ML12129A377

Enclosure - Watts Bar Nuclear Plant, Unit 1 - 2011 Annual Non-Radiological Environmental Operating Report

ML12129A377
Person / Time
Site:	Watts Bar
Issue date:	05/07/2012
From:	Tennessee Valley Authority
To:	Office of Nuclear Reactor Regulation
References
Download: ML12129A377 (14)

Text

Enclosure Watts Bar Nuclear Plant, Unit 1 2011 Annual Non-Radiological Environmental Operating Report E-1

TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT ANNUAL NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FEBRUARY 7, 2011 THROUGH FEBRUARY 6, 2012 E-2

TABLE OF CONTENTS I. IN T R O D UCT IO N ......................................................................................................... E -4 I1. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WATTS BAR NUCLEAR PLANT NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM PERMIT .......................................................... E-4 II1. SPECIAL BIOLOGICAL MONITORING REPORTS ..................................................... E-5 IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES ................................. E-7 V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERM ITS AND CERTIFICATIO NS ........................................................................... E-10 VI. CHANGES IN FACILITY DESIGN OR OPERATION ................................................. E-12 V II. NO N-R O UT INE R EPO RTS ....................................................................................... E-14 VIII. CHANGES IN APPROVED ENVIRONMENTAL PROTECTION P LA N S P E C IF ICA T IO NS .......................................................................................... E -14 E-3

I. INTRODUCTION The Watts Bar Nuclear Plant (WBN) Annual Non-Radiological Environmental Operating Report (ANEOR) is provided for the period of February 7, 2011 through February 6, 2012. This report was prepared in accordance with Appendix B to facility operating license NPF-90, "Environmental Protection Plan" (EPP), Section 5.4.1, "Routine Reports." This report includes a summary of:

A. Reports previously submitted as specified in the WBN National Pollutant Discharge Elimination System (NPDES) Permit Number TN0020168.

B. All special reports submitted per EPP Section 4.1, "Environmental Monitoring."

C. All EPP noncompliances and the corrective actions taken to remedy them.

D. Changes made to applicable state and federal permits and certifications.

E, Changes in station design that could involve a significant environmental impact or changes to the findings of the Final Environmental Statement (FES).

F. Non-routine reports submitted per EPP Section 4.2, "Unusual or Important Environmental Events."

G. Changes in the approved EPP.

REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WBN NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT The following reports were submitted as specified in the WBN NPDES Permit Number TN0020168 and the Tennessee Storm Water Multi-Sector General Permit (TMSP)

Numbers TNR051343 and TNR050000:

A. The annual sampling and analysis required by the TMSP for storm water was performed and the annual report was submitted to the Tennessee Department of Environment and Conservation (TDEC) prior to the March 31, 2011, deadline.

B. As required by the NPDES permit, Discharge Monitoring Reports (DMRs) were completed and submitted monthly to the TDEC no later than 15 days after the completion of the reporting period.

C, As required by the General NPDES Permit for Discharges of Hydrostatic Test Water No.TNG670000, WBN completed and submitted the monthly hydrostatic test water DMR sheets to the TDEC with the corresponding monthly NPDES permit DMR sheets. The exception was May 2011, as discussed in the EPP Noncompliance section of this submittal.

D, DMR Quality Assurance (QA) Laboratory Performance Evaluation Study 31 was completed by and submitted to Environmental Resource Associates, the TDEC, and the Environmental Protection Agency (EPA) prior to the August 19, 2011, E-4

REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WBN NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT (continued) deadline. All analyte performance evaluations were "acceptable".

E. The annual Biocide/Corrosion Treatment Report was completed and submitted to TDEC prior to the February 15, 2011, deadline.

F. The "Summer 2010 Compliance Survey for Watts Bar Nuclear Plant Outfall 113 Passive Mixing Zone" was submitted to TDEC, Division of Water Pollution Control (referred to as TDEC later in this report), on March 14, 2011. The "Winter 2011 Compliance Survey for Watts Bar Nuclear Plant Outfall 113 Passive Mixing Zone" was submitted to TDEC on February 11, 2012.

II1. SPECIAL BIOLOGICAL MONITORING REPORTS A. EPP Section 4.1.1, "Aquatic Monitoring"

1. Routine semi-annual Whole Effluent Toxicity (WET), or chronic biotoxicity tests, were conducted on plant effluents and the appropriate reports were submitted as part of the DMRs for Outfall Serial Numbers (OSNs) 101 and 113 in March/April and October, as required by the NPDES permit.

All TVA test results were valid for all sampling outfalls and dates and for both 25 percent inhibition concentration (IC25 ) tests (P. promelas and C.

dubia).

2. The annual report, "Biological Monitoring of the Tennessee River near the Watts Bar Nuclear Plant 2010," was submitted to the TDEC on August 10, 2011, indicating no adverse impact to aquatic life due to WBN operation. This report is not required in accordance with Part Ill,Section I of the WBN NPDES Permit, but was a recommendation in the "Watts Bar Nuclear Plant Supplemental Condenser Cooling Water System Fish Monitoring Program, 2001" report for consistency with other required annual reporting programs at Tennessee and Alabama nuclear plants.

3. In accordance with the provisions of Tennessee Code Annotated Section 69-8-301 et seq., the Water Resources Information Act, WBN submitted the Water Withdrawal Registration Form for Calendar Year (CY) 2011 to the TDEC prior to the February 15, 2012, deadline. Although federal agencies are not subject to laws and regulations promulgated by state governments unless Congress has clearly waived the federal government's sovereign immunity, TVA voluntarily agreed in 2003, as a matter of policy, to provide the registration information in order to assist both TVA and the TDEC in carrying out their water management responsibilities.

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Ill. SPECIAL BIOLOGICAL MONITORING REPORTS (continued)

B, EPP Section 4.1.2, "Maintenance of Transmission Line Corridors" Listed below are the 500 kV transmission lines associated with WBN and information regarding the maintenance that was performed on each line:

500 kV Line Identifier Maintenance Performed Bull Run - Watts Bar (Note Below) Three different mixes were used to treat 364.5 brush acres (structures 15 thru 58)

1. Mix 1: Low Volume - 990 gallons

• Dow agro science Accord XRT2 - 4%

• DuPont - Viewpoint - 64 oz/1 00 gal.

• Aligare - MSO - 1%

2. Mix 2: Low Volume Aquatic - 1110 gallons

" Dow Agro-Science Rodeo (Glyphosate) - 3%

" Arsenal - 1%

" Aqufact (Surfactant) - .75%

3. Mix 3: High Volume - 10250 gallons

" Dow Agro-Science Accord XRT2 - 1.5%

" DuPont Viewpoint 16 oz/100 gal.

• Aligare MSO- 1%

Watts Bar - Roane No major clearing was performed on these line corridors using herbicides Watts Bar - Volunteer 1469 Brush Acres treated

1. Mixture:

• 4% Rode produced by Dow Agri-science

• 25 ounces Lineage Clearstand produced by Dupont

• 1% Aqu-fact surfactant Watts Bar - Sequoyah 1 (Note Below) 665 Brush Acres treated

1. Mixture:

• 4% Rode produced by Dow Agri-science

• 25 ounces Lineage Clearstand produced by Dupont

• 1% Aqu-fact surfactant Watts Bar - Sequoyah 2 666 Brush Acres treated

1. Dow Agro-Science Accord XRT2 - 4%

2. BASF's Arsenal Powerline - .75%

3. DuPont's Escort - 3 oz./100 gal.

4. Agufact (Surfactant) - .50%

Note:

The transmission line designated as Bull Run - Sequoyah in previous versions of this report has been split into the following transmission lines; 1) Watts Bar-Sequoyah 1, 2) Bull Run - Watts Bar.

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IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES WBN did not receive any Notice of Violations (NOV) from February 2011 to February 2012. In accordance with the NPDES permit, the following noncompliances were reported to the TDEC.

A. The TMSP Sector 0 requires annual monitoring of total recoverable iron. On April 27, 2011, WBN exceeded the benchmark monitoring requirement for total recoverable iron as stated in the NPDES permit, Table 0-2 (Benchmark Monitoring Requirements for Steam Electric Power Generating Facilities at monitoring point SW-8). According to the TDEC, the Benchmark Monitoring Requirements are target values and should not be construed to represent permit limits. Therefore, this was not a permit noncompliance or a reportable environmental event (REE).

In accordance with the TMSP, WBN notified the TDEC of this exceedance, reviewed its storm water pollution prevention plan (SWPPP), made an addition to the SWPPP which would assist in reducing specific effluent concentrations to equal to or less than Benchmark Monitoring Requirements, and submitted a brief summary of the proposed SWPPP modification (including a timetable for implementation) to the State. Best management practices (BMPs) were implemented following the April benchmark exceedance and the outfall was re-sampled on October 28, 2011. Since the October 28, 2011 value also exceeded the benchmark monitoring requirement for total recoverable iron, WBN evaluated more effective BMP's. One of the preventative measures taken to minimize recurrence was an assessment of the flows into the monitoring outfall.

It was observed that when SW-8 was located in the culvert across the road from the construction switchyard it was receiving the majority of runoff from the Unit 2 parking lot. Therefore, to obtain a representative sample from the construction switchyard rather than the Unit 2 parking lot, WBN channelized the sheet flow construction from the switchyard and is in the process of confirming adequate drainage from this monitoring point.

B. On May 13, 2011, WBN reported to the TDEC in the April DMR that on May 2, 2011, WBN discovered that the Unlined Pond was discharging to the Yard Holding Pond through a crack in a pond inlet piping sleeve seal. Samples collected to characterize the batch release as required by the NPDES permit were determined to be within limits for all outfall serial number (OSN) 107 parameters. Utilizing estimated reported flows and daily staff gauge readings, the worst case start of the batch release was defined as April 15, 2011, at 11:20 a.m. The Unlined Pond was lowered on May 4, 2011 via OSN 107 to facilitate corrective actions and the discharge through the crack stopped on May 4, 2011, at 12:10 p.m. Until repairs are made, WBN has interim measures in place to ensure the pond does not discharge through the crack.

C. On June 20, 2011, per the TDEC's June 17, 2011 request, TVA provided written notification for the Intake Pumping Station (IPS) releases that were observed on June 16, 2011 at 1:09 p.m. and 2:35 p.m. Verbal notification was provided by telephone to the Chattanooga Environmental Field Office on June 17, 2011, at 9:48 a.m. A summary of the events are as follows:

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IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES (continued)

On June 16, 2011, at 1:09 p.m., WBN personnel noticed a small steam of water releasing over a trough on the outside of the IPS and entering the Intake Forebay. The water was determined to be raw water treated with sodium hypochlorite and Flogard MS6237, a zinc chloride and phosphoric acid mixture.

These chemicals are injected into plant systems per the WBN Biocide Corrosion Treatment Plan (BCTP). The chemical feeds were terminated at 1:20 p.m. for sodium hypochlorite and at 2:00 p.m. for Flogard MS6237. The water release from the trough was terminated at 2:30 p.m.

Samples in the intake at the release were collected for total residual chlorine (TRC), pH, total phosphorus, and total zinc. TRC collected at 3:18 p.m. was initially 0.19 mg/L, decreasing to less than <0.05 mg/L by 6:57 p.m. The Daily Maximum Calculation for TRC was determined to be <0.09 mg/L. pH collected at 2:52 p.m. at the same location was 7.2. Total phosphorus and total zinc results were provided in the June DMR. The cause of this event was determined to be an obstruction from vegetation in the trough that blocked the flow from the Essential Raw Cooling Water (ERCW) strainers, causing the water flow to release over the side of the trough. The trough is located approximately three quarters of the way up the south wall of the IPS and runs the entire length of the south side of the building. It directs water from the ERCW strainer and traveling water screen backwash to the Yard Holding Pond which discharges to the Tennessee River via NPDES Outfall 101.

At 2:35 p.m., soon after the trough release was terminated, WBN personnel then noticed a release from a broken pipe on the same outer wall outside of the IPS with water entering the Intake Forebay. It was determined that this water was treated with Flogard MS6237. WBN personnel terminated the A and B Corrosion Control Chemical Dilution Water Supply to stop the flow from the broken pipe at 4:05 p.m. on June 16, 2011.

During this period there was no threat to public drinking supplies, to human health, or to the environment. Furthermore, the locations of the releases are in close proximity of the plant intake and would likely be drawn through the IPS for plant use and discharged through permitted outfalls. TVA biologists surveyed by boat the Intake Forebay and downstream of the diffusers the evening of June 16, 2011 and did not observe any fish distress, fish mortality, or abnormal bird migration. Additionally, since the day of discovery, WBN has not observed fish distress, fish mortality, or abnormal bird migration.

D. On September 1,2011, at approximately 11:00 a.m., WBN personnel observed a small area with cloudy appearance below the water's surface of the Intake Forebay, approximately three feet in front of the intake screens at the IPS. A courtesy notification was made to the TDEC Chattanooga Field Office on September 2, 2011. An update was provided on October 12, 2011, with the September DMR. After further investigation, the source was determined to be raw water treated with CT1 300, a non-oxidizing molluscicide, which had been initiated at the IPS per the approved WBN BCTP. CT1300 was inadvertently being directed toward the Intake Forebay due to a minor change of the chemical E-8

IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES (continued) injection piping. The CT1 300 chemical treatment that began on August 31, 2011, at 06:55 a.m. was terminated on September 1, 2011, at 11:30 a.m. after discovering the potential concern. At no time was there a threat to public drinking supplies, human health, or the environment. Since the location of the chemical injection remained in close proximity to the plant intake, the treated raw water would have been drawn into the IPS as intended for plant use and discharged through permitted outfalls. No fish distress, fish mortality, or abnormal bird migration was observed.

E. On November 17, 2011, the Unit 2 cooling tower basin overflowed to Trench A, which drains to a wetland prior to discharging to the Tennessee River. The cause of the overflow was trash rack screens clogged with seasonal foliage. As described in the August 1998 Environmental Assessment WBN's Supplemental Condenser Cooling Water (SCCW) Project and WBN's NPDES permit, the SCCW is the source of the Unit 2 cooling tower basin water. The SCCW is untreated / raw river water which is used to cool the plant condensers (thermally loaded after this point), then flows to the Unit 1 cooling tower basin, and is discharged to the Tennessee River via OSN 101 or OSN 113. Upon discovery of the overflow, WBN immediately isolated SCCW, and, as a conservative measure, collected all of the NPDES parameters for OSN 113. All analytical values were within permit limits and flow was estimated to be 120,000 gallons.

This overflow was documented in the TVA Corrective Action Program (PER 464070), the trash racks were cleaned prior to returning the SCCW to service, and the risk of future screen clogging is evaluated daily. No adverse impacts to any wetlands or other habitat were observed as a result of the overflow.

F. The TDEC conducted a Compliance Evaluation Inspection (CEI) August 29-31, 2011. The purpose of the inspection was to independently determine WBN's compliance with the terms and conditions of NPDES Permit Number TN0020168 and TMSP TNR051343. Records and all permitted outfalls were examined during the inspection. TDEC questioned the accuracy of the TDEC Nashville office DMR printout and TDEC data entry errors were identified. It was recognized that TVA had submitted all facility DMRs on-time and that all of TVA actions were in compliance and appropriate. No violations were found.

However, on November 3, 2011, TVA received a call and letter from the TDEC as a courtesy notification that WBN had been placed on EPA's Facilities September 2011 Clean Water Act Watch List for extended non-submittal of DMRs. Although the official 2011 EPA Watch List is published quarterly, the EPA publishes preliminary versions of the Watch List monthly, often prior to completion of all data entry. The TDEC stated that all TVA plants were in compliance and that they were correcting the situation. Due to the delay in the entry process between the TDEC and the EPA databases, which resulted in WBN's DMR data not being entered into the system by the TDEC, WBN erroneously appeared on the EPA preliminary Watch List published in September 2011. The TDEC has corrected WBN's DMR data entry and WBN will not appear on the next official Watch List.

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IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES (continued)

G. The TVA Compliance Office completed its assessment of WBN (Unit 1 & Unit 2).

on December 8, 2011. All media areas with associated records were inspected.

Six findings were identified, two of which were level two (moderate) findings and four level three (minor) findings. One hazardous waste finding was a repeat from a previous assessment on February 3, 2010. Although WBN received a repeat finding in hazardous waste, there has been noticeable improvement in the hazardous waste program since the previous assessment. WBN was commended for developing and implementing a Gap to Excellence Plan to prevent potential environmental violations and to minimize environmental challenges. The findings were as follows:

1. Hazardous waste determination requirements are not being met for various containers of wastes stored in the Chemical Surplus Area.

2. Commitments identified in WBN's Environmental Assessment for the Spring City Sewer Pipeline Project were entered into ENTRAC (environmental tracking database), but were not closed out by the end of the project. Although the project was completed and the commitments were met in 2008, these commitments were not closed in ENTRAC until this assessment.

3. Secondary containment requirements are not being met for 55-gallon drums of petroleum product located in Warehouse E or for totes of hazardous chemicals stored at Warehouse C.

4. Documentation of tank integrity testing required to be completed during the summer of 2011 was not available for review during the assessment.

5. An oil fill line abandoned in place near the fuel oil storage tanks in 2010 was not labeled as to its origin.

6. WBN Hydrostatic Test Water Permit No. TNG670347 effective April 6, 2011 through July 31, 2011 requires monitoring results to be submitted with the DMR monthly. Due to an inadvertent error, WBN did not submit monitoring results for the month of May 2011. However, the May hydrostatic test water DMR was included with the November DMR.

V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTIFICATIONS A. NPDES Permit TN 0020168

1. On January 28, 2011, WBN noted that the CO 2 sparging system to control the Low Volume Waste Treatment Pond effluent pH was not functioning properly. As the pond elevation was too high to allow maintenance to be performed on the sparger, WBN added sulfuric acid to E-10

V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTIFICATIONS (continued) the pond per TDEC temporary approval to ensure the site maintained compliance with pH permit limits. WBN provided TDEC written confirmation regarding this treatment on February 11, 2011, with the January DMR. In addition, as a preventative measure, WBN installed another temporary CO 2 sparging system on February 6, 2011.

2. In support of Unit 2 construction, WBN received coverage under General NPDES Permit No. TNG670000 for Discharges of Hydrostatic Test Water effective as of April 6, 2011, with an expiration date of April 1, 2013.

3. On September 9, 2011, WBN requested termination of coverage for discharges under hydrostatic test water permit tracking number TNG670347. TDEC terminated the above referenced permit coverage on September 19, 2011.

4. On April 29, 2011, WBN provided the Nuclear Regulatory Commission a response to a Request for Additional Information (RAI) regarding the IPS flow rates used for environmental reviews. Enclosures included: (1)

Response to IPS Water Velocity RAI and (2) Fish Impingement at Watts Bar Nuclear Plant Intake Pumping Station Cooling Water Intake Structure during March 2010 through March 2011, Revised April 2011.

5. On August 31, 2011, TDEC reissued WBN's NPDES permit, effective October 1,2011, with an expiration date of June 31, 2016. The reissuance included the addition of Unit 2 operation. WBN received record of reissuance on September 1, 2011.

B. Air Permits

1. WBN is currently operating under Air Permit Number 448529 which expired on September 1, 2010. Continued operation under this permit is permissible since TVA submitted a 2010 Air Permit application on June 29, 2010. This application met the 60-day requirement prior to the permit's expiration date.

2. As required by WBN Air Permit Numbers 448529 and 957606P, WBN submitted the annual compliance status report, including supporting documentation, for the CY 2010 on March 30, 2011. WBN emitted 0.22 tons of sulfur dioxide in CY 2010 and did not exceed 99.9 tons during any period of 12 consecutive months. WBN also emitted 9.39 tons of nitrogen oxides in CY 2010 and did not exceed 99.9 tons during any period of 12 consecutive months. Also provided were certifications that all shipments of #2 diesel fuel oil received at WBN for the CY 2010 met ASTM D975-90 specifications for ultra low sulfur content.

3. On September 13, 2011, WBN submitted an initial notification of Applicability of the National Emission Standards for Hazardous Air E-11

V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTIFICATIONS (continued)

Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources to the TDEC Division of Air Pollution Control.

4. WBN submitted a revised operating permit renewal application on July 29, 2011 to satisfy the TDEC Divisions of Air Pollution Control request to account for green house gas emissions, expressed as carbon dioxide equivalents. Also included in this revision were the necessary forms that describe a small carpenter shop with filter controls as this source was not included in the original application.

VI. CHANGES IN FACILITY DESIGN OR OPERATION In accordance with EPP Section 3.1, "Plant Design and Operation," facility design and operational changes were reviewed for potential effect on the environment as described below. A review of facility design and operational changes proposed from February 7, 2011, through February 6, 2012, was performed. Projects considered as having potential impact on the environment included those that:

• Could have caused waste stream generation/alteration.

• Required the acquisition/modification of permits.

• Involved the use of hazardous material.

• Required physical construction.

The review, performed in accordance with the guidelines of TVA's National Environmental Policy Act (NEPA) Program, documented that design and operational changes did not involve an unreviewed environmental question. The following criteria were used to identify those projects with a potential for environmental effects:

A. Waste stream generation/alteration Air, Hazardous Waste, Solid Waste, Polychlorinated Biphenyls, Asbestos, Wastewater B. Permit Acquisition/Modification NPDES, Air, Inert Landfill, Other (316b, 404, etc.)

C. Hazardous Materials Hazardous Materials that are environmentally unfriendly and are likely to generate a Resource Conservation and Recovery Act (RCRA) hazardous or Toxic Substances Control Act (TSCA) waste D. Physical Construction Involved Erosion/Sedimentation Effects, Transportation Effects, Noise Effects, Groundwater Effects, Surface Water Effects, Floodplain Effects, Wetland Effects, Prime Farmland Effects, Unique Natural Features Effects, Aquatic Ecology Effects, Terrestrial Ecology Effects, Protected Species Effects, Sensitive Habitat Effects, Visual Effects, Historical, Cultural and Archeological Effects, E-12

VI. CHANGES IN FACILITY DESIGN OR OPERATION (continued)

Changes in Site Land Use, and Controversy.

E. Special Tests There were no special tests conducted during this period that met the environmental impact criteria.

F. Temporary Alterations There were no temporary alterations conducted during this period that met the environmental impact criteria.

G. Design and Operational Changes Most of the design and operational changes conducted during this period did not meet the environmental impact criteria. There were 22 facility design and operational changes made during this report period with a potential impact on the environment. The appropriate environmental reviews were completed and all changes were found to be within the scope of existing environmental permits and in compliance with NEPA regulations. Those Categorical Exclusion Checklists (CECs) written to document the site changes reviewed are as follows:

(1) 23832 U1R10 Special Project Trailers (2) 24011 WBN DCN-54521 Passive Underground Pathways (3) 24462 Plant Beautification Project (4) 24592 Insulation, Coatings and Thermal Lag (5) 24599 Flag Pole (6) 24680 Tritiated Water Storage Tank (7) 24714 Generic Site Beautification / Landscaping (8) 24763 Project/Crew Trailers to Support WBN Unit 2 Completion (9) 24916 Watts Bar Unit 2 Lay Down area for Insulation, Coatings and Thermal Lag (10) 24953 WBN U2 Laydown Area (11) 25033 WBC 5740 VLF Project (12) 25124 New WBN U2 Trailers By Cooling Towers (13) 25127 WBN U2 Trailer Relocation (14) 25130 WBN U2 Trailer Relocation (15) 25132 Trailer 79 Relocation (16) 25133 Dome Plugs (17) 25324 WBC 5716 Security Upgrade Project (18) 25335 WBN Main Control Room Chiller B Replacement DCN 53273 Rev A (19) 25349 Re-Coat Lube Oil Containment Liner/Design change for Fuel Oil Containment (20) 25353 Sealand Relocation (21) 25519 EP Siren Relocation (22) 25627 Soil Boring to Support Site Bunker Bldg. and Dry Cask Storage All other facility design and operational changes made during this report period with a potential impact on the environment were found to be within the scope of existing environmental permits and in compliance with regulations.

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VI. CHANGES IN FACILITY DESIGN OR OPERATION (continued)

In summary, there were no facility designs or operational changes from February 7, 2011 to February 6, 2012 resulting in an unreviewed environmental question.

VII. NON-ROUTINE REPORTS No non-routine reports for EPP Section 4.2 were issued during this reporting period.

VIII. CHANGES IN APPROVED ENVIRONMENTAL PROTECTION PLAN SPECIFICATIONS No changes were made to Appendix B, EPP, of the WBN operating license during the reporting period.

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