CP-202300175, Submittal of 2022 Annual Environmental Operating Report (Non-Radiological)

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Submittal of 2022 Annual Environmental Operating Report (Non-Radiological)
ML23110A799
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 04/20/2023
From: Hicks J
Luminant, Vistra Operations Company
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
CP-202300175, TXX-23023
Download: ML23110A799 (1)
v • d • e


Text

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

Luminant P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254 .897.6725 CP-202300175 TXX-23023 April 20, 2023 U.S. Nuclear Regulatory Commission Ref CPNPPEPP ATIN: Document Conh*ol Desk Washington, DC 20555-0001

Subject:

Comanche Peak Nuclear Power Plant Docket Nos. 50-445 and 50-446 2022 Am1Ual Envir01m1ental Operating Report (Non-Radiological)

References:

Dear Sir or Madam:

Vistra Operations Company LLC ("Vish*a OpCo") hereby submits the Comanche Peak Nuclear Power Plant (CPNPP) 2022 Annual Environmental Operating Report (Non-Radiological). The enclosed report is provided pursuant to Appendix B to the CPNPP Units 1 and 2 Facility Operating License Nos. NPF-87 & NPF-89 (Enviromnental Protection Plan). The report covers the period from January 1, 2022, to December 31, 2022.

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@lurninant. com.

Sincerely,

Enclosure:

CPNPP 2022 Ammal Environmental Operating Report (Non-Radiological) c (email) - Robert Lewis, Region IV [Robert.Lewis@mc.gov]

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

John Ellegood, Senior Resident Inspector, CPNPP Uohn.Ellegood@mc.gov]

David Nani, Resident Inspector, CPNPP [David.Nani@mc.gov]

Enclosure with TXX-23023 Page 1 of 8 VISTRA OPERATIONS COMPANY, LLC COMANCHE PEAK NUCLEAR POWER PLANT UNITS 1 & 2 2022 ANNUAL ENVIRONMENTAL OPERATING REPORT (NON-RADIOLOGICAL)

FACILITY OPERATING LICENSE NOs. NPF-87 & 89 1

Enclosure with TXX-23023 Page 2 of 8 I. INTRODUCTION This report describes implementation of the Environmental Protection Plan (EPP) for the calendar year 2022 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 2022, the CPNPP Non-Radiological Environmental Monitoring Program was effective in implementing and monitoring all CPNPP environmental regulatory commitments. Program effectiveness in 2022 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.

2

Enclosure with TXX-23023 Page 3 of 8 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 2022. Based on the results of these activities, there were no observed adverse environmental impacts resulting from plant operation during 2022.

1. Groundwater Pumpage As indicated in Table 2, groundwater pumpage during 2022 averaged 0.1 gals

/min. (gpm) or 52700 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 2022 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 0.1 gpm for 2022 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 2022 from a low level in August of 613.23 ft. Mean Sea Level (MSL) to a high level in March of 619.41 MSL. Overall, the water level in OB-3 during the reporting period (January through December) decreased 2.95 ft = - 0.90 m. 2022 annual average groundwater levels in wells OB-3 and OB-4 were 616.52 ft. MSL and 547.89 ft.

MSL respectively.

3

Enclosure with TXX-23023 Page 4 of 8

3. Surface Water Treatment System Operation The stations Water Treatment System processed 181.2 MGD of surface water during 2022 for plant process use. No outages in 2022 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 13.99 February 12.69 March 14.20 April 17.50 May 15.71 June 14.36 July 14.31 August 14.21 September 16.53 October 16.10 November 15.57 December 16.05 Total annual production 181.2 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

Enclosure with TXX-23023 Page 5 of 8 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 2022 via EPAs netDMR tool Central Data Exchange (CDX)
2. Bio-monitoring (e.g. whole effluent toxicity (WET) testing was on a semi-annual frequency in 2022 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 two Issue Reports in 2022 with reference to TPDES wastewater discharge permit variances.
a. TR-2022-00139 - Notification by off-site lab of BOD analysis QA/QC failure. Per discussion with Corporate Environmental, samples performed in February entered in State electronic reporting database (CDX) with comments detailing second sample QA/QC failure. Correction for this issue was a termination of off-site lab services and use of other NELAC certified laboratory. No issues with BOD analysis since changing of labs.
b. TR-2022-003871 - Bypass of Outfall 004 due to discharge line isolation due to valve close on loss of power. NOTE: TPDES Permit allows alternate discharge path (i.e. bypass) to waters-of-the-state as long as discharge compliant with permit parameters. All TPDES Permit required analysis performed and within Permit limits. A courtesy notification was made to the TCEQ at time of occurrence.
4. There were twelve (12) incidental spills in 2022 with none being reportable.

x Petroleum - 7 x Chemical - 5 5

Enclosure with TXX-23023 Page 6 of 8 TABLE 1 2022

SUMMARY

OF GROUNDWATER LEVELS IN OBSERVATION WELLS ANNUAL GROUNDWATER LEVEL CHANGE FOR 2022:

Well OB-3: 275.75 ft. - 278.70 ft. = -2.95 ft = - 0.90 m (decrease)

Well OB-4: 294.14 ft. - 301.31 ft. = -7.17 ft. = - 2.19 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)

January I

DEPTH (1) 275.75 MSL (2) 618.38 I DEPTH (1) 294.14 MSL (2) 553.74 I

February 275.20 618.93 291.98 555.90 March 274.72 619.41 291.56 556.32 April 274.90 619.23 291.43 556.45 May 275.05 619.08 292.83 555.05 June 276.21 617.92 295.99 551.89 July 278.69 615.44 303.39 544.49 August 280.90 613.23 310.57 537.31 September 280.48 613.65 310.18 537.70 October 280.52 613.61 309.82 538.06 November 280.22 613.91 306.69 541.19 December 278.70 615.43 301.31 546.57 6

ANNUAL PRODUCTION WELL REPORT RECREATION/TRAINING SYSTEM Annual Production Well Report for Recreation/Training System

+ + +

YEAR 2022 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 TABLE 2 December 539400 January 542700 3300 3300 31 31 106.45 0.074 0.0739 7 February 544400 1700 5000 28 59 60.71 0.042 0.0589 March 545800 1400 6400 31 90 45.16 0.031 0.0494 April 547300 1500 7900 30 120 50.00 0.035 0.0457 May 549700 2400 10300 31 151 77.42 0.054 0.0474 June 553400 3700 14000 30 181 123.33 0.086 0.0537 July 563800 10400 24400 31 212 335.48 0.233 0.0799 August 577000 13200 37600 30 242 440.00 0.306 0.1079 September 579400 2400 40000 31 273 77.42 0.054 0.1018 October 582600 3200 43200 31 304 103.23 0.072 0.0987 Enclosure with TXX-23023 November 585300 2700 45900 30 334 90.00 0.063 0.0954 December 592100 6800 52700 31 365 219.35 0.152 0.1003 Totals 6800 52700 365 0.1003 Page 7 of 8

Enclosure with TXX-23023 Page 8 of 8 FIGURES 1.5 1.25 FIGURE 1 GROUNDWATER PUMPAGE 2012 thru 2022 1

NOTE Gallons per Minute (GPM)

Somvervell County Water District (SCWD) supplied potable water started 2012 0.75 0.5 0.25 0

2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 700 680 660

~ OB-3 FIGURE 2 ANNUAL AVERAGE GROUNDWATER LEVEL 2012 through 2022

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