ML20343A254
| ML20343A254 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/03/2020 |
| From: | Marshall T Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML20343A254 (10) | |
Text
Tennessee Valley Authority, Sequoyah Nuclear Plant, P.O. Box 2000, Soddy Daisy, Tennessee 37384 December 3, 2020 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-001 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328
Subject:
Annual Non-Radiological Environmental Operating Report - 2020 The purpose of this letter is to submit the enclosed Sequoyah Nuclear Plant (SQN) 2020 Annual Non-Radiological Environmental Operating Report. The Tennessee Valley Authority is submitting this report in accordance with Section 5.4.1 of Appendix B, Environmental Technical Specifications (Non-Radiological), of the SQN, Units 1 and 2, Renewed Operating Licenses.
This report, which addresses the period from October 1, 2019, through September 30, 2020, is required to be submitted within 90 days following each anniversary of issuance of the operating licenses. Issuance dates for the SQN, Units 1 and 2, Operating Licenses were September 17, 1980, and September 15, 1981, respectively, indicating this report to be submitted no later than December 15, 2020.
There are no new regulatory commitments in this letter. Please direct questions concerning this report to Jeffrey Sowa, Site Licensing Manager, at (423) 843-8129.
Respectfully, Thomas B. Marshall Site Vice President Sequoyah Nuclear Plant
Enclosure:
Tennessee Valley Authority - Sequoyah Nuclear Plant Annual Non-Radiological Environmental Operating Report, October 1, 2019 through September 30, 2020 cc: See page 2
U.S. Nuclear Regulatory Commission Page 2 December 3, 2020 cc (Enclosure):
NRC Regional Administrator - Region II NRC Senior Resident Inspector - SQN NRR Project Manager - SQN Division of Radiological Health - State of Tennessee
ENCLOSURE Tennessee Valley Authority Sequoyah Nuclear Plant Annual Non-Radiological Environmental Operating Report October 1, 2019 through September 30, 2020
TABLE OF CONTENTS TABLE OF CONTENTS ................................................................................................................ 1 I INTRODUCTION ............................................................................................................... 2 II REPORTING FOR THOSE PROGRAMS NOT CONCERNED WITH WATER QUALITY OR PROTECTION OF AQUATIC BIOTA, WHICH ARE REGULATED BY THE CLEAN WATER ACT ..................................................................................................................... 2 III ENVIRONMENTAL MONITORING PERFORMED ........................................................... 3 IV REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE SQN NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT......................... 4 V ENVIRONMENTAL TECHNICAL SPECIFICATION (ETS) NONCOMPLIANCES ............ 5 VI CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMIT CERTIFICATIONS ............................................................................................................ 5 VII CHANGES IN FACILITY DESIGN OR OPERATION ........................................................ 5 VIII NON-ROUTINE REPORTS .............................................................................................. 6 IX SPECIAL STUDIES .......................................................................................................... 6 X CHANGES IN APPROVED ENVIRONMENTAL TECHNICAL SPECIFICATION ............. 7 E-1
I INTRODUCTION The Sequoyah Nuclear Plant (SQN) Annual Non-Radiological Environmental Operating Report for the period of October 1, 2019, through September 30, 2020, has been 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 non-compliances 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. Non-routine 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 impacts upon 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 2019 Summary of Asbestos Removal Projects - submitted to the Hamilton County Air Pollution Control Bureau on October 8, 2019 B. Annual Asbestos Removal Notification - submitted to Hamilton County Air Pollution Control Bureau on December 6, 2019.
C. Fourth Quarter 2019 Summary of Asbestos Removal Projects - submitted to the Hamilton County Air Pollution Control Bureau on January 8, 2020 D. Semi-Annual Auxiliary Boiler Fuel Report - submitted to the Hamilton County Air Pollution Control Bureau on January 8, 2020 E. Annual C&D Landfill Report - submitted electronically (via email) to Tennessee Department of Environment and Conservation (TDEC) on January 8, 2020 F. Tier Two Emergency and Hazardous Chemical Inventory - submitted to Soddy-Daisy Fire Department, Hamilton County Local Emergency Planning Commission, and the Tennessee Emergency Management Agency (electronically) on February 29, 2020 G. Annual Hazardous Waste Activity Report for 2019 - submitted to the Tennessee Department of Environment and Conservation on February 26, 2020 H. Sequoyah Nuclear Plant Hazardous Waste Minimization Plan - maintained on file at Sequoyah Nuclear Plant since February 5, 2020 I. First Quarter 2020 Summary of Asbestos Removal Projects - submitted to the Hamilton County Air Pollution Control Bureau on April 8, 2020 J. Sequoyah Nuclear Plant Annual Report on the Hours of Operation for diesel permitted equipment - submitted to the Hamilton County Air Pollution Control Bureau (electronically) on April 19, 2020 K. Notification for a New Special Waste Permit - submitted to Tennessee Department E-2
of Environment and Conservation on November 6, 2019 L. Forms A and R Toxic Chemical Release Information CY2019 Required by Emergency Planning and Community Right to Know Act - submitted to the Environmental Protection Agency [EPA] EPCRA Reporting Center and Tennessee Department of Environment and Conservation (electronically) on April 30, 2020 M. Written Annual Document Log of polychlorinated biphenyls (PCBs) and PCB Items for Calendar Year 2019 - maintained on file since June 3, 2020 N. Semi-Annual Auxiliary Boiler Fuel Report - submitted to the Hamilton County Air Pollution Control Bureau on July 14, 2020 O. Second Quarter 2020 Summary of Asbestos Removal Projects - submitted to the Hamilton County Air Pollution Control Bureau on July 9, 2020 P. Demolition Landfill Annual Maintenance Fee - submitted to Tennessee Department of Environment and Conservation on August 27, 2020 III ENVIRONMENTAL MONITORING PERFORMED A. Storm water samples collected 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 hazardous waste inspections conducted as required by 40 CFR 262 and by the Tennessee Rule Chapter 0400-12-01, Hazardous Waste Program G. Weekly landfill inspections performed as required by 40 CFR 258 and by the Tennessee Rule Chapter 0400-11-01, Solid Waste Processing and Disposal H. Monthly operational hours of Auxiliary Boilers A and B, Emergency Generators 1A, 1B, 2A, and 2B, Emergency Flex Generator Engines 3A and 3B, and Blackout Generators 1 and 2 as required by Federally Enforceable Certificate of Operation Nos. 4150-10200501-08C and 4150-20200102-11C I. Monthly operational hours of Auxiliary Boilers A and B, Emergency Generators 1A, 1B, 2A, and 2B, Emergency Flex Generator Engines 3A and 3B, and Blackout Generators 1 and 2, High Pressure Diesel Fire Pump, Security Backup Diesel Generator, I/S Diesel Generator, 225 KV Diesel Generators, and Communications Backup Diesel Generators as required by 40 CFR 63 J. Intake fore-bay 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 monthly to ensure compliance with Title VI of the Clean Air Act M. Waste sampling and characterization as required by 40 CFR 261 and by the Tennessee Rule Chapter 0400-12-01, Hazardous Waste Program N. Quarterly PCB transformer inspections as required by 40 CFR 761 (last PCB transformers removed in 2020)
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O. Asbestos removal tracking as required by the Hamilton County Air Pollution Control Bureau P. Hazardous waste minimization (such as chemical control and substitution) as required by the Tennessee Rule Chapter 0400-12-01, Hazardous Waste Program Q. National Environmental Policy Act (NEPA) reviews conducted to evaluate potential environmental impact of temporary or permanent facility modifications as required by 40 CFR 1500 R. EOC-1201-NPG-SQN(Water)-E - SQN Environmental Compliance S. Miscellaneous Media Reviews 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 and General Industrial Discharge Storm Water Permit No. TNR050015.
A. Monthly Discharge Monitoring Report (DMR) for September 2019 - submitted to Tennessee Department of Environment and Conservation on October 15, 2019.
B. Monthly Discharge Monitoring Report for October 2019 - submitted to Tennessee Department of Environment and Conservation on November 12, 2019 C. 2019 Annual Stormwater Monitoring Report (SW-1, SW-16, SW-17), submitted to the Tennessee Department of Environment and Conservation on November 20, 2019.
D. Monthly Discharge Monitoring Report for November 2019 - submitted to Tennessee Department of Environment and Conservation on December 9, 2019 E. Biocide/Corrosion Treatment Plan update submitted to Tennessee Department of Environment and Conservation on December 19, 2019.
F. Monthly Discharge Monitoring Report for December 2019 - submitted to Tennessee Department of Environment and Conservation on January 8, 2020 G. 2019 Biocide/Corrosion Treatment Plan (B/CTP) Annual Report - submitted to Tennessee Department of Environment and Conservation on January 24, 2020 H. Monthly Discharge Monitoring Report for January 2020 - submitted to Tennessee Department of Environment and Conservation on February 5, 2020 I. 2020 Annual Stormwater Monitoring Report (SW-4, SW-16, SW-17), submitted to the Tennessee Department of Environment and Conservation on February 19, 2020.
J. Water Withdrawal Registration Forms - submitted to Tennessee Department of Environment and Conservation on February 7, 2020 K. Monthly Discharge Monitoring Report for February 2020 - submitted to Tennessee Department of Environment and Conservation on March 4, 2020 L. Monthly Discharge Monitoring Report for March 2020 - submitted to Tennessee Department of Environment and Conservation on April 7, 2020 M. Monthly Discharge Monitoring Report for April 2020 - submitted to Tennessee Department of Environment and Conservation on May 14, 2020 N. Monthly Discharge Monitoring Report for May 2020 - submitted to Tennessee Department of Environment and Conservation on June 10, 2020 O. Monthly Discharge Monitoring Report for June 2020 - submitted to Tennessee Department of Environment and Conservation on July 14, 2020 P. Monthly Discharge Monitoring Report for July 2020 - submitted to Tennessee Department of Environment and Conservation on August 13, 2020 Q. Monthly Discharge Monitoring Report for August 2020 - submitted to Tennessee E-4
Department of Environment and Conservation on September 11, 2020 R. Biocide/Corrosion Treatment Plan update submitted to Tennessee Department of Environment and Conservation on September 29, 2020.
V ENVIRONMENTAL TECHNICAL SPECIFICATION (ETS) NONCOMPLIANCES None.
VI CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMIT CERTIFICATIONS A. Notice of Coverage (NOC) under General Multi-Sector Permit for Storm Water Associated with Industrial Activities, Permit No. TNR050015, also known as Tennessee Multi-Sector Permit (TMSP), was issued on July 20, 2020. There were no changes to the existing general permit, and the issuance of the NOC essentially extended the sites coverage under the TMSP general permit for an additional two years. The coverage extension will allow TDEC to review and adopt changes following the issuance of EPAs proposed Multi-Sector General Permit in 2020.
B. NPDES renewal permit TN0026450 was issued effective on August 1, 2020.
Significant changes include the following:
Changes in monitoring requirements at Outfall 101, including reduced Total Residual Chlorine monitoring, increase in toxicity limit, and the addition of monitoring of PCBs.
Reduction in sampling frequency for pH, oil and grease, and total suspended solids at Outfall 103.
Addition in sampling for pH, oil and grease, total suspended solids, copper, and iron at Outfall 107.
Change in definition for weekly monitoring.
Requirements to satisfy 316(b) regulations for cooling water intake structures.
VII CHANGES IN FACILITY DESIGN OR OPERATION In accordance with ETS 5.3.C, facility design and operational changes were reviewed for potential effect on the environment. These reviews are completed per Tennessee Valley Authority Instruction IX Environmental Review in compliance with the National Environmental Policy Act and with TVAs Environmental Management System (EMS) procedure.
A. Tests and Experiments There were no tests or experiments conducted during this period that had an unreviewed environmental question of significant impact.
B. 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 E-5
permits and in compliance with environmental regulations. Those changes reviewed are as follows:
Environmental Assessments None.
Categorical Exclusion Checklists (CEC)
CEC 42713 - SQN Unit 1 and Unit 2 Digital Electro Hydraulic Controls (EHC)
(FP614224 and FP614225) - This project will replace existing cabinets (1 each unit) in the Unit 1 and Unit 2 Auxiliary Instrument Rooms and replace the control panels (2) in the Unit 1 and Unit 2 Main Control Room (MCR). Some small instrumentation will be added to the low pressure turbine of each unit. The new cabinets in the Auxiliary Instrument Room will be marginally larger than the existing cabinets. The control panel changes in the MCR are near identical in appearance. The Main Turbine EHC at SQN are obsolete and include multiple Single Point Vulnerabilities (SPVs) relating to obsolete parts. This obsolescence and aging is decreasing equipment reliability and has resulted in plant trips. The Project objective is to replace the Analog Electro Hydraulic system with a new Digital Electro Hydraulic (DEH) system to address the SPVs, increase redundancy, and increase reliability of the Turbine controls system.
CEC 41999 - Demolition and removal of the Overlook Building at Sequoyah Nuclear Plant. In support of the TVA valley wide effort to reduce under utilized space, the 1980s era Overlook building at SQN site was removed to slab and disposed offsite. TVA concluded that a categorical exclusion, associated with 18 CFR Part 1318 Subpart C, Appendix A Item 37, for this action would not have a significant impact on the environment and that no extraordinary circumstances exists.
In summary, there were no facility designs or operational changes from October 1, 2019 through September 30, 2020, which resulted in a significant environmental impact or change to the findings of the FES. The CECs are maintained in an electronic database.
Note that TVAs NEPA procedures have been updated. The new procedures were published in the Federal register on March 27, 2020 and went into effect April 2020. Under the revised procedures, TVAs list of Categorical Exclusions (CEs) was expanded from 38 to 50 CEs.
VIII NON-ROUTINE REPORTS None.
IX SPECIAL STUDIES None.
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X CHANGES IN APPROVED ENVIRONMENTAL TECHNICAL SPECIFICATION There were no changes in approved ETSs during this period.
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