ML18120A126

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Annual Non-Radiological Environmental Operating Report - 2017
ML18120A126
Person / Time
Site: Watts Bar  Tennessee Valley Authority icon.png
Issue date: 04/30/2018
From: Simmons P
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML18120A126 (10)


Text

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 April 30, 2018 10 cFR 50 4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390 and 50-391

Subject:

Watts Bar Nuclear Plant - Annua! Non-Radiological Environmental Operating Report - 2017 ln accordance with Section 5.4.1, "Routine Reports," of Appendix B, "Environmental Protection Plan (Non-Radiological)," to the Watts Bar Nuclear Plant WBN) Units 1 and2 Operating Licenses, enclosed is the 2017 Annual Non-Radiological Environmental Operating Report for WBN. This report is required to be submitted to the Nuclear Regulatory Commission (NRC) within 90 days following the anniversary of the issuance of the WBN Unit 1 operating license (i.e., February 7 , 1996). This report addresses the period from February 7,2017 through February 6, 2018.

There are no new regulatory commitments in this letter. lf you have any questions concerning this matter, please contact Kim Hulvey, WBN Licensing Manager, at (423) 365-7720.

Respectfully, Paul Simmons Site Vice President Watts Bar Nuclear Plant

U.S. Nuclear Regulatory Commission Page 2 Apri! 30,2018

Enclosure:

Tennessee Valley Authority Watts Bar Nuclear Plant Annual Non-Radiological Environmental Operating Report February 7 ,2017 Through February 6, 2018 cc (Enclosure):

NRC RegionalAdministrator - Region !l NRC Project Manager - Watts Bar Nuclear Plant NRC Senior Resident lnspector - Watts Bar Nuclear Plant

' U.S. Fish and Wildlife Service

TEN NESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT AN N UAL NON.RADIOLOGICAL ENVI RON M ENTAL OPERATING REPORT FEBRUARY 7, 2017 THROUGH FEBRUARY 6, 2018 E-1 of I

TABLE OF CONTENTS

r. INTRODUCT!ON............... ..... E-3 II. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WBN NATIONAL POLLUTANT DTSCHARGE ELTMTNATTON SYSTEM (NPDES) PERMIT ... E-3 IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES.. .............. E.5 V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTTFICATTONS .............. ............ E-6 VI. CHANGES IN FACILIry DESIGN OR OPERATION........... ......E-7 vrr. NoN-RouTrNE REPORTS.......... ........... E-8 V!II. CHANGES IN APPROVED ENVIRONMENTAL PROTECTION PI.AN SPECIFICATIONS ....... E.8 E-2 of 8

I. INTRODUCTION The Tennessee Valley Authority Watts Bar Nuclear Plant (VVBN) Annual Non-Radiological Environmental Operating Report is provided for the period of February 7,2017 through February 6, 2018. This report was prepared in accordance with Appendix B to facility operating licenses NPF-90 and NPF-96, "Environmental Protection Plan (EPP)," Section 5.4.1, "Routine Reports.' This report includes a summary of:

A. Reports previously submitted as specified in the WBN Nationa! Pollutant Discharge Elimination System (NPDES) Permit Number TN0020168.

B. Allspecia! 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 or operation that could involve a significant environmental impact or changes to the findings of the Final Environmental Statement (FES).

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

G. Changes in the approved EPP.

!I. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WBN NATIONAL POLLUTANT DTSCHARGE ELTMINATION SYSTETU (NPDES) pERMtT The following reports were submitted as specified in the WBN NPDES Permit Number TN0020168 and the Tennessee Storm Water Multi-Sector General Permit (TMSP)

Numbers TNR051343 and TNR050000:

A. As required by the NPDES permit, Discharge Monitoring Reports (DMRs) were completed and submitted monthly to the Tennessee Department of Environment and Conservation (TDEC) no later than 15 days after the completion of the reporting period.

B. WBN submitted to the TDEC the "Compliance Survey forWatts Bar Nuclear Plant Outfall 113 Passive Mixing Zone" for'Summer 2016", "Winter 2016" and "Summer 2017". As summarized in the reports, the compliance surveys confirm the adequacy of the passive mixing zone and the adequacy of the thermal model to evaluate the operation of Outfall 113.

C. The annual Biocide/Corrosion Treatment Report was completed and submitted to TDEC priorto the February 15, 2018 deadline.

D. The annualsampling and analysis required by the 2017 and 2018 TMSP for storm water was performed and the annual reports were submitted to the TDEC within 30 days after the sample results were obtained.

E-3 of 8

ll. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WBN NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERIUIIT (continued)

E. DMR Quality Assurance (QA) Laboratory Performance Evaluation Study 37 was completed by and submitted to Environmental Resource Associates, the TDEC, and the Environmental Protection Agency (EPA) prior to the September 1,2017 deadline. The copper value for DMR-QA Study 37 analysis performed and reported by our contract analytical laboratory - Environmenta! Science Corporation, was "Not Acceptable". The lab completed conective actions and reanalysis of the failed parameter was completed with acceptable results.

III. SPECIAL BIOLOGICAL MONITORING REPORTS A. EPP Section4.l.l, "Aquatic Monitoring"

1. Routine semi-annualWhole Effluent Toxicity WET), a.k.a. chronic biotoxicity tests, were conducted on plant effluents and the appropriate reports were submitted as part of the DMR for Outfall Serial Numbers (OSNs) 101 and 113, in June and October 2017 as required by the NPDES permit. All TVA test results were valid for a!! sampling outfalls and dates and for both lC25 tests (P. promelas and C. dubia).
2. A report on the "Biological Monitoring of the Tennessee River near the Watts Bar Nuclear Plant 2012" is not required in accordance with Part lll, 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. TVA determined in January 2013 that these reports, or an equivalent, would be submitted with the permit renewals versus the historical annual basis (last submitted December 29,2015 as a component of the NPDES permit renewal application).

3. ln accordance with the provisions of Tennessee Code Annotated Section 69-7-301 et seq., the Water Resources lnformation Act, WBN submitted the WaterWithdrawal Registration Form for Calendar Year (CY) 2017 to the TDEC prior to the February 15,2018 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 registration information in order to assist bolh TVA and TDEC in carrying out their water management responsibilities.
4. On July 27,2017, TVA submitted 316(b) Compliance Study Reports as required under 40 CFR S 122.21 paragraphs (rX2), (rX4), through (r)(8) to the TDEC.

E-4 of I

lll. SPECIAL BIOLOGICAL MONITORING REPORTS (continued)

B. EPP Section 4.1.2, "Maintenance of Transmission Line Conidors" Listed below are the 500 kV transmission lines associated with WBN and information regarding the maintenance that was performed on each line:

500 kV Line ldentifier Maintenance Performed No chemical or herbicide was utilized on these Bull Run - Watts Bar (Note Below) lines within the period.

Watts Bar - Roane No chemical or herbicide was utilized on these lines within the period.

Watts Bar - Volunteer No chemical or herbicide was utilized on these Iines within the period.

Watts Bar - Sequoyah 1 (Note Below) No chemical or herbicide utilized on these lines within the period.

Watts Bar - Sequoyah 2 (Note Below) No chemical or herbicide utilized on these Iines within the period.

Note:

The transmission line designated as Bull Run - Sequoyah in previous versions of this report has been split into the following transmission lines: 1) Watts Bar - Sequoyah 1 , and 2) Bull Run -

Watts Bar.

IV. ENVIRONMENTALPROTECTIONPLANNONCOMPLIANCES WBN received zero Notice of Violations (NOVs) from February 2017 to February 2018.

ln accordance with the NPDES permit, the following noncompliances were reported to the TDEC.

A. WBN did not record valid temperature readings at outfall 101 from November 23, 2017 through November 25, 2017. The NPDES permit requires the station to monitor for temperature daily at outfall 101. Temperature element 0-TE-27-99 is used to monitor temperature continuously at outfall 101. There is also a battery powered backup monitor that can monitor temperature if needed in order to comply with the NPDES permit. From November 23, 2017 through November 25,2017,0-TE-27-99 was not recording valid temperature readings. At the same time, the battery power backup monitor lost power. Therefore, no temperature data was recorded for that period. Conective Actions: (1) Enhance site procedures; (2) Verify operation of battery powered backup monitor daily whenever 0-TE-27-99 is not recoding valid temperature readings.

E-5 of I

V. CHANGES iiADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTIF!CATIONS A. NPDES Permit Number TN 0020168

'1. ln accordance with 40 CFR 122.22, TVA updated the NPDES signatory authority authorizing the positions of WBN Plant Manager and the Chemistry and Environmental Senior Manager as the duly authorized persons for signing reports required under the permit as wel! as other WBN compliance reports.

2. TVA submitted a request for a waiver of the Section ($ 122.21 (r)(9) through (13) of the $ 316(b) rule on September 5, 2017 . This request was based largely on the flow reductions associated with the facility's closed-cycle recirculating cooling water system, as augmented by a supplemental cooling water system, and upon the unique use of two distinct waterbodies as cooling water sources.

B. Air Permits Number 463822

1. ln accordance with 1200-03-09-.02(11)(b)21(i) of the Tennessee Air Pollution Control Regulations, TVA updated the Air signatory authority authorizing the position of WBN Plant Manager as the duly authorized persons for signing reports required under the permit as well as otherWBN compliance reports.
2. TVA applied for the Air permit to include the DG-8 Construction Permit for a TSOB Building Replacement Emergency Generator Diesel Engine in March, 2016. The TDEC finalized the approval in March 2017.

E-6 of I

VI. CHANGES IN FACILITY DESIGN OR OPERATION ln accordance with EPP Section 3.1, "Plant Design and Operation," facility design and operationa! changes were reviewed for potential effect on the environment as described below. A review of facility design and operational changes proposed from February 7, 2017, through February 6, 2018, 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.

o lnvolved the use of hazardous material.

. Required physical construction.

The review, performed in accordance with the guidelines of TVA's National Environmental Policy Act (NEPA) Program, documented that design and operational changes did not involve an unreviewed environmenta! question. The following criteria were used to identify those projects with a potentialfor environmental effects:

A. Waste stream generation/alteration:

Air, Hazardous Waste, Solid Waste, Polychlorinated Biphenyls, Asbestos, or Wastewater B. Permit Acquisition/Modification:

NPDES, Air, lnert Landfill, or Other C. Hazardous Materials:

Hazardous Materials that are environmentally unfriendly and are likely to generate a Resource Conservation and Recovery Act (RCRA) hazardous or Toxic Substances ControlAct (TSCA) 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, Tenestrial Ecology Effects, Protected Species Effects, Sensitive Habitat Effects, Visual Effects, Historical, Cultural and Archeological Effects, Changes in Site Land Use, or Controversy.

E. Temporary Alterations:

There were no temporary alterations conducted during this period that met the environmental impact criteria.

Desion and Operationa! Chanoes Most of the design and operational changes conducted during this period did not meet the environmental impact criteria. There were 7 facility design and operational changes made during this reporting 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.

E-7 of I

Vl. CHANGES lN FACILITY DESIGN OR OPERATION (continued)

The following EnvironmentalAssessments (EAs) written to document the review of site changes are as follows:

(1) Watts Bar Nuclear Plant Unit 2 Steam Generator Replacement , December 5, 2017 Those Categorical Exclusion Checklists (CECs) written to document the review of site changes are as follows:

(1) 36515 Clean 11 Replacement Thimbles Tubes for instaflation during the WBN Unit 1 Refueling Outage (2) 37073 WBN Water Treatment Plant Refurbishment (3) 37110 Watts Bar Nuclear Plant FLEX Ramp Modification (4) 37356 FP610429, Feed Water Heater/Heater Drain Tank, Digital Control System upgrade. Single Point Vulnerability (SPV) elimination (5) 37436 lnstallation of new Ruxitlary ControlAir Subsystem (nCnS) swing air compressor and air dryer skid (6) 37854 Replacement of the system 030 Control Rod Drive (CRD)

Equipment Room Air Conditioning Units 14, 18, 2A and 28 located in the Auxiliary Building on EL. 782.0 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 environmenta! permits and in compliance with regulations.

ln summary, there were no facility designs or operational changes from February 7,2017 to February 6, 2018, which resulted in an unreviewed environmental question.

VII. NON.ROUTINE REPORTS No non-routine reports for EPP Section 4.2were issued during this reporting period.

VIII. CHANGES IN APPROVED ENVIRONMENTAL PROTECTION PLAN SPECIFICAT!ONS No changes were made to the WBN operating license, Appendix B, EPP during the reporting period.

E-8 of 8

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 April 30, 2018 10 cFR 50 4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390 and 50-391

Subject:

Watts Bar Nuclear Plant - Annua! Non-Radiological Environmental Operating Report - 2017 ln accordance with Section 5.4.1, "Routine Reports," of Appendix B, "Environmental Protection Plan (Non-Radiological)," to the Watts Bar Nuclear Plant WBN) Units 1 and2 Operating Licenses, enclosed is the 2017 Annual Non-Radiological Environmental Operating Report for WBN. This report is required to be submitted to the Nuclear Regulatory Commission (NRC) within 90 days following the anniversary of the issuance of the WBN Unit 1 operating license (i.e., February 7 , 1996). This report addresses the period from February 7,2017 through February 6, 2018.

There are no new regulatory commitments in this letter. lf you have any questions concerning this matter, please contact Kim Hulvey, WBN Licensing Manager, at (423) 365-7720.

Respectfully, Paul Simmons Site Vice President Watts Bar Nuclear Plant

U.S. Nuclear Regulatory Commission Page 2 Apri! 30,2018

Enclosure:

Tennessee Valley Authority Watts Bar Nuclear Plant Annual Non-Radiological Environmental Operating Report February 7 ,2017 Through February 6, 2018 cc (Enclosure):

NRC RegionalAdministrator - Region !l NRC Project Manager - Watts Bar Nuclear Plant NRC Senior Resident lnspector - Watts Bar Nuclear Plant

' U.S. Fish and Wildlife Service

TEN NESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT AN N UAL NON.RADIOLOGICAL ENVI RON M ENTAL OPERATING REPORT FEBRUARY 7, 2017 THROUGH FEBRUARY 6, 2018 E-1 of I

TABLE OF CONTENTS

r. INTRODUCT!ON............... ..... E-3 II. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WBN NATIONAL POLLUTANT DTSCHARGE ELTMTNATTON SYSTEM (NPDES) PERMIT ... E-3 IV. ENVIRONMENTAL PROTECTION PLAN NONCOMPLIANCES.. .............. E.5 V. CHANGES MADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTTFICATTONS .............. ............ E-6 VI. CHANGES IN FACILIry DESIGN OR OPERATION........... ......E-7 vrr. NoN-RouTrNE REPORTS.......... ........... E-8 V!II. CHANGES IN APPROVED ENVIRONMENTAL PROTECTION PI.AN SPECIFICATIONS ....... E.8 E-2 of 8

I. INTRODUCTION The Tennessee Valley Authority Watts Bar Nuclear Plant (VVBN) Annual Non-Radiological Environmental Operating Report is provided for the period of February 7,2017 through February 6, 2018. This report was prepared in accordance with Appendix B to facility operating licenses NPF-90 and NPF-96, "Environmental Protection Plan (EPP)," Section 5.4.1, "Routine Reports.' This report includes a summary of:

A. Reports previously submitted as specified in the WBN Nationa! Pollutant Discharge Elimination System (NPDES) Permit Number TN0020168.

B. Allspecia! 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 or operation that could involve a significant environmental impact or changes to the findings of the Final Environmental Statement (FES).

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

G. Changes in the approved EPP.

!I. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WBN NATIONAL POLLUTANT DTSCHARGE ELTMINATION SYSTETU (NPDES) pERMtT The following reports were submitted as specified in the WBN NPDES Permit Number TN0020168 and the Tennessee Storm Water Multi-Sector General Permit (TMSP)

Numbers TNR051343 and TNR050000:

A. As required by the NPDES permit, Discharge Monitoring Reports (DMRs) were completed and submitted monthly to the Tennessee Department of Environment and Conservation (TDEC) no later than 15 days after the completion of the reporting period.

B. WBN submitted to the TDEC the "Compliance Survey forWatts Bar Nuclear Plant Outfall 113 Passive Mixing Zone" for'Summer 2016", "Winter 2016" and "Summer 2017". As summarized in the reports, the compliance surveys confirm the adequacy of the passive mixing zone and the adequacy of the thermal model to evaluate the operation of Outfall 113.

C. The annual Biocide/Corrosion Treatment Report was completed and submitted to TDEC priorto the February 15, 2018 deadline.

D. The annualsampling and analysis required by the 2017 and 2018 TMSP for storm water was performed and the annual reports were submitted to the TDEC within 30 days after the sample results were obtained.

E-3 of 8

ll. REPORTS PREVIOUSLY SUBMITTED AS SPECIFIED IN THE WBN NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERIUIIT (continued)

E. DMR Quality Assurance (QA) Laboratory Performance Evaluation Study 37 was completed by and submitted to Environmental Resource Associates, the TDEC, and the Environmental Protection Agency (EPA) prior to the September 1,2017 deadline. The copper value for DMR-QA Study 37 analysis performed and reported by our contract analytical laboratory - Environmenta! Science Corporation, was "Not Acceptable". The lab completed conective actions and reanalysis of the failed parameter was completed with acceptable results.

III. SPECIAL BIOLOGICAL MONITORING REPORTS A. EPP Section4.l.l, "Aquatic Monitoring"

1. Routine semi-annualWhole Effluent Toxicity WET), a.k.a. chronic biotoxicity tests, were conducted on plant effluents and the appropriate reports were submitted as part of the DMR for Outfall Serial Numbers (OSNs) 101 and 113, in June and October 2017 as required by the NPDES permit. All TVA test results were valid for a!! sampling outfalls and dates and for both lC25 tests (P. promelas and C. dubia).
2. A report on the "Biological Monitoring of the Tennessee River near the Watts Bar Nuclear Plant 2012" is not required in accordance with Part lll, 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. TVA determined in January 2013 that these reports, or an equivalent, would be submitted with the permit renewals versus the historical annual basis (last submitted December 29,2015 as a component of the NPDES permit renewal application).

3. ln accordance with the provisions of Tennessee Code Annotated Section 69-7-301 et seq., the Water Resources lnformation Act, WBN submitted the WaterWithdrawal Registration Form for Calendar Year (CY) 2017 to the TDEC prior to the February 15,2018 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 registration information in order to assist bolh TVA and TDEC in carrying out their water management responsibilities.
4. On July 27,2017, TVA submitted 316(b) Compliance Study Reports as required under 40 CFR S 122.21 paragraphs (rX2), (rX4), through (r)(8) to the TDEC.

E-4 of I

lll. SPECIAL BIOLOGICAL MONITORING REPORTS (continued)

B. EPP Section 4.1.2, "Maintenance of Transmission Line Conidors" Listed below are the 500 kV transmission lines associated with WBN and information regarding the maintenance that was performed on each line:

500 kV Line ldentifier Maintenance Performed No chemical or herbicide was utilized on these Bull Run - Watts Bar (Note Below) lines within the period.

Watts Bar - Roane No chemical or herbicide was utilized on these lines within the period.

Watts Bar - Volunteer No chemical or herbicide was utilized on these Iines within the period.

Watts Bar - Sequoyah 1 (Note Below) No chemical or herbicide utilized on these lines within the period.

Watts Bar - Sequoyah 2 (Note Below) No chemical or herbicide utilized on these Iines within the period.

Note:

The transmission line designated as Bull Run - Sequoyah in previous versions of this report has been split into the following transmission lines: 1) Watts Bar - Sequoyah 1 , and 2) Bull Run -

Watts Bar.

IV. ENVIRONMENTALPROTECTIONPLANNONCOMPLIANCES WBN received zero Notice of Violations (NOVs) from February 2017 to February 2018.

ln accordance with the NPDES permit, the following noncompliances were reported to the TDEC.

A. WBN did not record valid temperature readings at outfall 101 from November 23, 2017 through November 25, 2017. The NPDES permit requires the station to monitor for temperature daily at outfall 101. Temperature element 0-TE-27-99 is used to monitor temperature continuously at outfall 101. There is also a battery powered backup monitor that can monitor temperature if needed in order to comply with the NPDES permit. From November 23, 2017 through November 25,2017,0-TE-27-99 was not recording valid temperature readings. At the same time, the battery power backup monitor lost power. Therefore, no temperature data was recorded for that period. Conective Actions: (1) Enhance site procedures; (2) Verify operation of battery powered backup monitor daily whenever 0-TE-27-99 is not recoding valid temperature readings.

E-5 of I

V. CHANGES iiADE TO APPLICABLE STATE AND FEDERAL PERMITS AND CERTIF!CATIONS A. NPDES Permit Number TN 0020168

'1. ln accordance with 40 CFR 122.22, TVA updated the NPDES signatory authority authorizing the positions of WBN Plant Manager and the Chemistry and Environmental Senior Manager as the duly authorized persons for signing reports required under the permit as wel! as other WBN compliance reports.

2. TVA submitted a request for a waiver of the Section ($ 122.21 (r)(9) through (13) of the $ 316(b) rule on September 5, 2017 . This request was based largely on the flow reductions associated with the facility's closed-cycle recirculating cooling water system, as augmented by a supplemental cooling water system, and upon the unique use of two distinct waterbodies as cooling water sources.

B. Air Permits Number 463822

1. ln accordance with 1200-03-09-.02(11)(b)21(i) of the Tennessee Air Pollution Control Regulations, TVA updated the Air signatory authority authorizing the position of WBN Plant Manager as the duly authorized persons for signing reports required under the permit as well as otherWBN compliance reports.
2. TVA applied for the Air permit to include the DG-8 Construction Permit for a TSOB Building Replacement Emergency Generator Diesel Engine in March, 2016. The TDEC finalized the approval in March 2017.

E-6 of I

VI. CHANGES IN FACILITY DESIGN OR OPERATION ln accordance with EPP Section 3.1, "Plant Design and Operation," facility design and operationa! changes were reviewed for potential effect on the environment as described below. A review of facility design and operational changes proposed from February 7, 2017, through February 6, 2018, 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.

o lnvolved the use of hazardous material.

. Required physical construction.

The review, performed in accordance with the guidelines of TVA's National Environmental Policy Act (NEPA) Program, documented that design and operational changes did not involve an unreviewed environmenta! question. The following criteria were used to identify those projects with a potentialfor environmental effects:

A. Waste stream generation/alteration:

Air, Hazardous Waste, Solid Waste, Polychlorinated Biphenyls, Asbestos, or Wastewater B. Permit Acquisition/Modification:

NPDES, Air, lnert Landfill, or Other C. Hazardous Materials:

Hazardous Materials that are environmentally unfriendly and are likely to generate a Resource Conservation and Recovery Act (RCRA) hazardous or Toxic Substances ControlAct (TSCA) 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, Tenestrial Ecology Effects, Protected Species Effects, Sensitive Habitat Effects, Visual Effects, Historical, Cultural and Archeological Effects, Changes in Site Land Use, or Controversy.

E. Temporary Alterations:

There were no temporary alterations conducted during this period that met the environmental impact criteria.

Desion and Operationa! Chanoes Most of the design and operational changes conducted during this period did not meet the environmental impact criteria. There were 7 facility design and operational changes made during this reporting 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.

E-7 of I

Vl. CHANGES lN FACILITY DESIGN OR OPERATION (continued)

The following EnvironmentalAssessments (EAs) written to document the review of site changes are as follows:

(1) Watts Bar Nuclear Plant Unit 2 Steam Generator Replacement , December 5, 2017 Those Categorical Exclusion Checklists (CECs) written to document the review of site changes are as follows:

(1) 36515 Clean 11 Replacement Thimbles Tubes for instaflation during the WBN Unit 1 Refueling Outage (2) 37073 WBN Water Treatment Plant Refurbishment (3) 37110 Watts Bar Nuclear Plant FLEX Ramp Modification (4) 37356 FP610429, Feed Water Heater/Heater Drain Tank, Digital Control System upgrade. Single Point Vulnerability (SPV) elimination (5) 37436 lnstallation of new Ruxitlary ControlAir Subsystem (nCnS) swing air compressor and air dryer skid (6) 37854 Replacement of the system 030 Control Rod Drive (CRD)

Equipment Room Air Conditioning Units 14, 18, 2A and 28 located in the Auxiliary Building on EL. 782.0 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 environmenta! permits and in compliance with regulations.

ln summary, there were no facility designs or operational changes from February 7,2017 to February 6, 2018, which resulted in an unreviewed environmental question.

VII. NON.ROUTINE REPORTS No non-routine reports for EPP Section 4.2were issued during this reporting period.

VIII. CHANGES IN APPROVED ENVIRONMENTAL PROTECTION PLAN SPECIFICAT!ONS No changes were made to the WBN operating license, Appendix B, EPP during the reporting period.

E-8 of 8