ML20114E322

Submittal of 2019 Annual Environmental Operating Report (Non-Radiological)

ML20114E322
Person / Time
Site:	Comanche Peak
Issue date:	04/23/2020
From:	Hicks J Luminant, TXU Energy, Vistra Energy, Vistra Operating Co. (VistraOpCo)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP- 202000210, TXX- 20021
Download: ML20114E322 (11)

Text

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• energy 1 m Luminant Jack C. Hicks Manager, Regulatory Affairs Lumi n ant P. O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 0 254.8 97 .6725 CP-202000210 TXX-20021 U.S. Nuclear Regu latory Comm ission Ref CPNPP EPP ATTN: Document Control Desk Washington, DC 20555-0001 April 23, 20 20

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 AND 50-446 2019 ANNUAL ENVIRONMENTAL OPERATING REPORT (NON-RADIOLOGICA L)

Dea r Sir or Madam :

Vistra Operations Company LLC ("Vistra OpCo" ) hereby subm its the Comanche Peak Nuclear Power Plant (C PNPP) 2019 An nu al Environmental Operating Repo rt (Non-Radiological). The attached report is provided pursuant t o Appendix B to the CPNPP Units 1 and 2 Facility Operating License Nos. NPF 87 & NPF-89 (Environmental Protection Plan). Th e report covers the period from Janu ary 1, 2019 to Dece mber 31, 2019.

This co mmunication co ntains no new co mm itm ents rega rd ing CPNPP Units 1 and 2.

Should you have any questions, please contact Jim Ba rn ette at (254) 897-5866 or Mark Clark at (254) 897-6835 .

Sincere ly, 6555 SIERRA DRIVE IRVING, TEXAS 75039 0214-812-4600 VISTRAENERGY.COM

TXX-20021 Page 2 of 2

Attachment:

1 CPNPP 2019 Annual Environmental Operating Report (Non-Radiological) (9 pages) c- Scott A. Morris, Region IV Dennis Galvin, NRR Resident Inspectors, Comanche Peak

VISTRA OPERATIONS COMPANY, LLC COMANCHE PEAK NUCLEAR POWER PLANT UNITS 1 & 2 2019 ANNUAL ENVIRONMENTAL OPERATING REPORT (NON-RADIOLOGICAL)

FACILITY OPERATING LICENSE NOs. NPF-87 & 89 1

I. INTRODUCTION This report describes implementation of the Environmental Protection Plan (EPP) for the calendar year 2019 as required by Appendix B to Facility Operating License Nos. NPF-87 & 89 for Comanche Peak Nuclear Power Plant (CPNPP) for Units 1 & 2.

During 2019, the CPNPP Non-Radiological Environmental Monitoring Program was effective in implementing and monitoring all CPNPP environmental regulatory commitments. Program effectiveness in 2019 was substantiated by both Environmental Services (ES) - Corporate audits and Texas Commission on Environmental Quality (TCEQ) inspections concerning the CPNPP Environmental program.

II. SCOPE Section 5.4.1 of the EPP requires that CPNPP submit to the NRC an Annual Environmental Operating Report that shall address the following environmental protection activities:

A. Summaries and analyses of the results of the environmental protection activities required by Section 4.2 of the EPP, including a comparison with related preoperational studies, operational controls (as appropriate), and previous non-radiological environmental monitoring reports, and an assessment of the observed impacts of plant operation on the environment. If harmful effects or evidence of trends toward irreversible damage to the environment are observed, a detailed analysis of the data and a proposed course of mitigating actions are required. Section 4.2 of the EPP pertains to results from:

1. Groundwater levels and station water use monitoring.

2. Water treatment facility outages impact assessment and reporting.

B. The report shall also include:

1. A list of EPP non-compliances and the associated corrective actions.

2. A list of all changes in station design and operation, tests, and experiments made in accordance with Subsection 3.1 of the EPP which involved a potentially significant unreviewed environmental question.

3. A list of non-routine reports submitted in accordance with Subsection 5.4.2 of the EPP.

4. A summary list of Texas Pollutant Discharge Elimination System (TPDES) permit related reports relative to matters identified in Subsection 2.1 of the EPP which were submitted to the Texas Commission on Environmental Quality (TCEQ) during the report period. Subsection 2.1 of the EPP pertains to aquatic matters that are addressed by the effluent limitations, and the monitoring requirements contained in the TCEQ TPDES station wastewater discharge permit.

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III. RESULTS OF ACTIVITIES A. As required by Subsection 4.2 of the EPP, the following are summaries and analyses of the environmental protection activities during 2019. Based on the results of these activities, there were no observed adverse environmental impacts resulting from plant operation during 2019.

1. Groundwater Pumpage As indicated in Table 2, groundwater pumpage during 2019 averaged 0.076 gals /min. (gpm) or 39,800 total gallons withdrawn for the year. CPNPP continues to be supplied by Somervell County Water District (SCWD) which started in January 2012. Groundwater withdrawal dropped to <1 gpm after Somervell County Water District (SCWD) became our supplier.

Groundwater withdrawn during 2019 was used primarily for potable and sanitary purposes. No groundwater was used to supplement the stations Surface Water Treatment System.

The average annual pumpage rate of 0.076 gpm for 2019 represents <1% of the predicted operational pumpage (127 gpm) identified in Section 3.3 of the Stations Environmental Report - Operational License Stage. This rate also represents approximately 0.1 % of the actual average withdrawal rate (158 gpm) reported in the Stations Final Environmental Statement - Operating License Stage (Section 5.3.1.2) for the period 1975 to May 1979.

2. Groundwater Levels As indicated in Table 1, the groundwater level in the on-site observation well OB-3 (intersection of Highway 56 and the Plant Access Road) fluctuated during 2019 from a low level in October of 619.63 ft. Mean Sea Level (MSL) to a high level in December of 623.88 ft. MSL. Overall, the water level in OB-3 during the reporting period (January through December) decreased 1.01 ft. = 0.31 m The 2019 annual average groundwater levels in wells OB-3 and OB-4 were 621.7 ft. MSL and 561.34 ft. MSL respectively.

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3. Surface Water Treatment System Operation The stations Water Treatment System processed 199.4 MGD of surface water during 2019 for plant process use. No outages in 2019 that required reporting in accordance with Section 4.2.2 of the EPP.

The following is a summary list of monthly surface water usage:

Month MGD Clarified January 18.80 February 16.80 March 17.27 April 15.59 May 16.28 June 15.87 July 12.61 August 18.60 September 16.61 October 17.11 November 16.70 December 17.20 Total annual production 199.4 B. EPP Noncompliance and Corrective Actions - Subsection 5.4.1(1)

There were no non-compliances with the requirements of the EPP during the reporting period.

C. Changes in Station Design or Operation, Tests, and Experiments Made in Accordance with Subsection 3.1 Which Involved a Potentially Significant Unreviewed Environmental Question.

There were no changes in station design, operation, tests or experiments conducted during the reporting period that are reportable under this subsection.

D. Non-routine Reports Submitted in Accordance with Subsection 5.4.2 None 4

E. Texas Pollutant Discharge Elimination System (TPDES) Permit-Related Reports Relative to Matters Identified in Subsections 2.1 and 5.4.1

1. Routine monthly electronic Discharge Monitoring Reports (netDMRs) for all wastewater outfalls were submitted to the Texas Commission on Environmental Quality (TCEQ) for each month during 2019 via EPAs netDMR tool Central Data Exchange (CDX)

2. Bio-monitoring (e.g. whole effluent toxicity (WET) testing was on a bi-annual frequency in 2019 for water flea and annual frequency for fathead minnow. All required test passed satisfactorily.

a. Chronic static renewal survival and reproduction test using water flea (Ceriodaphnia dubia) Method 1002.0.

b. Chronic static renewal 7-day larval survival and growth testing using fathead minnows (Pimephales promelas) Method 1000.0

3. There were no excursions in 2019 with reference to TPDES wastewater discharge permit.

4. There were nine (9) incidental spills in 2019 with none being reportable.

Petroleum - 4 Chemical - 1 Sewage - 1 Process Water - 1 5

TABLE 1 2019

SUMMARY

OF GROUNDWATER LEVELS IN OBSERVATION WELLS ANNUAL GROUNDWATER LEVEL CHANGE FOR 2019:

Well OB-3: 273.20 ft. - 274.21 ft. = - 1.01 ft. = 0.31 m (decrease)

Well OB-4: 285.76 ft. - 291.23 ft. = - 5.47 ft. = 1.67 m (decrease)

NOTES:

(1) Depth to water table (ft.)

(2) Water table elevation (ft.) Mean Sea Level (MSL)

WELL OB-3 WELL OB-4 MONTH (G-3) (G-4)

DEPTH (1) MSL (2) DEPTH (1) MSL (2)

January 273.20 620.93 285.76 562.12 February 272.57 621.56 285.45 562.43 March 272.41 621.72 286.17 561.71 April 271.72 622.41 284.63 563.25 May 271.61 622.52 284.60 563.28 June 270.53 623.60 280.87 567.01 July 270.25 623.88 280.67 567.21 August 270.90 623.23 284.99 562.89 September 273.31 620.82 291.14 556.74 October 274.50 619.63 291.88 556.00 November 273.95 620.18 291.04 556.84 December 274.21 619.92 291.23 556.65 6

Annual Production Well Report for Recreation/Training System YEAR 2019 Well Reading Monthly Well Last Day of Well Cumulative Gallons Per Yearly Month Total Total Number Total Day Monthly Cumulative Month (gallons) (gallons) (gallons) Days/Month Days/Year (average) GPM GPM December 429300 January 432500 3200 3200 31 31 103.23 0.072 0.0717 February 436200 3700 6900 28 59 132.14 0.092 0.0812 March 439500 3300 10200 31 90 106.45 0.074 0.0787 April 443200 3700 13900 30 120 123.33 0.086 0.0804 May 446100 2900 16800 31 151 93.55 0.065 0.0773 June 449600 3500 20300 30 181 116.67 0.081 0.0779 July 454000 4400 24700 31 212 141.94 0.099 0.0809 August 457300 3300 28000 30 242 110.00 0.076 0.0803 September 460700 3400 31400 31 273 109.68 0.076 0.0799 October 464300 3600 35000 31 304 116.13 0.081 0.0800 November 466500 2200 37200 30 334 73.33 0.051 0.0773 December 469100 2600 39800 31 365 83.87 0.058 0.0757 Totals 2600 39800 365 0.0757 NOTE: All other site wells plugged in 2012 7

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