ML031670179

National Pollutant Discharge Elimination System (NPDES) Permit No. TN0020168 - Response to Notice of Violation

ML031670179
Person / Time
Site:	Watts Bar
Issue date:	06/04/2003
From:	Edward Robinson Tennessee Valley Authority
To:	Hannah C Office of Nuclear Reactor Regulation, State of TN, Dept of Environment & Conservation
References
Download: ML031670179 (6)

Text

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 June 4, 2003 Mr. Chip Hannah Tennessee Department of Environment & Conservation Division of Water Pollution Control Enforcement & Compliance Section Sixth Floor, L & C Annex 401 Church Street Nashville, Tennessee 37243-0455

Dear Sir:

WATTS BAR NUCLEAR PLANT (WBN) - NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT NO. TN0020168 - RESPONSE TO NOTICE OF VIOLATION This letter is in response to a Notice of Violaton letter dated May 6, 2003, see attached leter.

As indicated with the DMR, this was an upser. WBN nobfied the Chattanooga Environmental Assistance Center and followed up with a written confirmaton within one week.

The March 7, 2003 written confirmaton to the Environmental Assistance Center is also attached for your review. Therefore, WBN respectfully requests TDEC to resend the Notice of Violabon dated May 6, 2003.

If you should have any questions or need additional informaton, please contact Robert J.

Crawford at (423) 365-8005 at Watts Bar.

I certify under penalty of law that this document and a attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel property gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and impnsonment for knowing violations.

Sincerely, Edward R. Ro ins6in Radwaste/Environmental Superintendent Enclosures cc (Enclosures):

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Tennessee Department of Environment & Conservation Division of Water Pollution Control Environmental Assistance Center 540 McCallie Avenue, Suite 550 Chattanooga, Tennessee 37402 Ptd on recyed pa

STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION DIVISION OF WATER POLLUTION CONTROL ENFORCEMENT AND COMPLIANCE SECTION 401 CHURCH STREET, 6TH FLOOR, ANNEX NASHVILLE, TN 37243-0455 May 06, 2003 CERTIFIED MAIL Mr. Robert J. Crawford TVA - Watts Bar Nuclear Plant P.O. Box 2000 Spring City, TN 373812000 Re: Notice of Violation NPDES Permit #TN0020168 TVA - Watts Bar Nuclear Plant Rhea County, Tennessee

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Dear Mr. Crawford:

This letter serves as a Notice of Violation. The Division of Water Pollution Control has reviewed the Discharge Monitoring Reports (DMRs) for TVA - Watts Bar Nuclear Plant and found the violation(s) of permit terms, shown on the attached report.

The Division of Water Pollution Control requires a written explanation of the violation(s) summarized on the attached report within 30 days, if you did not submit an explanation with the DMR. The explanation must include the reason for the violation(s) and the corrective action taken to avoid future violation(s). The explanation should be sent to the attention of Mr. Chip Hannah at the address shown in the letterhead.

Your facility is subject to enforcement action due to non-compliance with permit terms. However, your explanation will be considered prior to further action from this Division. If you have questions or concerns regarding this correspondence, contact Mr. Chip Hannah at (615) 532-0683.

Sincerely, Christopher S. Moran, Section Manager z

(< c' cc: Chattanooga Environmental Assistance Center Compliance File

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9rk NPDES Permt ,, 020168 May 06, 2003 TVA - Watts Bar Nuclear Plant Facility Type: Major Industrial Rhea County, Tennessee WPC Staff: Mr. Chip Hannah

SUMMARY

OF VIOLATIONS Discharge Monitoring Reports (DMRs) for 0201/2003 through 02128/2003.

Explanation Recelved Reported Permit with DMR Outfall Parameter Value Limit Unit Code Statistical Base Vlolation Type f sw

- ee1 j-l S &l i Kl- --- -l- t S:-*-*s-- i~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

I il1 F-.

lTotal Suspended Solids (as TSS) i w-w-Sl 11 661 i I -

4511 I

MG/L IIDaily Maximum I '

IlINumeric Violation

NOTICE OF UPSET NPDES PERMIT TN0020168 WATTS BAR NUCLEAR PLANT February 16, 2003 Outfall 111: Treated Sanitary Wastewater -

According to the criteria found in NPDES permit No. TNO020168 Part II C 4, an upset occurred at the Sewage Treatment Plant on February 16, 2003 due to heavy rain and flooding conditions. According to operator logs, rain totaled approximately 7 inches over the February 14'h weekend and flooding conditions occurred at Plants A & B but no "washout" occurred. The heavy rains also caused flooding conditions for the Construction Runoff Holding Pond, OSN 112. Flood waters backed up into the Sewage Treatment Plant effluent box. During the time of the upset, the facility was operated in a prudent and workman-like manner and was in compliance with proper operation and maintenance procedures. Conversations with the licensed operator indicate that this was beyond the reasonable control of WBN and no actions could have been taken to stop the flooding of the effluent box.

The upset lead directly to a high Total Suspended Solids. (TSS) concentration for the sample collected on February 19, 2003 at 09:50 a.m. Sample results fevealed a Total Suspended Solids (TSS) concentration of 66 mg/L. The daily maximum permit limitation is 45 mg/L. Another sample was collected on February 25 at 07:20. The result of that analysis showed TSS was back within permit limits with a result of 3.9 mgtL. All other discharge and operating parameters during that time frame were well within permit limitations. This was an isolated event due to the heavy flooding conditions at WBN and not caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation.

A phone call was made to the Tennessee Department of Environment and Conservation, Chattanooga Field Office about the high TSS value and plant conditions the working day after WBN became aware the plant upset. A follow up letter was mailed within 5 days to the Chattanooga field office.

Tennessee Valley Authority, Post Office Box 2000, Spring City. Tennessee 37381-2000 March 7, 2003 Mr. Mike Kelley Tennessee Department of Environment & Conservation Division of Water Pollution Control Environmental Assistance Center 540 McCallie Avenue, Suite 550 Chattanooga, Tennessee 37402-2013

Dear Mr. Kelley:

WATTS BAR NUCLEAR PLANT (WBN) - NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT NO. TN0020168 -

FOLLOW-UP TO NOTICE OF UPSET This letter is a follow-up to the phone call made on March 3, 2003 to your office about the TSS exceedance at WBN's Sewage Treatment Plant Effluent due to the heavy rain which began at WBN on the weekend of February 14th. Rain totaled approximately 7 inches over that weekend and flooding conditions occurred at Plants A & B but no

";washout" occurred. In accordance with NPDES permit No. TNO020 168 Part II C 4, WBN believes an upset occurred at the Sewage Treatment Plant on February 16, 2003.

WBN meets the criteria found in Part II C 4 of the permit for the conditions of an upset. The cause was due to the heavy rains causing flooding conditions for the Construction Runoff Holding Pond, OSN 112, flooding and backing up into the Sewage Treatment Plant effluent box. During the time of the upset, the facility was operated in a prudent and workman-like manner and was in compliance with proper operation and maintenance procedures.

Mr. Mike Kelley Page 2 March 7, 2003 The upset lead directly to a high Total Suspended Solids (TSS) concentration for the sample collected on February 19, 2003 at 09:50 a.m. Sample results were obtained on February 27, 2003 and revealed a Total Suspended Solids (TSS) concentration of 66 mg/L. The daily maximum permit limitation is 45 mg/L. Another sample was collected on February 25 at 07:20. The result of that analysis performed on February 26 at 09:35 a.m. resulted in a measurement of 3.9 mg/L. This value met the permit limit. All other discharge and operating parameters during that time frame were well within permit limitations. This was an isolated event due to the heavy flooding conditions at WBN and not caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation.

If you should have any questions or need additional information, please contact me at (423) 365-8005 or Martha Ervin at (423) 365-3585 at Watts Bar.

Sincerely, Robert J. Crawford Environmental Supervisor cc: Tennessee Department of Environment and Conservation Division of Water Pollution Control Enforcement & Compliance Section Sixth Floor, L & C Annex 401 Church Street Nashville, Tennessee 37243-1534