ML20092C797

Application for Amend to License NPF-29,for Termination of Cooling Tower Drift Program,Environmental Protection Plan. Rate of Salt Deposition from Cooling Tower Minerals Without Statistical Importance

ML20092C797
Person / Time
Site:	Grand Gulf
Issue date:	02/07/1992
From:	Cottle W ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20092C800	List: ML20092C797 ML20092E149
References
GNRO-92-00017, GNRO-92-17, PCOL-92-01, PCOL-92-1, NUDOCS 9202120099
Download: ML20092C797 (8)

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W. T. C ot tle

e4 February 7, 1992 *

.e U.S. Nuclear Regulatory Commission Hall Station PI-l'17 Washington, D.C. 20555 Att en t ion : Document Control Desk

Subject:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 LJecnso No. NPF-29 Termination of the Cooling Tower Drift Program Proposed Amendment to tho Operating Licensn (PC0h-92/01)

GNRO-92/00017 Gent 1 omen:

Entert;y Opera t. ions , Inc. is submitting by this intter a propor,ed amendment to t.ho Grand Gulf Nuclear Station (GGNS) Operating License. The proposed amendment requests terminatit.n of the Cooling Tower Drift Program of the t Environmental Prot.ection Plan and changes references to thn program to I reflect the terminat.ien. The program was required to continue for three years of operation to determino the deposit. ion of drif t containing dissolvnd minerals on the landscape caused by t.no operation of the evaporative cooling t ower. No statistically significant ofrect upon the salt deposition rato for thot.n chemical specien ovaluated con be attributed to operat inn of t he GGNS cooling tower. Entergy Operations , Inc. t.hc rn fci e believna that the intent of the Cooling Tower Drift Program has been ant.

In accordance with the provisions of 10CFi30.4, the sigund original of the requested amendment is enclosed. At.tachment 2 provides t he dine.ussion and jus t ificat.Jon to support the requested amendment . This anondment has been revjewed and acenpted by the Plant Saf et.y Review Commit t.nn and the Sa fet y Review Committee.

to Based on t.he guidelinos prescut.ed in 10CFK50.92, Entergy Operations'has concluded that this proposed amendment involves no significant hazards "O

f considerations. l n

.o Yours truly,

, :s: c49 F Cr-s

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a WTC/Willl/mte

[ attachments: 1.

2.

Affirmation per 10CFF50.30 g GGNU PCOL 92/01 )

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09202031/SNLICFLR - 1 100104

h: February 7. 1992 GNRO-92/00017 Page 2 of 3 cc: Mr. D. C. Ilintz (w/a) .

Mr. J. _ L. Mathis (w/a)

Mr. R. B. McGehoe (w/a)

Mr. N. S. Reynolds (w/a)

Mr.11. L. Thomas (w/o)

Mr. Stewart D. Ebneter (w/a)

Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. P. W.-O'Connor, Project Manager (w/2)

Office of-. Nuclear' Reactor Regulation-U.S.-Nuclear Regulatory Commissio's Mail Stop 13113 Washington, D.C. 20555 Dr. Alton B. Cobb (w/a)

State lloalth Officer State Board of Ilealth P.O. Box 1700 Jackson, Mississippi 39205 l

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G9202031/SNLICFLR - 2.

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BEFORE Tile UNITED STATES NUCLEAR REGULATORY COMMIFSION LICENSE NO. NPF-29 DOCKET NO. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC.

and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC.

AFFIRMATION I, W. T. Cottle, being duly sworn, state that I am Vice President, Operations GGNS of Entergy Operations, Inc.; that on behalf of Entorgy Operations, Inc., System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by Entergy Operations, Inc. to sign and file with the Nuclear Regulatory Commission, this applicacion for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Operations GGNS of Entergy Operations, Inc.; and that the statements made and the matters set forth therein are true and correct to the best of my knowledge, information and belief, cN W. T. Cottle STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIBED AND SWORN To before.me, a Notary Publ(c, in and for the County and State above named, this % day of l#shtunau k , 1992.

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AwCo Mton\Ennnn '

Notary >11,c My commiss2on expires:

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Attachment 1 to GNRO-92/00017 A. SUBJECT

1. PCOL 92/01 Terminntion of the Cooling Tower Drift Program

2. Affected requirements:

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a. Section 4.2.2 of the Environmental Protection Plan, Cooling Tower Drift Program, Pages 4-2 and 4-3

b. Section 2.2 of the Environmental Protection Plan, Page 2-1 B. DISCUSSION

1. Entergy Operations, Inc. is requesting revisions to the Environmental Protection Plan (EPP) which will terminate the Cooling Tower Drift Program.

2. Section 4.2.2 of the EPP states: "This program is to be implemented at Icast 3 months prior to the operation of Unit I above 5% power and will be continued for three years of operation. If no statistically significant amounts of the analyzed components are detected during the time period, then a proposal can be made to the NRC to terminate the program."

3. The present program was initiated in 1982. The results of the program were evaluated annually to determine the effect upon the salt deposition rate. This was reported each year to the NRC in the Annual Environmental Operating Report. . Based on the data collected,-Entergy Operations has determined that there was no statistically significant effect on the salt deposition rate.

Therefore, the intent of the Cooling Tower Drift Program has been fulfilled.

4. A request to terminate the program was previously submitted without a change to the EPP in a letter to the NRC (GNRO-91/00029) dated February 19, 1991.

C. JUSTIFICATION Eight sampling-sites were utilized to measure cooling tower drift deposition. Six of the eight sampling sites were located.in areas where maximum salt deposition was predicted. These areas were identified from the Bechtel Salt Deposition Model developed'for the GGNS Final Environmental Report. The romaining two sampling sites were control sites (i.e., located offsite), one of which was added in 1985. Four of the sampling' sites were equipped with replicato sampling devices and two of the replicate sampling sites had

-triplicate sampling devices.

Fallout samples were collected on a quarterly basis and analyzed for ten constituents:

• Calcium . Magnesium

• Sodium

• Iron

• Phosphate

• Nitrate

• Chloride = Fluoride

• Sulfate

• Total dissolved solids G9202031/SNLICFLR - 5 7 W

I Attachment 1 to GNRO-92/00017-Results were reported to the NRC in the Annual Environmental Operating Report.

The critoria for the Cooling Tower Drift Program are contained in Paragraph 4.2.2 of the EPP:

If statistically significant amounts of the analyzed components, at the 95% confidence level as determined by a repeated-measure analysis of variance, are obtained between the preoperational and operational samples, then a supplemental program will be implemented to determine if the increase in drift is of biological significance.

Entergy Operations reviewed the results of the annual evaluation of samples collected between the years 1983 and 1988 to determine if the cooling tower drift had a statistically significant effect upon salt deposition rate.

i An understanding of the chronology of major events which impacted - the -

results of the salt deposition analysis is essential in understanding the analysis. The dates of these events are-listed below:-

August 18, 1982 Achieved Critical Power September 25, 1983 Started Low Power Testing November 8, 1983' Stopped Iow Power Testing April 22, 1984 Resumed Low Power Testing.

August 31, 1984 Received Full Power Operating.

License May 12, 1985 Achieved 100% Power July 1, 1985 Commenced Commercial Operation  ;

January, 1987 Replaced Cooling Tower Media '

The years 1983 and 1984 represent the salt deposition rates'before -

plant commercial operation. The years 1985 and 1986 represent the salt deposition rates with clay block-fill-material in the cooling tower. During the period when clay block fill material was in use,1 GGNS experienced visible drif t carryover deposition onto site parking lots and buildingsEin close proximity to the cooling l tower.

Following the change of fill material visible carryover from the cooling tower was greatly reduced. .The years 1987 and 1988 represent the salt deposition rates with a.new t'astic fill material installed in the cooling tower.

d The analysis performed annually on the data utilized a statistical ~

technique called Analysis of Variance (ANOVA). This technique is a well documented and accepted method for determining statistical significance between various populations forl major potential influence (period and location). Confidence limits were-established at 95% in accordance with the requirements of the EPP.

The ANOVA analysis was applied in two ways on the data:

1. A three-way analysis was performed on sample locations #2 and #5 since these locations were collected in. replicate for interaction between period and location.

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Attachment 1 to GNRO-92/00017

2. A two-way analysis was perfarmed on the remaining locations. The two remote stations were classiffen as control stations and represented background salt deposition rates. Analysis results were reported in our Annual Environmental Operating Report.

An evaluation of the data for influence by period. determined that the deposition rate for most salts varied significantly by quarter.

Analysis for interaction showed that there is' interaction between sample period and location. ' Evaluations performed for influence by location showed that sample location did not have a significant influence on deposition rates for some salts while other salts appear to be significantly influenced by location. These variations made it difficult to directly compare preoperational plant conditions against operational plant conditions. Also, the initial set of conditions for ANOVA analysis did not provide a direct comparison of onsite sample stations against offsite sample stations (control stations).

To alleviate these problems an additional two-way ANOVA analysis was performed on all salts for the years 1987 and 1988. This analysis was performed to determine if there was any statistical difference between the mean of the onsite samples and the mean of the offsite-(control) samples. In evaluating the data for influence between onsite and offsite, it was determined that there was no statistical difference between the mean of the data collected onsite and the mean of the data collected of fsite (control stations).

Based on the above, Entergy Operations - GGNS has concluded that the operation of the GGNS cooling tower does not have a statistically significant effect upon the salt deposition rate for those chemical species evaluated and further believes that the requirements of Section 4.2.2 of the EPp-have been met. This change will produce no significant environmental impact.

D. NO SIGNIFICANT HAZARDS CONSIDERATION

1. Entergy Operations, Inc. is proposing that Section 4.2.2-of the Environmental Protection Plan (EPp) be revised to reflect the termination of the Cooling Tover Drift Program. Based on the

• data collected, Entergy Operations has determined that cooling-tower drift has no statistically significant effect on the salt deposition rate. Therefore, the purpose of the Cooling Tower Drift program has been fulfilled.

2. The Commission has provided standards for determining whether a no significantLhazards consideration exists as stated in-

-10CFR50.92(c). A proposed amendment to an operating license involves no significant hazards if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant' increase-in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a-new or.different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

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Attachment i to'GNRO-92/00017 4

3. Grand Gulf Nuclear Station (GGNS) has evaluated the no significant hazards considerations in its request for a license amendment._ In accordance with 10CFR50.91(a), GGNS is providing the following analysis of Lthe proposed amendmet.t against the three standards in 10CFR50.92.-

a. No significant increase in the probability or consequences of an accident previously evaluated lresults from this_ change.-

The intent of the Cooling Tower Drift Program is to measure the deposition of drift containing dissolved minerals from-the cooling tower to determine the effect on the ecosystem.

The deposition was measured prior to plant startup and i monitored during at least three years of operation in accordance with the requirements of the EPP. Operational monitoring observations and prestartup reference monitoring--

observations were compared. No statistically significant.

difference in the amounts of the analyzed components were-detected. Additionally. - the program does not affect the performance, integrity. or reliability of;any system-in any way that could lead to an accident.

Thus, the probability or consequences of previously analyzed accidents are not increased.

b. The change would not create the possibility lofTa new or different kind of accident from any previously analyzed.

The termination of=the Cooling. Tower Drift Program has been-anticipated. The EPP states that the program "will be continued for three years of operation" and "ifino-statistically significant amounts of the analyzed components are detected during this time period, then a proposal can-be -

made to NRC-to terminate the program." -The scope of the--

change is limited =to termination of the program as described in the EPP. There are no new or different surveillance tests or actions implemented by the revision. There is no addition, deletion, or modification to any system or component.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from thoso

-previously analyzed.-

c. The change would not involve a significant reduction in the margin of safety.

Ti.e termination of the Cooling Tower Drift Program has previously been anticipated in the EPP. _The-required three-

-years-of operation with the program in place has been exceeded. ; No assumption, methods, or results' of applicable safety analyses are changed.

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Attachment _1 to GNRO-92/00017 .!

The additional deposition of minerals into the ecosystem has boon shown to be statistically insignificant when compared to preexisting levels.

These changns thus do not involve a significant reduction in  : '

the margin of safety.

4. Based on the above evaluation, Entergy Operations has concluded ,

that operation in accordance with the proposed amendment involves no significant hazards considerations.

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