CP-202100224, (Cpnpp), 2020 Annual Environmental Operating Report (Non-Radiological)

(Cpnpp), 2020 Annual Environmental Operating Report (Non-Radiological)

ML21119A347
Person / Time
Site:	Comanche Peak
Issue date:	04/29/2021
From:	Hicks J Luminant, Vistra Operations Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-202100224, TXX-21078
Download: ML21119A347 (10)

Text

Jack C. Hicks Comanche Peak Manager, Regulatory Affairs Nuclear Power Plant (Vistra Operations Company LLC)

P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254.897.6725 CP-202100224 TXX-21078 April 29, 2021 U. S. Nuclear Regulatory Commission Ref CPNPP EPP ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 2020 Annual Environmental Operating Report (Non-Radiological)

Dear Sir or Madam:

Vistra Operations Company LLC (Vistra OpCo) hereby submits the Comanche Peak Nuclear Power Plant (CPNPP) 2020 Annual Environmental Operating Report (Non-Radiological). The attached report is provided pursuant to Appendix B to the CPNPP Units 1 and 2 Facility Operating License Nos. NPF-87 & NPF-89 (Environmental Protection Plan). The report covers the period from January 1, 2020 to December 31, 2020.

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

Should you have any questions, please contact Jim Barnette at (254) 897-5866 or James.barnette@luminant.com.

Sincerely, Jack ack C. Hicks

Attachment:

CPNPP 2020 Annual Environmental Operating Report (Non-Radiological) (9 pages) c (email) - Scott Morris, Region IV [Scott.Morris@nrc.gov]

Dennis Galvin, NRR [Dennis.Galvin@nrc.gov]

John Ellegood, Senior Resident Inspector, CPNPP [John.Ellegood@nrc.gov]

Neil Day, Resident Inspector, CPNPP [Neil.Day@nrc.gov]

Attachment to TXX-21078 Page 1 of 9 VISTRA OPERATIONS COMPANY, LLC COMANCHE PEAK NUCLEAR POWER PLANT UNITS 1 & 2 2020 ANNUAL ENVIRONMENTAL OPERATING REPORT (NON-RADIOLOGICAL)

FACILITY OPERATING LICENSE NOs. NPF-87 & 89 1

Attachment to TXX-21078 Page 2 of 9 I. INTRODUCTION This report describes implementation of the Environmental Protection Plan (EPP) for the calendar year 2020 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 2020, the CPNPP Non-Radiological Environmental Monitoring Program was effective in implementing and monitoring all CPNPP environmental regulatory commitments. Program effectiveness in 2020 was substantiated by both Environmental Services (ES) - Corporate audits and Texas Commission on Environmental Quality (TCEQ) inspections concerning 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 non-radiological 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 actions are 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 non-compliances 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 non-routine reports submitted in accordance with Subsection 5.4.2 of the EPP.

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.

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Attachment to TXX-21078 Page 3 of 9 III. 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 2020. Based on the results of these activities, there were no observed adverse environmental impacts resulting from plant operation during 2020.

1. Groundwater Pumpage As indicated in Table 2, groundwater pumpage during 2020 averaged 0.068 gals /min. (gpm) or 35,900 total gallons withdrawn for the year. CPNPP continues to be supplied by Somervell County Water District (SCWD) which started in January 2012. Groundwater withdrawal dropped to <1 gpm after Somervell County Water District (SCWD) became our supplier.

Groundwater withdrawn during 2020 was used primarily for potable and sanitary purposes. No groundwater was used to supplement the stations Surface Water Treatment System.

The average annual pumpage rate of 0.068 gpm for 2020 represents <1% of the predicted operational pumpage (127 gpm) identified in Section 3.3 of the Stations Environmental Report - Operational License Stage. This rate also represents approximately 0.1 % of the actual average withdrawal rate (158 gpm) reported in the Stations Final Environmental Statement - Operating License Stage (Section 5.3.1.2) for the period 1975 to May 1979.

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) fluctuated during 2020 from a low level in September of 615.72 ft. Mean Sea Level (MSL) to a high level in April of 621.32 MSL. Overall, the water level in OB-3 during the reporting period (January through December) decreased 3.7 ft. = 1.13 m The 2020 annual average groundwater levels in wells OB-3 and OB-4 were 618.72 ft. MSL and 555.58 ft. MSL respectively.

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Attachment to TXX-21078 Page 4 of 9

3. Surface Water Treatment System Operation The stations Water Treatment System processed 190.0 MGD of surface water during 2020 for plant process use. No outages in 2020 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 MGD Clarified January 17.01 February 15.67 March 15.53 April 15.10 May 19.60 June 15.00 July 16.80 August 15.10 September 14.32 October 15.09 November 14.38 December 16.44 Total annual production 190.0 B. EPP Noncompliance and Corrective Actions - Subsection 5.4.1(1)

There were no non-compliances 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. Non-routine Reports Submitted in Accordance with Subsection 5.4.2 None 4

Attachment to TXX-21078 Page 5 of 9 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 electronic Discharge Monitoring Reports (netDMRs) for all wastewater outfalls were submitted to the Texas Commission on Environmental Quality (TCEQ) for each month during 2020 via EPAs netDMR tool Central Data Exchange (CDX)

2. Bio-monitoring (e.g. whole effluent toxicity (WET) testing was on a quarterly frequency in 2020 for water flea and annual frequency for fathead minnow. All required test passed satisfactorily.

a. Chronic static renewal survival and reproduction test using water flea (Ceriodaphnia dubia) Method 1002.0.

b. Chronic static renewal 7-day larval survival and growth testing using fathead minnows (Pimephales promelas) Method 1000.0

3. There were no excursions in 2020 with reference to TPDES wastewater discharge permit.

4. There were seven (7) incidental spills in 2020 with none being reportable.

x Petroleum - 2 x Chemical - 3 x Sewage - 2 5

Attachment to TXX-21078 Page 6 of 9 TABLE 1 2020

SUMMARY

OF GROUNDWATER LEVELS IN OBSERVATION WELLS ANNUAL GROUNDWATER LEVEL CHANGE FOR 2020:

Well OB-3: 273.55 ft. - 277.25 ft. = - 3.70 ft. = 1.13 m (decrease)

Well OB-4: 280.21 ft. - 296.53 ft. = -16.32 ft. = 4.97 m (decrease)

NOTES:

(1) Depth to water table (ft.)

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

WELL OB-3 WELL OB-4 MONTH (G-3) (G-4)

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

January 273.55 620.58 280.21 567.67 February 273.55 620.58 288.00 559.88 March 273.41 620.72 288.98 558.90 April 272.81 621.32 286.47 561.41 May 273.50 620.63 286.94 560.94 June 274.33 619.80 289.76 558.12 July 275.36 618.77 293.89 553.99 August 277.13 617.00 297.31 550.57 September 278.41 615.72 301.46 546.42 October 277.85 616.28 299.26 548.62 November 277.75 616.38 298.82 549.06 December 277.25 616.88 296.53 551.35 6

Attachment to TXX-21078 Page 7 of 9 Annual Production Well Report for Recreation/Training System YEAR 2020 Well Reading Monthly Well Last Day of Well Cumulative Gallons Per Yearly Month Total Total Number Day Cumulative Month (gallons) (gallons) (gallons) Days/Month Total Days/Year (average) Monthly GPM GPM December 469100 January 470600 1500 1500 31 31 48.39 0.034 0.0336 7 February 471700 1100 2600 29 60 37.93 0.026 0.0301 March 472500 800 3400 31 91 25.81 0.018 0.0259 TABLE 2 April 473800 1300 4700 30 121 43.33 0.030 0.0270 May 475300 1500 6200 31 152 48.39 0.034 0.0283 June 479000 3700 9900 30 182 123.33 0.086 0.0378 July 481200 2200 12100 31 213 70.97 0.049 0.0394 August 484400 3200 15300 30 243 106.67 0.074 0.0437 September 485500 1100 16400 31 274 35.48 0.025 0.0416 October 493000 7500 23900 31 305 241.94 0.168 0.0544 November 498300 5300 29200 30 335 176.67 0.123 0.0605 December 505000 6700 35900 31 366 216.13 0.150 0.0681 Totals 35900 366 0.0681

Attachment to TXX-21078 Page 8 of 9 8

Gallons per Minute (GPM)

Attachment to TXX-21078 Page 9 of 9 9

Mean Sea Level