CP-201100565, Submittal of Annual Non-Radiological Environmental Operating Report for 2010

Submittal of Annual Non-Radiological Environmental Operating Report for 2010

ML11116A095
Person / Time
Site:	Comanche Peak
Issue date:	04/20/2011
From:	Flores R, Madden F Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201100565, TXX11049
Download: ML11116A095 (14)

Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Luminant rafael.flores@luminant.com Glen Rose, TX 76043 T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201100565 Log # TXX11049 April 20, 2011 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445/446 SUBMITTAL OF THE ANNUAL NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FOR 2010

Dear Sir or Madam:

Luminant Generation Company LLC (Luminant Power) hereby submits for Comanche Peak Nuclear Power Plant (CPNPP), the enclosed copy of the Annual Non-Radiological Environmental Operating Report for the CPNPP Radiological Environmental Monitoring Program. This report is submitted pursuant to Appendix B of the CPNPP Unit 1 and 2 Operating License Nos. NPF-87 and NPF-89. The report covers the period from January 1, 2010 through December 31, 2010 and summarizes the results of measurements and analysis of data obtained from samples collected during this interval.

This communication contains no new licensing basis commitments regarding CPNPP Units 1 and 2.

If there are any questions regarding this report, contact Steve Dixon at (254) 897-5482 or Bruce Turner at (254) 897-8901.

Sincerely, Luminant Generation Company LLC Rafael Flores By: ,Z VýMau_

Fred W. Madden Director, Oversight & Regulatory Affairs A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek 77i%9i3

U. S. Nuclear Regulatory Commission TXX- 11049 Page 2 04/20/11 Enclosure - Annual Non-Radiological Environmental Operating Report for 2010 Attachments - Figure 1, "Summary of Groundwater Pumpage 1975 through 2010 (gpm)

Figure 2, "Annual Average Groundwater Level 1980 through 2010 c- E. E. Collins, Region IV B. Singal, NRR Resident Inspectors, Comanche Peak A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway Comanche Peak

• Diablo Canyon - Palo Verde

• San Onofre South Texas Project Wolf Creek

LUMINANT POWER COMANCHE PEAK NUCLEAR POWER PLANT UNITS 1 & 2 2010 ANNUAL ENVIRONMENTAL OPERATING REPORT (NON-RADIOLOGICAL)

FACILITY OPERATING LICENSE NOS. NPF-87 & 89 I

I. INTRODUCTION This report describes implementation of the Environmental Protection Plan (EPP) for the calender year 2010 as required by Appendix B to Facility Operating License Nos. NPF-87 & 89 for Comanche Peak Nuclear Power Plant (CPNPP) for Units 1 & 2.

During 2010, the CPNPP Nonradiological Environmental Monitoring Program was effective in implementing and monitoring all CPNPP environmental regulatory commitments. Program effectiveness in 2010 was substantiated by Luminant Corporate environmental audits and compliance evaluations of the CPNPP environmental program.

II. SCOPE Section 5.4.1 of the EPP requires that CPNPP submit to the NRC an Annual Environmental Operating report that shall address the following environmental protection activities:

A. Summaries and analyses of the results of the environmental protection activities required by Section 4.2 of the EPP, including a comparison with related preoperational studies, operational controls (as appropriate), and previous nonradiological environmental monitoring reports, and an assessment of the observed impacts of plant operation on the environment. If harmful effects or evidence of trends toward irreversible damage to the environment are observed, a detailed analysis of the data and a proposed course of mitigating action is required. Section 4.2 of the EPP pertains to results from:

1. Groundwater levels and station water use monitoring.

2. Water treatment facility outages impact assessment and reporting.

B. The report shall also include:

1. A list of EPP noncompliances and the associated corrective actions.

2. A list of all changes in station design and operation, tests, and experiments made in accordance with Subsection 3.1 of the EPP which involved a potentially significant unreviewed environmental question.

3. A list of nonroutine reports submitted in accordance with Subsection 5.4.2 of the EPP.

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4. A summary list of Texas Pollutant Discharge Elimination System (TPDES) permit related reports relative to matters identified in Subsection 2.1 of the EPP which were submitted to the Texas Commission on Environmental Quality (TCEQ) during the report period. Subsection 2.1 of the EPP pertains to aquatic matters that are addressed by the effluent limitations, and the monitoring requirements contained in the TCEQ TPDES station wastewater discharge permit.

Ill. RESULTS OF ACTIVITIES A. As required by Subsection 4.2 of the EPP, the following are summaries and analyses of the environmental protection activities during 2010.

Based on the results of these activities, there were no observed adverse environmental impacts resulting from plant operation during 2010.

1. Groundwater Pumpage As indicated in Table 2, groundwater pumpage during 2010 averaged 13.2 gals /min. (gpm) or 6,921,200 total gallons withdrawn for the year. This withdrawal rate represents a 7.7%

decrease from the 2009 average rate of 14.3 gpm. Groundwater withdrawal was highest in March at 19.9 gpm and lowest in December with an average monthly withdrawal rate of 8.1 gpm.

Groundwater withdrawn during 2010 was used primarily for potable and sanitary purposes with only a very small amount used as make-up to the plant fire protection system. No groundwater was used to supplement the station's Surface Water Treatment System.

The average annual pumpage rate of 13.2 gpm for 2010 represents 10.4% of the predicted operational pumpage (127 gpm) identified in Section 3.3 of the Station's Environmental Report - Operational License Stage. This rate also represents approximately 8.4 % of the actual average withdrawal rate (158 gpm) reported in the Station's Final Environmental Statement -

Operating License Stage (Section 5.3.1.2) for the period 1975 to May 1979.

The combined annual rate for all recorded pre-operational groundwater pumpage averaged 68.8 gpm, while the average operational pumpage for the period 1990 through 2010 was 23.87 gpm. Therefore, the average operational rates are 65.3% less than the groundwater pumpage during the preoperational period.

Figure 1 illustrates the annual fluctuation of groundwater withdrawal over the entire pre-operational and operational period.

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2. Groundwater Levels As indicated in Table 1, the groundwater level in the on-site observation well OB-3 (intersection of Highway 56 and the Plant Access Road) could not be measured beginning in March, 2010. It appears the pipe well casing may have shifted, preventing well water level measurement. A new well was developed within a few feet of the existing well and readings of this well were initiated in July, 2010. The old OB-3 well was plugged in accordance with Texas Commission on Environmental Quality (TCEQ) regulatory requirements.

The water level reading taken in July, 2010 of the new OB-3 well was approximately twenty (20) ft. lower than the reading taken of the old OB-3 well in February, 2010. It is recommended this level differential is not indicative of a sudden change in aquifer water levels, but a reflection of a failure of the OB-3 well casing and possible infiltration of water from an upper water saturated zone into OB-3 well. As shown in Figure 2, during the period 1980 through 2009, both OB-3 and OB-4 water levels demonstrated gradual declines over the years; however, OB-3 rate of decline was less than OB-4. Although water levels between these two wells can vary to some degree, the rate of decline over 30 years should approximate one another considering the proximity of the two wells. In addition, there were no significant differences in groundwater demands in the immediate vicinity of the two wells.

Regardless, in 1980 the water level elevation difference between the two wells was 48.5 ft., while in 2009 the difference was almost 73 ft. This reflects a change of 24.5 ft. during the period 1980 through 2009, with OB-3 declining 39.8 ft., while OB-4 declined 64.2 ft. during this period. When comparing the new OB-3 well water level to the OB-4 well water level, the difference was 52.2 ft.

in December, 2010, more closely approximating the water level difference between the two wells in 1980.

Although historical water level readings of OB-3 may have been influenced by infiltration, the overall general decline in levels is consistent with the decline in levels associated with OB-4 well. It is recommended this overall aquifer water level decline is associated with the overall groundwater use in the region and not to CPNPP plant specific use. This is further supported by the historical decline in CPNPP groundwater withdrawal rates during the period 1980 through 2010 (11Ogpm to 13.2 gpm). The decline in aquifer level did not appear to be attenuated by the reduction in groundwater withdrawal rate. Consequently, no back fits are necessary relative to impact assessments of previous annual reports, since these reports also reflect a regional impact to groundwater levels as opposed to CPNPP plant specific impact.

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Based on the above information, the 2010 summary of annual average groundwater levels for well OB-3 will only include the data collected for the new well, which covers the period July, 2010 through December, 2010. This data reflects an average groundwater level elevation of 597.8 ft. MSL for OB-3. During this period OB-3 level demonstrated an increase of 4.0 ft. (11.2m).

The annual average water level in well OB-4 was 547.6 ft. MSL and it demonstrated a decrease of 2.6 ft. (0.8m). However, the average annual water level during 2010 was 4.6 ft. (1.4 m) higher than the average annual water level during 2009 (Figure 2).

Due to the limited monitoring data of the new OB-3 well, water level comparisons between OB-3 and OB-4 are not possible.

Monthly ground water levels during 2010 are tabulated in Table 2.

3. Surface Water Treatment System Operation The station's Water Treatment System processed 236,861,100 total gallons (450 gpm) of surface water during 2010 for plant process use. There were no outages during 2010 that required reporting in accordance with Section 4.2.2 of the EPP.

The following is a summary list of monthly surface water usage:

MONTH SURFACE WATER PROCESSED (GALS.)

JANUARY 22,970,400 FEBRUARY 21,720,400 MARCH 25,394,420 APRIL 24,004,580 MAY 22,665,200 JUNE 24,590,400 JULY 25,076,400 AUGUST 20,237,000 SEPTEMBER 12,578,800 OCTOBER 14,382,500 NOVEMBER 11,337,500 DECEMBER 11,903,500 TOTAL 236,861,100 5

B. EPP Noncompliance and Corrective Actions - Subsection 5.4.1(1)

There were no noncompliances with the requirements of the EPP during the reporting period.

C. Changes In Station Design or Operation, Tests, and Experiments Made In Accordance With Subsection 3.1 Which Involved A Potentially Significant Unreviewed Environmental Question.

There were no changes in station design, operation, tests or experiments conducted during the reporting period that are reportable under this subsection.

D. Nonroutine Reports Submitted In Accordance With Subsection 5.4.2 Other than those nonroutine reports identified in section Ill.E, there were no other nonroutine reports submitted under this subsection.

E. Texas Pollutant Discharge Elimination System (TPDES) Permit-Related Reports Relative to Matters Identified In Subsections 2.1 and 5.4.1

1. Routine monthly Discharge Monitoring Reports (DMR) for all wastewater outfalls were submitted to the Texas Commission on Environmental Quality (TCEQ) for each month during 2010.

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

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Month Monitored Log Number/Date January TXE-10030 02/15/2010 February TXE-10047 03/08/2010 March TXE-10056 03/31/2010 April TXE-10075 05/13/2010 May TXE-10087 06/15/2010 TXE-10095 06/28/2010 June TXX- 10096 (Biomonitoring Report for 01/01/2010-06/30/2010)

July TXE-10114 06/16/2010 August TXE-10119 09/13/2010 September TXE-10146 10/13/2010 October TXE-10153 11/15/2010 November TXE-10164 12/06/2010 December TXE-11007 01/12/2011 TXE-1 1008 (Biomonitoring Report for 07/01/2010 -12/31/2010)

2. Current biomonitoring in reduced status in accordance with TPDES Permit. The 1/year 7-day Fathead Minnow (Pimephales promelas) Survival and Growth Test was passed. The chronic testing using an invertebrate species is required 1/6 months. The first 7-day Ceriodaphniadubia Survival and Reproduction Test was invalid due to insufficient neonate production resulting from elevated Total Dissolved Solids (TDS) in the source water, Squaw Creek Reservoir. In accordance with an agreement with TCEQ, a 4-day Daphnia magna Survival and Growth Test was conducted and passed. Due to continued elevated source water TDS in the autumn, the D. magna test was again utilized and passed during the second monitoring period. Acute 24-hour screen tests with appropriate invertebrates and the fathead minnow were also passed during each semi-annual monitoring period. The Company currently has a TPDES Permit Application pending which includes the agreed alternate invertebrate species test, the 4-day D. magna Survival/Growth test for use when the reservoir TDS is elevated.

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3. There was one (1) TPDES wastewater discharge permit limit exceedance in 2010. This exceedance occurred June 14, 2010 and pertained to elevated Total Suspended Solids (TSS) levels in the Wastewater System's Discharge Outfall 004. The elevated TSS resulted from high winds that re-suspended sediment in Basin A. The TSS in the discharge was 103 mg/L with a TPDES permit limit of 100 mg/L. Corrective actions were taken by removing some of the sediment from the basin.

4. There were also no reportable spills during 2010.

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TABLE 1 2010

SUMMARY

OF GROUNDWATER LEVELS IN OBSERVATION WELLS WELL OB-3 WELL OB-4 MONTH (G-3) (G-4)

DEPTH (1) MSL (2) DEPTH (1) MSL (2)

January 276.9 516.93 296.91 550.97 February 277.1 516.73 294.42 553.46 Unable to obtain March reading NA 293.27 554.51 Unable to obtain April reading NA 293.64 554.24 Unable to obtain May reading NA 299.55 548.33 Unable to obtain June reading NA 302.54 545.3 July 297.5 596.63 306.15 541.73 August 298.2 595.93 306.82 541.06 Sep tember 297.2 596.93 305.26 542.62 October 296.4 597.73 304.14 543.74 November 295.1 599.03 301.65 546.23 I

December 293.5 600.63 299.48 548.40 ANNUAL GROUNDWATER LEVEL CHANGE FOR 2010:

Well OB-3: Drilled a new observation well due to blockage of existing well (3)

Well OB-4: 296.91 ft. - 299.48 ft. = -2.57 ft. = -0.78 m (decrease)

NOTES:

(1) Depth to water table (ft.)

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

(3) In March, 2010, the existing OB-3 well experienced blockage and water level readings could not be taken. A new well was drilled and placed in service in July, 2010. Please refer to section III.A.2 for a discussion relative to inability to make direct comparison between the old and new OB-3 wells.

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TABLE 2 2010

SUMMARY

OF GROUNDWATER PUMPAGE I PLANT WELL 1 I] PLANT WELL 2 1 NOSF WELL 1 NOSF WELL 2 11RECrFRAININ[ TOTALS NO.OF DAYS Month Total Avg. Tota Avg. Total Avg. Total Avg. Total Avg. Total Avg. BETWEEN Gallons Gallons/ Gallons Gallons/ Gallons Gallons/ Gallons Gallons/ Gallons Gallons/ Gallons Gallons/ READINGS Minute Minute Minute Minute Minute Minute January 240,200 5.4 0 0.0 226,100 5.1 124,500.0 2.8 1,800 0.0 592,600 13.3 31 February 398,200 9.9 0 0.0 52,200 1.3 68,500 1.7 1,100 0.0 520,000 12.9 28 March 774,700 17.4 15,200 0.3 48,700 1.1 47,100 1.1 2,500 0.1 888,200 19.9 31 April 695,600 16.1 0 0.0 40,200 0.9 33,800 0.8 2,500 0.1 772,100 17.9 30 May 370,500 8.3 0 0.0 54,800 1.2 61,600 1.4 1 800 0.0 488,700 10.9 31 June 348600 8.1 0 0.0 70,600 1.6 73,200 1.7 1 600 0.0 494,0001 11.4 30 July 410,800 9.2 0 0.0 87,500 2.0 41,500 0.9 3,000 0.1 542,800 12.2 31 August 546,100 0 0 0.0 110,000 2.5 122,900 2.8 2,300 0.1 781,300 17.5 31 Septembe 234,400 5.4 0 0.0 155,300 3.6 151,200 3.5 1,700 0.0 542,600 12.6 30 October 211,500 4.7 0 0.0 173,700 3.9 141,400 3.2 1,200 0.0 527,800 11.8 31 November 0 0 0 0.0 234,800 5.4 172,700 4.0 1,700 0.0 409,200 9.5 30 December 0 0.0 0 0.0 145,300 3.3 215,500 4.8 1,100 0.0 361,900 8.1 31

[Total I[ 352,5501 7.011 1,2671 700]1 116,6001 2.7j[ 104,4921 2.41 1,8581 0.0l 6,921,200 13.2 365 10

Attachment to TXX- 11049 FIGURE 1

SUMMARY

OF GROUNDWATER PUMPAGE 1975 THROUGH 2010 (GPM)

Annual Groundwater Pumpage 200 --

180 1 160 - 'A /\

140 Al4 ý 120 100 CL 80 60 40 20 0

oh Oh

,~

Oh O~

~? ~)

Oh 4'

Oh Oh ~

4) A% 4) I\ ~

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

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

Attachment to TXX- 11049 FIGURE 2 ANNUAL AVERAGE GROUNDWATER LEVEL 1980 through 2010 Mean Sea Level (MSL) 665 645 625 *1-605 -.OB-3 585 +

565 545 525 I I I I I I I I I 11111111 I I I I I I I I I I I I e~c e" eeeeee

• New OB-3 Well Refer to Section III.A.2 for basis of level change