24, 2015 2:32 PM To: BUCKLEY, RICKY N
| |
| | |
| ==Subject:==
| |
| Re: Waterford 3 Steam Electric Station Unit 3 - Gulf sturgeon EXTERNAL SENDER. DO NOT click links if sender is unknown. DO NOT provide your user ID or password.
| |
| Hi Rick, Thank you for speaking with me earlier today. As we discussed, under the Magnuson-Stevens Fishery Conservation and Management Act, EFH is designated for federally managed fishery species (e.g. , shrimp, reef fish, and red drum). There is no Essential Fish Habitat (EFH) designated for Gulf sturgeon. More information on EFH can be found at the following website:
| |
| http://sero .nmfs. noaa. gov/habitat conservation/efh/index.html Gulf sturgeon is not a fishery species, rather it is listed as threatened under the Endangered Species Act. Critical habitat for Gulf sturgeon has been designated in the Gulf of Mexico, including in Lake Pontchartrain (Unit 8). Gulf sturgeon information and maps of Gulf sturgeon critical habitat can be found at tl following websites:
| |
| Species Information http://www. nmfs.noaa. gov/pr/ species/fish/ gulfsturgeon.htm Critical Habitat Maps and GIS files http://sero.nmfs.noaa.gov/maps gis data/protected resources/critical habitat/index.html Based on the shortest distance between the project location you provided in your letter and the closest area designated as Gulf sturgeon critical habitat, your project appears to be at least 19 miles away from critical habitat. However, please confirm this yourself using the information provided above.
| |
| If you have any other questions, please feel free to contact me.
| |
| Kelly On Wed, Jun 24, 2015 at 9:37 AM, Kelly Shotts - NOAA Federal <kelly.shotts@noaa.gov> wrote:
| |
| Hi Rick, 1
| |
| B- 17
| |
| | |
| I just left you a voicemail pertaining to your May 28, 2015, letter regarding the subject project. Please give me a call at your earliest convenience to discuss issues related to Gulf sturgeon and their habitat. My direct line is 727-551 -5603 .
| |
| thanks for coordinating with us!
| |
| Kelly Kelly Shotts Section 7 Coordinator Protected Resources Division NOAA Southeast Regional Office National Marine Fisheries Service 263 13th Ave S St. Petersburg. FL 33701 Ph: 727-824-5312 Fax: 727-824-5309 kelly. shotts@noaa.gov Kelly Shotts
| |
| ';ection 7 Coordinator
| |
| >rotected Resources Division NOAA Southeast Regional Office National Marine Fisheries Service 263 13th Ave S St. Petersburg, FL 33701 Ph: 727-824-5312 Fax: 727-824-5309 kelly.shotts@noaa.gov 2
| |
| B- 18
| |
| | |
| -
| |
| Entergy Services, Inc 1340 Echelon Parkway Jackson, Mississippi 39213 May 28, 2015
| |
| .. j r * ~ r:
| |
| Mr. Brad Rieck Deputy Field Supervisor - 's.
| |
| U.S. Fish and Wildlife Service i 1 i\"""i vf ~1.b ,"'\""**
| |
| Louisiana Field Office 646 Cajundome Blvd., Suite 400 Lafayette, LA 70506
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 Licens~ Renewal Application CEO 2015-00052
| |
| | |
| ==Dear Mr. Rieck,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish, Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application , Entergy will then have the option to continue operating WF3 for an additional 20 years until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application.
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses potential environmental impacts from plant operations during the license renewal term. One of these potential environmental impacts would be the effect of license renewal on Federally-listed threatened, B-19
| |
| | |
| endangered or candidate species and designated critical habitat located on the WF3 property and its immediate environs (Figure 1). Accordingly, the NRG requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51 .53). Later, during its review of the license renewal environmental report pursuant to the National Environmental Policy Act, the NRG may request information from your office to ensure compliance with Section 7 of the Endangered Species Act.
| |
| Entergy is contacting you now in order to obtain input regarding issues that may need to be addressed in the WF3 license renewal environmental report, and to assist in identifying any information your staff believes would be helpful to expedite NRC's review.
| |
| WF3 is located on approximately 3,560 acres of Entergy Louisiana, LLC (ELL) owned property that consists primarily of wetlands, agriculture, and developed areas. The WF3 plant area itself covers 40.1 acres and is zoned as an industrial area by St. Charles Parish. The land in the vicinity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the ELL property. The length of these transmission lines is approximately 0.6 miles, and there is limited right-of-way since the lines cross the WF3 industrial area where vegetation is sparse.
| |
| Based on review of information available, Entergy has included in Table 1 threatened, endangered and candidate species identified as being Federally-listed in St. Charles and St. John the Baptist parishes, of which portions of are included within a 6-mile radius of WF3 (Figure 1). As shown in Table 1, no suitable habitat for these species was identified on the ELL property during a pedestrian survey conducted on October 29, 2014, or was any species observed during the survey. Entergy does not anticipate that the one Federally-listed species identified only in St. John the Baptist Parish (Alabama heelsplitter mussel, LaSfJ1igona alabamensis) would be affected by the renewal of the WF3 operating license since the Mississippi River does not provide suitable habitat for this species. In addition during Entergy's review, no designated critical habitat was identified for the species listed in Table 1 within the immediate environs (6-mile radius) of WF3.
| |
| However, Entergy does not expect that WF3's operations during the license renewal term would result in adverse effects to threatened, endangered or candidate species and designated critical habitats even if present since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to B-20
| |
| | |
| comply with applicable state and federal laws to preserve biological resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to threatened, endangered or candidate species and designated critical habitat on the property where WF3 is located, or the immediate environs, or alternatively, confirming our conclusion that these species and habitats will not be adversely affected as a result of renewing the WF3 operating license for. an additional 20 years. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application.
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address, rbuckle@entergy.com.
| |
| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental B-21
| |
| | |
| Thif' project hJ.s bee n reviewed 'or effer.ts to Federal trust resources una ~ r our jur,s*j 1ciion ancl "*Jr sr 'y ;; otect r d by the t=nd a;1gerad Species Act of 1!F 3 (Acl) . The, ~ :* *:.t as p;oposad,
| |
| ~ ~u .ave
| |
| * o tho... e "Dr ,e<>
| |
| ( ) Is not litr !y 10 ad ' E :;~l*l .**:,.-; th~.::. e *~*~mrc r.:s.
| |
| Thh:; :ini:ing fu i fi l'~; , L ia qu i. & *1~ c;~~~s unr:.:r M:;1*J n 7(ej (2) of the Act.
| |
| -t- ~.,_,,....,,.~
| |
| .\ <. . *: S1:;; <> f';i:c:
| |
| Li:*uisia"** F1 P1 '" "Jifio:;9 U. :. Fish arv:i W1it",f9 Sa:-vice B-22
| |
| | |
| Waterford Steam Electric Station, Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment C Cultural Resources Consultation
| |
| | |
| Attachment C Cultural Resources Consultation
| |
| * Rick Buckley, Entergy Services, Inc., to Phil Boggan, Office of Historic Preservation-Division of Historic Preservation. June 1, 2015.
| |
| * Rick Buckley, Entergy Services, Inc., to Kimberly Walden, Tribal Historic Preservation Officer-Chitimacha Tribe of Louisiana. June 1, 2015.
| |
| * Rick Buckley, Entergy Services, Inc., to Dr. Linda Langley, Tribal Historic Preservation Officer-Coushatta Tribe of Louisiana. June 1, 2015.
| |
| * Rick Buckley, Entergy Services, Inc., to Alina Shively, Deputy Tribal Historic Preservation Officer-Jena Band of Choctaw Indians. June 1, 2015.
| |
| * Rick Buckley, Entergy Services, Inc., to Earl J. Barbry, Jr, Tribal Historic Preservation Officer-Tunica-Biloxi Tribe of Louisiana. June 1, 2015.
| |
| * Jill Crawford, Section 106 Coordinator-Coushatta Tribe of Louisiana, to Rick Buckley, Entergy Service, Inc. June 5, 2015.
| |
| * Pam Breaux, State Historic Preservation Officer, to Rick Buckley, Entergy Services, Inc. June 8, 2015.
| |
| * Alina Shively, Deputy Tribal Historic Preservation Officer-Jena Band of Choctaw Indians, to Rick Buckley, Entergy Services, Inc. July 15, 2015.
| |
| * Phil Boggan, Deputy State Historic Preservation Officer (stamp of receipt/review/acceptance), to Rick Buckley, Entergy Services, Inc. July 15, 2015.
| |
| C-1
| |
| | |
| *
| |
| -=~*Entergy Entergy Services, Inc 1340 Echelon Parkway Jackson, Mississippi 39213 June 1, 2015 Mr. Phil Boggan Office of Historic Preservation Division of Historic Preservation Post Office Box 4424 7 Baton Rouge, LA 70804
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Application CEO 2015-00054
| |
| | |
| ==Dear Mr. Boggan,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy'') plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish, Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application, Entergy will then have the option to continue operating WF3 until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application.
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses the potential environmental impacts from operation during the license renewal term. One of these potential environmental impacts would be the effect of license renewal on archaeological resources located on the WF3 site, its immediate environs (6-mile radius) as shown in Figure 1, and transmission line corridors constructed for purposes of connecting the plant to the regional transmission grid.
| |
| C-2
| |
| | |
| Accordingly, the NRC requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51.53). Later, during its review of the license renewal environmental report pursuant to the National Environmental Policy Act, the NRC may request information from your office to ensure compliance with Section 106 of the National Historic Preservation Act of 1966, as amended (16 USC 470), and Federal Advisory Council on Historic Preservation regulations (36 CFR 800).
| |
| WF3 is located on approximately 3,560 acres of Entergy owned land (Figure 1) that consists primarily of wetlands, agriculture, and developed areas. The WF3 plant area itself covers 40.1 acres and is zoned as an industrial area by St. Charles Parish, with the exception of the property south of LA-3127. The land in the vicinity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the property.
| |
| Although not required, Entergy voluntarily contracted with Coastal Environments, Inc. to conduct a Phase 1A literature review and archaeological sensitivity assessment of the Entergy property in August and September 2014 to supplement WF3's existing administrative controls to ensure that potential resources are properly managed during the license renewal period. This assessment, which is included in Attachment 1, determined that no cultural resources would be impacted as a result of renewal of the WF3 operating license.
| |
| Table 1 lists archaeological resources within a 6-mile radius of WF3 while Table 2 lists National Register of Historic Places (NRHP) properties within this same radius that were identified by Entergy during our view. For the one partially eligible/unknown property in Table 1 that is located on the ELL property (16SC41 ), WF3 has a site-specific cultural resource protection plan that is incorporated by reference in the Environmental Protection Plan to the operating license to protect those areas on the property determined to be eligible for the NRH P, specifically the Waterford Plantation ( 16SC41 ).
| |
| This requirement ensures that cultural resource remains are not damaged and are protected from unauthorized removal, and ensures that in the event that ground disturbance is required in these areas, remains will be appropriately protected for their cultural resource information value.
| |
| However, Entergy does not expect WF3 operations during the license renewal term to adversely affect any historic or archaeological resources since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to comply with applicable state and federal laws to preserve C-3
| |
| | |
| cultural resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to historic or archaeological resources on the property where WF3 is located, or the immediate environs, or alternatively, confirming our conclusion that the operation of WF3 during the license renewal term would have no effect on known historical or archaeological properties. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application.
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address at rbuckle@entergy.com.
| |
| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental C-4
| |
| | |
| Table 1 Archaeological Sites within a 6-Mile Radius of WF3 Site Number Parish Quadrangle NRHP Status 16SC10 St. Charles Laplace Unknown 16SC19 St. Charles Hahn ville Unknown 16SC21 St. Charles Hahn ville Unknown 16SC22 St. Charles Hahnville Unknown 16SC24 St. Charles Hahnville Unknown 16SC31 St. Charles Laplace Partially lneligible/Unknown\ai 16SC39 St. Charles Hahn ville Unknown 16SC41 1u 1 St. Charles Hahn ville Partially Eligible/Unknown\CJ 16SC47 St. Charles Hahnville Unknown 16SC50 St. Charles Laplace Listed 16SC51 St. Charles Laplace Listed 16SC52 St. Charles Laplace Ineligible 16SC53 St. Charles Laplace Ineligible 16SC54 St. Charles Laplace Ineligible 16SC55 St. Charles Hahn ville Ineligible 16SC56 St. Charles Hahnville Unknown 16SC57 St. Charles Hahn ville Unknown 16SC58 St. Charles Hahnville Unknown 16SC59 St. Charles Hahnville Unknown 16SC65 St. Charles Hahnville Ineligible 16SC71 St. Charles Hahn ville Unknown 16SC72 St. Charles Hahn ville Partially lneligible/Unknown 13' 16SC79 St. Charles Laplace Ineligible 16SC80 St. Charles Laplace Eligible 16SC85 St. Charles Laplace Ineligible 16SC86 St. Charles Hahn ville Unknown 16SC88 St. Charles Laplace Unknown 16SJB6 St. John the Baptist Reserve Unknown 16SJB8 St. John the Baptist Reserve Unknown 16SJB10 St. John the Baptist Reserve Unknown 16SJB12 St. John the Baptist Reserve Unknown 16SJB22 St. John the Baptist Reserve Unknown 16SJB24 St. John the Baptist Laplace Unknown 16SJB25 St. John the Baptist Laplace Unknown 16SJB27 St. John the Baptist Reserve Unknown 16SJB67 St. John the Baptist Laplace Unknown
| |
| : a. Only a portion of the site is determined not eligible for inclusion on the NRHP; the eligibility of the rest of the site is unknown.
| |
| : b. Located on WF3 property.
| |
| : c. Only a portion of the site is determined eligible for inclusion on the NRHP; the eligibility of the rest of the site is unknown.
| |
| C-5
| |
| | |
| Table 2 NRHP-Listed Properties within a 6-Mile Radius of WF3 Parish Resource Name Quadrangle NRHP Distance from Listed WF3(al St. Charles Dorvin House, Mollere House, Rosedon Hahn ville 1990 3.1 mi
| |
| -*
| |
| St. Charles Homeplace Plantation House, Keller Homestead Hahnville 1970 4.1 mi St. Charles Kenner and Kugler Cemeteries Archaeological District Laplace 1987 2.0 mi(O)
| |
| (16SC50 and 16SC51)
| |
| St. Charles Ormond Plantation House Hahnville 1990 5.8 mi St . John the Baptist Haydel-Jones House Reserve 2010 6.0m i St. John the Baptist Montegut Plantation House Laplace 1988 4.4 mi St. John the Baptist Sorapuru House Reserve/Laplace 1999 3.9mi
| |
| : a. Distances are approximate and based on the WF3 reactor center point and NRHP location data.
| |
| : b. The NRHP lists Kenner and Kugler Cemeteries as "address restricted. " The distance given was created using GIS to compare the two cemetery locations and background landmarks depicted in the February 8, 2012, USACE Bonnet Carre Public Meeting - Long Term Management Report to a USGS topographic map. An approximate equidistant point was placed between the two locations to estimate distance.
| |
| C-6
| |
| | |
| Figure 1 Location of Entergy Property, 6-Mile Radius
| |
| \ . \
| |
| \ :-"
| |
| . .
| |
| ~:-
| |
| :* ;....
| |
| : _.. .. --
| |
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| |
| .... _ * * *
| |
| .... ..St ...... ..._
| |
| -~~
| |
| '* *_:i! *
| |
| .......
| |
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| |
| ~ ---~-..-.,-~-----Ao...'* ..... ,.. \? ~" -*,. - . .:.o: /._,,r
| |
| /
| |
| ' , II .*.
| |
| *-------*- -:-~ . . .u' ...: __....,_....~ - * *. :<.*.-st
| |
| * Jo hn the Baptist 7,
| |
| * 53 R~ ,
| |
| ,
| |
| \ ,. * * .- * / ',
| |
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| |
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| |
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| |
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| |
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| |
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| |
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| ~ .....
| |
| . , ;.,
| |
| ** *.
| |
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| |
| ~be*
| |
| .........
| |
| . ,/
| |
| / '
| |
| ',
| |
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| |
| ....,
| |
| I '
| |
| ~''"' /
| |
| ,I _. . .*' \
| |
| *: . ;.* - :,.)\ 1' .' *' '
| |
| I .......... ; .*.
| |
| , ~. *r * ' \.
| |
| .,
| |
| \
| |
| ' \
| |
| \
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| ! - \
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| |
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| '
| |
| I Legend .
| |
| =
| |
| ea Alrpc.11 Heilport
| |
| -
| |
| -
| |
| F>rope"'J Souodary lnterslatfl
| |
| <>-*
| |
| -- Stirl Ct! W.iler -
| |
| l.. _ ..1 6* h~ Radius -
| |
| U S Route Slaw 01Jta
| |
| *~ : :.* J Ccm.us Pia~ LOCill Ro3ds 0
| |
| ................-===============~4 ~ tlc-.
| |
| L__j P.-11 --+- ~dfO.'.ld C-7
| |
| | |
| Attachment 1 Phase 1 A Literature Review and Archaeological Sensitivity Assessment of the Waterford Steam Electric Station Unit 3 The attachment noted here that was sent to the Louisiana Historic Preservation Office is not enclosed because it contains sensitive information .
| |
| C-8
| |
| | |
| *
| |
| *~Entergy Entergy Services, Inc 1340 Echelon Pari<way Jackson, Mississippi 39213 June 1, 2015 Ms. Kimberly Walden Tribal Historic Preservation Officer Chitimacha Tribe of Louisiana Post Office Box 661 Charenton, LA 70523
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Application CEO 2015-00055
| |
| | |
| ==Dear Ms. Walden ,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish , Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge , Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application, Entergy will then have the option to continue operating WF3 until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application.
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses the potential environmental impacts from operation during the license renewal term. One of these potential environmental impacts would be the effect of license renewal on archaeological resources located on the WF3 site, its immediate environs (6-mile radius) as shown in Figure 1, and transmission line corridors constructed for purposes of connecting the plant to the regional transmission grid.
| |
| C-9
| |
| | |
| Accordingly, the NRC requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51 .53). Later, during its review of the license renewal environmental report pursuant to the National Environmental Policy Act, the NRC may request information from your office to ensure compliance with Section 106 of the National Historic Preservation Act of 1966, as amended ( 16 USC 470) , and Federal Advisory Council on Historic Preservation regulations (36 CFR 800).
| |
| WF3 is located on approximately 3,560 acres of Entergy owned land (Figure 1) that consists primarily of wetlands, agriculture , and developed areas. The WF3 plant area itself covers 40.1 acres and is zoned as an industrial area by St. Charles Parish, with the exception of the property south of LA-3127. The land in the vicinity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the Entergy property.
| |
| Entergy does not expect WF3 operations during the license renewal term to adversely affect any historic or archaeological resources since there are no plans to alter current operations during the 20-year license renewal period , and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to comply with applicable state and federal laws to preserve cultural resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to historic or archaeological resources on the property where WF3 is located, or the immediate environs, or alternatively, confirming our conclusion that the operation of WF3 during the license renewal term would have no effect on known historical or archaeological properties. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application.
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address at rbuckle @entergy.com.
| |
| Rick Buckley, CHMM , REM Sr. Project Manager, Environmental C-10
| |
| | |
| Figure 1 Location of Entergy Property, 6-Mile Radius Map Legend
| |
| .
| |
| Cl Alrpmt - Pro r e1ty Bounda'Y *<>-*
| |
| !I He4po rl - lnt,...fs *atl*
| |
| __ ,
| |
| l.. _ 1 6-Mil" Rad-us *- - Stato Ro.i re
| |
| :: ~ ~ _-] Cert~u11 Place L1>*, al Rr>ads L._J Pani;h - .- - ~ailr\l<ld C-11
| |
| | |
| *
| |
| *~Entergy Entergy Services, Inc 1340 Echelon Parkway Jackson, Mississippi 3921 3 June 1, 2015 Dr. Linda Langley Tribal Historic Preservation Officer Coushatta Tribe of Louisiana Post Office Box 10 Elton , LA 70532
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Application CEO 2015-00056
| |
| | |
| ==Dear Dr. Langley,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3), which is located in St. Charles Parish , Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge , Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application , Entergy will then have the option to continue operating WF3 until 2044. In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application .
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses the potential environmental impacts from operation during the license renewal term. One of these potential environmental impacts would be the effect of license renewal on archaeological resources located on the WF3 site , its immediate environs (6-mile radius) as shown in Figure 1, and transmission line corridors constructed for purposes of connecting the plant to the regional transmission grid.
| |
| C-12
| |
| | |
| Accordingly, the NRC requ ires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51 .53). Later, during its review of the license renewal environmental report pu rsuant to the National Environmental Policy Act, the NRC may request information from your office to ensure compliance with Section 106 of the National Historic Preservation Act of 1966, as amended (16 USC 470) , and Federal Advisory Council on Historic Preservation regulations (36 CFR 800) .
| |
| WF3 is located on approximately 3,560 acres of Entergy owned land (Figure 1) that consists primarily of wetlands, agriculture , and developed areas. The WF3 plant area itself covers 40 .1 acres and is zoned as an industrial area by St. Charles Parish , with the exception of the property south of LA-3127. The land in the vicinity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the Entergy property.
| |
| Entergy does not expect WF3 operations during the license renewal term to adversely affect any historic or archaeological resources since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to comply with applicable state and federal laws to preserve cultural resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to historic or archaeological resources on the property where WF3 is located, or the immediate environs , or alternatively, confirming our conclusion that the operation of WF3 during the license renewal term would have no effect on known historical or archaeological properties. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application.
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address at rbuckle @entergy.com.
| |
| Rick Buckley, CHMM , REM Sr. Project Manager, Environmental C-13
| |
| | |
| Figure 1 Location of Entergy Property, 6-Mile Radius Map St . Ch a rl4":S
| |
| /
| |
| *.. .. **
| |
| l 11r n c\ ' llf1m111nd.*
| |
| Legend a A.iroort - Pro pe rty 9 .ivnr.!a l')I
| |
| £1 He~rx>rt - lnl er s131~
| |
| Snrf;oe*:" 'Na le r **~-US Route
| |
| -- .
| |
| \.. - ' 6-Mile R" OllJS . - State Root.i
| |
| :* .. _ *: ~ flsus Pl:!ce
| |
| ........ .
| |
| ,--- 4
| |
| ~ -------ic::=======>Mdt1s 0 2 4 L _J Pans11 ~- Ra1lroa .J C-14
| |
| | |
| *
| |
| *~Entergy Entergy Serv ices, Inc 1340 Echelon Parkway Jackson, Mississippi 39213 June 1, 2015 Ms. Alina Shively Deputy Tribal Historic Preservation Officer Jena Band of Choctaw Indians Post Office Box 14 Jena, LA 71342
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Appl ication CEO 2015-00057
| |
| | |
| ==Dear Ms. Shively,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3) , which is located in St. Charles Parish , Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application , Entergy will then have the option to continue operating WF3 until 2044 . In conjunction with this effort, Entergy is gathering information relative to th is license renewal project to assist with the preparation of the application .
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses the potential environmental impacts from operation during the license renewal term. One of these potential environmental impacts would be the effect of license renewal on archaeological resources located on the WF3 site, its immediate environs (6-mile radius) as shown in Figure 1, and transmission line corridors constructed for purposes of connecting the plant to the regional transmission grid.
| |
| C- 15
| |
| | |
| Accordingly, the NRC requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51 .53) . Later, during its review of the license renewal environmental report pursuant to the National Environmental Pol icy Act, the NRC may request information from your office to ensure compliance with Section 106 of the National Historic Preservation Act of 1966, as amended ( 16 USC 470), and Federal Advisory Council on Historic Preservation regulations (36 CFR 800).
| |
| WF3 is located on approximately 3,560 acres of Entergy owned land (Figure 1) that consists primarily of wetlands, agriculture , and developed areas. The WF3 plant area itself covers 40.1 acres and is zoned as an industrial area by St. Charles Parish , with the exception of the property south of LA-3127. The land in the vicinity of the WF3 site is mostly wetlands . Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the Entergy property.
| |
| Entergy does not expect WF3 operations during the license renewal term to adversely affect any historic or archaeological resources since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site . Although administrative procedural controls are in place to comply with applicable state and federal laws to preserve cultural resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
| |
| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to historic or archaeological resources on the property where WF3 is located, or the immediate environs, or alternatively, confirming our conclusion that the operation of WF3 during the license renewal term would have no effect on known historical or archaeological properties. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application.
| |
| If you have any questions, please contact me at (601) 368-5823 or through my email address at rbuckle @entergy.com .
| |
| ~~
| |
| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental C-16
| |
| | |
| Figure 1 Location of Entergy Property, 6-M ile Radius Map J,f/4*' Prm1d,.1nrui n St. Childes Legend '
| |
| E:I Airpon *-<?*
| |
| iJ Hefipo r*t - .rtc rs:are
| |
| --*
| |
| L_
| |
| *-- --~ ~]
| |
| Sui fa ce Wdler *- - - U S Roule 1 6- M ile R3~1us -- -
| |
| Crmilus Place Slat'!! ~ ou tt:
| |
| \.01;a1 Ro<<ds --------========:::i M~es 0 2 4 C_J P;in:;h R:1111o;io C-17
| |
| | |
| *
| |
| ~Entergy Entergy Services, Inc 1340 Echelon Parkway Jackson. Mississippi 3921 3 June 1, 2015 Mr. Earl J . Barbry, Jr Tribal Historic Preservation Officer Tunica-Biloxi Tribe of Louisiana Post Office Box 1589 Marksville, LA 71351
| |
| | |
| ==SUBJECT:==
| |
| Waterford 3 Steam Electric Station Unit 3 License Renewal Application CEO 2015-00058
| |
| | |
| ==Dear Mr. Barbry,==
| |
| | |
| In 2016, Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") plans to apply to the Nuclear Regulatory Commission (NRC) for renewal of the operating license for the Waterford Steam Electric Station Unit 3 (WF3) , which is located in St. Charles Parish, Louisiana on the west (right descending) bank of the Mississippi River at River Mile 129.6, approximately 25 miles west of New Orleans, Louisiana and 50 miles southeast of Baton Rouge, Louisiana. The existing operating license for WF3 was issued for a 40-year term that expires in 2024. If the NRC approves the application , Entergy will then have the option to continue operating WF3 until 2044 . In conjunction with this effort, Entergy is gathering information relative to this license renewal project to assist with the preparation of the application.
| |
| The NRC requires that the license renewal application for WF3 include an environmental report that assesses the potential environmental impacts from operation during the license renewal term. One of these potential environmental impacts would be the effect of license renewal on archaeological resources located on the WF3 site , its immediate environs (6-mile radius) as shown in Figure 1, and transmission line corridors constructed for purposes of connecting the plant to the regional transmission grid.
| |
| C-18
| |
| | |
| Accordingly, the NRC requires that the environmental report for each license renewal application assess such a potential effect (10 CFR 51.53). Later, during its review of the license renewal environmental report pursuant to the National Environmental Policy Act, the NRC may request information from your office to ensure compliance with Section 106 of the National Historic PreseNation Act of 1966, as amended (16 USC 470), and Federal Advisory Council on Historic PreseNation regulations (36 CFR 800).
| |
| WF3 is located on approximately 3,560 acres of Entergy owned land (Figure 1) that consists primarily of wetlands , agriculture , and developed areas. The WF3 plant area itself covers 40 .1 acres and is zoned as an industrial area by St. Charles Parish, with the exception of the property south of LA-3127. The land in the vicin ity of the WF3 site is mostly wetlands. Transmission lines that connect WF3 to the regional electricity grid which the NRC considers to be within the scope of its environmental review for renewal of the WF3 operating license are located entirely within the Entergy property.
| |
| Entergy does not expect WF3 operations during the license renewal term to adversely affect any historic or archaeological resources since there are no plans to alter current operations during the 20-year license renewal period, and any maintenance activities necessary to support continued operation of WF3 would be limited to currently developed areas of the site. Although administrative procedural controls are in place to comply with applicable state and federal laws to preseNe cultural resources when facility expansion or land disturbance activities do occur, no expansion is planned or needed in support of license renewal.
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| After your review of the information provided in this letter, I would appreciate you sending a letter detailing any concerns you may have about potential impacts to historic or archaeological resources on the property where WF3 is located, or the immediate environs, or alternatively, confirming our conclusion that the operation of WF3 during the license renewal term would have no effect on known historical or archaeological properties. Entergy will include copies of this letter and your response in the environmental report submitted to the NRC as part of the WF3 license renewal application .
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| If you have any questions, please contact me at (601) 368-5823 or through my email address at rbuckle @entergy.com .
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| Rick Buckley, CHMM , REM Sr. Project Manager, Environmental C-19
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| Figure 1 Location of Entergy Property, &-Mlle Radius Map
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| ,
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| /
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| I r.k .: f'orrtch.,nrll.in Leg&nd 1:1 Arrpon - Pro perty 5 oundary
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| --<>-*
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| £1 Heliport - tnl*irs! ate
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| -_, Surfeca Watur l.-, 6-Mi\c; R.Jdius
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| _s Route Slate ROLie
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| ;: ~:: J Ct!nsu s Pldce 1- - -1 L __J P~rr.;n
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| - Louil Roads
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| -----+-- R1111toad
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| --------===:::::==:=:::i" 0 2 Mlk?~
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| C-20
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| COUSHATTA TRIBE . . .
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| OF LOUISIANA H E RITAGE D E PARTMENT Junes. 2015 Rick Buckley Entergy Service, !nc 134-0 Echelon Park.way Jackson Miss issippi 39213 Subj ect; Waterford 3 Steam Electric Station Unit 3, License Renewal Applkation Dear Mr. Buckley The Coushatta Tribe of Louisiana Heritage Department has reviewed the above reforence p roposed undertaking, and we are in concurrence with your .findings of "no historica l properties afft.-<:ted''.
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| At this time, l know of no know11 sacred or ceremonial sites in the immed iate area, and do not require further Sec-tion 106 consultation on this proj~t. However, if any cultl!ra1 resources sueh as, bone, pottery, stone tools, etc ,
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| are fu und s11bseqmmtly, we may elect to discuss addrtional mitigation steps, including on-siie monitoring. In die event that ardiacvlogical prnpertks or human remains are di &cover~ , please stop work and cotrmcr us Immediate-ly, consiste-nt with Section fX of the Nationwide Programmatk .>\greem<:-nt and applica ble laws.
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| Sincere!y, Jil l Crawford.
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| S~tion 106 Coordinator KOWASSAAT ON NATHIHILKAS-LET US SPEAK KOASATl 3 37-584- 1 560 337~584- 1 616 (FAX) PO Box 10 E:LTON , LA 70532 C-21
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| C HAR LES R. D AVI S JAY D ARDENNE
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| :§tat .e of i!rnui.s iana DEPUTY S ECRETARY LIEUTENANT GOVERNOR OFF I CE OF THE L I EUTEN A NT GOVE R N O R P AM BRE AU X DEPA RT M ENT OF CU L T U RE , RECRE A T IO N & TOU RI S M AS S I S TA NT S ECRETARY OFF I CE O F C U L T UR A L DE V ELOP M E N T 8 June 20 15 Rick Buckley Sr. Project Manager Entergy Services. lnc .
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| 1340 Echelon Parkway Jackson, MS 39213 Re : Draft Report La Divisio n of Archaeology Report No. 22-4955 Phase 1A Literarure Re1*iew and Archaeological Sensiti1*i1y Assessmem of the fVare1.ford Steam Electric Station Unit 3, Kil!ona. St. Charles Parish, Louisiana
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| ==Dear Mr. Buckley:==
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| We acknowledge receipt of your letter dated l June 2015 and one copy of the above referenced rep ort.
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| We have comple ted our review o f this report and have no comments to offer.
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| The above-referenced report provides a thorough and sufficient evaluation of the known and potential cultural resources on the Waterford 3 property. As noted in the repon and attached to it, the fac ility has an existing Cu ltural Resources Protection Plan with our office and we believe this plan will be appropriate in the future. We concur that the operation of Waterford 3 during the license renewal tem1 will have no effect on known historic properties.
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| We look forward to receiving two bound copies of the final report a long with a pdf of the report. ff you have any questio ns, please contact Chip McGimsey in the Division of Archaeology by email at cmcgimsev@crt. la.gov or by phone at 225-219-45 98.
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| Sincerely,
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| /)
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| ~1!!)
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| Pam Breaux State Historic Preservation Officer PB: cnn C-22 P.O. eox 44247
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| * S A.T O N ROUGE , LOU I SIANA 70804 * <1247. PHONE ( 225} 3..:12 - 820 0 .. F A X ( 225 ) 219*9772. WWW . CRT . STATE . LA . US AN EQUAL 0 PPOR1"U NrTY EM PL.OYER
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| BUCKLEY, RICKY N From: Alina Shively <ashively@jenachoctaw.org >
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| Sent: Wednesday, July 15, 2015 11:32 AM To: BUCKLEY, RICKY N
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| ==Subject:==
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| RE: Waterford 3 Steam Station Unit 3, License Renewal; CEO 2015 -00057
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| ==Dear Sir:==
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| After researching the site files, it seems this location is on top of a prehistoric site that is considered ineligible. Several artifacts were found at the site, per the state' s documentation and record ; however, we hereby offer the determination of No Adverse Effect. Should any inadvertent discoveries of cultural resources occur, please contact our office immediately. Thank you .
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| Sincerely, Alina J. Shively Jena Band of Choctaw Indians Deputy Tribal Historic Preservation Officer P.O. Box 14 Jena, LA 71342 (318) 992-1205 ashively@jenachoctaw.org From: BUCKLEY, RICKY N [mailto :RBUCKLE@entergy.com ]
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| Sent: Tuesday, July 14, 2015 4 :39 PM To: Alina Shively <ashively@jenachoctaw.org>
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| ==Subject:==
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| RE: Waterford 3 Steam Station Unit 3, License Renewal; CEO 2015-00057 Alina ,
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| The coordinates for Waterford 3 are "latitude 30 degrees , 45 minutes, 26 seconds north; longitude 91 degrees , 19 minutes, 54 seconds west.
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| The conversion to decimal degrees is 30 .757222 and -91 . 331666 . The site will fall in the correct location when you run it in google earth .
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| Please let me know if this satisfies your requests or if you need additional information.
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| : Thanks, 1
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| C-23
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| Rick Buckley, CHMM, REM Sr. Project Manager S::ntergy Nuclear Jost Office Box 31995 Jackson, MS 39286-1995 601-368-5823 (Office) 601-927-5132 (Cellular) 601-368-5812 (Fax) rbuckle@entergy.com This e-mail and any attachments thereto are intended only for the use by the addressee(s) named herein and contain proprietary and confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, or copying of this e-mail and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify me by telephone and permanently delete the original and any copy of any e-mail and any printout thereof.
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| From: Alina Shively [mailto :ashively@jenachoctaw.org]
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| Sent: Tuesday, July 14, 2015 3:25 PM To: BUCKLEY, RICKY N
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| ;ubject: Waterford 3 Steam Station Unit 3, License Renewal; CEO 2015-00057 EXTERNAL SENDER. DO NOT click links if sender is unknown. DO NOT provide your user ID or password.
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| ==Dear Sir:==
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| Regarding the above-mentioned project, the Jena Band of Choctaw Ind ians' requests GPS coordinates, so that we may check the stat e site files . We request t his information in order to properly comment.
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| Sincerely, Alina J. Shively Jena Band of Choctaw Indians Deputy Tribal Historic Preservation Officer P.O. Box 14 Jena, LA 71342
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| {318) 992-1205 ashive ly@ jen achoctaw.org 2
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| C-24
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| *
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| ~*Entergy Entergy Services, Inc 1340 Echelon Pa ri<way Jackson. Mississippi 39213 Ms. Pam Breaux Office of Historic PreseNation Division of Historic PreseNation Post Office Box 4424 7 Baton Rouge , LA 70804
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| ==SUBJECT:==
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| La Division of Archaeology Report No. 22-4955 Phase IA Literature Review and Archaeological Sensitivity Assessment of the Waterford Steam Electric Station Unit 3, Ki/Iona, St. Charles Parish, Louisiana
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| ==Dear Ms. Breaux,==
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| As requested in June 8, 2015 letter, enclosed are two bound copies of the final Phase IA Literature Review and Archaeological Sensitivity Assessment of the Waterford Steam Electric Station Unit 3 report along with a pdf copy of the report.
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| If you have any questions, please contact me at (601) 368-5823 or through my email address at rbuckle @entergy.com .
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| j T he l'i nal iZ:; lrt h:t$ bt*c n reviewed JaJ n.ccq.JLCO.
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| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental 1...1 -t. r-: ~
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| :: .:. i \
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| . *, I I !* ~ ,. ....
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| C-25
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| Waterford Steam Electric Station, Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment D Severe Accident Mitigation Alternatives Analysis
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment D Severe Accident Mitigation Alternatives Analysis Attachment D contains the following sections:
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| D.1 - Evaluation of Probabilistic Risk Analysis Model D.2 - Evaluation of WF3 SAMA Candidates
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| ',
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| '
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| Page D-1
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table of Contents D.1 Evaluation of Probabilistic Safety Analysis Model ...................................................... 8 D.1.1 PSA Model- Level 1 Analysis ............................................................................. 8 D.1.2 PSA Model - Level 2 Analysis ...........................................................................26 D.1.2.1 Containment Performance Analysis ................................................................... 26 D.1.2.2 Radionuclide Analysis ....................................................................................... 51 D.1.3 External Events and Internal Flooding ............................................................... 61 D.1.3.1 Seismic Analysis ................................................................................................ 61 D.1.3.2 Fire Analysis ...................................................................................................... 62 D.1.3.3 Other External Hazards ..................................................................................... 63 D.1.3.4 Internal Flooding ................................................................................................ 63 D.1.4 PSA Model Revisions and Peer Review Summary ............................................ 64 D.1.4.1 Major Differences Between the 2000 (R2) PSA Model and the IPE Model. ........ 64 D.1.4.2 Major Differences Between the 2003 (R3) PSA Model and the 2002 (R2) PSA Model. ............................. :.................................................................................. 64 D.1.4.3 Major Differences Between the 2009 R4C1 (R4) PSA Model and the 2003 WSES-3 PSA (R3) PSA model .......................................................................... 65 D.1.4.4 Major Differences Between the 2015 (R5) PSA Model and the 2009 (R4) PSA Model. ................................................................................................................65 D.1.4.5 PSA Model Peer Review .................................................................................... 66 D.1.5 The WinMACCS Model-Level 3 Analysis ......................................................... 68 D.1.5.1 Introduction ........................................................................................................68 D.1.5.2 Input ..................................................................................................................68 D.1.5.3 Results .............................................................................................................. 74 D.1.6 References********'*********************************************************************************************** 77 D.2 Evaluation of WF3 SAMA Candidates ......................................................................... 81 D.2.1 SAMA List Compilation ...................................................................................... 81 D.2.2 Qualitative Screening of SAMA Candidates (Phase 1) ........................................ 82 D.2.3 Final Screening and Cost Benefit Evaluation of SAMA Candidates (Phase 11) ... 82 D.2.4 Sensitivity Analyses ........................................................................................... 93 D.2.5 References ........................................................................................................ 94 Page D-2
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage List of Tables D.1-1 WF3 Model CDF Results by Major Initiators ................................................................. 9 D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF) .. 12 D.1-3 Containment Event Tree Tops .................................................................................... 27 D.1-4 Correlation of Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Large Early Release Frequency ...........................................................................................43 D.1-5 Correlation of Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Level 2 Release Frequency ....................................................................................................48 D.1-6 Release Timing Classification ..................................................................................... 53 D.1-7 WF3 Release Categories ............................................................................................ 53 D.1-8 WF3 Release Categories ............................................................................................ 54 D.1-9 Summary of Containment Event Tree Quantification .................................................. 57 D.1-10 WF3 Release Category Source Terms ....................................................................... 59 D.1-11 Estimated WF3 Core Inventory (Becquerels) .............................................................. 73 D.1-12 Base Case Mean PDR and OECR Values for Postulated Internal Events ................... 75 D.1-13 Summary of Offsite Consequence Results for Sensitivity Cases ................................ 76 D.2-1 Phase I SAMAs Related to IPE and IPEEE Insights ................................................... 95 D.2-2. Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation ...... 100 D.2-3 Sensitivity Analysis Results ...................................................................................... 121
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| \
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| Page D-3
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage List of Acronyms Acronym Definition ABWR Advanced Boiling Water Reactor AC Alternating Current ACCW Auxiliary Component Cooling Water ADV Atmospheric Dump Valve AFW Auxiliary Feedwater AM SAC A lWS Mitigating System Actuation Circuit AOV Air-Operated Valve ASME American Society of Mechanical Engineers AlWS Anticipated Transient Without Scram BWR Boiling Water Reactor CCF Common Cause Failure ccw Component Cooling Water CDF Core Damage Frequency CET Containment Event Tree CFC Containment Fan Coolers CHR Containment Heat Removal COE Cost of Enhancement cs Containment Spray CSP Condensate Storage Pool css Containment Spray System CST Condensate Storage Tank DC Direct Current OCH Direct Containment Heating DG Diesel Generator DWST Demineralized Water Storage Tank ECCS Emergency Core Cooling System EOG Emergency Diesel Generator EFW Emergency Feedwater EOOS Equipment Out of Service EOP Emergency Operating Procedure EPRI Electrical Power Research Institute EPU Extended Power Uprate EPZ Emergency Planning Zone ERFBS Electric Raceway Fire Barrier System ESF Engineered Safety Features ES FAS Engineered Safety Features Actuation System ETE Evacuation Time Estimates FIVE Fire Induced Vulnerability Evaluation FP Fission Product FPS Fire Protection System FW Feedwater FWCS Feedwater Control System HEAF High Energy Arcing Fault HPCI High Pressure Coolant Injection HPSI High Pressure Safety Injection HVAC Heating Ventilation and Air Conditioning Page D-4
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Acronym Definition IA Instrument Air ILRT Integrated Leak Rate Test IPE Individual Plant Examination IPEEE Individual Plant Examination of External Events ISLOCA Interfacing Systems Loss of Coolant Accident L1 Level 1 L2 Level2 LAR License Amendment Request LERF Large Early Release Frequency LOCA Loss of Coolant Accident LOOP or Loss of Off-site Power LOSP LPSI Low Pressure Safety Injection MAAP Modular Accident Analysis Program MACCS2 Melear Accident Consequences Code System 2 MCCI Molten Cerium-Concrete Interaction MCR Main Control Room MDAFW Motor-Driven Auxiliary Feedwater MOV Motor-Operated Valve MSIV Main Steam Isolation Valve MSL Mean Sea Level MSLB Main Steam Line Break MSSV Main Steam Safety Valve NPSH Net Positive Suction Head NRC Nuclear Regulatory Commission OECR Off-site Economic Cost Risk OSP Off-site Power PDR Population Dose Risk PDS Plant Damage State PORV Pressure-Operated Relief Valve PRA Probabilistic Risk Assessment PSA Probabilistic Safety Assessment PWR Pressurized Water Reactor RAS Recirculation Actuation System RCIC Reactor Core Isolation Cooling RCP Reactor Coolant Pump RCS Reactor Coolant System RHR Residual Heat Removal RPS Reactor Protection System RPV Reactor Pressure Vessel RRW Risk Reduction Worth RWSP Refueling Water Storage Pool RWST Refueling Water Storage Tank SAMA Severe Accident Mitigation Alternative SAM DA Severe Accident Mitigation Design Alternative SAMG Severe Accident Management Guideline SBO Station Blackout scv Steel Containment Vessel soc Shutdown Cooling Page D-5
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Acronym Definition SER Safety Evaluation Report SG Steam Generator SGTR Steam Generator Tube Rupture SI Safety Injection SIS Safety Injection System SMA Seismic Margin Assessment SPDS Safety Parameter Display System SQUG Seismic Qualification Utility Group SRV Safety Relief Valve SSC Systems, Structures, and Components SSEL Safe Shutdown Equipment List SUPS Static Uninterruptible Power Supply SW Service Water TDAFP Turbine-Driven Auxiliary Feedwater Pump TDEFW Turbine-Drive Emergency Feedwater UHS Ultimate Heat Sink VB Vessel Breach WCT Wet Cooling Tower WF3 Waterford Steam Electric Station Unit 3 Windows Melcer Accident Consequences Code WinMACCS System
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| )
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| Page D-6
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment D.1 Evaluation of Probabilistic Safety Analysis Model Page D-7
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1 EVALUATION OF PROBABILISTIC SAFETY ANALYSIS MODEL The severe accident risk was estimated using the Probabilistic Safety Analysis (PSA) model and a Level 3 model developed using the most recent version (version 3.10.0) of the Windows Melear Accident Consequences Code System (WinMACCS code). The CAFTA code was used to develop the Waterford 3 (WF3) PSA Level 1 and Level 2 models. This section provides descriptions of the WF3 PSA levels 1, 2, and 3 analyses, Core Damage Frequency (CDF) uncertainty, Individual Plant Examination of External Events (IPEEE) and NFPA 805 analyses, and PSA model peer review.
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| D.1.1 PSA Model - Level 1 Analysis The SAMA analysis was performed using the most recent WF3 internal events risk models (Level 1 and Level 2). The Level 1 model is documented in PSA-WF3-01-QU [D.1-1] and the Level 2 model is documented in PSA-WF3-01-L2-01 [D.1-2]. The WF3 model adopts the small event tree
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| /large fault tree approach and uses the CAFTA code for quantifying risk.
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| The PSA model has had four major revisions since the IPE due to the following:
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| Modeling changes - The PSA model. was updated with the latest information Power Uprate- Several different analyses were conducted to reflect the Extended Power Update (EPU) plant.
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| Modeling Updates - The PSA model was refined to incorporate the latest state of knowledge and recommendations from internal and industry peer reviews.
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| The internal events PRA model contains the major initiators leading to core damage with baseline CDFs listed in Table D.1-1.
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| The WF3 Level 1 Model was reviewed to identify those potential risk contributors that made a significant contribution to CDF. GDF-based Risk Reduction Worth (RRW) rankings were reviewed down to 1.005. Events below this point would influence the CDF by less than 0.5% and are judged to be highly unlikely contributors for the identification of cost-beneficial enhancements. These basic events; including component failures, operator actions, and initiating events, were reviewed to determine if additional SAMA actions may need to be considered.
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| Table D.1-2 provides a correlation between the Level 1 RRW risk significant events (component failures, operator actions, and initiating events) down to 1.005 identified from the WF3 PSA model and the SAMAs evaluated in Section D.2.
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| Page D-8
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-1 WF3 Model CDF Results by Major Initiators Initiating Event Group Total IE Group Probability %CDF LARGE LOCA 4.87E-09 0.05%
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| AOV Sl-405A DISK RUPTURE WHILE 2.22E-10 0.00%
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| INDICATING CLOSED (YEAR)
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| AOV Sl-4058 DISK RUPTURE WHILE 2.22E-10 0.00%
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| INDICATING CLOSED (YEAR)
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| SI CHECK VALVE 335A RUPTURE 1.59E-11 0.00%
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| (PER YEAR)
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| SI CHECK VALVE 3368 RUPTURE 1.59E-11 0.00%
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| (PER YEAR)
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| SI CHECK VALVE 336A RUPTURE 1.59E-11 0.00%
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| (PER YEAR)
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| SI CHECK VALVE 3368 RUPTURE 1.59E-11 0.00%
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| (PER YEAR)
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| CCF OF 2 FWIVs FAIL TO REMAIN 3.39E-09 0.03%
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| OPEN INADVERTENT OPEN RELIEF VALVE 4.80E-07 4.58%
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| Medium LOCA 3.75E-08 0.36%
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| SI MOV 401A RUPTURES (PER YEAR) 2.22E-10 0.00%
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| SI MOV 4018 RUPTURES (PER YEAR) 2.22E-10 0.00%
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| Steam Generator Tube Rupture 1.03E-07 0.98%
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| RCP SEAL LOCA 9.31 E-08 0.89%
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| Small LOCA 9.49E-07 9.04%
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| Reactor Trip (General Transient) 1.18E-07 1.13%
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| Loss of Condenser Heat Sink 2.51 E-08 0.24%
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| Turbine Trip (General Transient) 1.95E-07 1.86%
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| Page D-9
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Initiating Event Group Total IE Group Probability %CDF Loss of Main Feedwater 9.86E-08 0.94%
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| Loss of Offsite Power 4.42E-06 42.14%
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| Steam Line Break I Leak Inside 4.05E-10 0.00%
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| Containment Steam Line Break Outside Containment 3.57E-08 0.34%
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| or Inadvertent Closure of MSIVs Feedwater Line Break I Leak 5.63E-08 0.54%
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| Loss of Condensate System 6.30E-08 0.60%
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| Loss of CCW System 4.97E-08 0.47%
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| CCW Loss to RCPs Only Initiator 6.30E-09 0.06%
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| Loss Of 6.9KV Bus A 3.45E-09 0.03%
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| Loss Of 6.9KV Bus B 4.18E-09 0.04%
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| LOSS OF 4.16KV BUS 3A3-S 8.79E-07 8.38%
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| LOSS OF 4.16KV BUS 3B3-S 2.53E-06 24.13%
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| LOSS OF 480V BUS 3A31-S 2.75E-08 0.26%
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| LOSS OF 480V BUS 3B31-S 2.86E-08 0.27%
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| LOSS OF 480 V BUS 3AB31-S 7.87E-08 0.75%
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| LOSS OF 480V MCC 3AB311-S 1.44E-09 0.01%
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| Loss of DC Bus A IE 6.94E-08 0.66%
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| Loss of DC Bus B IE 8.17E-08 0.78%
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| Loss of DC Bus AB IE 3.08E-10 0.00%
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| Page D-10
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Initiating Event Group Total IE Group Probability %CDF Loss Of PDP 3014-AB IE 3.02E-10 0.00%
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| Loss of DC Bus TGB IE 6.18E-11 0.00%
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| Loss of Instrument Air System 1.16E-08 0.11%
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| Loss of Turbine Cooling Water System 1.78E-09 0.02%
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| Reactor Vessel Rupture Initiator 3.20E-08 0.30%
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| Total CDF 1.05E-05 100.0%
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| Total ATWS 1 == 1.45E-07 1.38%
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| Total SB0 1 == 3.61 E-06 34.37%
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| Note 1: SBO and A TWS may occur following multiple initiators, thus their contributions to GDF are listed separately.
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| Page D-11
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| Waterford Steam Electric Station unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
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| Event Name I Probability I RRW l Event Description I Disposition I
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| #RX 1.00E+OO 1.0087 RX Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| #SBO 1.00E+OO 11.5237 SBO Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| #SU 1.00E+OO 1.0287 SU Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| #SX 1.00E+OO 11.1318 SX Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| #TB 1.00E+OO 1.49 TB Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| #TK 1.00E+OO 1.014 ATWS Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| #TQX 1.00E+OO 1.1767 TQX Sequence Marker This term is a flag. No SAMAs need to be aligned.
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| This term represents an inadvertent open relief valve, which has similar INADVERTENT OPEN RELIEF VALVE consequences as a small LOCA. Phase II SAMAs 13 and 18 for reducing
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| %10RV 1.83E-03 1.048 <INITIATOR> the frequency of core melt from a small LOCA were evaluated.
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| This term represents a steam generator tube rupture (SGTR). Phase II SAMA 57 for eliminating a release pathway to the environment following a SGTR; SAMAs 58, 59, 60, and 61 for reducing the consequences of a
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| %R 2.07E-03 1.0099 Steam Generator Tube Rupture SGTR; and SAMA 56 for reducing the frequency of SGTRs were evaluated.
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| This term represents a Reactor Coolant Pump (RCP) seal LOCA. Phase II SAMAs 57, 59, 25, 26 and 27 for reducing the likelihood of an RCP seal
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| %RCP 3.67E-04 1.009 RCP SEAL LOCA <INITIATOR> LOCA were evaluated.
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| This term represents a small LOCA. Phase II SAMAs 13 and 18 for
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| %S 3.50E-03 1.0995 Small LOCA reducing the frequency of core melt from a small LOCA were evaluated.
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| This term represents a general transient reactor trip. Phase II SAMA 20 for elimination of ECCS dependency on component cooling system; SAMAs 22, 23, 24, and 25 for increased availability of cooling water; and SAMAs 14, 15, and 17 for improved core injection capability were
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| %Tl 2.12E-01 1.0114 Reactor Trip (General Transient) evaluated.
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| Page D-12
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 I Correlation Event Name I Probability I of~evel 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
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| RRW I Event Description I Disposition I This term represents a general transient turbine trip. Phase II SAMA 20 for elimination of ECCS dependency on component cooling system; SAMAs 22, 23, 24, and 25 for increased availability of cooling water; SAMAs 14, 15, and 17 for improved core injection capability were
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| %T3 2.17E-01 1.0189 Turbine Trip (General Transient) evaluated.
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| This term represents a loss of Main Feedwater. Phase II SAMAs 31, 32, and 33 for increased feedwater availability; and SAMA 34 for improved
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| %T4 7.96E-02 1.0095 Loss of Main Feedwater feedwater supply were evaluated.
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| This term represents a loss of offsite power (LOOP). Phase II SAMAs 13 and 24 for improving offsite power reliability; SAMAs 5 and 7 for increased availability of on-site AC power; and SAMAs 8, 9, and 11 for
| |
| %TS 2.62E-02 1.7282 Loss of Offsite Power increasing diesel generator availability were evaluated.
| |
| This term represents a feedwater line break or leak. Phase II SAMAs 32 and 33 for increased feedwater availability; and SAMA 34 for improved
| |
| %T7 1.83E-03 1.0054 Feedwater Line Break I Leak feedwater supply were evaluated.
| |
| This term represents a loss of the condensate system. Phase II SAMA 32 to create ability for emergency connection of existing or new water
| |
| %T8 2.52E-02 1.006 Loss of Condensate System sources to feedwater and condensate systems was evaluated.
| |
| This term represents a loss of 4.16kV power to bus 3A3-S. Phase II SAMAS 5 and 7 for increased availability of on-site AC power and SAMAs 8, 9, and
| |
| %TAC3 2.18E-03 1.0914 LOSS OF 4.16KV BUS 3A3-S 11 for increased diesel generator availability were evaluated.
| |
| This term represents a loss of 4.16kV power to bus 3B3-S. Phase II SAMAs 5 and 7 for increased availability of on-site AC power and SAMAs 8, 9, and
| |
| %TAC4 2.18E-03 1.318 LOSS OF 4.16KV BUS 3B3-S 11 for increased diesel generator availability were evaluated.
| |
| This term represents a loss of a 480 VAC bus 3AB31-S. Phase II SAMA 13 to install an independent active or passive high pressure injection system;
| |
| %TAC7 5.22E-04 1.0076 LOSS OF 480 V BUS 3AB31-S and phase II SAMAs 35 and 36 to enhance HVAC were evaluated.
| |
| Pc: , -13
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
| |
| Event Name I Probability j RRW I Event Description I Disposition l This term represents a loss of DC bus A. Phase 11 SAMAs 1, 2 and 3 for
| |
| %TDC1 1.84E-04 1.0067 Loss of DC Bus A IE improving DC power availability were evaluated.
| |
| This term represents a loss of DC bus B. Phase II SAMAs 1, 2 and 3 for
| |
| %TDC2 1.84E-04 1.0078 Loss of DC Bus B IE improving DC power availability were evaluated.
| |
| Battery life extended and battery This term is a flag for successful battery load shedding. No SAMAs need AABATT3ABD 1.00E+OO 11.8819 drain occurs to be aligned.
| |
| AACSPEMPTY 1.00E+OO 1.0119 CSP is Empty Flag This term is a flag. No SAMAs need to be aligned.
| |
| Logic flag that indicates Loss of all SG Feed Water (LOSP recovery AALOSPEVTB 1.00E+OO 1.4935 Flag) This term is a flag. No SAMAs need to be aligned.
| |
| Logic flag that indicates that DG/TEDG to 3A3-S has failed (LOSP AA FAIL3AS 1.00E+OO 1.7326 recovery Flag This term is a flag. No SAMAs need to be aligned.
| |
| Logic flag that indicates that DG/TEDG to 3B3-S has failed (LOSP AA FAIL3BS 1.00E+OO 1.775 recovery Flag This term is a flag. No SAMAs need to be aligned.
| |
| AB ELECTRIC POWER IS ALIGNED A TO AB 5.00E-01 11.0137 TOA TRAIN This term is a flag. No SAMAs need to be aligned.
| |
| AB ELECTRIC POWER IS ALIGNED IB_TO_AB 15.00E-01 11.0381 TO B TRAIN This term is a flag. No SAMAs need to be aligned.
| |
| CCWABSTBY 3.30E-01 1.0717 CC Pump AB in standby This term is a flag. No SAMAs need to be aligned.
| |
| CCWASTBY 3.30E-01 11.0715 CC Pump A in standby This term is a flag. No SAMAs need to be aligned.
| |
| This term represents a failure of bus load shedding to extend battery Operators fail to shed battery depletion time. Phase II SAMAs 1, 2 and 3 for improving DC power DHFBAT LSP 1.00E+OO 1.2475 loads for A or B or AB battery availability were evaluated.
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| Page D-14
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 I I Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
| |
| Probability I Event Name RRW I Event Description l Disposition I This term represents a loss of 4.16kV power to bus 3A3-S. Phase II SAMAs 5 and 7 for increased availability of on-site AC power and SAMAs 8, 9, and EB1003A3SF 3.34E-05 1.0087 BUS 3A3-S FAULT 11 for increased diesel generator availability were evaluated.
| |
| This term represents a loss of 4.16kV power to bus 3B3-S. Phase II SAMAs 5 and 7 for increased availability of on-site AC power and SAMAs 8, 9, and EB1003B3SF 3.34E-05 1.0201 BUS 3B3-S FAULT 11 for increased diesel generator availability were evaluated.
| |
| This term represents a failure of breaker 0002A1 which fails bus 3A2.
| |
| Phase 11 SAMAs 5 and 7 for increased availability of on-site AC power and AC BREAKER 0002A1 FAILS TO SAMAs 8 and 9 for increasing diesel generator availability were ECB0002A1D 2.39E-03 1.0201 OPERATE evaluated.
| |
| This term represents a failure of breaker 0002A4 which fails bus 3A2.
| |
| Phase II SAMAs 5 and 7 for increased availability of on-site AC power and AC BREAKER 0002A4 FAILS TO SAMAs 8 and 9 for increasing diesel generator availability were ECB0002A4D 2.39E-03 1.0201 OPERATE evaluated.
| |
| This term represents a failure of breaker 0002B1 which fails bus 3B2.
| |
| Phase II SAMAs 5 and 7 for increased availability of on-site AC power and AC BREAKER 0002B1 FAILS TO SAMAs 8 and 9 for increasing diesel generator availability were ECB0002B1D 2.39E-03 1.0232 OPERATE evaluated.
| |
| This term represents a failure of breaker 0002B4 which fails bus 3B2.
| |
| Phase II SAMAs 5 and 7 for increased availability of on-site AC power and AC BREAKER 0002B4 FAILS TO SAMAs 8 and 9 for increasing diesel generator availability were ECB0002B4D 2.39E-03 1.0232 OPERATE evaluated.
| |
| This term represents a breaker failure that leads to DG 3A-S failing to A312 ASSOCIATED CIRCUITS FAIL start. Phase II SAMAs 5, 6, 7, and 10 for increased availability of AC power ECB312A8MD 2.39E-03 1.0278 TO STRIP ON DEMAND were evaluated.
| |
| This term represents a breaker failure that leads to DG 3B-S failing to B312 ASSOCIATED CIRCUITS FAIL start. Phase II SAMAs 5, 6, 7, and 10 for increased availability of AC power ECB312B8MD 2.39E-03 1.0261 TO STRIP ON DEMAND were evaluated.
| |
| Pc -15
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
| |
| ,Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (13ased on CDF)
| |
| Event Name I Probability I RRW I Event Description ! Disposition I This term represents a breaker failure that leads to DG 3A-S failing to A313 ASSOCIATED CIRCUITS FAIL start. Phase II SAMAs 5, 6, 7, and 10 for increased availability of AC power ECB313A8MD 2.39E-03 1.0278 TO STRIP ON DEMAND were evaluated.
| |
| This term represents a breaker failure that leads to DG 3B-S failing to B313 ASSOCIATED CIRCUITS FAIL start. Phase II SAMAs 5, 6, 7, and 10 for increased availability of AC power ECB313B8MD 2.39E-03 1.0261 TO STRIP ON DEMAND were evaluated.
| |
| This term represents a breaker failure that leads to DG 3A-S failing to A314 ASSOCIATED CIRCUITS FAIL start. Phase II SAMAs 5, 6, 7, and 10 for increased availability of AC power ECB314A2MD 2.39E-03 1.0278 TO STRIP ON DEMAND were evaluated.
| |
| This term represents a breaker failure that leads to DG 3B-S failing to B314 ASSOCIATED CIRCUITS FAIL start. Phase II SAMAs 5, 6, 7, and 10 for increased availability of AC power ECB314B2MD 2.39E-03 1.0261 TO STRIP ON DEMAND were evaluated.
| |
| This term represents a loss of startup transformers. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for increased CCF 2 OF 2 SUT FAIL TO PROVIDE availability of on-site AC power; and SAMAs 8, 9, and 11 for increasing ECCOOOSUTF 1.60E-04 1.0177 OUTPUT diesel generator availability were evaluated.
| |
| This term represents the diesel generators failing to run. Phase II SAMAs CCF DIESEL GENERATORS FAIL TO 5, 6, 7, 10, 11, and 13 for increased availability of AC power were ECCDGNORUN 7.20E-05 1.0108 RUN evaluated.
| |
| CCF DIESEL GENERATORS FAIL TO This term represents the diesel generators failing to start. Phase II SAMAs ECCDGSTART 1.92E-05 11.0059 START 5, 6, 7, 10, and 13 for increased availability of AC power were evaluated.
| |
| This term represents a loss of Diesel Fuel Oil, which leads to loss of DGs A CCF Diesel Fuel Oil Transfer Pumps and B. Phase II SAMAs 5, 6, 7, 10, and 11 for increased availability of AC ECCFOXFRA 1.41E-04 1.0454 Fail to Start power were evaluated.
| |
| DIESEL GENERATOR 3A-S FAILS TO This term represents a failure of DG 3A-S to start. Phase II SAMAs 5, 6, 7, EDGODG3ASAE 1.56E-03 11.0178 START 10, and 13 for increased availability of AC power were evaluated.
| |
| Page D-16
| |
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
| |
| Event Name I Probability I RRW I Event Description I Disposition I DIESEL GENERATOR 3A-S FAILS TO This term represents a failure of DG 3A-S to run after the first hour of RUN AFTER FIRST HOUR OF operation. Phase II SAMAs 5, 6, 7, 10, 11, and 13 for increased availability EDGODG3ASFE 5.48E-03 1.0381 OPERATION of AC power were evaluated.
| |
| DIESEL GENERATOR 3B-S FAILS TO This term represents a failure of DG 3B-S to start. Phase II SAMAs 5, 6, 7, IEDGODG3BSAE li.56E-03 11.0167 START 10, and 13 for increased availability of AC power were evaluated.
| |
| DIESEL GENERATOR 3B-S FAILS TO This term represents a failure of DG 3B-S to run after the first hour of RUN AFTER FIRST HOUR OF operation. Phase II SAMAs 5, 6, 7, 10, 11, and 13 for increased availability EDGODG3BSFE 5.48E-03 1.0371 OPERATION of AC power were evaluated.
| |
| This term represents a failure of a human action to energize bus AB3-S from bus opposite initial supply. Phase II SAMAs 6, 7, and 10 for increased availability of on-site and offsite power and SAMAs 8, 9, and 11 for increased diesel generator availability were evaluated. In addition, the Failure to energize bus 3AB3-S failure of this human action causes a loss of battery power due to a loss from bus opposite initial of AC power in which phase II SAMAs 1 and 2 for improving DC power EHFALNAB_P 1.00E+OO jl.0481 supply--recovery flag availability were evaluated.
| |
| This term represents a failure ofthe exhaust fan for DG 3A-S. Phase II MOTOR-DRIVEN FAN EXFANA SAMAs 5, 6, 7, 10, and 13 for increased availability of AC power were EMFEXFANAA 8.42E-04 1.0094 FAILS TO START evaluated.
| |
| MOTOR-DRIVEN FAN EXFANA . This term represents a failure of the exhaust fan for DG 3A-S. Phase II FAILS TO RUN AFTER FIRST HOUR SAMAS 5, 6, 7, 10, 11, and 13 for increased availability of AC power were EMFEXFANAF 1.04E-03 1.0068 OF OPERATION evaluated.
| |
| MOTOR-DRIVEN FAN EXFANA This term represents a failure of the exhaust fan for DG 3A-S. Phase II FAILS TO RUN DURING FIRST HOUR SAMAs 5, 6, 7, 10, and 13 for increased availability of AC power were EMFEXFANAL 1.07E-03 1.0121 OF OPERATION evaluated.
| |
| This term represents a failure of the exhaust fan for DG 3B-S. Phase II MOTOR-DRIVEN FAN EXFANB SAMAs 5, 6, 7, 10, and 13 for increased availability of AC power were EMFEXFANBA 8.42E-04 1.0089 FAILS TO START evaluated.
| |
| Pc: -17
| |
| | |
| Waterford Steam Electric Station unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
| |
| Event Name! Probability I RRW I Event Description I Disposition I MOTOR-DRIVEN FAN EXFANB This term represents a failure of the exhaust fan for DG 3B-S. Phase II FAILS TO RUN AFTER FIRST HOUR SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC power were EMFEXFANBF 1.04E-03 1.0066 OF OPERATION evaluated.
| |
| MOTOR-DRIVEN FAN EXFANB This term represents a failure of the exhaust fan for DG 3B-S. Phase II FAILS TO RUN DURING FIRST HOUR SAMAs 5, 6, 7, 10, and 13 for increased availability of AC power were EMFEXFANBL 1.07E-03 1.0113 OF OPERATION evaluated.
| |
| This term represents a loss of Diesel Fuel Oil, which leads to loss of DG Fuel Oil Transfer Pump 3A-S.Phase II SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC EMPOILTRAA 5.68E-03 1.0695 EDG-MPMP-OOOlA Fails to Start power were evaluated.
| |
| This term represents a loss of Diesel Fuel Oil, which leads to loss of DG Fuel Oil Transfer Pump 3B-S. Phase II SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC EMPOILTRBA 5.68E-03 1.0651 EDG-MPMP-OOOlB Fails to Start power were evaluated.
| |
| DIESEL GENERATOR 3A-S IN TEST This term represents the unavailability of DG 3A-S. Phase II SAMAs 5, 6, 7, ETMOODG3AS 4.00E-03 1.0352 OR MAINTENANCE 10, and 13 for increased availability of AC power were evaluated.
| |
| DIESEL GENERATOR 3B-S IN TEST This term represents the unavailability of DG 3B-S. Phase II SAMAs 5, 6, 7, IETMOODG3BS 16.09E-03 11.0568 OR MAINTENENCE 10, and 13 for increased availability of AC power were evaluated.
| |
| This term represents a loss of a startup transformer 3A. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for STARTUP TRANSFORMER 3A IN increased availability of on-site AC power; and SAMAs 8, 9, and 11 for ETM SUT-3A 1.75E-03 1.0142 TEST OR MAINTENANCE increasing diesel generator availability were evaluated.
| |
| This term represents a loss of a startup transformer 3B. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for STARTUP TRANSFORMER 3B IN increased availability of on-site AC power; and SAMAs 8, 9, and 11 for ETM SUT-3B 1.75E-03 1.0165 TEST OR MAINTENANCE increasing diesel generator availability were evaluated.
| |
| This term represents a failure to isolate HPSI pump recirculation lines CCF of Sl-120A and 121A to Close after initiation of sump recirc. Phase II SAMAs 29 and 30 for greater HCCISOMNAC 1.llE-05 1.0062 After RAS RWSP inventory were evaluated.
| |
| Page D-18
| |
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1..:2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
| |
| Event Name I Probability I RRW I Event Description I Disposition -1 This term represents a failure to isolate HPSI pump recirculation lines CCF of Sl-120B and 121B to Close after initiation of sump recirc. Phase II SAMAs 29 and 30 for greater HCCISOMNBC 1.llE-05 1.0062 After RAS RWSP inventory were evaluated.
| |
| This term represents HPSI pumps failing to run. Phase II SAMAs 13 and 17 for decreasing HPSI pump CCF were evaluated and Phase II SAMA 12 for increasing the availability of charging which is a backup to HPSI was HCCPMPSBCF 1.46E-05 1.0084 CCF FOR HPSI PUMPS FAIL TO RUN evaluated.
| |
| This term represents a failure of HPSI pump recirculation. Phase II SAMAs HCCSI0602N 1.04E-05 1.0058 CCF Sl-602 FAIL TO OPEN ON RAS 29 and 30 for greater RWSP inventory were evaluated.
| |
| This term represents a failure of a human action to align the standby HPSI pump to replace the failed pump. Phase II SAMAs 13 and 17 for Failure to align standby HPSI pump enhancing the HPSI system by adding or enhancing the HPSI pumps were to replace failed pump--recovery evaluated and Phase II SAMA 27 for increasing the availability of charging HHFALNAB P 1.00E+OO 1.0158 flag which is a backup to HPSI was evaluated.
| |
| Failure to isolate HPSI pump This term represents a failure of a human action to isolate HPSI pump recirculation lines after initiation recirculation lines after initiation of sump recirculation. Phase II SAMAs HHFISOMINP 1.00E+OO 1.0183 of sump recirc 29 and 30 for greater RWSP inventory were evaluated.
| |
| MOV-602A FAILS TO OPEN ON This term results in a failure of HPSI train A recirc mode. Phase II SAMAs HMVSl602AN 9.63E-04 1.0059 DEMAND 29 and 30 for greater RWSP inventory were evaluated.
| |
| MOV-602B FAILS TO OPEN ON This term results in a failure of HPSI train B recirc mode. Phase II SAMAs HMVSl602BN 9.63E-04 1.0053 DEMAND 29 and 30 for greater RWSP inventory were evaluated.
| |
| HPSI AB IS ALIGNED AS STANDBY HPIABISSTBY 3.30E-01 li.0051 PUMP This term is an alignment flag. No SAMAs need to be aligned.
| |
| HPSI A is the Standby pump for H PIAISASTBY 3.30E-01 1.0067 Train A (I PE) This term is an alignment flag. No SAMAs need to be aligned.
| |
| HPSI Bis the standby pump for HPIBISBSTBY 3.30E-01 1.0067 Train B (IPE) This term is an alignment flag. No SAMAs need to be aligned.
| |
| P; -19
| |
| | |
| Waterford Steam Electric Station unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 .Risk Significant Terms to Evaluated SAMAs (Based on CDF)
| |
| Event Name I Probability J RRW I Event Description j Disposition I I
| |
| This term represents adverse MTC during an ATWS event. Phase II SAMAs 63, 64, 65, and 66 for improved reliability during an ATWS were KMTCO 4.00E-01 1.0137 ADVERSE MTC (-1.145 MTC) evaluated.
| |
| This term represents a mechanical failure of the reactor to trip. Phase II FAILURE OF REACTOR TRIP SAMAs 63, 64, 65, and 66 for improved reliability during an ATWS were KRTMECH 8.40E-07 1.014 (MECHANICAL) evaluated.
| |
| This term is a loss of offsite power (LOOP) after a plant trip. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for increased availability of on-site AC power; and SAMAs 8, 9, and 11 for LOSP-EPRI 1.00E-03 1.0105 Conditional LOSP after a plant trip increasing diesel generator availability were evaluated.
| |
| This term represents a failure of a human action to trip the RCPs following a loss of seal cooling leading to a Reactor Coolant Pump (RCP)
| |
| Failure to trip RCPs following loss seal LOCA. Phase II SAMAs 23, 24, 25, 26, and 27 for reducing the OHFRCPTRIP 1.00E+OO 1.177 of seal cooling likelihood of an RCP seal LOCA were evaluated.
| |
| CCF 4 of 4 EFW AOVs 223A, 2238, This term represents a failure of EFW due to CCF valve failures. Phase II QCC442234N 3.74E-06 1.0139 224A,2248 SAMAs 32, 33 and 34 for increased feedwater availability were evaluated.
| |
| CCF 4 of 4 EFW AOVs 228A, 2288, This term represents a failure of EFW due to CCF valve failures. Phase II QCC442289N 3.74E-06 1.0139 229A,2298 SAMAs 32, 33 and 34 for increased feedwater availability were evaluated.
| |
| This term represents a failure of EFW Motor driven pumps. Phase II SAMAs 32, 33, and 34 for increased feedwater availability were QCCPMDPSSF 8.66E-05 1.0153 CCF EFW MDP FAIL TO RUN evaluated.
| |
| This term represents a failure of all EFW pumps. Phase II SAMAs 32, 33, QCCPUMPSSF 1.33E-05 1.0518 CCF ALL EFW PUMPS FAIL TO RUN and 34 for increased feedwater availability were evaluated.
| |
| This term represents failure of a human action to supply makeup to the CSP during EFW operation. This term is essentially a flag for the HFE and no combination or H FE with the associated probability are contained in Failure to supply makeup to CSP the RRW tables. Phase II SAMA 32 is also evaluated for making the QHFCSPEMPP 1.00E+OO 1.0052 during EFW operation transfer ofthe condensate storage pool to the DWST automatic.
| |
| Page D-20
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (.Based on CDF)
| |
| Event Name l Probability I RRW I Event Description J Disposition I This term represents failure of a human action to align EFW suction to WCT after CSP depletion. This term is essentially a flag for the HFE and no combination or HFE with the associated probability are contained in the Failure to align EFW suction to RRW tables. Phase II SAMA 32 is also evaluated for making the transfer of QHFCSPWCTP 1.00E+OO 1.0085 WCT after CSP depletion the condensate storage pool to the DWST automatic.
| |
| MOTOR-DRIVEN PUMP EFW PMP This term represents a failure to start of EFW pump A. Phase II SAMAs 32, QMPEFPMPAAQ 5.75E-04 1.0068 A FAILS TO START 33, and 34 for increased feedwater availability were evaluated.
| |
| MOTOR-DRIVEN PUMP EFW PMP A FAILS TO RUN AFTER FIRST HOUR This term represents a failure to run of EFW pump A. Phase II SAMAs 32, QMPEFPMPAF 2.83E-03 1.0354 OF OPERATION 33, and 34 for increased feedwater availability were evaluated.
| |
| MOTOR-DRIVEN PUMP EFW PMP This term represents a failure to start of EFW pump B. Phase II SAMAs 32, QMPEFPMPBAQ 5.75E-04 1.0068 B FAILS TO START 33, and 34 for increased feed water availability were evaluated.
| |
| EFW MDP A TRAIN UNAVAILABLE This term represents unavailability of EFW pump A. Phase II SAMAs 32, QTMEFWPPAM 6.27E-04 11.0067 (MAINTENANCE) 33, and 34 for increased feedwater availability were evaluated.
| |
| EFW MDP B TRAIN UNAVAILABLE This term represents unavailability of EFW pump B. Phase II SAMAs 32, QTMEFWPPBM 6.27E-04 1.007 (MAINTENANCE) 33, and 34 for increased feedwater availability were evaluated.
| |
| TURBINE-DRIVEN PUMP 3PMPAB This term represents a failure of the turbine-driven EFW pump. Phase II FAILS TO RUN AFTER FIRST HOUR SAMAs 32, 33, and 34 for increased feedwater availability were QTP3PMPABF 3.06E-02 1.0974 OF OPERATION evaluated.
| |
| This term represents the transfer closed of a manual valve that results in failure of the DWSTto CSP flow path. Phase II SAMA 32 is evaluated for MANUAL VALVE CMU142 making the transfer of the condensate storage pool to the DWST QXVCMU142K S.53E-04 1.0052 TRANSFERS CLOSED automatic.
| |
| This leads to a loss of Component Cooling Water (CCW) to DG 3A-S. Phase AIR-OPERATED VALVE CC413A II SAMAs 8 and 9 for backup sources of diesel generator cooling were SAVCC413AN 9.51E-04 1.0107 FAILS TO OPEN evaluated.
| |
| Pc:* *-21
| |
| | |
| Waterford Steam Electric Station unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF)
| |
| Event Name I Probability I RRW I, Event Description. I Disposition I This leads to a loss of Component Cooling Water (CCW} to DG 3B-S. Phase AIR-OPERATED VALVE CC-413B II SAMAs 8 and 9 for backup sources of diesel generator cooling were SAVCC413BN 9.51E-04 1.01 FAILS TO OPEN evaluated.
| |
| CCF of ACCW Pump Discharge Isolation MOVs ACC-110A/B Fail To This represents CCF of the ACCW pump discharge isolation valves. Phase SCCPMPISON 1.85E-05 1.0104 Open II SAMAs 22 and 23 to decrease the importance of ACCW were evaluated.
| |
| This term represents failure of a human action to align CCW train AB to replace lost train A or B. Phase II SAMAs 8, 9, 20, 23, and 27 to decrease Failure to align CCW train AB to the importance of and enhance the availability and reliability of the CCW SHFABCCWRP 1.00E+OO 1.1549 replace lost train A or B system to provide cooling water were evaluated.
| |
| This term represents unavailability of CCW train B. Phase 11 SAMAs 8, 9, 20, 23, and 27 to decrease the importance of and enhance the availability CCW TRAIN B UNAVAILABLE DUE and reliability of the CCW system to provide cooling water were STMCCTRNBF 1.17E-03 1.015 TO TEST/MAINTENANCE evaluated.
| |
| This term represents a failure of the exhaust fans for both DGs. Phase II CCF EDG EXHAUST FANS FAIL TO SAMAs 5, 6, 7, 10, and 13 for increased availability of AC power were UCCEDGFANA 8.42E-05 1.0266 START evaluated.
| |
| This term represents a failure of the exhaust fans for both DGs. Phase II CCF EDG EXHAUST FAN FAILS TO SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC power were UCCEDGFANF 1.07E-04 1.0161 RUN evaluated.
| |
| This term represents a failure of room cooling for DG 3A-S. Phase II INLET DAMPER HVR-501A FAILS TO SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC power were UMCHV501AN 5.80E-04 1.0064 OPEN evaluated.
| |
| This term represents a failure of room cooling for DG 3B-S. Phase II INLET DAMPER HVR-5018 FAILS TO SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC power were UMCHV501BN 5.80E-04 1.006 OPEN evaluated.
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| Page D-22
| |
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2 Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based on CDF}
| |
| Event Name I Probability I RRW I Event Description I Disposition I This term represents a failure of the exhaust fan for DG 3A-S. Phase II EDG EXHAUST FAN UNAVAILABLE SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC power were UTMFANA3AS 2.00E-03 1.0193 DUE TO TEST OR MAINTENANCE evaluated.
| |
| This term represents a failure of the exhaust fan for DG 3B-S. Phase II EDG EXHAUST FAN B IN TEST OR SAMAs 5, 6, 7, 10, 11, and 13 for increased availability of AC power were UTMFANB3BS 2.00E-03 1.0192 MAINTENANCE evaluated.
| |
| CCFACCW BASIN STRAINERS This represents CCF of the ACCW basin strainers. Phase II SAMAs 22, 23, XCCWCTSTRP 3.60E-05 1.0204 PLUGGED 24, 25 and 26 to decrease the importance of ACCW were evaluated.
| |
| MOTOR DRIVEN PUMP ACCW-lA This represents a failure of MDP ACCW-lA. Phase II SAMAs 19, 21, 22, 23, XMP3ACCWAAX l.54E-03 1.0071 FAILS TO START 24, 25 and 26 to decrease the importance of ACCW were evaluated.
| |
| MOTOR DRIVEN PUMP ACCW-lB This represents a failure of MDP ACCW-18. Phase II SAMAs 19, 21, 22, 23, XMP3ACCWBAX 1.54E-03 1.0062 FAILS TO START 24, 25 and 26 to decrease the importance of ACCW were evaluated.
| |
| This term represents a failure of a human action to perform bus load Failure to shed loads on the A or B shedding. Phase II SAMAs 1, 2, and 3 for improving DC power availability ZDHFBAT LSP 8.40E-02 1.0398 battery were evaluated.
| |
| This term represents a failure of a human action to align CCW train AB to Failure to align CCW train AB to replace lost train A or Band failure to trip RCPs after loss of seal cooling.
| |
| replace lost train A or Band failure Phase II SAMAs 8, 9, 20, 23, and 27 to decrease the importance of and to trip RCPs after loss of seal enhance the availability and reliability of the CCW system to provide cooling (SH FABCCWRP
| |
| * cooling water were evaluated. Phase II SAMAs 24, 25, and 26 for reducing ZHF-C2-011 8.20E-04 1.1294 OHFRCPTRIP) the likelihood of an RCP seal LOCA were evaluated.
| |
| PC -23
| |
| | |
| Waterford Steam Electric Station unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1~2 I . Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs .(Based on CDF)
| |
| Event Name] Probability I RRW I Event Description I Disposition 1 This term represents a failure of a human action to trip RCPs or swap AB bus supply. Phase II SAMAs 23, 24, 25, 26, and 27 for reducing the likelihood of an RCP seal LOCA were evaluated. Phase II SAMAs 6, 7, and 10 for increased availability of on-site and offsite power and SAMAs 8, 9, and 11 for increased diesel generator availability were evaluated. In Failure to trip RCPs or swap AB bus addition, the failure of this human action causes a loss of battery power supply {OHFRCPTRIP
| |
| * due to a loss of AC power in which phase II SAMAs 1 and2 for improving ZHF-C2-052 1.20E-04 1.0128 EHFALNAB_P) DC power availability were evaluated.
| |
| This term represents a failure of a human action to align CCW train AB to replace lost train A or Band failure to trip RCPs after loss of seal cooling and failure to energize bus 3AB3-S from bus opposite initial supply. Phase II SAMAs 8, 9, 20, 23, and 27 to decrease the importance of and enhance the availability and reliability of the CCW system to provide cooling water Failure to align CCW train AB to were evaluated. Phase II SAMAs 24, 25, and 26 for reducing the likelihood replace lost train A or Band failure of an RCP seal LOCA were evaluated. Phase II SAMAs 6, 7, and 10 for to trip RCPs after loss of seal increased availability of on-site and offsite power and SAMAs 8, 9, and 11 cooling and failure to energize bus for increased diesel generator availability were evaluated. In addition, the 3AB3-S from bus opposite initial failure of this human action causes a loss of battery power due to a loss supply {SHFABCCWRP
| |
| * of AC power in which phase II SAMAs 1 and 2 for improving DC power ZHF-C3-020 1.20E-04 1.0168 OHFRCPTRIP
| |
| * EHFALNAB_P) availability were evaluated.
| |
| Failure to isolate HPSI pump This term represents a failure of a human action to isolate HPSI pump recirculation lines after initiation recirculation lines after initiation of sump recirculation. Phase II SAMAs ZHFISOMINP 3.20E-05 1.0181 of sump recirc 29 and 30 for greater RWSP inventory were evaluated.
| |
| This term represents a failure of a human action to trip the RCPs following a loss of seal cooling leading to a Reactor Coolant Pump {RCP)
| |
| Failure to trip RCPs following loss seal LOCA. Phase II SAMAs 23, 24, 25, 26, and 27 for reducing the ZHFRCPTRIP 2.20E-03 1.0057 of seal cooling likelihood of an RCP seal LOCA were evaluated.
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| Page D-24
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-2
| |
| '
| |
| Correlation of Level 1 Risk Significant Terms to Evaluated SAMAs (Based' on CDF)
| |
| Event Name I Probability I RRW .I Event Description I Disposition I This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for LOOP Recovery with Batt Depl and increased availability of on-site AC power; and SAMAs 8 and 9 for ZLOOP_BO 9.52E-02 1.2877 0 Run Fail increasing diesel generator availability were evaluated.
| |
| I This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for LOOP Recovery with Batt Depl and increased availability of on-site AC power; and SAMAs 8 and 9 for ZLOOP _BONL 1.59E-01 1.0323 0 Run Fail (No Load Shed) increasing diesel generator availability were evaluated.
| |
| This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for LOOP Recovery with Batt Depl and increased availability of on-site AC power; and SAMAs 8, 9, and 11 for ZLOOP Bl 4.34E-02 1.0674 1 Run Fail increasing diesel generator availability were evaluated.
| |
| ' This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for LOOP Recovery with Batt Depl and increased availability of on-site AC power; and SAMAs 8, 9, and 11 for ZLOOP_BlNL 5.77E-02 1.0069 1 Run Fail (No Load Shed) increasing diesel generator availability were evaluated.
| |
| I This term represents a failure to recover offsite power when lost. Phase II I SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for LOOP Recovery without Batt Depl increased availability of on-site AC power; and SAMAs 8, 9, and 11 for ZLOOP Dl 1.07E-01 1.0092 and 1 Run Fail increasing diesel generator availability were evaluated.
| |
| Pc -25
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage CDF Uncertainty The uncertainty associated with core damage frequency was estimated and documented in the WF3 PSA Uncertainty and Sensitivity Analysis Report [D.1-3].
| |
| The ratio of the 95th percentile GDF to the mean is approximately 1.99. An uncertainty factor of 1.99 was applied to determine the internal and external benefit with uncertainty as described in Section 4.15.1.4.4.
| |
| D.1.2 PSA Model - Level 2 Analysis D.1.2.1 Containment Performance Analysis The WF3 Level 2 PSA model used for the SAMA analysis is the most recent internal events risk model.
| |
| The WF3 Level 2 model includes two types of considerations: 1) a deterministic analysis of the physical processes for a spectrum of severe accident progressions, and 2) a probabilistic analysis component in which the likelihood of the various outcomes are assessed. The deterministic analysis examines the response of the containment to the physical processes during a severe accident. This response is performed by
| |
| * utilization of the MAAP 4.0.6 code [D.1-2] to simulate severe accidents that have been identified as dominant contributors to core damage in the Level 1 analysis, and
| |
| * reference calculation of several hydrodynamic and heat transfer phenomena that occur during the progression of severe accidents. Examples include debris cool-ability, pressure spikes due to ex-vessel steam explosions, direct containment heating, high pressure melt ejection, molten debris filling the pedestal area and flowing over the drywell floor, containment bypass, deflagration and detonation of hydrogen, and thrust forces at reactor vessel failure.
| |
| The development of the CET was based on the plant-specific information and conditions associated with the Level 1 event tree end states that result in a plant core damage state. Using the information from the Level 1 core damage states including the accident sequence, equipment availability, and Containment Heat Removal (CHR) systems, the Level 1 core damage states were used to define the initial states for the Level 2. The progression of these Level 2 initial states through the CETs ends in a radionuclide release end state (CET end state). The WF3 Level 2 containment event trees model the postulated course of core melt progression events. This CET tool integrates the sequence-based accident scenario with the plant mitigation features (active and passive}, operator actions, phenomenological effects, and containment capability to calculate the fission product (FP) distribution .
| |
| . Four CETs have been developed to address the core melt progression and radioactive releases associated with the Level 2 plant response [D.1-2].
| |
| The event tree headings are based on previously developed CETs [D.1-4] and results obtained from the deterministic MAAP calculations for each of the Level 2 accident sequences. A summary of the CET tops are included in table D.1-3.
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| Page D-26
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage The Large Early Release Frequency (LERF) is an indicator of containment performance from the Level 2 results because the magnitude and timing of these releases provide the greatest potential for early health effects to the public. The frequency calculated is approximately 1.88E-06/ry.
| |
| LERF represents a fraction (-18%) of all release end states. Table D.1-4 provides a correlation between the Level 2 LERF RRW risk significant events (severe accident phenomenon, initiating events, component failures and operator actions) and Table D.1-5 provides the correlation between all level 2 release states RRW risk significant events down to 1.005 identified from the WF3 PRA Level 2 model and the SAMAs evaluated in Section D.2.
| |
| Table D.1-3 CONTAINMENT EVENT TREE TOPS CETTop Description of CET Top CFC Containment Fans ON cs Containment Sprays ON CB Containment Bypass Cl Containment Isolation 1-SGTR Induced SGTR Occurs DP Depressurization Successful REC RPV Water Level Sufficient EXC Successful Ex-Vessel Cooling CFE No Early Containment Failure CAV Wet Cavity VB Vessel Intact- No Breach BMT Basemat Melt Through CFL No Late Containment Failure Because deterministic MAAP calculations were performed for each of the Level 1 core damage sequences, no binning of the accident sequences was performed to group plant damage states with similar accident sequence characteristi.cs, mitigating systems, and containment responses.
| |
| The sequence-specific Level 2 responses were evaluated directly from the MAAP results. To provide a more accurate determination of the Level 2 sequence response, different configurations of Containment Heat Removal (CHR) system performance was applied to each Level 2 sequence and evaluated independently.
| |
| CHR systems are key to.integrity and performance of the containment structure during the Level 2 accidents analysis. As a result, four CHR configurations were developed to represent the specific combination of the CHR systems available during the accident progression. These configurations of the Level 2 sequences and CHR systems are represented in four separate event trees as follows:
| |
| * Tree B: Both containmen_t spray system (CSS) and containment fan coolers (CFC) are available and operate (CHR-B)
| |
| * Tree D: CFC is available and operates; CSS are not available or fail to operate (CHR-D)
| |
| * Tree F: CSS is available and operates; CFC are not available or fail to operate (CHR-F)
| |
| * Tree H: Neither CSS nor CFC is available or successfully operates (CHR-H)
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| Page D-27
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage The sections below describe top events used in the development of the CET.
| |
| D.1.2.1.1 CFC - Containment Fans ON The CFC CET Top considers the operation of the containment fans for the removal of heat from the containment atmosphere and the reduction of containment pressure. The configuration of the containment heat removal systems has been integrated with the Level 1 core damage sequences as part of the generation of the Level 2 accident sequence. This integration is consistent with the previous WF3 Level 2 analysis [D.1-4].
| |
| Level 2 accident sequences with the CHR configuration of B or D are considered to have successful operation of the containment fans, whereas CHR configurations of F and H are not considered to be successful due to failure of the containment fans to operate. Success of the CFC top is considered as the successful start and long-term operation of 2 of 4 containment cooling fans [D.1-5, D.1-6].
| |
| For SBO sequences, the loss of power results in the failure of the containment cooling fans to start. As a result, no operation of the containment fans is considered for SBO sequences.
| |
| D.1.2.1.2 CS - Containment Sprays ON The CS CET Top considers the operation of the CSS for the removal of heat from the containment atmosphere, the reduction of containment pressures, limiting hydrogen concentrations, and the removal of radioactive components. Like the CFC CET Top, the CS CET Top is integrated with the Level 1 core damage sequences as part of the generation and evaluation of the Level 2 accident sequences and is consistent with the previous WF3 Level 2 analysis [D.1-4].
| |
| Level 2 accident sequences with the CHR configuration of 8 or F are considered to have successful operation of the containment sprays, whereas CHR configurations of D and H are not considered to be successful due to failure of the containment sprays to operate. Success of the CS top is considered as the succei;;sful start and operation of 1 of 2 containment spray trains
| |
| [D.1-5, D.1-6]. The Level 2 does not consider refilling of the RWSP or alternate water sources, and as a result, the operation of the containment spray following depletion of the RWSP is not considered. In addition, the operation of containment spray in recirculation mode is not considered in the Level 2 because the Level 1 sequences with successful recirculation do not
| |
| ,. progress to core damage.
| |
| For SBO sequences, the initial loss of power results in the failure of the containment spray system. For SBO sequences where the batteries are credited for short-term, no credit is assumed
| |
| . for the operation of the containment spray system.
| |
| D.1.2.1.3 CB - <;;ontainment Bypass The CB CET Top considers a unique set of Level 2 accident sequences where an early pathway opens as a result of a pipe break outside of containment that would allow for the unmitigated release of fission products (FP) to the environment. Because a bypass sequence results in a containment release at a time point coincident with the initiation of the accident, the FP releases from the bypass sequence are characterized as unmitigated. The shortened residence time of the FP in containment are released without the benefit of radioactive decay time, scrubbing effects, or gravitational settling.
| |
| Accident sequences with the potential to bypass a traditional containment failure include SGTR
| |
| . Page D-28
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage and ISLOCA. In addition to the early containment release pathway, mitigation actions engaged during an ISLOCA and SGTR sequence result in the release of RWSP water outside of containment. This depletion of water available for cooling of the core or cerium, or scrubbing of FP releases, contributes to the potential for severe consequences associated with these containment bypass sequences.
| |
| As a result of the early unmitigated release pathway, all containment bypass sequences are characterized as high-early release scenarios.
| |
| The CB CET Top is successful when no containment bypasses occur.
| |
| D.1.2.1.4 Cl - Containment Isolation The Cl CET Top considers containment isolation failures in excess of 2.25 inches [D.1-6, D.1-7]
| |
| which is consistent with the definition associated with the LERF analysis. Release scenarios associated with the Cl top include all non-bypass core damage sequences accompanied by a containment isolation failure. Two types of containment isolation failures have been considered, including (1) pre-existing containment flaw failure and (2) isolation failures of the valves, piping, and systems associated with the Containment Isolation System.
| |
| Containment failure due to pre-existing errors, cracks or tears represent a potential direct release pathway for FP release outside of containment. Based on an evaluation of pre-existing flaws conducted as part of the LERF analysis, the WF3 leakage liner tear is found to be less than the LERF sizing of 2.25-inches. As a result, the pre-existing flaw isolation failure was not considered for the LERF in that they represent a small isolation failure. For the purpose of the Level 2, the pre-existing flaw containment isolation failure is conservatively retained and considered as a potential Cl faiiure. Although the liner leakage tear size does not meet the minimum release sizes, this containment isolation failure will be considered in the Level 2 based on the uncertainty associated with the significance of liner cracks and tears in the steel containment vessel (SCV).
| |
| Failure of containment valves, piping, and systems to properly isolate represents another potential containment isolation pathway for FP releases. These failures occur as a result of the failure to isolate containment given actuation of a CIAS signal (pressurizer pressure decreases to 1684 psia or containment pressure increases above 17.1 psia). Penetrations and valves with flow diameters of 2.25-inches and above are considered as potential containment isolation pathways.
| |
| These Cl pathways and their failure modes have been developed as part of the Level 1 and LERF analyses [D.1-8, D.1-6].
| |
| Like the containment bypass sequences, a containment isolation failure has the potential to release radionuclides early in the accident progression. As a result of the early unmitigated release pathway, all containment isolation sequences are characterized as high-early release scenarios. A containment isolation failure is considered for all L2 accident sequences.
| |
| The CET Top Cl is successful when no containment isolation failures occur.
| |
| D.1.2.1.5 1-SGTR -INDUCED STEAM GENERATOR TUBE RUPTURE Induced Steam Generator Tube Rupture (1-SGTR) represents a containment bypass similar to a SGTR sequence. The 1-SGTR CET Top represents a failure of a SG tube as a result of severe accident conditions, either pressure-induced or temperature-induced tube failures. These (
| |
| induced tube failures are similar in nature with other SGTR accident sequences in that they result Page D-29
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage in a containment bypass release scenario. However, these 1-SGTR failures differ from the SGTR sequence in that the tube failures have the potential to occur later in the sequence and may occur in cornbination with other severe accident sequences.
| |
| The 1-SGTR GET Top considers only sequences with potential for induced SG tube failures.
| |
| 1-SGTR can be caused by temperature-induced mechanisms or pressure-induced mechanisms.
| |
| Temperature-induced SGTR (Tl-SGTR) failures result from long-term exposure to high temperatures that result in creep rupture of the tube wall with elevated pressure differential across the primary to secondary system sides. Pressure-induced SGTR (Pl-SGTR) failures result from a high pressure differential between the primary to secondary system sides.
| |
| Based on the L2 MAAP deterministic calculations, potential induced-SGTR failures were identified for sequences with the potential for long-term, high temperature exposure of the tubes and thinning of the tube walls, for sequences with high primary-secondary differential pressures, and for sequences with loss of heat removal.
| |
| Characteristics used to identify potential Pl-SGTR accident sequences included the following
| |
| [D.1-9, D.1-1 O]:
| |
| * Primary-secondary heat removal failures
| |
| * High pressure differential between primary and secondary side (-2500 psid)
| |
| * Timing of rupture likely to occur early, well before core damage Characteristics used to identify potential Tl-SGTR accident sequences included the following
| |
| [D.1-9, D.1-10]:
| |
| * Primary-secondary heat removal failures
| |
| * Accident sequences with loss of feedwater and/or SG dryout
| |
| * Likely to occur after core damage
| |
| * High SG tube surface temperatures
| |
| * Occur in sequences where creep-related failures of RCS piping and other pressure boundary failures are also likely to occur.
| |
| Once potential 1-SGTR scenarios were identified, the timing of the failure was estimated and compared to the timing of other sequence events such as containment failure and creep rupture.
| |
| For sequences where conditions characterizing either Pl-SGTR or Tl-SGTR occurred at or near the timing of a hot leg creep rupture or before containment failure, a potential 1-SGTR was identified. For conditions of 1-SGTR occurring later in the sequence, no probability of an 1-SGTR was assumed to occur. Because no actual tube ruptures occurred based on the MAAP calculations, a probability of occurrence (Pl_SGTR, Pl_SGTR_SBO and Tl_SGTR) was developed to account for the uncertainty in the. understanding of the phenomena and the application of the analyses [D.1-2].
| |
| The GET Top 1-SGTR represents success when no induced SGTR failure occurs. The failure branch, 1-SGTR, represents an early 1-SGTR that occurs and results in the release of FP. 1-SGTR are included in the Level 2 model under the gates named Tl-SGTR, Pl-NSGTR and Pl-SGTR_SBO.
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| Page D-30
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.2.1.6 DP Depressurization The CET Top DP represents the successful depressurization of the RCS to a pressure below the high pressure melt ejection (HPME) minimum of approximately 200 psig [D.1-11 ]. Successful depressurization allows for the operation of SI systems to initiate and aid in lowering the pressure in the RPV to below a pressure where HPME is not expected to occur (approximately 200 psig) prior to a vessel breach.
| |
| Several depressurization mechanisms are available and can be implemented in response to a Level 2 severe accident sequence including:
| |
| * Phenomena based on initiating events (IE)
| |
| * Creep rupture failure of the RCS
| |
| * Sequence-based depressurization IE Phenomena Certain initiating events result in the depressurization of the RCS to levels below the HPME minimum pressure of 200 psig. For WF3, initiating events that lead to depressurization include large, medium, and small break LOCA.
| |
| * DPL - The DPL gate represents a LOCA break scenario in combination with the other features of the accident progression that lead to successful depressurization of the RPV.
| |
| The #DP_LOCA flag has value of 1.0 and represents the inadvertent depressurization associated with a LOCA break.
| |
| * xDPL - The gate, xDPL, is included to address the potential for unsuccessful depressurization of the RPV as a result of the LOCA. The #NO_DP_LOCA flag has value of 1.0 and represents accident conditions in which a LOCA break is unsuccessful in providing depressurization in a timely manner.
| |
| Creep Rupture Another method by which RCS pressure may be reduced prior to RPV failure is by a thermally induced failure of an RCS hot leg. During core melt progression, heat is transferred throughout the RCS piping causing increased gas temperatures in the pipes. When surface temperatures in the piping reach temperatures consistent with failure properties of the metal, a pipe failure due to a thinning of the pipe wall can create an opening in the RCS pipe that acts to depressurize the RCS. RCS piping susceptible to creep failures include the hot legs and pressurizer surge lines.
| |
| The occurrence of a hot leg creep, as indicated by the Level 2 MAAP calculations, facilitates a mechanism by which the RCS begins to depressurize. Due to the small size of the creep rupture openings, a creep rupture alone is not always sufficient to reduce pressure levels to below 200 psig. However, the contribution of the hot leg ru.pture phenomena is accounted for in the progression of the accident sequence. The following gates are included for phenomena related to the occurrence of hot leg creep ruptures.
| |
| * #HLCREEP - The #HLCREEP gate represents the creep failure of a hot leg with the accompanied unintentional depressurization of the RCS prior to containment failure. This flag has a value of 1.0 and is represented by the flag event #HLCREEP.
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| Page D-31
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
| |
| * #NO_HLCREEP-The #NO_HLCREEP gate represents an intact hot leg with no creep damage failure and without any unintentional depressurization. This flag has a value of 1.0 and is represented by the flag event #NO~HLCREEP.
| |
| Sequence-Based Depressurization During the progression of Level 2 accident sequences, operating systems are available and operated to reduce the RCS pressure. Because success of these operating systems is required to the specific sequences, the success and failure of these systems to perform their depressurization functions and to achieve sufficient depressurization to below 200 psig is considered. These sequence-based depressurization operations include:
| |
| * PT01 - This gate models RCS pressure control via the pressurizer to adequately control RCS pressure using SRVs. The function is part of the sequence-specific success criteria and is applied to TRANS sequences that support depressurization of the RPV. The function for successful RCS pressure control is applied to sequences TB, TQX, TQB, and TQU [D.1-5] as part of the sequence definition.
| |
| * @PRAlWS - This gate models the failure of the PRVs to provide depressurization as required forthe AlWS sequence [D.1-12]. The function is part of the sequence-specific success criteria applied to A lWS sequences that aid in the depressurization of the RPV.
| |
| The function for successful operation of the PRVs is applied to sequences TKC, TKX, and TKW [D.1-12] as part of the sequence definition.
| |
| * SBORCPLOCA - This gate represents a leakage failure through the RCP seals. This is a sequence-based event that supports inadvertent depressurization due to RCP seal rupture for SBORCP accident sequences. For the Level 2 analyses, this function is included as part the SBORCP sequence definition under the gate SBORCP The Level 2 MAAP calculations evaluate the successful depressurization of the RPV. The CET Top DP success branch represents RPV depressurization to below the HPME minimum of 200 psig. Similarly, the failure branch represents the failure to adequately reduce RPV pressures.
| |
| However, Level 2 sequences may include the success operation of systems or other measures that provide depressurization, but these are ineffective in lowering the RPV below 200 psig.
| |
| D.1.2.1.7 REC - Reactor Pressure Vessel Reflood and Refill The REC CET Top represents successful SI injection to refill and maintain the RPV water level to ensure core cooling and to prevent vessel breach. Re-flooding of the RPV and maintaining a water level in the RPV serves to re-establish core cooling and to end the core melt progression and subsequent hydrogen generation (zirconium oxide and water reaction). A side effect of re-flooding of the core is the generation of significant amounts of steam that re-pressurize the RPV and re-start the zirconium-water reaction.
| |
| Successful RPV injection and core reflood is dependent upon the operation of the HPI or LPI systems to provide a source of water to provide in vessel cooling of the core, to retain the cerium in vessel, and maintain vessel integrity. For A lWS sequences, the successful injection of borated water into the RCS by the charging pumps is also considered as a potential injection source to refill the RPV. No other active systems or recovery actions are credited to supplement water levels in the RPV.
| |
| Results from the deterministic MAAP calculations were used to evaluate the success of the REC Page D-32
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage top. Successful core reflood is defined as restoration of the RPV water level to greater than 22 ft.
| |
| at the end of injection. This water level represents the elevation of the top of the active fuel within
| |
| =
| |
| the RPV (MAAP Parameter ZCRU 21.926 ft.).
| |
| Reflooding of the RPV to water levels less than 22.0 ft. is considered unsuccessful in the CET Trees despite the successful operation of injection systems. The in-vessel arrest of core melt in accidents that progress rapidly to core melt and/or lead to early core relocation may not be accomplished by SI injection. The timing of the RPV reflood must take place such that appreciable core relocation to the plenum is arrested [D.1-2].
| |
| The following tops are used to model the success and failure of the REC CET top.
| |
| * REC1
| |
| * REC2 For Level 2 accident sequences where no injection sources are credited, a successful REC Top is not considered in the event tree, and the sequence progresses to the next CET top on the down branch. Likewise, no consideration of RPV reflood and recovery is considered in the Level 2 model for these sequences.
| |
| REC1 The REC1 top models HPSI injection as a source of water for re-flooding the RPV. The use of this gate is specific to the success criteria associated with Level 2 accident sequences. Failures in the HPSI syste-m are modeled by the gate H1000 and would lead to a failure of vessel reflood and recovery. As a result, any failures of the system operations and components in the H1000 gate would subsequently result in the failure of the REC1 top. For Level 2 sequences where the HPSI system is credited for RPV re-flood, the REC1 gate is included under the sequence-specific accident sequences.
| |
| REC2 The REC2 top models emergency boration as an injection source for re-flooding of the RPV. The use of this gate is specific to the success criteria associated with Level 2 accident sequences and is used only for ATWS sequences. Failures in the emergency boration system would lead to a failure of vessel re-flood and recovery. For Level 2 accident sequences where emergency boration is credited for RPV re-flood, the REC2 gate is included under the sequence-specific accident sequences.
| |
| D.1.2.1.8 EXC - Ex-Vessel Cooling The EXC CET Top represents the contribution of outside factors to aid in the cooling of the RPV and subsequently the core and corium within the vessel. The contribution of these external cooling factors associated with the EXC CET Top is considered for sequences where internal cooling of the core and restoration of RPV water levels have been unsuccessful (REC). EXC is considered for sequences where RPV injection sources are not considered during the progression of the accident, as well as sequences where active injection sources have been unsuccessful in providing full reflood of the RPV.
| |
| Deterministic MAAP calculations are used to assess the success of the ex-vessel cooling on mitigating in vessel core melt and preventing rupture of the RPV. Successful ex-vessel cooling is defined as a water level in the reactor cavity sufficient to cover the lower head of the RPV. A dry reactor cavity allows for unmitigated heating of the corium to occur in the RPV due to a lack of Page D-33
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage cooling to the RPV. The presence of water in the cavity insulates the RPV and prevents the direct contact of the RPV with these hot gases. A minimum cavity water of 15.5' is defined as successful ex-vessel cooling. This elevation of water column in the cavity corresponds to the elevation of the
| |
| =
| |
| bottom of active fuei (MAAP Parameter ZCRL 9.428 ft.) above the bottom of the RPV (MAAP Parameter ZNVP =6.0 ft.). Maintenance of this water level in the RPV ensures that the lower head is submerged [D.1-2].
| |
| Successful EXC has been shown to occur in large LOCA sequences and in accident sequences with operating containment sprays for containment heat removal. Under these conditions, a large amount of water is being deposited into containment either through the break in the RCS piping or the containment spray headers. This water is conveyed through the floor drain system and ends up in the Containment Sump. With a minimum water level of 3.0 feet in the containment sump, leakage through the gaskets and under the marine access door provides a continuous source of water to fill the Reactor Cavity. Without the contribution from the operating containment sprays, water levels in the reactor cavity are insufficient to submerge the lower RPV head.
| |
| D.1.2.1.9 BURN - Hydrogen Burns in Containment Compartments Hydrogen combustion burns can cause large, rapid increases in pressure and high spikes in temperature that result in a combination of mechanical and thermal load with potential impact to containment integrity. The BURN CET Top assesses the containment compartment conditions that lead to the occurrence of hydrogen burns. With the presence of sufficient concentrations of hydrogen and at elevated temperature, localized burn and global burns have the potential to occur and result in challenges to containment. The success branch of the CET top xBURN represents conditions in the containment compartments that are insufficient to support and propagate hydrogen burns. Similarly, the down failure branch to CET BURN represents conditions conducive to facilitating hydrogen burns that challenge contail')ment and can lead to containment failure.
| |
| Burns that occur in the upper, annular, or upper RPV dome portions of the WF3 containment are considered to lead to containment failures due to the proximity of these containment compartments to the SCV. Burns that occur in other portions of the containment are not considered as events that will challenge containment or result in failure of containment.
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| During the progression of severe accident scenarios, several mechanisms have the potential to produce concentrations of hydrogen both in-vessel and ex-vessel. Some of these mechanisms that produce hydrogen include:
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| * Zircaloy oxidation
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| * Molten cerium-concrete interaction (MCCI)
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| * Steam Reactions with boron carbide, uranium, or steel
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| * Cerium debris Interactions Because hydrogen is a burnable gas in the presence of air, the WF3 large dry containment supports hydrogen burn scenarios.
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| In-Vessel When the reactor core uncovers, zirconium oxidation of the fuel cladding may occur when the cladding comes in contact with steam. Hydrogen is generated during this reaction and is produced at the onset of core damage. As core degradation continues, hydrogen continues to be Page D-34
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage generated as more cladding becomes exposed and the core begins to relocate. If reflooding and quenching of the relocated debris in the RPV occurs, the ziracloy oxidation increases, which in turn increases steam generation due to the cooling effect that also results in increased hydrogen generation. During severe accidents, the hydrogen generated and contained in the RPV can escape through openings in the RCS piping, RCP seal leaks, and lifting of safety and relief valves.
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| If large quantities of hydrogen are generated, hydrogen burns after in-vessel recovery could result in an early release of radionuclides that escaped the fuel during the initial heatup.
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| Ex-Vessel If the core degradation and relocation progress and a vessel rupture occurs, the cerium debris is ejected from the RPV and into cavity compartments contributing to hydrogen concentrations occurring outside of the vessel. At the point of vessel breach, the hydrogen contained in the vessel is released to the cavity and can migrate through containment. Also, as a result of the vessel breach, the cerium debris is ejected and deposited onto the concrete floor of the cavity.
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| This MCCI interaction between the concrete and the ejected core materials will lead to additional hydrogen generation as a result of concrete ablation. If quantities of water are present in the cavity, the rapid cooling of the ejected cerium debris in the water pool can result in large quantities of steam to be produced.
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| The concentration of steam present is an important factor in the potential occurrence of a hydrogen burn. The flammability limits of the two-component mixture (hydrogen:air) differ from the flammability limits of a three-component mixture (hydrogen:air:steam). The changes in flammability limits leads to steam inerting attributed to a' change in the dominant heat transfer pathway by combination of both convective and radiative mechanisms. In environments with moderate quantities of steam present, hydrogen burns can be precluded due the presence of the steam concentrations. Steam concentrations above which denotation can occur in the three-component mixture have been reported from 55% up to 75% for a steam mass fraction.
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| Deterministic MAAP calculations are used to assess the likelihood and occurrence of hydrogen burns in containment. Factors evaluated to assess hydrogen bums include the following:
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| * Concentration of hydrogen present in the containment atmosphere
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| * Steam concentration
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| * Operating containment heat removal systems - ignition source
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| * Ability for a Hydrogen burn to cause a containment failure Hydrogen Concentration Hydrogen gas has the potential to ignite in normal air concentrations at concentrations as low as 4% LEL (lower explosive limit) and up to concentrations of about 75% UEL (upper explosive limit).
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| These limits are based on the two-component mixture (hydrogen:air). These explosive limits are affected by the presence of steam concentrations as discussed below.
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| Steam Concentration Steam inerting due the presence of moderate to high mole concentrations of steam (a range in excess of 55% to 75%) have been shown to prevent hydrogen bums. The Level 2 MAAP calculations used the higher steam fraction of 75%. When steam concentrations exceed this concentration, no hydrogen burns are allowed. This represents an upper limit, which would conservatively allow for the likelihood of more hydrogen burns to occur.
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| Page D-35
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Containment Spray Systems The operation of the containment spray systems affect the localized and global distribution of hydrogen concentrations within the containment environment. The containment spray system
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| * introduces water droplets from the spray header located in the upper portion of containment. As the water droplets fall, steam condensation occurs on the surface of the droplet lowering the steam within containment and thereby the containment pressure. However, the reduction in the concentration of steam corresponds to an increase in hydrogen concentrations within Containment.
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| Burn Causes Containment Failure Hydrogen bums provide challenges to the integrity of containment, including both the thermal and pressure loads and spikes from the propagation of dynamic pressure pulses. This phenomena is not modeled specifically in the MAAP code used for the deterministic Level 2 MAAP calculations.
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| However, for the CET BURN tops, hydrogen burns occurring in the upper, annular, or upper RPV dome portions of the WF3 containment were considered to have the potential to lead to a containment failure given the presence of an ignition source. If AC power is available in the containment, which is required for the operation of the containment heat removal systems, many potential sources of ignition will be present and an ignition source is almost assured.
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| D.1.2.1.10 CFE - Containment Failure Early Early containment failures are failures that occur concurrent with or shortly after the RPV has ruptured. The timing of these failures are based on time of less than 4 hours between vessel rupture and containment failure. The CFE CET Top assesses the Level 2 accident progression and containment compartment conditions that lead to the occurrence of an early containment failure. The success branch of the CET Top xCFE represents an intact early containment status.
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| Similarly, the down failure branch to the CET Top CFE represents a containment status where failure has occurred early.
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| Based on the characteristics and capacity of the WF3 containment, the following forms of early containment failure mechanisms were considered and evaluated as part of the Level 2 analysis.
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| * Hydrogen Burns
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| * Direct Containment Heating (OCH)
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| * Containment Penetration Isolation Failure
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| * Mechanical integrity Failures
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| * Steam Explosions Hydrogen Burns As discussed in D.1.2.1.9 and considered in the CET Top BURN, hydrogen burns present challenges to containment stemming from high thermal and pressure loads and the propagation of dynamic pressure pulses. As a result, hydrogen bums occurring in the upper, annular, or upper RPV dome portions of the WF3 containment are considered to have the potential to lead to a containment failure. Based on the timing of the containment burns, these containment failures may present an early containment challenge.
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| Direct Containment Heating Direct containment heating of the RPV vessel has the potential to lead to an early containment
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| "' -
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| Page D-36
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage failure. In the event of a high pressure ejection of molten cerium from the RPV breach, the potential exists for fragmented core to travel to outside of the cavity to other areas of containment. Oxidation of these fragmented cerium particles may produce significant quantities of heat and hydrogen that can challenge containment. The combination of the RPV breach and containment failure provides significant impact to health and safety due to the early timing of the release and the short residence time in containment to aid in the retention of the fission products.
| |
| Mechanical Integrity Failures Mechanical integrity failures of containment can occur in a number of ways. When a catastrophic vessel breach occurs (initiating event %V), the potential exists for the vessel or pieces of the vessel to become airborne or otherwise dislodged. The uplifting of the vessel structure and/or generation of missiles is likely to result in damage to the containment and/or cavity structure.
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| Steam Explosions An in-vessel steam explosion in the RPV can occur when a large amount of cerium relocates to the lower plenum where it comes in contact with water in the lower head. This encounter with water in the lower head can result in an in vessel explosive steam explosion which may lead to an induced lower head failure or may cause internal RPV structure to be thrust upwards inducing an upper head failure. Due to the energy of these failures, it is likely to result in damage to the containment and/or cavity structure.
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| CFE2 The CFE2 gate is used to model an early containment failure with a given vessel breach. During the vessel breach, the core melt is ejected into the cavity bottom. If the cavity conditions are such that a pool of water has collected, the rapid cooling of the ejected core materials generates large quantities of steam. The WF3 cavity design does permit the.conveyance and collection of the water within the cavity. Based on the L2 MAAP deterministic calculations, an early containment failure occurs as a result of the ejection of the core melt, which causes a rapid formation of steam that leads to containment over-pressurization. Without the operation of containment fans, the cooling and condensation of the steam is limited, and containment pressures increases. Upon reaching the ultimate containment capacity, containment fails.
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| Based on the Level 2 MAAP deterministic results, early containment failures only occur in sequences where both forms of containment heat removal fail to operate. The consideration of this CET Top is only addressed in the CET H event tree.
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| D.1.2.1.11 VB Vessel Breach The VB CET Top represents the conditions within the RPV where significant core degradation has occurred such that the integrity of the reactor pressure vessel has been challenged with a subsequent RPV breach. The fundamental process controlling RPV integrity is the heat removal and cooling of the molten cerium pool within the RPV. The success VB branch (No_VB) in the CETs occurs with sequences where RPV injection source are available and operating (REC) or when sources of water are available in sufficient quantities to support external cooling of the vessel (EXC). The failure VB branch (VB) in the CET considers the remaining sequences where core and vessel cooling mechanisms are unavailable or ineffective. These sequences have a likelihood of leading to extensive rupture of the vessel given the degree of core degradation and Page D-37
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage in-vessel geometry of the core debris.
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| For the accident sequences where in-vessel and ex-vessel cooling actions have not been successful, the core melt has progressed to the lower plenum and subsequently to the RPV bottom. At this point, the melt-vessel interface is the contact point at which the cerium melt and the RPV material interact. The RPV lower head is subjected to the internal system pressure, thermal loads from the cerium melt, and dead loads associated with the relocation of the cerium.
| |
| These factors challenge the mechanical integrity of the RPV and lead the way for creep rupture of the RPV material to occur. Creep of RPV materials occurs at temperatures above 600 °C (1100 OF).
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| The VB CET top considers the following vessel breach mechanisms for the WF3 Level 2:
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| * Catastrophic Vessel Breach
| |
| * Lower Head Failure Mechanism Catastrophic Vessel Breach Catastrophic vessel ruptures are characterized as an unrecoverable vessel failure. Scenarios such as in-vessel steam explosion or vessel failure due to internal relocation of loads are considered as catastrophic failures.
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| Lower Head Failure Mechanisms Mechanisms for lower head vessel breach include the following:
| |
| * Heat up and/or Failure of Instrument Tubes, CRD Tubes, and Drain Line
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| * Ejection of Instrument Tubes, CRD Tubes, and Drain Line (not applicable)
| |
| * Jet ablation of the vessel wall ,
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| * Attack of wall by overlaying steel
| |
| * Creep rupture Because the RPV lower head has no penetrations, the tube ejections and failures are not applicable to the WF3 vessel breach evaluation. The primary mechanism for the vessel breach failure is an extensive creep rupture. A creep rupture represents the long-term exposure of the RPV materials to temperature and pressures that result in thermal stresses that cause thinning of the material wails.
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| '
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| Deterministic MAAP calculations were used to evaluate the RPV integrity for the Level 2 sequences. The MAAP analysis considers vessel failure mechanisms and accounts for a layered lower debris bed model. Creep rupture fractions in the lower head were used to determine the status of the RPV vessel. Failure to maintain an intact VB was determined to be a lower head creep damage fraction in a single node that exceeds 0.4. Creep damage fractions in excess of 0.4 lead to failure of the RPV.
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| Based on the Level 2 MAAP calculations, a breach of the WF3 vessel only occurs with no containment-heat removal systems operating. As a result, the VB CET Top is only addressed in the CET H event tree.
| |
| D.1.2.1.12 CAV - Cavity Status The CAV CET Top represents the status of the reactor cavity at the time of vessel breach. A wet cavity has a sufficient quantity of water to receive the cerium ejected during the vessel breach and mitigate the transport of materials to other areas outside of containment. A dry cavity cannot fully submerge to ejected cerium debris and is thus limited in potential to capture and retain the cerium Page D-38
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage within the cavity.
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| Successful CAV requires the operation of the containment sprays. Under these conditions, spray water is deposited into containment via the containment spray headers. Some of this water is conveyed through the floor drain system and ends up in the Containment Sump. With a minimum water level in the containment sump, leakage through the gaskets and under the marine access door provides a continuous source of water to fill the Reactor ~avity. Without the contribution from the operating containment sprays, water levels in the reactor cavity are insufficient to submerge the lower RPV head.
| |
| Results from the deterministic MMP calculations were used to evaluate the success of the CET Top CAV. A wet cavity is defined as a cavity water level greaterthan 6 ft. (MMP Parameter ZNVP) at the time of vessel breach. Maintenance of this water level in the RPV will provide a wet cavity in the event of an ejection of corium debris for the purpose of capturing and mitigating the dispersion of these materials to other areas of within containment. The CET Top CAV is considered following a VB and is included on the VB failure branch of the CET H event tree.
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| D.1.2.1.13 BMT - Bas'emat Melt Through The BMT CET Top represents the status of the corium debris released from the RPV during VB that is ejected and received in the reactor cavity. The loads released from the RPV can fail containment due to thermal attacks of corium melt on the concrete basemat. This attack by the corium melt can lead to basemat concrete erosion and generation of hydrogen gas and steam which can pressurize containment. Because of the high energies and heat associated with the corium debris, the potential exists for the ejected material to become a long-term source of FP for release.
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| Factors that affect the retention and stabilization of the corium debris include the quantities of material released, the pressure of the RPV at the time of release, and the mechanisms in place to provide cooling or retention of the released corium. The amount of material released to the cavity and the cavity geometry determines the initial depth of the corium. Debris beds with depths greater than 25 cm are considered uncoolable and represent a failure to arrest ex-vessel corium melt [D.1-11]. The failure to arrest the corium debris melt in the cavity can lead to a breach of containment through the lower basemat.
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| An unmitigated core melt on the cavity floor can result in a failure of the basemat. The basemat concrete depth on the floor of the cavity is 12.0 feet thick. A depth of erosion greater than 12.0 feet would have the potential to fail the basemat. In addition, corium spread to the cavity tunnel has the potential to. fail the marine access door that separates the cavity tunnel from the Containment Sump. Failures to the access door could result from the degradation of the gasket seal material or deformation of the door steel plate. However, due to the uncertainty and unknowns associated with basemat melt scenarios, unquenched corium pools with increasing erosion depths are assumed to lead to containment breach based on basemat melt-through.
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| Debris depths following vessel breach were used to evaluate and determine the ability to cease the ex-vessel corium melt based on the deterministic MMP calculations. The success branch of the CET top BMT represents a debris depth in the cavity of less than 25 cm (0.82 ft) where cooling and stabilization of the corium debris spread is still possible. Similarly, the down failure branch to the CET Top (xBMT) represents a debris depth in the cavity of more than 25 cm. The BMT CET Top is considered following VB and is included on the VB failure branch of the CET H event tree.
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| Page D-39
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.2.1.14 CFL - Late Containment Failure Late containment failures are failures of the containment as a result of a vessel breach as well as challenges other than those associated with a breach of the RPV. The timing of these containment failures are based on times of greater than 4 hours from the time of core damage to the time of containment failure. The CET Top CFL assesses the Level 2 accident progression and containment compartment conditions that lead to the occurrence of a late containment failure.
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| The success branch of the CET Top (xCFL) represents an intact late containment status given no early containment failure has occurred. Similarly, the down failure branch to the CET Top CFL represents a containment status where failure has occurred late.
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| Based on the characteristics and capacity of the WF3 containment, the following forms of late containment failure mechanisms were considered and evaluated as part of the Level 2 analysis.
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| * Hydrogen Burns
| |
| * Containment Over-pressurization above the Ultimate Containment Capacity Hydrogen Burns As discussed in Section D.1.2.1.9 and considered in the CET Top BURN, hydrogen burns present challenges to containment stemming from high thermal and pressure loads and the propagation of dynamic pressure pulses. As a result, hydrogen burns occurring in the upper, annular or upper RPV dome portions of the WF3 containment are considered to have the potential to lead to a containment failure. Based on the timing of the containment burns, these containment failures may present an early or late containment challenge. Late containment challenges are considered in the CFL CET Top.
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| Containment Over-Pressurization During the progression of severe accident sequences, mechanisms generate quantities of steam as a result of the heating and oxidation of the core materials, the introduction of sources of cooling water, and the lifting of safety and relief valves. These quantities of steam contribute to a buildup of pressure in containment. At pressures in excess of the containment capacity, containment fails and releases FP outside of containment to the environment.
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| For Level 2 accident sequences where an early containment failure occurs, the CET Top CFL is not considered in the event tree. A successful CFL Top, xCFL, represents an intact containment.
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| A late containment failure is represented on the failure branch of the CET Top CFL branch. The following gates are used to model the failure of the CET Top CFL.
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| * CFL2
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| * CFL3
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| * CFL4
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| * CFLS CFL2 The CFL2 gate is used to model a late containment failure with a vessel breach. Based on the L2 MAAP deterministic calculations, vessel breaches can occur when both containment spray and containment cooling fans fail to operate. As a result, the CFL2 can only occur without the operation of containment heat removal systems fans. Under these conditions, containment pressures increase due to increasing steam concentration from both the release of hydrogen Page D-40
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage from the RPV and the ex-vessel cerium melt, as well as the pressure increases associated with long-term buildup of steam due to no containment heat removal.
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| CFL3 The CFL3 CET Top models a late containment failure due to over-pressurization. For these sequences, the RPV remains intact, but the containment pressure is slowly allowed to increase in containment due to the failure of containment fans to operate. Once the containment pressure in one of the containment compartments - annular, upper dome or upper RPV head - exceeds the containment capacity of 99.3 psig, a rupture in containment occurs and release of FP begins.
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| CFL4 The CFL4 CET Top is used to model a late containment failure due to a hydrogen burn. Based on the L2 MAAP deterministic calculations, a late containment failure due to a hydrogen burn can occur when containment cooling fans operate. Without the operation of containment fans, steam concentrations increase rapidly to levels where steam inerting inhibits hydrogen burns.
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| CFL5 The CFL5 CET Top is used to model containment isolation failures that have the potential to occur as a result of high temperatures (T-CIF) inside of containment. Temperatures in containment in excess of 600 °F are considered in the Level 2 analysis based on the FEA analyses performed to evaluate the ultimate containment capacity [D.1-13]. The containment over pressurization at 600 °F was determined to be 104 psi. Using this over pressurization value, a probability of occurrence corresponds to 0.601.
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| Page D-41
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| Waterford Steam Electric Stati1 t3 Applicant's Environmental Report Operating License Renewal Stage Figure D.1-1 WF3 Radionuclide Release Category Summary Other 0.03% _ _ _~
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| M/L 0.18%
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| 1.28% 0.26%
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| Page D-42
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-4 Correlation of Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Large Early Release Frequency)
| |
| Event Name Probability RRW Event Description Disposition EARLY CONTAINMENT FAILURE WITH VESSEL
| |
| #CFE2 1.00E+OO 5.3337 FAILURE Thi s term is a flag . No SAMAs need to be aligned .
| |
| CHR SEQUENCE MARKER B - Both Sprays and Fans are
| |
| #CHR B 1.00E+OO 1.0683 available and operate rrhis term is a flag . No SAMAs need to be aligned .
| |
| CHR_ H - Neither Sprays nor Fans are available
| |
| #CHR H 1.00E+OO 5.5758 or successfully operate This term is a flag . No SAMAs need to be aligned .
| |
| HOT LEG CREEP
| |
| #HLCREEP 1.00E+OO 5.3337 RUPTURE OCCURS !This term is a flag . No SAMAs need to be aligned .
| |
| PRESURE INDUCED STEAM GENERATOR TUBE RUPTURE - NON
| |
| #Pl -SGTR 1.00E+OO 1.0086 SBO !This term is a flag . No SAMAs need to be aligned .
| |
| PRESURE INDUCED STEAM GENERATOR
| |
| #P l-SGTR-SBO 1.00E+OO 1.1052 TUBE RUPTURE - SBO !This term is a flag. No SAMAS need to be aligne d.
| |
| THERMALLY INDUCED STEAM GENERATOR TUBE RUPTURE - NON
| |
| #Tl -SGTR 1.00E+OO 1.0073 SBO This term is a flag. No SAMAs need to be aligned.
| |
| #V 1.00E+OO 1.0173 V Sequence Marker This term is a flag. No SAMAs need to be aligned .
| |
| D-43
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| | |
| (
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| Waterford Steam Electric S1.;tmm Unit 3 Applicant's Environmental Report Operating License Renewal Stage
| |
| *. ' *' .. 'Table D.1-4. '* '
| |
| * ..
| |
| :
| |
| J!
| |
| .. LeV:~12 *Risk *significan.t Term~ to Evaluated SAMAs (Based on Correlation of
| |
| ' ,'
| |
| .. .
| |
| .:* ' ,' '
| |
| ._.
| |
| ' *
| |
| * Large** Early.Release Frequency)
| |
| ,,* <
| |
| * I 1
| |
| .Event Name
| |
| ..
| |
| **.* l *probability I ~RV)f
| |
| * j Ev~nt Descr:iption'. !
| |
| ;.
| |
| .El is position .. !I NO LOWER HEAD I, FAILURE OFRPV- NO I CREEP RUPTURE MAAP
| |
| #X_VB 1.00E+OO 5~3337 ANALYSES This term is a flag. No SAMAs need to be aligned. 1!
| |
| This term represents a loss of the CCW system. Phase II SAMAs !
| |
| 8, 9, 20, 23, and 27 to decrease the importance of and enhance
| |
| * the availability and reliability of the CCW system to provide
| |
| %T9 1.75E-05 1.0237 Loss of CCW System cooling water were evaluated. I This term represents a reactor vessel rupture initiator. Phase II Reactor Vessel Rupture SAMA 44 to create a large concrete crucible with heat removal
| |
| %V 3.20E-08 1.0173 Initiator potential to contain molten core debris was evaluated. i CHR- FAIL 1.00E+OO 1.0251 CHR Flag This term is a flag. No SAMAs need to be aligned.
| |
| I EA2 SBO 1.00E+OO 1.1348 SBO Flag This term .is a flag. No SAMAs need to be aligned. ~
| |
| EA3_SBO 1.00E+OO 1.1358 SBO Flag This term is a flag. No SAMAs need to be aligned. I EB2 SBO 1.00E+OO 1.1382 SBO Flag This term is a flag. No SAMAs need to be aligned.
| |
| EB3_SBO 1.00E+OO 9.3555 SBO Flag This term is a flag. No SAMAs need to be aligned.
| |
| Thi_s term represents a conditional LOSP given SIAS signal after a plant trip. Phase II SAMAs 6 and 10 for improving offsite Conditional LOSP given power reliability; SAMAs 5 and 7 for increased availability of SIAS signal after a plant on-site AC power; and SAMAs 8, 9, and 11 for increasing diesel !
| |
| LOSP-ECCS 1.00E-02 1.0184 trip generator availability were evaluated. I Page D-44
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
| |
| - -- .. -.
| |
| *- table D.14 _.- _
| |
| *" '
| |
| I'
| |
| .
| |
| Correlation
| |
| *,
| |
| ''
| |
| oi'-evel 2 Risk Significant Terms to Evaluated.$AMAs
| |
| .
| |
| ' . '
| |
| (Based oh large Early Release Frequency)' !
| |
| *Event Name, 1..Probability j *RRW __ I E_vent.Description I Disposition li
| |
| !This term represents a failure of a human action to initiate cooldown of the RCS following a steam generator tube rupture (SGTR). Phase II SAMA 57 for eliminating a release pathway to Failure to initiate the environment following a SGTR; SAMAs 58, 59, 60, and 61 cooldown of the RCS for reducing the consequences of a SGTR; and SAMA 56 for OHFSGTRCDP 1.00E+OO 1.0212 following a SGTR reducing the frequency of SGTRs were evaluated.
| |
| [This term represents a failure of a human action to blowdown the steam generator to prevent overfilling the affected Failure to blowdown generator. Phase II SAMA 57 for eliminating a release steam generator to pathway to the environment following a SGTR; SAMAs 58, 59, prevent overfilling 60, and 61 for reducing the consequences of a SGTR; and SAMA*
| |
| PHFSGTRBDP 1.00E+OO 1.0069 affected generator 56 for reducing the frequency of SGTRs were evaluated. I n-his term represents a pressure induced steam generator tube rupture without a SBO. Phase II SAMA 57 for eliminating a release pathway to the environment following a SGTR; SAMAs 58, 59, 60, and 61 for reducing the consequences of a SGTR; Pl-SGTR NON-SBO and SAMA 56 for reducing the frequency of SGTRs were '
| |
| Pl SGTR 4.80E-03 1.0086 FAILURE OCCURS evaluated.
| |
| This term represents a pressure induced steam generator tube rupture with a SBO. Phase II SAMA 57 for eliminating a release pathway to the environment following a SGTR; SAMAs 58, 59,
| |
| . Pl-SGTR SBO FAILURE 60, and 61 for reducing the consequences of a SGTR; and SAMA Pl_SGTR_SBO 4.41E-03 1.1052 OCCURS 56 for reducing the frequency of SGTRs were evaluated.
| |
| PROBABILITY THAT I VESSEL BREACH FAILS i P FCONTVB 9.90E-Ol 5.3337 CONTAINMENT This term is a split fraction. No SAMAs need to be aligned.
| |
| i I ' D-45
| |
| | |
| Waterford Steam Electric Static~ Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-4 Correlation of Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Large Early Release Frequency)
| |
| Event Name I Probability I RRW I Event Description I Disposition I AB charging pump is assigned to emergency RABCVCASA 5.00E-01 1.0142 start in place of A rrhis term is a flag. No SAMAs need to be aligned.
| |
| AB Charging pump is assigned to emergency RABCVCASB 5.00E-01 1.0123 start in place of B h'"his term is a flag. No SAMAs need to be aligned.
| |
| Weighting factor for likelihood that SGTR RSGTRONSGl 5.00E-01 1.0285 happens in SGl This term is a flag. No SAMAs need to be aligned.
| |
| Weighting factor for likelihood that SGTR '
| |
| RSGTRONSG2 5.00E-01 1.0285 happens in SG2 This term is a flag. No SAMAs need to be aligned.
| |
| This term represents a thermally induced steam generator tube Tl-SGTR - INTACT rupture. Phase II SAMA 54 to modify procedures such that the CONTAINMENT OR water loop seals in the reactor cooling system (RCS} cold legs Tl_SGTR 3.19E-02 1.0073 BEFORE VB are not cleared following core damage was evaluated.
| |
| NO LOWER HEAD FAILURE OF RPV - NO CREEP RUPTURE MAAP X_VB 9.90E-01 5.3337 ANALYSES This term is a split fraction. No SAMAs need to be aligned.
| |
| This term represents a failure of a human action to blowdown i the steam generator to prevent overfilling the affected Failure to use steam generator. Phase II SAMA 57 for eliminating a release generator blowdown pathway to the environment following a SGTR; SAMAs 58, 59, to prevent overfilling 60, and 61 for reducing the consequences of a SGTR; and SAMA.
| |
| ZHFSGTRBDP 2.70E-02 1.0068 affected S/G 56 for reducing the frequency of SGTRs were evaluated. !
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| Page D-46
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-4 II Correlation of Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Large Early Release Frequency) II I
| |
| Event Name I Probability I RRW j Event Description I Disposition l This term represents a failure of a human action to initiate i cooldown of the RCS following a steam generator tube rupture (SGTR). Phase II SAMA 57 for eliminating a release pathway to Failure to initiate the environment following a SGTR; SAMAs 58, 59, 60, and 61 cooldown of the RCS for reducing the consequences of a SGTR; and SAMA 56 for ZHFSGTRCDP 1.80E-05 1.0202 following a SGTR reducing the frequency of SGTRs were evaluated.
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| This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for increased availability of on-site LOOP Recovery with AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP CSP 6.30E-02 1.0109 CSP Depletion generator availability were evaluated.
| |
| This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power LERF LOOP Recovery reliability; SAMAs 5 and 7 for increased availability of on-site with Batt Depl and 0 AC power; and SAMAs 8 and 9 for increasing diesel generator ZLOOP _LERF _RF _BO 9.15E-01 1.0541 Run Fail availability were evaluated.
| |
| This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power LERF LOOP Recovery reliability; SAMAs 5 and 7 for increased availability of on-site with Batt Depl and 1 AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP _LERF _RF _Bl 9.59E-01 1.0344 Run Fail generator availability were evaluated.
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| Note: Basic events that are correlated in Table D.1-2 are not listed again in Table D..1-4 if they are equivalent basic events .
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| . D-47
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage TableD.1".s
| |
| '
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| Correlation Qf ~e'(el 2. Risk Significant, Terms to Evaluated*SAMAs (Based on Lewd 2*Release Frequency}'
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| ... *' .
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| *~* ~ ~ . ' ... '
| |
| l;verit Name RRW l Event De.scripti9n J Disposition WATER LEVEL IN CAVITY BELOW BOTIQM OF RPV [> 6
| |
| #CAV 1.00E+OO 3.2723 FT] This term is a flag. No SAMAs need to be aligned.
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| LATE CONTAINMENT FAILURE WITH VESSEL f#CFL2 1.00E+OO 1.3031 BREACH This term is a flag. No SAMAs need to be aligned.
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| LATE CONTAINMENT FAILURE DUE TO LOSS OF CONTAINMENT
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| #CFL3 1.00E+OO 1.0227 FANS This term is a flag. No SAMAs need to be aligned.
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| FAILURE OF EX VESSEL SYSTEMS TO MAINTAIN ADEQUATE
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| #CS_UNAVAIL 1.00E+OO 3.4,449 WATER LEVELS This term is a flag. No SAMAs need to be aligned.
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| LOCA DEPRESSURIZATION
| |
| #DP _LOCA 1.00E+OO 1.0223 OCCURS This term is a flag. No SAMAs need to be aligned.
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| #TQU 1.00E+OO 1.0386 TQU Sequence Marker This term isa flag. No SAMAs need to be aligned.
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| RPS VESSEL HAS BEEN
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| #VB 1.00E+OO 3.2723 BREACHED This term is a flag. No SAMAs. need to be aligned.
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| CONTAINMENT FAILURE - DUE TO This term represents containment failure due to concrete CONCRETE EROSION erosion of the basemat. Phase II SAMAs 44 and 46 to reduce BMT 1.00E-02 1.0062 OF BASEMAT the probability of basemat melt-through were evaluated.
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| Page D-48
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-5 Correlation o.f Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Level 2 Release Frequency)
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| Event Name l Probability I RRW I Event Description I Disposition I FAILURE TO MANUALLY RECOVER This term represents a failure of a human action to manually COOLING FANS TO recover cooling fans to prevent late failure. Currently this is a GHFFANM 1.00E+OO 3.4536 PREVENT LATE FAILURE flag and no SAMAs need to be aligned.
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| NO BASEMAT FAILURE DUE TO CONCRETE X BMT 9.90E-01 3.2081 EROSION This term is a split fraction. No SAMAs need to be aligned.
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| This term represents a failure to recover offsite power when LERF LOOP lost. Phase II SAMAs 6 and 10 for improving offsite power Non-Recovery with reliability; SAMAs 5 and 7 for increased availability of on-site Batt Depl and 0 Run AC power; and SAMAs 8 and 9 for increasing diesel generator ZLOOP - LERF- NRF- BO 8.47E-02 1.4337 Fail availability were evaluated.
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| This term represents a failure to recover offsite power when LERF LOOP lost. Phase II SAMAs 6 and 10 for improving offsite power Non-Recovery with reliability; SAMAs 5 and 7 for increased availability of on-site Batt Depl and 0 Run AC power; and SAMAs 8 and 9 for increasing diesel generator ZLOOP_LERF_NRF _BONL 1.35E-01 1.0362 Fail {No Load Shed) availability were evaluated.
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| This term represents a failure to recover offsite power when LERF LOOP lost. Phase II SAMAs 6 and 10 for improving offsite power Non-Recovery with reliability; SAMAs 5 and 7 for increased availability of on-site Batt Depl and 1 Run AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP- LERF- NRF- Bl 4.06E-02 1.0984 Fail generator availability were evaluated.
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| This term represents a failure to recover offsite power when LERF LOOP . lost. Phase II SAMAs 6 and 10 for improving offsite power Non-Recovery with reliability; SAMAs 5 and 7 for increased availability of on-site Batt Depl and 1 Run AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP - LERF- NRF- B1NL 5.27E-02 1.0083 Fail {No Load Shed) generator availability were evaluated.
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| D-49
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| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-5
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| <'
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| Correlation of Level 2 Risk Significant Terms to Evaluated SAMAs (Based on Level 2 Release Frequency)
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| Event Name I Probability I RRW I Event Description j Disposition I This term represents a failure to recover offsite power when LERF LOOP lost. Phase II SAMAs 6 and 10 for improving offsite power Non-Recovery with reliability; SAMAs 5 and 7 for increased availability of on-site Batt Depl and 2 or AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP_LERF _NRF _B2 3.18E-02 1.006 more Run Fail generator availability were evaluated.
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| This term represents a failure to recover offsite power when LERF LOOP lost. Phase II SAMAs 6 and 10 for improving offsite power Non-Recovery without reliability; SAMAs 5 and 7 for increased availability of on-site Batt Depl and 1 Run AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP_LERF _NRF_Dl 9.SOE-02 1.0107 Fail generator availability were evaluated.
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| This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power reliability; SAMAs 5 and 7 for increased availability of on-site LERF LOOP Recovery AC power; and SAMAs 8, 9, and 11 for increasing diesel ZLOOP_LERF _RF _CSP 9.42E-01 l.0094 with CSP Depletion generator availability were evaluated.
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| This term represents a failure to recover offsite power when lost. Phase II SAMAs 6 and 10 for improving offsite power i LERF LOOP Recovery reliability; SAMAs 5 and 7 for increased availability of on-site without Batt Depl and AC power; and SAMAs 8, 9, and 11 for increasing diesel '
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| ZLOOP_LERF_RF _Dl 9.0SE-01 1.0058 1 Run Fail generator availability were evaluated. I Note: Basic events that are correlated m Tables 0.1-2 and 0.1-4 are not hsted agam m Table 0.1-5 1f they are equivalent basic events.
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| Page D-50
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License "Renewal Stage D.1.2.2 Radionuclide Analysis D.1.2.2.1 Introduction The goal of the radionuclide release characterization is to capture and collect accident scenarios resulting in releases from containment in a manner that best represents potential outcomes to public health consequences.
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| By using the end states of the CET, the progression of each accident sequence is passed through the CET to an end state. Associated with each of these end states is an accident release scenario that is characterized by the mechanism by which FPs are released outside of containment, the magnitude of FP release, and the timing of the release mechanism. The nature of the radioactive release categories is such that the spectrum of severe accidents is divided up into bins that represent a group with similar public health consequences. However, the determination of these public health consequences can be affected by a number of factors that impact the characterization of the radionuclide characterization.
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| The main characteristics of the containment end states for consideration in the development of the radionuclide release categories are shown below and are discussed in the following sections.
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| * Containment Failure Mechanism
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| * Timing of The Release
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| * Magnitude of the Release D.1.2.2.2 Containment Failure Mechanism The containment failure mechanism by which the FP releases occur affects the magnitude of the release and are considered in the classification of radionuclide releases. Factors for consideration regarding *the containment failure pathways include:
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| * Size of the Containment Breach
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| - Containment Failure
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| - SGTR
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| - Containment Isolation
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| * Location of Containment Breach The size of the containment breach is dictated by the specific accident sequence and the type of breach. The relative size of the outside opening in the RCB can determine the ability and capacity of the RCB to retain and contain FP from being released.
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| A containment failure represents a catastrophic rupture of the containment vessel based on exceeding the ultimate containment capacity.
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| SGTR releases bypass containment and are directly released outside of the RCB. The size of this containment breach is consistent with the break size of a single SG tube. However, no retention time exists to retain FP prior to release, and scrubbing of the releases can only occur if the tube break is below the SG water level.
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| Failure of containment isolation systems to operate are defined as 2.25-inches or greater in size.
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| Page D-51
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Cl failures also provide a direct release of FP outside of containment. However, FP must travel through containment prior to release, allowing for natural deposition and gravitational settling mechanisms to attenuate the FP releases.
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| Similarly, the location of the containment failure breach plays a role in reducing the FP released.
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| The distance the FP must travel inside of containment to the point of release can reduce the magnitude of radionuclides reduced. For containment failures, the release point was determined to be the escape hatch located in the lower portion of the annular compartment based on the finite element analysis of the WF3 containment [D.1-13].
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| D.1.2.2.3 Timing of Release Release timing of the accident sequences are based on a number of considerations including the timing of the containment release against the implementation of plant responses actions to control and contain the release. Of equal importance to the determination of release timings is the timing of notification to the public to ensure adequate warning for implementation of protective actions, such as evacuation.
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| The WF3 Emergency Plan identified four classes of Emergencies: Unusual Event, Alert, Site Area Emergency and General Emergency. Issuance of a General Emergency is made based on core degradation with a potential challenge to containment integrity and requires the initiation of predetermined protective actions for the public. The WF3 plant maintains a readiness level to declare an emergency within 15 minutes of indication showing exceedance of an emergency action level [D.1-14].
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| In consideration of response times, the Emergency Plan provides the conditions for deriving accident response times. A Category F accident, characterized as degraded FP barrier, requires the loss of two barriers with a potential loss of the third barrier for declaration of a WF3 General Emergency.
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| With regard to characterization of release timing, the indication timing of the second FP barrier would indicate the beginning of the emergency action timing. The timing to the failure of the third FP barrier would indicate the timing of the accident release.
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| An evacuation study was performed for WF3 to evaluate evacuation time estimates (ETE) under varied conditions. These ETEs address mobilization times and voluntary evacuations of the permanent residents and the shadow population in the Emergency Planning Zone (EPZ). The time to clear 90% of the affected population in the EPZ boundary under worst case conditions is 3 hours and 45 minutes [D.1-15]. An evacuation from WF3 would be considered to be complete within 4 hours from the start of the evacuation, which accounts for the 15 minute timing to declare the General Emergency and the worst-case ETE. This evaluation is used to characterize "early" radionuclide releases as any release initiated less than four (4) hours following the declaration of a General Emergency, which would not allow the population in the EPZ to evacuate Jn time.
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| The following timing categories were used for the Level 2 radionuclide release classification.
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| Release timings used in the Level 2 are based on the actual accident scenario timing (failure of the FP barriers) as determined by the MAAP calculations and include MAAP timing to core damage, vessel breach, containment failure, low SG water level and high containment pressure, as calculated in the MAAP calculation spreadsheets.
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| Page D-52
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-6 Release Timing Classification Time of Initial Release Classification Classification Relative to Time for General Abbreviation Category Emergency Declaration E Early Time< 4 hours I Intermediate 4 to 24 hours L Late > 24 hours D.1.2.2.4 Magnitude of Release The source term values were determined from the deterministic Level 2 sequence calculations using the MMP code. MMP results were used to classify the magnitude of the FP releases for each Level 2 accident sequence. Because sequence-specific data was obtained for every sequence, no estimation of FP releases was required for the Level 2 analysis. Each source term is characterized by a set of release fractions quantifying the releases *Of those FP of interest because of possible deleterious effects to humans and the environment. Based on a review of the MMP results, the following classification was selected to characterize the severity of the radionuclide releases based on the fraction of cesium iodide (Csl) released.
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| Table D.1-7 WF3 Release Categories Classification Classification Cs Iodide % in Abbreviation Category Release H High Csl > 10%
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| M Moderate 1-10%
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| L Low 0.1-1 %
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| LL Low-Low << 0.1 %
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| Negligible Intact 0 D.1.2.2.5 Release Category Bin Assignments The combination of the timing and magnitude of release categories results in 12 different release categories with an additional intact category as shown in Table D.1-8. The actual magnitude of the release for each Level 2 scenario was evaluated to the maximum release fraction of Csl over the duration of the run as found in the MMP results.
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| Page D-53
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-8 WF3 Release Categories Identifier Description Definition Intact Containment Intact Nominal leakage rate.
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| Intact H-E High - Early Release Category Csl > 10%
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| Release Time < 4 hours M-E Moderate - Early Release Category Csl: 1 - 10%
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| Release Time < 4 hours L-E Low - Early Release Category Csl:0.1-1%
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| Release Time < 4 hours LL-E Low Low - Early Release Category Csl << 0.1%
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| Release Time < 4 hours H-1 High- Intermediate Release Category Csl > 10%
| |
| Release Time: 4 - 24 hours M-1 Medium- Intermediate Release Category Csl: 1 - 10%
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| Release Time: 4 - 24 hours L-1 Low - Intermediate Release Category Csl: 0.1 -1%
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| Release Time: 4 - 24 hours LL-I Low Low- Intermediate Release Category Csl << 0.1%
| |
| Release Time: 4 - 24 hours H-L High - Late Release Category Csl > 10%
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| Release Time: > 24 hours M-L Medium - Late Release Category Csl: 1 - 10%
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| Release Tiine: > 24 hours L-L Low - Late Release Category Csl: 0.1 -1%
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| Release Time > 24 hours LL-L Low Low - Late Release Category Csl << 0.1%
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| Release Time > 24 hours 0.1.2.2.6 Mapping of Level 1 Results into the Various Release Categories The purpose of the Level 1 is to identify and capture accident sequences that have the potential to result in core damage. These sequences include the core damage states from the Level 1 PRA
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| [D.1-5, 0.1-16 & 0.1-12]. Success criteria used in the Level 1 look at sequences that result in core damage with a 24-hour time frame. Once core damage has occurred, the accident sequences are no longer considered for success and are labeled as "core damage".
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| Page D-54
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Guidance for performing Level 2 analyses and determination of LERF identifies core damage sequences and groups them into four containment failure plant states as shown below [D.1-6].
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| * Containment Bypass
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| * Containment Isolation
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| * Containment Failure with low RCS pressure
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| * Containment Failure with high RCS pressure The WF3 Level 2 considers these containment failure states as identified in the guidance. The purpose of this guidance is to ensure that accident sequences with the potential to impact off-site emergency response, public health and the corresponding protective measures have been identified and addressed. The potential exists for the identification of accident sequences that lead to core damage, but can be returned to a safe and stable state as a result of plant response measures (safeguard systems) within a period of time. These sequences would then be precluded from further Level 2 analysis due to establishing a safe and stable state and the mitigation of offsite impacts.
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| These accident sequences were evaluated deterministically using the MAAP 4.0.6 code and a 36-hour accident time period. This time period was selected to ensure that sufficient time was allotted to allow for late failures and to capture the peak steady-state FP release concentrations.
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| Accident sequences identified and evaluated as Level 2 sequences include:
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| * Transients
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| * Large Loss of Coolant Accidents (LOCA) - ALOCA
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| * Medium Loss of Coolant Accidents - MLOCA
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| * Small Loss of Coolant Accidents - SLOCA
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| * Steam Generator Tube Rupture Accidents - SGTR
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| * Station Blackout Accidents - SBO
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| * Anticipated Transients Without Scram -ATWS
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| * Interfacing System LOCA - ISLOCA Bridge trees can be used to convert the results from the Level 1 into the inputs for the Level 2 accident sequences. The Level 2 accident sequences are comprised of elements from the Level 1 core damage sequence to include both the success and failure accident-sequence pathways in combination with the containment safeguard systems. The resulting Level 2 accident sequences from the bridge tree process results in plant damage states (PDS).
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| To simplify the process and reduce the number of Level 2 accident sequences, these PDS can then be grouped based on a shared containment response. The previous WF3 Level 2 performed as part of the IPE used this binning process to combine the sequences into the following groups as shown below [D.1-11 ]:
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| I - Medium Pressure RCS at core uncovery, No HPI II - Medium Pressure RCS at core uncovery, No RAS Ill - High Pressure RCS at core uncovery, No HPI IV - Small LOCA with SG dryout, High pressure RCS at core uncover prevents HPI V - Large LOCA, no HPSI VI - Large LOCA, no RAS Page D-55
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
| |
| *, For the WF3 Level 2 analysis, no grouping into PDS was performed to group accident sequences with similar safety features and containment failure responses. A more rigorous approach was taken where each Level 2 accident sequence was assessed individually based on the accident-specific containment response.
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| The WF3 Level 2 accident sequences were named using the two or three letter identification for the CD sequences from the Level 1 core damage event trees (i.e., AX, MU, SB, TQX, TKQ, and RB) and combined with a one-letter code to represent core melt sequences (core damage with containment safeguard systems).
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| D.1.2.2.7 Process Used to Group the Source Terms With the development of the Level 2 release scenarios based on the integration of the Level 1 accident sequences, the containment safeguard configurations, and the Level 2 phenomena, these sequences were grouped under one of the 12 Release Categories identified in Table D.1-9.
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| These groupings are based on the release timing and magnitude of FP as determined by the deterministic MAAP Level 2 calculations.
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| Exceptions were made in the classification of the release scenario associated with the following:
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| * Containment Bypass Sequences
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| * Containment Isolation Sequences
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| * Reactor Vessel Rupture Events
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| * Interfacing System LOCA Events Containment Bypass Sequences SGTR and 1-SGTR sequences are characterized as bypass sequences due to a direct opening outside of containment at the onset of the accident sequence. These sequences were grouped with the H-E (high-early) release category based on an early release with minimal potential for mitigation of the FP releases. No consideration of FP scrubbing, retention, or deposition was considered for the bypass sequences.
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| Containment Isolation Sequences Containment isolation failures are defined as early failures based on open pathways through the containment at the onset of the accident sequences. These sequences were grouped with the H-E (high-early) release category based on an early release with minimal potential for mitigation of the FP releases. No consideration of FP scrubbing, retention, or deposition was considered for the containment isolation sequences.
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| Reactor Vessel Rupture Events .
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| Catastrophic reactor vessel rupture events pose a high likelihood of the occurrence of a containment failure concurrent with the vessel breach. As a result, these sequences were grouped with the H-E (high-early) release category based on an early release with maximum potential for the release of significant quantities of FP. No consideration of FP scrubbing, retention, or deposition was considered for the catastrophic vessel rupture sequences.
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| Interfacing System LOCA Events Like the SGTR sequences, the ISLOCA events are characterized as bypass sequences due to a direct opening outside of containment at the onset of the accident sequence. These sequences were grouped with the H-E (high-early) release category based on an early Page D-56
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage release with minimal potential for mitigation of the FP releases. No consideration of FP scrubbing, retention, or deposition was considered for the ISLOCA sequences.
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| Table D.1-9 Summary of Containment Event Tree Quantification Release Category Release Frequency (Magnitude/Timing) (Perry)
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| H-E 1.88E-06 H-1 4.75E-06 H-L O.OOE+OO L-E O.OOE+OO L-1 2.42E-09 L-L 5.56E-10 LL-E O.OOE+OO LL-I O.OOE+OO LL-L 3.85E-10 M-E 2.74E-08 M-1 1.34E-07 M-L 1.84E-08 lntact1 3.67E-06 CDF 1.05E-05 1
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| The "intact" column is calculated as (Base CDF - Total Release).
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| Nomenclature:
| |
| Timing (time between General Emergency Declaration and initial release):
| |
| Late (L) - Greater than 24 hours Intermediate (I) - 4.0 to 24 hours Early (E) - Less than 4.0 hours Magnitude:
| |
| Intact- Much less than 0.1% Csl release fraction Low-Low (LL) - Less than 0 .1 % Csl release fraction Low (L) - 0.1 % to 1% Csl release fraction Medium (M) - 1% to 10% Csl release fraction High (H) - Greater than 10% Csl release fraction D.1.2.2.8 Consequence Analysis Source Terms Input to the Level 3 WF3 model from the Level 2 model is a combination of radionuclide release fractions, timing of radionuclide releases, and frequencies at which the releases occur. This Page D-57
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage combination of information is used in conjunction with WF3 site characteristics in the Level 3 model to evaluate the off-site consequences of a core damage event.
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| Source terms were developed for the release categories identified in Table D.1-8. Table D.1-10 provides a summary of the Level 2 results that were used as Level 3 input for the WF3 SAMA analysis (the baseline analysis case).
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| Consequences corresponding to each of the release categories are developed in the WF3 Level 3 model, which is discussed in section D.1.5.
| |
| D.1.2.2.9 Release Magnitude Calculations The MMP computer code is used to assign both the radionuclide release magnitude and timing based on the accident progression characterization. Specifically, MMP provides the following information:
| |
| * containment pressure and temperature (time of containment failure is determined by comparing these values with the nominal containment capability);
| |
| * radionuclide release timing and magnitude for a large number of radioisotopes; and
| |
| * release fractions for twelve radionuclide species.
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| Page D-58
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
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| ( \
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| Table D.1-1 O WF3 Release Category Source Terms RDRELFRC001 - Release Fractions Warning Time (sec) RDPDELAY - Start RDPLHITE - Height RDPLUDUR-Release Freq. RDOALARM MACCS - Measured from scram of Plume release - MAAPTiming of plume release - Energy of Release Release Cat. Level 2 MAAP Run ID Duration of (per year) Time to declare GE, sec time; uses 15 minute from scram time Release Ends (sec) centerline of Escape EREL(6), W Release (sec)
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| GE declaration (sec) Hatch (26.5 ft)
| |
| Noble Gases I Cs Te Sr Ru La Ce Ba TPQU_BI 900.00 3224.35 Intact 3.68E-06 Plume#1 2324 88724 86400 65.38 2.07E-+-03 6.59E-03 3.20E-04 1.91E-04 1.18E-04 2.15E-07 9.28E-07 3.30E-09 7.80E-08 4.80E-07 Plume#2 88724 129600 40876 65.38 2.45E-+-03 9.99E-03 3.24E-04 1.92E-04 1.18E-04 2.15E-07 9.28E-07 3.30E-09. 7.80E-08 4.81E-07 TQX H 900.00 49288.77 H-E 1.88E-06 Plume#1 48389 50042 1653 65.38 2.45E-+-03 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 O.OOE-+-00 Plume#2 50042 129600 79558 8.08 4.11E-+-06 0.9998 0.2129 0.1987 0.2352 9.90E-04 1.36E-02 4.43E-05 1.02E-04 6.49E-03 SBO 900.00 8233.16 H-1 4.75E-06 Plume#1 7333 80630 73297 65.38 2.45E-+-03 5.89E-03 1.01E-04 3.89E-05 1.36E-04 1.29E-06 7.58E-05 3.44E-08 1.05E-07 8.69E-06 Plume#2 80630 129600 48970 8.08 7.57E-+-05 0.9803 0.2563 1.17E-01 1.64E-01 1.76E-03 9.04E-04 2.90E-05 1.08E-03 9.11E-04
| |
| - - - - - - - - - - - - - - - -
| |
| H-L NA1 NA
| |
| \_ -- /
| |
| SX B 900.00 32997.73 M-E 2.74E-08 Plume#1 32098 82532 50434 65.38 2.45E-+-03 3.25E-03 3.30E-04 1.88E-04 2.70E-04 3.24E-07 3.10E-06 2.01E-08 4.49E-08 2.71E-06 Plume#2 50434 129600 79166 8.08 2.09E-+-04 0.4946 0.0542 1.33E-02 7.49E-03 5.88E-06 5.86E-05 3.58E-07 7.62E-07 7.11E-05 SU_H 900.00 3270.88 M-1 1.34E-07 Plume#1 2371 43200 40829 65.38 2.45E-+-03 0.8415 5.65E-02 1.62E-02 4.64E-02 1.48E-03 2.42E-02 7.69E-05 1.42E-04 6.26E-03 Plume#2 43200 129600 86400 8.08 5.03E-+-06 0.8801 7.69E-02 2.42E-02 4.87E-02 1.57E-03 2.57E-02 8.04E-05 1.48E-04 6.61E-03 TB_F 900.00 3198.58 M-L 1.84E-08 Plume#1 2299 72608 70310 65.38 2.45E-+-03 5.85E-03 4.30E-04 2.02E-04 1.66E-04 1.81E-08 5.45E-07 1.77E-09 4.39E-09 1.92E-07 Plume#2 72608 129600 56992 8.08 4.54E-+-06 0.9996 7.85E-02 2.10E-02 1.16E-02 2.84E-08 5.75E-07 1.87E-09 4.88E-09 5.39E-06
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| --- --- --- --- -- --- - --- --- - --- -- --- --- --- -
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| L-E NA1 NA MU_H 900.00 3735.56 L-1 2.42E-09 Plume#1 2836 43200 40364 8.08 1.39E-+-07 0.8260 7.47E-03 7.42E-03 4.32E-02 1.75E-02 3.29E-02 8.76E-04 3.72E-03 4.91E-02 Plume#2 43200 129600 86400 8.08 5.05E-+-06 0.9016 7.93E-03 7.83E-03 6.59E-02 2.39E-02 3.48E-02 1.17E-03 5.06E-03 5.25E-02 TQX_B 900.00 19751.58 L-L 5.56E-10 Plume#1 18852 105252 86400 65.38 2.45E-+-03 6.08E-03 1.27E-04 8.81E-05 9.61E-05 4.00E-07 7.79E-06 2.17E-08 1.44E-07 2.29E-06 Plume#2 105252 129600 24348 8.08 2.35E-+-04 4.56E-01 2.48E-03 8.41E-04 3.53E-02 4.54E-07 8.65E-06 2.42E-08 1.61E-07 4.21E-06
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| - - - - - -- - -- - -- --- - - - -- -
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| LL-E NA1 NA
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| --- -- - --- -- -- --- --- -- -- --- -- --- --- --- ---
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| LL-I NA1 NA l) LL-L 3.85E-10 AX_D Plume#1 900.00 910.00 10 86410 86400 65.38 2.45E-+-03 6.27E-03 3.03E-04 2.10E-04 2.11E-04 2.19E-06 5.54E-06 6.24E-08 1.69E-07 7.05E-06 Page D-59
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
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| /~
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| . )
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| RDRELFRC001 - Release Fractions Warning Time (sec) RDPDELAY - Start RDPLHITE - Height RDPLUDUR-Release Freq. RDOALARM MACCS - Measured from scram of Plume release - MAAPTiming of plume release - Energy of Release Release Cat. Level 2 MAAP Run ID Duration of (per year) Time to declare GE, sec time; uses 15 minute from scram time Release Ends (sec) centerline of Escape EREL(6), W Release (sec)
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| GE declaration (sec) Hatch (26.5 ft)
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| Noble Gases I Cs Te Sr Ru La Ce Ba Plume#2 86410 129600 43190 8.08 3.81E-+-05 0.5375 5.06E-04 5.49E-03 3.09E-03 2.22E-06 5.65E-06 6.33E-08 1.71E-07 1.08E-05 I
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| These Release Categories were included as part of the level 2 model, but were not present m the level 2 results. As a result, release scenarios were not developed as part of the level 3 analysis.
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| )
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| Page D-60
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.3 External Events and Internal Flooding D.1.3.1 Seismic Analysis The WF3 PRA used for the SAMA analysis does not include external events. In the absence of such an analysis, Entergy used the WF3 IPEEE and more recent analyses to estimate the benefit of potential SAMAs using an external events benefit modifier as discussed in Section 4.15.1.4.4.
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| The seismic portion of the WF3 I PEEE [D.1-17] follows the guidance of NU REG-1407
| |
| [D.1-18], defined as a reduced scope plant, and EPRI NP-6041-SL [D.1-19]. This was accomplished by performing a Seismic Margins Assessment (SMA) of the Safe Shutdown Equipment List (SSEL) with plant walkdowns in accordance with the guidelines and procedures documented in Electrical Power Research Institute (EPRI) Report NP-6041-SL.
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| The SMA approach is a deterministic and conservative evaluation that does not calculate risk on a probabilistic basis. Therefore, its results should not be compared directly with the best-estimate internal events results.
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| The conclusions of the WF3 IPEEE seismic margin analysis are as follows:
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| : 1. Walkdowns resulted in no outliers that are operability issues at the plant.
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| : 2. No unique decay heat removal vulnerabilities to seismic events were found.
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| : 3. Seismic-induced flooding and fires do not pose major risks.
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| : 4. No unique seismic-induce.d containment failure mechanisms were identified.
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| However, there were three unresolved issues at the completion of the walkdowns. These issues are not significant to seismic risk and were made to conform to standard practice in seismic design. The issues and resolutions are [D.1-20]:
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| Issue Resolution Loose items in the Control The equipment identified was analyzed for potential impact Room to safety-related equipment. As good engineering practice the book cases near CP-22 and the tool cart in the EDG Room B were removed and there was no additional impact to safety related equipment following the evaluation.
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| Station air pipe not meeting CR-94-1111 contains the evaluation that the existing clearance requirements clearance for the station air pipe which is adjacent to 4KVESWGR3B will have no significant adverse impact during a seismic condition.
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| Storage of temporary Procedural guidance was updated for temporary storage in equipment UNT-007-060 to prevent potentially hazardous situations under seismic conditions.
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| Though the IPEEE did not calculate a CDF due to seismic events, an Integrated Leak Rate Test (ILRT) Interval Extension Report from August 2014 [D.1-21] conservatively estimated a value of Page D-61
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage 6.87E-07 forthe seismic CDF. For conservatism in the SAMA benefit analysis, this value will used to calculate the internal/external events benefit multiplier discussed in Section 4.15.1.4.4.
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| D.1.3.2 Fire Analysis The Waterford 3 (WF3) IPEEE included an internal fire analysis employing EPRl's FIVE methodology [D.1-22]. The NRC's IPEEE SER for WF3 reports a total fire CDF of 7 .OE-06/yr.
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| However, the IPEEE fire analysis has been superseded by the WF3 fire PRA created for NFPA 805, which utilizes guidance in NUREG/CR-6850 [D.1-23].
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| The WF3 fire PRA was not used in the SAMA analysis to estimate the risk reduction of individual SAMAs. Rather, the WF3 fire PRA was used in the SAMA analysis for determining the fire contribution to the external events multiplier, as well as for identifying potential SAMAs to mitigate the internal fire risk.
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| Since the WF3 fire PRA model is not fully integrated with the most recent Level 2 and 3 analyses, it wasn't used directly for the SAMA analysis. In addition, the WF3 fire PRA is based on NFPA 805 modifications that have not been implemented. However, the SAMA evaluation should be performed using the best available information on risk insights. Considering that the interim fire PRA model is a more current analysis of the fire risk at WF3 than the IPEEE fire analysis, and, therefore, is the best currently available fire risk information, use of the fire PRA model provides an acceptable basis (best available information) for identifying and evaluating SAMA candidates.
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| The total fire CDF was reported to be 1.62E-05/yr per the fire PRA model associated with the most recent LAR submittal [D.1-24]. In May 2015, an updated fire CDF of 1.80E-05/yr was calculated in PRA-W3-05-049 [D.1-25] due to changes resulting from NRC RAls. Since the CDF reported in PRA-W3-05-049 is the most recent value, this value was used in calculating the SAMA internal/external events multiplier discussed in Section 4.15.1.4.4.
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| Page D-62
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.3.3 Other External Hazards The WF3 IPEEE submittal, in addition to the internal fires and seismic events, examined a number of other external hazards:
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| * high winds and tornadoes;
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| * external flooding; and
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| * ice, hazardous chemical, transportation, and nearby facility incidents The WF3 Individual Plant Examination of External Events (IPEEE) concluded for high winds, floods, and other external events that WF3 meets the applicable NRC SRP requirements, and therefore has an acceptably low risk with respect to these hazards. As these events are not dominant contributors to external event risk and quantitative analysis of these events is not practical, they are considered negligible.
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| D.1.3.4 Internal Flooding An internal flooding analysis was performed in response to Generic Letter 88-20 (November 23, 1988) issued by the NRC. An updated analysis was performed with significant changes including how small diameter lines are handled, the assumed duration of releases, the handling of drains and turbine building floods, the charaQterization of rupture frequencies and sizes, and elimination of any screening of potential core damage scenarios by rupture frequency. These changes allowed the internal flooding analysis to satisfy the requirements in the ASME Standard and Regulatory Guide 1.200.
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| Revision 3 of the internal flooding notebook, PRA-W3-01-002 [D.1-45], calculates a total CDF contribution of 2.48E-06 from internal floods. This value was used, along with external events CDF values discussed above, to calculate the internal/external events multiplier discussed in Section 4.15.1.4.4. The multiplier was utilized because the current internal flooding model hasn't been integrated with the current internal events model or the Level 2 and 3 models.
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| Page D-63
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.4 PSA Model Revisions and Peer Review Summary The summary of the WF3 PSA models GDF and LERF is presented in the table below.
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| Summary of Major PSA Models PSA Model CDF (/nc-yr) LERF (/nc-yr) 1992 (IPE) (R1) 1.?0E-05 1.SOE-06 2000 (R2) 2.54E-05 5.33E-07 2003 (R3) 6.75E-06 2.42E-07 2009 (R4) 3.96E-06 4.94E-07 2015 (RS) 1.0SE-05 1.36E-07 D.1.4.1 Major Differences Between the 2000 (R2) PSA Model and the IPE Model The WF3 IPE model was created in 1992 [D.1-26]. The model was updated in 2000 and documented in Reports EC-S00-001Rev.0 [D.1-39], EC-S93-008 Rev. 1, Rev. 1C1, and Rev.
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| 1C2 [D.1-27]; with the final GDF and LERF values documented in ILRT Interval Extension Report W3F1-2001-0108 [D.1-28]. Changes to the model are summarized below.
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| * The main focus of Revision 2 was to remove asymmetries existing in the model for standby components (i.e. - the HPSI, CCW, eve and CHW systems) and incorporate missed support functions (i.e. - EOG dependency on DC power).
| |
| * DC control power dependencies were also added to FW-173A&B, AB bus alignment, ACC pumps, CCW AB pump, HPSI Pumps, LPSI Pumps, CS Pumps, EFW Pumps, and the AB Switchgear.
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| * Incorporated changes from a plant modification (DC-3402) which moved some loads from the AB battery to the turbine building battery.
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| * Updated EOG fail to run and start rates.
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| * Updated Loss of Offsite Power recovery analysis.
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| D.1.4.2 Major Differences Between the 2003 (R3) PSA Model and the 2002 (R2) PSA Model
| |
| * Included ISLOCA and A TWS sequences.
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| * Improved RCP seal LOCA modeling.
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| * Updated human reliability analysis.
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| * Updated generic and plant-specific failure rates.
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| * Improved Loss of Offsite Power recovery analysis.
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| * Improved common cause failure analysis.
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| * Updated HRA and LOSP analyses to reflect the Extended Power Uprate (EPU). The EPU changes the times available for operator actions and recovery of offsite power.
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| Page D-64
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
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| * Hot Leg Injection was added to mitigate medium and large LOCAs after the EPU which increased power that created the need for hot leg injection.
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| * Added Primary Safety Valve LOCA Initiating Event.
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| * Updated the Level 1 containment heat removal logic to 1 of 2 containment spray trains OR 2 of 4 containment cooling system fans.
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| Calculations EC-S00-001, Rev.1 [D.1-40], ECS93-008 [D.1-29], DRN_05-142, ORN 06-26, and PRA-W3-01-001S12 [D.1-30] summarize changes incorporated in the Revision 3 model, the overall core damage frequency results, and other additional information from the Revision 3 version of the model.
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| D.1.4.3 Major Differences Between the 2009 R4C1 (R4) PSA Model and the 2003 WSES-3 PSA (R3) PSA model The update of the Revision 4 Model is designated as the WF3 Level-1 Model R4C1 [D.1-31 ]. The following list describes the most significant changes from the WF3 PSA model R3 to PSA model 2009 R4C 1 Model.
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| * Updated initiating event data for plant operating experience with Bayesian updates using NUREG/CR-5750.
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| * Added safety injection (SI) valve rupture initiating events.
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| * Added instrument air system initiating event.
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| * Updated ATWS system interactions and failure propagations.
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| * Added initiating event %FVIVCC to the AFW system modeling.
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| * Updated the loss of offsite power (LOOP) logic to address both the consequential LOOP and the LOOP frequency for conditions such as severe weather, grid degradation, and switchyard work.
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| * Updated generic failure rates and component boundaries using NUREG/CR-6928.
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| * Added logic to the dry and wet cooling tower fans to allow for out of service selections as required for EOOS-related activities.
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| * Added emergency feedwater (EFW) recirculation line and component failures.
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| * Removed or replaced NOT gates in the model logic where possible.
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| * Added common cause failures for the diesel generator fuel oil transfer pumps.
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| * Added initiating event %T60C, for a line break outside of containment.
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| * Addressed most peer review and expert panel model comments.
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| D.1.4.4 Major Differences Between the 2015 (RS) PSA Model and the 2009 (R4) PSA Model Several changes were made in the Revision 5 PSA model update. The most significant changes are listed below.
| |
| * Resolved Peer Review findings.
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| * Updated success criteria associated with the number of dry cooling towers and wet cooling towers required to mitigate various accident sequences.
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| * Developed WF3-specific LOCA break sizes and associated frequencies.
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| * Converted from "flag" set alignments to conditional probability alignments.
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| * Updated generic and plant-specific failure rate data.
| |
| * Updated common cause failure (CCF) event probabilities.
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| Page D-65
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
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| * Updated initiator frequencies.
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| * Updated human failure events.
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| * HVAC dependencies were removed from the switchgear rooms and some pump rooms based on NRC comments and available room heat-up calculations associated with the room.
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| * A main control room (MCR) notebook and model was developed and included in the integrated model.
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| * Removed dependency to refill nitrogen accumulators by extending credited operation time from 10 hours to 24 hours.
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| * Revised modeling of refill of the CSP to reflect current procedural guidance.
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| * Added containment cooling system fan coil isolation valves.
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| * Revised battery depletion modeling to credit new procedural direction to strip batteries to extend battery life.
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| Details about the changes are included in calculation PSA-WF3-01-QU [D.1-32].
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| In addition, a full level 2 model was created which is based on the 2015 internal events model.
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| D.1.4.5 PSA Model Peer Review The Waterford 3 IPE [D.1-26] PRA was reviewed by an independent review team in three levels.
| |
| The first consisted of normal engineering Quality Assurance carried out by the organization performing the analysis. A qualified individual with knowledge of PRA methods and plant systems performed an independent review of all assumptions, calculations, and results for each task and system model in the Level 1 analysis (except the Internal Flood analysis).
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| The second level of review was performed by plant personnel not directly involved with the development of the PRA model. This consisted of individuals from Operations, Engineering, Training, and licensing groups which reviewed the system models and accident sequence description. This provided diverse expertise with plant design and operations knowledge to review the system fault trees for accuracy.
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| The third level of review was performed by PRA experts from ERIN Engineering. This review provided broad insights on techniques and results based on experience from other plant PRAs.
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| This review was conducted in two phases. During the first phase, the review team concentrated on the overall PRA methodology, accident sequence analysis, and system fault trees. The intent was to provide early feedback to the Waterford 3 staff concerning the adequacy and accuracy of the reviewed products. The second phase included Level 1 results, human failure and recovery analysis, preliminary plant damage state cutsets that combined Level 1 with containment system failures, and a preliminary CET.
| |
| An additional review was performed near the end of the project on the Level 2 analysis by experts from ABB Combustion Engineering. The intent of this review was to ensure that all important phenomena were considered and modeled correctly. Design features unique to CE plants were given particular emphasis. Detailed and specific comments on analysis methods, assumptions, and results were obtained.
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| The review teams found that the project was successfully meeting those objectives with a sound methodology and relatively minor adjustments necessary. The major comments are summarized below:
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| Page D-66
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage
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| * The overall methodology reflects the current state of the art for PRAs and will meet the requirements of GL 88-20.
| |
| * Cutset results were found to be complete and reasonable with few modeling errors.
| |
| * Several conservatisms were identified in the success criteria, system modeling, and failure data used.
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| * The level of documentation was generally found to be good with more detail recommended for the accident sequence descriptions, treatment of RCP seal failures, and human recovery analysis. Some inconsistencies between the documentation and the modeling were found.
| |
| * Control of changes to the model should be improved so as to document which files were used for a particular solution.
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| * The EFW turbine driven pump can be expected to continue to operate with low quality steam or even water at the turbine inlet.
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| * Plant damage state category IV (high RCS pressure with late core melt) contained no cutsets due to the method of modeling. Although this is adequate for categorizing risk at the plant, it should be kept in mind during accident management guidance development that sequences such as those in category IV can in fact exist.
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| * Instrument air initiators should be included in the model.
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| In August 2009 the WF3 PRA was peer reviewed against the requirements of the American Society of Mechanical Engineers (ASME) PRA standard and the requirements of Regulatory Guide (RG) 1.200, Revision 1. This peer review was performed using the process defined in Nuclear Energy Institute (NEI) 05-04. The ASME PRA Standard contains a total of 327 numbered supporting requirements in nine technical elements and the configuration control element.
| |
| Thirteen of the SRs represent deleted requirements, and of the remaining 314 SRs, thirteen were determined to be not applicable to the WF3 PRA. Of the 301 remaining SRs, 244 SRs (81 % ) were rated as Capability Category II or greater and approximately 9% were Capability Category I. Only 10% of the SRs were rated as not met. In the course of this review, ninety-six new Facts and Observations (F&Os) were prepared, including two "Best Practices".
| |
| Many of the findings pertained to documentation issues. However, there were some technical Issues in various parts of the PRA. The F&Os were resolved and resulted in documentation updates, model updates, human action updates, and procedure updates.
| |
| The documentation of the Integration and Quantification Work Package, PRA-W3-01-001S02, was found to be a Best Practice because it was well-written and appropriately detailed. Also, in the Systems Analysis, the documentation of the Component Dependency tables was found to be a Best Practice because of the completeness, clarity, and ease of use of the tables.
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| Page D-67
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.5 The WinMACCS Model-Level 3 Analysis D.1.5.1 Introduction SAMA evaluation relies on Level 3 PRA results to measure the effects of potential plant modifications. A Level 3 PRA model using version 3.10.0 of the Windows Melcer Accident Consequences Code System (WinMACCS) [D.1-33] was created for WF3. A WinMACCS calculation consists of three phases: input processing and validation, phenomenological modeling, and output processing. The phenomenological .models are based mostly on empirical data. The modeling software is subdivided into three modules:
| |
| * ATMOS treats atmospheric transport and dispersion of material and its deposition from the air utilizing a Gaussian plume model with Pasquill-Gifford dispersion parameters.
| |
| * EARLY models consequences of the accident to the surrounding area during an emergency action period. The emergency action period is the duration that begins when the first plume of the release arrives and ranges between 1 and 7 days.
| |
| * CHRONC considers the intermediate long-term impact in the period subsequent to the emergency action period.
| |
| Detailed. site-specific meteorological, population, and economic data are required. Model parameters can be varied by the user via input files, thus facilitating the analysis of consequence sensitivities due to uncertainties in specific model parameters. Assumptions associated with the model parameters can be found in the input document [D.1-34].
| |
| The Level 3 report evaluates a base case and two sensitivity. cases to account for variations in data and assumptions for postulated internal events. The base case uses estimated evacuation speed and times for evacuation based on site-specific evacuation calculations and consequence analysis best practices [D.1-35, D.1-34]. A sensitivity case (TIME) is the base case with the initial time to seek shelter extended from 2 hours to 3 hours. The other sensitivity case (SPEED) is the base case with a slower evacuation speed.
| |
| The population dose risk (PDR) was estimated by summing the product of population dose (obtained via WinMACCS calculation) and frequency for each accidental release over all releases. The offsite economic cost risk (OECR) was estimated by summing the product of offsite economic cost (obtained via WinMACCS calculation) and frequency for each accidental release over all releases. The offsite economic cost includes costs that could be incurred during the emergency response phase and the long-term protective action phase.
| |
| D.1.5.2 Input The following sections describe the site-specific input parameters used to obtain the off-site dose and economic impacts for cost-benefit analyses.
| |
| D.1.5.2.1 Projected Total Population Projected permanent, transient, and total population estimates in parish and sector geography was developed. Sector geography consists offifteen concentric bands at 0-0.914 km (0.568-mi.),
| |
| 0.914-1.61 km (1-mi.), 1.61-3.22 km (2-mi.), 3.22-4.83 km (3-mi.), 4.83-6.44 km (4-mi.), 6.44-8.05 km (5-mi.), 8.05-9.66 km (6-mi.), 9.66-11.27 km (7-mi.), 11.27-12.87 km (8-mi.), 12.87-14.48 km Page D-68
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage (9-mi.) 14.48-16.09 km (10-mi.), 16.09-32.19 km (20-mi.), 32.19-48.28 km (30-mi.), 48.28-64.37 km (40-mi.), and 64.37-80.47km (50 mi.) from the center point in 22.5 degree segments centered on the 16 compass points .
| |
| 2010 Census information found the following:
| |
| * Permanent Population within 20 Miles = 371,976 persons
| |
| * 20 Mile Population Density (371,976/Area) = 296 persons/square mile
| |
| * Permanent Population within 50 Miles= 2,006,583 persons
| |
| * 50 Mile Density (2,006,583/Area) = 255 persons/square mile 2045 Total Population= 2,882,454 2010-2045 Annual Growth Rate for all Parishes within the Region = 0.92.
| |
| Additional details of the distri.bution of the population can be found in reference WF3-EP-14-00012 [D.1-34]
| |
| D.1.5.2.2 Land Fraction The percentage of land in each of the 240 spatial elements is required by WinMACCS. The National Hydrography Dataset (NHD) for the watersheds and the area within the 50-mile region was used to calculate the ratio of land to surface water coverage [D.1-36]. Swampland was included as land, rather than water, so that WinMACCS habitability and farmability decisions would be applied to the swampland, resulting in a conservative estimate of the costs for decontamination, interdiction, and condemnation. Calculated values ranged from 0.00 to 1.00. A value of 1.00 indicates the spatial element area is all land, with no significant surface water.
| |
| D.1.5.2.3 Watershed Class Watershed Index is defined by NUREG/CR-4551, Volume 2, Rev. 1 as areas drained by rivers (Class 1) or large water bodies (Class 2). Class 2 is intended only for use with a very large lake, similar in size to Lake Michigan. Thus for WF3, a .watershed index of 1 (drained by rivers) was used for all spatial elements.
| |
| D.1.5.2.4 Regional Economic Data Economic data were obtained from SECPOP 2013 [D.1-41], U.S. Census of Agriculture for 2012
| |
| [D.1-42], Global Insight [D.1-43] and Department of Labor Statistics [D.1-44].
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| Page D-69
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Region Index Each spatial element was assigned to an economic region, defined in this report as a parish.
| |
| When a spatial element was comprised of more than one parish, it was assigned to the parish that had the most area in that spatial element. Four parishes in Louisiana (Iberia, St. Helena, St. Mary, and West Baton Rouge) were not assigned due to their small representation in any one spatial element.
| |
| Regional Economic Data Economic data were obtained from SECPOP 2013 [D.1-41 ], U.S. Census of Agriculture [D.1-42]
| |
| for 2012, Global Insight [D.1-43] and Department of Labor Statistics [D.1-44].
| |
| VAL WF- Value of Farm Wealth WinMACCS input requires VALWF, an average value of farm wealth (dollars/hectare) for the 50-mile radius area. This value is calculated by first, converting each parish's VFRM to dollars per county using U.S. Census of Agriculture item approximate land area (acres, 2012) and the conversion factor of 0.4047 ha/acre. These values are then weighted by the area each of the 21 parishes has in the WF3 50-mile area. Finally, the resultant values are then summed, producing a dollar value for the region, and divided by the total number of hectares within the region. The resulting value is $9281.53/ha.
| |
| VALWNF- Value of Non-Farm Wealth WinMACCS input requires a regional average value of non-farm wealth. This value is calculated by first multiplying the VNFRM by the 2010 parish permanent population, and then weighting by the area each of the 21 parishes have in the WF3 50-mile region. These resultant values are then summed, producing a dollar value for the region, and divided by 2010 permanent population within the 50-mile region. The 2010 permanent population within the region was obtained from the U.S. Census Bureau (USCB 2010). The regional value of non-farm wealth is $448,741.03/person.
| |
| VALWNF is based upon fixed, reproducible, tangible wealth, a measure of the durable goods owned in an area. This value was modified by adding a measure of total economic activity based upon the state gross domestic product (GDP). The modified VALWNF is $512,597.99/person.
| |
| D.1.5.2.5 Agriculture Data WinMACCS requires input regarding the crop type, growing season, and average fraction of farmland devoted to each crop type. The WinMACCS model requires average values for the 50-mile radius area instead of specific values for each of the 240 spatial elements. Agriculture data were obtained from the 2012 Census of Agriculture for the 21 parishes of interest in Louisiana [D.1-37]. The acres for each crop type and land in area (acres) were downloaded for each parish and the crop data were classified into seven crop categories, as defined in NUREG/CR-4551 Evaluation of Severe Accident Risks: Quantification of Major Input Parameters.
| |
| D.1.5.2.6 Meteorological Data Meteorological data representative of the WF3 site was collected to support the Level 3 analysis.
| |
| This data included wind speed, wind direction, atmospheric stability class, accumulated precipitation, and atmospheric mixing heights. The required data were obtained from the onsite WF3 meteorological monitoring system and regional National Weather Service stations [Slidell, LA (National Weather Service Station No. 53813) and Armstrong International Airport, LA Page D-70
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage (National Weather Service Station No. 72231 )]. Data records were collected for years 2004 through 2013 [D.1-34] and converted into formatted files for use in the WinMACCS model.
| |
| Site-Specific Data The site-specific meteorological data from the refined data set was used to produce fourteen separate WinMACCS input files, one for each year from 2004 through 2009 and two for each year from 2010 through 2013. Any missing hourly data was filled in the WinMACCS input files using data from approved data substitution methods as needed. Data from years 2010 through 2013 was missing seasonal mixing height averages. As a result, both minimum and maximum mixing heights were calculated for these years and incorporated into the meteorological data Regional Mixing Height Data The NCDC daily values for morning and afternoon mixing heights were averaged for each season and year. Calculated seasonal mixing height values were rounded to the nearest hundred and divided by 100 to express values in hundreds of meters for the WinMACCS model. Because data was not available for 2010 through 2013, the minimum and maximum average seasonal values for the years 2000 through 2009 were used for these years.
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| Page D-71
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.5.2.7 Evacuation Scenario Two cohorts were used to define the WF3 evacuation scenario for the evacuation of 90% of the affected population [D.1-33]. Cohort 1 defines the evacuation of 90% of the affected population while Cohort 2 defines the remaining 10% of the population that does not evacuate. The emergency response implementation for the execution of these 2 cohorts is defined by the parameters ESPEED, DLTSHL, TIMHOT, and TIMNRM as described below.
| |
| Travel Speed of Evacuees [ESPEED]
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| This value is the speed at which the evacuees move through the area based on evacuation of a full 10 mile EPZ [D.1-35]. This value is 1.192 mis based on traveling the full 10 miles in 3 hours and 45 minutes. The 3 hour and 45 minute evacuation time is determined based on the longest evacuation time occurring in Regions R14 and R15 as part of the Evacuation Time Estimate evaluations
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| [D.1-34].
| |
| Delay to Shelter [DL TSHL]
| |
| The delay to shelter (DLTSHL) is the time it takes for residents in the EPZ to receive the alert and notification and to enter a shelter (their residence, workplace, etc.) This value reflects the time required to execute the activities prior to beginning the evacuation trip [D.1-34]. This value is 7200 seconds based on the maximum time for all employees, residents and commuters [D.1-34]. This time includes the 1 :45 minute time for trip generation based on the 901h percentile evacuation time plus 15 minutes for the remaining 101h of evacuation times to begin.
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| Hotspot Relocation Time [TIMHOT] & Normal Relocation Time [TIMNRM]
| |
| These times are associated with the hotspot and normal time required to relocate residents from the area based on EPA Protective Action Guides (PAGs) [D.1-35]. Times of 43,200 and 86,400 seconds were used for TIMHOT and TIMNRM, respectively, and are based on NRC guidance
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| [D.1-35].
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| Page D-72
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.5.2.8 Core Inventory The WF3 core inventory input to the WinMACCS model [D.1-33] is based on a core thermal power of 3735 MWt [D.1-38]. The core inventory is shown in Table D.1-11.
| |
| Table D.1-11 Estimated WF3 Core Inventory (Becquerels)*
| |
| Nuclide Inventory Nuclide Inventory Co-58 3.53E+l6 Te-131m 5.75E+l7 Co-60 2.70E+l6 Te-132 5.61E+18 Kr-85 4.92E+l6 1-131 3.94E+l8 Kr-85m 1.45E+l8 1-132 5.70E+l8 Kr-87 2.94E+l8 1-133 7.97E+l8 Kr-88 4.15E+l8 1-134 8.87E+l8 Rb-86 2.07E+l5 1-135 7.48E+l8 Sr-89 4.06E+l8 Xe-133 7.80E+18 Sr-90 3.96E+l7 Xe-135 2.29E+l8 Sr-91 5.43E+l8 Cs-134 1.11E+l8 Sr-92 5.26E+l8 Cs-136 2.92E+l7 Y-90 4.18E+l7 Cs-137 5.91E+l7 Y-91 5.09E+l8 Ba-139 6.88E+18 Y-92 5.28E+l8 Ba-140 7.03E+l8 Y-93 5.97E+l8 La-140 7.30E+l8 Zr-95 6.61E+l8 La-141 6.38E+l8 Zr-97 6.30E+l8 La-142 6.15E+l8 Nb-95 6.61E+18 Ce-141 6.19E+l8 Mo-99 7.15E+l8 Ce-143 6.34E+l8 Tc-99M 6.26E+l8 Ce-144 4.73E+l8 Ru-103 6.23E+l8 Pr-143 6.15E+l8 Ru-105 3.23E+l8 Nd-147 2.64E+l8 Ru-106 2.38E+l8 Np-239 7.08E+l9 Rh-105 2.24E+l8 Pu-238 4.01E+l5 Sb-127 3.05E+l7 Pu-239 9.04E+l4 Sb-129 l.29E+l8 Pu-240 l.14E+l5 Te-127 2.95E+l7 Pu-241 l.92E+l7 Te-127m 3.90E+l6 Am-241 l.27E+l4 Te-129 l.27E+l8 Cm-242 4.86E+l6 Te-129m l.88E+l7 Cm-244 2.84E+l5
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| *Based on a thermal power of 3735 MWt (100.5% of upgraded power level of 3716 MWt)
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| Page D-73
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.5.2.9 Source Terms Twelve release categories, corresponding to internal event sequences, were part of the WinMACCS input. Section D.1.2.2.7 provides details of the source terms for postulated internal events. Based on the Level 2 results, a review of the dominant accident classes and maximum release of fission products was performed to select a representative accident sequence for each release category. The representative accident sequences selected for each release category represented both the dominant accident class based on the Level 2 results and the maximum release of fission products from the MAAP analyses.
| |
| Based on regulatory guidance and best practices [D.1-35], two plume segments were used to represent each release category based on the MAAP results from the Level 2
| |
| [D.1-2]. In general, these plumes characterize the two-phases of the source term release associated with (1) the initial accident sequence from core damage up to containment failure, and (2) the accident sequence following containment failure.
| |
| D.1.5.3 RES ULTS The WinMACCS model was run with each of the fourteen separate WinMACCS input files, one for each year from 2004 through 2009 and two for each year from 2010 through 2013 (one with the minimum average mixing heights and one with the maximum average mixing heights). The results showed that the site-specific meteorological data from year 2010, with the minimum average mixing heights, generated the highest population dose and the highest offsite economic cost.
| |
| Therefore, the base case results are those obtained using the site-specific meteorological data from year 2010, with the minimum average mixing heights.
| |
| Risk estimates for a base case and two sensitivity cases were analyzed to account for variations in data and assumptions with WinMACCS. The base case uses estimated evacuation speed (1.192 m/s) and sheltering times (2 hours). A sensitivity case, SPEED, is the base case with a slower evacuation speed (reduced by a factor of 2 from 1.192 m/s (base) to 0.596 m/s) with the sensitivity case, TIME, being a longer sheltering time (increased from 2 hours to 3 hours). These sensitivities were evaluated to conservatively reflect and quantify the uncertainties in specific model parameters. Results from the Level 3 sensitivities are shown in Table D.1-13.
| |
| Table D.1-12 shows estimated base case mean risk values for each release mode. The estimated mean values of PDR and offsite OECR forWF3 are 15.9 person-rem/yr and $147,339/yr, respectively [D.1-33].
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| Page D-74
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-12 Base Case Mean PDR and OECR Values for Postulated Internal Events Characteristics of Release Results - Year 2010M Mode Population Dose Offsite Economic Release ID Frequency (per year) person-sv Cost($)
| |
| Intact 3.68E-06 1.39E+03 1.59E+08
| |
| - ~~-~*--~-----
| |
| H-E 1.BBE-06 2.94E+04 2.79E+10 H-1 4.75E-06 1.96E+04 1.92E+10 M-E 2.74E-08 1.01E+04 6.02E+09 M-1 1.34E-07 3.43E+04 2.04E+10 M-L 1.84E-08 1.18E+04 8.53E+09 L-1 2.42E-09 4.01E+04 1.87E+10 L-L 5.56E-10 3.55E+03 4.44E+08 LL-L 3.85E-10 6.83E+03 2.41E+09 1.59E+01 1.47E+05 Totals person- rem/yr $/yr Com.ersion Factor: 1 sv = 100 rem A sensitivity case (SPEED) was performed to assume an evacuation speed that is reduced from 1.192 m/s (base) to 0.596 m/s. This sensitivity case (SPEED) assumes a lower average evacuation speed. Results of sensitivity analyses as shown in Table D.1-13 indicate that a slower evacuation speed slightly increases the population dose offsite consequences by less than 1%
| |
| with no change to economic impact.
| |
| A sensitivity case (TIME) was conducted assuming a longer delay in the initial time to seek sheltering (parameter DLTSHL). The sheltering time of 2 hrs was used for the baseline. This time was increased to time of 3 hrs (10,800 sec) evacuation for the sensitivity run. Results of sensitivity analyses as shown in Table D.1-13 indicate that a longer period between the onset of the accident and the start of the sheltering period does not significantly impact population doses (less than 1% )
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| or the offsite costs.
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| Page D-75
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.1-13 Summary of Offsite Consequence Results for Sensitivity Cases Characteristics of 1 Population Dose (person-sv) Offsite Economic Cost($)
| |
| Release Mode Frequency Baseline Speed Time i Baseline Speed Time ID (per year) (person-sv) (person-sv) (person-sv) i ($) ($) ($)
| |
| Intact 3.68E-06 1.39E+03 1.40E+03 1.39E+03 1.59E+08 1.59E+08 1.59E+08 H-E 1.88E-06 2.94E+04 2.94E+04 2.94E+04 2.79E+10 2.79E+10 2.79E+10 H-1 4.75E-06 1.96E+04 1.96E+04 1.96E+04 1.92E+10 1.92E+10 1.92E+10 M-E 2.74E-08 1.01E+04 1.01E+04 1.01E+04 6.02E+09 6.02E+09 6.02E+09 M-1 1.34E-07 3.43E+04 4.06E+04 3.59E+04 2.04E+10 2.04E+10 2.04E+10 M-L 1.84E-08 1.18E+04 1.18E+04 1.18E+04 8.53E+09 8.53E+09 8.53E+09 L-1 2.42E-09 4.01E+04 4.85E+04 4.21E+04 1.87E+10 1.87E+10 1.87E+10 L-L 5.56E-10 3.55E+03 3.56E+03 3.55E+03 4.44E+08 4.44E+08 4.44E+08 LL-L 3.85E-10 6.83E+03 6.84E+03 6.83E+03 2.41E+09 2.41E+09 2.41E+09 Totals 1.59E+01 1.60E+01 1.59E+01 1.47E+05 1.47E+05 1.47E+05
| |
| % Change NA 0.57% 0.14% NA 0.00% 0.00%
| |
| Units person- rem/yr person-rem/yr person- rem/yr $/yr $/yr $/yr Conwrsion Factor: 1 sv= 100 rem Page D-76
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1.6 References D.1-1 WF3 Calculation No: PSA-WF3-01-QU," WF3 PSA At-Power Level 1 Integration and Quantification Analysis", Rev. 3, October 2015.
| |
| D.1-2 PSA-WF3-01-L2-01, 'Waterford 3 Level 2 PRA", Revision 0.
| |
| D.1-3 PSA-WF3-01-QU-01, 'WF3 PSA Uncertainty and Sensitivity Analysis", Revision 0, July 2015.
| |
| D.1-4 Waterford 3 Probabilistic Risk Assessment Individual Plant Examination Submittal, August 1992.
| |
| D.1-5 PSA-WF3-01-SC, WF3 PSA At-Power Level 1 Success Criteria Analysis, Rev. 1.
| |
| D.1-6 PSA-WF3-01-LE Large Early Release Frequency (LERF) Model, Rev. 1.
| |
| D.1-7 RSC-CALKNX-2013-0706, Waterford LERF-Containment Isolation System Break Size MMP Sensitivity Assessment, Rev. 0.
| |
| D.1-8 PSA-WF3-01-SY, WF3 PSA Model System Analysis Work Package, Rev. 0.
| |
| D.1-9 NUREG-1570 Risk Assessment of Severe Accident-Induced Steam Generator Tube Rupture.
| |
| D.1-10 WCAP-16341-P Simplified Level 2 Modeling Guidelines, Westinghouse, Rev. 0.
| |
| D.1-11 Waterford 3 Probabilistic Risk Assessment Individual Plant Examination Submittal, August 1992.
| |
| D.1-12 PSA-WF3-01-AS-01, WF3 PSA At-Power Level 1 Anticipated Transient Without Scram Analysis, Rev.a.
| |
| D.1-13 PSA-WF3-01-L2-02, Finite Element Analysis for Entergy Waterford Unit 3 Containment Failure Analysis, Rev. 0.
| |
| D.1-14 Waterford 3 SES Emergency Plan, Revision 45.
| |
| D .1-15 KLD TR-502, Waterford-3 Steam Electric Station Development of Evacuation Time Estimates, Rev.1.
| |
| D.1-16 PSA-WF3-01-AS, WF3 PSA At-Power Level 1 Accident Sequence Analysis, Rev. 0.
| |
| D.1-17 WF3 IPEEE "Internal Plant Examination of External Events", Revision 0, July 1995.
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| D.1-18 NUREG-1407, "Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities," June, 1991.
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| D.1-19 EPRI NP-6041-SL, "A Methodology for Assessment of Nuclear Power Plant Seismic Margin," August, 1991.
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| Page D-77
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1-20 NRC SER "Safety Evaluation of Individual Plant Examination of External Events (IPEEE)
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| Submittal On Waterford Electric Station, Unit 3" July 27, 2000.
| |
| D .1-21 W3F1-2015-0021, "Waterford Steam Electric Station, Unit 3 Response to Request for Additional Information Regarding the Request to Permanently Extend the Integrated Leak Rate Test Frequency to 15 Years", May, 2015.
| |
| D.1-22 Fire-Induced Vulnerability Evaluation (FIVE), EPRI TR-100370 Project 3000-41, April 1992.
| |
| D.1-23 NUREG/CR-6850, "Fire PRA Methodology for Nuclear Power Facilities", 2005.
| |
| D.1-24 W3F1-2013-0048, "Supplement to NFPA 805 License Amendment Request (LAR)
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| Waterford Steam Electric Station, Unit 3", December, 2013.
| |
| D.1-25 WF3 Calculation No: PRA-W3-05-049, "Comparison of Waterford 3 MOR and FRE CDF and LERF", Revision 1, May, 2015.
| |
| D.1-26 Individual Plant Examination Submittal for the Waterford 3 Nuclear Plant, August, 1992.
| |
| D.1-27 EC-S93-008, "Waterford 3 Level 1 Internal Events PSA Model," Revision 1, August, 2000.
| |
| D.1-28 W3F1-2001-0108, "Risk Evaluation of ILRT Interval Extension", November 8, 2001.
| |
| D.1-29 EC-S93-008, 'Waterford 3 Level 1 Internal Events PSA Model," Revision 2, June, 2003.
| |
| D.1-30 PRA-W3-01-001S12. "Waterford 3 PRA LERF Model", Rev 0.
| |
| D.1-31 PRA-W3-01-001, 'Waterford Steam Electric Station Unit 3 Probabilistic Safety Assessment Level-1 Model R4C1 Summary Report", Revision 0, March, 2009.
| |
| D.1-32 PSA-WF3-01-QU, "WF3 PSA At-Power Level 1 Integration and Quantification Analysis",
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| Rev. 0.
| |
| D.1-33 W3-EP-14-00013, 'Waterford 3 Level 3 PRA," Rev. 0.
| |
| D.1-34 WF3-EP-14-00012, Site-Specific MACCS2 Input Data for WF3, Rev. 0.
| |
| D.1-35 NUREG/CR-7009, MACCS Best Practices as Applied in the State-of-the-Art Reactor Consequence Analysis (SOARCA) Project, June 2014.
| |
| D.1-36 USGS (U.S. Geological Survey). 2014. National Hydrography Dataset (NHD). Retrieved from ftp://nhdftp.usgs.gov/DataSets/Staged/States/FileGDB/HighResolution (accessed June 9, 2014).
| |
| D.1-37 USDA (U.S. Department of Agriculture). 2012. 2012 Census of Agriculture Louisiana State and Parish Data. May 2014.
| |
| D.1-38 WSES-FSAR-UNIT-3, Waterford 3 Steam Electric Station Unit 3 Final Safety Analysis Report, Rev. 308.
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| Page D-78
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.1-39 EC-S00-001, "PSA Model Summary Report," Revision 0.
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| D.1-40 EC-S00-001, "PSA Model Summary Report," Revision 1.
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| D.1-41 SECPOP (SECPOP 4.2.0 Software). 2013. Sector Population, Land Fraction and Economic Estimation Program. Released 10/21/2013. Sandia National Laboratories, Albuquerque, NM.
| |
| D.1-42 USDA (U.S. Department of Agriculture). 2012. 2012 Census of Agriculture Louisiana State and Parish Data. May 2014.
| |
| D.1-43 Global Insight, 2014. U.S. Metro Economies- GMP and Employment 2013-2015. June 2014.
| |
| D.1-44 USDL (U.S. Department of Labor). 2015. U.S. Bureau of Labor Statistics Quarterly Census of Employment and Wages for 2013. Retrieved from
| |
| <http://www.bls.gov/data/#employment> (accessed January 27, 2015).
| |
| D.1-45 WF3 Calculation No: PRA-W3-01-002, "W3 Internal Flooding Analysis", Revision 3.
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| Page D-79
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment D.2 Evaluation of WF3 SAMA Candidates Page D-80
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.2 EVALUATION OF WF3 SAMA CANDIDATES This section describes the generation of the initial list of potential SAMA candidates, screening methods, and the analysis of the remaining SAMA candidates.
| |
| D.2.1 SAMA List Compilation Candidate SAMAs are defined as potential enhancements to the plant design, operating procedures, inspection programs, or maintenance programs that have the potential to reduce the severe accident risk of WF3. These SAMAs can be characterized as either hardware (e.g.,
| |
| physical modification of plant structure, systems, and components) or non-hardware enhancements (e.g., operation, maintenance programs, and procedure changes), or a combination of the two. The candidate SAMAs considered for WF3 encompass both hardware and non-hardware enhancements.
| |
| A list of SAMA candidates was developed by reviewing industry documents and considering other plant-specific enhancements not identified in the published industry documents. Since WF3 is a PWR, considerable attention was paid to the SAMA candidates from SAMA analyses for other PWR plants. Industry documents reviewed included the following.
| |
| * NEI 05 Severe Accident Mitigation Alternatives Analysis [D.2-1]
| |
| * Davis-Besse Nuclear Power Station SAMA Analysis [D.2-2]
| |
| * South Texas Project, Units 1 and 2 SAMA Analysis [D.2-3]
| |
| * Callaway Plant SAMA Analysis [D.2-4]
| |
| * Seabrook Station SAMA Analysis [D.2-5]
| |
| * Sequoyah Nuclear Plant, Units 1 and 2 SAMA Analysis [D.2-6]
| |
| In addition to SAMA candidates from review of industry documents, additional SAMA candidates were obtained from plant-specific sources, such as the WF3 Individual Plant Examination (IPE)
| |
| [D.2-7] and the WF3 Individual Plant Examination of External Events (IPEEE) [D.2-8]. In the IPE and IPEEE several enhancements related to severe accident insights were recommended and implemented. These enhancements are included in the comprehensive list of phase I SAMA candidates as 183 through 195 (Table D.2-1). The current WF3 PSA Level 1and2 models were also used to identify plant-specific modifications for inclusion in the comprehensive list of SAMA candidates. The risk significant events from the current PSA model were reviewed for similar failure modes and effects that could be addressed through a potential enhancement to the plant.
| |
| The correlation between SAMAs and the risk significant terms are listed in Tables D.1-2, D.1-4, and D.1-5.
| |
| The comprehensive list of 201 candidate SAMAs considered for implementation at WF3 is provided in onsite documentation [D.2-1 O].
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| Page D-81
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.2.2 Qualitative Screening of SAMA Candidates (Phase I)
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| The purpose of the preliminary SAMA screening was to eliminate from further consideration enhancements that were not viable for implementation at WF3. Potential SAMA candidates were screened out if they modified features not applicable to WF3, if they had already been implemented at WF3, or if they were similar in nature and could be combined with another SAMA candidate to develop a more comprehensive or plant-specific SAMA candidate. During this process, 48 of the Phase I SAMA candidates were screened out because they were not applicable to WF3, 11 of the Phase I SAMA candidates were screened out because they were similar in nature and could be combined with another SAMA candidate, and 68 of the Phase I SAMA candidates were screened out because they had already been implemented at WF3, leaving 74 SAMA candidates for further analysis. The final screening process involved identifying and eliminating those items whose implementation cost would exceed their benefit as described below. Table D.2-2 provides a description of each of the 74 Phase II SAMA candidates.
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| D.2.3 Final Screening and Cost Benefit Evaluation of SAMA Candidates (Phase II}
| |
| To assess the viability of each SAMA considered for a final cost-benefit evaluation, the cost of implementing that particular SAMA was estimated and compared with the estimated benefit. If the cost of implementation was greater than the attainable benefit of a particular SAMA, then the modification was not considered economically viable and was eliminated from further consideration.
| |
| The expected cost of enhancement to implement each SAMA (COE) was established from existing estimates of similar modifications combined with engineering judgment. Most of the cost estimates were developed from similar modifications considered in previously performed SAMA analyses. In particular, these cost-estimates were derived from the following major sources.
| |
| * Davis-Besse [D.2-2]
| |
| * South Texas project [D.2-3]
| |
| * Callaway [D.2-4]
| |
| * Seabrook Station [D.2-5]
| |
| * Sequoyah [D.2-6]
| |
| * AN0-2 [D.2-11]
| |
| * Indian Point [D.2-12]
| |
| Detailed cost estimates were often not required to make informed decisions regarding the economic viability of a potential plant enhancement when compared to attainable benefit. The implementation costs for of the SAMA candidates were clearly in excess of the attainable benefit estimated from a particular analysis case. Nonetheless, the cost of each SAMA candidate was conceptually estimated to the point where conclusions regarding the economic viability of the proposed modification could be adequately gauged.
| |
| Based on a review of previous submittals, SAMA evaluations, and an evaluation of expected implementation costs at WF3, the following estimated cost ranges for each type of proposed SAMA were used.
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| Page D-82
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage ESTIMATED COST Type of Change RANGE Procedural only $25K-$50K Procedural change with engineering or training required $50K-$200K Procedural change with engineering and testing/training $200K-$300K required Hardware modification $100K to >$1000K Detailed cost estimates were based on the engineering judgment of project engineers experienced in performing design changes at the facility. The detailed cost estimates considered engineering, labor, materials, and support functions such as planning, scheduling, health physics, quality assurance, security, safety, and firewatch. The estimates included a 20%-30%
| |
| contingency on the design and a 30%-40% contingency on the installation costs, but did not account for inflation, replacement power during extended outages necessary for SAMA implementation, or increased maintenance or operation costs following SAMA implementation.
| |
| The cost benefit comparison and disposition of each of the 74 Phase II SAMA candidates is presented in Table D.2-2. Three of the Phase II SAMA candidates were retained without evaluation as they are already commitments in the NFPA 805 LAR [D.2-13]
| |
| Bounding evaluations (or analysis cases) were performed to address specific SAMA candidates or groups of similar SAMA candidates. These analysis cases overestimated the benefit and thus were conservative calculations. For example, if the objective of the SAMA was to reduce the likelihood of a certain failure mode, then eliminating the failure mode from the PSA bounded the benefit, even though the SAMA would not be expected to be 100% effective in eliminating the failure. This calculation obviously overestimated the benefit, but if the inflated benefit indicated that the SAMA candidate was not cost beneficial, then the purpose of the analysis was satisfied.
| |
| A description of the analysis cases used in the evaluation follows.
| |
| Case 1: SBO Reduction This analysis case was used to evaluate the change in plant risk from providing additional DC or AC power to reduce SBO contribution. A bounding analysis was performed by eliminating the SBO contribution from the PSA model by setting events #SBO and #SBORCP to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $5,597,783. This analysis case was used to model the benefit of Phase II SAMAs 1, 2, and 7.
| |
| Case 2: Improve Feedwater Reliability This SAMA analysis case was used to evaluate the change in plant risk from installing a digital feed water upgrade. A bounding analysis was performed by eliminating the failure of feedwater by setting the %T4 initiator to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $35,361. This analysis case was used to model the benefit of phase II SAMA 31.
| |
| Case 3: Add DC System Cross-ties This analysis case was used to evaluate the change in plant risk from providi~g DC bus cross-ties. A bounding analysis was performed where the failure of DC bus 38-DC-S (gate D100) was ANDed with the failures of DC busses 3A-DC-S (gate 0200) and 3AB-OC-S (0300) below Page D-83
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage gate 0605. Similarly, below gate 0605A, gates 01 OOA, 0200A, and 0300AW were ANOed; below gate 0352, gates 01 OO_AX, D201A, and D301AW were ANDed; and below gate H0217, gates 01 OO_AD, D200_AD, and D300_AD were ANDed. Also, BEs DBD03BOCSF (DC BUS 03BDCS FAULT) and %TDC2 (Loss of DC Bus B IE) were set to zero. This resulted in an internal and external benefit (with uncertainty) of approximately $3,912,412. This analysis case was used to model the benefit of phase II SAMA 3.
| |
| Case 4: Increase Availability of On-Site AC Power This analysis case was used to evaluate the change in plant risk from improving the 4.16 kV bus cross-tie ability. Two bounding analyses were performed, conservatively ANDing the failure of 4.16 kV bus 3B3-S logic (E100) with the logicfor4.16 kV BUS 3A3-S (E300) and vice versa. It was determined that adding a crosstie from 4.16 kV BUS 3B3-S to 4.16 kV BUS 3A3-S would give the maximum CDF reduction, and the following changes were made in order to evaluate this SAMA case: Gate E100 was ANDed with E300, gate E100JZ was ANDed with E300JZ, gate E100-L2 was ANDed with E300-L2, gate E100X was ANDed with E300X, and gates E0003B3S_L 1 and E0003A3S_L 1 were ANDed under gates E507 A, E508A, and E51 OA. This SAMA case resulted in an internal and external benefit (with uncertainty) of approximately
| |
| $4,047,285. This analysis case was used to model the benefit of Phase II SAMA 5.
| |
| Case 5: Reduce Loss of Off-Site Power This SAMA analysis evaluated the change in plant risk from installing an additional buried off-site power source or burying off-site power lines. A bounding analysis was performed by changing the frequency of % TS initiator to 1. 79E-02 /rx-critical-yr by removing severe weather contribution based on PSA-WF3-01-IE-01, which resulted in an internal and external benefit (with uncertainty) of approximately $1,816, 135. This analysis case was used to model the benefit of Phase II SAMAs 6 and 10.
| |
| Case 6: Provide Backup EOG Cooling This analysis case was used to evaluate the change in plant risk from increasing EOG reliability by adding a backup source of diesel cooling. A bounding analysis was performed by eliminating failure of CCW cooling to the EOG gates. Gates EMMCCAVALV, S002, S002-L2, and BE SCCMDPSTRT were deleted from gates E340 and E340-L2 and gates EMMCCBVALV, S502, S502-L2, and event SCCMDPSTRT were deleted from gates E140 and E140-L2. Also, gate EMMCCAVALV was deleted from E340X and EMMCCBVALV was deleted from E140X, which resulted in an internal and external benefit (with uncertainty) of approximately $1,337,906. This analysis case was used to model the benefit of phase II SAMAs 8 and 9.
| |
| Case 7: Reduced Frequency of Loss of Auxiliary Component Cooling Water This analysis case was used to evaluate the change in plant risk from adding the ability to cross-tie the ACCW trains. Since Waterford 3 does not have a traditional service water system, the closest system is the ACCW system. WF3 can't currently cross-tie the ACCW pumps for cooling. A bounding analysis was performed to evaluate adding the ability to cross-tie the ACCW trains by removing ACCW gates 0519, 0527, S133, S233, S133-L2, and S233-L2 which resulted in an internal and external benefit (with uncertainty) of approximately $183,427. This analysis case was used to model the benefit of phase II SAMAs 21, 22 and 23.
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| Page D-84
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Case 8: Increased availability of feedwater Description/Evaluation This analysis case was used to evaluate the change in plant risk from increased availability of feedwater. A bounding analysis was performed by eliminating DWST failure to supply the CSP in the PSA model. Basic events QHFCSPEMPP, QPP6CD250J, QXVDW4411K, QCVCMU123N, OXVDW4414K, QXVCMU141K, QXVCMU142K, and QXVCMU141N were set to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $46,934. This analysis case was used to model the benefit of phase II SAMA 32.
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| Case 9: High Pressure Safety Injection System This analysis case evaluated the change in plant risk from plant modifications that would increase the availability of high pressure safety injection. A bounding analysis was performed by eliminating failure of HPSI in the PSA model by replacing gates H1000, H 1OOO_REC, and H2000 with a single basic event set to zero representing the new HPSI system, which resulted in an internal and external benefit (with uncertainty) of approximately $541,919. This analysis case was used to model the benefit of phase II SAMAs 13 and 17.
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| Case 10: Extend Reactor Water Storage Pool Capacity This analysis case was used to evaluate the change in plant risk from throttling RWSP demands and providing additional makeup to the RWSP to maintain RWSP inventory. Due to an increase in RWSP inventory, more time is available to swap ECCS pump suction from the RWSP to the Safety Injection Sump. A bounding analysis was performed by setting two operator actions to zero, HHFISOMINP and HHFMANRA_P, and also setting the tank rupture probability, HTK3RWSPRJ, to zero. This resulted in an internal and external benefit (with uncertainty) of
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| $37,457. This analysis case was used to model the benefit of phase II SAMAs 16, 29, 30, and 49.
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| Case 11: Eliminate ECCS Dependency on Component Cooling Water System This analysis case was used to evaluate the change in plant risk from replacing ECCS pump motors with air-cooled motors. A bounding analysis was performed by eliminating failure of ECCS motor cooling due to failure of CCW in the PSA model [CCWTOA, CCWTOABA, CCWTOB, CCWTOABB, L 130, and L230 were deleted], which resulted in an internal and external benefit (with uncertainty) of $361,328.This analysis case was used to model the benefit of phase II SAMA 20.
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| Case 12: Increase Availability of ACCW This analysis case was used to evaluate the change in plant risk from adding redundant power to the dry cooling tower fans, wet cooling tower fans, and ACCW pumps. A bounding analysis was performed by eliminating the DC control power gates to the ACCW pumps (gate D200A under S 135 and Gate D1 DOA under S235) and the DC power logic to the dry and wet cooling tower fans (Gates SA51 R3, SA52R3, SB51 R3, and SB52R3), which resulted in an internal and external benefit (with uncertainty) of approximately $18,655.This analysis case was used to model the benefit of phase II SAMA 19.
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| Page D-85
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Case 13: Low Pressure Safety Injection System This analysis case was used to evaluate the change in plant risk from adding an alternate Low Pressure Safety Injection system. A bounding analysis was performed by eliminating failure of the Low Pressure Safety Injection system in the PSA model [gate L 1000 was deleted], which resulted in an internal and external benefit (with uncertainty) of approximately $39. This analysis case was used to model the benefit of phase II SAMAs 14 and 15.
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| Case 14: Increase Component Cooling Water Availability This analysis case was used to evaluate the change in plant risk from installing an additional component cooling water pump. A bounding analysis was performed by eliminating failure of CCW pump failures and CCFs in the PSA model. Events SCCMOPNRUN, SMPCCW-ABG, SMPCCW-ABB, SHFCCWPABA, STMCCWPABF, CCWABSTBY, SMP3CCW1 BGS, STMCCWPPBF, SMP3CCW1 BBS, CCWBSTBY, SMP3CCW1AGS, STMCCWPPAF, CCWASTBY, SMP3CCW1ABS were set to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $3,532,265. This analysis case was used to model the benefit of phase II SAMA 27.
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| Case 15: Decreased Charging Pump Failure This analysis case was used to evaluate the change in plant risk from increasing availability of electrical power to the normal charging pump by adding an alternate power source. A bounding analysis was performed by eliminating the normal charging pump power gates in the PSA model.
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| Gates E604 and R384 under R392, and gate E604 under RABFAIL were deleted, which resulted in an internal and external benefit (with uncertainty) of approximately $96, 156. This analysis case was used to model the benefit of phase II SAMA 12.
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| Case 16: Reactor Coolant Pump Seals This analysis case was used to evaluate the change in plant risk from improving the RCP seals or cooling system. A bounding analysis was performed by eliminating RCP Seal LOCA. in the PSA model. Initiators %RCP and %T9RCP were set to zero and gate QT02 was dele~ed, which resulted in an internal and external benefit (with uncertainty) of approximately $3,969,811. This analysis case was used to model the benefit of phase II SAMAs 24, 25, and 26.
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| Case 17: Main Feedwater System Reliability This analysis case was used to evaluate the change in plant risk from installing a motor-driven feedwater pump. A bounding analysis was performed by setting loss of main feedwater to zero in the PSA model. Initiator% T4 was set to zero and gate BT02 was deleted, which resulted in an internal and external benefit (with uncertainty) of approximately $2,637,923. This analysis case was used to model the benefit of phase II SAMA 33.
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| Case 18: EOG Fuel Oil This analysis case was used to evaluate the change in plant risk from installing a large volume EOG fuel oil tank at an elevation greater than the EOG fuel oil day tanks. A bounding analysis was performed by setting the failure of the fuel oil pumps to zero in the PSA model [basic events ETKFOTNKAK, ETKFOTNKAG, ECVEG109AN, EXVEG117AK, EXVEG111AK, ETKFOSTKAJ, EXVF0105AK,ETKFOSTKAG,EHFFOXFRAA,ETKFOTNKBK,ETKFOTNKBG,ECVEG109BN, Page D-86
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage EXVEG117BK,EXVEG111BK,ETKFOSTKBJ,EXVF0105BK,ETKFOSTKBG,EHFFOXFRBA, EMPOILTRAL, EMPOILTRAA, ECCFOXFRA, ECCFOXFRF, EMPOILTRBF, EMPOILTRBL, EMPOILTRBA, and EMPOIL TRAF were set to zero] which resulted in an internal and external benefit (with uncertainty) of approximately $2, 722, 110. This analysis case was used to model the benefit of phase II SAMA 11.
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| Case 19: Intentionally Left Blank Case 20: Create a reactor coolant depressurization system This analysis case was used to evaluate the change in plant risk from creating a reactor coolant depressurization system. A bounding analysis was performed by eliminating small LOCA events by setting events #SB, #SU, and #SX to zero. This resulted in an internal and external benefit (with uncertainty) of approximately $465, 700. This analysis case was used to model the benefit of phase II SAMA 18.
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| Case 21 : Steam Generator Inventory This analysis case was used to evaluate the change in plant risk from using the fire water system as a backup for steam generator inventory. A bounding analysis was performed by reducing the frequency of the turbine-driven AFW pump and failure of local operation of AFW during SBO in the PSA model [gates 0304, 0305, 0471, 0481, 0120, 0202, and EFW were ANOed with a basic event set to 1.0E-03 (based conservatively on the failure of the entire firewater system)],
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| \ which resulted in an internal and external benefit (with uncertainty) of approximately $8,212,217.
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| This analysis case was used to model the benefit of phase II SAMA 34.
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| Case 22: Instrument Air Reliability This analysis case was used to evaluate the change in plant risk from increasing the reliability of the Instrument Air system. A bounding analysis was performed by eliminating the loss of the Instrument Air System initiating event in the PSA model [Initiator% TIA was set to zero, and gates 1110, IMM3SLWTRA, IMM3SLWTRB, MMM3SLWTRA, MMM3SLWTRB, MMM3SLWTRC were pruned and set to zero], which resulted in an internal and external benefit (with uncertainty) of approximately $4,532. This analysis case was used to model the benefit of phase II SAMA 37.
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| Case 23: Increased availability of HVAC This analysis case was used to evaluate the change in plant risk from a loss of HVAC in the battery, EOG, and main control rooms with temporary HVAC such as fans, portable coolers, or opening doors. A bounding analysis was performed by running three cases, each eliminating one system; MCR HVAC (gate W001), EOG room 3A cooling (gate U007), and EOG room 38 cooling
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| .(gate U008). It was determined that removing the EOG room 3A cooling gate U007 would provide the most benefit. This case resulted in an internal and external benefit (with uncertainty) of approximately $1,550,385. This analysis case was used to model the benefit of phase II SAMAs 35 and 36.
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| Page D-87
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Case 24: Debris coolability and core concrete interaction This analysis case was used to evaluate the change in plant risk from enhancing debris coolability and mitigating core concrete interaction. A bounding analysis was performed by eliminating failure of debris coolability and core concrete interaction in the PSA model [Gate CMR_3 under gate CMR, gate XCAV underneath gate Hl_2F, and basic event CAV-FSUMP underneath gate VB_FAIL were deleted and basic event BMT was set to zero], which resulted in an internal and external benefit (with uncertainty) of approximately $61, 182. This analysis case was used to model the benefit of phase II SAMAs 38, 47, 72, and 73.
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| Case 25: Decay Heat Removal Capability This analysis case was used to evaluate the change in plant risk from installing a containment vent. A bounding analysis was performed by eliminating late containment failure due to over-pressurization in the PSA model [BE Flags #CFL2, #CFL3, #CFL4, and #CFL5 were set to FALSE], which resulted in an internal and external benefit (with uncertainty) of approximately
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| $2,612,900. This analysis case was used to model the benefit of phase II SAMAs 41 and 42.
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| Case 26: Improve Containment Spray Capability This analysis case was used to evaluate the change in plant risk from improving the Containment Spray system. A bounding analysis was performed by reducing failure of containment spray in the PSA model. Gate Y001L1 was ANDed with an event set to 1.0E-03, and events P_CSFAILS and YHFSPRAYLP were set to 1.0E-03 based conservatively on the failure of the entire containment spray system, which resulted in an internal and external benefit (with uncertainty) of approximately $3,864,827. This analysis case was used to model the benefit of phase II SAMAs 39, 40, and 50.
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| Case 27: Reduce Hydrogen Ignition This analysis case was used to evaluate the change in plant risk from implementing means to reduce hydrogen ignition. A bounding analysis was performed by eliminating hydrogen detonation in the PSA model. Basic events H2GLOBCON, CNTH2FAILG, H2LOCCON, CNTH2FAILL, H2LCH, H2LCL, CNTFAILLCH, CNTFAILLCL, H2HCL, CNTFAILHCL, H2HCH, CNTFAILHCH, P_IGN, P_H2BURN were set to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $25,290. This analysis case was used to model the benefit of phase II SAMAs 43, 51, and 52.
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| Case 28: Increase Cooling and Containment of Molten Core Debris This analysis case was used to evaluate the change in plant risk from creating a large concrete crucible to contain molten core debris or creating a core melt reduction system. A bounding analysis was performed by eliminating containment core melt propagation in the PSA model.
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| Basic events BMT, X_BMT, and PRCOOLDBIV were set to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $6,946,981. This analysis case was used to model the benefit of phase II SAMAs 44, 45, and 46.
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| Case 29. High Pressure Core Ejection Occurrences This analysis case was used to evaluate the change in plant risk from erecting a barrierthat would \
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| provide enhanced protection of the containment walls (shell) from ejected core debris following a '
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| Page D-88
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage core melt scenario at high pressure. A bounding analysis was performed by eliminating high pressure core ejection occurrences in the PSA model [basic events HPME, and X_BMT were set to zero], which resulted in an internal and external benefit (with uncertainty) of approximately
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| $6,885,811. This analysis case was used to model the benefit of phase II SAMA 53.
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| Case 30: Reduce Probability of Containment Failure This analysis case was used to evaluate the change in plant risk from constructing a building to be connected to the primary/secondary containment and maintained at a vacuum. A bounding analysis was performed by eliminating containment failure from the PSA model [BE Flags #CFE2,
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| #CFL3, #CFL2, #CFL4 , and #CFL5 were set to FALSE], which resulted in an internal and external benefit (with uncertainty) of appro!{imately $10,535,565. This analysis case was used to model the benefit of phase II SAMA 48.
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| Case 31 : Containment Isolation This analysis case was used to evaluate the change in plant risk from adding redundant and diverse limit switches to each containment isolation valve. A bounding analysis was performed by eliminating containment isolation failure by setting #CIF to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $14,752. This analysis case was used to model the benefit of Phase II SAMA 55.
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| Case 32: Reduce Frequency of Steam Generator Tube Ruptures This SAMA analysis case was used to evaluate the change in plant risk with reducing the frequency of steam generator tube ruptures. A bounding analysis was performed by eliminating steam generator tube ruptures in the PSA model by setting events %R, #Tl-SGTR, Tl-SGTR_SBO, Tl_SGTR and Tl-SGTR_NOSBO, Pl_SGTR_SBO, #Pl-SGTR-SBO, Pl-SGTR_NOSBO, Pl_;SGTR, and #Pl-SGTR to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $694,437. This analysis case was used to model the benefit of phase II SAMAs 56, 57, 58, 59, and 60.
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| Case 33: Reduce Consequences of Steam Generator Tube Ruptures This analysis case was used to evaluate the change in plant risk from implementing mitigation strategies for reducing steam generator tube rupture consequences. A bounding analysis was performed by reassigning the SGTR CDF contribution from H-E (2.17E-7 per year) to release category L-1. The frequency of 2.17E-7 was determined by eliminating the SGTR contribution to H-E by eliminating or setting to zero gates UR01_1 and UR01_2 along with basic events
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| #Tl-SGTR, Tl-SGTR_SBO, Tl_SGTR, Tl-SGTR_NOSBO, Pl_SGTR_SBO, #Pl-SGTR-SBO, Pl-SGTR_NOSBO, Pl_SGTR, and #Pl-SGTR. This resulted in an internal and external benefit (with uncertainty) of approximately $100,807. This analysis case was used to model the benefit of phase II SAMA 61 .
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| Case 34: Reduce ATWS Frequency This analysis case was used to evaluate the change in plant risk from reducing the A TWS frequency and consequences. A bounding analysis was performed by setting the A TWS events from the PSA model [#TK, #TKQ, and #TKC] to FALSE, which resulted in an internal and external benefit (with uncertainty) of approximately $39,577. This analysis case was used to model the benefit of phase II SAMAs 63, 64, 65, and 66.
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| Page D-89
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Case 35: Intentionally Left Blank Case 36: Intentionally Left Blank Case 37: Reduce Probability of a LOCA This analysis case was used to evaluate the change in plant risk from installing a digital large break LOCA protection system. A bounding analysis was performed by setting the initiators for a Large LOCA (%A) and a medium LOCA (%M) to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $28,650. This analysis case was used to model the benefit of phase II SAMA 69.
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| Case 38: Prevent Secondary Side Depressurization This analysis case was used to evaluate the change in plant risk from installing secondary side guard pipes up to the main steam isolation valves. A bounding analysis was performed by eliminating the initiator for a steam line break outside containment or the inadvertent closure of MS IVs in the PSA model by setting events %T6 and % T60C to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $10,417. This analysis case was used to model the benefit of phase II SAMA 70.
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| Case 39: Eliminate Thermally Induced Tube Ruptures Following Core Damage This analysis case was used to evaluate modifying procedures such that the water loop seals in the reactor cooling system (RCS) cold legs are not cleared following core damage. A bounding analysis was performed by eliminating thermal induced steam generator tube rupture events by setting events #Tl-SGTR, Tl_SGTR, Tl-SGTR_SBO, and Tl-SGTR_NOSBO to zero. This resulted in an internal and external benefit (with uncertainty) of approximately $29,591. This analysis case was used to model the benefit of phase II SAMA 54.
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| Case 40: Replace CARMVAAA201-B with a fail closed AOV This analysis case was used to evaluate replacing MOV CARMVAAA201-B to remove its AC power dependency. A bounding analysis was performed by eliminating motive power dependency from gate JMMCAR201 C (Gate G024), which resulted in an internal and external benefit (with uncertainty) of approximately $0. This analysis case was used to model the benefit of phase II SAMA 62.
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| Case 41: Improve internal flooding response procedures and training This analysis case was used to evaluate the change in plant risk from improving internal flooding response procedures and training to improve the response to internal flooding events.
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| The WF3 internal flooding notebook states the following for the modified operator actions:
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| Based on a review of the operator actions impacted by internal flooding three actions in Turbine Generator Building +15 elevation and one action on Reactor Auxiliary Building +46 elevation were Page D-90
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage identified. Therefore, two additional rule recovery files, recovery_rulesTB15.txt and recovery_rulesRAB46.txt, were developed that removed the actions on these elevations.
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| Since the internal event risk analysis does not include internal flooding, this internal flooding SAMA would not mitigate internal event risk. A bounding analysis was performed by assuming the SAMA would eliminate the contribution to internal flooding CDF in the Turbine Generator Building
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| +15 elevation and Reactor Auxiliary Building +46 elevation. The total internal flooding CDF is 2.48E-06/rx-yr [D.2-9]. This analysis case was used to model the benefit of phase II SAMA 67.
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| The internal flooding CDF eliminated is as follows:
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| Event CDF RAB46-299-A 1.58E-08 RAB46-299-B 1.58E-08 RAB46-300-46E-46W-A 3.26E-09 RAB46-300-46E-46W-B 1.62E-09 TB15-250-3 1.94E-08 TB15-250-1B 1.13E-08 TB15-250-5 2.05E-09 TB15-250-2 6.47E-10 TB15-250-4 4.00E-10 TB15-250-1A 6.14E-11 TB15-250-1 3.29E-12 Total 7.03E-08 The percent reduction is 7.03E-08/2.48E-06 = 2.83%
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| The internal events model cannot be used to assess the benefit from this internal flooding SAMA.
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| However, the consequences resulting from internal flooding core damage and internal event-induced core damage would be comparable. Since we have already estimated the maximum benefit from removing all internal event risk, the maximum benefit of removing all internal flooding risk can be estimated by reducing the maximum internal event benefit by the ratio of the total internal flooding CDF to the internal event CDF. The total internal flooding benefit is calculated below.
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| Given, Maximum internal benefit is $2, 163, 103 Total internal flooding CDF = 2.48E-06/rx-yr [D.2-9]
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| Internal events CDF = 1.05E-05/rx-yr Maximum internal flooding benefit = Maximum internal benefit x Total internal flooding GDF/Internal events CDF Maximum internal flooding benefit= $2, 163, 103 x (2.48E-06/1.05E-05) = $510,904 SAMA case 41 benefit= 2.83% x (Maximum internal flooding benefit)= 0.0283 x $510,904 SAMA case 41 benefit= $14,459 Applying the uncertainty factor of 1.99,
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| *SAMA case 41 benefit with uncertainty= $14,459 x 1.99 = $28,773 Page D-91
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Case 42: Water tight doors for the largest contributor to internal flooding This analysis case was used to evaluate the change in plant risk from installing flood doors to prevent water propagation in the electric board room. The electrical equipment rooms at WF3 do not have water tight flood doors. Specifically this SAMA will evaluate water tight doors for the largest contributor to internal flooding, which is flood zone RAB21-212/2258. This analysis case was used to model the benefit of phase II SAMA 68.
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| Since the internal event risk analysis does not include internal flooding, this internal flooding SAMA would not mitigate internal event risk. A bounding analysis was performed by assuming the SAMA would eliminate the contribution to internal flooding CDF from flood zone RAB21-212/2258.
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| The total internal flooding CDF is 2.48E-06/rx-yr [D.2-9].
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| The internal flooding CDF eliminated is as follows:
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| Event CDF RAB21-212-225B-80MIN 7.19E-07 RAB21-212-225B-45MIN 3.47E-10 RAB21-212-225B-15MIN 8.40E-11 RAB21-212-225B-15-45MIN 2.76E-11 Total 7.19E-07 The percent reduction is 7 .19E-07 /2.48E-06 = 28.99%
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| The internal events model cannot be used to assess the benefit from this internal flooding SAMA.
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| However, the consequences resulting from internal flooding core damage and internal event-induced core damage would be comparable. Since we have already estimated the maximum benefit from removing all internal event risk, the maximum benefit of removing all internal flooding risk can be estimated by reducing the maximum internal event benefit by the ratio of the total internal flooding CDF to the i.nternal event CDF. The total internal flooding benefit is calculated below.
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| : Given, Maximum internal benefit is $2, 163, 103 Total internal flooding CDF = 2.48E-06/rx-yr [D.2-9]
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| Internal events CDF = 1.05E-05/rx-yr Maximum internal flooding benefit = Maximum internal benefit x Total internal flooding GDF/Internal events CDF Maximum internal flooding benefit= $2, 163, 103 x (2.48E-06/1.05E-05) = $510,904 SAMA case 42 benefit= 28.99% x (Maximum internal flooding benefit) = 0.2899 x $510,904 SAMA case 42 benefit= $148, 111 Applying the uncertainty factor of 1.99, SAMA case 42 benefit with uncertainty= $148, 111 x 1.99 = $294,741
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| /
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| I Page D-92
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Case 43: Gagging device to close a stuck open safety valve This analysis case was used to evaluate installing a gagging device to close a stuck open safety valve. A bounding analysis was performed by eliminating the failure of stuck open relief valves by setting events PRYMS 1068T, PRYMS 112BT, PRYMS 1088T, PRYMS 1138T, PRYMS 11 OST, PRYMS114BT, PRYMS106AT, PRYMS112AT, PRYMS108AT, PRYMS113AT, PRYMS110AT, PRYMS114AT, and OHFMSSGAGR to zero, which resulted in an internal and external benefit (with uncertainty) of approximately $76. This analysis case was used to model the benefit of phase II SAMA 71.
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| D.2.4 Sensitivity Analyses Two sensitivity analyses were conducted to gauge the impact of assumptions upon the analysis.
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| The benefits estimated for each of these sensitivities are presented in Table D.2-3.
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| A description of each sensitivity case follows.
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| Sensitivity Case 1: Years Remaining Until End of Plant Life The purpose of this sensitivity case was to investigate the sensitivity of assuming a 29-year period for remaining plant life (i.e. nine years on the original plant license plus the 20-year license renewal period), rather than the 20-year license renewal period used in the base case.
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| Changing this assumption does not cause additional SAMAs to be cost-beneficial.
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| Sensitivity Case 2: Conservative Discount Rate The purpose of this sensitivity case was to investigate the sensitivity of each analysis case to the discount rate. The discount rate of 7.0% used in the base case analyses is conservative relative to corporate practices. Nonetheless, a lower discount rate of 3.0% was assumed in this case to investigate the impact on each analysis case. Changing this assumption does not cause additional SAMAs to be cost-beneficial.
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| Page D-93
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage D.2.5 References D.2-1 Nuclear Energy Institute (NEI), NEI 05-01, Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance Document, November 2005, Revision A.
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| D.2-2 U.S. Nuclear Regulatory Commission (USNRC), NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Davis-Besse Nuclear Power Station (NUREG-1437, Supplement 52) Final Report, April 2015.
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| D.2-3 USNRC, NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding South Texas Project, Units 1 and 2 (NUREG-1437, Supplement 48) Final Report, November 2013.
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| D.2-4 USNRC, NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Callaway Plant, Unit 1 (NUREG-1437, Supplement 51) Final Report, October 2014.
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| D.2-5 USNRC, NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Seabrook Station (NU.REG-1437, Supplement 46) Final Report, July 2015.
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| D.2-6 USNRC, NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Sequoyah Nuclear Plant, Units 1 and 2 (NUREG-1437, Supplement 53) Final Report, March 2015.
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| D.2-7 Waterford 3 Probabilistic Risk Assessment Individual Plant Examination Submittal, August 1992.
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| D.2-8 WF3 IPEEE "Internal Plant Examination of External Events", Revision 0, July 1995.
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| D.2-9 WF3 Calculation No: PRA-W3-01-002, 'W3 Internal Flooding Analysis", Revision 3.
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| D.2-10 WF3-EP-14-00014, "Cost-Benefit Analysis of Severe Accident Mitigation Alternatives,"
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| Revision 0.
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| D.2-11 NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Arkansas Nuclear One, Unit 2 (NUREG-1437, Supplement 19)
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| Final Report", April 2005.
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| D.2-12 Entergy Letter NL-14-143, "Reply to Request for Additional Information Regarding the License Renewal Application," November 20, 2014(ML14337A042).
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| D.2-13 W3F1-2011-007 4, "License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)", November 2011.
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| Page D-94
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-1 Phase I SAMAs Related to IPE and IPEEE Insights Phase I SAMA Title Result of Potential Screening SAMA Disposition Credited in SAMA ID Enhancement Results PSA Model Number 183 Cross-tie of AC power trains. Proceduralize the process to #2 - Similar See disposition on SAMA 11. No cross-tie power from train A item is to train B equipment. The addressed ability to cross-tie power under other trains can have a significant proposed impact on preventing core SAM As melt when failure of one train is due to power failures.
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| 184 Install a portable generator to A portable generator that #3 -Already The AB battery is generally utilized to Yes charge the AB battery. can be used to continue to installed power the TDEFW pump. The TDEFW supply DC power to the EFW control system is operable until the turbine driven pump AB station battery reaches its controls (and necessary minimum voltage. At this time local monitoring instrumentation) manual control of the TDEFW pump is can decrease the likelihood implemented. Due to the length of of core melt before AC time before battery depletion and power is restored. the ability to perform manual operation it's not expected that additional charging capacity would have significant importance for the AB system. Therefore, the intent of this SAMA is considered to have already been implemented at WF3 Page D-95
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-1 Phase I SAMAs Related to IPE and IPEEE Insights Phase I SAMA Title Result of Potential Screening SAMA Disposition Credited in SAMA ID Enhancement Results PSAModel Number 185 Add guidance for aligning the LPSI !The LPSI pumps can be #3 -Already Using LPSI to replace containment No pump for containment spray. aligned to serve as installed spray is proceduralized in containment spray pumps OP-902-009, Appendix 28. The and therefore may provide a containment spray system is utilized backup to this function. in response to a large LOCA, however, Guidance for this alignment the operator action has not been would decrease the included in the PRA model due to probability of containment insufficient time to perform the failure caused by steam alignment.
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| overpressurization.
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| 186 Enhance refill of condensate storage Emphasize the need to refill #3 -Already For Emergency Feedwater (EFW) the Yes pool. the condensate storage pool installed CSP inventory is not sufficient for the (CSP) with acceptable 24 mission time, so either CSP quality water (or switch to makeup or transfer of the EFW the wet cooling tower basin) suction to the wet cooling towers in training. Makeup from (WCTs) via the ACCW system is other sources can extend needed.
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| the time for the coo Id own or If CSP level drops below 25%, the ensure continued heat operators are instructed to align EFW removal. suction to ACCW per OP-902-009, Appendix 10. Operators are trained to this procedure.
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| F .)-96
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| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-1 Phase I SAMAs Related to IPE and IPEEE Insights Phase I SAMA Title Result of Potential Screening SAMA Disposition Credited in SAMA ID Enhancement Results PSA Model Number 187 Provide feedwater from the fire The fire protection system #2 - Similar See disposition on SAMA 83. No protection system to the steam has its own diesel driven item is generator pumps. During station addressed blackouts or total loss of under other feedwater, this system could proposed provide an additional source SAM As of feedwater to remove heat from the RCS.
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| 188 Provide additional guidance for Room cooling failures are #2 - Similar See SAMA 93 for implementing No chiller/HVAC failure. important to the long term item is procedures for temporary HVAC.
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| operation of the HPSI and addressed EFW pumps. Additional under other guidance to address room proposed cooling failures can provide SAMAs information to identify actions to recover cooling and minimize the effects of room heatup.
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| 189 Provide water from the fire Providing water to the Retain This SAMA is being retained to No protection system to the reactor cavity from the fire consider providing water to the containment sump. protection system may reactor cavity from the fire prevent vessel breach by protection system.
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| allowing ex-vessel cooling.
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| Page D-97
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-1 Phase I SAMAs Related to IPE and IPEEE Insights Phase I SAMA Title Result of Potential Screening SAMA Disposition Credited in SAMA ID Enhancement Results PSA Model Number 190 Enhance communication between Increasing the flow area Retain This SAMA is being retained to No sump and cavity. through the door in the consider removal of the door in the ductwork (or removal of the ductwork to allow increased flow of door completely) will allow a water from the containment sump more free flow of water into the reactor cavity.
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| from the containment sump into the reactor cavity.
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| 191 Add a portable pump in the cooling Reduce risk due to external #3 -Already The licensee added a portable pump No tower area to mitigate excess flooding in the cooling tower installed in the cooling tower area to mitigate ponding due to a PMP or probable area. excess ponding due to a postulated maximum hurricane event. probable maximum precipitation or probable maximum hurricane event.
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| rrhis pump was added to the surveillance testing program.
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| 192 Remove or restrain the lockers and Reduce seismic risk in the #3 -Already The equipment identified was No file cabinets in the control room, Control Room installed analyzed for potential impact to remove book shelves in the vicinity safety-related equipment. As good of safety-related cabinets, and engineering practice the book cases relocate or restrain other loose near CP-22 and the tool cart in the items in the vicinity of safety-related EOG Room B were removed and cabinets. there was no additional impact to safety related equipment following the evaluation.
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| ::>-98
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-1 Phase I SAMAs Related to IPE and IPEEE Insights Phase I SAMA Title Result of Potential Screening SAMA Disposition Credited in SAMA ID Enhancement Results PSA Model Number 193 Revise procedure FP-001-17, Include guidance for #3 -Already Procedural guidance for temporary No Transient Combustibles and temporary storage of temp installed storage is provided in UNT-007-060 Designated Storage Areas. equipment inside the to prevent potentially hazardous Seismic Category I buildings situations under seismic conditions.
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| to prevent hazardous seismic interactions.
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| 194 Add fire wrap to the B Chilled Water A fire on Chiller A or Chilled #3 -Already Fire wrap has been installed in fire No cables in the vicinity of the A Chiller. Water Pump A could installed area RAB-2 to the B chilled water damage cables associated cables in the vicinity of the A chiller with Chiller train B. Adding and is being maintained in the NFPA fire wrap to the B train 805 submittal for defense in depth.
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| cables would add robustness Also, one of the NFPA-805 mods is in of the plant to fire hazards RAB 2 and is to construct a radiant in this fire area. heat barrier to further separate the A and B trains of chilled water pumps.
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| This change protects each trains chiller pump (and associated nearby equipment) from a fire in the opposite train.
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| 195 Evaluate why existing clearance for Reduces seismic risk for the #3 -Already CR-94-1111 contains the evaluation No the station air pipe which is adjacent equipment in the panel. installed that the existing clearance for the to 4KVESWGR3B XPANEL does not station air pipe which is adjacent to meet the clearance requirements 4KVESWGR3B will have no significant stated on the design drawing. adverse impact during a seismic condition.
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| Page D-99
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
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| ~
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| Case 1. SBO Eliminated SBO
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| .Reduction contribution. 34.4% 42.5% 44.5% $2,812,956 $5,597,783
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| : 1. Provide additional WF3 plant specific DC battery capacity. cost $3,172,695 Retain
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| : 2. Replace lead-acid WF3 plant specific Not cost batteries with fuel cells. cost $6, 185,319 effective
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| : 7. Install a gas turbine Davis-Besse cost generator. estimate $2,000,000 Retain Case 2. Improve Eliminated failure of Feedwater Reliability feedwater. 0.9% 0.2% 0.2% $17,769 $35,361
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| : 31. Install a digital feed Seabrook Cost Not cost water upgrade. estimate $6, 100,000 effective I; .D-100
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Changed gates to Case 3. Add DC require multiple DC System Cross-ties bus failures. 20.8% 31.0% 31.3% $1,966,036 $3,912,412
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| : 3. Provide DC bus WF3 plant specific cross-ties. cost $1,449,686 Retain Case 4. Increase Changed gates to Availability of On-Site require multiple AC AC Power bus failures. 22.2% 32.0% 32.3% $2,033,811 $4,047,285
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| : 5. Improve 4.16-kV bus WF3 plant specific cross-tie ability. cost $1,554,988 Retain Reduce the frequency of the LOOP initiator Case 5. Reduce Loss by removing severe of Off-Site Power weather contribution. 13.5% 13.7% 14.1% $912,630 $1,816,135
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| : 10. Bury off-site power Seabrook Cost Not cost lines. estimate $3,000,000 effective Page D-101
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 6. Install an additional, buried off-site power Seabrook Cost Not cost source. estimate $3,000,000 effective Eliminated failure of Case 6. Provide CCW cooling to the Backup EOG Cooling EDGs. 4.4% 10.8% 11.0% $672,315 $1,337,906
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| : 8. Use fire water system as a backup source for Seabrook Cost Not cost diesel cooling. estimate $2,000,000 effective
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| : 9. Add a new backup source of diesel Seabrook Cost Not cost cooling. estimate $2,000,000 effective Case 7. Reduced Frequency of Loss of Auxiliary Component Eliminated failure of Cooling Water ACCW. 6.4% 1.3% 0.7% $92,174 $183,427
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| : 21. Enhance procedural Generic cost estimate guidance for use of for procedural change cross- tied component with engineering and cooling or service water testing/training Not cost pumps. required. $200,000 effective F )-102
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| | |
| Waterford Steam Electric Srauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
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| : 22. Add a service water Sequoyah cost Not cost pump. estimate $1,043,000 effective
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| : 23. On loss of essential raw cooling water, proceduralize shedding Generic cost estimate component cooling for procedural change water loads to extend with engineering and the component cooling testing/training Not cost water heat-up time. required. $200,000 effective Case 8. Increased Eliminated DWST availability of failure to supply the feedwater CSP. 1.2% 0.3% 0.2% $23,585 $46,934
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| : 32. Create ability for emergency connection of existing or new water sources to feedwater and condensate WF3 plant specific Not cost systems. cost $885,760 effective Case 9. High Pressure Eliminated failure of Injection System HPSI. 8.4% 4.7% 3.4% $272,321 $541,919 Page D-103
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
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| : 17. Replace two of the four electric safety injection pumps with Callaway cost Not cost diesel-powered pumps. estimate $1,500,000 effective
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| : 13. Install an independent active or passive high pressure Callaway cost Not cost injection system. estimate $1,500,000 effective Case 10. Extend Reactor Water Reduced failure from Storage Pool operator actions and Capacity tank rupture. 1.8% 0.2% 0.1% $18,822 $37,457
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| : 16. Throttle low pressure injection pumps earlier in medium or large-break LOCAs to maintain reactor water storage Seabrook Cost Not cost tank inventory. estimate $3,000,000 effective
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| : 29. RWST fill from firewater during containment injection-Modify 6 inch RWST flush flange to have a 2%-inch female fire hose adapter with WF3 plant specific Not cost isolation valve. cost $747,640 effective F *)-104
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
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| : 30. High-volume makeup to the refueling Sequoyah cost Not cost water storage tank. estimate $565,000 effective
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| : 49. Install automatic containment spray pump header throttle Not cost valves. AN0-2 cost estimate $2,500,000 effective Case 11. Eliminate ECCS Dependency on Component Cooling Eliminated failure of Water System ECCS motor cooling. 0.7% 2.8% 3.1% $181,572 $361,328
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| : 20. Replace ECCS pump motors with Seabrook Cost Not cost air-cooled motors. estimate $6,000,000 effective Eliminated the DC Case 12. Increase control power gates to Availability of ACCW the ACCW pumps. 0.2% 0.1% 0.1% $9,374 $18,655
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| : 19. Add redundant DC control power for SW Callaway cost Not cost pumps. estimate $100,000 effective Page D-105
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Eliminated failure of Case 13. Low the Low Pressure Pressure Safety Safety Injection Injection System system. 0.0% 0.0% 0.0% $20 $39
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| : 14. Add a diverse low pressure injection Callaway cost Not cost system. estimate $1,000,000 effective
| |
| : 15. Provide capability for alternate injection via diesel-driven fire Davis-Besse cost Not cost pump. estimate $6,500,000 effective Case 14. Increase Eliminated failure of Component Cooling CCW pump failures Water Availability and CCFs. 13.5% 28.1% 29.0% $1,775,007 $3,532,265
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| : 27. Install an additional component cooling Seabrook Cost Not cost water pump. estimate $6,000,000 effective Case 15. Decreased Eliminated the normal Charging Pump charging pump power Failure gates. 0.4% 0.8% 0.8% $48,319 $96,156 p )-106
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| | |
| i' Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 12. Install modification to power the normal charging pump from an existing spare breaker from the alternate emergency power Callaway cost Not cost system. estimate $350,000 effective Case 16. Reactor Eliminated RCP Seal Coolant Pump Seals LOCA. 16.0% 31.6% 32.4% $1,994,880 $3,969,811
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| : 24. Install an independent reactor coolant pump seal injection system, with Seabrook Cost Not cost dedicated diesel. estimate $6,400,000 effective
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| : 25. Install an independent reactor coolant pump seal injection system, without dedicated Seabrook Cost Not cost diesel. estimate $6,400,000 effective
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| : 26. Install improved reactor coolant pump Seabrook Cost seals. estimate $2,000,000 Retain Page D-107
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Case 17. Main Feedwater System Set loss of main Reliability feedwater to zero. 33.3% 19.5% 18.5% $1,325,589 $2,637,923
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| : 33. Add a motor-driven Sequoyah cost Not cost feedwater pump. estimate $10,000,000 effective Set the failure of fuel Case 18. EOG Fuel Oil oil pumps to zero. 17.1% 20.8% 21.5% $1,367,894 $2,722,110
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| : 11. Install a large volume EOG fuel oil tank at an elevation greater than the EOG Callaway cost fuel oil day tanks. estimate $150,000 Retain Case 20. Create a reactor coolant depressurization Eliminated small system LOCA events. 14.5% 3.8% 1.9% $234,020 $465,700
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| : 18. Create a reactor coolant depressurization Callaway cost Not cost system. estimate $500,000 effective
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| | |
| Waterford Steam Electric 8tauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Reduced the frequency of turbine-driven AFW Case 21. Steam pump failure during Generator Inventory SBO. 67.3% 61.8% 62.9% $4,126,742 $8,212,217
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| : 34. Use fire water system as a backup for steam generator Cost from Indian Point inventory. (IP2) $3,073,130 Retain Case 22. Instrument Eliminated the loss of Air Reliability Instrument Air. 0.1% 0.0% 0.0% $2,278 $4,532
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| : 37. Replace service and instrument air compressors with more reliable compressors which have self-contained air cooling by shaft driven Callaway cost Not cost fans. estimate $500,000 effective Case 23. Increased Eliminated failure of Availability of HVAC EOG room 3A cooling. 9.4% 11.9% 12.3% $779,088 $1,550,385 Page D-109
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert ,WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 35. Provide a redundant train or means of WF3 plant specific Not cost ventilation. cost $3,574,481 effective
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| : 36. Implement procedures for Callaway cost temporary HVAC. estimate $100,000 Retain Eliminated failure of Case 24. Debris debris coolability and coolability and core core concrete concrete interaction interaction. 0.0% 0.5% 0.5% $30,745 $61,182
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| : 38. Create a reactor Cost from Indian Point Not cost cavity flooding system. (IP2) $1,741,724 effective
| |
| : 47. Provide a reactor vessel exterior cooling Not cost system.* Cost f ram AN0-2 $2,500,000 effective
| |
| : 72. Provide water from the fire protection system to the WF3 plant specific Not cost containment sump. cost $715,918 effective I: D-110
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| | |
| Waterford Steam Electric 8tat1on Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
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| : 73. Enhance communication between sump and WF3 plant specific Not cost cavity. cost $702,551 effective Eliminated late containment failure Case 25. Decay Heat due to Removal Capability over-pressurization. 0.0% 21.5% 22.8% $1,313,015 $2,612,900
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| : 41. Install an unfiltered, hardened containment Seabrook cost Not cost vent. estimate $3,000,000 effective
| |
| : 42. Install a filtered containment vent to remove decay heat Option 1: Gravel Bed Filter Option 2: Multiple Seabrook cost Not cost Venturi Scrubber estimate $20,000,000 effective Case 26. Improve Containment Spray Reduced failure of Capability containment spray. 5.8% 17.2% 35.9% $1,942,124 $3,864,827
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| : 39. Install a passive containment spray Seabrook cost Not cost system. estimate $10,000,000 effective Page D-111
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 50. Install a redundant containment spray Seabrook cost Not cost system. estimate $10,000,000 effective
| |
| : 40. Use the fire water system as a backup source for the containment spray WF3 plant specific system. cost $2,455,808 Retain Case 27. Reduce Eliminated hydrogen Hydrogen Ignition detonation. 0.0% 0.3% 0.2% $12,709 $25,290
| |
| : 43. Provide post-accident containment inerting Callaway cost Not cost capability. estimate $100,000 effective
| |
| : 51. Install an independent power supply to the hydrogen control system using either new batteries, a non-safety grade portable generator, existing station batteries, or existing AC/DC independent power supplies, such as Callaway cost Not cost the security system estimate $100,000 effective F '.D-112
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion diesel.
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| : 52. Install a passive hydrogen control Seabrook cost Not cost system. estimate $100,000 effective Case 28. Increase Cooling and Eliminated Containment of containment core melt Molten Core Debris propagation. 0.0% 54.3% 61.1% $3,490,945 $6,946,981
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| : 44. Create a large concrete crucible with heat removal potential to contain molten core Callaway cost Not cost debris. estimate $10,000,000 effective
| |
| : 45. Create a core melt source reduction Callaway cost Not cost system. estimate $10,000,000 effective
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| : 46. Increase depth of the concrete base mat or use an alternate concrete material to ensure melt- through Callaway cost Not cost does not occur. estimate $10,000,000 effective Page D-113
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Case 29. High Eliminated high Pressure Core pressure core ejection Ejection Occurrences occurrences. 0.0% 53.8% 60.6% $3,460,207 $6,885,811
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| : 53. Erect a barrier that would provide enhanced protection of the containment walls (shell) from ejected core debris following a core melt scenario at Callaway cost Not cost high pressure. estimate $10,000,000 effective Case 30. Reduce Probability of Eliminated Containment Failure containment failure. 0.0% 84.6% 92.2% $5,294,254 $10,535,565
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| : 48. Construct a building to be connected to primary/secondary containment and maintained at a Seabrook cost Not cost vacuum. estimate $56,700,000 effective Eliminated Case 31. Containment containment isolation Isolation failure. 0.0% 0.1% 0.1% $7,413 $14,752
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| | |
| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 55. Add redundant and diverse limit switches to each containment Sequoyah cost Not cost isolation valve. estimate $692,000 effective Case 32. Reduce Frequency of Steam Eliminated steam Generator Tube generator tube Ruptures ruptures. 1.0% 5.6% 5.9% $348,963 $694,437
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| : 56. Institute a maintenance practice to perform a 100%
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| inspection of steam generator tubes during Callaway cost Not cost each refuelinq outaqe. estimate $3,000,000 effective
| |
| : 57. Increase the pressure capacity of the secondary side so that a steam generator tube rupture would not cause Callaway cost Not cost the relief valves to lift. estimate $10,000,000 effective
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| : 58. Install a redundant spray system to depressurize the primary system during a steam generator tube Callaway cost Not cost rupture estimate ' $10,000,000 effective Page D-115
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 59. Route the discharge from the main steam safety valves through a structure where a water spray would condense the steam and remove most of Callaway cost Not cost the fission products. estimate $10,000,000 effective
| |
| : 60. Install a highly reliable (closed loop) steam generator shell-side heat removal system that relies on natural circulation and Callaway cost Not cost
| |
| *-
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| stored water sources estimate $10,000,000 effective Case 33. Reduce Reassigned the SGTR Consequences of CDF contribution from Steam Generator H-E release category Tube Ruptures to release category L-1. 0% 0% 1.4% $50,657 $100,807
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| : 61. Direct steam Generic cost estimate generator flooding after for procedural change a steam generator tube with engineering and rupture, prior to core testing/training Not cost damage. required. $200,000 effective Case 34. Reduce Eliminated ATWS ATWS Frequency contribution. 1.4% 0.3% 0.2% $19,888 $39,577 F ~ D-116
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| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 63. Add an independent Seabrook cost Not cost boron injection system. estimate $500,000 effective
| |
| : 64. Add a system of relief valves to prevent equipment damage from pressure spikes Seabrook cost Not cost during an ATWS. estimate $500,000 effective
| |
| : 65. Install motor generator set trip breakers in control Sequoyah cost Not cost room. estimate $100,000 effective
| |
| : 66. Provide capability to remove power from the bus powering the Sequoyah cost Not cost control rods. estimate $100,000 effective Eliminated the initiators for a Large Case 37. Reduce LOCA and a medium Probability of a LOCA LOCA. 0.4% .0.2% 0.2% $14,397 $28,650
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| : 69. Install digital large break LOCA protection Seabrook cost Not cost system. estimate $500,000 effective Page D-117
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Eliminated the initiator for a steam line break Case 38. Prevent outside containment Secondary Side and for inadvertent Depressu rization closure of MSIVs. 0.3% 0.1% 0.0% $5,235 $10,417
| |
| : 70. Install secondary side guard pipes up to the main steam Seabrook cost Not cost isolation valves. estimate $500,000 effective Case 39. Eliminate Thermally Induced Eliminated thermal Tube Ruptures induced steam Following Core generator tube Damage rupture. 0.0% 0.2% 0.3% $14,870 $29,591
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| : 54. Modify procedures such that the water loop seals in the reactor cooling system (RCS) cold legs are not cleared following core South Texas cost Not cost damage. estimate $100,000 effective Eliminated motive Case 40. Replace power dependency CARMVAAA201-B from MOV with a fail closed AOV CARMVAAA201-B. 0.0% 0.0% 0.0% $0 $0
| |
| : 62. Hardware change to eliminate MOV CS-V-17 AC power Seabrook cost Not cost dependency. estimate $300,000 effective F )-118
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| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion Eliminated the contribution to internal flooding CDF from Case 41. Improve floods in the Turbine Internal Flooding Generator Building Response + 15 elevation and Procedures and Reactor Auxiliary 1
| |
| Training Building +46 elevation. N/A N/A N/A $14,459 $28,773
| |
| : 67. Improve internal flooding response procedures and training to improve the response to internal Sequoyah cost Not cost flooding events. estimate $400,000 effective Eliminated the Case 42. Water tight contribution to internal doors for the largest flooding CDF from contributor to internal floods in flood zone 1
| |
| flooding RAB21-212/225B. N/A N/A N/A $148,111 $294,741
| |
| : 68. Install flood doors to prevent water propagation in the Sequoyah cost Not cost electric board room. estimate $4,695,000 effective Case 43. Gagging device to close a Eliminated failure stuck open safety events for of stuck valve open relief valves. 0.0% 0.0% 0.0% $38 $76 Page D-119
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-2 Summary of Phase II SAMA Candidates Considered in Cost-Benefit Evaluation Internal and Internal External Analysis Case (bold) CDF PDR OECR and Benefit SAMA Number and Reduction Reduction Reduction External with Uncert WF3 Cost Title Assumptions (%) (%) (%) Benefit($) ($) Estimate ($) Conclusion
| |
| : 71. Manufacture a gagging device for a steam generator safety valve and developing a procedure or work order for closing a stuck-open Seabrook cost Not cost valve. estimate $30,000 effective These SAMA candidates were retained without evaluation as they are already commitments in the NFPA 805 LAR
| |
| [D.2-13] N/A N/A N/A N/A N/A N/A
| |
| : 74. In Fire Area RAB 2 construct a radiant heat barrier to further separate the A and B This modification is trains of chilled water from the Waterford 3 pumps. NFPA 805 LAR N/A N/A N/A N/A N/A N/A Retain
| |
| : 75. In Fire Area RAB 8C construct a radiant heat This modification is shield in Switchgear from the Waterford 3 Room A/B. NFPA 805 LAR N/A N/A N/A N/A N/A N/A Retain
| |
| : 76. In Fire Area RAB 6 install a 1-hour fire resistance rating This modification is ERFBS fire wrap barrier from the Waterford 3 from fire damage. NFPA 805 LAR N/A N/A N/A N/A N/A N/A Retain
| |
| \1)
| |
| These analysis cases only impact internal flooding and have been evaluated as described in Section D.2.3.
| |
| D-120
| |
| | |
| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate($)
| |
| Case 1. SBO Reduction $2,812,956 $3,312,210 $3,889,025
| |
| : 1. Provide additional DC battery capacity. $3,172,695
| |
| : 2. Replace lead-acid batteries with fuel cells. $6,185,319
| |
| : 7. Install a gas turbine generator. $2,000,000 Case 2. Improve Feedwater Reliability $17,769 $22,368 $23,693
| |
| : 31. Install a digital feed water upgrade. $6,100,000 Case 3. Add DC System Cross-ties $1,966,036 $2,308,511 $2,722,034
| |
| : 3. Provide DC bus cross-ties. $1,449,686 Case 4. Increase Availability of On-Site AC Power $2,033,811 $2,389,512 $2,815,012
| |
| : 5. Improve 4.16-kV bus cross-tie ability. $1,554,988 Case 5. Reduce Loss of Off-Site Power $912,630 $1,079,233 $1,258,950
| |
| : 10. Bury off-site power lines. $3,000,000
| |
| : 6. Install an additional, buried off-site power source. $3,000,000 Page D-121
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% . Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| Case 6. Provide Backup EOG Cooling $672,315 $783,999 $934,124
| |
| : 8. Use fire water system as a backup source for diesel cooling. $2,000,000
| |
| : 9. Add a new backup source of diesel cooling. $2,000,000 Case 7. Reduced Frequency of Loss of Auxiliary Component Cooling Water $92,174 $119,090 $121,050
| |
| : 21. Enhance procedural guidance for use of cross-tied component cooling or service water pumps. $200,000
| |
| : 22. Add a service water pump. $1,043,000
| |
| : 23. On loss of essential raw cooling water, Proceduralize shedding component cooling water loads to extend the component cooling water heat-up time. $200,000 Case 8. Increased availability of feedwater $23,585 $29,547 $31,533
| |
| : 32. Create ability for emergency connection of existing or new water sources to feedwater and condensate systems. $885,760 Case 9. High Pressure Injection System $272,321 $330,726 $370,403
| |
| : 17. Replace two of the four electric safety injection pumps with diesel-powered pumps. $1,500,000
| |
| : 13. Install an independent active or passive high pressure injection system. $1,500,000 Case 10. Extend Reactor Water Storage Pool Capacity $18,822 $25,402 $24,064
| |
| : 16. Throttle low pressure injection pumps earlier in medium or large-break LOCAs to maintain reactor $3,000,000
| |
| : f. D-122
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| water storage tank inventory.
| |
| : 29. RWST fill from firewater during containment injection-Modify 6 inch RWST flush flange to have a 2%-inch female fire hose adapter with isolation valve. $747,640
| |
| : 30. High-volume makeup to the refueling water storage tank. $565,000
| |
| : 49. Install automatic containment spray pump header throttle valves. $2,500,000 Case 11. Eliminate ECCS Dependency on Component Cooling Water System $181,572 $210,796 $252,845
| |
| : 20. Replace ECCS pump motors with air-cooled motors. $6,000,000 Case 12. Increase Availability of ACCW $9,374 $11,229 $12,845 Page D-123
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 19. Add redundant DC control power for SW pumps. $100,000 Case 13. Low Pressure Safety Injection System $20 $23 $28
| |
| : 14. Add a diverse low pressure injection system. $1,000,000
| |
| : 15. Provide capability for alternate injection via diesel-driven fire pump. $6,500,000 Case 14. Increase Component Cooling Water Availability $1,775,007 $2,073,694 $2,463,907
| |
| : 27. Install an additional component cooling water pump. $6,000,000 F 1
| |
| )-124
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs .. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| Case 15. Decreased Charging Pump Failure $48,319 $56,495 $67,046
| |
| : 12. Install modification to power the normal charging pump from an existing spare breaker from the alternate emergency power system. $350,000 Case 16. Reactor Coolant Pump Seals $1,994,880 $2,332,233 $2,768,106
| |
| : 24. Install an independent reactor coolant pump seal injection system, with dedicated diesel. $6,400,000
| |
| : 25. Install an independent reactor coolant pump seal injection system, without dedicated diesel. $6,400,000
| |
| : 26. Install improved reactor coolant pump seals. $2,000,000 Page D-125
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| Case 17. Main Feedwater System Reliability $1,325,589 $1,595,223 $1,811,895
| |
| : 33. Add a motor-driven feedwater pump. $10,000,000 Case 18. EOG Fuel Oil $1,367,894 $1,611,548 $1,890,640
| |
| : 11. Install a large volume EOG fuel oil tank at an elevation greater than the EOG fuel oil day tanks. $150,000 Case 20. Create a reactor coolant depressurization system $234,020 $298,942 $309,396
| |
| : 18. Create a reactor coolant depressurization system. $500,000 F .)-126
| |
| | |
| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit,
| |
| . Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| Case 21. Steam Generator Inventory $4,126,742 $4,893,060 $5,684,889
| |
| : 34. Use fire water system as a backup for steam generator inventory. $3,073, 130 Case 22. Instrument Air Reliability $2,278 $2,894 $3,021
| |
| : 37. Replace service and instrument air compressors with more reliable compressors which have self-contained air cooling by shaft driven fans. $500,000 Case 23. Increased Availability of HVAC $779,088 $917,204 $1,077,216
| |
| : 35. Provide a redundant train or means of ventilation. $3,574,481 Page D-127
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 36. Implement procedures for temporary HVAC. $100,000 Case 24. Debris coolability and core concrete interaction $30,745 $35,448 $42,962
| |
| : 38. Create a reactor cavity flooding system. $1,741,724
| |
| : 47. Provide a reactor vessel exterior cooling system. $2,500,000
| |
| : 72. Provide water from the fire protection system to the containment sump. $715,918
| |
| : 73. Enhance communication between sump and cavity. $702,551 F . )-128
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| Case 25. Decay Heat Removal Capability $1,313,015 $1,513,887 $1,834,753
| |
| : 41. Install an unfiltered, hardened containment vent. $3,000,000
| |
| : 42. Install a filtered containment vent to remove decay heat Option 1: Gravel Bed Filter Option 2: Multiple Venturi Scrubber $20,000,000 Case 26. Improve Containment Spray Capability $1,942,124 $2,250,883 $2,706,801
| |
| : 39. Install a passive containment spray system. $10,000,000
| |
| : 50. Install a redundant containment spray system. $10,000,000 Page D-129
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 40. Use the fire water system as a backup source for the containment spray system. $2,455,808 Case 27. Reduce Hydrogen Ignition $12,709 $14,649 $17,761
| |
| : 43. Provide post-accident containment inerting capability. $100,000
| |
| : 51. Install an independent power supply to the hydrogen control system using either new batteries, a non-safety grade portable generator, existing station batteries, or existing AC/DC independent power supplies, such as the security system diesel. $100,000
| |
| : 52. Install a passive hydrogen control system. $100,000 Case 28. Increase Cooling and Containment of Molten Core Debris $3,490,945 $4,025,013 $4,878,098 F* 0-130
| |
| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 44. Create a large concrete crucible with heat removal potential to contain molten core debris. $10,000,000
| |
| : 45. Create a core melt source reduction system. $10,000,000
| |
| : 46. Increase depth of the concrete base mat or use an alternate concrete material to ensure melt-through does not occur. $10,000,000 Case 29. High Pressure Core Ejection Occurrences $3,460,207 $3,989,572 $4,835,145
| |
| : 53. Erect a barrier that would provide enhanced protection of the containment walls (shell) from ejected core debris following a core melt scenario at high pressure. $10,000,000 Case 30. Reduce Probability of Containment Failure $5,294,254 $6,104,206 $7,397,963 Page D-131
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 48. Construct a building to be connected to primary/secondary containment and maintained at a vacuum. $56,700,000 Case 31. Containment Isolation $7,413 $8,544 $10,361
| |
| : 55. Add redundant and diverse limit switches to each containment isolation valve. $692,000 Case 32. Reduce Frequency of Steam Generator Tube Ruptures $348,963 $404,313 $486,439
| |
| : 56. Institute a maintenance practice to perform a 100% inspection of steam generator tubes during each refueling outage. $3,000,000
| |
| : 57. Increase the pressure capacity ofthe secondary side so that a steam generator tube rupture would not cause the relief valves to lift. $10,000,000 F . 'J-132
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate($)
| |
| '.
| |
| : 58. Install a redundant spray system to depressurize the primary system during a steam generator tube rupture $10,000,000
| |
| : 59. Route the discharge from the main steam safety valves through a structure where a water spray would condense the steam and remove most of the fission products. $10,000,000
| |
| : 60. Install a highly reliable (closed loop) steam generator shell-side heat removal system that relies on natural circulation and stored water sources $10,000,000 Case 33. Reduce Consequences of Steam Generator Tube Ruptures $50,657 $58,655 $70,635
| |
| : 61. Direct steam generator flooding after a steam generator tube rupture, prior to core damage. $200,000 Case 34. Reduce ATWS Frequency $19,888 $25,698 $26,117 Page D-133
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 63. Add an independent boron injection system. $500,000
| |
| : 64. Add a system of relief valves to prevent equipment damage from pressure spikes during anATWS. $500,000
| |
| : 65. Install motor generator set trip breakers in control room. $100,000
| |
| : 66. Provide capability to remove power from the bus powering the control rods. $100,000 Case 37. Reduce Probability of a LOCA $14,397 $17,406 $19,630
| |
| : 69. Install digital large break LOCA protection system. $500,000 F *)-134
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| | |
| Waterford Steam Electric Stauon Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| Case 38. Prevent Secondary Side Depressurization $5,235 $6,722 $6,900
| |
| : 70. Install secondary side guard pipes up to the main steam isolation valves. $500,000 Case 39. Eliminate Thermally Induced Tube Ruptures Following Core Damage $14,870 $17,141 $20,780
| |
| : 54. Modify procedures such that the water loop seals in the reactor cooling system (RCS) cold legs are not cleared following core damage. $100,000 Case 40. Replace CARMVAAA201-B with a fail closed AOV $0 $0 $0
| |
| : 62. Hardware change to eliminate MOV CS-V-17 AC power dependency. $300,000 Case 41. Improve Internal Flooding Response Procedures and Training 1 N/A N/A N/A Page D-135
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| | |
| Waterford Steam Electric Station Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 67. Improve internal flooding response procedures and training to improve the response to internal flooding events. $400,000 Case 42. Water tight doors for the largest contributor to internal flooding 1 NIA N/A N/A
| |
| : 68. Install flood doors to prevent water propagation in the electric board room. $4,695,000 Case 43. Gagging device to close a stuck open safety valve $38 $44 $53
| |
| : 71. Manufacture a gagging device for a steam generator safety valve and developing a procedure or work order for closing a stuck-open valve. $30,000 These SAMA candidates were retained without evaluation as they are already commitments in the NFPA 805 LAR [D.2-13] N/A N/A N/A N/A
| |
| : 74. In Fire Area RAB 2 construct a radiant heat barrier to further separate the A and B trains of chilled water pumps. N/A N/A N/A N/A
| |
| : 75. In Fire Area RAB BC construct a radiant heat shield in Switchgear Room A/B. N/A N/A N/A N/A P, :)-136
| |
| | |
| Waterford Steam Electric Stafl6n Unit 3 Applicant's Environmental Report Operating License Renewal Stage Table D.2-3 Sensitivity Analysis Results Sensitivity Case Sensitivity Case Internal and 1, Internal and 2, Internal and External External Benefit, External Benefit, Benefit, 20 yrs. 29 yrs. 20 years Analysis Case (bold) Remaining, 7% Remaining, 7% Remaining, 3% WF3 Cost SAMA Number and Title Discount Rate Discount Rate Discount Rate Estimate ($)
| |
| : 76. In Fire Area RAB 6 install a 1-hour fire resistance rating ERFBS fire wrap barrier from fire damage. N/A N/A N/A N/A 111 These analysis cases only impact internal flooding and have been evaluated as shown in Section D.2.3.
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| Page D-137
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| Waterford Steam Electric Station, Unit 3 Applicant's Environmental Report Operating License Renewal Stage Attachment E Coastal Zone Consistency Determination
| |
| | |
| Attachment E Coastal Zone Consistency Determination
| |
| * Rick Buckley, Entergy Services, Inc. to Jeff Harris, Louisiana Department of Natural Resources, Office of Coastal Management. April 9, 2015.
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| * Don Haydel, Louisiana Department of Natural Resources, Office of Coastal Management, to Rick Buckley, Entergy Services, Inc. April 14, 2015.
| |
| E-1
| |
| | |
| Entergy Services, Inc 1340 Echelon Parkway Jackson, Mississippi 39213 Date: April 9, 2015 Mr. Jeff Harris Louisiana Department of Natural Resources Office of Coastal Management Post Office Box 94396 Baton Rouge, LA 70804-9396
| |
| | |
| ==Subject:==
| |
| Waterford Steam Electric Station, Unit 3 Coastal Zone Consistency Determination CEO 2015-00033
| |
| | |
| ==Dear Mr. Harris,==
| |
| | |
| Entergy Louisiana, LLC and Entergy Operations, Inc. (collectively referred to as "Entergy") are applying to the Nuclear Regulatory Commission (NRC) for renewal of the Waterford Steam Electric Station Unit 3 (WF3) operating license (OL) for an additional 20 years to preserve the option for Entergy to continue to operate WF3 to provide reliable base-load power throughout the extended license renewal period. For WF3 (Facility OL NPF-38), the requested renewal would extend the license expiration date from December 18, 2024, to December 18, 2044.
| |
| On June 4, 2014, Entergy submitted a Coastal Use Permit application (Attachment 1) to your agency regarding a Request for Determination that the renewal of the WF3 OLdid not require a Coastal Use Permit. In your response letter dated June 18, 2014 (Attachment 2), it was determined that "the proposed activity is exempt and a Coastal Use Permit is not required".
| |
| As previously stated above, license renewal only preserves the option for Entergy to continue to operate WF3 to provide reliable base-load power throughout the extended license renewal period. It does not authorize changes to the WF3 facility or operations.
| |
| E-2
| |
| | |
| As stated in the Coastal Use Permit application submitted by Entergy and the response letter from your agency, no plant refurbishment or other license-renewal-related construction activities have been identified as necessary to support the continued operation of WF3 beyond the end of the existing operating license term.
| |
| Therefore, Entergy is requesting a determination from your agency that the proposed activity, renewal of the WF3 OL, will be consistent with Louisiana's Coastal Resources Program.
| |
| If you have any questions or need additional information, please contact me at 601-368-5823 or by email at rbuckle@entergy.com.
| |
| I certify to the best of my knowledge that the proposed activity complies with, and will be conducted in a manner that is consistent with the Louisiana Coastal Resources Program.
| |
| Rick Buckley, CHMM, REM Sr. Project Manager, Environmental E-3
| |
| | |
| Attachment 1 Entergy's Request for Determination E-4
| |
| | |
| Joint Permit Application Louisiana Department of Natural For Work Within the Louisiana U.S. Army Corps Of Engineers Resources Coastal Zone (COE)
| |
| Office of Coastal Management New Orleans District (OCM)
| |
| Print Application Permit Number: P20140826 Date Received: 06/04/2014 Step 1 of 15 - Applicant Information Applicant/Company WATERFORD 3 STEAM ELECTRIC Applicant Type: INDUSTRY/OTHER Name: STATION Mailing Address: 17265 RIVER ROAD KILLONA, LA 70057 Contact Information: Rick Buckley Daytime: 6013685823 Fax: 6013685812 Contact Email: rbuckle@entergy.com Step 2 of 15 - Agent Information Company Name:
| |
| Mailing Address:
| |
| Contact Information:
| |
| Daytime: Fax: Contact Email:
| |
| Step 3 of 15 - Permit Type
| |
| ~ Request for Determination D Coastal Use Permit (CUP) D Solicitation of Views (SOV)
| |
| (RFD)
| |
| Step 4 of 15 - Pre-Application Activity
| |
| : a. Have you participated in a Pre-Application or Geological Review Meeting for the proposed project?
| |
| D No ~Yes Date meeting was held:
| |
| E-5
| |
| | |
| Attendees:
| |
| (Individual or Company Rep) (OCM Representative) (COE Representative)
| |
| : b. Have you obtained an official wetland determination from the COE for the project site? .
| |
| 181 No D Yes JD Number:
| |
| : c. Is this application a mitigation plan for another CUP?
| |
| 181 No D Yes OCM Permit Number:
| |
| Step 5 of 15 - Project Information
| |
| : a. Describe the project:
| |
| Entergy Louisiana, LLC will be submitting an application to the Nuclear Regulatory Commission during the first quarter of 2016 for renewal of the Waterford 3 Steam Electric Station (WF3) license which will preserve the option to continue to operate WF3 to provide reliable base-load power for an additional 20 years beyond its existing 40 year license to meet Entergy's system generating needs. For WF3, the requested renewal would extend the license expiration date from midnight December 18, 2024, to midnight December 18, 2044.
| |
| In summary, there will be no changes related to this project with respect to operation of WF3 that wou'ld significantly change the plant's effects on the environment during the period of extended operation. In addition, no plant refurbishment or other license-renewal-related construction activities have been identified as ne.cessary to support the continued operation of WF3 beyond the end of the existing operating license term.
| |
| : b. Is this application a change to an existing permit?
| |
| 181 No D Yes OCM Permit Number:
| |
| Have you previously app/if#d for a permit or emergency authorization for all or any part of the
| |
| : c. proposed project? **
| |
| 181 No D Yes Agency Name Permit Number Decision Status Decision Date OCM COE Other Step 6 of 15 - Project Location
| |
| : a. Physical Location E-6
| |
| | |
| Street: 17265 RIVER .ROAD City: KILLONA Parish: SAINT CHARLES Zip: 70057 Water Body: MISSISSIPPI RIVER
| |
| : b. Latitude and Longitude Latitude: 29 59 42 Longitude: -90 28 16
| |
| : c. Section, Township, and Range Section#: 26 Township#: 12S Range#: 20E Section#: Township#: Range#:
| |
| : d. Lot, Tract, Parcel, or Subdivision Name Lot#: Parcel#:
| |
| Tract#: Subdivision Name:
| |
| : e. Site Direc,tion:
| |
| 1-10 East toward New Orleans. Exit 220 to 1-310 South toward Boutee/Houma. Exit #10 onto LA-3127 North toward Donaldsonville. Turn right on LA-3142 North. Turn left onto River Road. Turn left at the Entergy Waterford 3 SES Sign. Turn right, turn left and turn right into the Generation Support Building parking lot. -
| |
| END. .
| |
| Step 7 of 15 - Adjacent Landowners Step 8 of 15 - Project Specifics WATERFORD 3 STEAM ELECTRIC STATlON LICENSE RENEWAL
| |
| : a. Project Name and/or Title: PROJECT
| |
| : b. Project Type: Non-Residential
| |
| : c. Source of Funding: Private
| |
| : d. What will be done for the proposed project?
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| Home D Bridge/Road 0 Site/Driveway D Pipeline/Flow Line D Rip Rap/Erosion Control D Bulkhead/Backfill D Levee ConstructionD Plug/Abandon D Site Clearance Drainage Production 0 D Dredging D Barge/Structure D Subdivision Improvements D Drill Barge/Structure D Prop Washing D Vegetative Plantings D Wharf/Pier/Boathouse E-7
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| D Drill Site D Pilings D Remove Structures Major D Fill D Marina 0 Industrial/Commercial
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| !!;a Other: RENEWAL OF AN EXISTING OPERATING LICENSE FOR AN ADDITIONAL 20 YEARS.
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| : e. Why is the proposed project needed?
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| The proposed project would renew the operating license for WF3 which would preserve the option for Entergy Louisiana, LLC to continue to operate WF3 to provide reliable base-load power for an additional 20 years beyond its existing 40 year license to meet Entergy's system generating needs. ForWF3, the requested renewal would extend the license expiration date from midnight December 18, 2024, to midnight December 18, 2044.
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| Step 9 of 15 - Project Status
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| : a. Proposed project start date: Proposed project completion date:
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| : b. Is any of the project work in progress?
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| !!;a No D Yes
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| : c. Is any of the project work complete?
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| !!;a No D Yes Step 10of15 - Structures, Materials, and Methods for the Proposed Project
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| : a. Excavations 0 yd 3 O Acres
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| : b. Fill Areas O Acres
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| : c. Fill Materials D Concrete: D Rock: yd3 Crushed Stone or 0 Gravel: D Sand: yd3 Excavated and placed Hauled in 0 onsite: 0 topsoil/Dirt:
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| yd3 Excavated and hauled 0 offsite:
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| Other: NO FILL
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| !!;a MATERIALS ARE 0 yd 3 INVOLVED.
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| E-8
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| : d. What equipment will be used for the proposed project?
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| D Airboat D Bulldozer/Grader D Marsh Buggy Other Tracked or Wheeled D Backhoe D Dragline/Excavator 0 Vehicles Barge Mounted Bucket Self Propelled Pipe Laying 0 D Handjet 0 Dredge Barge
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| . D Barge Mounted Drilling Rig D Land Based Drilling Rig D Tugboat a Other: None. There is no construction activities associated with this project.
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| Step 11 of 15 - Project Alternatives
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| '.
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| : a. Total acres of wetlands and/or waterbottoms filled and/or excavated.
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| acres What alternative locations, methods, *and access routes were considered to avoid impact to wetlands
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| : b. and/or waterbottoms?
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| : c. What efforts were made to minimize impact to wetlands and/or waterbottoms?
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| : d. How are unavoidable impacts to v~getated wetlands to be mitigated?
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| Step 12 of 15 - Permit Type and Owners
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| : a. Are you applying for a C9astal Use Permit?
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| la!No D Yes
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| : b. Are you the sole landowner/oyster lease holder?
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| DNo la! Yes D The applicant is an owner of the property on which the proposed described activity is to occur.
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| D The applicant has made reasonable effort to determine the identity and current address of the owner(s) of the land on which the proposed described activity is to occur, which includeq, a search of the public records of the parish in which the proposed activity is to occur.
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| The applicant hereby attests that a copy of the application has been distributed to the following 0
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| landowners/oyster lease holders: .
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| : c. Does the project involve drilling, production, and/or storage of oil and gas?
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| E-9
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| ~ No D Yes Step 13 of 15 - Maps and Drawing Instructions CoastalZoneVicinitvMap.jpg 06/04/2014 02:18:06 PM Step 14 of 15 - Payment The fee for this permit is: $100.00 Step 15 of 15 - Payment Processed Applicant Information Applicant Name: WATERFORD 3 STEAM ELECTRIC STATION Address: 17265 RIVER ROAD City/State/Zip : KILLONA, LA 70057 Application Information Permit Type: RFD To the best of my knowledge the proposed activity described in this permit application complies with, and will be conducted in a manner that is consistent with the Louisiana Coastal Resources Program. If applicable, I also certify that the declarations in Step 12c, oil spill response, are complete and accurate.
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| View Comments related to this project E-10
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| PROJECT SITE:
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| Sect 26 T12S - R2 0E Lat: 29 ° 59' 42" Long: 90° 28' 16" X: 743963 Y: 3320744 NAD27 Legend
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| - Property Boundary
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| ----=====::::i Feet 0 2,000 4,000 E-11
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| Attachment 2 Louisiana Department of Natural Resources Determination E-12
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| BOBBY JINDAL STEPHEN CHUSTZ GOVERNOR SECRETARY
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| ~tate of JLoutstana DEPARTMENT OF NATURAL RESOURCES OFFICE OF COASTAL MANAGEMENT 06/18/2014 WATERFORD 3 STEAM ELECTRIC STATION 17265 RIVER ROAD KILLONA, LA 70057 RE: P20140826, Request for Determination WATERFORD 3 STEAM ELECTRIC STATION
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| == Description:==
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| Entergy Louisiana, LLC will be submitting an application to the Nuclear Regulatory Commission during the first quarter of 2016 for renewal of the Waterford 3 Steam Electric Station (WF3) license. There will be no changes related to this project with respect to operation of WF3 that would significantly change the plant's effects on the environment during the period of extended operation. In addition, no plant refurbishment or other license-renewal-related construction activities have been identified as necessary to support the continued operation of WF3 beyond the end of the existing operating license term.
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| Location: Lat. 29° 59' 42" N, Long. -90° 28' 16" W; Section 26 T12S R20E; 17265 River Road, Killona Saint Charles Parish, LA
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| ==Dear Rick Buckley:==
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| | |
| We have received a Request for Determination for the above referenced project, which has been found to be inside the Louisiana Coastal Zone. In accordance with the State and Local Coastal Resources Management Act of 1978, as amended (La. R.S. 49:214.34.a), the proposed activity is exempt and a Coastal Use Permit is not required.
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| This determination is valid for two (2) years from the date of this letter. If the proposed activity is not initiated within this 2-year period, this determination will expire and the applicant will be required to submit a new application. This determination does not eliminate the need to obtain a permit from the United States Army, Corps of Engineers (USA CE) or any other Federal, state, or local approval, that may be required by law.
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| This determination has been made on the basis of information provided by your application. If it is later established that you furnished erroneous data, you may be directed to alter or modify your plans, to remove structures you have installed, and/or to restore the work area to pre-project conditions at your own expense. If it is established that you knowingly furnished erroneous data, you could also be subject to legal action.
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| Post Office Box 44487
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| * Baton Rouge, Louisian a 70804-4487 617 North Third Street
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| * 1Orh Floor
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| * Suite 1078
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| * Bato n Rouge, Louisiana 70802 (225 ) 342-7591
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| * fax (225 ) 342-9439
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| * http://www.dnr.louisiana.gov An Equal Opportunity Employe r E-13
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| P20140826, Request for Determination WATERFORD 3 STEAM ELECTRIC STATION 06118/2014 Page 2 The drawings submitted with your referenced application are attached hereto and made a part of the record. If you have any questions regarding this authorization, please contact our office at (225) 342-7591 or (800) 267-4019.
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| Sincerely,
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| ~~
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| Keith Lovell For Karl L. Morgan, Administrator Keith Lovell/aw Attachments E-14
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| P20140826, Request for Determination WATERFORD 3 STEAM ELECTR IC STA TIO 06/18/2014 Page 3 Final Plats:
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| : 1) P20140826 Final Plats 06/04/2014 cc: Martin Mayer, COE w/plats Dave Butler, LDWF w/plats Jessica Diez, OCM w/plats Lafourche Basin Levee District, LD w/plats Kirk Kilgen, CMD/FI w/plats E-15
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| | |
| PROJECT SITE:
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| Sect 26 T12S - R20E Lat: 29° 59 ' 42" Long : 90° 28' 16" X: 743963 Y: 3320744 NAD27 Legend
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| - Property Boundary E-16
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| ****c::===F 0 2,000 eet 4,000
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| BOBBY Jr DAL TEPHE CHUSTZ GOVERNOR SECRETARY
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| ~t te of JLoui!)i n OF RESOURCE OFFICE OF COASTAL . . . ~"'" ...ciG*EMENT April 14, 2015 Rick Buckley Entergy Services Inc.
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| 1340 Echelon Parkway Jackson, MS 39213 RE: C20150075, Coastal Zone Consistency Entergy Louisiana, LLC and Entergy Operations, Inc.
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| Nuclear Regulatory Commission Federal License or Permit Renewal of the operating license for the Waterford Steam Electric Station Unit 3, throu gh December 18, 2044 St. Charles Parish, Louisiana
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| ==Dear Mr. Buckley:==
| |
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| The above referenced project has been reviewed for consistency with the approved Louisiana Coastal Resource Program (LCRP) as required by Section 307 of the Coastal Zone Management Act of 1972, as amended . The project, as proposed in the application, is consistent with the LCRP. If you have any questions concerning thi s determination, please contact Jeff Harris of the Consistency Section at (225) 342-7949 or 1-800-267-4019.
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| Sincerely yours,
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| /S/ Don Haydel Acting Administrator lnteragency Affairs/Field Services Division DH/SK/jdh cc: Martin Mayer, NOD-COE Dave Butler, LDWF Kirk Kil gen, OCM Fl E-17 PoSt Office Box 44487
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| * Baton Rouge, Louisiana 70804-4487 617 North Third Street
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| * l 0th Floor
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| * Suite l 078
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| * Baton Rouge, Louisiana 70802 (225) 342-7591
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| * Fax (225) 342-9439
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| * http://www.dnrJouisiana.gov An Equal Opportunity Employer
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| * .\i;
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| [)f!P--003}}
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