CY-99-023, Provides Summary of Understandings Reached During 990108 Meeting Between Util & CT Dept of Environ Protection Re Dike Area Rainwater Reporting Protocol

Provides Summary of Understandings Reached During 990108 Meeting Between Util & CT Dept of Environ Protection Re Dike Area Rainwater Reporting Protocol

ML20203C221
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	01/28/1999
From:	Mellor R CONNECTICUT YANKEE ATOMIC POWER CO.
To:	Grier J CONNECTICUT, STATE OF
References
CY-99-023, CY-99-23, NUDOCS 9902110280
Download: ML20203C221 (3)

Text

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ONNECTICUT YANKEE AT O M I C POWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW ROAD e EAST HAMPToN. CT 06424-3099 January 28,1999 CY-99-023 Mr. James Grier Supervising Sanitary Engineer Water Management Bureau CT Department of Envi anmental Protection 79 Elm Street Hartford, CT 06106-5127 Connecticut Yankee Atomic Power Company Dike Area Rainwater- Reoortina Protocol

Dear Mr. Grier:

On Januany 8,1999, representatives from both Connecticut Yankee Atomic Power Company (CYAPCo) and the Connecticut Department of Environmental Prctection (DEP or the Department) met to discuss CYAPCo's January 6,1999 notification to the Department concerning seepage of rainwater through the floor of a diked area at CYAPCo's Haddam i Neck Plant.

Present at the meeting on behalf of the Department were yourself, Charles Nezianya, '

Michael Firsick, Denny Galloway, and Charles Zieminski. In attendance on behalf of CYAPCo we:e Kenneth Heider, Paul Brindamour, Ker:y Harner, James Borowitz, Gerry van i Noordennen and Harold Blinderman. The following summarizes discussions and understandings reached during the meeting regarding reporting protocols should a subsequent event involving rainwater seepage from the diked area occur.

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Backaround h O

CYAPCo is authorized under its NPDES Pemiit to collect rainwater from various dikes in the Radiologically Controlled Area (RCA). The rainwater is potentially contaminated at very low

levels because the rainwater runs through the RCA and associated equipment during rainfall ever,ts. As a result, rainwater is collected in diked areas and then processed and discharged via DSN 001 A as authorized under CYAPCo's NPDES discharge permit.

3 A 41 G (l'3 8 {(N 9902110280 990128 PDR ADOCK 05000213 W PM j

1028-3 REV 2-91

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l Mr. James Grier i L CY-99-023/Page 2 -l L  :

i CYAPCo's NPDES permit requires, among other regulatory provisions, compliance with the

! notification provisions of Section 22a-430-3(j) of the Regulations of Connecticut State l

l Agencies (RCSA).. This section specifies the circumstances under which " actual or  :

anticipated non-compliance with permit terms or conditions" must be reported to the l

- Department. CYAPCo has been notifying the Department, pursuant to RCSA Section 22a-  !

430-3(j), of seepage from the dike area floor. CYPACo has also been making a separate i l notification to the Oil and Chemical Spill Section pursuant to Section 22a-450 of the Connecticut General Statutes of these same events. ,

in discussing whether this dual reporting was necessary, the Department requested .

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. information regarding radioactivity levels in both thed' iked area and the contained tanks. As l L

set forth in previous correspondence m (2) ( ) testing of residual rainwater from the dike area sump, over the past several months, indicates the presence of very low levels of radioactivity, 1/1,000,000 below reportability criteria established by the United States Environmental

• Protection Agency. The Department requested information regarding the activity in the dike $

area tanks in order to understand the effects of a postulated worst case scenario. The i largest and most contaminated tank, the Aerated Drains Hold-up Tank (ADHUT), contains  ;

approximately 85,000 gallons of waste water with a total activity of approximately 4 Ci. The  !

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activity is comprised mainly of cobalt, tritium, and cesium. Chemical characterization results  !

- of the ADHUT have been provided to the Department in a acember 22,1998 letterW .  !

l Reportina Protocol i

During the meeting it was agreed that, because CYAPCo's NPDES Permit authorizes the collection, processing, and discharge of rainwater from the diked area, the Purmitting and

~ Enforcement Section of the Water Management Bureau has primary jurisdiction with respect to the reporting of seepage of rainwater from the diked area floor. As a result, it was agreed that the Oil and Chemical Spill Section would not need to be immediately notified of such E

R - Russell A. Mellor Letter (CY-98-160) to Wilibm D. Hegener, "CYAPCO - Report of l Rainwater Seepage from Dike Area," dated Octcber 5,1998.

! - (2) Russell A. Mellor Letter (CY-98-207) to William D. Hegener, "CYAPCO - Report of i Rainwater Seepage frc'n Dike Area," dated December 7,1998.

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• Russell A. Mellor Letter (CY-99-020) to Mr. William D. Hegener and Mr. James Grier, .]

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" Report of Rainwater Seepage from Dike Area," dated January 11,1999. f

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}. Russell A. Mellor Letter (CY-98-126) to Mr. James Grier, " Request for Determination

Processing of Wastewater Stored in Hold-up Tank and Reactor Coolant System" ,

i . dated December 22,1998.

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Mr. James Grier -

i CY-99-023,/Page 3

~ seepage so long as: (1) the notification and reporting provision of RCSA Section 22a-430-3 are complied with; (2) the Oil and Chemical Spills unit is provided a copy of all written reports following up on notifications under Section 22a-430-3; and (3) the levels of radioactivity in the rainwater do not trigger a separate report to the United States Nuclear Regulatory Commission (NRC). If a report of rainwater seepage to the NRC is required, CYAPCo will:

immediately notify t_he Department's Oil and Chemical Spills unit and additional follow-up notifications will be made to the Division of Radiation Protection and the Water Management Bureau. ,

Should the above not' accurately reflect the understanding reached at the January 8,1999 L meeting between the Department and CYAPCo, please contact Mr.'Gerry van Noordennen at (860) 267-3938 to discuss this matter.

Very truly yours,-

CONNECTICUT YANKEE ATOMIC POWER COMPANY .;

nY- '3

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. Russell A. M Vice President - ations and Decommissioning cc: Mr. Charles Zieminski, Connecticut Department of En'vironmental Protection ,

Ms. Michelle DiNoia, Connecticut Department of Environmental Protection 1 Mr. Charles Nezianya, Connecticut Department of Environmental Protection Mr. Denny Galloway, Connecticut Department of Environmental Protection Mr. Michael Firsick, Connecticut Department of Environmental Protection Mr. R. Bellamy, Chief, Decommissioning and Laboratory Branch, U.S. Nuclear Regulatory Commission f

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