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{{#Wiki_filter:U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001  
{{#Wiki_filter:May 8, 2009 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
 
In the Matter of the                                       )           Docket No. 50-390 Tennessee Valley Authority                                 )
Gentlemen:  
 
In the Matter of the ) Docket No. 50-390 Tennessee Valley Authority )
 
WATTS BAR NUCLEAR PLANT (WBN) - UNIT 1 - 2008 ANNUAL NONRADIOLOGICAL ENVIRONMENTAL OPERATING REPORT (ANEOR)
WATTS BAR NUCLEAR PLANT (WBN) - UNIT 1 - 2008 ANNUAL NONRADIOLOGICAL ENVIRONMENTAL OPERATING REPORT (ANEOR)
In accordance with Section 5.4.1 of Appendix B, "Environmental Protection Plan," of the  
In accordance with Section 5.4.1 of Appendix B, Environmental Protection Plan, of the WBN Operating License, provided in the enclosure is the 2008 ANEOR for WBN. This report addresses the period from February 7, 2008 through February 6, 2009.
 
There are no regulatory commitments in this letter and should there be any questions regarding this letter, please contact me at (423) 365-1824.
WBN Operating License, provided in the enclosure is the 2008 ANEOR for WBN. This  
Sincerely, Original signed by M. K. Brandon Manager, Site Licensing and Industry Affairs Enclosure cc: See page 2


report addresses the period from February 7, 2008 through February 6, 2009.  
U.S. Nuclear Regulatory Commission Page 2 May 8, 2008 Enclosure cc (Enclosure):
NRC Resident Inspector Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381 U.S. Nuclear Regulatory Commission Mr. John G. Lamb, Senior Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation MS O-8 H1A Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 U.S. Fish and Wildlife Service 446 Neal Street Cookeville, TN 38501


There are no regulatory commitments in this letter and should there be any questions
Enclosure 2008 Annual Nonradiological Environmental Operating Report (ANEOR)
E-1 of 12


regarding this letter, please contact me at (423) 365-1824.
TENNESSEE VALLEY AUTHORITY TVA WATTS BAR NUCLEAR PLANT ANNUAL NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FEBRUARY 7, 2008 THROUGH FEBRUARY 6, 2009 E-2 of 12


Sincerely,
TABLE OF CONTENTS I. INTRODUCTION ...............................................................................................E-4 II. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WATTS BAR NUCLEAR PLANT (WBN) NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT................................E-4 III. SPECIAL BIOLOGICAL MONITORING REPORTS...........................................E-5 IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES.........................................................................................E-6 V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTIFICATIONS....................................................................E-8 VI. CHANGES IN FACILITY DESIGN OR OPERATION.........................................E-9 VII. NON-ROUTINE REPORTS .............................................................................E-12 VIII. CHANGES IN APPROVED ENVIRONMENTAL PROTECTION PLAN SPECIFICATIONS ...........................................................................................E-12 E-3 of 12
 
M. K. Brandon
 
Manager, Site Licensing
 
and Industry Affairs
 
Enclosure
 
cc:  See page 2 U.S. Nuclear Regulatory Commission Page 2
 
Enclosure
 
cc (Enclosure):
NRC Resident Inspector Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381
 
U.S. Nuclear Regulatory Commission Mr. John G. Lamb, Senior Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation MS O-8 H1A Washington, DC 20555-0001
 
U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303
 
U.S. Fish and Wildlife Service 446 Neal Street Cookeville, TN 38501
 
E-1 of 12 Enclosure 2008 Annual Nonradiological Environm ental Operating Report (ANEOR)
 
E-2 of 12 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT ANNUAL NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT        FEBRUARY 7, 2008 THROUGH FEBRUARY 6, 2009 T VA E-3 of 12 TABLE OF CONTENTS  
 
I. INTRODUCTION...............................................................................................E-4 II. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WATTS BAR NUCLEAR PLANT (WBN) NATIONAL POLLUTANT DISCHARGE ELIMINATION SYST EM (NPDES) PERMIT................................E-4 III. SPECIAL BIOLOGICAL MONITO RING REPORTS...........................................E-5 IV. ENVIRONMENTAL PROTECTION PLAN   NONCOMPLIANCES.........................................................................................E-6 V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL   PERMITS AND CERTIFICATIONS....................................................................E-8 VI. CHANGES IN FACILITY DES IGN OR OPERATION.........................................E-9 VII. NON-ROUTINE REPORTS.............................................................................E-12 VIII. CHANGES IN APPROVED ENVIRONMENTAL PROTECTION PLAN SPECIFICATIONS...........................................................................................E-12
 
E-4 of 12 I. INTRODUCTION The Watts Bar Nuclear Plant (WBN) Annual Non-Radiological Envi ronmental Operating Report is provided for the period of February 7, 2008 through February 6, 2009. This report was prepared in accordance with Appendi x B to facility operating license NPF-90, "Environmental Protection Plan (EPP)," Section 5.4.1, "Rout ine Reports."  This report includes a summary of:
 
A. Reports previously submitted as s pecified in the Watts Bar Nuclear Plant National Pollutant Discharge Eliminat ion System (NPDES) Permit Number TN0020168.
 
B. All special reports submitted per EPP Se ction 4.1, "Environmental Monitoring."


I. INTRODUCTION The Watts Bar Nuclear Plant (WBN) Annual Non-Radiological Environmental Operating Report is provided for the period of February 7, 2008 through February 6, 2009. 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 Watts Bar Nuclear Plant 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.
C. All EPP noncompliances and the corrective actions taken to remedy them.
D. Changes made to applicable state and federal permits and certifications.  
D. Changes made to applicable state and federal permits and certifications.
 
E. Changes in station design that could involve a significant environmental impact or change the findings of the Final Environmental Impact Statement (FEIS).
E. Changes in station design that could in volve a significant environmental impact or change the findings of the Final Envi ronmental Impact Statement (FEIS).  
F. Non-routine reports submitted per EPP Section 4.2, Unusual or Important Environmental Events.
 
G. Changes in approved EPP.
F. Non-routine reports submitted per EPP Section 4.2, "Unusual or Important Environmental Events."
II. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WATTS BAR NUCLEAR PLANT (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) Number TNR051343:
 
A. As required by the NPDES permit, Discharge Monitoring Reports (DMRs) were completed and submitted monthly prior to the 15th of the month deadline to the Tennessee Department of Environment and Conservation (TDEC).
G. Changes in approved EPP.  
B. DMR Quality Assurance (QA) Laboratory Performance Evaluation Study 28 was completed by and submitted to Environmental Resource Associates, the TDEC, and the Environmental Protection Agency (EPA) prior to the October 29, 2008 deadline.
 
E-4 of 12
II. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WATTS BAR NUCLEAR PLANT (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 Sto rm Water Multi-Sector General Permit (TMSP) Number TNR051343:  


A. As required by the NPDES permi t, Discharge Monitoring Reports (DMRs) were completed and submitted monthly prior to the 15 th of the month deadline to the Tennessee Depar tment of Environment and Conservation (TDEC).  
II. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WATTS BAR NUCLEAR PLANT (WBN) NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT (continued)
C. The annual Biocide/Corrosion Treatment Report was completed and submitted to the TDEC prior to the February 15, 2008 deadline.
D. The Winter 2008 Compliance Survey for Watts Bar Nuclear Plant Outfall 113 Passive Mixing Zone was completed and submitted to the TDEC prior to the semi-annual requirement deadline. The field work for the Summer 2008 Compliance Survey for Watts Bar Nuclear Plant Outfall 113 Passive Mixing Zone was completed August 28, 2008. The data is currently under analysis with plans to submit the reports to the TDEC, Division of Water Pollution Control no later than May 29, 2009. This issue is being addressed in TVAs Corrective Action Program as Problem Evaluation Report (PER) Number 169819.
E. The annual sampling and analysis required by the TMSP TR050000 for storm water was performed and the annual report was submitted prior to the March 31, 2008 deadline.
III. SPECIAL BIOLOGICAL MONITORING REPORTS A. EPP Section 4.1.1, Aquatic Monitoring
: 1. Routine semi-annual Whole Effluent Toxicity (a.k.a. chronic biotoxicity tests) were conducted on plant effluents and the appropriate reports were submitted as part of the DMR in May [Outfall Serial Numbers (OSNs) 101, 112, 113] and November (OSNs 101, 112, 113), as required by the NPDES permit.
: 2. An annual report on the Biological Monitoring of the Tennessee River near the Watts Bar Nuclear Plant 2007 was submitted to the TDEC in May 2008 indicating no adverse impact to aquatic life due to WBN operation. This report is not required in accordance with Part III, 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 to be consistent with other required annual reporting programs at Tennessee and Alabama nuclear plants.
E-5 of 12


B. DMR Quality Assurance (QA)
III. SPECIAL BIOLOGICAL MONITORING REPORTS (continued)
Laboratory Performance Evaluation Study 28 was completed by and submi tted to Environmental Resource Associates, the TDEC, and the Envir onmental Protection Agency (EPA) prior to the October 29, 2008 deadline.  
: 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 2008 to the TDEC prior to the February 15, 2009 deadline. Although federal agencies are not subject to laws and regulations promulgated by state governments unless Congress has clearly waived the federal governments sovereign immunity, in 2003 TVA voluntarily agreed 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.
B. EPP Section 4.1.2, Maintenance of Transmission Line Corridors Listed below are the 500 kV transmission lines associated with Watts Bar Nuclear Plant and information regarding the maintenance that was performed on each line:
500 kV Line Identifier                    Maintenance Performed Bull Run - Sequoyah No major clearing was performed on these line Watts Bar - Roane        corridors using herbicides.
Watts Bar - Volunteer Sequoyah - Watts Bar        374 acres were treated with the following mixture of herbicides:
* 4% Dow AgroScience Accord XRT
* 25 ounces of DuPont Lineage Clearstand
* 0.5% surfactant
* 0.1% dye IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES WBN received zero Notice of Violations (NOV) from February 2008 to February 2009. In accordance with the NPDES permit, the following noncompliances were reported to the TDEC.
: 1. WBN reported to the Chattanooga Field Office on February 20, 2008 that an iron cut-off concentration was exceeded at sample point SW-9 in Drainage Area 11. WBN did not receive a NOV from the TDEC. A separate notification was provided to the Field Office for each occurrence (refer to table below). While the October result indicates continued improvement, the November result indicated that continued monitoring and remediation efforts are needed. These results are summarized in the table below:
E-6 of 12


E-5 of 12 II. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WATTS BAR NUCLEAR PLANT (WBN) NATIONAL POLLUTANT DISCHARGE
IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES (continued)
Date Collected              Analytical Results January 29, 2008                    13 mg/L April 11, 2008                  9.6 mg/L October 24, 2008                  6.4 mg/L November 13, 2008                    11 mg/L As described in correspondence to the TDEC, the SWPPP characterizes this drainage area as one associated with industrial activity. Since the last required 2007 Storm Water sample for iron, collected on March 16, 2007 (0.78 mg/L), there was considerable activity relating to movement of industrial materials in this drainage area which created soil disturbance directly upstream of the sample point, SW-9. WBN increased the Best Management Practices (BMPs) in this area (soil stabilization and silt fences) to reduce iron analytical results to below the cut-off concentration limit. In addition, soil stabilization via increased vegetation density remains in progress. The downward trend from the January through the October sample analytical results indicate that the BMPs are reducing the mobilization of iron and WBN will continue to monitor this storm water outfall. The SWPPP was also reviewed but determined that changes to the plan are unnecessary at this time.
: 2. OSN 112 NPDES samples collected on June 16, 2008 at 10:30 yielded a dissolved oxygen (DO) of 3.9 mg/L. The back-up sample analyzed June 17th yielded a DO of 3.9 mg/L. This is a NPDES violation as the minimum daily permit limit is 5.0 mg/L. Chemistry/Environmental verbally informed the Chattanooga Field Office of the noncompliance on June 18, 2008. In addition, per Part II.C.2. b. of the WBN NPDES permit, the noncompliance was reported on the June Discharge Monitoring Report which was sent to the TDEC Nashville office and the Chattanooga Field Office on July 9, 2008 via certified mail. WBN did not receive an NOV from the TDEC. The corrective action was to reinforce the need for timely communication of all limit threats to permit noncompliance.
: 3. A Biological Oxygen Demand sample collected July 14, 2008 at OSN 111, the sewage treatment plant, was not analyzed by Environmental Science Corporation within the 40 CFR 136 48-hour hold time requirement. As the analytical lab did not notify WBN of the hold time exceedance, WBN was unaware of the hold time exceedance until the following week when the results were received. Since WBN did not have the opportunity to collect an additional sample for the week of E-7 of 12


ELIMINATION SYSTEM (NPDES) PERMIT (continued)
IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES (continued)
C. The annual Biocide/Corrosion Tr eatment Report was completed and submitted to the TDEC prior to the February 15, 2008 deadline. 
July 14th, this resulted in a missed NPDES sample. In accordance with Part II.C.2. b. of the WBN NPDES permit, the noncompliance was reported on the July Discharge Monitoring Report which was sent the TDEC Nashville office and the Chattanooga Field Office on August 7, 2008 via certified mail. WBN did not receive an NOV from the TDEC. The corrective actions were; (1) Provide WBN expectations for NPDES sample analysis and immediate notification of issues to Environmental Science Corporation, (2) Revise the governing procedure, 0-PI-ENV-3.1, NPDES Plant Effluents, to include an action step to contact the analytical lab in the event the analytical results were not received by the requested date, and (3) WBN requested a two-day turn around time for all weekly NPDES samples from the analytical laboratory.
 
D. The "Winter 2008 Compliance Survey for Watts Bar Nuclear Plant Outfall 113 Passive Mixing Zone" was completed and submitted to the
 
TDEC prior to the semi-annual require ment deadline. The field work for the "Summer 2008 Compliance Survey fo r Watts Bar Nuclear Plant Outfall 113 Passive Mixing Zone" was completed August 28, 2008. The data is
 
currently under analysis with plans to submit the reports to the TDEC, Division of Water Pollution Control no later than May 29, 2009. This issue
 
is being addressed in TVA's Correct ive Action Program as Problem Evaluation Report (PER) Number 169819.
 
E. The annual sampling and analysis required by the TMSP TR050000 for storm water was performed and the annual report was submitted prior to
 
the March 31, 2008 deadline.
III. SPECIAL BIOLOGICAL MONITORING REPORTS A. EPP Section 4.1.1, "Aquatic Monitoring"
: 1. Routine semi-annual Whole Effluent Toxicity (a.k.a. chronic biotoxicity tests) were conducted on plant effluents and the appropriate reports were
 
submitted as part of the DMR in May [Outfall Serial Numbers (OSNs) 101, 112, 113] and November (OSNs 101, 112, 113), as required by the NPDES permit.
: 2. An annual report on the "Biologica l Monitoring of the Tennessee River near the Watts Bar Nuclear Plant 2007" was submitted to the TDEC in
 
May 2008 indicating no adverse impact to aquatic life due to WBN
 
operation. This report is not requir ed in accordance with Part III, 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 to be consistent with other required annual reporting programs at Tennessee and Alabama nuclear plants.
 
E-6 of 12 III. SPECIAL BIOLOGICAL MONITORING REPORTS (continued)
: 3. In accordance with the prov isions of Tennessee Code Annotated Section 69-8-301 et seq., the Water Resources Information Act, WBN
 
submitted the Water Withdrawal R egistration Form for Calendar Year 2008 to the TDEC prior to the February 15, 2009 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, in 2003 TVA voluntarily agreed as a
 
matter of policy to provide the registra tion information in order to assist both TVA and the TDEC in carrying out their water management
 
responsibilities.
 
B. EPP Section 4.1.2, "Maint enance of Transmission Line Corridors"
 
Listed below are the 500 kV transmission lines associated with Watts Bar Nuclear Plant and information regarding the maintenance that was
 
performed on each line:
500 kV Line Identifier Maintenance Performed Bull Run - Sequoyah Watts Bar - Roane Watts Bar - Volunteer No major clearing was performed on these line corridors using herbicides. Sequoyah - Watts Bar 374 acres were treated with the following mixture of herbicides:  4% Dow AgroScience Accord XRT  25 ounces of DuPont Lineage Clearstand  0.5% surfactant  0.1% dye IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES WBN received zero Notice of Violati ons (NOV) from February 2008 to February 2009. In accordance with the NPDES permit, the following noncompliances were
 
reported to the TDEC.
: 1. WBN reported to the Chattanooga Fiel d Office on February 20, 2008 that an iron cut-off concentration was exceeded at sample point SW-9 in
 
Drainage Area 11. WBN did not rece ive a NOV from the TDEC. A separate notification was provided to the Field Office for each occurrence (refer to table below). While the October result indicates continued improvement, the November result i ndicated that continued monitoring and remediation efforts are needed. These results are summarized in the
 
table below:
E-7 of 12 IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES (continued)
Date Collected Analytical Results January 29, 2008 13 mg/L April 11, 2008 9.6 mg/L October 24, 2008 6.4 mg/L November 13, 2008 11 mg/L As described in correspondence to the TDEC, the SWPPP characterizes this drainage area as one associated with industrial activity. Since the last
 
required 2007 Storm Water sample for iron, collected on March 16, 2007
 
(0.78 mg/L), there was considerable activity relating to movement of industrial materials in this drai nage area which created soil disturbance directly upstream of the sample point, SW-9. WBN increased the Best
 
Management Practices (BMPs) in this area (soil stabilization and silt fences) to reduce iron analytical result s to below the cut-off concentration limit. In addition, soil stabilizat ion via increased vegetation density remains in progress. The downwar d trend from the January through the October sample analytical results indi cate that the BMP's are reducing the mobilization of iron and WBN will continue to monitor this storm water
 
outfall. The SWPPP was also reviewed but determined that changes to
 
the plan are unnecessary at this time.
: 2. OSN 112 NPDES samples collected on June 16, 2008 at 10:30 yielded a dissolved oxygen (DO) of 3.9 mg/L. The back-up sample analyzed
 
June 17th yielded a DO of 3.9 mg/L. This is a NPDES violation as the
 
minimum daily permit limit is 5.0 mg/L. Chemistry/Environmental verbally informed the Chattanooga Field Office of the noncompliance on June 18, 2008. In addition, per Part II.C.2.
: b. of the WBN NPDES permit, the noncompliance was reported on the June Discharge Monitoring Report which was sent to the TDEC Nashville office and the Chattanooga Field
 
Office on July 9, 2008 via certified mail. WBN did not receive an NOV
 
from the TDEC. The corrective action was to reinforce the need for timely
 
communication of all limit threats to permit noncompliance.
: 3. A Biological Oxygen Demand sample collected July 14, 2008 at OSN 111, the sewage treatment plant, was not analyzed by Environmental Science Corporation within the 40 CFR 136 48-hour hold time requirement. As the analytical lab did not notify WBN of the hold time exceedance, WBN was unaware of the hold time exceedance until the following week when the
 
results were received. Since WBN did not have the opportunity to collect
 
an additional sample for the week of E-8 of 12 IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES (continued)
July 14 th , this resulted in a missed NPDES sample. In accordance with Part II.C.2. b. of the WBN NPDES permit, the noncompliance was  
 
reported on the July Discharge Moni toring Report which was sent the TDEC Nashville office and the Chattanooga Field Office on  
 
August 7, 2008 via certified mail. WB N did not receive an NOV from the TDEC. The corrective actions were
; (1) Provide WBN expectations for NPDES sample analysis and immediate notification of issues to  
 
Environmental Science Corporation, (2) Revise the governing procedure, 0-PI-ENV-3.1, NPDES Plant Effluents, to include an action step to contact the analytical lab in the event the analyt ical results were not received by the requested date, and (3) WBN reques ted a two-day turn around time for all weekly NPDES samples fr om the analytical laboratory.
V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTIFICATIONS A. NPDES Permit TN 0020168
V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTIFICATIONS A. NPDES Permit TN 0020168
: 1. The NPDES permit renewal application packet consisting of EPA Form 1, site map, Form 2C, Form 2C addendum , flow schematic, Form 2E, and a permit address form submitted to the State of Tennessee on May 3, 2006  
: 1. The NPDES permit renewal application packet consisting of EPA Form 1, site map, Form 2C, Form 2C addendum, flow schematic, Form 2E, and a permit address form submitted to the State of Tennessee on May 3, 2006 is still pending. Sampling for permit renewal occurred in December 2005 and historical data were compiled from the period of October 1, 2004 through September 30, 2005.
: 2. In accordance with the TDEC Environmental Permits Handbook, WBN submitted an Application for Information Regarding a Subsurface Sewage Disposal System Permit and Certification of Completion for the security training building septic tank in drainage area Number 13 in April 2008.
TDEC Division of Groundwater Protection inspected the septic tank on April 28, 2008 and approved the construction. PER Number 143393 was written to document that a permit was not applied for prior to construction due to an error in understanding between county, state, and federal policies which govern the installation. The TDEC reported that the issue had been corrected and WBN did not receive an NOV.
: 3. During June 2008, WBN re-evaluated its industrial activity in drainage areas and in accordance with the TMSP notified the TDEC of the removal of Storm Water Outfall 5 (SW-5) and Storm Water Outfall 7 (SW-7). WBN believes coverage under the Tennessee Multi-Sector General Permit for Industrial Activities Sector L and O is appropriate, consistent with the previous Notice of Coverage E-8 of 12


is still pending. Sampling for permit renewal occurred in December 2005
V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTIFICATIONS (continued) issued for this facility. An up to date SWPPP and supporting documents are available at the site. In a previous SWPPP, SW-5 was incorrectly described as representative of the discharge from Storm Water Outfall SW-2. As SW-2s drainage area is associated with industrial activity and SW-5 no longer has industrial activity associated with it, SW-5 could not be representative of SW-2. Inspections and monitoring continue at SW-2.
 
A change occurred in the land use for the drainage area associated with SW-7. While previously used for laydown activities (industrial), this area has now been converted for use as office space (non industrial). SW-5 and SW-7 were removed from the Notice of Intent.
and historical data were compiled fr om the period of October 1, 2004 through September 30, 2005.
: 4. On September 10, 2008, WBN submitted a minor modification to the TDEC Nashville office for termination of discharges from NPDES Internal Monitoring Point (IMP) 111. The WBN sewage treatment plant had been connected to the Spring City Publicly Owned Treatment Plant effective August 9, 2008 with October 3, 2008 (date the effluent box was completely filled with gravel) as the actual termination date of the discharge from IMP 111.
: 2. In accordance with the TDEC Environmental Permits Handbook, WBN submitted an Application for Information Regarding a Subsurface Sewage
B. Air Permits WBN is currently operating under Air Permit Number 448529. No changes to this permit were made during the reporting period.
 
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, 2008 through February 6, 2009 was performed.
Disposal System Permit and Certification of Completion for the security
Projects considered as having potential impact on the environment included those that:
 
* Could have caused waste stream generation/alteration.
training building septic tank in dr ainage area Number 13 in April 2008.
* Required the acquisition/modification of permits.
TDEC Division of Groundwater Protec tion inspected the septic tank on April 28, 2008 and approved the construction. PER Number 143393 was
* Involved the use of hazardous material.
 
* Required physical construction.
written to document that a permit was not applied for prior to construction
E-9 of 12
 
due to an error in understanding betw een county, state, and federal policies which govern the installation.
The TDEC reported that the issue had been corrected and WBN did not receive an NOV.
: 3. During June 2008, WBN re-evaluated its industrial activity in drainage areas and in accordance with the TMSP notified the TDEC of the removal
 
of Storm Water Outfall 5 (SW-5) and Storm Water Outfall 7 (SW-7). WBN believes coverage under the Tennessee Multi-Sector General Permit for
 
Industrial Activities Sector L and O is appropriate, consistent with the previous Notice of Coverage E-9 of 12 V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTIFICATIONS (continued) issued for this facility. An up to date SWPPP and supporting documents are available at the site. In a previous SWPPP, SW-5 was incorrectly  
 
described as representative of the discharge from Storm Water Outfall SW-2. As SW-2's drainage area is associated with industrial activity and  
 
SW-5 no longer has industrial activity associated with it, SW-5 could not  
 
be representative of SW-2. Inspecti ons and monitoring continue at SW-2.
A change occurred in the land use fo r the drainage area associated with SW-7. While previously used for laydown activities (industrial), this area  
 
has now been converted for use as office space (non industrial). SW-5  
 
and SW-7 were removed from the Notice of Intent.
: 4. On September 10, 2008, WBN subm itted a minor modification to the TDEC Nashville office for termination of discharges from NPDES Internal Monitoring Point (IMP) 111. The WBN sewage treatment plant had been  
 
connected to the Spring City Publicly Owned Treatment Plant effective August 9, 2008 with October 3, 2008 (date the effluent box was completely filled with gravel) as t he actual termination date of the discharge from IMP 111.  
 
B. Air Permits
 
WBN is currently operating under Air Permit Number 448529. No changes to this permit were made during the reporting period.
VI. CHANGES IN FACILITY DESIGN OR OPERATION In accordance with EPP Section 3.1, "Pl ant Design and Operation," facility design and operational changes were reviewed fo r potential effect on the environment as described below. A review of facility design and operational changes  
 
proposed from February 7, 2008 through February 6, 2009 was performed.
Projects considered as having potent ial impact on the environment included those that:
Could have caused waste st ream generation/alteration.
Required the acquisition/modification of permits.
Involved the use of hazardous material.
Required physical construction.  
 
E-10 of 12 VI. CHANGES IN FACILITY DESIGN OR OPERATION (continued)
The review, performed in accordance wit h the guidelines of the Tennessee Valley Authority's National Environmental Po licy 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 Wast e, Polychlorinated Biphenyl, Asbestos, Wastewater) 


VI. CHANGES IN FACILITY DESIGN OR OPERATION (continued)
The review, performed in accordance with the guidelines of the Tennessee Valley Authoritys 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 Biphenyl, Asbestos, Wastewater)
B. Permit Acquisition/Modification
B. Permit Acquisition/Modification
[NPDES, Air, Inert Landfill, Other (316b, 404, etc.)]  
[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 hazardous or Toxic Substances Control Act waste)
C. Hazardous Materials (Hazardous Materials that are envir onmentally unfriendly and are likely to generate a Resource Conservation and Recovery Act hazardous or Toxic  
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, 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.
Substances Control Act waste)
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 eight 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 written to document the site changes reviewed are as follows:
D. Physical Construction Involved (Erosion/Sedimentation Effects, Tr ansportation Effects, Noise Effects, Groundwater Effects, Surface Water E ffects, 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, Changes in Site Land Use, and Controversy)
E-10 of 12
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 cr iteria. There were eight facility design and operational changes made dur ing 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 Exclus ion Checklists written to document the site changes reviewed are as follows:
VI. CHANGES IN FACILITY DESIGN OR OPERATION (continued)
E-11 of 12 VI. CHANGES IN FACILITY DESIGN OR OPERATION (continued)
(1) 19929-Installation of Power & Communications Fiber Optic Line & Fence repositioning at the Unit 1 Staging Area (2) 19869-Generic Nuisance Tree Removal (3) 19554-Yard Holding Pond (YHP) Boat Ramp (4) 19540-Installation of Power & Communications Fiber Optic Line Between the Unit 2 Work Control Center and the Railroad Trailer (5) 19506-Installation of Communications Fiber Optic Line Between the Switchyard fence and Trailer Number 12 (6) 19474-Installation of Communications Fiber Optic Line Between Unit 1 Warehouse A and Warehouse B (7) 19395-Chain Link Fence Between Unit 1 Warehouses A and B (8) 19392-Paint Shop Addition (9) 19273-WBN Training Center Cooling Tower Blowdown to Catch Basin Number 97 (10) 19194-Unit 2 West Parking Lot Light Poles (11) 19063-Transport Generator Rotor from and to WBN via Sequoyah Nuclear Plant (12) 18902-WBN Unit 2 Tree Removal (13) 18868-WBN Unit 2 Warehouse Telecommunication & Fiber Optic Service Construction (14) 18591-Quality Control Office Trailer at the Unit 2 Receiving Warehouse (15) 18532-Sewage Treatment Plant Building Hook-Up to Spring City Line (16) 18415-WBN Unit 2 Condenser Bundle Storage Area & Haul Route (17) 18414-Generic - Chain Link Fences Outside of the Probable Maximum Flood (PMF), Probable Maximum Precipitation (PMP), and Protected Area (PA)
(1) 19929-Installation of Power & Communications Fiber Optic Line & Fence repositioning at the Unit 1 Staging Area (2) 19869-Generic Nuisance Tree Removal (3) 19554-Yard Holding Pond (YHP) Boat Ramp (4) 19540-Installation of Power & Co mmunications Fiber Optic Line Between the Unit 2 Work Control C enter and the Railroad Trailer (5) 19506-Installation of Communications Fiber Optic Line Between the Switchyard fence and Trailer Number 12 (6) 19474-Installation of Communications Fiber Optic Line Between Unit 1 Warehouse A and Warehouse B (7) 19395-Chain Link Fence Between Unit 1 Warehouses A and B (8) 19392-Paint Shop Addition (9) 19273-WBN Training Center Cooling Tower Blowdown to Catch Basin Number 97 (10) 19194-Unit 2 West Parking Lot Light Poles (11) 19063-Transport Generator Rotor fr om and to WBN via Sequoyah Nuclear Plant   (12) 18902-WBN Unit 2 Tree Removal (13) 18868-WBN Unit 2 Warehouse Telecommunication & Fiber Optic Service Construction (14) 18591-Quality Control Office Traile r at the Unit 2 Receiving Warehouse (15) 18532-Sewage Treatment Plant Building Hook-Up to Spring City Line (16) 18415-WBN Unit 2 Condenser Bundle Storage Area & Haul Route (17) 18414-Generic - Chain Link Fenc es Outside of the Probable Maximum Flood (PMF), Probable Maximum Prec ipitation (PMP), and Protected Area (PA) (18) 18413-Generic - Cooling Tower Perimeter Fill Replacement (19) 18378-Generic - Surfac e Preparation via Sandblasting (20) 18344-Generic - Temporary Wa rehouse Complex and Loading Dock (21) 18271-Watts Bar Nuclear Plant 500-kV Switchyard Startup Unit 2 - Project No. Z0172 - Work Orders 62189, 62190 & 62191 (22) 18270-Firing Range Trailer, Septic Tank & Field (23) 18268-Dean Building Sidewalk Extension (24) 18217-WBN Unit 2 Powerline Upgrade (25) 18149-Security Shelter (26) 18134-Asphalt Existing Safe Walkway From North Portal Parking Lot to North Portal Entrance (27) 18092-Engineering Quality Building (EQB) Safe Walkway (28) 18088-Drainage Area Number 14 Chain Link Fencing (29) 18087-Drainage Area Number 11 Chain Link Fencing (30) 18079-Drainage Area 2 Chain Link Fencing E-12 of 12 VI. CHANGES IN FACILITY DESIGN OR OPERATION (continued)
(18) 18413-Generic - Cooling Tower Perimeter Fill Replacement (19) 18378-Generic - Surface Preparation via Sandblasting (20) 18344-Generic - Temporary Warehouse Complex and Loading Dock (21) 18271-Watts Bar Nuclear Plant 500-kV Switchyard Startup Unit 2 - Project No. Z0172 - Work Orders 62189, 62190 & 62191 (22) 18270-Firing Range Trailer, Septic Tank & Field (23) 18268-Dean Building Sidewalk Extension (24) 18217-WBN Unit 2 Powerline Upgrade (25) 18149-Security Shelter (26) 18134-Asphalt Existing Safe Walkway From North Portal Parking Lot to North Portal Entrance (27) 18092-Engineering Quality Building (EQB) Safe Walkway (28) 18088-Drainage Area Number 14 Chain Link Fencing (29) 18087-Drainage Area Number 11 Chain Link Fencing (30) 18079-Drainage Area 2 Chain Link Fencing E-11 of 12
All other facility design and operati onal changes made during this reporting period with a potential impact on the envir onment were found to be within the scope of existing environmental permits and in compliance with regulations.


VI. CHANGES IN FACILITY DESIGN OR OPERATION (continued)
All other 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 environmental permits and in compliance with regulations.
In summary, there were no facility design or operational changes from February 7, 2008 to February 6, 2009 which resulted in an unreviewed environmental question.
In summary, there were no facility design or operational changes from February 7, 2008 to February 6, 2009 which resulted 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.}}
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.
E-12 of 12}}

Latest revision as of 06:05, 14 November 2019

Unit 1 - 2008 Annual Nonradiological Environment Operation Report
ML091310178
Person / Time
Site: Watts Bar Tennessee Valley Authority icon.png
Issue date: 05/08/2009
From: Brandon M
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML091310178 (14)
v • d • e


Text

May 8, 2009 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

In the Matter of the ) Docket No. 50-390 Tennessee Valley Authority )

WATTS BAR NUCLEAR PLANT (WBN) - UNIT 1 - 2008 ANNUAL NONRADIOLOGICAL ENVIRONMENTAL OPERATING REPORT (ANEOR)

In accordance with Section 5.4.1 of Appendix B, Environmental Protection Plan, of the WBN Operating License, provided in the enclosure is the 2008 ANEOR for WBN. This report addresses the period from February 7, 2008 through February 6, 2009.

There are no regulatory commitments in this letter and should there be any questions regarding this letter, please contact me at (423) 365-1824.

Sincerely, Original signed by M. K. Brandon Manager, Site Licensing and Industry Affairs Enclosure cc: See page 2

U.S. Nuclear Regulatory Commission Page 2 May 8, 2008 Enclosure cc (Enclosure):

NRC Resident Inspector Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381 U.S. Nuclear Regulatory Commission Mr. John G. Lamb, Senior Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation MS O-8 H1A Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 U.S. Fish and Wildlife Service 446 Neal Street Cookeville, TN 38501

Enclosure 2008 Annual Nonradiological Environmental Operating Report (ANEOR)

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TENNESSEE VALLEY AUTHORITY TVA WATTS BAR NUCLEAR PLANT ANNUAL NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FEBRUARY 7, 2008 THROUGH FEBRUARY 6, 2009 E-2 of 12

TABLE OF CONTENTS I. INTRODUCTION ...............................................................................................E-4 II. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WATTS BAR NUCLEAR PLANT (WBN) NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT................................E-4 III. SPECIAL BIOLOGICAL MONITORING REPORTS...........................................E-5 IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES.........................................................................................E-6 V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTIFICATIONS....................................................................E-8 VI. CHANGES IN FACILITY DESIGN OR OPERATION.........................................E-9 VII. NON-ROUTINE REPORTS .............................................................................E-12 VIII. CHANGES IN APPROVED ENVIRONMENTAL PROTECTION PLAN SPECIFICATIONS ...........................................................................................E-12 E-3 of 12

I. INTRODUCTION The Watts Bar Nuclear Plant (WBN) Annual Non-Radiological Environmental Operating Report is provided for the period of February 7, 2008 through February 6, 2009. 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 Watts Bar Nuclear Plant 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 change the findings of the Final Environmental Impact Statement (FEIS).

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

G. Changes in approved EPP.

II. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WATTS BAR NUCLEAR PLANT (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) Number TNR051343:

A. As required by the NPDES permit, Discharge Monitoring Reports (DMRs) were completed and submitted monthly prior to the 15th of the month deadline to the Tennessee Department of Environment and Conservation (TDEC).

B. DMR Quality Assurance (QA) Laboratory Performance Evaluation Study 28 was completed by and submitted to Environmental Resource Associates, the TDEC, and the Environmental Protection Agency (EPA) prior to the October 29, 2008 deadline.

E-4 of 12

II. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WATTS BAR NUCLEAR PLANT (WBN) NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT (continued)

C. The annual Biocide/Corrosion Treatment Report was completed and submitted to the TDEC prior to the February 15, 2008 deadline.

D. The Winter 2008 Compliance Survey for Watts Bar Nuclear Plant Outfall 113 Passive Mixing Zone was completed and submitted to the TDEC prior to the semi-annual requirement deadline. The field work for the Summer 2008 Compliance Survey for Watts Bar Nuclear Plant Outfall 113 Passive Mixing Zone was completed August 28, 2008. The data is currently under analysis with plans to submit the reports to the TDEC, Division of Water Pollution Control no later than May 29, 2009. This issue is being addressed in TVAs Corrective Action Program as Problem Evaluation Report (PER) Number 169819.

E. The annual sampling and analysis required by the TMSP TR050000 for storm water was performed and the annual report was submitted prior to the March 31, 2008 deadline.

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

1. Routine semi-annual Whole Effluent Toxicity (a.k.a. chronic biotoxicity tests) were conducted on plant effluents and the appropriate reports were submitted as part of the DMR in May [Outfall Serial Numbers (OSNs) 101, 112, 113] and November (OSNs 101, 112, 113), as required by the NPDES permit.
2. An annual report on the Biological Monitoring of the Tennessee River near the Watts Bar Nuclear Plant 2007 was submitted to the TDEC in May 2008 indicating no adverse impact to aquatic life due to WBN operation. This report is not required in accordance with Part III,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 to be consistent with other required annual reporting programs at Tennessee and Alabama nuclear plants.

E-5 of 12

III. SPECIAL BIOLOGICAL MONITORING REPORTS (continued)

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 2008 to the TDEC prior to the February 15, 2009 deadline. Although federal agencies are not subject to laws and regulations promulgated by state governments unless Congress has clearly waived the federal governments sovereign immunity, in 2003 TVA voluntarily agreed 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.

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

500 kV Line Identifier Maintenance Performed Bull Run - Sequoyah No major clearing was performed on these line Watts Bar - Roane corridors using herbicides.

Watts Bar - Volunteer Sequoyah - Watts Bar 374 acres were treated with the following mixture of herbicides:

  • 4% Dow AgroScience Accord XRT
  • 25 ounces of DuPont Lineage Clearstand
  • 0.5% surfactant
  • 0.1% dye IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES WBN received zero Notice of Violations (NOV) from February 2008 to February 2009. In accordance with the NPDES permit, the following noncompliances were reported to the TDEC.
1. WBN reported to the Chattanooga Field Office on February 20, 2008 that an iron cut-off concentration was exceeded at sample point SW-9 in Drainage Area 11. WBN did not receive a NOV from the TDEC. A separate notification was provided to the Field Office for each occurrence (refer to table below). While the October result indicates continued improvement, the November result indicated that continued monitoring and remediation efforts are needed. These results are summarized in the table below:

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IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES (continued)

Date Collected Analytical Results January 29, 2008 13 mg/L April 11, 2008 9.6 mg/L October 24, 2008 6.4 mg/L November 13, 2008 11 mg/L As described in correspondence to the TDEC, the SWPPP characterizes this drainage area as one associated with industrial activity. Since the last required 2007 Storm Water sample for iron, collected on March 16, 2007 (0.78 mg/L), there was considerable activity relating to movement of industrial materials in this drainage area which created soil disturbance directly upstream of the sample point, SW-9. WBN increased the Best Management Practices (BMPs) in this area (soil stabilization and silt fences) to reduce iron analytical results to below the cut-off concentration limit. In addition, soil stabilization via increased vegetation density remains in progress. The downward trend from the January through the October sample analytical results indicate that the BMPs are reducing the mobilization of iron and WBN will continue to monitor this storm water outfall. The SWPPP was also reviewed but determined that changes to the plan are unnecessary at this time.

2. OSN 112 NPDES samples collected on June 16, 2008 at 10:30 yielded a dissolved oxygen (DO) of 3.9 mg/L. The back-up sample analyzed June 17th yielded a DO of 3.9 mg/L. This is a NPDES violation as the minimum daily permit limit is 5.0 mg/L. Chemistry/Environmental verbally informed the Chattanooga Field Office of the noncompliance on June 18, 2008. In addition, per Part II.C.2. b. of the WBN NPDES permit, the noncompliance was reported on the June Discharge Monitoring Report which was sent to the TDEC Nashville office and the Chattanooga Field Office on July 9, 2008 via certified mail. WBN did not receive an NOV from the TDEC. The corrective action was to reinforce the need for timely communication of all limit threats to permit noncompliance.
3. A Biological Oxygen Demand sample collected July 14, 2008 at OSN 111, the sewage treatment plant, was not analyzed by Environmental Science Corporation within the 40 CFR 136 48-hour hold time requirement. As the analytical lab did not notify WBN of the hold time exceedance, WBN was unaware of the hold time exceedance until the following week when the results were received. Since WBN did not have the opportunity to collect an additional sample for the week of E-7 of 12

IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES (continued)

July 14th, this resulted in a missed NPDES sample. In accordance with Part II.C.2. b. of the WBN NPDES permit, the noncompliance was reported on the July Discharge Monitoring Report which was sent the TDEC Nashville office and the Chattanooga Field Office on August 7, 2008 via certified mail. WBN did not receive an NOV from the TDEC. The corrective actions were; (1) Provide WBN expectations for NPDES sample analysis and immediate notification of issues to Environmental Science Corporation, (2) Revise the governing procedure, 0-PI-ENV-3.1, NPDES Plant Effluents, to include an action step to contact the analytical lab in the event the analytical results were not received by the requested date, and (3) WBN requested a two-day turn around time for all weekly NPDES samples from the analytical laboratory.

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

1. The NPDES permit renewal application packet consisting of EPA Form 1, site map, Form 2C, Form 2C addendum, flow schematic, Form 2E, and a permit address form submitted to the State of Tennessee on May 3, 2006 is still pending. Sampling for permit renewal occurred in December 2005 and historical data were compiled from the period of October 1, 2004 through September 30, 2005.
2. In accordance with the TDEC Environmental Permits Handbook, WBN submitted an Application for Information Regarding a Subsurface Sewage Disposal System Permit and Certification of Completion for the security training building septic tank in drainage area Number 13 in April 2008.

TDEC Division of Groundwater Protection inspected the septic tank on April 28, 2008 and approved the construction. PER Number 143393 was written to document that a permit was not applied for prior to construction due to an error in understanding between county, state, and federal policies which govern the installation. The TDEC reported that the issue had been corrected and WBN did not receive an NOV.

3. During June 2008, WBN re-evaluated its industrial activity in drainage areas and in accordance with the TMSP notified the TDEC of the removal of Storm Water Outfall 5 (SW-5) and Storm Water Outfall 7 (SW-7). WBN believes coverage under the Tennessee Multi-Sector General Permit for Industrial Activities Sector L and O is appropriate, consistent with the previous Notice of Coverage E-8 of 12

V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTIFICATIONS (continued) issued for this facility. An up to date SWPPP and supporting documents are available at the site. In a previous SWPPP, SW-5 was incorrectly described as representative of the discharge from Storm Water Outfall SW-2. As SW-2s drainage area is associated with industrial activity and SW-5 no longer has industrial activity associated with it, SW-5 could not be representative of SW-2. Inspections and monitoring continue at SW-2.

A change occurred in the land use for the drainage area associated with SW-7. While previously used for laydown activities (industrial), this area has now been converted for use as office space (non industrial). SW-5 and SW-7 were removed from the Notice of Intent.

4. On September 10, 2008, WBN submitted a minor modification to the TDEC Nashville office for termination of discharges from NPDES Internal Monitoring Point (IMP) 111. The WBN sewage treatment plant had been connected to the Spring City Publicly Owned Treatment Plant effective August 9, 2008 with October 3, 2008 (date the effluent box was completely filled with gravel) as the actual termination date of the discharge from IMP 111.

B. Air Permits WBN is currently operating under Air Permit Number 448529. No changes to this permit were made during the reporting period.

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, 2008 through February 6, 2009 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.

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VI. CHANGES IN FACILITY DESIGN OR OPERATION (continued)

The review, performed in accordance with the guidelines of the Tennessee Valley Authoritys 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 Biphenyl, 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 hazardous or Toxic Substances Control Act 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, 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 eight 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 written to document the site changes reviewed are as follows:

E-10 of 12

VI. CHANGES IN FACILITY DESIGN OR OPERATION (continued)

(1) 19929-Installation of Power & Communications Fiber Optic Line & Fence repositioning at the Unit 1 Staging Area (2) 19869-Generic Nuisance Tree Removal (3) 19554-Yard Holding Pond (YHP) Boat Ramp (4) 19540-Installation of Power & Communications Fiber Optic Line Between the Unit 2 Work Control Center and the Railroad Trailer (5) 19506-Installation of Communications Fiber Optic Line Between the Switchyard fence and Trailer Number 12 (6) 19474-Installation of Communications Fiber Optic Line Between Unit 1 Warehouse A and Warehouse B (7) 19395-Chain Link Fence Between Unit 1 Warehouses A and B (8) 19392-Paint Shop Addition (9) 19273-WBN Training Center Cooling Tower Blowdown to Catch Basin Number 97 (10) 19194-Unit 2 West Parking Lot Light Poles (11) 19063-Transport Generator Rotor from and to WBN via Sequoyah Nuclear Plant (12) 18902-WBN Unit 2 Tree Removal (13) 18868-WBN Unit 2 Warehouse Telecommunication & Fiber Optic Service Construction (14) 18591-Quality Control Office Trailer at the Unit 2 Receiving Warehouse (15) 18532-Sewage Treatment Plant Building Hook-Up to Spring City Line (16) 18415-WBN Unit 2 Condenser Bundle Storage Area & Haul Route (17) 18414-Generic - Chain Link Fences Outside of the Probable Maximum Flood (PMF), Probable Maximum Precipitation (PMP), and Protected Area (PA)

(18) 18413-Generic - Cooling Tower Perimeter Fill Replacement (19) 18378-Generic - Surface Preparation via Sandblasting (20) 18344-Generic - Temporary Warehouse Complex and Loading Dock (21) 18271-Watts Bar Nuclear Plant 500-kV Switchyard Startup Unit 2 - Project No. Z0172 - Work Orders 62189, 62190 & 62191 (22) 18270-Firing Range Trailer, Septic Tank & Field (23) 18268-Dean Building Sidewalk Extension (24) 18217-WBN Unit 2 Powerline Upgrade (25) 18149-Security Shelter (26) 18134-Asphalt Existing Safe Walkway From North Portal Parking Lot to North Portal Entrance (27) 18092-Engineering Quality Building (EQB) Safe Walkway (28) 18088-Drainage Area Number 14 Chain Link Fencing (29) 18087-Drainage Area Number 11 Chain Link Fencing (30) 18079-Drainage Area 2 Chain Link Fencing E-11 of 12

VI. CHANGES IN FACILITY DESIGN OR OPERATION (continued)

All other 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 environmental permits and in compliance with regulations.

In summary, there were no facility design or operational changes from February 7, 2008 to February 6, 2009 which resulted 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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