ML083110571

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Annual Environmental Operating Report for Period from October 1, 2007 Through September 30, 2008
ML083110571
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 11/06/2008
From: James Smith
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML083110571 (11)
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Text

November 6, 2008 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority (TVA) ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) - ANNUAL ENVIRONMENTAL OPERATING REPORT The enclosure contains the Annual Environmental Operating Report for SQN for the period from October 1, 2007, through September 30, 2008. This report is submitted in accordance with Appendix B of the SQN Operating License, Section 5.4.1.

Please direct questions concerning this issue to me at (423) 843-7170.

Sincerely, Original signed by James D. Smith Manager, Site Licensing and Industry Affairs Enclosures cc: See page 2

U.S. Nuclear Regulatory Commission Page 2 November 6, 2008 JDS:JWP:SKD cc (Enclosure):

Mr. Brendan Moroney, Senior Project Manager U.S. Nuclear Regulatory Commission Mail Stop 08G-9a One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2739

U.S. Nuclear Regulatory Commission Page 2 November 6, 2008 JDS:JWP:SKD cc (Enclosure):

Mr. Brendan Moroney, Senior Project Manager U.S. Nuclear Regulatory Commission Mail Stop 08G-9a One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2739 G. Arent, EQB 1B-WBC W. R. Campbell, LP 3R-C T. P. Cleary, OPS 4A-SQN C. R. Church, POB 2B-SQN T. Coutu, LP 3R-C D. E. Jernigan, LP 3R-C K. R. Jones, OPS 4A-SQN M. J. Lorek, LP 3R-C L. E. Nicholson, LP 3R-C M. A. Purcell, LP 4K-C H. R. Rogers, LP 6A-C L. E. Thibault, LP 3R-C S. A. Vance, ET 10 A-K G. E. Vickery, OPS 4A-SQN B. A. Wetzel, BR 4X-C E. J. Vigluicci, ET 10A-K T.J. Bradshaw, NSRB Support, BR 4X-C WBN Site Licensing Files, ADM 1L-WBN EDMS, WT CA-K I:license\annual reports\2008\2008 Annual Environmental Operating Report

ENCLOSURE ANNUAL NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT October 1, 2007 through September 30, 2008

TABLE OF CONTENTS TABLE OF CONTENTS .................................................................................................. 2 I. INTRODUCTION ................................................................................................... 3 II. REPORTING FOR THOSE PROGRAMS NOT CONCERNED WITH WATER QUALITY OR PROTECTION OF AQUATIC BIOTA, WHICH ARE REGULATED BY THE CLEAN WATER ACT ............................................................................... 3 III. ENVIRONMENTAL MONITORING PERFORMED ................................................ 4 IV. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE SQN NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT .............. 5 V. ENVIRONMENTAL TECHNICAL SPECIFICATION (ETS) NONCOMPLIANCES . 6 VI. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMIT CERTIFICATIONS ................................................................................................. 6 VII. CHANGES IN FACILITY DESIGN OR OPERATION............................................. 7 VIII. NON-ROUTINE REPORTS ................................................................................... 7 IX. SPECIAL STUDIES ............................................................................................... 8 X. CHANGES IN APPROVED ENVIRONMENTAL TECHNICAL SPECIFICATIONS 8 E-1

I. INTRODUCTION The Sequoyah Nuclear Plant Annual Non-Radiological Environmental Operating Report for the period of October 1, 2007 through September 30, 2008 is prepared in accordance with Environmental Technical Specifications (ETS) (Non-Radiological), Appendix B, Section 5.4.1. This report includes a summary of:

A. Reporting for those programs not concerned with water quality or protection of aquatic biota, which are regulated by the Clean Water Act B. Environmental monitoring performed C. Reports previously submitted as specified in the SQN National Pollutant Discharge Elimination System (NPDES) Permit No. TN0026450 D. ETS noncompliances and the corrective actions for remediation E. Changes made to applicable State and Federal permits and certifications F. Changes in station design that could involve a significant environmental impact or change the findings of the Final Environmental Statement (FES)

G. Nonroutine reports submitted per ETS Section 4.1 H. Special studies I. Changes in approved ETS Reporting, monitoring, and inspections conducted as required by permits and regulations indicated no adverse impact on the environment as a result of station operation.

II. REPORTING FOR THOSE PROGRAMS NOT CONCERNED WITH WATER QUALITY OR PROTECTION OF AQUATIC BIOTA, WHICH ARE REGULATED BY THE CLEAN WATER ACT A. Third Quarter 2007 Summary of Asbestos Removal Projects - submitted to the Hamilton County Air Pollution Control Bureau on October 1, 2007 B. Annual Asbestos Removal Notification - submitted to Hamilton County Air Pollution Control Bureau on October 31, 2007 C. Air Permit Application updates for Unit 1 and Unit 2 Lubricating Oil System -

submitted to Hamilton County Air Pollution Control Bureau on December 20, 2007 D. Fourth Quarter 2007 Summary of Asbestos Removal Projects - submitted to the Hamilton County Air Pollution Control Bureau on January 7, 2008 E. Report on Diesel Fuel Shipments for Auxiliary Boilers A and B - submitted to the Hamilton County Air Pollution Control Bureau on January 7, 2008 F. Tier Two Emergency and Hazardous Chemical Inventory - submitted to Soddy-Daisy Fire Department, Hamilton County Emergency Services and the Tennessee Emergency Response Commission on February 5, 2008 G. Annual Hazardous Waste Activity Report for 2007 - submitted to the Tennessee Department of Environment and Conservation on February 27, 2008 H. Sequoyah Nuclear Plant Hazardous Waste Minimization Plan - maintained on file at Sequoyah since March 1, 2008 I. Waste Evaluation Application for Sound Mufflers - submitted to the Tennessee Department of Environment and Conservation on March 31, 2008 J. Sequoyah Spill Prevention Control and Countermeasures Plan Revision 13 -

submitted to Erlanger Hospital, Memorial Northpark Hospital, and Soddy-Daisy Fire Department on April 7, 2008 K. First Quarter 2008 Report on Nonscheduled Removal of Asbestos Containing Material - submitted to the Hamilton County Air Pollution Control Bureau on April 7, 2008 E-2

L. Sequoyah Nuclear Plant Annual Report on The Hours of Operation for diesel permitted equipment - submitted to the Hamilton County Air Pollution Control Bureau on May 1, 2008 M. Forms A and R Toxic Chemical Release Information CY2007 Required by Emergency Planning and Community Right to Know Act - submitted to the Environmental Protection Agency EPCRA Reporting Center and Tennessee Department of Environment and Conservation on June 23, 2008 N. Written Annual Document Log of PCBs and PCB Items for Calendar Year 2007 -

maintained on file since July 1, 2008 O. Second Quarter 2008 Summary of Asbestos Removal Projects - submitted to the Hamilton County Air Pollution Control Bureau on July 1, 2008 P. Report on Diesel Fuel Shipments for Auxiliary Boilers A and B - submitted to the Hamilton County Air Pollution Control Bureau on July 1, 2008 III. ENVIRONMENTAL MONITORING PERFORMED A. Storm water samples taken at required frequencies and Best Management Practices implemented as required by General Industrial Storm Water Discharge Permit TNR050015 B. Semi-annual facility inspections as required by General Industrial Storm Water Discharge Permit TNR050015 C. Outfall sampling and inspection is performed as required by NPDES Permit TN0026450 (results previously submitted to NRC as required)

D. Monthly erosion and sediment control inspections are conducted as required by General Industrial Storm Water Discharge Permit TNR050015 E. Weekly tank, piping, and secondary containment inspections are performed as required by General Industrial Storm Water Discharge Permit TNR050015 and the Spill Prevention Controls and Countermeasure Plan F. Weekly and monthly hazardous waste inspections conducted as required by 40CFR261 and by the Tennessee Rule Chapter 1200, Hazardous Waste Management G. Weekly landfill inspections performed as required by 40CFR261 and by the Tennessee Rule Chapter 1200, Hazardous Waste Management H. Daily operational hours of Auxiliary Boilers A and B, Emergency Generators 1A, 1B, 2A, and 2B, and Blackout Generators 1 and 2 as required by Federally Enforceable Certificate of Operation Nos. 4150-10200501-08C and 4150-20200102-11C I. Diesel fuel recovery trench, extraction, and monitoring well sampling, maintenance and operation conducted as required by the State of Tennessee J. Intake forebay aeration system sampling, maintenance and operation performed as required by the State of Tennessee K. Air emissions inspected monthly for equipment permitted by the Hamilton County Air Pollution Control Bureau L. Refrigeration equipment performance and repairs are tracked weekly to ensure compliance with Title VI of the Clean Air Act M. Waste sampling and characterization as required by 40CFR261 and by the Tennessee Rule Chapter 1200, Hazardous Waste Management N. Quarterly PCB transformer inspections as required by 40CFR761 O. Daily inspections of leaking PCB transformers as required by 40CFR761 P. PCB spill and leak cleanup as required by 40CFR761 Q. Asbestos removal tracking as required by the Hamilton County Air Pollution Control Bureau E-3

R. Hazardous waste minimization (such as chemical control and substitution) as required by the Tennessee Rule Chapter 1200, Hazardous Waste Management S. National Environmental Policy Act (NEPA) reviews are conducted to evaluate potential environmental impact of temporary or permanent facility modifications as required by 40CFR1500 T. Hazardous Waste self-assessment SQN-CEM-F08-003 IV. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE SQN NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES)

PERMIT The following reports were submitted as specified in the SQN NPDES Permit No.

TN0026450, General Industrial Discharge Storm Water Permit No. TNR050015.

A. Monthly Discharge Monitoring Report for September 2007 - submitted to Tennessee Department of Environment and Conservation on October 11, 2007 B. Monthly Discharge Monitoring Report for October 2007 - submitted to Tennessee Department of Environment and Conservation on November 14, 2007 C. DMR - QA Study 27 Provider Graded Test Results - submitted to Tennessee Department of Environment and Conservation and Environmental Protection Agency on November 28, 2007 D. Monthly Discharge Monitoring Report for November 2007 - submitted to Tennessee Department of Environment and Conservation on December 13, 2007 E. Monthly Discharge Monitoring Report for December 2007 - submitted to Tennessee Department of Environment and Conservation on January 14, 2008 F. Water Withdrawal Registration Forms - submitted to Tennessee Department of Environment and Conservation on January 22, 2008 G. 2007 Biocide/Corrosion Treatment Plan (B/CTP) Annual Report - submitted to Tennessee Department of Environment and Conservation on January 29, 2008 H. Multi-Sector Storm Water General Permit 2007 Storm Water Monitoring Report -

submitted to Tennessee Department of Environment and Conservation on February 4, 2008 I. Monthly Discharge Monitoring Report for January 2008 - submitted to Tennessee Department of Environment and Conservation on February 13, 2008 J. Monthly Discharge Monitoring Report for February 2008 - submitted to Tennessee Department of Environment and Conservation on March 13, 2008 K. Monthly Discharge Monitoring Report for March 2008 - submitted to Tennessee Department of Environment and Conservation on April 14, 2008 L. Monthly Discharge Monitoring Report for April 2008 - submitted to Tennessee Department of Environment and Conservation on May 14, 2008 M. Monthly Discharge Monitoring Report for May 2008 - submitted to Tennessee Department of Environment and Conservation on June 11, 2008 N. Monthly Discharge Monitoring Report for June 2008 - submitted to Tennessee Department of Environment and Conservation on July 15, 2008 O. Compliance Evaluation Inspection comments and recommendations - submitted to Tennessee Department of Environment and Conservation on July 22, 2008 P. Monthly Discharge Monitoring Report for July 2008 - submitted to Tennessee Department of Environment and Conservation on August 14, 2008 Q. DMR - QA Laboratory Performance Evaluation Study 28 - submitted to Environmental Resource Associates, Tennessee Department of Environment and Conservation, and Environmental Protection Agency on August 27, 2008 R. Monthly Discharge Monitoring Report for August 2008 - submitted to Tennessee Department of Environment and Conservation on September 11, 2008 E-4

V. ENVIRONMENTAL TECHNICAL SPECIFICATION (ETS) NONCOMPLIANCES None.

VI. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMIT CERTIFICATIONS Air Permits: The Nuclear Regulatory Commission was notified on December 4, 2007 of changes to SQN Air Permits effective November 6, 2007.

The following are the approved changes to SQN Air Permit 4150-30700804-06C Insulator Saws A and B, Permit 4150-10200501-08C Auxiliary Boilers A and B, and Permit 4150-30900203-10C Abrasive Blasting Operation:

Insulator Saws A and B - Permit 4150-30700804-06C (formerly permits 4150-30700804-06C and 4150-30700804-07C)

  • Process weight increased from 151 pound per hour (lb/hr) to 160 lb/hr.
  • Saw A allowable emission of particulate matter increased from 0.44 lb/hr to 0.49 lb/hr.
  • Saw B allowable emission of particulate matter decreased from 0.39 lb/hr to 0.20 lb/hr.
  • Saw B requirement added: "Particulate matter emissions from each of these emission sources shall be vented to and controlled by a settling drum followed by a bag filter or other piece or pieces of control equipment that have an equivalent or greater particulate matter control efficiency..."

Auxiliary Boilers A and B - Permit 4150-10200501-08C

  • Maximum allowable emissions of particulate matter from each of Boilers A and B reduced from 1.80 lb/hr to 1.64 lb/hr.
  • Requirement added: "Visible emissions from Boilers A and B shall not exceed twenty (20) percent opacity on average in any six (6) minutes, except for one six (6) minute period in any period of one hour in which visible emissions shall not exceed twenty-seven (27) percent opacity on average..."

Abrasive Blasting Operation - Permit 4150-30900203-10C

  • Process weight increased from 267 lb/hr to 500 lb/hr.
  • Requirement added: "Particulate matter emissions from the abrasive blasting operation shall be contained within an enclosure and vented and controlled by a filter that completely covers any exhaust intake or by another piece of control equipment that has an equivalent or greater particulate matter control efficiency.

The blasting operation shall not be used if the filter for any exhaust intake is not in place..."

  • Maximum allowable emissions of particulate matter from abrasive blasting operation decreased from 1.01 lb/hr to 0.30 lb/hr.
  • "Visible emissions from the abrasive blasting operation shall not exceed twenty (20) percent opacity for an aggregate of more than five (5) minutes in any period of one hour or more than twenty (20) minutes in any period of twenty-four hours..." to "Visible emissions from any exhaust stack that serves the abrasive blasting operation shall not exceed ten (10) percent opacity for any aggregate of more than five (5) minutes in any period of one hour or more than twenty (20) minutes in any period of twenty-four hours..." and "Visible emissions from the building or other enclosure that the abrasive blasting operation is performed in E-5

shall not exceed five (5) percent opacity for an aggregate of more than five (5) minutes in any period of one hour or more than twenty (20) minutes in any period of twenty-four hours..."

VII. CHANGES IN FACILITY DESIGN OR OPERATION In accordance with Technical Specification 5.3.c, facility design and operational changes were reviewed for potential effect on the environment. This review is completed per Tennessee Valley Authority upper tier Instruction IX Environmental Review and implementing Environmental Management System (EMS) procedures Environmental Review Process and Standards and Criteria for Environmental Reviews, in compliance with the National Environmental Policy Act. An evaluation of facility design and operational changes proposed from October 1, 2007 through September 30, 2008 was completed.

A. Special Tests There were no special tests conducted during this period that met environmental impact criteria B. Temporary Alterations There were no temporary alterations conducted during this period that met environmental impact criteria.

C. Design and Operational Changes The facility design and operational changes made during this reporting period with a potential impact on the environment were found to be within the scope of existing permits and in compliance with environmental regulations. Those changes reviewed are as follows:

Environmental Assessments - None.

Categorical Exclusion Checklists

1. Generic SQN Blanket Review
2. U1 & U2 RWST Moat TACF 1-07-008-063 and 1-07-007-063
3. TSC 08-02 Containment Purge and Valve Isolation
4. Sodium Hypochlorite Tank installation at the ERCW skid
5. SQN-SQS2-0242 SQN Site Iodine-131 Release Concentrations in the Tennessee River
6. Sharing of Overlook Training Facility with Hamilton County
7. Cooperative Range Project with Hamilton County
8. 4-Face Visual Fuel Assembly Inspection System
9. Tritium Ground Water Detection, Prevention, and Remediation
10. Relocation of the Weld Test Shop
11. 1A, 1B, 2A, 2B EDG Battery Replacement
12. Critical Infrastructure Protection Cyber security Compliance Phase 2 - Project Number 105622 VIII. NON-ROUTINE REPORTS E-6

None.

IX. SPECIAL STUDIES There were two environmental study conducted during this reporting period.

Fish Impingement at Sequoyah Nuclear Plant During 2005 through 2007 was submitted to the Tennessee Department of Environment and Conservation and Nuclear Regulatory Commission on December 19, 2007 as required by the NPDES permit TN0026450 Part III F.2.a. The report concluded that the cooling water intake at SQN has not adversely impacted fish and shellfish communities in the Chickamauga Reservoir.

Biological Monitoring of the Tennessee River near Sequoyah Nuclear Plant Discharge 2007 was performed by TVA Aquatic Monitoring and Management. This report was submitted to the Tennessee Department of Environment and Conservation and Nuclear Regulatory Commission on June 11, 2008 as required by the NPDES permit TN0026450 Part III F.1.a. This study concluded that despite low flow conditions resulting from the drought, annual aquatic monitoring has not reflected negative trends in the aquatic communities in Chickamauga Reservoir.

X. CHANGES IN APPROVED ENVIRONMENTAL TECHNICAL SPECIFICATION There were no changes in approved ETSs during this period.

E-7

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