AEP-NRC-2014-72, Follow-Up Notification of Groundwater Permit Exceedance for Sodium and Chloride

Follow-Up Notification of Groundwater Permit Exceedance for Sodium and Chloride

ML14273A438
Person / Time
Site:	Cook
Issue date:	09/25/2014
From:	Scarpello M Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2014-72
Download: ML14273A438 (6)

Text

INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant POWER" One Cook Place A unit of American Electric Power Indiana Michiga Powercom September 25, 2014 AEP-NRC-2014-72 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 and 2 FOLLOW-UP NOTIFICATION OF GROUNDWATER PERMIT EXCEEDANCE FOR SODIUM AND CHLORIDE

References:

1. Letter from M. K. Scarpello, Indiana Michigan Power Company (I&M), to U.S. Nuclear Regulatory Commission, "Notification of Groundwater Permit Exceedance for Sodium and Chloride," AEP-NRC-2014-69, dated August 26, 2014.

2. Letter from J. H. Harner, I&M, to J. Sanders, Michigan Department of Environmental Quality, "American Electric Power Company, Donald C. Cook Nuclear Plant, Groundwater Permit No. GW1810102," dated August 28, 2014.

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 U.S. Nuclear Regulatory Commission a notification I&M made to the Michigan Department of Environmental Quality (MDEQ) of noncompliance for sodium and chloride concentrations at Monitoring Well 19, for Groundwater Permit GW1810102.

By Reference 2, I&M submitted to MDEQ a follow-up notification of this noncompliance as required by GW1810102. Reference 2 is provided as an enclosure to this letter in accordance with CNP's Nonradiological Environmental Protection Plan, Section 5.4.2.

On July 31, 2014, the sodium concentration at Monitoring Well 19 was confirmed to be 482 milligrams/liter (mg/I), which exceeds the permit limit of 120 mg/I. The chloride concentration at Monitoring Well 19 was confirmed to be 821 mg/I, which exceeds the permit limit of 250 mg/I. I&M resampled this monitoring well on August 1, 2014, and submitted the sample for lab analysis. The August 1, 2014, sample results showed that the sodium and chloride levels were lowering, but still above the permit limits. Sodium concentration was 284 mg/l. Chloride concentration was 426 mg/l.

The probable cause of this exceedance is due to construction of a new building taking place within 200 feet of Monitoring Well 19. Exposed soils have allowed stormwater to wash sodium and chloride held in the soils, from deicing compounds used in previous winter months, to the groundwater. This event was driven by a large storm in early July.

Since July, I&M has restored the grade at the construction site. The construction site will be stabilized upon completion of the project in fall 2015. I&M will resample Monitoring Well 19 in September 2014, QoQO

U.S. Nuclear Regulatory Commission AEP-NRC-2014-72 Page 2 and complete quarterly sampling in October 2014. I&M anticipates Monitoring Well 19 to be in compliance at the October sampling based on the downward trend, and due to the fact that this was an isolated storm event not caused by a spill or leak of a substance, or by routine manufacturing processes at the facility. Based on the short duration of the exceedance there is minimal impact to the surrounding groundwater.

This letter contains no new or revised commitments. Should you have any questions please contact Jon H. Harner, Environmental Manager, at (269) 465-5901, extension 2102.

Sincerely, A-X- Ak, -se-a-'r-F-e-ki D Michael K. Scarpello Regulatory Affairs Manager

Enclosure:

Letter from J. H. Harner, I&M, to J. Sanders, Michigan Department of Environmental Quality, "American Electric Power Company, Donald C. Cook Nuclear Plant, Groundwater Permit No. GW1810102," dated August 28, 2014.

KMH/amp c: M. L. Chawla, NRC Washington D.C.

J. T. King - MPSC NRC Resident Inspector, w/o enclosure C. D. Pederson - NRC Region III A.J. Williamson - AEP Ft. Wayne

ENCLOSURE TO AEP-NRC-2014-72 Letter from J. H. Harner, I&M, to J. Sanders, Michigan Department of Environmental Quality, "American Electric Power Company, Donald C. Cook Nuclear Plant, Groundwater Permit No. GW1810102," dated August 28, 2014.

INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant One Cook Place OWER Bridgman, MI 49106 A unit of American Electric Pwer IndianaMichiganPower.com Mr. Jerrod Sanders, District Supervisor Michigan Department of Environmental Quality 7953 Adobe Road Kalamazoo, MI 49009 August 28, 2014 Re: American Electric Power Company Donald C. Cook Nuclear Plant Groundwater Permit No. GW1810102

Dear Mr. Sanders:

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 August 5, 2014. Upon discovery of the monitoring well 19 exceedence for sodium and chloride, we resampled well 19 on August 1, 2014. Results of confirmation sampling for monitoring well 19 showed that the sodium and chloride levels were dropping, but still above the permit limits. Sodium concentration was 284 mg/l (sampled 8/1/2014), down from 482 mg/l (sampled 7/7/2014). Chloride concentration was 426 mg/l (sampled 8/1/2014), down from 821 mg/l (sampled 7/7/2014).

Evaluation of the cause for the limit being exceeded and the impact of that event to the groundwater: Construction of a new building is taking place within 200 ft of the monitoring well. Exposed soils have allowed stormwater to wash sodium and chloride held in the soils to the groundwater. The monitoring well is downgradient of the main road and sidewalks of the site and deicing compounds were used in the previous winter months. Based on evaluation of the most recent monitoring well data, we have concluded that a combination of deicing applications and the recently exposed soils have caused the exceedence. Previous groundwater sample data from 4/22/2014 shows that this event was short in duration and the most recent data shows that the data is improving. Based on the' short duration of the exceedence there is minimal impact to the surrounding groundwater.

Proposal detailing steps taken to prevent recurrence. This event was driven by a large storm event in early July to the recently exposed construction site. The accumulated deicing materials used on the nearby roadways and sidewalks from the past winter were washed from the soils to the groundwater.

Currently, the site grade has been restored after the foundations have been completed.. The site will be stabilized at the conclusion of the project in the fall of 2015. We have scheduled a resample of well 19 in September to trend groundwater quality. All monitoring wells are scheduled for their permit required quarterly sampling in October 2014, based on the downward

Mr. Jerrod Sanders Well 19 exceedence 60 day report Page 2 August 28, 2014 trends; we anticipate that the well will be in compliance at that time due to the fact that this was an isolated storm event not caused by a spill or leak of a substance or by routine manufacturing processes at the facility. No further corrective actions are necessary for this issue. 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: Ms. Christina Bauer, MDEQ - Kalamazoo USNRC per Appendix B, T.S.

Mr. Jerrod Sanders Well 19 exceedence 60 day report Page 3 August 28, 2014 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