ML12121A008

Submittal of 2011 Annual Non-radiological Environmental Operating Report

ML12121A008
Person / Time
Site:	Palisades
Issue date:	04/26/2012
From:	Gustafson O Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML12121A008 (7)

Text

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Otto W. Gustafson Licensing Manager April 26, 2012 Facility Operating License Appendix B, Section 5.4.1 U. S. Nuclear Regulatory Commission AnN: Document Control Desk Washington, DC 20555-0001

Subject:

2011 Annual Non-radiological Environmental Operating Report Palisades Nuclear Plant Docket 50-255 License No. DPR-20

Dear Sir or Madam:

Entergy Nuclear Operations, Inc (ENO) is providing the Palisades Nuclear Plant (PNP)

Annual Non-radiological Environmental Operating Report for 2011. This report was prepared in accordance with the PNP Renewed Facility Operating License, Appendix B, section 5.4.1. The attached report describes the implementation of the Environmental Protection Plan from January 1,2011, through December 31,2011.

This letter contains no new commitments and no revisions to existing commitments.

Sincerely, OWG/bed

Attachment:

1.2011 Annual Non radiological Environmental Operating Report

2. Herbicide Treatments cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

ATTACHMENT 1 2011 ANNUAL NON RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT

1.0 BACKGROUND

Appendix 8 of the Renewed Facility Operating License for the Palisades Nuclear Plant (PNP) requires the submittal of an annual environmental operating report to the Nuclear Regulatory Commission (NRC), describing the implementation of the Environmental Protection Plan (EPP) during the previous year. The reporting period is January 1,2011, through December 31,2011.

The PNP operated for 8,409 hours0.00473 days <br />0.114 hours <br />6.762566e-4 weeks <br />1.556245e-4 months <br /> and produced a net total of 6,641,013 MWHe during 2011. This represents 92.4% of the net demonstrated capacity of the design electric rating of 805 MWe.

2.0 ENVIRONMENTAL IMPACT EVALUATIONS Four engineering change documents were evaluated per Entergy Nuclear Operations, Inc. (ENO) procedure, EN-EV-115, "Environmental Reviews and Evaluations," during 2011.

Engineering Changes (EC) 26813, 26814 and 26815 were reviewed and approved for installation of gas in oil monitors for start up transformers 1-1 ,

1-2 and 1-3, respectively.

EC 30739 was approved to allow re-installation of the augmented cooling system for condensate pump P-28 thrust bearing (the same temporary modification was installed in 2010 under EC 20672).

There were no changes, tests, or experiments that involved an unreviewed environmental question and no EPP changes were required.

3.0 ADDITIONAL ACTIVITIES AUTHORIZED UNDER NPDES ENO received approval from the MDEQ on May 25, 2011 , for the reduction in monitoring of low level mercury (LLHg). The site NPDES permit was issued in November 2009, which required sampling and analysis for LLHg on a monthly basis. Approval was given to eliminate monthly sampling and sample annually.

A request and subsequent information to increase the discharge concentration of Thruguard THR404 from Outfall 001 was submitted. The request was approved by the Michigan Department of Environmental Quality (MDEQ) on August 12, 2011. Outfall 001 discharges to Lake Michigan. Thruguard THR404 is used for scale prevention in the plant cooling water system.

. Page 1 of 2

ENO received approval from the MDEQ on August 24,2011, for the use of wood flour as a water treatment additive (WTA) under the site national pollutant discharge elimination system (NPDES) permit. The wood flour additive is used as an aide in condenser tube plugging for leaking tubes.

4.0 UNUSUAL ENVIRONMENTAL EVENTS The MDEQ Water Resources Division (WRD) conducted a site inspection on June 16, 2011. The purpose of the inspection was to evaluate the property for compliance with MDEQ permit 09-80-0058-P issued under Part 353, Sand Dunes Protection, of Natural Resources and Environmental Protection Act, 1994 PA 451 as amended (Part 353). The permit was issued in support of the security owner controlled area (SOCA) fence installation project. At the time of the inspection, MDEQ staff observed activities unrelated to the above permit: placing a volume of sand with mixed debris along the south side of the "A" cooling tower area, and excavation of an area for the purpose of emergency repair work.

These activities are regulated under the authority of Part 353.

A review of WRD files indicated that no permits were issued for these activities, which is a violation of Part 353. The MDEQ issued a violation and order to restore on July 14, 2011. Immediate remediation was performed to the satisfaction of the MDEQ Engineer. The violations were tracked and closed under CR-PLP-2011-03487.

5.0 ENVIRONMENTAL MONITORING Documentation of the effect of cooling tower operation on meteorological variables was required for two years following the conversion from the once-through cooling system to the cooling towers. Because the cooling towers have been in operation for 37 years, meteorological monitoring and other monitoring activities related to the cooling towers were not required during 2011. Herbicides were not applied to the transmission line exit corridor in 2011.

TruGreen and Katerberg VerHage treated other areas of the property for vegetation management during 2011. The application of herbicides is documented in Attachment 2.

6.0 NON-ROUTINE REPORTS During 2011, no non-routine reports were generated.

Page 2 of 2

ATTACHMENT 2 HERBICIDE TREATMENTS Company: Katerberg VerHage 3717 Michigan NE Grand Rapids, Michigan 49525 Date of Treatment: 5/23 (16 gallons), 5/24 (16 gallons), 7/12 ( 16 gallons), 9/13 (16 gallons)

Commercial Names of Products in Solution: Roundup PROMAX and Lesco Tracker Green Chemical Names of Products:

Roundup PROMAX- Potassium salt of N-(Phosphonomethyl) Glycine Lesco Tracker Green- Proprietary Green Dye Concentrate (No CAS Number)

Concentration of Active Ingredient in Field Use Mix. One solution was mixed together that contained the following:

5 oz. per 1 gallon (Roundup)

Less than 0.25 oz. per 1 gallon (Lesco Green Tracker)

Solution was applied to 1.5 acres at a rate of 21.3 gallons per acre for initial (May) treatment and applied to 1.5 acres at a rate of 10.7 gallons per acre for second (July) and third (September) treatments.

Diluting Substance: Water Rate of Application: 21 .3 gallons per acre first treatment, 10.7 gallons per acre second and third treatment Total Amount Used: 64 Gallons total volume used for treatment Method of Application: Hand sprayer for all areas Frequency of Application: SOCA fence application as needed Location: Along and near SOCA fence Purpose of Treatment: Control of weed species Page 1 of 4

Company: Katerberg VerHage 3717 Michigan NE Grand Rapids, Michigan 49525 Date of Treatment: 5/18/2011 to 5/20/2011 Commercial Names of Product: Soil Moist Disk 5-5-5 Chemical Names of Product:

Soil Moist Disk Propenoic acid, 2-methyl-, 2-hydroxyethyl ester, polymer with methyl 2-propenoate, 2-propenamide and 2-propenoic acid, ammonium sodium salt Concentration of Active Ingredient in Field Use Mix. Undiluted Diluting Substance: None Rate of Application: 1 disk per shrub planted Total Amount Used: 2,200 individual disks Method of Application: Inserted by hand Frequency of Application: Once at shrub installation Location: Dunes near SOCA fence Purpose of Treatment: Increase survival of installed shrubs through increased localized soil moisture retention.

Page 2 of 4

Company: TruGreen 9077 Portage Industrial Portage, Michigan 49024-9935 Date of Treatment: May 19, 2011 (180 pounds applied)

June 21, 2011 (100 gallons applied)

June 30, 2011 (300 gallons applied)

July 27, 2011 (360 pounds applied)

August 30,2011 (100 gallons applied)

September 28, 2011 (195 pounds applied)

October 25, 2011 (300 pounds applied)

Commercial Names of Products in Solution: Oust XP, Escort DF60, Dimension, Merit, Tru Power 3 Chemical Names of Products:

Oust XP- (Sulfometuron Methyl) (Methyl 2- (((((4, 6-dimethyI1-2-pyrimidinyl)-amino]

carbonyl] sulfonyl] benzoate)

Escort DFSo- METSULFURON METHYL (METHYL 2-(((((4-METHOXY-6-METHYL-1, 3, 5-TRIAZIN-2-YL) AMINO] CARBONYL] AMINO] SULFONYL] BENZOATE)

Dimension - Dimethyl 2-(difluoromethyl)-4-(2-methylpropyl)-6-(trifluoromethyl)-3,5-pyridinedicarbothioate)

Merit- 1-((6-Chloro-3-pyridinyl) methyl)-N-nitro-imidazolidinimine Tru power 3- Triisopropanolamine Salt of 2, 4-Dichlorophenoxyacetic Acid Concentration of Active Ingredient in Field Use Mix One solution was mixed together that contained the following:

4 oz. per 87 gallons per acre (Oust XP) applied to 4 acres 1 oz. per 87 gallons per acre (Escort 60DF) applied to 4 acres One solution was mixed together that contained the following:

12 oz. per 50 gallons per acre (Merit) applied to 2.3 acres One solution was mixed together that contained the following:

25 oz. per 50 gallons per acre (Tru power 3) applied to 2.3 acres Diluting Substance: Water for wet applications No dilutions for dry applications Rate of Application: 87 gallons per acre liquid application (Oust XP and Escort 60DF) 50 gallons per acre liquid application (Merit, Tru power 3) 300 pounds per acre dry application (Fertilizer & Dimension)

Total Amount Used: 500 Gallons total volume used for liquid treatment 1035 Pounds total volume used for dry treatment Page 3 of 4

Method of Application: Hand sprayer for liquids Broad cast spreader for dry application Frequency of Application: Through out the year as needed Location: Along and near roadways, fence lines, walkways, parking lots, Containment areas, substations, cooling towers, protected area, and microwave zones.

Purpose of Treatment: Fertilizer, control of weed species, crabgrass, nuisance vegetation, nuisance broadleaf vegetation Page 4 of 4