PNP 2019-019, Annual Non-Radiological Environmental Operating Report
| ML19086A037 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/26/2019 |
| From: | Hardy J Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PNP 2019-019 | |
| Download: ML19086A037 (7) | |
Text
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- ~ Entergy PNP 2019-019 March 26, 2019 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Jeffery A. Hardy Regulatory Assurance Manager
Subject:
2018 Annual Non-Radiological Environmental Operating Report Palisades Nuclear Plant Docket 50-255 Renewed Facility Operating 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 2018. This report was prepared in accordance with the PNP Renewed Facility Operating License, Appendix S, section 5.4.1. The attached report describes the implementation of the Environmental Protection Plan from January 1, 2018, through December 31, 2018.
This letter contains no new commitments and no revisions to existing commitments.
Respectfully, JAH/bed
Attachment:
- 1. 2018 Annual Non-Radiological Environmental Operating Report
- 2. Herbicide and Pesticide Treatments cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
ATTACHMENT 1 2018 ANNUAL NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT
1.0 BACKGROUND
Appendix B 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, 2018, through December 31, 2018.
The PNP operated for 6,906.45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> and produced a net total of 5,455,944 MWHe during 2018. This represents 77.2% of the net demonstrated capacity of the design electric rating of 805 MWe.
2.0 ENVIRONMENTAL IMPACT EVALUATIONS During 2018 there were no significant changes that warranted new Environmental Reviews per Entergy Nuclear Operations, Inc. (ENO) procedure, EN-EV-115, "Environmental Reviews and Evaluations." There were two projects that underwent the Environmental Review process in accordance with EN-EV-115 during 2018. The two Engineering Changes are as follows:
Engineering Change, EC-76698 was performed to modify two of the storm water catch basins near the support building. The existing catch basins, Catch Basin (CB) South of the security building and the CB Northeast of the support building, were excavated and removed. The new dual catch basins/pipe barriers were constructed, installed in the same locations, and tied into the existing storm drain lines so the existing flow path was maintained. The modification does not impact the area of land that storm water runs over to the storm drain, nor does the storm water discharge to a different outfall. The EC and work was completed in 2018.
Engineering Change, EC-74489 was performed to install a cathodic protection system with five deep well anodes surrounding the site. The construction of each deep anode involved excavating (by vacuum truck) a well 300 feet deep and 11 inches in diameter. The excavation hole was backfilled and then topped with 5.5 foot square concrete pad on which an electrical junction box was installed. Buried cable was also run to the junction box. The state of Michigan deemed that a critical dune permit was not required due to the work temporarily impacting areas already under existing use. The EC and work was completed in November 2018.
In 2017, an EC for NFPA 805 was reviewed for environmental impacts (and submitted with the 2017 report). The excavation portions of the NFPA 805 project were completed in 2018 with no challenges or environmental impacts.
There were no additional changes, tests, or experiments that involved un-reviewed environmental questions or EPP changes.
Page 1 of 2
3.0 ADDITIONAL ACTIVITIES AUTHORIZED UNDER NPDES PNP received National Pollutant Discharge Elimination System (NPDES) permit approvals to use three new chemicals in applications that will impact discharge streams. The first was for the continuous addition of an anti-scalant, (GenGARD GN8020), to the turbine building sump to address the calcium carbonate issues that were impacting the sump pump's ability to perform its designed function.
The other two chemicals are associated with the operation of the new reverse osmosis unit that is currently being installed. One is a detergent (KLEEN MCT503) and was approved based on the discharge concentrations and frequency (no more than twice a year). The detergent will be used for cleaning the reverse osmosis unit membranes. The second chemical associated with the new reverse osmosis unit (Hypersperse MDC714) is an anti-scalant that is used continuously during the operation of the reverse osmosis unit.
In-accordance with MDEQ requirements, a NPDES permit application renewal was applied for and verified as being received by the State of Michigan prior to required due dates. Palisades' new NPDES permit has not been received from the State of Michigan at this time; however, by submitting by the required due date, in accordance with the process, PNP is still covered under the old NPDES permit. No changes at this time are expected to the permit with the exception of the recently approved discharge chemicals for the turbine sump and the operation of the new reverse osmosis unit.
The Air Operating Permit renewal application package was submitted and received by the State of Michigan prior to the required due date in accordance with Article II, Chapter 1, Part 55 (Air Pollution Control) of P.A.451 of 1994 and the federal Clean Air Act of 1990. PNP has received the new approved Air Operating Permit.
No additional activities were authorized under the NPDES permit.
4.0 UNUSUAL ENVIRONMENTAL EVENTS No unusual environmental events occurred during 2018.
5.0 ENVIRONMENTAL MONITORING TruGreen treated areas of the property for vegetation management during 2018. Rose Pest Solutions treated areas of the property for tick and pest control. Herbicides were not applied to the transmission line exit corridor in 2018. The application of herbicides and pesticides is documented in Attachment 2.
6.0 NON-ROUTINE REPORTS During 2018, no non-routine reports were generated.
Page 2 of 2
ATTACHMENT 2 HERBICIDE & PESTICIDE TREATMENTS Company:
TruGreen 9077 Portage Industrial Portage, Michigan 49024-9935 Date of Treatment: May 19, 2018 May 19, 2018 May 24,2018 July 12, 2018 July 12, 2018 July 13, 2018 September 5, 2018 September 5, 2018 October 5,2018 October 5,2018 November 7,2018 (495 pounds applied)
(.08 gallons applied)
(2.84 gallons applied)
(495 pounds applied)
(0.92 gallons applied)
(2.84 gallons applied)
(495 pounds applied)
(0.46 gallons applied)
(495 pounds applied)
(0.08 gallons applied)
(495 pounds applied)
- Liquid volumes are the active chemicals used and do not include the dilution water.
Commercial Names of Products in Solution: Tru Power 3, Razor Pro, Dimension, tripower Chemical Names of Products:
Tru power 3-Triisopropanolamine Salt of 2, 4-Dichlorophenoxyacetic Acid, Dimethylamine Salt of (+)-R-2-(2-Methyl-4-Chlorophenoxy) propionic acid, Dicamba Acid Razor Pro: -Glyphosate, N(phosphonomethly) glycine, in the form of its isoprophlamine salt, Ethoxylated Tallowamines Dimension - Dimethyl 2-(difluoromethyl)-4-(2-methylpropyl)-6-(trifluoromethyl)-3,5-pyrid ined icarboth ioate)
Tripower: Dimethyliamine salt of 2-methyl4-chloicophenoxy acid, Dimethalyne salt of
(+ )-R-2-(2-methl-4-chlorophynoxy)proprionic acid, Dimethylamine salt of Dicamba (3,6-Dichloro-o-anisic acid) 17-0-5 All Mineral: Urea Nitrogen, Potassium 25-0-8: Urea based fertilizer mix, granular nitrogen and potassium Page 1 of 4
Concentration of Active Ingredient in Field Use Mix:
One solution was mixed together that contained the following:
50 oz. per 44 gallons per acre (Tru power 3) applied to 3.75 acres Diluting Substance: Water for wet applications No dilutions for dry applications Rate of Application: 44 gallons per acre liquid application (Tru power 3, Tripower, Dimension, Razor Pro) 132 Ibs per acre applied of dry fertilizer Total Amount Used:
7.22 Gallons total volume used for liquid treatment*
24,775 Pounds total volume used for dry treatment
- Liquid volumes are the active chemicals used and do not include the dilution water.
Method of Application: Hand sprayer for liquids Broadcast spreader for dry application Frequency of Application: Throughout 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 broad leaf vegetation Page 2 of 4
Company:
Rose Pest Solutions 2714 South 11 th St. Ste B Niles, Michigan 49120-4420 Date of Treatment: Feb 19, 2018 Feb 26,2018 Mar 20,2018 Mar 21,2018 Mar 26,2018 April 12, 2018 April 23, 2018 May 3, 2018 May 14, 2018 June 8,2018 June 11, 2018 June 25, 2018 July 5,2018 July 9,2018 July 9,2018 July 23, 2018 Aug 7,2018 Aug 13,2018 Aug 27,2018 Sept 10, 2018 Sept. 10,2018 Sept 12,2018 Sept. 24, 2018 Oct. 08, 2018 Oct. 08, 2018 Oct. 22, 2018 Nov. 12,2018 Dec. 10,2018 Dec. 28, 2018 (20 grams applied)
(240 grams applied)
(40 grams applied)
(100 grams applied)
(100 grams applied)
(9 gallons applied)
(240 grams applied)
(4 gallons applied)
(240 grams applied)
(3.5 gallons applied)
(240 grams applied)
(300 grams applied)
(4.5 gallons applied)
(185 grams applied)
(5.5 gallons applied)
(160 grams applied)
(4 gallons applied)
(220 Grams applied)
(300 Grams applied)
(140 grams applied)
(3 gallons applied)
(3.5 gallons applied)
(200 grams applied)
(260 grams applied)
(4 gallons applied)
(440 grams applied)
(180 grams applied)
(100 grams applied)
(120 grams applied)
Commercial Names of Products in Solution: Final all-Weather Blox and OvoControl P Chemical Names of Products:
Final AW Blox - Brodifacoum [3-[3-(4'-Bromo-[1, 1'-biphenyl]-4-yl)-1,2,3,4-tetrahydro-1-naphthalenyl]-4-hyd roxy-2H-1-benzopyran-2-one]
OvoControl P - Nicarbazine [4,4'-Dinitrocarbanilide and 2-Hydroxy-4,6-dimethyl pyrimidine]
Page 3 of 4
Talstar Pro - Bifenthrin (2-methyl [1, 1'-biphenyl]-3-yl)methyl 3-(2-chloro-3,3,3-trifluoro-1-propenyl)-2,2-dimethylcyclopropanecarboxylate Onslaught Microencapsulated 1- (S)-cyano(3-phenoxyphenyl)methyl-(S)-4-chloro-alpha-( 1-methylethyl)benzeneacetate Maxforce FC Select Roach Killer Bait Gel - Fipronil: 5-amino-1-[2,6-dichloro (trifluoromethyl)phenyl] (trifluoromethylsulfinyl)-1 H-pyrazole-3-carbonitrile Concentration of Active Ingredient in Field Use Mix:
One solution was mixed together that contained the following:
1.00 fluid oz. of the chemicals per gallon of water Diluting Substance: No dilutions for dry applications Total Amount Used (active ingredient amounts):
40 Gallons total volume used for liquid treatment 3925 Grams total volume used for dry treatment 500 pounds total volume for OvoControl Method of Application:
Hand sprayer for liquids Bait Station Installation for dry application Frequency of Application: Throughout the year as needed Location: Along and near roadways, fence lines, walkways, and the protected area.
Purpose of Treatment: Tick, Mice and Roach control; and OvoControl P for reducing the pigeon egg hatch on site.
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