ML14126A010

Annual Environmental Operating Report

ML14126A010
Person / Time
Site:	Wolf Creek
Issue date:	04/25/2014
From:	Westman M Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA 14-0037
Download: ML14126A010 (14)

Text

W9LF CREEK NUCLEAR OPERATING CORPORATION Michael J. Westman Manager Regulatory Affairs April 25, 2014 RA 14-0037 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482: 2013 Annual Environmental Operating Report Gentlemen:

The purpose of this letter is to submit the enclosed Annual Environmental Operating Report, which is being submitted pursuant to Wolf Creek Generating Station (WCGS) Renewed Facility Operating License NPF-42, Appendix B, "Environmental Protection Plan." This report covers the operation of WCGS for the period of January 1, 2013, through December 31, 2013.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4009, or Mr. William Muilenburg at (620) 364-4186.

Sincerely, Michael J. Westman MJW/rlt

Enclosure:

2013 Annual Environmental Operating Report cc: M. L. Dapas (NRC), w/e C. F. Lyon (NRC), w/e N. F. O'Keefe (NRC) w/e Senior Resident Inspector (NRC), w/e P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 2-5 An Equal Opportunity Employer M/F/HC/VET

Enclosure to RA 14-0037 Wolf Creek Generating Station Annual Environmental Operating Report 2013 (12 pages)

WOLF CREEK GENERATING STATION ANNUAL ENVIRONMENTAL OPERATING REPORT 2013 ENVIRONMENTAL MANAGEMENT ORGANIZATION WOLF CREEK NUCLEAR OPERATING CORPORATION P.O. BOX 411 BURLINGTON, KANSAS 66839

TABLE OF CONTENTS 1.0 IN T R O D UC T IO N ........................................................................................... .. 3 2.0 ENVIRONMENTAL MONITORING ................................................................. 3 2.1 AQUATIC [Environmental Protection Plan (EPP) Section 2.1] ...... 3 2.1.1 Impacts of Water Withdrawal on the Neosho River ................. 3 2.1.2 Oxidizing Biocide Discharges to Coffey County Lake ............. 4 2.1.3 C old S hock .......................................................................... .. 5 2.1.4 Impingement and Entrainment ................................................ 5 2.1.5 Impacts of Coffey County Lake Discharges ............................ 5 2.2 TERRESTRIAL [EPP Section 2.2] ...................................................... 6 2.2.1 Control of Vegetation in the Exclusion Zone ........................... 6 2.2.2 Vegetation Buffer Zone Surrounding Coffey County Lake ..... 6 2.2.3 Herbicide Use for Maintenance of WCGS Structures ............. 6 2.2.4 Waterfowl Disease Contingency Plan and Monitoring ............ 7 2.2.5 Fog Monitoring Program [EPP Subsection 4.2.1] .................... 7 2.2.6 Wildlife Monitoring Program [EPP Subsection 4.2.2] ............... 7 2.2.7 Land Management Program [EPP Subsection 4.2.3] ............. 8 3.0 ENVIRONMENTAL PROTECTION PLAN REPORTING REQUIREMENTS ........ 8 3.1 PLANT DESIGN OR OPERATION CHANGES [EPP Section 3.1] ..... 8 3.2 NON-ROUTINE ENVIRONMENTAL REPORTS ................................. 10 3.2.1 Submitted Non-routine Reports ............................................. 10 3.2.2 Unusual or Important Environmental Event Evaluations ...... 10 4.0

SUMMARY

OF ENVIRONMENTAL INVESTIGATIONS AT WOLF CREEK G EN ERA TING STA TIO N................................................................................ 11 4.1 2013 LAND MANAGEMENT ACTIVITIES .......................................... 11 4.2 2013 ZEBRA MUSSEL MONITORING ACTIVITIES ........................... 11 4.3 2013 FISHERY MONITORING ACTIVITIES ....................................... 11 2

1.0 INTRODUCTION

The 2013 Annual Environmental Operating Report is being submitted in accordance with the objectives of the Environmental Protection Plan (EPP), Appendix B to the Facility Operating License NPF-42. The purpose of this report is to demonstrate that the Wolf Creek Generating Station (WCGS) operated during 2013 in a manner protective of the environment.

2.0 ENVIRONMENTAL MONITORING 2.1 AQUATIC [EPP Section 2.1]

2.1.1 Impacts of Water Withdrawal on the Neosho River There were no adverse impacts to the Neosho River due to water-use conflicts because river flows downstream of the makeup pumps were maintained during 2013. The WCGS Final Environmental Statement/Operating License Stage (FES/OLS, Section 5.6), NUREG-0878, postulated that makeup water withdrawal of 41 cubic feet per second (cfs) during drought conditions would extend the duration and severity of low-flow conditions below John Redmond Reservoir (JRR). This, in turn, was expected to reduce riffle habitat that would adversely affect the Neosho madtom, a federally listed threatened species.

Actual makeup water withdrawals during 2013 are summarized as follows:

Average Average River Duration Pump Rate Flow at Pump Source Period (days) (cfs) (cfs) (1)

Neosho River VI 5/11 to 5/30/13 20 114 446 8/1 to 8/3/13 3 121 718 11/4 to 11/30/13 27 111 679 JRR Storage 4/25 to 4/28/13 4 83 139 4/30 to 5/10/13 11 110 164 7/31/13 1 47 155 8/4/13 1 69 193 (1) Flow measured at JRR spillway discharge.

(2) Before natural flows from the Neosho River are permitted by the Kansas Department of Agriculture, Division of Water Resources to be pumped, a 250 cfs minimum must be maintained downstream of the pumps. Otherwise makeup water is considered to be from JRR storage.

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As shown above, average pump rates were less than average river flows measured at the JRR spillway, immediately upstream of the pumps at the Makeup Water Screenhouse (MUSH). This demonstrates that downstream flows were maintained. In addition, of the 67 days makeup pumps were operated, 50 were during periods of higher river flow.

For comparison purposes, the 41 cfs assessed in the FES/OLS refers to a continuous annual average from JRR storage. Combining the four pumping periods, the actual 2013 pumping from JRR storage averaged 98 cfs for 17 days, which was equivalent to 5 cfs, when calculated on a similar, annual basis. This flow rate was lower than the 41 cfs evaluated as impacting the Neosho River during drought conditions.

Consequently, makeup pumping activities did not impact flows intended to maintain minimum desirable stream flows in the Neosho River, and no adverse impacts due to water-use conflicts occurred during 2013.

2.1.2 Oxidizing Biocide Discharges to Coffey County Lake (CCL)

Circulating Water System (CWS) Discharge:

There were no adverse impacts observed due to biocides during 2013. Biocide use at WCGS was predicted to cause periodic, appreciable mortality in a conservatively estimated 40 acres of the discharge area to CCL. However, these impacts were not expected to meaningfully affect the overall biological productivity of the lake (FES/OLS, Section 5.5.2.2). The postulated biocide levels expected to cause the impacts were from 0.68 to 1.08 mg/I of total residual chlorine at the CWS discharge (FES/OLS, Section 4.2.6.1).

Actual biocide use during 2013 averaged 0.07 mg/I total residual oxidant (TRO).

This level was much lower than those evaluated in the FES/OLS, thus impacts were considered to be correspondingly less. The Kansas Department of Health and Environment (KDHE) also requires, through the WCGS National Pollutant Discharge Elimination System (NPDES) permit, that biocide discharges for the CWS be less than 0.2 mg/I TRO, for a maximum of two hours per day.

Consequently, biocide impacts to CCL have been less than initially evaluated in the FES/OLS, and NPDES compliance assures that this will continue.

Essential Service Water System (ESWS) Discharge:

Flow from the WCGS Service Water System (SWS) diverted through the Essential Service Water System (ESWS) was completed to provide microbiologically induced corrosion protection and sedimentation control. The KDHE established a 1.0 mg/I TRO limit for the SWS diversion through the ESWS. Actual measurements of TRO averaged 0.26 mg/l. Based on this information, permitted biocide discharges did not have appreciable effects on the cooling lake environment.

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2.1.3 Cold Shock In the event of a rapid decline in plant power level during winter, fish attracted to the WCGS heated discharge could experience mortality due to a quick reduction in body temperature (cold shock). In reference to licensing document evaluations, the WCGS EPP Section 2.1 (c) states, "Cold shock effects on fish due to reactor shutdowns could cause significant mortality to aquatic species in the cooling lake."

Fish mortality due to cold shock was not observed in CCL following declines in plant power level. Five such plant shutdowns or power level decreases occurred as follows:

Date Duration (days) 2/4 to 4/16/13 71.2 4/29 to 5/2/13 2.5 5/6 to 5/13/13 6.7 9/12 to 9/30/13 18.7 10/18 to 10/28/13 9.7 Fish mortality was not observed following the plant power changes.

Consequently, significant impact to the fishery in CCL due to cold shock events did not occur.

2.1.4 Impingement and Entrainment Impacts of entrainment and impingement of fish and aquatic organisms due to WCGS cooling water pumping were projected to be significant, as indicated in the WCGS EPP, Section 2.1 (d). EPP Section 2.1 states that the NRC relies on the State of Kansas for determination of the need for monitoring entrainment and impingement impacts. The KDHE requested WCGS to monitor impingement impacts for the Clean Water Act (CWA) 316 (b), Phase II regulations. This monitoring has been completed, and results have been submitted to the KDHE.

Entrainment monitoring has not been required. No significant adverse impacts to the CCL fishery were identified because of impingement. Fishery management at WCGS has succeeded in controlling impingement, and minimizes potential impacts of impingement to the fishery.

2.1.5 Impacts of Coffey County Lake Discharges to the Neosho River The WCGS NPDES permit requires that CCL discharges be sampled on the first day of each discharge and weekly thereafter until the end of each respective discharge. A discharge limit was set for pH (NPDES Outfall 004). Lake discharges typically can occur at the Blowdown Spillway and Service Spillway.

During 2013, no discharges occurred at the Blowdown Spillway. There were no NPDES violations from discharges from the Service Spillway, and no detrimental effects were expected to the Neosho River water quality.

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2.2 TERRESTRIAL [EPP Section 2.2]

2.2.1 Control of Vegetation in the Exclusion Zone The composition and structure of vegetation in the 453 hectare (1120 acre) exclusion zone were selectively controlled to be compatible with the function and security of station facilities. Most areas in the immediate vicinity of the power block typically have been planted and maintained in a lawn-type condition. Other areas within the exclusion area have been mowed for security and aesthetic purposes. Tree and brush control occurred in some areas.

Various maintenance and construction activities during 2013 have caused temporary impacts to the vegetation in many areas surrounding WCGS. As projects are completed, restoration of the areas involved is expected to return the vegetation in the exclusion zone similar to previous conditions.

2.2.2 Vegetation Buffer Zone Surrounding Coffey County Lake To create a buffer zone of at least 500 acres around CCL, as specified in EPP Section 2.2 (b), agricultural production activities were curtailed in 1980 within a border ranging from approximately 200-400 feet adjacent to the lake shoreline.

This area is approximately 1440 acres. Previously grazed or hayed native grass areas were left undisturbed. Previously cultivated lands were allowed to advance through natural succession stages, or native grasses were established in these areas. Land management activities included controlled burning to enhance and/or maintain the designated buffer zone with a naturally occurring biotic community.

2.2.3 Herbicide Use for Maintenance of WCGS Structures Herbicides were used on transmission corridors, gravel areas, railroad easements, and various land areas associated with WCGS. Application rates followed label instructions. No environmental impacts from herbicide treatment of WCGS facilities were identified. A summary of herbicide application is provided below.

The transmission lines associated with WCGS include the Wolf Creek-Rose Hill and a small portion of the Wolf Creek-Benton and Wolf Creek-La Cygne lines.

Herbicide treatment of the Wolf Creek-Rose Hill corridor was completed during 2013. Herbicides included a mix of Tordon K (EPA Reg No 62719-17), Garlon 3A (EPA Reg No 62719-37), and Escort (EPA Reg No 352-439). In areas adjacent to water bodies, a mix of Habitat (EPA Reg No 241-426) and Accord (EPA Reg No 62719-517) was used.

In areas where bare-ground control was desired, Karmex DF (EPA Reg. No 352-508), Oust (EPA Reg. No. 352-401), or Sahara DG (EPA Reg. No. 241-372) herbicides were used. Roundup Ultra (EPA Reg. No 524-475), or comparable substitute, was also used for problem weed areas. These herbicides were used 6

on various gravel areas, including the switchyard, protected area boundary, meteorological tower, storage tank berms, railroad beds, and storage yards.

Noxious weed and nuisance tree/brush growth were controlled with Tordon RTU (EPA Reg. No. 62719-31), Remedy (EPA Reg. No. 62719-70), Weed Pro 2,4-D (EPA Reg. No. 10107-31), and Roundup Ultra. Areas treated included the dam, railroad easements, and selected grassland areas around the cooling lake.

2.2.4 Waterfowl Disease Contingency Plan and Monitoring A waterfowl disease contingency plan was maintained to provide guidance for station biologists in the event of suspected or actual disease outbreaks. The contingency plan lists appropriate federal and state wildlife agency contacts to be made by Wolf Creek Nuclear Operating Corporation (WCNOC) in the event of such problems. During routine environmental monitoring and surveillance activities taking place over this reporting period, no waterfowl mortality attributable to disease pathogens was identified.

2.2.5 Fog Monitoring Program [EPP Subsection 4.2.1]

Fog monitoring concluded that operation of WCGS did not appreciably increase fogging incidents from that measured before operation. Visibility monitoring was initiated in December, 1983, and continued through 1987. The purpose of this study was to evaluate the impact of waste heat dissipation from CCL on fog occurrence along U.S. 75 near New Strawn, Kansas. The program was required through one year of commercial operation that started in September 1985. Upon conclusion of 1987 data collection, sufficient information was available to evaluate cooling lake fogging, and all commitments relevant to fog monitoring had been satisfied.

During 2013, there were no reports of fogging incidents in the vicinity of nearby U.S. 75 from individuals or local agencies responsible for traffic safety. Periodic fogging likely caused by the cooling lake did occur during the winter months of 2013, but was restricted to the plant site and immediate vicinity of the lake. No mitigation actions or further monitoring were warranted.

2.2.6 Wildlife Monitoring Program [EPP Subsection 4.2.2]

A wildlife monitoring program was initiated in 1982 to monitor and assess waterfowl, waterbird, and bald eagle usage of CCL. This program included transmission line collision surveys to assess collision mortality and determine potential mitigation needs. This wildlife monitoring program was to continue for at least two years following WCGS start-up (FES-OLS Section 5.5.1.2), which occurred in September 1985.

Transmission line surveys were conducted from 1983 through 1988. Monitoring of lake use by waterfowl, waterbirds, and bald eagles continued through 1996.

By then, sufficient data had been collected to determine waterfowl, waterbird, and bald eagle usage of CCL. Consequently, the scope of the wildlife monitoring 7

program was reduced. The current program consists of reviewing CCL waterfowl and bald eagle survey data collected by the Kansas Department of Wildlife, Parks and Tourism (KDWPT). If review of the KDWPT's data indicates that usage has increased from that previously documented, then additional monitoring may be initiated if warranted.

Review of waterfowl and bald eagle monitoring data for 2013 collected by the KDWPT indicate that waterfowl and waterbird usage was consistent with past years. Increased transmission line collision potential was not indicated. No disease outbreaks or widespread crop depredation attributable to waterfowl use of CCL were observed. No changes to the wildlife monitoring program were warranted.

2.2.7 Land Management Program [EPP Subsection 4.2.3]

Land management activities on all company-owned lands except within the 453 hectare (1120 acre) WCGS exclusion area were designed to achieve balances between agricultural production and conservation values. An annual management plan addressed needs and accepted techniques for land maintenance, soil conservation, and wildlife management. These included the repair or construction of soil conservation structures, wetland areas, and permanent vegetative covers. An environmental education area was improved and maintained as part of the land management program. The land management program continued to balance agriculture production and conservation values.

3.0 ENVIRONMENTAL PROTECTION PLAN REPORTING REQUIREMENTS 3.1 PLANT DESIGN OR OPERATION CHANGES [EPP Section 3.1]

Plant design or operational changes were evaluated for potential significant affects to the environment, the presence of which would constitute an unreviewed environmental question (UEQ) per the EPP. Evaluations completed during 2013 demonstrate that significant impacts to the environment would not occur, and that no changes constituted a UEQ. Below are brief descriptions of these evaluations completed in 2013.

1. Essential Service Water - Buried Piping Replacement Project Replacement of the underground ESWS piping was evaluated and determined not to involve a UEQ. Evaluations during 2013 complemented those completed in 2012 for the same ESW piping replacement project. Facets evaluated included excavation, material coatings, cathodic protection needs, chemical addition modifications, security generator addition, site oily waste separator replacement, and discharge structure needs. Environmental or regulatory interfaces that were identified and addressed included:

a. Temporary air emission source provisions, 8

b. Stormwater Pollution Prevention Plan (SWPPP) development, approval, and implementation,

c. U. S. Corp of Engineers Section 404 authorization,

d. Solid waste management,

e. NPDES compliance assurances,

f. Permanent air emission source permitting,

g. Spill Prevention Control and Countermeasure (SPCC) plan provisions,

h. Refrigerant Management System use,

i. Superfund Amendments and Reauthorization Act considerations,

j. Hazardous waste management,

k. Activities confined to areas designated as previously disturbed during WCGS construction, I. Work stop provisions in the event cultural, historical, or archeological resources are discovered.

Necessary environmental permits from state and federal agencies were acquired.

Implementation of protective practices required in the permits ensured potential environmental impacts were minimal. All regulatory aspects protective of the environment were identified, thus a UEQ was not present.

2. Security Generator for Radio Backup Power Installation of a generator to supply backup power for the Security radio system was evaluated and it was determined that a UEQ was not involved. Temporary air emission source tracking for construction was addressed. Permitting requirements from the KDHE for a permanent air emission source were addressed. The SPCC plan provisions were identified to include the new fuel storage tank. All environmental interfaces were accounted for, thus a UEQ did not exist.

3. Removal and Replacement of Buss Feeder Cables Replacement of buss feeder cables for auxiliary power systems was evaluated and a UEQ was not identified. Environmental interfaces involved with this project were tracking requirements for temporary air emission sources, and groundwater testing measures in the event subsurface water was encountered. Work packages and procedures controlled these interfaces, thus a UEQ did not exist.

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4. Station Blackout Diesel Generator Installation The installation of the Station Blackout Diesel Generators (SBO-DG) was evaluated and a UEQ was not identified. This project involved constructing generator enclosures with missile barriers, a power equipment center, transformers, and associated equipment. The environmental interfaces evaluated and addressed included tracking temporary air emission sources during construction, and acquiring KDHE permitting for permanent air emission sources. Above-ground fuel storage tank permitting, SPCC provisions, and SWPPP needs were addressed. Since all environmental permitting needs were identified, a UEQ was not present.

5. Main Generator Rebuild Rebuilding the main generator was evaluated and a UEQ was not identified.

Rebuilding included stator rewind, replacing current transformers, high voltage bushings, and hydrogen coolers. Environmental interfaces involved tracking needs for temporary air emission sources and proper disposal of hazardous waste generated. With these interfaces addressed, a UEQ did not exist.

6. Construct Pre-cast Concrete Buildings Constructing two pre-cast concrete buildings were evaluated and a UEQ was not identified. These buildings are to house equipment for the Diverse and Flexible Coping Strategy. Environmental interfaces included tracking needs for temporary air emission sources and SWPPP implementation. With these interfaces addressed, a UEQ did not exist.

3.2 NON-ROUTINE ENVIRONMENTAL REPORTS [EPP Section 5.4.2]

3.2.1 Submitted Non-routine Reports There were no environmental reports involving significant non-routine impacts submitted to the NRC during 2013.

3.2.2 Unusual or Important Environmental Event Evaluations

[EPP Section 4.1]

No unusual or important environmental events that indicated or resulted in a significant environmental impact related to plant operations occurred during 2013.

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4.0

SUMMARY

OF ENVIRONMENTAL INVESTIGATIONS AT WOLF CREEK GENERATING STATION 4.1 2013 LAND MANAGEMENT ACTIVITIES This document presents the land management program activities for 2013. The Environmental Protection Plan (EPP, Section 4.2.3), Appendix B to the Facility Operating License, requires a land management program that will balance production and conservation values. Beyond regulatory compliance, the land management program reflects Wolf Creek Nuclear Operating Corporation's dedication to proper stewardship of the natural resources.

The objectives of the Land Management Program are:

1. to conserve and/or improve both agricultural and natural resources;

2. to foster positive relationships with local and natural resource communities;

3. to enhance, for educational purposes, the natural resources on the Environmental Education Area;

4. to meet license requirements;

5. to maintain rent income while placing the higher priority on the above objectives.

Areas around the cooling lake's shoreline have been maintained in a naturally occurring biotic community to comply with Section 2.2(b) of the EPP. Some land areas have been maintained as wildlife habitat or reserved for educational purposes. The remainder of the land has been leased for grazing, hay, and crop production.

4.2. 2013 ZEBRA MUSSEL MONITORING ACTIVITIES This document presents 2013 monitoring results for zebra mussel presence and their potential impacts to water quality and aquatic vegetation within Coffey County Lake (CCL). Data are used to characterize the impacts, and allow for proactive measures to be taken to prevent challenges to WCGS. In addition, results are intended to enhance WCNOC responses to SOER 07-02 "Intake Cooling Water Blockage - Wolf Creek Nuclear Operating Corporation Review and Evaluation".

Zebra mussel populations were calculated to be as high as 206,667/M2 at the spillway.

Water clarity monitoring did not identify significant changes from 2012 that could be attributed to mussel density increases. Likewise, aquatic vegetation expansion was not detected during 2013. A vegetation density index was determined to compare future vegetation changes in an accurate and reproducible manner which will allow for proactive measures to be assessed before impacting cooling water use. Finally, concurrent nutrient and eutrophication data summaries were collected so that future zebra mussel impacts to the ecology of the lake can be assessed.

4.3 2013 FISHERY MONITORING ACTIVITIES This report presents the results of fishery monitoring activities on CCL and documents long-term trends. The fishery has functioned as desired through 2013 with the management goal to increase WCGS operating efficiency by reducing the potential for 11

excessive gizzard shad young-of-year impingement on the Circulating Water System intake screens. Shad impingement problems to date have not occurred due largely to the characteristics of the current fishery.

Public use of the fishery is also important to maintain community relations and local economic benefits. Consequently, maintaining and/or enhancing public enjoyment of the fishery that is compatible with the shad impingement control are other important goals of this program. Creel and length limits were determined jointly with the KDWPT.

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