RA-20-0138, Annual Environmental (Non-Radiological) Operating Report for 2019

Annual Environmental (Non-Radiological) Operating Report for 2019

ML20121A177
Person / Time
Site:	Harris
Issue date:	04/30/2020
From:	Riley K Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0138
Download: ML20121A177 (8)

Text

Kevin P. Riley Nuclear Support Services Manager Harris Nuclear Plant 5413 Shearon Harris Rd New Hill, NC 27562-9300 984.229.2124 April 30, 2020 Serial: RA-20-0138 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63

Subject:

Annual Environmental (Nonradiological) Operating Report Ladies and Gentlemen:

In accordance with Section 5.4.1 of the Environmental Protection Plan, issued as Appendix B to the Renewed Operating License (NPF-63) for the Shearon Harris Nuclear Power Plant, Unit 1, Duke Energy Progress, LLC, is providing the enclosed Annual Environmental (Nonradiological)

Operating Report for 2019.

This submittal contains no regulatory commitments. Should you have any questions regarding this submittal, please contact Dennis Earp at (984) 229-2673.

Sincerely, Digitally signed by Kevin Kevin Riley Riley Date: 2020.04.30 06:51:33

-04'00' Kevin P. Riley Enclosure cc: J. Zeiler, NRC Senior Resident Inspector, HNP T. Hood, NRC Project Manager, HNP L. Dudes, NRC Regional Administrator, Region II

Duke Energy Progress, LLC Shearon Harris Nuclear Power Plant Unit 1 ANNUAL ENVIRONMENTAL (NONRADIOLOGICAL)

OPERATING REPORT January 1, 2019 through December 31, 2019 Renewed Facility Operating License No. NPF-63 Appendix B Docket No. 50-400

1.0 INTRODUCTION

Duke Energy Progress, LLC (previously known as Duke Energy Progress Inc., Progress Energy Carolinas, Inc. and Carolina Power & Light Company) received a low-power Facility Operating License (No. NPF-53) and full-power Facility Operating License (No.

NPF-63) for the Shearon Harris Nuclear Power Plant, Unit 1, from the U.S. Nuclear Regulatory Commission (NRC) on October 24, 1986, and January 12, 1987, respectively. The NRC issued a Renewed Facility Operating License (No. NPF-63) on December 17, 2008, extending operations until October 24, 2046. Appendix B (the Environmental Protection Plan (EPP) [Nonradiological]) of the renewed operating license requires submittal of an Annual Environmental (Nonradiological) Operating Report to the NRC describing the implementation of the plan during the previous year. The purpose of this document is to fulfill the requirement for the period January 1 through December 31, 2019.

On September 18, 2015, The North Carolina Department of Environment and Natural Resources (NCDENR) officially became the North Carolina Department of Environmental Quality (NCDEQ) when Governor McCrory signed the 2015-2016 state budget into law. NCDEQ will be used in this report.

2.0 PLANT CONSISTENCY REQUIREMENTS [EPP Section 3.0]

2.1 Plant Design and Operation There were no changes in plant design or operation and there were no tests or experiments performed which involved a potentially significant unreviewed environmental question during the reporting period.

2.2 Reporting Related to the NPDES Permit As required by National Pollutant Discharge Elimination System (NPDES) permit NC0039586, monitoring data was submitted to the North Carolina Department of Environmental Quality (NCDEQ) via monthly discharge monitoring reports and separate correspondence as warranted.

The renewed NPDES permit NC0039586 became effective on September 1, 2016 by NCDEQ. This permit will expire on August 31, 2021. HNP submitted a copy of the renewed permit to the NRC by letter dated September 28, 2016, as required by Renewed Facility Operating License No. NPF-63 Appendix B.

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3.0 UNUSUAL OR IMPORTANT ENVIRONMENTAL EVENTS [EPP Section 4.1]

No occurrence of an unusual environmental event that would indicate or could result in a significant environmental impact causally related to plant operations occurred during the reporting period. No releases or exceedances of permit conditions caused any significant environmental impact. The existence of biofouling organisms (Asiatic clams, Corbicula fluminea) and the presence of troublesome aquatic vegetation (hydrilla, Hydrilla verticillata) in the Harris Reservoir are considered important topics worthy of inclusion in this report. No zebra mussels were detected at any location in the Harris Lake or the auxiliary reservoir during 2019.

3.1 Aquatic Biological Monitoring A. Inspections for Asiatic clams (Corbicula fluminea) in the Harris Nuclear Plant Emergency Service Water System (e.g., intake structures)

The Emergency Service Water (ESW) intake structure is inspected once every four years in accordance EPT-168 (Engineering Performance Test) and Periodic Maintenance Identification Numbers (PMIDs) 23528 and 23529 as part of HNPs Generic Letter 89-13 Testing and Inspection Program.

Inspections of the ESW screening structure bays ESW B Bay 6, 1X CTMU (Cooling Tower Make-up) and 1&2X CTMU occurred during 2019.

No clogging events of HNP cooling water systems were observed during 2019 because of Asiatic clam infestation.

B. Monitoring aquatic vegetation Main Reservoir Prior to 2019, Hydrilla and Creeping Water Primrose were observed throughout the reservoir. Grass Carp were stocked by the state of North Carolina into the reservoir during Spring 2019. Non-qualitative aquatic vegetation surveys did not detect Hydrilla and Creeping Water Primrose in 2019. The Grass Carp were effective at removing the previously observed aquatic vegetation as well as other species from the reservoir. Hydrilla was not observed in the intake embayment or in the intake canal. No new species of aquatic plants were observed in the main reservoir.

Auxiliary Reservoir No Hydrilla, American Elodea, Bladderwort, or Southern Pond Weed was observed in the auxiliary reservoir, intake canal, or along the shoreline adjacent to the auxiliary intake canal in 2019. There were a few small areas of Baldwins Spikerush (Eleochris baldwinii), and was mixed with some Muskgrass (Chara spp.). There were also a few scattered areas of Alligator Weed (Alternanthera philoxeroides) and Creeping Water Primrose (Ludwigia spp.), but only in very small amounts. No submerged aquatic vegetation was observed in the intake canal and embayment. The scant amount of aquatic vegetation does not pose any operational concerns. For preventative aquatic vegetation management in the Auxiliary Reservoir, 100 Grass Carp will be stocked in spring 2020.

No impacts to HNP operations from aquatic vegetation occurred in 2019.

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3.2 Combined Construction and Operating License Application Evaluations In a letter dated February 18, 2008, Carolina Power & Light Company applied for a combined construction permit and operating license (COL) for two AP1000 advanced pressurized water reactor units to be located at the Shearon Harris Nuclear Power Plant site. In the initial application, Carolina Power & Light Company relied on Integrated Resource Plans (IRPs) prepared for the North Carolina Utilities Commission and the Public Service Commission of South Carolina to demonstrate the need for the two units. The IRPs used a 15-year period for forecasting native load requirements, supply-side and demand side resources, and options considered for satisfaction of the load requirements and other system obligation. Duke Energy Progress, LLC (DEP) continued to evaluate the need for power, however the commercial operation dates for the two units no longer fell within the 15-year planning window of the IRP. DEP requested an additional exemption in a letter dated October 13, 2016, to the NRC. The NRC renewed the exemption through December 31, 2019. DEP requested on December 02, 2019 to extend the exemption date to December 31, 2024. The NRC approved the request on April 06, 2020.

No work was performed in 2019 in support of the COL for the two units at the Shearon Harris Nuclear Power Plant site.

3.3 Harris Land Sales Two large sales of property outside of the Owner Controlled Area occurred in 2019.

A. Wake County Board of Education On March 29, 2019 a deed was recorded with the Wake County Register of Deeds for 73.587 acres sold to Wake County School Board for a future school site in the Holly Springs, North Carolina area.

B. Shenandoah Homes On October 10, 2019 a deed was recorded with the Wake County Register of Deeds for 387.307 acres sold to Shenandoah Homes for Carolina Springs, a master-planned community in the Holly Springs, North Carolina area.

No significant environmental impacts have been caused or identified by these activities 3

4.0 ENVIRONMENTAL MONITORING [EPP Section 4.2]

4.1 Aquatic Monitoring [EPP Section 4.2.1]

Under the authority of the Clean Water Act, the state of North Carolina renewed the HNP NPDES permit (NC0039586) which took effect on September 1, 2016.

The permit includes the Harris Energy & Environmental Center (HE&EC) sewage treatment plant discharge as an outfall (007).

The permit requires that a state-certified laboratory perform the analyses on all non-field parameters analyzed for effluent samples. In accordance with this requirement, the HNP Environmental & Chemistry Laboratory was certified by NCDEQ as a Wastewater Laboratory, effective January 1, 2019, and valid through December 31, 2019. In addition, the Duke Energy Carolinas Laboratory in Huntersville, NC, provided NPDES analytical support for effluent samples.

During 2019, DEP also contracted with three NCDEQ certified private laboratories (Environmental Testing Solutions, Inc. (ETS), GEL Laboratories (GEL), and PACE Analytical Laboratories (PACE)) to perform analyses.

4.1.1 Effluent Monitoring Routine effluent monitoring was conducted and reported to NCDEQ as required by the NPDES permit. The following NPDES permit noncompliances or events occurred.

• May 2019, Notice of Violation, Case Number: NOV-2019-LV-0317 - On May 7, 2019, DEP received the subject Notice of Violation & Intent to Assess Civil Penalty letter dated May 1, 2019.

The zinc daily maximum of 1 mg/L and the monthly average of 1 mg/L were exceeded by February 10, 2019 sample for the HNP Cooling Tower Blowdown. These results were recorded on the February 2019 eDMR Outfall 001.

Possible Cause:

A review of the records for the February 2019 electronic Discharge Monitoring Report (eDMR) reveal a data entry error for Outfall 001. The zinc result for February 10, 2019 was entered as 10.1 mg/L whereas the result should have been entered as 0.010 mg/L. The 10.1 mg/L entry also contributed to a miscalculation of the monthly average of 2.54 mg/L. The correct monthly average is 0.018 mg/L.

The permit Outfall 001 effluent limitations for zinc are 1.0 mg/L for the daily maximum and monthly average, respectively. Neither the daily maximum limit nor the monthly average limit for zinc in Outfall 001 was exceeded.

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Corrective Actions:

1 - The February 2019 electronic Discharge Monitoring Report (eDMR) was revised with the corrected sample result for February 10, 2019 of 0.010 mg/L zinc (RA-19-0249).

2 - A letter of response to NCDEQ for Case Number: NOV-2019-LV-0317 was issued with a copy of the sample analysis, and the corrected eDMR for February 2019 (RA-19-0247).

No additional communications have been received from NCDEQ regarding this item.

No impacts to the environment were observed.

• 2019 Notice of Violation Case No. NOV-2019-LV-0373 - On November 04, 2019, DEP received the subject Notice of Violation & Assess Civil Penalty letter dated October 30, 2019.

The August 2019 electronic Discharge Monitoring Report (eDMR), results for the primary and backup samples collected August 10, 2019 for Outfall 005 (batch radwaste treatment system) Oil & Grease (O&G) were 25.0 mg/L and 26.6 mg/L, respectively. Results from contract lab were not received until August 26 and 29 which were too late for any additional compliance sampling. Initial notification of exceeding daily maximum of 20 mg/L and the monthly average of 15 mg/L the effluent limits for O&G limit was communicated to the NCDEQ Raleigh Regional Office on August 30, 2019.

Corrective Actions:

1. The Treated Laundry and Hot Shower Tank B that had the O&G in the release has been taken out of service and will be cleaned.

2. Plant Operations changed the carbon filters in the Outfall 005 batch radwaste treatment system.

3. A failure of a resin vessel releasing resin into the radwaste treatment system may have made O&G removal less effective, the resin vessel has been taken out of service awaiting repairs or replacement.

4. Chemistry staff is taking operational O&G samples to ensure Outfall 005 batch radwaste treatment system is removing O&G to within regulatory limits.

5. Other radwaste associated tankage was inspected and tested for O&G to ensure no oil or grease was present in the tanks.

On November 13, 2019, DEP submitted a 10-day follow-up letter to the NCDEQ as required by Notice of Violation Case No. 2019-LV-0373.

On December 31, 2019, DEP received NCDEQ submitted letter Notice of Violation with Assessment of Civil Penalty for Case No. 2019-LV-0373.

On January 20, 2020, DEP submitted a 30-day follow-up letter to the NCDEQ as required by Notice of Violation Case No. 2019-LV-0373. The required penalty was paid. A confirmation letter from NCDEQ of payment of the penalty was received on January 24, 2020.

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No additional communications have been received from NCDEQ regarding this item.

No impacts to the environment were observed.

4.1.2 NPDES Inspections NCDEQ, Division of Water Resources personnel did not visit the Harris Plant nor the Harris Energy & Environmental Center to conduct a review of the domestic wastewater treatment plants in 2019.

4.2 Terrestrial Monitoring [EPP Section 4.2.2]

Terrestrial monitoring is not required.

4.3 Noise Monitoring [EPP Section 4.2.3]

Noise monitoring is not required.

5.0 EPP REVIEW and AUDIT [EPP Section 5.1]

DEP provides for the review and audit of compliance with the EPP on a periodic frequency. The results of these reviews and audits are on file and available for inspection.

6.0 PLANT REPORTING REQUIREMENTS [EPP Section 5.4]

6.1 EPP Noncompliances There were no EPP noncompliances identified during the reporting period.

NPDES permit noncompliances are discussed in Section 4.1.1 of this report.

6.2 Changes in Station Design and Operation There were no changes in station design or operation and there were no tests or experiments performed which involved a potentially significant unreviewed environmental question during 2019.

6.3 Non-routine Reports There were no additional non-routine reports submitted in accordance with EPP Section 5.4.2. from those acknowledged in Section 4.1.1.

6.4 Other Reporting Requirements There were no other EPP reportable events during 2019.

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