AEP-NRC-2013-95, Submittal of Turbine Room Sump Ph Lower Limit Exceedance
| ML13353A045 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/12/2013 |
| From: | Scarpello M Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| AEP-NRC-2013-95 | |
| Download: ML13353A045 (10) | |
Text
INDIANA Indiana Michigan Power MICHIGAN 0 Cook Nuclear Plant POW.ER One Cook Place Bridgman, MI 49106 A unit of American Electric Power IndianaMichiganPower.com December 12, 2013 AEP-NRC-2013-95 10 CFR 50.4 Docket Nos.: 50-315 50-316 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Donald C. Cook Nuclear Plant Units 1 & 2 SUBMITTAL OF TURBINE ROOM SUMP pH LOWER LIMIT EXCEEDANCE
References:
- 1. Letter from J. H. Harner, Indiana Michigan Power Company (I&M), to K. Jordan, Michigan Department of Environmental Quality (MDEQ), "American Electric Power Company, Donald C. Cook Nuclear Plant, Groundwater Permit No. GW1 810102," dated November 20, 2013.
- 2. Letter from J. H. Harner, I&M, to K. Jordan, MDEQ, "American Electric Power Company, Donald C. Cook Nuclear Plant, Groundwater Permit No. GW1810102," dated November 27, 2013.
By Reference 1, Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, submitted to the Michigan Department of Environmental Quality (MDEQ), a notification of Turbine Room Sump (Outfall OOD) pH lower limit exceedance for Groundwater Permit GW1 810102. I&M is submitting this report as required by CNP's Environmental Technical Specification, Part II - Nonradiological Environmental Protection Plan, Section 5.4.2. On November 14, 2013, between 1747 hours0.0202 days <br />0.485 hours <br />0.00289 weeks <br />6.647335e-4 months <br /> and 1752 hours0.0203 days <br />0.487 hours <br />0.0029 weeks <br />6.66636e-4 months <br />, the Turbine Room Sump pH lower limit of 6.5 was exceeded.
During this period, a discharge of approximately 9400 gallons at a pH range of 2.5 - 2.4 to the onsite absorption pond occurred. Turbine Room Sump pH value of 8.4 was recorded on November 15, 2013, at 0220 hours0.00255 days <br />0.0611 hours <br />3.637566e-4 weeks <br />8.371e-5 months <br /> during the next discharge period, which is within CNP's Groundwater Permit pH range of 6.5 - 9.5. (This date was incorrectly documented as November 13, 2013, in Reference 1, but correctly documented in Reference 2).
By Reference 2, I&M submitted to the MDEQ a 60-day follow-up notification as required by GW1 810102. The event was caused when a tank overflowed during a transfer of sulfuric acid from the main tank. Some of the acid overflowed the secondary containment and flowed to the turbine room sump. The pH of the sump dropped to a value of 2.4. The sump level was rising and in order to prevent an overflow of the sump, a small volume was pumped to the onsite absorption pond to clear the level alarm. The pH of the pond was 7.7 on November 18,2013, which is within CNP's Groundwater Permit range of 6.5 - 9.5. To correct this event, the sump was neutralized until the correct pH levels were obtained. Corrective action taken to preclude repetition of this event is being managed by the Human Resources Organization, as I&M's evaluation identified this event as an isolated procedure violation.
There was no impact to the environment as a result of this event.
C OD
U.S. Nuclear Regulatory Commission AEP-NRC-2013-95 Page 2 Reference 1 and Reference 2 are provided as enclosures to this letter in accordance with CNP's Environmental Technical Specification, Part II - Nonradiological Environmental Protection Plan, Section 5.4.2. This letter contains no new commitments. Should you have any questions, please contact Jon Harner, Environmental Manager, at (269) 465-5901, extension 2102.
Sincerely, Michael K. Scarpello Regulatory Affairs Manager
Enclosures:
- 1. Letter from J. H. Harner, Indiana Michigan Power Company (I&M), to K. Jordan, Michigan Department of Environmental Quality (MDEQ), "American Electric Power Company, Donald C. Cook Nuclear Plant, Groundwater Permit No. GW1810102," dated November 20, 2013.
- 2. Letter from J. H. Harner, I&M, to K. Jordan, MDEQ, "American Electric Power Company, Donald C. Cook Nuclear Plant, Groundwater Permit No. GW1810102," dated November 27, 2013.
KMH/amp c: J. T. King - MPSC S. M. Krawec - AEP Ft. Wayne NRC Resident Inspector, w/o enclosure C. D. Pederson - NRC Region III T. J. Wengert - NRC Washington, DC
ENCLOSURE 1 TO AEP-NRC-2013-95 Letter from J. H. Harner, Indiana Michigan Power Company (I&M), to K. Jordan, Michigan Department of Environmental Quality (MDEQ), "American Electric Power Company, Donald C. Cook Nuclear Plant, Groundwater Permit No. GW1810102," dated November 20, 2013.
INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant P!FER~* One Cook Place Bridgman, MI 49106 A unit of American ElectricPower IndianaMichiganPower.com Mr. Kameron Jordan, District Supervisor Michigan Department of Environmental Quality Surface Water Quality Division 7953 Adobe Road Kalamazoo, MI 49009 November 20, 2013 Re: American Electric Power Company Donald C. Cook Nuclear Plant Groundwater Permit No. GW1810102
Dear Mr. Jordan:
This notification is made pursuant to Cook Nuclear Plant's Groundwater Permit GW1810102, Part I.11.b, Compliance Requirements.
On November 14, 2013, the pH lower limit was exceeded at Outfall OOD, Turbine Room Sump (TRS) . Between 1747 hrs and 1752 hrs on November 14, 2013 a discharge of approximately 9400 gallons at a pH range of 2.5 - 2.4 to the on-site absorption pond occurred. This exceeds the permit minimum pH limit of 6.5.
The discharge was performed to prevent overflowing the TRS, and was isolated as soon as practical.
As required by Part I.1l.c, we have resampled using the on-line pH meter data. A pH value of 8.4 was recorded on November 13, 2013 at 0220 hrs during the next discharge period.
As required by Part I.11.d, we will submit a written report to the Kalamazoo Office within 60 days (due date January 13, 2014).
Please contact me at telephone (269) 465-5901 ext. 2102 if you have any questions regarding this information.
Sincerely, 6 9* #
Jon H. Harner Environmental Manager Donald C. Cook Nuclear Plant c: Mr. Steve Norton, MDEQ - Kalamazoo USNRC per Appendix B. T.S.
Mr. Kameron Jordan TRS pH exceedence Page 2 November 20, 2013 I certify under penalty of law that I have personally examined and am familiar with the information submitted on this and all attached documents, and based on my inquiry of those individuals immediately responsible for obtaining the information, I believe the submitted information is true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine And imprisonment.
J.H. Harner Environmental Manager
Mr. Kameron Jordan TRS pH exceedence Page 3 November 20, 2013 bc: S. M. Partin J. P. Gebbie J. H. Harner C. E. Hawk R. E. Hite L. J. Weber M. K. Scarpello W. H. Schalk J. C. Krieger B. K. Zordell NDM MDEQ File
ENCLOSURE 2 TO AEP-NRC-2013-95 Letter from J. H. Harner, I&M, to K. Jordan, MDEQ, "American Electric Power Company, Donald C. Cook Nuclear Plant, Groundwater Permit No. GW1810102," dated November 27, 2013.
INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant POWER" PCMEROBridgman, One Cook Place Ml 49106 A unit of American Electric Power IndianaMichiganPower.com Mr. Kameron Jordan, District Supervisor Michigan Department of Environmental Quality Surface Water Quality Division 7953 Adobe Road Kalamazoo, MI 49009 November 27, 2013 Re: American Electric Power Company Donald C. Cook Nuclear Plant (CNP)
Groundwater Permit No. GW1810102
Dear Mr. Jordan:
This notification is made pursuant to Cook Nuclear Plant's Groundwater Permit GW1810102, Part I.ll.d, Compliance Requirements.
This letter is a follow-up letter to our previous notification dated November 20, 2013. On November 14, 2013, the pH lower limit was exceeded at Outfall 0OD, Turbine Room Sump. Between 1747 hrs to 1752 hrs on November 14, 2013, a discharge of approximately 9400 gallons at a pH range of 2.5 - 2.4 to the on-site absorption pond occurred. This exceeds the permit minimum pH limit of 6.5.
As required by Part I.ll.c, we have resampled using the on-line pH meter data.-A pH value of 8.4 was recorded on November 15, 2013, at 0220 hrs.
during the next discharge period.
The following is a summary of an internal evaluation of the cause for the pH lower limit to be exceeded:
The neutralization system for Outfall COD was removed from service for maintenance at the time. The event was caused when a tank overflowed during a transfer of sulfuric acid from the main tank. Some (approximately 50 gallons) of the acid overflowed the secondary containment and flowed to the turbine room sump (Outfall COD) . The pH of the sump dropped to a value of 2.4. The sump level was rising, and in order to prevent an overflow of the sump, a small volume was pumped to the onsite absorption pond to clear the level alarm. There were no impacts to the receiving pond. The pH of the pond was 7.7 on November 18, 2013.
The CNP corrective action process investigated the incident to determine if this procedure violation or shortcut, is a work group norm, or a routine violation. The other Make Up Plant operators interviewed noted that they are fully aware of the consequences of an acid transfer and follow the procedure's written instructions not to leave- the area when a transfer is occurring. Therefore, this procedure
Mr. Kameron Jordan Outfall OOD exceedence report Page 2 November 27, 2013 violation was noted as an isolated incident, so additional preventive actions are not necessary to prevent recurrence. This particular incident was managed by Human Resources, where-the individual was terminated.
The exceedence occurred for approximately 5 minutes; the outfall pH was resampled on the next pump out and had returned to 8.4 pH (within permit limits) . A pH sample of the receiving pond on November 18, 2013 was based on the dilution of the effluent by a 6 million gallon settling pond, and additional groundwater dilution, there is no impact to the surrounding groundwater from this event.
Please contact me at telephone (269) 465-5901 ext. 2102 if you have any questions regarding this information.
Sincerely, Jon H. Harner Environmental Manager Donald C. Cook Nuclear Plant c: Mr. Steve Norton, MDEQ - Kalamazoo USNRC per Appendix B. T.S.
Mr. Kameron Jordan Outfall OOD exceedence report Page 3 November 27, 2013 I certify under penalty of law that I have personally examined and am familiar with the information submitted on this and all attached documents, and based on my inquiry of those individuals immediately responsible for obtaining the information, I believe the submitted information is true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment.
J.H. Harner Environmental Manager