ML19263C173

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Application for Amend 35 to License to Eliminate Unnecessary Environ Monitoring Requirements & Change Reporting Requirements Accordingly.W/Proposed Changes to Tech Specs
ML19263C173
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 02/02/1979
From: Short T
OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML19263C170 List:
References
NUDOCS 7902080242
Download: ML19263C173 (17)


Text

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g BEFORE THE U'!ITED STATES IIUCLEAR REGUUsTORY CO:0H03 ION In the Matter of )

OMAHA PUBLIC PO'JER DISTRICT ) Docket :Io. 50-285 (Fort Calhoun Station, )

Unit :Io. 1) )

APPLICATIO:I FOR AE::ID:E:IT OF OPERATI:IC LICE:;SF Pursuant to Section 50 90 of the regulations of the U. 3. :!uelear Regulatory Commission ("the Commissicn"), Omaha Public Power Distric holder of Facility Operating License :!o. DPR-h0, herewith requests that Sections 2., 3. , L. , and 5. of the Technical Specifications set forth in Appendix B to that License be amended to eliminate unnecessary environ-mental mcnitoring requirements and change reporting requirements accord-ingly.

The proposed changes in Technien1 Specifications are set forth in Attachment A to this Application. A discussion, doncnstrating that the proposed changes do not involve significant hazards considerations, is appended in At tachment B. The proposed Amendment is deemed to be a Class IV Amendment, within the meaning of Section 170.22 of the Commission's regulations. Accordingly, a check for the appropriate fee, $12,300, ac-companies this Application. Justification for classificaticn of the Amendment pursuant to 10 CFR 5 17U.22 is included in Attachment ; to this Application. The proposed chanres in specifications would not authorize any chance in the types or any increase in the amounts of ef-fluents or any chance in the authorized power level of the facility.

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'THEREFORE, Applicant respect fully requests that Sections 2. ,

3., L.,

rund 5. of Appendix B to Facility Operating License '!o. DPR h0 be a ended in the form attached hereto as Attachment A.

0 WIA PUBLIC PO'ER DISTRICT

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By v,T. E. Short Assistant General Wmacer Cubscribed Emd sworn to before te

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2. MONITORIIIG PROGRAM 2.1 Monitoring of Discharges Applicability This section applies to monitoring end c. ding temperatures and certain chemical characteristics in discharges to the Missouri River.

Objective To determine the effects of operating the station on the temperature and certain chemical characteristics of the Missouri River. l Specification

1. Upstream river ambient and cooling water intake and discharge temperatures shall be continuously monitored and recorded; and dates and time intervals of recirculating discharge water for ice control at the intake shall also be recorded. Operating Mode Required for Testing: 1, 2 or 3.

In the event the temperature monitoring system becomes inoper-able for more than four (h) hours, alternate equipment shall be used to measure river ambient temperature every two hours until the normal monitoring and recording equipment is returned to service. When river i;ing conditions are present and icing conditions on the river bank preclude a safe means of obtain-ing upstream river temperature, 32 F vill be assumed to be the upstream river te=perature.

2. Discharge from the chemical equalization and decantation hold-ing basin (lagoon) shall oe sampled vcekly and discharge from the circulating water discharge sampled monthly.

When chlorination of the circulating water system is being conducted:

(a) the discharge shall be grab sampled at a time during the chlorina-tion period when the maximum residual chlorine concentration is ex-pected to be present, and (b) chlorine shall be sampled weekly and analyzed with the amperometric filtration techniqua.

The data collected pursuant to Sections 2.1.1 and 2.1.2 of the Tech-nical Specifications shall be correlated to station operating levels and results shall be summarized in the annual report.

Amendment No. IJ , 35 2.1-1 ATTACHIETT A

DELETED Amendment No. 35 2.1-2

9 DELETED 2,2-1

1 DELETED Amendment No. 35 3-1

m DELETED Amendment No. 35 3-2

4. DURATION OF OPERATIIIG LIMITS The operating limits in section 1 shall continue in effect throughout the operating life of the station.

5 REPORTING REQUIREME!ITS Data gathered in section 1 shall be analyzed as collected. Re s u.'.t s o f the analyses and summaries .of significant data shall be submitted to the Directorate of Licensing in the Semi-Annual Environmental Operating Re-port following each annual period terminating on December 31.

Amendment No. 35 h-1

DISCUSSION Technical Specification Section 2.1.2 The Technical Specification to monitor the thermal plume at Omaha Public Power District's h81 electrical gross megawatt Fort Calhoun Station Unit No. 1 is based upon the Mixing Zone Statement which was a part of the Nebraska Water Quality Standards adopted by the Hebraska Environmental Control Council on June 19, 1972. The incorporation of the thermal plume monitoring into the Technical Specificaticas was to insure compliance with the State of Nebraska's Water Quality Standards. Temperature monitor-ing would determine the physical dimensions of the thereci plume under fluctuating Missouri River flow and variable operating cor.ditions of the station. Compliance with the Mixing Zone Statement would ue determined by thermal plume monitoring.

The original intent to satisfy the 1972 requirements has become ob-solete due to the promulgation of the revised Water Quality Standards issued effective June 30, 1976, and amended September 26, 1976, and December 27, 1976. This new set of standards exe: pts effluents rrom mix-ing zone requirements as were specified in the 1972 regulations. The change is the Water Quality Standards was based on the i=plementation of regulations by the Environmental Prbtection Agency under the authority of the Federal Water Pollution Control Act. These regulations made ther-mal effluents illegal with the exception of units as specified in the Code of Federal Regulations (h0 CFR Part 423) that are smaller than 500 MW or were in service before January 1,197h. These units did not have a ther-mal effluent limitation. Fort Calhoun's thermal discharge to the LHssouri River operates on National Pollutant Discharge Elimination System Permit No. NE0000hl8 and has as its only temperature requirement a thermal maxi-mum.

In support of the deletion of this Technical Specification is the extent of the data generated, that demonstrates plume configurations under commonly occurring plant operating and river flow conditions.

Thermal plume measurements were taken when flows ranged as lov as 14,000 cfs to as high as 67,000 cfs. Since the Missouri River is characterized by vide variations in river flow, the monthly thermal plume mappings are indicative of these flow patterns. Flows recorded by the U. S. Geological Ptrvey (USGS) at Omaha, Ncoraska during the five-year study period ranged

-ing the vinter months from about 10.,000 cfs to 22,000 cfs. Five ther-mal a lumes were mapped, representing these vinter flow conditions. Data from three of these five plumes was collected by aerial infrared scanning due to the fact that hazardous vinter conditions and heavy ice flow generally inhibited thermal measurements by boat. During the spring and summer months, the USGS recorded river flows ranging from 30,000 to 50,000 cfs. l'ermal plume measurements were taken on 26 occasions which repre-sent this range of conditions. Occasional peaks in flow beyond 60,000 cfs were recorded by the USGS and five thermal plures were taken to re-present these conditions. The thermal plume data collected is typical of bussouri River flows as recorded by the USGS during the five-year study period.

ATTACHMENT B

Although Technical Specification 2.1.2 requires monthly thermal plume surveillance for at least the first two years of plant operation, surveil-lance has continued since 1973, and currently there is five years of data which has been collected by Omaha Public Power District, the rabraska State Department of Environmental Control (DEC), and Texas Instruments, Inc.

Aerial infrared temperature recordings were taken by Texas Instruments.

Gurface and triple depth plume data was collected throughout the five year study. This data indicated that the magnitude of the thermal plume dimensions is dependent primarily upon percent power (total BTU's of heat discharged), Missouri River flow, and circulating water discharge flow.

Under all conditions tested to date, a zone of passage for the movement or drift of fish and aquatic biota has been maintained. This was docu-mented in the District's Five-Year Report which has been submitted to the Commission on July 24, 1978.

Another requirement which was incorporated into Technical Specifi-cation 2.1.2 was the development of a mathematical thermal plume model.

The modeling concept was intended to mathematically predict the dimensions of the thermal plume so that compliance with the Water Quality Standards could be estimated under the varying plant power and river flow conditions.

It is believed by the District that development of theoretical modeling for a predictive estimate of the nature of the thermal plume has lost significance from its once intended purpose. The extensive accumulation of thermal plume data over five years has eliminated the need for model-ing. High, average,. and low river flow plumes have been recorded, such that the nature of the Fort Calhoun Station's thermal plume has been clearly defined. The biological influence of the thermal plume has been monitored throughout the five year study and was reported upon in the Fort Calhoun Station Unit No.1 Five-Year Report previously submitted to the Conmission. The operation of the Fort Calhoun Station has had minimal effects on the availability and composition of phytoplankton, zooplankton, and macroinvertebrates in the drift of the Misscuri River.

The impact of the station on the distribution and abundance of forage fish has been negligible.

Due to the fact that there are no current thermal plume regulations at the Fort Calhoun Station, and because there exists a well documented record of thermal plume, it is the District's belief that thermal plume monitoring should be discontinued. It is also the District's opinion that the purpose of thermal plume modeling has lost significance due to the extensive data base generated.

Technical Specification Section 2.2 It is recommended that Technical Specification 2.2, entitled "Moni;or-ing and Reporting on Loss of Biota by Impingement", be deleted as a re-quirement at the Fort Calhoun Station Unit No. 1. This ongoing surveil-lance study has been continuing since May of 1973 All data from 1973 through 1977 was compiled and reported upon in the station's Five-Year Report which was submitted to the Commission on July 24, 1978.

The deletion of this requirement is based upon the fulfillment of the studies' specific objectives. The number, species , size , quantity ,

and physical condition of fish and other aquatic fauna impinged on the traveling screens were determined and reported. Daily samples were col-lected at noon (+2 hours) and midnight (+2 hours) from May through September, and at noon only (+2 hours) from October through April. A total of 2,3h5 hourly samples was collected during the 56-month study.

In addition, 2h hour impingement studies were conducted on 29 occasions from 197h through 1976 to determine diurnal impingement rates.

Freshwater drum and gizzard shad were the most common species in- '

pinged throughout the study except in 1976 when channel catfish were the second most common fish collected. The size of the impinged fish were generally less than 100 mm in length. Approximately 50% of the fish

- sampled were recorded as dead, although the annual percentage classified as dead ranged from 30 75 in 1976 to 73.4% in 197h. Of the two major species impinged, gizzard shad had the lowest percent of individuals classified as alive (28.3%) followed by freshwater drum (38.2%). The survival rate, classified as alive, for channel catfish was 71.85.

" Variations in the rate of impingement was related to the natural variability in water temperature, spawning and recruitment success, seasonal distribution and abundance of fishes, mad controlled river flows. A comparison of hourly and 2h hour studies indicated that the daily studies provided an accurate estimate of monthly impingement rates (King, 1978)."

By projecting the monthly impingement rates, it was estimated that approximately 500,000 fish were impinged at the "nrt Calhoun Station from May, 1973, through December, 1977. The 'mpact ot the removal of these fish can be put into perspective by anatyzing fish population data col-lected in the vicinity of the station. Studies conducted by NALCO En-vironmental Sciences near the vicinity of the Fort Calheun Station has shown no modification in the fish population's total size, relative species composition, or age-class distribution such as to be attribut-able to impingement losses. Based upon catch rate and the size of fish near the station, changes in the fish community have not been noted.

The numerical catch 3 aried substantially among years, but species rela-tive abundance was similar from 1973 through 1977 The combined average catch per unit effort (CPE) for the five most abundant fish caught by electroshocking was consistently higher at locations on the Iowa shore than at locations on the Nebraska shore. The sections sampled along the Iowa shore included quiet water habitat behind wing dikes, which provides better resting and feeding habitat than the channelized cutting bank habitat along the Nebraska shore. The CPE downstream of the thermal dis-charge on the Nebraska side of the river was higher than the upstream Nebraska side location which indicated that fish generally did not avoid the area of thermal influence. The average size of fish collected through-out the five years was quite uniform indicating fish stocks have not been reduced. Hesse & Wallace (Nebraska Game & Parks Commission,1976) reported that little effect could be attributed to the operation of the station.

.4-As previously stated, the majority of the fish impinged at the Fort Calhoun Station were generally less than 100 mm in length representing the young-of-the-year fish. Under natural conditions, young-of-the-year fish have high mortality rates (>90.0%) (Marcy, B. C. , Jr. ,1974).

Although naturcl mortality coupled with fish losses due to impingement may reduce the juvenile population, the overall effect of impingement at the Fort Calhoun Station appears to be minimal. Few adult fish are impinged and are thus left in the natural environment for breeding pur-poses. Five years of fish population studies indicate no alteration in the abundance and diversity of fish near the station. This is a strong indication that the losses due to impingement have not affected the Missouri River fishery ecosystem.

Another consideration for deletion of this monitoring requirement

- is based upon an evaluation of the impingement data by the Nebraska Department of Environmental Control. After a review of tha Int ake Monitoring Report for the Fort Calhoun Station, produced in compliance with NPDES Permit No. 0000hl8, they concluded that losses due to im-pingement were within an acceptable range and that further monitoring was unnecessary.

As a result of this five-year surveillance program, it was deter-mined that no long-term adverse changes have occurred in the ecosystem as a result of plant operation. The District believes that the in-pingement study is no longer needed and should be deleted as a Tech-nical Specification requirement.

Technical Specification Section 3.1 It is recommended that Technical Specification 3.1, entitled " Peri-phyton, Macroinvertebrate, and Fish", be deleted as a requirement at the Fort Calhoun Station Unit No. 1. This ongoing study consisted of pre-operational investigations (1971-1972) and investigations conducted while the plant has been in operation (197h-1977). All data from these primary, secondary, and tertiary populations were compiled and reported in the station's Five-Year Report, which has been subaitted to the Com-mission on July 24, 1978. The request for deletion of this requirement is based upon the results of the data and the overall fulfillment of the studies' specific objectives.

Periphyton and macroinvertebrate studies were conducted by three separate groups (i.e. , Davironmental Protection Agency (EPA), Region VII, 1971-1972 ; EPA and NALCO Environmental Sciences (NALCO),1974; EPA, NALCO, and Ecology Consultants Incorporated (ECI),1975; and ECI, 1976-1977). All biological collections were conducted by Omaha Public Power District (OPPD) with the exception of the EPA which collected its own samples.

-5 Results of all periphyton and macroinvertebrate monitoring studies at the Fort Calhoun Station indicate that the station's thermal discharge influenced the assemblages of these organisms in the immediate vicinity of the station,100 feet downstream from the thermal discharge. These effects were localized and rarely statistically significant. After re-viewing studies condacted by the 'lebraska State Department of Environ-mental Control on the Missouri River, the District believes that the natural variations within these parameters in the Missouri River are greater than the localized variations attributable to the thermal dis-charge. Biochemical reaction rates are normally accelerated by in-creases in temperature. This was verified by higher productivity (based upon chlorophyll a values 7f periphyton and biomass of macroinvertebrates) in the immediate ares of the thermal discharge. Comparisons of pro-ductivity levels f a cher downstream of the thermal discharge were com-parable to upstream or unaffected river conditions indicating that the increased productivity was very localized in the immediate discharge area.

Biomass analysis from macroinvertebrates samples was normally greater at the most thermally effected zone except on certain occasions which normally occurred during the hot summer months when temperatures were greater than 300C. During these periods, the locations upstream from the thermal discharge and 2,000 feet downstream of the discharge generally exhibited higher biomass than the location nearest to the immediate dis-charge 100 feet downstream.

Analysis of the periphyton community studied throughout the five year program indicate an increase in chlorophyll a and total pigment values of samples located 100 feet downstream of the discharge. These increases favored the production of certain bluegreen algae, but no significant effect was detected on the structure of the periphyton com-munity at this location when temperatures were greater thr.n 300C. Further downstream from the immediate thermal discharge (2,000 feet downstream),

the periphyton community was similar to the uneffected location upstream from the discharge. The results obtained indicate that the thermal ef-feet was localized in the area of the immediate discharge.

NALCO conducted fish population studies near the Fort Calhoun Station and noted that no changes had occurred in the fish community structure near the station. This conclusion was based upon catch rate and the size of fish throughout the five year study. Ve'. Femno L "111 ace (Nebraska Game & Parks Cn==4 cci:n,1;TC) reportea tnat little effect could be at-tributed to the operaticn of the station.

In conclusion, the District believes that preoperational and post-operational data provide sufficient evidence to show that the only ef-feet the operation of the Fort Calhoun Station has caused upon the pri-mary and secondary populations is localized in a small area at the im-mediate thermal discharge from the plant. Also, the tertiary consumers

.have not been influenced by station operation as evidenced by five years of fish population studies. The extensive data already generated indi-cate no further need to continue =onitoring as specified in Technical Specification 3.1. It is therefore recommended that this specification be deleted from Appendix B to Operating License DPR 40.

Technical Specification Section 3.2 The ichthyoplankton ertrainment study in the Missouri River near the Fort Calhoun Station was initiated in April,197h. The goal of the study was to evaluate the impact of station operation on drifting lar-val fish that were subjected to condenser and plune entrainment. The study was desicaed to fulfill monitoring requirements as specified in Technical Specification 3.2 of Appendix B to Operating License DPR 40 for the Fort Calhoun Station Unit No. 1 and to provide information to meet the station's UPDE3 permit. Accumulative results were presented in the station's Five-Year Report, which van submitted to the Nuclear Regulatory Commission as scheduled in July,1978. Data on species com-position and abundance, horizontal and vertical distribution, and viabi-lity of larvae collected from the intake, discharge, and plume loca-tions were used to determine the impact of station operation on the lar-val fish community. The following discussion is an excerpt from studies presented in the Fort Calhoun Station's Five-Year Report (King, 1978).

The larval fish assembla a in the Missouri River was dominated by freshwater drum, catot*s mids, carp, and Stizostedion sp.

Freshwater drum were the most abundaat larvae collected, ccm-prising from h3.7 (197h) to 88,a,5 (1977) of the total yearly larval catch. Catostomids, includiic carpsucker (Carniodes sp.),

white sucker, buffalo (Ictiobus sp.), and redhorse (Moxosto'ma sp. ) were the second most common larvae encountared. Combined, freshwater drum and catostomids accounted for 95.4% of the lar-vae collected during the study.

The occurrence of larval fish in the drift followed similar pat-terns throughout the 5 year study. The sauger-valleye group (Stizostedian sp. ) and Catostomidae, primarily Ictiobus sp. ,

were the dominant taxa in May and freshwater drum and catostomids, primarily Carniodes sp. , were dominant from June through July.

The relative abundance of larvae did not necessarily correspond to the relative abundance of adult fish present in the vicinity of the station. Game fish, including white bass, Lecomis sp. ,

yellow perch, Pomoxis sp. and sauger-valleye comprised less than 1% of the larvae collected. These fishes are either nest builders or random spawners which lay adhesive or demersal eggs. Spawn-ing characteristics combined with low relative abundance of adults near the station probably account' for the lov occurrence of game fish larvae in the drift. In contrast, freshwater drum com-prised .9% of the adult fish in the vicinity of the station in 1977; hcuever, 90% of the larvae in the drift were drum. Fresh-water drum are pelagic spawners (Davis 1959; Helson et al.1967 )

which probably accounts for the high relative abundance of drum larvae in the drift. Other fishes that are either random or pelagic spawners whose larvae commonly occurred in the drift in-cluded carp, catostomids, gizzard shad, and goldeye which are common species in the vicinity of the station.

The horizontal distribution of larval fish was determined on each sampling date to estimate the percentage of larvae that were exposed to entrainment. Results of the transect studies

_7-indicated sicaificantly (p 10.05) higher densities along the cutting bank of the river, adjacent to the station's intake structure. Densities generally were lovest at the mid-channel location. Larval densities near the filling bank varied but were generally similar to those at the mid-channel location.

Species composition was similar along the transect.

The vertical distribution of larval fish in the Missouri River has not been as extensively studied as horizontal dis-tribution because of high river velocity and the difficulty in obtaining mid-depth and bottom samples. Data collected from the intake and discharge locations suggest that larvae also exhibit a heterogeneous vertical distribution. Intake densities averaged approximately 555 higher than discharge densities over the 5 year study. Differences between loca-tionc generally were most pronounced during peak periods of larval abundance, which corresponded to high relative abund-ance of freshwater drum.

In 1977, the vertical distribution of larvae was determined near the intake structure by Omaha Public Power District per-sonnel. The results of this study documented a significant (p 10.05) decrease from surface *to bottom in vertical dis-tribution (Omaha Public Power District, unpublished data).

Mecn surface and bottom densities differed by a factor greater than three.

Entrainment effects were determined only during periods of heat transfer, which prevent 2d the separation of mechanical and thermal effects. The estimated entrainment losses ranged from 2.6 to 5 3% of the total larval assemblage.

The deletion of Technical Specification 3.2 from the operating license at the Fort Calhoun Station is recommended by the District. Support for the deletion of this requirement was provided by the Nebraska Department of Environmental Control (DEC). After a review of the Intake Monitoring Report for the Fort Calhoun Station, produced in compliance with NPDES Permit No. 0000h18, it was concluded that larval fish losses due to entrainment were within an acceptable range and that no further monitor-ing would be required by the DEC.

Based upon the conclrsion as presented in the Fo"t Calhoun Station's Five-Year Report, submitted to the Commission on July J4,1978, it can be seen that all objectives of the study as defined in Technical Speci-fication 3.2 have been clearly met. It is the District's belief, which is also supported by the Department of Environmental Control, that the level of larval fish entrainment is within an acceptable range and that further monitoring is unnecessary. It is therefore recommended that Technical Specification 3.2 be deleted as a requirement of the Fort Cal-houn Station Unit No. 1.

Technical Specification Sections h. and 5 All programs as defined in Technical Specifications 2. and 3. have been studied for five years beyond the initial startup of the Fort Cal-houn Station Unic No. 1. An evaluation of these study programs was sub-mitted to the Commission as scheduled in July of 1978. The report was entitled " Fort Calhoun Station Unit No.1 Five-Year Report", a su . mary of environmental study programs conducted in compliance with Appendix B to Opere. ting License DPR- LO. The revision of Sections 2. and 3. is requested due to the fulfillment of all specific objectives of these studies and the ultimate conclusion that further c:onitoring is unnecessary.

The change vill delete references to Sections 2. and 3. and require an-nual reporting for Section 1.

e

JUSTIFICATION FOR FEE CLASSIFICATION This Application is deemed to be a Class IV Amendment, within the meening of Section 170.22 of the regulations of the U. S. Nuclear Regula-tory Commission, because it involves more than one environmental issue.

It seeks the removal of various environmental monitorin6 programs from the Fort Calhoun Station Technical Specifications.

ATTACHMENT C